Third Five-Year Review Report us EPA RECORDS CENTER REGION 5
for the 449688
Adams County Quincy Municipal Landfills #2 & #3 Superfund Site
Quincy, Adams County, Illinois
Prepared By:
United States Environmental Protection Agency Region 5 Chicago, Illinois
Approved by: Date:
""H^^^riTV. (^ 6/^ j TOiS Richard C. Karl, Director Superfund Division U.S. EPA Region 5 Cover Photograph: Landfill cap, with groundwater monitoring well in the background, at the Adams County Quincy Municipal Landfills #2 & #3 Superfund site. (Photograph by Howard Caine, June 13, 2012) Five-Year Review Report
Table of Contents
List of Acronyms I
Executive Summary ill
Five Year Review Summary Form v
\. Introduction 1
II. Site Chronology 2
III. Background 2 Physical Characteristics 2 Land and Resource Use 3 History of Contamination 4 Initial Response 4 Basis for Taking Action 4
IV. Remedial Actions 7 Remedy Selection 7 Remedy Implementation 8 Institutional Controls ; 11 System Operations/Operation and Maintenance (O&M) 13
V. Progress Since the Last Five-Year Review 14
VI. Five-Year Review Process 17 Administrative Components 17 Community Notification and Involvement 18 Document Review 18 Data Review 18 Site Inspection 20 Interviews 21
VII. Technical Assessment 21 Question A: Is the remedy functioning as intended by the decision documents? 21 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid? 21 Question C: Has any other information come to light that could call into question the protectiveness of the remedies? 22 Technical Assessment Summary: 22 VIII. Issues : 22
IX. Recommendations and Follow-Up Actions 23
X. Statement of Protectiveness 23
XI. Next Review 24
Tables Table 1 - Chronology of Site Events Table 2 - Hazardous Substances Released at the Site Table 3 - Cancer Risk Level and Hazard Index Results Table 4 - Institutional Controls Summary Table Table 5 - Operation and Maintenance Costs Table 6 - Operation and Maintenance Schedule Table 7 - Actions Taken Since the Last Five-Year Review Table 8 - Summary of Leachate Concentration Compared to the Surface Water Criteria Table 9 - Other Recommendations
Attachments Attachment A - Site Map Attachment B - Five Year Review Correspondence Attachment C - Five Year Review Inspection Report Attachment D - Public Notice of Five Year Review Attachment E - Leachate Permits Attachment F - Monthly Leachate Volumes Attachment G - Environmental Covenant April 1, 2011: Uniform Environmental Covenant Act
Documents Reviewed Record of Decision - 1993 Consent Order-1996 Explanation of Significant Differences - 1998 Five Year Review - 2008 Site Data-2007 to 2012 LIST OF ACRONYMS
AOC Administrative Order on Consent ARARs Applicable or Relevant and Appropriate Requirements BOD Biological Oxygen Demand CERCLA Comprehensive Enviroimiental Response, Compensation, and Liability Act CFR Code of Federal Regulations COD Chemical Oxygen Demand DMF Design Maximum Flow ESD Explanation of Significant Differences FIT Field Investigative Team FFS Focused Feasibility Study lAC Illinois Administrative Code ICs Institutional Controls Illinois EPA Illinois Environmental Protection Agency GCL Geosynthetic Clay Liner MCL Maximum Contaminant Level NCP National Contingency Plan NPDES National Pollution Discharge Elimination System NPL National Priorities List O&M Operation and Maintenance QAPP Quality Assurance Project Plan QA/QC Quality Assurance/Quality Control PCBs Polychlorinated Biphenyls POOR Preliminary Close Out Report PM Project Manager POTW Publically Owned Treatment Works PRPs Potentially Responsible Parties RAOs Remedial Action Objectives RD/RA Remedial Design/Remedial Action RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager STP Sewage Treatment Plant SDWA Safe Drinking Water Act SWRAU Site-Wide Ready for Anticipated Use TSS Total Suspended Solids WPCP Water Pollution Control Permit UUAJE Unlimited Use or Unrestricted Exposure U.S. EPA United States Environmental Protection Agency VOC Volatile Organic Compound [This page intentionally left blank.]
11 Executive Summary
The Adams County Quincy Municipal Landfills #2 & #3 (Adams County Landfill) Superfund site is located in Quincy, Adams County, Illinois. Drinking water wells at two homes adjacent to the site were found to be contaminated with volatile organic compound (VOC) contamination exceeding Maximum Contaminant Levels (MCLs) under the Safe Drinking Water Act in 1985. Illinois EPA notified the home owners of the contamination and recommended that the use of private wells be discontinued. The city of Quincy connected both homes to the local public water supply in April 1986.
Illinois EPA selected a cleanup remedy for the Adams County Landfill site in a 1993 Record of Decision (ROD). The selected remedy included: 1) installation of a security fence around the landfill, 2) deed restrictions to prohibit groundwater use and building construction on the site, 3) leachate collection, treatment and monitoring, 4) installation of surface controls to reduce erosion, 5) landfill cap improvements to provide a minimum of three feet of cover on the landfill over a Geosynthetic Clay Liner/Layer (GCL), 6) provision of a public water supply to nearby residents, 7) groundwater monitoring, and 8) groundwater containment and treatment if groundwater cleanup goals are not met and maintained. The potentially responsible party group began construction of the remedy in 1998 and substantially completed it in 1999.
U.S. EPA conducted the third Five-Year Review at the Adams County Landfill site under the authority of Section 121(c) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and in accordance with the National Contingency Plan (NCP). U.S. EPA found that the remedy was implemented in accordance with the requirements of the ROD and Explanation of Significant Differences (ESD).
U.S. EPA found that the remedy at the Adams County Quincy Municipal Landfills #2 & #3 site is protective of human health and the environment. All engineered remedies are functioning as designed. Immediate threats to human health and the environment have been addressed. There is no known consumption of contaminated groundwater and no current exposure to the contaminants in the landfill. Institutional controls are in place and are effective.
U.S. EPA will place a copy of this third Five-Year Review Report for the Adams County Landfill site into the site file and into the local information repository at the following locations:
Quincy Public Library U.S. EPA Region 5 526 Jersey Street Records Center-7''^ Floor Quincy, Illinois 62301 77 West Jackson Boulevard Chicago, Illinois 60604
111 [This page intentionally left blank.]
IV Five-Year Review Sunnmary Form
SITE IDENTIFICATION
Site Name: Adams County Quincy Municipal Landfills #2 & #3
EPA ID: ILD 980 607 055 Region: 5 State: IL City/County: Quincy/Adams 1
NPL Status: Final
Multiple Operational Units Has the site achieved construction completion? (OUs)? Yes No
Lead agency: U.S. EPA
Author name (Federal or State Project Manager): Howard Caine, Remedial Project Manager
Author affiliation: U.S. EPA Region 5
Review period: May 2012-January 2013
Date of site inspection: 6/13/2012
Type of review: Statutory Review number: 3
Triggering action date: 3/21/2008
Due date (five years after triggering action date): 3/21/2013 Five-Year Review Summary Form (continued)
Issues/Recommendations OU(s) without Issues/Recommendations Identified In the Five-Year Review: OU 1
Protectiveness Statement(s)
Operable Unit: Protectiveness Determination: OU 1 Protective Protectiveness Statement: The remedy at the Adams County Quincy Municipal Landfills #2 & #3 site is protective of human health and the environment. All engineered remedies are functioning as designed. Immediate threats to human health and the environment have been addressed. There is no known consumption of contaminated groundwater and no current exposure to the contaminants in the landfill. Institutional controls are in place and are effective.
Site-wide Protectiveness Statement Protectiveness Determination: Protective Protectiveness Statement: The remedy at the Adams County Quincy Municipal Landfills #2 & #3 site is protective of human health and the environment. All engineered remedies are functioning as designed. Immediate threats to human health and the environment have been addressed. There is no known consumption of contaminated groundwater and no current exposure to the contaminants in the landfill. Institutional controls are in place and are effective.
VI Third Five-Year Review Report
I. Introduction
The United States Environmental Protection Agency (U.S. EPA), in consultation with the Illinois Environmental Protection Agency (Illinois EPA), has conducted the third Five-Year Review of the remedial actions implemented at the Adams County Quincy Municipal Landfills #2 & #3 (Adams County Landtlll) Superfund site in Quincy, Adams County, Illinois. The review was conducted from May 2012 tlirough January 2013. This report documents the results of the review.
The Purpose of the Review
The purpose of a Five-Year Review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and provide recommendations to address them.
Authority for Conducting the Five-Year Review
U.S. EPA, in consultation with Illinois EPA, conducted this Five-Year Review pursuant to CERCLA Section 121 and the National Confingency Plan (NCP). CERCLA Section 121 states:
Ift^ie President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the . remedial action being implemented. In addition, if upon such review it is the judgment of the President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list of facilities for which such review is required, the results of all such reviews, and any actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR Section 300.430(f)(4)(ii) states:
If a remedial action 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 five years after the initiation of the selected remedial action.
Triggering Action
U.S. EPA is required to conduct a Five-Year Review at the Adams County Landfill site because hazardous substances, pollutants, or contaminants at the site have remained on site above levels that allow for unlimited use and unrestricted exposure (UU/UE) after the remedial action was completed. The remedial actions evaluated in this Five-Year Review report include the landfill cap, groundwater monitoring wells, and the leachate collection system.
The triggering action for this statutory Five-Year Review is the date that U.S. EPA issued the second Five-Year Review Report for the Adams County Landfill site (March 21, 2008).
IL Site Chronology Table 1: Chronology of Site Events Event Date
Discovery of Contamination at Adams County Landfill site May 1, 1981 Site proposed on the National Priorities List (NPL) June 24, 1988 Adams County Landfill site listed on the NPL August 30, 1990 Remedial Investigation/Feasibility Study (RI/FS) conducted September 12, 1990- SeptemberSO, 1993 Record of Decision (ROD) issued September 30, 1993 Remedial Design conducted March 31, 1996- December 18, 1997 Remedial Action (RA) Start December 18, 1997 Explanation of Significant Differences (ESD) issued January 7, 1998 RA Construction Start March 10, 1998 RA Completed March 31,1999 Site Inspection of Completed Construction March 24, 1999 Preliminary Closeout Report issued March 31, 1999 Operation and Maintenance (O&M) Activities Begin August 1, 1999 First Five-Year Review Report issued March 28, 2003 Second Five-Year Review Report issued March 21, 2008
III. BACKGROUND
Physical Characteristics
The 56-acre Adams County Landfill site is located in a rural area on Rock Quarry Road (formerly known as Old Broadway Road) south of Illinois Route 104 about 5 miles east of the city of Quincy in Melrose Township, Adams County, Illinois. Its northern limits are bounded by Rock Quarry Road and residences, the eastern boundary is adjacent to a dairy farm and a residence, the southern limit is bounded by a wooded tract, and the western boundary is bordered by a private lane and residence (see Attachment A). The site is located in a semi-rural setting where agriculture is the most common local land use. Pastureland and a small wooded tract immediately adjoin the site. A rock quarry is located approximately one-half mile west of the landfill. Though the area is generally rural, there are numerous houses nearby. A few residences are located just across Rock Quarry Road to the north, and one each to the west and east within one hundred yards of the site. Quincy reported that a new mobile home, equipped with a water meter, was added to the east property in 2012. A small subdivision is located approximately one mile north of the site and the village of Burton is the closest community, located to the northeast within approximately one and one-half miles of the site.
The landfilled areas are located upland of the Mississippi River and the topography is generally hilly, sloping from the north to the south and southwest. Surface drainage on the site flows to the south and southwest to an unnamed stream tributary to Mill Creek. A drainage ditch on the western boundary of the site collects surface runoff and discharges to the stream.
The landfill is typical of most co-disposal municipal landfills where general refuse was mixed with municipal and industrial wastes. Disposal occurred from 1967 to 1978. The site is wire fenced on all sides with a locked access gate on the northern boundary and the only stmcture is a metal equipment storage building located near the north entrance gate. A blacktop road crosses the middle of the site from the entrance gate on the north to the southwestern side of the site to the leachate collection tank. The landfilled area covers about 37 acres of the property but the landfill cap itself is only about 29 acres.
The northern two-thirds of the landfill site, which was the area of landfill operation, is vegetated with herbaceous plants (grasses, forbs and legumes) though some woody shrubs and small trees occur throughout the surface water drainage ways. Woody vegetation, including large deciduous trees with an herbaceous understory, occurs in the drainage along the stream and on the southern part of the site (outside the fenced area) where no disposal activities occurred. No wetlands have been identified on or near the site.
No leachate collection or containment system was installed at the site during its operational period. Numerous leachate seeps occurred throughout the landfill area during its operating history and after closure. Most seeps were located on the southwestern side of the site, although several were seen in the old roadway and a large seepage area occurred in a low-lying area in the middle of the site. Leachate accumulated in low areas and drainageways, then ran off-site primarily in two locations: along the western boundary fence and on the southwest to the nearby stream.
Land and Resource Use
Prior to initiation of landfill operations in 1967, the site was used for the pasturage of livestock. In January 1967, the Adams County Health Department approved a landfill development permit requested by Ronald Thomas. In March 1971, Illinois EPA issued Ronald Thomas and Marion Neill a permit to operate a landfill at the site; however, Marion Neill's association ceased later that year. A new pennit was issued to Ronald and Sarah Thomas the following year. The city of Quincy leased the landfill 1972 and received a permit to operate the landfill the following year. Permits to expand the size of the landfill were issued in 1974 and in 1975. The city operated the site until August 1978 and purchased the site fi-om Ronald and Sarah Thomas in April 1982.
History of Contamination
After the closure of Quincy Municipal Landfill #1 in September 1972, the site became the only operating landfill in Adams County until August 1975. During its operational history, the site received the majority of the solid waste generated in the county, as well as industrial waste from the Quincy area manufacturing sector. Liquid industrial wastes were allegedly disposed of at the site.
Because no leachate collection or containment system was installed at the site prior to the Remedial Action (RA), numerous leachate seeps occurred throughout. Leachate collected in low areas and could have potenfially migrated off-site on the surface. This could have occurred in two locations: along the western boundary and the southwest to the nearby intermittent stream.
Initial Response
On May 19, 1981, Quincy completed a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Notification of Hazardous Waste Site form for the Adams County Quincy Municipal Landfills #2 & #3 site. The notification acknowledged the disposal of unknown quantities of inorganic chemicals, organic solvents, heavy metals, mixed municipal wastes, and other undetermined wastes at the landfill. Additional response notices were received from generators of wastes disposed at the site.
On July 1, 1983, U.S. EPA completed a preliminary assessment of the site. The preliminary assessment estimated that approximately 3,000 people were potentially affected by groundwater contamination from spent halogenated solvents used in degreasing, wastewater treatment sludge from electroplating operations, 1,1,1-trichloroethane, and other hazardous substances that were accepted at the site.
On March 7, 1984, U.S. EPA completed a site inspection and document review. It was estimated that among other wastes, the site had received 343,000 gallons of sludge containing paint and toluene, 2,800,000 gallons of oily waste, 312,000 gallons of solvents, 343,200 gallons of other organic chemicals, 180,000 gallons of inorganic chemicals, and 180,000 gallons of caustic chemical bases. Estimates were based on Illinois EPA supplemental permits for disposal at the site.
Basis for Taking Action
In 1985, drinking water wells at two homes adjacent to the site were found to be contaminated with volatile organic compound (VOC) contamination exceeding Maximum Contaminant Levels (MCLs) under the Safe Drinking Water Act. Consequently, Illinois EPA notified the home owners of the contamination and recommended that the use of private wells be discontinued. Quincy connected both homes to the local public water supply in April 1986 and the two wells were reportedly properly closed and abandoned and no longer available for use.
