US EPA RECORDS CENTER REGION 55us EPA RECORDS CENTER REGION

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Third Five-Year Review ReportThird Five-Year Review Report forfor

Pagel's Pit Superfund SitePagel's Pit Superfund Site Winnebago County, IllinoisWinnebago County, Illinois

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Prepared by:Prepared by: United States Environmental Protection AgencyUnited States Environmental Protection Agency

RegionRegion 55 Chicago, IllinoisChicago, Illinois

S e p t e m b e r 2012September 2012

ApprovedApproved by:by: Date:Date:

_t2..,r / ^j c d t ^ {!a ite f- lO' / -L. Richard C. Karl, DirectorRichard C. Karl, Director Superfund DivisionSuperfund Division U.S. EPA, RegionU.S. EPA, Region 55

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Table of ContentsTable of Contents

List of~cronymsList of AcronymsExecutive SummaryExecutive SummaryFive-Year Review Summary FormFive-Year Review Summary Form

I.I.II.II.III.III.

IV.IV.

V.V.VI.VI.

VII.VII.VIILVIII. IX.IX. X.X. XI.XI.

IntroductionIntroduction Site ChronologySite Chronology BackgroundBackground Physical CharacteristicsPhysical Characteristics Land and Resource UseLand and Resource Use History of ContaminationHistory of Contamination Initial ResponseInitial Response Basis for Taking ActionBasis for Taking Action Remedial ActionRemedial ActionRemedy SelectedRemedy Selected Remedy ImplementationRemedy Implementation Institutional ControlsInstitutional Controls Systems Operation and Operation and MaintenanceSystems Operation and Operation and Maintenance Progress Since the Last Five-Year ReviewProgress Since the Last Five-Year ReviewFive-Year Review ProcessFive-Year Review ProcessAdministrative ComponentsAdministrative Components Community Notification and InvolvementCommunity Notification and Involvement Document ReviewDocument Review Data ReviewData Review Site InspectionSite Inspection InterviewsInterviews Technical AssessmentTechnical Assessment

IssuesIssues Recommendations and Follow-Up ActionsRecommendations and Follow-Up Actions Protectiveness StatementProtectiveness Statement Next ReviewNext Review

TableTable Table 1. Institutional Controls Summary TableTable 1. Institutional Controls Summary Table Table 2: Issues, Recommendations and Follow-Up ActionsTable 2: Issues, Recommendations and Follow-Up Actions

FiguresFigures Figure 1. Map of Site with Potentiometric Surface for Fourth Quarter 2011Figure 1. Map of Site with Potentiometric Surface for Fourth Quarter 2011 Figure 2. 2012 Upper Zone GMZ Boundary MapFigure 2. 2012 Upper Zone GMZ Boundary Map Figure 3. 2012 Lower Zone GMZ Boundary MapFigure 3. 2012 Lower Zone GMZ Boundary Map

v~

viiVII

ixix

11 22 22

1111

1515 1717

1919 2020 2020 2121 2121

1414 2020

2222 2323 2424

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List of A c r o n y m sList of Acronyms

AOCAOCAGQSACQSARARsARARsCFRCFRCERCLACERCLACERCUSCERCLIS

cis-1,2-DCEcis-I,2-DCE CQACQAESDESDFSFSGCCSGCCS GIAGlA GMZGMZ HCTUHCTUHIHI lAClAC ICIC IEPAlEPAILCSILCSWCBIPCBLEGLFG LTRALTRAMCLMCL MCLGMCLG mslmslNN NCPNCP NPDESNPDES NPLNPLOUOU PAHPAHPCEPCEPRPPRPRARARPMRPMRCRARCRA RDRDRIRI RODROD SVOCSVOC TCETCE U.S. EPAU.S. EPA UU/UEUUIUE VOCVOC

Administrative Order by ConsentAdministrative Order by Consent applicable groundwater quality standard of 35 lAC 811.320applicable groundwater quality standard of 35 lAC 811.320 applicable or relevant and appropriate requirementsapplicable or relevant and appropriate requirements Code of Federal RegulationsCodeof Federal Regulations Comprehensive Environmental Response, Compensation, and Liability ActComprehensive Environmental Response, Compensation, and Liability Act Comprehensive Environmental Response, Compensation, and Liability IiifonnationComprehensive Environmental Response, Compensation, and Liability Infonnation

SystemSystem cis-1,2-dichloroethenecis-I,2-dichloroethene construction quality assuranceconstruction quality assurance Explanation of Significant DifferencesExplanation of Significant Differences feasibility studyfeasibility study gas collection and control systemgas collection and control system groundwater impact assessmentgroundwater impact assessment groundwater management zonegroundwater management zone home carbon treatment unithome carbon treatment unit hazard indexhazard index Illinois Administrative CodeIllinois Administrative Code institutional controlinstitutional control Illinois Environmental Protection AgencyIllinois Environmental Protection Agency Illinois Compiled StatutesIllinois Compiled Statutes Illinois Pollution Control BoardIllinois Pollution Control Board landfill gaslandfill gas long-tenn remedial actionlong-term remedial action maximum contaminant levelmaximum contaminant level maximum contaminant level goalmaximum contaminant level goal mean sea levelmean sea level nitrogennitrogen National Contingency PlanNational Contingency Plan National Pollutant Discharge Elimination SystemNational Pollutant Discharge Elimination System National Priorities ListNational Priorities List operable unitoperable unit polynuclear aromatic hydrocarbonspolynuclear aromatic hydrocarbons tetrach loroethylene (perchloroethylene)tetrachloroethylene (perchloroethylene) potentially responsible partypotentially responsible party remedial actionremedial action remedial project managerremedial project manager Resource Conservation and Recovery ActResource Conservation and Recovery Act remed ial designremedial design remedial investigationremedial investigation Record of DecisionRecord of Decision semivolatile organic compoundsemivolatile organic compound trich loroethenetrichloroethene United States Environmental Protection AgencyUnited States Environmental Protection Agency unlimited use or unrestricted exposureunlimited use or unrestricted exposure volatile organic compoundvolatile organic compound

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Pagel's Pit Site--Five-Year Review Report Page vi September 2012 Pagel's Pit Site-Five-Year Review Report Page vi September 2012

Executive SummaryExecutive Summary

The remedy for the Pagel's Pit Superfund site (Site), Winnebago County, Illinois, is set forth in aaThe remedy for the Pagel's Pit Superfttnd site (Site), Winnebago County, Illinois, is set forth in Record of Decision (ROD) dated June 28, 1991 for operable unit (aU) 11 and a ROD datedRecord of Decision (ROD) dated June 28, 1991 for operable unit (OU) and a ROD dated September 30, 1999 which includes the remedy for OU and also the remedy for OU 1.September 30, 1999 which includes the remedy for au 22 and also amendsamends the remedy for au 1.

This remedy included:This remedy included: an engineered cover system for the waste disposal area (OU 1);•• an engineered finalfinal cover system for the waste disposal area (aU 1);

•• leachate extraction and transfer of the leachate to the local publicly owned treatment worksleachate extraction and transfer of the leachate to the local publicly owned treatment works for treatment (aU 1);for treatment (OU 1);

•• gas extraction and the use of the gas for fiiel or the flaring of the gas (OU 1);gas extraction and the use of the gas for fuel or the flaring of the gas (aU 1); restoration of the aquifer the waste disposal area and the zone of attenuation to•• restoration of the aquifer outsideoutside the waste disposal area and the zone of attenuation to drinking water standards monitored natural attenuation with contingency for thedrinking water standards viavia monitored natural attenuation with aa contingency for the groundwater downgradient of the Site (OU 1);groundwater downgradient of the Site (aU 1); deed restrictions limiting the development of the property and the placement ofnew wells on•• deed restrictions limiting the development of the property and the placement of new wells on the property and adjacent to the Site, including the area west of Killbuck Creek (aU 1), andthe property and adjacent to the Site, including the area west of Killbuck Creek (OU 1), and limiting the placement of new wells on the southeast comer property (aU 2); andlimiting the placement of new wells on the southeast comer property (OU 2); and

•• Site monitoring, including monitoring of the groundwater in the southeast comer, andSite monitoring, including monitoring of the groundwater in the southeast comer, and maintenance of all remedial action components (OU I and OU 2).maintenance of all remedial action components (aU 1 and au 2).

The contingency remedy for the aquifer restoration is an active system that would beThe contingency remedy for the aquifer restoration is an active system that would be implemented if it were determined that the groundwater contamination was not decreasingimplemented if it were determined that the groundwater contamination was not decreasing satisfactorily downgradient or the contaminated groundwater would become an immediate threatsatisfactorily downgradient or the contaminated groundwater would become an immediate threat to downgradient water supply. The U.S. Environmental Protection Agency (U.S. EPA) notedto aa downgradient water supply. The U.S. Environmental Protection Agency (U.S. EPA) noted constmction completion in the ROD dated September 30, 1999. The construction of the coverconstruction completion in the ROD dated September 30, 1999. The construction of the cover was completed with the acceptance by Illinois Environmental Protection Agency (lEPA), Bureauwas completed with the acceptance by Illinois Environmental Protection Agency (IEPA), Bureau of Land, Permit Section of the constmction quality assurance (CQA) report for the eastern por­of Land, Permit Section of the construction quality assurance (CQA) report for the eastern por­tion in May 2002. The trigger for this third review was the signing of the second five­tion in May 2002. The trigger for this third five-yearfive-year review was the signing of the second five­year review on September 24, 2007. In late 2007, landfill gas-to-electricity plant that uses gasyear review on September 24,2007. In late 2007, aa landfill gas-to-electricity plant that uses gas from the Site became operational and was supplying power to the grid.from the Site became operational and was supplying power to the grid.

