363. 7237 DEPARTMENT OF H2face 1391 HEALTH AND ENVIRONMENTAL SCIENCES STANSTEPHENS, GOVERNOR FAX#(406)444-1499 OF MONTANA STATE OFFICE 836FrontStreet MAILING CogswellBuilding LOCATION: Helena, Montana ADDRESS: Helena, MTS9620 MONTANASTATELIBRARY S363.7287H2fuce1991c.1 Solid and Hazardous Waste Bureau Factsheetforahazardouswastemanagem (406) 444-1430 3 0864 00072977 5 MEMORANDUM TO: Interested Parties FROM: Mark Hall DATE: April 19, 1991 SUBJECT: NOTICE OF ISSUANCE OF A DRAFT CLOSURE/POST-CLOSURE PERMIT FOR CENEX REFINERY IN LAUREL, MONTANA, MTHWP- 91-01 The Department has issued a draft closure/post-closure permit for the Cenex refinery in Laurel, Montana. The permit will be public noticed on April 21, 1991. Enclosed is a fact sheet which summarizes the proposed requirements. Please contact me if you have any questions. STATE DOCUMENTS COLLECTION r JUN 1 9 1991 nss E v .MONTANA 59G20 HELENA L v l Ln1 1 uL jMjL;,, I |Us'U I -j AN EQUAL OPPORTUNITYEMPLOYER FACT SHEET FOR A HAZARDOUS WASTE MANAGEMENT FACILITY PERMIT FARMERS UNION CENTRAL EXCHANGE/CENEX REFINERY LAUREL, MONTANA EPA ID. NO. MTD006238083 The Environmental Protection Agency, Region VIII (EPA) and the Montana Department of Health and Environmental Sciences (MHDES) intend to issue a hazardous waste management permit under Title 75, Chapter 10, Part 4 of the Montana Hazardous Waste and Underground Storage Tank Act (MSHWUSTA) and the Resource Conservation and Recovery Act (RCRA) to Cenex for the closure and post-closure care of a land treatment unit located at the refinery in Laurel and for the provisions of the Hazardous and Solid Waste Amendments of 1984 (HSWA). The State of Montana is authorized RCRA to administer and enforce those portions of in effect prior to the enactment of HSWA. EPA retains authority for HSWA regulations. This fact sheet was prepared in accordance with the requirements of 40 Code of Federal Regulations (C.F.R.) 124.8 and Administrative Rules of Montana (ARM) 16.44.904. PURPOSE OF THE PERMIT ISSUANCE PROCESS The purpose of the permit issuance process is to allow MDHES, EPA, other governmental agencies, and interested citizens the opportunity to evaluate the ability of the Permittee to comply with the applicable requirements promulgated under RCRA, as amended by HSWA. The draft permit sets forth all the applicable requirements with which the EPA and MDHES intend to require the Permittee to comply during the duration of the permit. The public is given forty-five (45) days to review and comment on the draft permit conditions prior to EPA and MDHES taking any final action on the draft permit. FACILITY DESCRIPTION The CENEX Refinery is located in Yellowstone County, Laurel, Montana. The refinery has existed at this location since 1930. The major products produced at the Cenex refinery are gasoline, diesel fuel, heating oils, asphalt, asphalt emulsions, deasphalted pitch, and propane. HAZARDOUS WASTE ACTIVITIES A thirty acre land treatment area was used from 1964 to November, 1988 for the treatment and disposal of a mixture of refinery sludges and leaded tank bottoms, all listed as hazardous wastes by the MDHES. The location of the unit is shown in Figure 1. Approximately 5,520 tons of waste were placed on the land treatment unit during its active lifetime. Land treatment, or landfarming, is a waste management practice in which soils receiving the waste are tilled and fertilized while microorganisms degrade the waste to a less hazardous form. Land treatment has been employed successfully for many years by the petroleum and chemical industries. In 1984, the State of Montana was authorized EPA by to regulate the land treatment of hazardous wastes. In November, 1984, Congress amended RCRA. The new amendments required operators RCRA of hazardous waste management units regulated under to submit an application for a final operating permit (Part B permit) or to close the unit. If hazardous wastes or hazardous waste constituents remain at the facility at closure, post-closure maintenance and groundwater monitoring are required for up to thirty years. These activities must be covered by a permit issued by MDHES. During the process of preparing a Part B permit application, Cenex discovered the presence of hazardous waste constituents at a depth of greater than five feet in the land treatment unit and elected to close the unit and send its hazardous waste to an off-site permitted treatment facility. Because of the presence of hazardous wastes in the landfarm, Cenex is required to have a Closure/Post- Closure permit which will specify the requirements and appropriate procedures for closing and monitoring the land treatment unit. Remediation and Closure of the Land Treatment Unit RCRA Under regulations, a hazardous waste management unit must be closed in a manner that: (1) Minimizes the need for further maintenance, and (2) Controls, minimizes, or eliminates to the extent necessary to protect human health and the environment, post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous wastes decomposition products to the ground or surface waters or to the atmosphere. The draft permit calls for the excavation of wastes and hazardous constituents which have