Because of the apparent release of landfill contaminants into the groundwater that migrated off site, Illinois EPA, pursuant to Section 4(q) of the Illinois Environmental Protection Act, issued notices to Quincy and eight other potentially responsible parties (PRPs) on June 12, 1986, and December 14, 1986, to conduct a remedial investigation and feasibility study (RI/FS) at the site. The nine parties named in the 1986 notices formed a PRP group and proposed to undertake the development of an RI/FS without entering into a consent order. The remedial investigation was performed to determine the nature and extent of site contamination in 1987-88 and a final RI report was written in May 1989. A supplemental remedial investigation along with a risk assessment was performed in 1990. Based on the results of this remedial investigation and the risk assessment, U.S. EPA placed the site on the National Priorities List in August 1990.
Risk estimates for potential current and future threats to human health and the environment were developed for the following exposure scenarios: domestic use of groundwater from hypothetical wells down gradient of the site (including both ingesfion of drinking water and inhalation of VOCs during showering); domestic use of water from the two homes with contaminated drinking water wells at some time in the future (including both ingestion of drinking water and inhalation of VOCs during showering); and dermal contact with leachate by local children.
Although the data used in the prior risk assessment resulted in the detemiination that no excess risk existed from dermal contact with leachate, Illinois EPA had taken the position that if it were to conduct a risk assessment at the time of the ROD, the evaluation would result in the presence of excess risk from dermal contact with leachate. Also, on-site leachate within the landfill was considered a source of groundwater contamination and the potential exists for additional degradation in leachate quality from the landfill contents.
Risk associated with future use of the landfill site was also evaluated, although a landfill is the only anticipated future land use at the site. Residential or commercial development is unlikely due to the topography and remote location of the site. On-site dermal contact with leachate during a future hypothetical recreational use was considered and was determined that it would only slightly increase the associated risk, if no remedy was implemented.
No critical habitats, endangered species, or habitats of endangered species were identified or evaluated in the RI/FS or risk assessment process. However, the U.S. Department of the Interior Fish and Wildlife Service identified two endangered species possibly present in the vicinity of the site, which were the Indiana bat and the bald eagle.
Based on data gathered in the Remedial Investigation and risks identified in the risk assessment, actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response action selected in the Record of Decision, may have presented an imminent and substantial endangerment to public health, welfare, or the environment.
Hazardous substances that have been released at the site in each media are listed in Table 2 on the following page. Table 2: Hazardous Substances Released at the Adams County Landfill Site Soil Leachate Groundwater Benzene Benzene Benzene Ethylbenzene Ethylbenzene Ethylbenzene Total Xylenes Total Xylenes Total Xylenes Bis(2-ethylhexyl phthalate) Bis(2-ethylhexyl phthalate) Bis(2-ethylhexyl phthalate) Chlorbethane Chloroethane Chloroethane Lead Lead Lead Mercury Mercury Mercury Arsenic Arsenic Arsenic Selenium Selenium Selenium 1,1-dichloroethane 1,1-dichloroethane 1,1-dichloroethane Trans-1,2-dichloroethene Trans-1,2-dichloroethene Trichloroethene Tetrachloroethene Tetrachloroethene Trans-1,2-dichloroethene 1,1,1 -trichloroethane 1,1,1 -trichloroethane Tetrachloroethene Vinyl chloride Vinyl chloride 1,1,1-trichloroethane 1,1-dichloroethene 1,1-dichloroethene Vinyl chloride Arochlor-I254(PCB) Arochlor-1254(PCB) 1,1-dichloroethene Di-n-butylphthalate Arochlor-1242 (PCB) Chlorobenzene
The RI determined that exposure to groundwater is associated with significant human health risks due to exceedances of U.S. EPA's risk management criteria for the reasonable maximum exposure scenarios. The NCP establishes acceptable levels of risk for Superfund sites ranging from I in 10,000 (1 x 10"^) to 1 in 1,000,000 (I x 10"^) for excess lifetime cancer risk (ELCR). ECLR refers to the number of cancer cases in addition to those that would ordinarily occur in a population of that size under natural conditions should people be exposed to contaminants over their lifetime. For the non-cancer causing compounds, noncarcinogens, a risk number called the hazard index (HI) is calculated. If the HI is less than or equal to 1, no adverse health effects would be expected. If the HI is great than 1, adverse health effects are possible.
Table 3: Cancer Risk Level (CRL) and Hazard Index Results
Impacted Media Type of Exposure Cancer Risk Hazard Level (ELCR) Index (HI) Downgradient Well Groundwater Reasonable Maximum 1.86x10' 0.108 Exposure (RME) Allen Well Groundwater Average Exposure 2.47x10"^ 0.176 (AE) Allen Well Groundwater RME 7.34x10-' 0.281 Jacobs Well Groundwater AE 4.11 x 10"' 0.173 Jacobs Well Groundwater RME 2.34x10-^ 0.268 Dermal Contact Leachate Incremental CRL 9.40x10"' 0.0000203 The CRLs exceeded the point-of-departure risk level for all groundwater scenarios. The HI was less than 1, which indicates that adverse health effects are not anticipated.
Risk associated with future use of the landfill site was also evaluated, although continued landfill maintenance was the only anticipated future land use at the site. Dermal contact with leachate during a future hypothetical recreational use was considered and would only slightly increase the associated risk level if exposure were to occur on a daily basis. The carcinogenic risks were highest for exposure to contaminated groundwater from a possible future ingestion pathway.
IV. REMEDIAL ACTIONS
Remedy Selection
Illinois EPA signed a ROD to select a remedial action to address site risks at the Adams County Landfill site on September 29,1993. The major components of the selected remedy included:
• installation of a security fence around the site; • placement of deed restrictions to prohibit groundwater use and building construction on the site; • performanceof leachate collection, treatment, and monitoring; • installation of surface controls to reduce erosion; • installation of a new multi-layer landfill cap, including a minimum three feet of cover on the landfill over a GCL and drainage layers; • provisionof a public water supply to nearby residents; and • performance of groundwater monitoring, with provision for groundwater containment and treatment if groundwater goals are not met and maintained.
A Consent Order, dated May 13, 1996, was entered with Illinois EPA by the main PRPs also known as the Quincy Remedial Design/Remedial Action (RD/RA) Group. The Quincy RD/RA Group consisted of seven PRPs who had previously entered into the RI/FS Consent Order with Illinois EPA. The remedial action objective addressed two areas of concern, leachate and groundwater. The leachate remedial action addressed the source of the contamination by collecting and treating on-site waste. The function of this action was to control the landfill site as a source of groundwater contamination, to reduce the risks associated with the site by reducing exposure to contaminated materials, and to prevent untreated leachate from flowing off site. The groundwater remedial response action involved long-temi monitoring with specific cleanup levels. Failure to meet those cleanup levels would trigger further remedial action.
To adequately address the remedial objectives for both leachate and groundwater, a multi-layer landfill cover system (cap) was required for containment and to minimize the amount of precipitation infiltrating into the landfill and generating leachate. The landfill cap would cover approximately 29 acres of the 37 acre landfill area, and would be a multi-layer design including a geosynthetic clay liner/layer (GCL). The GCL was designed as a low pemieability layer that was to significantly reduce infiltration and intercept possible leachate seeps. A drainage layer was installed to drain precipitation to the leachate collection trench and into a leachate collection storage tank. Leachate generated on-site would be recovered and transported off-site for treatment and disposal. A passive landfill gas venting system was constructed as part of the cap.
On January 7, 1998, Illinois EPA issued an Explanation of Significant Differences (ESD) that modified the remedy selected in the ROD. The ESD modified two parts of the selected remedy: rewording the warning signs on the fence and allowing for leachate to be discharged to Quincy's Publicly Owned Treatment Works (POTW) rather than to surface waters by way of an NPDES permit. An on-site leachate treatment system was to remain as a potential part of the remedy until, at a minimum, the first Five-Year Review was completed at the site. If at any time prior to the Five-Year Review and for any reason an on-site system was deemed necessary and warranted or if the off-site treatment was incapable of handling the generated leachate, an on-site leachate treatment system was to be designed, constructed, and operated within six months after notification of the need for on-site treatment.
A Consent Order, No. 96-3072, was also negotiated between the state of Illinois and the Quincy RD/RA Group for reimbursement of costs incurred by the state of Illinois for response actions at the Adams County Quincy Municipal Landfills #2 & #3 facility and performance of studies and response work by the defendants at the site consistent with the NCP.
Remedy Implementation The remedy included physical access restriction by installing a six-foot high cyclone fence, with barbed wire at the top, around the entire site sufficient to prevent trespassers from easily entering the site.
The Notice of Access Agreement, filed May 28, 1996, prohibited and restricted the use of groundwater, construcfion of buildings, drilling, excavating or other soil intrusive activities on any portion of the site in accordance with and except as otherwise provided in the 1996 Consent Order.
A public water supply was supplied to six nearby residences located northwest of the site in order to eliminate the groundwater exposure pathway to those persons consuming groundwater. Other residences located near the landfill, both east and west, were later connected to the public water supply system and their drinking water wells were closed.
The remedy included a groundwater monitoring program to track the changes of concentrations of site constituents on groundwater, which would then be used to determine if additional actions were triggered by concentrations exceeding levels pursuant to the Illinois Groundwater Quality Standards at 35 Illinois Administrative Code 620. It should be noted that a contaminated groundwater plume migrating off-site has not been detected. However, other than the landfill, no other source of off-site groundwater contamination has been identified as potentially being responsible for the detected off-site well contamination.
The ROD did not require the immediate implementation of an active groundwater remedy because existing data indicated that relatively few sampling results showed groundwater contamination concentrations at levels of concern. The leachate control remedy (when adequately implemented) has had a positive impact on groundwater quality, and is an effective source control measure combined with natural attenuation to adequately address low-level groundwater contamination. Groundwater monitoring results obtained between 2003 and 2007 indicated that contamination had not exceeded compliance levels at the landfill boundary. No groundwater monitoring has been conducted since 2007. The ROD allowed for the installation of a groundwater pump-and-treat system to be installed to minimize contaminant migration if levels are exceeded. The pump-and-treat has not been installed based on past groundwater monitoring data showing no exceedances of compliance levels.
The monitoring program is consistent with Illinois Administrative Codes (lAC) 620.505 and 620.510. A groundwater management zone as described at 35 I AC 620 was established for areas undergoing effective corrective action.
The Consent Order specified "Monitoring will continue for a minimum of fiveyear s with further duration of monitoring dependent on residts of the statistical evaluation of groundwater data. Monitoring may cease after standards at 620.410 have been complied with for a minimum of one year after the minimum five year monitoring period. " In addition, monitoring may cease only after the remedy is proven effective in significantly reducing leachate, as well as reducing groundwater contamination below compliance levels per the ROD. Groundwater monitoring ceased in 2007 because the PRP Group believed that it had met the conditions of the Consent Order. Illinois EPA has recently revisited this issue and believes that the Consent Order requires another round of groundwater sampling.
Pursuant to the requirements of 35 lAC 724.195, a groundwater point of compliance must be established at the site boundary, which is also the source boundary. Compliance shall be determined by analysis for the parameters in Appendix I at 35 lAC 724.
The leachate monitoring program tests leachate for five-day biological oxygen demand (BOD), chemical oxygen demand (COD), total suspended solids (TSS), dissolved iron, pH, and any other parameters known to be present based on analytical data or believed present at the point of leachate discharge into surface waters. Any discharge to surface waters of the state is subject to the NPDES program at 40 CFR 122, which is implemented in Illinois pursuant to 35 lAC 309.
Surface water controls include beiTns, riprap lined ditches, and gabion basket catch basins composed of riprap and heavy gauge wire mesh to manage surface water infiltration into the landfill and to minimize landfill surface erosion. The purpose of the controls is to direct storm water (snow and rain) from the landfill cover system's surface to off-site, thereby drastically reducing infiltration into known disposal areas.
Components of the remedy were constructed and maintained pursuant to the requirements of 35 lACs 807 and 811, Solid and Special Waste Management Regulations, specifically regarding final cover and closure requirements. This included a minimum of three feet of clay cover over the landfill surface, particularly in areas of cap erosion and leachate management. Site leachate is collected through a network of subsurface drains and is discharged to the Quincy Wastewater Treatment Plant for treatment. The site achieved construction completion in March 1999. A Preliminaiy Close Out Report (PCOR) was signed on March 31, 1999. This report found that:
• Site access was restricted by installing six foot chain link-barbed wire fencing around the perimeter of the landfills. Warning signs were posted on the fence at the four principal compass directions, as well as, in other locations where there was potential for public access;
• The Notice of Access Agreement, dated May 28, 1996, restricted and prohibited the use of groundwater, on-site building construction, and on-site drilling, excavating or other soil intrusive activities except as otherwise provided in the May 13, 1996 Consent Order (Case No. 96-3072);
• The public water supply was extended to six residences northwest of the site;
• Groundwater will be monitored via the existing well system surrounding the site for a minimum of five years. The standards of 35 lAC 620.410 must be met for a period of one year before monitoring can cease;
• A groundwater point of compliance may be established at the site boundary pursuant to 35 lAC 724.195. Compliance shall be determined by analysis of parameters found in Appendix I of 724;
• A leachate collection system was installed. The system is capable of testing leachate quality for BOD, COD, TSS, dissolved iron, pH, and any other known constituents based on previous analytical results or believed present at the site;
• Surface controls including berms, line ditches, and catch basins were installed to manage surface water infiltration and to minimize erosion;
• The landfill was covered and closed in accordance with 35 lACs 807 and 811; and
• Leachate treatment is provided by the Quincy Wastewater Treatment Plant. In June of 1998, over two thousand feet of leachate collection lines were installed in a trench/French drain type manner at depths ranging from three to ten feet along the shallow down gradient (south and west) sides of the site. A collection tank was installed to store the collected leachate. In the fall of 1998, the construction of the solid waste cap was completed over the thirty acres of landfilled wastes. The cap consists of a geosynthetic clay liner/layer, a gravel drainage layer, and a protective vegetative layer. Landfill gas is released through a network of passive vents installed through the cap in late 1998.
Illinois EPA found that the implementation of the remedial action commenced in 1998 was substantially complete and was documented in the 1999 PCOR. Minimal final site grading, fence repairs, erosion controls, well repairs, final seeding, and minor access road repair work and construction needed to be finished.
10 A Certification of Completion of the Remedial Action report was submitted to Illinois EPA on November 17, 2000, by the PRPs' consultant. Illinois EPA responded on April 10, 2002, that "After a detailed review of the documents, Illinois EPA has determined that they are, in general, acceptable for their intended purpose." However, the original cap design called for in the ROD was not installed at the landfill; therefore, Illinois EPA did not approve the Certification of Completion. This issue has since been further evaluated by Illinois EPA and it has determined the following:
The Record of Decision, when describing the cap stated that "This includes a minimum of three feet of clay cover over the landfill surface." In accordance with the Consent Order, however, the cap was constructed with the following, from ground surface to waste materials (top to bottom):
• 6 inches of topsoil • 18 inches of compacted clay • 12 inches of pea gravel (drainage layer) . • a GCL, and • 6 inches of sub-grade (existing soil cover assumed to be clay)
While the cap does not include a minimum of 3 feet of clay over the landfill surface, it does consist of 3 feet of cover material, and the hydraulic conductivity of those materials, according to the specifications, are equivalent to the 3 feet of clay specified in the ROD. Therefore, the only difference between what was called for in the ROD and what was constructed per the Consent Order, is the actual amount (thickness) of clay placed there.
