&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-K-92-809
March 1988
Survey of State Programs
Pertaining to
Contaminated Soils
y Printed on Recycled Paper
-------
-------
EPA 510-K-92-809
SURVEY OF STATE PROGRAMS PERTAINING TO CONTAMINATED SOILS
March 22, 1988
U. S. Environmental Protection Agency
Office of Underground Storage Tanks
401 M Street, S.tf.
Washington, D.C. 20460
-------
-------
This report was prepared under the direction of Mr. Michael R.
Kalinoski of the U. S. Environmental Protection Agency and was written and
researched by Ms. Janet Dean, Ms. Rashne Baetz, Ms. Lori Bailey, and
Mr. Lee Humphrey of Midwest Research Institute, under EPA contract
No. 68-01-7383.
-------
-------
SURVEY OF STATE PROGRAMS PERTAINING TO CONTAMINATED SOILS
I. PURPOSE
A telephone survey of persons in each of the 50 states and the
District of Columbia was conducted in order to identify current policies
and procedures pertaining to soils contaminated with petroleum and
hazardous substances. The purpose of this report is to describe the key
findings and results of this survey.
Numerous technical and regulatory issues confront state regulatory
personnel and owners and operators of underground storage tanks (USTs)
containing petroleum and hazardous substances. These issues include how
the soils contaminated with released substances are classified (i.e., are
soils considered hazardous waste or not), how the determination is made
and who makes it, and what type of treatment Is allowed or required. The
state contaminated soils programs described In this report are undergoing
change and further refinement as more information is known on the issues
described above. This survey will help the reader identify other state
regulatory programs that appear to be effective and hopefully will provide
some solutions to their implementation problems..
Individuals in the states were contacted by telephone and questioned
about their procedures and policies pertaining to soils contaminated from
leaking underground storage tanks. The same questions were asked of each
participant. Questions were asked about program administration? soil
classification criteria; cleanup management for spills, releases, or
closure; disposal and treatment options; cleanup levels; anticipated
regulatory changes; disposal and treatment effectiveness; extent of the
state contaminated soils problem; tank testing; and followup tests. The
results of the survey are tabulated in Section IV.
II. RESULTS
All 50 states and the District of Columbia were contacted by
telephone. Summaries of the state responses for each of the question
areas are presented below. The table in Section IV provides more detailed
answers on a state-by-state basis. The questions are divided into
administrative and technical areas.
1
-------
A. Administrative
1. Responsible office. This is the state agency, department, or
office that administers the contaminated soil program; if there is not a
state program, this is the local administrator. Forty-eight of the
51 survey respondents had formal programs for the management of
contaminated soils. The agencies responsible for the programs included
state departments of water, health, natural resources, solid waste
management, hazardous waste management, underground storage tanks, and
environmental protection; local agencies; and state fire marshals. Three
states (Florida, Nebraska, North Carolina) have separate programs for
hazardous materials and petroleum products. Three states (Alaska,
Arkansas, West Virginia) do not have formal programs.
2. Management of spills, releases, or closure. This is the party
responsible for soil cleanup and supervision at tank closure, and for soil
cleanup from spills and releases from tanks. In many cases, the
department that is responsible for a state's contaminated soils program
also is responsible for cleanup management of spills and releases or
closure. Twenty-four states oversee the cleanup activities performed by
the responsible party, either the tank owner or local agency.
3. Soil classification criteria. These are the classification
criteria used by the states to determine if the soil is hazardous or
nonhazardous. Most states use visibility, odor, and some analytical
method to determine if soil is contaminated with petroleum products. In
many states, soils are considered hazardous according to the RCRA
characteristics of corrosivity, reactivity, extraction procedure (EP)
toxicity (i.e., lead content), or ignitability. Some states currently are
using the proposed toxicity characteristic leaching procedure (TCLP) (see
51 FR 21648 December 26, 1986) to classify soils contaminated with organic
compounds. If soils contaminated with petroleum products exceed the RCRA
characteristic levels, they are treated as hazardous by 46 of the
51 survey respondents.
4. Cleanup levels. These are numerical standards set by the state
for soil cleanup. Twenty-one states have set numerical standards for soil
cleanup. Twenty-eight states allow the local agency or owner to make
site-specific judgments based on either numerical criteria or subjective
-------
criteria such as odor or visibility to set cleanup levels. Two states
(Oregon, Pennsylvania) did not provide this information.
5- Anticipated regulatory changes. Twenty-nine of the states are
anticipating changes in rules and regulations governing soils contaminated
from leaking underground storage tanks. Most are looking to EPA and the
final UST regulations for guidelines by which to design their programs.
6- Extent of problem. The states were asked for their perspective
on the extent of their contaminated soils problem. Twenty-four of the
states are experiencing problems today and anticipating very significant
problems in the future. These problems include the volume of contaminated
soils being generated and the lack of specific treatment and disposal
options for these soils. Seventeen states are unsure of the extent of
their contaminated soils problems, while 10 other states do not feel their
contaminated soils problem is significant.
B. Technical Categories
!• Disposal and treatment alternatives. These are the methods
currently used for disposal and treatment of hazardous or nonhazardous
contaminated soil. Thirty-nine states treat petroleum product
contaminated soils with aeration, either on site or off site, then either
dispose of the soil in a landfill or leave it on site. Most states
dispose of soils contaminated with hazardous waste by transportation off
site to permitted hazardous waste treatment and! disposal facilities (RCRA
Subtitle C). Ten states use incineration as a disposal method for soils.
