The California State Water Resource Control Board ordered the closure of single-walled underground storage tank systems and single-walled product piping at all facilities. The deadline to remove all single-walled underground storage tanks and single-walled piping is December 31, 2025.
Underground storage tanks recognized as out of compliance will be subject to enforcement actions beginning January 1, 2026.
Grants and loans may be available to eligible small business owners who want to remove, replace, or upgrade USTs.
The professionals at SCS Engineers are ready to assist with closing and removing underground storage tanks. SCS Engineers provides turnkey services, including licensed tank removal contractors, consulting services for agency compliance, and California-certified analytical testing laboratories.
SCS’s National UST Practice Covers:
Contact a UST professional at SCS Engineers today at ; for service in California, click here.
For information on the EPA Federal program, click here.
Additional California Code Information:
Health and Safety Code – HSC
DIVISION 20. MISCELLANEOUS HEALTH AND SAFETY PROVISIONS [24000 – 26275] ( Division 20 enacted by Stats. 1939, Ch. 60. )
CHAPTER 6.7. Underground Storage of Hazardous Substances [25280 – 25299.8] ( Chapter 6.7 added by Stats. 1983, Ch. 1046, Sec. 3. )
25292.05.
(a) On or before December 31, 2025, the owner or operator of an underground storage tank shall permanently close that underground storage tank in accordance with Section 25298 and the regulations adopted pursuant to that section, if the underground storage tank meets either of the following conditions:
(1) The underground storage tank is designed and constructed in accordance with paragraph (7) of subdivision (a) of Section 25291 and does not meet the requirements of paragraphs (1) to (6), inclusive, of subdivision (a) of Section 25291.
(2) The underground storage tank was installed on or before January 1, 1984, and does not meet the requirements of paragraphs (1) to (6), inclusive, of subdivision (a) of Section 25291.
(b) Notwithstanding subdivision (a), the board may adopt regulations to require the owner or operator of an underground storage tank to permanently close that underground storage tank before December 31, 2025, in accordance with Section 25298 and the regulations adopted pursuant to that section, if the underground storage tank meets the conditions specified in either paragraph (1) or (2) of subdivision (a) and the underground storage tank poses a high threat to water quality or public health. The board shall consult with stakeholders before adopting regulations pursuant to this subdivision.
(Added by Stats. 2014, Ch. 547, Sec. 1. (SB 445) Effective September 25, 2014.)
The commercial office sector in cities around the country is facing unprecedented challenges due to high vacancy rates that have been driven by factors including the work-from-home trend and the highest interest rates in almost 20 years. SCS Engineers worked with a panel of experts in the fields of economics, law, architecture, property development, and building sciences to explore the opportunities and challenges of the adaptive reuse of existing commercial buildings into new uses such as residential ones.
The resulting article provides valuable solutions and insight and can be found in Western Real Estate Business at this link: Western Real Estate Business April 2024 Page 20
SCS Engineers provides environmental consulting services for the real estate industry, including asbestos and lead-based paint surveys that are often needed before any building renovations or adaptive reuse. Once asbestos-containing materials or lead-based paint is identified at the building site, abatement activities to remove or mitigate the risks from these materials take place.
SCS monitors these abatement activities with air monitoring and inspections to make sure the removal is conducted according to regulations, and to protect workers and members of the surrounding community from exposure to these harmful chemicals; protecting and rehabilitating these spaces for re-occupancy.
About the Author: Cristobal Ramirez, CAC, is an environmental professional with over 20 years of experience in the United States, Canada, and Mexico. As a bilingual speaker in Spanish and English, he provides environmental services for clients in the United States and Mexico. His experience includes completing over 2,000 environmental assessments and implementing remediation activities for contaminated properties. He is an expert in performing Environmental Site Assessments (ESAs) according to U.S. EPA 40 CFR, Part 312, Standards and Practices for All Appropriate Inquiry (AAI); and Final Rule and American Society for Testing and Materials (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process E 1527-13. In addition to ESA services, he conducts subsurface investigations, health and safety plans, community health and safety plans, geophysical surveys, soil vapor surveys, health risk assessments, remediation conceptual cost estimates, property mitigation plans, and soil reuse plans.
Additional Information:
Jennifer Taylor has been promoted to Project Director at SCS Engineers. Her exceptional leadership skills have been instrumental in managing a multidisciplinary team and exceeding client expectations. In her new role, she will also oversee the liquids management team in KC, further expanding her leadership responsibilities.