Based upon this definition, Illinois EPA has determined that the change from 3 feet of clay to 18 inches of compacted clay with the addition of the GCL qualifies as minor change, as it occurred during the design phase, is a modification of the functional specification, addresses performance optimization and cost minimization/value engineering process, affected the type of materials, and did not have a significant impact of the scope, performance, or cost of the remedy.
Institutional Controls
Institutional Controls (ICs) are required to ensure the protectiveness of the remedy. ICs are non- engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UU/UE).
The ROD requires the landfill to be capped in-place (containment) and requires deed restrictions to prohibit and restrict on-site groundwater use; on-site building construction; and on-site drilling except for the purposes of remedial design, sampling, monitoring, and remedial action. The ROD also states that a public water supply shall be supplied to six nearby residences located northwest of the site in order to eliminate the groundwater exposure pathway to those persons consuming groundwater. This was to supplement the 1986 extension of the Mill Creek Water District to nearby residents.
11 The 1999 Preliminary Close Out Report states that the real estate deed was amended to prohibit on-site groundwater use, on-site building construction, and on-site drilling except for the purposes of remedial design, sampling, monitoring, and remedial action. The title of the document which was referenced in the PCOR is Notice of Access Agreement; that document was filed at the County Recorder's office on May 28, 1996. Also filed at the County Recorder's Office is a copy of the state Consent Decree on May 24, 1996.
In a letter dated October 4, 2007, U.S. EPA required the Quincy RD/RA Group to complete and submit an ICs Study. The Quincy RD/RA Group and their consultant agreed to perform the study on October 26, 2007, and submitted a report in December 2007. Initial IC evaluation activities revealed that a Deed Restriction has been implemented.
After reviewing the IC Study, U.S. EPA determined that it would be appropriate to incorporate the existing deed notice for the Adams County Landfill site into an IC prescribed under the Illinois Uniform Environmental Covenant Act (UECA). Recording the UECA covenant improves the permanence and enforceability of the IC. The UECA IC was recorded with Adams County on April 1, 2011 (see Attachment G).
Institutional controls known at this time to be required, implemented or recommended are listed in the table on the following page.
Table 4: Institutional Controls Summary Table Media, Engineered Controls & institutional Control Objective Title of IC Instrument Areas that Do Not Support Implemented, Planned or UU/UE based on Current Recommended Conditions Adams County Quincy Municipal Restrict and prohibit on-site building UECA, April 1,2011. Landfills #2 8. #3 Property- construction, and on-site drilling, consists of capped landfill and excavating or other soil intrusive other remedy components activities except as otherwise provided in the May 13, 1996, Consent Order (Case No. 96-3072). Groundwater-current area that Restrict and prohibit the use of UECA, April 1,2011. exceeds groundwater cleanup groundwater, on-site building standards on Adams County construction, and on-site drilling, Quincy Municipal Landfills #2 & #3 excavating or other soil intrusive property activities except as otherwise provided in the May .13, 1996, Consent Order (Case No. 96-3072).
Current Compliance: A UECA was recorded on April 1, 2011 which meets the IC requirements.
System Operations/Operation and Maintenance (O&M')
Leachate treatment is provided by the Quincy Wastewater Treatment Plant. In June 1998, over 2,000 feet of leachate collection lines were installed in a trench/French drain type manner at depths ranging from 3 to 10 feet along the shallow down gradient (south and west) sides of the site. A collection tank was installed to store the collected leachate. In fall 1998, the construction of the multi-layer solid waste cap was completed over approximately twenty-eight (28) acres of
12 landfill. The cap consists of a sub-base, geo-synthetic clay layer, a gravel drainage layer, and a protective/vegetative layer. Landfill gas is released through passive vents installed within and through the cap. The passive vent network was installed across the landfill in 1998.
Operation, maintenance, and monitoring activities are performed by the PRP Group. In addition, Quincy has on-site personnel performing activities associated with operation and maintenance. Maintenance activities for the final cover include mowing, earthwork activities to con-ect erosion and sedimentation problems, re-vegetation of disturbed or distressed areas, regrading in settlement areas, as necessary, and localized repairs due to intrusion, vandalism, etc., as needed. The final cover is inspected quarterly for signs of damage. Inspections are projected to continue for a minimum period of 30 years (see Table 5 for O&M costs).
Table 5: Operation and Maintenance Costs Annual System Operations/0«&M Costs Dates Total O&M Costs 2008 $289,908.00 2009 $221,581.40 2010 $215,120.59 2011 $266,375.02 2012 $134,228.86* •Through June 2012
Storm water management system maintenance involves activities to maintain the flow of stonn water across the cap through rip-rapped channels, drop basins, discharge structures, etc. which compromise the system, and direct the water to off-site drainage ways to the intermittent creek. O&M activities include: the clearing of debris to allow for water flow, maintaining the vegetated channels and berms, where necessary, and any earthwork necessary to maintain channel slopes and channel berms.
Operation of the leachate management system involves the periodic removal of collected leachate from the storage tank with subsequent transportation to and disposal at an off-site treatment facility, currently the Quincy Publicly Owned Treatment Works (POTW). The leachate storage tank has a capacity of 10,000 gallons which is approximately 3 times the maximum anticipated 5-day leachate generation rate for the facility. The 1999 Post Closure Groundwater Monitoring Work Plan discusses the cap and leachate reduction and leachate was to be reduced from 10,000 gallons per day to 2,500 gallons per day. The frequency of leachate removal, transport, and disposal activities is dependent on the results of ongoing monitoring activities performed to gauge leachate generation and collection quantities. Leachate is removed from the leachate storage tank via a vacuum truck or portable pump to a tanker truck. The leachate is then transported to the Quincy POTW for disposal.
Maintenance of the leachate management system requires activities necessary to ensure the system performs as designed. The system has been designed to collect leachate from known leachate seep locations and direct the leachate through the collection and conveyance piping, via gravity flow, to the leachate storage tank for eventual removal, treatment, transport, and disposal. Maintenance activities include the cleaning of piping runs to remove blockages and solids
13 buildup and the repair/replacement of system appurtenances (manhole covers, tank vents, access covers, valves, clean out ports, etc.) as required.
Leachate disposal rates are compiled and submitted to the Agencies monthly. Increases in leachate production are accounted for in seasonal fluctuations, possible cap failure/compromise, or groundwater infiltration from a ravine intersecting under the road on the northwest side of the site.
Inspection of monitoring wells is performed to evaluate well conditions, whenever a sampling round is undertaken. The inspection involves looking at general well conditions including the condition of the lock, cap, protective casing, pad (if present), and well casing.
Table 6: Operation and Maintenance Schedule Adams County Quincy Municipal Landfills #2 & #3 Item Inspection Frequency Final Cover System Quarterly for up to 5 years; may be reduced Storm Water Management System Same frequency as Final Cover System Leachate Management System Quarterly for as long as system remains in operation Groundwater Monitoring System Annual Sampling (Groundwater monitoring ceased in 2007 because the PRP Group believed that it had met the conditions of the Consent Order. Illinois EPA has recently revisited this issue and believes that the Consent Order requires another round of groundwater sampling.) Road Inspected Quarterly; may be reduced Fencing, gates, building Same frequency as Final Cover System Passive Landfill Management System Same frequency as Final Cover System
V. PROGRESS SINCE LAST REVIEW
This is the third Five-Year Review report for this site. Illinois EPA detennined in the second Five-Year Review report in 2008 that the selected remedy had been implemented and was protective of human health and the environment in the short term. Long-tenn protectiveness would be achieved by compliance with effective ICs that restrict land and groundwater use. The following table summarizes the issues and recommendations of the 2008 report and the response or follow-up actions that have occurred.
14 Table 7: Actions Taken Since the Last Five-Year Review Issues from Recommen Party Mile Action Taken Date of 2008 Review dations Respons stone & Outcome Action ibIe Date The existing ICs Review the IC Illinois December A UECA was recorded April1,2011. are under study submitted EPA 2008 at the Adams County evaluation. A by [the PRP Recorder's Office. review of the Group] and institutional prepare IC Plan to controls is incorporate results necessary to of IC study and determine if the plan for additional remedy is activities as functioning as needed for IC intended with implementation regard to the ICs and long term and to ensure stewardship. effective procedures are in-place for long- term stewardship at the site.
Other progress since the last Five-Year Review included a cap investigation and maintenance and drop basin repairs as discussed below.
Drop Basin Repairs
The PRP Group repaired erosional damage to two drop basins (DB-13 and DB-14) in fall 2008. The repair was done to prevent the potential surface water runoff from entering the Leachate Collection System (LCS), which could increase the leachate collection volume. After sufficient time had passed and the data reviewed, it was concluded that this repair did not reduce the leachate volume. The PRPs then looked at extending and repairing the landfill cap. A report documenting these acdvites was submitted to Illinois EPA and the Agency concuired with the report on September 12, 2012.
Landfill Cap Repairs
The PRPs performed a cap repair at the site from April 11 - May 5, 2011. The repair further extended the landfill cap materials beyond the Leachate Collection System (LCS) along the margins of the landfill in an attempt to reduce infiltration of precipitation into the Leachate Collection System, which would then reduce the amount of leachate collected at the site. Higher than permitted leachate volumes were documented in the second Five-Year Review based on the data provided in the Monthly Progress Reports.
The conclusions from the landfill cap repair were:
• The general condition and construction of the geo-synthetic clay liner (GCL) panels exposed during the repairs appeared to be unifontily installed and intact. • There were no observable breaches in the exposed GCL, except for one area which was repaired, to indicate that infiltration of surface water into the LCS was occurring.
15 • There is a possibility that there could be GCL issues elsewhere in the cap system contributing to the leachate volumes or there is another source unrelated to the GCL.
A report was submitted to Illinois EPA and the Agency concurred with the report on September 24, 2012. The PRP Group submitted a proposal on October 15, 2012, to improve the drainage of surface water off the cap. This will consist primarily of filling in the low areas on the cap with clean topsoil. Illinois EPA has approved the workplan for this project.
Off-site Gas Migration Investigation
Background. The PRPs had conducted an off-site gas migration investigation in 2003. Illinois EPA reviewed the investigation results in 2012 and had no comments on the 2003 investigation. However, because the only landfill gas monitoring that had been completed at this site was the bar hole survey and that data, which was considered a "snapshot" representative of conditions at the time of sampling, was already nine years old, Illinois EPA requested another gas migration investigation be conducted to confirm that there continues to be no landfill gas migrating away from the landfills. Illinois EPA believes a similar investigation can be conducted, but will need to satisfy additional landfill gas monitoring requirements and the pending state vapor intrusion regulation requirements. Since there are homes in the vicinity of the landfill there needs to be a demonstration that there are no impacts via vapor intrusion at these homes. Also, the monitoring point should be at the top of the groundwater elevation rather than the 3-foot depth utilized in the 2003 investigation. Illinois EPA would also like this type of investigation every five years until all monitoring of the landfill has ceased. Based on historical groundwater data, a vapor intrusion issue at neighboring residences is not anticipated based on historical VOC concentrations in the groundwater which are meeting the cleanup goals.
Off-site Groundwater Migration Investigation
Background. The PRPs had conducted an off-site groundwater migration investigation in 2003. Illinois EPA concluded, in 2012, that the collected data does not indicate any adverse impacts to the shallow groundwater to the west of the landfill at that single point in time. Illinois EPA also agreed that the sand lenses appear to be discontinuous and not very extensive. However, Illinois also noted that one data point was insufficient to make a detennination as to the need for further evaluation of the off-site groundwater. A single point cannot take into account any potential seasonal variations, among other things. However, given the amount of time that has passed since this investigation was conducted, and the fact that all groundwater monitoring at this site had since been discontinued (as of 2007), Illinois EPA agreed that no further evaluation of the off-site groundwater is needed, as long as there continues to be no exceedances of the Class I Groundwater Quality Standards in the groundwater monitoring wells in the underlying aquifer on site. If in the future an exceedance of one of those standards is identified or reported, additional off-site groundwater monitoring may be required.
On-site Groundwater Monitoring
Groundwater monitoring ceased in 2007 because the PRP Group believed that it had met the conditions of the Consent Order. Illinois EPA has recently revisited this issue and believes that
16 the Consent Order requires another round of groundwater sampling. Illinois EPA has been in discussion with the PRP Group in regards to conducting an additional round of on-site groundwater monitoring and the PRP Group has provided a statistical evaluation of the groundwater data. The PRP Group has stated that it has met the terms of the Consent Decree and additional groundwater monitoring is not necessary. Both groups are working towards resolution of this issue. U.S. EPA supports Illinois EPA's position in obtaining the addifional information.
Removal of Till Wells
Background. Illinois EPA was concerned that VOC migration could occur through the shallower saturated sand lenses within the clay till unit beneath the site. Subsequent groundwater data showed that the sand lenses did not contain landfill-related VOCs. Data was collected for several years and upon the conclusion of the groundwater sampling the data showed that VOC concentrations met their respective Illinois Class I Remediation Objectives. The PRP Group requested the removal of the till groundwater monitoring wells in 2004. Illinois EPA conducted a review of the submitted letters and the referenced data and reports in 2012. The request to remove all the till wells from the groundwater monitoring network would be approved, provided another round of groundwater monitoring was completed on the deep sand aquifer wells.
Site- Wide Ready for A nticipated Use
On September 10, 2010, U.S. EPA determined the site met the requirements for the Site-Wide Ready for Anticipated Use (SWRAU) designation. The site was found to meet the following requirements: 1) All cleanup goals in the ROD or other decision documents have been achieved for all media that may affect current and reasonably anticipated fliture land uses, so that there are no unacceptable risks and 2) all ICs, or other controls, required in the RODs or identified as part of the response action to help ensure long-term protection have been put in place. The Uniform Environmental Covenant Act (UECA) institutional control was subsequently recorded on April 1, 2011, at the Adams County Recorder's Office.
VI. FIVE-YEAR REVIEW PROCESS
Administrative Components:
U.S. EPA notified the representatives of the PRP Group, Illinois EPA, and city of Quincy of the initiation of the Five-Year Review in a letter dated May 1, 2012 (see Attachment B). The review team included Howard Caine of U.S. EPA and Brian Conrath of Illinois EPA.
From May 2012 through December 2012, the review team reviewed historical data and documents, visited and inspected the site, and prepared the report. Howard Caine and Brian Conrath also completed the site inspection on June 13, 2012.
17 Community Notification
The community was notified of the beginning of the Five-Year Review via display advertisements in the Quincy Herald-Whig on June 25, 2012 (see Attachment D).
Meetings were held with representatives from the following groups to review information and solicit comments as part of the review process:
• David Kattelman, city of Quincy; • Phil Harvey, Conestoga-Rovers and Associates (CRA); • Rustin Kimmel, Lathrop & Gage; and • Eric Ballenger, Republic Services
Document Review
The site documents reviewed for this Five-Year Review include the ROD, ESD, Consent Order, Monthly Progress reports, and other information and correspondence. Remedial action objectives (RAOs), ARARs, and site cleanup levels are found in the ROD.
Data Review
Monthly Progress Reports
The PRP Group submits monthly progress reports to Illinois EPA pursuant to Paragraph 26 of the Consent Order. The progress reports consist primarily of volume of leachate collected and shipped to the Quincy POTW (see Attachment E).
The leachate discharge volume is regulated under Water Pollution Control Permit (WPCP) 2004- EN-0414 which was issued on May 21, 2004 (see Attacliment F). This permit allows the leachate to be hauled from the Adams County Landfill site to the Quincy Sewage Treatment Plant (STP). The permit was issued to allow the increase in the maximum flow of leachate to be hauled to the Quincy STP from 35,000 gallons per week to 80,000 gallons per week. The design average flow of 25,000 gallons per week was not increased. The prior discharge was permitted under WPCP 2001-EN-2829 and was issued on April 6, 2001.
