A Summary of the Latest Updates for AST Inspections Using STI SP001 7th Edition
The Steel Tank Institute (STI) released the 7th Edition of the SP001 Standard for the Inspection of Aboveground Storage Tanks (ASTs) in late February 2024. This release comes six years after updating the previous Edition in January 2018.
The first update is the change to STI’s website, which is now www.stispfa.org. This new website includes much of the same information as the previous website, but the site map of that information is very different, with some data behind a membership wall, including the list of certified inspectors.
Revisions and Definitions
As for the SP001 7th Ed. text, it now includes a few revised and new definitions. The definition of Double-walled AST and Spill Control now specifies that “A tank insulation system or insulating jacket placed on a tank does not constitute a double wall tank.” This clarification distinguishes between insulation and the actual structure of the tank.
The Initial Service Date is specific to the tank “regardless of the AST’s current location or ownership. If the initial service date is unknown (e.g., rented or repurposed AST),” refer to the Inspection Schedule section of SP001.
In addition, the Standard now includes a definition for a Permit-Required Confined Space, providing clear guidelines on the safety requirements for confined spaces in line with the applicable OSHA requirements.
The Ultrasonic Testing Scan (UTS) is further clarified to mean “An ultrasonic scan which scans 100% of a designated surface area.” This scan detects thinning from material loss, not just corrosion.
Relevance to AST Inspections
Several items during formal tank inspections are now specifically mentioned. Manways are now on the list of tank components for inspection. The Basic Tank Anatomy Figure (Figure A.1.2) is revised to include the Manway, Fill Pipe, Tank Gauge, and Tank Support. This enhancement provides a more comprehensive overview of common tank components.
In addition to these updates, tank inspections now specifically include verifying the accuracy of the owner’s STI SP001 AST Record data, inspecting for vegetation growing alongside or against the AST or the foundation, and Ultrasonic Thickness Testing (UTT) readings of the corroded areas if corrosion is evident on the outside surface of the secondary tank shell.
The 7th Edition also broadens the range of potential inspectors, designating the responsibility of conducting Periodic AST inspections and the Leak test to “a qualified party designated by the owner” or “a qualified party designated by the owner or owner’s designee.” A detailed description of the grid pattern for Formal Internal Inspections (FII) is in the 7th Edition.
If Microbiologically Influenced Corrosion (MIC) is suspected, the standard now suggests testing a sample of liquid from the tank bottom for bacteria that could cause MIC going forward.
A written report is required for each Formal External Inspection (FEI) & Formal Internal Inspection (FII) performed.
Should the integrity of spill control be compromised during an inspection, SP001 7th Ed. includes a reevaluation of the tank category and inspection timetable. This new standard introduces more flexibility and responsiveness to potential issues that may arise during inspections.
In conclusion, the 7th Edition of STI’s SP001 Standard for the Inspection of Aboveground Storage Tanks presents significant updates and clarifications that aim to enhance the inspection process, ensuring the safety and longevity of ASTs.
About the Author: Benjamin Reynolds is a Senior Project Professional in our Little Rock, Arkansas, office. His experience includes Spill Prevention, Control, and Countermeasures (SPCC), Tank Assessments, Storm Water Pollution Prevention Plans (SWPPPs), and Phase I and II Environmental Site Assessments. He is a Professional Engineer licensed in Arkansas, Oklahoma, Tennessee, and Florida. Reach out to Ben at or on LinkedIn.
Additional AST and SPCC Resources and Tips:
Developers looking to build in or near wetlands in Florida must navigate a complex permitting process, particularly considering the recent court order affecting the State 404 Program. With the pause in the State 404 Program, developers must revert to the federal permitting process under the Clean Water Act (CWA) Section 404, administered by the U.S. Army Corps of Engineers and overseen by the Environmental Protection Agency (EPA).
As of February 15, 2024, the Florida Department of Environmental Protection (DEP) has temporarily lost its authority to issue State 404 Program permits.
