July 27, 2006

Illinois Pollution Control Board

James R . Thompson Center

Suite 11-500

Chicago, IL 60601-3218

Attn

: Dorothy Gunn, Clerk

Subject:

Dear Ms

. Gunn :

This letter is to accompany the Delisting Petition that was submitted under certified mail (7001

1940 00010935 1205) on July 26, 2006

. This is to inform you that the Delisting Risk Assessment

Software (DRAS) model used for statistical analysis has been identified by the United States

Environmental Protection Agency (US EPA) Region 6, creators of the software, to have problems

and is not recommended for use until the problems have been resolved

. It is unknown when the

revised version of the DRAS model will be available

. The Delisting Petition submittal uses EPA's

Composite Model for Landfills (EPA CML), an older model due to the problems with DRAS

. The

Illinois Environmental Protection Agency (Illinois EPA) agrees with BP's reasoning of using EPA

CML and not the DRAS software .

If you have any questions, please contact me at (312) 596-6717 .

Sincerely,

George Varela

Senior Environmental Scientist

cc:

US EPA - Permits and State Programs Division

US EPA, Region V - Waste, Pesticide, and Toxics Division

Illinois Department of Natural Resources

Illinois EPA - Division of Legal Counsel

Tom Tunnicliff, Atlantic Richfield Company a BP affiliated company

URS Corporation

100 South Wacker Drive, Suite 500

Chicago, IL 60606

Tel : 312 .939 .1000

Fax

: 312

.939 .4198

RECEIVEDCLERK'S

OFFICE

JUL 2 7 2006

STATE

Pollution

ILLINOIS

Board

~<p

RCRA Delisting Adjusted Standard Petition for BP Former Wood River Refinery

BP Products North America Inc

.

Madison County

---

RECEIVED

CLERK'S

OFFICE

JUL 2 7 2006

BEFORE THE ILLINOIS POLLUTION CONTROL BOAR ~STATE

-

T'OllutionOF

Control

ILLINOISBoard

IN THE MATTER OF

:

)

PETITION OF BP Products North America Inc

. )

FOR AN ADJUSTED STANDARD

)

PURSUANT TO 35 Ill. Adm. Code 720.122

)

TO: Dorothy Gunn, Clerk

Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

(CERTIFIED MAIL)

U.S. EPA

Permits and State Programs Division

Office of Solid Waste and

Emergency Response

1200 Pennsylvania Avenue N.W .

Washington, D .C. 20460

(CERTIFIED MAIL)

Stanley Yonkauski, Jr .

Illinois Dept. of Natural Resources

524 South Second Street

4th Floor

Springfield, IL 62701-1787

(CERTIFIED MAIL)

PLEASE TAKE NOTICE that on January 19, 2006, we filed with the Illinois Pollution

Control Board (IPCB), a signed original and 9 duplicate copies (10 total), and one copy to

each of the above listed, of the PETITION OF BP Products North America Inc . for an

ADJUSTED STANDARD PURSUANT TO 35111

. Adm. Code 720 .122, Docket Number AS

2006-002, RCRA Delisting Adjusted Standard

. The attached resubmittal consists of a signed

original and 4 duplicate copies for the IPCB and one copy each for the above listed

. A

MOTION TO REQUEST A WAIVER TO REDUCE THE 9 COPY REQUIREMENT OF 35

NOTICE OF FILING

William Ingersoll

Illinois Environmental Protection Agency

Division of Legal Counsel

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

(CERTIFIED MAIL)

THIS FILING IS SUBMITTED ON RECYCLED PAPER

RCRA Delisting Adjusted

Standard

Harriet Croke

U.S. EPA, Region V

Waste, Pesticide, and Toxics Division

77 West Jackson Street

Chicago, IL 60604

(CERTIFIED MAIL)

---

111

. Adm. Code 101 .302(h) TO ONE SIGNED ORIGINAL AND 4 DUPLICATE COPIES

OF BP PRODUCT'S ADJUSTED STANDARD PETITION and to INCORPORATE BY

REFERENCE APPENDICES A THROUGH J FROM THE PETITION FILED IN

DOCKET

NUMBER AS 2006-002 INTO THIS PETITION PURSUANT TO 35111

. Adm. Code

101 .306(a) is also attached .

BP Products North America Inc .

B

Ronald J

. Ganim

Senior Attorney

BP Legal

BP America Inc .

Mail Code 4 West

4101 Winfield Road

Warrenville, Illinois 60555

630-821-2263

630-821-3406 (fax)

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

RECEIVED

JUL 2 7 2006

CERTIFICATE OF SERVICE

Pollution

STATE

OF

Control

ILLINOIS

Board

I, the undersigned, on oath state that I have served the attached Petition of BP Products North

America Inc

. for an ADJUSTED STANDARD PURSUANT TO 35 Ill

. Adm. Code 720 .122

and a MOTION TO REQUEST A WAIVER TO REDUCE THE 9 COPY REQUIREMENT

OF 35111 . Adm. Code 101

.302(h) TO ONE SIGNED ORIGINAL AND 4 DUPLICATE

COPIES OF BP PRODUCT'S ADJUSTED STANDARD PETITION and to

INCORPORATE BY REFERENCE APPENDICES A THROUGH J FROM DOCKET

NUMBER AS 2006-002 INTO THIS PETITION PURSUANT TO 35 Ill

. Adm. Code

101

.306(a) upon the person(s) to whom it is directed, by placing a copy in an envelope

addressed to :

Dorothy Gunn, Clerk

Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

(CERTIFIED MAIL)

U.S . EPA

Permits and State Programs Division

Office of Solid Waste and

Emergency Response

1200 Pennsylvania Avenue N.W .

Washington, D

.C. 20460

(CERTIFIED MAIL)

Stanley Yonkauski, Jr.

Illinois Dept. of Natural Resources

524 South Second Street

4th Floor

Springfield, IL 62701-1787

(CERTIFIED MAIL)

and mailing it from Chicago, Illinois on

affixed.

Ryan Hartley, P .E.

Project Engineer

URS Corporation

312-939-1000

William Ingersoll

Illinois Environmental Protection Agency

Division of Legal Counsel

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

(CERTIFIED MAIL)

Harriet Croke

U.S . EPA, Region V

Waste, Pesticide, and Toxics Division

77 West Jackson Street

Chicago, IL 60604

(CERTIFIED MAIL)

THIS FILING IS SUBMITTED ON RECYCLED PAPER

2CDt0 sufficient

postage

---

SUBSCRIBED AND SWORN TO BEFORE

ME

this

'

day

u-i

200(0

OFFICIAL SEAL

KIMBERLY LUDFORD

NOTARY PUBLIC-STATE OF IU

JIOSS

MY CaassON VvmI Vlf

THIS FILING

IS SUBMITTED ON RECYCLED PAPER

---

RECEIVED

JUL 2

BEFORE THE ILLINOIS POLLUTION CONTROL BOARWATE

Pollution

OFControl

ILLINOIS

Boaro

IN THE MATTER OF :

)

O~ _()

PETITION OF BP Products North America Inc . )

FOR AN

ADJUSTED STANDARD

) RCRA Delisting Adjusted

PURSUANT TO 35

III. Adm. Code 720 .122

)

Standard

MOTION TO REOUEST A WAIVER TO REDUCE THE 9 COPY REOUIREMENT

OF 35111. Adm. Code 101.302(h)

TO ONE SIGNED ORIGINAL AND 4 DUPLICATE

COPIES OF BP PRODUCT'S ADJUSTED STANDARD PETITION and to

INCORPORATE BY REFERENCE APPENDICES A THROUGH J FROM THE

PETITION FILED IN DOCKET NUMBER AS 2006-002 INTO THIS PETITION

PURSUANT TO 35 III . Adm. Code 101.306(a).

BP Products North America Inc .

(BP), by its attorney, requests approval to submit one signed

original and 4 duplicate copies of the Adjusted Standard Petition

. One signed original and 9

duplicate copies of the Petition were originally filed with the Illinois Pollution Control Board

(IPCB) in Docket Number AS 2006-002

. BP is also requesting approval to incorporate by

reference Appendices A through J from the Petition filed in Docket Number AS 2006-002

into this Petition

. In support of its motion, BP states the following :

1

. On January 19, 2006, BP filed a RCRA Delisting Adjusted Standard Petition

("1/19/2006 Petition") with the Board, seeking an Adjusted Standard Delisting

pursuant to 35 Ill . Adm. Code 720 .122

. The purpose of the petition is to delist

leachate generated from the BP's Wood River, Illinois, Pond 1 Landfill from

regulation as a "listed hazardous waste" . The 1/19/2006 Petition was assigned a

docket number of AS 2006-002 .

2. On February 21, 2006, the Illinois Pollution Control Board (IPCB) requested that BP

file a certificate of publication, however, BP did not timely meet the Petition Notice

and Certification of Publication requirements of 35 Ill

. Adm. Code 104 .408 and

104.410 .

3. In an order issued on March 2, 2006, the IPCB observed that the fourteen-day period

for publication was jurisdictional

. Because proof of publication was not provided to

the IPCB, the IPCB concluded that it has no basis to conclude that it has statutory

authority to hear the petition . Accordingly, the IPCB dismissed the 1/19/2006

Petition for an adjusted standard and closed its docket

.

4

. In order to satisfy the requirements noted in point 2 above, BP is resubmitting the

Petition for an ADJUSTED STANDARD PURSUANT TO 35111 . Adm. Code

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

720.122

. BP will submit proof of public notification within 14 days of filing this

motion and the certificate of publication within 30 days after refiling the Petition

.

5

. 35 Ill. Adm. Code 101

.306 allows the IPCB or hearing officer to incorporate materials

from the record of another Board docket into any proceedings provided that the

material to be incorporated is authentic, credible, and relevant to the proceeding

. See

35 Ill . Adm. Code 101 .306(a).

6

. BP moves the IPCB to reduce the 9 copy requirement (35 Ill . Adm. Code 101

.302(h))

to one signed original and 4 duplicate copies because the refilled Petition is identical

to the original 1/19/06 Petition of which BP provided one signed original and 9

duplicate copies to the Board

. This makes the 1/19/2006 Petition both credible and

relevant

. The signed original of the Petition that accompanies this filing should also

adequately demonstrate the authenticity of the 1/19/2006 Petition

. In this motion, BP

is also requesting approval to incorporate by reference Appendices A through J from

the Petition filed in Docket Number AS 2006-002 into this Petition in an effort to

conserve paper and resources

. As explained above and in point 5, the Petition that

accompanies this filing should adequately meet the requirements of 35 Ill

. Adm. Code

101 .306.

