Speedway LLC

Speedway Office P.O. Box 1500 November 17, 2017 Springfield, OH 45501 Telephone 937-864-3000 Mr. Wayne Zuehlke Environmental Protection Agency Bureau of Land - #24 Leaking Underground Storage Tank Section 1021 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 62794-9276

Re: Corrective Action Plan and Budget LPC #0430835011 - DuPage County Warrenville / Speedway LLC No. 7146 2S540 Route 59 Leaking UST Incident #20150891 Leaking UST Technical File

Dear Mr. Zuehlke:

Speedway LLC is pleased to provide the Illinois Environmental Protection Agency with the attached Corrective Action Plan and Budget prepared for Speedway LLC No. 7146. The following document was prepared by Practical Environmental Consultants, Inc. in response to the release associated with incident number 20150891.

If you have any questions or need additional information, please do not hesitate to contact the undersigned at (937) 863-7224.

Sincerely,

SPEEDWAY LLC

J. Travis Powell Environmental Representative

Copy: Remediation File Store No. 7146 Reimbursement File Store No. 7146 Jenny Roether (PEC)

CORRECTIVE ACTION PLAN AND BUDGET

Site:

Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261

LPC # 0430835011 – DuPage County Leaking UST Incident #20150891 LEAKING UST TECHNICAL FILE

Prepared for:

SPEEDWAY LLC P.O. Box 1500 Springfield, Ohio 45501-1500 Phone: (937) 864-3000

Prepared by:

PRACTICAL ENVIRONMENTAL CONSULTANTS, INC. 1305 Remington Road, Suite A Schaumburg, Illinois 60173-4820 Phone: (847) 519-3430 Website: www.pec-inc.com

November 17, 2017

TABLE OF CONTENTS

Section Page

D. Soil and Groundwater Investigation Results ...... 1

E. Technical Information – Corrective Action Plan ...... 5

F. Exposure Pathway Exclusion ...... 16

Appendices

FIGURES ...... APPENDIX A

DATA TABLES ...... APPENDIX B

LABORATORY ANALTYICAL REPORT ...... APPENDIX C

TIER 2 SOIL REMEDIATION OBJECTIVES ...... APPENDIX D

TACO GROUNDWATER MODELING ...... APPENDIX E

HIGHWAY AUTHORITY AGREEMENT APPLICATION FORM ...... APPENDIX F

PROPOSED CORRECTIVE ACTION PLAN BUDGET ...... APPENDIX G

Corrective Action Plan and Budget Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261 Leaking UST Incident No. 20150891

D. Soil and Groundwater Investigation Results (for incidents subject to 35 Ill. Adm. Code 731 only or 732 that were classified using Methods One or Two, if not previously provided)

Practical Environmental Consultants, Inc. (PEC) was retained by Speedway LLC (Speedway) to prepare this Corrective Action Plan (CAP) and Budget for Leaking Underground Storage Tank (LUST) incident number 20150891 associated with Speedway LLC No. 7146, located at 2S540 Route 59 in Warrenville, DuPage County, Illinois (the site). Please note that Speedway purchased the land located north of the site at 2S480 Route 59 (parcel ID 0427301015) on August 30, 2017. The site layout plan has been updated to reflect the new land addition.

Provide the following: 1. Description of investigation activities performed to define the extent of soil and/or groundwater contamination;

Site Description The site is an active petroleum retailer/convenience store owned and operated by Speedway. The site is located on the northwest corner of the intersection of Route 59 and Batavia Road in the NW¼ of the NW¼ of the SW¼ of Section 27, Township 39 North, Range 9 East of the Third Principal Meridian, in DuPage County, Illinois. The site currently contains six underground storage tanks (USTs), which includes two 8,000-gallon regular unleaded (RUL) gasoline USTs which are manifolded together, one 8,000-gallon midgrade unleaded gasoline UST, one 8,000-gallon premium unleaded gasoline UST, one 8,000-gallon bio-diesel fuel UST, and one 4,000-gallon kerosene UST. These six USTs were installed on May 1, 1989.

The station building is located in the southern portion of the site with the fuel dispensers and associated canopy located to the east and a common basin for the USTs located to the northeast. The kerosene dispenser is located northeast of the station building. A general site location map and a site layout map are provided as Figures 1 and 2, Appendix A. An aerial photograph depicting the site and surrounding properties is provided as Figure 3, Appendix A.

On August 13, 2015, Speedway’s environmental consultant, PEC, was on-site after speaking with a Speedway maintenance technician who stated that approximately 0.9 feet of free product was observed to be contained within the RUL gasoline submersible turbine pump (STP) sump of

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UST #4. The RUL STP sump was checked after multiple line test failures occurred. Speedway maintenance technicians bailed out approximately 10 gallons of a free product/water mixture, and recognized that the RUL STP sump continued to refill with product. The RUL line was shut down until repairs and line testing were completed. Based on visual observations made by PEC, product may have reached the top of the STP sump; therefore, a release of unleaded gasoline was reported to the Illinois Emergency Management Agency and subsequently, incident number 20150891 was assigned to the release. The release point for incident number 20150891 is shown on Figure 2, Appendix A.

Site history with respect to the release for site investigation was previously provided to the Illinois Environmental Protection Agency (Illinois EPA) in the Site Investigation Completion Report (SICR), dated April 21, 2017, which was approved in a letter dated August 29, 2017.

On September 18, 2017, a Speedway representative was on-site to collect groundwater samples from monitoring wells MW-02 and MW-06 to obtain current groundwater data. The groundwater samples were collected into three laboratory-prepared 40-milliliter (mL) vials with Teflon-lined lids and hydrochloric acid preservative using a disposable bailer. The vials were filled with no headspace and inspected for air bubbles to minimize the volatilization of volatile organic compounds (VOCs). The groundwater samples were packed on ice and shipped to Pace Analytical Services, LLC for laboratory analysis of benzene, toluene, ethylbenzene, total xylenes (BTEX), and methyl tertiary butyl ether (MTBE) compounds.

Benzene was detected above the Tier 1 Class I Groundwater Remediation Objective (GRO) in the groundwater sample collected from monitoring well MW-02, and MTBE was detected above the Tier 1 Class I GRO in the groundwater sample collected from monitoring well MW-06.

2. Analytical results, chain-of-custody forms, and laboratory certifications;

The analytical laboratory report, chain-of-custody form, and laboratory certification for the September 18, 2017, groundwater sampling event are provided in Appendix C. All other analytical laboratory reports, chain-of-custody forms, and laboratory certifications were previously submitted to the Illinois EPA. The analytical results of soil samples collected at the site for incident number

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20150891 are shown on Figure 4, Appendix A. A potentiometric surface map for groundwater elevations measured on March 6, 2017, is shown on Figure 5, Appendix A. Groundwater analytical data for samples collected between June 2016 and September 2017, is shown on Figure 6, Appendix A.

3. Tables comparing analytical results to applicable remediation objectives;

Tables summarizing the soil, groundwater, and soil gas data associated with incident number 20150891 are provided in Tables 1 through 4, Appendix B. Exceedances of the applicable Tier 1 remediation objectives are shown in bold.

4. Boring logs;

All soil boring logs were previously submitted to the Illinois EPA.

5. Monitoring well logs; and

All monitoring well completion reports were previously submitted to the Illinois EPA.

6. Site maps meeting the requirements of 35 Ill. Adm. Code 732.110 (a) or 734.440 and showing: a. Soil sample locations; b. Monitoring well locations; and c. Plumes of soil and groundwater contamination.

The site maps in Appendix A provide: 1) Sufficient detail and accuracy to show required information; 2) The map scale, an arrow indicating north orientation, and the date the map was created; 3) The property boundary lines of the site, properties adjacent to the site, and other properties that are, or may be, adversely affected by the release; 4) The uses of the site, properties adjacent to the site, and other properties that are, or may be, adversely affected by the release; 5) The locations of all current USTs at the site, and the contents of each UST; and 6) All structures, other improvements, and other features at the site, properties adjacent to the site, and other properties that are, or may be, adversely affected by the release, including but not limited to buildings, dispenser islands, canopies, roadways and other paved areas,

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utilities, easements, Right-of-Ways (ROWs), and actual or potential natural or man-made pathways.

There are three former USTs which were installed at the site in 1970: two 10,000-gallon gasoline USTs and one 6,000-gallon gasoline UST. These three tanks were removed from the site on May 1, 1989, according to the Office of the Illinois State Fire Marshal website. There are no maps available of the site from this time; therefore, the location of the former USTs is not known, and they are not shown on the site maps provided in Appendix A.

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E. Technical Information - Corrective Action Plan Provide the following: 1. Executive summary identifying the objectives of the corrective action plan and the technical approach to be utilized to meet such objectives; a. The major components (e.g., treatment, containment, removal) of the corrective action plan; b. The scope of the problems to be addressed by the proposed corrective action; and

Tier 1 Remediation Objectives Evaluation The soil and groundwater sample analytical data provided in Tables 1 and 3, Appendix B, were compared to the Tier 1 Class I Soil Remediation Objectives (SROs) for residential and industrial/commercial properties as identified in Appendix B, Tables A and B, of Title 35 of the Illinois Administrative Code Part 742 (35 IAC 742) and the Tier 1 Class I Groundwater Remediation Objectives (GROs) as identified in 35 IAC 742, Appendix B, Table E.

Tier 1 Soil Investigation Results Comparison of the soil sample analytical data with the applicable Tier 1 SROs as included in 35 IAC 742 indicates the following:

Soil Saturation Limits: None of the indicator contaminants were detected in concentrations that exceeded the soil saturation limits.

Outdoor Inhalation Exposure Route Residential Inhalation Exposure Route: Benzene was detected at concentrations exceeding the Tier 1 SRO (0.8 milligrams per kilogram [mg/kg]) for this exposure route in soil samples SB-2 (4’) and SB-10 (3’).

Industrial/Commercial Inhalation Exposure Route: Benzene was detected at concentrations exceeding the Tier 1 SRO (1.6 mg/kg) for this exposure route in soil sample SB-2 (4’) and SB-10 (3’).

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Construction Worker Inhalation Exposure Route: Benzene was detected at a concentration exceeding the Tier 1 SRO (2.2 mg/kg) for this exposure route in soil sample SB-2 (4’). Toluene was detected at a concentration exceeding the Tier 1 SRO (42 mg/kg) for this exposure route in soil sample SB-2 (4’). Total Xylenes was detected at a concentration exceeding the Tier 1 SRO (5.6 mg/kg) for this exposure route in soil sample SB-2 (4’).

Ingestion Exposure Route Residential Soil Ingestion Exposure Route: None of the indicator contaminants were detected in concentrations exceeding the Tier 1 SROs for this exposure route.

Industrial/Commercial Soil Ingestion Exposure Route: None of the indicator contaminants were detected in concentrations exceeding the Tier 1 SROs for this exposure route.

Construction Worker Soil Ingestion Exposure Route: None of the indicator contaminants were detected in concentrations exceeding the Tier 1 SROs for this exposure route.

