RCRA Closure of Petroleum Contaminated Soil Containing Characteristically Hazardous Waste

In 2006, a Midwest sanitary landfill received over 21,000 tons of petroleum contaminated soil for treatment at the landfill’s permitted petroleum contaminated soil treatment unit. Upon receipt, the petroleum contaminated soils were stored as two piles within the footprint of the treatment area. Following delivery of the soil, the facility was notified through a notice of violation that the State agency considered the soil to contain an undetermined volume of characteristically (D018) hazardous waste. This conclusion was based on limited in-situ total benzene data and use of the “20 rule” from soil collected by the state agency during soil sampling activities at the initial spill site. This determination was made in spite of TCLP data provided by the generator prior to acceptance and by the facility following acceptance of the petroleum contaminated soil.

Through Director’s Final Findings and Orders, the facility was required to conduct RCRA closure at the areas in which the soil was stored and treated. Cox-Colvin was retained by a national solid waste management company which operated the Subtitle D facility conduct RCRA closure of the two areas. Cox-Colvin negotiated a closure approach and plan that involved constructing a compacted clay liner on which to treat the petroleum contaminated soil, moving the soil from the storage area to the treatment area and closure of the storage area, treatment of the soil in accordance with the facility’s permit to treat non-hazardous petroleum contaminated soil, and, following treatment, closure of the soil treatment area. Soil from the beneath the storage area was excavated and added to the petroleum contaminated soil piles for treatment. Following treatment, the treated soil was used for daily landfill cover. The compacted clay liner then was excavated (closed) and utilized for daily landfill cover. Clean closure by removal was certified by Cox-Colvin in 2011.

  • Negotiated novel closure approach which utilized existing permitted biological treatment technology to treat petroleum contaminated soil considered by State agency to contain characteristically hazardous waste
  • Treated soil, compacted clay liner, and underlying soils excavated during closure were used onsite for landfill daily cover at minimal cost
  • Clean closure eliminated ongoing post-closure activities and financial assurance