2. Followup tests. States were asked iflfollowup tests were done
to ensure that the disposal and treatment methods were effective. Ten
states require followup testing at the release site after a leak has been
noticed while nine states require followup tests; only on a case-by-case
basis. Thirteen states require no followup testing.
3. Disposal and treatment effectiveness. The states were asked for
their perspective on the effectiveness from a cost and results standpoint
of their current disposal and treatment alternatives. Twenty-nine states
are unsure about the effectiveness of their program. Some states (18)
feel their contaminated soil programs are working. Most states feel that
the extent of the problem is just beginning to be known and it will take
time to evaluate the effectiveness of their programs.
-------
4. Required tank testing. States were asked if they require
testing to determine if tanks are leaking. Thirty-five states surveyed
require testing only if a release is confirmed. Six states require
.testing at tank closure. Ten states require periodic testing and
monitoring of ground water or tank volumes.
III. DISCUSSION
The state agencies currently implementing contaminated soil programs
expressed the most concern over the following issues. First, the majority
of the states surveyed, either have or anticipate significant contaminated
soils problems with the volume of soils to be generated and the
availability of options to treat and dispose of them. Second, although
most of these state programs are currently in place, there is some
uncertainty over their effectiveness. The states without effective
programs in this area are looking to the U. S. EPA to assist in program
development especially through the final rule for USTs. These state
agencies need information such as alternative implementation policies and
technical procedures to design contaminated soils programs that are
effective and best meet their individual needs.
Therefore, in order to provide information on alternative policy and
technical procedures, selected state programs are described below. These
programs appear to be the most comprehensive and effective in dealing with
contaminated soil from both an administrative and a technical
perspective. The common elements in an effective program seem to be:
(1) responsibility for management and decision making is clearly
established; (2) both hazardous and nonhazardous materials are regulated;
(3) any effective treatment and disposal alternatives are allowed for use;
and (4) cleanup criteria are established.
A. Florida
The Florida Department of Environmental Regulations administers the
contaminated soils program. Petroleum product and nonpetroleum hazardous
material contamination are considered separately. Soils contaminated with
petroleum products are considered hazardous if they are contaminated with
a listed waste or if they fail the EP toxicity test for lead or
ignitability characteristic. Soils contaminated with nonpetroleum
-------
hazardous chemicals are considered hazardous if they fail the EP toxicity
test or the proposed TCLP for organic substances (including pesticides).
Soils contaminated by nonhazardous petroleum products are treated on
or off site then disposed at either a municipal landfill or incinerator.
On-site treatments consist of soil spreading to allow volatilization or in
situ vacuum extraction. Off-site treatments include volatilization in an
asphalt dryer and the use of a mobile incinerator.
Several treatments are used on hazardous material contaminated soil,
including incineration, soil washing with water or methylene chloride, and
solidification (mixing soil with a solidifying agent such as concrete or
lime). Contaminated soils of this type are not placed in landfills in
Florida; they must be shipped to another state for disposal in a
Subtitle C facility.
After treatment, soils contaminated with nonhazardous petroleum
products are tested and must have less than 500 parts per billion (ppb)
total hydrocarbons and less than 100 ppb total aromatic hydrocarbons in
order to be disposed in a municipal landfill. So far, all petroleum
contaminated soils in the state have been classified as nonhazardous after
treatment.
A risk assessment is performed in all cases to determine the cleanup
levels for each site contaminated with hazardous material. The risk
assessment is based on such factors as population in the area, future land
use, and whether the ground water is the future water supply for the
area. Ground-water monitoring is routinely performed as a followup
test. ;
B. Rhode Island
- -- • **,
The Rhode Island Department of Environmental Management administers
the contaminated soils program. Soils are classified as either hazardous
or nonhazardous depending upon the lead content,; flammability, odor, and
visibility of the contaminant. After excavation, contaminated soils that
are considered hazardous may be temporarily stored on site (30 days) if
covered with polyethylene and placed on an impervious base. If the soil
is determined to be hazardous, it must be transported out of the state to
a Subtitle C facility. Currently, discussions are being held to determine
the feasibility of siting a Subtitle C facility in Rhode Island for
-------
contaminated soils disposal. The state also is trying to determine the
best possible treatment methods. Contaminated soils are no longer used in
asphalt production because the state felt that such use of these soils was
contributing to air pollution. Cleanup levels for the soils are
established on a site-by-site basis but usually are visual.
C. Vermont
The Vermont Department of Environmental Conservation in the Agency
of Natural Resources administers the state's contaminated soils program.
An "HNU meter" or "Photovac" calibrated to benzene is used to determine
whether the soil is hazardous. Soil may be replaced on site if the level
of contamination is less than 20 parts per million (ppm). The soil is
hazardous waste and must be shipped to a licensed facility under manifest
if the level of contamination is greater than 100 ppm. If the soil is
contaminated with between 20 and 100 ppm of benzene, then it may be
disposed in a municipal landfill. The state has placed a moratorium on
shipping hazardous wastes out of state because of the expense to tank
owners and the possibility that some states used the hazardous soils as
fill in municipal landfills. The state is currently testing several on-
site programs, most notably biorestoration.
D. Wisconsin
The Wisconsin Department of Natural Resources administers the
state's contaminated soil cleanup program through the Bureau of Solid
Waste Management. The Wisconsin program covers three types of
contamination: petroleum contamination, hazardous waste contamination,
and nonpetroleum product contamination. Soil contaminated with petroleum
products is considered nonhazardous but must be cleaned up to levels
between 10 and 50 ppm total hydrocarbons; a lower cleanup level may be
required depending upon the applicable ground-water standards. The soil
is usually excavated, and any soil with lower contamination levels
(<50 ppm) may be used as landfill cover. Soil with high contamination
levels (>50 ppm) must go to one of the state's newer clay-lined
landfills. Some contaminated soils are used in asphalt production. The
only other treatment currently being used is aeration of the soil to allow
volatilization and to decrease the total hydrocarbon level.