Soil Component of the Groundwater Ingestion Route (SCGIER) Tier 1 Class I SCGIER: Benzene was detected at concentrations exceeding the Tier 1 SRO (0.030 mg/kg) for this exposure route in soil samples SB-02 (4’), SB-03 (4’), SB-10 (3’), SB-16 (3’), SB-20 (3’), SB-21 (3’), and SB-22 (3’). Toluene was detected at a concentration exceeding the Tier 1 SRO (12 mg/kg) for this exposure route in soil sample SB-02 (4’). Ethylbenzene was detected at a concentration exceeding the Tier 1 SRO (13 mg/kg) for this exposure route in soil sample SB-02 (4’). MTBE was detected at a concentration exceeding the Tier 1 SRO (0.320 mg/kg) for this exposure route in soil sample SB-21 (3’).

The soil sample analytical results are shown on Figure 4, Appendix A, and presented in Table 1, Appendix B.

Tier 2 Remediation Objectives Evaluation Because exceedances of the Tier 1 SROs have been identified with the current site soil data, Tier 2 SROs for surface and subsurface soil samples were calculated. Surface soil samples are those that are collected from within one meter of the ground surface, and subsurface soil samples

Practical Environmental Consultants, Inc. Page 6 November 17, 2017 Corrective Action Plan and Budget Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261 Leaking UST Incident No. 20150891 are those that are collected from deeper than one meter below the ground surface (bgs). Specifically, Tier 2 SROs were calculated for the industrial/commercial inhalation, construction worker inhalation, and/or mass-limit of the soil component of the Class I groundwater ingestion exposure routes for benzene, toluene, ethylbenzene, total xylenes, and MTBE. The surface and subsurface Tier 2 SROs were calculated in accordance with 35 IAC 742, Subparts F and G. The Soil Screening Level (SSL) equations provided in 35 IAC 742, Table A, Appendix C, were used to develop the Tier 2 SROs.

The values used in the Tier 2 calculations were previously presented to the Illinois EPA in a laboratory report in the SICR dated April 21, 2017, which was approved in a letter dated August 29, 2017. The laboratory report was for the sample collected on February 20, 2017, from geotechnical sample GT-01. Geotechnical soil boring GT-01 was advanced in a non-impacted area of the site to an approximate depth of five feet bgs, and a Shelby tube sample was collected from between three and five feet bgs. The foc was determined through laboratory analysis to be 0.840% (weight/weight [w/w]) and is presented in Table 2, Appendix B. The average dry soil bulk density was calculated to be 101.3 pounds per cubic foot (1.62 grams per cubic centimeter [g/cm3]).

Groundwater elevation data collected on March 6, 2017, was used to calculate the hydraulic gradient value (i) for the site. That value is 0.0101 (please refer to Figure 5, Appendix A, for the hydraulic gradient calculation). Depth of source is approximately 3.75 feet, according to the cross sections provided in the SICR dated April 21, 2017.

On March 6, 2017, rising-head slug tests were performed on monitoring wells MW-05, MW-08, and MW-09. Hydraulic conductivity analysis was conducted using Aqtesolv software to calculate the hydraulic conductivity of the unconfined aquifer using the Bouwer-Rice method. The hydraulic conductivity at the site was determined to be 2.718 x 10-4 centimeters per second (cm/s) at monitoring well MW-05, 8.517 x 10-4 cm/s at monitoring well MW-08, and 1.593 x 10-4 cm/s at monitoring well MW-09. The hydraulic conductivity test results from the Aqtesolv software were previously submitted to the Illinois EPA in the SICR dated April 21, 2017.

The detailed Tier 2 SRO calculations are provided in Appendix D. The applicable Tier 1 and Tier 2 SROs proposed for the site are provided below in Chart 1.

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Chart 1 APPLICABLE TIER 1 AND TIER 2 SOIL REMEDIATION OBJECTIVES (mg/kg) SPEEDWAY LLC No. 7146 Industrial/ Construction Industrial/ Construction Commercial Worker SCGIER Soil Commercial Worker Inhalation Inhalation (Class I) Indicator Saturation Ingestion Ingestion Exposure Exposure (Tier 1/ Contaminants Limits Exposure Exposure Route Route Tier 2) (Tier 1) Route Route (Tier 1/ (Tier 1/ (Tier 1) (Tier 1) Tier 2) Tier 2) Benzene 580 23(1) 100 478(1) 2,300 0.68 (1) Toluene 290 650 410,000 2,450(1) 410,000 136 (1) Ethylbenzene 150 400 200,000 58 20,000 95 (1) Total Xylenes 110 320 410,000 613(1) 41,000 150 MTBE 8,400 8,800 20,000 140 2,000 10 (1) Notes: SCGIER – Soil Component of the Groundwater Ingestion Exposure Route (1) –Calculated Tier 2 SRO

Soil Evaluation Results A comparison of the soil sample analytical data presented in Table 1, Appendix B, to the Tier 1 and Tier 2 SROs indicated the following:

Industrial/Commercial Inhalation Exposure Route: None of the indicator contaminants were detected in concentrations exceeding the Tier 2 SROs for this exposure route.

Construction Worker Inhalation Exposure Route: None of the indicator contaminants were detected in concentrations exceeding the calculated Tier 2 SROs for this exposure route.

Soil Component of the Class I Groundwater Ingestion Exposure Route: Benzene was detected at concentrations exceeding the Tier 2 SRO (0.68 mg/kg) in soil samples SB-02 (4’), SB-03 (4’), and SB-10 (3’).

Groundwater Evaluation Results A comparison of the groundwater sample analytical data presented in Table 3, Appendix B, to the Tier 1 Class I GROs indicated the following:

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Groundwater Component of the Groundwater Ingestion Exposure Route for Class I Groundwater: Based upon the groundwater sampling events conducted on September 3, 2015, June 20, 2016, March 6, 2017, March 30, 2017, and September 18, 2017, benzene, toluene, and ethylbenzene were detected above the Tier 1 Class I GROs in the groundwater sample collected from well MW-02. Additionally, MTBE was detected at a concentration above the Tier 1 Class I GRO in the groundwater sample collected from well MW-06. The groundwater sample analytical results are shown on Figure 6, Appendix A, and presented in Table 3, Appendix B.

Groundwater Modeling and Soil-to-Groundwater Modeling Using the soil sample concentrations that exceed the Tier 2 SROs and the groundwater sample concentrations that exceed the Tier 1 Class I GROs, Tiered Approach to Corrective Action Objectives (TACO) modeling was performed using Risk-Based Corrective Action (RBCA) and SSL equations found in 35 IAC 742, Appendix C, Tables A and C to determine the predicted future extent of impacted groundwater from the source area. TACO soil modeling was performed using only those (three) soil sample concentrations that exceed the Tier 2 SROs calculated for this CAP. Four other soil samples that exhibited only Tier 1 exceedances were not used in the TACO modeling. The soil concentrations of the contaminants were multiplied by a leaching factor to obtain the predicted leached groundwater concentration. This leached groundwater concentration was then used as a source groundwater concentration in Equation R26 to determine the compliance distance at which the contaminants would meet the Tier 1 Class I GROs. The maximum groundwater modeling compliance distances to achieve the Tier 1 Class I GROs are provided in Chart 2 below. All modeled groundwater impacts remain on the site property with the exception of the compliance distance for MTBE at monitoring well MW-06, which extends into the Route 59 ROW. The groundwater modeling calculations are provided in Appendix E, and the calculated distances are shown on Figure 7, Appendix A.

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Chart 2 SUMMARY OF GROUNDWATER MODELING SPEEDWAY LLC No. 7146 Type of Sample Compliance Sample Location Used in the Indicator Distance (feet) Modeling Contaminant MW-02 Groundwater Benzene 46 MW-06 Groundwater MTBE 29 SB-02 (4’) Soil Benzene 100 SB-03 (4’) Soil Benzene 27 SB-10 (3’) Soil Benzene 57

Soil Gas Sampling On February 20, 2017, a Speedway representative collected a soil gas sample from vapor port VP-01. According to 35 IAC 742.515(d), if using Table H, compliance is determined by meeting either the Soil Gas Remediation Objectives (SGROs) or the GROs. Based upon the laboratory analytical results of soil gas sample collected on February 20, 2017, concentrations of indicator contaminants did not exceed any of the Tier 1 SGROs listed in Table H for the indoor inhalation exposure route. In addition, none of the concentrations of the indicator contaminants exceeded the SGROs defined by the Little, Daisy, and Nazaroff (LDN) model. Based upon the soil gas sample evaluation, neither a building foundation restriction nor a building control technology will be required for the site and further evaluation of the indoor inhalation exposure route is not necessary. The laboratory analytical results are provided in Table 4, Appendix B. The boring log, well construction diagram, laboratory analytical report, and laboratory certification were previously provided to the Illinois EPA in the SICR dated April 21, 2017.

As incorporated by Little, Daisy, and Nazaroff (1992), the LDN model is a mass-flux model, which simulates conditions where the full concrete slab-on-grade or the full concrete basement floor and walls (as assumed in Tier 1 TACO) are absent. The LDN model describes transport from a planar source and includes both diffusion and advection transport mechanisms. The LDN model assumes that the entire flux of constituents is transported into the building. Since the LDN model assumes that there are no transport limitations due to the presence of a concrete slab and, instead, all subsurface constituents in soil gas are swept into the building, the overall rate of movement of soil gas to indoor air is limited by the rate of diffusion in soil (that is, diffusion-limited conditions for constituent transport). The LDN model is used to evaluate the scenario where the on-site building

Practical Environmental Consultants, Inc. Page 10 November 17, 2017 Corrective Action Plan and Budget Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261 Leaking UST Incident No. 20150891 does not include a concrete slab or a basement with concrete floor and walls, which would otherwise limit vapor transport into the building.

Proposed Corrective Actions Based on a review of the soil, groundwater, and soil gas sample analytical data, the Tier 1 and Tier 2 evaluations, the groundwater modeling, and the LDN model evaluation, the following corrective actions are proposed for the closure of incident number 20150891:

1. An industrial/commercial land use restriction will be placed on the site deed.

2. A groundwater use restriction will be placed on the site deed to prohibit the use of groundwater as a potable water supply at the site.

3. A Highway Authority Agreement (HAA) for Route 59 will be pursued with the Illinois Department of Transportation (IDOT) to address potential groundwater impacts located within the Route 59 ROW. A copy of the IDOT HAA application form is provided in Appendix F.

A Corrective Actions map is included as Figure 8, Appendix A.

c. A schedule for implementation and completion of the plan;

The proposed corrective actions will be implemented upon Illinois EPA approval of this CAP.

2. Identification of the remediation objectives proposed for the site;

Soil Remediation Objectives: The on-site soil analytical results were compared to the calculated Tier 2 SROs and the applicable Tier 1 SROs for industrial/commercial properties as identified in Appendix B, Table B of 35 IAC 742. Tier 2 SROs were calculated and are provided in Appendix D; please refer to Chart 1 above for the applicable Tier 1 and Tier 2 SROs proposed for the site.

No off-site soil samples were collected to evaluate incident number 20150891.

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Groundwater Remediation Objectives: Tier 1 Class I GROs, as provided in Appendix B, Table E of 35 IAC 742, will be used as the applicable GROs for all indicator contaminants located on and off the site property.

Soil Gas Remediation Objectives: The soil gas sample analytical results were compared to Appendix B, Table H of 35 IAC 742 for the indoor inhalation route.

3. A description of the remedial technologies selected: a. The feasibility of implementing the remedial technologies; b. Whether the remedial technologies will perform satisfactorily and reliably until the remediation objectives are achieved; and c. A schedule of when the technologies are expected to achieve the applicable remediation objectives;

Not applicable for the proposed corrective actions.

