BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
WEBEL FEEDS and TLHUS, INC.
as Successor-in-Interest,
Petitioner,
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PCB
(+-71'-anX
0 IS
/A
v.
?
(UST Appeal)
RECEIVED
CLERK'S
OFFICE
NCV
1 5 2007
_STATE OF ILLINOIS
P
ollution
Control Board
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
NOTICE OF FILING
PLEASE TAKE NOTICE that I have filed with the Office of the Clerk of the Pollution
Control Board the APPEARANCE of Jeryl L. Olson and APPEAL OF UNDERGROUND
STORAGE TANK DECISION, copies of which are herewith served upon you.
Jeryl L. Olson
Seyfarth Shaw LLP
131 N. Dearborn Street, Suite 2400
Chicago, Illinois 60603
(312) 460-5000
Dated: November 15, 2007
C111 11350891.1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PCB erinCXDg
Yk
D
C
ECEIVED
LERK'S OFFICE
NC
V
1 5 2007
;STATE
OF ILLINOIS
0110H,ln
Control Board
WEBEL FEEDS and TLHUS, INC.
as Successor-in-Interest,
Petitioner,
v.
(UST Appeal)
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
APPEARANCE
I hereby file my APPEARANCE in this proceeding, on behalf of Pittsfield/Webel Feeds.
Jeryl L. Olson
Seyfarth Shaw LLP
131 N. Dearborn Street, Suite 2400
Chicago, Illinois 60603
(312) 460-5000
Dated: November 15, 2007
(THIS DOCUMENT IS SUBMITTED ON RECYCLED PAPER)
CHI 11350891.I
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDR
CLERKS
ECEIVE
OFFI
D
CE
WEBEL FEEDS and TLHUS, INC.
)
as Successor-in-Interest,
))
Petitioner,
v.
)
)
ILLINOIS ENVIRONMENTAL PROTECTION
)
AGENCY,
)
Respondent.
)
PCI3SICICX
t
(UST Appeal)
NOV 1 5 2007
STATE OF ILLINOIS
Pollution Control Board
APPEAL OF UNDERGROUND STORAGE TANK DECISION
Pursuant to the requirements of 35 IL Adm. Code Part 105 Subpart D, Webel Feeds, and
its successor-in-interest, TLHUS, INC., (hereinafter "Company," or "Petitioner") through their
counsel, Seyfarth Shaw LLP, hereby appeal the October 4, 2007 final decision of the Illinois
Environmental Protection Agency ("Agency") rejecting the Company's Amended Corrective
Action Plan dated September 12, 2007, ("Amended CAP") for LUST Incident No. 921798. The
final decision of the Agency appears in Exhibit A. Pursuant to 35 11. Adm. Code § 105.402, the
Company is entitled to file a Petition for review of the Agency's determination concerning the
Corrective Action Plan for the high priority site. The final decision was received by the
Petitioner on October 11, 2007, and the deadline for this appeal is November 15, 2007.
The grounds for this appeal are the Agency's arbitrary and capricious actions in rejecting
the Amended CAP including:
1. The
Agency's rejection of Petitioner's alternative remedy as set forth in the
Amended CAP;
CHI 11350891.1
2. The
Agency's requirement that the groundwater recovery and remediation system
currently operated by the Company be shut down;
3.
The Agency's error in identifying downgradient off-site groundwater as Class 11
groundwater, contrary to the 35 IL Adm. Code Part 620 classification regulations, which if
properly applied, would cause the water to be classified as Class 1 groundwater;
4.
The Agency's determination that a No Further Remediation Letter ("NFR") can
be issued without further remediation to meet offsite groundwater cleanup objectives or without
elimination of the offsite groundwater pathway using an institutional control.
In support of this appeal, Petitioner states as follows.
a. Webel
Feeds, Inc. produced and stored animal feeds at its Pittsfield facility,
located along Rural Route No. 3 in Pike County, Illinois. (Webel Feeds has changed ownership
several times; first to PM Ag Products, then to the Company, and then to The Maschhoffs.)
TLHUS is taking responsibility for the LUST Incident and resolution thereof. The facility at
which the incident occurred is approximately 3-miles north of Pittsfield, Illinois and 1.5-miles
south of U.S. Route 36. The facility is bordered in all directions by farmland, with an unnamed
creek.
In 1994, a remediation system was first approved by Illinois EPA to treat soil and
groundwater contamination resulting from a release of leaded and unleaded gasoline and diesel
fuel from five (5) underground storage tanks (USTs) (Incident Number 921798). From
December 1994 to October 2003, Corrective Actions were performed under the regulations of 35
IL. Adm. Code § 731, and detailed in CAP Addendums and Groundwater Monitoring and
Remediation Progress Reports. In 2003, the Agency approved addressing the remediation under
the then-newly approved 35 II. Adm. Code § 734 regulations.
CHI 11350891.1
Over the years Petitioner has undertaken substantial remediation of the LUST incident;
the response has included expenditures in excess of $1 million to treat contaminated soils by
soils vapor extraction ("SVE"), to treat saturated soils and groundwater by chemical injection,
and to install and operate a groundwater "pump and treat" remediation system.' Groundwater is
monitored to demonstrate the remediation system operates successfully to maintain off-site
groundwater below Tier 1 standards for Class I groundwater (the most stringent groundwater
standards applicable to the agricultural land down gradient). Despite the Company's efforts,
under current conditions, without further remediation of soils, it is estimated the groundwater
remediation system would need to be operated for 3 to 10 more years at a cost of $50,000 -
$75,000 per year to maintain offsite groundwater below the Class I Tier 1 standards.
In May 2003, expressing concern that the groundwater treatment system was operating
too slowly and with minimal effect, the Agency suggested Petitioner take an alternative approach
to remediation. Since that time, Petitioner has submitted various CAP amendments or
addendums, including the Amendment that is the subject of this Appeal. (Exhibit B contains
relevant portions of the CAP Amendment, without Appendices).
As an alternative to long-term groundwater treatment and monitoring, in the Amended
CAP Petitioner proposed excavation and removal of the soils contributing to the groundwater
contamination, at a cost of approximately $110,000. That remediation, combined with several
months continued operation of the groundwater treatment system, would restore the groundwater
to cleanup objectives within months (as opposed to the 3-10 years estimated cleanup under the
The SVE system has been discontinued since 2001, however, the groundwater pump and treat
remediation system continues in operation.
CHI 11350891.1
existing system), in a more cost effective manner than the existing long-term groundwater
remediation by "pump and treat."