The State 404 Program, effective December 22, 2020, was designed to streamline the permitting process by allowing the state to evaluate and issue permits for a broad range of water resources within the state to protect Florida’s waters, residents, and economy more efficiently. The EPA had approved Florida’s assumption of the CWA Section 404 program, making it one of the only three states with Michigan and New Jersey to have such authority.
A recent court ruling shifts the administration of the 404-permitting process in Florida back to the U.S. Army Corps of Engineers and EPA, affecting developers, government projects, and any activities requiring dredge or fill permits in state-assumed waters. Specifically, the decision was part of a larger judicial examination of how agency deference is applied and its impacts on individual rights versus governmental interests.
Before starting any project, it is essential to determine if the land in question falls under the authority of the CWA Section 404. This involves identifying if the project area includes waters of the United States, including wetlands. The U.S. Army Corps of Engineers conducts jurisdictional determinations to make this assessment.
It is advisable to schedule a pre-application meeting with the U.S. Army Corps of Engineers. During this meeting, developers can present their project plans and receive guidance on the permitting process,
Depending on the project’s impact on the wetlands, developers may need to apply for either a Nationwide Permit (for minimal impacts) or an Individual Permit (for significant impacts). The application process requires detailed project descriptions, impact assessments, and mitigation plans.
A general Nationwide Permit may be suitable for activities with minimal adverse effects, streamlining the review process. An individual permit is required for potentially significant impacts, involving a more detailed review process, including public notice and opportunity for hearing.
General permits, like Nationwide Permits, are designed for activities with minimal environmental impacts and offer a streamlined review process. They apply broadly to numerous similar projects, reducing the need for detailed scrutiny of each case.
Individual permits, on the other hand, are required for projects that might have significant environmental impacts. This process is more rigorous, involving a detailed review, public notices, and opportunities for hearings to assess the potential environmental consequences more closely.
Developers must demonstrate efforts to avoid impacts on wetlands, minimize unavoidable impacts, and provide compensation for any remaining unavoidable impacts through restoration, establishment, enhancement, or preservation of aquatic resources.
Certain projects may require consultation with other federal agencies, such as the U.S. Fish and Wildlife Service or the National Marine Fisheries Service. Additionally, the public and interested stakeholders can comment on Individual Permit applications.
Developers must ensure compliance with other relevant environmental regulations, such as the Endangered Species Act and the National Historic Preservation Act, as part of the permitting process.
Given the current uncertainty and potential for further legal developments regarding Florida’s State 404 Program, developers should closely monitor any updates from the Florida Department of Environmental Protection and the U.S. Army Corps of Engineers. Consulting with legal and environmental professionals familiar with Florida’s federal and state wetland regulations is highly recommended to navigate this complex regulatory landscape effectively.
Developers in Florida working with their consultants on wetlands issues need to navigate a complex regulatory landscape. Determining if a project requires a Nationwide Permit for minimal impacts or an Individual Permit for significant impacts is crucial. Developers and their consultants should engage in pre-application meetings with the U.S. Army Corps of Engineers, understand the necessity of demonstrating efforts to avoid, minimize, and compensate for wetland impacts, and ensure compliance with other relevant regulations like the Endangered Species Act. Consulting with environmental legal professionals is highly recommended to navigate these regulations effectively.
Additional Environmental Permitting Resources & Protections in the U.S.
About the Author: David Palmerton, Jr., PG, is a Project Director for the Environmental Services Practice. Mr. Palmerton has managed strategic and technical environmental consulting issues for Fortune 100 companies throughout the United States. He has typically provided senior technical oversight, strategic support, and cost control for large multi-component environmental sites. His consulting assignments have included environmental science-based investigations, including soil, sediment, groundwater, and dense non-aqueous phase (DNAPL) investigations and remediation at some of the nation’s most high-profile sites. Mr. Palmerton has over 35 years of experience in environmental consulting in the areas of environmental liability assessment, investigation and remediation. Reach Dave on LinkedIn, or our consultants and engineers nearby at .
SCS Engineers, a leading environmental engineering firm, proudly announces the appointment of its new executive leadership team subsequent to its semiannual Board of Directors meeting, under the guidance of Chairman Jim Walsh and CEO Doug Doerr.
