A request for comment
Reduce the end points for petroleum contaminated soils
The current standards for TPH endpoints range anywhere between 2000 ppm - 5000 ppm. We propose that the standards for TPH endpoints be reduced to 20 ppm - 200 ppm. These changes are necessary because of progress in technology in recent years. The current standards have not been adjusted for more than two decades. We have demonstrated through pilot studies and subsequent field applications during the past several years that these lower values are now achievable. Notably there are sites in Brazil that had contamination levels of greater than 700,000 ppm to less than 200 ppm and many more sites are being actively being treated in Brazil. It is our firm belief that the United States play a leadership role in helping improve environment standards and when such standards can be achieved economically and without burdening the taxpayer unduly, it is almost a "slam-dunk" case. We believe that the deteriorating state of the environment demands a solution that has a upper bounds on time and costs.