4. A confirmation sampling plan that describes how the effectiveness of the corrective action activities will be monitored during their implementation and after their completion;

Not applicable for the proposed corrective actions.

5. A description of the current and projected future uses of the site;

The site is currently being used as a petroleum service station and is anticipated to remain as such in the foreseeable future.

6. A description of engineered barriers or institutional controls that will be relied upon to achieve remediation objectives: a. an assessment of their long-term reliability; b. operating and maintenance plans; and c. maps showing area covered by barriers and institutional controls;

The following institutional controls will be relied upon at the site: an industrial/commercial land use restriction to be placed on the site deed; a groundwater use restriction to be placed on the site deed; and an HAA to be obtained for the Route 59 ROW adjacent to the site. A Corrective Actions map is included as Figure 8, Appendix A.

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7. The water supply well survey; a. Map(s) showing locations of community water supply wells and other potable wells and the setback zone for each well; b. Map(s) showing regulated recharge areas and wellhead protection areas; c. Map(s) showing the current extent of groundwater contamination exceeding the most stringent Tier 1 remediation objectives; d. Map(s) showing the modeled extent of groundwater contamination exceeding the most stringent Tier 1 remediation objectives; e. Tables listing the setback zone for each community water supply well and other potable water supply wells; f. A narrative identifying each entity contacted to identify potable water supply wells, the name and title of each person contacted, and any field observations associated with any wells identified; and g. A certification from a Licensed Professional Engineer or Licensed Professional Geologist that the survey was conducted in accordance with the requirements and that documentation submitted includes information obtained as a result of the survey (certification of this plan satisfies this requirement);

According to the Warrenville Water Quality Report for 2016, the Village of Warrenville obtains its drinking water supply through five public water supply wells drilled approximately 300 feet bgs into the Silurian-Dolomite aquifer. Warrenville homes normally receive a mixture of water from Wells #9, #10, #11, and #12, which utilize iron removal equipment in the production process. The Illinois EPA Source Water Assessment Program (SWAP) Factsheets indicate that well #8 (Illinois EPA #20769), well #9 (Illinois EPA #00309), well #10 (Illinois EPA #00622), well #11 (Illinois EPA #01158), and well #12 (Illinois EPA #01842) supply approximately 973,000 gallons per day to an estimated population of 10,500 individuals at approximately 3,700 service connections. The location of the wells are as follows: well #8 is located at the water tower on Country Ridge Drive, across the street from the hardware building; well #9 is located at the water tower site at Warrenville Road and Lorraine Street; well #10 is located at Batavia Road and Cherice Drive in the Summerlakes Subdivision; well #11 is located next to Bower School on River Road; and well #12 is located at 3S000 Timber Drive, between the Warrenville Lakes and Timber Creek subdivisions. Well #8 is located approximately 1,000 feet from the site, all of the remaining community supply wells are located over 1,500 feet from the site. A community water supply well map with 1,000-foot setback zones, showing the site location and a water well survey, was previously provided to the Illinois EPA in the 45-Day Report dated September 22, 2015, which was approved in a letter dated December 8, 2015.

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8. Appendices; a. References and data sources report that are organized; and b. Field logs, well logs, and reports of laboratory analyses;

Please refer to Appendices A through F. A budget for the work proposed in this CAP is provided in Appendix G.

9. Site map(s) meeting the requirements of 35 Ill. Adm. Code 732.110(a) or 734.440;

Please refer to the figures provided in Appendix A.

10. Engineering design specifications, diagrams, schematics, calculations, manufacturer’s specifications, etc.;

Not applicable for the proposed corrective action.

11. A description of bench/pilot studies;

Not applicable for the proposed corrective action.

12. Cost comparison between proposed method of remediation and other methods of remediation;

Not applicable for the proposed corrective actions. A proposed budget for this CAP is included in Appendix G.

13. For the proposed Tier 2 or 3 remediation objectives, provide the following: a. The equations used; b. A discussion of how input variables were determined; c. Map(s) depicting distances used in equations; and d. Calculations; and

Site-specific Tier 2 SROs for surface and subsurface soil samples were calculated and are discussed in detail in Section E.1 of this report. Tier 2 SROs were calculated in accordance with 35 IAC 742, Subparts F and G. SSL equations identified in Table A, Appendix C of 35 IAC 742 were used to develop the Tier 2 SROs. Specifically, SSL equations S4 and S6 were used to calculate the surface SRO for the industrial/commercial inhalation exposure route; SSL equations

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S5 and S7 were used to determine the surface SRO for the construction worker inhalation exposure route; and SSL equation S28 was used to determine the subsurface mass-limit SRO for the SCGIER. The detailed Tier 2 SRO calculations are provided in Appendix D.

14. Provide documentation to demonstrate the following for alternative technologies: a. The proposed alternative technology has a substantial likelihood of successfully achieving compliance with all applicable regulations and remediation objectives; b. The proposed alternative technology will not adversely affect human health and safety or the environment; c. The owner or operator will obtain all Illinois EPA permits necessary to legally authorize use of the alternative technology;

The institutional controls proposed at the site are put in place to be protective of human health and safety. Illinois EPA permits are not required for the proposed remediation activities. The proposed corrective actions are shown on Figure 8, Appendix A.

d. The owner or operator will implement a program to monitor whether the requirements of subsection (14)(a) have been met; e. Within one year from the date of Illinois EPA approval, the owner or operator will provide to the Illinois EPA monitoring program results establishing whether the proposed alternative technology will successfully achieve compliance with the requirements of subsection (14)(a); and f. Demonstration that the cost of alternative technology will not exceed the cost of conventional technology and is not substantially higher than at least two other alternative technologies, if available and technically feasible.

Not applicable for the proposed corrective actions.

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F. Exposure Pathway Exclusion Provide the following: 1. A description of the tests to be performed in determining whether the following requirements will be met: a. Attenuation capacity of the soil will not be exceeded for any of the organic contaminants; b. Soil saturation limit will not be exceeded for any of the organic contaminants; c. Contaminated soils do not exhibit any of the reactivity characteristics of hazardous waste per 35 Ill. Adm. Code 721.123; d. Contaminated soils do not exhibit a pH < 2.0 or > 12.5; and e. Contaminated soils which contain arsenic, barium, cadmium, chromium, lead, mercury, selenium or silver (or their associated salts) do not exhibit any of the toxicity characteristics of hazardous waste per 35 Ill. Adm. Code 721.124.

Soil Attenuation Capacity The concentrations of organic contaminants of concern remaining in the soil shall not exceed the attenuation capacity of the soil, as determined under 35 IAC 742.215 (b). The soil attenuation capacity is not exceeded if:

 The sum of the organic contaminant residual concentrations analyzed for the purposes of the remediation program, for which the analysis is performed, at each discrete sampling point, is less than the natural organic carbon fraction of the soil. If the information relative to the concentration of other organic contaminants is available, such information shall be included in the sum. The natural organic carbon fraction (foc) shall be either:

o A default value of 6,000 mg/kg for soils within the top meter and 2,000 mg/kg for soils below one meter of the surface; or

o A site-specific value as measured using ASTM D2974-00 and appropriately adjusted to estimate the fraction of organic carbon as stated in Nelson and Summers (1982).

A review of the soil sample analytical results presented in Table 1, Appendix B, indicates that in no case did the sum of the BTEX concentrations in the soil samples exceed 2,000 or 6,000 mg/kg. This evaluation indicates that the attenuation capacity of the soil will not be exceeded for any of the organic contaminants.

Practical Environmental Consultants, Inc. Page 16 November 17, 2017 Corrective Action Plan and Budget Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261 Leaking UST Incident No. 20150891

Soil Saturation Limits The Tier 1 soil saturation limits are listed in 35 IAC 742, Appendix A, Table A. A review of the soil sample analytical results presented in Table 1, Appendix B, indicates that the Tier 1 soil saturation limits were not exceeded for any chemical of concern.

Reactivity Any soil that contains contaminants of concern shall not exhibit any of the characteristics of reactivity for hazardous waste as determined under 35 IAC 721.123 (a)(8). Per this regulation, a solid waste exhibits the characteristics of reactivity if a representative sample of the waste exhibits any of the following properties:

 It is normally unstable and readily undergoes violent change without detonating.

 It reacts violently with water.

 It forms potentially explosive mixtures with water.

 When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

 It is a cyanide or sulfide-bearing waste which, when exposed to pH conditions between 2.0 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

 It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

 It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

 It is a forbidden explosive as defined in 49 Code of Federal Regulations (49 CFR) 173.54 (Forbidden Explosives), or a Division 1.1, 1.2, or 1.3 explosive, as defined in 49 CFR 173.50 (Class 1 – Definitions), each incorporated by reference in 30 IAC 720.111(b).

The site is an operating petroleum retail service station. There is no reason to expect that the soil impacts at the site associated with incident number 20150891 exhibit any of the reactivity characteristics of hazardous waste per 35 IAC 721.123. Therefore, soil samples will not be collected for the above-listed analyses.

Practical Environmental Consultants, Inc. Page 17 November 17, 2017 Corrective Action Plan and Budget Speedway LLC No. 7146 2S540 Route 59 Warrenville, Illinois 60555-1261 Leaking UST Incident No. 20150891 pH Determination Any soil that contains contaminants of concern shall not exhibit a pH less than or equal to 2.0 or greater than or equal to 12.5. The west portion of the site has a history of use as a petroleum service station and the east portion as residences. There is no historical information to indicate that corrosive materials may be present in site soil that would cause the soil pH to be less than or equal to 2.0 or greater than or equal to 12.5.

Toxicity Characteristics The indicator contaminants associated with incident number 20150891 are BTEX and MTBE. There is no reason to expect that the soil would exceed the toxicity characteristics of hazardous waste per 35 IAC 721.124.

2. A discussion of how any exposure pathways are to be excluded.

Subpart C of 35 IAC 742.300 sets forth the requirements to demonstrate that an actual or potential impact to a receptor or potential receptor from a contaminant of concern can be excluded from consideration from one or more exposure routes. If an evaluation under Subpart C 35 IAC 742.300, 742.305, 742.310, 742.321, 742.315, and 742.320 demonstrates that the applicable requirements for excluding an exposure route are met, then the exposure route is excluded from consideration and no remediation objective(s) need be calculated for that exposure route.

Exposure routes are not being excluded from consideration for incident number 20150891. The institutional controls and corrective actions discussed in this CAP are proposed for the site to limit exposure to one or more exposure pathways are presented above in Section E.1 of this report.

