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EPA Region 5 Records etr. 1111111111111111111111111111111111111111 377544 Five-Year Review Report Second Five-Year Review Report for Amoco Chemicals (Joliet Landfill) Will County, Illinois September 2010 PREPARED BY: Illinois Environmental Protection Agency Springfield, Illinois ApPIO\'ed by: Date: cSt-&- I::h.ml C. Karl. I1irector Superflmd Di,ision US. EPA. Region 5
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Page 1: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

EPA Region 5 Records etr.

1111111111111111111111111111111111111111

377544

Five-Year Review Report

Second Five-Year Review Report for

Amoco Chemicals (Joliet Landfill) Will County, Illinois

September 2010

PREPARED BY:

Illinois Environmental Protection Agency Springfield, Illinois

ApPIO\'ed by: Date:

"~~'l()~~o' cSt-&­,.-.--~ I::h.ml C. Karl. I1irector

Superflmd Di,ision US. EPA. Region 5

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Five-Year Review Report

Table of Contents

List ofAc:ronyms____________________________________________________________________________________________________________________________ v Executi VE' Summary ___ __ _____________________ __________________ _______________ _____ _____ ___________________ ______________ _______ ____________ vii F'i ve-Year Review Summary Form_ ........................................................................................................ix [ Introduction ................................................................................................................................._...... 1 [I. Site Chronology .................................................................................................................................2

11 I.A. Physical Cllaracteristics........................................................................................................._.2

I1I.C. Initial Response ............................................................................................... _...................... _.4

[[I. I~ackground ... _............................................................................................................................ _......2

IlI.B. Land and Resources Use..........................................................................................................3

IlI.D. Basis for Taking Action...........................................................................................................5 [ V. Remedial Actions 6

IV.A. Remedy Selection, Design, and Implementation............................................................_......6 IV.B. Description of the Current Remedy ........................................................................................7 IV.C'. General Operation and Maintenance (0 & M) Requirements ..............................................9

V. Progress Since the Last Review......................................................................................................... 11 VI. Five Year Review Process.............................................................................................._................. 13

VI.A. Administrative Components.................................................................................................... 13 VLB. Community Notification and Involvement ........................................................................... 13 VI.C. Document Review .................................... _............................................................................ 14 V·I.D. Data Review............................................................................................................................. 14 VI.E. Site Inspection....................................................................................................................._.... 15 V·I.F. Interviews.. _............................................................................................................................... 15

VII. Technical Assessment.................................................................................................................... 16 VILA. Question A: Is the Remedy Functioning as Intended by the Decision Documents?......... 16 VILB. Question R: Are Exposure Assumptions, Toxicity Data, Cleanup Levels and Remedial

Action Objectives (RAOs) Used at the Time of Remedy Selection Sti11 Valid? ......I 7 VILe. Question C: Has Any Other Information Come to Light that Could Call Into Question

the Protectiveness of the Remedy? ............................................................................... 18 \'111. Issues........ _...................................................................................................................................... 19 IX. RecommendatiOJls and Follow-Up Actions.....................................................................................22 >:. Protectiveness Statement .................................................................................................................22 XI. Next Review 22

III

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Tables Table I - Chronology of Site Events Table 2 - Summary of Recommendations of Last Five-year Review and Follow-up Actions Table 3 - Issues Table 4 - Recommendations and Follow-up Actions

Attachments Attachment I - Figure I, Site Map Attachment = - Public Notice Advertisement Attachment:: - List of Documents Reviewed Attachment 4 - Photos Documenting Site Conditions

Appendices Appendix A- Property Boundary Wells Appendix B- Shallow Wells Appendix C- Sentinel Wells Appendix D- Monitoring Well Groundwater Elevations Appendix E- Comments received from Support Agencies and/or the Community (TBD) Appendix F- Institutional Control Study

IV

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List of Acronyms

AECO:\1 AOC ARARs CERCLA

CFR CQAP HDPE IEPA IPCB Facility FMl GWOU HSU LFOU NCP NPL 0&1\1 GCL PRP QA PRG QAPP RA RAO RCRA RD RVFS ROD Site SVOC TBC gpm mg/l flg/ml U.S. EPA VOC

Fonnerly RETEC, BP Amoco Technical Consultants Administrative Order on Consent Applicable or Relevant and Appropriate Requirements Comprehensive Environmental Response, Compensation and Liability Act Code of Federal Regulations Construction Quality Assurance Plan High Density Polyethylene Illinois Environmental Protection Agency Illinois Pollution Control Board Existing manufacturing facility (fonnerly BP Amoco Chemicals plant) Flexible Membrane Layer Groundwater Operable Unit Hydrostratigraphic Units Landfill Operable Unit 'l"ational Contingency Plan 'Jational Priorities List Operation and Maintenance Geosynthetic Clay Layer Potentially Responsible Party Quality Assurance Preliminary Remediation Goal, proposed in the Record of Decision Quality Assurance Project Plan Remedial Action Remedial Action Objective Resource Conservation and Recovery Act Remedial Design Remedial InvestigationlFeasibility Study Record of Decision BP Amoco Chemicals Landfill Site in Joliet, Illinois Semi-Volatile Organic Compound 'r0-Be-Considered Gallons per minute milligrams per liter (parts per million) micrograms per milliliter (parts per million) U.S. Environmental Protection Agency Volatile Organic Compound

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Executive Summary

Two operable units have been identified for the Amoco Chemicals (Joliet Landfill) Site in Joliet, Illinois (herein after referred to as the "Site"). The Landfill Operable Unit (LFOU or OUI) remedy includes: construction of a landfill cap on the North and South Landfills that conforms to the requirements of RCRA, installation of a gas venting system, installation of new leachate collection systems at the down-gradient side of the South Landfill and at two locations of historical leachate seepage on the southern end of the North Landfill, installation of surface water control measures to minimize erosion and infiltration, interim groundwater monitoring of the monitoring wdl network at the Site to assess LFOU remedy effectiveness, physical access re-strictions, and institutional controls to limit land use. Construction of the LFOU was started on May 24, :2000. As of January 23, 2001, the landfill cap was substantially completed. The other operable unit is for contaminated groundwater at the Site. The Groundwater Operable Unit (GWOU or OU 2) will be evaluated under a separate feasibility study, proposed plan, and Record of Decisic.n, yet to be issued. The triggering action date for this second five-year review is th~ date of the first five-year review which is September 29,2005.

The constructed remedy at the Landfill Operable Unit will be protective of human health and the environment in the long term upon attainment of groundwater cleanup goals. In the short term, exposure pathwa} s that could result in unacceptable risks are being controlled through institutional contwls, site access restrictions, and O&M Plan activities. However, the leachate seeps need to be expeditiously addressed so that the remedy will be protective for an intermediate period.

A site··wide protl!ctiveness determination will be made after the GWOl] remedy has been implemented. Based on groundwater flow direction, wells near the Site are not expected to be affected by the Sileo

VII

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Five-Year Review Summary Form

IX

SITE IDENTIFICATION

Amoco Chemicals

Has 'te b I t' t e se? YES 181 NO

REVIEW STATllS

r-!~~d agency: EPA 181 State _ Tribe -: Other Federal Agency

~uthor name: Eric Runkel

Author title: Eltvironmental Protection Engineer IAuthor affiliation: Illinois EPA1--­

Re"ie~ ~eriod:--- April 3, 2010 to September 2010

J~~e(s) of site inspection: August 10, 20 I 0

TYJle of review: 181 F'osl-SAR<\ - Pre-SARA NPL-Removal only

1-_ Non-NPL Remedial Action Site NPL Staterrribe-lead Regional Discretion

Review number: I (first) x 2 (second) _ 3 (third) =Other (specifY)

Triggering action: 181 t,crual RA Ons te Construction =Actual RA Start

Con.,truction Cc'mpletion - Previous Five-Year Review Report Other (specify)

Triggering action date (from WasteLAN): September 29, 2005

Du~ date (jive ye,lTS after triggering action date): September 29, 20 I 0

* ["OU" refers to oper,lble unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

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Five-Year Review Summary Form, cont'd.

Issues:

Nef·d to develop Institutional Controls Plan and Evaluate the IC Study submitted by BP Amoco

Rer'om mendatif·ns and Follow-up Actions:

Develop IC Plan Evaluate the IC Study submitted by BP Amoco to detennine whether existing implemented ins1itutional controls need to be enhanced.

Protectiveness Statement:

The remedy at the Landfill Operable Unit is expected to be protective of human health and the environment in the long tenn \lpon attainment of groundwater cleanup goals. In the short tenn, exposure pathways that could result in uracceptable risks are being controlled through institutional controls, site access restrictions, and O&M activites. However, the leachate seeps need to be expeditiously addressed so that the remedy will be protf'ctive for an intennediate period.

The ins1itutional controls that are in place include restrictive easements and covenants, and Environmental l.and Cse Covenants limiting on-site groundwater use, and limitations on the disturbam:e of the landfills and oth(~r activities that might interfere with the implemented remedy. The continued presence of Flint Hills perwnnel at the operating chemical production facility and BP Amoco personnel at the landfill area, and phy;;ical access CJnstraints provides security for the Site property.

A site-wide protectiveness detennination will be made after the GWOU remedy has been implemented.

Other Comments:

None.

Environmental Indicator Data:

Date oflast Regional review of Human Exposure Indicator (from WasteLan): 04/26/2010 Human Exposure Survey Status: Current Human Exposure Controlled Date of last Regional review of Groundwater Migration Indicator (from WasteLan): 04/26/20 I 0 Groundwater Migration Survey Status: Insufficient Dato to Detennine Contaminated Groundwater Migration Control Status. Ready tor Reuse Detennination Status (from WasteLan): Not Ready for Anticipated USI~

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Amoco Chemicals (Joliet Landfill) Site Joliet, Illinois

First Five-Year Review Report

I. Introduction

The purpose ofth~ five-year review is to determine whether the remedy at a Site is or is expected to be protective of human health and the environment. The methods, findings, and conclusions of revi.;!ws are documented in Five-Year Review reports. In addition, Five-Year Review reports identi1y issues found during the review, if any, and recommendations to address them.

The Illinois EnvirJnmental Protection Agency (Illinois EPA) is preparing this five-year review pursuant to the C(lmprehensive Environmental Response, Compensation, and Liability Act (CERCLA) § 121 :lOd the National Contingency Plan (NCP). CERCLA § 121 states:

If the President selects a remedial action (RA) that results in any hazardous substances, pollutants, 'Jr contaminants remaining at the site, the President shall review such RA no less often than each fve years after the initiation ofsuch RA to assure that human health and the enl'irOnmel't are being protected by the RA being implemented. In addition, ifupon such review it is the jud.?ment ofthe President that action is appropriate at such site in accordance with section [lOl} or [l06}, the President shall take or require such action. The President shall report to th'? Congress a list ojfacilities for which such review is required, the results ofall such reviews, and any actions taken as a result ofsuch reviews.

The U.S. EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (eFR) §300.430(f)(4)(ii) states:

If a RA is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every jive years after the initiation (If the selected RA.

The Illinois Envimnmental Protection Agency conducted a statutory, five-year review of the Site, focusing mainly on the RA for the Landfill Operable Unit implemented at the Site. Since remedial actions have not yet begun at GWOU (or OU 2), the remedy there could not be evaluated at this time. This report documents the results of the review.

This is the second five-year review for the Site. The triggering action for this review is the date of the first five-yen review which is September 29,2005

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II. Site Chronology

Table 1. Chronology of Site Events

Event Date

Waste Disposal Operations at North Landfill Approx.1958 - mid 1970s

Waste Disposal Operations at South Landfill Approx. 1973- 1975

Initial discovery ;)f contamination July 1974

Site fi nalized on National Priorities List (NPL) February 21, 1990

Consent Decree Requiring Remedial InvestigationlFeasibility April 7, 1994 Study

IIIino). s EPA and BP Amoco Chemical Company agree to split Early 1998 . the Si te into two units: Landfill Operable Unit (LFOU or OUI) and Groundwater Operable Unit (GWOU or OU2)

IIlinois EPA LFCIU Remedial Investigation completed March 25, 1998

IIIinois EPA LFCIU Focused Feasibility Study completed October 5, 1998

Record of Decision (ROD) signature for LFOU July 15, 1999

Remedial Design (RD) for LFOU complete March 16, 2000

Remedial Action Work Plan for construction of the LFOU March 20, 2000 remedyapproved

RD/RA,. Supplemental Consent Decree for the Landfill Operable April 24, 2000 Unit 1,odged

Const ruction of LFOU remedy started May 24,2000

IConstruction sub~tantially completed at LFOU January 23, 2001

1sl Five-Year Review completed September 29,2005

Force}nain completed to send leachate to POTW June 26, 2007

, 2nd Five-Year Review completed September 2010

III. Background

IIl.A Physical Characteristics

A manufacturing fi:lcility formerly owned by the BP Amoco Chemical Company ("BP Amoco") is located approximately one mile southeast of the intersection of Illinois Route 6 and Interstate H:ighway :55. It is .m active chemical manufacturing facility located on approximately 750 acres of land in a semi-rural industrial/agricultural area. In May 2004 that manufacturing facility was acquired by Flint Hills Resources ("Flint Hills") from BP Amoco.

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The manufacturing facility has been in continuous operation since approximately 1958, manufilcturing purified isophthalic acid, trimellitic anhydride, maleic anhydride, and polystyrene. The manufacturing wastes generated by the facility were contained in thin-wa11, rust away drums and disposed in two landfi11s (North and South landfi11s), which were closed in the mid 19705. The closed landfi11 areas cover approximately 26 acres (see Figure 1).

The former landfill areas, consisting of two parcels which are roughly triangular in shape, are located in the SOUl hem portion of the property. The landfi11s are located about 600 feet west and northwest of the Des Plaines River on a small bluff. Moving toward the east from the landfi11s therr is a 25-30 foot steep drop in elevation and then the land gently slopes down another 30 feet towards the River

The landfills are It)cated within an industrial use area currently zoned as "intt!nsive industrial", with adjacent farnl fields and "rural residential" land use. The landfi11s have access that is restricted and mOllitored through the manufacturing facility's security system. Access is also restricted by the south gate, which borders private property. There is a potential for site access from the river.

III.B Land and Resources Use

The contents of the landfills include approximately 5,900,000 cubic feet (218,518 cubic yards) of wastes, some in 5S-ga11on drums, including organics, inorganics, heavy metals, acids, and general plant refuse. U.S. EPA suggested in 1983 that 135,000 tons of chemical wastes were probably contained in the landfills, including plasticizers, resins, elastomers, ethers, esters, ketones, aldehydes, and inorganic chemicals (such as salts, asbestos, acids, and heavy metals.).

Specifically, BP Amoco records indicate disposal of solid wastes containing isophthalic, terephthalic, benzoic, toluic and trimellitic acids, aromatic aldehydes, cobalt and manganese acetates, cobalt, manganese, cerium, and "other metal" oxides, sodium bromide, zinc, and "other metal salts", acetic acid, "tar and high boilers", and polystyrene. Liquid slurries and "semisolid" wastes were also disposed which contained many of the above constituents as well as dimethylterephthalate, styrene, mineral oil and rubber, chromium, iron, and copper. Records also indicate that activated carbon (with associated isophthalic and terephthalic acids), construction mateJials, insulation, and general plant refuse were placed in the landfills. Solid wastes and liquid ~;lurries were reported to have low pH, in the range of 2.5 to 4.8. Because no sampling of the landfill wastes was conducted during the Remedial Investigation and because there is evidence that some hazardous wastes were disposed in the landfills, all landfill contents were assumed to be hazardous wastes, as defined by RCRA.

The nOJ1hern or mlin landfill was operated by clearing the shallow soils associated with the fonner farm land Clnd leveling the areas for disposal of wastes. No liner or clay material was placed beneath the wastes in the northern landfill. In some cases excavations or pits were used for disposal of material. Aerial photos indicate one excavation (approximately 200 feet in diameter) along the east side of the landfill appears to be over 30 feet in depth, while the water table is approximately 20 feet in depth for that area.

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In general, waste material, including drums, solids, and some liquids, were placed on the ground surface or in excavations and then covered with stockpiled dirt. The cover material for the northern landfill was excavated from the area now occupied by the southern, smaller landfill area

In 1 qn, a large pJrtion ofthe landfill was closed. This area was leveled, sloped toward the river. and covered with up to two feet of clayey soil and two feet of clay to reduce infiltration. In 1973, the smaller, southern landfill area began receiving process waste. The clayey soil which was exca"ated in this smaller triangular area was eventually used as cover material for the landfiq to the nOT1h. The bottom elevation ofthe southern landfill area (top of excavated clays) is approximately ~;even feet below the water table at the north edge. Disposal into the south landtill continued until 1975. The southern landfill was covered in the 1970s.

II I.e Initial Response

There have been several documented releases associated with the Site, dating back to July 2, 1974, when the Illinois EPA observed a reddish leachate discharging into the Des Plaines River and traced its origin to the landfill area.

Two separate leachate sources were later identified, one from the closed, the other from the then still active landfill. One ofthe sources was actually a natural stream, contaminated with seepage from the landfills. This stream contained concentrations of several contaminants in excess of Illinois effluent st.mdards for biological oxygen demand, suspended solids, iron, manganese, phenolics and dissolved solids. Elevated levels of alkalinity, chemical oxygen demand, total organic carbon, chlorides, and cobalt were also detected.

A leachate recovery system was installed by BP Amoco in March 1975. The system was designed to intercept leachate moving laterally down gradient from the bluff area toward the Des Plaines River in the shallow groundwater. The system was upgraded in 1988. Site visits during the mid-1990s indicated the leachate and groundwater was escaping containment as evidenced by iron staining at two locations on the ground surface at the south end of the collection system, and at a small stream outcrop downgradient of the collection system near the backwater area (slough area) east <Jfthe landfill.

In March 1987, the u.S. EPA scored the landfills using the hazard ranking system (HRS) and assigned the Site a score of 39.44. A facility which receives a score of28.5 or higher is a candidate for the National Priorities List (NPL). The Site was placed on the NPL under CERCLA on February 21,1990.