Despite the demonstration by Petitioner that the remediation proposed in the Amendment
is better for the environment and is more cost effective than the current groundwater remediation
system, in the final Agency action at issue the Agency rejected the proposal for soils excavation
and removal. On its face, such action by the State is arbitrary and capricious, however, the
Agency's actions go much further than being arbitrary and capricious. Not only has the Agency
rejected the technically feasible and economically reasonable amended remediation plan, it has
further advised Petitioner "The groundwater recovery and remediation system at this site needs
to be shut down." This requirement is environmentally and legally unreasonable. Modeling and
monitoring have show that cessation of operation of the current groundwater remediation system,
without further remediation of soils, would cause the contamination levels in off-site
groundwater to increase above the Class I, Tier 1 cleanup objectives, posing a risk to human
health and the environment. If Petitioner complies with the Agency directive, Petitioner
becomes potentially subject to common law, statutory and regulatory liability to the state, the
federal government and private parties, for the exceedences which would occur by shutting down
the groundwater treatment system.
Because Petitioner has proposed a technically feasible, economically reasonable and
environmentally preferable alternative to the current remediation system, the Agency's denial of
the Amended CAP is arbitrary and capricious; furthermore, the Agency's direction to Petitioner
to "shut down" the groundwater treatment system, will likely result in risks to human health and
the environment, and will subject Petitioner to liability.
CHI 11350891-1
b.
Despite several attempts by Petitioner to correct the Agency's error, the Agency
has improperly characterized off-site groundwater as Class II groundwater; it is the Petitioner's
position that the off-site groundwater is Class I groundwater. As measured by Petitioner, the
hydraulic conductivity of groundwater in MW-16 (which is an off-site monitoring well) is 4.26 x
lecm/s; by definition, groundwater is considered Class I groundwater if the hydraulic
conductivity is greater than 1.10'
4
cm/s. Therefore the off-site groundwater is Class I
groundwater.
This mistake in groundwater classification by the Agency has significant ramifications
both in terms of the environment, and for the liability of the Petitioner. An improper Class 2
characterization by the Agency will result in a higher groundwater cleanup objectives for the off-
site groundwater, allowing higher levels of contaminants to be present than should be allowed in
this potable water source. The State's mischaracterization puts the state's most protected class of
groundwater at risk, and does not protect the adjacent agricultural property owner, as there are no
institutional controls present for the adjacent site which prohibit the use of the groundwater as
potable drinking water.
Further at issue is legal risk to Petitioner; if Petitioner follows the Agency's directive to
cease the operation of the groundwater remediation system, the contaminant levels are modeled
to exceed the Class I cleanup objectives. If the State (or a third party) recognizes later that the
Agency made a mistake in the classification, Petitioner would potentially have liability for
allowing the contamination in excess of the standards, even though the cessation of operation of
the system was at the direction of the Agency.
c.
In the absence of the additional soils remediation proposed by Petitioner in the
Amended CAP, groundwater contaminant concentrations will not naturally attenuate to the Class
C111 11350891.1
I groundwater Tier 1 cleanup objectives before reaching the adjacent property. According to
State regulations, in order to be eligible for an NFR, it is necessary for the site to either remediate
the off-site groundwater to meet applicable standards, or, as an alternative, to ensure an
institutional control (or environmental land use control) is in place to limit off-site use of the
groundwater, and thus eliminate the groundwater pathway. Because in the absence of the
Petitioner's proposed soils remediation, the groundwater will not meet cleanup objectives for
several years, and because of the absence of institutional controls on adjacent property to limit
the exposure pathway, the State cannot at anytime in the next few years issue a No Further
Remediation Letter ("NFR") to Petitioner. The Agency is aware there are currently no
institutional controls in place limiting use of off-site groundwater on the adjacent property, and
that the off-site groundwater does not meet cleanup objectives without operation of the
groundwater treatment system. If the groundwater remediation system is "shut down" as
required by the Agency, the groundwater contaminant levels will exceed applicable standards,
and because there are no institutional controls in place to eliminate the groundwater pathway,
contrary to the Agency's assertion in the final agency determination that ". . . the No Further
Remediation Letter can be issued for the incident after providing documentation that the on-site
well has been properly abandoned. . .", state law will not allow issuance of the NFR at any time
in the foreseeable future. Therefore the Agency's rejection of the Petitioner's Amended CAP,
and the Agency's proffered directive to shut down the existing remediation system is arbitrary
and capricious, is not in conformance with state law, and poses a risk to the environment.
Petitioner's Amendment to the Corrective Action Plan proposes effective remediation to
the levels necessary to form the basis of issuance a NFR in a much shorter time than the current
remedy. Remediation is necessary because establishment and reliance on an institutional control
CHI 11350891.1
is not an option to address offsite groundwater contamination on the adjacent property. For the
reasons set forth above, Petitioner respectfully requests a public hearing of this matter, and a
determination by the Board that the Amended Corrective Action Plan be approved.
Jeryl L. Olson
Seyfarth Shaw LLP
131 N. Dearborn Street, Suite 2400
Chicago, Illinois 60603
(312) 460-5000
Dated: November 15, 2007
CHI 11350891 1
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached APPEARANCE, NOTICE OF
FILING and APPEAL OF UNDERGROUND STORAGE TANK DECISION on November 15,
2007 by U.S. Mail, upon:
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL
62794-9276
CIII 11350891.1
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST, P.O. Box 19276,
SPRINGFIELD,
ItuNots 62794-9276 - ( 217) 782-3397
JAMES R. THOMPSON CENTER, 100
WEST RANDOLPH, SUITE 11-300,
CHICAGO,
IL 60601 - (312) 814-6026
ROD R. BLAGOIEVICH, GOVERNOR
?
DOUGLAS
P.
SCOTT, DIRECTOR
217/782-6762
OCT 0 4 2007
PM Ag Products, Inc.
Attention: Don Moster
2200 East Eldorado Street
Decatur, Illinois 62525
Re: LPC #1490755017 -- Pike County
Pittsfield / Webel Feeds
Rural Route 3
Leaking UST Incident No. 921798
Leaking UST Technical File
Dear Mr. Moster:
CERTIFIED MAIL
7007 0220 000E1 0152
9917
The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the Amended
Corrective Action Plan (plan) submitted for the above-referenced incident. This plan, dated
September 12, 2007, was received by the Illinois EPA on September 17, 2007. Citations in this
letter are from the Environmental Protection Act (Act), as amended by Public Act 92-0554 on
June 24, 2002, and 35 Illinois Administrative Code (35 Ill. Adm. Code).
The plan is rejected for the reason(s) listed below (Sections 57.7(b)(2) and 57.7(c) of the Act and
35 III. Adm. Code 734.505(b) and 734.510(a)):
The proposed activities are excessive since it appears that the applicable objectives can be
met without completing additional excavation. Information has already been submitted for
this site that shows Tier 2 objectives can be met without completing the proposed soil
excavation or obtaining an institutional control with the adjacent property owners. Modeling
has demonstrated that Class I groundwater objectives are met before reaching off-site
monitoring wells near the neighboring creek. The clayey/silty sand layers encountered in
MW-16, 17, and 18 do not meet the Class 1 groundwater definition since the hydraulic
conductivity reported from the area was less than 1 x 10
4
cm/s.