The assessment of this five-yearfive-year review is that the remedy was constructed in accordance withThe assessment of this review is that the remedy was constmcted in accordance with the two RODs and is functioning as anticipated. The remedies for au 11 and au 2 are protectivethe two RODs and is functioning as anticipated. The remedies for OU and OU 2 are protective of human health and the environment in the short term because exposure pathways that couldof human health and the environment in the short term because exposure pathways that could result in unacceptable risks are being controlled. Therefore the remedy for the entire Site isresult in unacceptable risks are being controlled. Therefore the remedy for the entire Site is protective in the short term. Long-term protectiveness requires compliance with effectiveprotective in the short term. Long-term protectiveness requires compliance with effective institutional controls (ICs). In order for the remedies for OU and OU 2 to be protective in theinstitutional controls (lCs). In order for the remedies for au 11 and au 2 to be protective in the long term, additional ICs are necessary and the effectiveness of the ICs and of the long-termlong term, additional ICs are necessary and the effectiveness of the ICs and of the long-term stewardship procedures need to be evaluated. Long-term stewardship requires that effective ICsstewardship procedures need to be evaluated. Long-term stewardship requires that effective ICs will be maintained and monitored along with maintaining the Site remedy. All required remedieswill be maintained and monitored along with maintaining the Site remedy. All required remedies are included in the active permits issued by lEPA.are included in the active permits issued by IEPA.

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Five-Year Review Summary FormFive-Year Review Summary Form

SITE IDEl\TIFICATIONSITE IDENTIFICATION

1 Site Name: Pagel's Pit

EPA ID: ILD980606685

Region: 5

Site Name: Pagel's Pit

EPA ill: ILD980606685

State: IL City/County: Winnebago County

1

1 NPL Status: Final

1 Multiple OUs? Yes

SITE STATUS

Has the site achieved construction completion? Yes

1

1

Lead agency: U.S. EPA

Author name: Bemard Schorle

Author affiliation: U.S. EPA

Review period: 9/11 to 9/12

Dateof site inspection: 9/08/1

Type of review: Statutory

Review number:

Triggering action date: 9/24/07

Due date (fiveyears after triggering action date):

Lead agency: U.S. EPA

Author name: Bernard Schorle

Author affiliation: U.S. EPA

Review period: 9/11 to 9/12

Date of site inspection: 9/08/11

Type of review: Statutory

Review number: 33

Triggering action date: 9/24/07

Due date (five years after triggering action date): 9/24/129/24/12

Issues/RecommendationsIssues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None

OU(s) without Issues/Recommendations Identified in the Five-Year Review:

None

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Five-Year Review Summary Form (continued)

Issues and Recommendations Identified in the Five-Year Review:

Issue Category: Institutional controlsOU(s):OU(s): auOU I and1 and Issue Category: Institutional controls 0 U 2OU2

Issue:Issue: IA. Institutional Controls-- The additional ICs specified by the 1999 ROD need to1 A. histitutional Controls- The additional ICs specified by the 1999 ROD need to be impJ,::~mented and existing ICs need to be reviewed.be implemented and existing ICs need to be reviewed. IB. Institutional Controls-Along with assuring that effective ICs are in place forIB. Institutional Controls--Along with assuring that effective ICs are in place for all areas that do not support unlimited use, long-term stewardship must be assured,all areas that do not support unlimited use, long-tenn stewardship must be assured, which includes maintaining and monitoring effective ICs.which includes maintaining and monitoring effective ICs.

Recommendation:Recommendation: IA. Institutional Controls--The landfill owner will be directed to perfonn a study1 A. Institutional Controls—The landfill owner will be directed to perform a study of the ICs.of the ICs. 18. Institutional Controls--U.S. EPA will review the landfill owner's IC study andIB. Institutional Controls-U.S. EPA will review the landfill owner's IC study and existing solid waste permit, develop an IC plan to identify required follow-upexisting solid waste pennit, develop an IC plan to identify required follow-up actions to assure that effective ICs are in place, and based on IC study, PRP willactions to assure that effective ICs are in place, and based on IC study, PRP will implement ICs as needed, and assure that effective procedures exist for long-termimplem;:nt ICs as needed, and assure that effective procedures exist for long-tenn Site stewardship.Site stewardship.

Affect CurrentAffect Current Affect FutureAffect ]~uture ImplementingImplementing Oversight PartyOversight Party Milestone DateMilestone Date ProtectivenessProtectiveness ProtectivenessProtectiveness PartyParty

NoNo YesYes PRP/U.S. EPAPRPIU.S. EPA U.S. EPAU.S. EPA June 2013June 2013

Site" ide Pmteetinness StatementSitcwide Protecti\eness Statement

Protectiveness Determination:Protectiveness Determination: Short-tenn ProtectiveShort-term Protective

Protectiveness Statement:Protectiveness Statement: The remedies for au I and au 22 are protective of human health and the environment in the short tennThe remedies for OU 1 and OU are protective of human health and the environment in the short term because the remedy is functioning as anticipated and exposure pathways that could result in unacceptablebecause the remedy is functioning as anticipated and exposure pathways that could result in unacceptable risks are being controlled. Therefore the remedy for the entire Site is protective in the short term. Long­risks are being controlled. Therefore the remedy for the entire Site is protective in the short tenn. Long­term protectiveness requires compliance with effective ICs. In order for the remedies forOU and OU 2 totenn protectiveness requires compliance with effective ICs. In order for the remedies for au 11and au 2 to be protective in the long term, additional institutional controls are necessary and the effectiveness of thebe protective in the long terril', additional institutional controls are necessary and the effectiveness of the institutional controls and of the long-term stewardship procedures need to be evaluated. Long-terminstitutional controls and of the long-tenn stewardship procedures need to be evaluated. Long-tenn stewardship requires that effective ICs will be maintained and monitored along with maintaining the Sitestewardship requires that effe:ctive ICs will be maintained and monitored along with maintaining the Site remedy.remedy.

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Pagel's Pit Superfund SitePagel's Pit Superfund Site Winnebago County, IllinoisWinnebago County, Illinois

Third Five-Year Review ReportThird Five-Year Review Report

I. IntroductionI. Introduction

The purpose of the five-yearfive-year review is to detennine whether the remedy at aa site is protective ofThe purpose of the review is to determine whether the remedy at site is protective of human health and the environment. The methods, and conclusions of reviews are docu­human health and the environment. The methods, findings,findings, and conclusions of reviews are docu­mented in review report. In addition, the review report identifies issuesmented in aa five-yearfive-year review report. In addition, the five-yearfive-year review report identifies issues found during the review, if any, and identifies recommendations to address them.found during the review, if any, and identifies recommendations to address them.

The United States Environmental Protection Agency (U.S. EPA) is preparing thisThe United States Environmental Protection Agency (U.S. EPA) is preparing this five-yearfive-year review report pursuant to Section 121 of the Comprehensive Environmental Response,review report pursuant to Section 121 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. 9621, and to the National ContingencyCompensation, and Liability Act (CERCLA), 42 U.S.C. §§ 9621, and to the National Contingency Plan (NCP), 40 CFR Part 300. Secfion 121 of CERCLA states:Plan (NCP), 40 CFR Part 300. Section 121 ofCERCLA states:

If the President selects aa remedial action that results in any hazardous substances, pollutants, orIf the President selects remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less oftencontaminants remaining at the site, the President shall review such remedial action no less often than each 55 years after the initiation of such remedial action to assure that human health and thethan each 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 uponenvironment are being protected by the remedial action being implemented. In addition, ifupon such review it is the Judgment of the President that action is appropriate at such site in accordancesuch 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 reportwith section 104 or 106, the President shall take or require such action. The President shall report to the Congress list of facilities for which such review is required, the results of all such reviews,to the Congress aa list offacilities for which such review is required, the results of all such reviews, and any actions taken as result of such reviews.and any actions taken as aa result of such reviews.

U.S. EPA interpreted this requirement further in the NCP. The NCP in 40 CFRU.S. EPA interpreted this requirement further in the NCP. The NCP in 40 CFR §300.430(f)(4)(ii) states:§300.430(f)(4)(ii) states:

If remedial action is selected that results in hazardous substances, pollutants, or contaminantsIf aa 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 leadremaining 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 theagency shall review such action no less often than every five years after the initiation of the selected remedial action.selected remedial action.

