MISSOURI RISK-BASED CORRECTIVE ACTION (MRBCA) FOR PETROLEUM STORAGE TANK SITES -

ON-SITE LANDFARMS

Hazardous Waste Program fact sheet
04/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2207

There are two general types of landfarms: off-site landfarms and on-site landfarms. Because of a decision between the Missouri Department of Natural Resources’ Water Protection Program and the department’s Hazardous Waste Program, the general permit for landfarms (MO-R401) will no longer be issued. This fact sheet will inform you about the requirement of constructing on-site landfarms only.

Landfarms that are operated off-site of the property on which a petroleum spill occurs will be required to obtain a site specific permit from the Water Protection Program. A land disturbance permit may be required for the construction of landfarms. Contact the Water Protection Program at 573-751-1300 for guidance or questions regarding a site specific landfarm permit or a land disturbance permit.

On-Site Landfarms
The Hazardous Waste Program will continue to provide oversight for any on-site landfarms, which do not accept waste from off-site sources regardless of owner. These on-site remedial actions will not be required to obtain a permit from the Water Protection Program, provided that these activities do not result in a discharge to waters of the state. In the event that a discharge is detected or contamination is found off-site, a site specific permit from the Water Protection Program is required. 

What types of contaminated soil can be landfarmed?
Only soils contaminated with gasoline, diesel fuel, fuel oil, kerosene or aviation fuel and having a TPH concentration of less than 2,500 ppm dry weight, may be placed in a treatment cell. This does not include soils contaminated with used oil, as described in 10 CSR 25-11.279. Find out more about resource recovery in the rules of the Department of Natural Resources located on the Secretary of State’s at http://www.sos.mo.gov/adrules/csr/current/10csr/10c25-9.pdf.

What are the treatment cell requirements and specifications?
Treatment cell construction and operation shall comply with all guidelines and regulations of the Solid Waste Management Program, Air Pollution Control Program, Water Protection Program and Hazardous Waste Program.

Treatment cells shall be located within the property boundaries of the cleanup site.

The treatment cell shall not be located within a wetland, or the 10 year floodplain of a classified stream, as defined in 10 CSR 20-7.031

The treatment cell shall be located at least:

The treatment cell shall be surrounded by a two-foot berm to contain contaminated soils, stormwater and exclude water run-on.

The treatment cell shall be lined with a petroleum resistant liner or impermeable layer (see below).

Can there be a stormwater discharge from the landfarm?
No, discharges to waters of the state are not permitted and are a violation of the Missouri Clean Water Law. The landfarm should be constructed so that the run-off from a 25 year, 24 hour storm event can be contained. In the event that a discharge is detected or contamination is found off-site, a site specific permit from the Water Protection Program may be required. 

How do I go about proposing a landfarm as a corrective action for my cleanup?
The corrective action plan should contain information regarding the landfarming of petroleum contaminated soils. This should include the following:

How must I construct the liner for my on-site landfarm?
The treatment cell shall be lined with a petroleum resistant or 12 ml plastic liner or a liner consisting of soils having a permeability coefficient of 10-7 cm/sec or less with a compacted thickness of at least 12 inches. The liner shall be placed and maintained so as to form a seal that effectively keeps stormwater in the cell. A 12 inch layer of material (such as limestone fines, etc.) that will not tear the liner and have a discernable color difference from the petroleum contaminated soil being treated shall be placed on top of the liner. The petroleum contaminated soil will then be placed upon this. Any plastic liner shall be removed upon termination of the landfarm. 

What guidance is available for constructing a landfarm?
Chapter 5 from a technical bulletin for the construction of landfarms is available on the U.S. Environmental Protection Agency’s Web site at http://www.epa.gov/oust/pubs/tum_ch5.pdf.  

How do I terminate the on-site landfarm?
Soil removed from the land farm should be managed in accordance with the Missouri Risk-Based Corrective Action (MRBCA) for Petroleum Storage Tanks, Guidance. Since there are two versions of this guidance currently in use, information that explains which version of the guidance document would apply to your site, is available on the Department’s Web site at http://www.dnr.mo.gov/env/hwp/docs/tanks-transition-explanation-11-20-13.pdf.

Soil must be sampled and may be removed if it complies with the applicable Tier 1 Risk Based Target Levels (RBTLs) for the applicable land use and applicable exposure pathways. As an alternative to determining the appropriate RBTLs, the site owner may instead remediate soils to comply with the Default Target Levels (DTLs). If soil will be remediated to DTLs, confirmation sampling is still required prior to removing the soil from the landfarm. In either case, the site owner shall submit sample analysis along with the proposed end use to Water Protection Program and Hazardous Waste Program for approval prior to removal.

The sampling frequency shall be one composite sample per 100 cubic yards of soil and composed of soil from no more than four separate locations collected from depths no less than 12 inches.

For more information

Missouri Department of Natural Resources
Hazardous Waste Program
Tanks Section
P.O. Box 176, Jefferson City, MO 65102-0176
1-800-361-4827 or 573-751-6822
www.dnr.mo.gov/env/hwp/tanks/tanks.htm

Missouri Department of Natural Resources
Water Protection Program
P.O. Box 176, Jefferson City, MO 65102-0176
1-800-361 4827 or 573-751-1300 office
573-526-1146 fax
www.dnr.mo.gov/env/wpp/index.html

Missouri Department of Natural Resources
Air Pollution Control Program
P.O. Box 176, Jefferson City, MO 65102-0176
1-800-361-4827 or 573-751-4817 office
573-751-2706 fax
www.dnr.mo.gov/env/apcp/index.html

Missouri Department of Natural Resources
Solid Waste Management Program
P.O. Box 176
Jefferson City, MO 65102-0176
1-800-361-4827 or 573-751-5401 office
573-526-3902 fax
www.dnr.mo.gov/env/swmp/index.html