-------
Any soil contaminated with wastes known to be hazardous is removed
from the site, if practical, until the remaining soil is at background
levels. The excavated material is then shipped to a Subtitle C facility
out of state.
Any soils contaminated with hazardous products, such as
trichloroethylene, are considered hazardous by Wisconsin's mixture rule
(i.e., solid waste + hazardous waste = hazardous waste). The cleanup
level may be between 1 and 10 ppm, depending upon the site and the
contaminant of concern. If contamination is greater than 10 ppm, the
responsible party must send the soil to a hazardous waste facility, or
submit a plan for state approval to reclaim the site by "cleaning" the
soil with appropriate treatment methods. Soil that is cleaned up to 1 ppm
or less of the contaminant of concern may be returned to the site. Soil
that cannot be cleaned up to that level must be sent to a Subtitle C
facility.
As a result of implementation of this program, the amount of soil
shipped to Subtitle C facilities has decreased by about 50 percent. In
addition, the program administrators have developed a decision tree for
their district staff to assist them in site assessment and cleanup.
IV. TABLES SUMMARIZING INDIVIDUAL STATE RESPONSES TO THE VARIOUS
QUESTION CATEGORIES
The responses are organized into administrative categories (Table 1)
and technical categories (Table 2).
-------
r
TABLE 1. SUMMARY OF RESPONSES ON ADMINISTRATIVE ISSUES
State
Alabama
Responsible office
Department of
Environs ental
Management -
Groundwater Section
Soil classifica-
tion criteria
RCRA characteristics
Management of spills,
releases, or closure
Owner/contractor -
closure/corrective
action
Cleanup levels
Site-specific: <1 ppn
hydrocarbon concentra-
tion"
Anticipated
regulatory
changes
Yes
Extent of problen
Current problen Is "fairly"
significant
Alaska
Arizona
00
Arkansas
California
Colorado
Ho formal progran
Department of Environ-
mental Quality
Ho formal progran
Water Quality Control
Board and Department
of Health Services,
Toxic Substances
Control Division, and
Local Agency
Department of Health
RCRA characteristics
RCRA characteristics for
nonpetroleun products,
the soils contaminated
with petroleum
products are called
"special waste* or
nonhazardous
RCRA characteristics or
listed waste
Local agency decides if
hazardous or non-
hazardous - State
recommendations
include: ignitabil-
tty, corrosivity, and
toxicity
EP toxicity and other
RCRA characteristics
Department of Environ-
mental Control-
closure/ corrective
action
Hazardous - hazardous
waste coaplfance unit;
Nonhazardous - UST/water
pollution compliance
unit - closure/
corrective action
Environmental Field
Services - Hazardous
Waste Division -
closure/corrective
action
Local agency - closure/
corrective action
Owner - closure/correc-
tive action
Appearance and odor
Remedial action levels -
total petroleum hydro-
carbons: 10,000 ppbb
Benzene: 67 ppb
Toluene; 200 ppn
Xylene: 44 ppn
Ethylene dibromide:
0.05 ppb
Case-by-case
determination
Local agency decides
Ho
Yes
Ho
Ho
Hone. Owner must pro-
vide state with final
analysis for judgment
Yes
Hot a significant problen at
this point.
Hot a significant problem
because ground water Is
very deep
Extent of the problem is
uncertain
Since January 1984,
4,000 sites of UST leaks
have been Identified
Approximately 0.5 percent of
tanks are reported to be
leaking
(continued)
-------
TABLE 1. (continued)
State
' | ' i-
Connecticut
Delaware
District of
Columbia
Flor1dac
Florida"1
Georgia
Hawaii
Responsible office
— •———________
Department of Environ-
mental Protection
Department of Natural
Resources
Department of Consider
and Regulatory
Affairs, Environnental
Control Division
Bureau of Operations
Department of Environ-
mental Regulations
Hazardous waste only -
Hazardous Waste Man-
agement Division
No program for petroleum
products
Department of Health -
Hazardous Waste
Departnent
Sod classifica-
tion criteria
Visibility, odor, THC
RCRA characteristics
Visibility, odor,
ignitability
EP toxiclty/proposed
TCLP (organic
substances)
On Florida list of
hazardous waste
EP toxlcity
igni tabimy
RCRA Appendix 9 list
Petroleum products -
visibility, odor, some
soil sampling
(Ho problens with
hazardous waste tanks)
Management of spills,
releases, or closure
— — — — — — — —
Oil and chemical spills
unit - corrective
ftrHnn
Cleanup levels
Visibility
=======.=
Anticipated
regulatory
changes
Yes
Extent of problem
Extent of problem Is
uncertain
Hazardous materials
•anagenent unit -
closure
Consultants following
state guidelines -
corrective action; UST
Branch - closure
EPA - now
(Environmental Control
Division - soon)
closure, corrective
action
District offices of
state agency and
Bureau of Operations -
closure/corrective
action
District office of state
agency - closure;
Emergency response
section of state
agency - corrective
action
Hazardous Waste Manage-
ment Division -
closure/corrective
action
Responsible party with
state oversight -
closure/corrective
action
1 ppa of benzene, yes
toluene, xylene, and
ethyl benzene
EPA guidance yes
Based upon risk assess-
ment performed at each
site
-------
TABLE 1. (continued)
State
Idaho
Responsible office
Division of Environment
Soil classifica-
tion criteria
RCRA characteristics.