7

. The granting of this motion will not modify the Petition or prejudice any party

:

WHEREFORE, BP requests that the Board grant this motion referenced above

.

Respectfully submitted,

BP Products North America Inc

.

By:

Ronald J

. Ganim

Senior Attorney

BP Legal

BP America Inc

.

Mail Code 4 West

4101 Winfield Road

Warrenville, Illinois 60555

630-821-2263

630-821-3406 (fax)

Ronald J

. Ganim

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

PETITION

RECEIVEDCLERK'S

OFFICE

RCRA DELISTING

JUL 2 7 2006

STATE OF ILLINOIS

ADJUSTED STANDARD

Pollution Control Board

PETITION FOR BP

PRODUCTS NORTH

AMERICA INC

., FORMER

WOOD RIVER REFINERY

IN MADISON COUNTY,

ILLINOIS

Greg Jevyak

Environmental Business Manager

Atlantic Richfield Company

A BP Affiliated Company

301 Evans Avenue

Wood River, Illinois 62095

Ronald J

.

Ganim

BP America Inc.

Mail Code 4 West

4101 Winfield Road

Warrenville, Illinois 60555

Original

: January 18, 2006 and Filed with the Board on

January 19, 2006 (AS 2006-002)

July 26, 2006

---

RECEIVEDCLERK'S

OFFICE

JUL 2 7 2006

BEFORE THE ILLINOIS

POLLUTION CONTROL BOARD

Pollution

STATE OF

Control

ILLINOISBoard

IN THE MATTER OF :

)

PETITION OF BP Products North America Inc

. )

FOR AN

ADJUSTED STANDARD

)

PURSUANT TO

35 111. Adm. Code 720.122

)

EXPLANATORY NOTE

Please Note, Appendices A through J are supporting documentation for the RCRA delisting

adjusted standard petition and are not included in this submittal

. Please reference Docket

Number AS 2006-002 for the Appendices

.

BP filed a motion for approval to incorporate by reference Appendices A through J from

Docket Number AS 2006-002 into this Petition in an effort to conserve paper and resources

.

The Petition filed with the Illinois Pollution Control Board on January 19, 2006, Docket

Number AS-2006-002 is identical to this Petition when Appendices A through J are

incorporated by reference .

THIS FILING IS SUBMITTED ON RECYCLED PAPER

RCRA Delisting Adjusted

Standard

---

RECEIVEDCLERK'S

OFFICE

JUL 2 7 2006

BEFORE THE ILLINOIS POLLUTION CONTROL B

TE OF ILLINOIS

ion Control Board

IN THE MATTER OF

:

)

PETITION OF BP Products North America Inc

. )

FOR AN ADJUSTED STANDARD

)RCRA Delisting Adjusted Standard

PURSUANT TO 35 111

. Adm. Code 720.122

)

THIS PILING IS SUBMITTED ON RECYCLED PAPER

---

TABLE OF CONTENTS

Executive Summary

ES-1

Section 1

Introduction

1-1

1 .1

Facility Description

1-1

1 .2

Site Setting

1-2

Section 2

Administrative Information

2-1

2 .1

Name of Petitioner

2-1

2.2

Names of Personnel to be Contacted for Additional Information

Pertaining to this Petition

2-1

2.3

Facility Responsible for Generating Petitioned Waste 2-1

2.4

Location of Petitioned Waste

2-2

2.5

Description of the Proposed Delisting Action 2-2

2.6

Statement of Interest in the Proposed Action

2-2

2.7

Statement of the Need and Justification for the Proposed Action

2-2

2.8

Affidavit of Material Facts - Certification Statement

2-3

Section 3

35 I.A.C

. 720.122 Requirements

3-1

Section 4

35 I.A.C. Sec.104

Subpart D Requirements

4-1

4

.1

Standard from which Adjustment is Sought (35 IAC 104

.406(a)) 4-1

4.2

Regulation of General Applicability (35 IAC 104

.406(b)) 4-1

4.3

Level of Justification for Adjusted Standard (35 IAC 104

.406(c)) 4-1

4.4

Description of the Nature of the Petitioner's Activity (35 IAC

104.406(d))

4-2

4.5

Efforts Necessary to Comply with Regulation of General

Applicability (and Alternative) (35 IAC 104

.406(e)) 4-2

4.6

Narrative Description of the Proposed Adjusted Standard (35 IAC

104.406(f))

4-3

4.7

Impact of Request for Adjusted Standard on the Environment (35

IAC 104

.406(g))

4-3

4.8

Justification for the Proposed Adjusted Standard (35 IAC

104.406(h))

4-4

4.9

Statement of IPCB Action with Regard to Federal Law (35 IAC

104.406(i)

4-4

4.10 Waiver of Hearing (35 IAC 104

.406(j))

4-4

4

.11 Supporting Documents or Legal Authorities

4-4

Section 5

Waste and Waste Management History Information 5-1

5 .1

Description of Waste and Basis for Waste Listing

5-1

5.2

History of Waste Generation

5-1

URS

THIS FILING

IS SUBMITTED

ON RECYCLED PAPER

---

TABLE OF CONTENTS

6.3.1

Analytical Parameters

6-3

6.3 .2 Analytical Laboratory

6-3

6.3 .3

Analytical Methodology

6-3

6.3.4

Reporting of Analytical Results

6-4

6.3 .5

Quality Assurance and Quality Control 6-4

6.3.6

Data Validation

6-4

Section 7

Evaluation of Leachate Data

7-1

7 .1

Presentation of Results

7-1

7.2

Identification of Comparison Benchmarks

7-1

7.2.1

Toxicity Characteristic Regulatory Levels 7-2

7.2 .2 Delisting Levels

7-2

7.3

Comparison of Results with Benchmarks

7-3

7.4

Supplementary Analytical Data

7-3

Section 8

Summary and Conclusions

8-1

Section 9

References

9-1

THIS FILING IS SUBMITTED ON RECYCLED PAPER

5 .2.1

Source of Waste Placed in the Pond 1 Landfill 5-1

5.2.2

Characteristics of Waste in the Pond 1 Landfill 5-2

5.2.3

Stockpiling and Stabilization of the Waste Prior to

Placement in the Pond I Landfill

5-2

5

.2.4

Engineering Features of the Pond 1 Landfill 5-2

5.2

.5

Characteristics of the Pond 1 Landfill Leachate

5-3

5 .2.6

Groundwater Monitoring in the Vicinity of the Pond 1

Landfill

5-3

5.3

5.4

Waste Volume

5-5

Waste Management Activities

5-5

5.4 .1

5.4.2

Current Waste Management Methods 5-5

Proposed Waste Management Method 5-7

Section 6

Waste Sampling and Analysis Information

6-1

6.1

Objective of Waste Sampling and Analysis 6-1

6.2 Strategy of Waste Sampling

6-1

6.2.1

Sample Representativeness

6-1

6.2.2 Sample Number

6-2

6.2.3 Sample Location

6-2

6.2.4

Sample Collection Methodology

6-2

6.2.5

Sampling Team

6-3

6.3

Chemical Analysis of the Waste

6-3

---

List of Tables, Figures and Appendices

THIS FILING IS SUBMITTED ON RECYCLED PAPER

Tables

Table 5-1

Maximum Detected Chemical Concentrations in Bulk Pre-solidified Soils

and Sludges from Ponds 1, 2, 3, and 4

Table 5-2

EP Toxicity Analysis - TSB Sludges

Table 5-3

Comparison of In-Situ-Generated Leachate with Toxicity Characteristic

Regulatory Levels and Health-Based Levels Modified by a Dilution-

Attenuation Factor

Table 5-4

Groundwater Monitoring Results for the Last Four Available Events

Table 6-1

Summary of Sampling and Analysis Efforts

Table 6-2

Parameters Analysed for Leachate Delisting

Table 6-3

Comparison of Leachate Concentrations with TC Regulatory Levels and

Delisting Levels

Table 7-1

TC Regulatory Levels and Delisting Levels

Table 7-2

Calculation of Health-Based Levels

Figures

Figure 1-1 Site Location Map

Figure 2-1

Regulated Waste Management Area Locations

Figure 4-1

Proposed Leachate Discharge Configuration

Figure 5-1

Monitoring Well Location Map

Figure 7-1

Dilution-Attenuation Factors for Delisting

Appendices

Appendix A

IPCB Adjusted Standard dated October 2, 1997

Appendix B

Adjusted Standard dated March 11, 1992

Appendix C

Qualifications of Sampling and Data Review Personnel

Appendix D

Qualifications of Analytical Laboratories

Appendix E

Laboratory Data Sheets

Appendix F

Sampling and Analysis Plan for Characterizing the Leachate from the

Pond 1 Landfill

Appendix G

Regional and BP Former Refinery Geology and Hydrogeology

Appendix H

Boring Logs and Well Construction Reports

Appendix I

Application for Waste Stream Authorization

Appendix J

Data Validation Report

UM

iii

---

BP Products North America Inc

. ("BP"),

formerly known as Amoco Oil Company*, submits this

petition to the Illinois Pollution Control Board (IPCB) for an adjusted standard pursuant to 35

Illinois Administrative Code 720 .122. The petition requests delisting via an adjusted standard

for leachate from the Pond 1 Landfill at the Riverfront Property, former Amoco Wood River

refinery, in Madison County, Illinois .

The material for which delisting is sought is leachate generated from the Pond 1 Landfill. The

Pond 1 Landfill contains sludge and associated soil and debris, now solidified, from the facility's

former wastewater treatment plant surface impoundments at the closed refinery. The only

hazardous waste in the surface impoundments was dissolved air flotation (DAF) float. DAF

from petroleum refining is a listed hazardous waste under federal and Illinois regulations (35

IAC 721

.132), hazardous waste number K048, because of the customary presence of hexavalent

chromium and lead

. Because of the discharge of a listed hazardous waste into the

impoundments, all sludges and underlying impacted soils in the impoundments were classified as

hazardous waste according to the "mixture rule" in 35 IAC 721

.103a(2)(D) . Therefore, the waste

residuals in the Pond 1 Landfill, specifically the landfill leachate, carry the K048 hazardous

waste code (per 35 IAC 721.103e[1]).