Jenny’s passion for mentoring staff and building client relationships makes her a valuable asset to our team.
Outside work, she enjoys camping in southern Missouri and exploring the Ozark trails on ATVs with her family.
Congratulations, Jenny!
SCS is thrilled to announce the promotion of Morgan Sykes to the esteemed position of Senior Project Manager. Known for his exceptional engineering prowess and dedication to finding innovative solutions for complex projects, Morgan has been a valuable asset to our team since joining SCS in October 2021. His leadership on various engineering-heavy design projects, including transfer stations, has been instrumental in our continued success.
Not only is Morgan a skilled project manager, but he also excels as a mentor, guiding young engineers in the principles of civil engineering design. His diverse talents have made a significant impact on SCS, particularly in the Energy and Construction sectors.
Originally from a ranch in southern Colorado, Morgan’s journey led him to the Colorado School of Mines and eventually to his role as a City Engineer, where he met his wife Tess, a journalist covering City activities. Together, they are proud parents to three children and are currently immersed in planning their eldest’s wedding, attending swim meets, and cheering loudly at soccer games.
Please join us in congratulating Morgan on this well-deserved promotion. We look forward to witnessing his continued success and contributions to our organization.
Please contact SCS Engineers if you are interested in working with our clients to make the world safer and cleaner!
Since joining SCS in February 2023, Tim Buelow has quickly established himself as a highly respected and trusted advisor within the industry. Known for his thorough evaluation of complex scenarios and ability to consider multiple perspectives, Tim has successfully led unique projects for clients in Iowa. Clients value Tim’s technical expertise and rely on him to provide innovative solutions to their most pressing issues.
Internally, Tim is known for his humility and collaborative nature, always willing to share his knowledge and mentor colleagues with his client-first approach. In recognition of his outstanding contributions, Tim has been promoted to Project Advisor, where he will continue to deliver exceptional service to clients at a high technical level.
Outside of work, Tim celebrates important milestones in his personal life, including 20 years of marriage to his wife Heidi and raising two sons. In his free time, Tim enjoys quality time with his family and sharing his passion for music by playing trumpet and euphonium alongside his sons at local churches.
We are thrilled to announce Bret Clements’s promotion to Project Director at SCS! Since 2008, Bret has showcased exceptional leadership, driving the success of key client projects and fostering growth within our engineering team. His dedication and hard work have been pivotal in completing numerous Renewable Natural Gas projects.
Bret is passionate about developing our staff in Overland Park and ensuring their professional growth. His business acumen and analytical skills are vital in addressing business challenges and driving continued success.
Congratulations, Bret, on your well-deserved promotion!
Kevin Jensen has been promoted to the role of Project Manager at SCS. Since joining our team in February 2023, Kevin has consistently demonstrated exceptional dedication to our Iowa industrial clients. His commitment to delivering projects on time and within budget has earned him a reputation as a trusted advisor in compliance and engineering services. Kevin’s proactive approach to client advocacy and his ability to keep our internal team aligned with project goals have been instrumental in our continued success.
A native of north-central Iowa and a graduate of Iowa State University, Kevin brings a wealth of experience from his time at John Deere and ADM before transitioning to consulting in 2016. Outside of work, Kevin enjoys relaxing on his deck, listening to music with his fiancée, and tending to their lively menagerie of two dogs, ducks, and chickens.
Please join us in congratulating Kevin on his well-deserved promotion. We are excited to see where his leadership takes us in the future!
Please contact SCS Engineers if you are interested in working with our clients to make the world safer and cleaner!
SCS Engineers is working to complete a regional assessment of rare earth elements and other critical mineral (CM) opportunities within parts of Iowa, Kansas, Missouri, Nebraska, Oklahoma, and the Osage Nation as part of a multi-state effort led by the Kansas Geological Survey (Critical Minerals in Coaly Strata of the Cherokee-Forest City Basin | netl.doe.gov).
This project is part of a multi-year Carbon Ore, Rare Earth, and Critical Minerals (CORE-CM, FOA-0002364) initiative funded by the U.S. Department of Energy to address all aspects of establishing a domestic critical mineral supply chain and the reuse of high-value, nonfuel, carbon-based resources. SCS Engineers is working with stakeholders within the Cherokee-Forest City Basin to develop assessments and strategies for waste stream reuse, infrastructural capacities and capabilities, technology development, outreach, and public-private partnerships.