Hanagenent of spills,
releases, or closure Cleanup levels
ResDonslhle nartv with H*7«rH™ic . urns ..HI*
Anticipated
regulatory
changes
.* VAC
Extent of problen
Water Quality Bureau
Illinois
Indiana
Iowa
Kansas
Kentucky
State fire narshall
Department of Envlron-
nental Hanagenent
Department of Natural
Resources
Department of Health and
Envlronnent
Division of Waste
Hanagenent
CERCLA or otherwise
EPA listed
Petroleun - nonhazardous
unless neets one of
the above criteria
Hazardous - lead con-
tent, flashpoint;
petroleun products are
called "special waste"
RCRA characteristics
Visibility, odor
Sone soil sanpllng,
sometlnes use portable
GC
Visibility, odor,
Ignllability
EP toxiclty, ignit-
ablllty, nostly site
specific
state oversight for
corrective action
Closure - State Fire
Marshall's Office Mist
Issue a permit for
abandonment, lay
require Inspection by
local or stati fir*
officials
State fire marshal! -
closure/corrective
action
Responsible party with
state oversight -
corrective action
Responsible party -
closure
State - corrective
action; owner-closure
Bureau of Environmental
Remediation - closure/
corrective action
Energency response
teas - corrective
action; Division of
Waste Management -
closure
Yes
Konhazardous - site-
specific, to back-
ground levels If
feasible
Hot a large percentage of
leaking tanks but this Is
the leading cause of
ground-water contanlnatlon
In Idaho
Analytical testing to
meet health-based
criteria
Background levels, if
practical
Hone specified
1HC below 100 ppn
Background levels on a
site-specific basis,
related to health and
environmental consid-
erations
Yes
No
No
No
No
Not an extensive problem
Problems are increasing as
new laws are enforced
Extent of the problen is
uncertain
Not an extensive problen
Problen is extensive
(continued)
-------
TABLE 1. (continued)
State
Louisiana
Responsible office
Office of Solid and
Hazardous Waste
Hanagenent
Soil classifica-
tion criteria
EP toxlclty. Ignlt-
ablllty
Management of spills,
releases, or closure
Responsible party with
state oversight -
closure/ corrective
action
Cleanup levels
Totals BTEXf around SO
to 100 ppo or lower,
site specific
Anticipated
regulatory
changes
Yes
Extent of problem
Currently the problei
severe
J —
Is
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Oepartnent of Environ-
mental Protection
Department of Environ-
nent
Department of
Envlronnental Quality
Engineering
Environmental Protection
Bureau
Solid and Hazardous
Waste Management
Bureau of Pollution
Control
Local authorities or
state agency (DHR)
Sensory observation, HNU
tieter
Flashpoint
Any petroleun
contaalnation makes
soil hazardous
Visibility, odor
If gasoline - nonhazard-
ous (unless leaded)
Haste oils-tested for
lead or leachates
KNU meter
LEL aeter (lower explo-
sive Unit)
Reportable quantities,
all RCRA charac-
teristics
State field investi-
gator - corrective
action; certified
installer and/or
professional flrenan
closure
State - closure/correc-
tive action
Responsible party with
state oversight -
closure/corrective
action
Responsible party -
closure
State - corrective
action
Responsible party with
state oversight -
closure/corrective
action
Responsible party with
state oversight -
closure/corrective
action
Owner/operator with
state oversight -
closure/corrective
action
Site specific-environ- No
•ental and health
considerations
BTX9 - petroleum Ho
THC - hazardous to site
specific cleanup
levels
Site specific, odor Yes
detection
Hone specified Yes
Hondetectable levels of Yes
volatlles
<10 percent LEL yes
Site specific - Yes
envlronnental and
safety considerations
Problen appears to be Severe
500 to 1,100 closures last
year had contaminated
soils
The problem is very
extensive
Greater than 90 percent
leakage or overfill
contamination when tanks
are pulled
Problen is very severe.
Currently 450 sites are
contaminated
Currently problem Is
extensive
Extent of problem 1s
uncertain
(continued)
-------
TABLE 1. (continued)
State
Montana
Responsible office
Solid and Hazardous
Haste Bureau
Soil classifica-
tion criteria
Flashpoint, lead content
Hanageaent of spills,
releases, or closure Cleanup levels
Responsible party with Hone
state oversight -
closure/corrective
action
Anticipated
regulatory
changes
Yes
Extent of problea
Extent of problen Is
uncertain
Nebraska
Nevada
New Hanpshlre
New Jersey
New Mexico
New York
Departnent of Environ-
mental Control - If:
Hazardous - hazardous
waste section
Petroleun - technical
service section
Division of Underground
Storage Tanks
Department of Environ-
nental Services
Division of Water
Resources, Bureau of
Hazardous Waste
Management
Department of Health and
Environment - Environ-
mental Improvement
Division
Departnent of Under-
ground Storage Tanks
Hazardous - RCRA
characteristics if
hazardous
Petroleun - visibility,
odor
RCRA - Ignltablllty,
lead content
Flashpoint, sensory
observatIon
RCRA - EP toxicity
characteristics, THC,
or total PCB's, or
percent saturation
EP toxicity or source of
contamination nay
cause soil to be
considered hazardous.
fill petroleun con-
taninated soil has
passed EP toxicity
tests. Ho known
nonpetroleun leaks in
state.
