Ohio BUSTR Petroleum Contaminated Soil - Reuse, Treatment, and Disposal
Ohio BUSTR petroleum contaminated soil management - stockpile sampling, reuse action levels, storage limits, treatment options, and disposal requirements.
Overview
Every UST closure, corrective action excavation, and interim response action in Ohio generates soil that must be managed under BUSTR’s petroleum contaminated soil (PCS) rules. OAC 1301:7-9-16 and 17 (effective September 1, 2022) govern the characterization, storage, transport, treatment, disposal, and reuse of excavated soil from BUSTR-regulated petroleum UST sites.
The fundamental rule is simple: all excavated soil from a UST site is assumed to be PCS until analytical data proves otherwise. This means you must handle it as contaminated material from the moment it comes out of the ground, and you cannot dispose of it, reuse it, or leave it unmanaged without following the PCS rules.
When the PCS Rules Apply
The PCS rules apply to soil generated during any of the following activities at BUSTR-regulated petroleum UST sites:
- UST removals (permanent closure)
- UST upgrades
- Soil boring and monitoring well installations
- Immediate and interim response actions
- Corrective action activities (excavation, remedial system trenching)
Soil from exempt UST systems (Section 1.4 of the TGM) is exempt from the PCS rules. Volunteers who choose not to follow the PCS rules must consult with Ohio EPA’s Division of Solid and Hazardous Waste for proper disposal guidance.
Characterization
The 48-Hour Rule
PCS must be characterized and sampled within 48 hours of completing excavation activities. Until analytical data demonstrates otherwise, all excavated soil is managed as PCS.
Separating Soil by Contamination Level
The TGM requires separating soil based on the “apparent degree of contamination.” Piles with the same apparent degree of contamination may be combined, but each pile (including combined piles) must be characterized and sampled individually. When two or more lab results are required from one pile, the highest analytical result determines the disposition for the entire stockpile.
Soil from different UST sites may be combined for characterization purposes. However, if any COC exceeds reuse action levels, the entire combined pile must be disposed of or treated.
Hazardous Waste Screening
Characterization must also determine whether the soil is PCS or hazardous waste. Contact Ohio EPA’s Division of Hazardous Waste Management when evaluating soil as a potential hazardous waste. PCS that is classified as hazardous waste is excluded from the PCS rules and must be managed under hazardous waste regulations.
Calculating Stockpile Volume
The volume of each soil pile must be calculated to determine sampling requirements. In-situ soil volume must be converted to excavated volume by multiplying by an expansion factor of 1.25.
From Excavation Dimensions
- Measure the excavation (length x width x depth) to get cavity volume in cubic feet
- Divide by 27 to convert to cubic yards
- Subtract the volume of the removed UST(s) (1 U.S. gallon = 0.00495 cubic yards)
- Multiply the remaining in-situ volume by 1.25 to get the stockpile volume
Example: A 16 ft x 10 ft x 12 ft excavation containing one 5,000-gallon UST:
- Cavity volume: 1,920 cu ft / 27 = 71.1 cu yd
- Tank volume: 5,000 gal x 0.00495 = 24.75 cu yd
- In-situ soil: 71.1 - 24.75 = 46.35 cu yd
- Stockpile volume: 46.35 x 1.25 = 57.94 cu yd
From Stockpile Dimensions
For rectangular stockpiles: length x width x height, then divide by 27 for cubic yards.
For conical stockpiles: (1/3 x pi) x radius squared x height = volume in cubic feet, then divide by 27.
Stockpile Sampling Requirements
After calculating the stockpile volume, use the following table to determine how many samples to collect and submit to the lab:
| Stockpile Volume | Min. Grab Samples to Field Screen | Min. Samples to Lab |
|---|---|---|
| Less than 25 cu yd | 3 | 2 |
| 26-100 cu yd | 6 | 3 |
| 101-250 cu yd | 12 | 6 |
| 251-450 cu yd | 18 | 8 |
| More than 450 cu yd | 18 plus 1 per additional 50 cu yd | 8 plus 1 per additional 100 cu yd |
For containers 55 gallons or less: One grab sample from the center at mid-depth of the soil in the container, submitted directly to the lab.
Sampling Procedure
- Visually divide the stockpile into sections equal to the number of samples required for field screening
- Collect individual samples from the center of each section at a minimum depth of 12 inches below the stockpile surface
- Field screen all samples
- Submit the samples with the highest field screening readings to the lab
If field screening is not conducted, all collected samples must go to the lab.
Reuse Action Levels
If analytical results do not exceed any of the reuse action levels, the soil may be used for any lawful purpose. The reuse action levels are significantly lower than the closure action levels for several compounds - they represent the threshold below which soil is considered clean enough for unrestricted use.
| Chemical | Reuse Action Level (mg/kg) |
|---|---|
| Benzene | 0.0246 |
| Toluene | 7.07 |
| Ethylbenzene | 8.45 |
| Total Xylenes | 42.7 |
| Naphthalene | 0.051 |
| 1,2,4-Trimethylbenzene | 0.237 |
| MTBE | 0.158 |
| EDB | 0.000982 |
| EDC | 0.0101 |
| Benzo(a)anthracene | 12 |
| Benzo(a)pyrene | 1.2 |
| Benzo(b)fluoranthene | 12 |
| Benzo(k)fluoranthene | 120 |
| Chrysene | 1,200 |
| Dibenz(a,h)anthracene | 1.2 |
| Indeno(1,2,3-cd)pyrene | 12 |
| TPH C6-C12 | 1,000 |
| TPH C10-C20 | 2,000 |
| TPH C20-C34 | 5,000 |
Note that the reuse action levels for benzene (0.0246 mg/kg), toluene (7.07 mg/kg), and naphthalene (0.051 mg/kg) are roughly one-tenth of the Class 1 closure action levels for those same compounds. PAH and TPH reuse levels are the same as Class 1 closure levels.