BP previously sought to delist the waste contained in the Pond 1 Landfill

. The Board denied that

petition because it concluded that sampling of the in situ waste was insufficient (see Appendix A

IPCB Adjusted Standard [AS 96-6] dated October 2, 1997) . This new petition is distinguishable

from the earlier one in that it only seeks to delist the hazardous waste leachate after it is

generated from the Pond 1 Landfill . This petition in no way seeks to alter the status of the Pond

1 Landfill as a RCRA facility or the associated corrective action requirements .

BP is pursuing this delisting petition in order to reduce the costs and risks associated with the

management of the "hazardous waste" leachate from the Pond 1 Landfill

. BP currently

transports the leachate by truck to the City of Wood River Wastewater Treatment Facility

(WWTF) . Leachate generated from the Pond 1 landfill is not a listed hazardous waste when

removed and handled in accordance with the exclusion at 35 Ill . adm. Code 721 .104 (a)(1)(b). If

delisted and thus non-hazardous, the leachate could be discharged into BP's East Surge Pond and

transferred along with stormwater through a series of existing stormwater retention basins (via

pumps and gravity flow) to the WWTF (along with other discharged waste streams) at essentially

no cost, while eliminating the risk inherent in transporting the waste via trucks .

Illinois is an authorized State to carry out the Resource Conservation & Recovery Act (RCRA),

and its petition mechanism for waste delisting provides under 35 IAC 720

.122 and 35 IAC 104

Subpart D for the demonstration that a specific waste stream from a particular generating facility

should not be regulated as listed hazardous waste

. To be successful in delisting a site-specific

waste stream, 35 IAC 720 .122 requires the petitioner to demonstrate that the waste stream does

not meet any of the listing criteria, does not exhibit any of the hazardous waste characteristics,

and does not contain any other toxics in excess of health-based levels

. The IPCB may grant the

adjusted standard consistent with federal law if the requirements of 35 IAC 720

.122 are

demonstrated

. This document provides the justification necessary for an adjusted standard

demonstration, consistent with

EPA RCRA Delisting Program Guidance Manual for the Petitioner

(U.S

. EPA, 2000), as referenced in 35 IAC 720 .111 .

* Amoco Corporation and BP p .l.c . merged in 1998 . Today, the corporate parent is BP p .l .c .

V iW

THIS FILING IS SUBMITTED ON RECYCLED PAPER

Executive Summary

ES-1

---

SECTIONONE

Introduction

The purpose of the petition is to exempt (delist) from regulation as "listed hazardous waste"

leachate generated from the Pond I Landfill at the Riverfront Property at the former Amoco

Wood River Refinery in Madison County, Illinois

. Under 35 Illinois Administrative Code (IAC)

720.122,

IEPA provides a petition mechanism to allow for the demonstration that a specific

waste stream from a particular generating facility should not be regulated as hazardous waste .

This petition presents information in support of delisting of the generated leachate

.

1 .1

FACILITY DESCRIPTION

The former Amoco Wood River Refinery is located in Madison County, Illinois . The Wood

River Refinery began oil-refining operations in 1908 as Standard Oil Company, later Amoco Oil

Company and ceased operations in 1981

. Currently, a BP marketing terminal occupies a portion

of the former Main Plant site

. BP's Wood River Riverfront Property is located about 1,000 feet

to the west of the former plant

. The Riverfront Property is bordered on the west by the

Mississippi River, on the east by the Wood River Levee District (WRLD) levee, on the south by

property owned by ConocoPhillips (formerly owned by Shell Oil Company), and on the north by

the former channel of Wood River

. The waste management area of the Riverfront Property, of

which the Pond I Landfill is a part, covers approximately 40 acres and is located on the east side

of the Riverfront Property

. Figure 1-1 is a site location map .

In 1957, Ponds 1 through 5 and the inlet channel were created at the Riverfront Property by the

U.S

. Army Corps of Engineers as borrow sources for the adjacent Wood River Levee District

levee

. Use of the ponds as surface impoundments for wastewater treatment began in 1958

. In

1958, Pond IA was constructed for use as an oil skimmer

. In 1977, Amoco started operation of

an advanced design wastewater treatment plant containing a dissolved air flotation (DAF) unit .

Ponds 1, 1A, 2, 3, and 4, were used in sequence for wastewater treatment from this time until

petroleum-refining operations ceased in 1981 .

A temporary surge basin (TSB), located north and west of the former Pond 1, was built in 1983

after refinery operations had ceased

. The TSB was used to hold storm water and process

wastewater streams as part of a National Pollution Discharge Elimination System (NPDES)-

permitted wastewater treatment system while closure activities took place in the other ponds

.

Ponds 1 through 5 contained hazardous waste (K048)

. In 1983, BP commenced closure of the

Ponds. A permitted non-hazardous waste management unit or landfill ("PNWL") was

constructed on the area formerly occupied by Pond 5. The PNWL contains sludges from Ponds

1 through 4 that were solidified through a "Chemfix TM" process. The sludges solidified by the

ChemfixTT"

process were delisted by the U .S . EPA and the Illinois Pollution Control Board in

1985.

By 1985, the PNWL had been filled to its design capacity . In 1991, BP began construction of an

approved RCRA landfill, the Pond 1 Landfill, for placement of the remaining sludges . Sludges

and the soil liner from Ponds I through 4 and the TSB were solidified and placed into the Pond I

Landfill

. A 100-year flood protection dike was concurrently constructed around the PNWL,

Pond I Landfill, and Ponds 2, 3, and 4 .

Ponds 2, 3 and 4 have been consolidated into one large impoundment (the East Surge Pond) .

The sludges have been removed, as discussed above, and the consolidated impoundment lined

with one foot of compacted clay. The East Surge Pond is operating under the delay of closure

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONONE

Introduction

regulations in accordance with the Adjusted Standard issued by the Illinois Pollution Control

Board (AS-91-4, 3/11/92) (see Appendix B Adjusted Standard AS 91-4 dated March 11, 1992)

.

The East Surge Pond currently receives non-hazardous wastewater from the City of Wood River

Publicly Owned Treatment Works (Wastewater Treatment Facility [WWTF]) and from the BP

facilities in the main plant area.

1 .2 SITE SETTING

The former Amoco Wood River Refinery and Riverfront Property are located in Wood River,

Madison County, Illinois, adjacent to the Mississippi River . The Riverfront Property is located

in an area of the Mississippi River floodplain valley called the American Bottoms .

Unconsolidated sediments in the American Bottoms are designated as "valley fill" and include

recent alluvial and glacial material

. Two water tables have been encountered at the Riverfront

Property above the bedrock. A discontinuous, shallow, perched water table is found in the

floodplain deposits . The shallow water table fluctuates with the level of the water in the Ponds

and the basins of the Riverfront Property . This indicates that the shallow water table is

hydraulically connected to the Ponds and basins . The uppermost aquifer is the American

Bottoms aquifer, the regional water table, and extends from the water table to the bedrock

surface .

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONTWO

Administrative information

In compliance with 35 IAC 720 .120, 35 IAC 720.122, 35 IAC 101.302,

35 IAC 104 Subpart D,

and the relevant federal delisting petition guidance (U .S

. EPA, 2000), the following

administrative information is presented .

2.1 NAME OF PETITIONER

TIIIS FILING IS SUBMITTED ON RECYCLED PAPER

a.

b.

Name of firm :

Mailing Address :

BP Products North America, Inc

.

Former Amoco Wood River Refinery

301 Evans Avenue

Wood River, Illinois 62095

2

.2

NAMES OF PERSONNEL TO BE CONTACTED FOR ADDITIONAL

INFORMATION PERTAINING TO THIS PETITION

Name

:

Title:

Address:

Telephone :

Name:

Title:

Address:

Telephone:

Gregory S. Jevyak

Environmental Business Manager

Atlantic Richfield Company,

A BP Affiliated Company

301 Evans Avenue

Wood River, Illinois 62095

(618) 254-9866

Ronald J. Ganim

Senior Attorney

BP America Inc .

Mail Code 4 West

4101 Winfield Road

Warrenville, Illinois 60555

(630) 821-2263

2.3 FACILITY RESPONSIBLE FOR GENERATING PETITIONED WASTE

a.

Name of Firm:

BP Products North America, Inc .

Former Amoco Wood River Refinery

b.

Location of Facility :

301 Evans Avenue

Wood River, Illinois 62095

c.

USEPA LD Number:

ILD 980 503 106

d.

[EPA ID Number

:

1191155009 -- Madison County

Permit #145

---

SECTIONTWO

Administrative Information

2.4

LOCATION OF PETITIONED WASTE

The petitioned waste leachate is generated from the Pond I Landfill at the BP facility described in

Section 2.3

. Figure 1-1 presents a location map for the Pond I Landfill

. Figure 2-1 presents the

location of the regulated waste management area, which includes the Pond I Landfill, on BP's

Riverfront Property .

2.5

DESCRIPTION OF THE PROPOSED DELISTING ACTION

BP is petitioning the Illinois Pollution Control Board to delist leachate generated from the Pond

I Landfill

. This delisting will be valid when the leachate from the Pond I Landfill is discharged

to the East Surge Pond and transferred to the WWTF

. The leachate is generated from the Pond I

Landfill, which contains stabilized sludges generated from the former operation of surface

impoundments and a wastewater treatment plant, and is listed as a K048 waste (dissolved air

flotation [DAF] float from the petroleum refinery industry), pursuant to the mixture rule

.

2.6

STATEMENT OF INTEREST IN THE PROPOSED ACTION

BP is pursuing this delisting petition in order to reduce the costs and potential risks of

spills/releases associated with the management of the leachate from the Pond 1 Landfill

. BP

currently transports the leachate by truck to the WWTF for treatment at a cost of $0

.13 per

gallon

. In 2003, BP spent approximately $14,000 to haul the leachate from the Pond 1 Landfill

for discharge at the WWTF

. If delisted and determined to be non-hazardous, the leachate could

be discharged into BP's East Surge Pond and transferred along with a much larger volume of

stormwater through a series of existing stormwater retention basins (via pumps and gravity flow)

to the WWTF at essentially no cost .

2 .7

STATEMENT OF THE NEED AND JUSTIFICATION FOR THE PROPOSED

ACTION

BP believes that the leachate is not hazardous and would not present a hazard to human health

and the environment if the leachate were to be discharged, to the surface impoundments as

proposed in Section 5.4.2

. Continuing to manage the leachate as a hazardous waste presents an

unnecessary cost and potential risk of spills and releases during truck loading, transport and

unloading .

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONTWO

Administrative Information

2

.8

AFFIDAVIT OF MATERIAL FACTS -

CERTIFICATION STATEMENT

I certify under penalty of law that I have personally examined and am familiar with the

information submitted in this demonstration and all attached documents, and that, based on my

inquiry of those individuals immediately responsible for obtaining the information, I believe that

the submitted information is true, accurate, and complete

. I am aware that there are significant

penalties for submitting false information, including the possibility of fine and imprisonment

.

Signed by Authorized Representative :

Ronald J . Ganim

Senior Attorney

BP Legal

BP America Inc .

Mail Code 4 West

4101 Winfield Road

Warrenville, Illinois 60555

630-821-2263

630-821-3406 (fax)

SUBSCRIBED AND SWORN TO BEFORE

ME

this J `{ day of

.