The work from this project will identify information, technology, and infrastructure gaps that will need to be addressed to develop economic opportunities for critical mineral production, refining, and utilization specific to the Cherokee-Forest City Basin. These assessments may be utilized in future Phase II and Phase III components of the planned CORE-CM program for potential implementation within the region.
This study along with others have the potential to reduce U.S. reliance on foreign sources of critical minerals that are essential for electronics, renewable energy technologies, advanced manufacturing, and defense applications. It could also provide coal mines with additional markets for their product, transforming coal from something that is burned into a 21st century feedstock for advanced manufacturing.
Department of Energy Program Goals and Funding
Some research efforts are focused on unconventional and secondary feedstocks, such as coal and coal refuse, coal fly ash, acid mine drainage, mine waste, oil- and gas-produced waters, and brines extracted as part of carbon sequestration efforts. These feedstocks are known to contain elevated concentrations of CMMs, potentially in economic quantities, however their occurrence and distribution is not well constrained.
In April 2024, the U.S. Department of Energy’s (DOE) Office of Fossil Energy and Carbon Management (FECM) announced up to $60 million in funding to create regional teams to support the development of critical mineral and materials supply chains and novel high-value, nonfuel carbon-based products from unconventional and secondary feedstocks, such as coal and coal by-products, effluent waters from oil and natural gas development and production, and acid mine drainage. Realizing the critical mineral and materials potential in these feedstocks would enable the United States to rebuild a domestic supply chain for rare earth elements and other critical minerals and materials—which support high-tech manufacturing and the production of components for clean energy technologies—and reduce our dependence on international supply chains.
The funding period is now closed but projects selected under this funding opportunity will be announced in October and will continue the work of DOE’s CORE-CM Initiative, and expand the focus from the basin scale to a larger, regional scale. CORE-CM projects will develop and implement strategies that enable each specific basin to realize its full economic potential for producing REE, CM and high-value, nonfuel, carbon-based products from basin-contained resources.
Learn More Here:
Speak with our Author, Dr. Jon Yang, Senior Project Professional. Dr. Yang is a geochemist/engineer experienced in identifying and developing solutions to geochemical questions utilizing skillsets in experimental design, analytical chemistry, geochemical modelling, geological characterization, and engineering process design. He is also experienced in advancing research from early technology readiness levels along pathways for potential commercialization and/or technological transfer.
The U.S. Environmental Protection Agency and the U.S. Department of Energy announced on June 21st that applications are open for $850 million in federal funding for projects that will help monitor, measure, quantify, and reduce methane emissions from the oil and gas sectors. The funding aims to specifically help small oil and natural gas operators reduce methane emissions and transition to available methane emissions reduction technologies, while also supporting partnerships that improve emissions measurement and provide accurate, transparent data to impacted communities.
A competitive solicitation for this funding will enable a broad range of eligible U.S. entities to apply, including industry, academia, non-governmental organizations, Tribes, and state and local governments. This funding opportunity is expected to achieve measurable outcomes for skilled workforce training, community involvement, and environmental justice. Funding applicants are required to submit Community Benefits Plans to demonstrate meaningful engagement with and tangible benefits to the communities in which the proposed projects will be located. These plans must provide details on the applicant’s commitments to community and labor engagement, quality job creation, diversity, equity, inclusion and accessibility, and benefits to disadvantaged communities.
The primary objectives of this funding opportunity announcement are to:
1. Help small operators significantly reduce methane emissions from oil and natural gas operations, using commercially available technology solutions for methane emissions monitoring, measurement, quantification, and mitigation.
2. Accelerate the repair of methane leaks from low-producing wells and the deployment of early-commercial technology solutions to reduce methane emissions from new and existing equipment such as natural gas compressors, gas-fueled engines, associated gas flares, liquids unloading operations, handling of produced water and other equipment leakage.
3. Improve communities’ access to empirical data and participation in monitoring through multiple installations of monitoring and measurement technologies while establishing collaborative relationships between equipment providers and communities.
4. Enhance the detection and measurement of methane emissions from oil and gas operations at regional scale, while ensuring nationwide data consistency through the creation of collaborative partnerships. These partnerships will span the country’s oil and gas-producing regions and draw in oil and natural gas owners and operators, universities, environmental justice organizations, community leaders, unions, technology developers, Tribes, state regulatory agencies, non-governmental research organizations, federally funded research and development centers, and DOE’s National Laboratories.