Curtis Jang assumes the role of President, leveraging his extensive 30-year tenure in financial management and organizational improvement. Mr. Jang, will spearhead strategies aligning with the overarching goals set forth by the CEO and Board.
CEO Doug Doerr affirms the significance of this leadership transition, stating, “To ensure our continued success and to position ourselves for future growth, I’ve entrusted several key individuals to assume new executive roles. As one of the country’s foremost environmental engineering firms experiencing remarkable growth, it is imperative that we equip ourselves for the challenges and opportunities ahead.”
In his capacity as President, Mr. Jang will collaborate closely with Doug Doerr and the newly appointed executive leadership team to steer SCS Engineers towards its envisioned future – prioritizing the welfare of its employee-owners, fostering a cohesive ‘One SCS’ ethos, and delivering unparalleled service to our valued clients.
Eddy Smith, assuming the role of Chief Operating Officer, will lead business strategies across various units and practices to foster enhanced collaboration company-wide, thereby enhancing value delivery to clients. With over three decades of experience in environmental and civil engineering design and consulting, Mr. Smith brings a wealth of expertise to his new role.
Chief Financial Officer Steve Liggins, leveraging his financial acumen and a notable career spanning over 17 years, will oversee finance and accounting functions, ensuring fiscal stewardship within the organization.
Stacey Dolden, entrusted with the role of Chief People Officer, will spearhead the company’s intensified focus on enhancing the employee experience. As a certified Senior Professional in Human Resources with 24 years of experience, Ms. Dolden is committed to nurturing a best-in-class workplace, with a particular emphasis on fostering effective career pathways for all employees.
Jay Hatho, SCS’ Chief Information and Chief Technology Officer, will lead the development and implementation of innovative technological solutions within SCS, as well as for our clients. With over 25 years of experience, Mr. Hatho is dedicated to ensuring SCS remains at the forefront of technological advancement, thereby enhancing client service delivery and fostering employee-owner collaboration.
Nathan Hamm, in his capacity as Senior Vice President, will focus on driving strategic initiatives aimed at expanding the company’s service platform and offering creative solutions to clients’ environmental and business challenges. With over 26 years of industry experience, Mr. Hamm brings a wealth of knowledge and expertise across various service sectors within the engineering consulting arena.
The appointment of this new executive leadership team underscores SCS Engineers’ unwavering commitment to excellence, innovation, and client satisfaction. With their collective expertise and vision, SCS Engineers is poised to embark on an exciting new chapter of growth and success.
About SCS Engineers: SCS Engineers is a renowned environmental engineering firm dedicated to providing innovative and sustainable solutions to complex environmental challenges. With a steadfast commitment to excellence and client satisfaction, SCS Engineers has emerged as a trusted industry leader, serving clients across various sectors with integrity, expertise, and unparalleled professionalism.
EPA is issuing a new Clean Water Act (CWA) rule that requires certain facilities to prepare and implement facility response plans (FRP) that address the storage and worst-case discharge of hazardous substances (HSs).
According to the EPA, the facility response plan requirements apply to facilities that could reasonably be expected to cause substantial environmental harm based on their location. These include facilities with a maximum onsite quantity of a CWA hazardous substance that meets or exceeds threshold quantities, located within a 0.5-mile radius of navigable water or conveyance to navigable water, and meets one or more substantial harm criteria.
From EPA’s site: See CWA Hazardous Substance Facility Response Plan Applicability.
Facilities may be identified as posing substantial harm either through a self-identification process or a process whereby EPA Regional Administrators may assess facilities on a case-by-case basis and, if appropriate, require a facility to develop a response plan based on, among other things, concerns related to potential impacts of a worst-case discharge on communities with environmental justice concerns.
The CWA hazardous substance FRP requirements apply to facilities that:
EPA estimates that the rule will impact 12,618 facilities, including 7,264 estimated for rule familiarization and the Substantial Harm Certification Form, and 5,354 facilities further developing and maintaining FRPs under the final rule.
