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In the majority of cases when an underground storage tank (UST) is removed, soil contamination is discovered. This soil contamination is an environmental concern and may lead to the more serious problem of groundwater contamination. Before removing a leaking underground storage tank, you should examine some of the what ifs. Planning will save you both time and money. Treatment and clean-up actions relating to leaking underground storage tanks are abundant; however which one is the best?On-site and off-site treatment areas should be chosen with care. Ideal locations are at a reasonable distance (ie 100 feet) from wetlands, streams, residential areas, or other locations where potential run-off or fugitive vapors may result in threats to the environment or cause public exposure or nuisance conditions. Proposed treatment within a 100 year flood area will require a case by case review. You must have the property owners written approval to use their site for treatment of contaminated soils. Public access to the aerating soil must be restricted. This may require fencing the area and/or posting signs at the site to alert the public of potential health hazards. The treatment area must be prepared to meet certain conditions including lining, berming, and covering the contaminated soil (except during active treatment times). This is necessary to prevent surface water run on and run off within the treatment area. Ideally, the petroleum contaminated soil should be spread within the prepared treatment area at a depth of 6 to 1 inches and left exposed to the atmosphere. The contaminated soil should be covered with plastic sheeting during rainy periods. The plastic sheeting should be weighted or anchored so that the soil does not become exposed during storms or windy conditions. Periodic tilling or turning of the soil is generally necessary in order to facilitate complete treatment. The treatment site must be checked periodically to ensure that site security remains intact, to make progress checks on the treatment, and to generally assure that everything is going according to plan. This is especially important in order to prevent problems from developing. Another method of clean-up action is soil removal.If soil removal appears to be the best method for soil cleanup, a decision must be made concerning how the soils will be managed. Once the soils are removed, they can be independently treated (by you or your consultant) or taken to an authorized facility for treatment or disposal. If the soils are to be independently treated, precautions must be taken to prevent adverse environmental impacts or nuisance conditions. Stockpiling of contaminated soils can only be conducted on a temporary basis while making arrangements for disposal or treatment. During this time, soils must be placed within a secure (i.e. fenced), lined, and bermed area and kept covered at all times. Individuals or corporations have thirty (0) days to either dispose of the soil at an authorized facility or to obtain a solid waste treatment permit from their local Department of Environmental Quality. As landfill space becomes restricted, the cost of disposal of contaminated soils may go up. Ideally, no contaminated soils would be disposed of in a landfill since this result's in the problem being moved from one location to another. Also, should there be problems with the landfill in the future, or if cleanup of the landfill should be required, persons who disposed of contaminated soil in the landfill may be held partially responsible for cleanup costs. However, until alternative disposal and treatment methods become readily available, landfill disposal may be the most cost effective option for some cleanup projects. One should be aware that individual landfills may have specific requirements that must be met before disposal is allowed. If landfill disposal is the option chosen, contact them in advance ensure that ample time is allotted to coordinate sampling efforts to meet both landfill, public, and federal requirements at the same time. Another treatment method is above ground treatment.
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This treatment method is excellent for gasoline contamination and works relatively well for diesel, waste oil, and other heavy hydrocarbon contamination which does not aerate readily. Since the treatment results in destruction of the contaminants, this method reduces long term liability and is a better environmental solution than soil aeration or landfill disposal. However, unless the amount of soil to be treated is large, bioremediation is a relatively costly method for dealing with contamination. The services of a qualified consultant are usually necessary in the design of an appropriate treatment system. A solid waste permit from your local Department of Environmental Quality might be required. There are some restrictions on how the treated soil can be reused.Soil aeration works best for gasoline contaminated soils. Due to the low volatility of diesel and heavier hydrocarbons, soil aeration for these contaminants is very slow or requires frequent maintenance (tilling, etc.) and often does not work at all. Aeration of gasoline contaminated soils works best on sandy or silty soils with low clay content, and is most effective in warm, dry weather.If the proposal for handling the petroleum contaminated soil includes on-site or off-site bioremediation, soil aeration, or thermal treatment with a mobile unit, a solid waste permit for treatment is required. This type of permit is called a Solid Waste Letter of Authorization. One will need to obtain approval for the treatment site from the local land use authorities before you proceed. The application for a solid waste treatment permit requires that a written Treatment Plan be prepared that demonstrates the ability to be able to effectively treat the contaminated soil. The owners of the properties where the treatment will occur, and where the treated soil will be reused, must sign statements to document that they understand what the restrictions are with these activities. Permits are good for six months from the date issued. Generally, if treatment has not been successful within one treatment season, find alternatives (disposal at an approved facility) for handling the soil (although there may be some exceptions, as in the case of true bioremediation projects). If the proposal to treat soil from one or more cleanup project at a single location, a more comprehensive solid waste permit will be required. The Letter of Authorization contains specific permit conditions which must be met throughout the treatment period. Violations of permit conditions could result in enforcement actions that include civil penalties or revocation of the permit. In addition to the permit requirements for treating soil, some cleanup projects may also require a Water Quality permit to discharge water from an excavation or discharge treated water from a groundwater treatment system. Representative soil samples must be collected quarterly to measure the reduction of concentrations and progress reports submitted to the Department of Environmental Quality in your region. Soil treatment activities must be coordinated throughout the project and approval received before moving any contaminated or treated soils off-site. Regardless of the treatment methods, there are some restrictions on how the treated soil can be reused. Contact the regional DEQ office that has jurisdiction for your cleanup project for more information.Thermal treatment is preferred over aeration and landfill disposal. This treatment method may reduce your future liability for the contaminated soils (the cradle to grave philosophy). Contaminated soil can be treated on-site through the use of a mobile unit or transported to a stationary facility. A mobile unit is especially useful for sites that are remote from a permanent thermal treatment facility or landfill. Costs in hauling the contaminated soil can be saved or reduced. However, you must be careful to ensure that your treatment site is suitable for the treatment equipment. Individuals will need to contact local land use authorities to make sure this activity is allowed for your site. Specific information about the use of the mobile unit must be provided to the Department. A solid waste permit from the Department of Environmental Quality is required. There are some restrictions on how the treated soil can be reused. Contact the regional DEQ office that has jurisdiction for the cleanup project for more information. A permanent facility operates similar to a landfill from a user perspective. Individuals must provide the facility with information about where the contaminated soils originated and contamination levels. Once the application has been approved, the contaminated soils are taken to the facility for processing. The beginning manufacturer involvement is then over, unless arrangements for reusing the treated soil have been accomplished. Contact the specific facilities for more information on their specific requirements.To minimize treatment costs, careful advance planning is required. Although several options are present, some are more desirable than others. From an environmental perspective, your local Department of Environmental Quality will most likely strongly encourage selection of a treatment method that actually destroys contamination rather than transferring it from one media to another (e.g. from soil to air). In addition, effective treatment of soils - if done correctly - results in the ability to reuse the soil for other purposes (with some restrictions). Therefore, individuals may be required to submit information to justify the selection of other, less environmentally preferred methods for handling petroleum contaminated soil. Because treatment conditions for each site are unique, proper planning, execution, and remedial action with need to be accomplished. Careful coordination and prior approval from your local Department of Environmental Quality regional office at specific junctures in the treatment process is extremely important. A final determination that no further action is required for the entire cleanup project will not be made until all details regarding the treated soils have been satisfactorily addressed and documented. WORKS CITEDhttp//ecfrback.access.gpo.govhttp//www.epa.gov/swerust1/fedlaws/statute.htm Please note that this sample paper on Leaking Underground Storage Tanks is for your review only. 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