Additional Resources:
1. Read more details of this funding opportunity.
3.GHG Monitoring, Control, Verification, Reporting
In March 2024, the EPA launched a new Office of Climate Adaptation and Sustainability that supports efforts to build resilience to climate change and promote sustainability in support of the agency’s mission and its partnerships. Federal agencies have been making progress in efforts to build adaptive capacity and resilience across federal operations.
Today’s publication of EPA’s 2024-2027 Climate Adaptation Plan is part of a coordinated release of more than twenty federal agencies’ climate adaptation plans that highlight efforts across the federal government. The Plan describes agency actions to address the impacts of climate change and help build a more climate-resilient nation. The plan expands the agency’s efforts to ensure its programs, facilities, workforce, and operations are increasingly resilient to climate change impacts.
Highlights from EPA’s 2024-2027 Climate Adaptation Plan are included below.
Fostering a Climate-Ready Workforce – The EPA is building a climate-literate workforce through ongoing education and training to ensure staff are equipped with an understanding of projected climate impacts, the vulnerability of EPA programs to these impacts, and adaptation approaches. One example is the agency-wide Climate Conversations webinar series helping to build a community of practice and encourages peer-to-peer sharing of experiences.
Building Facility Resilience – EPA is continuing to conduct facility resiliency assessments to identify vulnerabilities to the impacts of climate change and make recommendations to increase facility resilience.
Developing Climate-Resilient Supply Chains – EPA has included an assessment of climate hazard risk as part of its overall Agency Supply Chain Risk Management plan. The agency plans to conduct supply chain risk assessments under the Program Management Improvement Accountability Act and the Federal Information Technology Acquisition Reform Act in fiscal year 2024.
Integrating Climate Resilience into External Funding Opportunities – EPA is modernizing its financial assistance programs to encourage investments by communities and Tribes that are more resilient in an era of climate change. To support this effort, the EPA launched an internal Climate-Resilient Investments Clearinghouse website to help managers of financial assistance programs incorporate climate adaptation and resilience considerations in the investment decisions the EPA makes each day.
Applying Climate Data and Tools to Decision Making – EPA is equipping communities and the recipients of financial resources with the tools, data, information, and technical support they need to assess their climate risks and develop the climate-resilience solutions most appropriate for them.
Integrating Climate Adaptation into Rulemaking Processes – EPA is integrating climate adaptation into its rulemaking processes where appropriate and in keeping with our statutory authorities to ensure they are effective even as the climate changes. For example, on March 14, 2024, EPA finalized a rule requiring a broad array of facilities that manage hazardous materials to develop response plans to prepare for the largest foreseeable discharges in adverse weather conditions, including more extreme weather conditions expected as the climate changes. EPA is also committed to applying climate change and environmental justice policy principles through National Environmental Policy Act reviews.
Additional Climate Adaption Resources:
FREE LIVE WEBINAR & Q/A
We hope you can join SCS Engineers for our next client webinar. Feel free to share this invitation with others who may be interested!
Live on Thursday, July 18, 2024, at 2:00 pm Eastern Time for 1 hour
You will receive a unique Zoom link to join the event. SCS Engineers never shares or sells your information.
The amount of organic waste produced in North America burdens waste management systems and, when placed in landfills, creates methane and uses up valuable landfill space or gets incinerated. In response, municipalities and private companies are diverting organic wastes from landfills and recycling them into high-quality compost. While theoretically simple, there is a logical series of processes and parameters, some specific to each site, to reach the goals communities and solid waste management organizations hope to achieve.
As with all SCS Client Webinars, we’re here to answer your questions throughout the forum and afterward. Our panelists take us through the Southeastern Connecticut Regional Resources Recovery Authority’s (SCRRRA) proposed compost facility. This facility reflects a well-thought-out strategy that leverages advanced composting technologies and engineering practices to create a sustainable and economically viable operation.
Join SCRRRA Executive Director David Aldridge and Professional Engineer Greg McCarron as they step through the Design, Siting, & Permitting of SCRRRA’s Municipal Compost Facility. The live educational presentation is on Thursday, July 18th, at 2:00 pm (Eastern) and includes an open Q&A forum.