The permit has Standard Condition No. 8 wherein the Illinois EPA may file a complaint with the Illinois Pollution Control Board for suspension or revocation of a permit: a) upon discovery that the permit application contained misrepresentations, misinformation or false statement or that all relevant facts were not disclosed; or b) upon finding that any standard or special conditions have been violated; or c) upon any violation of the Environmental Protection Act or any Rules or Regulation effective there under as a result of the construction or development authorized by this permit.
The PRP Group submitted letters over the last five years of "Nofice of Excessive Discharge Volumes" to Alan Keller, Manager, Permit Section, Division of Water Pollution Control, Illinois EPA. The letters state, "As described to lEPA previously, leachate discharge increases
18 significantly in response to precipitation events." Each letter cites spring thaw, heavy rain, snow melt, and/or heavy precipitation as the source of the discharge increase. Each letter further states, "The increased discharge is due primarily to the addition of clean water into the leachate collection system."
The weekly maximum flow of leachate hauled to the Quincy STP was exceeded:
12 times in January 2008; 6 times in February 2008; 9 times in March 2008; 7 times in April 2008; 7 times in August 2009; 7 times in October 2009; 10 times in November 2009; 5 fimes in December 2009; 5 fimes in January 2010; 5 dmes in March 2010; 4 times in February 2011; 11 times in November 2011; 6 times in February 2012; and 6 times in September 2012.
This translates to 72 times over the third Five Year Review period. This is 47 percent lower than during the second Five-Year Review period which indicates that the repairs that have been made may have helped reduce leachate volume. However, these exceedances were of the revised DMF (80,000 gallons/week) rather than the original DMF (25,000 gallons/week) and there was also a drought in 2012 which would also have helped reduce leachate volumes.
To date, Illinois EPA has not invoked Standard Condition No. 8 or required the PRP Group to obtain another amended WPCP to allow for the increased discharge of leachate to the Quincy POTW. This is subject to change if the requested additional groundwater monitoring event is conducted and yields results in contrast with those obtained previously.
The Adams County Landfill site also has an Industrial User Water Pretreatment permit (QWTF #01-029) from Quincy. The permit was effective August 31, 2007, and expired on August 31, 2012. The permit contains requirements on effluent limitations; monitoring schedule; schedule of conditions; and reporting requirements summary. A review of the grab samples collected shows that the leachate meets the conditions set forth in the permit. One sample, however, collected on July 3, 2008 shows that lead exceeded its permitted limit of 1.4 mg/L. The sample result was 3.19 mg/L. A new permit was issued and became effective on August 31, 2012 and will expire on August 31,2017.
Illinois EPA had suggested that the PRPs consider looking at the leachate quality before and after cap repair work. The PRPs were also evaluating other options of leachate management. Samples were collected prior to the landfill cap work (October 2010 and March 2011) and after the landfill cap work (June 2011 and September 2011). The samples were also collected initially
19 under low flow conditions followed by high flow conditions. The data were compared to the surface water criteria for comparison purposes. The vast majority of analytes showed no difference between high flow and low flow conditions. The data in Table 8, below, shows the contaminants which exceeded at least one of the surface water criteria limits. The PRPs' evaluation of additional leachate management options has been put on hold until further landfill cap work is completed. (The ROD had initially selected discharge of the leachate to a surface water body through a NPDES permit. The ESD changed this to off-site disposal at a wastewater treatment plant.) Off-site disposal to the Quincy POTW meets the criteria in the permit.
Table 8: Summary of Leachate Concentration Compared to the Surface Water Criteria
Illinois EPA Surface Water Criteria Daily Tank Tank Tank Tank Parameter Units l-Acute 1-Chronic U-Acute U-Clironic Max 10/21/10 3/17/11 6/14/11 9/7/11 Aluminum ug/L 750 87 626 6410 550 3,500 Arsenic ug/L 360 190 340 150 180 125 472 64 510 Copper ug/L 253.40 131.46 200.13 103.72 3,380 24.8 J 162 11 J 90 Iron ug/L 1,000 124,000 118,000 118,000 120,000 870,000 Lead ug/L 1,373.46 288.04 1,171.56 45.65 1,400 213 750 150 450 Nickel ug/L 931.05 56.37 5,292.32 587.81 2,110 62.3 165 31 J 130 Zinc ug/L 1,355.58 244.72 1,329.40 1,360.29 2,610 3,870 J 19,700 J 2,600 7,600 ug/L = micrograms per liter or parts per billion
Site Inspection The site inspection was conducted by Howard Caine and Brian Conrath, on June 13, 2012. David Kattelman of the city of Quincy, Phil Harvey of CRA, and Rustin Kimmel of Lathrop & Gage participated in the site inspection (see Attachment C).
A tour of the landfill was performed that included walking on the access road to the southern end of the property and walking on the landfill cap. The landfill is equipped with a leachate collection tank that has a 10,000 gallon capacity. The collected leachate is transferred to the city of Quincy POTW via truck. There was fencing surrounding the site. Warning signs were posted on the fence.
Significant low areas were observed on the landfill cap. These low spots lead to ponding during rain events which can contribute to the leachate volume by allowing stonnwater to infiltrate the cap. Several areas showed signs of burrowing animals in the landfill cap. The evidence points to the animals being voles. A farm to the east has a drainage pipe draining towards the landfill. That pipe should connect with an existing constructed drainage way in order to eliminate channeling on the landfill surface.
The piezometer by DB-13 was not locked and the protective bollards by the cleanout south of DB-13 were loose. In addition, there were several other locations where the protective bollards around the monitoring wells, gas vents, and clean-outs had significant erosion at their base (see Attachment C).
Prior to the landfill inspection, Mr. Conrath and Mr. Caine went to Mr. Kattelman's office to discuss the site with the PRP team and review records.
20 Interviews
The following interviews were conducted:
• David Kattelman, city of Quincy, Engineering Technician/Landfill Technician. He is responsible for maintaining the landfill as well as maintaining billing/invoice information and keeping data records.
• Phil Harvey, CRA. Mr. Harvey has been the main consultant for this site for a number of years and has a lot of historical knowledge of the site. He also assisted in explaining site operations during the inspections.
• Rustin Kimmel, Lathrop & Gage. Mr. Kimmel participated in the site inspection. He provided the legal position for the PRP Group.
• Eric Ballenger, Republic Services. Mr. Ballenger assisted in explaining site operations.
VII. TECHNICAL ASSESSMENT
Question A: Is the remedy functioning as intended by the decision documents?
Yes. Review of the remedial systems operations data and the site inspection provide evidence that the selected engineered remedies are fiincfioning as intended by the ROD and ESD. There is no evidence of site or groundwater uses which are inconsistent with existing ICs and objectives of the required use restrictions. A UECA is in place at the site.
There is a concern regarding high leachate volumes exceeding the Water Quality permit issued to the Adams County Quincy Municipal Landfills #2 & #3 site. Further cap invesdgation needs to be performed by the Quincy RD/RA Group to determine the cause of the excess leachate volumes. It should be noted that no wastewater exceedances have been noted discharging from the Quincy POTW from the excess leachate discharge from the landfill. No inappropriate site or media uses have been noted during the inspection or interviews.
Residences in the vicinity of the landfill are connected to municipal water.
The landfill property is fenced with chain link fence. Warning signs were observed at the site at the time of the inspection. There was no evidence of trespassing.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?
Yes. There have been no changes in the physical conditions of the site that would affect the protectiveness of the selected remedies at these sites. Neither has there been any substantive change in the use of the property during the last five years. There have been no changes in land use near the site, nor are changes expected in the near fijture. There have been no newly observed species or ecologic settings. Potential exposure scenarios remain the same.
21 There have been no changes in either the contaminant characteristics/toxicity or the federal Safe Drinking Water Act (SDWA) standards for protection of groundwater as they, relate to the contaminants of concern at these sites. Standard risk assessment methods have not changed in a way that would affect the protectiveness of the remedies at this site.
In general, contaminant concentrations in groundwater, when monitored, were stable or continued to decline at the Adams County Landfill site. Groundwater monitoring data showed that the cleanup goals had been met based on the 2007 data. The selected remedies have been and continue to be effective in protecting human health and the environment.
Question C: Has any other information come to light that could call into question the protectiveness of the remedies?
No. No new information has come to light in the last five years that would call into question the protectiveness of the selected remedies at the Adams County Landfill site. However, the cap needs to be further investigated to determine if the increased leachate discharge levels are caused by increased precipitation or by cap damage. There have been no newly-discovered ecological risks. There have been no significant impacts from natural disasters.
Summary of Technical Assessment:
Based on the data reviewed, the site inspection and the interviews, the remedy for the Adams County Quincy Municipal Landfills #2 & #3 site is functioning as intended by the ROD. There have been no changes in the physical conditions or exposure scenarios of the sites that would affect the protectiveness of the remedy. There have been no changes in the groundwater standards, either federal or state, for the contaminants of concern that would affect protectiveness at this site. ICs are in place and are effective.
VIII. ISSUES
There are no issues that affect the future protectiveness of the remedy.
This review also notes several other concerns that must be resolved through routine O&M, but that do not affect protectiveness of the remedy. They are:
• Illinois EPA and the PRP Group need to come to resolution on fliture monitoring requirements at the site. Groundwater monitoring ceased in 2007 because the PRP Group believed that it had met the conditions of the Consent Order. Illinois EPA has recently revisited this issue and believes that the Consent Order requires another round of groundwater sampling. Illinois EPA also requested a statistical analysis of the groundwater monitoring data as required in the Consent Order. • Low spots need to be filled in on the cap. Cap investigation should continue to determine the source of high leachate volumes and the cap should be repaired, as necessary. • Significant vole burrowing was observed at the landfill and needs to be addressed. • Trees and other vegetation need to be removed from the drainage channels.
22 • Protective bollards surrounding a leachate cleanout by DB-13 were loose and should be secured. • Several protective bollards around the monitoring wells, gas vents, and clean-outs had significant erosion at their base. This needs to be addressed. • Illinois EPA should determine if the Certification of Completion of the Remedial Action dated November 17, 2000, can be approved.
IX. Recommendations and Follow-up Actions
There are no recommendations and follow-up actions that affect protectiveness for the site.
Other concerns noted by this review should be addressed as follows:
Table 9: Other Recommendations Concern Recommendation To Be Done Over- Target By Sight By Date Future monitoring Illinois EPA and Quincy RD/RA Group Illinois U.S. EPA Sept. requirements to determine future monitoring EPA/Quincy 2013 •equirements at the site to respond to RD/RA Group PRP request to remove monitoring wells from the sampling list. Fill in low spots on cap PRPs to fill in low spots on cap Quincy RD/RA Illinois EPA April 2013 Group
Voles burrowing holes in Control infestation of voles at the site Quincy RD/RA Illinois EPA June. landfill Group 2013 City of Quincy Trees and vegetation need Remove trees and vegetation from Quincy RD/RA Illinois EPA April 2013 to be removed from the drainage channels Group drainage channels City of Quincy
Protective bollards Secure protective bollards Quincy RD/RA Illinois EPA June 2013 surrounding leachate Group cleanout were loose City of Quincy Erosion around protective Fill in and re-seed Quincy RD/RA Illinois EPA June 2013 bollards Group City of Quincy Determine status of Need to determine if Certification of Illinois EPA U.S. EPA September Certification of Completion Completion of the Remedial Action is 2013 of the Remedial Action complete or if more information is needed.
X. STATEMENT OF PROTECTIVENESS
The remedy at the Adams County Quincy Municipal Landfills #2 & #3 site is protective of human health and the environment. All engineered remedies are functioning as designed. Immediate threats to human health and the environment have been addressed. There is no known consumption of contaminated groundwater and no current exposure to the contaminants in the landfill. Institutional controls are in place and are effective.
23 XI. NEXT FIVE-YEAR REVIEW
The next Five-Year Review will be due five years from the signature date of this report.
24 Attachment A: Site Map
Attachment B: Five Year Review Correspondence i ^^ \ I ^^^ ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY %,'>•?* REGION 5 ^' """'^ 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590
REPLY TO THE ATTENTION OF:
(SR-6J)
May 1,2012
Brian Conrath Remedial Project Manager Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 , Re: Notification of Five Year Review Start for Adams County Quincy Municipal Landfills 2 and 3 Superfund Site, Quincy, Illinois
Dear Mr. Conrath:
This letter is to confirm that the U.S. Environmental Protection Agency (EPA) and the Illinois Environmental Protection Agency (Illinois EPA) have begun the process of the Five Year Review for the Adams County Quincy Municipal Landfills 2 and 3 (Adams County) Superfund site in Quincy, Illinois. The EPA will lead this Five Year Review at this State-lead site. A Statutory Five Year Review will be conducted at the site as required by Section §121 of CERCLA, as amended by the Superfiind Amendments and Reauthorization Act of 1986 (SARA).
The Five Year Review of the Adams County Superfiind site is due on March 21, 2013 and since there are several topics to be covered in the Five Year Review, it is appropriate that the EPA and Illinois EPA provide the key parties appropriate notification so that we can begin the necessary coordination activities. The necessary activities include such matters as notifying the public of the Five Year Review process and accepting public input, gathering data in order to summarize performance of site hazardous substances and key contaminant containment and treatment devices, arrange for site visits and inspections to review remediation and operation and maintenance functions, as well as develop any pertinent site related recommentdations. I would like to conduct the site visit in June 2012 and will contact all parties shortly to confirm availability.
Printed on Recycled Paper I look forward to working with the Illinois EPA, City of Quincy, Quincy RD/RA Group and their contractor, Conestoga-Rovers & Associates (CRA) in compiling the Five Year Review report for the Adams County Superfund site.
If you have any comments or questions, please contact me at 312 353 9685 or via email at caine.howard(g),epa. gov.
Sincerely,
Howard Caine, RPM EPA cc: Bonnie Eleder, EPA (via email) Tom Krueger, EPA (via email) David Kattelman, City of Quincy Rustin Kimmel, Lathrop & Gage, LLP Phil Harvey, CRA Attachment C: Five Year Review Inspection Report U.S. Environmental Protection Agency Region 5 77 West Jackson Blvd. (SR-6J) Chicago, IL 60604
January 8, 2013
Subject: Adams County Quincy Municipal Landfills 2 & 3
Five Year Review Inspection
From: Howard Caine, RPM
To: File
Introduction and Purpose The Adams County Quincy Municipal Landfills 2 & 3 was inspected on October 9, 2012 as part of the third Five Year Review. The site was toured with representatives of Illinois EPA, the City of Quincy, Conestoga-Rovers & Associates (CRA; PEIP consultant) and Lathrop & Gage (PRP counsel). A meeting was held prior to the site visit to go over progress since the last Five Year Review.
Participants
Howard Caine, RPM, U.S. EPA
Brian Conrath, PM, Illinois EPA
David Kattelman, Engineering Technician, City of Quincy
Phil Harvey, CRA
Rustin Kimmel, Counsel, Lathrop & Gage
File Review
Mr. Conrath and I met with Messrs. Kattelman, Harvey and Kimmel. We discussed site conditions, progress since the last Five-Year Review and reviewed data records kept for the site. After this discussion and review, we went to the site.
Site Tour
We walked around the site and observed that groundwater monitoring wells were locked. A piezometer was found to be unlocked. We also observed areas of the landfill cap that had significant damage from critters, most likely voles. Several areas of the landfill were also found to have low spots which would cause ponding on the cap. The site is fenced and "No Trespassing" signs are posted at various spots on the fence.