Visibility, odor
(petroleum)
Hazardous - hazardous
waste section
Petroleun - technical
service section
Division of Underground
Storage Tanks -
closure/corrective
action
Water supply and pollu-
tion control
division - closure/
corrective action
Bureau of Enforcement -
closure/corrective
action
Responsible party with
local oversight at
closure, state over-
sight for corrective
action
Visual inspection
Ho Problen Is not very
extensive
RCRA - Ignitability.
lead content
Total volatiles, lead
Background levels
Visual and olfactory
observation after
aeration
No
Yes
Yes
Yes
Extent of problem uncertain
Problem appears to be
extensive
Problen is very extensive
Problem is very extensive
State - corrective
action; owner-closure
Hone specified
No
Problen is very extensive,
approximately 4,000 sites
(continued)
-------
TABLE 1. (continued)
State
North Carolina
Responsible office
Hazardous - Division of
Health and Hunan
Services - Solid and
Hazardous Waste
Management Branch
Nonhazardous - Division
of Environmental
Management
Soil classlfica- Management of spills,
tlon criteria releases, or closure Cleanup levels
RCRA characteristics - Owner/contractor THC below 100 pp>
teachability
Anticipated
regulatory
changes
No
Extent of
problem
400 Incidents are In some
phase of
disposal
treatment/
co
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Department of Health -
Division of Waste
Hanagenent Special
Studies
State fire narshall and
EPA
Department of Health
(prograa Is just
beginning, v«ry few
cases at this point,
no set rules)
Department of
Environmental Quality
Department of Environ-
mental Resources
Department of Environ-
mental Management
State Department of
Health and Environ-
mental Control
Classify petroleum as
nonhazardous
Hone established yet
considered on
individual basis
Owner/contractor
Owner/operator (o/o)
with state fire
marshal! oversight -
closure/ corrective
action
Site specific levels
Site specific unless
close to aquifer, then
ground water (health,
environmental-based)
levels required
Intonation not obtained Infomation not obtained Inflation not obtained
EPA listed hazardous
wastes
Visibility, odor, lead,
flammabillty, some
others If necessary
Petroleum - nonhazardous
Others - 100 ppn trigger
level with OVA or HNU
analyzer
Unable to obtain this
information
State - closure and
corrective action
State - with contractor
hired by 0/0 - at
closure only unless
otherwise reported by
0/0
Uiable to obtain this
information
Visual observation
100 ppm THC - arbitrary
"clean" level
No
Yes
Infcrsation
not
obtained
Yes
Yes
Yes
Problem Is not extensive
Problem is consistent with
EPA projections
Inforraation not obtained
Information not obtained
Problem is not extensive
Will he a problem in the
future
(continued)
-------
TABLE 1. (continued)
State
South Dakota
Responsible office
Departwnt of Kater and
Natural Resources
Soil classifica-
tion criteria
RCRA characteristics
Management of spills,
releases, or closure
Owner/contractor -
closure/corrective
action
Antlclt
regulat
Cleanup levels change!
RCRA characteristics Ho
Tennessee Division of Groundwater
Protection
Texas Texas Hater Cowlsslon
and Department of
Health
Utah Regulated by local
county Health Depart-
ments with variability
among counties.
Example: Salt Lake
County Health Depart-
ment, Bureau of Hater
Qua!Ity
Vermont Agency of Natural
Resources, Department
of Environmental
Conservation
Virginia state Hater Control
Board
Washington Department of Ecology -
Four regional offices
which nay vary In
procedure, information
Is from the Southwest
Region
West Virginia Ho formal program
Laboratory analysis of
total BTX by GC or
photo lonizatfon
Petroleum - total BTX,
Ignltabllity
Hazardous - EPA listed
Nonpetroleun - any
amount
Total hydrocarbons
Responsible party with
state oversight for
corrective action
Responsible party with
state oversight -
closure/corrective
action
Responsible party with
county oversight for
corrective action
<10 ppn BTX
<500 ppo BTX and
nonlgnltable
1 mg/1 THC in water,
100 «g/l THC in soil
Yes
Yes
Ho
"Photovac" calibrated to State - closure, correc- Hone specified yet
benzene tive action
RCRA guidelines for
leaded product
RCRA characteristics,
PCB levels. EP toxtc-
Hy characteristics
Nonhazardous
State Water Control
Board
Owner/contractor
Responsible party with
state oversight -
closure/corrective
action
Owner/contractor
RCRA guidelines for
leaded (EP toxicity
levels) products
Hone specified
Yes
Ho
Yes
Extent of problem
Problem is not very
extensive
Approxinately 130 sites
Extent of the problen is
uncertain
Extent of the problem is
uncertain
Background levels
Yes
High percent of closures
have contaminated soils
Extent of the problen Is
uncertain
Problem is extensive and
getting worse
Problem may be severe
(continued)
-------
tn
Wyoming
TABLE 1. (continued)
State
Wisconsin
Soil classifica-
Responslble office tion criteria
Hanagenent of spills,
releases, or closure Cleanup levels
Anticipated
regulatory
changes
Extent of problem
Management, Hazardous
Haste Management
Section
Department of Envlron-
nental Quality - Water
Quality Division
?Parts per nil lion In soil.
"Parts per billion In soil.
[jNonpetroleum products.
"Petroleim products.
Hotal hydrocarbons.
Benzene, toluene, ethylbenzene, xylene.
"Benzene, toluene, xylene.