Practical Environmental Consultants, Inc. Page 18 November 17, 2017 Appendix A Figures FIGURE 1—GENERAL SITE LOCATION MAP

SPEEDWAY STORE #7146 2 South 540 Illinois Route 59 Warrenville, IL 60555-1261

Appendix B Data Tables

Table 1 BTEX/MTBE Soil Analytical Results Speedway #C210007146 Warrenville, IL Sample COC Sample Benzene Toluene Ethylbenzene Total Xylenes MTBE Location Sample ID Date Time (mg/Kg) (mg/Kg) (mg/Kg) (mg/Kg) (mg/Kg) Action Levels - On Site Soil Boring .030 12.000 13.000 5.600 .320 MW-03 (02') MW-03 (02') 06/13/2016 08:20 <0.011 <0.014 <0.015 <0.061 <0.016 MW-03 (07') MW-03 (07') 06/13/2016 08:25 <0.011 <0.013 <0.015 <0.058 <0.015 MW-04 (02') MW-04 (02') 06/13/2016 08:51 <0.012 <0.014 <0.016 <0.063 <0.016 MW-05 (03') MW-05 (03') 06/13/2016 09:42 <0.011 <0.014 <0.015 <0.061 <0.016 MW-06 (05') MW-06 (05') 06/13/2016 10:53 <0.012 <0.014 <0.016 <0.063 <0.016 MW-08 (03') MW-08 (03') 06/13/2016 11:56 <0.011 <0.013 <0.015 <0.059 <0.015 SB-01 (4') SB-1 (4') 08/28/2015 09:00 <0.018 <0.021 <0.024 <0.094 <0.024 SB-02 (4') SB-2 (4') 08/28/2015 08:35 5.700 65.300 19.100 101.000 <0.196 SB-03 (4') SB-3 (4') 08/28/2015 08:00 0.755 2.540 0.482 1.800 <0.016 SB-04 (2') SB-4 (2') 01/04/2016 09:03 <0.012 <0.014 <0.016 <0.063 <0.016 SB-05 (2') SB-5 (2') 01/04/2016 09:14 <0.011 <0.014 <0.016 <0.062 <0.016 SB-06 (2') SB-6 (2') 01/04/2016 09:56 <0.011 <0.014 <0.015 <0.061 <0.016 SB-07 (2.5') SB-7 (2.5') 01/04/2016 10:15 <0.011 <0.013 <0.015 <0.058 <0.015 SB-08 (3') SB-8 (3') 01/04/2016 10:43 <0.011 <0.014 <0.015 <0.061 <0.016 SB-09 (3') SB-9 (3') 01/04/2016 11:05 <0.011 <0.014 <0.016 <0.062 <0.016 SB-10 (3') SB-10 (3') 01/04/2016 11:46 1.950 <0.014 1.770 2.200 <0.016 SB-13 (1') SB-13 (1') 01/04/2016 13:37 <0.010 <0.012 0.824 0.210 <0.014 SB-15 (2') SB-15 (2') 01/04/2016 14:14 <0.011 <0.013 <0.015 <0.058 <0.015 SB-16 (3') SB-16 (3') 01/04/2016 14:39 0.049 <0.014 <0.015 <0.060 <0.015 SB-17 (2') SB-17 (2') 01/05/2016 08:10 <0.011 <0.014 <0.015 <0.060 <0.015 SB-18 (2') SB-18 (2') 01/05/2016 08:40 <0.011 <0.014 <0.015 <0.060 <0.015 SB-19 (2') SB-19 (2') 01/05/2016 08:50 <0.010 <0.013 <0.014 <0.056 <0.014 SB-20 (3') SB-20 (3') 01/05/2016 09:25 0.375 <0.013 0.363 0.335 <0.015 SB-21 (3') SB-21 (3') 01/05/2016 09:40 0.278 <0.013 0.097 <0.059 0.424 SB-22 (3') SB-22 (3') 01/05/2016 10:30 0.154 <0.013 0.084 <0.060 <0.015 SB-23 (1.5') SB-23 (1.5') 01/05/2016 10:53 00.031.031 <0.012 0.346 <0.053 <0.013 SB-24 (3') SB-24 (3') 01/05/2016 11:28 <0.011 <0.014 <0.016 <0.062 <0.016

Page 1 of 1 Table 2 Non-BTEX/MTBE Soil Analytical Results Speedway #C210007146 Warrenville, IL Sample COC Sample Location Sample ID Date Analyte Action Level Results Units GT-01 GT-01 02/20/2017 09:33 Fractional Organic Carbon NA 0.840 %

Page 1 of  Table 3 BTEX/MTBE Groundwater Analytical Results Speedway #C210007146 Warrenville, IL TOC GW GW Total Sample Reading Elev Elev Depth LNAPL LNAPL COC Sample Benzene Toluene Ethylbenzene Xylenes MTBE Location Date Time (feet) (feet) (feet) Depth Thick Sample ID Date Time (ug/L) (ug/L) (ug/L) (ug/L) (ug/L) Action Levels - Trip Blank 5.000 1,000.000 700.000 10,000.000 70.000 TRIP BLANK TRIP BLANK 04/20/2015 00:00 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 09/03/2015 13:13 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 06/13/2016 08:00 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 06/20/2016 10:30 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 03/06/2017 09:05 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 03/30/2017 12:39 <0.500 <0.500 <0.500 <1.500 <0.170 TRIP BLANK 09/18/2017 11:20 <0.500 <0.500 <0.500 <1.500 <0.170 Action Levels - On Site Monitoring Well 5.000 1,000.000 700.000 10,000.000 70.000 MW-01 09/03/2015 00:00 99.85 90.3 9.55 03/06/2017 10:33 99.85 98.2 1.65 03/30/2017 12:47 99.85 98.48 1.37 MW-01 03/30/2017 13:20 <0.500 <0.500 <0.500 <1.500 <0.170 09/18/2017 11:30 99.85 94.49 5.36 MW-02 09/03/2015 13:05 100.03 97.33 2.7 MW-2 09/03/2015 13:05 5670.000 20900.000 1930.000 9640.000 <87.100 06/13/2016 07:35 100.03 97.25 2.78 02/20/2017 07:30 100.03 97.14 2.89 03/06/2017 10:40 100.03 97.85 2.18 09/18/2017 11:50 100.03 96.03 4 MW-02 09/18/2017 13:00 18.200 11.700 128.000 390.000 <3.500 MW-03 06/20/2016 09:58 100.45 97.27 3.18 MW-03 06/20/2016 10:52 <0.500 <0.500 <0.500 <1.500 <0.170 03/06/2017 10:26 100.45 98.7 1.75 09/18/2017 11:26 100.45 91.61 8.84 MW-04 06/20/2016 10:04 98.36 92.28 6.08 MW-04 06/20/2016 11:10 <0.500 <0.500 <0.500 <1.500 <0.170 02/20/2017 07:35 98.36 91.99 6.37 03/06/2017 10:10 98.36 92.4 5.96 09/18/2017 11:18 98.36 90.71 7.65 MW-05 06/20/2016 10:21 99.03 96.08 2.95 MW-05 06/20/2016 13:14 <0.500 <0.500 <0.500 <1.500 21.900 03/06/2017 10:20 99.03 95.79 3.24 09/18/2017 11:40 99.03 95.45 3.58 MW-06 06/20/2016 10:17 99.17 96.09 3.08 MW-06 06/20/2016 12:51 <0.500 <0.500 <0.500 <1.500 116.000 03/06/2017 10:15 99.17 96.76 2.41 09/18/2017 11:45 99.17 95.38 3.79 MW-06 09/18/2017 12:45 <0.500 <0.500 <0.500 <1.500 86.500 MW-07 06/20/2016 10:13 97.74 93.63 4.11 MW-07 06/20/2016 12:18 <0.500 <0.500 <0.500 <1.500 1.400 03/06/2017 09:55 97.74 94.29 3.45 09/18/2017 11:35 97.74 93.29 4.45 MW-08 06/20/2016 10:09 100.21 95.79 4.42 MW-08 06/20/2016 11:42 <0.500 <0.500 <0.500 <1.500 <0.170

Page 1 of 2 Table 3 BTEX/MTBE Groundwater Analytical Results Speedway #C210007146 Warrenville, IL TOC GW GW Total Sample Reading Elev Elev Depth LNAPL LNAPL COC Sample Benzene Toluene Ethylbenzene Xylenes MTBE Location Date Time (feet) (feet) (feet) Depth Thick Sample ID Date Time (ug/L) (ug/L) (ug/L) (ug/L) (ug/L) Action Levels - On Site Monitoring Well 5.000 1,000.000 700.000 10,000.000 70.000 MW-08 03/06/2017 10:50 100.21 96.63 3.58 09/18/2017 11:13 100.21 94.79 5.42 Action Levels - Off Site Monitoring Well 5.000 1,000.000 700.000 10,000.000 70.000 MW-09 02/20/2017 10:00 99.06 95.48 3.58 03/06/2017 09:45 99.06 96.34 2.72 MW-09 03/06/2017 11:30 <0.500 <0.500 <0.500 <1.500 <0.170 09/18/2017 11:04 99.06 95.13 3.93 Action Levels - Field Blank - Sample collected in the Field (liquid) 5.000 1,000.000 700.000 10,000.000 70.000 FIELD BLANK FIELD BLANK 08/28/2015 09:30 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 09/03/2015 13:10 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 06/13/2016 08:05 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 06/20/2016 10:35 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 03/06/2017 09:00 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 03/30/2017 12:40 <0.500 <0.500 <0.500 <1.500 <0.170 FIELD BLANK 09/18/2017 11:25 <0.500 <0.500 <0.500 <1.500 <0.170

Page 2 of 2 Table 4 BTEX/MTBE Soil Gas Analytical Results Speedway LLC #C210007146 Warrenville, IL Sample Sample Benzene Toluene Ethylbenzene Total Xylenes MTBE Location Date (mg/m3) (mg/m3) (mg/m3) (mg/m3) (mg/m3) Table H Indoor Inhalation1 - Residential 0.37 6,200 1.3 140 3,700 Table H Indoor Inhalation1 - I/C 2.8 40,000 9.3 840 24,000 VP-01 2/20/2017 0.142 0.112 0.0191 0.106 <0.0062 Notes: 1 - For these action levels, soil gas is considered to move by diffusion and advection. In diffusion, soil gas moves from an area of higher concentration to an area of lower concentration and at a steady rate of entry. In advection, soil gas moves in response to a pressure gradient, such as those caused by building heating/cooling systems, atmospheric pressure changes, and/or wind.

Page 1 of 1

Appendix C Laboratory Analytical Report

#=CL# Pace Analytical Services, LLC 1241 Bellevue Street - Suite 9 Green Bay, WI 54302 (920)469-2436

LIMS USE: FR - JENNY ROETHER LIMS OBJECT ID: 40157314 September 28, 2017

Jenny Roether Practical Environmental Consultants, Inc. 1239 76th St SW Suite A Byron Center, MI 49315

RE: Project: C210007146 COC 46955 Pace Project No.: 40157314

Dear Jenny Roether: Enclosed are the analytical results for sample(s) received by the laboratory on September 23, 2017. The results relate only to the samples included in this report. Results reported herein conform to the most current, applicable TNI/NELAC standards and the laboratory's Quality Assurance Manual, where applicable, unless otherwise noted in the body of the report.

If you have any questions concerning this report, please feel free to contact me.