The site has passive gas vents and appeared to be intact. Several trees and other vegetation were observed in the various drainage channels. The liner under the rip rap on these drainage channels should be checked for possible damage. A drainage pipe was observed from the adjacent farm towards the landfill. This pipe should be connected to the drainage way.
This concluded the inspection. Photo 1: Trees growing in drainage channel near road on landfill
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Photo 2: Vegetation in drainage chaimel around landfill Photo 3: Tree and vegetation in drainage charmel
Photo 4: Trees and vegetation in drainage charmel ^"^"^mm
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Photo 5: Burrowing animal damage
Photo 6: Low spot on landfill cap Photo 7: Low spots on landfill
Photo 8: Burrowing animal damage Photo 9: Gabian basket DB-12
Photo 10: More trees by drainage channels Photo 11: Gabian basket DB-13 with overgrown vegetation
Photo 12: Loose protection posts by trap Photo 13: Broken concrete support on Q6S
Photo 14: Groundwater monitoring well outside fence •'s '('
Photo 15: Low spot on the landfill cap
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Photo 16: Lowspot on the landfill cap Photo 17: Tire tracks in low spot on landfill cap
Photo 18: Gabian basket DB-14 Photo 19: Erosion on landfill cap
Photo 20: Groundwater monitoring well 2D Photo 21: Cleanout trap
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Photo 22: Groundwater monitoring well with tree near it Photo 23: Groundwater monitoring well
Photo 24: Leachate collection area Photo 25: Leachate collection area
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Photo 26: Gap under fence by leachate collection area Photo 27: Warning sign
Photo 28: Warning sign Photo 29: Vegetation in drainage channel by on-site road
Photo 30: Vegetation and trees in drainage channel by on-site road Photo 31: Trees growing in drainage channel adjacent to farm
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Photo 32: Trees growing in drainage channel next to on-site road Photo 33: Trees growing in drainage charmel
Photo 34: Burrowing animal in cap Photo 35: Low spot on landfill cap
Photo 36: Low spot on landfill cap Photo 37: Trees growing in drainage channel /
OSWERNO.9355.7-03B-P Please note that "O&M" is referred to throughout this checklist. At sites where Long-Term Response Actions are in progress, O&M activities may be referred to as "system operations" since these sites are not considered to be in the O&M phase while being remediated under the Superfund program.
Five-Year Review Site Inspection Cliecl^list (Template)
(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation of site status. "N/A" refers to "not applicable.")
I. SITE INFORMATION Site name: ^ "Q/P/M^ Cjy /f Jl/5 Date of inspection: ^/n/fL Location and Region: QU//U6f ^[^ EPA ID: Agency, office, or conuiany leading the five-year Weather/temperature: revie>v: US-hW^iAf^AJ T Remedy Includes: (Check all that apply) G Landfill cover/containment G Monitored natural attenuation G Access controls G Groundwater containment G Institutional controls G Vertical barrier walls G Groundwater pump and treatment G Surface water collection and treatment G Other
Attachments: G Inspection team roster attached G Site map attached
II. INTERVIEWS (Check all that apply) 1. O&M site manager "V/hJ (D K^l^i^A/^Jj^lfy t)(^^/^CY Name Title Date Interviewed G at site G at office G by phone Phone no. Problerns, suggestions; G Report attached
2. O&M staff P/f)L fM/ll^O-y Ci^ Name Title Date Interviewed G at site G at office G by phone Phone no. Problems, suggestions; G Report attached
D-7 OSWER No. 9355.7-03B-P Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.) Fill in all that apply.
A..ncv #"'%#-' Contact ~gZ7y^^ 0>/^/^^'nt ._ Name Title Date Phone no. Problems; suggestions; G Report attached .
Agency . Contact Name Title Date Phone no. Problems; suggestions; G Report attached
Agency " Contact Name Title Date Phone no. Problems; suggestions; G Report attached
Agency Contact Name Title Date Phone no. Problems; suggestions; G Report attached
Other interviews (optional) G Report attached. f!\JW/^ ^^m^^ ro^A/j^K ^'f^^/J^^/^r
D-8 OSWER No. 9355.7-03B-P
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1. O&M Documents G O&M manual G Readily available G Up to date G N/A G As-built drawings G Readily available G Up to date G N/A G Maintenance logs G Readily available G Up to date G N/A Remarks Qf.t^-^ ^iSl^i' ir^D/^)^ '7l)^/o
2. Site-Specific Health and Safety Plan ^--tf Readily available G Up to date G N/A G Contingency plan/emergency response plan i-.e^eadily available G Up to date G N/A Remarks
3. O&M and OSHA Training Records t^*€ Readily available G Up to date G N/A Remarks
4. Permits and Service Agreeinents G Air discharge permit G Readily available G Up to date G N/A G Effluent discharge i*'"'^ Readily available G Up to date G N/A G Waste disposal, POTW i G Readily available G Up to date G N/A G Other permits G Readily available G Up to date G N/A Remarks
5. Gas Generation Records G Readily available G Up to date -tfN/A Remarks
6. Settlement Monument Records G Readily available G Up to date ^WA Remarks
7. Groundwater Monitoring Records G Readily available ^ G Up to date G N/A . Remarks LMT '^OA'l:: fvA
8. Leachate Extraction Records ••""^ Readily available G Up to date G N/A Remarks A^/nU'V> /^^^A/^r^Vf 1V V.i.(ff^/h/:P6'^^
9. Discharge Compliance Records G Air G Readily available G Up to date .e-l^/A • G Water (effluent) G Readily available G Up to date Remarks
10. Daily Access/Security Logs G Readily available G Up to date jAilK Remarks
D-9 OSWER No. 9355.7-03B-P IV. O&M COSTS
O&M Organization G State in-house G Contractor for State G PRP in-house G Contractor for PRP G Federal Facility in-hotise G Contractor for Federal Facility G Other fl^P /^^'^ CiVY ^^- QU^A^^y O^/P^^-y
2. O&M Cost Records G Readily available G Up to date G Funding mechanism/agreement in place Original O&M cost estimate G Breakdown attached
Total amiual cost by year for review period if available
From To G Breakdown attached Date Date Total cost From To G Breakdown attached Date Date Total cost From To G Breakdown attached Date Date Total cost From To G Breakdovra attached Date Date Total cost From To G Breakdown attached Date Date Total cost
Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: ' /l^O
V. ACCESS AND INSTITUTIONAL CONTROLS G Applicable G N/A
A. Fencing 1. Fencing damaged G Location shown on site map Abates secured G N/A Remarks / ^Ai^ oSfM^lSfj 0y l-^}h^4/KT^ Cf>Um7&/U/iH^y^
B. Other Access Restrictions
1. Signs and other security measures ;g^oocatio( n shown on site map G N/A Remarks
D-10 OSWER No. 9355.7-03B-P C. Institutional Controls (ICs) 1. Implementation and enforcement U^^/^ f^ ^ ^^'vZ^ Site conditions imply ICs not properly implemented G Yes G No G N/A Site conditions imply ICs not being fully enforced G Yes G No G N/A
Type of monitoring (e.g., self-reporting, drive by) Frequency Responsible party/agency Contact Name Title Date Phone no.
Reporting is up-to-date G Yes G No G N/A Reports are verified by the lead agency G Yes G No G N/A
Specific requirements in deed or decision documents have been met G Yes G No , G N/A Violations have been reported G Yes G No G N/A Other problems or suggestions: G Report attached
2. Adequacy _;3^Cs are adequate G ICs are inadequate ' G N/A Remarks
D. General 1. Vandalism/trespassing G Location showTi on site map Js\\o vandalism evident Remarks
2. Land use changes on sitae N/A Remarks
VI. GENERAL SITE CONDITIONS A. Roads G Applicable G N/A
1. Roads damaged G Location shown on site map ^gnkoads adequate G N/A Remarks
D-11 OSWER No. 9355.7-03B-P
B. Other Site Conditions ...... w \louf n}/^/>yiAC^. N=^ SYMlf ^(fis /y^ ^/J/Z^/t^^^ (im^/ii/u>
VII. LANDFILL COVERS G Applicable G N/A
A. Landfill Surface 1. Settlement (Low spots) •^ G Location shown on site map G Settlement not evident Areal extent Depth Remarks
2. Cracks A/ G Location shown on site map G Cracking not evident Lengths Widths Depths Remarks
3, Erosion V 5^'^^|^ G Location shown on site map G Erosion not evident Areal extent ' Depth Remarks
4. Holes -^ \/0(,tO G Location shown on site map G Holes not evident Areal extent Depth Remarks
5. Vegetative Cover /S^mss G Cover properly established G No signs of stress G Trees/Shrubs (indicate size apd locations on a diagram) Remarks
6. Alternative Cover (armored rock, concrete, etc.) Jg^l\ Remarks
7. Bulges ^'y G Location shown on site map G Bulges not evident Areal extent • ' Height Remarks
D-12 OSWER No. 9355.7-03B-P Wet Areas/Water Damage G Wet areas/water damage not evident G Wet areas . / / G Location shown on site map Areal extent G Ponding v^ ^Si>^ '^^ij^ '^ Location shown on site map Areal extent_ G Seeps G Location shown on site map Areal extent_ G Soft subgrade G Location shown on site map Areal extent Remarks
9. Slope Instability G Slides G Location shown on site map Q'm) evidence of slope instability Areal extent , Remarks
B. Benches S^pplicable G N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
I. Flows Bypass Bench G Location shown on site map (S^/KA or okay Remarks
2. Bench Breached G Location shown on site map «^l\/.A or okay Remarks
3. Bench Overtopped G Location shown on site map (yW/AA or okay Remarks
C. Letdown Channels QT^pplicable G N/A (Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)
1. Settlement t-^Uf G Location shown on site map G No evidence of settlement Areal extent "^^^ Depth_ Remarks
2. Material Degradation G Location shown on site map G^o evidence of degradation Material type Areal extent Remarks
3. Erosion G Location shown on site map S^o evidence of erosion Areal extent_ Depth Remarks
D-13 OSWER No. 9355.7-03B-P 4. Undercutting G Location shown on site map 5^o evidence of undercutting Areal extent Depth Remarks
5. Obstructions Type /p/tif^ }f(^l//J4l7^ G No obstructions G Location shown on site map Areal extent Size Remarks
Excessive Vegetative Growth Type /fy \(^^-^ _/ f ^/)^ C G No evidence of excessive growth '^(ICiyK/ 7 \ fyt/y-^ G Vegetation in channels does not obstruct flow G Location shown on site map Areal extent Remarks
D. Cover Penetrations G Applicable G N/A
Gas Vents G Active (J-'t'assive G Properly secured/lockedG Functioning G Routinely sampled G Good condition G Evidence of leakage at penetration G Needs Maintenance G N/A Remarks
2. Gas Monitoring Probes G Properly secured/lockedG Functioning G Routinely sampled G Good condition G Evidence of leakage at penetration G Needs Maintenance S^/A Remarks
3. Mopitoring Wells (within surface area of landfill) GH'roperly secured/lockedG Functioning G Routinely sampled G Good condition G Evidence of leakage at penetration G Needs Maintenance G N/A Remarks
Le^hate Extraction Wells e Properly secured/lockedG Functioning G Routinely sampled G Good condition G Evidence of leakage at penetration G Needs Maintenance G N/A Remarks
5. Settlement Monuments G Located G Routinely surveyed (^G N// A Remarks
D-14 OSWER No. 9355.7-03B-P E. Gas Collection and Treatment G Applicable G N/A B>it/^ r,^ \/S^ 1. Gas Treatment Facilities G Flaring G Thermal destruction G Collection for reuse G Good condition G Needs Maintenance Remarks
2. Gas Collection Wells, Manifolds and Piping G Good condition G Needs Maintenance Remarks
3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) G Good condition G Needs Maintenance G N/A Remarks
F. Cover Drainage Layer G Applicable G N/A.
1. Outlet Pipes Inspected G Functioning G N/A Remarks
2. Outlet Rock Inspected G^unctioning G N/A 1 Remarks
G. Detention/Sedimentation Ponds G Applicable S^/A
1. Siltation Areal extent Depth G N/A G Siltation not evident Remarks
2. Erosion Areal extent Depth G Erosion not evident Remarks
3. Outlet Works G Functioning G N/A Remarks
4. Dam G Functioning G N/A Remarks ^—
D-15 OSWER No. 9355.7-03B-P H. Retaining Walls G Applicable ^N/A
1. Deformations G Location shown on site map G Deformation not evident Horizontal displacement Vertical displacement Rotational displacement Remarks
2. Degradation G Location shown on site map G Degradation not evident Remarks
I. Perimeter Ditches/Off-Site Discharge G Applicable Q^/A 1. Siltation G Location shown on site map G Siltation not evident Areal extent Depth Remarks
2. Vegetative Growth G Location shown on site map G N/A G Vegetation does not impede flow Areal extent Type Remarks
3. Erosion G Location shown on site map G Erosion not evident Areal extent Depth Remarks
4. Discharge Structure G Functioning G N/A Remarks
VIII. VERTICAL BARRIER WALLS G Applicable (>WA
1. Settlement G Location shovra on site map G Settlement not evident Areal extent Depth Remarks
2. Performance MonitoringType of monitoring G Performance not monitored Frequency G Evidence of breaching Head differential Remarks
D-16 OSWER No. 9355.7-03B-P IX. GROUNDWATER/SURFACE WATER REMEDIES G Applicable G N/A
A. Groundwater Extraction Wells, Pumps, and Pipelines G Applicable a^/A
1. Pumps, Wellhead Plumbing, and Electrical G Good condition G All required wells properly operating G Needs Maintenance G N/A Remarks
2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances G Good condition G Needs Maintenance Remarks
Spare Parts and Equipment G Readily available G Good condition G Requires upgrade G Needs to be provided Remarks
B. Surface Water Collection Structures, Pumps, and Pipelines G Applicable eH^l/A
1. Collection Structures, Pumps, and Electrical G Good condition G Needs Maintenance Remarks
Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances G Good condition G Needs Maintenance Remarks
3. Spare Parts and Equipment G Readily available G Good condition G Requires upgrade G Needs to be provided Remarks
D-17 OSWER No. 9355.7-03B-P C. Treatment System G Applicable Qi^l/iA
1. Treatment Train (Check components that apply) G Metals removal G Oil/water separation G Bioremediation G Air stripping G Carbon adsorbers G Filters G Additive (e.g., chelation agent, flocculent)_ G Others G Good condition G Needs Maintenance G Sampling ports properly marked and fimctional G Sampling/maintenance log displayed and up to date G Equipment properly identified G Quantity of groundwater treated annually G Quantity of surface water treated annually Remarks
Electrical Enclosures and Panels (properly rated and functional) G N/A G Good condition G Needs Maintenance Remarks
3. Tanks, Vaults, Storage Vessels G N/A G Good condition G Proper secondary containment G Needs Maintenance Remarks
Discharge Structure and Appurtenances G N/A G Good condition G Needs Maintenance Remarks _' ~
Treatment Building(s) G N/A G Good condition (esp. roof and doorways) G Needs repair G Chemicals and equipment properly stored Remarks
Monitoring Wells (pump and treatment remedy) G Properly secured/lockedG Functioning G Routinely sampled G Good condition G All required wells located G Needs Maintenance G N/A Remarks
D. Monitoring Data
1. Monitorinngu*tg Data W/M^ OHs routinely submitted on time i^Is of acceptable quality Mojiitoring data suggests: (^Groundwater plume is effectively contained G Contaminant concentrations are declining ihJfb^ oA^ fn }-nf£u/^ ^JT/^
D-18 OSWER No. 9355.7-03B-P D. Monitored Natural Attenuation Monitoring Wells (natural attenuation remedy) Q'Troperly secured/lockedG Functioning G Routinely sampled G Good condition G All required wells located G Needs Maintenance G N/A Remarks
X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XI. OVERALL OBSERVATIONS Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). <^}^ M^ /g^ /?^ ..^^^ ^^^//f eM/^<- ,4^y^^^z^ ^^'^S^. ^^^f^ftZ^^A^^d C^^/i'^S e^u^Tjfr^ ^^^£2^
Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and-long-term protectiveness of the remedy.