Hazardous waste - any
aaount Is hazardous
Hazardous "product" -
any Mount is hazard-
ous by Wisconsin
mixture rule
HNU neter and/or
analysis of soil
samples
Responsible party with
state oversight -
closure/corrective
action
Responsible party with
state oversight -
closure/corrective
action
Petroleu» - 10 to 50 pp« Yes
THC, site specific
using ground water
standards
Hazardous waste -
background levels
"Product" - 1 to 10 ppn
of contaminant of
concern - site and
contaminant specific
Olfactory levels Yes
Problem is extensive
Problem is severe
-------
TABLE 2. SUMMARY OF RESPONSES ON TECHNICAL ISSUES
State
Alabama
Alaska
Arizona
CTl
Arkansas
Californla
Colorado
Disposal and treatment
effectiveness
Program currently effective
but extent of the problem
Is uncertain.
Unsure of program's
effectiveness.
Effective from a results
standpoint, unsure about
effectiveness from a cost
standpoint.
Unsure of program's
effectiveness.
Studies currently are being
done to determine
effectiveness.
Unsure of program's
effectiveness.
Disposal and treatment
alternatives
On-slte aeration then moved
to Subtitle D landfill for
petroIeum-contamInated
soils.
Aeration both on- and off-
slte.
Hazardous to Subtitle C
facllIty out-of-state.
Nonhazardous to Subtitle D
landfill or asphalt plant.
Special: evaporation after
placing on plastic lining,
air stripping, sent to
Subtitle D landfill or
reuse on site.
Nonhazardous: Subtitle D
landfill (If they will
accept it).
Aeration, evaporation by
negative pressure, or
Incineration.
Hazardous to Subtitle C
facility, Incinerated,
Injection well, or fuel
blenders.
If treated, taken back to
site for refill, or to a
Class II or Class III
landfill.
Hazardous to Subtitle C
facility.
Hazardous: out-of-state
Subtitle C facility.
Nonhazardous: I andf)11
after solidification,
volatilization, or
bioreclamation.
Required tank testing
Only when a tank Is noticed
to have leaked.
According to Federal UST
program.
No routine testing is done.
Testing is required If a
problem is suspected.
No required testing.
Precision tests done
annually on existing
tanks. New tanks are con-
tinuously monitored.
Monthly tests done on soil
underneath tanks contain-
ing hazardous chemicals.
No required testing.
Followup testing
No followup tests
are done.
No followup tests
are done.
Ground-water
monitoring Is
required.
No followup tests
are done.
Followup tests are
site specific.
Tank owner must
provide final
soil analysis.
(continued)
-------
TABLE 2. (continued)
State
Disposal and treatment
effectiveness
Connecticut
Delaware
Washington,
D.C.
Florida9
Florida6
Georgia
HawaIi
Idaho
The program Is effective.
Very effective.
Unsure of program's
effectiveness.
Unsure what the long-term
effectiveness will be.
Programs are effective.
Unsure of program's -_
effectiveness.
Programs are effective.
Unsure of program's
effectiveness.
Disposal and treatment
alternatives
Evaporation, aeration before
use in Subtitle D
landfill.
Subtitle D landfill or Sub-
title C facility, which-
ever is appropriate.
Hazardous: Subtitle C
facility.
Nonhazardous: Subtitle D
landfill.
No treatment at this time.
Out-of-state Subtitle C
facility, incineration,
soil washing,
solidification.
Subtitle D landfill or
incinerator, on-slte
volatilization, vacuum
extraction, asphalt dryer,
mobile
Landfill (Subtitle C).
Petroleum nonhazardous
products to Subtitle D
landfill after aeration.
Nonhazardous: to Subtitle D
landfill or asphalt plant
after removal of free
product by pumping and any
treatment that the respon-
sible party wants to use.
Hazardous: RCRA rules.
Required tank testing
Annual testing for steel
tanks >12 years old and
a 11 new tanks.
Testing when a tank is
removed, abandoned, or
retrofitted.
Unknown.
Unsure of state's testing
requIrements.
According to Florida's tanks
program: Code 1761.
No routine testing required.
Testing done only when
problem is noticed.
No periodic testing
required.
Followup testing
No followup tests
are done.
No followup tests
are done.
Unknown.
Ground-water moni-
toring required.
Ground-water mon tu-
tor Ing required.
Ground-water moni-
toring required.
No followup tests
are done.
No followup tests
are done.
(continued)
-------
TABLE 2. (continued)
Stote
Illinois
Indiana
oo
Iowa
Kansas
Kentucky
Louisiana
Maine
Disposal and treatment
effectiveness
Only effective on some types
of pollutants.
Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
Program Is effective.
Unsure of program's
effectiveness.
Program Is effective at this
time.
Unsure of program's
effectiveness.
Disposal and treatment
alternatives
Landfills, experimenting
with aeration and soil
washing.
Hazardous: to In- or out-
of-state Subtitle C
facility.
Special: To licensed
special waste facility
after aeration.
Aeration then landfill or
added to farmland.
Hazardous waste: out-of-
state Subtitle C facility.
Aeration, venting,
Subtitle D landfill.
Hazardous to Subtitle C
facllity, petroleum
products to Subtitle D
facility.
On-slte passive aeration.
Hazardous: In-state
Subtitle C facility
Nonhazardous: industrial
waste facility or
Subtitle D landfill,
aeration, venting
Commercial landfill, public
landfill, landspreading,
asphalt production, road-
bulIding, venting.
Required tank testing
Testing at tank closure.
No periodic testing
required.
Testing at tank closure.
Test only If a problem is
suspected.
No periodic testing
required.
Testing required but details
of the testing program not
disclosed.
New tanks must have
monI tor Ing we 11s.
Followup testing
No followup tests
are done.
Recommended to
owner for legal
protection.
No followup tests
are done.
Monitoring we I Is
are installed.