./u /y

, 20O,

'0 AN /

UM

OFFicaSEAL

CAROL A

,

NOT* PUBLIC •

OF IL"

MY COWISSION EUS:O$04

THIS FILING IS SUBMITTED ON RECYCLED PAPER

-/2y/zoo

Date

,/ i/

2-3

---

SECTIONTHREE

35 I.A.C.720.122

Requirements

35 IAC Part 720 Subpart C (Rulemaking Petitions and other Procedures), Section 120

.122 lists

the requirements to delist a waste from a particular generating facility

. The petitioner must

demonstrate that the waste does not meet any of the criteria under which the waste was listed as a

hazardous waste

. The following list identifies the requirements under 35 IAC 720

.122

(i)(1) to

(12) for preparation of a delisting petition, and references the section within this petition in

which the requirement is addressed

:

•

122(1)(1) The name and address of the laboratory facility performing the sampling tests

.

See Section 6.3.2

.

•

122(1)(2) The names and qualifications of the persons sampling and testing the waste

.

See

Sections 6.2.5 and 6.3.2

and Appendices C and D .

•

122(i)(3) The dates of sampling and testing

.

See Section 6.2.1

for sampling dates and

Appendix

E for testing dates

.

•

122(i)(4) The location of the generating facility .

See Section 2.1.

•

122(i)(5)

Description of the manufacturing processes or other operations and feed materials

producing the waste and an assessment of whether such processes, operations or

feed materials can or might produce a waste that is not covered by the

demonstrations . See Sections 5.1

and 5.2.

• 122(i)(6)

Description of the waste and an estimate of the average and maximum monthly

and annual quantities of waste covered by the demonstration

. See Sections 5.1,

3.2.5 and 3.3.

•

122(i)(7)

Pertinent data on and discussion of the factors delineated in the respective

criterion for listing a hazardous waste, where the demonstration is based on the

factors in 35 IAC 721 .111(a)(3).

See Sections 5 .1, 5.2,

and 7.0.

•

122(i)(8)

Description of the methodologies and equipment used to obtain the representative

samples.

See Sections 6.2.3 and 6.2.4

and Appendix F

.

•

122(i)(9)

Description of the sample handling and preparation techniques, including

techniques used for extraction, containerization and preservation of the samples

.

See Sections 6.2.4 and 6.3

and Appendix F.

•

122(i)(10) Description of the test performed (including results)

.

See Section 6.3.

•

122(i)(11) The names and model numbers of the instruments used in performing the tests

.

See Appendix D

.

•

122(1)(12) The certification as prescribed by this section signed by the generator or the

generator's authorized representative

. See Section 2.8.

THIS FILING LS SURMrrrEn ON

RECYCLED PAPER

---

SECTIONFOUR

35 IAC. Sec.104

Subpart D Requirements

This petition is submitted for an adjusted standard pursuant to 35 IAC 720 .122. Additionally, 35

IAC Section 104 Subpart D applies to any party seeking an adjusted standard pursuant to Section

28.1 of the Environmental Protection Act . A party may initiate an adjusted standard proceeding

by filing a petition that meets the requirements of Section 104

.406 of Subpart D . Demonstration

that these requirements are met is provided below .

4.1 STANDARD FROM WHICH ADJUSTMENT IS SOUGHT (35 IAC 104 .406(a))

This petition seeks to exclude from regulation as a listed hazardous waste under 35 IAC 721

.132

leachate generated from the Pond I Landfill at the Riverfront Property of the former Amoco

Wood River Refinery . This exclusion would be applicable at the point where the leachate from

the Pond 1 Landfill is generated (i.e., where it exits the leachate collection system) and

discharged to the East Surge Pond (as illustrated in Figure 4-1)

. It would then be transferred to

the WWTF along with stormwater from the East Surge Pond via a series of stormwater retention

basins.

The Pond I Landfill contains solidified sludge and associated soil and debris from the former

wastewater treatment plant surface impoundments . The only hazardous waste in the surface

impoundments was DAF float . DAF from petroleum refining is a listed hazardous waste under

federal and Illinois regulations (35 IAC 721 .132), hazardous waste number K048, because of

customary presence of hexavalent chromium and lead

. All sludges and underlying impacted

soils in the impoundments were classified as hazardous waste according to the "mixture rule" in

35 IAC 721 .103a(2)(D), because of the discharge of a listed hazardous waste into the

impoundments . Therefore, the waste residuals (Pond 1 Landfill leachate) carry the K048

hazardous waste code (per 35 IAC 721 .103e[I]).

4.2 REGULATION OF GENERAL APPLICABILITY (35 IAC 104 .406(b))

In order to implement the requirements of RCRA 42 U.S.C. Section 6901 et . seq ., Section

721.132

of 35 IAC was adopted as an identical in substance rule to 40 CFR Section 261

.32.

4.3 LEVEL OF JUSTIFICATION FOR ADJUSTED STANDARD (35 IAC 104

.406(c))

35 IAC 721 .132 (Subpart D) does not specify a level of justification

. According to the general

requirements of 35 IAC 720 .122 (a), any person seeking to exclude a waste from 35 IAC 721

Subpart D must demonstrate that the waste does not meet any of the criteria under which the

waste was listed as a hazardous or acutely hazardous waste, and does not contain additional

constituents or factors that could cause the waste to be classified as a hazardous waste . This

demonstration must be made by reliance on, and in a manner consistent with,

EPA RCRA

Delisting Program Guidance Manual for the Petitioner (U.S

. EPA 2000), incorporated in 35 IAC

720.11

L 35 IAC 720 .122(d) specifically applies to the subject waste because the waste is listed

as code "T" in 35 IAC 721 Subpart D . According to this subsection, a petitioner must

demonstrate that the waste :

A)

Does not contain the constituent or constituents that caused the waste to be listed,

or,

THIS FILING IS

SUISMITrED ON RECYCLED PAPER

---

SECTIONFOUR

35 IAC. Sec.104

Subpart D Requirements

B)

If containing one or more of the hazardous constituents that caused the waste to

be listed, does not meet the criterion of 35 IAC 721 .11 l(a)(3) when considering

the factors used in 35 IAC 721 .11 l(a)(3)(A)

through (K) under which the waste

was listed as hazardous .

Further, the petitioner must demonstrate that the waste does not exhibit any hazardous waste

characteristics . Sections 6 and 7 of this petition present the technical support for this

justification .

4

.4

DESCRIPTION OF THE NATURE OF THE PETITIONER'S ACTIVITY (35 IAC

104.406(d))

This information, required as part of the adjusted standard petition, is discussed in depth in

Section 5 . Section 5 presents the following information : Description of waste and basis for

waste listing (Section 5 .1); History of waste generation (Section

5 .2); Waste volume (Section

5

.3)

; and Waste management activities (Section 5 .4).

4.5

EFFORTS NECESSARY TO COMPLY WITH REGULATION OF GENERAL

APPLICABILITY (AND ALTERNATIVE) (35 IAC 104 .406(e))

BP is currently managing the leachate as hazardous waste in compliance with applicable

regulations . The leachate is currently collected and transferred via trucks to a wet-well in a

domestic sewage system sewer upstream of the W WTF

. The average volume of leachate

generated annually was 102,300 gallons between 1994 and 2003 .

If delisted, the non-hazardous leachate could be discharged into BP's East Surge Pond and

transferred along with stormwater from that pond through a series of existing stormwater

retention basins (via pumps and gravity flow) to the WWTF .

A compliance alternative would be to discharge the leachate through a pipe meeting RCRA

standards (including secondary containment, inspection, and maintenance) under the highway

separating the BP Riverfront Property from the WWTF

.

Costs are presented below for the following alternatives

: (a) compliance with regulation of

general applicability, (b) compliance with an alternative (i .e., discharge of leachate through a

RCRA pipe), and (c) compliance with the adjusted standard (i.e.,

managing the leachate as a

delisted and non-hazardous waste) :

(a) costs that are currently being incurred under compliance with the regulation of general

applicability include transportation and discharge fees for the leachate of approximately

$14,000 per year on average . Additionally, there is a large potential cost of clean up if

there were an accident during truck transport resulting in the spill of leachate

.

(b) the cost for construction of a leachate transfer pipe (under Route 3) is estimated to be

$500,000

. RCRA inspection and maintenance costs would be additional . This

alternative would eliminate the leachate transport costs identified in (a) above

.

(c) if the leachate were managed as a delisted and non-hazardous waste and discharged to the

WWTF via the existing network of surface impoundments, BP would eliminate the

UM

4-2

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONFOUR

351AC. Sec.104

Subpart 0 Requirements

transportation and discharge fees and the risk of potential spills or releases during

transport .

Delisting of the leachate from the Pond I Landfill is sought because handling and disposal of

leachate as a listed hazardous waste imposes an unnecessary burden and cost on the petitioner

and carries the risk of a transportation accident

. The recommended alternative (alternative

[c])

provides the best management practice for this waste stream with no adverse environmental

impacts

. The proposed action does not modify the existing permit conditions or associated

corrective actions at the Pond 1 RCRA facility .

4.6

NARRATIVE DESCRIPTION OF THE PROPOSED ADJUSTED STANDARD (35

IAC 104

.406(f))

BP requests that the leachate from the Pond I Landfill be exempt from classification as a listed

hazardous waste

. BP requests the Board make the following determination

:

Leachate generated from the Pond I Landfill at BP's former Wood River Refinery, Wood

River, Illinois is not a listed hazardous waste

. This delisting does not modify the

facility's RCRA Permit conditions, including corrective action requirements

.

The costs to comply with the proposed standard are estimated as follows

:

•

Install a pipe to discharge the leachate directly to the East Surge Pond -

$25,000

; and,

•

Annual cost for maintenance of the leachate pump

- $2,000.

4.7

IMPACT OF REQUEST FOR ADJUSTED STANDARD ON THE ENVIRONMENT

(35 IAC 104.406(g))

As described in detail in other portions of this petition for an adjusted standard, the potential

impact upon the environment of meeting the adjusted standard rather than the regulation of

general applicability is not significant

. The leachate is contained in an engineered landfill, with

multiple natural and engineered liner systems, a leachate collection system, and an engineered

and maintained cap

. These systems effectively preclude releases to the environment

.