Facilities will be required to submit FRPs to the EPA within three years of the new rule’s effective date.
Here is the link for the EPA webpage: https://www.epa.gov/hazardous-substance-spills-planning-regulations/final-rulemaking-clean-water-act-hazardous
And here is the link for the pre-publication of the Federal Register notice for the new rule: https://www.epa.gov/system/files/documents/2024-03/cwa-hs-frp-final-rule-pre-publication_.pdf
Using a computer, iPad, or cell phone landfills and renewable energy plants can diagnose and balance wellfields faster and more efficiently. Office and field stay in touch 24/7, shortening compliance time. This week, SCS Field Services demonstrates how it works – in a monthly educational forum open to landfill and landfill gas management, renewable energy staff, and agencies.
Liquid Level Diagram Report to Improve LFG Extraction – By viewing the real-time relationships between liquids accumulated in landfill gas extraction wells and the perforated portion of the wells, your data shows how liquids impact well perforations, which can reduce, restrict, or prohibit landfill gas extraction. You’ll see well profiles, where the liquids are, if they’re potentially impacting perforations, how much solid pipe is on the well, and where the current liquid elevation is within the well in relation to the amount of perforated pipe.
SCS MobileTools – is a portable version of SCS DataServices, which provides data access while the technician conducts field measurements in the wellfield. Technicians can access their historical wellfield data from their smartphone or smart tablet. As the technician progresses through monitoring, the project team gets updates while the data is being collected in the field. SCS MobileTools uploads the data into DataServices, generating updated information like the Liquid Level Diagram Report for the project team.
6-Month Wellfield Data Review Report to Gauge Actions to Results – The Report illustrates wellfield performance over the previous six-month period for the different parameters that owners and operators value. Wellfield trends and progress show at a glance if methane is up, oxygen is down, the balance gas is down, or the flow per well is up. Are you losing the vacuum on any wells? It also provides a visual snapshot assessment of your most current month’s data and is useful to demonstrate if field actions are getting the desired results.
Exceedance Tracking and Exceedance Manager for Compliance Actions – Addressing NSPS exceedances or similar issues is already available in SCS DataServices. The Exceedance Manager details closeouts and actions for state and federal compliance reporting. As your staff works, it builds a record for responding to NSPS, OOO, XXX, and NESHAP Quad A reporting.
So whether you use an air consultant on an individual facility or manage multiple facilities, your staff can get the documented reason of how an exceedance was closed up and exactly when meeting crucial timelines of five days, 15 days, 60 days, 75 days, and 120 days. It provides a good compliance record for the supporting air consultant and regulatory authority.
SCS Surface Emissions Module – SCS has added a Surface Emissions module for uploading, reviewing, and tracking SEM exceedances. Having all of your wellfield and NSPS compliance data in one place provides landfill compliance personnel with peace of mind that all of the data has been captured and is being stored and managed in a single location, while providing easy access to other pertinent wellfield data. We’ll also show you how the Surface Emissions Monitoring features with an Exceedance Manager document NSPS exceedance tracking and cleanup for surface emissions monitoring events.
Reduce labor hours and shorten compliance timelines by reviewing wellfield data from your GCCS. Our SCS Field Services panelists demonstrate how to transform wellfield data into critical and actionable information.
Liquid Level Diagram Report to Improve LFG Extraction – By viewing the real-time relationships between liquids accumulated in landfill gas extraction wells and the perforated portion of the wells, your data shows how liquids impact well perforations, which can reduce, restrict, or prohibit landfill gas extraction. You’ll see well profiles, where the liquids are, and if they’re potentially impacting perforations, how much solid pipe is on the well, and where the current liquid elevation is within the well in relation to the amount of perforated pipe.
SCS MobileTools – is a portable version of SCS DataServices, which provides data access while the technician conducts field measurements in the wellfield. Technicians can access their historical wellfield data from their smartphone or smart tablet. As the technician progresses through monitoring, the project team gets updates while the data is being collected in the field. SCS MobileTools uploads the data into DataServices, generating updated information like the Liquid Level Diagram Report for the project team.
