&EPA
United States
Environmental Protection
Agency
          /neerfng issue
Indoor Air Vapor Intrusion  Mitigation Approaches
         Table of Contents
 1  PURPOSE                         1

 2  INTRODUCTION                   1
   2.1  Subject and Intended Audience          1
   2.2  Overview of Contaminant Entry
      into Structures and Mitigation           3
   2.3  Vapor Intrusion into Various Building Types  6
   2.4  Quality Assurance Considerations        8
 3  AVAILABLE ENGINEERED
   CONTROL MEASURES              8
   3.1  Active and Passive Sub-slab Ventilation   10
   3.2  Sealing of Penetrations and Entryways    19
   3.3  Passive Barriers (including Membranes)   22
   3.4  Natural Ventilation and HVAC Modification 23
   3.5  Air Cleaning using Adsorbents, Scrubbers
      or Photocatalytic Oxidation            25
   3.6  Combinations of Multiple Technologies    26
 4  SELECTING A TECHNOLOGY       26
   4.1  Concentration Limits for the Contaminant  27
   4.2  Reliability                       28
   4.3  Effect of the Technology on Other
      Aspects of I ndoor Ai r Qual ity           28
   4.4  Structural and Occupancy Aspects
      for New and Existing Buildings         30
   4.5  Cost Factors                     33
   4.6  Risk Communication and Stakeholder
      Involvement Considerations           34
 5  VERIFICATION OF
   MITIGATION PERFORMANCE       35
   5.1  Defining the Performance Objective      35
   5.2  Defining the Performance Baseline      37
   5.3  Methods of Measuring Indoor Contaminants37
   5.4  Measuring or Estimating Sub-slab Soil
      Gas Concentrations During Mitigation    39
   5.5  Indirect Measurements of Mitigation
      Performance                     40
   5.6  Initial and Long-Term Verification
      of System Performance              41
   5.7  The Role of Ongoing Warning
      Devices and System Labeling          42
 6  ACRONYMS AND ABBREVIATIONS   43
7  ACKNOWLEDGMENTS

8  REFERENCES
                    43

                    44
                         1    PURPOSE

                         The U.S. Environmental Protection Agency (EPA) Engineering Issue
                         in one of a new series of technology transfer documents that sum-
                         marize the latest available information on selected treatment and site
                         remediation technologies and related issues. The Engineering Issues
                         are designed to help remedial project managers (RPMs), on-scene
                         coordinators (OSCs), contractors, and other site managers under-
                         stand the type of data and site characteristics needed to evaluate a
                         technology for potential applicability to their specific sites. Each En-
                         gineering Issue document is developed in conjunction with a small
                         group of scientists inside the EPA and with outside consultants and
                         relies on peer-reviewed literature, EPA reports, Web sources, current
                         research, and other pertinent information. The purpose of this docu-
                         ment is to present the "state of the science" regarding management
                         and treatment of vapor intrusion into building structures.

                         Wherever feasible, this information relies on independently reviewed
                         mitigation performance information. In an effort to keep this Engi-
                         neering Issue paper concise, important information is summarized,
                         while references and Web links are provided for readers interested
                         in additional information; these Web links, verified as accurate at
                         the time of publication, are subject to change. Although we have
                         endeavored to make these links fully functional with a mouse click,
                         if they do not function on your system, you may need to copy them
                         into your browser or reenter them. As science and technology associ-
                         ated with this route of exposure continues to develop, other mitiga-
                         tion measures may become available.


                         2    INTRODUCTION
2.1  Subject and Intended A udience

Vapor intrusion is defined as the migration of volatile contaminants
from the subsurface into overlying buildings. Volatile contaminants
from buried wastes and/or contaminated groundwater or soil can
migrate through subsurface soils and into indoor air spaces of overly-
ing buildings. The vapor intrusion risk pathway may be important
for buildings with or without a basement (EPA, 2002a).

Vapor intrusion issues are widespread; for example, as of March 15,
2006, there were 268 site investigations in the State of New York
and mitigations were underway or completed at 72 of those sites

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(Anders, 2006). Similar studies and mitigations have
been carried out in a large number of the states.
This paper is focused on the mitigation of vapor in-
trusion to prevent human exposure to anthropogenic
soil and groundwater contaminants. This document is
designed to provide sufficient information to allow the
reader to understand the range of mitigation technolo-
gies available. The document also provides information
on selecting appropriate technologies in consultation
with qualified engineering and risk management profes-
sionals. The intent is not to provide detailed engineer-
ing protocols, nor to provide lists of vendors. Rather, it
is intended that the reader will be generally informed to
make appropriate selections, and to evaluate the recom-
mendations of mitigation contractors and engineers.
The primary target audience for this paper includes EPA
staff, regional program offices, RPMs and state govern-
ment environmental staff. Others who may be interested
in this document may include:
 • Engineering consultants
 • Building professionals, including architects, property
    developers, contractors and engineers
 • Health and safety/industrial hygiene specialists
 • Stakeholder groups and the general public
Because of its concentration on vapor intrusion mitiga-
tion, this paper will not directly consider the following.

Characterization and Risk Assessment Techniques
Vapor intrusion is typically  first evaluated with charac-
terization measurement and risk assessment techniques.
This document will not provide much discussion of
these topics, which are covered in EPA's draft vapor in-
trusion guidance document (EPA, 2002a; at
http://www.epa.gov/correaiveaaion/eis/vapor/complete.
pdf) and are expected to be  the subject of an upcoming
revised guidance.1 The reader should therefore consult
the EPA guidance and other appropriate documents [for
example, Interstate Technology and Regulatory  Council
(ITRC) at http://www.itrcweb.org/Documents/VI-l.pdf
and http://www.itrcweb.org/Documents/BRNFLD-l.
pdfl for information on issues such as fate and transport
of volatile organic compounds (VOCs) in the subsur-
face, assessment methods, risk assessment, and regulatory
1Though the  revised guidance has not been released,
recent presentations by EPA  staff provide an overview of
possible changes—see for example http://iavi.rti.org/attach-
ments/WorkshopsAndConferences/0910_-_Schuver.pdf
standards. Much of the regulatory authority in this area
resides with the individual states.

Rather, this paper is focused on solutions that can be
implemented once an unacceptable risk from vapor
intrusion is determined to exist, or as precautionary
measures. As further discussed below, the type of control
implemented will be based on many factors including
site use, amount of impact, cost, and regulatory accep-
tance, but can be generally broken into two classes of
solutions: source control and controls implemented at
the structure.

Remediation
Remediation in the plumes or at the sources will even-
tually mitigate potential exposure pathways and can
include any of the following:

 •  Removal of contaminated soil (typically for off-site
    treatment) and groundwater (typically for ex-situ
    treatment with pump and treat approaches)
 •  In-situ remediation of contaminated soil and
    groundwater—often referred to in this context as
    source removal
 •  Non-engineered/institutional controls such as zon-
    ing, deed restrictions or resident relocation

Numerous other EPA resources are available to provide
assistance with selecting technologies and approaches as-
sociated with source control. See, for example:

 •  http://www.clu-in.org/remedl .cfm
 •  http://www.epa.gov/superfund/policy/ic/index.htm
 •  http://www.brownfieldstscorg/pdfs/Roadmap.pdf
 •  Various state guidance documents are also discussed
    in this paper and are listed in the reference section.

This document, however, focuses on the engineered
controls implemented at the affected structure(s), which
can be considered interim remedial measures. The miti-
gation approaches dealt with in this paper are primarily
engineered "direct" mitigation strategies for vapor intru-
sion such as sealing of entry routes, sub-slab venting, or
installation of membrane barriers. A formal definition
of engineering controls, as provided in American Society
for Testing and Materials (ASTM) E2435-05 (ASTM,
2005), is as follows: "Physical modifications to a site or
facility to reduce or eliminate the potential for exposure
to chemicals of concern."
                            Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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Other Sources of Indoor Air Pollutants:
In addition to vapor intrusion, there are many other
causes of poor indoor air quality (e.g., exposure of build-
ing occupants to contaminated well water/shower water),
and other pollutant sources in the indoor environment.
Readers interested in a more general view of indoor air
quality can refer to EPA's indoor air website
(http://www.epa.gov/iaq/index.html), which among
other resources includes:
 •  A general overview of indoor air issues
    http://www.epa.gov/iaq/pubs/insidest.html
 •  Specific resources for indoor air problems in homes
    http: //www. epa. gov/iaq/ho mes/
 •  Resources for large buildings/offices
    http://www.epa.gov/iaq/largebldgs/
 •  Resources for schools
    http://www.epa.gov/iaq/schools/

Radon and other Inorganic Species
Although radon mitigation theory and methods form a
substantial  and relevant foundation for the mitigation
techniques  and approaches discussed here, the intent of
this paper is to discuss mitigation as applied to vapor
intrusion of toxic VOCs. Mitigation approaches specific
to inorganic species such as radon are covered by other
resources (e.g., http://www.epa.gov/radon/).

2.2  Overview of Contaminant Entry
     into Structures and Mitigation
The majority of vapor intrusion cases occur when con-
taminants from either the soil or groundwater enter the
soil gas at the water table or in the vadose (unsaturated)
zone. The contaminated soil gas then migrates under the
influences of advective flow or diffusion until they escape
into the atmosphere or enter the zone of influence of a
building. The term "advective flow" here refers to bulk
flow driven by pressure or density differences.
One additional mode of entry occurs when contami-
nated groundwater itself enters the building. Entry of
groundwater may occur in sumps or in flooded base-
ments, where contaminants dissolved in the water may
partition directly to the indoor air. This situation is
believed to  account for only a small fraction of the build-
ings with indoor air contaminated by chemicals origi-
nating in the  soil but it is a very significant risk pathway
when it does occur.
Volatile chemicals can enter the vapor phase via parti-
tioning across the groundwater/soil gas interface (a pro-
cess which at equilibrium can be described by Henry's
law). Volatile species can also enter soil gas via volatiliza-
tion from a free phase contaminant or adsorbed con-
taminant. Contaminants may undergo transformation
in the subsurface, and the flux of contaminants may vary
seasonally or otherwise due to changes in soil moisture,
height of the water table, barometric pressure, and other
factors. More quantitative discussion of these processes
is provided in the users guide to the Johnson & Ettinger
(J-E) model (Environmental Quality Management,
2004). Once in soil gas, deep in the soil and absent any
natural or anthropogenic preferential flow conditions,
diffusion dominates the soil vapor transport process; but
near the building, advective flow is the dominant mecha-
nism. The building's zone of influence arises from two
primary effects:

 1. The building constitutes a barrier to the free upward
    migration of the contaminants so they tend to accu-
    mulate  under the building.
 2. The building interacts with the soil through pressure
    differences that are induced between the interior of
    the building and the soil.

A basic conceptual model of subsurface contaminant
movement  into the sub-slab space involves the migra-
tion of volatile contaminants upward from a contami-
nated soil or groundwater source, through soils, to the
engineered fill material which may underlie a building
slab. In this sub-slab space, the distribution of contami-
nants is dependent on a number of factors,  including the
distance from and geometry of the source area, geologi-
cal influences on vapor migration, and footing design.
Sub-slab vapors may also follow preferential pathways
such as utility corridors instead of collecting uniformly
under the slab or above the source (NJDEP, 2005). Sub-
slab vapors can then migrate into the overlying structure.
Vapor migration into residences is generally thought to
be at its maximum during the cold season, when there
is a significant difference in temperature between ambi-
ent and indoors. An exception to this generalization may
occur in karst terrains where radon has been observed to
have higher indoor values during the summer months,
because air flows in nearby underground  caves can
control contaminants' flow in the sub-slab region. The
term "karst" refers to an irregular limestone region with
sinkholes, caves and underground drainages formed by
dissolution and solution processes. For houses built over
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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caves at large distances from the entrance, air tends to
flow through the cave system away from the house in the
winter and toward the house in the summer. The pres-
sures in these cave systems can be coupled to the house
pressure (Gammage 1992).

When the pressure in the lowest portion of the build-
ing (i.e., basement, crawlspace or ground floor) is lower
than the pressure in the soil below the building soil gas
advectively flows into the building through cracks or
openings. This negative pressure in the building is often
due to the stack effect  (buoyancy of warmer indoor air),
barometric pressure changes or the interaction of the
building with winds. This advective flow of contaminat-
ed soil gas is the primary mechanism by which soil vapor
intrudes into buildings. It is much more important than
direct diffusion through pores.

Only after advective flow through macroscale cracks has
been substantially reduced (by reducing driving forces
and closing entry routes) does diffusion through con-
crete slab pores become the dominant entry mechanism.
Typically this situation occurs only in buildings in which
the foundation has been specifically engineered to pre-
vent entry of soil gases through cracks. Diffusion consti-
tutes a significant risk pathway only if the concentration
in the sub-slab soil gas is very high or the slab is unusu-
ally thin and porous. Unparged cinder block walls are,
however, a separate case. Cinder blocks are intentionally
designed to be lighter than concrete blocks  and are more
porous. Advective flow through cinder block walls is
therefore likely.

The stack effect is a process that induces a negative pres-
sure in the interior of the building as warm air rises and
escapes through the top of the building. In  turn this
process draws replacement air in through the openings
in the lower portion of the building;  some of these open-
ings will draw in soil gas. The stack effect is less strong
in the summer time in buildings with a cooling system
running. Although, this simplified view of the stack ef-
fect would suggest that the flow would reverse directions
in the summer, empirical observations indicate that the
driving forces across the slab still are in the direction of
vapor intrusion during the summer, at least on average
over 24 hours. The phenomenon of summertime soil gas
entry is probably aided by the fact that the temperature
in the sub-slab remains lower than the indoor air tem-
perature during summer. This phenomenon is further
supported by observations that warm climates such as
Florida continue to have radon problems, though per-
haps reduced, during the summer. (The stack effect is
explained more fully at
http://irc.nrc-cnrc.gc.ca/pubs/cbd/cbdl04 e.html).

Negative pressures in a building can also be enhanced by
mechanical systems such as heating and cooling systems,
exhaust fans (including those built into stoves or grills),
clothes dryers, central vacuums and combustion devices,
especially fireplaces. The effect of clothes dryers, central
vacuums, etc., only occurs when they exhaust outside.
Since bathroom, kitchen,  or utility room ventilation
fans remove large volumes of air from those rooms, the
rooms may depressurize if the doors are shut. This de-
pressurization could cause at least brief periods of high
vapor intrusion if the kitchen, bath, or utility room is on
the lowest floor (in contact with the soil). The expo-
sure period in these cases can be short.  "Whole house"
or building exhaust fans, if operated for a long period
of time, can cause significant depressurization in whole
buildings, especially if there is no system providing an
inflow of outside air.

In order to have a potential vapor intrusion problem,
there must be:

 •  Contaminants in the soil gas
 •  Entry routes for soil gas to enter the building
 •  Driving forces (pressure gradients or diffusion gra-
    dients) to draw the contaminants into the building.
    (Geyer, 2006)

A method for removing any one of these three condi-
tions would constitute mitigation. Removal of the source
is the definitive long-term solution. However, it should
be noted that many contaminant removal (remediation)
technologies, or passive methods such as natural attenu-
ation, might require years or even decades [see section
6.1.2 of ASTM (2005)]. Moreover, there may be natural
sources of contaminants such as radon or methane that
cannot be effectively removed. Consequently, it is neces-
sary to utilize one or a combination of the other two
conditions to create intermediate  mitigation methods to
protect the public health.

The primary options are to:

 •  Prevent entry of the contaminants into the building
    or
 •  Remove the contaminants after they have entered
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2.2.1   A Simplified Conceptual Model
       of Vapor Entry to Structures

As a conceptual model for understanding the entry
and removal of soil gas contaminants in a building, the
building can be viewed as a single zone enclosed by a
continuous shell that may have small openings through
which air can flow in or out. The lower portion of this
zone is in contact with or is somewhat sunken into the
soil. For simplicity, assume the contaminant of concern
(COC) is initially located only in the soil gas and that it
does not change with time. Suppose the driving forces
for entry are dominated by the stack effect which draws
soil gas into the building. If we assume the contaminants
do not adsorb on surfaces significantly and do not react
chemically, then a steady indoor concentration exists
when the entry rate matches the removal rate. For this
simplified model, the important building features are
the ones that influence the soil gas entry rate and the air
exchange rate.

Suppose for a moment that the only openings in the
building were located at the top and near the bot-
tom. According to the known stack effect, the pressure
near the top is slightly positive causing air to flow out
through the upper openings, while the pressure near the
bottom is equally negative causing air and soil gas to
enter through the lower openings. At about mid height,
the pressure would be zero (neutral pressure plane) sug-
gesting that no air would enter or leave at this location
even if an opening were present (caution: large openings
in the shell can distort the local pressure distribution
in that part of the zone). Under the scenario of top and
bottom openings, when the outdoor temperature drops
the magnitude of the positive pressure at the top and
the negative pressure at the bottom would both increase,
resulting in an increased entry rate at the bottom and a
corresponding increased flow out at the top.

For this simple one zone case, mass conservation requires
the contaminant entry rate to  be equal to the removal
rate (Qs Cs =  Q; Q) where Qs is the entry flow rate of
soil gas, Cs is the concentration of the contaminant in
the soil gas, Q; is the flow rate of indoor air leaving (ex-
filtration) through openings above the neutral pressure
plane of the building, and Q is the indoor concentration
of the contaminant.

When all the entry routes are located at the bottom
of the structure, approximately the same pressure dif-
ferential drives the entry of ambient air and soil gas.
Consequently, the ratio of Qs and Qa (entry flow rate of
ambient air) would be expected to remain nearly con-
stant as the outdoor temperature decreases. Therefore,
the indoor concentration would not change very much
as the air exchange rate increases with falling tempera-
ture. This phenomenon occurs because the soil gas entry
rate increases in proportion to the increase in the air ex-
change rate.

Since the scenario of openings only at the top and bot-
tom is often not realized, the indoor concentration of
soil gas contaminants will not  always be independent of
the air exchange rate. In fact, opening a window below
the neutral pressure plane will  usually result in an
increased air exchange rate without proportionately
increasing the entry rate of soil gas. Similarly, it  is pos-
sible to open a window above the neutral pressure plane
and increase the indoor concentration. The implication
is that if one opens a window on an upper floor, a win-
dow on the lowest floor should also be opened to avoid
pulling more soil gas into the building.

According to this simplified conceptual model, the
important building features are the location and size of
openings which can influence the magnitude and dis-
tributions of the pressure differentials. The limitations
of this model become apparent when larger and more
complex buildings that cannot be represented by a single
zone are considered. Multiple zones require descriptions
of the interactions and exchanges among the zones. De-
tailed discussion of such complex models is beyond the
scope of this document.

From a mitigation perspective, it is usually not necessary
to model the details of a very complex building. The im-
portant observation is that the contaminant comes from
the soil gas, which enters the portion of the building that
is in contact with the soil. If contaminant entry can be
denied in  the lowest part of the building, it may not be
necessary to deal with the rest  of the building.

For tall buildings, however, there are  some potentially
important observations:

 •  Tall buildings give rise to strong stack effects.
 •  Isolating individual stories of a tall building by seal-
    ing the floors reduces the stack effect.
 •  Floors act as dampers that  reduce the stack effect
    pressures by preventing upward flows.
 •  Elevator sumps may be required by code to have
    drains at the bottom, not connected to sewers. These
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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    drains should be equipped with one-way valves or
    traps below the slab to prevent soil gas entry.

2.2.2   Prevention of Contaminant Entry
       into the Building

To prevent entry of the contaminants into the building,
one must do one of the following:
 •  Eliminate the entry routes or
 •  Remove or reverse the driving forces (the negative
    pressure or diffusion gradients) that lead the con-
    taminants into the building or provide a preferential
    pathway to divert contaminants away from the struc-
    ture (section 2.2.3)
The two general approaches to eliminating the entry
routes are to seal the individual routes or to create a bar-
rier such as a membrane that isolates all the entry routes
from the soil gas.

The pressure gradient that drives advective flow into the
building can be neutralized or reversed by inducing a
positive pressure in the building or a negative pressure
in sub-slab soil gas. Installing  a pipe under the slab that
uses a fan to extract soil gas from under the slab and
vent it to the atmosphere is the most common approach.
Such a system is called a sub-slab ventilation system
or sub-slab depressurization system. Sub-slab ventila-
tion may also significantly reduce the diffusion gradient
across the foundation.

