United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/SR-92/096 June 1992
EPA Project Summary
Potential Reuse of Petroleum-
Contaminated Soil: A
Directory of Permitted
Recycling Facilities
James H. Nash, Seymour Rosenthal, George Wolf, and Marilyn Avery
Soil contaminated by virgin petro-
leum products leaking from under-
ground storage tanks Is a pervasive
problem in the United States. Economi-
cally feasible disposal of such soil con-
cerns the responsible party (RP),
whether the RP is one individual small
business owner, a group of owners, or
a large multinational corporation. They
may need a starting point in their search
for an appropriate solution, such as
recycling.
This summary describes a more com-
prehensive report that provides initial
assistance in two important areas. First,
it discusses four potential recycling
technologies that manufacture market-
able products from recycled petroleum-
contaminated soil: the hot mix asphalt
process, the cold mix asphalt system,
cement production, and brick manu-
facturing. The report also presents the
results of a project survey designed to
identify recycling facilities. It lists recy-
cling facilities alphabetically by loca-
tion within each state, organized by
U.S. Environmental Protection Agency
(EPA) Region. The facilities shown have
each reported that they are operating
either under a permit or another re-
quired vehicle of formal state approval,
at the time of the survey; that they
have temporarily ceased previously ap-
proved operations; or that they are in
the final stages of the permit/approval
cycle and expect to begin operations
shortly. The report also Includes de-
tailed addresses, recycling locations,
telephone numbers, and contacts for
these facilities. The scope of the project
limits listings to fixed facilities or small
mobile facility owners that recycle soil
contaminated by virgin petroleum prod-
ucts into marketable commodities. It
does not address site-specific or com-
mercial hazardous waste remediation
facilities.
The Project Summary was developed
by EPA's Risk Reduction Engineering
Laboratory, Cincinnati, OH, to announce
key findings of the research project
that Is fully documented in a separate
report of the same title (see Project
Report ordering information at back).
Introduction
Soil contaminated by virgin petroleum
products leaking from underground stor-
age tanks is a pervasive problem in the
United States. Economically feasible dis-
posal of such soil concerns the respon-
sible party (RP), whether the RP is an
individual small business owner, a group
of owners, or a large multinational corpo-
ration. Disposal of such soil is costly, both
in terms of money and landfill resources.
Federal legislation makes the generator
responsible for soil contaminated by chemi-
cal materials, even if the contaminants
are virgin products rather than processed
waste [40 CFR 261.3(a)(92)]. In the case
of a large corporate site, the responsible
party may need a starting point for a com-
petent technical team that can explore the
appropriate remedies and implement them.
At the other extreme, however, for a small
business, finding an economically feasible
remedy may be more difficult. A typical
example is the gasoline station owner who
has arranged to have an old tank removed/
Printed on Recycled Paper
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replaced, but is then left with a substantial
pile of excavated, contaminated soil, cov-
ered by a tarpaulin pending cleanup.
Public Law 98:616 (the reauthorization
of the Resource Conservation and Recov-
ery Act, called RCRA, published in 1984)
mandates the development and implemen-
tation of an extensive regulatory plan for
underground storage tanks (USTs). The
-U.S. Environmental Protection Agency
(EPA) must promulgate the agency regu-
lations that protect human health and the
environment. Therefore, EPA must define
long-term corrective actions for the treat-
ment of petroleum-contaminated soils at
UST sites regulated under RCRA Subtitle
I.
Under RCRA, soil contaminated by vir-
gin petroleum product is not considered a
hazardous waste. However, the indivia'uar
states, and even individual communities,
have the right to legislate standards that
are more restrictive than federal statutes.
Such regulations, peculiar to a particular
state or community, can and do change
rapidly. Past trends indicate that the fu-
ture may bring even more restrictive stat-
utes on a state-by-state basis or even on
the federal level [42 USC 6901 et seq.,
RCRA Section 3006(a)]. Therefore, the
persons or companies responsible for the
disposal or recycling of petroleum-contami-
nated soil must periodically familiarize
themselves with any applicable legisla-
tion, and any changes to such legislation,
on the national, state, county, and munici-
pal level.
Due to differing statutes and random
changes, the concept of a permitted facil-
ity cannot be uniform. For the purposes of
this summary, "permitted" will mean that
the facility operates with formal govern-
mental authorization. This may take the
form of an air permit, a RCRA permit,
certification, or some other vehicle from
the appropriate governing body that for-
mally authorizes the facility's operation. In
some cases the permitting is required for
the manufacturing process, regardless of
whether petroleum-contaminated soil is
part of the raw material.
