How Will the Adoption of Amendments to 6 NYCRR Part 597 Affect You?

 

On April 25, 2016, Chemical Bulk Storage (CBS)669c8468-9bf5-4360-9502-8f25099605bd registration requirements at new facilities became mandatory for perfluorooctanoic acid (PFOA-acid), ammonium perfluorooctanoate (PFOA-salt), perfluorooctane sulfonic acid (PFOS-acid), and perfluorooctane sulfonate (PFOS-salt) with amendments to 6 NYCRR Part 597.

Effective on March 3, 2017, the aforementioned compounds shall be added to 6 NYCRR Section 597.3, the list of hazardous substances. These substances are common components of firefighting foam; it is important to note that foams which contain PFOA/PFOS compounds are permissible for firefighting purposes up until and through April 25, 2017. However, foams which contain these compounds may not be used for any other purposes, notably training sessions during this phase-in period.

The updated rule also provides information regarding units with respect to release reporting.

It is crucial to consider the following deadlines:

April 25, 2017 – As mentioned above, foams containing PFOA/PFOS compounds are prohibited for firefighting use after April 25, 2017. In order to dispose of the foams, The New York State Department of Environmental Conservation (NYSDEC) recommends solidification of the foam using Type 1 Portland Cement. More information can be found at https://www.dec.ny.gov/regulations/106078.html.

April 25, 2018 – Existing facilities with storage of PFOA/PFOS prior to April 25, 2016 must comply with the CBS registration by this date.

Existing foam fire suppression systems need to be inspected to determine if they contain PFOA/PFOS. As a reminder, recently PFOA/PFOS compounds have been identified in groundwater within New York State. Even at an extremely low concentration, exposure to contaminated groundwater has been linked to human cancers.

Walden can aid owners of affected foam systems by designing retrofitted systems with substitute (unregulated) foam-producing compounds.

For more information on how Walden can help you comply with the amendments to 6 NYCRR Part 597, please give us a call at 516-624-7200.

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