On April 7, 1994, .1 Consent Decree (CD) requiring a Remedial Investigation/Feasibility Study (RI/FS) was enter(d. BP Amoco initiated the RIlFS as stipulated by the CD. In early 1998, an agreement between the Illinois EPA and BP Amoco split the Site into two operable units: the Landfill Operable Unit and the other for the contaminated groundwater (Groundwater Operable Unit). This decision enabled the development of a Focused Feasibility Study (FFS) concerning only capping the landfills. Due to the dispute resolution of irreconcilable differences, the Illinois EPA exercised its-ights under the CD and relieved BP Amoco of the task of conducting the

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RifFS, The RI W,IS completed on March 25, 1998, and the FFS on October 5, 1998. Illinois EI'A completed a ROD for the landfill operable unit on July 15, 1999.

A Supplemental Consent Decree for Remedial Design/Remedial Action (RD/RA) for the Lmclfi I Operable Unit was lodged on April 24, 2000. The Remedial Design was completed on March 16. 2000. [he Remedial Design specified a cap that conforms to the requirements of RCR ,!I .. to be plac;!d on the north and south landfills, and installation of a new leachate collection syste In al(mg the down gradient side of the south landfill and at the southern end of the north land: III at tw'o loc Itions of historical leachate seepage.

Com;trlJction was started on May 24, 2000. The project suffered numerous delays due to \veather, engineerng design changes, and a labor strike which resulted in replacement of the constr'"ction contI actor. As of January 23, 2001, the landfill cap was substantially completed. The tina! construction inspection was conducted on August 23, 2001.

Thenanufacturin 5 facility north of the landfill (formerly owned by BP Amoco Chemical; sold to FllJ1t Hills Resour::es in 2004) is conducting remedial activities under the Illinois EPA Site R'~:medialion Program (SRP). The manufacturing plant portion of the facility entered into the III inois EPA Pre Notice program (now known as the SRP) officially in November of 1993, primarily in response to a xylene spill in the southeastern portion of the plant area. Groundwater data fo:" the plant area was collected in 1992, 1993 and 1994. This information was used to prepan: a Correcti ve Action Plan that was submitted to the Illinois EPA. In 1998, BP Amoco ins1:alll~d a groundwater recovery trench (GWIT) located to the east of the northern third of the north landfill. and extending north into the manufacturing plant property. The trench is not part of th~ NPL site remedy.

III.D Basis For Taking Action

The :,hallow aquit~r system beneath the Site consists of two hydrostratigraphic units; uncol1!;olidated glacial deposits (Henry formation), denoted by HSUI, and shallow limestone and dolomite bedrock formations, denoted by HSU2. Both are in hydraulic communication under portions of the landfill. HSUI has a groundwater divide on the western edge of the north lalldfill. The Uppt r portion of HSU2 beneath the Site is highly fractured with dissolution and mineralization features present at depth.

A third h:-drostrat graphic unit beneath the Site (HSU3), comprising the Scal,~s Shale or Brainard Shak J;:)Jmations, forms a regional and local aquitard between the shallow aquifer system and the deep~r bedrock aquifer. The Scales Shale is disrupted by the faulting associated with the Sandw,ch Fault Zlme in the Site area. The Sandwich fault zone strikes south~ast to northwest under the landtill. As a result of the fault, in the north portion of the Site the Scales Shale is fOl.lnJ at ~;hallow cepths (less than 50 feet) and forms the bottom of the shallow aquifer. In the south I:orl lOll of tl.e Site where the Sandwich Fault has displaced the Scales Shale, the Brainard Sllak;; found at depths of approximately 100-120 feet. The Brainard shale forms the bottom of tht~ shallc\\' aquifer in the south area of the Site.

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Below HSU3 is the regional deep aquifer referred to as the Galena-Platteville-Glenwood-St. Peter Aquifer. The manufacturing facility uses water slUppllied f,'om production wells completed in this deep aquifer.

Groundwater in the glacial deposits and shallow bedrock generally flows east toward the Des Plaines River. Currently, ther~ are seven residences using ~roundwater within one mile of the landfill. Based on groundwater flow direction, the wellls are not expected to be affected by the landfills. One additional well is located less than one mile southeast of the landfill on the opposite side of the Des Plaines River. The well appears tu he located on Stepan Chemical property.

The groundwater in HSU I and in HSU2 has been contaminated by landfill related contaminants. The depth of contamination of site groundwater below the upper-most weathered and fractured portions of the shallow limestone and dolomite formations is unknown due to lack of monitoring well data. In general, the highest concentrations of contaminants are detected directly adjacent to the landfill boundaries by monitoring wells completed within the shallow glacial deposits of HSUl.

Contaminants of concern for the Site are organic compounds of henzene, toluene, ethylbenzene, xylene, phenol, trimellitic acid. terephthalic acid, benzoic acid. isophthalic acid, phthalic acid, toluic acid, maleic acid, naphthalene. and inorganic compounds of arsenic. cadmium, lead, iron, zinc, cobalt, manganese and chromium. These contaminants have been detected in waste samples, surface soils, groundwater. leachate seep soils, swrface water, and in the leachate collection system sump at the Site. The contaminants detected at the Site are consistent with those that were documented in disposal records and spill reports for the facility.

IV. Remedial Actions

IV.A Remedy Selection, Design, and Implementation

IV.A.1 Record of Decision for Landfill Operable Unit

On July 15, 1999, the Illinois EPA signed a ROD selecting a remedy for the LFOU with the concurrence of the U.S. EPA provided on June 24, 1999. The remedial response objectives are as follows:

• Prevent the public from incidental ingestion of and direct contact with soil/waste containing contaminal ion in excess of federal and ;;tate soil standards or criteria, or which pose a threat to human health;

• Prevent the public from inhalation of airborne contaminants (from disturbed soil waste) in excess of federal and state air standards or criteria, or which pose a threat to human health: and

• Prevent the further migration of contamination frum the landfill that would result in degradation of groundwater or surface water to levels in excess of federal and state drinking water or water quality standards or criteria or which poses a threat to human health or the environment. to the extent feasible and practical.

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The m'DC'! components of the 1999 ROD included:

c' The const! uction of a RCRA compliant landfill cap conforming to th(! requirements of 35 Ill. Adm. Code 724;

C In:;tallatioll of a gas venting system; Ci I mtallation of a new leachate collection system down gradient of the southern landtill

and a new leachate collection system down gradient of the southern portion of the north landfill;

C Imtallation of surface water management features to minimize erosion and infiltration; ( Groundwater monitoring; C' Maintenarce of physical access restrictions; Ci R(!al estate deed restrictions.

rV.A.2 Sllpplemt~ntal Consent Decree For LFOU Remedial Design And Remedial Action

A Supplemental Consent Decree (,'Supplemental CD") was lodged on April 24, 2000 with BP Ame'c:1 Chemical Company. The Supplemental CD committed BP Amoco Chemical to perform tb,~ W,:ork 1S referenced in a Remedial Action Work Plan. The RA Work Plan required construction and implementation of the remedy set forth in the ROD, and achievement of the Performance Stan jards in accordance with the Supplemental CD, the ROD, the Statement of 'Nor-\. (SOW). anc as set forth in the design plans and specifications.

IV.A.J Remedial Design / Remedial Action for LFOU Remedy

On March 16. 20( 0, the Illinois EPA approved the 100% Remedial Design. The Remedial Action Work Plan was approved on March 20,2000, and construction of the LFOU remedy stm1ed on May 24. 2000.

IV.AA Groundwater Operable Unit Record of Decision

T\vo operable uni1 S have been identified at this site--one for the landfills and the other for the contan-jnated grollndwater. The groundwater operable unit, when formalized, will be evaluated uncler 5eparate dOI:uments, and will be included in the next Five Year Review due in 2015. A remedy filr the GWOU will be established by another Record of Decision to be developed and is-md bel~)re the next Five Year Review in 2015. Development ofa ROD for the GWOU will inclld~' investigat'on of groundwater monitoring data and a determination of the LFOU remedy's ef'~~c tivell'~ss in pI eventing leaching of contaminants from site waste materials into groundwater.

(':.E.. Dcscriptioll of the Current Remedy

r~:.n.ll f'inal Conr System

TIII~ Joliet Landfill cover system is comprised of the following components: a vegetative layer of Sliste med plant grt)\vth, a topsoil layer, a rooting zone layer, a drainage layer; a flexible m\~rr: braJK layer ( :;'ML); a geosynthetic clay layer (GCL); a passive gas venting system; and a

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leachate collection system upgrade for the South Landfill. In addition, seep collection tile was also installed along the bluff area to capture two areas of historical seepage.

From top to bottom, the cover system consists of the following materials and layer thicknesses:

(J Vegetation Cover; (J Topsoil (6 inches); (J Rooting Z,me (30 inches including a 12 inch protective layer); (J Geocompc.site drainage layer with geotextile; (J Flexible Membrane Liner *; (J Geocompc.site Clay Liner; (l Grading Layer, including a 6 inch bedding layer

* Geomembrane consists of 40-mil LLDPE (Linear low density polyethylem:)

IV.B.2 Storm / Surface Water Drainage

One requirement jor the LFOU remedy was implementing surface water control measures to minimize erosion lnd infiltration. Surface water drainage on the landfill cap is controlled by sloprs promoting :;heet flow towards diversion berms on the landfill cap which direct the runoff to drainage swale~ on the east side of the landfill or to the Quad Pond Area. The Quad Pond Area is adjacent tc· and directly west of the landfill. The Quad Pond Area is the location of the fonner wastewater treatment lagoons for the BP Amoco Chemical Wastewater Treatment Plant for the manufacturing facility. The Quad Ponds were removed from service and closed under the Illinois EPA Site Remediation Program (SRP). In conjunction with the landfill construction project, the Quad Ponds were regraded and a storm water retention basin was constructed in the Quad Area. The storm water detention basin has a concrete storm water outlet structure and HDPE culvert that directs the discharge to a nearby natural drainage way.

Water that infiltrates through the top soil and rooting zone layer of the landfill cap is diverted to perimeter toe draills. The toe drains have several outlets which discharge to the ground surface outside the landfill perimeter or connect to underground piping for routing to the storm water drainage system.

IV.B.3 Landfill {;as Venting System

As part of the LFOU construction, a passive landfill gas venting system was installed on the landfills. The 100% Design Report characterized the landfill site as having minimal potential for generating landfill gas. The purpose of the gas venting system is to provide effective landfill gas migration control and to prevent physical disruption oflandfill cover components resulting from gas migration. A Iletwork of gas vents was installed at a grid density of approximately one vent per acre. Existing landfill piezometers were converted to gas probes, and some new probes were installed to monitor for gas build up and lateral migration under the cover.

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IV.BA Leachate Collection System

The leachate collection system pumps collected leachate to the offsite POTW wastewater treatment plant (onerated by the City of Joliet). The original leachate collection system was installed by BP Amoco around the mid 1970s, and was upgraded to expand the leachate collection piping in the south landfill, abandon and replace the collection sumps in the south landfill with a nevI leachate pump station (EO-307 pump station), and replace old forcemain and c1ean-cl uts with new double walled-transfer pipe and forcemain. The work also included installation of a gJavity seep collection system along the forcemain trench, as well as extension up the ;;lope of tht' bluff on the east side of the landfill to two areas where surficial seeps have occurred. The gravity line drains to the groundwater interceptor trench (GWIT) system, thence to the on-site wastewater treatment plant. Clean-out structures were installed along both the gravity and forcemain lines to allow for maintenance of the system.

IV.C General Operation and Maintenance (O&M) Requirements

IV.C.1 Landfill Cover System

The Illinois EPA has conducted periodic Site visits to observe Site conditions including the land1ill cover syskm. The most recent Site inspection by !EPA was on August 10, 2010. Pt:rimeter gates and locks were intact and access was being restricted. The condition of the south land1ill cover and slopes was good. At the north landfill, an area where gully erosion was noted at the south storm water diversion dike on previous visits had been repaired with placement of additional soil to redirect the flow along the dike. The storm water detention basin was discharging approximately 50-100 gpm through the orifice at the outlet structure with no unusual conditions noted at the outfall. The storm water drainage ditch along the east side of the north landfill ("East Ditch"), and the drainage swale along the east side ofthe south landfill were dry, with the riprap in the East Ditch in good condition and both drainage ditch outlets normal. The toe drain outlets for the south landfill and the outlets on the west and northeast side of the north landfill were ponded with no unusual conditions noted.

At the south landfill leachate collection manhole, contributing flows into the manhole were noted as follows: the shallowest collection pipe discharge from the south was dry with no flow. The middle collection pipe from the north had a trickle of flow discharging to the manhole. The deep collection pipe from the west, which is the old existing leachate collection pipe that pre-dates the landfill cap projec':, was discharging approximately 12 gpm to the leachate collection manhole. The leachate colledion system manhole drains through approximately 100 feet of double-walled gravity pipe to the leachate collection system pump station designated as EO-307. Two areas along the bluft: where gravity seep collection pipe was installed at the locations ofhistorical leachaTe seepage, were found to be dry at the ground surface. The gravity see:p collection pipe was oDsen'ed to be discharging approximately 10 gpm to the OWIT system.

Periodic inspections should continue to monitor the condition of the landfill cover system at the north and south landfills. Inspections should assess the condition of vegetation, perimeter slopes, riprap, toe drain outlets, Quad Pond area, East Ditch and south landfill storm water drainage

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dttches, triangle area structures and pipes, south landfill leachate collection system, and gravity seep collection system in two areas along the bluff of historical leachate seepage. Any evidence of erosion, tension cracks or cover soil instability, or damage from burrowing animals should be noted for future repair. In addition, if depressed areas on the landfill cover system that may pond water develop, they should be noted for future repair. The condition of the toe drain outlets should be observed and any necessary follow-up action taken. The bluff area should be inspl~cled at the t\'vO locations of historical leachate seepage to verify the gravity seep collection pipe is preventing the seeps from occurring. The bluff area should be checked for the presence of any additional areas of seepage that were not addressed under the landfill cap project. The SO W (Section 1.2.7) states that the surficial seeps should be eliminated as a result of the installation of the new cap and leachate collection system. However, ifleachate seeps persist after the completion of the remedial action, under the 0 & M phase of the project, necessary steps will be taken to characterize the nature and extent of the seepage and remedial actions that will curtail the seepage. During the August 10,2010 Five Year Inspection, additional areas of leachate seepage were noted (see Attachment 4).

IV.C.2 Landfill Gas Collection System

The SOW require~j the quality of gas emitted from the gas venting system to be monitored semi­annually for a period of two years. If deemed necessary to protect human health and the environment, an active gas collection and treatment system wiIl be designed and implemented. The data has been collected and results indicate no impact to off-site receptors.

IV.C.3 Interim Ground Water Monitoring

Following completion of construction of the landfill cap, the project entered the interim groundwater monitoring period with groundwater monitoring performed on a quarterly basis to assess the effectiveness of the landfill cap. The Illinois EPA and its contractor, Camp Dresser & McKee (CDM), have performed quality assurance oversight during the quarterly ground water sampling events. The interim groundwater monitoring program was approved by Illinois EPA on November 9, 2001, and some new groundwater monitoring wells and piezometers were installed in November and December 2001. The interim groundwater monitoring was initiated in December 2001. Groundwater monitoring frequency was altered from monthly to quarterly in 2009.

IV.C.4 Institutional Controls

Institutional controls (lCs) are non-engineered instruments, such as administrative and legal controls that help to minimize the potential for exposure to contamination and that protect the integrity of the remedy. ICs are required to assure the long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure. ICs are also n:quired to maintain the int~:grity of the remedy. The 1999 ROD for the LFOU required that ICs would be impkmented "to include prohibition of on-site groundwater use, on-site building constl1lction, and on-site drilling except for the purpose of remedial design,sampling, monitoring, and remedial action."

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Table 1 - Institutional Controls Summary Table Media, Engineered

Controls & Areas that Do Not Support llUIUE

Based 0 n Current Conditions

Lmdfill ("Burdened Pmperty'"), including

~roundwater

IC Objective

-Prohibit the installation of groundwater wells for the purpose of producing potable water, and;

-Prohibit the use, improvement or maintenance for any type of residential or commercial purposes, and;

IC Instrument Implemented (planned)

Two separate Environmental Land Use Controls; one on the original landfill parcel; the other on the property transf(!rred to Flint Hills

I I

Grou ndwater i Prohibit the installation of groundwater wells Two separate Environmental I for any purposes except for groundwater Land Use Controls; one on

monitoring or remediation activities. I the original landfill parcel; the other on the property

I transfc;,rred to Flmt Hills

An Ie Study was prepared by BP Amoco. The IC Study contained a recent title commitment showing proprietary controls, and current deed restrictions (See Appendix F). Illinois EPA will evaluate BP's IC Study to detennine whether it needs to be supplemented, and whether the institutional controls which are shown for the site will be protective in the long run.

V. Progress Since the Last Review

This is the second five-year review for this Site. The last five-year review was completed in September 29,2005. The protectiveness statement from the previous five-year review stated the following:

The constructed remedy at the Landfill Operable Unit is expected to be protective of human health and the environment upon attainment ofgroundwater cleanup goals. In the interim. exposure pathways that could result in unacceptable risks are being controlled through instilUt;onal controls (believed to be implemented), site access restrictions, and maintenance of the lan4fill cap. Ihe institutional controls at the LFOU will be further evaluated for their current effectiveness, and their ability to protect against exposure to contaminants over time.

A site-widt protectiveness determination will be made: after necessary steps are taken to charl7Cter;ze the nature and extent ofrecent leachate seepage, after remedial alternatives are implemented to curtail seepage and address any resultant contaminated soil, and after the GWOL' remedy has been implemented. Based on groundwater flow direction, wells near the Site are Yo 0.' expected to be affected by the Site.

The last five-year review indentified a number of critical issues and provided a number of recommendations. The following table lists those recommendations along with the responses.

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Table 2. Summary of Recommendations of Last Five-year Review and Follow-up Actions

Issue

1. Site Documents and Records

2. Access roads

3. Grass Cover

4. Landfill surface

5. Landfill surface

6. Leachate Seepage Collection System

Recommendations and Follow-up Actions

Collect and maintain referenced records on-site in such a manner as they are readily available for inspection by Illinois EPA at all reasonable times.

Repair ruts on access roads and maintain the roads.

Mow the ·Iandfill cap at a minimum on an annual basis.

Continued observation of deer tracks, small areas of slightly sparse vegetation on the southeast and southwest corners of the north landfill and along the northeast corner of the north landfill, take corrective actions as necessary.

Collect settlement monument survey data as part of the Site 0 & M.