The groundwater recovery
and remediation system at this site needs to be shut down
and the approach provided in Attachment A of the Illinois EPA review letter dated July
24, 2007 needs to be followed. The No Further Remediation Letter can
be issued for
this incident after providing documentation that the on-site potable water supply
well
has been properly abandoned and post-remediation groundwater sampling completed.
ROCKFORD -
4302 North Main Street, Rockford, IL 61103 - (615) 987-7760 • DES PLAINES -
9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000
ELGIN -
595 South State, Elgin, IL 60123 - (847)608-3131
?• PEORIA -
5415 N. University St., Peoria, IL 61614 - (309) 693-5463
at IREAU OF
LAND -
PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462•
CHAMPAIGN -
2125 South First Sheet, Champaign, IL 61820 - (217) 278-5800
SPRINGFIELD -
4500 S Sixth Street Rd., Springfield, IL 62706 - (217) 786-6892 •
COLLINSVILLI -
2009 Mall Street, Collinsville, IL 62234 - (618) 346-5120
MARION - 2309 W. Main St., Suite 116, Marion, IL 62959 - (618) 993-7200
PRINTED ON RECYCLED PAPER
EXHIBIT A
Page 2
Pursuant to Sections 57.7(b) and 57.12(c) and (d) of the Act and 35111. Adm. Code 734.100 and
734.125, a plan and/or budget must be submitted within 90 days of the date of this letter to:
Illinois Environmental Protection Agency
Bureau of Land - #24
Leaking Underground Storage Tank Section
1021 North Grand Avenue East
Post Office Box 19276
Springfield, IL 62794-9276
Please submit all correspondence in duplicate and include the Re: block shown at the beginning
of this letter.
An underground storage tank system owner or operator may appeal this decision to the Illinois
Pollution Control Board. Appeal rights are attached.
If you have any questions or need further assistance, please contact Melinda Friedel, P.E. at
217/785-5736.
Sincerely,
9-4Michael
T. Lowder
Unit Manager
Leaking Underground Storage Tank Section
Division of Remediation Management
Bureau of Land
Attachment: Appeal Rights
c: Christopher
Cailles / DAI Environmental, Inc.
BOL File
Erwiconmenlal Engin/op 1/2. Geulog ,„ and Scitinlisla ?
Tel 847, 57 3. 8900
?Polo
Park Business
Gaoler
?
Fax /347.573.0953
?278311
N. Irma (ea
Circle
Lake
Forest. Minds 60045.5130
November 5, 2007
Ms. Melinda Friedel
Illinois Environmental Protection Agency
Bureau of Land
LUST Section
1021 North Grand Avenue East
P.O. Box #9276
Springfield, IL 62794-9276
Re: LPC # 1490 75501 7 – Pike County
Pittsfield/Webel Feeds
Rural Route # 3
Pittsfield, IL 62363
Incident II: 921798
LUST Technical File
Ms. Friedel,
This letter is written in response to the Illinois EPA letter dated October 4, 2007. The Illinois
EPA letter rejected the September 12, 2007, dated
Corrective
Action Plan Amendment
(CAP
Amendment) written by DAI Environmental, Inc., (DAI) for Webel Feeds (Site), Incident
Number 921798.
The CAP Amendment proposed a modification to the Illinois EPA suggested approach to Site
Closure that was detailed in Attachment A of a letter dated July 24, 2007. DAI indicated that
TACO modeling cannot be used to achieve Site Closure without further remediation and
presented soil excavation and disposal as the most ex
pedient
and certain method to complete the
remediation. With removal of most highly contaminated soils, then TACO modeling could be
used to achieve final Site Closure. The Illinois EPA October 4, 2007, letter rejected DAI's
modification and stated the following:
The proposed activities are excessive since it appear that the applicable objectives can be
met without completing additional excavation. Information has already been submitted
for this site
that shows Tier 2 objectives can be met without completing the proposed soil
Ms. Melinda Friedel
November. 2007
excavation or obtaining an institutional control with the adjacent property owners.
Modeling has demonstrated that Class I groundwater objectives are met before reaching
off-site monitoring wells near the neighboring creek. The clayey/silty sand layers
encountered in MW-16, 17, and 18 do not meet the Class 1 groundwater definition since
the hydraulic conductivity reported from the area was less than 1 x 10-4
cm/s.
The groundwater recovery and remediation system at this site needs to be shut down and
the approach provided in Attachment A of the Illinois EPA review letter dated
July 24, 2007 needs to be followed. The No Further Remediation Letter can be issued for
this incident after providing documentation that the on-site potable water supply well has
been property abandoned and post-remediation groundwater sampling completed.
In response to the above comment, Tate & Lyle would like to point out discrepancies in the
information used by Illinois EPA. Illinois EPA is correct that fate and transport modeling has
been provided indicating that on-site groundwater contamination will attenuate to Tier 1 Class I
Groundwater Remediation Objectives (GROs) before reaching off-site monitoring wells
(MW-I6 to MW-18) near the neighboring creek. However, although current groundwater
concentrations on-site will attenuate before reaching the off-site monitoring wells that are located
62.75-feet downgradient, modeling indicates that concentrations will not attenuate to Tier I
Class I GROs before extending onto the neighboring property that is located only 25.5-feet
downgradient. The table included in the September 2007 CAP Amendment clearly demonstrated
these results. Therefore it is incorrect to state that Tier 2 GROs
can
be met without obtaining an
environmental land use control (ELUC) from the neighboring property owner, and Illinois EPA
has been clearly informed that
an
ELUC is not an option.
Further, although a Class H groundwater designation will apply on-site following the formal
abandonment of the on-site potable water well, Illinois EPA is incorrect in stating that the
downgradient groundwater does not meet the Class I groundwater definition because the
hydraulic conductivity reported from the area was less than I x 10
6
cm/s. The August 30, 2006,
report provided data analysis showing a hydraulic conductivity at off-site monitoring well
MW-16 of 4.26x10-etn/s, greater than the Class I criteria of 1 xle-cm/s and an observed
clayey sand layer of over 5-feet in thickness. Therefore, Tier I Class I GROs do apply to the
downgradient property, unless Illinois EPA can arbitrarily ignore 35 IAC 620 regulations and
designate the downgradient groundwater as Class II.
2
Mr. Melinda Friedel
iVovember5, 2007
Because current groundwater contaminant concentrations will not attenuate to the Tier 1 Class I
GROs before reaching the downgradient property, then an ELUC must be obtained from the
neighboring property owner. Again, it has been clearly stated that an ELUC is not an option.
For this reason, soil excavation (or other physical remedial option) to eliminate the source of
groundwater contamination on-site is necessary.
Tate & Lyle and Illinois EPA both desire an expeditious cleanup of this property. However,
Tate & Lyle is extremely concerned that if it follows Illinois EPA's approach by shutting down
the groundwater recovery and remediation system, that in all likelihood the downgradient
property may be unnecessarily contaminated and potentially expose Tate
&
Lyle to liability.
Tate & Lyle would like further assurances and/or clarification regarding Illinois EPA's approach.