Region of the U.S. EPA, which is the lead agency for the Site, has conducted theRegion 55 of the U.S. EPA, which is the lead agency for the Site, has conducted the five-yearfive-year review of the remedy implemented at the Pagel's Pit Superfund Site (the Northern Unit,review of the remedy implemented at the Pagel's Pit Superfund Site (the Northern Unit, sometimes called the North Unit, of Winnebago Reclamation Service's Winnebago Landfill) nearsometimes called the North Unit, of Winnebago Reclamation Service's Winnebago Landfill) near Rockford, Illinois. This review was conducted for the entire Site by the remedial projectRockford, Illinois. This review was conducted for the entire Site by the remedial project manager (RPM) through May 2012. This report documents the results of the review.manager (RPM) through May 2012. This report documents the results of the review.

This is the third review for the Pagel's Pit Site. The triggering action for this statutoryThis is the third five-yearfive-year review for the Pagel's Pit Site. The triggering action for this statutory review is the signature date of the second review report, September 24, 2007. The five­review is the signature date of the second five-yearfive-year review report, September 24,2007. The five­year review is required due to the fact that hazardous substances, pollutants, or contaminantsyear review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use or unrestricted exposure (UU/UE).remain at the Site above levels that allow for unlimited use or unrestricted exposure (UUIUE).

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II. Site ChronologyII. Site Chronology

EventEvent

Landfill began operationLandfill began operation

Discovered landfill gas escaping from the landfill and began gas extractionDiscovered landfill gas escaping irom the landfill and began gas extraction

Fund-lead remedial investigation (RI) and feasibility study (FS) beganFund-lead remedial investigation (RI) and feasibility study (FS) began

Site proposed for the National Priorities List (NPL)Site proposed for the National Priorities List (NPL)

Finalized on the NPLFinalized on the NPL

Administrative Order by Consent for the RI and FSAdministrative Order by Consent for the RI and FS

Potentially responsible parties (PRPs) take over the RI and FSPotentially responsible parties (PRPs) take over the RI and FS

Reports for the RI and FS submittedReports for the RI and FS submitted

Proposed Plan for operable unit (aU) 11 releasedProposed Plan for operable unit (OU) released

Public meeting to discuss Proposed Plan and RI and FS reportsPublic meeting to discuss Proposed Plan and RI and FS reports

End of public comment period for the Proposed Plan for au 11End of public comment period for the Proposed Plan for OU

Record of Decision (ROD) for au ]Record of Decision (ROD) for OU 1

Consent Decree for OU 1 remedial design (RD) and remedial action (RA)Consent Decree for au ] remedial design (RD) and remedial action (RA)

RD beganRD began

On-site mobilization for RA began (closure of western portion of landfill)On-site mobilization for RA began (closure of western portion oflandfill)

RA beganRA began

Construction quality assurance report for western portion submitted to IllinoisConstruction quality assurance fl~port for western portion submitted to l1Iinois Environmental Protection Agency (IEPA)Environmental Protection Agency (lEPA)

Western portion construction quality assurance report accepted by the IEPAWestern portion construction quality assurance report accepted by the lEPA

Proposed Plan for au 22 remedy and au I remedy amendment releasedProposed Plan for OU remedy and OU 1 remedy amendment released

Public meeting to discuss au 22 proposed remedy and au ] proposed remedy changePublic meeting to discuss OU proposed remedy and OU 1 proposed remedy change

Informal public meeting to expand on the discussion that began at 8/25/99 meetingInformal public meeting to expand on the discussion that began at 8/25/99 meeting

End of public comment period for the 1999 Proposed PlanEnd of public comment period for the 1999 Proposed Plan

ROD for OU remedy and ROD Amendment for OU remedy changeROD for au 22 remedy and ROD Amendment for au 11 remedy change

Construction completion under CERCLAConstruction completion under CERCLA

Closure of eastern portion of landfill beganClosure of eastern portion of landfill began

Construction quality assurance report for eastern portion submitted to IEPAConstruction quality assurance report for eastern portion submitted to lEPA Eastern portion construction quality assurance report accepted by the lEPAEastern portion construction quality assurance report accepted by the IEPA

First five-yearfive-year review reportFirst review report

Second review reportSecond five-yearfive-year review report

Site inspection for third reviewSite inspection for third five-yearfive-year review

III. BackgroundIII. Background

Physical CharacteristicsPhysical Characteristics

DateDate

7/]7/727/17/72

approximately 1980approximately 1980

]0/118410/1/84

10/15/8410/15/84

6/10/866/10/86

8/27/868/27/86 effective 10/16/86effective 10/16/86

8/27/868/27/86

March 1991March 1991

4/] 6/914/16/91

4/25/914/25/91

5/16/915/16/91

6/28/916/28/91

lodged 11/25/92lodged 11125/92 entered 2/11/93entered 2/11193

12/14/9212/14/92

7/]4/977/14/97

8/8/978/8/97

2/23/982/23/98

6/18/986/18/98

about 8/13/99about 8/13/99

8/25/998/25/99

9/8/999/8/99

9/1 ]/999/11/99

9/30/999/30/99

9/30/999/30/99

August 2000August 2000

September 1September 200200 I

May 2002May 2002

9/27/029/27/02

9/24/079/24/07 9/08/119/08/11

The former Pagel's Pit Site occupied about 90 acres and is located in southern WinnebagoThe fonner Pagel's Pit Site occupied about 90 acres and is located in southern Winnebago County at 8403 Lindenwood Road. It is on the west side of Lindenwood Road, south of BaxterCounty at 8403 Lindenwood Road. It is on the west side of Lindenwood Road, south of Baxter Road, about 55 miles south of Rockford, Illinois. The solid waste landfill part of the SuperfundRoad, about miles south of Rockford, Illinois. The solid waste landfill part of the Superfiand Site began accepting wastes in 1972 under an IEPA permit and is designated as the Northern UnitSite began accepting wastes in 1972 under an lEPA permit and is designated as the Northern Unit Pagel's Pit Site-Five-Year Review Report Page September 2012Pagel's Pit Site--Five-Year Review Report Page 22 September 2012

of the Winnebago Landfill Facility. The Northern Unit ceased accepting solid wastes in 2000of the Winnebago Landfill Facility. The Northem Unit ceased accepting solid wastes in 2000 when it reached its permitted capacity; it encompassed about 42.7 acres. The operator haswhen it reached its pennitted capacity; it encompassed about 42.7 acres. The operator has developed and operated new landfill under an lEP permit for the remaining acreage, locateddeveloped and operated aa new landfill under an IEPAA pennit for the remaining acreage, located south of the Northem Unit, which is called the Southem Unit; it encompasses about 27.65 acres.south of the Northern Unit, which is called the Southern Unit; it encompasses about 27.65 acres. These two disposal units are separate units but are authorized under single lEP permit. PermitThese two disposal units are separate units but are authorized under aa single IEPAA pennit, Pennit No. 1991-138-LF. The Southem Unit, however, is not part of the Superfiand Site. These twoNo. 1991-138-LF. The Southern Unit, however, is not part of the Superfund Site. These two units, the groundwater monitoring wells, and some other features near the Site are shown inunits, the groundwater monitoring wells, and some other features near the Site are shown in Figure 1. It is to be noted that the designations for some of the monitoring wells have changedFigure 1. It is to be noted that the designations for some of the monitoring wells have changed over the years due to permit requirements. Wastes have also been disposed of on the landover the years due to pennit requirements. Wastes have also been disposed of on the land between the Northem and the Southem Units and on the side slopes of these two units above thebetween the Northern and the Southern Units and on the side slopes of these two units above the land between them, an area which is call the Southem Unit Expansion. This area permittedland between them, an area which is call the Southern Unit Expansion. This area waswas pennitted by the State under Subtitle D standards and is constmcted with an earthen and high-densityby the State under Subtitle 0 standards and is constructed with an earthen and high-density polyethylene liner with leachate collection system. With the construction of the Southem Unitpolyethylene liner with aa leachate collection system. With the construction of the Southern Unit Expansion, the area of the Northem Unit has been reduced to about 31.59 acres. The total area ofExpansion, the area of the Northern Unit has been reduced to about 31.59 acres. The total area of the Southem Unit Expansion is about 13.1 acres. There is another unit north of the Northemthe Southern Unit Expansion is about 13.1 acres. There is another unit north of the Northern Unit, called the North Expansion Unit, which is now accepting wastes. This unit wasUnit, called the North Expansion Unit, which is now accepting wastes. This unit was constmcted and is operating under different permit (Permit No. 2006-221-LF).constructed and is operating under aa different pennit (Pennit No. 2006-221-LF).

Municipal refiise and sewage treatment plant sludge (non-hazardous solid wastes) were theMunicipal refuse and sewage treatment plant sludge (non-hazardous solid wastes) were the primary wastes accepted at the Site. Other industrial wastes were accepted that are defined asprimary wastes accepted at the Site. Other industrial wastes were accepted that are defined as "special wastes" in the Illinois statutes. An Illinois special waste is aa broad category of wastes"special wastes" in the Illinois statutes. An Illinois special waste is broad category of wastes that does not meet the definition of municipal refuse. Special wastes are defined in 35 Illinoisthat does not meet the definition of municipal refiise. Special wastes are defined in 35 Illinois Administrative Code (lAC) Part 810 as "industrial process waste, pollution control waste orAdministrative Code (lAC) Part 810 as "industrial process waste, pollution control waste or hazardous waste, except as determined pursuant to section 22.9 of the act and 35 111. Adm. Codehazardous waste, except as detennined pursuant to section 22.9 of the act and 35 Ill. Adm. Code 808."808."