Address changes made to the leachate seepage collection system, if necessary, and

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Status

On-going

Completed on as needed

basis

Completed Annually

Semi-annual inspections and

as needed

Completed per O&M Plan; in May 2009, BP

agreed to continue

surveying every 3 years for continued

compliance

Completed

Comments

BP maintains copies of the HASP, O&M Manual, and other relevant field documents in a site trailer. Because there is not a permanent structure or staff onsite, all project records are maintained in their consultant's office located in Warrenville, IL. BP is in the process of creating CDs of important Site documents to keep at a local library and make available at the Site trailer.

Repairs were performed during construction of the conveyance line; road conditions are monitored during Site activities and semiannual inspections. Minor repairs are completed as warranted.

The landfill cap is mowed annually, during the fall.

The landfill surface is inspected during semiannual inspections; ruts along the northeastern portion of the landfill created by deer were repaired in June 2009. Issues identified during the April 2010 inspection are being monitored, and any repairs will be completed by September 2010.

The O&M Plan required this only for the first 2 years after construction provided settling was not observed; no settling was observed so surveying was discontinued between 2003 and 2008. Following a May 2009 meeting with IEPA, settlement surveying was completed.

Changes to the system were made during construction of the conveyance line, and a

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7. Leachate Seepa~le

8. Perimeter Ditche~;

9. Groundwater mO'1itoring

10. Groundwater Monitoring

VI. Fh·e-Year Review Process

implement an approved contingency plan to prevent surcharge conditions from occurring in the future.

Take necessary steps to characterize the nature and extent of the seepage and remedial alternatives that will curtail the seepage.

Monitor area of erosion on the East Ditch; take corrective actions as necessary.

Provide locks for PZ-13, 14, 15, 16, 17, secure cap on PZ-17.

Continue until sufficient data has been collected to determine the effectiveness of the landfill operable unit remedy.

Initial Sampling and Analysis

Plan submitted 2005

Semi-annual inspections and

as needed

Completed

Quarterly sampling was

continued through 2008;

currently performing semiannual

sampling

contingency plan has been included in the Draft O&M Plan Addendum submitted in April 2010.

Grab samples were collected from two seeps along the North Landfill in March 2009. Additional sampling will be conducted as part of the 2010 Remedial Investigation.

See item 4

All wells have locking caps and are secured by locks. Problems with wells are identified during each sampling event and subsequently addressed.

IEPA provided verbal approval in August 2008 for modification from quarterly to semiannual sampling schedule; semiannual sampling began with the March 2009 sampling event, and sampling is now scheduled for April and October of each year.

VI.A. Administrative Components

The Illinois EPA is the lead agency for this five-year review. The support agency is the U.S.EPA. The U.S. EPA and BP Amoco were notified in mid 2010 of the five-year review.

Camp, Dresser & McKee, as contractor to the Illinois EPA, performed most of the tasks required for the review. The review consisted ofthe following components:

• Community Notification and Involvement • Document Review • Data Revi(w • Site Inspection • Fi\"e-Year Review Report Development and Review

VI. B. Community Notification and Involvement

A notice was published in the Joliet Herald News on July 23, 2010 and the Channahon Weekly on JlIly 29, 2010, :;tating that a five-year review was being conducted. The notice invited the public 1:0 submit cmnments to the Illinois EPA by August 31, 2010. Comments from the

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community were received by the Illinois EPA or U.S. EPA and responses provided (see Appendix E). The results of the review and this Five-Year Review Report will be placed in the Site repository located at the Three Rivers Public Library, 25207 West Channon Drive, Chalmahon, Illinois, or the Illinois EPA Headquarters, 1021 North Grand Avenue East, Springfield, Illinois. A copy of the published notices can be found as Attachment 2.

VI.c. Document Review

The list of the documents that were reviewed for this five-year review can bt: found in Attachment 3.

VI.D. Data Review

The primary objective of the LFOU remedy is to control the landfills as a source of continuing groundwater contamination by reducing the infiltration of rainfall and reducing the quantity of leachate migrating from the Site. A quarterly groundwater monitoring program has been in place since implementalion of the remedy and provides the data utilized in this analysis. The overall objective of the five-year review process is to evaluate if the remedy, as implemented, is or will be protective of human health and the environment. The guidance document for the five-year review process (U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, June 2001, Comprehensive Five-Year Review Guidance, OSWER No. 9355.7-03B-P, EPA 540-R-OI-007) indicates that this evaluation is based on the risk range and hazard index. This review focuses on using Site monitoring data to determine if the remedy has had an impact 011 either groundv. ater levels or groundwater quality. Ideally, if the remedy is meeting its stated intention in the ROD, recharge through the waste materials should decrease since a multilayer ReM cap was installed. Likewise, under ideal circumstances, a decrease in concentrations of Site contaminants at downgradient monitoring wells should be observed at some point after remedy implementation. It should be noted that the remedy did not include a liner or other means of limiting recharge from leachate that may have been present in the waste, or areas where the waste may be within the saturated zone. Natural systems also may require significant time to equilibrate with changes in conditions, such as a change in the recharge rate. Variability in rainfall will also impact the response of the system to the remedy implementation. During the five year period since the year 2005, precipitation has been variable.

The groundwater ~;ystem at the Site consists of an upper unit comprised of saturated, unconsolidated material and shallow weathered bedrock (HSU1), underlain by deeper fractured bedrock (HSU2). Several wells at the Site monitor a transition zone between the major hydrostratigraphic units. The landfill is located on an upland area and waste may be in contact with the upper aquifer unit in some locations. Hydrographs of water level elevation over time, indicate that seasonal factors are important at the Site and must be considered in evaluating the eflectiveness of the remedy. The hydrographs were examined to qualitatively assess trends. The contaminants of concern at the Site include organic acids, volatile organic compounds and metals. Metals are detected at many of the wells, especially iron and manganese, likely due to the highly reducing environment that has developed due to the landfill leachate. VOCs are sporadically detected at the Site, though below action levels. Benzene, chlorobenzene, toluene and xylene have been detected in several samples during the past five years at low levels.

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Based on analysis of monitoring data at the Site, it is difficult to definitively state that the remedy is meeting its objective of protection of human health and the environment. Once the GWOU is implemented conditions at the LFOU should significantly improve to meet objectives of protectiveness. Organic acids at concentrations that exceed comparison values are present outside of the landfill. However, this may be due to continued drainage ofleachate from the waste, or groundwater levels rising into the waste materials, rather than failure of the capping or leachate collection systems.

VI.K Site Inspection

A Site inspection was completed on August 10,2010. Participants and affiliations were as follows:

Lori Littrell BP Amoco BP representative John Frankenthal BP Amoco BP representative Randy McKay AECOM BP's technical consultant Bob Carson Illinois EPA NPL Unit (Unit Manger) Eric Runkel Illinois EPA NPL Unit (Project Manager) Giang-Van Nguyen U.S.EPA Project Manager Shawn Schipper CDM Project Manager

The inspection was conducted according to the checklist provided in Appendix D of the Comprehensive Five-Year Guidance provided by the U.S. EPA.

After the review of the checklist was complete, the attendees performed a walkover of each land1ill. The landfills were checked to visually observe that they were operating as designed and to check for previously unseen problems. Pictures were taken by CDM that would aid in the description ofthe landfill conditions in this report (see Attachment 4).

The landfill covers were inspected for low areas and areas of stressed or different ground cover to detelmine if landfill settlement had occurred since installation of the landfill cap. There was no evidence of significant settlement observed. However, due to large amounts of vegetation lying on the ground, small changes in elevation or settlement were not detectable. There was no evidence of wet areas or water damage observed on the landfill covers. The covers did show signs of deer activity as evidenced by several deer tracks running across the landfill. Several items identified in the inspection report (listed under Section VIII) warrant further follow-up.

VI.F. Interviews

From 1999 to 200 I, during the design and construction of the remedy, the community surrounding the Site was given opportunity to provide input into development of the remedy and express any concerns or questions about the Site. Since the achievement of the last construction completion at LFOU in 2001, there have been no major problems communicated to the regulatory agencies by the community. The need has not arisen for any community involvement events and the proximity of the Illinois EPA's offices to the Site facilitates th{! agency's

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-----

availability. Therefore, it was determined that no formal interviews with the community were necessary for this five-year review. No formal interviews with the U.S. EPA or BP Amoco were performed for thi~, five-year review.

VlI. Technical Assessment

VlI. A Question A: Is The Remedy Functioning As Intended By The Dedsion Documents?

Remedial Action Performance The review of documents, ARARs, risk assumptions, and the results of the Site inspection indicate that the remedy is not functioning as intended by the ROD. There is a continuing problem of leachate seeps from the landfill which were noted in the first five-year review in 2005. concentrations of organic acids in excess of comparion values are present outside of the landfill and additi.)nal area ofleachate seepage were noted during the August 10, 2010 Five Year Inspection.

S\stc...!ni2neration5/0&M Based on periodic Site visits and the August 10, 2010 Five Year Review Inspection, the landfill cover system and gas venting system are generally functioning as intended by the ROD and other decision documents. As a result, no significant future modifications are recommended for the land1ill cover system or gas venting system at this time. The plans to address the concerns noted regarding the leachate seepage are discussed below.

Qpportunities for Optimization Leachate seeps, as noted in the August 10,2010 Five Year Inspection Report, will be addressed through necessary steps to characterize the nature and extent of seepage and through remedial alternatives to curtail the seepage. BP Amoco changed the leachate seepage collection system with review, approval, or oversight by the Illinois EPA. BP Amoco provided construction reports in several submittals; the most recent is dated June 2010. These are currently under review by the Illinois EPA. This leachate seepage collection issue affects CUlTent and future protectiveness of the LFOU remedy and warrants continued follow-up.

Irrmlementation of Institutional Controls and Other Measures The institutional c.)ntrols that have been recorded in property records include Environmental Land Use Covenants limiting on-site groundwater use, and limitations on the disturbance of the landfills and other activities that might interfere with the implemented remedy. In September 2010, BP Amoco submitted an institutional controls study to Illinois EPA which included a CUlTent title commitment for the Site, a summary of proprietary controls such as easements, covenants, and/or~eversionary interests currently assigned to the land, and a summary of any local ordinances or property zoning applicable to the Site property. Illinois EPA will evaluate the infiJrmation provided by BP Amoco to determine whether the existing institutional controls are sufficient for long-term protectiveness for the Site, and if necessary, develop an IC plan to enhance existing Ie controls. Based upon the August 10, 2010 Site Inspection, no evidence was observed that suggested that there was any land or resource use which is inconsistent with the remedial action objectives.

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The re-use initiative is a consideration for this Site. Future decisions regarding re-use ofthe Site will consider the requirement for the remedy to remain protective of human health and the enviromnent. However, because the site property is privately owned and is currently subject to land use restrictio 1S, and because a Record of Decision has not been developed or issued for the GWOU, it is likely that re-use of the Site property will not be implemented before the next Five Year Review in 20] 5. Residential development on this Site is not consistent with current or projt'cted land use patterns.

Inl~im Monitoring Interim monitoring of the monitoring well network has been performed quarterly since Dectmber 200 I under the supervision of Camp, Dresser & McKee, as oversight contractor for the Illinois EPA. Based on analysis of monitoring data at the Site, it is difficult to definitively state that the remedy is meeting its objective of protection of human health and the environment becam.e a final groundwater remedy still needs to be finalized. Concentrations of organic acids in excess of comp:lrison values are present outside of the landfill. However, this may be due to continued drainag;: ofleachate from the waste or from groundwater rising into the waste materials, and not due to failure of the capping or leachate collection systems.

Two operable units have been identified at this Site--one for the landfills and the other for the contaminated groundwater. The assessment included in this document focuses on the landfill operable unit. A remedy for the GWOU will be established by another Record of Decision. Development of a ROD for the GWOU will include investigation of groundwater monitoring data and a determination of the LFOU remedy'S effectiveness in preventing Site waste materials from leaching contaminants into groundwater.

VII.B Question 8: Are The Exposure Assumptions, Toxicity Data, Cleanup Levels, And Rem(~dial Action Objectives (RAOs) Used At The Time Of Remedy Selection Still Valid?

There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy.

Cbang~s in Standards and To-Be-Considereds (TBCs) There have been no changes in ARARs for groundwater cited in the ROD and no new standards or TBCs affecting the protectiveness of the remedy.

Cbang~s in Exposure Pathways, Toxicity, and Other Contaminant Characteristics The exposure assumptions used to develop the Human Health Risk Assessment included both CUlTent exposures :md potential future exposures for ingestion of contaminated groundwater, dennal contact with contaminated groundwater, inhalation of volatile contaminants during domestic use of groundwater, incidental ingestion of contaminated surface water in seeps and the Des Plaines River, and incidental ingestion of sediment in seeps and the Des Plaines River. There have been no changes in the toxicity factors for the contaminants of concern that could affect the protecti\'eness of the remedy. These assumptions are considered to be conservative and reasonable in '~valuating risk, and no changes are warranted.

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Physical controls (such as site access control, fencing, security locks and site security) have already been implemented and have eliminated exposure pathways at the Site. Environmental Lal1Cl Use Covenants have already been implemented, although their current and future effectiveness needs to be evaluated. These measures signify that the LFOU remedy remains protective of humm health and the environment in the short term, although additional measure to ensure long-term protectiveness and stewardship will need to be implemented.

CDan..g~s in Risk Assessment Methods There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.

E~ill'~led Progres~. Towards Meeting RAOs No fiJrmal estimates for the time requirement to achieve for remedy objectives have been made. For this Site is it assumed that remedy objectives will be obtained in not more than 30 years from the date of the completion of remedy construction.

VILe Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

As indicated in the ROD, the Baseline Risk Assessment concludes that for protection of ecological resources, control of: (1) Site runoff, (2) leachate discharges to the surface (via leachate seeps), (3) sediment transport to the Des Plaines River and its associated backwaters, and (4) groundwater discharges to surface water bodies are most critical. Potential sediment­related impacts to the Des Plaines River will be assessed in a forthcoming supplemental Ec:ological Risk Assessment.

Based on analysis of monitoring data at the Site, it is difficult to definitively state that the remedy is meeting its objective of protection of human health and the environment b,xause a final groundwater remedy has not yet been implemented. Organic acids at concentrations that exceed comparison values are present outside of the landfill. However, this may be due to continued drainage of leachate from the waste, or groundwater levels rising into the waste materials, rather than failure of the capping or leachate collection systems. The LFOU remedy is expected to be protective when is'mes listed in Section VIII are satisfactorily addressed on an expedited timeframe. A Record of Decision establishing a remedy for the GWOU will be issued before the next Five Year Review in 2015. In the interim, exposure pathways are being controlled through Site security, access controls and through the notice provided by the Enviromnental Land Use Covenants. although institutional controls will be the subject of follow-up activities.

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VIII. Issues

Table 3. Issues

Issues Affects Current Protectiveness

(YIN)

Affects Future Protectiveness

(YIN)

"'Jeed to develop Institutional Controls Plan and Evaluate the IC Study submitted by BP Amoco

N Y

A.) Based on CDM discussions with Retec and BP Amoco during the August 10,2010 inspection, O&M :iocuments are not kept on-site. The O&M documents that were previously maintained at the BP Amoco manufacturing facility (now owned by Flint Hills Resources), are currently available through Conestoga-Rovers and Associates, technical consultant for BP Amoco.

B.) The Site Specific Health and Safety Plan and Contingency/Emergency Response Plan is rep0l1edly kept on site, and reviewed at the time of the August 10,2010 inspection.

C. ) The 0 & M and safety training records were not available.

D.) Permits and Service Agreements including the air discharge permit and l(!achate discharge service agreement were not available on-site. Based on COM discussions with BP Amoco, the landfill gas vents were included under the air discharge permit for the former BP Amoco manufacturing facility; the permit will need to be changed. The leachate collection system currently discharges into a sewer connection to the City of Joliet Publicly Owned Treatment Works. BP Amoco has obtained all necessary permits and approvals from the Illinois EPA and others as appropriate.

E.) Leachate extraction records for the leachate collection system were reviewed.

F.) Discharge compliance records for the air permit and leachate discharge service agreement were not available. This information was previously available at the former BP Amoco manufacturing facility, now owned by Flint Hills Resources.

G.) Illinois EPA will review the institutional contol study submitted by BP Amoco in September 2010 to detemline if additional information is needed, and to determine ifthe existing ICs which are in place at the Site, the Environmental Land Use Covenants, will need to be enhanced.

In summary, the Illinois EPA has requested BP Amoco, within a 30 day timeframe or longer if agreed to by Illinois EPA, to collect and maintain the above referenced records on-site in such a maimer as they aT(' readily available for inspection by Illinois EPA at all reasonable times. The Supplemental Consent Decree requires BP Amoco to provide information relating to activities at the Site, et alia, upon request by the State.

19

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2,_ General Site Conditions.

A.) During the August 10, 2010 inspection, the access roads along the perimeter of the north and south landfills and in the lower portion of the Site to the east of the bluff area were found to be in good condition. HP Amoco and AECOM had indicated the roads were repaired recently.

A.) During the August 10,2010 inspection, the north and south landfill areas were inspected for low areas and areas of stressed or different ground cover to determine if landfill settlement had occurred since installation of the landfill cap. There was no evidence of significant settlement observed.

B.) There are several deer tracks running across the landfill and evidence of deer inhabitation. These tracks are areas of reduced vegetation and slight depressions that warrant continued observation. In addition to the deer tracks, small areas of slightly sparse vegetation were observed on the southeast and southwest comers of the north landfill and along the northeast corner of the north landfill. These areas warrant continued observation.

c. )Based on CDM discussions with BP Amoco, landfill settlement monitoring has not been conducted. BP Amoco will be directed to collect settlement monument survey data as part of the Site's 0 & M .

.1:.._Leachate Seepage.

A..l During 2010, BP Amoco made some changes to the leachate seepage collection system with the review. appro\ aI, and oversight by the Illinois EPA.

B.) During the August 10,2010 Site inspection, several seeps, wet areas, and areas ofponding to the east of the land fill below the bluff were observed. The most significant area of concern was the drainage ditch along the lower access road which had staining on the rip rap and discoloration of the water in the ditch. This discoloration appeared to originate at seeps located along the slope of the bluff which borders the north landfill. Several other areas to the south showed evidence (If staining on the soil and discolored seepage water along the bluff which borders the landfilis. The Illinois EPA will direct BP Amoco to investigate these areas and provide appropriat~ remedial alternatives to curtail the seepage. This finding affects current and future protectiveness of the remedy, and warrants continued follow-up.

