The ASTSWMO Board of Directors approved the Position Paper on Addressing PFAS in March 2021. The paper acknowledges the work Federal and State agencies have taken to date and recommends federal regulatory action, guidance development, and further research to address PFAS.
The ASTSWMO Recycling Position Paper, developed by ASTSWMO’s Materials Management Subcommittee, was approved by the Association’s Board of Directors on July 21, 2020.
ASTSWMO recommends EPA consider promoting substantial changes to the country’s recycling system as EPA develops a national strategy for recycling. The position paper describes challenges the current system is facing and includes content recommendations for a national recycling strategy.
In March 2020, ASTM released E3225-20, Standard Practice for Performing a Liquid Test of Spill Prevention Equipment and Containment Sumps Used for Interstitial Monitoring of Piping by Visual Examination. ASTM E3225-20 provides a practice for inspection of spill prevention equipment and containment sumps by visual examination (“naked eye”) that does not use vacuum, pressure, or liquid testing.
The ASTSWMO CERCLA and Brownfields Subcommittee has published a position paper on CERCLA Modernization in which there are specific areas of the Superfund Program where States could contribute in a larger, more significant role which would make the process more efficient.
The history of community involvement in the environmental field has been one of staggered improvement across the nation. The process, priority, and status of community involvement differs significantly not only from each of the 50 States and six Territories, but also from program to program, and site to site. Community involvement is dependant upon program priorities, agency lead (State, Environmental Protection Agency [EPA], Department of Defense (DoD), or other lead agency), program statutory requirements, resources, community economic levels, community interest, and project manager focus. These inherent differences have contributed toward the level of frustration expressed by citizens, regulators, and responsible parties.
Over the last five years, the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) CERCLA and Brownfields (CaBS) Subcommittee members have been evaluating State and Territorial (State) roles at CERCLA cleanups. One troubling area has been the process of identifying and accepting States cleanup standards and rules as Applicable or Relevant and Appropriate Requirements (ARARs) in CERCLA cleanups.
On January 11, 2002, President Bush signed the Small Business Liability Relief and Brownfields Revitalization Act (Pub.L.No. 107-118, 115 stat. 2356, “the Brownfields Law”). The Brownfields Law amended the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) by providing funds to assess and clean up brownfields; clarified CERCLA liability protections; and provided funds to enhance State and tribal response programs. Other related laws and regulations impact brownfields cleanup and reuse through financial incentives and regulatory requirements.
Due to the fast-paced changes in technology and consumer interest in buying new electronic products, many States are seeing an increase in the amount of older electronic items being discarded. Monitors and televisions with cathode ray tube (CRT) technology are a growing concern for the States. CRT units can contain a variety of toxic metals, such as barium, lead, and cadmium. Therefore, improper or uncontrolled disposal of these devices can have an adverse impact to the environment.
Performance-based contracting (PBC) is frequently used for implementing environmental cleanup work at federal facilities under the Defense Environmental Restoration Program (DERP). The Association of State and Territorial Solid Waste Management Officials (ASTSWMO) has produced two white papers on the subject: “Performance Based Remediation Contracts and Compendium of State Lessons Learned – A Guide to Performance Based Environmental Remediation, November 2004,” and “State Perspectives on the Use of Performance-Based Contracting at Federal Facilities Cleanups, August 2010.” Both papers provide recommendations for improving the PBC process.
The Department of Defense (DoD) developed the advanced geophysical classification for munitions response process (hereafter referred to as advanced geophysical classification, or AGC) to improve the efficiency and effectiveness of munitions cleanup.1 AGC represents a major change in how munitions cleanup is conducted. DoD and its partners have identified several advantages in using AGC over other technologies, including greatly improved performance at detecting and identifying munitions and explosives of concern (MEC) resulting in faster investigation and remediation; higher data quality and greater confidence under its accreditation process, which promotes State acceptance of the data; and less invasive fieldwork (fewer digs) due to the in-situ detection and classification of objects. In order for the DoD to regularly apply this technology at Munitions Response Sites (MRSs), State regulators must have an understanding and acceptance of AGC.