Periodic followup
tests required.
No followup tests
are done.
Unknown.
(continued)
-------
TABLE 2. (continued)
State
Disposal and treatment
effectiveness
Disposal and treatment
alternatives
Required tank testing
Fo!lowup testing
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Venting is an effective
option.
Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
Studies on program's
effectiveness currently
are being done.
Unsure of program's
effectiveness.
Because there are no
standard procedures,
effectiveness cannot be
determined.
Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
Hazardous: most to out-of-
state Subtitle C facility.
Nonhazardous: Subtitle D
landfill or incinerator,
on-slte forced venting.
Subtitle C facilities out-
of-state.
Hazardous: Subtitle C
facility.
Nonhazardous; Type 11
landfill.
Petroleum-contaminated soil
is used in asphalt produc-
tion after incineration,
some on-slte venting.
Ventilation, Subtitle D
landfill.
Compaction/extraction -
aeration,
Hazardous: possibly
Incineration (have not had
any HW yet).
Nonhazardous: on-sIte
venting or landfarmlng.
Hazardous: Subtitle C
facility.
Nonhazardous: Subtitle D
landfill.
Landfill/aeration.
No periodic testing
required.
Testing done according to
RCRA regulations.
No periodic testing
required.
No periodic testing
required.
No periodic testing
required.
No periodic testing
required.
Are in the process of
developing requirements.
Testing required when tank
is removed.
Testing done only when
problem is noticed.
Unknown.
Unknown.
Unknown.
Unknown.
Unknown.
Site-specific
continuous
fflOiil I or Ing.
Unknown.
No followup tests
required.
Site specific.
(continued)
-------
TABLE 2. (continued)
ro
o
State
New .HampshI re
Disposal and treatment
effectiveness
New York
Unsure of program's
effectiveness.
New Jersey Unsure of program's
effectiveness.
New Mexico Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
North Carolina Program is effective so far.
North Dakota Program is effective.
Ohl° Program is effective.
Disposal and treatment
alternatives
Oil contaminated Is non-
hazardous, use In asphalt
production; gasoline con-
taminated Is hazardous,
air stripping and/or
passive aeration then ship
to appropriate landfill,
usually In-state.
Incinerators, oil recyclers,
out-of-state Subtitle C
landfill.
Saturated: remove to solid
waste landfill, aerate and
use for cover.
Nonsaturated soil: leave In
place.
Hazardous: Incineration,
Subtitle C facility.
Nonhazardous: Subtitle D
landfill, aeration.
Hazardous: removed to
landfill (Subtitle C).
Nonhazardous: on-slte
venting.
Venting/landfill.
Hazardous: Subtitle C
facility.
Nonhazardous: aeration/
biorestoration.
Required tank testing
Followup testing
No periodic testing
required.
Monitoring wells set up near
some tanks.
No testing required.
No testing required.
Testing only when a problem
is noticed.
Testing only when a problem
is noticed.
No periodic testing
required.
Unknown.
Unknown.
Unknown.
Site specific.
Some monitoring
required.
Some monitoring
required.
Only on large
spills.
Ok Iahoma
Program Is just beginning.
(continued)
-------
TABLE 2. (continued)
State
Disposal and treatment
effectiveness
Oregon
Pennsylvania
Rhode Island
South CarolIna
South Dakota
Tennessee
Texas
Information not obtained.
Information not obtained.
Program Is effective.
Unsure of program's
effectiveness.
Program Is effective for
petroleum products.
Program Is effective.
Program is effective.
Disposal and treatment
alternatives
Information not obtained.
Aeration, Subtitle D
landfill.
If hazardous, presently ship
to Maine or Ohio.
Hazardous: Incinerated.
Nonhazardous: aerated and
landfllled.
Vent ing/landfill: If
hazardous, shipped out-of-
state.
Hazardous: >100 ppm BTX, is
either shipped to out-of-
state Subtitle C facility
or aerated on an imperme-
able base and treated.
Nonhazardous: OO ppm and
>100 ppm BTX, treated In
place or taken to a sol id
_waste landfill .or. used-for<
asphalt.
Treated by venting, bio-
degradation, Incineration.
Hazardous: Subtitle C
facility in-state or
treatment (aeration on an
impermeable base) before
going to a regular
landfIII.
Nonhazardous: if <50 ppm
BTX may go to a landfill
with enough room.
Required tank testing
Information not obtained.
Information not obtained.
They have ongoing tests.
Testing only if problem is
noticed.
Testing when tank is
removed.
No testing is required.
No testing Is required.
Followup testing
Information not
obtained.
Information not
obtained.
Site specific.
No followup
testing is done.
Some monitoring ,is
done.
No followup
testing is done.
Unknown.
(continued)
-------
TABLE 2. (continued)
Vermont
Disposal and treatment
effectiveness
Unsure of program's
effectiveness.
Program Is effective.
ro
Virginia
Washington
Unsure of program's
effectiveness.
Unsure of program's
effectiveness.
West Virginia Unsure of program's
effectiveness.
Wisconsin
Program is effective.
Disposal and treatment
alternatives
In situ vapor extraction or
landfarmlng for petroleum
products (have not had any
nonfuel leaks).
Testing blorestoratlon,
moratorium on shipping out
until develop new regula-
tions, nonhazardous soils
taken to Subtitle D land-
fill or rep Iaced on sI te
depending on level of
contamination.
Landfills/venting off site
and some Incineration.
Landfarming.
No in-state landfill will
take petroleum-
contaminated soils.
Venting/incineration/
landfills.
Petroleum: aeration, then
landfill cover, or clay-
lined landfill, or asphalt
production.