As a consequence, Tate & Lyle and DAI request a meeting with Illinois EPA representatives to
discuss this matter further.
Pending the outcome of this meeting with Illinois EPA, Tate & Lyle has requested a 90-day
extension of the Illinois EPA letter dated October 4, 2007, that rejected the September 12, 2007,
CAP Amendment submitted by DAI in order to preserve its Appeal Rights in this matter.
Sincerely,
DAI Environmental, Inc.
411.4.4
t
y
Christopher Cailles, P.E.
Project Engineer
cc:
?
Don Mosier – Tate & Lyle
3
E N
A
Environmental Engineers. Goologisis and SeierilIsIs?
Tel 647.573.8900
Fax 847.513.8953
April 2, 2007
Ms. Melinda Friedel
Illinois Environmental Protection Agency
Bureau of Land - #24
Leaking Underground Storage Tank Section
1021 N. Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Re:
?
Corrective Action Plan Amendment/
Corrective Action Budget Amendment
LPG 11'490755017 – Pike County
Pittsfield/Webel Feeds, Inc.
Rural Route 3
Pittsfield, Illinois
LUST Incident 11921798
Dear Ms. Friedel:
Polo Park Business Center
27834 N. Irma
Lee
Gado
Lake Forest, Illinois 600455130
I have enclosed two copies (one bound, one unbound) of the
Corrective Action Plan
(CAP)
Amendment
for Webel Feeds, Incident Number 921798. The CAP Amendment responds to
Illinois EPA's most recent letter dated November 3, 2006, and proposes Corrective Actions that
address all remaining environmental issues. The Corrective Actions proposed
in
this CAP
Amendment are adequate to obtain a letter of No Further Remediation granting closure of the
Site. Also included with this CAP Amendment is a Corrective Action Budget Amendment
requesting $319,727.48 for the costs of historical and proposed Corrective Actions through the
anticipated end of the project. If you have any questions or require additional information,
please contact me at (847) 573-8900 extension 118. Thank you for your time.
Sincerely,
DAI Environmental, Inc.
ax,
Christopher Cailles, P.E.
Project Engineer
Enclosures
cc: Don
Moster – Tate & Lyle (w/enclosure)
EXHIBIT B
E N
A L
Polo Park Business Center
27E134 14. Irma Lee Glide
Lake Forest, Illinois 60046-5130
J
Environmental Engineers, Geologists and Scientists
?
Tel 847.573.8900
Fax 847.673 8363
CORRECTIVE ACTION PLAN AMENDMENT
PITTSFIELD/WEBEL FEEDS, INC.
RURAL ROUTE # 3
PITTSFIELD, ILLINOIS
LPC # 1490755017 - PIKE COUNTY
INCIDENT # 921798
March 19, 2007
DAI Project No. 6601
Prepared For:
Tate & Lyle
2200 East Eldorado Street
Decatur, Illinois 62521-1578
Prepared By:
DAI Environmental, Inc.
Polo Park Business Center
27834 Irma Lee Circle
Lake Forest, Illinois 60045
1
TABLE OF CONTENTS
LIST
LIST
LIST
CORRECTIVE
1.0 INTRODUCTIONOF
OF
OF
FIGURESAPPENDICESTABLESACTION
?
?
?
?
PLAN FORM
?
1
1.1 SITE DESCRIPTION ?
1
1.2 REGULATORY HISTORY ?
1
2.0 RESPONSE TO COMMENTS ?
5
3.0 CORRECTIVE ACTIONS ?
9
3.1 ABANDONMENT OF ON-SITE POTABLE WATER WELL
?
10
3.2 SOIL EXCAVATION AND DISPOSAL ?
10
3.3 CONTINUED OPERATION OF THE REMEDIATION SYSTEM
?
10
3.4 GROUNDWATER SAMPLING ?
10
3.5 CORRECTIVE ACTION COMPLETION REPORT
?
11
LIST OF FIGURES
Topographic Site Location Map
?
Figure 1
Site Plan with Monitoring Wells
?
Figure 2
Proposed Soil Excavation ?
Figure 3
LIST OF TABLES
Proposed Post-Soil Excavation Groundwater Sampling Regimen
?
7
LIST OF APPENDICES
CORRECTIVE ACTION BUDGET AMENDMENT ?
APPENDIX A
LABORATORY CERTIFICATIONS ?
APPENDIX B
CAP Amendment, Incident ft 921798
j
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
5007, DAI Environmental, Mc.
1
1.0 INTRODUCTION
1.1 SITE DESCRIPTION
Webel Feeds, Inc. (Webel Feeds) produced and stored animal feeds at its Pittsfield facility, located
along Rural Route No. 3 in Pike County, Illinois. (Webel Feeds has changed ownership to
PM Ag Products, then Tate & Lyle, and then The Maschhoffs.) This facility is approximately
3-miles north of Pittsfield, Illinois and 1.5-miles south of U.S. Route 36. The facility is bordered on
the north by Rural Route No. 3, then farmland; on the east by an unnamed creek, then farmland; and
on the south and west by farmland. Figure 1 provides a Topographic Site Location Map, and
Figure 2 provides a Site Plan.
1.2 REGULATORY HISTORY
In a letter dated April 11, 1994, a remediation system was approved by Illinois EPA to treat soil and
groundwater contamination resulting from a release of leaded and unleaded gasoline and diesel fuel
from five (5) underground storage tanks (USTs) (Incident Number 921798). From December 1994
to October 2003, Corrective Actions were performed under the regulations of 35 IAC 731, and
detailed in CAP Addendums and Groundwater Monitoring and Remediation Progress Reports.
However, in a letter dated May 27, 2003, Illinois EPA responded to a Corrective Action Plan (CAP)
Addendum with four (4) comments. Comments 1 and 3 of the letter stated:
1.
It appears that the current method of groundwater treatment is not affecting the existing
levels of BTEX and PNAs in the groundwater. Since this system has been in operation for
eight years with little effect in reducing the remaining contaminant concentrations, the
Illinois EPA recommends you consider an alternative approach to address the remaining
contamination.
3.
The Illinois EPA suggests that options available under 35 Illinois Administrative Code
742, Tiered Approach to corrective Action Objectives (TACO) be utilized. The development
of risk-based cleanup objectives may be appropriate after contaminant levels are shown to
be stable and/or decreasing to demonstrate adequate protection of human health and the
environment for this incident.
Following the May 2003 letter, Tate
&
Lyle elected to proceed with Corrective Actions under the
newly approved 35 IAC 734 regulations. Since that time, several CAP Addendums have been
CAP Amendment, Incident # 921798
1
Mara 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
°2007, DAI Environmental, Inc.
submitted in response to the May 2003 letter. The CAP Addendums and Illinois EPA responses are
summarized below.
October 21, 2003, CAP Addendum: This letter report was submitted in response to a meeting held
on October 8, 2003, at the offices of Illinois EPA. A proposal for installation of four (4) additional
shallow groundwater monitoring wells was submitted along with the form
Election To Proceed
Under Title XVI.