5. Pe.I!!neter ditch,.!s.

No erosion was observed for the North landfill. Areas warrant continued obsl;!rvation, and will be addressed by BP Amoco as part of the required continuous O&M activity for the LFOU remedy.

20

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6. Groundwater Monitoring.

A.) Quarterly groundwater monitoring, at a minimum, has been conducted since the completion of the landfill cap in Summer 2005. At this time it is difficult to determine whether the LFOU remfdy has had a significant impact on groundwater contamination. Water levels and contaminant conc(~ntrations have varied significantly and contaminant concentrations have exceeded the proposed remediation goals in monitoring wells downgradient of the landfill. QUaJ1erly groundwater monitoring should be conducted until sufficient data has been collected to detelmine the effectiveness of the remedy. The groundwater operable unit will be evaluated under separate documents and will be included in the next Five Year Review, due in 2015. A remedy for the GWOU will be established by another Record of Decision, to be developed and issued before the next Five Year Review in 2015. Development ofa ROD for the GWOU will include investigation of groundwater monitoring data and a determination of the LFOU remedy's effectiveness in pleventing leaching of contaminants from site waste materials into groundwater.

7. £;'~~l.Qgical Risk Assessment.

The Illinois EPA is working with BP Amoco to determine if the landfills have impacted the sediment in a badwater slough area of the Des Plaines River. Potential sediment-related impacts to the De~. Plaines River from the Site will be assessed in a forthcoming supplemental Ecological Risk Assessment.

8. Groundwater Operable Unit Record of Decision.

The GWOU will be evaluated under separate documents and a remedy selected and implemented before the next Five Year Review due in 2015. A remedy for the GWOU will be established by another Record of Decision. Development of a ROD for the GWOU will include investigation of groundwater monitoring data and a determination of the LFOU remedy's effectiveness in preventing site waste materials from leaching contaminants into groundwater.

21

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IX. Recommendations and Follow-up Actions

TubJe 4. Recommendations and Follow-up Actions

-Affects Protectiveness

Recommendations and Party Oversight Milestone (YIN)Is!>ue Follow-up Actions Responsible Agency Date

Current Future --Develop Ie Plan~'Ieed to develop BPAmoco IEPA and December N Y

Institutional U.S. EPA 2010 Controb Plan and

-Evaluate the IeEvaluate the Ie

IEPAStudy submitted by December y:,tudy submitted by NBPAmocoto 2010FP Amoco determine whether {'xisting implemented institutional (ontrois need to be E·nhanced .

.::::

x. Protectiveness Statement

The remedy at the Landfill Operable Unit is expected to be protective of human health and the environment in the long term upon attainment of groundwater cleanup goals. In the short term, exposure pathways that could result in unacceptable risks are being controlled through institutional controls, site access restrictions, and O&M activities. However, the leachate seeps need to be expeditiously addressed so that the remedy will be protective for an intermediate period.

The institutional c,)ntrols that are in place include restrictive easements and covenants, and Environmental Land Use Covenants limiting on-site groundwater use, and limitations on the disturbance of the landfills and other activities that might interfere with the implemented remedy. The continued pre~,ence of Flint Hills personnel at the operating chemical production facility and BP Amoco personnel at the landfill area, and physical access constraints provides security for the site property.

A site-wide protectiveness determination will be made after the GWOU remedy has been implemented.

XI. Next Revi(~w

The next five-year review for the Site is required by September 2015, five years from the approval signature date of this report.

22

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ATTACHMENTS

Page 34: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

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Figure 1 SITE MAP

BP Amoco Joliet Landfill SlteIJoilet, IL 19780000011W111County

Page 35: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

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AUG-17-2010 09:17 FROM: TO: 2177857725

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Attachment 3

List of Documents Reviewed

1. Supplemental Consent Decree for Remedial Design and Remedial Action, People of the State of Illinois vs. BP Amoco Chemical Company, U.S. District Court for the Northern District of Illinois, Eastern Division, Civil Action 94-C-0869.

2. Record of Decision for Amoco Chemicals (Joliet Landfill) Superfund Site, Landfill Operable Unit, July 15, 1999.

3. Final (100%) Design Report, BP Amoco Joliet Landfill Superfund Site, Joliet Illinois, CRA, June 1999.

4. Remedial Action Work Plan (RA WP), BP Amoco Joliet Landfill Superfund Site, Joliet Illinois, as amended, CRA July 1999.

5. Statement of Work for BP Amoco Chemicals (Joliet Landfill) Superfund Site, Landfill Operable Unit, May 24, 2000.

6. Five Year Review, Landfill Inspection and Groundwater Impacts, COM, August 19,2005. 7. Five Year Review Report, BP Amoco Chemicals (Joliet Landfill) Superfund Site, Illinois EPA, September 29,2005.

8. Groundwater Monitoring Results, 2nd Semiannual Round of Interim Post-Closure Monitoring, AECOM, February 5, 2010.

9. AECOM Monthly progress report on behalf of BP Amoco for the BP Amoco Chemicals (Joliet Landfill), May 2010

10. Correspondence, Illinois EPA to BP Amoco, Request for Institutional Control Study, July 1, 2010.

11. Correspondence, Illinois EPA to U .S.EPA, Notification of Five Year Review Start, July 1, 2010.

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Attachment 4

Photograph #1 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: Project documents available in on-site trailer.

Photograph #2 Photographed by: Shawn Shiffer Date: August 10, 2010

Page 39: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

Description : EG308 Collection Vault

Photograph #3 Photographed by: Shawn Shiffer Date: August 10, 2010

Description : EG308 Collection vault and transfer system to Joliet POTW. - Facing West.

Photograph #4 Photographed by: Shawn Shiffer Date: August 10, 2010

Page 40: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

Description: Seep 2 - Some staining along drainage ditch- Facing West.

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Photograph #5 Photographed by: Shawn Shiffer Date: August 10, 2010 ~n;g:~m

Description: Seep 2 - Staining along drainage ditch - Facing West.

Photograph #6 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: Monitoring well MW-63R-94 - Facing East.

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Photograph #7 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: Quad Pond Drainage Outfall- Facing South.

Photograph #8 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: Site Maintenance- Mowing to access to monitoring wells West side of North Landfill- Facing

West.

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Photograph #9 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: West side of the North landfill facing South.

Photograph #10 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: East side of landfills facing South - Current road conditions.

Page 44: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

Photograph #11 Photographed by: Shawn Shiffer Date: August 10, 2010

Description: EG308 Collection Vault and transfer system to Joliet POTW. - Facing East from North landfill.

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APPENDICES

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APPENDIX A

PROPERTY BOUNDARY WELLS

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3

2

Phthalic Acid and Groundwater Trends for MW-63R-94 (Property Boundary)

10 r----------------------,---------------------------------------------, Landlil CAP Cer1ified: Augaist 200 1

II

8

7 ~----------------~~--------------------------------------~

o ~~._-=~~__~~~~~~~~~~~~._~~~~~~~~~~~__ 5I!lIDII 3121109/1II1II 6I28J99 4l231OO 2117101 12114101 1011D1D2 8IMl3 1111104 3128105 1l22106 11118106 9/141D7 711008

S"""fIIing EVBIl

[ --- 1'NtIac~ - Companscn va. -..-GIIt ~

545

543

541

539=• 537 !:.

535' j• iii

533~ JI ~

531 1

52Il

527

525

8I1tlJ2010

Page 48: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

lsophthalic Acid and Groundw ter Trends for MW-65-89 (Property Boundary)

10~---------------------------------------r------------------------------, ~

Lardill CAP Certified: AavASl200l

g 533

8 531

7 ~--------------------------------------~------------------------------~ ~~

3

2

o

517

2111114 4l21li5 5131~ 7fYlNT 111281118 11127/Q11 112Mll 3/26102 5I25IIl3 7123104 11121105 11I20I0II 1/19/08 3/1lI/0II

S~EwN

--,-___ ~ ;alIR GN~rL.__I5ophINIicAcid· _ -__--'-__V_ __

MW-65-81UI610..xls 811012010

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Phthalic Acid and Groundwater Trends for MW-65-89 (Property Boundary)

10 r----------------------------------------,-------------------------------, 5~ undfill CAP Certified:

II Al9JSl2001 --....

8 531

7 -1---------------------+----------------1 520~ ~

5'Z1 !;.

,.j 525 ,

iU

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JI 3 521 i

5111

517

2

o 515

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SM1pIing EYenI

[ __ f'hIh;aic~ - eo......risCln v;;- .......GWEIe¥ation I

MW-8!HHL0510.m 811Dr.!010

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lsophlbalic Acid and Groundwater Trends for MW-66-89 (Property Boundary)

10 .------------------------,-----------------------------------------------, 5~

9

8 521

1

3

2 · . 5IJ9

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S~nuEyent

___ lsoph*alicAcid -Comp~Value ~GWEJevaIion I

MW-e6-S1UI510.xfs 811012010

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Phthalic Acid nd Groundwater Trends for MW-66-89 (Pmperty Boundary)

lD 525

~

8

7

~ 6 E

5 5

~ 4

3

523

521

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515 ~ .II w..

513~

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$""'fIIing Event

L__PhINIicXld - eo.......nson v.... -'-GW ~

MW-66·8~L0510" 811012010

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lsophthafic Acid and Groundwilter Trends for MW-67 -89 (Property Boundary)

10 525

II

8

7 ­

i , S

6

Ii 5, S4

3

2

!i23

521

5111.

i 517~

15 ~

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507

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SiiImJ>ing Event

r-tl- lsophihalicAcid - C<lmpaIson Viii.., ....... GW EIe¥atlon I

811D12010

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Phthalic Acid and Groundwater Trends for fIM-67-89 (Property Boundary)

to ·r-----------------------r---------------------------------------------,~

9 523

8 521

3

2

507

09ID1JW DIII28i9II D4I23IOO 02117/01 12114101 10110102 OB/06ID3 OMll104 03l281D5 0 1122105 111181D61Kl1141U7 D7111W111l51061D9 D3/02Il0

S;onopIing Event

[ __ f'M1oaIic~-~ Valle --GW EBao~

8/1D12(ttO

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lsophth ic Acid and Groundwater Trend for MW-68-a9 (Property Booodary)

10 525

U 523

8 521

7 51Ui'

i l! 517£ g g S "" 5 515 r..

III

'iS4 513 .§

3 511 1

2 509

Q/11911 8117/99 8ItJDO 7/17101 7f2lO2 11(17103 11(1104 5117105 512106 41171fJ1 411100 311710U 312110

$-.pIing Ev8d

UW-M-8U_051D.xIs 8111l'2010

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Phtharc Acid and Groundwater Trends for MW-68-89 (Property Boundary)

10 r-----------------------,---------------------------------------------, 5~Landlil CAP Certified:

August 2001 ~ 9 523

8

3

2 509

507

91tlll8 8117199 811100 7/171111 1f2JU2 8/17J03 8/1/04 5117J05 5I2ID6 4117101 411J08 3/t7J09 312110

5anping Ewnl

[ -e-PlWicDl -~va.e ___GN~

811Dr.2010

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lsophthalic Acid and Groundwater Trends for MW-69-90 (Property Boundary)

10 r---------------------------------------~----------------------------~ ~

II

8

lMIdfiII eN> Cer1Ified: August 2IlDI

7 ~------._--------~~--------~--~----_.------P_--~--~--~

3

2

D 211194 .wJII5 MtJIIII 7130197 I1128III8 tlm/llO Il25IIll 3I2Ml2 5I2!itU3 7123104 I112t/05 1112D1D6 111Q/D8 3111W9

S-.ping Event

[±IsophIh*Acid =Compari5.an va. __GW ~

MW-G9-IIIU151D.xIs

533

531

5211i'

•Ei

527£ g =

525'• ..

523'..J

5211

5111

517

M5

811012010

Page 57: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

8

Phthalic Acid and Groundwater Trends for MW-69-90 (Property Boundary)

10,-------------------------------------,----------------------------, ~5

LandfiH C/'P Certified:

August 2001 ---.

7 ~------r_--------_r----------~~~----y_----~--~r_~--~

521 J;3

51112

517

o 515

211/94 <II2JII5 5I31J116 7f3O/Q7 QI28/II8 l1mlllll 1125101 3I2MI2 5/25103 7123104 11121105 111201D6 1/111/08 311Qot)g

Sownping Event

811012010

Page 58: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

lsophtll ic Acid and Groundwater Trends for MW-86-98 (Property Boundary)

10 ~-------------------r----------------------------------------------~ ~

5339

5318

7~~--------------~----------------------~-----¥~-+~~~ i 6 .s ! 5 !

3

2 519

517

o M5

211/99 11/28I11III 9123/00 712Oi1l1 511M12 3112103 II1!104 1111104 1!128105 11124106 4f21JI07 2114108 12110108 lD.16109

5~gEnnt

[ ..... -------·--- v~ GW Eft..;tJ- IsophtI*Aad ~--------

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Phth. r Acid and Groundwater Trends for MW-86-98 (PToperty Boundary)

10 -r------- ---------r-----------------------------------------------, ~5

9

8

5211~7 ~~----------------+_------------------------~------~~~~~--~ E•52]t:.

;:sIi 525 !

"II 523 !

If 3 5211

2 519

517

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S.npling Event

~PhII;oIicilCid - eo.np.nsanV.... -+-GWEI8aIian 1

811012010

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APPENDIX B

SHALLOW WELLS

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5118

8

Phthafc Acid and Groundwater Trends for W-103..o1 (Shallow)

'D~------------------------------------------------------------------------r ~O

"

7 ~------------------------------------------------------------------------~ ~~ ~ 562 E.

c: o g

560! Ii]

558 ~ t

3 55CI ~

2

552

o __-'__-'~~~~__--~'-~__~~-'~-'-'-4~~~~'--'~~~--~'---~--__ 550 1112Mll 7191f12 21111/03 lDI2ID3 5/14/04 12125m4 817/05 3I2Q/OC 10131106 6113107 1124J06 II<!iI!III 4118101l 11129J09

$-.pling Event

[ -e-PhIhaIocXld - ComparisonViIIlR ......... GW~

8/1012010

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Isophthalic Acid and Groundwater Trends for MW-104-01 (Sh low)

10 r-----------------------------------------------------------------------~ ~

II 5511

8 558

7 ~----------------------------------------------------------------------__t ~~

3

2

o ~--~--------~--~~~~~~~--~~~~~--~~~~~--~--_.--__

i 556~

&., 555!

Ii)

554~

-10 553~

552

551

550

11126101 7/QJfJ2 211Q/03 10/2103 5114.04 121251D4 8fTJ05 3I2QIDe 11113101 11113107 1124108 lII5I08 4J1M1C1 11l2III011

S....,1ing Event

L~lsophII;aIic Acid -Com~Va.e ----GWEIPGtiDnl

811012010

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Phthalic Acid and Groundwater Trends for MW-10oUl1 (Shallow)

511010 ~--------------------------------------------------------------------,

II 5511

8 558 7 ~______________________________________________________________________"~ 557j

11126101 7/QIC11. 211Il103 1~ 5I14J04 12125104 8/7/05 3I2OIIJ6 10131/06 611:Ml7 1124J1l8 915108 4/18IDQ II/211JOII

5-.p1ing Ennt

[ ~PhiNIic;oad - ComJWisonValue __GW~

MW-1D4-0 ,-D510.x1s 811012010

3

2

O __~~~~~~~~L---~~db~~4-'-__~~~~~~~--~~_______

i 558 E.

'" 8 555!

554 ~

­553 :

552

551

55D

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Phthalic Acid and Groundwater Trends for MW-10s..01 (Shal ow)

10 ~--------------------------------------------------------------------, M5

II M3

8 Mt ~__________________________________________________________________________-+ 5311~

7

i 537';'~ 6

oS ~..c: 0.. 5 535!

i m ______...- 533~

8 • ~

: 4

3 531~

529

527

o L-~______-=~~____________~.-~~__________________________~ 525 1112610t 7191[12 211Q/03 1D12103 5114104 12125104 8f7JOo 3/20/06 t0l311116 6113107 1124108 915/08 4J18/OQ 111291119

S...,1ing E .... nt

-e-Phlhillica::id - Comparison Value -*""GW ElevaIian I

811012010

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Isophthalic Acid and Groundwater Trends for MW-108-01 (Shallow)

10 .~________________________________________________________________________-,M5

9

8

7

~________________-+~____________________________________________________-+ ~9~

____­ ....

3

2

o __~__--------~~----~~~~--~~----------------------------------~

11126101 71Wrf2 211Il103 1~ 5114~ 12125104 9/7/05 3/2010II 10131106 8113107 1124108 lII5I08 4118.()Q 1112910Q

S-..IinG Event

M3

Ml

Ii ~7t=.

a 535l

~

~3~ ~ 11

531~

5~

527

525

[ ____ ~lCkcI - Coonpomanva.e ---GWEIeAIion1

811012010

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Isophthalic Acid and Groundwater Trend for MW-109-01 (Shallow)

t10

u

8

7

~ II ..s g

5 1: i ~ 4 U

3

2 ­

t 30.2

r

535

o __----------------------~~~----~----------------------------~ 530 1tl2Mll 7/01f12 211U103 lD12/03 5114/04 1212M14 811105 3I2Q/DC1 10131100 11113107 1/24108 U/5I08 4118I0Il l1J2U101l

s..mpling Eftnt

811012010

APPENDIXC

SENTINEL WELLS

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Phth lie Acid and Groundwater Trends for 0-3 (Sentinel)

10

II

8

7

~ 6 oS ~ 5

J c

4

3

2

o

-----~--------------------------------------------_, M5

l.iI1dIiI1 CAP Certified: Augu5t2DDl

Ml

539.

•E

537 !:. g D•535 ~ ill..

533& .J

531 ! 5211

527

525 3/26198 5f15IQ7 7124198 W22IIl9 111201DO 111Il102 3120103 5118104 7117/05 1If151D6 11/14m 1/12109 3f13ftD

s........ Ewnt

[

811012010

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Isophth Acid and GrowldwaterTrends for MW-100-99 (Sentinel)

12

10

4

2

543

541

539 i"

537!:.

