SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND MONTANA COMMUNITIES November 12 13, 2008

1. SPECIAL WASTE MANAGEMENT FOR LANDFILLS AND MONTANA COMMUNITIESNovember 12 � 13, 2008

2. PETROLEUM & OTHER CONTAMINATED SOILSREGULATORY INTRODUCTION Tim Stepp Solid Waste Program Waste & Underground Tank Management Bureau

3. 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

4. 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 >5 1,600 CY 1

5. ANNUAL LANDFARM FEESBASED ON VOLUME & TONNAGE One-time landfarm Minor landfarm Intermediate landfarm Major landfarm ANNUAL DISPOSAL LICENSE FEE FEE/TON $ 0 $ 0 $ 600 $0.40 $1,200 $0.40 $1,800 $0.40

6. STF LICENSE APPLICATION Subgrade permeability, groundwater depth & flow, & run-on/runoff control Screening & Treatment O&M Plan for remediation Location of treatment cells, slope, berms, wells, piezometers, lysimeters Stockpile areas & volumes Sampling & Analysis QA/QC Plan Closure Plan (& FA?)

7. 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%

8. 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

9. STF DESIGN PERFORMANCE STDCONSTRUCTED, OPERATED, & MAINTAINED TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT

10. 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 < 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

11. 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, Kjeldahl+nitrate 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

12. STF IN COMPLIANCEWell-managed treatment

13. TREATMENT VS. ACCEPTANCE Windrow imbalance & oily saturation

14. STF CLOSURE CRITERIASPECIFIC SAMPLING & TESTING TPH is less than 100 ppm & BTEX < 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

15. PCS REMEDIATION CLASSES USES ALLOWED UPON REMOVAL 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. CLASS OF END-USE 1 2 3 4 <60 60-200 200-2000 >2000 <10 10-200 200-500 >500 <20 20-100 100-250 >250 <0.005 0.005-0.5 =0.5 >0.5 <0.005 0.005-20 =20 >20 <0.005 0.005-40 =40 >40 <0.005 0.005-20 =20 >20 2 = Industrial fill or landfill cover. 4 = Re-treatment or landfill disposal.

16. 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