The topography surrounding the landfill area is generally relatively to gently rolling. TheThe topography surrounding the landfill area is generally relatively flatflat to gently rolling. The landfill lies outside the 100-year of Killbuck Creek and is not within any designatedlandfill lies outside the 100-year floodplainfloodplain of Killbuck Creek and is not within any designated wetland area. AA small wetland area waswas identified near the waste disposal area but has sincesmall wetland areawetland area. identified near the waste disposal area but has since been moved and expanded under U.S. Army Corps of Engineering permit.been moved and expanded under aa U.S. Anny Corps of Engineering pennit.

The surficial unconsolidated deposits in the area of the Site are predominantly glacial drift rang­The surficial unconsolidated deposits in the area of the Site are predominantly glacial drift rang­ing from aa thin mantle over the dolomite in the bedrock uplands to the east of the Site to greatering from thin mantle over the dolomite in the bedrock uplands to the east of the Site to greater than 70 feet in the bedrock valley west of the Site. The unconsolidated deposits arethan 70 feet in the bedrock valley west of the Site. The unconsolidated deposits are predominantly sand and gravel undemeath and north of the Site with silty clay to the south ofpredominantly sand and gravel underneath and north of the Site with aa silty clay to the south of the Site. The underlying bedrock surface is highly variable. The dolomite bedrock is generallythe Site. The underlying bedrock surface is highly variable. The dolomite bedrock is generally fractured but the intensity is variable. Chert layers or nodules were commonly noted on boringfractured but the intensity is variable. Chert layers or nodules were commonly noted on boring logs as were vugs, small void spaces, expected in dolomite, but cavemous zones are present.logs as were vugs, small void spaces, expected in dolomite, but cavernous zones are notnot present.

Land and Resource UsesLand and Resource Uses

The Site is located in aa predominately rural unincorporated area. It is bounded on the west byThe Site is located in predominately mral unincorporated area. It is bounded on the west by Killbuck Creek and on the east by Lindenwood Road. The contaminated groundwater has movedKillbuck Creek and on the east by Lindenwood Road. The contaminated groundwater has moved to the west side of Killbuck Creek, thus moving the boundaries of the Site beyond the 90 acresto the west side of Killbuck Creek, thus moving the boundaries of the Site beyond the 90 acres mentioned above. Killbuck Creek, perennial stream, merges with the Kishwaukee River aboutmentioned above. Killbuck Creek, aa perennial stream, merges with the Kishwaukee River about 2.5 miles northwest of the Site. The Kishwaukee River merges with the Rock River about 1.52.5 miles northwest of the Site. The Kishwaukee River merges with the Rock River about 1.5

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miles northwest of the confluence of Killbuck Creek and the Kishwaukee River. The Site ismiles northwest of the confluence of Killbuck Creek and the Kishwaukee River. The Site is located on topographic high between Killbuck Creek to the west and unnamed intermittentlocated on aa topographic high between Killbuck Creek to the west and unnamed intermittent streams to the north and the south. Land use around the Site has been mix of agricultural, mralstreams to the north and the south. Land use around the Site has been aa mix of agricultural, rural residential, and industrial. However the residences that were closest to the Site atresidential, commercial,commercial, and industrial. However the residences that were closest to the Site at the time of the remedial investigation no longer exist or are not used as residences. Thethe time of the remedial investigation no longer exist or are not used as residences. The Rockford Skeet and Trap Club is located near the entrance to the Site.Rockford Skeet and Trap Club is located near the entrance to the Site.

The Acme Solvent Reclaiming (Morristown Plant) Superfund site (Acme Solvent site) is locatedThe Acme Solvent Reclaiming (Morristown Plant) Superfund site (Acme Solvent site) is located east of the Pagel's Pit Site; the Acme Solvent site is shown on Figure 1. The Acme Solvent siteeast of the Pagel's Pit Site; the Acme Solvent site is shown on Figure I. The Acme Solvent site was proposed for U.S. EPA's National Priorities List (NPL) in December 1982 and was finalizedfinalizedwas proposed for U.S. EPA's National Priorities List (NPL) in December 1982 and was on the list in September 1983. Around 1990 the general direction of groundwater flowflow in theon the list in September 1983. Around 1990 the general direction of groundwater in the area of the two sites was from east to west in the upper aquifer. Contamination released from thearea of the two sites was from east to west in the upper aquifer. Contamination released from the Acme Solvent site carried toward the Pagel's Pit Site. Part of the remediation for the AcmeAcme Solvent site waswas carried toward the Pagel's Pit Site. Part of the remediation for the Acme Solvent site the installation of pump-and-treat system that includes downgradientSolvent site waswas the installation of aa pump-and-treat system that includes downgradient extraction wells approximately half-way between the two sites and mass extraction wells closerextraction wells approximately half-way between the two sites and mass extraction wells closer to the Acme Solvent site. The system was placed into full-scale service in January 1996; theto the Acme Solvent site. The system was placed into full-scale service in January 1996; the downgradient extraction wells were taken out of service in January 2000. The groundwaterdowngradient extraction wells were taken out of service in January 2000. The groundwater extraction and treatment system was placed in long-duration pulse mode operation inextraction and treatment system was placed in aa long-duration pulse mode operation in September 2007 to address changes in site conditions and improve performance of the system inSeptember 2007 to address changes in site conditions and improve performance of the system in meeting ground water cleanup objectives. Under the pulse mode operational adjustment, themeeting ground water cleanup objectives. Under the pulse mode operational adjustment, the system is mn intermittently and then maintained in stand-by status during inactive periods.system is run intermittently and then maintained in stand-by status during inactive periods. Operation of the system has affected the groundwater directions between the two sites. TheOperation of the system has affected the groundwater flowflow directions between the two sites. The purpose of this system is to prevent or minimize the movement of contaminated groundwaterpurpose of this system is to prevent or minimize the movement of contaminated groundwater from the Acme Solvent site toward the west, northwest, and southwest. The treated water is dis­from the Acme Solvent site toward the west, northwest, and southwest. The treated water is dis­charged into the intermittent stream that passes across the Acme Solvent site, lies north of thecharged into the intermittent stream that passes across the Acme Solvent site, lies north of the Pagel's Pit Site, and discharges into Killbuck Creek; generally the water infiltrates the groundPagel's Pit Site, and discharges into Killbuck Creek; generally the water infiltrates the ground before it reaches Killbuck Creek. The population of Winnebago County was approximatelybefore it reaches Killbuck Creek. The population of Winnebago County was approximately 295,000 in 2010 with about 139,000 people residing in Rockford.295,000 in 2010 with about 139,000 people residing in Rockford.

History of ContaminationHistory of Contamination

The Northern Unit is located at aa former sand and gravel quarry. It opened for business on JulyThe Northem Unit is located at former sand and gravel quarry. It opened for business on July 17, 1972. The unit has been sequentially constmcted and in several sections. Development17, 1972. The unit has been sequentially constructed and filledfilled in several sections. Development has generally occurred in an east to west direction, in the southem half and then in thehas generally occurred in an east to west direction, firstfirst in the southern half and then in the northem half as proceeded westward, but the westem portion was the part to benorthern half as fillingfilling proceeded westward, but the western portion was the firstfirst part to be brought to the permitted height. The landfill liner was constmcted by grading andbrought to the finalfinal permitted height. The landfill liner was constructed by grading and compacting the base and side walls of the landfill. Asphaltic concrete installed over thecompacting the base and sidle walls of the landfill. Asphaltic concrete waswas installed over the sides and and compacted, resulting in minimum two-inch thick layer. The surface of thesides and floorfloor and compacted, resulting in aa minimum two-inch thick layer. The surface of the asphalt was sealed with cationic coal tar sealer. This sealed asphalt liner was covered withasphalt was sealed with aa ca.tionic coal tar sealer. This sealed a.sphalt liner was covered with eight inches of sand.eight inches of sand.

AA network of perforated pipes was installed in the sand on the sloping base. The pipes were con­network of perforated pipes was installed in the sand on the sloping base. The pipes were con­nected to manholes where the liquid that drains from the wastes (leachate) collected. However,nected to manholes where the liquid that drains from the wastes (leachate) collected. However, this original leachate collection system no longer functions. The leachate is now pumped fromthis original leachate collection system no longer functions. The leachate is now pumped from vertical dual leachate/gas extraction wells, which have been installed nearly to the base of thevertical dual leachate/gas extraction wells, which have been installed nearly to the base of the landfill, to tank on the landfill's property. From there it is pumped through force main tolandfill, to aa tank on the landfill's property. From there it is pumped through aa force main to aa

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sewer connected to the wastewater treatment plant in Rockford. Landfill gas is collected and waswassewer connected to the wastewater treatment plant in Rockford. Landfill gas is collected and originally flared.flared. Presently it is being used as aa fuel in combustion engines that generateoriginally Presently it is being used as ftiel in combustion engines that generate electricity. The previously used flaresflares remain in service as aa backup for the engines. The systemelectricity. The previously used remain in service as backup for the engines. The system for landfill gas extraction has been developed over the years, since the discovery in about 1980for landfill gas extraction has been developed over the years, since the discovery in about 1980 that landfill gas was leaking from the waste disposal area.that landfill gas was leaking from the waste disposal area.