535'

533'

5311

525

SllM19 1111 MlO 4f71D1 2/11112 111281D2 11124103 7f201D4 5flCW5 3112JD11 lJa1D7 1 tI2I01 8128108 tv24IDII 4I2DIID

s~Evmt

SllD12010

•E

I ..iii ..J

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Phthalic Acid and GromdWater Trends for 1IW-100-S9 (Sentinel)

10 ------------------------------------------------------, M5

Landfill CAP Certified: 9 Au",st2DDl ___

8

7 +----------------+------------------------------------------------~

3

2

543

Ml

5391j E•

537 £ 8...•535'iii 11

533'

527

J...

o ~

8116/99 6Il1JOO 417J01 211J02 11128102 11124103 7I20I04 5/UW5 3/12JO!1 11'6107 1112107 8128108 6/24109 412Q110

s-.ping e-nt

811012010

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lsophthalic Acid and Gromdwater Trends for MW-101-99 (Sentinel)

10 545

9 landfill CAP Certified: 543

August2D11 1

8 ~ 541

7 539j'

~ 6 .§.

S

i 5"

J4

3

2

o Bl1611lO 6111100 'll7lUt 2J1IU2 11128102 9/241'03 7120104 !ilt61U5 3112106 116107 t tI2JU7 8/28108 11124109 412D110

s-piing Ennt

•E

- 537E. 5,..

535'• m..

533'..J 0.­

5311

529

527

525

Bl10120tO

Page 71: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

8I1t111111 6111100 417101 211102 11128102 Q/24J03 712W04 5116105 3112106 lla107 llJ2J07 8I28J08 11124109 4120110

Saupling Event

MW-l01·4I1UI510.Jds 8I1(L12010

10

9

8

7

6 g g ~ 5

J4

3

2

PhthaflC Acid and GrowdwaterTrends for MW-101-99 (Sentine )

landfill CAP CA!nified: August 2110 1

545

543

541

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Isophtha ic Acid and Gromdwater Trends for M'N-102-99 (Sentinel)

7 ~--------------~+_--~~~----------------------------------~

3

2

56010 r----------------T----~--------------------------------------------~

5589

5568

542

o L-____________~-L--__----~----~~~----------__--__--~__~__~~__ 540

8116199 6/11/00 417/01 211/02 111281D2 Ql24/D3 7120104 51161!15 3If 2JD6 llM17 11121D7 8128108 6'24I'0Il 4l2OIl0

5-.pIing &em

F Isop/IIIgIicAcid -~va.e c:NI~

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---------------,----------------------------------------------------,

Landfll CAP Certified.;

August 2001

7 +---------------~--------------------------------------~+_--~

542

540

8I16/QQ 6111100 417'()1 211m 11121W2 Ql24.{)3 712MM 5116105 3I12J06 1/M17 1112.()7 8I2Ml8 6/24IOQ 4121l11D

S......gEftnt

811012010

Phthalic Acid and GroundwaterTrends for MW-102-99 (Sentinel'

10,­

9

8

3

2

o

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IsophthalicAcid and GromdwaterTrends for MW"(5-88 (Sentinel)

560

Uncfil CAP Certified:

II

10 r----------------------------------,----------------------------------, AI9lst 2001

8 545

7 ~~--__~------~----------~~~------~--~--~--~----~ c­•i 540!:.

•j

~ ii

535 ~ 3

2 530

525 W2MI5 H / 111M1 12JM17 1/10lIl9 2114100 3/20101 412-4102 5I2Q/()3 712104 MIJ05 1II1M16 1Of15107 11/18108 12l23I0II

S...piingEYO!lll

GW EInooion I

811CW2010

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Phthalic Acid and Groundwa er Trends for MW-45.a8 (Sentinel)

10 r---------------------------------~r_--------------------------------_,

Lanc:fll CAP Certified:

9 August 2001

8

7~----~------------------~~+_~------~--~--~--~----~

3

2 530

o ~==~==__~~~ __--~~~~~~~ ..~~~__cd....~MP~~HH._~_4~ ~5

2J!i/Il6 3/11197 4115198 5I2OI9Il (1123/00 7128101 11/1/02 lCW103 11l1l/I)4 121141O!i 1118107 2122/08 3/28100 512110

Sm>Pino Event

MW--45·S!L0510.xls 81UW201 0

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Iso ic Acid and Gromdwater Trends for MW-49..$ (Sentinel)

57010

CAP CIriied:9 August 2001

8

7 ----------------------~--------------------------------~ ~~ ~

I ~ 562 !:.6

i,. 560~

5 iii

~ 4 558~ 8

3

2

552

o L---~------__--~--~~----~~~~~~MH~~~..~re..~..~~.______ 550

3I2Mi6 5f'1!5JV7 71241118 W22J99 11l20l00 1/19102 7/17/05 QJI5IIl6 11/14J07 1112J1l9 3113110

GIll EIevaIion 1[

8Jl~10

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Phthalic Acid and Groundwater Trends for MW-49-89 (Sentinel)

~ r j

c

~ 8

10

9 L.-diI CAP Cer1i1Ied: August 2001

8

7

II

5

4

3

2

570

568

O ~======--~----~'---"HN~~~MH~"~MM~"'-'-~ 1011195 11121111111 tl28l98 3I29t'IIG 51ZlJOO 712Ml1 1li24102 11123/03 112111)5 3/22I'D8 5121107 1/19/08 lIf17Joo

S-.pIingEYI!fIt

MW-49...SIL0510.xIs 811012010

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lsophthalic Acid and Grotmdwater Trends for MW-51-89 (Sentinel)

!i6D10 ~-----------I---------------------------------------------------------'

cfiI CAP Certified: g 5<58

2001~

5<56

1

8

544

542

D 540

3 ­

2

3f2MlIl 4130100' 6!4IIl8 7l1li99 8112100 MOO) 10121102 11125103 t2l29lll4 2I2J06 3/Q1fJ7 4112J08 5/17109

S...-np&ne Event

MW-5t -8IU151D-x1s 811012010

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Phthalic Acid and Groundwater Trends for MW-51-89 (Sentinel)

10

II CAP Certified: 2001

8

7

::r II

S. g ¥:I 5

C

J4

3

2 544

542

o 3l21li96 4I3()/g7 IIHI08 7/111OQ 8112JOO 9/11l1li1 10/211112 11125103

Silmpling Ewnt

12J2Q/04 2I2JDII 3/OIf11 4112JD8 51171119

540

MW-51-81Ul510.lCIs 81111/2010

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Isoph ic Acid and Gromdwater Trends for MW-88-98 (Sentinel)

10 545

Landfil C/lP Cer1ilied: August 2001

8

7 ~--------------------+-----------------------------------------~

3

2

543

541

539lj E•

537fi!. g..,•5351 m..

5331 ..J..

531 ~

0 ~~~----~--~---4~~L---------~----~--~--~--------------~----~ 525

8f23/II8 6I1Q199 4114iOO 2I8IIll 12151111 10/1J02 712B103 5I23ID4 3IllW5 1/13m l111W6 W5/07 7I1.()8 4127/09 2121/10

5.wnpling e-nt

tIW~_0510.lII5 Bll!W2010

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---Phthalic Acid and Groundwater Trends for MW-mI-98 (Sentinel)

10 545

lMdiII eN' Cet1ified: 9 August 2001 543

8 541

7

3" II

!. ! 5

J4

3

2

o 525

52Q

527

8IZW8 61111199 4114100 218101 12151111 1Df1J02 712B/03 5123104 3I1W05 l f1 3JOC1 11111/06 9151117 7I1J08 4I27JOQ 2121/ 10

~&.nt

UW-88-9IL051D_xIs 611Df20 10

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Isophth ic Acid and Gmmdwater Trend for MW-92-98 (Sentinel)

10

9

8

1 ~---------------------~----------------------------------------~

3

2

L-__~__~~ ____~~~~~ __-=~~ __~~~~ ____~=-__________________~ o

Landfill CAP Certified: August 2001 558

554i" •E

552E. g ""•55D~ ..

548~ ..... ...

546~

544

542

~

811M 6/221119 5112100 412101 2/211112 \112103 1213/03 10/23104 W13105 614106 fJ/25I07 5115108 4I5IOQ 2/24110

S-.pIing EnrIl

611 IY.!OI 0

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542

540

Phthalic Acid and Groundwater Trends for MW-92-98 (Sentinel)

10

Landfil eN' Cenilied: g August 2001

560

558

5511

554~

•E

552E. 5 '"

550 •& IiJ..

548& ....I..

5411~

6/Q1!I8 4I!iIIlII lJ3(J(10

8110/2010

8

7

~ 6 .s. 5 '" t;

5

J c

4

3

2

o 8111118 5I2lWg 3J23IOO 1117101 11113101 Q/Q/Q2 716103 511104 2rJ!iI05 12l22J051011111t16 8114107

s-.piAg Ewnt 1r--..... PhNIic ..ad _~~GW~----·--·-

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Isophtha ic Acid and Gromciwater Trends for MW-94-98 (Sentinel)

10 r------­5639

5618

7

3

2 549

547

D L-~~~~~~ ..~~~~~~~t_~~~~~~~_4~ 545

81flQ8 GI22IIl9 5112100 412/01 8I4I(XI 6f1!iI07 5115108 4151D9 2124110

811012010

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Phthalic Acid and Groundwater Trends for MW-94-98 (Sentinel)

10 r-----------------------~--------------------------------------------~ lM1dIiIl CAP Cer1ified: Al9l5t2001

8

Q

561

7 I-------------------~----------------------------------------~

3

2 54Q

547

o 545

8111118 Il/22IIKI 5Il2JOO 412101 21211112 1112103 1213103 10l23I04 111131115 8/<IIOCI fVl5lO7 5115108 4l5IOII 2124110

S.>n>p5na Ewell

Cotnpoonson va.e __ GW ~

811012010

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2

Isoptllflalic Acid and GromdWater Trends for MW-95-98 (Sentinel)

to

II Landfill CAP Certified: August200f

585

583

a · 561

7 I---------------------~------------------------------------------~ ~9~•e

:i 557E.a. 6

S g

5551

!•"" ID..i

5

J4 5531 oJ

I3 . 551 it

o 545

8111118 7J17199 711/00 6fl6JDl fll1lOil 5117J1l3 511104 4J16J1l5 4/1J1lfl 3Jl1/ffl 3flJ1l8 211-4m9 113WtO

5.vnpling e ... nt

549

547

l ___ lscJphIhaIickid -Comparison va.e --GIN EJevation 1

81100.010

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Phthalic Acid and GroundWater Trends for MW-95-98 (Sentinel)

10 ,-------~ 565

Landfill CloP Certiied: August 2001 563

8 561

7

3

8111118 7/17~ 7/1/00 CllMll Cll102 5117103 511104 ""I1.'D5 411106 31171rI7 311108 2114/011 1/30/10

Sompling Ewnt

GW~an

MW-Il&98 _051 O.x15 811012010

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lsophthalic Acid and Groundwater Trends for MW-96-98 (sentinel)

10

8

7

~ II S !• 5

3

2

l--------------------~----------------------------------------~

563

561

549

547

811Jg8 7/171Q9 7/1100 11116101 1111102 51171113 511104 4Ill1J05 4/1/06 3/17tr17 3/1/08 2114I0Il 113()(IO

s..mpling ewnt

8110f2010

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Phthalic Acid and GroundWater Trends for MW-96-98 (Sentinel)

10 ~----------------------~-------------------------------------------.

\I

8

7

3

2

o ~----~-----4~----~~~~~~~~~~~~"~~~~~'-"4H'--4~__--4 8Ill1l8 71171911 7/1m 1II1Mll 1111/02 5117103 511104 411Ml5 4/1/06 3117107 311108 2114I0Il 113B'10

S;vnplino Ewnt

r"[-_ PhII -·--.. ------ a-.tion--- . -·-_Comp~ v....... .....GW

Landfil CAP Cet1&cI: August 2001

565

563

561

559 i' e•

557~

I 555C

III.. 553~

551!

549

547

545

8Il0C!010

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lsophtha6c Acid and Groundwater Trends for MW-97R-OO (Sentinel)

10

U 548/ 8

7 544i' •E

~ II 542 £ gSo ll>•~ 5 540' iii.. ..Jj

~ 4 538' 3 5381 2 534

532

o ~------~~--~--------~~--~~----__--~~--~____~~ ____~~__~ 530

[ -e- I5aphIh*Acid - Conpison V;u __GIN ~

81tDl2Dl0

1011100 MIIOI 2113/02 lD121J1l2 tII28I03 314104 111lW4 7/17105 3I24JIIII tll2WD11 BIMl7 "'t21D8 1211Bm8 8I25IIlII 512110

s-.-.uEwnt

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Phthalic Add and Groundwater Trends for MW-97R-OO (Sentinel)

10 r-------~I-----~--_r----~~------~~--Tr~----r_~rr--_r---*------_, 550

9 2311 11 III 16 548

8 546

1 ~------~----+_~----~------~--------+_--~--~------------~

3

2 534

532

o 530

1011100 lII8I01 2113102 10121102 6128103 3.'4/04 1119J04 1117105 3124106 11121l/O6 8I6IIl7 4112108 12118108 8/25109 512110

Sillhpling Event

[ _____ PhIIaIic xad - Comp;In5<ln Vab! -..-GW ~

8/1012010

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lsophtbalic Acid and Gromdwater Trends for MW-98-99 (Sentinel)

545

II

10 .-----------------~----~------------------------------------------------~

543

8 541

7 +-----~~------~~~------~------------------------------~

3

2

o

5211

527

525

712D11!9 5/24100 3I20I01 1114102 1111002 Q06I03 712/04 4/28/05 2122J1J6 1211Il106 101151U7 8I10r0a 6/6JOO 412110

S-.pIing Event

MW-Q8-9I!_ 051 D.xIs 8/1fl12010

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7 +-------------~~_+----------------------------------------------------~ ~II~•E

~7E. g

~5l '"• iii..

~l ..I

3 ~1! 2

5Il

o ~5

7rzJiUfJIiJ !5124.m 3I2DIDI 1/14102 l1/1D1D2 IMIi!l3 7121D4 4I28lOO 2I22IDII 1211111D6 lD11M17 811DtD8 MIIOII 412110

5..np1ing Event

MW-98-IIILD510.xls 811D12Dl0

10

II

8

Phthalic Acid and Groundwater Trends for MW-98-99 (Sentinel)

545

543

541

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Isophthalic Acid and Groundwater Trends for MW-99R.oo (Sentinel)

10 r--------T---,--~--~~~--_,r_----__--~_w--------------__~--------__,

II 548

8 546

7 ~----~--~--~--------~--~--~~~----------~_+------~

3

2

o L-----~~~~------~~--~~----~------~--~----_r--------------~ 11l/1JOO 7/2811l1 51241D2 3/20103 1114104 l111W4 III5IIl5 7f2Jf1fj 4f28JrJ7 202IC1d 121181118 10114m9

Silmplinll Event

Bll InO10

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Phthalic Acid and Grotmdwater Trends for MW-99R..oo (Sentinel)

10 r--------.--._----.-r-r--.~------------.__r--------------~--------__,

g 31

8

7 ~------~~----~----------~~--~~~_.------------------~

e ~ 4 8

3

2

o L-______-+____________________~~--~~~~----4_----~~----------~

550

548

54G

544 e•Ii 542!:.

j.. 5401

iii

~~ ~

536 i

534

532

53D

1011/00 712&'01 51241Cl2 3/2003 111 4.iIl4 1 1J'Q/Q4 QI5IIl!i 712J06 4I28IfJ7 '1n2lfJ8 12118108 10/14101l

SmlfIIng Event

APPENDIXD

811012010

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MONITORING WELL GROUNDWATER ELEVATIONS

SUMMARY OF GROUNDWATER ELEVATIONS - APRIL 12, 2010 INTERIM POST-CLOSURE GROUNDWATER MONITORING PROGRAM

FORMER BP AMOCO JOLIET LANDFILL SITE JOLlET,IL

Location

Reference Elevation

Depth to Groundwater

Groundwater Elevation

(ft NGVD)' (ft btoC)2 (ft NGVD)

HSU1 Wells A-12 555.93 5.50 550.43

MW-103-01 567.53 11.77 555.76 MW-i04-0i 566.28 11.48 554.80 MW-l05-01 560.14 8.26 551.88 MW-l06-01 564.57 9.30 555.27

MW-107-01 555.42 5.68 549.74

MW-l08-01 542.56 9.55 533.01 MW-109-01 569.34 17.90 551.44 MW-112-02 551.39 8.97 542.42 MW·113·02 545.22 14.61 530.61

Piezometers PZ-ll-01 566.87 7.19 559.68 PZ-12-01 572.23 20.18 552.05 PZ-13-01 561.27 10.72 550.55 PZ-14-01 559.62 9.58 550.04 PZ-15-01 568.59 15.54 553.05 PZ-16-01 574.16 NM NM PZ-17-0i 567.93 17.15 550.78 PZ·18-01 567.99 19.78 548.21 PZ-19-01 547.47 13.29 534.18 PZ-20-01 545.38 8.60 536.78

Transition Zone Wells

MW-13R·99 MW-45-88

MW·63R-94

56B.BO 558.00 539.69

16.45 13.25 7.48

552.35 544.75 532.21

. It NGVD . feet as referenced to National Geodetic Vertical Datum

2 It bloc . feet below lop of casing

" GWIT . groundwater Interceptor trench

• NM . Not Measured· Well nol accessible due to elevated riser preventing well case to open

BP 60149353.709 Page 1 012 June 2010

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SUMMARY OF GROUNDWATER ELEVATIONS - APRIL 12, 2010 INTERIM POST-CLOSURE GROUNDWATER MONITORING PROGRAM

FORMER BP AMOCO JOLIET LANDFILL SITE JOLlET,ll

location

Reference Elevation

Depth to Groundwater

Groundwater Elevation

(ft NGVD)' (ft btoC)2 (ft NGVD)

HSU2Wells

0-3 535.05 2.92 532.13

MW-49-89 560.67 4.96 555.71

MW-51-89 557.43 7.14 550.29

MW-65-89 528.70 4.13 524.57 MW-66-89 527.70 4_97 522.73

MW-67-89 526.60 3.75 522.85

MW-68-89 525.70 2.89 522.81

MW-69-90 532.78 4.18 528.60

MW-86-98 535.01 6.43 528.58

MW-8B-9B 540.83 6.35 534.4B

MW-92-98 556.52 11.72 544.80 MW-94-98 555.01 6.15 548.86

MW-95-98 554.51 6.10 548.41

MW-96-98 555.20 4.79 550.41

MW-97R-OO 541.40 4.71 536.69

MW-98-99 540.68 4.29 536.39

MW-99R-00 540.85 5_07 535.78

MW-100-99 539.84 3.54 536.30 MW-l01-99 535.21 3.45 531.76

MW-102-99 552.34 5.80 546.54

Select GWn-3 Locations MW-62-89 540.77 6.74 534.03

PZ-5-9S 554.55 11.21 543.34 PZ-6-98 544.54 15.54 529.00 PZ-7-99 551.28 6.89 544.39 PZ-8-99 543.12 9.96 533.16

MS-8 543.51 4.01 539.50 MS-11 540.77 13.48 527.29 EG-323 547.77 20.48 527.29 EG-324 544.96 17.51 527.45

'It NGVD· feet as referenced to National Geodellc Vertical Datum <It btoc . feet below lop of casing

3 GWIT - groundwater Interceptor Irench

• NM· Not MBasured . Well not accessible due to elevated riser preventing well case to open

Page 2 of 2 BP 60149353.709 June 2010

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APPENDIX E

COMMENTS RECEIVED FROM SUPPORT AGENCIES AND/OR THE COMMUNITY

1). Who monitors groundwater?