2.2.3   Removal of Contaminants from Buildings
If the contaminants have  not been kept out, then it is
necessary to remove them. One approach to remov-
ing contaminants is by increasing ventilation. Natural
ventilation may be accomplished by opening windows,
doors, and vents. Forced or mechanical ventilation may
be accomplished by using a fan to blow air into or out of
the building. Exhausting  air from the building will gen-
erally contribute to the negative pressure  in the building
resulting in increased infiltration of soil gas. Another
option for removal may include collection on an adsorb-
ing material (such as activated carbon) that can be either
recycled or properly disposed. In a more rarely used
approach some contaminants  may be chemisorbed on
treated sorbents that result in  chemical breakdown of the
contaminants.
2.3  Vapor Intrusion into Various Building Types

In order to understand the range of engineering controls
available and how they may apply to a particular situa-
tion, it is essential to understand the range of building
structures that are potentially subject to vapor intrusion.
Structures can be classified on the basis of the following:

 •  Use
 •  Type of foundation/basement
 •  Type of heating/cooling/ventilation systems

Each of these characteristics can influence the choice of
mitigation methodology and they are commonly docu-
mented on survey forms during vapor intrusion investi-
gations. In some jurisdictions, this information also can
be obtained from online property tax records.

2.3.1    Classification by Use

Structures can be classified by use:
 •  Residential (subdivided into single family or multi-
    family)
 •  Commercial/multi-use
 •  Industrial
 •  Educational/governmental
 •  Religious/community
These different uses are characterized by different typical
periods  of occupation (exposure durations). Residential,
commercial, and industrial buildings also differ in the
factors that influence the dilution of intruding vapors
[characterized by their air exchange rate (AER)]. The
AER is the rate at which outside air replaces indoor air
in a building. These and other terms common in dis-
cussions of indoor air quality are described more fully
in EPA's Indoor Air Glossary (http://www.epa.gov/ied
webOOO/glossary.html). If the use of a building changes after a
mitigation system is installed, the exposure scenarios and
thus the mitigation objective may need to be reevalu-
ated.
2.3.2   Classification by Foundation Type

Structures can be classified by foundation type:
 •  Basements (with concrete slabs or dirt floors)
 •  Slab on grade
 •  Slab below grade
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 •  Foundation/crawlspace (the foundation may be
    wood, stone, brick or block masonry, poured in
    place concrete or precast concrete panels)
 •  Footings/piers
 •  Mobile home

Slabs, whether on  grade or below are typically not simple
rectangular solids. Slabs are usually supported under the
load bearing walls either by a block foundation or by a
thicker section of a monolithically poured slab.

Figure 1 shows some of the main entry routes of vapor
intrusion (advective flow). For all structural types, utility
penetrations through floors and basement walls  are a key
route of entry—these are shown schematically in Figure
2. The most common routes of vapor intrusion  include:

 •  Seams between construction materials (including
    expansion and other joints)
 •  Utility penetrations and sumps
 •  Elevator shafts
 •  Cracks,  etc.

A fairly extensive diagram of potential routes of entry is
also provided as Figure 2-2 of EPA (1993a).
(http://www.du-in.org/conf/tio/vapor 021203/pb94l 10517.pdf)
           CONCRETE SLAB
                                    MOBILE HOME
 CRAWLSPACE OR BASEMENT
    WITH DIRT FLOOR
 CRACKS &    EXPOSED :
 OPENINGS   FRACTURED'
 IN CINDER     ROCK
  BLOCKS
Poured concrete walls are generally less permeable than
those constructed with cinder blocks. Cinder block walls
can thus be a significant entry route.

2.3.3   Classification by Ventilation

Structures can also be classified based on their heating/
cooling/ventilation methods. While a detailed discus-
sion of systems is not included here, it is important to
assess how the system or combination of systems con-
trols the airflow in the structure and thus may influence
vapor intrusion. Some systems will increase pressure,
while others will decrease pressure inside the structure. If
the net infiltration increases over the net exfiltration, the
resulting pressure change will be positive. If the exfiltra-
tion increases more than infiltration, the pressure change
will be negative. In some cases information on  heating,
ventilation and air conditioning (HVAC) design and
operation may be available from a previous Test and Bal-
ance report or energy audit.
Figure 1. Vapor intrusion potential in various residential structural types.
Legend Figure 2
1. Structural openings
2. HVAC vents
3. HVAC return duct (with hole)
4. Gaps and cracks
5. Sewer pipe
6. Water pipe (note large cutout, e.g. for bath and shower drains)
7. Drain or sump
8. Electrical, phone or fiber optic line

Figure 2. Vapor intrusion pathways through utility penetrations and
structural openings in floors and walls.
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2.4  Quality Assurance Considerations

Achievement of customer and stakeholder objectives in
vapor intrusion mitigation requires that a quality system
be established and followed both in:
 •  Measurement activities (air concentrations and engi-
    neering parameters such as pressures)
 •  Mitigation technology selection, site specific engi-
    neering design and construction.

Quality assurance considerations for measurement ac-
tivities, especially the verification of mitigation system
performance are covered in sections 5.1 and 5.2 of this
document and in EPA 2002b.

It is essential that quality considerations be embedded
throughout the steps of:

 •  Organizing a project team with appropriate qualifi-
    cations and experience
 •  Developing project team communication strategies
    and document controls
 •  Establishing requirements and objectives for the
    needed engineered systems
 •  Conducting feasibility studies to select technologies
 •  System design, including design inputs and design
    document review
 •  System construction—including procurement, in-
    spection, verification testing and control
 •  Building system performance testing
 •  Operation  and monitoring—including development
    of procedures, system startup, inspection, and testing
Although these topics are not treated at length in this
engineering issue paper, readers are urged to consult:

 •  Guidance on Quality Assurance for Environmental
    Technology Design, Construction, and Operation
    http://www.epa.gov/QUALITY/qs-docs/gl 1 -final-05.pdf
 •  Guidance for Conducting Remedial Investigations
    and Feasibility Studies Under CERCLA
    http://www.epa.gov/superfund/policy/remedy/
    pdfs/540g-89004-s.pdf
 •  Quality Control and Safety During Construction
    http://pmbook.ce.cmu.edu/13  Quality Control
    and Safety During Construction.html
 •  Integrated Design Process
    http://www.sbc.nrcan.gc.ca/buildings/pdfs/IDP
    overview.pdf
As will be discussed later in this document, many specif-
ic quality assurance documents developed for radon are
also useful for other types of vapor intrusion mitigation

 • "Model Standards and Techniques for Control of
   Radon in New Residential Buildings" U.S. Envi-
   ronmental Protection Agency, Air and Radiation
   (6604-J) EPA 402-R-94-009, March 1994
 • ASTM E2121 Standard Practice for Installing Radon
   Mitigation Systems in Existing Low-Rise Residential
   Buildings
 • Radon Prevention in the Design and Construction
   of Schools and Other Large Buildings Third Printing
   with Addendum, June 1994
   http://www.epa.gov/ORD/NRMRL/
   pubs/625r920l6/625r92016.pdf
 • Radon Reduction Techniques for Existing Detached
   Houses: Technical Guidance (Third Edition) for Ac-
   tive Soil Depressurization Systems [EPA 625/R-93-
   011,  October 1993]

3    AVAILABLE ENGINEERED
     CONTROL MEASURES

Vapor intrusion can be mitigated either during construc-
tion or as a retrofit on an existing structure. Strategies  for
mitigating vapor intrusion include both active and pas-
sive techniques, both of which require careful engineer-
ing design.

Decisions to mitigate are made primarily on the basis
of a demonstrated potential for vapors migrating from
subsurface to yield an unacceptable risk. Mitigation may
also be undertaken as a proactive measure to avoid a
costly characterization study. Remedial actions may also
be based  in part on site-specific factors that influence
decisions on how to manage a threat or the speed with
which a responsible party responds to elevated contami-
nant levels (building construction, building occupants,
vapor concentrations, projected time for the remedia-
tion of contamination, etc.) [Colorado Department of
Public Health and Environment (CDPHE) 2004]. Such
decisions will take into account whether implementa-
tion is based on single sample results or multiple samples
collected over a period of time to account for seasonal
variations.

Figure 3 provides a generalized flow chart of the different
steps required for decision-making and selection of an
appropriate vapor intrusion mitigation technology. This

                            Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

-------
figure begins after a vapor intrusion investigation and
risk assessment have been performed and a decision to
mitigate has been made.

In most cases, active mitigation is based on achieving a
negative pressure gradient underneath a structure, which
more than compensates for the house depressurization
generated by the environment (the primary driving force
for vapor intrusion). Alternatively, when a relatively
small reduction (less than a factor 2) is sufficient, active
measures may be based on removing or diluting vapors
after they have entered the building (Babyak and Welt,
2006). This approach requires a removal rate that is
greater than the contaminant entry rate.

Active mitigation strategies, which typically require some
ongoing consumption of energy, include the following
(ITRC, 2003):

 •  Sub-slab depressurization systems that either reverse
    the  direction of air flow or dilute the contaminants
    with ambient air

 •  Drain-tile depressurization
 •  Block wall depressurization
 •  Sub-membrane depressurization
 •  Site remediation technologies such as soil vapor ex-
    traction
 •  Indoor air purifiers or adsorption systems such as
    carbon filtration
 •  Heat recovery ventilation technology
 •  Adjustments to building HVAC systems that in-
    crease AER or produce high, positive, sustained
    indoor/outdoor pressure differences

Passive mitigation approaches include:

 •  Passive sub-slab venting, a technology that relies on
    convective flow (further discussed  below)
 •  Sealing the building envelope (outer shell)  or install-
    ing  vapor barriers
 •  Modification of the building foundation
 •  Measures to increase natural ventilation such as
    opening windows, doors, and vents
 •  Selective placement of buildings on the site to avoid
    contact with the vapors
 •  Building on stilts, also known as pier construction
 •  The selective placement of occupancy spaces within
    the  building away from spaces directly affected by
    vapor intrusion
 •  Use of construction materials inherently resistant to
    vapor intrusion (i.e., passive barriers)
 •  Specialized building designs to minimize pressure
    differentials across the building shell. For example,
    the structure can be designed to minimize the stack
    effect. Building orientation with regard to prevailing
    winds can also have an impact (Geyer, 2006). In ad-
    dition, the building can be designed with additional
    windows or vents for ventilation of non-living space
    with low exposures on the lowest level, e.g., a garage.

Experience (mainly gathered from radon and methane
vapor intrusion work)  shows that active systems are
needed if a large decrease in the amount of vapor in-
trusion is required (EPA 1993b, Section 1.4). Passive
sub-slab  systems show a performance range that varies
from 30-90 percent efficient (EPA 1993b). These per-
formance results were mostly obtained from short term
 o
 0)
 c
 o
 o
 'E
 3

 8
 u>
 'o
 O)
 o
     Structural issue
     HVAC systems
     Entry ways
Define Technology
Selection Criteria
                     Consider additional
                     benefits of system
Reduction target
(performance baseline)

Duration
Robustness
O&M requirements
Cost range
Effect on Indoor air,
e.g., moisture
Permit required?
Regulatory approval
                   Construction planning
                   Compare to performance
                   objective and technology
                   selection criteria
                   Develop written plans
                   Develop written plan
Figure 3. Flow chart for decision-making and technology selection after a
vapor intrusion assessment determines that mitigation is required.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches


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monitoring. Few passive systems have been adequately
monitored for long periods of time. In many cases, the
performance of passive depressurization systems decreas-
es substantially during warm seasons (NAHB Research
Center, 1996).

If passive techniques are insufficient to limit risk or haz-
ard, more active techniques may be used to prevent the
entry of vapor contaminants into a building.

As applied to the development or redevelopment of con-
taminated properties (e.g., a brownfields redevelopment
project), mitigation  strategies should be considered early
in the planning phase and incorporated into the engi-
neering design to eliminate or minimize vapor intrusion.
These up-front capital costs are often as much as 60
percent less than the costs for installing more intrusive
mitigation systems as retrofits.

Table 1 (used with permission from Babyak and Welt,
2006) includes an overview of engineering controls, as
well as comments and cost data for these techniques.

3.1  Active and Passive Sub-slab Ventilation

The most commonly accepted mitigation  techniques use
active or passive sub-slab depressurization  (SSD) systems
developed for use in radon mitigation (Babyak and Welt,
2006). Radon mitigation systems are typically designed
to achieve a  sub-slab pressure field that more than ad-
equately compensates for the depressurization  of the
building. Generally, the average range of soil/building
depressurization is on the order of 4-10 Pa. Thus, a miti-
gation system that compensates for a minimum of 4-10
Pa everywhere under the slab should adequately mitigate
vapor intrusion. The actual depressurization necessary to
achieve the desired risk level reduction in vapor intrusion
may vary and performance should also be  based on dem-
onstration of the requisite reduction in risk level. If the
soil permeability of the sub-slab region is high so that it
is not possible or economical to achieve or maintain a
pressure field extension of 4-10 Pa, then system design
should be based on achieving and maintaining ventila-
tion airflow  under the building sufficient to capture
radon or VOCs in spite of the building depressurization.
In this scenario, the sub-slab concentration must de-
crease substantially after the mitigation system has been
operating for an extended period of time (several days).
For surrounding lower permeability regions, significant
time may be needed to dilute local concentrations.
                          The hardware used in sub-slab ventilation (SSV) systems
                          and sub-slab depressurization (SSD) systems is simi-
                          lar. The two names describe the different mechanisms
                          through which the system can be effective in keeping soil
                          gas contaminants out of the building. When the sur-
                          rounding soil has a relatively high permeability, the fan
                          pulls large quantities of air (largely from the atmosphere)
                          down through the soil thus diluting the contaminant in
                          the sub-slab region resulting in reduced entry into the
                          building. This mechanism  predominates in a sub-slab
                          ventilation system. It is  important to ensure that open-
                          ings in the slab and foundation are adequately sealed to
                          prevent large quantities of conditioned indoor air being
                          pulled into the mitigation system. Sealing as part of SSD
                          system installation is discussed in EPA  1993b, section
                          4.7 and in NYSDOH, 2006, section 4.3.1.

                          When the soil is much less permeable, less air flows and
                          the fan generates a larger negative pressure in the sub-
                          slab region (thus sub-slab depressurization occurs). The
                          result is a larger negative pressure gradient across the
                          slab. The system works because the negative pressure
                          gradient ensures that the flow is in the direction from
                          indoors to the soil and dilution of sub-slab gases is less
                          important in this SSD case. In extreme cases of low per-
                          meability and low flows, it may be necessary to specify a
                          special blower to ensure that adequate pressure gradients
                          are generated. Engineering aspects of sub-slab systems
                          will be addressed later in this document.
                          The following factors should be considered when design-
                          ing SSD/SSV systems:
                          Spacing of Collection Points: Active system collection
                          points (sometimes referred to as "suction points") and
                          manifold piping are installed immediately beneath or
                          adjacent to the slab. The number and spacing of col-
                          lection points (EPA, 1993b; Fowler, C.S. et. al., 1990)
                          should be  based upon diagnostic testing (e.g., pilot test-
                          ing and communication testing) reflecting the properties
                          of the soil and fill  underneath the building. The lengths
                          and diameters of all piping should be appropriate for
                          the design capacity of the system. Horizontal manifolds
                          are usually not required when an adequate layer of clean
                          aggregate is present. Building codes in most areas now
                          require such layers of sub-slab aggregate but they may
                          not be present in existing structures.

                          Selection  of Sub-slab Collection Points or Manifold
                          Pipe Layouts: Collection points or a sub-slab manifold
                          piping network are used to ensure good coverage under
10
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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Table 1. Overview of Mitigation Methods with Cost Data (adapted from Babyak and Welt, 2006)
 Remedy
           Description
           Comments/
     Regulatory Acceptance
              Cost
 Ventilation Technologies-
 General Characteristics
                                  Need to maintain and always keep
                                  in place
 HVAC adjustment to take in
 more outside air and pres-
 surize building
Building design for slightly positive
pressure compared to outdoor.
Established for large structures; less
common for residential.
Need to maintain and always run
HVAC system fan.
About one third of the states cur-
rently use this method as a mitiga-
tion measure.
Capital: $ 0
Annual Operation and Maintenance
(O&M): $200-$750.
Note: This estimate assumes the
current HVAC system is capable of
continuously supplying the neces-
sary pressure, and that only periodic
checks/adjustments will be required.
 Enhanced ventilation without
 pressurization
Increased indoor ventilation (AER).
Increase of ventilation must be done
without reducing the pressure of the
interior space. More negative indoor
pressures would be likely to actually
increase vapor intrusion!
Unlikely for residential structures
because of energy cost impact.

May be acceptable in unconditioned
areas (e.g., garages).

Need to maintain and always run
system.

About one third of the states cur-
rently use this method as a mitiga-
tion measure.
Capital: $300-$1,000 (capital likely
to be higher, i.e. $3,000-$5,000 if
heat recovery is implemented).

Annual O&M: $100-$500.

Note: This estimate assumes a
few(e.g., 2-4) new vents between
the space to be treated and ambi-
ent air and/or supply fans will be
installed.
 Passive measures-
 general characteristics
Need to maintain and always keep
in place.

Installation is appropriate only when
residual VOCs in soil gas are un-
likely to contribute to unacceptable
air impacts (e.g., soil vapor concen-
trations are below levels of health
concerns).

30-90% reduction in vapor intrusion
is possible.

Subject to seasonal variations in ef-
fectiveness.
 Sealing
Seal cracks and other openings in
the foundation.
Residential and commercial build-
ings.

Need to maintain.

Hard to find and seal all openings.

About one third of the states allow
sealing of the building as a control
measure to be used alone.
Capital: $2.00-$3.00 per linear ft.

Annual O&M: $200-$500.

Note: This estimate assumes an
existing slab in fair condition
(i.e., cracking is not excessive).
 Vapor barrier—
 geomembrane
Impermeable geomembrane placed
beneath building.
Residential and commercial build-
ings only in new construction—not
feasible as a retrofit.

 Feasibility depends on foundation
design, typically combined with a
sub foundation vent system.

Maintenance is easy.

Less environmental concerns.

Can use HOPE (40-60 mil), LDPE,
orVDPE(SOmil).
Capital: $0.75-$1.50 per sq ft.

Annual O&M: N/A.

Note: This estimate assumes ap-
propriate bedding material will be
provided.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                                                                  11

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Table 1. Overview of Mitigation Methods with Cost Data (adapted from Babyak and Welt, 2006) (continued)
 Remedy
           Description
           Comments/
     Regulatory Acceptance
              Cost
 Vapor barrier—spray-on
 (i.e., Liquid Boot, epoxy
 paint).
Placement of a spray-applied vapor
membrane. The membrane may be
a rubberized asphalt emulsion or an
epoxy (method of sealing all cracks
and potential vapor intrusion points).
Residential and commercial build-
ings.
If this is sprayed indoors VOC emis-
sion (off-gassing) is high during
application—Level B PPE required1
and close business until indoor air
quality has returned to acceptable
levels.  Installation may take a few
days (depends on thickness re-
quired, building conditions, weather
conditions, etc.) since each layer
needs to off-gas before the next one
is applied.
Spray-on membrane may be dif-
ficult to maintain as it may flake or
become damaged; it is also hard to
repair (patch).
Capital: $5.00-$7.00 per sq ft.

Annual Operation and Maintenance
(O&M): $500-$2,000.

Note: This estimate assumes
multiple layers (applications) will
be required to achieve adequate
thickness.
 Passive sub-slab ventilation
 [vapor barrier (i.e., spray-on
 or geomembrane) and pas-
 sive gas venting system].
Placement of a vapor barrier and an
additional venting system. System
consists of a vent pipe (or a series
of vent pipes) installed through the
slab—relies on convective flow of
warmed air upward in the vent pipe
to draw air from beneath the slab.
Residential and commercial build-
ings.

Type of sub grade: permeable.
Capital: $500-$3,000, plus vapor
barrier costs (see above).
Annual O&M: N/A.
Note: This estimate assumes that
vertical vent pipes will be adequate,
and a network of horizontal col-
lection pipes will not be needed
beneath the membrane.
 Passive crawlspace ven-
 tilation [vapor barrier (i.e.,
 spray-on or geomembrane)
 and passive gas venting
 system].
Placement of a vapor barrier with an
additional venting system beneath.
Venting system consists of a series
of collection pipes installed beneath
building—relies on convective flow
of warmed air upward in the vent to
draw air from beneath the slab.
Residential and commercial build-
ings.

Note: Geomembrane barrier is best.

Type of sub grade: permeable.

Need to maintain and always keep
in place.
Capital: $500-$3,000, plus vapor
barrier costs (see above).

Annual O&M: N/A.

Note: This estimate assumes that
vertical vent pipes will be adequate,
and a network of horizontal collec-
tion pipes will not be needed be-
neath the membrane.  If a network of
horizontal collection pipes is needed,
the installation cost would be sig-
nificant and other options should be
considered.
 Active measures-
 general characteristics
                                  Need to maintain and run constantly.