What to Do with Excavated Soil
The disposition of excavated soil depends on the analytical results:
All COCs Below Reuse Action Levels
The soil may be used for any lawful purpose. It is no longer classified as PCS.
COCs Above Reuse Action Levels but Below Closure/Corrective Action Levels
The soil may be deposited back in the original excavation without treatment. It must be covered with a minimum of one foot of clean fill.
COCs Above Closure/Corrective Action Levels
With BUSTR approval, the soil may be deposited in the original excavation for the purpose of remediation under the corrective action requirements. Otherwise, it must be disposed of at a licensed facility or treated under an approved PCS Treatment Plan.
Analytical Results Not Yet Received
The soil may be temporarily placed back in the original excavation if the excavation is lined with a synthetic liner at least 10 mil (0.01 inch) thick. If closure results later show the soil exceeds action levels and it was placed in an unlined excavation, a Tier 1 Source Investigation is required.
Storage Requirements
PCS may be stored either on-site or off-site, subject to time limits and management requirements.
Time Limits
| Storage Location | Storage Method | Maximum Duration |
|---|---|---|
| On-site | Portable containers (properly labeled) | 180 days |
| On-site | Stockpiles (properly protected) | 120 days |
| Off-site | Any method | 90 days from excavation |
Management Requirements
- Submit the PCS Form within 10 days of storing PCS on- or off-site
- Inspect storage areas monthly for damage or unauthorized removal of drums, lids, labels, covers, berms, fences, barriers, or signs
- Maintain a written inspection log (must be produced within 24 hours if requested by BUSTR)
- Keep records of estimated volume and containerization/stockpile dates for five years
Disposal
PCS that cannot be reused or placed back in the excavation must be disposed of at a licensed disposal facility. The disposal facility may have its own sampling and characterization requirements beyond what BUSTR requires.
After disposal, submit a PCS Form to BUSTR documenting the final disposition of each stockpile, regardless of whether disposal was on-site or off-site. All PCS must be managed in compliance with applicable federal, state, and local requirements.
Soil shipped directly to a licensed disposal facility without being stored on-site does not require BUSTR characterization, but must be sampled to the extent required by the receiving facility.
Treatment
PCS may be treated on-site or off-site to reduce COC concentrations to at or below the reuse action levels. Treatment requires BUSTR approval through a PCS Treatment Plan before work begins.
Treatment Options
- Landfarming - spreading PCS in a thin layer and tilling it into native soil to promote biodegradation. Limited to summer months with periodic tilling.
- Biopiles - above-ground treatment in piles with aeration and/or amendment with nutrients and moisture to stimulate microbial activity
- Low-temperature thermal desorption (LTTD) - applying heat to volatilize COCs from the soil
- Other methods - road base/asphalt batching, soil shredding, soil washing, high-temperature thermal desorption. Reference the USEPA publication “How to Evaluate Alternative Clean-up Technologies for Underground Storage Tank Sites.”
Landfarming Restrictions
Landfarming has specific restrictions that do not apply to other treatment methods:
- Cannot be conducted in residential areas or near day care, long-term health care, or educational facilities
- Cannot be conducted in a DWSPA or Sole Source Aquifer
- Soils from Analytical Groups 4 and 5 (used oil, unknowns) cannot be landfarmed
- Multiple applications of PCS in the same treatment zone are not permitted
- PCS must be tilled into native soil (max 6 inches of PCS into 4-6 inches of native soil) within 48 hours of application
- Cannot be applied to frozen ground
- Cover crops cannot be used for human or livestock consumption
- Must demonstrate that leaching will not impact groundwater (may require monitoring wells)
PCS Treatment Plan
The treatment plan must be submitted to BUSTR within 90 days of the UST removal date or the date the stockpile was generated. The plan must include:
- Volume of soil to be treated
- Description of the treatment process
- Conceptual design (detailed engineering drawings not necessary)
- Discussion of treatment alternatives considered with cost and effectiveness comparison
- Monitoring plan
- Required permits (air emissions, water discharge)
- Implementation schedule and projected completion date
- Site maps showing treatment areas, property boundaries, structures, utilities, drainage, wells, and residences
Public notice is required for PCS Treatment Plans, following the same requirements as RAPs (certified mail to adjacent properties and local government, 21-day comment period).
Treatment Completion
At the conclusion of treatment, submit documentation demonstrating that COC concentrations have been reduced to at or below the reuse action levels. If the treatment technology has operated for at least one year and cannot achieve the targets, re-evaluate assumptions, re-evaluate alternatives, and submit a revised plan.
Releases from PCS Storage or Treatment
If soil or groundwater contamination is discovered as a result of PCS treatment or storage activities:
- Cease all additional PCS applications until BUSTR instructs otherwise
- Notify BUSTR within 24 hours of discovering the contamination
- Perform immediate corrective action and continue with the corrective action process as necessary
If monitoring wells at a landfarming site indicate COCs above action levels in groundwater, a Tier 1 Source Investigation is required.
Source
BUSTR Technical Guidance Manual (TGM) 2022, Chapter 4: Petroleum Contaminated Soil Requirements. OAC 1301:7-9-16 and 17. TGM Table 4.1: Stockpile Sampling Requirements. TGM Table 4.2: Re-Use Action Levels.