Sincerely,

Steven Mleczko for Laurie Woelfel [email protected] (920)469-2436 Project Manager

Enclosures

REPORT OF LABORATORY ANALYSIS

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CERTIFICATIONS

Project: C210007146 COC 46955 Pace Project No.: 40157314

Green Bay Certification IDs 1241 Bellevue Street, Green Bay, WI 54302 Virginia VELAP ID: 460263 Florida/NELAP Certification #: E87948 South Carolina Certification #: 83006001 Illinois Certification #: 200050 Texas Certification #: T104704529-14-1 Kentucky UST Certification #: 82 Wisconsin Certification #: 405132750 Louisiana Certification #: 04168 Wisconsin DATCP Certification #: 105-444 Minnesota Certification #: 055-999-334 USDA Soil Permit #: P330-16-00157 New York Certification #: 12064 Federal Fish & Wildlife Permit #: LE51774A-0 North Dakota Certification #: R-150

REPORT OF LABORATORY ANALYSIS

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SAMPLE SUMMARY

Project: C210007146 COC 46955 Pace Project No.: 40157314

Lab ID Sample ID Matrix Date Collected Date Received

40157314001 FIELD BLANK Water 09/18/17 11:25 09/23/17 08:15 40157314002 MW-02 Water 09/18/17 13:00 09/23/17 08:15 40157314003 MW-06 Water 09/18/17 12:45 09/23/17 08:15 40157314004 TRIP BLANK Water 09/18/17 11:20 09/23/17 08:15 40157314005 DUP1 Water 09/18/17 00:00 09/23/17 08:15

REPORT OF LABORATORY ANALYSIS

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SAMPLE ANALYTE COUNT

Project: C210007146 COC 46955 Pace Project No.: 40157314

Analytes Lab ID Sample ID Method Analysts Reported Laboratory

40157314001 FIELD BLANK EPA 8260 HNW 8 PASI-G 40157314002 MW-02 EPA 8260 HNW 8 PASI-G 40157314003 MW-06 EPA 8260 HNW 8 PASI-G 40157314004 TRIP BLANK EPA 8260 HNW 8 PASI-G 40157314005 DUP1 EPA 8260 HNW 8 PASI-G

REPORT OF LABORATORY ANALYSIS

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ANALYTICAL RESULTS

Project: C210007146 COC 46955 Pace Project No.: 40157314 Sample: FIELD BLANK Lab ID: 40157314001 Collected: 09/18/17 11:25 Received: 09/23/17 08:15 Matrix: Water

Parameters Results Units PQL MDL DF Prepared Analyzed CAS No. Qual

8260 MSV UST Analytical Method: EPA 8260

Benzene <0.50 ug/L 1.0 0.50 1 09/27/17 16:14 71-43-2 Ethylbenzene <0.50 ug/L 1.0 0.50 1 09/27/17 16:14 100-41-4 Methyl-tert-butyl ether <0.17 ug/L 1.0 0.17 1 09/27/17 16:14 1634-04-4 Toluene <0.50 ug/L 1.0 0.50 1 09/27/17 16:14 108-88-3 Xylene (Total) <1.5 ug/L 3.0 1.5 1 09/27/17 16:14 1330-20-7 Surrogates Dibromofluoromethane (S) 92 % 67-130 1 09/27/17 16:14 1868-53-7 Toluene-d8 (S) 110 % 70-130 1 09/27/17 16:14 2037-26-5 4-Bromofluorobenzene (S) 85 % 61-130 1 09/27/17 16:14 460-00-4

REPORT OF LABORATORY ANALYSIS

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ANALYTICAL RESULTS

Project: C210007146 COC 46955 Pace Project No.: 40157314 Sample: MW-02 Lab ID: 40157314002 Collected: 09/18/17 13:00 Received: 09/23/17 08:15 Matrix: Water

Parameters Results Units PQL MDL DF Prepared Analyzed CAS No. Qual

8260 MSV UST Analytical Method: EPA 8260

Benzene 18.2J ug/L 20.0 10.0 20 09/27/17 09:22 71-43-2 Ethylbenzene 128 ug/L 20.0 10.0 20 09/27/17 09:22 100-41-4 Methyl-tert-butyl ether <3.5 ug/L 20.0 3.5 20 09/27/17 09:22 1634-04-4 Toluene 11.7J ug/L 20.0 10.0 20 09/27/17 09:22 108-88-3 Xylene (Total) 390 ug/L 60.0 30.0 20 09/27/17 09:22 1330-20-7 Surrogates Dibromofluoromethane (S) 94 % 67-130 20 09/27/17 09:22 1868-53-7 D3 Toluene-d8 (S) 108 % 70-130 20 09/27/17 09:22 2037-26-5 4-Bromofluorobenzene (S) 86 % 61-130 20 09/27/17 09:22 460-00-4

REPORT OF LABORATORY ANALYSIS

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ANALYTICAL RESULTS

Project: C210007146 COC 46955 Pace Project No.: 40157314 Sample: MW-06 Lab ID: 40157314003 Collected: 09/18/17 12:45 Received: 09/23/17 08:15 Matrix: Water

Parameters Results Units PQL MDL DF Prepared Analyzed CAS No. Qual

8260 MSV UST Analytical Method: EPA 8260

Benzene <0.50 ug/L 1.0 0.50 1 09/27/17 08:16 71-43-2 Ethylbenzene <0.50 ug/L 1.0 0.50 1 09/27/17 08:16 100-41-4 Methyl-tert-butyl ether 86.5 ug/L 1.0 0.17 1 09/27/17 08:16 1634-04-4 Toluene <0.50 ug/L 1.0 0.50 1 09/27/17 08:16 108-88-3 Xylene (Total) <1.5 ug/L 3.0 1.5 1 09/27/17 08:16 1330-20-7 Surrogates Dibromofluoromethane (S) 90 % 67-130 1 09/27/17 08:16 1868-53-7 Toluene-d8 (S) 110 % 70-130 1 09/27/17 08:16 2037-26-5 4-Bromofluorobenzene (S) 86 % 61-130 1 09/27/17 08:16 460-00-4

REPORT OF LABORATORY ANALYSIS

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ANALYTICAL RESULTS

Project: C210007146 COC 46955 Pace Project No.: 40157314 Sample: TRIP BLANK Lab ID: 40157314004 Collected: 09/18/17 11:20 Received: 09/23/17 08:15 Matrix: Water

Parameters Results Units PQL MDL DF Prepared Analyzed CAS No. Qual

8260 MSV UST Analytical Method: EPA 8260

Benzene <0.50 ug/L 1.0 0.50 1 09/27/17 16:36 71-43-2 Ethylbenzene <0.50 ug/L 1.0 0.50 1 09/27/17 16:36 100-41-4 Methyl-tert-butyl ether <0.17 ug/L 1.0 0.17 1 09/27/17 16:36 1634-04-4 Toluene <0.50 ug/L 1.0 0.50 1 09/27/17 16:36 108-88-3 Xylene (Total) <1.5 ug/L 3.0 1.5 1 09/27/17 16:36 1330-20-7 Surrogates Dibromofluoromethane (S) 91 % 67-130 1 09/27/17 16:36 1868-53-7 Toluene-d8 (S) 108 % 70-130 1 09/27/17 16:36 2037-26-5 4-Bromofluorobenzene (S) 86 % 61-130 1 09/27/17 16:36 460-00-4

REPORT OF LABORATORY ANALYSIS

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ANALYTICAL RESULTS

Project: C210007146 COC 46955 Pace Project No.: 40157314 Sample: DUP1 Lab ID: 40157314005 Collected: 09/18/17 00:00 Received: 09/23/17 08:15 Matrix: Water

Parameters Results Units PQL MDL DF Prepared Analyzed CAS No. Qual

8260 MSV UST Analytical Method: EPA 8260

Benzene 17.9J ug/L 20.0 10.0 20 09/27/17 09:44 71-43-2 Ethylbenzene 136 ug/L 20.0 10.0 20 09/27/17 09:44 100-41-4 Methyl-tert-butyl ether <3.5 ug/L 20.0 3.5 20 09/27/17 09:44 1634-04-4 Toluene 15.7J ug/L 20.0 10.0 20 09/27/17 09:44 108-88-3 Xylene (Total) 462 ug/L 60.0 30.0 20 09/27/17 09:44 1330-20-7 Surrogates Dibromofluoromethane (S) 94 % 67-130 20 09/27/17 09:44 1868-53-7 D3 Toluene-d8 (S) 107 % 70-130 20 09/27/17 09:44 2037-26-5 4-Bromofluorobenzene (S) 89 % 61-130 20 09/27/17 09:44 460-00-4

REPORT OF LABORATORY ANALYSIS

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QUALITY CONTROL DATA

Project: C210007146 COC 46955 Pace Project No.: 40157314

QC Batch: 268511 Analysis Method: EPA 8260 QC Batch Method: EPA 8260 Analysis Description: 8260 MSV UST-WATER Associated Lab Samples: 40157314001, 40157314002, 40157314003, 40157314004, 40157314005

METHOD BLANK: 1577627 Matrix: Water Associated Lab Samples: 40157314001, 40157314002, 40157314003, 40157314004, 40157314005 Blank Reporting Parameter Units Result Limit MDL Analyzed Qualifiers Benzene ug/L <0.50 1.0 0.50 09/26/17 16:20 Ethylbenzene ug/L <0.50 1.0 0.50 09/26/17 16:20 Methyl-tert-butyl ether ug/L <0.17 1.0 0.17 09/26/17 16:20 Toluene ug/L <0.50 1.0 0.50 09/26/17 16:20 Xylene (Total) ug/L <1.5 3.0 1.5 09/26/17 16:20 4-Bromofluorobenzene (S) % 84 61-130 09/26/17 16:20 Dibromofluoromethane (S) % 92 67-130 09/26/17 16:20 Toluene-d8 (S) % 107 70-130 09/26/17 16:20

LABORATORY CONTROL SAMPLE: 1577628 Spike LCS LCS % Rec Parameter Units Conc. Result % Rec Limits Qualifiers Benzene ug/L 50 43.6 87 73-145 Ethylbenzene ug/L 50 56.9 114 87-129 Methyl-tert-butyl ether ug/L 50 52.3 105 66-143 Toluene ug/L 50 54.3 109 82-130 Xylene (Total) ug/L 150 176 118 70-130 4-Bromofluorobenzene (S) % 99 61-130 Dibromofluoromethane (S) % 91 67-130 Toluene-d8 (S) % 108 70-130

MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 1577629 1577630 MS MSD 40157316001 Spike Spike MS MSD MS MSD % Rec Max Parameter Units Result Conc. Conc. Result Result % Rec % Rec Limits RPD RPD Qual Benzene ug/L <0.50 50 50 40.4 39.8 81 80 73-145 2 20 Ethylbenzene ug/L <0.50 50 50 52.7 50.9 105 102 87-129 3 20 Methyl-tert-butyl ether ug/L 0.21J 50 50 50.2 37.5 100 75 66-143 29 20 R1 Toluene ug/L <0.50 50 50 50.1 49.2 100 98 82-131 2 20 Xylene (Total) ug/L <0.0015 150 150 163 160 108 107 70-130 2 20 mg/L 4-Bromofluorobenzene (S) % 101 103 61-130 Dibromofluoromethane (S) % 92 93 67-130 Toluene-d8 (S) % 107 108 70-130

Results presented on this page are in the units indicated by the "Units" column except where an alternate unit is presented to the right of the result.