February 19, 2004, Response Letter from Illinois EPA: Illinois EPA's response letter approved the
monitoring well installation with modifications. The modifications indicated that groundwater
samples should be collected no sooner than two (2) weeks after well installation and analyzed for
BTEX only. Further, Illinois EPA requesting two (2) weeks notification prior to monitoring well
installation.
December 20 2004 CAP Addendum: The newly collected groundwater sampling results together
with TACO regulations and procedures were used to calculate Tier 2 Groundwater Remediation
Objectives (GROs) for the Site. Because the on-site groundwater contaminant concentrations
exceeded the Tier 2 GROs, additional remediation was proposed. As had been explained in several
previous submissions, the primary source of groundwater contamination is the continued desorption
of gasoline contamination from the highly contaminated saturated soils on the side of the hill. The
groundwater remediation would continue to be a very slow process until the contaminant mass in the
saturated soils were also addressed. The CAP proposed several remedial alternatives to address the
soils in the source area including soil excavation and disposal, °Re injection, chemical injection,
and air sparging (and combination soil excavation and air sparging).
February 9, 2005, Response Letter from Illinois EPA: Illinois EPA's response letter indicated
receiving the December 2004 submission, but the letter was apparently only addressing a separate
submission that included information about
an
Oxygen releasing product called StimulOX
TM . The
response letter requested additional data on the product before the use of the product could be
CAP Amendment, Incident ti
921798
2
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
'32007, DAI Environmental, Inc.
approved; however, no comments were provided on the several proposed Corrective Actions detailed
in the December 2004 report.
March 23, 2005, CAP Addendum: In following up on a telephone conference call with Illinois EPA
the following Corrective Action steps were proposed: shut down the remediation system for a period
of time sufficient to measure static water levels, hydraulic conductivity, and groundwater
concentrations under steady-state non-groundwater recovery conditions. The groundwater
concentrations were then to be compared with site specific Tier 2 GROs. Depending upon these
results, either Site Closure would be requested, or the system would be restarted, and a combination
soil excavation and air sparge system would be proposed in a CAP Addendum. The CAP Addendum
would include sampling saturated soils within the groundwater plume to better determine where the
residual contaminant mass was located, and the optimal location for the sparge system trench.
Mav 31, 2005, Response Letter from Illinois EPA: The CAP was conditionally approved but
required two (2) modifications. The first modification was that the monitoring wells chosen for
hydraulic conductivity testing should be selected to represent the entire Site, as opposed to being
representative of the groundwater contaminant plume and area immediately downgradient where the
contaminant migration is occurring. The second modification was to reject the saturated soil
sampling which was needed to identify the areas of highest contaminant mass and pinpoint the best
soil removal and air sparge trench locations.
March 27 2006 CAP Addendum: The results of the groundwater sampling and hydraulic
conductivity testing under non-groundwater recovery conditions were provided in this submission.
The results of the groundwater sampling still indicated exceedances of the newly calculated Tier 2
GROs (which were based upon the most recent data). For that reason, the groundwater remediation
system was restarted in December 2005 and operated continuously. It was also noted in the
submission that less restrictive (higher concentration) Tier 2 GROs could be calculated if the existing
on-site potable well were removed, and the current property owner agreed to a deed restriction on the
property prohibiting groundwater use. The additional saturated soil samples that were requested in
the March 2005 CAP Addendum and disapproved by Illinois EPA in the May 31, 2005, response
CAP Amendment, Incident # 921798
3
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
'2007, DAI Environmental, Inc.
were not collected; but based upon earlier saturated soil samples and the latest Tier 2 GRO
calculations, it was estimated that if the most contaminated soils in an area of approximately 90-ft by
70-ft could be removed, then the Tier 2 GROs could be achieved in a much shorter time. Removal
of the contaminant soil mass, together with the on-site groundwater use prohibition, would eliminate
the need for air sparging, shorten the remediation period, and reduce the overall remediation costs.
May 8, 2006, Response Letter from Illinois EPA: Illinois EPA responded with four (4) comments:
confirmation sampling should include analysis for Lead as a contaminant of concern; the option for
an on-site groundwater use restriction on the Property Owner Summary form is essentially the same
as an ELUC; it may be possible to meet Tier 2 GROs with a Class II groundwater designation (on the
downgradient off-site property); and that a proposal has not been submitted to use hydraulic
conductivity averaging (the earlier CAP used Site-wide averaged hydraulic conductivities as were
understood to have been requested by Illinois EPA in the May 31, 2005, response letter).
August 30, to Co mnignts/CAP
Amendment: DAI responded to Illinois EPA's
May 8, 2006, comments by requesting that Lead sampling not be required because historical
groundwater sampling for Lead had been previously conducted, and laboratory analysis indicated no
Lead contamination (documentation was supplied). The CAP Addendum also recognized that
signatures by the property owner agreeing to an on-site groundwater use restriction on the Property
Owner Summary form is equivalent to an ELUC, and explained that a proposal for hydraulic
conductivity averaging was not submitted because a Site-wide average hydraulic conductivity value
was used in response to Illinois EPA May 31, 2005, comment that, "The monitoring wells chosen for
hydraulic conductivity testing should be representative of the entire site...Hydraulic conductivity
testing should be performed on wells across the site."
The most significant comment and response from Illinois EPA were with regard to using Class II
groundwater criteria in calculating Tier 2 GROs. Using Class II criteria can provide a higher (less
restrictive) GRO, but an on-site Class II demonstration would be meaningless if the on-site
groundwater route of exposure were already eliminated. A Class II demonstration for the off-site
downgradient property would produce less restrictive Tier 2 GROs, but the hydraulic conditions on
CAP Amendment, Incident
14
921798
4
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
.2007, DAI Environmental, Inc.
the off-site property do not meet the 35 IAC 620.220 criteria for Class II groundwater (even after the
on-site potable well is closed). If Illinois EPA can designate the off-site property as Class II, then
less restrictive Tier 2 GROs can be calculated, and further remediation may not be necessary.
November 3, 2006 – Response Letter from Illinois EPA: Illinois EPA denied the CAP Amendment
and provided six (6) comments to address. The responses to the comments are provided in the
following section of this CAP Amendment. The proposed final course of Corrective Actions to
obtain Site closure are detailed in Section 3.0.
2.0 RESPONSE TO COMMENTS
1. A proposal that addresses all outstanding issues at this site has not been provided. An
Amended Corrective Action Plan (plan) cannot be approved unless it will address all
remaining concerns for the subject site. Please note that if additional soil excavation is
being proposed, a formal CAP meeting all necessary regulatory requirements must be
submitted.
Response:
Both soil and groundwater contamination remains at the Site. Proposals have been
submitted to Illinois EPA since 2003 with Corrective Actions to address all remaining concerns.
