Development of Commercial/Industrial Vapor Intrusion Mitigation BMPs

The Minnesota Pollution Control Agency (MPCA) is developing Best Management Practices for vapor intrusion mitigation at commercial and industrial properties. The agency will begin the development work in the spring, and hopes to have the BMP document completed by the fall of 2018.

The existing vapor intrusion mitigation BMP focuses on single-family residential buildings and does not specifically address commercial/industrial buildings.

Stakeholder contributions and timeline

The MPCA has formed a stakeholder advisory group to provide input to help make these BMPs practical and easy to implement consistently. The first meeting of this group will take place in mid-April. 

The stakeholder advisory group members are:

Name Title Organization Email Industry
Hava Blair Program Coordinator MnBrownfields Brownfield non-profit
Mark Ethen Chief Credit Officer Northeast Bank Banking
Mary Finch Supervising Environmentalist Hennepin County Government/grant funder
Donovan Hannu Group Manager Bay West Environmental consulting
Briana Kirby Lead Environmental Risk Analyst Bremer Bank Banking
Rick Kubler Principal Gray Plant Mooty Legal
Marcus Martin Senior Planner MetCouncil Environmental Services Government/grant funder
Linda Opperman Environmental Manager Target Corporation Commercial property redevelopment
Mary Sands Vice President Barr Engineering Environmental consulting
Cathy Undem Senior Environmental Scientist Dakota County Government/grant funder
Kaitlin Thell Ouverson Project Engineer Braun Intertec Environmental consulting


The MPCA will add dates to the timeline below as details of the development process are finalized. The goal is to have the commercial/industrial BMPs ready to release in the fall of 2018.

Graphic showing commercial BMP development timeline

How you can contribute to the process

MPCA invites all who are interested to provide input during the BMP development process, not just those who are on the stakeholder advisory group. Stakeholder input improves BMP development by providing:

  • Technical expertise
  • Different perspectives
  • Your needs as a program user

Some examples of stakeholder contributions include:

  • Providing proposals to address policy issues
  • Review and comment during development process

To provide input:

  • Call or email the Vapor Specialist Team to discuss questions, issues and concerns
  • Contact a stakeholder advisory group member from your industry sector

Issues and questions

Below are some of the questions and issues the BMPs for vapor intrusion mitigation at commercial and industrial properties will address:

Passive Mitigation

  • Are passive mitigation systems an option for mitigating a commercial/industrial building?
  • What would be sufficient verification testing for a passive system to meet the standard outlined in the Vapor Intrusion Guiding Principles?
  • Are there studies that show how well passive mitigations systems work?
  • Would a passive sub slab system be acceptable without also installing a vapor barrier?

Vapor Barriers

  • Are vapor barriers, alone or in conjunction with a passive mitigation system, an option for mitigating a commercial/industrial building?
  • Can I install vapor barrier then reevaluate the mitigation decision with a completed pathway investigation?
  • What would be appropriate technical specifications for a vapor barrier if it is approved as a mitigation approach?
  • Can a vapor barrier be used only if there is no building slab?

HVAC for Mitigation

  • Is positive pressurization of a building an acceptable mitigation technology?
  • Is increasing ventilation an acceptable mitigation technology, and if so, what are the minimum requirements?
  • Are there minimum engineering requirements for an HVAC system and building design for HVAC to be used as building mitigation?
  • Does the HVAC need to be operated continuously, or only during business hours?

Indoor Air Filtration

  • Under what conditions would indoor air filtration be an acceptable mitigation technology?

Underground Parking

  • Are there minimum engineering requirements for a parking garage to be considered a mitigation system?
  • Can parking garages with ventilation fans that are keyed to carbon monoxide concentrations be considered a mitigation system?

Mitigation Systems vs. Remediation Systems

  • Under what conditions could a remediation system also serve as a building mitigation system?

Required Verification Testing

  • What is the verification testing for each mitigation approach/technology?
  • Can the verification testing requirements be different for new construction?
  • Can I avoid drilling through the building slab and/or vapor barrier of new construction for confirmation testing?


If you have questions about the BMP development process or any facet of it, contact a member of the MPCA Vapor Specialist Team.