Recommended for These Audiences
This educational, non-commercial webinar with Q&A is free and open to all who want to learn more about composting programs. We recommend this month’s discussion for private and public solid waste management, municipal government, and agency staff looking to begin or refine a composting program as part of their waste management strategy. It also provides insight to processors, compostable product manufacturers, haulers, citizens, retailers, and businesses interested in reusing what was once considered waste into a valuable commodity with environmental benefits.
A Certificate of Attendance is available on request following the live session.
You will receive a unique link to join the event. Do not share the link. SCS Engineers never shares or sells your information.
CAN’T MAKE THE LIVE SESSION? NO PROBLEM.
On October 16, 2023, US EPA’s Integrated Risk Information System (IRIS) Program released an updated toxicological review for inorganic arsenic, which includes proposed changes to the toxicity factors. Many federal, state, and local agencies use IRIS toxicity factors to assess environmental risk and establish risk-based environmental standards.
For example, the State of Florida and Miami-Dade County derived their direct exposure Soil Cleanup Target Levels (SCTLs) using these toxicity values, per Chapter 62-777, Florida Administrative Code and Chapter 24-44(2), Code of Miami-Dade County. If adopted, the updated toxicity values will lead to lower arsenic cleanup standards and, as a result, will significantly impact the assessment and remediation of contaminated sites throughout Florida.
Toxicity Factors Under Review and Potential Impact
The specific toxicity factors under review are the oral cancer slope factor (CSFo) and the oral reference dose (RfDo). In the current draft of the updated assessment, the IRIS Program has proposed a CSFo of 53 mg/kg/day for combined cancer risk and an overall RfDo of 0.031 µg/kg/day to protect against all noncancer adverse health effects associated with inorganic arsenic across all life stages.
To illustrate the significance of these updates, we used the proposed CSFo to re-calculate the State of Florida SCTLs. The resulting SCTLs would decrease from the current Residential SCTL of 2.1 mg/kg to 0.1 mg/kg and from the current Commercial/Industrial SCTL of 12 mg/kg to 0.4 mg/kg (assuming all other exposure factors remain the same). If the proposed changes to the toxicity factors are approved, remediation in Florida could feel the impact. An environmental engineer/consultant knowledgeable in due diligence, background assessments, and risk assessment/management can help you navigate these changing regulatory requirements.
Rulemaking Process At Midpoint
The following links will direct you to the proposed toxicological review, a summary of the comments received during the public comment/peer review process, and information on the general assessment review process:
Given the potential impact on the cleanup standards, it is important to remain current with this updated assessment’s development and keep our clients informed of the potential changes. EPA is reviewing over a hundred comments received on the October 2023 draft IRIS Toxicological Review of Inorganic Arsenic. We understand that the final document’s projected release date will be announced once the Science Advisory Board delivers its peer-reviewed report. We’ll keep you informed.
Additional Resources:
About Arsenic
Arsenic is a naturally occurring trace element in the environment. It is in geological formations, and levels in soil can range from 1–40 milligrams per kilogram (mg/kg). Erosion, leaching, and some human activities can increase arsenic levels in soil. Arsenical pesticides were once commonly used in agriculture to maintain turf (e.g., golf courses, parks, etc.) and treat wood. While their use has been significantly restricted, residual concentrations can still be detected during an environmental site audit/assessment.
Land Remediation and Brownfields: Information, case studies, grants, and educational materials.
Meet our Authors: Environmental Scientist Anabel Rodriguez Garcia and Lisa Smith, a principal technical advisor and expert in risk-based corrective action.
New Regulations Impact Environmental Assessments
The Environmental Protection Agency (EPA) recently classified perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as the “Superfund” law. This new regulation will significantly affect real estate transactions, introducing stringent reporting requirements and complicating liability and insurance matters related to polyfluoroalkyl substances (PFAS) contamination.
Previously, Phase I property investigations did not have to consider evidence of releases of PFOA and PFOS. However, some did as a business risk similar to asbestos shingles or lead paint on woodwork. Now, environmental professionals must identify and report any releases or likely releases of these hazardous substances, which, in some cases, lead to more Phase II environmental sampling and remediation if significant contamination is confirmed.
Undertaking all appropriate inquiries—a Phase I site assessment—is one of several requirements for real estate purchasers to qualify for Superfund landowner liability protections. Others include complying with any reporting obligations and taking reasonable steps with respect to known contamination. Experienced consultants can help address the technical aspects of these requirements, typically working with experienced attorneys to address the legal aspects.