D-19 OSWER No. 9355.7-03B-P C. Early Indicators of Potential Remedy Problems Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the fiiture.
D. Opportunities for Optimization
Describicnbe possipossibll e opportunities for optimization in monitoring tasks or the operation of the remedy.
D-20 Attachment D: Public Notice of Five Year Review MONDAY, JUNE 25, 2012 Region The 0 jnc> Heral*Vflv| www.wtiigram 3A
POLICY RRiEBSAL Branstad order restrictive on voting rights for felons cates for policies to make it kick back and relax and live ea-sier for felons to vot«. For my hfe i^^'tead of lighting felons. Branstad is "making the system like that," he IOWA CITY, Iowa - Re your right to vote contin said. publican Gov. Terrj' Brans- gent on your financial abili Iowa had long been one tad has made Iowa one of ties." of the most restrictive states the mofil difficult states The tTfcnd in the U.S. for felons' voting rights. in the nation for felons to since 1996 has been to ex When Branstad served as vote, with an eicecutivp pand felon voting rights governor from ISR2 to 19flS, order he isRued lail year and make it easier to have he has said he restored already having disenfran them re:stored. according In thousands of felons' rights chised Lbousandii of people, a report from the Nati<;nal through a similar applica a review by the Associated Conference of State Legis tion process. Press shows. latures. Branstad's successor, On the day he took office, Kentucky. Florida and Vilsack. continued that pol Branstad signed an order Virginia are the other icy until his 2005 executive reversing a six-year policy states that require felons order that automatically re started under Democrat to apply to the governor, stored voting rights for fel Tbm Vilsack in which fel CO but they don't require a ons once they left prison or ons automatically regained credit report. Thirty-eight parole Republicans, includ o their votinf nghts once states allow most felons to ing Branstad, criticized the they were discharged from automatically regain their move as politicully motivat < state supervision. The move voting rights once they ed. Up to 100,000 felons had flew in the face of a nation complete their sentences, their rights restored under wide trend to make vot according to the report. the policy, which was in ef ing eaiiier for feionn. mak Maine and Vermont never fect until after Branstad ing Iowa one of four states Henry Stral^t. wtio has been trying to get kis voting right back, poses for a pictufe wfUi the truck take away voting rightp. won elertion to a fifth term where felons must apply to he drtves at Penford Products In C«dar Rapids, Iowa. A review by the Aswclated Press shows that Others require felons to in November 2010. the governor to have voting Iowa Gov, Tfltry Branstad has made Iowa one of the most dtTflcult states In the U.S. for felons to wait a certain amount of 03 The state's new top elec c rights restored. Branstad's aurclse their right to vote. (AP Phnui) time before becoming eli tions official. Republican o new process requires appU- gible. Secretary of State Matt cants to Eubmil a credit re how-to guide online Sunday Straight spent a year on tory report, which takes Branstad spokesman Schultz, urged Branstad to N port, a provision critics call to help felunB through a pro the effort and hired a law weeks and costs $15. Then Tim Albrecht said Iowa's reinstate the application "35 inappropriate and unique cess that has confused M>mc yer for $500 lo help. Yet he the review can take up to policy helps ensure felons process to 'send a message 60 SECONDS ANNUAL eVFWT CHICAGO (Bcened a S too gift card and reachen the 'doughnut hole,' a no questions asked, THose who certain spending level that isnl Western Electrical Electrical Co-op meetm^ set for Thursday EmergeiK^ test held 03 brought in replica or BB guns covered by h'edicare. CARTH.^GE. III. — The of Carroll White REMC of able to answer questions, at Midway Airport received $10 grfl cards. The governnieni has released 73rd annual mecling of the Monticollo. Ind and Prairie Power's energy- Emeiency officials reSMfid- The ff«nt on SaiunJay a f urry of posrlive ne*s aheaO Western Illinois Elertrical The Hancock County efficiency wall will he on E ed to an attpiane lire i: UidHi^y was held ai atwut two do^en of a Supreme Court ruling on Coop, will be held Thursday Health Department will of display 13 03 Imematiansl Airport thai injured churches. The CtiiMgo Sun- President Barack Obama's night in Carthage. fer blood pressure screen Refreshments of ice Z CL 160 people - but luckit/11 was Times reports rtial reports that health law, v/hich couki come as Registration will begin ings and a free PS.\ screen cream, chips and soda will |usl an emergency drril. so irany firearms were lumed in early as Moncay, at 6 p.m., followed by the ing test for men age 50 and be served. C Saturday's luK^cale *Jiai poHce ran ot;i of gift cards meeting at 7:30 p.m. at the older, or those older than For more information, and told oeople to come back o emergency response eiercise LOMBARD, ILL Ham^ck County Eitension 40 with a family history' of call 3,17-3125. involved Clicago. stale and :he fallowing weekend to gel Center, prostate cancer, Represen- •e .. ledetal o^iaals as well as •Jieir cards. Missing suburtian Reports from Manager lalivcs of Air Evac Lifetime 03 03 W3 N voluntee's posing as victims. It Authorties have loulec previ Chicago tortotse found Paul Dion, board Presi and Generac will be avail < £ CO O was mean; to evaluate how well ous events as a good way to get A 45-pound lonoise who dent Robert Gronewold and ciews would respond la a real deadty weaooffs off the streets. went missing from ttie Chicago Secretary-Treasurer Janet emeigency. In 2007. police collected suburb of tnmbard has beer Spory will follow election Such eierctses miisi be held more than G, 700 weapons. kicated. of the cooperative's board of at least once every three years. The (Adinglon Heights) directors. Nominated by the Chicago Departmerl Daily Hefald reanris the Afncan Nnminating Committee as candidates for re-election to ol Aviation Commissioner '[>oughnLit hole' spurred loriDse named tance Rosemane Andolino sa/s the was bund safe on Saturday in the board arc Mike Ford in safety and security of travel savings average $636 SI. Chartes. He's'i'l. District 1, William Newton ers and employees is of higt)- Thousands of Illinois in District 2 and Jay Mor Owners Andy and Susan rison in District 3. CSt pnonly, and errergency residents wnh high medlca- Lechner sa>' a visitor to Lombard preparedness training is a 1ion costs are seeing some fouid the tortoise in an alley Featured speakers for crillcal to ensuring everythirg gams from a provision of the last weekend and bdieved he the meeting include Jim Thompson, manager of Ad goes smoothly in the event of .Affordable Care Ad aimed at was w:\d. EPA Begins Review an emergency. shrinking the Medicare drug ams Electric Cooperative in The tortoise was kept in an coverage gap koown as the Camp Point; Jay Bartlrtt, of the Adams County Quincy The last ti^scale exercise at empty pool for several days. MIcfway International Atrpon was 'doLghnui hole." president and CEO of Prai Municipal Landfills 2 & 3 The tortoise was returned rie Power Inc. in Jackson- lnJune200g,andalO'Hare Tlie federal govetnment following neis repots about his Quincy, Illinois i-ille; and Randy Price, CEO tntemational, a srmia' rcQUired plans to rdease data Monday disappearance. U.S. Environmental Proleclion A9en[;y is conducting a exercise was neU m September showing more than 26,000 Hl)- Lance isrt the onl>' llllnais five-year revKvj of the Adams County Quincy MunicFpal 20i:. noisars with Medicare coverage tortoise to go m^s-sing in recent OUTWTOttll? Landlills 2 & 3 al Old Sroadway Road south of Illinois saved d total of S16.7 million years. Route 104, about five miles east of the city of Quincy. The on arescriplwn drugs in the first nopwinLeiii In 2009,3 SO^ound Afncan Superfund taw requires regular checkups of sites (hat 5,500 gurts turned in five months nf 2012. have been cleaned up - v/ith waste managed on-site - lo leopard tortoise named Thelma SUBSCRIBE OIM.in( make sure the cleanup continues to protect people and during Chicago event The figures were released went missing tmm Swansea but the environment. Ttiis is the third five-year review of this More than 5,500 weapons early tc the Associated Press. was returred Dy someone who BBlyal site. were lumed in djring Chicago's The average savir^ W3S spotted he' along a road more annual buy^ack event at ci^ IG36 per person. tt.an two weeks lale. EPA's cleanup of volatile organic compounds or VOCs churches. tast year, seniors began consisted of site access and land-use restrictions, Those tuTiing in a giin receiiJing discojnts when they - The Assoaaleti Press providing municipal water to nearby residents, monitoting liquid waste to make sure cleanup was working, improving the landfill cap, grading the landfiil to control erosion, installmg subsurface drains to collect liquid waste, transporting the liquid waste for treatment Are You Feeling...Fat? before discharge at the city's wastewater treatment plant, ^Frustrated? Out of Control? and groundwater monitoring. s Per Day! More information is available a( the Quincy Public ^co'S Library. 526 Jersey Si and al wvw.epa.govregionS/ Remarkable HCG Diet cleanup/adamscounty. The review should be completed by March 2013. M Take it oft & keep it off! JJ3 South Sth The frve^ear review is an opportunity lor you to tell EPA about site conditions and any concerns you have. Qitiru-y. Illmnit (f2S0l Ashley JL '^ 20 Days - '339 Contact: t(t(Xt> 763-9Mti lOSI 22 IBS. ^ ^Q Q . S43g PilTlcli Krami HowanI CaJfw at7t224~SS35 Commjrirv InvotvEtnent CDordi^U^r Remedi^ f^roject Manager In 20 Bans! ^ 312-88M506 312-3S3-9685 ktausE-palicia^pa-Bov ca LOG NUMBERS: 0414-04 PERMIT NO.: 2004-EN-0414 FINAL PLANS, SPECIFICATIONS, APPLICATION DATE ISSUED: ,:MAY 2 1 200V AND SUPPORTING DOCUMENTS PREPARED BY: Conestoga - Rovers & Associates, Inc. SUBJECT: ADAIWS COUNTY QUINCY l-ANDFILLS 2&3 - Hauling of Landfill Leachate - Tributary to the City of Quincy STP PERMITTEE TO CONSTRUCT RECe/VBD W/v Quincy Landfill Remedial Design im^ / Remedial Action Group 1801 Old Highway 8, Suite 114 ^BA, /A/C. St. Paul, fWinnesota 55112 Permit is hereby granted to the above designated pennittee(s) to construct and/or operate water pollution control facilities described as follows: An increase In the maximum flow of leachate to be hauled from the Adams County Quinj:y Landfills 2 &3 to the City of Quincy STP from a maximum of 35,000 gallons per week to 80,000 gallons per week Design Maximum Flow (DMF), The Design Average Flow of 25,000 gallons per week is not being increased. This existing discharge was permitted under Permit # 2001-EN-2829 which was issued on April 6, 2001 This Pennit is issued subject to the following Special Condition(s). If such Special Condition(s) require(s) additional or revised facilities, satisfactory engineering plan documents must be submitted to this Agency for review and approval for issuance of a Supplemental Permit. SPECIAL CONDITION 1: This Permit is issued with the expressed understanding that there shall be no surface discharge from these facilities. If such discharge occurs, additional or aitemate facilities shall be provide^. The construction of such additional or alternate facilities may not be started until a Permit for the construction is issued by this Agency. SPECIAL CONDITION 2: The operational portion of this permit shall be governed by the City of-Quincy. --•.:•: SPECIAL CONDITION 3: The issuance of this permit does not relieve the permittee of the responsibility of complying with 35 III. Adm, Code, Part 307 and/or the General Pretreatment Regulations (40 CFR 403) and any guidelines developed pursuant to Section 301, 306, or 307 of the Federal Clean Water Act of 1977. THE STANDARD CONDITIONS OF ISSUANCE INDICATED ON THE REVERSE SIDE MUST BE COMPLIED WITH IN FULL. READ ALL CONDITIONS CAREFULLY. SAK:DEL:014104.wpd DIVISION OF WATER POLLUTION CONTROL cc: EPA - Springfield FOS Conestoga - Rovers & Associates, Inc. City of Quincy Alan Keller, P.E. Records - Industrial Manager, Permit Section Binds READ ALL CONDITIONS CAREFULLY: STANDARD CONDITIONS The Illinois Environniental Protection Act (Illinois 5. The issuance of this permit: Revised Statutes Chapter 111-12. Section 1039) grants the Environmental Protection Agency authority to a. shall not be considered as in any manner Impose conditions on permits which It Issues. affecting the title of the preiiiises upon which the permitted facilities are to be located; 1. Unless the constmction for which this permit is issued has been completed, this permit will expire b. does not release the permittee from any (1) two years after the date of issuance for permits liability for damage to person or property to construct sewers or wastewater sources or (2) caused by or resulting from the construction, three years after the date of issuance for pemnits to maintenance, or operation of the proposed construct treatment works or pretreatment works. facilities; 2. The construction or development of facilities c. does not release the pemnittee from covered by this permit shall be done in compliance compliance with other applicable statutes and with applicable provisions of Federal laws and regulations of the United States, of the State regulations, the Illinois Environmental Protection of Illinois, or with applicable local laws, Act, and Rules and Regulations adopted by the ordinances and regulations; Illinois Pollution Control Board. d. does not take into consideration or attest to 3. There shall be no deviations from the approved the structural stability of any units or parts of plans and specifications unless a written request the project; for modification of the project, along with plans and specifications as required, shall have been e. in no manner implies or suggests that the submitted to the Agency and a supplemental Agency (or its officers, agents or employees) written permit issued. assumes any liability, directly or indirectly, for any loss due to damage, installation, 4. The pemnittee shall allow any agent duly maintenance, or operation of the proposed .authorized by the Agency upon the presentations equipment or facility. of credentials: 6, Unless a joint construction/operation permit has a. to enter at reasonable times, the permittee's been issued, a permit for operating shall be premises where actual or potential effluent, obtained from the agency before the facility or emission^ or noise sources are located or equipment covered by this pennit is placed into where any activity is to be conducted pursuant operation. to this permit; 7. These standard conditions shall prevail unless b. to have access to and copy at reasonable modified by special conditions. times any records required to be kept under the terms and conditions of this permit; 8, The Agency may file a complaint with the Board for suspension or revocation of a permit: c. to inspect at reasonable times, including during any hours of operation of equipment a, upon dlscovery^that the permit application constructed or operated under this permit, contained misrepresentations, misinformation such equipment or monitoring methodology or or false statement or that all relevant facts equipment required to be kept, used, were not disclosed; or operated, calibrated and maintained under this permit; b, upon finding that any standard or special conditions have been violated; or d. to obtain and remove at reasonable times samples of any discharge or emission of c, upon any violation of the Environmental pollutants; Protection Act or any Rules or Regulation effective thereunder as a result of the e. to enter at reasonable times and utilize any construction or:,development authorized by photographic, recording, testing, monitoring or this permit. other equipment for the purpose of presen/ing, testing, monitoring, or recording any activity, discharge, or emission authorized by this permit. ^ 700 West Lock and Dam Road P 217.228.4560. Contract Services Group n I ., .,*„. F 217.221.2293 Quincy, IL, 62305 dan.abblng@emcstl,com August 21, 2012 Significant Industrial Users (SlU's) Quiiicy, IL 62301 Dear Significant industriatUsers: Enclosed is the Final Pretrealmerit PeriTnil(s) for discharges for your specific site location. The permit as issued covers discharge limitations; monitoring, and reporting requirements. Please review the changes. Also note; failure to meet any portion of the Permit could result in penalties. The Permit, as issued, is effective as of the date indicated on the first page of the Permit.