6-Month Wellfield Data Review Report to Gauge Actions to Results – The Report illustrates wellfield performance over the previous six-month period for the different parameters that owners and operators value. Wellfield trends and progress show at a glance if methane is up, oxygen is down, the balance gas is down, or the flow per well is up. Are you losing the vacuum on any wells? It also provides a visual snapshot assessment of your most current month’s data and is useful to demonstrate if field actions are getting the desired results.
Exceedance Tracking and Exceedance Manager for Compliance Actions – Addressing NSPS exceedances or similar issues is already available in SCS DataServices. The Exceedance Manager details closeouts and actions for state and federal compliance reporting. As your staff works, it builds a record for responding to NSPS, OOO, XXX, and NESHAP Quad A reporting.
So whether you use an air consultant on an individual facility or manage multiple facilities, your staff can get the documented reason of how an exceedance was closed up and exactly when meeting crucial timelines of five days, 15 days, 60 days, 75 days, and 120 days. It provides a good compliance record for the supporting air consultant and regulatory authority.
SCS Surface Emissions Module – SCS has added a Surface Emissions module for uploading, reviewing, and tracking SEM exceedances. Having all of your wellfield and NSPS compliance data in one place provides landfill compliance personnel with peace of mind that all of the data has been captured and is being stored and managed in a single location, while providing easy access to other pertinent wellfield data. We’ll also show you how the Surface Emissions Monitoring features with an Exceedance Manager document NSPS exceedance tracking and cleanup for surface emissions monitoring events.
When it comes to running your facility, there are many things you are constantly considering and managing. The list can seem never-ending, from worker safety to product supply chain and staying staffed. The last thing you want is a surprise visit from your local, state, or federal regulator that goes badly. Here are five things to look for to avoid unpleasant surprises to ensure your aboveground storage tanks (ASTs) are inspection-ready.
Make sure that your AST secondary containment is empty. The secondary containment design is to prevent spills and leaks from reaching the environment, so the containment should be emptied after each rain, once the contents are verified to be only stormwater and free of sheen. Also, regular cleaning of the secondary containment of algae and debris build-up avoids potential issues during inspections.
A locked containment drain valve is essential to demonstrate compliance with your visiting regulator. The locked valve will prevent any unauthorized connections, which can lead to potential environmental hazards. For instance, during my time at the Arkansas Department of Environmental Quality, a facility was fined because an untrained maintenance technician had drained an overflowing paint tank to a nearby stream via a garden hose connected to the secondary containment valve. By locking your containment drain valve, you mitigate risks and show your commitment to environmental safety.
Ensure you update staff on spill response training. Proper training is key to handling spills efficiently and safely. By providing your employees with the necessary knowledge and skills, you can create a proactive culture of environmental responsibility within your organization.
Have a fully stocked spill kit next to your tank and other likely spill points. Accidents happen, and it is crucial to be prepared with the proper supplies for potential spills. Having a spill kit ready and available can help you respond quickly and effectively, minimizing any environmental impact. Your SPCC Plan should include a list of spill kit locations, the contents of each spill kit, and a schedule for inspection of these kits. Following your SPCC Plan’s inspection schedule and forms will help you check and replenish the spill kit to ensure they are always ready for you when needed.
Check that your AST safety features are in good working order. Your tanks should have functioning fill gauges and alarms. These devices are essential for monitoring the contents’ level and preventing overfilling, which can lead to spills and other hazardous situations. Another crucial aspect to consider is the functioning of the emergency vent. Common issues with emergency vents include manway bolts that are secured too tightly without any slack, painted-over vents, or busted heat latches that can allow water to enter.
Regularly inspect and maintain all of these to ensure their proper functioning – they play vital roles in preventing spills and other potential tank failures. Remember to keep a copy of all your inspection forms to show your visiting regulator – it gives agencies confidence in your ability to protect the environment.
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Being prepared for tank inspections is essential for any facility managing ASTs. Following the recommendations above demonstrates your commitment to worker and community safety, product supply chain integrity, and environmental responsibility.