                                  Requires significant stakeholder
                                  communication in residential build-
                                  ings due to long-term maintenance
                                  requirements.
 Active sub-slab suction [ac-
 tive gas venting system with
 or without vapor barrier
 (i.e., spray-on or geomem-
 brane)].
Placement of additional venting
system consisting of a vent pipe
(or a series of vent pipes) installed
through the slab and connected to a
vacuum pump to extract the vapors
from beneath the slab. May be
installed in conjunction with a vapor
barrier.
Need to maintain and always keep
in place.
Requires on-going monitoring and
maintenance of mitigation system.
Up to 99.5% reduction in vapor intru-
sion is possible.
About 40% of the States currently
use this technique to control vapor
intrusion; this is the most widely
used and accepted approach (from
Radon  Industry).
Capital: $1,500-$5,000, plus vapor
barrier costs (see above).

Annual O&M: $50-$400.

Note: This estimate assumes that
vertical vent pipes will be adequate,
and a network of horizontal col-
lection pipes will not be needed
beneath the membrane.
 12
       Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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Table 1. Overview of Mitigation Methods with Cost Data (adapted from Babyak and Welt, 2006) (continued)
 Remedy
          Description
           Comments/
     Regulatory Acceptance
              Cost
 Crawlspace depressuriza-
 tion [active gas venting
 system with or without a
 vapor barrier (i.e., spray-on
 orgeomembrane)].
Placement of an additional venting
system which uses fan-powered
vent system to draw air out of crawl-
space. May be installed in conjunc-
tion with a vapor barrier.
Commercial and residential Build-
ings.

Need to maintain and always keep
in place.

Requires on-going monitoring and
maintenance of mitigation system.

Up to 99.5% reduction in vapor intru-
sion is possible.

About one quarter of the States use
depressurization. Most states have
not yet addressed the issue.
Capital: $1,000-$4,000, plus vapor
barrier costs (see above).

Annual O&M: $50-$400.

Note: This estimate assumes one
fan will generate adequate suction
for multiple vent points.
 Sub-membrane
 depressurization
Fan-powered vent draws air from
beneath a soil gas retarder mem-
brane (laid on the crawlspace floor).
Residential and commercial build-
ings.

Need to maintain and run constantly.

About one quarter of the states use
depressurization. Most have not yet
addressed the issue.
Capital: $1,500-$5,000, plus vapor
barrier costs (see above).

Annual O&M: $50-$400.

Note: This estimate assumes that
vertical vent pipes will be adequate,
and a network of horizontal col-
lection pipes will not be needed
beneath the membrane.
 Block wall depressurization
Depressurizes the void network
within a block wall foundation by
drawing air from inside the wall and
venting it to the outside.
Residential and commercial build-
ings.

Need to maintain and run constantly.

Requires sealing of major openings.
Capital: $1,000-$5,000.

Annual O&M: $50-$200.

Note: This estimate assumes the
structure currently has a block wall
foundation.
General Cost Estimate Notes:
1.   All costs include labor, equipment, and materials, unless otherwise noted.
2.   Costs do not include treatment of gases unless specifically noted.
3.   Unit costs are in 2004 dollars and are estimated from standard estimating guides, vendors, and professional judgment and experience from
    other projects.
4.   Costs are based on a building footprint up to approximately 4,000 square feet.
5.   Cost estimates are for the purpose of comparing relative costs of these options against each other and do not represent actual design or
    construction cost estimates. A design/ construction cost estimate can be  prepared when additional site-specific details are available.
6.   These costs do not include: coordination, permitting, procurement, observation/oversight, reporting, air monitoring/laboratory analysis, or as-
    built drawings. Costs  may require future revision based on design, contractor quotes, required permits and other factors.
7.   The range of costs presented in this table is based on a review of literature (see Babyak 2006) and based on discussions with subcontractors
    and vendors).
8.   The true installation and operation and maintenance costs will depend on the site specific conditions and use.
the slab. Collection points often involve voids in the soil,
sometimes called suction pits, to improve the pressure
field extension under the slab. Mainfold installations will
be required for unusually large buildings or when the
building does not already have an effective air movement
pathway below the slab (i.e., aggregate, sand, etc.).
                                         Multiple sub-slab collection points connected through a
                                         vertically configured system of riser pipes (most com-
                                         mon). In cases where multiple collection points are
                                         used, vertical riser pipes connect the suction points
                                         in the floor of the building. These riser pipes rise
                                         vertically to the ceiling where piping may be most ef-
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                                                               13

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    ficiently consolidated into a single manifold pipe and
    run to a common location for exhaust.
 •  Horizontal Sub-slab Piping Network (less common).
    In this case a sub-slab network, of horizontal pip-
    ing is installed under and/or around the perimeter
    of buildings. Such systems are typically associated
    with new construction as it is usually uneconomical
    to install horizontal pipes  in trenches under existing
    buildings. In some cases, horizontal drilling tech-
    niques may be used to install piping under existing
    buildings.

With both vertical and horizontal multiple collection
point systems, some designers have incorporated pres-
sure regulating valves to  allow the suction at the various
points to be controlled (Dilorenzo 2007).

In all cases, care should be taken on installation of the
SSD/SSV system so that damage to building footings
and utility corridors is avoided. Also, deviations in pres-
sure fields or air flow patterns  arising from the presence
of footings and utility corridors must be taken into con-
sideration. The need for drainage or de-watering im-
provements to prevent soil moisture condensate blockage
of any portion of the collection piping should be evalu-
ated and suitable improvements contemplated, as neces-
sary, to ensure the proper operation of the collection
pipe system. There should be no low points for water to
collect in the lines and the pipes should be sloped to al-
low water to drain to the soil.

Design of System Vent Risers: Depending upon the
size of the building and the number of system fans/
pumps needed, system piping will be consolidated into
one or more vent risers that extend above the  building.
Vent risers should be equipped with a sampling port
and fitted with a non-restricting rain guard to prevent
precipitation and debris  from  entering the piping sys-
tem. Mesh is also helpful to exclude debris, nesting birds
and insects. Vent risers should be properly secured to the
building for protection against damage and should ter-
minate at a minimum of two feet above the roof of the
structure and be a minimum of 10 feet away from any
window or air intake into the  building. As a general rule,
the diameter of the vent riser should be appropriate  for
the capacity of the system; manifold piping is typically
a minimum of 3 or 4 inches in diameter for residential
buildings. A small fan or blower within the vent riser is
used in active systems. If a fan or blower is warranted for
the system, electrical power and controls  must be pro-
vided.
                          Utility Conduit Seals: Seals should be retrofit at the
                          termination of all utility conduits to reduce the poten-
                          tial for gas migration along the conduit to the interior of
                          the building. These seals should be constructed of closed
                          cell polyurethane foam, or other inert gas-impermeable
                          material, extending a minimum of six conduit diam-
                          eters or six inches, whichever is greater, into the conduit.
                          Wye seals should not be used for main electrical feed
                          lines. Design consideration should also be given to sump
                          pump drains and seals, to  ensure that they continue to
                          provide drainage when needed without compromising
                          the operation of the sub-slab depressurization system.
                          Proper sealing of penetrations  and entryways is especially
                          important for a  passive system because minor leaks in
                          buildings can offset the small pressure differentials that
                          passive systems rely on.
                          Additional design guidelines for SSD/SSV systems for
                          VOCs are provided in  (DiPersio and Fitzgerald, 1995),
                          http://www.mass.gov/dep/cleanup/laws/ssdle.pdf

                          3.1.1   Active Systems: Active Venting
                                 or Sub-slab  Depressurization (SSD)
                                 or Sub-slab Ventilation (SSV)
                          Active systems have been used successfully to mitigate
                          the intrusion of radon into buildings and have also been
                          successfully installed and operated in residential, com-
                          mercial, and school buildings to control VOC vapor
                          intrusion (Babyak and Welt, 2006). Active mitigation is
                          the more effective approach for use in existing structures
                          and/or where installation of a membrane  system below
                          the foundation is not feasible.  Note that permits or au-
                          thorizations from the local government may be required
                          for venting systems that exhaust to atmosphere (DTSC,
                          2004).
                          Active systems, often referred to as active  sub-slab venti-
                          lation (SSV) systems or sub-slab depressurization (SSD)
                          systems, are the  most common and usually the most
                          reliable mitigation method. The terms SSD and SSV  are
                          frequently used  interchangeably although the theory of
                          operation differs as described above. The system most
                          employed is the SSD.
                          EPA defines SSD technology as "a system designed to
                          achieve lower sub-slab air  pressure relative to indoor air
                          pressure by use of a fan-powered vent drawing air from
                          beneath the slab"
                          (http://www.epa.gov/radon/pubs/newconst.html).
14
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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In practice, these systems operate by either:
 •  Generating a sub-slab pressure field that adequately
    compensates for the depressurization of the building
    (SSD), or
 •  Achieving adequate advective air flow under the
    building sufficient to dilute VOCs diffusing from
    soil or groundwater (SSV).
In rare cases where both SSD and SSV have been shown
to be insufficiently effective, a third alternative is possi-
ble—sub-slab pressurization (SSP). SSP is normally used
when the permeability of the soil is too high to allow a
sufficient pressure to be generated for SSD but the fan
does not pull enough flow for effective SSV. In these
situations the fan can sometimes be reinstalled in the op-
posite orientation so that it blows into the sub-slab area
creating a flow away from the slab. SSP has been shown
to lead to improved performance in certain cases such as
where homes are built on well-drained gravel soils or on
highly  fractured rock. SSP systems are not better than
SSD systems in low-permeability soils even if there is a
gravel layer beneath the slab (EPA 1993b). More infor-
mation on these systems can be found in EPA 1993b
and ITRC 2007.
A diagnostic criterion for adequate performance of an
SSV system is more difficult to specify than such a cri-
terion for SSD systems because the flows required for
dilution are difficult to specify. Adequate negative pres-
sures under the slab are a good indicator of SSD system
effectiveness. Measurable negative pressures under the
slab also can indicate SSV systems are working, but it is
difficult to specify the pressure/rate of ventilation needed
for an adequate working margin of safety. For this situa-
tion, indoor air sampling should be weighted heavily in
the effectiveness evaluation.
As mentioned above, the most common approach to
achieving depressurization beneath the slab is to install
suction points through the floor slab into the crushed
Table 2. Reference Table of Pressure Unit Conversions
Multiply
Pascals
Atmospheres
Pounds per square inch
Bar
Inches of Water
By
1
101,325
6,894
105
249
To Obtain
Newtons/m2 (1 Newton is the
force required to accelerate
1 kg at 1 m/second2)
Pascal
Pascal
Pascal
Pascal
rock, drainage mat or pit underneath the slab. Ideally
the slab will have been built on a gravel or sand layer or
over a drainage mat (commercial drainage mat suppliers
include enkadrain http://www.colbond-usa.com/,
http: //www. sgs-geo technik. at/English/Pro ducts/
Drainage  mats.htm, and http://www.versicell.com/
drainage cell.htm).

A negative pressure is applied at the suction points suf-
ficient to achieve depressurization of approximately 4-10
Pa over the building footprint for SSD or the requisite
airflow for SSV. Again, for depressurization-based sys-
tems, the actual depressurization necessary to achieve
the desired level  of risk reduction may vary and perfor-
mance should be based, in part, on demonstration of the
requisite reduction in risk level. This demonstration may
best come from indoor contaminant concentration mea-
surements, in the absence of significant indoor sources
or from tracer gas attenuation tests. Excessive depres-
surization however can potentially lead to backdrafting
(induced spillage of combustion gases) of combustion
appliances, causing carbon monoxide exposure to oc-
cupants.

The number and location of suction points that are
needed  (as determined by visual inspections, diagnostic
tests, and experience within similar building structures
and contaminants) depends on how easily pressure or air
can propagate in the  crushed rock or soil under the slab,
and on the strength of the VOC vapor source. With a
clean aggregate layer one suction point is normally suf-
ficient for 2,700 ft2 of residential slab or 50,000 ft2 of
commercial slab (EPA 1993b). The results for commer-
cial buildings are based on use of larger fans and larger
diameter piping. This rule of thumb applies only when
the slab was built at one time. A vent fan is connected
to the suction pipe(s) drawing the VOC laden gas from
within the soil pore spaces beneath the building and
releasing it into the outdoor air, while simultaneously
creating a negative pressure beneath the slab.

In the case of low flow systems (SSD), a sustained nega-
tive pressure at all points under the slab is needed for ad-
equate performance of the system. As a practical matter
SSD systems are normally designed to achieve a pressure
differential of at least 0.02 inch of water (5 Pascal), dur-
ing the worst case season, to provide an adequate safety
factor for long-term variations. See Table 2 for pressure
unit conversions.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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Systems with only slightly negative pressure readings
tend to exhibit rapid pressure variations swinging be-
tween negative and positive. Installations that cannot
achieve the 5 Pa criterion for SSD recommended above
but demonstrate adequate risk reductions, should be
monitored more closely for long-term performance. For
a reliable measurement, these fluctuations must be aver-
aged over time periods of many minutes and sometimes
over several hours, which requires a digital gauge with
data-logging capabilities. The long-term average must
remain negative over all seasons for the system to be ef-
fective. Performance of these systems should be further
verified by another line of evidence such as an indoor air
measurement.

Common fan locations include attics and the exterior of
the building (Babyak and Welt, 2006). Fans should not
be installed in basements, other potential living spaces,
or any enclosed portion of the building that can poten-
tially communicate with the living space, since a leak on
the positive pressure side of the fan could introduce con-
taminants into the basement or living space (e.g., not in
or under a living space). Fans (or in some cases blowers)
should be selected to provide adequate flow and suction.
However excessively large fans should not be selected
because, though the capital cost increase might be small,
excessively large fans could lead to increased energy cost
in the long-term. There is a six page detailed discussion
of fan selection for SSD in EPA 1993b section 4.4 which
is also applicable for SSV. The most commonly used fans
for SSD are 50-90 watt in-line, centrifugal fans. Ninety
watt SSD fans are recommended  for homes with good
to marginal sub-slab communication. In cold climates a
bypass for condensation drainage should be provided to
prevent freezing and blockage of the fan. SSP fan selec-
tion is covered in EPA 1993b section 9.4.

Major design references for SSD/SSV technology in-
clude:

 •  ASTM E2121 -03 "Standard Practice for Installing
    Radon Mitigation in Existing Low Rise Buildings"
    which is recommended by EPA
    http://www.epa.gov/docs/radon/pubs/mitstds.html
    and is focused on residential buildings.
 •  EPA  1993b for existing detached houses, EPA
    1994b for schools, EPA  1994a for new residences,
    Fowler et. al., 1990 for low-permeability soils. Read-
    ers should also consider using the Florida (1995)
    guidance when working in areas with similar hous-
    ing types and geologic conditions. Section one of
                             the Florida guidance is for SSD in thickened edge
                             monolithic slab poured into stem wall, slab capping
                             stem wall, and slab-below-grade solid stem wall con-
                             struction.

                          Engler (2006) provides design considerations for sub-
                          slab depressurization and positive pressure systems to
                          combat vapor intrusion. Both types of systems work
                          with a fan and are therefore discussed together in this
                          work. The paper includes a chart with data for pre-
                          mitigation and post-mitigation indoor air concentra-
                          tions of VOCs at thirty locations. In all but three cases,
                          the VOC of concern was trichloroethene (TCE). Some
                          conclusions can be drawn  from this chart. For example,
                          the effectiveness of the controls is highest for the highest
                          pre-mitigation concentrations (around a factor of 100).
                          The mitigation systems were either barely or not at all
                          effective for the lowest pre-mitigation  concentrations,
                          which were  approximately 0.2 ug/m3 (0.04 ppb) TCE.
                          The paper concludes that, based on the chart, vapor in-
                          trusion (VI) mitigations are highly effective when prop-
                          erly designed and installed (Engler, 2006).

                          Folkes and Kurz (2002) describe a  case study of a vapor
                          intrusion mitigation program in Denver, Colorado. Ac-
                          tive soil depressurization systems have been installed in
                          over 300 residential homes to control indoor air con-
                          centrations of 1,1-dichloroethene (DCE) resulting from
                          migration of vapors from groundwater with elevated
                          1,1-DCE concentrations. Over three years of monitor-
                          ing data have shown that these systems are capable of
                          achieving the very substantial reductions in concentra-
                          tions necessary to meet the concentration levels currently
                          mandated by the state regulatory agency. Prior to instal-
                          lation  of the system, 1,1-DCE indoor air concentrations
                          ranged from below the reporting limit of 0.04 ug/m3 to
                          over 100 ug/m3. Post-mitigation monitoring showed that
                          in most cases, single suction-point  systems with 90 watt
                          fans were able to reduce 1,1 -DCE concentrations by 2
                          to 3 orders of magnitude, well below the state-required
                          standards. Approximately one quarter  of the systems
                          required minor adjustment or upgrading after initial in-
                          stallation in order to achieve the state standards (Folkes
                          and Kurz, 2002; Folkes, 2003).
                          Another case study of a large vapor intrusion mitigation
                          program is Hill Air Force Base (AFB) in Utah where 58
                          residential systems have been installed. Most (57) of the
                          systems are sub-slab systems with one  or two suction
                          points. Additionally the program includes two crawl-
                          space sub-membrane systems, one heat recovery venti-
16
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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lation system and four sump cover systems. As seen in
Figure 4, the program has been successful in reducing
concentrations significantly (Case, 2006; Elliot, 2005).

3.1.2   Variations of Sub-slab Depressurization (SSD)

Generally, creative variations of SSD depend on special
construction features of the building. The variations that
have been demonstrated to be successful are fully de-
tailed and illustrated by Henschel (EPA 1993b). Some
examples of variations are also found in (NYSDOH,
2005) and ASTM (2005):
Drain tile suction: Some houses have existing drain tiles
or perforated pipe to direct water away from the foun-
dation of the house. Suction on these tiles or pipes is
often effective especially if the drain tile extends entirely
around the building.
Sump-hole suction: If the building has a sump pump
to remove unwanted water, the  sump can be capped so
that it can continue  to drain water as well as serve as the
location of a suction pipe. However,  sumps connected to
exterior drain tiles are not appropriate SSD points un-
less a one-way valve  can be installed in the exterior drain
line. If the sump is not used as the suction or extraction
point, the associated wiring and piping should be sealed
and an airtight cover should be  installed, to enhance the
performance of the SSD system. In systems with active
dewatering, the potential for settlement over time should
be considered in  design of associated systems. Installa-
tion kits are readily available from mail order catalogs
(i.e., Infiltech.com) to either cover the sump or convert
it into a mitigation system. Nearly all materials needed
for  a complete SSD installation are available from manu-
facturer's web sites.
         System Sampling Results   £®J
Block wall suction: If the building has hollow block
walls, especially if the outside surfaces are in contact with
the soil and are not adequately purged, the usual sub-
slab suction point may not adequately mitigate the wall
cavities. In these cases  the void network within the wall
may be depressurized by drawing air from inside the wall
and venting it to the outside. This method is often used
in combination with SSD. When planning  such systems
it is important to distinguish between concrete blocks
and the more porous cinder blocks. A skilled and expe-
rienced mason may be able to  distinguish the two  types
of blocks once installed visually or by  sound after strik-
ing them. However, it  is difficult for a nonspecialist to
distinguish them once installed.

Crawlspace ventilation by depressurization is considered
by some to be a variation of SSD technology. Although
depressurization can be designed to reduce indoor con-
taminant levels, it may dramatically increase the crawl-
space concentrations making it a potentially high-risk
method of mitigation.  In contrast, crawlspace ventilation
that does not depressurize is a  useful mitigation method
and is discussed below in the section on HVAC modifi-
cations. Instead of crawlspace depressurization, consider
submembrane depressurization for crawlspace structures
(section 3.3.3) or possibly positive pressure  increased
ventilation of the crawlspace (section 3.4.3).
SSD and soil vapor extraction technologies are closely
allied, so site-specific engineering installations may re-
semble both technologies. NYSDOH  guidance (2005)
recognizes that soil vapor extraction (SVE) systems
which are used to remediate source contamination in
the vadose zone away from the building may also be
designed to mitigate vapor intrusion. The use of SVE
systems may be effective if the radius of influence of the
SVE system can be demonstrated to provide adequate
depressurization beneath the entire building foundation.
In this case, special attention must be  paid to the quan-
tity of contaminants exhausted to the  ambient air. Con-
ventional SVE systems can increase ambient outdoor air
concentrations. Regulation of these systems is described
under section 4.3.3 of this document and section 4.4 of
ITRC 2007.
                      BE AMERICA'S BEST
Figure 4. Results of the Hill AFB mitigation program.
3.1.3   Passive Systems

EPA has defined a passive sub-slab depressurization sys-
tem as "A system designed to achieve lower sub-slab air
pressure relative to indoor air pressure by use of a vent
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                 17

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pipe routed through the conditioned space of a building
and venting to the outdoor air, thereby relying solely on
the convective flow of air upward in the vent to draw air
from beneath the slab"
(http://www.epa.gov/radon/pubs/newconst.html). We
extend this definition of passive systems at the end of
this section to include a discussion of systems equipped
with a wind driven turbine to supplement convective
(temperature driven) flow.
The  passive stack (vent pipe) produces a reduced pres-
sure  zone below the building, intended to prevent radon
or VOC-bearing soil gas from entering the building.
This process is driven entirely by the surrounding  envi-
ronmental  conditions. Since mechanical devices do not
control the system, understanding the effects of wind
                 Passive New Construction
Figure 5. Passive venting system design. (Source: Illinois Department of
Nuclear Safety, Guide to Radon Mitigation, http://www.state.il.us/iema/
radon/pdf/guidetoradonmitigation.pdf).
                          and stack height on overall performance is crucial. For
                          more information, see
                          http://baba.astro.cornell.edu/research/radon/.