The only change in leachate management as a result of the adjusted standard will be that the

leachate would be pumped along with stormwater form the East Surge Pond to the WWTF rather

than transported by truck

. Analytical results indicate that the concentrations of constituents in

the leachate are below regulatory and health-based levels (see Sections 6 and 7)

. The resulting

constituent concentrations in the East Surge Pond would be insignificant

. Furthermore, the daily

production of leachate from the Pond I Landfill is less than 0

.00036% of the capacity of the East

Surge Pond 1

In addition, the proposed leachate management method would eliminate the need for

unnecessary truck traffic across Highway 3, reducing the potential for spills and releases in the

r

This calculation is based on data collected over a 10-year period from 1994

- 2003 of leachate from the Pond I

_

Landfill (an average of 102,300 gallons/ year) and the normal available East Surge Pond capacity of 80 million

gallons

.

THIS FILING IS SURMITtED ON RECYCLED PAPER

---

SECTION FOUR

351AC. Sec.104 Subpart D Requirements

area

. The adjusted standard would not affect other routine corrective action activities at the Pond

I Landfill such as the groundwater monitoring, the operation of the leachate collection and

detection system, or the post-closure monitoring . Granting of the adjusted standard will allow

more cost-effective and safe handling and disposal of the leachate .

4.8 JUSTIFICATION FOR THE PROPOSED ADJUSTED STANDARD (35 IAC

104.406(h))

Sections 6 and 7 of this petition present the technical justification for the proposed adjusted

standard, which demonstrates that the leachate meets the delisting criteria as specified in EPA

RCRA Delisting Program Guidance Manual for the Petitioner (U.S . EPA, 2000).

4

.9

STATEMENT OF IPCB ACTION WITH REGARD TO FEDERAL LAW (35 IAC

104.406(i))

In the Matter of: RCRA Delisting, R90-17, February 28, 1991, the IPCB indicated that the rules

it adopted were in substance identical to the federal RCRA rules

. Thus, compliance with the

IPCB Rules is compliance with federal law

. BP does not believe that there are any federal

procedural requirements applicable to the Board's decision that are not required by 35 IAC 104,

Subpart D.

4.10 WAIVER OF HEARING (35 IAC 104

.406(j))

Pursuant to 35 IAC Section 104 .406(j), BP hereby waives a hearing on this petition for an

adjusted standard if no adverse citizen responses are received within 30 days from the date of

public notice of the petition in a local newspaper .

4.11 SUPPORTING DOCUMENTS OR LEGAL AUTHORITIES

BP believes this document, Petition to Delist the Pond I Landfill Leachate at BP's Former Wood

River Refinery in Madison County, Illinois,

meets the regulatory requirements of 35 IAC 120 .22,

35 IAC 104.400 Subpart D, and EPA RCRA Delisting Program Guidance Manual for the

Petitioner (U.S

. EPA, 2000)

.

URS

4-4

THIS FILING IS SUBMITI ED ON RECYCLED PAPER

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SECTIONFIVE

Waste and Waste Management History Information

This section presents a description of the subject waste

; a discussion of the basis for listing the

Pond I Landfill leachate as a hazardous waste

; a history of the leachate production ; the volume

of leachate produced ; and the past, current, and proposed leachate management methods .

5

.1

DESCRIPTION OF WASTE AND BASIS FOR WASTE LISTING

The material for which delisting is sought is leachate generated from the Pond 1 Landfill

. The

Pond I Landfill contains solidified sludge and associated soil and debris from the former

wastewater treatment plant surface impoundments .

The only hazardous waste stream in the surface impoundments was DAF float

. DAF from

petroleum refining is a listed hazardous waste under federal and Illinois regulations (35 IAC

721 .132, Subpart D) waste number K048, because of the customary presence of hexavalent

chromium and lead

. Because of the discharge of a listed hazardous waste into the

impoundments, all sludge residuals and underlying impacted soils in the impoundments were

classified as hazardous waste according to the "mixture rule" in 35 IAC 721

.103a(2)(D) .

Therefore, the solidified waste in the Pond I Landfill and its leachate (per 35 IAC 721

.103e[1])

carries the K048 hazardous waste code.

5.2

HISTORY OF WASTE GENERATION

5.2.1

Source of Waste Placed in the Pond 1 Landfill

Ponds 1, 2, 3, and 4 were operated in sequence for equalization and storage of oily wastewater

prior to treatment at the wastewater treatment plant

. The waste streams to these impoundments

included facility surface water runoff and process wastewater from the refinery . For these

reasons, constituents contained in the wastewater sludges are representative of those constituents

associated with petroleum processing .

Prior to construction of a wastewater treatment plant in 1977, treatment occurred in the Ponds by

operation of floating aerators in Ponds 2 and 3 . In 1977, BP started operation of an advanced

design wastewater treatment plant, including a DAF unit

. Effluent from the DAF unit was

discharged into Pond lA for storage and oil reclamation . The DAF float would occasionally

overflow Pond 1 A and enter Ponds 1 and 2 .

A Temporary Surge Basin (TSB) was located north and west of Pond 1

. The TSB was built in

1983, after refinery operations had ceased, and was used to hold storm water and process

wastewater streams as part of an NPDES-permitted wastewater treatment system while closure

activities took place in the other ponds

.

Sludges and associated material that were formerly contained in Ponds 1 through 4 and the TSB

were solidified and placed in the Pond I Landfill . Approximately 78,720 cubic yards of the

solidified material was placed in the Pond I Landfill .

The waste in the landfill was generated in the past during the active phase of refinery operations

(1958 - 1981)

. The Wood River refinery is no longer an active refining facility, so no additional

waste is being generated.

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONFI V E

Waste and Waste Management History Information

5.2 .2 Characteristics of Waste in the Pond 1 Landfill

The following chemical data are available for the sludge that was eventually solidified and

placed in the Pond I Landfill :

•

Total analysis of bulk samples from pre-solidified sludges and underlying soils from

Ponds 1, 2, 3, 4 ; and

•

EP Toxicity protocol leachate from pre-solidified sludges from the TSB .

Each data set is discussed briefly below

.

In October 1988, samples of sludges and underlying soils from Ponds 1, 2, 3, and 4 were

collected and analyzed (bulk samples) for principal hazardous constituents (PHC) . These

constituents included benzene, ethylbenzene, toluene, xylenes, 18 polycyclic aromatic

hydrocarbons (PAHs), bis(2-ethylhexyl)phthalate, and 7 metals (as well as some other general

parameters, such as oil and grease) . The results of the sampling and a discussion of data quality

were presented in a report by Woodward-Clyde Consultants (now URS) in 1988 (WCC 1988) .

The maximum concentration of each chemical detected in soil and sludge from each pond is

summarized in Table 5-1 . With the exception of three PAHs, all chemicals were detected.

In June 1990, sludges from the TSB were sampled and analyzed for the hazardous waste

characteristics listed in 40 CFR 261 by the EP extraction procedure

. The results of this testing

indicated that the TSB sludges were non-hazardous . Table 5-2 presents the results of the EP

protocol analyses .

5.2.3 Stockpiling and Stabilization of the Waste Prior to Placement in the Pond 1 Landfill

Prior to the solidification, sludges from Ponds 1, IA, 2, 3,4 and the TSB were removed from

their respective ponds and stockpiled in Pond 2 in accordance with an approved amended closure

plan. The stockpiling allowed for the construction of the Pond 1 Landfill and the East Surge

Basin

.

Some sludges from Ponds 1, 2, 3, and 4 were previously solidified through the Chemfx

TM

process that uses Portland cement . Most of the sludges placed in the Pond 1 Landfill were

solidified with cement and lime kiln dust . The solidified material was deposited in the Pond 1

Landfill between November 9, 1992 and January 31, 1994 . The solidified material was placed in

the landfill in discrete "curing" cells, progressing in a circular fashion around the landfill

. Once

a particular cell was cured and verified, an additional "layer" of solidified material was placed on

top.

5.2 .4 Engineering Features of the Pond 1 Landfill

The Pond I Landfill is an engineered hazardous waste landfill that complies with the

requirements contained in 35 IAC 724 .400. The landfill covers approximately 4 .1 acres with a

design holding capacity of approximately 100,000 cubic yards . The landfill is lined by an

engineered liner system consisting of ten layers, including several layers of natural soil/clay,

multiple geotextile fabrics or membranes, and a sand and gravel leachate detection and collection

layer

. In addition, the landfill has containment dikes, a multimedia cap, run-on/run-off controls

on the cap, and a vegetative layer to stabilize the cap

. The landfill is completely surrounded by a

THIS FILING IS SUBMrITEU ON RECYCLED PAPER

---

SECTIONFIVE

Waste and Waste Management History Information

6-foot security fence with a padlocked gate . The landfill is protected from a 100-year flood

event by a flood protection dike. The design criteria for the landfill were described in

"Engineering Report, Pond 1 Landfill, Riverfront Property, Wood River (Former) Refinery"

(WCC 1991) . A permit application to construct the Pond 1 Landfill was submitted to the IEPA

on March 22, 1991. IEPA approved construction of the landfill on July 19, 1991, and

construction of the liner was completed by October 24, 1992 ; the cap construction was

completed in September 1994 . Final seeding of the cover was completed on June 15, 1995

.

5.2.5

Characteristics of the Pond 1 Landfill Leachate

The leachate from the Pond 1 Landfill was sampled previously for the 1997 delisting petition .2 A

detailed discussion of the additional sampling activities completed in 1998 is presented in

Section 6 . The results of the 1997 testing indicated that leachate contained the following organic

compounds :

•

benzene;

•

carbon disulfide;

•

methyl ethyl ketone;

•

toluene;

•

xylenes;

•

bis(2-ethylhexyl)phthalate ;

•

2,4-dimethylphenol ; and

•

phenol

.

The testing also indicated that the leachate contains the following metals :

•

arsenic;

•

barium;

•

nickel ; and

•

selenium.

A comparison to "benchmark" values (i.e.,

delisting levels) indicated that the leachate from the

landfill was suitable for delisting

. Table 5-3 presents a comparison of the analytical results for

the detected constituents in the leachate with the benchmark values . It should be emphasized

that these 1997 data are not to be used as the primary data supporting this petition, but rather as

supplementary data.

5.2.6 Groundwater Monitoring in the Vicinity of the Pond 1 Landfill

Groundwater monitoring information is included in the petition per EPA RCRA Delisting

Program Guidance Manual for the Petitioner (U.S . EPA, 2000). The Groundwater Monitoring

system required by the Part B Permit consists of 23 Compliance Monitoring wells that are

sampled annually, and 19 Corrective Action Monitoring Wells that are sampled semi-annually

.

Locations of the groundwater monitoring wells in the vicinity of the Pond 1 Landfill are

Z

Three waste samples and three in-situ leachate samples were collected from the Pond I Landfill for the 1997

delisting petition . These samples were analyzed for 54 constituents of concern (constituents common to petroleum

refining

processing) plus lead, chromium, vinyl chloride, carbon tetrachloride, and 1,2,4-trimethylbenzene

.

