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PFAS in Aboveground Storage Tanks: Key Regulations, Firefighting Foam Risks, and Compliance Strategies

On PFAS and ASTs

Per- and polyfluoroalkyl substances (PFAS) are a growing environmental and regulatory concern across many industries. Known as “forever chemicals” for their persistence in soil and water, PFAS are now shaping conversations in the aboveground storage tank (AST) industry. While PFAS are not stored in ASTs directly, their connection through firefighting foams, wastewater, vapor barrier fabrics (like Teflon®), and regulatory policies makes them increasingly relevant for tank owners and operators.

This article explains the basics of PFAS, their impact on AST operations, and the latest regulatory updates – providing a clear, factual resource for AST professionals.

What Are PFAS and Why Do They Matter?

PFAS are a large group of synthetic chemicals used since the 1940s for their durability and resistance to heat, water, and oil. They are common in:

  • Non-stick cookware
  • Water- and stain-resistant fabrics
  • Industrial surfactants and coatings
  • Firefighting foams, especially aqueous film-forming foam (AFFF)

Because they do not break down easily, PFAS persist in the environment, building up in soil, groundwater, and living organisms. According to the U.S. Environmental Protection Agency (EPA), their persistence makes them a long-term environmental challenge.

PFAS and Aboveground Storage Tanks: Key Connections

1. Firefighting Foam and Emergency Response

Historically, many AST facilities used AFFF for fire suppression, which contained PFAS. Although being phased out, residual contamination from AFFF use remains an issue. The U.S. Department of Defense has limited AFFF use to emergencies only and now treats AFFF discharges as chemical spills while testing fluorine-free foam replacements.

2. Wastewater and Stormwater Management

PFAS can enter wastewater streams through runoff from firefighting foam applications, cleanup, or legacy contamination. For AST facilities, this means drainage, containment, disposal, and treatment systems may need upgrades to handle PFAS in the future.

3. Infrastructure, Seals, and Containment Systems

As PFAS-related scrutiny expands, tank operators may be expected to ensure their floating roof drains, seals, liners, and containment areas prevent leaks and limit environmental exposure.

Current and Emerging PFAS Regulations

Federal Regulations

State-Level PFAS Standards

Several states have already implemented enforceable PFAS regulations:

  • Michigan and New Jersey: Established maximum contaminant levels for PFAS in drinking water.
  • California: Restricting PFAS use in firefighting foams and consumer products.

AST Industry Implications

While 40 CFR Part 60 Kc currently focuses on VOC emissions in storage tanks, it reflects the EPA’s direction toward tighter emissions and contamination controls. It is likely that PFAS restrictions and monitoring will expand in the coming years, with a focus beyond just foams and wastewater.

What AST Operators Should Do Now

  1. Plan for AFFF Transition
    Begin replacing PFAS-based firefighting foams with fluorine-free alternatives. Store and dispose of legacy foams safely.
  2. Review Wastewater Handling
    Monitor and assess drainage and containment systems for potential PFAS exposure, especially if firefighting foams have been used on-site.
  3. Strengthen Infrastructure Integrity
    Ensure tank seals, drains, and liners are properly maintained to minimize environmental risks if PFAS oversight expands.
  4. Stay Informed on Regulations
    Track federal and state PFAS policy developments to stay ahead of compliance requirements.
  5. Prepare for Disposal
    Begin planning on how you’ll dispose of any legacy PFAS laden materials (AFFF, Teflon®, etc.) 

Conclusion

PFAS are not yet directly regulated in the AST industry, but their presence in firefighting foams, wastewater, and environmental monitoring makes them increasingly relevant. The regulatory landscape is evolving quickly, and operators who prepare today will be best positioned for compliance tomorrow.

By staying informed about PFAS, the AST industry can contribute to environmental stewardship while protecting operations from future regulatory challenges.

For More Information:

EPA – PFAS Overview
https://www.epa.gov/pfas
General information on PFAS, persistence, uses, and risks

    EPA – PFAS Strategic Roadmap (2021–2024)
    https://www.epa.gov/pfas/pfas-roadmap
    Outlines the EPA’s planned regulatory actions on PFAS, including monitoring and hazardous substance designations

    DoD – Firefighting Foam Replacement and Remediation Efforts
    https://www.war.gov/News/News-Stories/Article/Article/2349028/dod-officials-discuss-fire-fighting-foam-replacement-remediation-efforts/
    Details the Department of Defense’s move away from AFFF, restrictions on use, and environmental cleanup efforts

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