                          While passive systems derive some benefits from stack
                          height and wind velocity, the primary driving forces
                          originate from the buoyancy of the air that is warmed
                          by passing through the heated indoor space. Since these
                          driving forces are relatively small, all piping should be
                          large diameter and risers should rise vertically from the
                          collection point with as few bends in the pipe as pos-
                          sible, such as that shown in Figure 5. Bends in the pipe
                          result in a drag on flow equating to a pressure drop:
                          because the system is based on transient environmental-
                          ly-induced pressures, minor design inefficiencies trans-
                          late into potentially significant compromise of system
                          performance. Furthermore, during cooling season these
                          systems may not provide significant flow or in the worst
                          case could even be subject to a small reverse stack effect.

                          Since the same environmental factors that pull the con-
                          taminated soil gas into the building are instrumental in
                          driving the passive mitigation stack, a successful passive
                          stack must be significantly more  efficient at extract-
                          ing the contaminant from the sub-slab region than the
                          building itself. If there are significant gaps in the build-
                          ing envelope the building  has a competitive advantage by
                          directly communicating with most of the soil beneath.
                          The passive stack must extend its communication from
                          the suction point outward to all critical points under the
                          building by extending a dominant negative pressure field
                          to those points. Thus a passive system may need more
                          collection points than an active system to be effective,
                          which reduces the capital cost advantage of the passive
                          systems.
                          Figure 6. Example of severe pressure transience in a passive system.
18
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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Three aspects of passive system performance are illus-
trated by Figure 6 (Cody 2006). In this example, first
note that passive system performance may depend upon
the location of the stack or riser relative to building
features such as rooflines. In this case, the difference in
stack performance solely as a function of location (east
and west) is dramatic at some times—such as between 0
and 20 hours when the west stack pressure is often posi-
tive.  Second, the system shown in Figure 6 demonstrates
severe transience. Although the system may transiently
reach depressurizations on the order of 20 or 25 Pa, the
average depressurization  over time is only around 4 Pa at
the suction point. Recall that to effectively compensate
for typical building depressurizations, active systems are
required to achieve a 4-10 PA difference over the entire
building footprint. In this case, the approximate 4 Pa av-
erage depressurization at the stack is unlikely to translate
into  a 4 Pa depressurization at distances away from the
stack. Typical active systems have 250-300 Pa negative
pressure at the suction point. In many  cases, even this
pressure difference will not yield 1 Pa at the slab perim-
eter.  Third, although the east stack averages a negative
pressure over the period of measurement, the west stack
exhibits a substantial positive pressure much of the time.
Positive pressure indicates the direction of airflow is from
atmosphere to the sub-slab region. This effect could pos-
sibly exacerbate vapor intrusion by increasing flow into
the house through the slab.

Passive rather than active systems may  be chosen when
the vapor intrusion issue is less severe.  Passive sub-slab
systems are relatively easily converted to active SSD/SSV
systems if need be. Passive system design  should keep in
mind the potential need for such conversion. NYSDOH
(2005) reports that passive systems are not as effective as
active systems and their performance varies depending
upon ambient temperatures and wind  conditions. The
greatest potential for passive depressurization systems to
be effective is with buildings having a good clean layer of
aggregate under the slab, a tight slab, and poured con-
crete foundation walls to minimize air  leakage. Passive
systems also require more intense and longer term moni-
toring to validate reliable performance.
Wind turbines may help to increase passive system per-
formance without an ongoing energy  cost. Some states
describe wind-induced vent systems (Pennsylvania De-
partment of Environmental Resources, not dated,
http://www.wpb-radon.com/pdf/PA%20Radon%20
Mitigation%20Standards.pdf) which include wind tur-
bines. However, documented long-term performance of
these systems is not available at this time.

3.2  Sealing of Penetrations and Entryways
Entryways include: openings in a slab, major cracks in
walls, utility penetrations, sump lids that do not fit tight-
ly, and floor drains. Relevant utility penetrations that
may need to be sealed include those for plumbing, sewer
drainage, HVAC, elevators and in some cases electrical
conduit. It can be difficult to identify and permanently
seal the places where vapors may be entering, as normal
settling of the building opens new entry routes and re-
opens old ones (Babyak and Welt, 2006). Nevertheless,
sealing cracks and other openings in the foundation is a
basic part of most approaches to reducing vapor intru-
sion since it makes SSD systems more efficient. Sealing
these openings limits the flow of soil gas into the build-
ing thereby making other vapor reduction techniques
more effective and cost-efficient.
Both the U.S. EPA (1993b, http://www.epa.gov/radon/
pubs/physic.html) and New York's guidance (NYSDOH,
2005) take the position that sealing alone is not a reli-
able technology, but that sealing is a useful and necessary
supplement to sub-slab depressurization.
Sealants are materials used to fill joints occurring be-
tween two different materials as well as expansion and
control joints. Effective sealants must:
 •  Have good adherence to building materials
 •  Be workable at the installation temperature
 •  Have high elasticity and compressibility to resist
    foundation movements
 •  Not shrink after curing
 •  Be compatible with the  VOCs of concern
 •  Have good recovery after stretching or compression
 •  Be durable and water resistant
 •  Be low in emissions of hazardous VOCs
Sealing materials include synthetic rubbers, acrylics, oil-
based sealants, asphaltic/bituminous products, swelling
cement, silicon and elastomeric polymers. Sealants are
sometimes supplemented with fillers or backup materi-
als, including filler rods, tapes and tubing and foams
(Dagostino, 1983). Caulking is a type of sealant used in
"noncritical joints subject to compressive forces only"
(Watson, 1978).  Sealants  should not be confused with
sealers, which are materials used to coat materials (for
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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example a basement wall) to prevent penetration (i.e., of
water).
More detailed information is provided in Watson
(1978), Dagostino (1983), EPA (1994a), FEMA (1999),
in ASTM's Guide for Use of Joint Sealants (ASTM,
1995a) and ASTM's Guide for Use in Selection of Liq-
uid-Applied Sealants (ASTM, 1995b). Practical advice
on techniques for applying sealants in residential settings
is available from a number of resources on waterproofing
including Blackburn (1991) and Reader's Digest (1977).
Sealing or weatherization is frequently recommended for
energy cost reduction. Note, however, if the source of
indoor contaminants is indoors and not vapor intrusion,
reducing the ventilation rate of a structure may result in
increased indoor air concentrations.
3.2.1   Utility Penetrations and other Routes of Entry

A utility corridor or utility trench is defined as one
or more underground or buried utility lines or pipes,
including any excavated and subsequently backfilled
trench that the utility line or pipe was constructed or
laid in. Utility corridors include, but aren't limited to:
sanitary and storm sewers, water lines, gas lines, sewer
force mains, buried electric power distribution lines and
buried telephone, cable television or telecommunication
lines. Utility corridors can be found in public rights of
way, including streets or roads, as well as on the proper-
ties being served by the utilities. Utility corridors that
are of higher permeability or higher porosity than the
surrounding soils are of greatest concern as pathways
for preferential migration. At such sites, vapors or free
product could migrate within a utility corridor regardless
of the groundwater depths. Flow through utility corri-
dors could be advective depending on pressure gradients
or diffusive which is independent of pressure gradients.
Furthermore, vapors could migrate in any direction,
while free product may tend to migrate in the down
slope direction along a trench (Wisconsin, 2000).

Utility penetrations through the walls of a structure are
of concern because they often provide a direct connec-
tion between the living space and the subsurface soil/
sub-slab soil gas. Concern arises because the construc-
tion of subsurface utility corridors (utility annul us) is of-
ten surrounded by high permeability gravel. Accordingly,
free product or vapor migrating along a utility corridor
could move toward and into buildings that are serviced
by or connected to a utility. Explosive vapors or flam-
                          mable free product in utility corridors may present an
                          emergency situation and thus must be addressed upon
                          discovery. NJDEP 2005 recommends that all poten-
                          tial pathways/defects (e.g., cracks, sumps, utility lines)
                          should be sealed during building walkthrough/initial
                          sampling/assessment. Examples of how utilities tie into
                          various types of structures are shown in Figure 2.

                          Most municipal and homeowner's association utilities
                          maintain water and sewer system maps, which normally
                          show the location and depths of sanitary and storm sew-
                          ers, water mains and sewer force mains (pipes carrying
                          the pressurized flow output from a sewage pumping or
                          lift station). Such maps also  normally show the locations
                          of sewer manholes, sewer and trench slope, water main
                          valves and fire hydrants, which are helpful to the investi-
                          gator when locating utility corridors in the field. How-
                          ever in other communities documentation of historically
                          installed infrastructure may be incomplete.

                          Other relevant information can include plans of the spe-
                          cific building being studied, utility maps, soil maps, re-
                          sults  from other nearby investigations and historical use
                          maps, including Sanborn insurance maps and the  U.S.
                          Geological Survey (USGS) topographic maps.  Com-
                          bining general  knowledge of the extent of a release, soil
                          and groundwater conditions in the site area with exami-
                          nation of actual utility maps can help the investigator
                          develop a conceptual model and make an initial determi-
                          nation of whether utility corridors may be potential mi-
                          gration pathways that would require special treatment.

                          Generally, sewers and water  mains are deeper than gas,
                          electrical and telecommunication lines and sewer lines
                          are normally routed below water lines. Where maps
                          showing utility depths are unavailable or unreliable, it
                          may be possible to  measure the depths of utilities by
                          dropping a tape measure down an access point, such as
                          a sewer manhole or telecommunications access. Materi-
                          als of construction  are normally known, and sometimes
                          bedding and backfill materials are known (Wisconsin,
                          2000). Most states  have a "one call" or similar utility lo-
                          cator service that must be notified before intrusive work.
                          See, for example: Risk Management Services™
                          (http://www.rmlibrary.com/sites/safetdigsa.php) or
                          Construction Weblinks™ (http://www.construc-
                          tionweblinks.com/Industry  Topics/Specifications
                          Technical  Data/Specifications and Technical D/
                          Earthwork and Site Work  Speci/underground  alert
                          centers/underground alert centers.html)
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Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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Placing utility dams can control vapors migrating along
utility corridors. Utility dams (a.k.a. trench plugs or
trench  saddles) are temporary or permanent barriers
installed at regular intervals in utility trenches. These
dams are used for preventing erosion and for minimizing
the potential of groundwater seeping along the path of
least resistance, along pipes and other utility lines in the
trench. They are generally one to two feet long and com-
posed of clay or pelleted bentonite because it has very
low permeability and excellent  sealing properties.
(http://www.pacd.org/products/bmp/trench plug.htm).
(ASTM E 2435-05).
The  use of bentonite as a sealant is an established tech-
nology, primarily associated with well drilling and
management. However the effectiveness of bentonite in
blocking vapors (as opposed to water) may not be fully
established. One example project was identified where
a trench dam was  specified as a barrier for landfill gas.
Specifications included:
 • Trench dams should be installed immediately adja-
   cent to the exterior perimeter of the building foun-
   dation,
 • Trench dams should have a minimum length of 36
   inches or twice the width of the trench,
 • Trench dams should be of a bentonite cement
   slurry—a mixture of 4  percent Type II cement and 2
   percent powdered bentonite. (Forbort, 2006)
Potential vapor intrusion along utility lines can also be
addressed at the building envelope using sealing tech-
niques. These sealing methods include mechanical
techniques (such as gaskets),  sealants, and caulking (see
discussion above). Information regarding sealing air leaks
in building envelopes is available in the following loca-
tions:

 • Department of Energy Technology Fact Sheet.
   http://www.toolbase.org/PDF/DesignGuides/doe
   airsealingFS .pdf a Department of Energy primer
   with useful diagrams and discussion of sealing mate-
   rials
 • Oregon Residential Energy Code.
   http://www.oregon.gov/ENERGY/CONS/Codes/
   docs/res 14.pdf similar energy oriented information
   from the State of Oregon
 • Alaska Housing Manual, 4th Edition.
   http://www.ahfc.state.ak.us/reference/housing
   manual.cfm The Alaska housing manual, though tai-
   lored for an extreme climate, provides much useful
    and well-illustrated material on sealing in chapters 2,
    4, 5 and 8.
 •  Habitat for Humanity, St. Louis.
    http://www.habitatstl.org/construction/cstmanual/
    airsealing/ contains practical hands-on information
    from a volunteer organization.


3.2.2   New Construction and Repairs

Most of the material covered in the preceeding sections
also applies to sealing the building envelope during new
construction. Indeed, sealing during new construction
generally should be easier and cheaper than a retrofit
(Welt and Thatcher, 2006), and there is a greater oppor-
tunity to use membrane (passive) barriers (see below).
Attention must be paid however to sequencing the trades
involved in construction so that one contractor does
not undo the sealing provided by another. EPA provides
extensive information on radon resistant new construc-
tion that can readily be adapted to vapor intrusion issues
for organic contaminants by ensuring that the materials
used are resistant to  diffusion of the contaminant of in-
terest and are durable in the presence of those contami-
nants.
 •  For residences see
    http://www.epa.gov/radon/construc.html and
    http://www.epa.gov/radon/pubs/newconst.html.
 •  For schools see http://www.epa.gov/iaq/
    schooldesign/controlling.html and
    http://www.epa.gov/ORD/NRMRL/
    pubs/625r920l6/625r920l6.htm.
 •  For large buildings see U.S. EPA Radon in Large
    Buildings
    http://www.epa.gov/ORD/NRMRL/
    pubs/625r920l6/625r920l6.htm.
 •  For other building types see ASTM's "Guide for
    Application of Engineering Controls to Facilitate
    Use or Redevelopment of Chemical-Affected Proper-
    ties" (ASTM, 2005)
Repairs to masonry and concrete work may be necessary
for basement walls, slabs and floors. Standard techniques
discussed above that were designed for structural, wa-
terproofing and/or aesthetic repairs can be adapted, but
air tightness against pressure is more difficult to achieve
than aesthetic or structural repair.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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3.3  Passive Barriers (including Membranes)

Both sheeting products and poured/cure-in-place prod-
ucts provide a passive, physical barrier to vapor in-
trusion. It is also possible to use clay barriers for this
purpose in new construction (Geyer, 2006) .There are
two main types of passive barriers that will be discussed
in this section: sheet membranes and fluid-applied
membranes. Later in the section we will provide general
information on installation and information about the
membranes used as part of sub membrane depressuriza-
tion systems, typically for crawlspaces.

3.3.1   Sheet Membranes

Sheet membranes are usually 40-60 mil high-density
polyethelene (HOPE) but can be polyethylene, poly-
vinylchloride, or EPDM (ethylene propylene diene
monomer) rubber. Sheet membranes less than 30 mil
(e.g., 6 mil visqueen) are not durable enough to prevent
significant damage during placement of reinforcing steel
and concrete and thus are not recommended in sub-slab
applications. An example of how a membrane is typically
installed is shown in Figure 7.

3.3.2  Fluid-applied Membranes

Fluid-applied or cured-in-place membranes are spray-
applied to a  specific thickness (e.g., 60 mil). One  of the
major vendors of cured in-place products reported that
to their knowledge there have not been any studies of
the effectiveness of these products published in the lit-
erature or presented at conferences (Ameli, 2006). Nor
has any formalized testing taken place  at a whole struc-
ture scale. However the vendor does have numerous case
        2-INCH (WIN.)
         SAND LAYER
       OTER MEMBRANE
                                        EXTERIOR WALL
        StXLE: NOT TO SCALE
Figure 7. Membrane barrier installation example

22
                         studies of applications as gas vapor barriers for methane,
                         chlorinated solvents and petroleum hydrocarbons avail-
                         able at their websites
                         (http://www.liquidboot.com/index-gasvapor.php;
                         http://www.polyguardproducts.com/products/
                         Underseal/index2. htm).
                         3.3.3  Membranes Used in Membrane
                                Depressurization Systems

                         In buildings with a crawlspace foundation, a membrane
                         may be used to install a sub-membrane depressuriza-
                         tion (SMD) system and is recommended in the state of
                         New York's guidance. NYSDOH (2005) recommends a
                         membrane of polyethylene or equivalent flexible sheeting
                         with a minimum thickness of 6 mil or 3 mil cross-lami-
                         nated. These thicknesses may not even be adequate if the
                         membrane will be heavily trafficked. The sheet should
                         cover the entire floor area and be sealed at the seams and
                         penetrations. During the installation the sheeting should
                         not be pulled tight, because when the depressurization
                         system is turned on, it will be drawn down which may
                         cause strain on the seals. Smoke testing is used after
                         installation to ensure a good seal (see section 5.5.1). Get-
                         ting a good seal around pipe chases  and other protrud-
                         ing objects can be problematic when using sheeting and
                         the vendors of spray-on type  membranes do not suggest
                         mixing the two types of barriers. Additional information
                         can be found in ASTM's "Specification for Plastic Water
                         Vapor Retarders Used in Contact with Soil or Granular
                         Fill under Concrete Slabs" (ASTM, 1993). This technol-
                         ogy is discussed in depth in section  3.6.1.

                         3.3.4  Installation of Membranes

                         Some discussion of techniques for installing membranes
                         and seals around penetrations in existing structures is
                         provided in section 2.2.2.1 of EPA's "Air/Superfund Na-
                         tional Technical Guidance Study Series: Options for De-
                         veloping and Evaluating Mitigation Strategies for Indoor
                         Air Impacts at CERCLA Sites" (EPA, 1993a), in section
                         4.2.2 of the New York Guidance (NYSDOH, 2005) and
                         in section III.2 of the California guidance
                         (http://www.dtsc.ca.gov/AssessingRisk/upload/HERD
                         POL Eval Subsurface Vapor Intrusion  interim final.
                         pd£).
                         We recommend that the integrity of all membranes
                         be verified not only at the time of membrane instal-
                         lation but also later after foundation and floor system
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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construction is complete. Multiple test times are sug-
gested because the cost of repairs is lower the sooner the
problem is identified and post membrane installation
construction work can damage a previously acceptable
membrane. All sheet products should be protected from
ultraviolet (UV) damage such as from sunlight.

New construction is a good time to install a membrane
but performance is only as  good as the quality of seals
that can be achieved and maintained at utility penetra-
tions. The installation of the membrane must be the last
step before pouring the slab. Experience has shown that
it is almost impossible to maintain a membrane without
penetrations at an active  construction site during the
building process. Boots are required at all penetrations
through the membrane. Boots are sheaths or coverings
that seal the membrane to vertical objects such as pipes,
utility chases, wires. The manufacturer of the geomem-
brane typically has  a quality assurance manual that speci-
fies the procedure for correct installation. This manual
should be requested and  reviewed. This topic is covered
in EPA's "Model Standards and Techniques for Control
of Radon in New Residential Buildings" (EPA, 1994a).
ITRC (2007) recommends preparation of a detailed
quality assurance/quality control (QA/QC) plan cover-
ing situations that could  damage the membrane during
installation and subsequent construction activities.

3.4  Natural Ventilation and HVAC Modification

In this section we will present information on a num-
ber of approaches to vapor intrusion mitigation through
modifying building ventilation. Passive and active ven-
tilation changes for the living  space are discussed first
followed by ventilation changes applied to crawlspaces.
Extensive additional information on ventilation and
HVAC systems can be found at:
 •  http://www.buildingscience.com
 •  http://eetd.lbl.gOv/ied/viaq/v pubs.html
 •  www.buildingamerica.gov
An aspect of ventilation is providing a dedicated air sup-
ply for combustion appliances, etc., to reduce indoor air
depressurization. A dedicated  air supply for combustion
appliances is a good practice for avoiding backdrafting of
the appliances. This approach usually has a modest effect
on the indoor pressure.
3.4.1   Increase Passive Ventilation
       of the Occupied Space

Some natural ventilation occurs in all buildings. By
opening windows, doors, and vents, ventilation in-
creases. This increase in ventilation mixes outdoor air
with the indoor air containing VOC vapors, and reduces
indoor levels of the contaminants. However, as discussed
in section 2.2 if a building is experiencing a "stack ef-
fect", which is normal, opening a window only in an
upper story above the neutral pressure plane can increase
the inflow of soil gas and thus be counterproductive.
Moreover, once windows, doors, and vents are closed,
the concentration of VOCs most often returns to previ-
ous values within about 12 hours. Thus, natural ventila-
tion in any type of building should normally be regarded
as only a temporary reduction approach (Babyak and
Welt, 2006) because the increased cost of heating or air
conditioning will lead to closing the doors, windows or
vents.

