SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND MONTANA COMMUNITIES November 12

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SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND
MONTANA COMMUNITIESNovember 12 13, 2008
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PETROLEUM OTHER CONTAMINATED SOILSREGULATORY
INTRODUCTION

• Tim Stepp
• Solid Waste Program
• Waste Underground Tank Management Bureau

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SOIL TREATMENT FACILITY (STF)LANDFARM METHODS

• Approved landfarm biodegradation methods for
  remediation of non-hazardous petroleum
  contaminated soils (PCS), sump grease waste
• Treatment must significantly reduce contaminant
  concentrations of gasoline, diesel, hydraulic
  fluid, crude oil, tank sludges, sump wastes, etc
• PCS can be disposed of on site (not favored)
  after meeting groundwater (GW) treatment
  standards for cell based on event/source
• SWP target concentrations/BTZ sampling for nondeg
• UST Tier 1 risk-based corrective action (RBCA)
• Closure according to requirements

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LANDFARM CATEGORIES TREATED SOIL VOLUME ACREAGE

• Minor landfarm
• Intermediate landfarm
• Major landfarm
• One-time landfarm generated from a single release

• VOLUME 12-IN MAX
• TREATED ACREAGE
• up to 3,200 cy 2
• 3,200-8,000 cy 5
• 8,000 cy gt5
• 1,600 CY 1

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ANNUAL LANDFARM FEESBASED ON VOLUME TONNAGE

• ANNUAL DISPOSAL
• LICENSE FEE FEE/TON
• 0 0
• 600 0.40
• 1,200 0.40
• 1,800 0.40

• One-time landfarm
• Minor landfarm
• Intermediate landfarm
• Major landfarm

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STF LICENSE APPLICATION

• Subgrade permeability, groundwater depth flow,
  run-on/runoff control
• Screening Treatment OM Plan for remediation
• Location of treatment cells, slope, berms, wells,
  piezometers, lysimeters
• Stockpile areas volumes
• Sampling Analysis QA/QC Plan
• Closure Plan ( FA?)

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STF LOCATIONAL STANDARDSLANDFARM MAY NOT BE
LOCATED

• Within residential zoned areas
• Within designated wetlands flood plains
• Within 100-ft of state surface waters or 1000-ft
  of domestic water wellheads
• Within less than 50-ft from groundwater
• Where permeability of the soil below the
  treatment zone (BTZ) exceeds 1 x 10-5 cm/sec for
  at least 3-ft depth
• unless natural clay or synthetic liners or
  groundwater monitoring are proposed
• evaluated on a case-by-case basis
• Where the slope exceeds 1.0

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STF TREATMENT OPERATIONSCONTAINMENT MAINTENANCE

• Incoming PCS shall be stockpiled per event and
  sampled for screening in the staging area where
  subgrade permeability may not exceed 1 x 10-7
  cm/s
• PCS shall be segregated by event tilled monthly
  into the existing topsoil to at least six inches
  (6") or maximum twelve inches (12")
• waste pile, windrow, or other approved treatment
  methods may be utilized after PCS placement in
  each treatment cell
• Topsoil may be first salvaged for run-on/run-off
  control, or stockpiled for use as final cover
  material for closure, or used during approved
  blending
• Blending with topsoil allows treatment of liquid
  byproducts
• Perimeter berms must be installed and vegetated
  throughout treatment to control fugitive dust and
  maintain soil productivity
• Run-off must be detained and used for treatment
  cell irrigation unless discharge to state water
  is allowed by an MPDES permit

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STF DESIGN PERFORMANCE STDCONSTRUCTED, OPERATED,
MAINTAINED TO PROTECT HUMAN HEALTH AND THE
ENVIRONMENT
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PCS SCREENING CRITERIAEVENT-SPECIFIC ANALYSIS

• Use composite sampling (5 grab samples) testing
  methods throughout baseline treatment following
  Section III QA/QC
• NO HAZARDOUS WASTES
• Acceptance per Section II criteria DEQ approval
  prior to placement in cell
• TPH lt 50k ppm (5 by weight liquid/paint filter)
• Toxic metals screened per Table IV concentrations
• PCS species characterized per Table VI during
  event screening establishes cell baseline
  annual testing suite
• Vehicle carwash sumps characterized adequately

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PCS SCREENING CRITERIAEVENT-SPECIFIC ANALYSIS

• Treatment cell baseline annual sampling
  testing per Table VI based on screening
• Groundwater 3 times for TPH, BTEX, VOCs
• PCS also each time add halogens, PAHs, metals
• Treatment zone as needed baseline species, pH,
  field capacity, C/N, N/P, Kjeldahlnitrate
• BTZ 1-3 ft once per season for TPH, BTEX, total
  metals
• Maximum 5-ft lifts of new PCS may be placed over
  remediated cells

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STF IN COMPLIANCEWell-managed treatment
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TREATMENT VS. ACCEPTANCE Windrow imbalance oily
saturation
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STF CLOSURE CRITERIASPECIFIC SAMPLING TESTING

• TPH is less than 100 ppm BTEX lt 10 ppm
• Benzene 0.5 ppm
• Minimum 3 seasons of sampling testing for
  gasoline (C6-C12) biodegradation
• Recalcitrant PCS phases demonstrated by sampling
  of gridded total depth in each cell
• Two feet of final cover revegetation
• DEQ approval demo of treatment zone as cover
• Two years of post-closure BTZ monit 1-3 ft
• Groundwater monitoring if necessary
• DEQ final approval

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PCS REMEDIATION CLASSES USES ALLOWED UPON REMOVAL

• CLASS OF END-USE
• 1 2 3 4
• lt60 60-200 200-2000 gt2000
• lt10 10-200 200-500 gt500
• lt20 20-100 100-250 gt250
• lt0.005 0.005-0.5 0.5 gt0.5
• lt0.005 0.005-20 20 gt20
• lt0.005 0.005-40 40 gt40
• lt0.005 0.005-20 20 gt20
• 2 Industrial fill or landfill cover.
• 4 Re-treatment or landfill disposal.

• MAJOR
• CONTAMINANT
• Heavy hydrocarbons (C24-C30)
• Diesel (C12-C24)
• Gasoline (C6-C12)
• BTEX Benzene
• Ethylbenzene
• Toluene
• Xylenes
• 1 Avoid human/env harm.
• 3 Landfill daily cover or fill.

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1997 STF DRAFT GUIDANCE

• General Guidelines for the Operation of a Soil
  Treatment Facility to Bioremediate Petroleum
  Contaminated Soils from Multiple Source Sites,
  and Sump Solids From Vehicle Service Shops and
  Car Washes
• DEQ Soil Treatment Facility Rules
• Drafted and awaiting final Legal review
• Public comment pending