The Defense Department and military services say Colorado's draft indoor air guidance to address vapor intrusion from volatile organic compounds has significant flaws, namely that its screening and cleanup levels are too stringent and that it gives regulators too much leeway in determining case-specific cleanup requirements while giving the regulated community little direction in appropriately addressing vapor intrusion problems.
Further, DOD argues Colorado should promulgate the guidance as a rule given it sets binding action and remediation standards, among other things.