V iw

THIS FILING IS SUBMITTED ON RECYCLED PAPER

5-3

---

SECTIONFIVE

Waste and waste management History information

illustrated in Figure 5-1

. Additional components of the site Groundwater Monitoring Program

include the Cone of Depression (COD) wells that control groundwater flow in the uppermost

aquifer, and a Groundwater Management Zone (GMZ) approved by Illinois EPA in April 2002

.

Regional, local and unit-specific geology and hydrogeology are described in Appendix G

.

Field and laboratory Quality Assurance/Quality Control (QA/QC) procedures are provided in the

sampling plan from RCRA Part B Post-Closure Permit Application for the North Cell of Spray

Pond #1 and the South Flare Pit (Jacobs Engineering Group Inc

., 1992), and in the Sampling

and Analysis Plans prepared on a quarterly basis by URS in advance of groundwater monitoring

activities (most recently in July 2005) . The quarterly documents, which are supplied to the

laboratory, the URS field crew, and URS program managers, include up-to-date methodology

and analysis requirements .

The 1992 sampling plan includes detailed discussion on the following topics :

•

Sampling Frequency

•

Potentiometric Surface Measurements and Product Thickness Measurements

•

Equipment and Materials

•

Well Evacuation

•

Sample Collection

•

Field Analysis

•

Field Log Book

•

Sample Containers, Preservation and Holding Times

•

Packaging, Shipping, and Handling Procedures

•

Sample Labels

•

Sample Number Format

•

Chain of Custody Record

•

Field QA/QC Procedures

•

Laboratory QA/QC Procedures

•

Disposition of Site Generated Wastes

Groundwater monitoring data from the last four monitoring events for three Corrective Action

Program wells (G119, G66D, and G103) in the vicinity of the Pond 1 Landfill are included in

Table 5-4

. The data provided are for parameters on the Part B Permit-required parameters list

for the Groundwater Monitoring Program wells that were also detected in the Pond 1 leachatc

samples.

Groundwater flow direction in the vicinity of the Pond 1 Landfill is to the east-southeast toward

the COD wells at the Main Plant . The data from downgradient groundwater monitoring wells

GI 19 and G66D were compared to data from well G103, which is representative of upgradicnt

Um

5-4

THIS FILING IS SURMI'1'VEn ON RECYCLED

PAPER

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SECTIONFIVE

Waste and Waste Management History Information

groundwater quality, to identify potential impacts to the groundwater from the Pond I Landfill

leachate . As indicated in Table 5-4, concentrations of the listed constituents were either not

detected in the downgradient wells, or were detected at lower concentrations than those at G103 .

Boring logs and construction diagrams for the wells are provided in Appendix H .

Although some of the same organic and inorganic constituents were detected at G 119 and G66B

as in the leachate samples, none were detected at concentrations exceeding the Tiered Approach

to Corrective Action Objectives (35 IAC 742, or TACO) Class I Groundwater Remediation

Objectives (ROs).

In conclusion, the Pond 1 Landfill does not appear to be impacting the groundwater

.

5.3 WASTE VOLUME

A total of 61,330 cubic yards of sludge were solidified with 8,186 cubic yards of reagent for a

total volume of approximately 69,520 cubic yards . This material and an additional 9,200 cubic

yards of clayey material that did not require solidification have been placed in the Pond I

Landfill . Therefore, the total volume of material contained in the Pond 1 Landfill is 78,720

cubic yards . This volume estimate was obtained from surveyed volumes recorded in the daily

logs maintained during the solidification and placement process .

The Pond 1 Landfill has generated an average of 102,300 gallons per year of leachate from 1994

through 2003 . The leachate is removed from the landfill on an as-needed basis . The leachate is

pumped from the leachate collection system located at the south-center edge of the landfill to a

6,000-gallon tanker truck . The tanker truck then delivers the leachate to the WWTF .

5.4 WASTE MANAGEMENT ACTIVITIES

5.4.1 Current Waste Management Methods

Thirty-year post-closure activities began after the Pond 1 Landfill was certified as closed in

1995 . The post-closure plan for the Pond 1 Landfill has the following principal components

:

•

Groundwater monitoring plan ;

•

Leachate collection and detection

; and

•

Pond 1 Landfill post-closure maintenance.

These components are discussed below . The activities being performed are described in more

detail in three documents previously submitted to the [EPA :

•

"RCRA Part B Permit for the East Surge Pond Located at Amoco's Wood River Riverfront

Property" (Mittelhauser/WCC 1992a) (Volume I of III)

;

•

"Post Closure Plan for the Pond 1 Landfill" (Mittelhauser/WCC 1992b) (Volume It of Ill)

;

and

•

"Groundwater Monitoring Plan for Amoco's Wood River Riverfront Property"

(Mittelhauser/WCC 1992c) (Volume III of 111) .

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Waste and Waste Management History Information

5.4.1.1 Groundwater Monitoring Plan

The groundwater monitoring plan (GWMP) for the Riverfront Property is part of the approved

Amended Closure Plan for the Riverfront Property

. The GWMP is intended to provide

information for assessment of groundwater quality during the corrective action program for the

waste management area (the Pond 1 Landfill and the East Surge Basin) . The GWMP will also be

used to demonstrate the effectiveness of groundwater control through the BP Interim Corrective

Action Program . The groundwater monitoring network includes 45 wells completed in the

uppermost aquifer : base monitoring wells (sampled semi-annually to annually) and assessment

wells (sampled on an "as needed" basis for various purposes) .

5.4.1.2 Leachate Detection and Collection

The Pond 1 Landfill has several liner systems and a leachate detection and collection system,

preventing the release of chemicals from the Pond 1 Landfill to groundwater .

Leachate from the Pond 1 Landfill that accumulates in collection sumps located beneath the

landfill is periodically removed via vacuum truck for treatment at the WWTF, which is located at

the following address :

559 State Aid Road

Wood River, Illinois 62095

BP was granted authorization from the IEPA to discharge the leachate to a municipal sewer

upstream of the WWTF. See Appendix I Application for Waste Stream Authorization .

5.4.1.3 Pond 1 Landfill Post-Closure Maintenance

The post-closure inspection and maintenance activities for the Pond I Landfill include the

following components :

•

Weekly inspection (minimum) of security control devices (two padlocked, 6-foot cyclone

security fences

: one surrounding the Riverfront Property area and the other surrounding the

Pond 1 Landfill) ;

•

Inspection of Flood Protection Dike prior to any peak flow period (river crest) ;

•

Inspection of the Pond 1 Landfill cover for erosion damage after each 24-hour/25-year storm

;

•

Inspection of the Pond 1 Perimeter Landfill Dike for erosion damage after each 24-hour/25-

year storm;

•

Inspection of the Flood Protection Dike for erosion damage after each 24-hour/25-year

storm;

•

Inspection of the Pond 1 Landfill cover's surface run-on and run-off control and cover

drainage layer for erosion or settlement, after each 24-hour/25-year storm

;

•

Quarterly inspection of the Pond 1 Landfill cover for settlement, subsidence or displacement ;

•

Quarterly inspection of the leachate collection, removal and leak detection systems for leaks

and proper functioning of the sumps

;

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Waste and Waste Management History Information

•

Quarterly inspection of the monitoring wells for damage to lock cap or cover

; and

•

Quarterly inspection of the cap's vegetative cover for areas of unexplained stress

.

Written records of any problems or potential problems noted during the inspections are

forwarded to the post-closure maintenance supervisor, who is responsible for initiating a follow-

up response, verifying the problem, arranging to solve the problem, and supervising the support

and maintenance personnel to implement the needed repairs

.

5.4.2

Proposed Waste Management Method

The proposed waste management method for the leachate from the Pond 1 Landfill is to pump

the leachate via existing stormwater retention basins to the WWTF

. Specifically, the Pond 1

Landfill leachate will be pumped to the East Surge Pond, which is located immediately south of

the Pond 1 Landfill

. From the East Surge Pond, the leachate, along with any water

(i .e.,

stormwater and sanitary wastewater) that is contained in the East Surge Pond, will be pumped to

Pond 2A

. From Pond 2A, water will flow by gravity through Pond 3A and then the Temporary

Surge Basin (TSB) to Forebay, the influent sump to the WWTF

.

Thus, the only change in management of the leachate will be that the leachate would be

pumped/gravity fed to the WWTF rather than transported by truck

. There will be no changes to

the groundwater monitoring plan, the leachate collection and detection system, or the Pond 1

Landfill post-closure maintenance program as a result of delisting

.

Though not anticipated, it is possible that the stabilization process employed could potentially

lose its effectiveness over time

. Therefore, the leachate would be sampled annually while the

landfill is generating leachate

. The samples will be analyzed for hexavalent chromium (SW-846

Method 7196A) and total lead (SW-846 Method 6010B)

. In addition, total chromium will be

analyzed per SW-846 Method 6010B to give indications on the maximum hexavalent chromium

concentration in the leachate

. (Total chromium is reported by the analytical laboratory as the

combined concentrations of trivalent and hexavalent chromium

.) These parameters will be

analyzed for trends after 10 years by the Mann-Kendall Test or comparable method

.

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SECTIONS IX

Waste Sampling and Analysis Information

On May 20, 1998, URS submitted a draft Sampling and Analysis Plan (SAP) to IEPA for review

.

This SAP was designed to characterize the leachate from the Pond 1 Landfill for the purpose of

delisting the leachate

. On July 2, 1998, IEPA responded with comments on the draft SAP

. URS

responded to IEPA's comments in a letter dated July 20, 1998

. Mark Crites of the IEPA Permit

Section verbally approved URS' comments in a telephone call on July 7, 1998

. The finalized

SAP was utilized to implement the leachate characterization program

.

This section presents a description of the objectives, strategy, and methodology used in sampling

and analyzing the leachate

.

6.1

OBJECTIVE OF WASTE SAMPLING AND ANALYSIS

The objective of this sampling effort was to obtain valid information that could be used as the

primary data to characterize the chemical and physical nature of the leachate from the Pond I

Landfill for the purpose of delisting

.

Specific sampling and analysis objectives were

:

•

to comply with the regulatory requirement for representativeness found in 35 IAC 720

.122(h)

(i.e.,

characterizing temporal variability in the leachate)

; and

•

to meet the data quality objectives

(i .e.,

accuracy and precision) defined in SW-846

.

6.2

STRATEGY OF WASTE SAMPLING

This section describes the sampling strategy that was used to meet the objectives specified in

Section 6.1

. A copy of the sampling plan is included as Appendix F

.