3.4.2  Active HVAC Adjustments
       in the Occupied Space

Sometimes HVAC modifications are made to maintain
adequate positive pressure within at least the lowest level
of a structure (and all levels in contact with soil) to miti-
gate vapor intrusion. Older structures,  however, rarely
exhibit the requisite air tightness to make this approach
cost effective. If sufficient positive pressure within the
structure can be consistently maintained, then advec-
tive flow from the subsurface into the structure should
be effectively eliminated although diffusive flow may
continue. Most forced air heating and cooling systems
only operate as needed. This system would need to be
modified to run continuously when used to maintain a
constant pressure within the structure.  In addition, some
buildings do not have forced air systems. For example,
many structures in the northern U.S. are heated with hot
water circulation systems (radiators) and may lack air
conditioning.
Some building operators assert that vapor intrusion can
be largely avoided in commercial structures by comply-
ing with ventilation codes. For example, the American
Society of Heating, Refrigerating and Air Conditioning
Engineers (ASHRAE) publishes standards such as:
 •  ASHRAE Standard 62-1989 "Ventilation for Ac-
    ceptable Indoor Air Quality"
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                 23

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 •  ASHRAE Standard 90.1-1989 "Energy Efficient De-
    sign of New Buildings Except Low-Rise Residential
    Buildings"
 •  ASHRAE Handbook (1985) Fundamentals. Chap-
    ter 22. Atlanta, Georgia. American Society of Heat-
    ing Refrigerating and Air Conditioning Engineers
    (ASHRAE). 1985.

Ventilation standards also exist in some jurisdictions
such as:
 •  Washington state
    http://www.energy.wsu.edu/documents/
    code/2003VIAO.pdf
 •  Massachusetts
    http://www.mass.gov/Elwd/docs/dos/iaq/iaq 392
    mechanical vent.pdf
 •  Minnesota http://www.doli.state.mn.us/pdf/
    be 2007msbc.pdf and http://www.health.state.
    mn.us/divs/eh/iarc/vent.html
Compliance with the provisions of those codes, that
require a minimum amount of fresh air to be provided,
will assist in minimizing vapor intrusion. Specifically, if
a positive pressure differential can be maintained consis-
tently between the interior and sub-slab air vapor intru-
sion will be minimized. Note, however, that existence
of a positive pressure differential between interior and
exterior of a structure is not sufficient, since exterior and
sub-slab pressures can differ. Nor are measurements of
positive air flow into  a structure sufficient to demon-
strate a pressure differential across the slab.

Note also that ventilation code standards have not always
existed in the past when many existing structures were
built, and compliance is normally required only for new
construction and/or significant rehabilitation. Anecdotal
evidence also suggests that "ventilation codes" may not
effectively govern the ongoing operation  of HVAC sys-
tems in small commercial structures.
Berry-Spark, et al. (2006) describes a former manu-
facturing facility that has been redeveloped for use as
a multi-unit commercial building where TCE was the
pollutant of concern. An HVAC adjustment to  positively
pressurize the building resulted in an increase in the
AER of a factor of two (using post-modification positive
pressure measurements). The average pressure differ-
ential was measured to be 0.01 to 0.08 inches of water
(2.3 to 19.8 Pa). Two rounds of indoor air samples were
collected about 5 and 6 weeks after the HVAC adjust-
                          ments were made. These show an order of magnitude
                          reduction in the contaminant was achieved. Dilution
                          associated with the factor of 2 increase in AER accounts
                          for a factor of 2 decrease in the  concentration, which is
                          only 20 percent of the total decrease. By deduction, the
                          additional 80 percent reduction must be due to reduced
                          negative pressure in the building. By increasing the AER,
                          the costs of heating and cooling would also increase sub-
                          stantially.
                          Methods that rely solely on increasing AER/ventilation
                          in the occupied space without pressurization can achieve
                          only modest reductions in concentrations (50-75 per-
                          cent). Further increases in ventilation rates usually be-
                          come uncomfortable for occupants. (CIRIA, 1994)

                          3.4.3   Crawlspace Ventilation

                          This section applies to crawlspaces that are substantially
                          enclosed. Crawlspaces that are freely ventilated (i.e., con-
                          struction on piers) will rarely need mitigation unless the
                          piers themselves are hollow. Foundations without effec-
                          tive cross ventilation (i.e., piers  on only one side) could
                          need mitigation.

                          Levels of VOCs in enclosed crawlspaces can be low-
                          ered by ventilating passively (without the use of a fan)
                          or actively (with the use of a fan). When a fan is used it
                          should blow into the space rather than out, to positively
                          pressurize the crawlspace and thus minimize concentra-
                          tion in the crawlspace. However, use of ambient air for
                          this purpose in cold climates  could cause problems with
                          pipe freezing. Crawlspace ventilation may lower the con-
                          centration of vapors in the indoor air both by reducing
                          the building's suction on the  soil (via a pressure increase
                          in the crawlspace) and by diluting the concentration of
                          vapors in the crawlspace.

                          Opening vents or installing additional vents achieves
                          passive ventilation in a crawlspace. In colder climates,
                          during either passive or active crawlspace ventilation,
                          water pipes, sewer lines and, appliances in the crawlspace
                          may need to be insulated against the cold. These ventila-
                          tion options could also result in increased energy costs
                          for the building (Babyak and Welt, 2006). Since it is
                          common to recommend to homeowners that these vents
                          be closed at some seasons of the year, it would be diffi-
                          cult to rely on natural  crawlspace ventilation as a long-
                          term remedy through changes at building occupants.
                          Skirted areas under mobile homes can also be opened or
24
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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ventilated for dilution to limit vapor intrusion. Ventila-
tion systems, however, should be designed not to nega-
tively pressurize these spaces with respect to soil gas.
These techniques are discussed in section 2.2.3 of EPA
1993a and sections 7.2 and 7.3 of "Reducing Radon in
Schools: A Team Approach" (EPA 1994b),  among other
sources.
Active crawlspace ventilation involves blowing air directly
into the crawlspace using a fan and can be combined
with sealing. This technique generally does  not work as
well as sub-membrane depressurization. It is important
to seal the unoccupied crawlspace from other portions  of
the building. This engineering control method may result
in increased  energy costs due to loss of conditioned air
from the building (Babyak and Welt, 2006). Crawlspace
venting that causes depressurization is not recommended
because it results in increased concentrations in the crawl-
space.

3.5  A ir Cleaning using A dsorbents,
     Scrubbers or Photocatalytic Oxidation
The devices  discussed in this section aim to mitigate va-
por intrusion by directly treating air in the  structure, as
opposed to blocking entrance or increasing ventilation.
Available air cleaners include both in-duct models and
portable air cleaners. These devices operate on various
principles including zeolite and carbon sorption, ozone
oxidation and photocatalytic oxidation. (Note, however,
that some regulatory agencies have taken strong posi-
tions to warn of potential problems with air cleaners
dependent on ozone generation:
http://www.arb.ca.gov/newsrel/nr012005.htm). Meth-
ods that inject ozone into the breathing space of the
indoor environment cannot be recommended as an  air
cleaning technique, as ozone is a criteria pollutant. The
state of California has  banned the  sale of residential
ozone producing air cleaners effective in 2009. Meth-
ods that rely on adsorption such as zeolites  and carbon
generate a waste that must be disposed of appropriately
or regenerated.
While the literature on the efficacy of air cleaning de-
vices for vapor intrusion is quite limited, literature has
recently been published regarding  use of these devices
for indoor air contaminants originating from other
sources, or from undetermined sources. Much of this
work focuses on pollutants not normally encountered  in
vapor intrusion—such as particulate matter. However,
tests have been conducted that showed some efficacy for
certain VOCs such as:

 •  Formaldehyde—test chamber scale. (Nozaki, et al.,
    2005 and references cited therein)
 •  Decane—field scale, multiple real buildings (How-
    ard-Reed, et al., 2005)
 •  Acetone—field scale, single real building (Kwan,  et
    al., 2005)
Henschel (1998) has conducted an economic analysis
comparing photocatalytic oxidation to activated carbon
systems for TCE,  formaldehyde, acetone, benzene and
toluene which concluded that for most contaminants
activated carbon was more cost effective. UV-photocat-
alytic oxidation is considered an attractive technology
because it typically converts most VOCs into carbon
dioxide (CO2) and water under indoor air conditions.
TCE photocatalatic oxidation yields hydrochloric acid
as well which is undesirable (Dibble and Raupp, 1992).
However, according to Chen, et al., (2005), the com-
mercialization of this technology as room cleaners is still
in the beginning stage.
Section 2.2.3.2  of EPA (1993a) includes a discussion on
air cleaning. Readers are also referred to another study:
"Performance of Air Cleaners for Removing Multiple
Volatile Organic Compounds in Indoor Air" (Chen,  et
al.,  2005). According to this study, sorption filtration is
still the most effective off-the-shelf commercial technol-
ogy, at least for the initial period, for general removal of
indoor VOC pollutants. Sorption filter design plays an
important role:  generally filters with more surface area
and better air-to-sorbent contact had higher efficiencies.

Berry-Spark et al., (2006) describes testing at an oc-
cupied residence that is located down gradient from a
former industrial facility where TCE had been released.
The TCE is  now present in soil and groundwater. A
commercially available residential air filter with an 18-lb
impregnated activated carbon filter cartridge was in-
stalled in the basement to remove the VOCs from the
indoor air. It is suggested that this is a good alternative
where a shallow water table may make sub-slab venting
difficult. Data are presented in this paper that appear to
show substantial concentration reductions although only
one background-sampling round was presented. Opera-
tion of the filter has generally reduced TCE  and TCE
daughter product concentrations in the indoor air below
detection limits of 1 to 2 ug/m3. Note that two detec-
tions occurred which are thought to have resulted from
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                 25

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impeded air circulation due to doors being closed. This
result would suggest such systems require careful moni-
toring.

In another study (Daisey and Hodgson, 1989), four dif-
ferent air cleaners were tested in a room-sized chamber.
Two of these devices were effective in removing five of
the six VOCs tested. Two devices were not very effec-
tive. Effectiveness was believed to  relate to the amount
of activated carbon in the devices and their flow rates.
Both effective devices had a flow rate of around 227 m3/
hour, while the key component was  an activated charcoal
filter. The VOCs that were successfully removed include:
2-butanone, n-heptane, toluene, tetrachloroethylene,
and hexanal. Nitrogen dioxide (NC^) was also tested
and removed. None of the devices could remove dichlo-
romethane. The removal rates and efficiencies decreased
substantially after 150 hours of operation. There was also
evidence of chemical reactions occurring in the carbon
after extended operation.

3.6  Combinations of Multiple Technologies
Depending on site-specific conditions, it may be desir-
able to combine one or more of the  above technolo-
gies to improve efficiency or reduce  cost. For example
sealing and other barrier approaches can be effectively
paired with sub-slab depressurization strategies and are
often considered part of that technology. Combinations
of technologies can be installed together or applied in a
phased approach, based on certain risk related triggers.

For example, passive systems can be  used with vapor-
resistant features (i.e., passive barriers) installed in newly
constructed homes where the water  table is well below
the gravel layer and vapor barrier (Babyak and Welt,
2006). Active SSD systems in conjunction with passive
membrane barriers would be even more effective (EPA,
1993b).

3.6.1   Sub-membrane Depressurization
In buildings with a crawlspace foundation, a membrane
may be used to install a SMD. A membrane similar to
those described above is placed on the ground in the
crawlspace to retard the flow of vapor into the building.
The membrane is sealed to the walls of the building and
one or more suction points are fitted through the  mem-
brane, using a plywood or plexiglass gasket. The gasket
is manufactured by sealing  the plywood (or other suit-
able material) to both sides of the  membrane (below and
                         above). A pump or fan is then connected to the suction
                         point(s) and the system is operated in a manner similar
                         to the SSD system; that is, the SMD system uses a suc-
                         tion point(s) and manifold to draw vapors from beneath
                         the membrane and vent them to the atmosphere. The
                         lower pressure beneath the membrane prevents vapors
                         from entering the building. Additional design recom-
                         mendations for these systems can be found in:

                          •  ASTM E 2121 -03 especially Section 7.3.8
                          •  Chapter 8 of EPA 1993b
                          •  Chapter 4 of NYSDOH 2005
                          •  Section 2 of the Florida (1995) guidance

                         The state of New York's guidance calls for the use of sub-
                         membrane depressurization systems in crawlspaces.

                         4    SELECTING A TECHNOLOGY
                         The process of selection, design, sizing, and installation
                         of vapor intrusion mitigation technologies is similar to
                         most other technologies (Figure 3 provides an overview
                         flowchart). First and foremost, the objective of the tech-
                         nology must be clearly defined and quantified (this as-
                         pect is discussed in more detail in sections 5.1 and 5.2).
                         Next, specific inputs must be identified and bounded to
                         narrow the selection to one choice, consisting of a dis-
                         tinct technology or a combination of technologies. This
                         is an iterative process, however some criteria and input
                         parameters are more important than others.

                         Vapor intrusion and other indoor air issues are driven
                         by concerns about the health of the  building occupants.
                         Thus, the primary input that governs the selection of
                         the appropriate technology or combination of technolo-
                         gies should be based on the required reduction target(s)
                         or acceptable air concentrations for the contaminants.
                         These reduction targets must be reached not only in the
                         short term, but they should also be sustainable over the
                         long term (i.e., the life of the building or the duration
                         of the vapor source, whichever is shorter). Therefore, the
                         second input to select a technology is reliability. Reliabil-
                         ity may be defined here as having three components:

                          •  The system should consistently produce acceptable
                             indoor air quality according to the required targets.
                          •  The system should not break down and failures, if
                             they occur, should be readily perceived and easily
                             remedied.
26
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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 •  The system should be robust (resistant to harm from
    reasonably foreseeable events occurring around it).

When assessing reliability and appropriateness of a vapor
intrusion mitigation system, it is important to keep in
mind that the system is likely to be impacted by people
who may not be fully cognizant of the system's intent.
When the system is noisy or consumes significant energy,
it may be turned off. Vents or windows may be opened
or closed, altered or blocked. Continued reliability and
effectiveness should be optimized through information
dissemination and training, or through other means,
such as deed restrictions or monitoring schemes.

The third input to consider in selecting a technology is
the determination of any negative effects that the tech-
nology may have on other indoor air quality parameters.
If a vapor intrusion technology significantly compro-
mises other aspects of indoor air quality (e.g., moisture
content or perceived ventilation rates), it will be unac-
ceptable. Information on the impact of ventilation rates
on perceived air quality can be found at
http://eetd.lbl.gOv/ied/viaq/v rates  6.html. Similarly,
acceptable ambient air quality outside the structure must
be maintained.

If a proposed system has "passed" the above threshold
criteria, the fourth input that will influence selection is
the physical structure of the building, including:

 •  Intended use (commercial, industrial or residential)
 •  New vs. existing building
 •  Foundation type (slab, basement, crawl space,  mo-
    bile home)
 •  Type of HVAC system

The fifth input to take into consideration in the selec-
tion process is cost, which may be broken down into:

 •  Capital cost
 •  Installation cost
 •  Operation and maintenance cost
 •  Monitoring cost

Because vapor intrusion is an issue that affects the  public
directly, especially in residential  structures, communica-
tion with the public is very important. A final factor to
be considered is the ease of public acceptance. This issue
is addressed in the section entitled "Risk communication
and stakeholder involvement considerations," below.
4.1  Concentration Limits for the Contaminant

The primary driver for selection of a best mitigation
technology will be the calculated or numeric risk-based
standard for the indoor exposures. In some states numer-
ic standards for indoor air have been developed as a mat-
ter of policy or regulation for vapor intrusion. In such
cases, acceptable mitigation technology would achieve
those indoor air standards. In other states (e.g., Connect-
icut, Massachusetts), allowable concentrations in other
environmental media (e.g., soil gas or groundwater)
have been derived to be protective for vapor intrusion.
In most cases, the regulations for such standards provide
for the installation of mitigation systems for buildings in
cases where rapid remediation of soil  and groundwater is
technically impracticable. The selected mitigation tech-
nology should then achieve the performance standards
set out in the regulations (or policies). Note: such perfor-
mance standards may presume that institutional controls
will be implemented to ensure long-term stewardship of
such sites until remediation is achieved.

In some jurisdictions,  specific numeric standards may
not be available. Typically in these cases, a site-specific
risk-based standard is determined based on an unaccept-
able health risk. A selected mitigation technology should
then achieve a reduction in COC concentration in in-
door air to the required risk-based level.

Obviously, whatever technology is selected must be able
to meet the applicable numerical contaminant standard.
Note that available radon literature supports the premise
that few techniques other than active sub-slab depressur-
ization can achieve two orders of magnitude reduction in
vapor intrusion. Thus alternatives such as sealing should
likely be used only as stand-alone options when a lower
level of reduction is acceptable, such as when no dem-
onstrated risk exists but proactive precautions are being
taken.

Other characteristics of the COC that may be relevant to
selecting a technology include:

 •  Flammability
 •  Toxicity
 •  Corrosiveness/incompatibility with certain materials
    from which the mitigation system may be constructed.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                  27

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4.2  Reliability

Because the reduction goals must be met consistently
over long periods of time, reliability is an important
criterion for selecting vapor intrusion mitigation tech-
nology. While most of these technologies are considered
mature (i.e., they have been used extensively for other
applications such as radon or moisture control), it is
advisable to thoroughly query the vendor or consulting
engineer on this issue.

Of special consideration is operational robustness. The
system should be robust in that the performance of the
system is not  negatively affected by actions of the occu-
pants that arise from use of the building (e.g., opening
or closing of basement doors or windows, crawlspace
vents or routine minor home maintenance). Occupant
activities are important when components of the system
are readily accessible, as with air purification equipment
or with HVAC modifications.
4.3  Effect of the Technology on Other
     Aspects of Indoor Air Quality

Designers must be aware that indoor air quality is a ho-
listic concept that may require more than just minimiza-
tion of the concentration of volatile organics contributed
by vapor intrusion. Appropriate levels of humidity, tem-
perature, carbon dioxide, carbon monoxide, particulates/
dust, mold, allergens and airflow must be maintained.
Other potential sources of volatile organics in the indoor
environment also must be taken into consideration in-
cluding environmental tobacco smoke, cleaning agents,
solvents,  glues and paints.

4.3.1   Moisture Infiltration and Vapor Intrusion—
       A Complex, Critical Relationship

Moisture infiltration into a structure, whether or not the
moisture is contaminated, presents a multifaceted prob-
lem for indoor air quality and thus should be addressed.
When contaminated groundwater is shallow enough
to infiltrate a building, it presents both a contaminant
vapor intrusion and mold risk. Even in those cases where
groundwater does not directly intersect a building and
sub-slab soils may appear dry, infiltration of soil mois-
ture can pose an equally significant mold threat because
soil gas is typically at 100 percent relative humidity
(Springer 1995). There is a symbiotic and sometimes
                          complex relationship between mitigation of moisture
                          problems and mitigation of vapor intrusion:

                           •  Sealing the building envelope and dewatering the
                             sub-slab area would be expected in many cases to re-
                             duce both moisture infiltration and vapor intrusion.
                           •  Gravel beds or sub-slab mats originally installed for
                             moisture control provide permeable layers for air
                             flow and thus aid in the installation of sub-slab ven-
                             tilation systems.
                           •  Water saturation of the full thickness of gravel beds
                             or sub-slab mats can dramatically interfere with air-
                             flow, rendering portions of a sub-slab system ineffec-
                             tive.
                           •  Water can also cause the typical pumps used in sub-
                             slab depressurization systems to work too hard and
                             burn out.
                           •  Drains and sumps may be preferential routes for en-
                             try of contaminant vapors.

                          The intrusion of contaminated groundwater directly
                          into the structure is considered by some to be a separate
                          matter from vapor intrusion (NJDEP, 2005). In many
                          cases, there will be a residual vapor intrusion problem
                          after the contaminated ground water intrusion has been
                          addressed.

                          Moisture problems can be addressed with drainage
                          modifications to the lot, drainage systems along the
                          foundation, or damp proofing of the foundation/base-
                          ment walls. The engineering practice in the area of mois-
                          ture resistance and moisture control is well developed.
                          See, for example, "Construction Dewatering," (Powers,
                          1992), which includes a chapter on water management
                          in contaminated construction sites, as well as discussion
                          of drains, sumps, pumps, etc., for structures. Moisture
                          exclusion technologies in construction are also well
                          documented. See, for example,
                          http://www.toolbase.org/techinv/techDetails.
                          aspx?technologyID=l65). Elimination of human expo-
                          sure to contaminant-affected groundwater is also covered
                          in ASTM (2005), for example, in section 6.2.4 and ap-
                          pendix X3.