Additional Resources:
About the Author: Benjamin Reynolds is a Senior Project Professional in our Little Rock, Arkansas, office. He is experienced in Spill Prevention, Control, and Countermeasures (SPCC) Plans, Tank Assessments, Storm Water Pollution Prevention Plans (SWPPPs), and Phase I and Phase II Environmental Site Assessments. He is a Professional Engineer licensed in Arkansas, Oklahoma, Tennessee, and Florida.
Reach out to Ben at or on LinkedIn.
Thirty years ago this week, on February 11, 1994, then-President Bill Clinton signed Executive Order 12898, Federal Actions To Address Environmental Justice In Minority Populations and Low-Income Populations. The Executive Order marked the first government action on environmental justice and an important part of the environmental justice movement.
Executive Order 12898 directed government agencies (particularly the US Environmental Protection Agency or EPA) to develop plans and strategies to help address any disproportionally high and adverse human health or environmental effects of their programs on minority and low-income populations.
Redlining
Executive Order 12898 responded to changes that began during the Civil Rights Movement. Minority groups, particularly African Americans, began to object to discriminatory practices long entrenched in government policy. The most notable being the practice of “redlining.” In the 1930s, the United States worked to end the Great Depression. To encourage banks to lend money for mortgages, the federal government began insuring or underwriting housing loans; however, government inspectors designated African American and immigrant neighborhoods uninsurable, and the residents could not obtain loans. Landlords were not vested in maintaining their properties, and much of the housing became sub-standard. Inexpensive swaths of property inside city limits encouraged businesses and industry to purchase and develop this land, increasing pollution from traffic, industrial processes, and edging out small businesses.
Solid Waste Disposal
In 1979, Texas Southern University sociologist Robert D Bullard, Ph.D., studied solid waste disposal sites in Houston, Texas, for a class-action lawsuit seeking to prevent the siting of a new landfill near the Northwood Manner subdivision, a Black, middle-class neighborhood. Dr. Bullard’s work found that five out of five city-owned landfills and six of the eight city-owned incinerators were in Black neighborhoods. While the case was lost, it increased awareness of environmental issues in minority communities.
Hazardous Waste
In 1982, North Carolina sited a toxic waste landfill in Afton, a rural Black community in Warren County, to hold 40,000 cubic tons of polychlorinated biphenyls from illegally dumped contaminated soil along state roads and highways. For six weeks, residents and activists protested, marking what many consider the birth of the Environmental Justice Movement. The contaminated soil ultimately went into the landfill and eventually caused a release that cost the state $18 million to clean up.
In subsequent years, the movement began to attract the attention of public officials. In 1983, the US General Accounting Office Study released the location of Hazardous Waste Landfills. It took another seven years before the federal government began to consider policy change when, in 1990, the Environmental Equity Workgroup was formed to gather information and make recommendations to the government, leading to the creation of EO 12898.
Gaining Traction
Throughout the 2010s, the EPA published a series of plans and guidance documents, including the public release of EJScreen in 2014, the Technical Guidance for Assessing Environmental Justice in Regulatory Analysis, and the Environmental Justice Research Roadmap in 2016.
In 2022, EPA Administrator Michael Regan traveled to Warren County, North Carolina, to officially create the new Office of Environmental Justice and External Civil Rights. Several people involved in the 1982 PCB protests were in attendance.
Today’s Protections
State and federal environmental permitting now requires Environmental Justice (EJ) reviews. Fortunately, most, if not all, of the necessary EJ review data is publicly available online. For example, environmental professionals use EPA’s EJScreen regularly for EJ reviews, and many states have developed or are developing interactive data tools.
In the past decade, the US Census Bureau developed a searchable, interactive online database, and in 2021, the US Council of Environmental Quality released the Climate and Economic Justice Screening Tool. Other online data sources include the Centers for Disease Control and Prevention, the US Department of the Interior Bureau of Indian Affairs, and individual state, county, and tribal organizations. These data not only allow us to meet permitting requirements and identify community challenges but also help guide outreach and facilitate communication with stakeholders.