The Pagel's Pit Site proposed for inclusion on the NPL in October 1984 because the nearbyThe Pagel's Pit Site waswas proposed for inclusion on the NPL in October 1984 because the nearby groundwater was found to be contaminated with arsenic, cadmium, and bis(2-ethylhexyl) phthal­groundwater was found to be contaminated with arsenic, cadmium, and bis(2-ethylhexyl) phthal­ate. The Site was on the NPL in June 1986.ate. The Site was finalizedfinalized on the NPL in June 1986.

Initial ResponseInitial Response

U.S. EPA and few of the PRPs for the Site reached an agreement embodied in an Administra­U.S. EPA and aa few of the PRPs for the Site reached an agreement embodied in an Administra­tive Order by Consent (AOC), with an effective date of October 16, 1986, that required the Re­tive Order by Consent (AOC), with an effective date of October 16, 1986, that required the Re­spondents to the Order to conduct aa RI and aa FS at the Site. Portions of these studies werespondents to the Order to conduct RI and FS at the Site. Portions of these studies were carried out by Warzyn Inc., who waswas retained by the PRPs who had signed the AOC. Thecarried out by Warzyn Inc., who retained by the PRPs who had signed the AOC. The reports for the remedial investigation and the feasibility study were submitted in March 1991.reports for the remedial investigation and the feasibility study were submitted in March 1991. Additional investigations were later carried out under this AOC and 1993 Consent Decree.Additional investigations were later carried out under this AOC and aa 1993 Consent Decree.

Based on the data from the remedial investigation, the water table occurs in the fractured dolo­Based on the data from the remedial investigation, the water table occurs in the fractured dolo­mite bedrock east of and below approximately the eastem quarter of the Pagel's Pit Site. Undermite bedrock east of and below approximately the eastern quarter of the Pagel's Pit Site. Under the remainder of the Site and west of the Site, the water table occurs in the unconsolidatedthe remainder of the Site and west of the Site, the water table occurs in the unconsolidated materials. The overall direction of groundwater in the area of the two sites was from east tomaterials. The overall direction of groundwater flowflow in the area of the two sites was from east to west in the upper aquifer during the RI. However, at the Acme Solvent site and along thewest in the upper aquifer during the RI. However, at the Acme Solvent site and along the southem edge of the waste disposal area of the Northem Unit, the was to the west-south­southern edge of the waste disposal area of the Northern Unit, the flowflow was to the west-south­west, with the direction being more southerly at the Acme Solvent site. Along the northem edgewest, with the direction being more southerly at the Acme Solvent site. Along the northern edge of the waste disposal area the flow was toward the west-northwest.of the waste disposal area the flow was toward the west-northwest.

Proposed Plan for OU was released to the public on April 16, 1991. This Proposed PlanAA Proposed Plan for OU 11 was released to the public on April 16, 1991. This Proposed Plan presented number of alternatives as possible remedies for the problems that had been identifiedpresented aa number of alternatives as possible remedies for the problems that had been identified at the Pagel's Pit Site. The Proposed Plan also included aa description of the remedy preferred byat the Pagel's Pit Site. The Proposed Plan also included description of the remedy preferred by U.S. EPA and IEPA. The Record of Decision (ROD) for OU 1, in which the remedy selected forU.S. EPA and lEPA. The Record of Decision (ROD) for OU 1, in which the remedy selected for the Site waswas described, waswas signed June 28, 1991. OU 11 is comprised of the landfill wastes andthe Site described, signed June 28, 1991. OU is comprised of the landfill wastes and contaminated groundwater at the downgradient side of the Site. OU 22 is the groundwatercontaminated groundwater at the downgradient side of the Site. OU is the groundwater contamination in the southeast comer of the Site that waswas undergoing further study at the time ofcontamination in the southeast comer of the Site that undergoing fiirtber study at the time of the ROD for OU 1. The separation into operable units was made because the source of thethe ROD for OU I. The separation into operable units was made because the source of the contamination in the southeast comer had not been determined at the time of the 1991 ROD. Thecontamination in the southeast comer had not been determined at the time of the 1991 ROD. The southeast comer (OU 2) waswas shown in the 1993 Consent Decree as aa strip of land that extendedsoutheast comer (OU 2) shown in the 1993 Consent Decree as strip of land that extended from the waste boundary along the south side of the Northern Unit south to the then landfillfrom the waste boundary along the south side of the Northem Unit south to the then landfill property boundary. On the west it began aa short distance east of the southernmost point of theproperty boundary. On the west it began short distance east of the southernmost point of the waste disposal area and extended on the east to Lindenwood Road.waste disposal area and extended on the east to Lindenwood Road.

AA ConsentConsent Decree, entered on February 11, 1993, requires several of the PRPs to perfoml theDecree, entered on Febmary II , 1993, requires several of the PRPs to perfomi the RD, RA, and operation and maintenance for the remedy selected in the 1991 ROD. ThisRD, RA, and operation and maintenance for the remedy selected in the 1991 ROD. This ConsentConsent Decree requires the operator of the landfill, one of the PRPs, to actually perform the remedialDecree requires the operator of the landfill, one of the PRPs, to actually perform the remedial work and to pay U.S. EPA for some of its past costs. It requires the other PRPs (de minimiswork and to pay U.S. EPA for some of its past costs. It requires the other PRPs (de minimis

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parties) to pay U.S. EPA for some of its past costs and to contribute to aa trust fund that was to beparties) to pay U.S. EPA for some of its past costs and to contribute to tmst fiind that was to be used to help pay for the remedial design and the remedial action.used to help pay for the remedial design and the remedial action.

The 1991 ROD did not require that the landfill be closed at that time. It could continue toThe 1991 ROD did not require that the landfill be closed at that time. It could continue to operate until it had reached its permitted capacity. Regular monitoring of the groundwater andoperate until it had reached its permitted capacity. Regular monitoring of the groundwater and the leachate continued at the Site, which was conducted pursuant to the 1991 ROD and thethe leachate continued at the Site, which was conducted pursuant to the 1991 ROD and the operating permit that had been issued by lEP for the landfill. This resulted in the installation ofoperating permit that had b{:en issued by IEPAA for the landfill. This resulted in the installation of additional monitoring wells and the acquisition of fiirther data on the groundwater and theadditional monitoring wells and the acquisition of ful1her data on the groundwater and the leachate since the remedial investigation.leachate since the remedial investigation.

Chloride ion served as an indicator of groundwater that may have been affected by leachate fromChloride ion served as an indicator of groundwater that may have been affected by leachate from the landfill for many years. Chloride ion is generally recognized as conservative, non-reactivethe landfill for many years. Chloride ion is generally recognized as aa conservative, non-reactive parameter in groundwater systems. Based on the April 1998 groundwater data, the area contain­parameter in groundwater systems. Based on the April 1998 groundwater data, the area contain­ing elevated chloride ion concentrations extended from about midway along the north border ofing elevated chloride ion concentrations extended from about midway along the north border of the landfill (east of well G15S (B15R)'), around the westem end of the landfill, and along thethe landfill (east of well Gl5S (BI5R)'), around the western end of the landfill, and along the south border of the landfill to at least the southwest area (well R42S l 15)) (see Figure for thesouth border of the landfill to at least the southwest area (well R42S (G(G 115)) (see Figure 11 for the locations of the wells). This is the area that may have been affected by leachate from the landfilllocations of the wells). This is the area that may have been affected by leachate from the landfill prior to any remediation. Generally, the affected area was relatively close to the waste boundaryprior to any remediation. Generally, the affected area was relatively close to the waste boundary (within 100 to 200 feet), but well on the other side of Killbuck Creek (well G34S) also had an(within 100 to 200 feet), but aa well on the other side of Killbuck Creek (well G34S) also had an elevated chloride ion concentration. Other wells west of the creek sometimes had elevatedelevated chloride ion concentration. Other wells west of the creek sometimes had elevated chloride ion concentrations in 1998 and before, particularly well G35D.chloride ion concentrations in 1998 and before, particularly well G35D.