- If you should have any questions or concerns with the Permit, please contact Daniel Ebbing, Pretreatment Coordinator, at 228-4560, extension 13. Sincerely, American Water Enterprises/ Contract Services Group Gregory M. Frieden Project Manager American Water Enterprises'/ Contract Services group Enclosure Proprietary and Confidential CITYOFQUINCV INDUSTRIAL WASTE PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT QWTF #01-029 Adams County Quincy Landfills 2 & 3 Application Date: 06/29/12 9426 Rock Quarry Road Issuance Date: 07/31/12 Quincy, IL 62301 Effective Date: 08/31/12 Expiration Date: 08/31/17 Renewal Date: 06/30/17 In accordance witli all terms and conditions of Chapter 24 of the Municipal Code of tlie City of Quincy of 198,0, as amended in 1995, 200() arid 2007, including any applicable provisions of Federal and Stafe law or regulation; permission is hereby granted: Adams County Quincy Landfills 2 & 3 9426 Rock Quarry Road Quincy, Illinois 62301 Standard Industrial Classification (SIC) #9511 to discharge from the above named facility into the collection system leading into the Quincy Wastewater Treatment Facility (QWTF) in accordance with the standard conditions and attaclimcnts herein. The permittee, the Adams County Quincy Landfills 2 & 3 located at 9426 Rock Quarry Road, is not authorized to discharge af^ef the above expiration date. In order to receiye authonzatioii to discharge beyond the expiration date, the permittee shall submit proper application, as required by Chapter 24 of the Miiiiicipal Code, no later tlvan sixty (60) days prior to the expiration date. /U/1. Gregory M. Frieden Project Manager American Water Enterprises/ Contract Seiyices group CITY OF QUINCY INDUSTRIAL WASTE PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT QWTF #01-029 Part A - Effluent Parameter Limitations The effluent parameter limitations in the table below are based on Section 24.805, "end of pipe" Local Discharge Limitations, and any applicable Federally promiilgated National Pretreatment Standards. When Local and Federal limitations for a parameter differ, Federal Regulations 40-CFR-403.4 and 40-CFR-403.5 requiie that the niore stringent limitations be enforced. The table below contain? the Local Standards that must be met by the Quincy Municipal Landfills 2 & 3's, "end of process" discharge point based on the Municipal Code of the City of Quincy, 40-CFR-4d3, and any other applicable State or Federal regulations. The "end of process" will be at the tank drainage manhole, located at the QWTF. The trucked leachate will be discharged to the QWTF at this point only. PARAMETER DAILY MAX. SOURCE OF LIMITS SAMPLE TYPE pH 5.5-10.0 Municipal Code grab TSS 250 nig/L Municipal Code grab B.CD. 200 mg/L Municipal Code grab Grease/Oil lOO mg/L Municipal Code grab Arsenic 0.18 mg/L Municipal Code grab Cadmium 0.24 mg/L Municipal Code grab Chromium 4.40 mg/L Municipal Code grab Copper 3.38 mg/L , Municipal Code grab Iron 124.4 mg/L Municipal Code grab Lead 1.40 mg/L Municipal Code grab Mercury 0.0031 mg/L Municipal Code grab Nickel 2.n nig/L Municipal Code grab Selenium 0,22 mg/L Municipal Code grab Silver 0.43 mg/L Municipal Code grab Zinc 2.61 mg/L Municipal Code grab ITO(I) 2.13 mg/L Municipal Code grab (1) TTO is the summation of all quantifiable Total Toxic Organics in 40-CFR 403 whose individual values exceed 0.01 mg/L. Part B - Monitoring Schedule The City's Engineering Department or personnel affiliated with Quincy Municipal Landfills 2 & 3 shall effectively monitor the quantity and quality of the Quincy Municipal Landfill 2 & 3 discharged twice per year. All parameters listed in Part A shall be monitored. This information shall be submitted in the "Self Moiiitorihg Report", one from each monitoring period Jariiiaiy 1- June 30 (due July 15) arid July 1 - December 31 (due Januaiy 15). It is also the responsibility of the permittee to ensure that all sampling, presei'vation and laboratory analysis from the discharge point be in accordance with 40-CFR-136. CITY OF QUINCY INDUSTRIAL WASTE PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT QWTF #01-029 7. Compliance Reports; When a compliance schedule has been included as part of the permit, a report is to be submitted by the permittee to the Project Manager in accordance with Section E(2) of this permit, within fourteen (14) days after the scheduled completion of each increment of progress. Municipal Code, Sections 24.1202-24.1204, 8. Accidental, Excessive, or Slug Load Discharge: The permittee shall notify the Project Manager @ 228-4560 or the Pretreatment Coordinator @ 228-4560 Ext. 13 as soon as an accidental, excessive, or slug load discharge occurs at the QWTF. Within five (5) days following the discharge, the user shall submit to the Project Manager, a detailed written report, in accordance with Section E(l) of this permit, describing the cause of the discliarge and the measures taken by the user to prevent future occurrences. Municipal Code, Section 24.1206 (1),(2),(3). 9. Access to Premises; The permittee will allow the QWTF's industrial representative, possessing proper identification, imriiediate access to the permittee's premises for the purpose of inspection, sampling, and monitoring if warranted pursuantto Section 24.1301 (l),(2),(3),(4),(5)of the Quincy Municipal Code. 10. Sludge Disposal: The permittee shall keep track of the disposal of any and all sludge if generated at the facility. The information to be recorded shall include; sludge origin, quantities disposed, sludge hauler, and disposal site. 11. Record Keeping Requirements and Record Access; The permittee will retain all records and liionitoring results pertaining to the permit for a minimum of three (3) years. This period may be extended during the course of any unresolved litigation. The QWTF, with all State and Federal officials, will be allowed access to these records. Municipal Code, Section 24.1213. 12. Permit Changes: The QWTF reserves the right to revise this permit, as limitations and requirements in the Ordinance or the Federal Pretreatment Regulations are modified, or other just cause exists. Municipal Code, Section 24.1105 (l),(2),(3). 13. Permit Transfer: This permit inay riot be reassigned or transfeited to a new owner and/Or operator without prior approval of the Project Manager. The permittee must give thirty (30) days prior notice. 14. Expenses: The permittee shall provide necessary treatment as required by the Ordinance and Federal Pretreatment Regulations. Any facility required to pretreat wastewater to a level acceptable to the City shall provide, operate, and maintain such facilities at the permittee's expense. Municipal Code, Section 24.906. 15. Penalties foi" Violation of Permit: A permittee who violates any provisions of this permit is subject to a civil penalty of not more than $1000 per violation, per day. Violations or noncompliance could result in additional penalties as stated in Article XIV, Article XV and Article XVI of the City's Municipal Code. CITY OF QUINCY IMDUSTRIAL WASTE PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT QWTF #01-029 16. Enforcement: The provisions of thjs permit must be aidhereid to, along with the provisions of the Municipal Code, Chapter 24, Article IV, Sections 24.1401-24.1407, Article XV, Section 24.1501, Article XVL 17. Renewal: The permittee shall have an application for renewal of this permit submitted and received by the Project Manager, in accoidahce with Section E(3) of this permit, a niinimum of sixty (60) days prior to the date of expiration. Municipal Code, Section 24.1107 18. Additional Stipulations: This permit is not all inclusive of the Local Pretreatment Ordinance #8680. The permittee shall be held responsible for all the provisions of the Local Pretreatirient Ordinance #8680. l9. Severability: The provisions of this permit shall be deemed separable, arid the iiwalidity of any portion hereof shall not affect the validity of the remainder thereof. The provisions of this permit are severablCj and if any provision of this permit, or the application of any provision of this permit to any circumstances; is held invalid, the application of such provision to other circumstances, and the reiiiainder of this permit, shall not be affected thereby. Part D - Reporting Requirements Summary 1. Self-Monitoring Reports 1. Submit t\vice each year by January 15 and July 15. 2. Spill or Slug Reports 2. Notify the QWTF's Pretreatment Coord inatoi- or the Project Manager by telephone, as soon as possible, after the spill or shig flow has been discovered, but no later than twenty-four (24) hours following the incident. A written report must be submitted to and received by the Project Manager within five (5) days following accidental, excessive, or slug load discharge. 3i Compliance Reports 3. Submit within fourteen (14) days after the completion of each increment of progress in the compliance schedule. CITY OF QUINCY INDUSTRIAL WASTE PRETREATMENT PROGRAM WASTEWATER DISCHARGE PERMIT QWTF #01-029 4. Permit Renewal Application 4, Submitted application must be received by the Project Manager, a minimum of sixty (60) days in advance of the current permit expiration date. 5. Process or Flow changes 5, Submitted changes must be received by the Project Manager within thiity (30) days, prior to any changes being made. QWTF Telephone Contacts; Mon.-Fri. 6:30am-2:30pm 228-4560 Ext. 13 Daniel Ebbing Pretreatment Coord inator All other times: 228-4560 Quincy Wastewater Treatment AWE/CSG Attachment F: Monthly Leachate Volumes 2008 Monthly Leachate Disposal Volume Leachate Disposal 2008 Gallons Disposed to Quincy POTW Month 260,400 January 204,600 February 260,400 March 235,600 April 86,800 May 161,200 June 105,400 July 43,400 August 142,600 September 37,200 October 12,400 November (DB Repairs) 74,400 December 2009 Monthly Leachate Disposal Volume Leachate Disposal 2009 Gallons Disposed to Quincy POTW Month 37,200 January 49,600 February 136,400 March 124,000 April 80,600 May 31,000 June 18,600 July 173,600 August 24,800 September 291,400 October 217,000 November 173,600 December 2010 Monthly Leachate Disposal Volume Leachate Disposal 2010 Gallons Disposed to Quincy POTW Month 167,400 January 93,000 February 266,600 March 173,600 April 148,800 May 130,200 June 124,000 July 105,400 August 93,000 September • 31,000 October 24,800 November 18,600 December 2011 Monthly Leachate Disposal Volume Leachate Disposal 2011 Gallons Disposed to Quincy POTW Month 49,600 January 204,200 February 155,000 March 136,400 April (Landfill Cap Repairs) 86,800 May 117,800 June 49,600 July 24,800 August 24,800 September 12,400 October 260,400 November 18,600 December Table 12: 2012 Monthly Leachate Disposal Volume Leachate Disposal 2012 Gallons Disposed to Quincy POTW Month 80,400 January 173,600 February 80,600 March 24,800 April 43,400 May 12,400 June 6,200 July 18,600 August 93,000 September 198,400 October November December Attachment G: Environmental Covenant, April 1, 2011: Uniform Environmental Covenant Act ANDREW W. STAFF ANTHONY B. CAMERON Corporation Counsel City Attorney 237 North Sixth Street, Suite 200 529 Hampshire Street, Suite 511 Quincy, Illinois 62301 Quincy, Illinois 62301 217-228-8470 217-228-8669 LEGAL DEPARTMENT CHRISTOPHER G. SCHOLZ City of Quincy BRUCEA.ALFORD Assistant Corporation Counsel Assistant City Attorney 625 Vermont Street 636 Hampshire Street, Suite 101 Quincy, Illinois 62301 Quincy, Illinois 62301 217-223-3444 217-228-9770 April 4, 2011 Mr. Rustin J. Kimmell - Lathrop & Gage LLP 2345 Grand Boulevard, Suite 2200 Kansas City, MO 64108-2618 Re: City of Quincy Landfill Nos. 2 & 3/Environmental Use Covenant Dear Mr. Kimmell: Per your letter of March 29,1 am returning herewith a copy of the recorded Environmental Covenant. Very truly yours, Andrew W, Staff AWS/amw Enclosure Tx:4011758 ZOllll-03147 aecGSiA \/tnM ADAMS COUNTY CLEKKJ RECORDER AOAHS COUHTT, IL LI HOIS aeccAtAa AM tM/Ql/iail 1:47 PH ftEC FEEl 27,00 fits RCCi^nDGR rUi LAd eiS COUNTVPEEi 19.09 Environmental Covenant Under Illinois Uniform Environmental Covenant Act Adams County Quincy Municipal Landfills 2 and 3 Superfund Site [space above reserved for recording information] Please return this instrument to: Name: City of Quincy Address: 730 Main Street Quincy, Illinois 62301 Attention: dAT-f ^LowvPrgo LcEfc. ENVIRONMENTAL COVENANT 1. This Environmental Covenant is made this 2-Z. day of t>io\t$^^^^, 2010, by and among the City of Quincy, Illinois ("Grantor" or "Quincy"), an Illinois municipal corporation^ and the Holders/Grantees further identified in Paragraph 3 below pursuant to the Uniform Environmental Covenants Act, 765 ILCS Ch, 122 ("UECA") for the purpose of imposing activity and use limitations described herein. 2. Property and Grantor A. Property. The real property (the "Property") subject to this Environmental Covenant is located at Rock Quarry Road in Quincy, Adams County, Illinois and is legally described in Appendix A, hereinafter referred to as the "Property". B. Grantor: Quincyisthecurrentfeeownerof the Property and is the "Grantor" of this Environmental Covenant. The mailing address of the Grantor is: City of Quincy 730 IVIaine Street Quincy, Illinois 62301 3. Holders (and Grantees for purposes of indexing): A. The Illinois Environmental Protection Agency (Illinois EPA) is a Holder (and Grantee for purposes of indexing) of this Environmental Covenant pursuantto its authority under Section 3(b) of UECA. The mailing address of the Illinois EPA is 1021 N. Grand Avenue East, P.O. Box 19276, Springfield, IL 62794-9276. B. Quincy is a Holder (and Grantee for purposes of indexing) of this Environmental Covenant pursuant to UECA. Regardless of any future transfer of the Property, Quincy shall remain a Holder of this Environmental Covenant. Quincy is to be identified as both Grantee and Grantor for purposes of indexing. 4. ' Agencies: The Illinois EPA and the United States Environmental Protection Agency (U.S. EPA) are "Agencies" within the meaning of Section 2(2) of UECA. The Agencies have approved the environmental response project described in Paragraph 5 below and may enforce this Environmental Covenant pursuant to Section 11 of UECA. 5. Environmental Response Prefect and Administrative Record; A. This Environmental Covenant arises under an environmental response project as defined in Section 2(5) of UECA. B. The Property is part of the Adams County Quincy Municipal Landfills 2 and 3 Superfund Site (the "Site"), which the U.S. EPA, pursuantto Section 105 of the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), 42 U.S.C, §,9605, placed on the National Priorities List, set forth at 40 C.F.R. Part 300, Appendix B, by publication in Volume 55 of the Federal Register on August 30,1990, page 35508. . In a Record of Decision ("ROD") signed by the Director of Illinois EPA on September 29,1993, and concurred on by the U.S. EPA Region 5 Superfund Division Director on September 30,1993, the Agencies approved a plan for environmental remediation of the Site. In a Consent Order filed on May 13, 1996, Settling Defendants agreed to implement the remedial action plan in the ROD, as later modified in an Explanation of Significant Differences issued by Illinois EPA on January 7,1998, including restricting and prohibiting on-site groundwater use, on-site building construction, and on-site drilling, excavating or other soil intrusive activities except for purposes of remedial design, sampling, monitoring and remedial action. The remedial action plan requires implementation and compliance with land and groundwater activity and use limitations at the Site in order to prevent unacceptable exposures from hazardous substances remaining at the Site. C. Grantor wishes to cooperate fully with the Agencies in the implementation, operation, and maintenance of all response actions at the Site. I D. The Administrative Record for the environmental response project at the Site (including the Property) is maintained at the U.S. EPA Superfund Record Center, 7"^ Floor, 77 West Jackson Blvd, Chicago, Illinois 60604. Persons may also contact Jan Ogden, Illinois EPA, Bureau of Land, #24, 1021 N. Grand Avenue East, P.O. Box 19276, Springfield, IL 62794-9276 for the Administrative Record or other information concerning the Site. 6. Grant of Covenant. Covenant Runs With The Land: Grantor creates this Environmental Covenant pursuant to UECA so that the Activity and Use Limitations and associated terms and conditions set forth herein shall "run with the land" in accordance with Section 5(a) of UECA and shall be binding on Grantor, its heirs, successors and assigns, and on all present and subsequent owners, occupants, lessees or other person acquiring an interest in the Property. 