6.2.1

Sample Representativeness

Potential temporal variability was addressed by collecting samples over a six-month leachate

generation period (i

.e ., April 1998 to October 1998)

. Since access to the leachate in the Pond I

Landfill is available only when the leachate is being pumped, sampling was done during the

scheduled leachate discharge events that occur on an as-needed basis

. Samples were collected

during three different leachate discharge events in 1998 (August 7 through 12, September 9 through

11, and October 14 through 16)

. The samples collected in August represented leachate that had

accumulated since April 1998 (i

.e.,

the leachate collection system was pumped dry on April 13,

1998 and was not pumped again until August 7, 1998 when URS initiated this leachate sampling

program) .

Temporal variability was further addressed by collecting samples on different days during a single

leachate discharge event

. For this sampling program, three 6,000-gallon vacuum trucks were filled

over the course of at least three days during each leachate discharge event

. One grab sample was

collected each day for a total of three grab samples per leachate discharge event (or one grab sample

per 6,000 gallons of leachate pumped)

.

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6-1

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Waste Sampling and Analysis Information

6.2.2 Sample Number

Sample number adequacy was considered in the sampling design

. Chapter 35 Section 720.122(h) of

the Illinois Administrative Code requires at least four demonstration samples for delisting . To be

conservative, URS collected three samples during three different leachate discharge events (i.e.,

nine investigative samples of leachate were collected) . In addition to the nine investigative samples,

quality control samples (duplicates, matrix spike/matrix spike duplicates [MSIMSDJ, and trip

blanks) were collected .

6.2 .3 Sample Location

Leachate samples were collected from a sampling valve at the outlet of the leachate collection

system

. The collection system consists of a 100-foot-long, 2-inch PVC pipe that extends from the

south edge of the landfill to the center of the landfill . The collection pipe, which has a submersible

pump at its base, is sloped at a 30-degree angle . Samples were collected from the sampling valve

while leachate was being pumped to vacuum trucks .

6.2.4

Sample Collection Methodology

The following is a summary of the sampling methodology:

•

Three grab samples were collected during three different discharge events (a total of nine

grab samples) .

•

During a single leachate discharge event, one grab sample was collected for every 6,000

gallons of leachate that are pumped from the landfill until three samples were collected .

•

In addition to the nine investigative samples, the following quality control samples were

collected:

= One field duplicate per sampling round (i .e., leachate discharge event)

;

=> One matrix spike and one matrix spike duplicate per sampling round

(i .e.,

leachate discharge event) ; and

One trip blank per sampling round (i .e., leachate discharge event) with each

cooler containing aqueous samples for volatile organic compound (VOC)

analyses .

Table 6-1 presents a summary of the sampling and analysis effort including sample container,

preservation, and holding time information for the various parameters analyzed .

•

The grab samples were collected from a sampling valve at the outlet of the leachate sump .

Each sample was collected at least 30 minutes after pumping had been initiated to ensure that

the discharge line had been flushed with leachate.

•

Sampling was conducted by personnel experienced in sample collection .

•

Volatile sample containers were filled and sealed immediately after sampling without

headspace or bubbles .

•

Sample containers were closed and sealed immediately after sampling .

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SECTIONS IX

Waste Sampling and Analysis Information

•

Sample containers were laboratory supplied

.

•

Sample containers were labeled with date, sample time, location, and analytical testing

procedures .

•

Chain-of-custody forms were completed in the field and submitted along with the samples

.

Samples were stored on ice in coolers and delivered to the analytical laboratory

.

6.2.5 Sampling Team

Sampling was conducted by URS personnel experienced in sample collection

. Resumes of

individuals involved in the collection of samples and review of data are contained in Appendix

C.

6.3

CHEMICAL ANALYSIS OF THE WASTE

6.3.1

Analytical Parameters

The samples were analyzed for the parameters listed in Table 6-2

. This list of parameters was

compiled from the following three sources :

•

The characteristics of a hazardous waste as defined in 35 IAC 721 Subpart C

;

•

A list of 54 compounds identified as constituents of concern for petroleum processes in

EPA

RCRA Delisting Program Guidance Manual for the Petitioner

(USEPA 2000)

; and

•

Ten additional compounds identified by BP as potentially being present in BP's wastewater

and, as a result, potentially accumulating in the waste that was placed in the Pond 1 Landfill

.

In addition, 1,2,4-trimethylbenzene was added to the list because it was analyzed as part of the

1997 delisting petition for the Pond 1 Landfill waste

.

6.3.2

Analytical Laboratory

Samples were shipped to American Technical and Analytical Services, Inc

. (ATAS), 875 Fee

Fee Road, Maryland Heights, Missouri, 63043

. Appendix D presents information on the

personnel involved in the chemical analysis or responsible for data reduction, validation and lab

quality control, as well as information on the equipment used in the analyses

.

6.3.3

Analytical Methodology

Analyses were performed using SW-846 methodologies (i

.e.,

Method 8240 for volatiles, Method

8250 for semi-volatiles, Method 6010 for metals, and other relevant SW-846 methods)

. Table 6-

2 identifies the specific analytical methods used in this investigation

.

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Waste Sampling and Analysis Information

6.3.4 Reporting of Analytical Results

Appendix E contains copies of the original laboratory sheets reporting the results of the chemical

analyses

. The laboratory sheets contain the following information required for this petition :

•

Sample identification number ;

•

Laboratory identification number ;

•

Sample type (i .e., either site sample or QC sample)

;

•

Analysis performed (method reference) ;

•

Date submitted, date analyzed, and date prepared/extracted (where applicable) ;

•

Analytical parameters ;

•

Analysis results and units ;

•

Reporting limits (practical quantitation limits plus any dilution)

;

•

The basis for each analysis (either "as is" sample or leachate) ; and

•

Quantitation limits .

The results of the analysis of the leachate are presented on Table 6-3 .

6.3.5 Quality Assurance and Quality Control

Various quality control samples were applied in the analysis, including method blanks, matrix

spikes, matrix spike duplicates, and surrogate spikes

. The analytical results for each QC sample

are contained in Appendix E . The laboratory sheets contain the following information

:

•

Detected concentrations in the method blanks ;

•

Name of chemical added to matrix spikes and/or matrix spike duplicates

;

•

Amount of chemical added to the spiked samples

;

•

Chemical concentration in the spiked samples

;

•

Chemical concentration in the unspiked sample ;

•

Calculated percent recovery ;

•

Acceptance criterion for recovery ; and

•

Relative percent difference (RPD) and acceptance criterion

.

6.3.6 Data Validation

The data received from the laboratory were externally reviewed by a qualified chemist

. A

memorandum summarizing the data review is contained in Appendix J

. The conclusion of the

data review was that the quality control was acceptable with two exceptions : 1) some zinc

results were qualified because zinc was detected in the laboratory blank and 2) one iron result

was qualified because iron was detected in the method blank

.

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SECTIONS EVEN

Evaluation of toachate Data

7.1 PRESENTATION OF RESULTS

Table 6-3 presents the results of chemical analysis of the nine leachate samples and three

duplicate samples . The following constituents were detected in at least one of the twelve

samples :

•

Seven volatile organic compounds (VOCs) (acetone, benzene, carbon disulfide, methyl ethyl

ketone, toluene, 1,2,4-trimethylbenzene, and xylene)

;

•

Four semivolatile organic compounds (2,4-dimethylphenol, 2-methylphenol [o- and p-

cresol], bis(2-ethylhexyl)phthalate, and phenol) ;

•

Three pesticides (endrin, lindane, and heptachlor) and one herbicide (silvex)

;

•

Ten metals (aluminum, arsenic, barium, chromium, iron, lead, manganese, nickel, silver, and

zinc); and

Other inorganics that were detected include ammonia, fluoride and sulfide

. The pH of the

leachate ranged from 7.3 to 8 .1

. The ignitability tests indicated that all twelve leachate samples

had flashpoints greater than 200 degrees F.

7.2 IDENTIFICATION OF COMPARISON BENCHMARKS

The potential hazards of the petitioned waste leachate were evaluated for delisting purposes

. The

evaluation consisted of two steps

: 1) determine if the petitioned leachate is a hazardous waste

pursuant to 40 CFR 261

.24 ; and 2) determine if the petitioned leachate is eligible for delisting

.

The first step was performed by comparing the leachate concentrations with the toxicity

characteristic (TC) regulatory levels . If the results concluded that the petitioned leachate does not

exhibit any of the characteristics of toxicity for hazardous waste, the petitioned leachate could be

managed as a non-hazardous waste.

The eligibility of the petitioned leachate for delisting was then determined by comparing the

leachate concentration with a "delisting level" . The delisting level represents a maximum

allowable concentration of the constituent in the leachate

. A delisting level for a specific

constituent is estimated from the acceptable exposure level to a potential human receptor

considering migration through the subsurface environment .

Delisting levels were estimated using toxicity reference levels, combined with dilution/

attenuation factors derived from the application of a subsurface fate and transport model, e

.g.,

EPA's Composite Model for Landfills (EPACML) . The dilution/attenuation factor derivation

assumes a reasonable worst-case management scenario .

If all leachate concentrations are below the respective delisting levels, the petitioned material is

suitable for delisting .

The identification of the two comparison benchmarks is described below

.

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Evaluation of leachate Data

7.2.1 Toxicity Characteristic Regulatory Levels

The first benchmark, considered generic, is the regulatory limit for the Toxicity Characteristic, as

presented in 35 IAC 721 .124 or Table 1 of 40 CFR 261 .24. These values are based on a

chemical's Safe Drinking Water Act

maximum contaminant level (MCL) value, multiplied by a

generic dilution/attenuation factor of 100

. These values represent concentrations above which a

substance is defined as a hazardous waste by the Toxicity Characteristic

. These values are

shown in Table 7-1 .

7.2.2 Delisting Levels

The second benchmark, the delisting criterion, is a Health-based Level (HBL) increased by a

site-specific dilution/attenuation factor . The HBL may be the chemical's MCL value, or may be

a calculated, non-regulatory, health-based value

. A calculated HBL is a concentration associated

with an acceptable cancer risk (1x10 -6) or non-carcinogenic health hazard (hazard index = 1),

based on consumption of the leachate by a 70 kg adult at a rate of 2 liters per day for 70 years

. It

should be noted that the HBLs are highly conservative screening values that do not take into

consideration analytical detection limits

.

Most HBLs reported in Table 7-1 are obtained from the "Docket Report on Health-Based Levels

and Solubilities Used in the Evaluation of Delisting Petitions, Submitted Under 40 CFR §260.20

and §260.22" (U.S .EPA 1994)

. For those chemicals not listed in this report, the HBLs were

calculated based on an acceptable cancer risk (1x10 -6) for carcinogens or a target health hazard of 1

for noncarcinogens, using the equations provided in the referenced document

. The calculations

are provided in Table 7-2 for carcinogens and noncarcinogens .