In accordance with the operating permit issued by lEPA, applicable groundwater qualityIn accordance with the operating permit issued by IEPA, applicable groundwater quality standards (AGQSs) have been established for the Site. The Site groundwater standards werestandards (AGQSs) have been established for the Site. The Site groundwater standards were established by sampling groundwater wells located hydraulically upgradient of the Site. Thisestablished by sampling groundwater wells located hydraulically upgradient of the Site. This method of sampling is called background sampling and establishes the quality of groundwatermethod of sampling is called background sampling and establishes the quality of groundwater before it enters and beneath the Site. The sampling includes large list of organic andbefore it enters and passespasses beneath the Site. The sampling includes aa large list of organic and inorganic compounds (constituents). The AGQS established for any constituent is the back­inorganic compounds (constituents). The AGQS established for any constituent is the back­ground concentration unaffected by site operations or an altemate standard established byground concentration unaffected by site operations or an alternate standard established by petitioning the Illinois Pollution Control Board (IPCB). (See 35 lAC 811.320 for fiirtherpetitioning the Illinois Pollution Control Board (lPCB). (See 35 lAC 811.320 for further information about AGQSs. Part 811 of 35 lAC is entitled "Standards for New Solid Waste Land­information about AGQSs. Part 811 of 35 lAC is entitled "Standards for New Solid Waste Land­

As used here, background concentration the concentration of a constituent that isfills".)fills".) As used here, background concentration meansmeans the concentration ofa constituent that is established as the background in accordance with the Illinois regulations, usually from upgradientestablished as the background in accordance with the Illinois regulations, usually from upgradient wells. Statistical tests and procedures are used in determining the background concentrations.wells. Statistical tests and procedures are used in determining the background concentrations. The AGQS values for the Northem Unit were derived from wells G09M, G09D, G13S, G13D,The AGQS values for the Northern Unit were derived from wells G09M, G090, G13S, G130, and G20D. However, only well G20D was designated by lEP as upgradient. Theand G20D. However, only well G20D was designated by IEPAA as upgradient. The concentrations in all of these wells have been influenced by releases from the Acme Solvent site;concentrations in all of these wells have been influenced by releases from the Acme Solvent site; this is especially tme for well G20D.this is especially true for well G200.

The AGQSs are not the cleanup standards required by the 1991 ROD. The cleanup standardsThe AGQSs are not the cleanup standards required by the 1991 ROD. The cleanup standards required by the ROD are maximum contaminant levels (MCLs) or non-zero maximumrequired by the ROD are maximum contaminant levels (MCLs) or non-zero maximum contaminant level goals (MCLGs), except that cumulative carcinogenic risk of I 10"̂ andcontaminant level goals (MCLGs), except that aa cumulative carcinogenic risk of 1 xx 10-5 and aa cumulative HI of 1.0 are to be used for 1,1-dichloroethene, arsenic, and those contaminantscumulative HI of 1.0 are to be used for 1, 1-dichloroethene, arsenic, and those contaminants without MCLs. However, groundwater cleanup standards below detection limits using U.S. EPAwithout MCLs. However, groundwater cleanup standards below detection limits using U.S. EPA

1. The fonner designation is given in parenthesis. Some wells do not have aa fonner designation.1. The former designation is given in parenthesis. Some wells do not have former designation.

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approved methods for analysis of drinking water might be modified. MCLs and the 1 x 10-5 riskapproved methods for analysis of drinking water might be modified. MCLs and the 1x10'^ risk level were selected because concentrations in the neighborhood of 1 xx 10-6 risk are often belowlevel were selected because concentrations in the neighborhood of I 10"̂ risk are often below reasonably achievable detection levels. Because the AGQS is determined using backgroundreasonably achievable detection levels. Because the AGQS is determined using background quality, the AGQS may be greater or less than the MCL or other cleanup standard that has beenquality, the AGQS may be greater or less than the MCL or other cleanup standard that has been established. In nearly all cases the AGQS is less than the MCL at the Pagel's Pit Site.established. In nearly all cases the AGQS is less than the MCL at the Pagel's Pit Site.

The AGQSs are used in defining groundwater management zone (GMZ) in the downgradientThe AGQSs are used in defining aa groundwater management zone (GMZ) in the downgradient direction under the current IEPAA permit. The GMZ consists of the area where concentrationsdirection under the current lEP permit. The GMZ consists of the area where concentrations exceed the AGQSs. The GMZ is three dimensional region containing beingexceed the AGQSs. The GMZ is aa three dimensional region containing groundwatergroundwater being managed to mitigate impairment caused by the release of contaminants from site. It is subjectmanaged to mitigate impairment caused by the release of contaminants from aa site. It is subject to corrective action process approved by lEPA. (35 lAC 620.250 and 35 lAC 811.324 andto aa corrective action process approved by IEPA. (35 lAC 620.250 and 35 lAC 811.324 and 811.325) At this Site, the initial GMZ was defined by the extent of the chloride and811.325) At this Site, the initial GMZ was defined by the extent of the chloride and ammoniaammonia contamination. The AGQS for chloride, dissolved and total, is 87.5 mg/1 and the AGQS forcontamination. The AGQS for chloride, dissolved and total, is 87.5 mg/l and the AGQS for dissolved ammonia-nitrogen is 0.9 mg/1. Roughly, in 1995, the GMZ, based on both the upperdissolved ammonia-nitrogen is 0.9 mg/l. Roughly, in 1995, the GMZ, based on both the upper and lower zones, included the area from about the mid-points of the waste disposal area on theand lower zones, included the area from about the mid-points of the waste disposal area on the north and the south borders toward the west to the vicinity of well nests GI6 l 16) and G34.north and the south borders toward the west to the vicinity of well nests G16 (G(G 116) and G34.

There is also zone of attenuation around the waste disposal area within which concentrations ofThere is also aa zone of attenuation around the waste disposal area within which concentrations of constituents in leachate discharged from the unit may exceed AGQSs. This zone is aa volumeconstituents in leachate discharged from the unit may exceed AGQSs. This zone is volume bounded by aa vertical plane at the property boundary or 100 feet from the edge of the unit,bounded by vertical plane at the property boundary or 100 feet from the edge of the unit, whichever is less, extending from the ground surface to the bottom of the uppermost aquifer andwhichever is less, extending from the ground surface to the bottom of the uppermost aquifer and excluding the volume occupied by the waste. Once the groundwater concentrations in the GMZexcluding the volume occupied by the waste. Once the groundwater concentrations in the GMZ are at or below the AGQSs, there will no longer be GMZ. However, the zone of attenuationare at or below the AGQSs, there will no longer be aa GMZ. However, the zone of attenuation will always exist.will always exist.

Volatile organic compounds (VOCs) have been found in the past in the shallow aquifer on, andVolatile organic compounds (VOCs) have been found in the past in the shallow aquifer on, and in the vicinity of, both the Pagel's Pit and Acme Solvent sites. VOCs have been found bothin the vicinity of, both the Pagel's Pit and Acme Solvent sites. VOCs have been found both inside and of the area defined by elevated chloride concentrations at the Pagel's Pit site.inside and outsideoutside of the area defined by elevated chloride concentrations at the Pagel's Pit site. During the 1988-90 remedial investigation, the highest concentrations of VOCs were found inDuring the 1988-90 remedial investigation, the highest concentrations ofVOCs were found in wells on or near the Acme Solvent site. The next highest concentrations were found in the south­wells on or near the Acme Solvent site. The next highest concentrations were found in the south­east comer of the Pagel's Pit site. During this initial remedial investigation connection betweeneast comer of the Pagel's Pit site. During this initial remedial investigation aa connection between the Acme Solvent site and the southeast comer of the Pagel's Pit Site not definitely shown,the Acme Solvent site and the southeast comer of the Pagel's Pit Site waswas not definitely shown, possibly because there is fractured bedrock between and in the two areas through which ground­possibly because there is fractured bedrock between and in the two areas through which ground­water would move primarily in the fractures. Later, well G20D (G120B) installed betweenwater would move primarily in the fractures. Later, well G20D (G120B) waswas installed between the two sites. Elevated levels of VOCs were found in water in this well which showed thatthe two sites. Elevated levels of VOCs were found in water in this well which showed that contamination was moving from the Acme Solvent site toward the Pagel's Pit Site. Thus, it wascontamination was moving from the Acme Solvent site toward the Pagel's Pit Site. Thus, it was shown that at least some of the VOCs present in the southeast comer could have come from theshown that at least some of the VOCs present in the southeast comer could have come from the Acme Solvent site. However, it is likely that some of the contamination in the southeast comerAcme Solvent site. However, it is likely that some of the contamination in the southeast comer was also coming from the landfill. Chlorinated benzenes were found in this area but were notwas also coming from the landfill. Chlorinated benzenes were found in this area but were not found in wells closer to the Acme Solvent site.found in wells closer to the Acme Solvent site.