7. • Activity and Use Limitations: The following Activity and Use Limitations apply to the use of the Property unless and until they are modified in accordance with Paragraphs: A. No disturbance of cover: Except as provided in a plan approved by Illinois EPA with U.S. EPA concurrence, and for activities required to comply with 35 III. Adm, Code Parts 807 and 811, no action shall be taken to excavate or drill or intrude into, or penetrate or othenwise disturb the Property except for purposes of remedial design, sampling, monitoring and remedial action that may be demarcated as part of the Remedial Action to be selected by U.S. EPA for the" Site. B. No interference with remedy: There shall be no interference of any sort, with the construction, operation, maintenance, monitoring, efficacy, or physical integrity of any component, structure, or improvement resulting from or relating to the Remedial Action on the Property. No action shall be taken that would cause waste materials covered as part of the remedy to become exposed. C. Land uses: No building shall be constructed on the Property. D. Ground water uses: No activities shall be conducted on the Property that extract, consume, or otherwise use any groundwater from the Property, nor shall any wells be constructed on the Property for purposes other than ground water monitoring, unless approved by Illinois EPA and U.S. EPA. 8. Right of Access: Grantor consents to officers, employees, contractors, and authorized representatives of the Holders, Illinois EPA and U.S. EPA entering and having continued access at reasonable times to the Property for the following purposes: A. Implementing, monitoring, operating and maintaining the environmental response project described in paragraph 5 above; B. Verifying any data or information submitted to the State or the United States; C. Conducting investigations relating to contamination at or near the Site, including conducting periodic reviews of the environmental response project described in paragraph 5 above; D. Obtaining samples; E. Assessing the need for, planning, preparing for, and/or Implementing response actions at or related to the Site; F. Inspecting and copying records, operating logs, contracts, or other documents maintained or generated related to response activity at the Site; G. Assessing compliance with the Consent Order; and H. Verifying that no action is being taken on the Property in violation of the terms of this instrument, the environmental response project described in paragraph 5 above or of any federal or state environmental laws or regulations. Nothing in this document shall limit or othenwise affect U.S. EPA and Illinois EPA's rights of entry and access or U.S. EPA's and Illinois EPA's authority to take response actions under CERCLA, the National Contingency Plan ("NCP"), RCRA or other federal and state law. 9. Reserved rights of Grantor: Grantor hereby reserves unto itself, its successors, and assigns, including heirs, lessees and occupants, all rights and privileges in and to the use of the Property which are not incompatible with the activity and use limitations identified herein. 10. No Public Access and Use: No right of access or use by the general public to any portion of the Property is conveyed by this instrument. 11. Future Convevances. Notice and Reservation: A. Grantor agrees to include in any future instrument conveying any interest in any portion of the Property, including but not limited to deeds, leases and mortgages, a notice and reservation which is in substantially the following form: THE INTEREST CONVEYED HEREBY IS SUBJECT TO AND GRANTOR SPECIFICALLY RESERVES THE ENVIRONMENTAL COVENANT EXECUTED UNDER THE UNIFORM ENVIRONMENTAL COVENANTS ACT (UECA) AT 765 ILCS CH. 122 RECORDED IN THE OFFICIAL PROPERTY RECORDS OF ADAMS COUNTY, ILLINOIS ON H'l-AOi\ AS DOCUMENT NO. AOf/^-A'^/^l. IN FAVOR OF AND ENFORCEABLE BY GRANTOR AS A UECA HOLDER, THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY AS A UECA HOLDER AND THE U.S. ENVIRONMENTAL PROTECTION AGENCY AS A UECA AGENCY. B. Grantor agrees to provide written notice to Illinois EPA and U.S. EPA at least 30 days prior to any conveyance of fee title to the Property or any portion of the Property. Among other things, the notice shall identify the name and contact information of the transferee, and the portion of the Property to be conveyed to that Owner. 12. Enforcement and Compliance. A. Civil Action for Injunction or Equitable Relief. This Environmental Covenant may be enforced through a civil action for injunctive or other equitable relief for any violation of any term or condition of this Environmental Covenant, including violation of the Activity and Use Limitations under Paragraph 7 and denial of Right of Access under Paragraph 8. Such an action may be brought individually or jointly by: i. the Illinois EPA; ii. the Holders of the Environmental Covenant; ill. U.S. EPA; B. Other Authorities Not Affected. No Waiver of EnforcemenL All remedies available hereunder shall be in addition to any and all other remedies at law or in equity, including CERCLA. Nothing in this Environmental Covenant affects U.S. EPA or Illinois EPA's authority to take or require performance of response alctions to address releases or threatened releases of hazardous substances or pollutants or contaminants at or from the Property, or to enforce a consent order, consent decree or other settlement agreement entered into by U.S. EPA or Illinois EPA. Enforcement of the terms of this instrument shall be at the discretion of the Holders, the U.S. EPA and Illinois EPA and any forbearance, delay or omission to exercise its rights under this instrument in the event of a breach of any term of this instrument shall not be deemed to be a waiver by the Holders, U.S. EPA or Illinois EPA of such term or of any subsequent breach of the same or any other term, or of any of the rights of the Holders, U.S. EPA or Illinois EPA of such term or of any subsequent breach of the same or any other term, or of any of the rights of the Holders, U.S. EPA or Illinois EPA. C. Former Owners And Interest Holders Subject to Enforcement. An Owner, or other person that holds any right, title or interest in or to the Property remains subject to enforcement with respect to any violation of this Environmental Covenant by the Owner or other person which occurred during the time when the Owner or other person was bound by this Environmental Covenant regardless of whether the Owner or other person has subsequently conveyed the fee title, or other right, title or interest, to another person. 13. Waiver of certain defenses: This Environmental Covenant may not be extinguished, limited, or impaired through issuance of a tax deed, foreclosure of a tax lien, or application of the doctrine of adverse possession, prescription, abandonment, waiver, lack of enforcement, or acquiescence, or similar doctrine as set forth in Section 9 of UECA. 14. Representations and Warranties: Grantor hereby represents and warrants to the Illinois EPA, U.S. EPA and any other signatories to this Environmental Covenant that, at the time of execution of this Environmental Covenant, that the Grantor is lawfully seized in fee simple of the Property, that the Grantor has a good and lawful right and power to sell and convey it or any interest therein, that the Property is free and clear of encumbrances, except those noted on Appendix B attached hereto, and that the Grantor will forever warrant and defend the title thereto and the quiet possession thereof. After recording this instrument, Grantor will provide a copy of this Environmental Covenant to ail holders of record of tlie encumbrances including those entities noted on Appendix B. 15. Amendment or Termination. Except the Illinois EPA and U.S. EPA, all Holders and other signers waive the right to consent to an amendment or termination of the Environmental Covenant, This Environmental Covenant may be amended or terminated by consent only if the amendment or termination is signed by the Illinois EPA, U.S. EPA and the current owner of the fee simple of the Property, unless waived by the Agencies. If Grantor no longer owns the Property at the time of proposed amendment or termination. Grantor waives the right to consent to an amendment or termination of the Environmental Covenant. 15. Notices: Any notice, demand, request, consent, approval, or communication that any party desires or is required to give to the others shall be In writing and shall either be served personally or sent by first class mail, postage prepaid, addressed as follows: City of Quincy 730 Main Street Quincy, Illinois 62301 United States Environmental Protection Agency Superfund Division 77 W. Jackson Blvd. Mail Code: SR-6J Chicago IL 60604-3590 Illinois Environmental Protection Agency Chief, Bureau of Land 1021 N. Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 16. Recording and Notice of Environmental Covenant. Amendments and Termination. A. The Original Environmental Covenant. An Environmental Covenant must be recorded in the Office of the Recorder or Registrar of Titles of the county in which the property that is the subject of the Environmental Covenant is ' located. Within 30 days after the Illinois EPA and U.S. EPA (whichever is later) sign and deliver to Grantor this Environmental Covenant, the Grantor shall record this Environmental Covenant In the office of the County Recorder or Registrar of Titles for the County in which the Property is located. B. Termination, Amendment or Modification. Within 30 days after Illinois EPA and U.S. EPA (whichever is later) sign and deliver to Owner any termination, amendment or modification of this Environmental Covenant, the Owner shall record the amendment, modification, or notice of termination of this Environmental Covenant in the office of the County Recorder or Registrar of Titles in which the Property is located. C. Providing Notice of Covenant, Termination, Amendment or Modification. Within 30 days after recording this Environmental Covenant, the Grantor shall transmit a copy of the Environmental Covenant in recorded form to: i. the Illinois EPA; ii. the U.S. EPA; ill. each person holding a recorded interest in the Property, including those interests in Appendix B; iv. each person in possession of the Property; and V. each political subdivision in which the Property is located. Within 30 days after recording a termination, amendment or modification of this Environmental Covenant, the Owner shall transmit a copy of the document in recorded form to the persons listed in items i to v above. , 17. General Provisions: A. Controlling law: This Environmental Covenant shall be construed according to and governed by the laws of the State of Illinois and the United States of America. B. Liberal construction: Any general rule of construction to the contrary notwithstanding, this instrument shall be liberally construed in favor of the grant to effect the purpose of this instrument and the policy and purpose of the environmental response project and its authorizing legislation. If any provision of this instrument is found to be ambiguous, an interpretation consistent with the purpose of this instrument that would render the provision valid shall be favored over any interpretation that would render it invalid. C. No Forfeiture: Nothing contained herein will result in a forfeiture or reversion of Grantor's title in any respect. D. Joint Obligation: if there are two or more parties identified as Grantor herein, the obligations imposed by this instrument upon them shall be joint and several. E. Captions: The captions in this instrument have been inserted solely for convenience of reference and are not a part of this instrument and shall have no effect upon construction or interpretation. 18. Effective Date. This Environmental Covenant is effective on the date of acknowledgement of the signature of the Illinois EPA and U.S. EPA, whichever is later. 8 19. List of Appendices; Appendix A - Legaj Description and map of the Property Appendix B - List of Recorded Encumbrances FOR THE CITY OF QUINCY IN WITNESS WHEREOF, the City of Quincy has caused this Notice to be signed in its name. Executed this 2-Z- day of /Wvi^^^^2010. City of Quincy, Illinois STATE OF ILLINOIS COUNTY OF ADAMS I, the undersigned, a Notary Public, in and for said County and State aforesaid, DO HEREBY CERTIFY, that-^^MAr^J^^^L. 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 acknowledged that he signed, sealed and delivered the said instrument as his free and voluntary act, for the uses and purposes therein set forth, including the release and waiver of the right of homestead. Given under my hand and Notary seal, this 2.Z. day of r^^^^^^*^D. 2010. fotary Public My Commission Expires: *VWVVVV.«(>N.wvA/VVS,»«.... OFRCIAL SEAL ANDREW W. STAFF NOTARV PUlitfC. ST Ai E OF laiNoe MV;cCi^K!5Si:!WEXPIRES 10-28-2IM4 10 FOR THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY Bv X\L,J?a^(^/jG^<^^ (smaiure) boucflds P - ^ctfff , Director llllndis Environmental Protection Agency State of Illinois ) )SS. County of • ) . This instrument was acknowledged before me on / I^A^C^ ^. 20 i ' . by 1?0U/^LAS P. ^CotV . a delegate of the Director of the lllinois^nvironmental Protection Agency, a state agency, on behalf of the State of Illinois. (signature) T^olary Public ^ .^f My Commission Expires /^^jy*^/^3 ^// / t ^.. OFFICIAL SEAL t % SHERRIE A. ELZINGA i t NOTARYPtJBLIO,STATEdFILLINOIS? I MY COMMISSION EXPIRES 12-23^201t:? 11 FOR THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY On behalf of the Administrator of the United States Environmental Protection Agency B^^3iAl^M(^^|^/17( ^(h) Richard C. Karl, Dlrect6r ^ * (/ Superfund Division U.S. Environmental Protection Agency, Region 5 STATE OF ILLINOIS )SS. COUNTY OF COOK ) The foregoing instrument was acknowledged before me this 9^ day of J^ECg/^ Q/l ^:h^^' (sionaturel Notary Public -/ / My Commission Expires -^/^^ /' V , _^ 12 Appendix A - Legal Description and map of the Property The land referred to in this Commitment is described as follows: A part of the West Thirty (30) acres of the Southeast Quarter of the Northeast Quarter of said Section One (1) which lies South of the Old Broadway Road, as now layed out, and more particularly described as follows, to-wit: Commencing at the Southwest corner of the Southeast Quarter of the Northeast Quarterof said Section One (1), running thence North parallel with the West line of said Southeast Quarter of the Northeast Quarter of said Section One (1) to the South line of said Old Broadway Road, thence in a Southeasterly direction along the South line of said Old Broadway Road to the West line of the East Ten (10) acres of said Southeast Quarter of said Northeast Quarter, thence South along the West tine of said Ten (10) acre tract to the South line of said Southeast Quarter of said Northeast Quarter of said Section One (1) , thence West along the South line of said Southeast Quarter of the Northeast Quarter of Section One (1) to the place of beginning, all of said real estate being situated in Township Two (2) South of the Base Line and in Range Eight (8) West of the Fourth Principal Meridian, all situated in the County of Adams and the State of Illinois, subject to Right of Way recorded in Book 11 of Right of Ways, at page 1380. The Northeast Quarter of the Southeast Quarter of Section One (1) In Township Two (2) South of the Base Line, and In Range Eight (8) West of the Fourth Principal Meridian, in the County of Adams, in the State of Illinois, subject to Right of Way recorded in Book 11 of Right of Ways, at page 1380. Parcel No,: 20-0-0031-000-00 20-0-0046-000-00 13 tf4in»4 rrwttr, iMt. EXPLANATIOH NOT TO SCALE 0 -— MtMOAUT OP LMtonix *a- John Moth«« it Atao'clahs, Inc. ____ •OUNOAIIV or UMCriLL #s **•—"" AMRMTI VJOHITY MAP aiIriMCT|JUJHOI$ PIQUHE 2- e«64S. 14 Appendix B - List of Recorded Encumbrances 1. NOTICE executed by the City of Quincy filed May 28,1996 in the Office of the Recorder of Deeds, Quincy. Adams County, Illinois in Volume 92 of Misc. at Page 37. 2. NOTICE OF ACCESS EASEMENT executed by the City of Quincy filed May 28,1996 in the Office of the Recorder of Deeds, Quincy, Adams County, Illinois In Volume 92 of Misc. at Page 36. 3. MEMORANDUM OF CONSENT ORDER AND JUDGMENT Civil Action No. 96-3072 filed May 23', 1996 In the U.S. District Court for the Central District of Illinois against City of Quincy, et al in favor of People of the State of Illinois. 4. PLAT OFRIGHT OF WAY filed June 11,1979 in the Office of the Recorder of Deeds, Quincy, Adams County, Illinois in Volume 11 rw at Page 1380. 15