                          Practical recommendations on moisture control tech-
                          niques for residential settings are available from a num-
                          ber of resources, including:

                           •  http://www.epa.gov/iaq/homes/hip-moisture.html
28
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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 •  http://www.buildingscience.com/buildingphysics/
    mo isturecontrol/.
 •  FEMA 312 "Homeowners Guide to Retrofitting"
    covers various strategies such as wet floodproofing,
    elevation, building relocation, and dry floodproof-
    ing.  FEMA 312 can be accessed from
    http://www.fema.gov/library/index.jsp.
 •  http://www.extension.iastate.edu/Publications/
    PM156l.pdf
 •  http://server.age.psu.edU/extension/factsheets/d/
    D12.pdf
 •  Blackburn (1991)
 •  Reader's Digest (1977)

Control of moisture attributable to contaminated
groundwater infiltration is likely to reduce but not elimi-
nate the potential for transport of contaminants into
the structure. If the groundwater is lowered by pump-
ing or improved drainage, the usual entry mechanisms
for contaminated soil vapor will still be operative. As a
side benefit, whatever the source of the observed mois-
ture, control to accepted humidity levels will improve air
quality by reducing the potential for mold growth.

Modifications to the HVAC system of the building for
the purpose of mitigating vapor intrusion problems
should be designed with careful attention to avoiding
condensation of water resulting from excessive humidity.
Excess moisture can foster the growth of mold, which
has significant negative impacts on indoor air quality
and potentially the health of building occupants. Added
HVAC capacity must have effective water drainage from
the cooling coils. Conversely, in some climates HVAC
modifications might lead to uncomfortably low levels of
humidity.


4.3.2   Effects of Changes in Air
       Circulation/Air Exchange

If significant sources of VOCs exist within the occupied
portion  of the space due to resident/occupant activities,
increased building ventilation may well be beneficial.
Other mitigation approaches such  as material substitu-
tion, changes in use practices or localized ventilation
may also be necessary in those cases, but are beyond the
scope of this paper.

On the other hand,  changes to  air flow can cause unan-
ticipated moisture problems due to condensation at the
building envelope or due to insufficient ventilation of
interior moisture sources
(http://learningstore.uwex.edu/pdf%5CB3783.pdf;
http://www.uwex.edu/news/2003/10/solving-winter-
home-moisture-problems-by-john-merrill-university-of;
http://extension.oregonstate.edu/catalog/pdf/ec/ecl437.
pdf). See information in section 2.2.3.1 of EPA 1993a
for a discussion of some additional effects of ventilation.

The effects of induced pressure/ventilation changes
should be carefully evaluated in any home with com-
bustion appliances such as heating, clothes drying and/
or cooking systems. These systems usually draw their
combustion air from the indoor airspace. Thus, it is es-
sential that depressurization systems for mitigation of
indoor air not cause backdrafting (induced spillage of
combustion gases) of combustion devices in the struc-
ture (NYSDOH, 2005). Backdrafting can release deadly
combustion byproducts into the structure. The various
available backdrafting tests generally involve setting ap-
pliances, HVAC systems, etc., for the worst case negative
pressurization anticipated for the building. Then a car-
bon monoxide or flow visualization test is performed for
backdrafting at each stack for a combustion device in the
home. Detailed recommendations on these issues includ-
ing testing procedures are provided in section 11.5 of
EPA 1993b and in ASTM E1998 "Guide for Assessing
Backdrafting  and Spillage from Vented Combustion Ap-
pliances." For more information on the general issue see
http://www.epa.gov/iaq/homes/hip-combustion.html.


4.3.3   Effects of Engineered Systems
       on Ambient Air Quality

The broader impact of VI systems that could increase
the concentration of VOCs in the community's ambi-
ent air (for example, active or passive sub-slab ventila-
tion) should be considered.  Consideration of this issue is
especially important where pollutants are acutely toxic,
local meteorology does  not facilitate dispersion, vented
concentrations are unusually high, multiple systems
are being installed in a densely populated area or other
factors limit the allowable stack height. Good engi-
neering practice requires outlets from a venting system
(pipe ends) not be close to a window or allow for the
vapors to re-enter the building (ASTM E 2121, ASTM
E 1465-92). In some cases mass loading calculations or
dispersion modeling may be appropriate to analyze the
potential impact of reentrainment.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                 29

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This issue is not unique to vapor intrusion mitigation
systems. Similar issues have been analyzed for years for
remediation technologies such as soil vapor extraction
or air sparging. However, the systems for vapor intru-
sion mitigation are more likely to be located in residen-
tial areas. EPA's Air Toxics Regulations [which are also
known as national emission standards for hazardous air
pollutants (NESHAPs) or maximum achievable control
technology (MACT) standards]  should be consulted.
Under the site Remediation MACT, a facility is required
to review a series of exemptions and, if none of them ap-
plies, then the MACT limits apply. New, reconstructed,
and existing remediation systems must meet the follow-
ing criteria for the MACT to apply:

 •  The site remediation activity is collocated at a facility
    that has other sources that are individually or col-
    lectively a major source of hazardous air pollutants
    (HAPs)
 •  A MACT activity, which is an  activity in a source
    category given by Section 112(c) of the Clean Air
    Act, is performed at the facility

The rule excludes remedial activities at gas stations for
the purposes of cleaning up remediation material from a
leaking underground storage tank, or that are located at
farm sites and residential sites. Remedial activities occur-
ring under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) program
(Superfund) and as corrective action under the Resource
Conservation and Recovery Act  (RCRA) to clean up
hazardous substances, hazardous wastes, and hazardous
contaminants are also excluded.  If the MACT limits
apply, then the limits can be met via control devices or
other means. As a broad rule of thumb, if the MACT
applies and emissions of an individual hazardous air pol-
lutant are above 3.0 Ib/hr and 3.1 tons per year (TPY),
you must reduce emissions via controls or work prac-
tices. In many cases the air emissions from these systems
are found to be below regulatory limits, but in other in-
stances emission control devices  may be required.  Gen-
erally, systems are screened against these Clean Air Act
Amendment regulatory requirements, initially using a
conservative approach of multiplying the worst-case soil
gas concentration by the operating flow of the system to
derive an emission in mass per unit time. More informa-
tion about this topic can be found in:

 •  Air Emissions from the Treatment of Soils Contami-
    nated with Petroleum Fuels and Other Substances
    EPA/600/SR-97/116 November 1997
                             http://www.p2pays.org/ref/07/06430.pdf. Also pre-
                             vious full text version is EPA-600/R-92-124, July
                             1992.
                             In the National Emission Standards for Hazardous
                             Air Pollutants for Site Remediation
                             http://www.epa.gov/ttn/atw/siterm/fr08oc03.pdf
                          4.4 Structural and Occupancy Aspects
                              for New and Existing Buildings
                          Relevant characteristics of building types for VI mitiga-
                          tion include:
                           •  Size
                           •  Air exchange rate (AER)/methods
                           •  Types of construction
                           •  Economic and effective life span of the building
                           •  Daily and/or seasonal occupation patterns
                           •  Other sources of related indoor air pollutants
                           •  Exhaust Ventilation, and
                           •  Current and reasonably anticipated future use.
                          Results of a detailed  building survey covering these
                          factors must be considered in design. Input should be
                          solicited from all interested stakeholders (including ten-
                          ants) and feedback received should be incorporated into
                          the design process. For instance, mitigation has a direct
                          impact on residential homeowners and they are accord-
                          ingly concerned about numerous issues such as potential
                          diminution of real estate value, aesthetics and health
                          risk. On-site design activities, installation, operation and
                          maintenance will need to accommodate homeowners
                          individual schedules and needs.
                          Designers of vapor intrusion mitigation systems should
                          consider all forms of ventilation of the structure—those
                          provided by heating  and cooling systems, operational
                          practices such as window and door opening, and ex-
                          haust ventilation. Design of a new structure provides
                          an opportunity to integrate mitigation of vapor intru-
                          sion into the selection of heating and cooling systems,
                          which are normally driven based on energy economics,
                          aesthetics/preference and custom.  For example, a system
                          design that avoids creating negative pressures inside the
                          structure and/or maintains positive pressure inside the
                          structure should be preferred and is required in some
                          jurisdictions.
                          Vapor intrusion mitigation of existing buildings is most
                          common, but installation of mitigation systems and
30
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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barriers is easiest and cheapest during new construc-
tion. Both situations are encountered in practice. Older
structures are less likely to have adequate vapor barriers
incorporated into the foundation construction and the
foundation itself is more likely to have developed cracks
(NHDES, 2006).

4.4.1   New Buildings

Siting of new construction can be one of the most pow-
erful means to control vapor intrusion potential in reuse
and revitalization (e.g., brownfields). For example, con-
taminated areas most likely to produce vapor intrusion
in a reuse scenario may be set aside for green space. If
land adjacent to an affected building is covered, such as
parking lots, the resultant direction of migration of the
vapors should be considered so as to not impact adjacent
structures. In construction of slabs for new buildings, a
monolithic pour is preferred to a slab floating on a foun-
dation, because it eliminates the expansion joint, that
can often be an entry pathway. Site-specific factors that
should be evaluated when selecting a remedy for existing
structures include the depth and seasonal variability of
the water table, the vadose zone soil type and permeabil-
ity and frost depth (EPA, 1993a).

One frequently-recommended remedy for new build-
ings involves the installation of a passive sub-slab VOC
collection and vent piping  (that can be converted to an
active system later if necessary), and a membrane system
underneath the foundation. Alternately, new buildings
may be designed to include a highly ventilated, low-
occupancy area underneath, such as a parking garage. All
considerations for the existing structure retrofit remedies
described above are applicable for installation of mem-
brane and passive venting in new construction with the
following changes: If an appropriately permeable engi-
neered layer of material (e.g., gravel or drainage mat) is
used beneath the slab, evaluation of native soil character-
istics may be less critical or unnecessary.
According to California's guidance, gas barrier/mem-
brane systems in new construction should meet the fol-
lowing requirements:

 • Gas resistant membranes should be constructed of
   appropriate materials and thicknesses for the situa-
   tion and contaminant of interest.
 • Gas resistant membranes should be placed a maxi-
   mum of one foot below the foundation slab and a
    maximum of six inches above the gas collection pip-
    ing.
 •  Protective layers consisting of at least two inches or
    more of sand and/or geotextile (six ounces per square
    yard at a minimum) should be laid below and above
    the membrane. The term "geotextile" refers here to a
    woven or nonwoven fabric used in civil engineering,
    usually synthetic.
 •  Without an engineering evaluation and confirma-
    tion data  to support the beneath footing passage,
    the membrane should not pass below footings and/
    or stiffener beams of slabs due to seismic concerns.
    Membranes should be  sealed carefully where they en-
    counter footings or stiffener beams.
 •  Gas tight seals (e.g., boots) should be provided at all
    pipe or conduit penetrations through the membrane
    and where the membrane attaches to interior and
    perimeter footings.
 •  A leak test of the membrane system (such as a smoke
    test) should be conducted to ensure no leaks ex-
    ist. Where leaks are identified, appropriate repairs
    should be undertaken and smoke testing should be
    repeated until no leaks are detected. (DTSC, 2004)
In some situations, newly constructed buildings will
require active subsurface venting to alleviate vapor intru-
sion. An air permit from the local regulatory authority is
sometimes required for an  active venting system. Addi-
tional design  considerations for an actively vented build-
ing include:
 •  Active injection of air under a building to enhance
    venting is not recommended without an engineer-
    ing design. The air injection system may force vapors
    into a building by creating elevated subsurface pres-
    sures or force vapors into unprotected neighboring
    structures. Permitting requirements may apply to
    these systems in some jurisdictions.
 •  For sites where subsurface concentrations are above
    the lower explosive  limit (LEL) of any contaminant/
    vapor the site should be carefully evaluated. A deep
    well pressure relief system or other improvements,
    which reduce or eliminate subsurface gas levels and
    pressures, should be considered in addition to the
    building protection system (DTSC, 2004).

A more detailed discussion of approaches that can be
used in new construction is presented in EPA (1993a),
pages 2-38 to 2-45.
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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Many provisions of model building codes that are in-
tended to ensure drainage or provide waterproofing may
also offer some benefit in vapor intrusion mitigation
when properly applied. The selections below are from
the international building code (IBC) while the interna-
tional residential code (IRC) is similar, see http://www.
iccsafe.org/ for full text.
IBC §  1806.1: Damp-proofing and Waterproofing/
Where Required. Walls that retain earth and enclose
interior spaces and floors below grade must be water-
proofed or damp-proofed. (Damp-proofing is the appli-
cation of coatings or other materials in order to prevent
the passage of water under slight hydrostatic pressure;
waterproofing is required to prevent the passage of water
or water vapor under significant pressure.)
IBC §  1806.2.1: Damp-proofing Required/Floors.
Damp-proofing materials must be installed between the
floor and the base course (gravel), unless a separate floor
is installed above the concrete slab, in which case the
damp proofing can be applied above the concrete slab.
Where applied below the slab, damp proofing should
consist of 6-mil polyethylene or other approved material;
above the slab, 4-mil polyethylene is acceptable. (This
prevents moisture from entering belowground spaces.
Rigid insulation would be preferable.)

IBC §  1806.3.3: Waterproofing Required/Joints and
Penetrations. Joints in walls and floors, joints between
the wall and floor, and penetrations of the wall and floor
must be made watertight (to ensure the effectiveness
of waterproofing, and prevent water from entering the
building or becoming trapped in  the foundation  walls or
floor slab).
IBC §  1806.4.1: Floor Base Course. Floors of base-
ments must be placed over a floor base course at least 4
inches thick consisting of gravel or crushed stone. (The
gravel or  stone provides a capillary break so that mois-
ture from the soil below  will not rise to the underside of
the floor. It can also act as a drainage system for water
under the slab.)

IBC §  1911.1: Minimum Slab Provisions/General.
Floor slabs placed directly on the ground must be at least
3V2 inches thick. A polyethylene vapor retarder or other
approved material must be placed between the base
course or sub grade and the concrete floor slab.
                          4.4.2   Existing Buildings

                          The existing structure and foundation type usually
                          dictate the type of mitigation system needed. For each
                          different foundation and structure type, attention should
                          be paid to the likely entry pathways of vapor intrusion
                          and how the pathways may indicate certain remedies as
                          discussed in section 3.  Qualitative discussion of the ef-
                          fect of foundation type on vapor intrusion potential is
                          found in ASTM (2005) section X2.3.2.2(d). In many
                          cases existing foundation features can be modified cost
                          effectively to provide vapor intrusion mitigation.  For
                          example, perimeter drainage systems can be adapted in
                          some cases to provide depressurization or ventilation
                          under the slab. A crawlspace may be isolated from the
                          living space by sealing and ventilated to reduce con-
                          centrations in the crawlspace. Foundation wall cavities
                          may also be ventilated to reduce vapor intrusion (EPA,
                          1993a).
                          4.4.2.1  Basements and Slabs on Grade

                          About 43 percent of U.S. single unit houses (that are
                          not mobile homes) have at least partial basements and
                          30 percent are on slabs (HUD, 2006). In these struc-
                          tures the composition of the sub-slab region should be
                          determined during a survey before system design. The
                          presence, composition, or absence of sub-slab aggregate/
                          drainage layers, the presence or absence of moisture
                          barriers, and the porosity of fill materials  can strongly
                          influence the potential for success of sub-slab depressur-
                          ization systems (EPA, 1993a).
                          Basements generally have more surface area in contact
                          with the soil providing more intimate  interaction and
                          consequently more opportunities for entry pathways.
                          Any cracks in the slab or openings around utility pen-
                          etrations offer potential pathways. Also, the expansion
                          joint between the slab and the foundation or basement
                          wall is a major potential entry route. Contaminated soil
                          gas can also migrate into the cores of a block wall to
                          enter either through openings at the top of the wall or
                          through the pores in the blocks. In some  cases, depres-
                          surization systems may be required in the block cores, as
                          well as under the slab.
                          For a slab-on-grade building, entry routes through the
                          slab are similar to those of basement slabs, except that
                          construction details of the contact between the slab and
                          foundation may be different.  Some slabs are floating on
                          top of a foundation, leaving an expansion joint between
32
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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the slab and wall. Other slabs are poured continuously
over top of the entire foundation wall and thus do not
need an expansion joint. In conjunction with the sealing
of potential subsurface vapor entry points, an active SSD
system can effectively be used in buildings with a base-
ment slab or slab-on-grade foundation.

Earthen floors and field stone foundations are more
porous and provide increased opportunity for vapor
intrusion. (NHDES, 2006) For buildings with dirt floor
basements, either an SSD system with a newly poured
slab or a sub-membrane depressurization system with a
soil vapor barrier may be used. Traffic on the membrane
and use of the area would need to be limited in an SMD
application. The SSD method is preferred in the NY
guidance (NYSDOH, 2005). SSD allows more effective
use of the space but would be more expensive to con-
struct.

4.4.2.2 Masonry Foundation/Crawlspace

About 26 percent of U.S. single unit housing (excluding
mobile homes) has a crawlspace (HUD 2006). Venti-
lation of crawlspaces is effective primarily when only
modest VI reductions are required. In cold climates ven-
tilation frequently results  in freezing the plumbing lines.
For crawlspaces with concrete slabs, SSD systems work
well. SMD systems also work well in the event of no
slab. If the air handler and the return ducts of the heat-
ing and cooling (HAC) system are located in the  crawl-
space, crawlspace contaminants may be transported into
the living space through the supply ducts. The ducts are
prone to leak and the return side of the system has very
large negative pressures, which can draw crawlspace air
with contaminants into the ducts and pump them to the
living space through the supply ducts.

New York State's guidance calls for sub-membrane de-
pressurization to be used in enclosed crawlspaces  (NYS-
DOH, 2005). This is consistent with Henschel's  (1992)
review of methods for radon mitigation specific to
crawlspaces. EPA (1993b) section 8 has extensive infor-
mation on sub-membrane depressurization applications
to crawlspaces. Additional information can be found in
ASTM's "Specification for Plastic Water Vapor Retarders
Used in Contact with Soil or Granular Fill under Con-
crete Slabs" (ASTM, 1993).
Conditioned  crawlspace with concrete slabs have been
recently recommended for energy and moisture reasons
(Lstiburek 2004), but these systems may be problematic
where vapor intrusion occurs because they encourage air
movement from the crawlspace into the occupied por-
tion of the structure. They also rely on passive sealing
to prevent soil gas entry into the crawlspace. An SSD
system would be a recommended addition when VI is
suspected and a conditioned crawlspace is selected.


4.4.2.3 Mobile Homes

Relatively little testing of mobile homes for vapor in-
trusion and few mitigation actions for them have been
published. However, since mobile homes constitute eight
percent of the of the U.S. housing stock and 15 percent
of new housing constructed they must be considered
(HUD, 2002). Mobile homes without skirts (and thus
with good circulation of ambient air under the floor)
should have  a lower risk of vapor intrusion than struc-
tures in which the floor is in direct contact with the
ground. Provisionally, it is reasonable to treat mobile
homes with well-sealed skirts as being similar to crawl-
space structures. In mobile homes it is always prudent to
understand where heating and HVAC intake and returns
are located. Anthropogenically induced or exacerbated
vapor intrusion problems may exist if intakes or returns
are located in the skirts of mobile homes. The same ap-
plies for crawlspaces. Some mobile homes are placed on
concrete slabs. In these cases mitigation strategies used in
frame structures placed on slabs are probably appropri-
ate. An extensive discussion of mobile home vapor intru-
sion is presented on pages C2 and C3 of ITRC 2007.


4.5 Cost Factors

When there  are two or more feasible technologies for
mitigation of vapor intrusion, cost will  obviously influ-
ence the selection. When the vapor intrusion is occur-
ring in multiple structures, the costs will rise, although
economies of scale may allay the additional expenses. A
quantitative  analysis of the costs associated with acquir-
ing, installing, monitoring, operating, and maintain-
ing different vapor intrusion technologies is highly site
specific and will not be attempted in this paper. Some
cost analysis information for vapor intrusion mitigation
options has been presented in Welt and Thatcher (2007)
and reprinted as part of Table 1 of this document. Costs
for various types of active soil depressurization systems
as applied for radon reduction were published by Hen-
schel (1991). Unit costs for many elements that may go
into mitigation systems are systematically surveyed and
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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cataloged in the RS Means manuals, along with adjust-
ment factors for costs in various locations. These costs
are updated annually, however it is important to note
that the costs are based on large commercial, industrial,
multi-family housing projects and may need to be ad-
justed when applied to small projects. The user should
also refer to the general instructions on estimating costs
provided in the introduction to each volume and chapter
of these manuals (www.rsmeans.com). The manuals pro-
vide detailed information for individual unit price items
as well as summarized information for typical assemblies.
For example:

 • The RS Means manual on "Building Construction
   Data" includes detailed data for such topics as vari-
   ous types of foundations, sub-slab drainage systems,
   waterproofing membranes, joint sealers and caulks.
 • The RS Means manual on mechanical cost data cov-
   ers drainage,  dewatering, foundations, joint sealers,
   caulking,  flashings, chimneys/stacks, HVAC sys-
   tems, energy recovery equipment, ducts, ventilators,
   air-cleaning devices etc. Costs for assemblies such as
   ventilation systems are also  provided.

