ILLINOIS POLLU~TIONCONTROL BOARD
    June
    6,
    1991
    IN THE MATTER OF:
    )
    )
    PETITION OF AMOCO OIL COMPANY.
    )
    AS 91-4
    FOR ADJUSTED STANDARDS FROM
    )
    35
    ILL. ADM. CODE SECTIONS
    )
    725.213(d)(l)(B) AND 725.321(a)
    )
    ORDER OF THE BOARD
    (by.
    B.
    Forcade):
    This matter involves a petition for an adjusted standard
    from the closure and design provisions of
    35
    Iii. Adm. Code
    725.213(d)(l)(B) and 725.321(a)
    filed by Amoco Oil Company
    (“Amoco”) on May 10, 1991.
    One portion of• the petition requests
    an adjusted standard pursuant
    to 35 Ill. Adm. Code 725.213(e),
    which Section authorizes
    a delay of closure for surface
    impoundments which will remain open to receive non-hazardous
    wastes only.
    Section 723.2J.3(e)(8)(B)
    specifies a level
    of
    justification.
    Another portion of the petition appears to
    request a generic adjusted standard from 35 Iii. Mm.
    Code
    725.213(d)(1)(B) and 725.321(a),
    which require the owner
    or
    operator to initiate closure of a surface impoundment within one
    year after
    the final receipt of hazardous waste,
    and a double
    liner and leachate collection system for any new surface
    impoundments.
    Section 725.213(e)
    sets forth a
    level of justification which
    includes a sufficient removal plan and contingent corrective
    measures plan.
    The latter
    is
    “a corrective action plan under
    Section 724.199,
    based on the assumption that a release has been
    detected from the unit”.
    There are a number of apparent
    deficiencies
    in Amoco’s information concerning the corrective
    measures plan.
    A corrective action plan is ordinarily a portion of
    a RCRA
    Part B permit application which
    is filed after
    a release has been
    detected.
    The corrective measures plan is somewhat different,
    in
    that
    it comes
    to the Board outside the context of the Part B
    •application,
    arid
    it
    is
    to be based on a hypothetical release
    which may occur
    in the future.
    The petition has a number of
    deficiencies which may stem from the petition not having enough
    of the Part B application to give enough information
    for
    the
    Board to understand petitioner’s prob1~m.
    The informational requirements for
    a corrective action plan
    are contained in 35
    Iii. Adm. Code 703.185(g).
    However,
    to
    evaluate the petitioner’s plan,
    it is necessary to have all, of
    the material called for
    in
    Section 703.185
    (which the Agency
    would automatically have before, it in the context of
    a Part B
    application).
    Amoco Oil Company
    is deficient in
    that it
    lacks
    the following materiai.:
    123—61
    —2—
    1.
    section
    725.213(e)(3)(B)
    provides
    that
    the
    contingent corrective measures plan may
    be
    a
    portion of a corrective action plan previously
    submitted.
    The
    petition
    makes
    reference
    to
    what
    appears
    to
    be
    a
    corrective
    action
    plan
    for
    a
    “hydrocarbon pool”
    on the faôility.
    It
    is unclear
    whether
    the
    contingent
    corrective
    measures plan is a portion of
    this plan.
    2.
    Section
    703.185(a)
    requires
    a
    summary
    of
    groundwater
    monitoring
    data
    obtained
    during
    interim status.
    3.
    Sections
    703.185(b)
    and
    (C)
    include
    requirements for hydrogeologic information and
    a topographic map on which certain points are
    located..
    The petition does not include a true
    topographic
    map,
    and
    does
    not
    locate
    all
    of
    the required points.
    In addition, most of the
    maps
    in
    the
    petition
    fail
    to
    indicate
    the
    location
    of
    the
    “East
    Surge
    Pond”
    (“ESP”),
    which
    is the subject of the petition.
    4.
    Section
    703.185(g)(l)
    requires
    a
    description
    of
    wastes
    previously
    handled
    at
    the
    facility.
    Petitioner
    has
    provided
    the
    characteristics
    of non—hazardous wastes
    to be
    handled
    by
    the
    ESP,
    but
    appears
    to
    have
    omitted
    past
    wastes.
    Although
    the
    removal
    plan
    calls
    for
    removal
    of
    all
    contaminated
    material,
    the
    conditions
    of
    the
    adjusted
    standard need
    to address
    the possibility that
    not all contaminated material will be removed,
    or
    that
    there may
    be
    an undetected
    plume
    of
    contamination
    from
    such
    already
    present.
    Continued
    use
    of
    the
    impoundment
    for
    non—
    hazardous
    wastes
    could
    provide
    a
    hydraulic
    head
    to produce or move a plume from such pre-
    existing
    contamination.
    ~4oriitoringshould
    address
    this
    possibility.
    Hence,
    a
    description
    of
    past
    wastes
    is
    needed
    to
    provide a
    focus for such monitoring.
    The petitioner
    is directed to amenci the petition to •address
    the deficiencies within
    30 days after
    the date of this Order.
    The petition will be subject to dismissal unless the petitioner
    addresses these deficiencies
    in a timely manner.
    The Board notes that the Illinois Environmental Protection
    Agency has not yet
    filed its recommendation in this matter.
    IT
    IS SO ORDERED.
    123—62
    —3—
    I, Dorothy M. Gum, Clerk
    of the Illinois Pollution Control
    Board, hereby certify that the above Order was adopted on
    the
    ~
    day of
    -,t~
    ,
    1991,
    by a vote
    of
    7-C
    ~6rothy M.
    nfl, Clerk
    Illinois Pollution CControl Baord
    123—63

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