On April 21, 2023, President Biden signed Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice for All, expanding upon the direction and intent of EO 12898. Thirty years on, we can see the effects of EO 12898 on incorporating environmental justice into environmental policy so that all people can have a healthier, safer, greener place to live, work, and play.
Meet Candy Elliott, PG. Candy brings her scientific perspective and experience as an Environmental Justice expert to support disadvantaged communities marginalized by underinvestment and overburdened by pollution. She helps make impactful changes through her work experience with site characterization, site assessment and remediation, brownfields, groundwater monitoring and reporting, groundwater corrective action, mining, and other industrial facility or site development projects.
These sites often provide excellent locations with existing infrastructure and transportation but with the need to clean the soil or, in some cases, mitigate other potential health risks to emerge as excellent opportunities for economic revitalization efforts and for creating green spaces.
Proposed PFAS Hazardous Constituents Under RCRA
The Environmental Protection Agency (EPA) is proposing to amend its regulation under the Resource Conservation and Recovery Act (RCRA) by adding nine specific per-and polyfluoroalkyl substances (PFAS), their salts, and their structural isomers to its list of hazardous constituents. EPA’s criteria for listing substances as hazardous constituents under RCRA require that they have been shown in scientific studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms.
Entities potentially affected by this action include hazardous waste treatment, storage, and disposal facilities (TSDFs) with solid waste management units (SWMUs) that have released or could release any of the PFAS proposed to be listed as RCRA hazardous constituents. EPA has identified 1,740 such facilities, which could be subject to additional corrective action requirements (under RCRA section 3004(u) and (v)) to address releases not already subject to corrective action under EPA’s corrective action regulations.
The nine PFAS and common uses are as follows:
EPA will collect comments on this PFAS to RCRA’s hazardous constituents proposal for 60 days once published in the Federal Register. Read a prepublication copy of this proposal.
Submit your comments on the Federal eRulemaking Portal: https://www.regulations.gov and identified by Docket ID No. EPA-HQ-OLEM-2023-0278.
As a result of this proposed rule, if finalized, when imposing corrective action requirements at a facility, these PFAS would be among the hazardous constituents expressly identified for consideration in RCRA facility assessments and, where necessary, further investigation and cleanup through the RCRA corrective action process at RCRA treatment, storage, and disposal facilities. Contact SCS Engineers for guidance about your facility at .
Additional Resources:
For additional information regarding EPA’s proposed RCRA PFAS rules, see:
The U.S. Environmental Protection Agency announces it is lowering recommended screening levels and strengthening guidance for investigating and cleaning up lead-contaminated soil in residential areas. This is the second time that EPA has reduced the screening value for lead in soil at residential properties. The original screening level range of 500 to 1,000 parts per million (ppm) was established in 1989. The original screening value was reduced to 400 ppm in 1994.
As a result of lower screening levels, EPA expects to investigate more residential properties for potential cleanup under the Superfund law and the Resource Conservation and Recovery Act. Today’s action delivers on the Biden-Harris Administration’s ongoing commitment to protect communities from lead poisoning, particularly in disadvantaged and overburdened communities facing multiple sources of lead exposure, advancing President Biden’s environmental justice goals.
EPA is lowering the screening level for lead in soil at residential properties from 400 ppm to 200 ppm. At residential properties with multiple sources of lead exposure, EPA will generally use 100 ppm as the screening level. Screening levels are not cleanup standards. EPA aims to help site teams make site-specific cleanup decisions to protect nearby communities; EPA makes cleanup decisions specific to each site, using site-specific factors, including risk factors and community input that can vary from site to site.
While the guidance goes into effect immediately, EPA welcomes feedback from the public for any future updates to the guidance. Please submit written feedback on the guidance in the public docket (Docket ID: EPA-HQ-OLEM-2023-0664) for 60 days, from January 17, 2024, to March 17, 2024.
For more information or implications for a site, visit the updated guidance webpage, or contact an SCS environmental professional in your state.