AECOM Technical Services, Inc. monitors groundwater on behalf of Atlantic Richfield Company, a BP affiliate

How often?

Groundwater sampling is performed semiannually during April and October as part of the Interim Post Closure Groundwater Monitoring Program.

Does Illinois EPA get data?

Yes, Illinois EPA receives the data in a semiannual report summarizing the groundwater sampling events.

2). Does the Joliet Westside wastewater treatment plant test the leachate from BP Amoco?

Yes, the POTW samples the effluent from the landfill annually. As required by the permit, AECOM also tests the leachate monthly for biological oxygen demand, chemical oxygen demand, total suspended solids, and pH. In January and July, the permit requires expanded sampling to include other water quality parameters and the landfill constituents of concern.

If no, does anyone test the leachate?

See above.

3). Does the Joliet wastewater treatment plant test their discharge water for contaminants that may have come from the Amoco leachate?

Yes, the wastewater treatment plant analyzes for six of the constituents that the Amoco landfill has in its leachate discharge.

4). How much leachate is handled by the wastewater treatment plant?

The average discharge rate of leachate handled by the wastewater treatment plant is 1,400,000 gallons per month, based on the collected since June 2007. The discharge rate fluctuates relative to wet and dry seasons.

5). Is the leachate pre-treated before being piped to the Joliet wastewater plant?

No, the concentrations present in the leachate are within the limits of the wastewater treatment plant, so no pre-treatment is necessary. The City of Joliet POTW permit specifies the need to immediately report any exceedances of permit limits from the monthly samples, and the plant operator decides if any corrective action or pre-treatment will be required. No such actions have been needed.

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6). Who monitors the Superfund Site?

Illinois EPA completed a Consent Decree (CD) with BP Amoco on April 24, 2000 to implement the requirements of the Record of Decision (ROD), issued on July 15, 1999, for the landfill operable unit (LFOU) at the Site. U.S.EPA concurred with the LFOU ROD. The ROD specifies that RCRA landfill caps would be placed on the north and south landfill, and that a leachate collection system be installed down gradient of the landfills. Illinois EPA provides oversight and review (with the assistance of Illinois EPA consultants CDM) for all documents and field work completed by BP Amoco in design and construction of the caps. AECOM completes field activities on behalf ofBP.

How often?

AECOM performs biweekly, quarterly, and annual inspections in accordance with the O&M plans, and these inspections are summarized in the monthly progress reports submitted to Illinois EPA. Semiannual inspections of the landfill are performed by AECOM and Illinois EPA and/or their consultant CDM, and site conditions requiring corrective actions are identified in a checklist and reported in the next monthly progress report. Illinois EPA or their consultants CDM provide field oversight for installation, investigation, or repair of any activities conducted by BP Amoco or AECOM on an as needed basis.

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APPENDIX F

INSTITUTIONAL CONTROL STUDY

£COM AECOIoI 6JD.8J6..17oo II!! 27755 OleN RoiId, sute 100 63Q.8J6.1711 tall

WiIneIftIIe." ti05S5

September 1.2010

Mr. Eric D. Runkel Prn;ect ManBgel" National Priorities List Unit lIinois ErNironmental Pmtedion Agency 1021 Nor1tI Grand AYe. East SpmgfIeId, llinois 6:2ro4

Subject: Institution~ Conb"oI Study BP Amoco C~ Undfil Superfund 5itI! - .Joliet, Illinois "1800000t - VIIiII County AECOM Project No.: 6OU9353.133

DearMr.~

AECOM T edlnical Services. Inc. (AECOM) is pleased 10 submit. on behalf at A1Iantic Richfietd ~ny (ARoo). the foIowing InshJtional ConIroI Study b 1he BP Amoco Ctlemical Landfil (SiIe) Icx:atN in Joiet. Wi! Courtly••inois (Figu~ 1) to lie llinois Environmental ProIection Agency (IEPA). The IEPA is reviewing institWonal conITOls (lCs) on behalf at the Uniled Stales Environmental Protedim Agency (USEPA). The goal of Ile nMew is to determine if ICs ~ired by Ile Record of Oecisioo (ROD) Of" consenl decn!e culJefldy exist. identify COfT'ediye measures and recommend new Of" additionallCs.

The ROO. dated J"Y 15. 1999. states.1he fDllawing: one reel e5l8te deed will be ameflded to include prohibition of on-site woundwater use. on-site building construction and on-site drilling except b the purpose of remecial design. sampling. monitDring and remedial action:

The Site consists c:I two ~ paroefs. Paroel nlI1iler 0410113000020010 and paroeI nurmec­0410113000020020. Figure 2 di!pM:Is the parcel boundanes. The 5itIe is ide with no structur-es or activities beyond !hose fl!quftod 10 maintain 1he closed landfill and monitor" groundwater. as defined in the ROD.

The IC Skldy is div;ded into llree sections: 1) review and asSE.>SSmeITI of existing ICs; 2) compliance and effectiveness of \Cs; and 3) recommendations..

Existing Proprietary Controls

The Sill! cum!nly has an IC in lie fa"" of an Erl'lliranmental Land Use ComuI (ELUC). The ELUC is attached to the propeny He. meaning it ·runs will the property". The auc stnes:

• Groundwater which underlies the Sire shall not be used for potable water.

• No weier supply well shal be ~ or otherwise used for any purpose at lie Site.

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630.836.1700 telAECOM~COM 27755 Diehl Road, Suite 100 630.836.1711 fax

Warrenville, IL 60555

September 1, 2010

Mr. Eric D. Runkel Project Manager National Priorities List Unit Illinois Environmental Protection Agency 1021 North Grand Ave. East Springfield, Illinois 62794

Subject: Institutional Control Study BP Amoco Chemical Landfill Superfund Site - Joliet, Illinois 1978000001 - Will County AECOM Project No.: 60149353.733

Dear Mr. Runkel:

AECOM Technical Services, Inc. (AECOM) is pleased to submit, on behalf of Atlantic Richfield Company (ARCO), the following Institutional Control Study for the BP Amoco Chemical Landfill (Site) located in Joliet, Will County, Illinois (Figure 1) to the Illinois Environmental Protection Agency (IEPA). The IEPA is reviewing institutional controls (ICs) on behalf of the United States Environmental Protection Agency (USEPA). The goal of the review is to determine if ICs required by the Record of Decision (ROD) or consent decree currently exist, identify corrective measures and recommend new or additional ICs.

The ROD, dated July 15, 1999, states the following: "The real estate deed will be amended to include prohibition of on-site groundwater use, on-site building construction and on-site drilling except for the purpose of remedial design, sampling, monitoring and remedial action."

The Site consists of two separate parcels. Parcel number 0410113000020010 and parcel number 0410113000020020. Figure 2 depicts the parcel boundaries. The site is idle with no structures or activities beyond those required to maintain the closed landfill and monitor groundwater, as defined in the ROD.

The IC Study is divided into three sections: 1) review and assessment of existing ICs; 2) compliance and effectiveness of ICs; and 3) recommendations.

Existing Proprietary Controls

The Site currently has an IC in the form of an Environmental Land Use Control (ELUC). The ELUC is attached to the property title, meaning it "runs with the property". The ELUC states:

• Groundwater which underlies the Site shall not be used for potable water.

• No water supply well shall be installed or otherwise used for any purpose at the Site.

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2 AECOM BP Joliet Institutional Control Study

• The Site shall not be used for any agricultural, recreational or residential purpose, or in any manner that would allow children to have the opportunity for exposure to potential contaminants through soil ingestion or inhalation, including but not limited to educational facilities, health care facilities, child care facilities, or outdoor recreational areas.

The ELUC area for the Superfund site has been professionally surveyed by the firm of Ruettiger, Tonelli, & Associates, Inc. of Joliet, Illinois. The American Land and Title Association (ALTA) plat survey was completed and converted to Universal Transverse Mercator (UTM) coordinates. The plat drawings and calculations were completed to within 0.01 foot (ft) tolerance and the field survey was completed within 0.05 ft tolerance. Figure 3 depicts the surveyed boundaries of the ELUC area. The ELUC encompasses both parcels in their entirety, and matches the boundaries of the restricted area and property boundaries. A CD-ROM is attached to this study containing the coordinates of the ELUC survey in ESRI® polygon-shape file format, as requested by IEPA.

A title insurance commitment was obtained from a title company on the restricted areas. A copy is presented in Attachment A. The title commitment identifies the existing ELUC for both parcels. A recorded copy of the ELUC is available in the title commitment.

A portion of the original ELUC area was transferred to Flint Hills Resources during the sale of the adjacent chemical plant in 2003. The approximate location of this ELUC area is depicted in Figure 4. Maintenance of the ELUC is the responsibility of Flint Hills Resources; they are obligated to comply with the land and groundwater restrictions as described above.

The property is currently zoned 1-3 or "Intensive Industrial District". This eliminates the construction of non-industrial structures such as, but not limited to, residences and schools. There are currently no other relevant governmental controls at the Site.

Compliance and Effectiveness of ICs

The ICs in place are effectively preventing exposure to pollutants or contaminants. The only potential human or ecological exposure in the area exists at the locations of two intermittent seeps along the bluff east of the landfill. Potential human exposure is limited to incidental contact during sampling activities. Ecological exposure is limited to local wildlife. Nearby creeks, springs, and the Des Plaines River provide said wildlife abundant drinking water sources. The seeps will be evaluated during a supplemental remedial investigation for groundwater scheduled for November­December 2010, and the data will be included in a subsequent risk assessment. The ownership and land use of the Site and the surrounding area have not changed since the ROD and inception of the ELUC. There are no constructed or planned developments in the area, and ARCO does not plan to sell or transfer the property. There have been no water wells installed within the ELUC area, except those for the purpose of groundwater monitoring and/or remediation.

The Site is visited on a biweekly basis by AECOM to perform operations and maintenance (O&M) on the leachate collection system. Semiannual site inspections are completed with IEPA to demonstrate compliance with the consent order and O&M plan. Compliance with the ELUC and condition and use of the Site are checked during these O&M visits and inspections. The site is fenced on three sides and "No Trespassing" signs are posted to prevent unauthorized access.

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3 AECOM BP Joliet Institutional Control Study

Recommendations

AECOM does not recommend changes to the ICs at this time. The existing ICs are comprehensive, maintained and effective at the prohibition of on-site groundwater use, on-site building construction and on-site drilling.

Please feel free to contact either of the undersigned should you have questions or comments.

Sincerely yours,

AECOM Technical Services, Inc.

Matthew Laub Randal J. MacKay Senior Staff Specialist Project Manager

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Figures

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AECOM AECOM 27755 DIEHL RD. SUITE 100 WARRENVILLE, ILLINOIS 60555 PHONE: (630) 836-1700 FAX: (630) 836-1711 WEB: HTTP://WWW.AECOM.COM

Site Location Map

BP Joliet Chemical Landfill Superfund Site Joliet, Illinois 1

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Parcel Boundaries

BP Joliet Chemical Landfill Superfund Site~COM Joliet, Illinois

AECOM 27755 DIEHL RD. SUITE 100 WARRENVILLE, ILLINOIS 60555 PHONE: (630) 636-1700 FAX: (630) 836-1711 WEB: HTTP:/NWVW.AECOM.COM

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AECOM AECOM 27755 DIEHL RD. SUITE 100 WARRENVILLE, ILLINOIS 60555 PHONE (630) 836-1700 FAX: (630) 836-1711 v.£B: HTTP:/M"N'N.AECOM.COM

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Approximate Location of ELUC Area Transferred with Plant SaleAECOM

BP Joliet Chemical Landfill Superfund Site AECOM 27755 DIEHL RD. SUITE 100 Joliet, Illinois WARRENVILLE, ILLINOIS 60555 PHONE: (630) 836-1700 FAX: (630) 836-1711 WEB: HTTP://WWW.AECOM.COM

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Attachment A

Title Commitment

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,," ~I ~: ~ I (. --,

COMMITMENT FOR TITLE INSURANCE

ISSUED BY

FIRSTAMERICAN TITLE INSlIRANCE COMPANY

Agreement to Issue Policy

We agree to issue a policy to you according to the terms of this Commitment. When we show the policy amount and your name as the proposed insured in Schedule A, this Commitment becomes effective as of the Commitment Date shown in Schedule A.

If the Requirements shown in this Commitment have not been met within six months after the Commitment Date, our obligation under this Commitment will end. Also, our obligation under this Commitment will end when the Policy is issued and then our obligation to you will be under the Policy.

Our obligation under this Commitment is limited by the following:

The Provisions in Schedule A.

The Exceptions in Schedule B.

The Conditions, Requirements and Standard Exceptions on the next page.

This Commitment is not valid without Schedule A and Schedule B.

1

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CONDITIONS

1. ['EHNITIONS. (a) 'rvJortqage" means mortgage, deed of trust or other security instrument. (I:) 'Public: Records" means title records that give constructive notice of matters affecting the title according to the state IEiN \,here the land i~, located.

2. LATER, DEFECTS. The :) cepllons in Schedule B may be amended to show any defects, liens or encumbrances that appear for the first time in the 1= uhlic records or are created or attach between the Commitment Date and the date on which all of the Requirements (a) and I c) shown below are met. We shall have no liability to you because of this amendment.

3. E l(ISTING DEFECTS If an~1 defects, liens c,r encumbrances existing at Commitment Date are not shown in Schedule B, we may amend Schedule B to show them, If we do amend Schedule B to show these defects, liens or encumbrances, we shall be liable to you aceo-dillg to Paragraph 4 below unless you knew of this information and did not tell us about it in writing.

4, LIMITATION OF OUR LIABILITY Ow only obligation i'; to issue to you the Policy referred to in this Commitment, when you have met its ReqUirements. If we hjve all'y liability ':0 you for any loss you incur because of an error in this Commitment, our liability will be limited to ycur actual loss caused by your relying on this Commitment when you acted in good faith to:

comply with the Requirements shown below or

eliminate with our written consent any Exceptions shown in Schedule B or the Standard Exceptions noted below.

We slall not be liable for more than the Policy Amount show in Schedule A of this Commitment and our liability is subject to th!~ terms of the Policy form to be issued to you.

5" CLAIMS MUST BE BASED ON THIS COMMITMENT ACIY claim, whether 01' not based on negligence, which you may have against us concerning 1he title to the land mus.t be base,j on t11S Commitment and is subject to its terms,

REQUIREMENTS

Th~ fc"l(lwin~1 requirements must be met: (a) Pc!'; the agreej amounts for the interest in the land and/or the mortgage to be insured. (b; PCI'; us the prE'rriums, fees and charges for the policy. (c) Documents satisfactory to us creating the interest in the land and/or the mortgage to be insured must be signed,

dE,livered and recorded. (d) Ycu must tell JS in writing the name of anyone not referred to in this Commitment who will get an interest in the land or

who will make a loan on the land. We may then make additional requirements or exceptions. (e) Prcl:Jer docum ~ntation to dispose of such exceptions as you wish deleted from Schedule B or the Standard Exceptions

nc,ted below.

STANDARD EXCEPTIONS

Th,~ fc IIc\Vin~ Standard Exceptions will be shown on your policy: (1) Ri,;hts or claims of parties in possession not shown by the public records. (2) Ecsements, or claims of easements, not shown by the public records. (3) Ar!'; encroachrnents, encumbrance, violation, variation or adverse circumstance affecting title that would be disclosed by

ar accurate and complete survey of the land pursuant to the "Minimum Standards of Practice,' 68 III. Admin. Code, Sec. 12 10.56(b)(6J:P) for residential property or the ALTNACSM land title survey standards for commercial/industrial pr:,perty .

(4) Ar'/ lien, or ri~ht to lien, for services, labor, or other material heretofore or hereafter furnishec, imposed by law and not shown by the public records.

(5) Tc:<es, or special assessments, if any, not shown as existing liens by the public records. (6) Lo~;s oc dama~,e by reason of there being recorded in the public records, any deeds, mortgages, lis pendens, liens or

oth~r title encumbrances subsequent to the Commitment date and prior to the effective date cf the final Policy.

2

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First American Title Insurance Company 27775 Diehl Road, Suite 200, Warrenville, IL 60555

Phone (S66)512-9926 Fax (SE;6)S92-1147 ALTA Commitrnent

Schedule A

Reference:

For title inquiries, please contact the Land Development Commercial Unit at 1-866-512-9926.

