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Milwaukee Roundhouse

Milwaukee Roundhouse. Craig Myers, OSC Region 8. Milwaukee Roundhouse Case Study. Facility overview - 1923. Bunker Oil Tank. Elevated Tank. Site Background. Sources Historic 500,000 gallon abandoned Bunker C tank

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Milwaukee Roundhouse

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  1. Milwaukee Roundhouse Craig Myers, OSC Region 8

  2. Milwaukee Roundhouse Case Study

  3. Facility overview - 1923 Bunker Oil Tank Elevated Tank

  4. Site Background Sources Historic 500,000 gallon abandoned Bunker C tank Steam equipment was switched to oil fire prior to diesel equipment coming on-line in the ’40-’50s. Drain line from roundhouse to oil/water separator

  5. Site Background Sources Diesel fueling operations for yard engines in later years Small AST (not shown) Large tank was buried by the FD to snuff a fire using soil/debris on site.

  6. Brownfields Referral • Across the river from the roundhouse at the former passenger refueling area, not the roundhouse - initially. • 12+ inches of LNAPL in one well • Passenger area still being evaluated • ERU involvement at the former roundhouse • OSC: “Is there much oil on the site?” • BF staff reply: “I don’t think so.” • OSC elected to stay in his lane. • Until…

  7. Communication – always the #1 lesson learned… • OSC, ERT, NPFC case officer and State RPM meeting with the Mayor about the refueling area • OSC mentions something about the old bunker oil tank at the roundhouse • State RPM looks shocked and says “it’s never been removed.” • NPFC case officer issues a verbal ceiling of 50k for assessment, with the caveat that, if the tank is there, an approved ceiling of $250k.

  8. Side Note: PRPs under OPA • OPA amended in 2007 • Included CERCLA-like language re: involuntary acquisition for state/local governments • No liability if the property is acquired through tax liens or other sovereign acts • Powell County purchased this property in hopes of establishing a business park. Are they an RP? • CERCLA attorneys had determined the county to be exempt from liability. • Yes, according to the NPFC, Powell County is the only viable PRP.

  9. The tank is, indeed, still present. START, ERT and an EM 31 in town for the other site. ERT conducted Geophysical investigation to locate the tank/piping.

  10. Initial Assessment MT DEQ installed monitoring wells in 1990 Product identified on the ground water around the tank. Additional work ~ 2008 by County consultant under Brownfields grant. Severely under estimated the threat posed by the former tank and associated contamination. Assumed Bunker C not mobile in the sub-surface, and thus low priority.

  11. Where did the BF project derail? • BF program model – use state VCUP • County consultant failed to develop an acceptable plan • EPA BF rep instructed that some cleanup is better than none, had to spend the stimulus funds • BF program did not have the expertise to directly oversee the process/cleanup • Resulted in lack of proper prioritization/perspective.

  12. The Problem(s) Top half high in Lead and Arsenic – highest XRF reading was ~ 8,000 for lead – but low in petroleum Bottom half very high in extractable petroleum hydrocarbons (C40 and shorter) ~ 30-45,000+ ppm. Tank contained ~15,000 gallons of oily water from surface infiltration.

  13. What to do? • The Problem: • 10,000+ yds petroleum contaminated soil, some with elevated lead levels • 15,000 – 20,000 gallons oily water • Logistics: • Nearest landfill – 40 miles away, TEPH limit • Nearest oily waste facility – 80 miles away • Nearest refinery – 300 miles away

  14. Tank Excavation and Dewatering

  15. OSC Authorities (or lack of) under CWA… • Excavation (in a flood plain) and dewatering, and waiting on analytical was not be possible for dewatering. • Did I need a 404 permit to dig? • What about discharging the water? NPDES permit? • Permit waiver is in 300.400(e) • Specifically applies to actions under CERCLA Sections104, 106, 120, 121, and 122. • Does not apply to CWA 311(c) actions.

  16. Permits by Rule – CWA 404 • Work is in the Clark Fork flood plain. • The excavation needs a 404 permit. • Nationwide Permit 20 • State/District riders exist for each USACE District, and usually exist for each state. • May require RRT concurrence of OSC action(s). • Does not apply on “Wild and Scenic Rivers” • Does not exempt EPA/OSCs from other state requirements • NPDES and other water quality regulations

  17. Discharge Authority De-watering the tank to effect removal: • Oil water separator • Activated Carbon filtration bed • State had concerns over low levels of Vinyl Chloride in the area

  18. Roundtable Discussion: • Can the OSC discharge? • Do they need a permit? • If so, from who? • Do they have to sample first? • Why or why not?

  19. Discharge Authority – Argument 1 • Yes, the OSC can discharge. • Sampling is neither here nor there. It’s better than it started out, even if not perfect. • Clean Water Act definition of a discharge – 311(a)(2)(d) • …excludes discharges incidental to mechanical removal authorized by the President (delegated to the OSCs)…. • Intent is that the action is making the situation better. • States will counter with: CWA is a federal law, this exclusion does not apply to state laws.

  20. Discharge Authority – Argument 2 • Yes, the OSC can discharge. They decide what sampling is necessary. • 40 CFR 122.3(d) exempts any discharge under the direction of an FOSC from requiring a permit. • But, the State program can be more stringent. • Not in this case. • 40 CFR 123.1(g)(1) reinforces this. Specifically excepts the 122.3(d) exclusions w/r to states prohibiting all point source discharges. • Unless states have their own independent discharge permitting separate from NPDES rules, the buck stops at the OSC.

  21. Permit waivers are a CERCLA invention. • Montana Air Program permits • Do not allow this material to be burned in a kiln, or really burned period within the State of Montana. • Extend to what paving companies can have in their pit and use in their process • Can’t use it as road-base under a new paved road. • Can’t use it as aggregate for a new paved road.

  22. Permits, Permits, Permits • Land-farming in Montana requires a permit • Not eligible if <25 feet to groundwater • Groundwater at the site was ~12 feet • Treating over 2,000 cubic yards is a permanent facility • Requires more robust liner, quarterly monitoring, etc. • Did I mention we had 10,000+ yards? • Sending the waste to a fuel blender was cost prohibitive • started at $65 per yard to transport via rail, plus disposal fees at the fuel blender

  23. Disposal Options • Best viable option was re-use as road base… • Disposal concerns: • T&D costs ~ $54/yard due to distance • Potential TCLP failure for lead • Montana DEQ limit for TEPH at the landfill at 30,000 ppm. • Solution: did not try to separate the lead and petroleum soils during excavation. • Average truckload: 2,000 ppm Lead, <10,000 ppm TEPH, no TCLP failure

  24. Removing the tank Bedding material saturated w/ diesel.

  25. Beyond the tank removal • Discovery of diesel plume under the tank • Believe it to be the plume identified by the County contractor • Explains the excessive mobility of the bunker C oil.

  26. A whole new ballgame… • Recovered ~9,600 gallons of waste oil out of the excavation before backfilling and suspending the removal in late July 2011 • Groundwater study done August 2011 • Cut-off/Recovery system being designed, planned installation Spring 2012 • NPFC Ceiling to date: $1,900,000

  27. Questions? Bueller?......Bueller? Craig Myers myers.craig@epa.gov 303.312.7067

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