A request for comment

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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.

Accountability driven

The cost of the cleanup should have an upper bound and the time for achieving the target endpoints should be limited to 30 days after Corrective Action Plan (CAP) is drawn.  In some case studies we have shown that the hydrocarbon contamination in soil is reduced by about 90% within 3 weeks saving the overall costs of the project significantly without sacrificing quality.

Significance of timeline

In our experience many  projects are extended for years because the available solutions are not effective. As an example, overall project costs that are amortized over a period of 10 years, at an outlay of  $400,000 would be easily met in a city budget and therefore not front-page news due to overspending. We believe that by saving dollars, more money would become available for addtional projects to clean the environment. Currently, according to the latest GAO report, there is only adequate funding ($12Billion) for 50% of the work that needs to be done.

Costs of using our solution