REPORT OF LABORATORY ANALYSIS

This report shall not be reproduced, except in full, Date: 09/28/2017 02:15 PM without the written consent of Pace Analytical Services, LLC. Page 10 of 14 #=QL# Pace Analytical Services, LLC 1241 Bellevue Street - Suite 9 Green Bay, WI 54302 (920)469-2436

QUALIFIERS

Project: C210007146 COC 46955 Pace Project No.: 40157314

DEFINITIONS

DF - Dilution Factor, if reported, represents the factor applied to the reported data due to dilution of the sample aliquot. ND - Not Detected at or above adjusted reporting limit. TNTC - Too Numerous To Count J - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit. MDL - Adjusted Method Detection Limit. PQL - Practical Quantitation Limit. RL - Reporting Limit. S - Surrogate 1,2-Diphenylhydrazine decomposes to and cannot be separated from Azobenzene using Method 8270. The result for each analyte is a combined concentration. Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values. LCS(D) - Laboratory Control Sample (Duplicate) MS(D) - Matrix Spike (Duplicate) DUP - Sample Duplicate RPD - Relative Percent Difference NC - Not Calculable. SG - Silica Gel - Clean-Up U - Indicates the compound was analyzed for, but not detected. N-Nitrosodiphenylamine decomposes and cannot be separated from Diphenylamine using Method 8270. The result reported for each analyte is a combined concentration. Pace Analytical is TNI accredited. Contact your Pace PM for the current list of accredited analytes. TNI - The NELAC Institute.

LABORATORIES

PASI-G Pace Analytical Services - Green Bay

ANALYTE QUALIFIERS D3 Sample was diluted due to the presence of high levels of non-target analytes or other matrix interference. R1 RPD value was outside control limits.

REPORT OF LABORATORY ANALYSIS

This report shall not be reproduced, except in full, Date: 09/28/2017 02:15 PM without the written consent of Pace Analytical Services, LLC. Page 11 of 14 #=CR# Pace Analytical Services, LLC 1241 Bellevue Street - Suite 9 Green Bay, WI 54302 (920)469-2436

QUALITY CONTROL DATA CROSS REFERENCE TABLE

Project: C210007146 COC 46955 Pace Project No.: 40157314

Analytical Lab ID Sample ID QC Batch Method QC Batch Analytical Method Batch

40157314001 FIELD BLANK EPA 8260 268511 40157314002 MW-02 EPA 8260 268511 40157314003 MW-06 EPA 8260 268511 40157314004 TRIP BLANK EPA 8260 268511 40157314005 DUP1 EPA 8260 268511

REPORT OF LABORATORY ANALYSIS

This report shall not be reproduced, except in full, Date: 09/28/2017 02:15 PM without the written consent of Pace Analytical Services, LLC. Page 12 of 14 Page 13 of 14 Page 14 of 14

Appendix D Tier 2 Soil Remediation Objectives Illinois Environmental Protection Age·ncy

Bureau of Land • 1021 N. Grand Avenue E. • P.O. Box 19276 • Springfield • Illinois • 62794-9276

The Agency Is authorized to requirethis lnfonnatlon under Section 4 and Title XVI of the Environmental Protection Act (416 ILCS 6/4, 6/67t- 67.17). Failure to disclose this lnfonnatlon may result In a clvll penalty of not to exceed $60,000.00 for the vlolatlon and an addltlonal civil penalty of not to exceed $10,000.00 for each day duringwhich the vlolatlon continues (416 ILCS 6/42). Any person who knowingly makes a false material statement or representation, orally or In writing, In any label, manifest, record, report, pennlt, or license, or other document flied, maintained or used for the purpose of compliance withTitle XVI commits a Class 4 felony. Any second or subsequent offense after conviction hereunder Is a Class 3 felony (416 ILCS 6/44and 67.17). This fonn has been approved by the Fonns Management Center. Leaking Underground Storage Tank Program SSL Input Parameters for Use with Tier 2 Calculations

A. Site Identification IEMA Incident# (6- or 8-digit): ------20150891 IEPA LPC # (10-digit): 0430835011 Site Name: Speedway LLC No. 7146 Site Address (not a P.0. Box): ----2 South 540------Route 59 ------City: Warrenville County: ---=------DuPage Zip Code: 60555-1261 Leaking UST Technical File

B. Tier 2 Calculation Information Equation(s) Used (ex: S12, S17, S28): ------S6, S7, S10, S28, S29 Contact Information for Individual Who Performed Calculations: Briana O'Halleran ATC Group Services, LLC; [email protected] Land Use: Ind/Commercial Soil Type: ---=------Clay Groundwater: I& Class I D Class II

Mass Limit: !'Xi Yes c: No If Yes, then Specify Acreage: [J0.5 ['11 I&, 2 r: 5 Li 10 ["30 - Mass Limit Acreage other than defaults must always be rounded up. - Failure to use site-specific parameters where allowed could affect payment from the Underground Storage Tank Fund. - Maps depicting source width, plume dimensions, distance, etc. must also be submitted. - Inputs must be submitted in the designated unit.

Symbol Unit Symbol Unit

AT (ingestion) = yr da = m

AT (inhalation) = yr ds = 1.14 m

ATc = 70 yr DA = 0.0000231 cm2/s

BW = kg Di = 0.088 cm2/s

Csat = mg/kg Dw = 0.0000102 cm2/s

Cw = 0.1 mg/L DF = 20 unitless

ED (ingestion of d = 2 m carcinogens) = 25 yr

IL 532-2860 SSL Input Parameters Page 1 of 3 LPC 645 8/07 1 of 3 Incident#: 20150891 Chemical: Benzene Land Use: Ind/Commercial

Symbol Unit Symbol Unit

ED (inhalation of 3 = yr Koc cm /g or L/kg carcinogens) 25 = 50 ED (ingestion of = yr K = m/yr noncarcinogens) s 10 ED (inhalation of = yr L = m noncarcinogens) 18.44 ED (ingestion of = PEF = m3/kg groundwater) yr

EDM-L = 70 yr PEF' = m3/kg

I Q/C (VF (g/m2-s)/ EF = d/yr = 85.81 250 equations) (kg/m3) Q/C (PEF (g/m2-s)/ F(x) = 0.194 unitless = equations) (kg/m3)

foe = 0.84 gig RfC = 0.03 mg/m3

GWobj = mg/L RfDo = mg/(kg-d)

H' = 0.23 unitless s = mg/L

i = 0.101 m/m SFo = (mg/kg-d)-1

= = I 0.3 m/yr T 790,000,0i s

IM-L = 0.18 m/yr TM-L = 30 yr

I

IFsoil-a dj = 114 (mg-yr)/(kg-d) THQ = 1 unitless

IRsoil = mg/d TR = 0.000001 unitless

IRw = Lid Um = 4.69 mis

K = 50.237 m/yr URF = 0.0000078 (µg/m3)-1

Kd (non-ionizing 3 U = 11.32 m/s organics) = cm /g or L/kg t Kd (ionizing = cm3/g or L/kg V = unitless organics)

Kd (inorganics) = 42 cm3/g or L/kg VF = 43,782 m3/kg

SSL Input Parameters Page 2 of 3 2 of3 Incident#: 20150891 Chemical: Benzene Land Use: Ind/Commercial

Symbol Unit Symbol Unit

VF' = m3/kg 0w = 0.15 Lwate/Lsoil

VFM-L = m3/kg Pb = 1.62 kg/L or g/cm3

VF'M-L = m3/kg Ps = 2.65 g/cm3

3 ri = 0.43 Lporellsoil Pw = 1 g/cm

0a = 0.28 Lai/Lsoil 1/(2b+3) = 0.042 unitless

Equation Result Unit(s)

S1 = mg/kg

S2 = mg/kg

S3 = mg/kg

S4 = mg/kg

S5 = mg/kg

S6 = 22.95 mg/kg

S7 = 478.05 mg/kg

S17 = mg/kg

S28 = 0.68 mg/kg

S29 = 75,838 mg/kg

SSL Input Parameters Page 3 of 3 3 of 3

Appendix E TACO Groundwater Modeling

SPEEDWAY LLC No. 7146 SOIL LEACHING TO GROUNDWATER MODELING

Model to Predict Impacts from Soil Leaching to Groundwater

Contaminant of Concern: Benzene Benzene Benzene Benzene GENERAL INPUT PARAMETERS SOURCE VALUE UNITS Tier 1 SROs (Actual Soil Concentration) SB-02 (4') Site-Specific 5.700 mg/kg

Infiltration Rate (mass-limit) (IM-L) Default (SSL Parameters) 0.18 m/year Exposure Duration for Migration to Groundwater (mass-limit)

(EDM-L) Default (SSL Parameters) 70 year 3 Dry Soil Bulk Density (pb) (Site-Specific) 1.620 g/cm

Depth of Source (ds) 6.56 feet (Site-Specific) 2.00 m

Soil Leaching Concentration (Cw) Equation S28 1.466 mg/L per mg/kg

Dilution Factor (DF) Default (SSL Parameters) 20.00 cm LEACHATE CONCENTRATION Equation S18 Calculated Value 0.0733 mg/L

Contaminant concentration at the source, C source SB-02 (4') 0.073 mg/L

Total Soil Porosity, θ T 0.43 (General) Default 0.43 0.25 (Gravel) Section 742.Appendix C 0.32 (Sand) Table D: RBCA 0.40 (Silt) Parameters 0.36 (Clay) Source Width Perpendicular to GW Flow Direction in

Horizontal plane, Sw 205.30 ft. Site Measurement 6258 cm

Source width perpendicular to GW flow in vertical plane, Sd 3.80 ft. Site-Specific 116 cm Aquifer Hydraulic Conductivity, K 8.517E-04 cm/s Site Measurement 73.5869 cm/day Hydraulic Gradient, i 0.0101 0.0101 ft./ft. First order degradation constant, λ 0.0009 (Benzene) Default 0.0009 1/day 0.011 (Toluene) Section 742.Appendix C 0.003 (Ethylbenzene) Table E: Default Physical 0.0019 (Xylenes) and Chemical parameters 0 (MTBE) 0.0027 (Naphthalene)

Distance along the centerline of the Groundwater Plume, X 100.00 ft. 3,048.0 cm OUTPUT VALUES

Longitudinal Dispersitivity, αΧ Equation R16 304.80 cm

Transverse Dispersitivity αΥ Equation R17 101.60 cm

Vertical Dispersitivity, αΖ Equation R18 15.24 cm

Specific Discharge, U Equation R19 1.72844 cm/day

a1 Calculated Value 2.811186026

a2 Calculated Value 0.268700577

erf(a1) Calculated Value 0.99993

erf(a2) Calculated Value 0.296055

Groundwater Objectives Benzene Class I 0.005 mg/L Benzene Class II 0.025 mg/L

Contaminant Concentration at distance X from the source

C x Equation R 26 0.005 mg/L at 100.00 ft.