When estimating costs for vapor intrusion mitigation
one should be aware that many solutions to vapor intru-
sion also have multiple benefits. For example, dewater-
ing/drainage systems that may already be planned may
be adaptable for vapor intrusion. Sealing may provide
energy cost savings as well as vapor intrusion mitigation.

In many cases, active and passive systems are similar in
capital cost, but active systems usually have higher oper-
ating, maintenance and energy  costs. Mitigation tech-
nologies are likely to affect energy consumption in the
building. Certain components of the technologies such
as fans for active  depressurization systems or air clean-
ers, are energy users themselves, but they are also likely
to have an effect  on the energy economy of the build-
ing. Typical active residential systems have a operating
and energy cost impact on the order of $300/year. Other
technologies such as sealing or the installation of mem-
branes are likely to provide modest energy cost benefit.
Extensive cost analysis is reported for various radon
mitigation systems in Henschel 1991 and EPA 1993b
chapter 13. A source for extensive further information is
http://www.energysavers.gov/ which includes sections
tailored for the specific needs of homeowners, contrac-
tors and builders, and building managers. Numerous
software tools used to evaluate energy efficiency and eco-
nomics are reviewed and cataloged at
                         http://www.eere.energy.gov/buildings/tools directory/,
                         including those specific to indoor air quality and ventila-
                         tion/airflow.
                         4.6  Risk Communication and Stakeholder
                              Involvement Considerations
                         Because vapor intrusion mitigation systems directly ad-
                         dress an ongoing or potential human exposure, clear and
                         timely risk communication with stakeholders is vital.
                         The general topic of risk communication and stakehold-
                         er involvement is too extensive to be addressed in this
                         engineering issue paper. Good information can be found
                         at:
                          •  http: //www. epa. gov/o swer/riskassessment/risk
                             communication.htm;
                          •  http://www.epa.gov/superfund/community/
                             pdfs/37riskcom.pdf
                          •  http://www.epa.gov/superfund/community/cag/
                             pdfs/ci handbook.pdf
                          •  State documents such as: Chapter 11 of the NJDEP
                             Vapor Intrusion Guidance Document (NJDEP,
                             2005) and section 5 of the Draft NY Guidance (NY-
                             DOH 2005)
                         A few specific stakeholder communication recommen-
                         dations for vapor intrusion mitigation projects can be
                         made:
                          •  Mitigators should remember that a "person's home is
                             his/her castle." Most people have a strong emotional
                             attachment to their home and neighborhood, so any
                             concern or need expressed by a homeowner should
                             be treated with sincerity and understanding
                          •  Environmental workers should provide stakeholders
                             with an understanding of the problem at the onset.
                             A written letter or notice that describes both the
                             problem and the steps that could or will be taken to
                             address the problem can make face-to-face negotia-
                             tion with homeowners easier. Project staff should
                             then schedule a time to meet with the stakeholder to
                             discuss how you intend to assess and solve the prob-
                             lem. Note: it is always best to not downplay any re-
                             quirements imposed on the stakeholder /homeowner
                             in advance, because any subsequent modifications
                             that require less of the homeowner's time or use of
                             the home or building will usually be interpreted in
                             favor of mitigation. However, any additional burden
                             not conveyed initially could likely be interpreted
34
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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    with a degree of suspicion, as a failure to understand
    the problem and its solution. In short, the hom-
    eowner's faith in the mitigation contractor's expertise
    is important for accomplishing the job correctly and
    on time.
 •  Stakeholders will likely be interested not only in risk
    reduction, but also in the maintenance of property
    resale value, aesthetics, system noise, system main-
    tainability and energy cost impacts. Environmental
    professionals should be prepared to address these
    issues when meeting with homeowners,  tenants or
    building owners.

 •  When making technology selections, environmental
    professionals should consider how intuitively un-
    derstandable the technology will be to a resident or
    occupant without  a background in environmental
    science. For example, the concepts of membrane bar-
    riers and sealing should be readily understandable.
    HVAC modifications or  sub-slab  ventilation systems
    may require more  careful explanation.
 •  Environmental workers should provide written
    materials explaining system operation and mainte-
    nance issues, which can be used for ongoing refer-
    ence and even conveyed from one owner/tenant to
    future tenants/owners.  If a given system will result in
    an increase in cost (e.g., electricity), be prepared to
    provide justification and  an estimate for the cost.

Further recommendations in this area are found in
Appendix A of ITRC 2007.


5     VERIFICATION OF
      MITIGATION PERFORMANCE

After a technology is selected, designed and  installed,
its performance must be verified before and  during long
term operation (see Figure  3  for a graphical  portrayal  of
the process).


5.1   Defining the Performance Objective

As was discussed in the previous section, prior to install-
ing a mitigation system, the project team must formulate
a clear overview of the problem to be solved. The  team
must know why the mitigation project will be done—
and have common pertinent background information
for decision making. As in  any environmental project, a
quality assurance project plan (QAPP) process, includ-
ing the development of data  quality objectives (DQO),
 1. STATE THE PROBLEM THAT REQUIRES MEASUREMENTS
Summarize the potential vapor intrusion situation that requires mitigation,
describe the need for measurements (i.e., to verify that the mitigation system
is performing adequately) and describe the conceptual site model. Define any
constraints on available personnel, time, building access or funds that limit the
measurements that can be made.
          2. IDENTIFY THE DECISION TO BE MADE
Determine the principal study question (i.e., is the subslab depressurization re-
ducing the concentration in the indoor air below risk based objectives). Define
the alternate actions that could arise from the measurements taken. For ex-
ample altering the operation or design of the mitigation system or determining
that it is ready for routine operation. The principal study question and potential
alternative actions are combined into a "decision statement"
           3. IDENTIFY INPUTS TO THE DECISION
Identify the regulatory and risk inputs that go into establishing an action
level that will define adequate performance of the mitigation system. Identify
relevant information sources such as regulations, engineering standards and
previous site characterization data. Determine that the available sampling and
analytical methods are adequate to determine compliance with the action lev-
el. By evaluating the available sampling and analysis methods the team can,
if necessary consider alternate approaches, such as measuring surrogates,
indicator variables, or adjustment of action levels to detection limits.
            4. DEFINE THE STUDY BOUNDARIES
In this step the spatial and temporal boundaries of the decision to be made
are defined. For example, the occupied areas of a particular building may
be determined to be the spatial boundaries. A temporal boundary could be
adequate performance in both heating and cooling season for the anticipated
occupied life of the building. Another example of a temporal boundary may be
an assumption of a given period of occupancy for a structure.
               5. DEVELOP A DECISION RULE
Develop a logical "if...then..." statement that defines the conditions that would
cause the remediation engineer or site manager to choose among alterna-
tive actions. In this step the team specifies the statistical parameter to be
used (such as a mean, difference between two means, median, proportion, or
maximum) that specifies the characteristic or attribute that the decision maker
would like to know. For example, for a vapor intrusion mitigation system this
characteristic might be a concentration of a given contaminant averaged over
a given exposure period or a ratio of indoor to sub-slab concentration of a
tracer. In this step an action level is defined based on risk or regulatory criteria
and the project team confirms that the sampling and analysis methodology
planned is adequately sensitive to reach that limit.
   6. SPECIFY ACCEPTABLE LIMITS ON DECISION ERRORS
Determine the possible range in the value of the parameter of interest. For
example, how high or low can the indoor air or sub-slab concentration be rea-
sonable expected to be. Specify the tolerable limits on measurement error and
use them to establish performance  goals for limiting uncertainty in the data.
For example, the acceptable probability of a given degree of error in the mea-
surement of the air concentration. Identify the consequences of false negative
and false positive measurements.
        7. OPTIMIZE THE PLAN FOR OBTAINING DATA
To identify a resource-effective sampling and analysis design for generating
data that are expected to satisfy the data quality objectives. For example, the
type of indoor air sampling (random, systematic etc.), the number of sampling
rounds and number of samples per room per round would be specified.
                                                               Figure 8. Data quality objective process. (Modified from EPA, 2000)
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                        35

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should be used to clearly define project objectives both
qualitatively and quantitatively. For cost efficiency, these
QAPPs are usually developed and applied on a site-wide
basis. The development and documentation of clear
objectives ensures that all involved understand and agree
on the underlying purpose of the project. The develop-
ment of clear objectives increases the likelihood that the
system design will address and accomplish that purpose
and that the measurements taken will be able to verify
that the purpose has been achieved (EPA, 2002b).

EPA recommends a formal seven step DQO process
(EPA, 2000) illustrated in Figure 8 whenever environ-
mental data are being gathered for decision making
http://www.epa.gov/quality/qa docs.html. In the case
of an engineered mitigation system the problem (step 1)
is to  control the vapor intrusion exposure pathway or to
remove the source of the vapors. The decision (step 2)
might typically be to determine whether the mitigation
system was operating as designed and/or was sufficiently
protective to yield an indoor environment that does not
lead to unacceptable exposures. Many of the inputs (step
3), boundaries (step 4) and decision rules (step 5) will
flow easily from information developed during the initial
investigation and risk assessment of the vapor intrusion
issue (see section 2.1 and EPA, 2002a). The primary
decision rule (step 5) would focus on whether the indoor
air concentration had been reduced below a risk based
standard with a given certainty and a given system reli-
ability (percent time in operation). Secondary decision
rules might be established based on engineering param-
eters of the system, such as maintenance of a given nega-
tive pressure in a sub-slab ventilation system, continuous
operation and/or a specified flow rate, etc.

According to EPA (2000), "Setting tolerable limits on
decision errors (step 6) is neither obvious nor easy. It
requires the planning team to weigh the relative effects
of threat to human health and the  environment, expen-
diture of resources, and consequences of an incorrect
decision, as well as the less tangible effects of credibility,
sociopolitical cost, and feasibility of outcome. In the
initial phases of the DQO development, these prob-
abilities need only be approximated to explore options in
sampling design and resource allocation." For example
it would be necessary to define the acceptable probabil-
ity of deciding on the basis of measurements that the
mitigation system was operating correctly (and in a pro-
tective manner) when in fact it was not and some unac-
ceptable level of exposure/risk or hazard remained.
                          In defining your statistical basis for decision (step 5) and
                          limits on acceptable error (step 6) several important fac-
                          tors should be acknowledged:

                           • The risks posed by a given vapor intrusion situa-
                             tion should be classified as either potentially acute
                             or chronic. An example  of an acute hazard is expo-
                             sure to a toxic VOC at levels that exceed 'Immedi-
                             ately Dangerous to Life  and Health' (IDLH) levels
                             set by National Institute for Occupational Safety
                             and  Health (NIOSH) for industrial settings or the
                             acute minimal risk level (MRL) set by the Agency for
                             Toxic Substances and Disease Registry (ATSDR) in
                             residential or educational settings. These values can
                             be found at
                             http://www.cdc.gov/niosh/idlh/intridl4.html and
                             http://www.atsdr.cdc.gov/mrls/index.html. Chronic
                             risks arise from long-term exposure to lower concen-
                             trations of toxic chemicals. Another example of an
                             acute hazard would be the presence of methane at a
                             concentration approaching its lower explosive limit
                             (LEL). The necessary system reliability (and thus en-
                             gineering redundancy) for a vapor intrusion problem
                             posing an acute risk would be much higher than for
                             an exposure posing  only a chronic risk. Remedies for
                             acute risks also  must be  implemented more quickly.
                             Because acute risk levels are often far above chronic
                             levels, situations with concentrations exceeding an
                             acute level will likely require a highly effective tech-
                             nology be selected to achieve several orders of mag-
                             nitude reduction. The issue of exposure duration is
                             thoroughly discussed in the Indiana draft guidance
                             [Indiana Department of Environmental Manage-
                             ment (IDEM, 2006)].
                           • The expected length of system operation, frequency
                             of monitoring and number of building occupants in-
                             fluences the development of a decision rule and the
                             tolerable decision error for a chronic risk.
                           • Ambient air concentrations in urban areas, as well as
                             typical indoor air concentrations, frequently exceed
                             conservative screening values used in many vapor
                             intrusion evaluations. Most vapor intrusion mitiga-
                             tion systems will not provide air quality better than
                             ambient air outside the home.

                          Although these  issues are critical, the remainder of the
                          section 5 of the engineering issue paper will address in
                          detail step 7: methods used for obtaining data about
                          whether the mitigation  system is functioning effectively.
36
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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5.2  Defining the Performance Baseline

The primary performance metric for a vapor intrusion
mitigation system is the achievement of acceptable levels
of contaminants in indoor air. Additionally, engineers
may wish to determine percent reduction in measured
contaminant(s) concentrations in indoor air resulting
from the engineered system or barrier. Secondary indica-
tors of performance may include engineering parameters
such as pressure differentials and AER,

Several factors influence the premitigation performance
baseline to which system performance is compared, and
thus should be held constant to the extent possible in
system performance measurements:
 •  Vapor intrusion is expected to be seasonally and
    temporally variable (influenced by weather) at most
    sites. Therefore, multiple measurements over several
    seasons or sets of meteorological conditions may
    be needed to accurately define the baseline. On the
    other hand, it may not be acceptable from a risk per-
    spective to delay installation of a mitigation system
    for many  months in order to obtain multiple base-
    line  measurements. This is one reason why systems
    and/or barriers should be designed conservatively.
 •  Vapor intrusion measurements can be easily compli-
    cated by the presence of sources of the same pollut-
    ants within the structure  (this is often referred to as
    vapor intrusion "background"). These sources can
    include, for example, consumer products and hobby
    materials, process emissions in an industrial setting
    and  emissions from both cooking and vehicles in
    many types of structures. If these conditions change
    independently of the VI source it may complicate
    interpretation of indoor air concentration measure-
    ments before and after mitigation. Sub-slab soil gas
    measurement can help determine whether vapor
    intrusion  makes a significant contribution to indoor
    levels of contaminants especially in the cases where
    one  contribution is dominant over the other. In
    many cases an independent tracer for sub-slab soil
    gas can be a useful tool for distinguishing vapor in-
    trusion.
 •  AER and  pressures in a structure can be significantly
    altered by such simple everyday actions  as turning on
    or off an HVAC system or opening a window. Pres-
    sure differences across the building shell can in turn
    be affected by changes in wind load, temperature
    and exterior barometric pressure.
 •  Exposure to pollutants stemming from vapor intru-
    sion depends on the location within the structure.
    For example exposures may differ by factors of two
    or three depending on floor or proximity to venti-
    lation sources. Variability is likely to be higher in
    structures without HVAC systems.

A detailed discussion of meteorological factors, sample
locations, etc., is provided in:
 •  Chapters 4 and 5 of The Commonwealth of Massa-
    chusetts, Indoor Air Sampling and Evaluation Guide
    (MADEP 2002)
 •  Chapter 2  of the NY State draft guidance (NYDOH
    2005)
    http://www.health.state.ny.us/nysdoh/gas/svi guidance/
    docs/svi  main.pdf
However, to ensure that a system is protective for chron-
ic exposure, measurement conditions must either:
 •  Represent the worst case indoor air concentration
    (conservative) or
 •  Be taken at multiple times sufficient to adequately
    describe the variation  in the indoor air concentration
    and thus estimate the  long term average exposure (30
    or 70 year  exposure periods are used for most risk as-
    sessment calculations).

5.3  Methods of Measuring Indoor Contaminants

Sampling the indoor air for  COC is the most direct way
to determine if exposure has been addressed at a site
where vapor intrusion is suspected. Measurements of
indoor air quality along with ambient and/or sub-slab
soil gas sampling could also  be used to more directly as-
sess the performance of the mitigation system. Keep in
mind that evaluation of VI risk reductions from indoor
air will often be complicated by the presence and varia-
tions in background COC from both outdoor (ambient)
and indoor sources.  In addition, spatial and temporal
distributions of contaminants in indoor air can depend,
to a large extent, on the locations of the indoor sources,
and the nature of their uses. For instance, the frequency
of opening and closing containers of cleaners, solvents,
paints and adhesives is a source of variation. Thus the
interpretation  of VI  is complex when multiple significant
sources (e.g., VI, indoor and ambient) are present. The
subjects of representative indoor air sampling and back-
ground sources have thus  been discussed widely in nearly
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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every vapor intrusion investigation document (both state
and federal) and other literature.
In addition to vapor intrusion, indoor sources can
contribute to degradation of indoor air quality. Thus,
mitigation-related sampling programs should include
updates to indoor air quality surveys (including chemi-
cal inventories) if any changes have occurred since the
characterization phase. Concurrent sampling of ambient
air, indoor air, and sub-slab vapors is preferable, both for
quality control and for comparisons to determine if con-
taminants are likely to be attributable to vapor intrusion
rather than ambient or indoor sources.
5.3.1   Indoor Air Sampling for Contaminants

In buildings, COC may not be distributed uniformly
in space and time. Thus, the sampling plan must care-
fully consider the locations, number and frequency of
samples. Sample placement (usually breathing zone) and
duration (usually 24 hours, but depends on facility use)
are frequently selected to meet risk-assessment-related
requirements. Durations of 24 hours are typically used
to average over the diurnal cycle. Ideally a period that is
a large multiple of 24 hours would be used to allow for
variations to occur on longer than a diurnal cycle. The
air within relatively open zones (such as auditoriums, re-
ception areas, and living spaces of residential buildings)
that have nearly uniform temperatures can be reason-
ably expected to have contaminants well mixed within
the zone. Measured variations within such zones are
often comparable to the observed variations of duplicate
measurements. Short term spatial variations are usually
small compared to temporal variations on daily and sea-
sonal scales. Strong drafts, strong temperature gradients,
or flow restrictions may be sufficient cause to question
whether the zone is well mixed. When a complex  build-
ing is being evaluated, it is typical to represent it by a
conceptual model consisting of a group of interacting
zones. It is often necessary to treat different floors of a
building as separate zones. It is also common practice to
consider parts of a building with separate air handler sys-
tems as independent zones. Special attention should be
applied to QA/QC considerations (especially sampling
and analysis) in the very low concentration environment
of the indoors (EPA, 2002).
The strategy for designing an indoor-air sampling pro-
gram depends very much on the  intended use  of the
results. An evaluation of health risks needs long-term
estimates of concentrations that can be applied to an ex-
posure scenario. For this purpose the building should be
operated in its normal manner.
Diagnostic measurements for studying a particular entry
mechanism or for evaluating the effect of a mitigation
system on a particular entry mechanism may require dif-
ferent building operation protocols. Most measurements
used for diagnostic purposes impose constraints on the
building that contribute to those purposes. Frequently,
investigations will attempt to minimize the short term
variation in indoor concentrations in order to obtain
more reproducible results. Often these procedures in-
volve maintaining the building in a closed condition
(windows  and doors closed), which usually tends to
maximize  the indoor concentrations. Some would argue
this yields a conservative value of concentration for risk
estimates,  which may be the case if the measurements
are performed during the season of highest indoor con-
centration. Using a consistent set of constraints on the
building has the advantage that data sets can be more
readily compared from season to season and from one
study to another.
Detailed advice for planning and implementing an in-
door air sampling program is given in  a number of docu-
ments, including MADEP, 2002 and DTSC, 2005. In
most cases, the HVAC system should be operated for at
least 24 hours before confirmation sampling to maintain
a normal indoor temperature. Windows should be closed
while such samples are collected.

The most  commonly used sampling methods are EPA
Methods TO-14A and 15, which require use of a stain-
less steel canister andTO-17, which uses sorbent tubes.
New Jersey and Massachusetts guidance (NJDEP, 2005
and MADEP 2002) provides a comprehensive discussion
of the use  and QA/QC requirements for each method.

ASTM (2005) recommends an initial  sampling round(s)
for COC shortly after start-up of the mitigation system;
then, when sufficient reductions have been demonstrat-
ed, reducing the monitoring frequency to "every couple
of years." They also recommend including winter sam-
pling in the long term monitoring program.