It should be noted that the reported HBL for inorganic ammonia of 30 mg/L is a drinking water

health advisory given by U.S . EPA . This value is based on a chronic exposure

. An HBL has not

been established for 2-methylnaphthalene since no toxicity information is available for this

chemical .

The dilution/attenuation factor, as defined by U.S.EPA,

is the contaminant concentration in leachate

leaving a disposal unit divided by the concentration in a receptor well predicted by the EPACML

. It

represents the reduction in contaminant concentration resulting from subsurface processes such

as

adsorption, three-dimensional dispersion, and dilution from groundwater recharge

.

The dilution/attenuation factor is derived under a generic worst-case scenario

. Site-specific physical

factors (e .g., site hydrogeology) are not considered in the EPA's model because a delisted waste is

no longer under hazardous waste controls and the Agency is unable to predict or does not control

how a waste will be managed after delisting

. Therefore, the site-specific conditions may not be

applicable under the scenarios after delisting .

The EPA considers two disposal scenarios for waste delisting

: landfill and surface impoundments .

The surface impoundment scenario generally results in a lower dilution/attenuation factor compared

to the landfill scenario due to the higher leachate flux at surface impoundments

. The proposed

disposal method for BP's Pond I Landfill Leachate is placement of the leachate in a surface

impoundment (see Section 5 .4.2 for a description of the proposed management method)

. Therefore,

a surface impoundment disposal scenario is an appropriate approach for determining the

dilution/attenuation factors for the purpose of this delisting petition

.

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Evaluation of leachate Data

The dilution/attenuation factor determination is based on the maximum waste volume

. Under the

surface impoundment scenario, the maximum annual generation rate of liquid waste is used in the

model. For the investigated landfill, 288,000 gallons (1,429 cubic yards) of leachate were generated

in 1997

. This rate is considered higher than that of a typical year (the average annual leachate

generation rate between 1994 and 2003 was about 102,300 gallons) and is therefore used to

approximately represent the maximum annual waste generation rate

. This rate corresponds to a

dilution/attenuation factor of 93 as given in the document entitled "Hazardous Waste Management

System

; Proposed Use of EPA's Composite Model for Landfills (EPAMCL) and Proposed

Exclusion" (U.S .

EPA 1991) and demonstrated in Figure 7-1 (56 FR 33000, July 18, 1991)

.

7.3 COMPARISON OF RESULTS WITH BENCHMARKS

Comparisons of leachate concentrations with TC regulatory levels and delisting levels are

presented in Table 6-3

. None of the TC constituent concentrations detected in the leachate

exceed the TC regulatory level

. Therefore, the petitioned leachate is a non-hazardous waste

.

The comparison of leachate concentrations with the delisting levels indicated that no constituents

were detected in the investigative and duplicate leachate samples at levels above the delisting

levels.

There are eight constituents that were not detected in any of the leachate samples, however their

detection limits were above the delisting levels

. Those chemicals are

: 7,12-

dimethylbenz(a)anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene,

dibenzo(a,h)anthracene,indeno(1,2,3-cd)pyrene,pentachlorophenol,and ethylene dibromide

.

The calculated health-based levels for these chemicals are considerably lower, which results in

delisting levels at or below the required quantitation limits established by U

.S . EPA

. For these

compounds, delisting levels calculated for those chemicals cannot be detected by routine

laboratory analysis

. The method detection limits were, therefore, used as the delisting criteria for

those chemicals .

The delisting criteria could not be estimated for 2-methylnaphthalene due to the unavailability of

the toxicity information

. 2-Methylnaphthalene was not detected in any leachate samples

.

Therefore, it is unlikely that any concern would exist for 2-methylnaphthalene contamination

.

These analytical results indicate that concentrations of chemicals in leachate are below regulatory

and health-based levels

. Therefore, this material is suitable for delisting and can be managed as a

non-hazardous waste and discharged to a surface impoundment leading to the WWTF via a

series of stormwater retention basins, as proposed

.

7.4

SUPPLEMENTARY ANALYTICAL DATA

Additional post-1998 leachate analytical data is provided in this discussion to augment the 1998

data

. One sample of the Pond 1 Landfill leachate was collected as part of a Compliance

Sampling Inspection by Illinois EPA in April 2003

. One additional sample was collected by BP

in August 2005

. The results from these samples were used to confirm that the chemistry of the

leachate remains similar to that sampled in 1998 .

Comparison of the 2003 and 2005 results with those from the 1998 samples indicates that the

chemistry of the leachate remains similar to that sampled in 1998 (see Table 6-3 for results)

. The

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Evaluation of

Leachate Data

detected VOCs, pesticides, and herbicides in the 1998 and 2003 samples were non-detect in the

2005 samples or detected at lower concentrations than the 1998 or 2003 samples

. The S VOCs

detected in the 1998 and 2003 samples were non-detect in the 2005 samples with the exception

of pentachlorophenol

. Pentachlorophenol was detected below the laboratory reporting limit and

the concentration was below the regulatory delisting level

. The metals were reported at similar

or lower concentrations for all elements with the exception of antimony, copper, and vanadium,

which were detected in the 2005 samples and not in the 1998 or 2003 samples

. The

concentrations were below the regulatory delisting level

. Additionally, the inorganic parameters

showed comparable results between the 1998, 2003, and 2005 samples

.

URS QA/QC procedures and data validation procedures for the 2005 analytical results followed

the SAP

. STL completed the 2005 analyses

. STL's qualifications are provided in Appendix D

.

Based on these results, it is evident that the leachate chemistry has not changed since 1998, and

that all delisting criteria continue to be met

. Therefore, the leachate generated from the Pond 1

Landfill is eligible for delisting under 35 IAC 720

.122 .

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SECTIONEIGHT

Summary and Conclusions

This is a petition to the IPCB to exempt (delist) from regulation as "listed hazardous waste"

leachate generated from the Pond 1 Landfill at the Riverfront Property at the former Amoco

Wood River Refinery in Madison County, Illinois . Under 35 JAC 720.122,

IEPA provides a

petition mechanism to allow for the demonstration that a specific waste stream from a particular

generating facility should not be regulated as hazardous waste

. This petition has presented

information in support of delisting of the leachate .

The Pond 1 Landfill contains sludges that were originally deposited in four RCRA interim status

surface impoundments that operated in sequence for equalization and storage of wastewater prior

to treatment at the former BP wastewater treatment plant

. Waste streams to the surface

impoundments included surface water runoff and process wastewater from the refinery

. The

refinery process wastewater contained DAF float, a listed hazardous waste under Illinois and

federal regulations (K048) for hexavalent chromium and lead

. Because of the presence of a

listed hazardous waste in the waste stream, all contents of the ponds were classified as hazardous

waste according to the "mixture rule" in 35 IAC 721

.103(a)(2)(D).

The sludges were removed from the surface impoundments in which they were originally

deposited

. They have been solidified using a cement/lime kiln dust reagent and re-deposited in

the Pond 1 Landfill under an IEPA approved closure plan

. The Pond 1 Landfill is an engineered

landfill with multiple natural and engineered liner systems, a leachate detection and collection

system, a flood protection dike, and an engineered cap with run-on/run-off controls and a

vegetative cover

. A comprehensive post-closure maintenance program has been developed to

ensure that the leachate collected will be properly managed and that the landfill remains in good

operating and functional condition

. This leachate is the subject of this delisting petition

.

Nine samples of the leachate were obtained from the Pond 1 Landfill leachate collection system

in 1998. These samples were in addition to the three leachate samples from 1997

. Additional

sample results collected in 2003 by the IEPA and in 2005 by BP, were used

as supplementary

data

. The samples were analyzed for the characteristics of hazardous waste and for constituents

that potentially could be present in the Pond 1 Landfill based on a review of past plant operations

(i .e., metals, VOCs, S VOCs, pesticides, and herbicides)

.

Concentrations of all detected chemicals in the samples were below Toxicity Characteristic

regulatory levels and health-based levels modified by a site-specific dilution/attenuation

.

Concentrations of total cyanide and sulfide were below that requiring testing for reactivity

.

Samples were found not to demonstrate the characteristics of ignitability or corrosivity

.

Based on the results of the sampling, all delisting criteria have been met

. The leachate generated

from the Pond I Landfill is eligible for delisting under 35 IAC 720

.122 in accordance with U

.S .

EPA's guidance entitled EPA

RCRA Delisting Program Guidance Manual for the Petitioner

(U .S .

EPA 2000)

. It is requested that the IPCB grant the delisting status for the Pond 1 Landfill

generated leachate according to the proposed management method that is judged to be more

environmentally sound and less burdensome than the current method

.

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

SECTIONNINE

References

40 Codes of Federal Regulations (40 CFR)

. 2004 Edition .

Illinois Environmental Protection Agency 1997

. Groundwater Evaluation System Pilot Study -

Ambient Groundwater Quality in the American Bottoms (April)

.

Mittelhauser/WCC 1992a

. RCRA Part B Permit Application for the East Surge Pond Located at

BP's Wood River Riverfront Facility

.

Mittelhauser/WCC 1992b . Post-Closure Plan for the Pond 1 Landfill

.

Mittelhauser/WCC 1992c

. Groundwater Monitoring Plan for BP's Wood River Riverfront Property

.

U.S . EPA 1991

. Hazardous Waste Management System; Proposed Use of EPA's Composite Model

for Landfills (EPAMCL) and Proposed Exclusion

. SW-FRL-3974-6, Proposed Rules in the

July 18, 1991 Federal Register

.

U.S. EPA 1994 . Docket Report on Health-Based Levels and Solubilities Used in the Evaluation of

Delisting Petitions Submitted Under 40 CFR 260

.20 and 260 .22. EPA Contract No

. 68-W9-

0091,1994

.

U.S. EPA 2000

. EPA RCRA Delisting Program Guidance Manual for the Petitioner

. EPA Region

6, Multimedia Permitting and Planning Division, March 23, 2000

.

Voelker, D

.C . 1984 . Quality of Water in the American Bottoms, East St

. Louis, Illinois

. U .S .

Geological Survey Water - Resources Investigations Report 84-4180

.

Woodward-Clyde Consultants (WCC) 1988

. Soil and Sludge Analytical Testing Report for the

Supplemental Sampling and Analysis Plan at BP Oil Company's Riverfront Property, Wood

River, Illinois

." November 10 .

WCC 1991

. Engineering Report, Pond 1 Landfill, Riverfront Property, Wood River (Former)

Refinery (March 22)

.

THIS FILING IS SUBMITPED ON RECYCLED PAPER