SB-2 (4') BENZENE Practical Environmental Consultants, Inc. SPEEDWAY LLC No. 7146 SOIL LEACHING TO GROUNDWATER MODELING

Model to Predict Impacts from Soil Leaching to Groundwater

Contaminant of Concern: Benzene Benzene Benzene Benzene GENERAL INPUT PARAMETERS SOURCE VALUE UNITS Tier 1 SROs (Actual Soil Concentration) SB-03 (4') Site-Specific 0.755 mg/kg

Infiltration Rate (mass-limit) (IM-L) Default (SSL Parameters) 0.18 m/year Exposure Duration for Migration to Groundwater (mass-limit)

(EDM-L) Default (SSL Parameters) 70 year 3 Dry Soil Bulk Density (pb) (Site-Specific) 1.620 g/cm

Depth of Source (ds) 6.56 feet (Site-Specific) 2.00 m

Soil Leaching Concentration (Cw) Equation S28 0.194 mg/L per mg/kg

Dilution Factor (DF) Default (SSL Parameters) 20.00 cm LEACHATE CONCENTRATION Equation S18 Calculated Value 0.0097 mg/L

Contaminant concentration at the source, C source SB-03 (4') 0.010 mg/L

Total Soil Porosity, θ T 0.43 (General) Default 0.43 0.25 (Gravel) Section 742.Appendix C 0.32 (Sand) Table D: RBCA 0.40 (Silt) Parameters 0.36 (Clay) Source Width Perpendicular to GW Flow Direction in

Horizontal plane, Sw 205.30 ft. Site Measurement 6258 cm

Source width perpendicular to GW flow in vertical plane, Sd 3.80 ft. Site-Specific 116 cm Aquifer Hydraulic Conductivity, K 8.517E-04 cm/s Site Measurement 73.5869 cm/day Hydraulic Gradient, i 0.0101 0.0101 ft./ft. First order degradation constant, λ 0.0009 (Benzene) Default 0.0009 1/day 0.011 (Toluene) Section 742.Appendix C 0.003 (Ethylbenzene) Table E: Default Physical 0.0019 (Xylenes) and Chemical parameters 0 (MTBE) 0.0027 (Naphthalene)

Distance along the centerline of the Groundwater Plume, X 27.00 ft. 823.0 cm OUTPUT VALUES

Longitudinal Dispersitivity, αΧ Equation R16 82.30 cm

Transverse Dispersitivity αΥ Equation R17 27.43 cm

Vertical Dispersitivity, αΖ Equation R18 4.11 cm

Specific Discharge, U Equation R19 1.72844 cm/day

a1 Calculated Value 10.4118001

a2 Calculated Value 0.995187322

erf(a1) Calculated Value 1.00000

erf(a2) Calculated Value 0.840693

Groundwater Objectives Benzene Class I 0.005 mg/L Benzene Class II 0.025 mg/L

Contaminant Concentration at distance X from the source

C x Equation R 26 0.005 mg/L at 27.00 ft.

SB-3 (4') BENZENE Practical Environmental Consultants, Inc. SPEEDWAY LLC No. 7146 SOIL LEACHING TO GROUNDWATER MODELING

Model to Predict Impacts from Soil Leaching to Groundwater

Contaminant of Concern: Benzene Benzene Benzene Benzene GENERAL INPUT PARAMETERS SOURCE VALUE UNITS Tier 1 SROs (Actual Soil Concentration) SB-10 (3') Site-Specific 1.950 mg/kg

Infiltration Rate (mass-limit) (IM-L) Default (SSL Parameters) 0.18 m/year Exposure Duration for Migration to Groundwater (mass-limit)

(EDM-L) Default (SSL Parameters) 70 year 3 Dry Soil Bulk Density (pb) (Site-Specific) 1.620 g/cm

Depth of Source (ds) 6.56 feet (Site-Specific) 2.00 m

Soil Leaching Concentration (Cw) Equation S28 0.501 mg/L per mg/kg

Dilution Factor (DF) Default (SSL Parameters) 20.00 cm LEACHATE CONCENTRATION Equation S18 Calculated Value 0.0251 mg/L

Contaminant concentration at the source, C source SB-10 (3') 0.025 mg/L

Total Soil Porosity, θ T 0.43 (General) Default 0.43 0.25 (Gravel) Section 742.Appendix C 0.32 (Sand) Table D: RBCA 0.40 (Silt) Parameters 0.36 (Clay) Source Width Perpendicular to GW Flow Direction in

Horizontal plane, Sw 205.30 ft. Site Measurement 6258 cm

Source width perpendicular to GW flow in vertical plane, Sd 3.80 ft. Site-Specific 116 cm Aquifer Hydraulic Conductivity, K 8.517E-04 cm/s Site Measurement 73.5869 cm/day Hydraulic Gradient, i 0.0101 0.0101 ft./ft. First order degradation constant, λ 0.0009 (Benzene) Default 0.0009 1/day 0.011 (Toluene) Section 742.Appendix C 0.003 (Ethylbenzene) Table E: Default Physical 0.0019 (Xylenes) and Chemical parameters 0 (MTBE) 0.0027 (Naphthalene)

Distance along the centerline of the Groundwater Plume, X 57.00 ft. 1,737.4 cm OUTPUT VALUES

Longitudinal Dispersitivity, αΧ Equation R16 173.74 cm

Transverse Dispersitivity αΥ Equation R17 57.91 cm

Vertical Dispersitivity, αΖ Equation R18 8.69 cm

Specific Discharge, U Equation R19 1.72844 cm/day

a1 Calculated Value 4.931905309

a2 Calculated Value 0.471404521

erf(a1) Calculated Value 1.00000

erf(a2) Calculated Value 0.495015

Groundwater Objectives Benzene Class I 0.005 mg/L Benzene Class II 0.025 mg/L

Contaminant Concentration at distance X from the source

C x Equation R 26 0.005 mg/L at 57.00 ft.

SB-10 (3') BENZENE Practical Environmental Consultants, Inc. Model to Predict Impacts from Remaining Groundwater Contamination

Contaminant of Concern: BENZENE BENZENE BENZENE BENZENE GENERAL INPUT PARAMETERS SOURCE VALUE UNITS

Contaminant concentration at the source, C source MW-02 0.0182 mg/L

Total Soil Porosity, θ T 0.43 (General) Default 0.43 0.25 (Gravel) Section 742.Appendix C 0.32 (Sand) Table D: RBCA 0.40 (Silt) Parameters 0.36 (Clay) Source Width Perpendicular to GW Flow Direction in

Horizontal plane, Sw 205.30 ft. Site Measurement 6258 cm

Source width perpendicular to GW flow in vertical plane, Sd 3.80 ft. Site-Specific 116 cm Aquifer Hydraulic Conductivity, K 8.517E-04 cm/s Site Measurement 73.58688 cm/day Hydraulic Gradient, i 0.0101 ft./ft. First order degradation constant, λ 0.0009 (Benzene) Default 0.0009 1/day 0.011 (Toluene) Section 742.Appendix C 0.003 (Ethylbenzene) Table E: Default Physical 0.0019 (Xylenes) and Chemical parameters 0.0 (MTBE) 0.0027 (Naphthalene) Note: if the value of the first order degration constant in not readily available, then set λ =0.

Distance along the centerline of the Groundwater Plume, X 46.00 ft. 1,402.1 cm

OUTPUT VALUES

Longitudinal Dispersitivity, αΧ Equation R 16 140.21 cm

Transverse Dispersitivity αΥ Equation R 17 46.74 cm

Vertical Dispersitivity, αΖ Equation R 18 7.01 cm

Specific Discharge, U Equation R 19 1.728436019 cm/day

a1 Calculated Value 6.11127397

a2 Calculated Value 0.584131689

erf(a1) Calculated Value 1.00000

erf(a2) Calculated Value 0.591245

Groundwater Objectives BENZENE Class I 0.005 mg/L BENZENE Class II 0.025 mg/L

Contaminant Concentration at distance X from the source

C x Equation R 26 0.005 mg/L at 46.00 ft.

MW-02 Benzene Practical Environmental Consultants, Inc.

Model to Predict Impacts from Remaining Groundwater Contamination

Contaminant of Concern: MTBE MTBE MTBE MTBE GENERAL INPUT PARAMETERS SOURCE VALUE UNITS

Contaminant concentration at the source, C source MW-06 0.0865 mg/L

Total Soil Porosity, θ T 0.43 (General) Default 0.43 0.25 (Gravel) Section 742.Appendix C 0.32 (Sand) Table D: RBCA 0.40 (Silt) Parameters 0.36 (Clay) Source Width Perpendicular to GW Flow Direction in

Horizontal plane, Sw 205.30 ft. Site Measurement 6258 cm

Source width perpendicular to GW flow in vertical plane, Sd 3.80 ft. Site-Specific 116 cm Aquifer Hydraulic Conductivity, K 8.517E-04 cm/s Site Measurement 73.58688 cm/day Hydraulic Gradient, i 0.0101 ft./ft. First order degradation constant, λ 0.0009 (Benzene) Default 0 1/day 0.011 (Toluene) Section 742.Appendix C 0.003 (Ethylbenzene) Table E: Default Physical 0.0019 (Xylenes) and Chemical parameters 0.0 (MTBE) 0.0027 (Naphthalene) Note: if the value of the first order degration constant in not readily available, then set λ =0.

Distance along the centerline of the Groundwater Plume, X 29.00 ft. 883.9 cm

OUTPUT VALUES

Longitudinal Dispersitivity, αΧ Equation R 16 88.39 cm

Transverse Dispersitivity αΥ Equation R 17 29.46 cm

Vertical Dispersitivity, αΖ Equation R 18 4.42 cm

Specific Discharge, U Equation R 19 1.728436019 cm/day

a1 Calculated Value 9.693744919

a2 Calculated Value 0.926553713

erf(a1) Calculated Value 1.00000

erf(a2) Calculated Value 0.809921

Groundwater Objectives MTBE Class I 0.070 mg/L MTBE Class II 0.070 mg/L

Contaminant Concentration at distance X from the source

C x Equation R 26 0.070 mg/L at 29.00 ft.

MW-06 MTBE Practical Environmental Consultants, Inc.

Appendix F Highway Authority Agreement Application Form

Application for Highway Authority Agreement (HAA)

Requirements generally: Any Applicant requesting that the State of Illinois enter into a Highway Authority Agreement shall submit to the State of Illinois, Department of Transportation (IDOT) the following:

Applicant Information

Applicant*: Speedway LLC Business Address: 500 Speedway Drive, Enon Ohio 45323 Telephone: 937-863-7224 E-Mail Address: [email protected]

*(UST Owner/Operator, Remediation Applicant, etc.)

Regulatory Program: UST SRP Other, please describe

The Applicant is doing business as (please check one): Individual(s) Partnership Corporation Trust or Estate Limited Liability Company (LLC) Government entity Other

Operator (if different): Address:

Individual Signing Agreement or Name and Title of Person Authorized to Sign for Applicant:

J. Travis Powell Environmental Representative Name Title

Name and Title of Person Authorized to Sign for Operator (if different):

Name Title

Applicant’s Attorney (optional) Environmental Consultant

Name: Company: Practical Environmental Consultants, Inc. Address: Project Mgr.: Jenny Roether Address: 1305 Remington Road - Suite A Schaumburg, Illinois 60173 Telephone: Telephone: 847-519-3430 Email: Email: [email protected]

Street Address and Description of Property Adjacent to the Impacted Right-of-Way

Property Name or Description: Speedway LLC No. 7146

Nearest Cross Street and/or Intersection Quadrant: Illinois Route 59 and Batavia Road Street Address: 2 S 540 Route 59 City: Warrenville State: IL Zip: 60555-1261 County: DuPage

Printed 9/29/2017 Page 1 of 3 OCC 2507 (Rev. 01/30/15) Right-of-Way(s) under State of Illinois jurisdiction requiring Agreement

Highway Number: 59

Street Name (if any):

Note: If Groundwater restricted by ordinance, IDOT requires Groundwater impact information and a copy of the ordinance for review.

Regulatory Information: IEMA Incident Number(s): 20150891 LPC Number: 0430835011 IEPA Project Manager: Wayne Zuehlke

Person(s) named in agreement for notification purposes Company Name: Speedway LLC Attn: J. Travis Powell Address: 500 Speedway Drive Springfield, Ohio 45323

Nature and Extent of Potential Contamination Impact Information – For Exhibit A, B and C

The Closure Report/Closure Response Letter will document the nature and extent of impact in the right-of-way.