5.3.2   Measurements of AER and Soil Gas Entry Rate

The air exchange rate (AER) can be measured using
either tracer gases (ASTM Method E741) or by the
blower door method (ASTM methods E779  or El827).
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When using a tracer gas one may use a constant emis-
sion rate source in which the AER is computed from the
measured steady state concentration of the tracer and
the known emission rate of the source. In an alternate
tracer approach one injects a puff of a tracer gas and
then monitors its rate of decay with time. The effective
rate of decay is then called the AER. Soil gas entry rates
can also be directly measured by monitoring a second
tracer unique to the soil gas (such as radon). A unique
tracer could  also be injected into a sub-slab gravel layer
or permeable mat. Any soil gas constituent that is known
not to have indoor or ambient sources can serve as a sur-
rogate for soil gas entry.
When the AER is measured under a positive pressure
scenario with frequent monitoring of individual con-
taminant concentration(s) in indoor air over time, soil
gas and indoor sources can be  distinguished. If, under
positive pressure, the contaminants do not decay to non-
detectable levels, an indoor or ambient source is indicat-
ed. Using the measured AER and the measured ambient
concentration, the effective emission rate of the indoor
source can be determined. Then from a mass balance
analysis  a soil gas entry rate can be calculated. For more
information on tracer methods of AER measurements
please see:

 •  ASTM E741 E741 -00 Standard Test Method for
    Determining Air Change in a Single Zone by Means
    of a Tracer Gas Dilution
 •  Dietz and Cote, 1982


5.4  Measuring or Estimating Sub-slab Soil
     Gas Concentrations During Mitigation
5.4.1   Sub-slab Measurements

During mitigation, sub-slab measurements are not al-
ways required but if performed, may be used for several
purposes. If the sub-slab concentration substantially
decreases that is a strong sign that an SSD or SSV system
is working. However, a failure to decrease the concentra-
tion is not necessarily an indication that the system is
not working. An SSD system can work even if it does
not reduce sub-slab concentration because it reverses the
pressure differential.
Sub-slab probes can also be used to monitor differential
pressures for a direct indication of the performance of
sub-slab depressurization or SVE systems.
5.4.2   Sub-slab Sampling Procedures

Sub-slab samples can be collected from beneath slab-on-
grade or basement slabs. A sub-slab sampling approach
is typically useful only if the water table is sufficiently
below the slab to allow a soil gas sample to be collected.
If the seasonal high water table and capillary water reach
the foundation, the entry processes are likely to be al-
tered for some period of time (NJDEP, 2005).
The sub-slab sampling plan  should be based on:

 • Knowledge of the building's footing and slab design
   (footings can sometimes subdivide the subsurface
   area beneath the building, potentially creating a
   "trapping zone" for vapors),
 • The location of utility corridors (both because they
   influence the contaminant distribution and for
   safety),
 • Knowledge of the dominant entry points to the
   structure, if possible, as well as the source location/
   expected routes of contaminant migration.
It is difficult to state general rules as to where in the
building footprint points should be placed or how many
are required. However, if there are multiple occupied
spaces that differ in ways likely to influence air exchange
with the sub-slab space (i.e., floor/sub-floor materials,
HVAC system in use, etc) samples from each space will
be needed.
Detailed instructions for installation of sub-slab sam-
pling probes are provided in several documents (e.g.,
DiGiulio, et al., 2005, NYSDOH, 2005; NJDEP, 2005;
and MADEP, 2002). Sub-slab sampling probes may be
temporary or permanent. A  small-diameter hole is made
through the slab and into the sub-slab fill material. The
probe is installed through the slab and must be well
sealed into the slab to prevent leakage between the probe
and the slab.

The HVAC system should be operated for at least 24
hours before sampling to maintain a normal indoor
temperature. Advice on sample collection from sub-slab
probes is provided in various documents (DiGuilio et al.,
2005; DTSC, 2005; NYSDOH, 2005; NJDEP, 2005).
These and other documents provide further information
on analytical methods, QA/QC procedures and supple-
mental data collection (e.g.,  building surveys, soil char-
acterization) essential to a sub-slab sampling program.

Generally, multiple rounds of testing are advised to as-
sess variability of sub-slab concentrations due to diurnal
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
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and seasonal effects, HVAC operation, changes in source
strength, vapor migration, and occupant activities (NYS-
DOH, 2005; ASTM, 2005), if the variability is not well
understood prior to mitigation. Diurnal and seasonal
effects are caused by temperature, wind, and barometric
pressure variations as well occupant activities and HVAC
operational changes. Usually diurnal patterns are less no-
ticeable in the sub-slab concentration than in the indoor
concentration.
5.5  Indirect Measurements
     of Mitigation Performance

The measurements described in this section are not de-
finitive measures of performance but are commonly used
to evaluate the mechanical operation and influence on
the sub-slab zone of a mitigation system. They do pro-
vide useful secondary indicators in some circumstances.

5.5.1   Tracer and Smoke Testing

Tracers can be used either to measure the AER in the
structure, which is discussed above in section 5.3.2 or for
leak detection through barriers or building materials as
discussed below. Tracers could also be used to find leaks
in HVAC systems or in SSD ducts.
Smoke testing is a qualitative form of tracer testing used
to detect leaks or preferential vapor migration pathways,
or to test airflow patterns. A smoke stick or smoke tube
which generates a stream of visible smoke can be used
to test for leakage through seams such as pipe joints and
slab-wall junctures (EPA,  1993). Leak testing of pipe
joints is more effective when the smoke is injected into
the pipe under positive pressure. Testing after the pipe
assembly is complete is more definitive than smoke test-
ing during assembly. However, testing during assembly
is a recommended quality control step. Timing of smoke
testing for membrane construction applications is dis-
cussed in section 3.3 A. New York guidance (NYSDOH,
2005) recommends the use of smoke tubes to test for
leaks at seams and seals of membranes in  sub-membrane
depressurization systems; at cracks and joints in the con-
crete slab, as well as at the suction point in sealed sub-
slab depressurization systems; and at potential leakage
points through floors above sealed crawlspace systems.
A limitation of smoke testing in existing structures is
that non-noxious smokes are expensive and cheap high
volume smoke sources can leave undesirable residues.
                          The efficacy of smoke testing in some applications has
                          been questioned on the grounds that many leaks are too
                          small for visual detection using this method (Maupins
                          and Hitchins 1998, Rydock, 2001), and that leaks large
                          enough to detect using smoke could be detected in other
                          ways. More quantitative methods have been recom-
                          mended, such as tracer testing and using instrumenta-
                          tion for quantitative results.

                          5.5.2  Communication Test of
                                Sub-slab Depressurization

                          Communication tests, or pressure field extension tests,
                          are commonly used in the design of sub-slab depressur-
                          ization systems to ensure that the engineered sub-slab
                          depressurization field extends under the entire slab and
                          foundation. A set of diagnostic tests referred to as sub-
                          slab communication and pressure field extension tests are
                          fully described in several documents (ASTM E2121-03,
                          EPA 1993b, Fowler, et al., 1990). These documents
                          describe not only how to use the results of the diagnos-
                          tic tests to select a mitigation method, but also how to
                          design and install the system. Good communication or
                          pressure field extension is necessary for effective SSD.
                          The absence of sub-slab depressurization suggests a
                          higher potential for contaminant entry. For  purposes of
                          designing a sub-slab depressurization system, the test is
                          conducted by applying suction at a drill hole in a central
                          portion of the slab and observing the pressure  differ-
                          ence across the slab at holes drilled in other  locations.
                          Locations for pressure measurements should extend to
                          the extremes of the slab. A micromanometer should be
                          used to measure pressure differentials at measurement
                          points (NYSDOH, 2005). If the pressure  field exten-
                          sion cannot be quantified with a micromanometer the
                          performance of the mitigation system may be in ques-
                          tion. A pressure difference that causes smoke to move in
                          the desired direction, but is not measurable  on a micro-
                          manometer probably indicates an insufficient margin
                          of safety. The same sub-slab measurement probes could
                          be used both to measure the design diagnostics and for
                          performance testing after the system is installed. A lack
                          of pressure differential could indicate moist  soils near the
                          slab that limit air permeability, a footing that separates
                          test points, or other flow issues. The potential  perfor-
                          mance of an SSD system may be judged on  its ability to
                          extend an adequate pressure field under the  entire slab.
                          Section 4.3.3 of ITRC (2007) presents a detailed discus-
                          sion of the pros and cons of conducting communication
40
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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tests before design vs. installing a standard system and     to determine whether modifications or replacement are
then testing it/adjusting it after installation.               warranted (ASTM, 2005).

                                                      If indoor air sampling for COC is included in the peri-
                                                      odic monitoring plan, sampling events during the heat-
                                                      ing season should be included. When assessing system
                                                      performance at new construction sites, monitoring of
                                                      volatile organics should take into account the initial off-
                                                      gassing of new building materials, furniture, etc. (NYS-
                                                      DOH, 2005)
5.5.3   Pressure Differential Testing

For designed pressurization systems or HVACs that
rely on differential pressure to prevent advective flow
of soil gases into the building, the mechanical perfor-
mance should be verified by measuring the pressure
differentials across the slab. This measurement is typi-
cally accomplished with micro manometers or electronic
pressure meters. While the pressure differential between
the indoors and ambient at ground level may serve as an
acceptable surrogate, it is the pressure differential across
the slab that prevents soil gas entry. For basements, the
walls that are underground become part of the critical
building envelope that must prevent soil gas entry.

5.6  Initial and Long-Term Verification
     of System Performance

After installation, the system performance must be
verified. Such initial acceptance testing should include
verification of the mechanical performance of the system
combined with appropriate air concentration measure-
ments. Initial verification might use an existing tracer
such as radon to demonstrate its reduction in the indoor
air.

Monitoring approaches, at least in the early stages,
should include direct measurement of the concentration
of VOCs in indoor air and possibly pressure differen-
tials in the sub-slab soil gas. Monitoring programs may
also include measurement of factors known to control
vapor intrusion such as pressure differentials, AER or the
achievement of complete negative pressure field exten-
sion for a sub-slab depressurization system.

As part of initial system operation testing, fireplaces,
woodstoves, or other combustion or vented appliances
must be checked for possible backdrafting which could
introduce dangerous combustion gases, especially carbon
monoxide (CO), into  the structure (NYSDOH, 2005).
Longer-term periodic monitoring may consist of inspec-
tions of equipment, materials and surrounding condi-
tions, physical measurements, leak testing, other testing
or sampling  (ASTM, 2005; NYSDOH, 2005). Comple-
tion of any needed maintenance should follow from the
results of periodic monitoring. Based on monitoring
results, system performance should be critically evaluated
                                                      When mitigation systems are not operating effectively,
                                                      diagnostic testing can be used to identify design or
                                                      installation problems and suggest ways to improve the
                                                      system. A detailed discussion of such diagnostic testing is
                                                      presented on pages 5-5 to 5-10 of EPA 1993a.
                                                      Termination of the system may be requested once it can
                                                      be demonstrated that the vapor intrusion pathway is no
                                                      longer complete. New Jersey requires termination sam-
                                                      pling of indoor and sub-slab air (NJDEP, 2005). Section
                                                      4.5 of ITRC (2007) provides a detailed discussion of
                                                      steps for regulatory closure of vapor intrusion mitigation
                                                      systems, including considerations for multiple building
                                                      sites. The stakeholders may, however, recognize addi-
                                                      tional benefits of the mitigation system that could justify
                                                      the continued operation of the system after the hazard
                                                      from the  contaminant of initial primary concern is reme-
                                                      diated. For example systems can reduce moisture leading
                                                      to reduced mold, mildew and musty odors indoors. Sys-
                                                      tems also provide protection against intrusion of natu-
                                                      rally occurring radon gas.

                                                      5.6.1   Operation and Monitoring (O&M)
                                                             Requirements for SSD/SSV Systems

                                                      ASTM (ASTM, 2005) calls for regular monitoring and
                                                      maintenance intervals and makes useful  suggestions for
                                                      how to select a monitoring interval (sections 6.3.8 and
                                                      8). The average lifetime of the devices should be taken
                                                      into account. For example, ASTM states: "The moni-
                                                      toring frequency will be a function of the timeframe for
                                                      possible failure of the engineering control (i.e.,  more
                                                      frequent for an active system, less frequent for a pas-
                                                      sive system) and the relative effect of such a failure on a
                                                      potential receptor (more frequent for immediate impact,
                                                      less frequent for a delayed impact). Design specifica-
                                                      tions may include (1) a monitoring frequency that varies
                                                      over the operating period of the engineering control or
                                                      (2) a provision to evaluate and modify the monitoring
                                                      frequency based on data or information  obtained dur-
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                                                                                       41

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ing monitoring and maintenance." For example, it may
be acceptable to reduce sampling frequency once perfor-
mance objectives for indoor air quality are met (prefer-
ably during the heating season). Likewise, decreased
inspection /maintenance frequency may be acceptable
once efficient system operation has been demonstrated
for a year (NJDEP, 2005). ASTM also suggests triggers
for unscheduled inspections such as floods, earthquakes,
building modifications, etc.

Typical O&M activities for the mitigation of vapor in-
trusion by either passive or active venting/depressuriza-
tion systems may include the following (from DTSC,
2004 and NYSDOH, 2005):
 •  All newly mitigated buildings should be given an
    initial indoor air test to determine if the mitigation
    remedies are operating and performing according
    to design specifications. For both active and passive
    depressurization systems this testing should include
    tests of the pressure field extension to the extremities
    of the slab. Manometers or suitable pressure gauges
    will be required to test the pressure field extension.
 •  Routine inspection of the area of concern, includ-
    ing all visible components of the mitigation system
    and collection points, should be performed to ensure
    there are no significant changes in site condition and
    there are no signs of degradation of the mitigation
    system.
 •  Routine monitoring of vent risers for flow rates and
    pressures generated by the fan should be conducted
    to confirm the system is working and moisture is
    draining correctly.
 •  Routine maintenance, calibration, and testing of
    functioning components of the VOC venting sys-
    tems should be performed in accordance with the
    manufacturers' specifications.
 •  Periodic monitoring of air on the lowest accessible
    floor and enclosed areas of the building and grade
    surface areas is needed to ensure there are no signifi-
    cant increases in subsurface gas concentrations.
 •  Periodic verification of adequate pressure differen-
    tials (min 5 Pa) across the slab should be done.
Additional information on operation and maintenance
of venting systems may be found in Chapter 4 of NYS-
DOH  (2005).
                          5.7  The Role of Ongoing Warning
                               Devices and System Labeling
                          According to ASTM (2003a): "All active radon miti-
                          gation systems shall include a mechanism to monitor
                          system performance (air flow or pressure) and provide a
                          visual or audible indication of system degradation and
                          failure." This advice should be equally applicable to
                          vapor intrusion systems for other contaminants. ASTM
                          goes on to say "The mechanism shall be simple to read
                          or interpret and be located where it is easily seen or
                          heard. The monitoring device shall be capable of having
                          its calibration quickly verified on site."
                          The Wisconsin guidance provides a detailed discussion
                          of what circumstances and for what contaminants odor
                          can provide a warning of the existence of vapor intrusion
                          problems (pages 7-9)
                          http://dhfs.wisconsin.gov/eh/Air/pdf/VI guide.pdf.
                          Fixed gas detectors have been widely employed for such
                          acutely hazardous air pollutants as CO and methane in
                          residential and industrial applications. Fixed detectors
                          using infrared (IR) or photoionization (PID) devices are
                          also available for volatile organics (Skinner and Avenell,
                          2005). Government websites that provide information
                          about the selection and installation of gas detectors of
                          various types include:
                           •  http://www.nidcd.nih.gov/health/smelltaste/gasdtar.asp
                           •  http://www.osha.gov/dts/ctc/gas  detec
                             instruments/index.html
                           •  http://www.lbl.gov/ehs/pub3000/CH 13A.html
                           •  http://www.msha.gov/TECHSUPP/ACC/
                             lists/22methne.pdf
                          The New York and New Jersey vapor intrusion docu-
                          ments also recommend durable pressure monitor-
                          ing devices and/or alarms  (NYSDOH, 2005; NJDEP,
                          2005). Such devices may indicate operational parameters
                          (such as on/off or pressure indicators)  or hazardous gas
                          buildup (such as percent LEL indicators). System fail-
                          ure warning devices or alarms should be installed on the
                          active mitigation systems (for depressurization systems),
                          and appropriate responses to them should be understood
                          by building occupants. Monitoring devices and alarms
                          should be placed in readily visible, frequently trafficked
                          locations within the structure. The proper operation of
                          warning devices should be confirmed on installation and
                          monitored regularly.
42
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

-------
Permanent placards should be placed on the system to
describe its purpose, operational requirements and what
to do if the system does not operate as designed (e.g.,
phone number to call). These placards should be placed
close to the monitoring/alarm part of the system as well
as close to the fan or other active parts of the system.
The placard should also tell the building occupant how
to read and interpret the monitoring instruments or
warning devices provided.

6   ACRONYMS AND ABBREVIATIONS
AER      Air Exchange Rate
AFB      Air Force Base
ASHRAE American Society of Heating, Refrigerating
          and Air Conditioning Engineers
ASTM    American Society for Testing and Materials
ATSDR   Agency for Toxic Substances and Disease
          Registry
CDPHE  Colorado Department of Public Health and
          Environment
CERCLA Comprehensive Environmental Response
          Compensation and Liability Act
CO       Carbon Monoxide
CO2      Carbon Dioxide
COC     Contaminant of Concern
COPC    Contaminants of Potential Concern
DCE      Dichloroethene
DQO     Data Quality Objectives
EPA      Environmental Protection Agency
EPDM    Ethylene Propylene Diene Monomer
HAC     Heating and Cooling
HAP      Hazardous Air Pollutants
HOPE    High Density Polyethylene
HVAC    Heating Ventilation and Air Conditioning
IBC      International Building Code
IDEM    Indiana Department of Environmental
          Management
IDLH     Immediately Dangerous to Life and Health
IR        Infrared
IRC      International Residential Code
ITRC     Interstate Technology and Regulatory
          Council
LDPE     Low Density Polyethylene
LEL      Lower Explosive Limit
MACT    Maximum Achievable Control Technology
MRL     Minimal Risk Level
NESHAP National Emission Standards for Hazardous
          Air Pollutants
NIOSH   National Institute for Occupational Safety
          and Health
NO2      Nitrogen Dioxide
O&M    Operation and Monitoring
OSC      On Scene Coordinator
PID      Photoionization Detector
QA/QC   Quality Assurance/Quality Control
QAPP    Quality Assurance Project Plan
RCRA    Resource Conservation and Recovery Act
RPM     Remedial Project Manager
SMD     Submembrane Depressurization System
SSD      Sub-slab Depressurization
SSP      Sub-slab Pressurization
SSV      Sub-slab Ventilation
SVE      Soil Vapor Extraction
TCE      Trichloroethene
TPY      Tons per Year
USGS    United States Geological Survey
UV      Ultraviolet
VI        Vapor Intrusion
VDPE    Very low density polyethylene
VOC     Volatile Organic Compounds

7   ACKNOWLEDGMENTS
This Engineering Issue was prepared for the U.S. Envi-
ronmental Protection Agency (EPA), Office of Research
and Development (ORD), National Risk Management
Research Laboratory (NRMRL) by Science Applica-
tions International Corporation (SAIC) under Contract
No. 68-C-02-067. Mr. Doug Grosse served as the EPA
Work Assignment Manager. Ron Mosley of EPA's ORD
NRMRL and Ray Cody of EPA Region 1, Boston, MA
served as EPA's technical leads. Ms. Lisa Kulujian was
SAIC's Work Assignment Manager. In addition to Mr.
Mosley and Mr. Cody, the primary authors were Chris
Lutes, Michiel Doom and Angela Frizzell of ARCADIS.
Helpful comments were received from numerous peer
reviewers both within EPA and in the private sector, for
which the authors would like to express their gratitude.
This Issue Paper was intended as an overview on vapor
intrusion mitigation for EPA staff, regional program of-
 Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches
                                               43

-------
fices, RPM's and State governmental environmental staf£
Because vapor intrusion is a rapidly evolving environ-
mental phenomenon, interested parties should further
consult the body of literature and experience that con-
stitutes the state-of-the-art of vapor intrusion and vapor
intrusion mitigation. As of the date of this publication,
questions may be addressed  to Mr. Mosley, EPA ORD
NRMRL (mosley.ronald@epa.gov: 919/541-7865)
and/or Mr. Cody, EPA Region I (cody.ray@epa.gov;
617/918-1366).
For additional information,  interested parties may also
contact the ORD Engineering Technical Support Center
(ETSC):
David Reisman, Director
U.S. EPA Engineering Technical Support Center
26 W. Martin Luther King Drive  MLK-489
Cincinnati, OH 45268
(513)487-2588

Reference herein to any specific commercial products,
process, or service by trade name, trademark, manufac-
turer, or otherwise, does not necessarily constitute or
imply its endorsement, recommendation or favor by the
United States Government. The views and opinions of
the authors expressed herein do not necessarily state or
reflect those of the United States Government, and shall
not be used for advertising or product endorsement pur-
poses.

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48
Engineering Issue: Indoor Air Vapor Intrusion Mitigation Approaches

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