migrated too deeply into the soil to be degraded. These contaminated soils will be placed on the surface of portions of the land treatment unit to allow for degradation to occur. The draft permit requires the continued operation of the land treatment unit for a period of up to five years. No new wastes may be added to the land treatment unit. Management practices are to be followed to provide optimum conditions for biological and chemical degradation, transformation, or immobilization of the hazardous constituents present in the waste. The management practices include tillage, and nutrient, pH, and moisture control. When soil samples taken from the unit indicate that hazardous constituents have degraded to either non-detection or to the maximum extent possible, the unit will be seeded with grass. Post-closure care may be required for up to thirty years. Cenex currently operates a groundwater monitoring program at the unit which has RCRA shown the release of hazardous waste constituents. regulations require corrective action for releases of hazardous constituents to groundwater from hazardous waste management units. The draft permit requires Cenex to submit MDHES a groundwater corrective action plan by January 1, 1992. will review the MDHES plan and request changes if necessary. will then prepare a draft permit modification to incorporate the plan into the permit. Additional public comment will be sought at that time. Post-Closure Care of the Land Treatment Unit Maintenance and monitoring of hazardous waste management units are required for a period of thirty years after closure. The draft permit establishes requirements for such maintenance and monitoring and includes maintenance of the vegetative cover, precipitaion run-on and run-off structures, groundwater and unsaturated zone monitoring. The draft permit also includes inspection schedules. MDHES RCRA The contact person for the portion of the permit is: Rosemary Rowe Department of Health and Environmental Sciences Solid and Hazrdous Waste Bureau Cogswell Building MT Helena, 59620 (406) 444-1430 HAZARDOUS AND SOLID WASTE AMENDMENTS One of the most important provisions of the Hazardous and Solid Waste Amendments of 1984 is the requirement for corrective action for continuing releases of hazardous waste or constituents from solid waste management units. Solid waste management units (SWMUs) are any active or inactive units at the facility from which hazardous waste or hazardous waste constituents might migrate, irrespective of when waste was placed in the unit or whether that unit was intended for the management of solid and/or hazardous RCRA wastes. This provision is established in Section 3004(u) of and can be found in the regulations at 40 C.F.R. 264.101. Congress established a requirement that all hazardous waste permits must address environmental contamination. All permit applicants must now (a) identify all solid waste management units (SWMUs) at the facility, (b) identify any releases that have occurred or are occurring from those units, (c) take appropriate corrective action to clean up those releases, and (d) demonstrate financial assurance for those corrective actions. As part of the HSWA permit, EPA Region VIII proposes to regulate SWMUs at Cenex subject to the corrective action provisions of HSWA. EPA Region VIII has completed SWMUs SWMUs a preliminary evaluation of the at the facility. Sixty-two and 11 areas SWMUs of concern were defined during this process. Included in the 62 are 28 active SWMUs units and 34 inactive units. The names and identifying numbers of the and areas of concern are given in Table 1. Figure 2 illustrates the approximate locations of SWMU's the at the facility. The basic standard for imposing corrective action at the Cenex Refinery is protection of human health and the environment. Module VI of the permit will address corrective action when there is or has been a probable release at the facility that poses a threat to human health and the environment. A substantial threat to human health and the environment is assumed if there is a likelihood of a hazardous waste or hazardous 125I . TABLE 1 Solid Waste Management Units Cenex Laurel Refinery Unit Number Unit Name Active SWMUs: Hydrocyclone 1 Tank 2 23 3 44 Tank 4 Pilkenroad Tilted Plate Separators API Separator 5 Dissolved Air Flotation Unit 6 Sludge Pit 7 Separation Towers 8 Clarifier 9 Sour Water Stripper I Wastewater Retention Pond System I Sputnik 1 13 HF Neutralization Pits 14 Old Landfill Pitch Waste Area 1 16 Asphalt Waste Area 17 FCC Catalyst Waste Area 18 Hot Process Lime Softener Waste Area 19 Calcium Fluoride Disposal Area 1 20 Half-Drum Storage Area and Reclaimer 21 Asbestos Waste Tanks 22 Wood Burn Area 23 Pitch and Asphaltic Material Reclaimer 24 Spent Caustic Recycler Tank 25 Heat Exchanger Cleaning Pad 26 Spent Lime Sludge Tank 27 Scrap and Drum Area 28 Miscellaneous Waste Area 3 Inactive SWMUs 29 Calcium Fluoride Disposal Area 2 30 Old Landfill Area 2 Leaded Tank Bottom Trench 3 32 Asphaltic Material Trenches 1 33 Spent Lime Sludge Trenches 34 Asphaltic Material and Spent Lime Sludge Disposal Area New Land Farm RCRA-regulated unit) 3 5 ( 36 Old Land Farm (RCRA-regulated unit) 1