Remediation methods included soil excavation, air sparging, chemical injection, and continued
groundwater remediation. Alternatives to reduce the level of cleanup as provided under TACO
regulations include calculation of the highest (least restrictive) Tier 2 GROs and on-site groundwater
use prohibition to eliminate the on-site groundwater ingestion route of exposure. Illinois EPA has
only responded by commenting that continued groundwater remediation is notreimbursable, and that
TACO may be utilized to obtain closure of the Site. We understand that TACO can be used to
calculate less stringent cleanup objectives and help reduce remediation costs, and TACO is being
utilized; however the current groundwater concentrations still exceed the highest (least stringent)
TACO derived Tier 2 GRO. Within the last few years the only remediation that has occurred is from
the'existing groundwater recovery and treatment system. This groundwater remediation system
works and has been effective in limiting further contaminant migration, but unless the contaminant
mass on the side of the hill is addressed, it could take several more years of operation to achieve the
Tier 2 GROs.
CAP Amendment, Incident # 921798
5
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
°2007, DAI Environmental, Inc.
Therefore, soil excavation is again being proposed to address the main contaminant mass that is
slowly desorbing into the groundwater from the saturated soils upgradient of MW-2. Previous soil
sampling results suggest that this area of highest soil concentration is approximately 1,000-yd
3. (The
March 27, 2006, CAP proposed additional soil sampling to better define the extent of the excavation,
but these sampling activities and costs were rejected). Historically the saturated soil contaminant
plume was much larger, but has diminished with time. Excavation of the most highly contaminated
soils will eliminate the contaminant source, which continues to contaminate the groundwater at the
bottom of the hill, near the property boundary. Figure 2 provides a Site Plan with the location of
monitoring wells. Figure 3 includes the approximate location and excavation extent.
Following removal of the contaminated soil, the groundwater remediation system will be operated
only long enough to remove contaminated groundwater at the bottom of hill. Once the contaminant
mass immediately upgradient of MW-2 is removed, the groundwater concentrations at MW-2 are
expected to decrease and meet the Tier 2 GRO within several months. Monitoring well MW-2 will
be sampled for Benzene, Toluene, Ethylbenzene, and total Xylenes (BTEX) monthly, and once the
contaminant concentrations at MW-2 meet the Tier 2 GROs, then a complete round of groundwater
sampling will be conducted. If all groundwater results are below the Tier 2 GROs, Site closure will
be requested.
To calculate the highest Tier 2 GROs, on-site groundwater prohibition must be approved by the
property owner, and the on-site potable water well must be formally abandoned. DAI proposes that
an Illinois licensed drilling contractor abandon the potable water well following 77 IAC 920.120,
Illinois Department of Public Health Water Well Construction Code. Tate
&
Lyle will also continue
to work towards obtaining approval by the current property owner for an on-site groundwater use
restriction. Finally, the groundwater remediation system will remain in operation as an intermediate
Corrective Action to reduce groundwater concentrations and prevent further groundwater
contaminant migration. Appendix A includes a Corrective Action Budget Amendment proposing
costs already incurred and to be incurred during final Corrective Actions and Site closure.
CAP Amendment, Incident # 921798
6
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
*2007, DAI Environmental, Inc.
2.
It needs to be clarified if the groundwater pump and treat system is still in operation. Any
operation of this system after May 2003 will not be eligible for reimbursement.
Response: Of course the groundwater pump and treatment system is still in operation because as
soon as the recovery trench pump is turned off, the area downgradient of the trench will become re-
contaminated. Much time, effort, and cost had been expended to remediate this area downgradient of
the recovery trench. If we can move beyond the letter writing stage and initiate Corrective Actions,
the contaminant source area can be addressed and the groundwater recovery system shut down soon
after.
3.
One round of confirmation groundwater sampling for lead should be completed since there
have been previously identified Tier 1 exceedances at this site and the most recent lead data
collected in response to the release reported at this site was collected in 1999.
Response: A complete round of groundwater sampling is proposed as part of the final Corrective
Actions for the Site. During the groundwater sampling, a complete round of samples will be
collected for analysis of Lead and BTEX. Samples will be collected from five (5) monitoring wells
for Polynuclear aromatics (PNAs) per the Illinois EPA request in a letter dated June 22, 2000. The
table below summarizes the planned sampling regimen.
Proposed Post-Soil Excavation Groundwater Sampling Regimen
.__
r
.
?
..:.?
'-.IP
i i?
f?
h
MW-1, MW-2, MW-9,
X
X
MW-19 RW-1
MW-3, MW-4, MW-5,
MW-5D, MW-6 MW-8, MW-10,
MW- 11, MW-12, MW-14, MW-15,
X
MW-16, MW-17, MW-18, MW-20,
MW-21, MW-22, MW-25, MW-26,
MW-27, MW-28, MW-29
MW-7
Well damaged, unable to be sampled
MW-13
Destroyed
Note – Some monitoring wells planned for sampling may be destroyed as part of the soil excavation activities.
DAI will preserve as many wells as possible.
CAP Amendment, Incident # 921798
7
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
02007, DAI Environmental, Inc.
4.
Hydraulic gradient calculations need to be provided.
Response: The fate and transport calculations documenting TACO procedures were being used for
Site closure. The calculations, utilizing equation R26, include hydraulic gradient
as
a parameter. As
noted in the fate and transport modeling documentation, the hydraulic gradient was taken from the
September 19, 2005, potentiometric surface. The hydraulic gradient (0.1-ft/ft) is the difference in
groundwater elevation along and downgradient of the contaminant plume (A 27-ft as measured at
MW-10 and MW-18), divided by the horizontal distance between these wells (27041).
5.
The adjacent property cannot be categorized as having Class 17 groundwater since that
property is still within the setback zone of the on-site potable well.
Response: DAI understands that the neighboring property cannot be designated as Class H
groundwater if the property is within the setback zone of the potable water well. An Illinois EPA
comment from the May 8, 2006, letter indicated, "...if it can be shown that the on-site potable water
supply wells have been properly abandoned..., it may be possible to obtain site closure at this time
using a Tier 2 TACO evaluation along with a Class II groundwater demonstration." Tate & Lyle
intends on formally abandoning the on-site potable water well, which would then allow for TACO
modeling to be used to calculate less restrictive Tier 2 GROs.
However, in the August 2006 CAP Amendment, DM provided documentation that the downgradient
neighboring property meets the Class 1 groundwater criteria per 35 IAC 620.210 regulations based
upon soil stratigraphy and calculated hydraulic conductivity. The August 2006 CAP Amendment
requested a determination by Illinois EPA of the off-site downgradient groundwater designation.
DAI suggested that if Illinois EPA could designate the downgradient property as Class II, the TACO
modeling could be used to calculate even higher (least restrictive) Tier 2 GROs.
CAP Amendment, Incident
14
921798
8
March 19, 2007
Webel Feeds, Inc„ Pittsfield, Illinois - 6601
•
2 007, DAI Environmental, Inc.
1
6. All quantitative analyses of samples collected on or after January 1, 2003, shall be
conducted by a laboratory accredited for the analyzed parameters ...It is not necessary to
submit the entire NELAC Certification for a lab, only the form found at...