Hazardous waste to out-of-
state Subtitle C facility.
Hazardous "product": if
>10 ppm of contaminant of
concern, to Subtitle C
facility; If treated to
<1 ppm, may go back in
hole; midrange - to
landfill or asphalt pro-
duction. Treatment by
venting, bloreclamatlon,
or other approved methods.
Required tank testing
Pollowup testing
Unknown.
When problem is noticed.
Unknown.
Site specific.
Testing required when tanks
are removed.
No periodic testing
required.
Testing done only If someone
notices a problem.
Some periodic testing of
petroleum tanks may be
starting soon.
Periodic followup
tests required.
Unknown.
Unknown.
Periodic followup
tests required.
(continued)
-------
TABLE 2. (continued)
State
Wyoming
Disposal and treatment
effectiveness
Unsure of program's
effectiveness.
Disposal and treatment
alternatives
Required tank testing
Aeration, Subtitle D land-
fill for nonsaturated
soils.
No periodic testing Is
required.
Followup testing
Unknown.
ro
oo
-------
V. LIST OF TELEPHONE INTERVIEWS
The following persons were contacted for information about their
state's policies and procedures for the treatment and disposal of
contaminated soils.
1. Alabama. Massey, S., Alabama Department of Environmental Management,
with Baetz, R., MRI. September 29, 1987.
2. Alaska. Miller, 6. and S. Osborne, Alaska Department of
Environmental Conservation, with Baetz, R., MRI. September 29,
1987.
3. Arizona. Ceilings, T., Arizona Department of Environmental Quality,
with Baetz, R., MRI. September 30, 1987.
4. Arkansas. Dunn, E., Arkansas Department of Pollution Control and
Ecology, with Baetz, R., MRI. September 30, 1987.
5. California. Patton, A., and K. Woodhouse, California Water Resources
Board, Department of Health Services, with Baetz, R., MRI.
September 30, 1987.
6. Colorado. Winters S., Colorado Department of Health, with Baetz, R.,
MRI. October 2, 1987.
7. Connecticut. Lee, C., and M. DeCaprio, Connecticut Department of
Environmental Protection, with Baetz, R., MRI. September 30, 1987.
8. Delaware. Herman, K., Delaware Department of Natural Resources, with
Baetz, R., MRI. October 2, 1987.
9. Washington, D.C. Padmanabha, A., Washington, D.C., Department of
Consumer and Regulatory Affairs, with Baetz, R., MRI. September 30,
1987.
10. Florida. Kulakowski,, Z., and J. Gentry, Florida Department of
Environmental Regulations, with Baetz, R., MRI. October 1, 1987.
11. Georgia. Langley, B., Georgia Hazardous Waste Management Division,
with Humphrey, L., MRI. October 5, 1987.
12. Hawaii. Lau, R., Hawaii Department of Health, with Humphrey, L.,
MRI. October 19, 1987.
13. Idaho. Brower, C., Idaho Water Quality Bureau, with Bailey, L.,
MRI. October 12, 1987.
14. Illinois. Ayers, T., Illinois Division of Land Pollutants Control,
with Humphrey, L., MRI. October 1, 1987.
24
-------
15. Indiana. Scranton, M., and 6. Oliver, Indiana Department of
Environmental Management, with Dean, J., MRI. October 16, 1987.
16. Iowa. Home, J., Iowa Department of Natural Resources, with
Bailey, L., MRI. October 5, 1987.
17. Kansas. Linn, C., Kansas Department of Health and Environment, with
Humphrey, L., MRI. October 2, 1987.
18. Kentucky. Huckaby, A., Kentucky Natural Resources and Environmental
Protection Cabinet, Division of Waste Management, with Dean, J.,
MRI. October 6, 1987.
19. Louisiana. Romanowsky, P., Louisiana Department of Environmental
Quality, Office of Solid and Hazardous Waste, with Bailey, L., MRI.
October 8, 1987.
20. Maine. Cogburn, P., Maine Department of Environmental Protection,
with Bailey, L., MRI. October 7, 1987.
21. Maryland. Meade, H., Maryland Department of Environment, with
Bailey, L., MRI. October 6, 1987.
22. Massachusetts. Benoit, E., Massachusetts Department of Environmental
Quality, with Bailey, L., MRI. October 13,, 1987.
23. Michigan. Couture, A., Michigan Department of Natural Resources
Environmental Protection Bureau, with Bailey, L., MRI. October 6.
1987.
24. Minnesota. Kable, D., Minnesota Pollution Control Agency Solid and
Hazardous Waste Management Division, with Efailey, L., MRI.
October 9, 1987.
25. Mississippi. Huff, W.9 Mississippi Bureau of Pollution Control, with
Bailey, L., MRI. October 9, 1987.
26. Missouri. Ackley, 6., Missouri Department of National Resources,
with Dean, J., MRI. October 6, 1987.
27. Montana. Riley, J., Montana Solid and Hazardous Waste Bureau, with
Bailey, L., MRI. October 9, 1987. \
28. Nebraska. Imig, B., Nebraska Department of Environmental Control,
with Humphrey, L., MRI. October 5, 1987.
29. Nevada. Biaggi, A., Nevada Division of Underground Storage Tanks,
with Humphrey, L., MRI. October 5, 1987.
30. New Hampshire. Woodbury, C., and R. Barry, New Hampshire Department
of Environmental Services, with Bailey, L., MRI. October 6, 1987.
25
-------
&EPA
United States
Environmental Protection
Agency
5403W
Washington, DC 20460
Official Business
Penalty for Private Use
$300
------- |