In the GMZ during 1997 and 1998 (closure of the western portion oflandfill began in AugustIn the GMZ during 1997 and 1998 (closure of the westem portion of landfill began in August 1997), tetrachloroethene the only organic compound whose concentrations exceeded the1997), tetrachloroethene waswas the only organic compound whose concentrations exceeded the maximum contaminant levels (MCLs) established under the Federal Safe Drinking Water Actmaximum contaminant levels (MCLs) established under the Federal Safe Drinking Water Act (MCL pg/1). The MCL for tetrachloroethene exceeded in wells G16M (Gl 16A), G16D(MCL == 55 /lg/l). The MCL for tetrachloroethene waswas exceeded in wells G16M (GI16A), G16D (Gl 16D), and G35S to the west of Killbuck Creek and in wells G41D (G132), G39S (G39), and(GI16D), and G35S to the west of Killbuck Creek and in wells G41D (GI32), G39S (G39), and

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G03M (P4R) to the east of the creek. The maximum concentration was 12 pg/1, so the AGQS,G03M (P4R) to the east of the creek. The maximum concentration was 12 Ilg/1, so the AGQS, which is 26 pg/1, not exceeded. The concentrations of several other organics exceeded theirwhich is 26 1lg/1, waswas not exceeded. The concentrations of several other organics exceeded their AGQSs in the GMZ, including those of 1,4-dichlorobenzene in four wells. Three of these wellsAGQSs in the GMZ, including those of l,4-dichlorobenzene in four wells. Three of these wells are in or very close to the zone of attenuation and the fourth is directly downgradient of the land­are in or very close to the zone of attenuation and the fourth is directly downgradient of the land­fill.fill. In the "background" wells (well G20D (G120B) and of the wells (not including wellIn the "background" wells (well G20D (G120B) and 44 of the 55 wells (not including well GI4D (Gl 14)) in the southeast comer), the concentrations of several substances exceeded theirG14D (G114)) in the southeast comer), the concentrations of several substances exceeded their MCLs: tetrachloroethene in wells G09D (G109A) and G13D l 13A); trichloroethene in wellsMCLs: tetrachloroethene in wells G09D (G109A) and G13D (G(G 113A); trichloroethene in wells G20D (G120B) and G13D (G113A); cis-l,2-dichloroethene in well G13D l 13A); vinylG20D (G 120B) and G13D (G113A); cis-1 ,2-dichloroethene in well G130 (G(G 113A); vinyl chloride in well G13D (Gl 13A) (the MCL was also exceeded in well G14D (Gl 14)); and 1,2­chloride in well G13D (G113A) (the MCL was also exceeded in well G14D (Gl14)); and 1,2­dichloropropane in well G13D l 13A). The concentrations of few other organics exceededdichloropropane in well G130 (G(G113A). The concentrations of aa few other organics exceeded their AGQSs in the southeast comer wells, including 1,2,3-trichlorobenzene, 1,2,4-trichloro­their AGQSs in the southeast comer wells, including 1,2,3-trichlorobenzene, 1,2,4-trichloro­benzene, 1,4-dichlorobenzene, and These numbers demonstrate the low levels ofbenzene, l,4-dichlorobenzene, and chlorobenzene.chlorobenzene. These numbers demonstrate the low levels of VOCs generally found in the GMZ. They also show the possible influence of the Acme SolventVOCs generally found in the GMZ. They also show the possible influence of the Acme Solvent site on the groundwater in the southeast comer because of the presence of several chlorinatedsite on the groundwater in the southeast comer because of the presence of several chlorinated ethenes. Well G20D (G120B) and the wells in the southeast comer are not part of the GMZethenes. Well G20D (G120B) and the wells in the southeast comer are not part of the GMZ since they are not considered to be downgradient of the waste disposal area.since they are not considered to be downgradient of the waste disposal area.

Killbuck Creek is also regullarly monitored by the landfill operator. In 1998, none of the majorKillbuck Creek is also regularly monitored by the landfill operator. In 1998, none of the major chlorinated ethenes were detected in the creek, nor were several other VOCs, for which analyseschlorinated ethenes were detected in the creek, nor were several other VOCs, for which analyses were done. The ammoniaammonia concentrations in the creek generally increased between the upstreamwere done. The concentrations in the creek generally increased between the upstream and downstream sampling points, which may indicate an effect from the landfill or from sourcesand downstream sampling points, which may indicate an effect from the landfill or from sources not related to the landfill. Elevated concentrations can also be due to agriculturalnot related to the landfill. Elevated ammoniaammonia concentrations can also be due to agricultural activities. However, the chloride concentrations increased only slightly.activities. However, the chloride concentrations increased only slightly.

The results of the monitoring of the landfill leachate in the 1997 to 1999 period showed that theThe results of the monitoring of the landfill leachate in the 1997 to 1999 period showed that the chloride and sodium concentrations in the leachate were generally somewhat higher than thechloride and sodium concentrations in the leachate were generally somewhat higher than the ranges for typical landfill leachate. However the concentrations are now decreasing over time.ranges for typical landfill leachate. However the concentrations are now decreasing over time. During this period there were no detections of chlorobenzene, 1,4-dichlorobenzene, the two tri-During this period there were no detections of chlorobenzene, 1,4-dichlorobenzene, the two tri­chlorobenzenes, 1,2-dichloropropane, or any of the major chlorinated ethenes in the leachate.chlorobenzenes, 1,2-dichloropropane, or any of the major chlorinated ethenes in the leachate.

An investigation for the remedial design of the OU barrier well system specified in the 1991An investigation for the remedial design of the OU 11 barrier well system specified in the 1991 ROD found that pumping well located between the waste disposal area and the creek resultedROD found that pumping aa well located between the waste disposal area and the creek resulted in much greater rate than had been anticipated when the ROD was issued. Also, thein aa much greater flowflow rate than had been anticipated when the ROD was issued. Also, the groundwater downgradient of the landfill was found to contain significant concentrations ofgroundwater downgradient of the landfill was found to contain significant concentrations of ammonia. Ammonia had not been considered in the remedial investigation done for this ROD.ammonia. Ammonia had not been considered in the remedial investigation done for this ROD. If this groundwater were extracted as part of system to prevent the movement of the con­If this groundwater were extracted as part of aa system to prevent the movement of the con­taminated groundwater downgradient, this would have to be removed before the treatedtaminated groundwater downgradient, this ammoniaammonia would have to be removed before the treated water could be discharged, unless the concentrations were significantly decreased duringwater could be discharged, unless the concentrations were significantly decreased during pumping because of the introduction into the groundwater of uncontaminated water from thepumping because of the introduction into the groundwater of uncontaminated water from the creek to the extraction wells through the ground. Generally, the removal of ammonia, ifcreek flowingflowing to the extracti'on wells through the ground. Generally, the removal of ammonia, if it needed, would involve raising the pH, stripping the ammonia, and then lowering the pH ofit waswas needed, would involve raising the pH, stripping the ammonia, and then lowering the pH of the water to an acceptable level for discharge. These results led to the determination that the costthe water to an acceptable level for discharge. These results led to the determination that the cost of the barrier well system and associated water treatment system would be much greater than hadof the barrier well system and associated water treatment system would be much greater than had been estimated for the 1991 ROD, and the Agency agreed to defer implementation of the systemsbeen estimated for the 1991 ROD, and the Agency agreed to defer implementation ofthe systems until altematives could be investigated.until alternatives could be investigated.

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Proposed Plan for the remedy for OU and for change in the remedy for OU releasedAA Proposed Plan for the remedy for OU 22 and for aa change in the remedy for au 11 waswas released to the public in August 1999. This Proposed Plan also informed the public of the dates for theto the public in August 1999. This Proposed Plan also informed the public of the dates for the comment period, August 13, 1999 through September 11, 1999, and the public meeting whichcomment period, August 13, 1999 through September 11, 1999, and the public meeting which was held on August 25, 1999. At the request of some attendees at the August 25 public meeting,was held on August 25, 1999. At the request of some attendees at the August 25 public meeting,

second meeting was held on September 8, 1999 to further discuss the Proposed Plan. The RODaa second meeting was held on September 8, 1999 to further discuss the Proposed Plan. The ROD for OU 2, which also served as ROD Amendment for OU 1, was signed September 30, 1999.for OU 2, which also served as aa ROD Amendment for OU 1, was signed September 30, 1999.

Basis for Taking ActionBasis for Taking Action

In the 1991 remedial investigation aa baseline risk assessment waswas prepared to characterize theIn the 1991 remedial investigation baseline risk assessment prepared to characterize the nature and estimate the magnitude of potential risks to public health and the environment. Thenature and estimate the magnitude of potential risks to public health and the environment. The potential risks were caused by the chemicals of concem and were based on current and possiblepotential risks were caused by the chemicals of concern and were based on current and possible future land use.future land use.

The chemicals of potential concern were selected on the basis of the following criteria: a)The chemicals of potential concem were selected on the basis of the following criteria: a) positively detected in at least one sample in medium; b) detected at levels significantly abovepositively detected in at least one sample in aa medium; b) detected at levels significantly above the levels in blank samples; c) detected at levels elevated above naturally occurring levels; d)the levels in blank samples; c) detected at levels elevated above naturally occurring levels; d) only tentatively identified, but which may be associated with the site; and e) transformationonly tentatively identified, but which may be associated with the site; and e) transformation products of chemicals demonstrated to be present. Those chemicals that met one of theseproducts of chemicals demonstrated to be present. Those chemicals that met one of these fivefive initial selection criteria were considered chemicals of potential concem. The exceptions to thisinitial selection criteria were considered chemicals of potential concern. The exceptions to this were those chemicals detected in landfill leachate but not in other media and chemicals for whichwere those chemicals detected in landfill leachate but not in other media and chemicals for which critical toxicity had not been developed; these latter were evaluated qualitatively.critical toxicity valuesvalues had not been developed; these latter were evaluated qualitatively.