Response: Laboratory certifications for all samples collected since the Site elected to proceed under
35 IAC 734 regulations are provided in Appendix B. The certifications include the final quarterly
sampling event conducted in December 2003 and all soil and groundwater sampling performed
through September 2005 (the most recent laboratory analysis). All future soil and groundwater
laboratory results will also be submitted with laboratory certifications.
3.0 CORRECTIVE ACTIONS
This CAP Amendment proposes final Corrective Actions believed necessary to address all
outstanding issues and meet Site closure criteria under TACO. Details of the chosen Corrective
Action are provided below. A Corrective Action Budget Amendment is included in Appendix A.
Please note that the CAP Addendum of December 20, 2004, proposed that the contaminated
saturated soils in the source area be addressed by a combination of soil removal and air sparging. At
that time it was considered more cost-effective to remove the most highly contaminated soils and
address the remaining soils by desorption and air sparging, rather than attempt to remove all the
contaminated soils. Since that time continued groundwater recovery, treated groundwater re-
injection, and soil desorption have reduced the extent of contamination in the saturated soils. The
request to obtain saturated soil samples was rejected, so the extent of contamination in the saturated
soils is not well known; however the best current estimate is an area of about 1,000-yd
3. In the
interest of minimizing cost and completing the closure as quickly as possible, removal of all the
contaminated soil is proposed at this time (and air sparging is no longer necessary).
The Corrective Actions include:
1.
Formally abandoning the on-site potable water well;
2.
Excavation and disposal of the contaminated soils upgradient of the recovery french;
3.
Sampling o f MW-2 until the groundwater remediation system decreases the contamination to
less than Tier 2 GRO (estimated as several months);
CAP Amendment, Incident # 921798
9
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
2007, DAI Environmental, Inc.
-n
to
I mg
C
CD
4.
Once the groundwater concentrations at MW-2 meets the Tier 2 GRO, obtaining a full round
of closure samples;
5.
Submission of a Corrective Action Completion Report (CACR) requesting a letter of No
Further Remediation (NFR) for the Site; and,
6.
System decontamination and decommission.
3.1 ABANDONMENT OF ON-SITE POTABLE WATER WELL
Formal abandonment of
the
on-site potable water well will be performed by an Illinois licensed
drilling contractor following 77 JAC
920.120. Once the well is abandoned, Tate & Lyle will contact
the current property owner to obtain approval for an on-site groundwater prohibition. The on-site
groundwater use restriction will be in the form of the property owner's signature on the Property
Owner Summary form.
3.2 SOIL EXCAVATION AND DISPOSAL
Removal of the source area will be accomplished by excavating the most highly contaminated
saturated soils along the side of the hill. The approximate area to be excavated is shown on Figure 3.
The extent and depth of soil contamination has not been determined but the total excavation is
estimated at 1,000–yd3
. Soils will be removed, transported, and disposed of using licensed special
waste handlers. The soils will be profiled for landfill acceptance prior to removal. DAI will manage
the soil removal activities and collect confirmatory soil samples to ensure completion of contaminant
removal. Documentation of the removal and disposal will be provided to Illinois EPA in the CACR.
3.3
CONTINUED OPERATION OF REMEDIATION SYSTEM
The groundwater remediation system will continue operation until the groundwater concentrations at
MW-2 meet the Tier 2 GROs. MW-2 will be sampled and analyzed for BTEX compounds on a
monthly basis.
3.4 GROUNDWATER SAMPLING
Once Tier 2 GROs are achieved at MW-2, a complete round of groundwater sampling will be
performed. The groundwater sampling will consist of
analysis of BTEX, PNAs, and Lead
(see
Section 2.0).
CAP Amendment, Incident # 921798
10
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
.2007, DAI Environmental, Inc.
33
CORRECTIVE ACTION COMPLETION REPORT
Following the completion of the above Corrective Actions, a CACR will be submitted detailing the
Site history, Site Investigations, and Corrective Actions conducted. Included in the CACR will be a
request for an NFR letter closing Incident Number 921798 and the Site. Following the approval of
the CACR, DAI will conduct Site restoration and system dismantling activities. Remaining
monitoring wells will be abandoned, supplies and equipment will be salvaged or scrapped, and any
wastes (e.g. spent activated carbon) will be disposed. Following completion of decommissioning, a
final reimbursement package will be submitted to Illinois EPA requesting Corrective Actions and
Site Closure costs.
CAP Amendment, Incident # 921798
11
March 19, 2007
Webel Feeds, Inc., Pittsfield, Illinois - 6601
62007, DAI Environmental, Inc.
The Agency Is authorized to esquire this informailon wider Section 4 and Title XVI of Me Envirormenial ProtectionAct (415 IL CS 514,5157 57.17). Fallow to disclose this Information
may resale in a cMI penally 01 not to exceed 1513,1100,00 lor ere violation and an additionalcivil penalty of not le peeped S10000.00 for eachday during Mich ihe violation continues (415
ILCS 5844 My personwho knowMgly makes a false materiel sielemant or representation In any label, manifest, record, report, permit, or license. or other document
mini,
maintained or
used for the purpose of compliance with TM, XVI commits a Class
4
latony Any second or Subsequent offense eller conviction hereunder Is a Class 3 'stony (4 15 ILC5 5/57.17). This
form leas
been approved by the Forms Management Centel,
Illinois Environmental Protection Agency
Leaking Underground Storage Tank Program
Corrective Action Plan
A.
?
Site Identification
IEMA Incident # (6- or 8-digit): 921798
?
IEPA LPC# (10-digit): 1490755017
Site
Site Address (Not
Name:
a P.O. Box): Rural Route #
Webel
3
Feeds
City: Pittsfield
County: Pike
ZIP Code: 62363
Leaking UST Technical File
B.?
Site Information
1.
Will the owner or operator seek reimbursement from
the Underground Storage Tank Fund?
?
Yes IS No
q
2.
If yes, is the budget attached?
?
Yes LS No
q
3.
Is this an amended plan??
Yes
ID No
q
4.
Identify the material(s) released: Gasoline (leaded and unleaded), diesel fuel
5.
This Corrective Action Plan is submitted pursuant to:
a.
35
III. Adm. Code
731.166
?
q
The material released was:
-petroleum
?
q
-hazardous substance (see Environmental
Protection Act Section 3.215)
?
q
b.
35 III. Adm. Code 732.404?
q
c.
35 III. Adm. Code 734.335?
El
C.?
Proposed Methods of Remediation
2.1.
Soil
Groundwater RemediatIon,
Excavation/disposal
on-site qw prohibition and TACO modeling (it needed)
D.
?
Soil and Groundwater Investigation Results
(for incidents subject to 35111. Adm. Code
731 only or 732 that were classified using Method One or Two, if not previously provided)
Provide the following:
1.
Description of investigation activities performed to define the extents of soil and/or
groundwater contamination;
2.