File No.: 2090548

1. Effective Date: August 25, 2010

2. Policy or Policies to be issued: Amount:

a. ALTA Owner's Policy ALTA Std Owner Policy 1402.06 (2006) $10,000.00

Proposed Insured: To Be Furnished

b. ALTA Loan Policy ALTA Loan Policy None None

Proposed Insured: None

3. The estate or interest in the land described or referred to in this commitment and covered herein is fee simple and title to the estate or interest in said land is at the effective date hereof vested in:

Amoco Chemicals Corporation n/k/a BP Amoco Chemical Company

4. The mortgage and assignments, if any, covered by this Commitment are described as follows:

To Be Furnished

3

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5. The land referred to in this Commitment is described as follows:

That part of the West Half of fractional Section 11 and the East Hellf of Section 10, all in Township 34 North, Range 9 East, of the Third Principal Meridian, described as follows:

(:ommendng at the Northwest corner of said fractional Section U.; thence South 00 degrees 22 minutes 35 seconds West, along the West line of the Northwest Quarter of said frelctional Section 11, 2403.25 feet to the point of beginning; thence North 9'0 degrees 00 minutes 00 seconds East, 962.38 feet; thence South 7:3 degrees 47 n,inutes CIS seconds East, 443.75 feet to the line between BP Amoco Chemical Company and the state of Illinois, according to the boundary line 'algreement recordl!d March 31,2003 as Document R2003074463; thence South 11 degrees 35 minutes 52 seconds West, 19.40 feet; thence South 13 degrees 56 minutes U: seconds West, 102.86 feet to the North line of the Southwest Quarter of said fradional Section 11; thence South 19 degrees 28 minutes 21 seconds West, 78.15 feet;: thence South 16 degrees 46 minutes 10 seconds West, 111.28 feet; thence South (]I8 degrees 30 nlinutes 22 seconds West, 127.28 feet; thence South 00 degrees 57 minutes 11 seconds West, 104.71 feet; thence South 02 degrees 34 minutes 1,3 seconds West, 121.65 feet; thence South 02 degrees 47 minutes 35 seconds East, 98.05 feet; thenc:e South 00 degrees 51 minutes 31 seconds East, 100.25 feet; thenc.~ South 06 degreeii 00 minutes 49 seconds East, 53.05 feet; thence South 04 degrees 06 minutes 43 seconds East, 139.59 feet; thence South 12 degrees 10 minutes 4~a seconds West, 95.47 feet; thence South 34 degrees 36 minutes 35 seconds West, 118.50 feet; thence South 25 degrees 06 minutes 06 seconds West, 58.77 feet; thence South 23 degrees 51 minutes 41 seconds West, 97.50 feet; thence South 20 degrees 31 minutes 17 seconds West, 199.60 feet; thence South 39 degrees 39 minutes 38 seconds West, 157.18 feet; thence South 37 degrees 33 minutes 19 seconds West, 84.22 feet; thence South 35 degrees 05 minutes 49 seconds West, 138.34 feet; thence South 26 degrees 12 minutes 55 seconds West, 120.00 feet; thence South 18; degrees 13 minutes 40 seconds West, 55.36 feet; thence South 30 degrees 06 minutes 32 seconds West, 67.37 feet; thence South 25 degrees 44 minutes 33 seconds West, 81.98 feet; thence South 21 degrees 28 minutes 31 seconds West, 86.35 feet; thence South 27 degrees 44 minutes 29 seconds West, 34.29 feet; thencle South 30 degrees 45 minutes 53 seconds West, 53.87 feet; thence South 26 degrees 47 minutes 03 seconds West, 81.44 feet; thence South 27 degrees 04 minutes 14 seconds West, 18.03 feet; thence South 26 degrees 31 minutes 58 seconds West, 36.37 feet; thence South 32 degrees 39 minutes 01 seconds West, 17.43 feet; thencl! South 26 degrees 44 minutes 09 seconds West, 102.05 feet; thence South 20 degrees 3:7 minutes 15 seconds West, 48.63 feet; thence South 29 degrees 32 minutes 46 seconds West, 146.16 feet; thence South 24 degrees 23 minutes 47 seconds West, 56.38 feet to the South line of the Southwest Quarter of said fractional Section 11; thence South 90 degrees 00 minutes 00 seconds West, along said South line, 415.53 feet to the Southwest corner of said fractional Section 11; thence North 44 degrees 15 minutes 07 seconds West, 823.09 feet; thence North 00 degree:5 00 minutes 00 seconds East, 551.86 feet; thence North 14 degrees 13 minutes 59 seconds East, 1;7,5.03 feet; thence North 00 degrees 00 minutes 00 seconds East, 429.09 feet; thence North 04 degrees 13 minutes 03 seconds West, 175.63 feet; thence North 06 degrees 58 minutes 41 seconds West, 255.11 feet; thence North 01) degrees 00 minutes 01) seconds East, 718.30 feet; thence North 90 degrees 00 minutes 00 sec:onds E<lst, 590.10 feet to the Point of Beginning; in Will County,. Illinois.

Note: FOI' informational purposes only, the land is known as:

23425 Amoco Road ChannahJn, IL

4

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THIS COMMITMENT IS VALID ONLY IF SCHEDULE B IS ATTACHED.

5

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ALTA Commitment

Schedule B

Part I File No.: 2.090548

Schedule B of the policy or policies to be issued will contain the exceptions shown on the inside front cover of this Commitment and the following exceptions, unless same are disposed of to the satisfaction of the Company:

If any doclIment referenced herein contains a covenant, condition or restriction violative of 42.USC 3604(c), slIch covenant, condition or restriction to the extent of such violation is hereby deleted.

1. Rights or claims of parties in possession not shown by the public records.

2.. Easements or claims of easements, not shown by the public records.

3. Any encroachments, encumbrance, violation, variation or adverse circumstance affecting title that would be disclosed by an accurate survey of the land pursuant to the "Minimum Standards of Practice," 68 III. Admin Code, Sec. 12.70.56(b)(6)(P) for residential property or the ALTA/ACSM land title survey standards for commercial/industrial property.

4. Any lien, or right to lien, for services, labor, or material heretofore or hereafter furnished, imposed by law and not shown by the public records.

5. Taxes, or special assessments, if any, not shown as existing liens by the public records.

6. Loss or damage by reason of there being recorded in the public records, any deeds, mortgages, lis pendens, liens or other title encumbrances subsequent to the Commitment date and prior to the effective date of the final Policy.

7. General taxes and assessments for the year 2.010 and subsequent years which are not yet due and payable.

Tax identification no.: 10-11-300-002.-0010 Affects a portion of subject property

Note for informational purposes 2009 taxes:

1st Installment in the amount of $3,42.9.83 with a status of PAID. (Due Date 06/02./2.010) 2.nd Installment in the amount of $3,42.9.83 with a status of PAID. (Due Date 09/02./2.010)

Note: If applicable, an original tax bill must be presented if taxes are to be paid at time of closing.

8. General taxes and assessments for the year 2.010 and subsequent years which are not yet due and payable.

Tax identification no.: 10-11-300-002-0020 Affects a portion of subject property

6

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11

Note for informational purposes 2009 taxes:

1st Installment in the amount of $27,538.76 with a status of PAID. (Due Date 06/02/2010) 2nd Installment in the amount of $27,538.76 with a status of PAID. (Due Date 09/02/2010)

Note: If applicable, an original tax bill must be presented if taxes are to be paid at time of closing.

9. Any lien, or right to a lien in favor of a property manager employed to manage the land. Note: we should be furnished either (a) an affidavit from the owner indicating that: there is no property manager employed; or (b) a final lien waiver from the property manager acting on behalf of the owner.

10. Existing unrecorded leases, if any, and rights of parties in possession under such unrecorded leases.

Upon a conveyance or mortgage of the land, a certified copy of proper resolutions passed by the authorized representative(s) of BP Amoco Chemical Company authorizing the execution of the deed of conveyance or mortgage should be furnished.

12. We should be furnished with a certificate of Good Standing from the Illinois Secretary of State for BP Amoco Chemical Company, a Corporation of Illinois.

13. A copy of the bylaws of the following corporation should be furnished and this commitment is subject to such further exceptions, if any, as may then be deemed necessary: BP Amoco Chemical Company

14. Note: If any contemplated deed of conveyance of the land is exempt from the operation of the provisions of paragraph l(a) of 765 ILCS 205/1, the plat act, such deed should be accompanied by a proper affidavit establishing to the satisfaction of the recorder of deeds of County, Illinois, that the conveyance is so exempt. If said conveyance is not so exempt, compliance should be had with the provisions of said paragraph l(a).

15. Relative to the deletion of Standard Exceptions 1 through 6, we should be furnished the following:

a) A properly executed Extended Coverage Affidavit.

b) A current survey of the land, properly certified to the Company, made in accordance with (i) thE! accuracy requirements of a survey pursuant to the 'Minimum Standard Detail Requirements for Land Title Surveys' Jointly Established and Adopted by the American Land Title Association and Amel-ican Congress on Survey and Mapping October 20, 1999; and (ii) the Laws of the State of Illinois.

c) A properly executed ALTA 2006 Loan and Extended Coverage Statement.

16. Plat of Vacation recorded March 31, 1997 as document no. R99-041601.

17. Illinois Environmental Protection Agency Environmental No Further Remediation Letter recorded April 5, 2004 as document no. R2004057134.

Land Use Restriction: Residential and/or Industrial/Commercial

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21

18. Notice of Obligation to Provide Access pursuant to that certain Supplemental Consent Decree entered June 15, 2000 in the matter of the People of the State of Illinois v. Amoco Chemical Company, case No. 94C0869 recorded July 10, 2000 as document no. R2000072758.

19. Terms, provisions, conditions and easements as contained in the Pipeline Right-of-Way Agreement made by and between BP Amoco Chemical Company and Guardian Pipeline L.L.c. recorded June 25, 2002 as document no. R2002103493.

20. Terms, provisions and conditions as contained in the Boundary Line Agreement made by and between BP Amoco Chemical Company and the State of illinois recorded March 31, 2003 as document no. R2003074463.

Terms, provisions and conditions as contained in the Environmental Indemnification Agreement made by and between Amoco Chemical Company, n.k.a. BP Amoco Chemical Company and the Illinois Department of Natural Resources recorded March 31, 2003 as document no. R2003074464 .

.22. Terms, provisions, conditions and easements as contained in the Declaration of Easement made recorded May 9, 2003 as document no. R2003108362 and re-recorded May 23, 2003 as document no. R2003119224, as amended by document no. R2004083460 and document no. R2006066966.

n. Terms, provisions and conditions as contained in the Environmental Land Use Control made by BP Amoco Chemical Company recorded October 24, 2003 as document no. R2003268133.

24. Terms, provisions and conditions as contained in the Environmental Land Use Control made by BP Amoco Chemical Company recorded October 24, 2003 as document no. R2003268134.

25. Covenants, conditions and restrictions contained in the Declaration of Restrictive Covenants recorded as document no. R2004083461 and re-recorded as document no. R2004085028, as amended and any amendments thereto, relating to, among other things: use restrictions.

26. Terms, provisions, conditions and easements as contained in the Buyer Easement Agreement made by and between BP Amoco Chemical Company and Flint Hills Resources, LP recorded May 28, 2004 as document no. R2004095760.

27. Rights of way for drainage tiles, ditches, feeders and laterals, if any.

28. Rights of the United States of America, State of Illinois, the Municipality and the Public in and to that part of the land lying within the bed of the Des Plaines River; and the rights of other owners of land bordering on the river in respect to the water of said river.

29. Note: The Extended Coverage Endorsement will be considered for approval upon receipt and review of the requirements referenced in exception number 14 above.

NOTE for informational purposes: The final 2006 ALTA Policy issued will contain an arbitration provision. When the Amount of Insurance is $2,000,000 or less, all arbitral matters in dispute shall be arbitrated at the :>ption of either the Company or the Insured and will be the exclusive remedy available to the Parties. You may review a copy of the arbitration rules at http://www.alta.org.

End of Schedule B - Part I MY

8

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Station Id :OBKR'Branch :NPS,User :NP49 Order: 2090548 Title Officer: RV Comment

PREPARED BY:

Gabriel M. Rodriguez, Esq. Schiff Hardin & Waite 6600 Scars Tower Chicago, minois 60606

RETURN TO:

Steven Hernandez, Esq.

UP America Inc.

4101 Winfield Road

Warrenville, IL 60555

R2003268133_ 1

IIY. me. 13.' 11& 11 C.1In~" ....,..

lUll C.....t"

• 213218133 P... 1of 13 pca 0.1.. 11I24/~ fl•• 11143121

hoercU,. ' ••• r n." THE ABOVE SPACE FOR RECORDER'S OFFICE

Environmental Land Use Control

THIS ENVIRONMENTAL LAND USE CONTROL ("ELUC"), is made this 21 st

day ofOctober, 2003, by SP Amoco Ch~ical Company, a Delaware corporation, ("Property

Owner") oC the real property located in Chananhon Township, WiII County, Illinois and

legally described as set forth in Exhibit "A" attached hereto and incorporated by reference

herein. ("Property").

WHEREAS, 415 ILCS SIS8.l7 and 3S nJ. Adm. Code 742 provide for the use of an

ELUe as an institutional control in order to impose land use limitations or requirements

related to environmental contamination 80 that persons conducting remediation can obtain a

No Further Remediation detennination from the Dlinois Environmental Protection Agency

("!EPA"). The reason for an ELUe is to ensure protection of human health and the

environment. The limitations and requirements contained herein are ncccuary in order to

protect against exposure to contaminated soil or groundwater, or both, that may be present on

the Property as a result of the Property Owner's historic operation of two landfills on the on

the Property. Under 3S Ill. Adm. Code 742, the use of risk-based. site-specific remediation

objectives may require the use of an ELUe on real property, and the ELue may apply to

certain physical features (e.g, engineered baniers, monitoring wells, caps, etc.).

ELUe-Retained ProPer!)' (v3)

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Station Td :OBKR· Bmnch :NPS.User :NP49 Order: 2090548 Title Officer: RV Comment:

- ·R2003268133__ 2

WHEREAS, Property Owner intends to request risk-based, site specific soil and

groundwater remediation objcctives from IEPA under 35 III. Adm. Code 742 to obtain risk­

bast:<! closure of sites located on or near the Property utilizing an ELUe, such sites being

identified by IEPA as IL ID No. 1978000001 (Will County) and IL ID No. 1910450056

(Will County).

NOW, THEREFORE, the recitals set forth above arc incorporated by reference as if

fully set forth herein, and the Property Owner agrees as follows:

SectioD ODe. Property Owner docs hereby establish an ELUC on the real estate,

situated in the County of Will, State ofllJinois and further described in Exhibit A.

Attached as Exhibit B are site maps that show the legal boundary of the Property, auy

physical features to which the BLUC applies, tho horizontal and vertical extent of the

contaminants of concern above the applicable remediation objectives for soil or groundwater

or both, and the nature, location of the soutee, and direction of movement of the

contaminants ofconcern, as required under 35 1l1. Adm. Code 742.

Sectiog Two. Property Owner represents and warrants that it is the current owner of

the Property and has the authority to record this ELUC on the chain of title for the Property

"'ith the Office of the Recorder ofDeeds in Will County, Illinois.

SectioD Three. The Property Owner hereby agrees, for itself. and its heirs,

grantees, successors, assigns, transferees and any other owner, occupant, lessee, possessor or

user of the Property or the holder of any portion thereof or interest therein, that:

a. Groundwater which underlies the Property shall not be used for porable

purposes

b. No water supply well shall be installed or otherwilC used for any purposes at

the Property. Installation and use of wells for groundwater monitoring or

remediation activities are not prohibited.

ELUC·Rellined Pnlpert)l (d)

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R2003268133_ 3

c. The Property shaU not be used for any agricultural, recreational or residential

purpose, or in any manner that would allow children to have the opportunity

for exposure to contaminants through soil ingestion or inhalation, including

but not limited to educational facilities, health care facilities, child care

facilities, or outdoor r~reational areas.

SectioD Four, Thi8 ELUe is binding on the Property Owner, its heirs, grantees,

successors, assigns, transferees and any other owner, occupant, lessee, POSSCS!lOT or user of

the Property or the holder ofany portion thereof or interest therein. This BLUC shall apply in

perpetuity against the Property and shall not be released until the IEPA determines there is no

longer a need for this ELUC as an institutional control; until the IEPA, upon written request,

issues a new no further remediation determination approving modification or removal of the

limitation(s) or ~uircment(s); and until and a release or modification of the land use

1 imitation 'or requirCltlent is filed on the chain oftitle for the Property.

Seetloa Fin, Infonnation regarding the remediation that has or will be performed

by the Property Owner on the sites located on or near the Property may be obtained from the

TEPA through a request under the Freedom of Infonnation Act (5 ILCS 140) and rules

promulgated thereunder by providing the IEPA with the identification numbers listed above.

Section Sb:. The effective date ofthis BLUe shall be the date that it is officially

recorded in the chain of title for the Property to which the SLUe applies.

WlTNESS the following signature:

Property Owner

By JOhnT":;U : Authorized Representative

Dale: 21 October 2003

I!l.UC·RNined I'ropcrty (vJ)

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•••••••••••••••••••••••••••

, Branch :NPS,User :NP49 Order: 2090548 Title Officer: RV Comment: Station Id :OBKR

R2003268133._ 4

STATE OF ILLINOIS

) SS:

COUNfYOF )

I, Steven Hernandez. the undersigned. a Notary Public for said' County and State. DO HEREBY CERTIFY, that John T. Dueker, personally known to me to be the Authorized Representative of BP Amoco Chemical Company. and pccaonally known to me to be the same person whose name is subscribed to the foregoing instrument, appeared before me this day in person and 8Cverally acknowledged that in said capacity he signed and delivered the said instrument as his free and voluntary act for the uses and purposes therein set forth.

Notary Public eoPFiClAL lEAL· • I'IIVIN HERNANDEZ :-....... --..-'.... :

.. C '."1" &,Iree ,,,.,,,. :

I!llC-Rctained Propel!)' (v)

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.. -R2003268133._ 5

Exhibit A

(ELUC AREA RETAINED BY SP AMOCO CHEMICAL COMPANY)

1hc subjcct property is locat~ in the Township of Chananhon, COl.D1ty of Will, State of Illinois and more particularly d~cribed as: . .

