The ASTSWMO Board of Directors approved an update to their March 2021 Position Paper on Addressing PFAS in November 2022. 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.
ASTSWMO Position Papers
Post-Closure Care Beyond 30 Years at RCRA Subtitle C Facilities
Regulations promulgated under the authority of Subtitle C of the Resource Conservation and Recovery Act (RCRA), include provisions regarding the post-closure care of hazardous waste land disposal units. The Subtitle C regulations establish a 30-year post-closure care period as the default requirement (See 40 CFR § 264.117). The 2022 position paper highlights key issues and recommends that EPA either revise the RCRA regulations for post-closure or issue supplemental guidance on the implementation of the post-closure regulations under Subtitle C of RCRA congruent with the key issues raised.
ASTSWMO Statement on Coal Combustion Residuals (CCR) Program Implementation
Many States are working towards obtaining EPA CCR permit program approval. As such, ASTSWMO members identified several topics related to State adoption and implementation of the CCR program that require additional input from EPA in the form of rule or guidance. In the Statement, ASTSWMO urges EPA to provide such input for greater certainty for States.
2022 ASTSWMO Position on Performance-Based Contracting at Federal Facilities
Performance-based contracting (PBC) is frequently used for implementing environmental cleanup work at federal facilities under the Defense Environmental Restoration Program (DERP). The Federal Facilities Subcommittee drafted the position paper to identify challenges States continue to face and provides ASTSWMO positions and recommendations for improving the PBC process. The paper also includes a checklist to assist all parties involved in the development and implementation of PBC at federal facility cleanups. This document updates and replaces ASTSWMO’s March 2017 position on PBC at federal facilities with additional examples of challenges and recognizes the U.S. Air Force for utilizing the ASTSWMO PBC checklist as a template in its contracting process.
2022 ASTSWMO Position on Advanced Geophysical Classification for Munitions Response
The Department of Defense (DoD) developed the advanced geophysical classification (AGC) for munitions response to improve the efficiency and effectiveness of munitions cleanup. This position paper summarizes the development and implementation of the AGC technology, outreach, training, and guidance activities, and provides ASTSWMO positions and recommendations on its acceptance at federal facility cleanups. This document updates and replaces ASTSWMO’s January 2017 position on AGC with revisions to definitions and the addition of new references.
UST Open Bermed Containment Systems at Retail Fueling Facilities
This position paper addresses open bermed containment systems at commercial retail fuel facilities that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c), and replaces ASTSWMO’s July 2016 position on these systems. The new document clarifies that ASTSWMO’s position addresses open bermed containment systems at retail fueling facilities, includes additional details about the construction and design of spill buckets vs open bermed containment systems, and new and updated references and resources.
ASTSWMO Recycling Position Paper
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.
ASTSWMO Statement on ASTM E3225-20 and Testing of Spill Prevention Equipment and Containment SUMPs Requirements in 40 CFR – 280.35
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.
CERCLA Modernization Position Paper
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.
ASTSWMO Position Paper on the Importance of Community Involvement
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.