This summary concentrates the infor-
mation contained in a more comprehen-
sive report of the same title. The full re-
port focuses on fixed recycling facilities
that are authorized to accept soils con-
taminated by virgin petroleum products. It
discusses four technologies that transform
such material into marketable products:
the hot mix asphalt process, the cold mix
asphalt system, cement production, and
brick manufacturing. The report also in-
cludes a user-friendly, quick-reference
table listing the names and locations of
recycling companies in each state that
allows such services, supplemented by a
detailed directory of specific contacts for
further information. It does not address
facilities that handle hazardous wastes or
address recycling at commercial hazard-
ous waste facilities. Since most states con-
sider petroleum-contaminated soil only a
solid waste, these recyclers neither re-
quire RCRA Part B permitting nor listing
RCRA data bases as transportation/stor-
age/disposal (TSD) facilities.
Procedure
A two-stage survey methodology pro-
vided the framework for preparing the full
report'arid this project summary. During"
Stage I, surveyors contacted authorities
and private companies in each state to
identify its facilities for recycling petroleum-
contaminated soil. This stage contained
four segments: a brief review of some
extant listings of treatment facilities; tele-
phone interviews of selected permit per-
sonnel in EPA regional offices to identify
region-specific facilities and knowledge-
able state contacts; requests to each state
UST and LUST office for information on
facilities; and a telephone survey of recy-
clers to gather basic information about
their operations.
Stage II refined the scope of the sur-
vey, supplemented the listings, and re-
viewed some of the earlier information.
This stage designed a revised, more user-
friendly report that would provide a more
streamlined table, divided not only by EPA
Region, but also by state, which would
pinpoint recycling facilities for ready ac-
cess according to the primary user's first
concerns: location and identity. The report
would then tabulate the capacity, cost,
product, and contaminant issues that would
help the RP make a "first cut" of potential
resources. A detailed directory would fol-
low the table, enabling the user to easily
find all the necessary information for fol-
low-up inquiries after initial identification.
In addition to the revised Directory,
Stage II produced a more thorough dis-
cussion of the targeted marketable prod-
ucts (hot mix asphalt, cold mix asphalt,
cement, and brick) that when supple-
mented with additional illustrations would
aid the RP in better understanding the
potential of recycling technologies. The
concept of a marketable product received
added attention because it lowers the re-
cycling cost and increases the environ-
mental value of the selection. Also, the
targeted application (i.e., universal assis-
tance to RPs with widely varying volumes
of contaminated soil) eliminated irrelevant
site-specific remediation facilities incorpo-
rating these technologies. To clarify the
scope of the report, the governing defini-
tion of "recycling" in the report was limited
to the reuse of petroleum-contaminated
soil for another purpose. Therefore, it also
precluded the listing of onsite "treat and
dispose" operations.
Discussion of Technologies
Each technology section contains the
same components: a process summary,
process theory, required equipment, de-
sired product mix, and applications for re-
cycling. Simplified process flow diagrams
"and "sketches further illumih'ate"th"e"spe-
cific technology.
Under the scope of this report, four tech-
nologies recycle petroleum-contaminated
soil into marketable products: hot mix as-
phalt processes, cold mix asphalt systems,
cement production, and brick manufactur-
ing techniques.
Hot Mix Asphalt
The hot mix process employs both mix-
ing and heating to make paving material.
It blends and dries mineral aggregates
like sand, gravel, and crushed stone (with
a diameter as large as 3/4-in.), heating
them to 300 to 350 °F. Mixing hot asphalt
(5-10% by weight) with the hot aggregate
produces paving material.
A hot mix temperature of 300 to 350 °F
does not destroy the hydrocarbons vapor-
izing from the soil. Secondary combustion
chambers have modified the process in
some hot asphalt plants used for recy-
cling. The recycling of petroleum-contami-
nated soil takes place in the aggregate
preparation process. Exhaust treatment by
cloth filters (baghouses) provides a means
of controlling particulate emissions.
Cold Mix Asphalt
The cold process mixes aggregate and
liquid asphalt in small open pugmills or
revolving drums to form the paving mate-
rial. It uses surfactant to emulsify asphalt
cement in water. Anionic, cationic, and
nonpolar asphalt emulsions are available.
These materials may contain pplynuclear
aromatic hydrocarbons, depending on the
grade of asphalt cement from which they
are derived. The resulting emulsions are
relatively nonvolatile. The asphalt particles
are suspended in the liquid and separated
from each other (and the aggregate) by a
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film of water. During paving, pressure ex-
pels the film of water, bringing the asphalt
particles together in contact with the ag-
gregate.
Cement
The cement manufacturing process em-
ploys raw materials such as limestone,
clay, and sand which are usually fed to a
rotary kiln. The raw materials enter the
raised end of the kiln and travel down the
incline to the lower end, which is heated
by coal, oil, or gas. Petroleum-contami-
nated soils may enter the process as part
of the raw material or drop into the hot
part of the kiln. As the raw materials move
through the inclined, rotating kiln, they heat
to extremely high temperatures — up to
2,700 °F. These temperatures cause physi-
cal and chemical reactions such as evapo-
ration of free water, evolution of combined
water, evolution of carbon dioxide from
carbonates, and combination of lime with
silica, alumina, and iron to form the de-
sired compounds in the clinker. The petro-
leum-contaminated soil also breaks apart
chemically. At extremely high tempera-
tures, the organic compounds burn — pro-
ducing heat, carbon dioxide, and water
vapor. The inorganic components recom-
bine with the raw materials and the clinker
incorporates them. The clinker leaves the
kiln in golf-ball-sized lumps. The rapidly
cooled clinker, mixed with gypsum and
ground to a fine powder, produces Port-
land cement.