Analytical results, chain-of-custody forms, and laboratory certifications;
IL 532 2287
?
Corrective Action Plan
LPC 513 Rev. March 2006
?
1 of 4
3.
Tables comparing analytical results to applicable remediation objectives;
4.
Boring logs;
5.
Monitoring well logs; and
6.
Site maps meeting the requirements of 35 Ill. Adm. Code 732.110(a) or 734.440 and
showing:
a.
Soil sample
locations;
b.
Monitoring well locations; and
c.
Plumes of soil and groundwater contamination.
E.?
Technical Information - Corrective Action Plan
Provide the following:
1.
?
Executive summary identifying the objectives of the corrective action plan and the technical
approach to be utilized to meet such objectives;
a.
The major components (e.g., treatment, containment, removal) of the corrective
action plan;
b.
The scope of the problems to be addressed by the proposed corrective action; and
c.
A schedule for implementation and completion of the plan;
2.
?
Identification of the remediation objectives proposed for the site;
3.?
A description of the remedial technologies selected:
a.
The feasibility of implementing the remedial technologies;
b.
Whether the remedial technologies will perform satisfactorily and reliably until the
remediation objectives are achieved; and
c.
A schedule of when the technologies are expected to achieve the applicable
remediation objectives;
4.
?
A confirmation sampling plan that describes how the effectiveness of the corrective action
activities will be monitored during their implementation and after their completion;
5.
?
A description of the current and projected future uses of the site;
6.
?
A description of engineered barriers or institutional controls that will be relied upon to
achieve remediation objectives:
a.
an assessment of their long-term reliability;
b.
operating and maintenance plans; and
c.
maps showing area covered by barriers and institutional controls;
7.?
The water supply well survey:
a.
Map(s) showing locations of community water supply wells and other potable wells
and the setback zone for each well;
b.
Map(s) showing regulated recharge areas and wellhead protection areas;
c.
Map(s) showing the current extent of groundwater contamination exceeding the
most stringent Tier
1 remediation objectives;
d.
Map(s) showing the modeled extent of groundwater contamination exceeding the
most stringent Tier 1 remediation objectives;
e.
Tables listing the setback zone for each community water supply well and other
potable water supply wells;
A narrative Identifying each entity contacted to identify potable water supply wells,
the name and title of each person contacted, and any field observations associated
with any wells identified; and
g.
?
A certification from a Licensed Professional Engineer or Licensed Professional
Geologist that the survey was conducted in accordance with the requirements and
that documentation submitted includes information obtained
as a result of the
survey (certification of this plan satisfies this requirement);
Corrective Action Plan
2 of 4
8.
?
Appendices:
a.
References and data sources report that are organized; and
b.
Field logs, well logs, and reports of laboratory analyses;
9.?
Site map(s) meeting the requirements of 35 III. Adm. Code 732.110(a) or 734.440;
10.
?
Engineering design specifications, diagrams. schematics, calculations, manufacturer's
specifications, etc.;
11.
?
A description of bench/pilot studies;
12.
?
Cost comparison between proposed method of remediation and other methods of
remediation;
13.
?
For the proposed Tier 2 or 3 remediation objectives, provide the following:
a.
The equations used;
b.
A discussion of how input variables were determined;
c.
Map(s) depicting distances used in equations; and
d.
Calculations;
14.
?
Provide documentation to demonstrate the following for alternative technologies:
a.
The proposed alternative technology has a substantial likelihood of successfully
achieving compliance with all applicable regulations and remediation objectives;
b.
The proposed alternative technology will not adversely affect human health and
safety or the environment;
c.
The owner or operator will obtain all Illinois EPA permits necessary to legally
authorize use of the alternative technology;
d.
The owner or operator will implement a program to monitor whether the
requirements of subsection (14)(a) have been met;
e.
Within one year from the date of Illinois EPA approval, the owner or operator will
provide to the
Illinois EPA monitoring program results establishing whether the
proposed alternative technology will successfully achieve compliance with the
requirements of subsection (14)(a); and
f.
Demonstration that the cost of alternative technology will not exceed the cost of
conventional technology and is not substantially higher than at least two other
alternative technologies, if available and technically feasible.
15.
?
Properly Owner Summary form.
F.?
Exposure Pathway Exclusion
Provide the following:
A description of the tests to be performed in determining whether the following
requirements will be met:
a.
Attenuation capacity of the soil will not be exceeded for any of the organic
contaminants;
b.
Soil saturation limit will not be exceeded for any of the organic contaminants;
c.
Contaminated soils do not exhibit any of the reactivity characteristics of hazardous
waste per 35 HI. Adm. Code 721.123;
d.
Contaminated soils do not exhibit a pH 5 2.0 or
12.5; and
e.
Contaminated soils which contain arsenic, barium, cadmium, chromium, lead,
mercury, or selenium (or their associated salts) do not exhibit any of the toxicity
characteristics of hazardous waste per 35 III. Adm. Code 721.124.
A discussion
of how any exposure pathways are to be excluded.
Corrective Action Plan
3 of 4
.Phone:?
421-24 2
Date:
Signature:
?
?
/ GPI0^.^
<-1
ar W
Phone:10471...5Signature:
?
Date:
■.■
G.
?
Signatures
All plans, budgets, and reports must be signed by the owner or operator and list the owner's or
operator's full name, address, and telephone number.
UST Owner or Operator
Name: Tate 8 Lyle
Contact: Don Moster
Address: 2200 Fast Eldorado Street
City:
?
Decatur
State:?
3 Illinois
ZIP Code: 62521-1578
Consultant
Company: DAI Environmental, Inc.
Contact: F. Thomas DePaul
Address: 27834 North Irma
•
eR Circle
City:?
Lake Forest
State:?
Illinois
ZIP Code: 60045
I certify under penalty of law that all activities that are the subject of this plan were conducted under
my supervision or were conducted under the supervision of another Licensed Professional Engineer
or Licensed Professional Geologist and reviewed by me; that this plan and all attachments were
prepared under my supervision; that, to the best of my knowledge and belief, the work described in
this plan has been completed in accordance with the Environmental Protection Act 015 ILCS 5], 35
III. Adm. Code 731, 732 or 734, and generally accepted standards and practices of my profession:
and that the information presented is accurate and complete. I am aware there are significant
penalties for submitting false statements or representations to the Illinois EPA, including but not
limited to fines, imprisonment, or both as provided in Sections 44 and 57.17 of the Environmental
Protection Act [415 ILCS 5/44 and 57.17].
Licensed Professional Engineer or Geologist
Name: Christopher Carnes
Company: DAI Environmental, Inc.
Address: 27834 North Irma Lee Circle
State:
City:
ZIP
Phone:
III.
?
Registration
?
?
Lake
Illinois
Code:
(847)
No.:
573-8900
Forest
60045
062-058280
License Expiration Date: 11/30/07
Signature:CAL,
Date:
?
/
L.P.E. or L.P.G. Seal
Corrective Action Plan
4 of 4
LEGEND
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