School Sites with Environmental Cleanups Addressing the Indoor Inhalation Pathway

Introduction

This fact sheet is intended for schools located on properties where soil and/or groundwater contamination has been or is being remediated under one of the Illinois EPA's Remediation Programs. On May 16, 2013, the Illinois Pollution Control Board added the indoor inhalation exposure route to Illinois EPA's risk-based cleanup methodology called the Tiered Approach to Corrective Action Objectives ("TACO"), 35 Ill. Adm. Code Part 742. These amendments are effective on July 15, 2013.

The remediation activities at school sites prior to the effective date are health-protective for potential soil ingestion, soil (dust) inhalation, and the consumption of groundwater as drinking water. At the time of those cleanups, however, Illinois EPA did not require program participants to evaluate the site for potential indoor inhalation exposure, which is also called vapor intrusion. Only recently has the science of vapor intrusion advanced far enough to enable statewide regulation of this exposure route for site cleanups. All future remediation activities at the a school site will be required to address the indoor inhalation pathway.

When volatile chemicals are spilled on the ground or leak from underground storage tanks, they emit gases, or vapors, that can migrate from the subsurface into the air space of overlying buildings. The addition of the indoor inhalation pathway is intended to protect building occupants from breathing air contaminated by these environmental releases.

Chemicals that can cause vapor intrusion include gasoline or diesel fuel, dry cleaning solvents, and industrial de-greasers. They are called volatile chemicals because they readily evaporate and form vapors. The vapors move through the soil and seep through cracks in slabs or basement floors and walls, openings for utility lines where pipes and electrical lines go through the foundation, crawl spaces below floors, and other openings.

In general, exposure to a volatile chemical does not necessarily mean that adverse health effects will occur. Whether or not a person experiences adverse health effects depends on several factors such as: the type of chemical(s) present, the levels of the chemical found, the length of exposure, a person's sensitivity to the chemical, and the overall health of the exposed person.

What is meant by the term "school"?

School is defined in Illinois EPA's Site Remediation Program as any public educational facility in Illinois, including grounds and campus, consisting of students comprising one or more grade groups or other identifiable groups, organized as one unit with one or more teachers to give instruction of a defined type. Public educational facility includes, but is not limited to, primary and secondary (kindergarten - 12th grade), charter, vocational, alternative, and special education schools. Public educational facility does not include junior colleges, colleges or universities.

How will I know if a property on which my school is located has been entered into the Illinois EPA's Site Remediation Program or Leaking Underground Storage Tank Program?

The databases for the Site Remediation Program and the Leaking UST Program may be accessed online. In addition, a list of probable school sites has been prepared for the Site Remediation Program and Leaking Underground Storage Tank Program.

Please be aware of the following:

  1. Illinois EPA cannot assure the accuracy of the lists generated from the cleanup program databases (e.g., a school might have entered a remediation program under a different name);

  2. the chemicals of concern at the school site may not be volatile chemicals, in which case vapor intrusion is not an issue;

  3. volatile chemicals that are present may not be in the area of a building where children attend classes; and

  4. the original cleanup may have sufficiently addressed the indoor inhalation exposure route even if not deliberately.

Does a future school need to enter a remediation program?

Yes and no. If the public school is located within Cook County, a review of the past history has identified the potential for contaminants to be located at the site and sampling has determined contamination exists at the site, construction of a building cannot commence until a remedial action plan is approved by the Illinois EPA. In addition, the building cannot be occupied until the remedial action plan has been completed. For school sites outside of Cook County, there is no requirement for those sites to enter a remediation program.

If so, what kind of assurance will I have that the cleanup was completed?

If the school site is entered into a remediation program, the school site will be issued a No Further Remediation letter after the cleanup has been completed. A No Further Remediation letter is a release from further responsibilities and states the site does not constitute a threat to human health and the environment for the identified land use. All school sites must meet the most stringent remediation objectives identified in the TACO regulations.

The No Further Remediation letter states a Building Control Technology is required at a school site. What is a Building Control Technology?

A Building Control Technology or "BCT" is any technology or barrier used at a site that affects air flow or air pressure within a building for purposes of reducing or preventing contaminant migration to the indoor air. Types of BCTs that may be used include sub-slab depressurization systems, sub-membrane depressurization systems, membrane barrier systems and vented raised floors. Other BCTs may be used if they can reduce migration of contaminants indoors and are approved by the Illinois EPA prior to use.

What happens if the Building Control Technology is not working at a school?

If a Building Control Technology quits working for five consecutive calendar days during the school year when school is in session, the school administrator shall notify the Illinois EPA, the school board and every parent or legal guardian of a student enrolled in that school.

If my school site has been cleaned up previously, is it required now to evaluate for vapor intrusion?

No. If a school has received a No Further Remediation (NFR) determination from Illinois EPA prior to July 15, 2013, the school will not be required to re-enter the site nor evaluate the site for vapor intrusion. The original NFR letter is still valid and protective for the other exposure routes (potential soil ingestion, soil (dust) inhalation, and the consumption of groundwater as drinking water).

However, in order to assure that no building occupants are at risk from vapor intrusion caused by environmental releases of volatile chemicals, the site may voluntary enroll in the Illinois EPA's Site Remediation Program, evaluate the new pathway, remediate if needed, and request a No Further Remediation letter addressing the indoor inhalation pathway.

Who would I contact if I have more questions concerning the Site Remediation Program or the Leaking Underground Storage Tank Program?

You can contact the Illinois Environmental Protection Agency at 217-524-3300 to be directed to the project manager on call for either program.

This fact sheet is for general information only and is not intended to replace, interpret, or modify laws, rules, or regulations.

June 2013