Brick
The brick manufacturing process blends
the petroleum-contaminated soil with the
clay and shale. It molds this raw material
into a green brick. Once the green brick is
dried and preheated, the kiln fires it at
1,700 to 2,000 °F for approximately 12
hours. The temperature and residence time
in the kiln destroy the organics, incorpo-
rating the inorganics in a vitrified brick
product.
Directory of Permitted
Recycling Facilities
The key portion of the comprehensive
report is its two-part DIRECTORY OF
PERMITTED RECYCLING FACILITIES.
The initial part of the Directory is a tabular
List of Permitted Facilities. This List identi-
fies permitted (or otherwise formally state-
approved) recycling facilities, organized
geographically by EPA Region. Within the
region, the List arranges the locations of
the facilities alphabetically within each
state. The facilities shown have each re-
ported their approval status (which is
shown on the List): they are operating
either under a permit or another required
vehicle of formal state approval at the
time of the survey; they have temporarily
ceased previously approved operations;
or they are in the final stages of the per-
mit/approval cycle and expect to begin
operations shortly.
[jnformation provided by the permitted
facilities was not verified by site inspec-
tion, copy of permit, or performance test-
ing. Any RP must require proof of permit/
approval before engaging in a contract.]
An RP can easily find potential recy-
clers by looking at the appropriate state
on the List and selecting those facilities in
the most convenient locations. Ail the de-
tails needed to obtain further information
appear in the subsequent, alphabetical (by
company name) section of the Directory
of Recycling Facilities. It provides specific
addresses, other recycling locations, tele-
phone numbers, and contact data for the
RP who may wish to follow up with indi-
vidual queries.
Each facility in the Directory has its own
analytical requirements. Because these
requirements (total hydrocarbons,
flashpoint, pH, etc.) respond to the local
state regulations as well as an individual
permit, they are subject to change. During
the follow-up query, the RP should re-
quest, from the selected facility, a written
list of requirements that apply at that time.
Conclusions and
Recommendations
The following conclusions have emerged
from this survey project to identify permit-
ted facilities that manufacture marketable
products from recycled petroleum-contami-
nated soil:
• This study identified 77 facilities in
the U.S. that recycle petroleum-con-
taminated soil into marketable prod-
ucts. They are not, however, evenly
distributed among the 10 EPA regions
or the 50 states.
• More than half of the recycling facili-
ties (41) are located in Region 1 and
Region 4 (22 and 19, respectively).
Region 5 has 13 approved facilities;
Region 3 has 11; and Region 10 has
5. The remaining facilities are spread
among the other five EPA regions.
• Most facilities in this study accepted
soil with all six typical contaminants
(gasoline, kerosene, diesel, fuel oil
#2, fuel oil #4, and fuel oil #6).
• Hot mix asphalt appears to be the
most commonly manufactured prod-
uct at these facilities. Other common
products consist of cold mix asphalt,
aggregate, hydraulic cement, and
brick.
• Regulations and requirements perti-
nent to recycling of petroleum-con-
taminated soil lie almost entirely within
the jurisdiction of individual states.
They vary significantly among the vari-
ous states.
• The cost per ton for recycling petro-
leum-contaminated soil ranged from
a low of $25Aon to a high of $100/
ton. The majority of the plants sur-
veyed reported a high of $50/ton.
• The constant changes in applicable
regulations and the rapid emergence
of new recyclers mandate the need
for scheduled updating of this techni-
cal resource document.
The full report was submitted in fulfill-
ment of Contract Number 68-C9-0033 by
Foster Wheeler Enviresponse, Inc., under
the sponsorship of the U.S. Environmen-
tal Protection Agency's Risk Reduction En-
gineering Laboratory.
•U.S. Government Printing Office: 1992 — 648-080/60026
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Jamas H. Nash is with Chapman, Inc., Atlantic Highlands, NJ 07716; and Seymour
Rosenthal, George Wolf, and Marilyn Avery are with Foster Wheeler
Enviresponse, Inc., Edison, NJ 08837.
Chten T. Chen is the EPA Project Officer (see below).
Th& complete report, entitled "Potential Reuse of Petroleum-Contaminated Soil: A
Directory of Permitted Recycling Facilities," (Order No. PB92-173 780/AS; Cost:
$17.00, subject to change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Edison, NJ 08837
United States
Environmental Protection
Agency
Center for Environmental
Research Information
Cincinnati, OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
Official Business
Penalty for Private Use $300
EPA/600/SR-92/096
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