Exhibit A: FIGURES –

SOIL: Refer to Figure 1 – Estimated Soil Impact in the Right-of-Way Scaled Map noting Northern Orientation and indicating Boring and Well Locations used in the Calculations Using Tier One Residential Corrective Action Objectives

GROUNDWATER: Refer to Figure 2 – Estimated Groundwater Impact in the Right-of-Way Scaled Map noting Northern Orientation and indicating Boring and Well Locations used in the Calculations Using Tier One Corrective Action Objectives Exhibit B: TABLES - Tables showing soil and groundwater sampling results in the right-of-way (if sampled) and/or adjacent to it keyed to Figures 1 and 2. Samples above Tier One Residential Corrective Action Objectives need to be highlighted. Exhibit C: HAA AREA MAP - Area Covered by Highway Authority Agreement (IDOT Only) Refer to Figure 3 – Proposed Highway Authority Agreement Area Scaled Map Northern Orientation and clearly marking the covered area with crosshatching and legend. Include the borings and/or monitoring wells on Figure 3 that the applicant used to determine the proposed HAA area. NOTE: Agreement area must radially delineate entire Area of Contamination (on State ROW only) including potential migration.

Attachments (On 8 ½ x 11 paper): Figure 1 Estimated Soil Impact Scaled Map – For use in Exhibit A Figure 2 Estimated Groundwater Impact Scaled Map – For use in Exhibit A Figure 3 Proposed Highway Agreement Area Scaled Map – For use in Exhibit C Tables Keyed to Figures 1 and 2 Showing Sampling Results – For use in Exhibit B Closure or Corrective Action Completion Report (if available 1 copy) R26 modeling for Soil and Groundwater Location map. A broader view of the area of the HAA for identification purposes. Evidence of signature authority for all non-individual applicants.

Printed 9/29/2017 Page 2 of 3 OCC 2507 (Rev. 01/30/15) IMPORTANT NOTICE

The IDOT Highway Authority Agreement requires the signatory to accept liability for future costs related to the contamination or modeled potential contamination of State of Illinois property under the jurisdiction of IDOT identified in the HAA. It also requires the acceptance of defense and indemnification of IDOT for claims against IDOT related the area identified in the HAA. Please review the model agreement for specific terms.

In some cases IDOT has already incurred costs related to the contaminated area being remediated by the Applicant. Pursuant to Section 57.12 of the Environmental Protection Act, notwithstanding any other provision or rule of law the Owner, Operator or both of an underground storage tank are liable to the State for costs of investigation, corrective and preventative action incurred as the result of an underground storage tank. Part of IDOT’s review of HAA applications includes a search for these costs. The liability of the Applicant must be made current by payment of the identified costs before IDOT will execute an HAA. The costs incurred by IDOT during design and construction of roadways are not intended as remediation but proper management of environmental risks pursuant to IDOT’s obligations to comply with environmental laws and regulations. As such these costs are most often not reimbursable through the LUST Fund. I, J. Travis Powell as applicant hereby verify that the information and data provided herein and attached are accurate and the most current available and that any new information will be timely supplemented.

Signature Date

IDOT contact for more information and submittals:

Office of Chief Counsel RE: Highway Authority Agreement Phone: (312) 793-1549 or (217) 782-3215 2300 S. Dirksen Parkway, Room 313 Email: [email protected] Springfield, IL 62764 Note: Initial information may be submitted via Email in PDF format (preferred) or mail hard copies.

Printed 9/29/2017 Page 3 of 3 OCC 2507 (Rev. 01/30/15)

Appendix G Proposed Corrective Action Plan Budget

Office of the Illinois State Fire Marshal “Partnering With the Fire Service to Protect Illinois”

November 6, 2015

Speedway, LLC P.O. Box 1500 Springfield, OH 45501-1500

In Re: Facility No. 2-014532 IEMA Incident No. 15-0891 Speedway #7146 2 S 540 Rt. 59 Warrenville, Du Page Co., IL

Dear Applicant:

The Reimbursement Eligibility and Deductible Application received on October 8, 2015 for the above referenced occurrence has been reviewed. The following determinations have been made based upon this review.

It has been determined that you are eligible to seek payment of costs in excess of $5,000. The costs must be in response to the occurrence referenced above and associated with the following tanks:

Eligible Tanks

Tank 4 8,000 gallon Gasoline

You must contact the Illinois Environmental Protection Agency to receive a packet of Agency billing forms for submitting your request for payment.

An owner or operator is eligible to access the Underground Storage Tank Fund if the eligibility requirements are satisfied:

1. Neither the owner nor the operator is the United States Government,

2. The tank does not contain fuel which is exempt from the Motor Fuel Tax Law,

3. The costs were incurred as a result of a confirmed release of any of the following substances:

“Fuel”, as defined in Section 1.19 of the Motor Fuel Tax Law

Aviation fuel

Heating oil

Kerosene

Used oil, which has been refined from crude oil used in a motor vehicle, as defined in Section 1.3 of the Motor Fuel Tax Law.

4. The owner or operator registered the tank and paid all fees in accordance with the statutory and regulatory requirements of the Gasoline Storage Act.

1035 Stevenson Drive  Springfield, IL 62703-4259 Printed on Recycled Paper

5. The owner or operator notified the Illinois Emergency Management Agency of a confirmed release, the costs were incurred after the notification and the costs were a result of a release of a substance listed in this Section. Costs of corrective action or indemnification incurred before providing that notification shall not be eligible for payment.

6. The costs have not already been paid to the owner or operator under a private insurance policy, other written agreement, or court order.

7. The costs were associated with “corrective action”.

This constitutes the final decision as it relates to your eligibility and deductibility. We reserve the right to change the deductible determination should additional information that would change the determination become available. An underground storage tank owner or operator may appeal the decision to the Illinois Pollution Control Board (Board), pursuant to Section 57.9 (c) (2). An owner or operator who seeks to appeal the decision shall file a petition for a hearing before the Board within 35 days of the date of mailing of the final decision, (35 Illinois Administrative Code 105.504(b)).

For information regarding the filing of an appeal, please contact:

Clerk Illinois Pollution Control Board State of Illinois Center 100 West Randolph, Suite 11-500 , Illinois 60601 (312) 814-3620

The following tanks are also listed for this site:

Tank 5 8,000 gallon Gasoline Tank 6 8,000 gallon Gasoline Tank 7 8,000 gallon Gasoline Tank 8 8,000 gallon Diesel Fuel Tank 9 4,000 gallon Kerosene Tank 10 10,000 gallon Gasoline Tank 11 10,000 gallon Gasoline Tank 12 6,000 gallon Gasoline

Your application indicates that there has not been a release from these tanks under this incident number. You may be eligible to seek payment of corrective action costs associated with these tanks if it is determined that there has been a release from one or more of these tanks. Once it is determined that there has been a release from one or more of these tanks you may submit a separate application for an eligibility determination to seek corrective action costs associated with this/these tanks.

If you have any questions, please contact our Office at (217) 785-1020 or (217) 785-5878.

Sincerely,

Deanne Lock Administrative Assistant Division of Petroleum and Chemical Safety cc: IEPA Pete Knoepfle - PEC

------·------· =------======WOODSTOCK WOODSTOCK 1050 COUNTRY CLUB RD 1050 COUNTRY CLUB RD WOODSTOCK, IL 60098-6402 WOODSTOCK, IL 60098-6402 11/27/2017 06:49:51 PM 11/27/2017 06: 43:16 PM ------======------�======: Sales Rece�pt Sales Receipt Product Sale Unit Final Product Sale Unit Final Description Qty P�ice Price, Description Qty Price Price SPRINGFIELD, IL 62794-9276 $10.95 INDIANAPOLIS, IN 46204-2273 $18.80 Zone-3 Zone-2 Priority Mail 3-Day® with up to $50.00 Insurance and USPS Priority Mail 2-Day@ with up to ™ $50.00 Insurance and USPS Tracking included Trackingrn included %% USPS Signature Tracking#: %% USPS Tracking#: 9510 8000 0714 7331 0002 49 9505 5000 0714 7331 0001 92 4 lb. 15. 80 oz. 18 lb. 6.00 oz. * Expected Delivery Day Saturday, December 2. * Expected Delivery Da� Friday, m December 1. �3 Signature Confirmation $2.90 \O (<"i;) --______h7-Z... t\CA-P Issue Postage: (l Plit--\S $����� Issue Postage: $13.8�i

INDIANAPOLIS, IN 46204-2273 $7.20 SPRINGFIELD, IL 62794-9276 $6. 6�i Zone-2 Zone-3 Priority Mail 2-Day® with up to Priority Mail 3-Day® FR Env with up to $50.00 Insurance and USPS $50.00 Insurance and USPS m Trackingm included Tracking included %% USPS Tracking#: %% USPS Signature Tracking#: 9505 5000 0714 7331 0002 08 9510 8000 0714 7331 0002 56 1 lb. 13.80 oz. * Expected Delivery Day Saturday, December 2. * Expected Delivery Day Friday, ™ December 1. Signature Confirmation -----$2.90-· l-1ys;- Q� q/'-{ft. ------:tG\? J'\fv\ -- Issue Postage: • ...) $9.55 Issue Postage: $7.20 � 3 s,p:B...t.� INDIANAPOLIS, IN 46204-2273 $6.6�i WAYNE, MI 48184-�1-�38 $6.6�i Zone-2 Zone-3 Priority Mail 2-Day® FR Env with Priority Mail 2-Day® FR Env with up to $50.00 Insurance and USPS up to $50.00 Insurance and USPS m Trackingm included Tracking included %% USPS Tracking#: %% USPS Tracking#: 9505 5000 0714 7331 0002 15 9505 5000 0714 7331 0002 60 * Expected Delivery Day Friday, * Expected Delivery Day Friday, December 1. i 5"2.. December 1. 7-1 ""t3 '::> G..3 �(2_, P111c ==-----­ s+ Issue Postage: $6.65 Issue Postage: � $6.6�i

SPRINGFIELD, IL 62794-9276 $8.70 SPRINGFIELD, IL 62703-4528 $6.65 Zone-3 Zone-3 Priority Mail 3-Day® with up to Priority Mail 3-Day® FR Env with up to $50.00 Insurance and USPS $50.00 Insurance and USPS ™ Trackingm included Tracking included %% USPS Signature Tracking#: %% USPS Tracking#: 9510 8000 0714 7331 0002 25 9505 5000 0714 7331 0002 77 2 lb. 10. 30 oz. * Expected Delivery Day Saturday, * Expected Delivery Day Saturday, December 2. l;S-(?:, \(!.JC. ______December 2. Signature Confirmationm $2.90 Issue Postage: Cf>rNC,gJ..J'rTION $6.65 1··1 '-Iy, ·a\P Issue Postage: $11. 60 Total: $36.70 Total $44.2ti Paid by: VISA $36.70 Paid by: Account.#: XXXXXXXXXXXX1373 VISA $44.25 Approval#: 637561 Account#: XXXXXXXXXXXX1373 Transaction#: 078 Approval#: 634096 4445023581785-99 Transaction#: 077 4445023581785-99 SSK Transaction#: 46 USPS®# 168616-9550 SSK Transaction#: 45 USPS®# 168616-955(1 %% Text your tracking number to 28777 (2USPS) to get the latest status. q,q,. T...,..,.,._ •�-··-· .&. ·- •