THAT PART OF THE WEST HALF OF FRACTIONAL SECTION II AND THE EAST HALF OF SECTION 10, ALL IN TOWNSHIP 34 NORTH, RANGE 9 EA.ST, OF THE TIURD PRINCIPAL MERIDIAN, DESCRmED AS FOLLOWS:

COMMENCING AT THE NORTHWEST CORNER OF SAlD FRACTlONAL SECTION II; THENCE SOUTH 00 DEGREES 22 MINUTES 35 SECONDS WEST, ALONO THE WEST LINE OF THE NORTHWEST QUARTER OF SAID FRACTIONAL SECTION II, 2403.25 FEET TO THE POINT OF BEGINNING; THENCE NORTH 90 DEGREES 00 MINUTES 00 SECONDS EAST, 962.38 FEET; THENCE SOUTH 73 DEGREES 47 MINUTES OS SECONDS EAST, 443.75 FE3T TO THE LINE BETWEEN BP AMOCO CHEMICAL COMPANY AND THE STATE OF ILLINOIS, ACCORDING TO THE BOUNDARY LINE AGREEMENT RECORDED MARCH 31, 2003 AS DOCUMENT R2003074463; TIJENCE SOUTH 11 DEGREES 3S MINUTES .52 SECONDS WEST, 19.40 FEET; THENCE SOUTH 13 DEGREES 56 MfNUTES 18 SECONDS WEST, 102.86 FEET TO THE NORTII LINE OF TIlE SOUTHWEST QUARTER OF SAID FRACTIONAL SECTION II; 11IENCE SOUTH 19 DEGREES 28 MINUTES 21 SECONDS WEST, 78.15 FEET; THENCE SOUll{ 16 DEGREES 46 MINUTES 10 SECONDS WEST, 111.28 FEET; THENCE SOlJTIl 08 DEGREES 30 MINUTES 22 SECONDS WEST, 127.28 FEET; THENCE soum 00 DEGREES 57 MINUTES 11 SECONDS WEST, 104.71 FEET; THENCE SOUTH 02 DEGREES 34 MINUTES 13 SECONDS WEST, 121.65 FEET; THENCE SOUTH 02 DEGREES 47 MINUTES 35 SECONDS EAST, 98.05 FEET; THENCE SOUTH 00 DEGREES 51 MINUTES 31 SECONDS EAST, lOO.25 FEET; THENCE SOUTH 06 DEGREES 00 MINUTES 49 SECONDS EAST, 53.05 FEET; THENCE SOUTH 04 DEGREES 06 MINUTES 43 SECONDS EAST, 139.59 FEET; THENCE SOUTH 12 DEGREES 10 MINUTES 49 SECONDS WEST, 95.47 FEET; THENCE SOUTH 34 DEGREES 36 MINUTES 35 SECONDS WEST, 118.50 FEET; THENCE SOtrrH 25 DEGREES 06 MrNUTES 06 SECONDS WEST, 58.77 FEET; THENCE SOUTH 23 DEGREES 51 MINUTES 41 SECONDS WEST, 97.50 FEET; THENCE SOUfH 20 DEGREES 31 MINUTES 17 SECONDS WEST, 199.60 FEET; THENCE SOUTH 39 DEGREES 39 MINUTES 38 SECONDS WEST, 157.18 FEET; THENCE SOUTH 37 DEGREES 33 MINUTES 19 SECONDS WEST, 84.22 FEET; THENCE SOUTH 35 DEGREES 05 MINUTES 49 SECONDS WEST, 138.34 FEET; THENCE SOUTH 26 DEGREES 12 MINUTES 55 SECONDS WEST, 120.00 FEET; THENCE SOUTH 18 DEGREES 13 MINUTES 40 SECONDS WEST, 55.36 FEET; THENCE SOUTH 30 DEGREES 06 MINUTES 32 SECONDS WEST, 67.37 FEET; THENCE SOUTH 25 DEGREES 44 MINUTES 33 SECONDS WEST, 81.98 FEET; THENCE SOUTH 21 DEGREES 28 MINUTES 31 SECONDS WEST, 86.3$ FEET; THENCE SOUTH 27 DEGREES 44 MINUTES 29 SECONDS WEST, 34.29 FEET; THENCE SOUTH 30 DEGREES 45 MIJ\UfES 53 SECONDS WEST, 53.87 FEET; THENCE SOUTH 26 DEGREES 47 MINUTES 03 SECONDS WEST, 81.44 FEET; THENCE SOUTH 27 DEGREES 04 MINUTES 14 SECONDS WEST, 18.03 FEET; THENCE SOUTH 26 DEGREES 31 MINUTES 58 SECONDS WEST, 36.37

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Station Id :OBKR Branch .'JPS,User :NP49 Order: 2090548 Title Officer: R V Comment:

R2003268133__ 6

FEET; THENCE SOUTH :32 DEGREES 39 MINUI'ES 01 SECONDS WEST, 17.43 FEET~ TIIENCE SOUTH 26 DEGREES 44 MINUTES 09 SECONDS WEST, 102.05 FEET; THENCE SOtrrH 20 DEGREES 37 MINUTES 1 S SECONDS WEST, 48.63 FEET; THENCE SOUTH 29 DEGREES 32 MINUTES 46 SECONDS WEST, 146.16 FEET; THENCE SOUTH 24 DEGREES 23 MINUTES 47 SECONDS WEST, 56.38 FEET TO TIlE SOUTH LINE OF THE SOUTHWEST QUARTER OF SAID FRACTIONAL SECTION 11; TIIENCE SOUTH 90 DEGREES 00 MI:NUTES 00 SECONDS WEST, ALONG SAID SOUTH LINE, 415.53 FEET TO THE SOUTHWEST CORNER OF SAID FRACTIONAL SECTION 11; THENCE NORTIi 44 DEGREES J5 MINUTES 07 SECONDS WEST, 823.09 FEET; THENCE NORTH 00 DEGREES 00 MINUfES 00 SECONDS EAST, 551.86 FEET; THENCE NORTH 14 DEGREES 13 MINUTES S9 SECONDS EAST, 175.03 FEET; THENCE NORTH 00 DEGREES 00 MINUTES 00 SECONDS EAST, 429.09 FEET; THENCE NORTII 04 DEGREES 13 MJNUTES 03 SECONDS WEST, 175.63 FEET; THENCE NORTH 06 DEGREES 58 MINUTES 41 SECONDS WEST, 255.11 FEET; THENCE NORTH 00 DEGREES GO MINUTES 00 SECONDS EAST, 718.30 FEET; THENCE NORTH 90 DEGREES 00 MINUTES 00 SECONDS EAST, 590.10 FEET TO THE POINT OF BEGINNING; IN WILL COUNTY, ILLINOIS.

Parcel Identification Numbers (PlN) Associated with ELUC Area Retained by BP

PIN 10-10-200-001-0000 PIN 10-11-100-001-0020 PIN 10-10-400-004-0000 PIN 10-11-100-001-0010 PIN 10-10-400-005-0000 PIN 10-)0-400'()03-0000

Common Address: 23425 Amoco Road Channahon, Illinois 60410

p:\\ ilJe\bp _ amoco\7066\j.5\1egll-dc:3C-elue area retained by bp.dOl;

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Document: NTC 2003.268133

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Document: I'TC 2003,268133

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Document: NTC 2003.268133

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WILL,IL Page 12 of 13 Printf;d on 81181201012:30:13 PM

Document: NTC 2003.268133

Page 130: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

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SOURCE LOCATION AND DIRECllON OF CONTAMINANT MIGAATlON

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Page 131: Second Five-Year Review Report for Amoco … · for Amoco Chemicals (Joliet Landfill) Will County, ... BP Amoco Technical Consultants ... Amoco Chemicals Has 'te b I t' t e se? YES

Station Id ;OBKROrder: 2090548 Title Officer: RV Comment:Branch :NPS.User :NP49

PREPARED BY:

Gabriel M. Rodriguez, Esq. SchiffHardin &; Waite 6600 Sears Tower Chicago. minois 60606

RETURN TO:

Sleven Hernandez, Esq.

BP America Inc.

4101 Winfield Road

Warrenville, JL 60555

R2003268134 _ 1

l'Wi 11 C,,".y 11..,.41.­W,ll c.wnt.v

R_134 Plitt M13 PCl De". 11114/_' n .. UI4S.2I ....,...,,'" ,... 2'7."

THE ABOVE SPACE FOR RECORDER'S OFFICE

Environmenta' Land yse Coatrol

THIS ENVIRONMENTAL LAND USB CONTROL ("BLue''). is made this 21st

day of October, 2003, by BP Amoco Chemical Company, a Delaware corporation. ("Property

Ownerj of the real property located in Chananhon Township, Will County, Illinois and

legally described as set forth in Exhibit "A" anached hereto and incoIpOrated by reference

herein. ("Property").

WHEREAS, 415 ILCS 5158.17 JIld 35 III. Adm. Code 742 provide for the use of an

BLue as an institutional control in order to impose land use limitations or requirements

related to environmental contamination so that pcrSOI15 conducting remediation can obtain a

No Further Remediation detennination from the minois Environmental Protection Agency

("IEPA'1. The reason for an BLUC is to ensure protection of human health and the

environment. The limitations and requirements contained herein arc necessary in order to

protect againsr exposure to contaminarcd soil or groUJ'ldwater. or both, that may be present on

the Property IIlI a result of the Property Owner's historic operation of a chemical

manufacturing plant on the Property. Under 3S TIL Adm. Code 742, the use of risk-based,

$ile-specific remediation objectives may require the use oran ELUe on real propeny. and the

BLUe may apply to certain physical features (e.g, engineen:d barrien, monitoring wells,

l:apS, etc.).

n.uc Tr.nal'cmd Propeny (.3)

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Station Id :OBKROrder: 2090548 Title Officer: RV Comment:Branch :NPS,User :NP49

R2003268134_ 2

WHEREAS, Property Owner intends to request risk-based, site specific soil and

groundwater remediation objectives from IEPA under 35 Ill. Adm. Code 742 to obtain risk­

based closure of sites located on or n~r the Property utilizing an ELUe. such sites being

identified by lEPA as IL 10 No. 1978000001 (Will County) and IL lD No. 1970450056

(Will County).

NOW, THEREFORE, the recitals set forth above are incorporated by reference as if

fully set forth herein. and the Property Owner agrees as follows:

Section Ope. Property Owner does hereby establish BJl ELUC on the real estate,

situated in the County of Will, State of Illinois and further described in Exhibit A.

Attached as Exhibit B are site maps that show the leBal boundary of the Property, any

pbysical features to which the BLUe applies, the horizontal and vertical extent of the

contaminants of concern above the applicable remediation objectives for soil or groundwater

or both, and the nature, location of the source. and direction of movement of the

contaminants ofconcem, as required under 35 DI. Adm. Codo 742.

SectJoD Two. Property Owner represents and warrants that it is the current owner of

the Property and has the authority to record this BLUe on the chain of title for the Property

with the Office ofthc RccorderofDeeds in Will County, Illinois.

SeedoD Tbres. The Property Owner bereby aarces. for irsclf, and its heirs,

grantees. successon, assigns. transferees and any other owner, o~pant, lessee, possessor or

user of the Property or the holder ofany portion thereof or interest therein, tbat:

a. Groundwater which underlies the Property shall not be used for potable

purposes regardless of the depth of the well.

b. No water supply well shall be installed or otherwise used f(lr any purposes at

the Property. Installation and use of wells for groundwater monitoring or

remediation activities are not prohibited.

c. The Property shall not be used for any agricultural, recreational or residential

purpose, or in any manner that would allow children to have the opportunity

for exposure to contamin8llts through lOil ingestion or inhalation, including

EllJC TmlSfcneoll'~ ('11)

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R2003268134_ 3

but not limited to educational facilities, health care facilities, child care

facilities, or outdoor recreational areas.

Sectton Four. This ELve is binding on the Property Owner,its heirs. grantees,

SUCCDSSOrs, assipls, transferees and any other owner, occupant, lessee, possessor or user of

the Property or the holder of any portion thereof or interest therein. This ELUC shall apply in

perpetuity against the Property and shall not be released WItil the (EPA determines there is no

longer a need for this ELUe as an institutional control; until the IEPA, upon written request,

ISSUes a DCW no further remediation determination approving modification or removal of the

limitation{!) or requirement(s); and until and a release or modification of the land use

limitation or requirement is filed on the chain oftitle for the Property.

Sedlo. Five. Information regarding the remediation that has or will be performed

by the Property Owner on the sites located on or near the Property may be obtained from the

rEPA through a request under the Freedom of Information Act (5 lLCS 140) and rules

promulgated thereunder by providing thalBPA with tha identification numbers listed above.

SectloD Six. The effective date of this ELUe shall be the date that it is officially

recorded in the chain oftitle for the Propeny to which the ELUC applies.

WITNESS the following signature:

Property Owner

s Authorized Representative

ate: 21 October 2003

FLuc Tl2IIJremd Propen)' (vl)

WILL,IL Page 3 of 13 Printed on 811812010 12:30:10 PM

DClcument: t\TC 2003.268134

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Station Id :OBKROrder: 2090548 Title Officer: R V Comment:Bran.;h :NPS,User :NP49

R2003268134_ 4

STATE OF ILLINOIS )

)SS:

COUNTY OF )

I, Steven Hernandez, the undersigned, a Notary Public for said County and State, DO HEREBY CERTIFY, that John T. Dueker, personally known to me to be the Authorized Representative of BP Amoco Chemical Company, and personally known to me to be the same person whose name is subscribed to the foregoing instrument, appeared before me this day in person and severally acknowledged that in said capacity he signed and delivered the said instrument as his free and voluntary act for the uses and purposes therein set fonh.

d and official seal, this 21 st day of October 2003.

ti·....······..·;,..-...cw.IUL· ....HIRNANDIZ...,MIIir" ..........

_ ...n" ' ..... '"............................1

auc TlSlllfemd Propcny (vl)

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1 ---

Station Id :OBKRBranch :NPS,User :NP49 Order: 2090548 Title Officer: RV Comment:

R2003268134 _ 5

Exhibit A

(ELUC AREA TRANSFERRED WITH PLANT SALE)

THAT PART OF THE NORTHWEST QUARTER OF FRACTIONAL SECTION II, THE EAST HALF OF SECTION 10, AND THE NORTHEAST QUARTER OF SECTION IS, ALL IN TOWNSHIP 34 NORTH, RANGE 9 EAST, OF THE THIRD PRiNCIPAL MERIDIAN, DESCRIBED AS FOLLOWS:

COMMENCING AT THE NORTHWEST CORNER OF SAID FRACfIONAL SECTION 11; THENCE SOUTH 00 DEGREES 22 MINUTES 35 SECONDS WEST, ALONG THE WEST LINE OF THE NOR1HWEST QUARTER OF SAID FRACTIONAL SECTION 11, 1999.93 FEET TO THE POINT OF BEGINNING; THENCE NORTH 90 DEGREES 00 MINUTES 00 SECONDS EAST, 151S.73 FEET TO THE LINE BETWEEN BP AMOCO CHEMICAL COMPANY AND THE STATE OF ILLiNOIS, ACCORDING TO TIlE BOUNDARY LINE AGREEMENl' RECORDED MARCH 31, 2003 AS DOCUMENT Rl003074463; THENCE SOUl1l21 DEGREES 25 MINUTES 07 SECONDS WEST, 14.81 FEET; THENCE SotITH 16 DEGREES 3S MINUTES 49 SECONDS WEST, 141.29 FEET; THENCE SOUTH 13 DEGREES 35 MINUTES 34 SECONDS WEST, Il5.32 FEET; THENCE SOUTH II DEGREES 43 MlNUTES 58 SECONDS WEST, 118.2S FEET; TIIENCE SOUTH \2 DEGREES 48 MINUTES 59 SECONDS WEST, 100.22 FEET; THENCE SOUTH 11 DEGREES 35 MINUTES 52 SECONDS WEST, 53.54 FEET; THENCE NORTH 73 DEGREES 47 MINUTES 05 SECONDS WEST, 443.75 FEET; THENCE SOUTH 90 DEGREES 00 MINUTES 00 SECONDS WEST, 1552.48 FEET; mENCE SOUTH OCI DEGREES 00 MINUTES 00 SECONDS WEST, 718.30 FEET; THENCE SOUTH 06 DEGREES 58 MINUTES 41 SECONDS EAST, 255.11 FEET; THENCE SOUTH 04 DEGREES ]3 MINUTES; 03 SECONDS EAST, 175.63 FEET; THENCE SOUTH 00 DEGREES 00 MINUTES OC· SECONDS WEST, 429.09 FEET; THENCE SOUTH 14 DEGREES 13 MINUTES S9 SECONDS WEST, 175.03 FEET; THENCE SOUTH 00 DEGREES 00 MINUTES 00 SECONDS WEST, 551.86 FEET; THENCE SOurH 44 DEGREES IS MINUTES 07 SECONDS EAST, 823.09 FEET TO THE NORTHEAST CORNER OF SAID SECTION 15; THENCE SOUTH 00 DEGREES 17 MINUTES I S SECONDS WEST, ALONG THE EAST LINE OF THE NORTHEAST QUARTER OF SAID SECTION 15,395.47 FEET TO THE TOP OF BANK. OF THE DES PLAlNES RIVER; TliENCE SOUTH 67 DEGREES 25 MINUTES 08 SECONDS WEST, ALONG SAID TOP OF BANK, 85.75 FEET; THENCE NORTH 44 DEGREES IS MINUTES 007 SECONDS WEST, 1247.49 FEET; THENCE NORTH 00 DEGREES 17 MINUTES 15 SECONDS EAST, 1195.25 FEET; THENCE NORTH 89 DEGREES 37 MINUTES 20 SECONDS WEST, 201.00 FEET; THENCE NORTH 00 DEGREES 17 MINUTES ] 5 SECONDS EAST, 990.00 FEET TO THE NORTH LINE OF THE SOUTHEAST QUARTER OF SAID SECTION 10; THENCE NORTH 00 DEGREES 00 MINUTES 00 SECONDS EAST, 561.63 FEET; THENCE NORTH 90 DEGREES 00 MINUTES 00 SECONDS EAST, 589.12 FEET; THENCE NORTH 00 DEGREES 00 MINUTES 00 SECONDS EAST, 76.82 FEET; THENCE NORTH 90 DEGREES 00 MINUTES 00 SECONDS EAST, 570.10 FEET TO THE POINT OF BEGINNING; IN WILL COUNTY, ILLINOIS.

S./

WILL.lL Page 5 of 13 Printed on 8/1812010 12:30:10 PM

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Branch :NPS,User :1\P49 Order: 2090548 Title Officer: RV Comment: Station ld :OBKR

R2003268134_ 6

Parcel Identification Numbers (PIN) Associated with ELUC Area Transferred with Plant Sale

PIN 10-11-100-001-0020 PIN 10-10-200-001-0000 PIN 10-10-400-004-0000 PIN 10-10-400-003-0000 PIN 10-10-400-005-0000 PIN 10-15-200-003-0000

Common Address: 23425 Amoco Road, Channahon, Dlinois 60410

p;\Iisle\bp_lmoco\7066'!iS\lelal-desc-eluc area tnDsfened with plant ..Ie.doc

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HORIZONTAl EXTENT OF GROUNDWATER CONTAMINATION BP AMOCO JOLIET lANDFllllWO SRP SliE AREA

Joliet, //IJnoi:;,

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Station [d :OBKRBranch :NPS,User :NP49 Order: 2090548 Title Officer: RV Corrunent:

R2003266134_ 9

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D()cument: NTC 2003,268134

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