PFOA and PFOS, widely used in various industries due to their heat, water, and oil resistance, can contaminate commercial or industrial properties from various sources, including firefighting foams and PFAS manufacturing plants. During Phase I environmental assessments, evaluating the property’s historical and current use and nearby properties is crucial to identify potential PFAS sources. This analysis guides further investigations, such as Phase II assessments, where specific sampling and analysis can verify PFAS presence and concentration.
The primary mechanisms and pathways through which PFAS are released at industrial facilities typically include discharges of wastewater and stormwater; disposal of solid wastes on and off the site; accidental occurrences like leaks and spills; and stack and fugitive air emissions. Emissions from stacks can lead to the aerial dispersion of PFAS, depositing these substances onto soil and surface water. In some circumstances, PFAS can leach or otherwise contaminate groundwater and potentially migrate offsite.
Facilities Using PFAS in Processes
Secondary manufacturing facilities often utilize fluoropolymers and PFAS-based materials, which are produced at primary manufacturing sites, as part of their industrial processes. This includes applying coatings to finished products.
Chrome Plating: Facilities use PFAS as mist suppressants to minimize chromium emissions into the air, enhancing air quality and worker safety. Facilities employ PFAS as mist suppressants to reduce chromium emissions into the air, thereby improving air quality and enhancing worker safety. According to the USEPA (2021), half of the 1,339 chromium electroplating facilities in the United States continue to use PFAS-based mist and fume suppressants. Chrome electroplating is identified as the primary industrial process where PFAS is significantly used. In this method, PFAS function as surfactants, lowering the surface tension of the electrolyte solution.
Textiles and Leather Production: Manufacturers of performance fabrics for outdoor gear and military uniforms often use PFAS to provide water, stain, and fire resistance. Similarly, PFAS are applied in the leather tanning process to improve the water and stain resistance of products like furniture and clothing.
Electronics Manufacturing: PFAS are utilized for their heat- and chemical-resistant properties when producing circuit boards and semiconductors, ensuring the longevity and reliability of these components.
Maintenance and Mechanical Areas
Lubricants and Greases: Industries such as automotive and machinery maintenance use PFAS-enhanced lubricants and greases for their ability to withstand extreme temperatures and reduce wear and friction, which are crucial for protecting machinery under harsh conditions.
High-Temperature Applications: PFAS compounds are included in formulations used in industrial ovens, automotive wheel bearings, and several types of valves and pumps to maintain performance under extreme heat.
Commercial and Research Uses
Commercial Properties: Facilities such as kitchens, laundries, and workshops might have used PFAS-containing products like sealants and adhesives, leading to potential soil or groundwater contamination from spills or improper disposal.
Aerospace and Defense: Beyond firefighting foams, these sectors may use PFAS in applications like coated fabrics and specialty hydraulic fluids.
Research Facilities: These may experience contamination from PFAS due to spills or disposal practices during experimental or development phases.
Special Applications and Adjacent Properties
Hydraulic Fluids and Special Equipment: PFAS are crucial in applications requiring non-reactivity and thermal stability, such as in hydraulic systems of aircraft and high-temperature industrial settings, or in vacuum pumps.
Adjacent Contamination: Properties neighboring PFAS-utilizing facilities can also become contaminated through runoff or subsurface water flow, highlighting the need for comprehensive environmental assessments.
Paints, Varnishes, and Inks: PFOS-related chemicals are utilized in several ways within paints and varnishes. They serve as wetting, leveling, and dispersing agents and are also used to enhance gloss and antistatic properties. Furthermore, these chemicals are employed as additives in both dyes and inks.
Architectural Fabrics: PFAS, including fluoropolymers such as PTFE, are used in the manufacture of architectural fabrics, such as those used in the construction of roof domes, including large stadiums and transportation facilities.
Enforcement Discretion
EPA is aware that many public institutions, such as municipal landfills and wastewater treatment plants, do not have a choice when they receive household waste containing PFAS. EPA’s PFAS Discretion Memo lists several factors the EPA will consider when determining not to pursue an entity for PFAS response actions or costs under CERCLA. PFAS Discretion Memo
The widespread use and environmental persistence of PFAS underscore the importance of thorough environmental assessments to identify potential contamination sources. Understanding the extensive applications and potential pathways of PFAS contamination is crucial for effective management and remediation strategies in environmental assessments.
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