The chemicals of potential concern identified for the Site were:The chemicals of potential concem identified for the Site were:

Volatile Organic CompoundsVolatile Organic Compounds Semi-Volatile CompoundsSemi-Volatile Compounds acetoneacetone bis(2-ethylhexyl)phthalatebis(2-ethylhexyl)phthalate benzenebenzene di-n-butylphthalatedi-n-butylphthalate bromoformbromoform 1,2-dichlorobenzene1,2-dichlorobenzene bromodichloromethanebromodichloromethane 1,3-dichlorobenzene1,3-dichlorobenzene carbon tetrachloridecarbon tetrachloride 1,4-dichlorobenzeneIA-dichlorobenzene chlorobenzenechlorobenzene diethylphthalatediethylphthalate chloroethanechloroethane PAHs (noncarcinogenic)PAHs (noncarcinogenic) chloromethanechloromethane chloroformchloroform Metals/InorganicsMetaisilnorganics dibromochloromethanedibromochloromethane arsenicarsenic 1,1-dichloroethaneI,I-dichloroethane bariumbarium 1,2-dichloroethane1.2-dichloroethane cadmiumcadmium 1,1-dichloroetheneI,I-dichloroethene chromiumchromium 1,2-dichloroethene (both)I,2-dichloroethene (both) cobaltcobalt

1,2-dichloropropane1,2-dichloropropane coppercopper 1,3-dichloropropene1,3-dichloropropene ironiron ethylbenzeneethylbenzene leadlead methylene chloridemethylene chloride manganesemanganese tetrachloroethenetetrachloroethene nickelnickel 1,1,2,2-tetrachloroethaneI, I ,2,2-tetrachloroethane nitrate nitritenitrate && nitrite toluenetoluene silversilver 1,1,1-trichloroethane1,1, I-trichloroethane sodiumsodium trichloroethenetrichloroethene thalliumthallium vinyl chloridevinyl chloride vanadiumvanadium xylenes (o-, m-, p-)xylenes (0-, m-, po) zinczinc

cyanidecyanide Pesticides/PCBsPesticideslPCBs

none

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Potential future groundwater use as aa water supply was found to represent the greatest risk toPotential fiiture groundwater use as water supply was found to represent the greatest risk to humans at the Pagel's Pit Site. Under this scenario, exposure would occur through groundwaterhumans at the Pagel's Pit Site. Under this scenario, exposure would occur through groundwater ingestion and from dermal contact and inhalation while bathing. The calculation waswas done foringestion and from dermal contact and inhalation while bathing. The calculation done for the groundwater west of Lindenwood Road, including the southeast corner. The calculatedthe groundwater west of Lindenwood Road, including the southeast corner. The calculated cumulative hazard index of 5, not including cobalt exposure (found in only one well), comparedcumulative hazard index of 5, not including cobalt exposure (found in only one well), compared to the Superfund goal of I, indicated that exposure to the noncarcinogens in the groundwaterto the Superfund goal of 1, indicated that exposure to the noncarcinogens in the groundwater might cause adverse health effects. The majority of the value of the hazard index was due tomight cause adverse health effects. The majority of the value of the hazard index was due to exposure to the 1,2-dichloroethenes, thallium, and zinc. The calculated cumulative cancer risk of 1x10'̂ exceeded the U.S. EPA target risk range of 10"̂ to 10"̂ .. The majorityThe majority of this was due toof this was due to exposure to the 1,2-dichloroethenes, thallium, and zinc. The calculated cumulative cancer risk of lxlO-3 exceeded the U.S. EPA target risk range of 10-4 to 10-6

exposure to vinyl chloride and arsenic.exposure to vinyl chloride and arsenic.

The totall,2-dichloroethem: concentration (the lesser of the 95% upper-bound confidence limitThe total 1,2-dichloroethene concentration (the lesser of the 95% upper-bound confidence limit of the arithmetic mean or the maximum concentration detected) used in the calculation for theof the arithmetic mean or the maximum concentration detected) used in the calculation for the risk in 1991 waswas 240 /lg/l. (A risk or hazard quotient (the sum of the hazard quotients for sub­risk in 1991 240 pg/1. (A risk or hazard quofient (the sum of the hazard quofients for sub­stances that cause aa similar effect is the hazard index) is directly proportional to the concentra­stances that cause similar effect is the hazard index) is directly proportional to the concentra­tion; if the concentration has decreased, so has the risk or hazard quotient.) In April 1998 theretion; if the concentration has decreased, so has the risk or hazard quofient.) In April 1998 there were only detects of 1,2-dichloroethene (all of the cis isomer) in the groundwater west ofwere only fivefive detects of 1,2-dichloroethene (all of the cis isomer) in the groundwater west of Lindenwood Road (31 wells sampled): 98 pg/1 in well G13D l 13A) in the southeast comerLindenwood Road (31 wells sampled): 98 /lg/l in well G13D (G(G113A) in the southeast corner and concentrations ranging from to pg/1 in four downgradient wells. The detection limit wasand conceptrations ranging from 66 to 77 /lg/l in four downgradient wells. The detection limit was

pg/1. The dissolved thallium concentration used for the 1991 risk assessment was 2.8 pg/155 /lg/l. The dissolved thallium concentration used for the 1991 risk assessment was 2.8 /lg/l (ranging from to pg/1). In April 1998 there were only two detects of total thallium (dissolved(ranging from 22 to 66 /lg/l). In April 1998 there were only two detects of total thallium (dissolved thallium waswas not analyzedthallium not analyzed for) at about 5.3 pg/1. The detection limit was:fix) at about 5.3 /lg/l. The detection limit was 55 /lg/l. The two thalli­pg/1. The two thalli­um detects were in wells from the same general area. No thallium was detected in the leachate inum detects were in wells from the same general area. No thallium was detected in the leachate in the 1997 through early 1999 period, with detection limits of 1.5, 2.2, and 100 pg/1. The dissolvedthe 1997 through early 1999 period, with detection limits of 1.5, 2.2, and 100 /lg/l. The dissolved zinc concentrafion used for the 1991 risk assessment was 6.3 mg/1 (ranging from 0.037 to 6.34zinc concentration used for the 1991 risk assessment was 6.3 mg/I (ranging from 0.037 to 6.34 mg/1). In April 1998 there were 25 detects of dissolved zinc in the wells west of Lindenwoodmg/l). In April 1998 there were 25 detects of dissolved zinc in the wells west of Lindenwood Road (31 wells sampled), ranging in concentrafion to 9.27 mg/1 (in well G09D (G109A), in theRoad (31 wells sampled), ranging in concentration to 9.27 mg/I (in well G09D (G109A), in the southeast comer, where the next highest concentration was 1.73 mg/1 in well G09M (G109)).southeast corner, where the next highest concentration was 1.73 mg/I in well G09M (G109». The maximum in the downgradient wells 4.18 mg/1. Hence, all but one of the detects of zincThe maximum in the downgradient wells waswas 4.18 mg/l. Hence, all but one of the detects of zinc were below 6.3 mg/1. The detection limit 0.022 mg/1. The vinyl chloride concentration usedwere below 6.3 mg/1. The detection limit waswas 0.022 mg/1. The vinyl chloride concentration used for the 1991 risk assessment 14 pg/1. In April 1998 there was only one detect of vinyl chlo­for the 1991 risk assessmenll waswas 14 /lg/l. In April 1998 there was only one detect of vinyl chlo­ride, at 15 pg/1, and this was in southeast comer well. The detection limit was pg/1. The dis­ride, at 15 /lg/I, and this was in aa southeast corner well. The detection limit was 22 /lg/l. The dis­solved arsenic concentration used for the 1991 risk assessment was 8.4 pg/1 (ranging from to 46solved arsenic concentration used for the 1991 risk assessment was 8.4 /lg/l (ranging from 22 to 46 pg/I). In April 1998 there were 10 detects of dissolved arsenic, ranging in concentration to 25/lg/l). In April 1998 there were 10 detects ofdissolved arsenic, ranging in concentration to 25 pg/1, but of the detects were below 8.4 pg/1. The detection limit was pg/1. Thus, the concen­/lg/l, but 88 of the detects were below 8.4 /lg/l. The detection limit was 22 /lg/l. Thus, the concen­trations of the substances that were the significant contributors to the risks calculated in 1991 hadtrations of the substances that were the significant contributors to the risks calculated in 1991 had generally been decreasing or remaining similar to the levels then, but it was clear that risks weregenerally been decreasing or remaining similar to the levels then, but it was clear that risks were still present above U.S. EPA's requirements for remedial action in 1999.still present above U.S. EPA's requirements for remedial action in 1999.

The environmental evaluation portion of the baseline risk assessment in 1991 done toThe environmental evaluation portion of the baseline risk assessment in 1991 waswas done to characterize the natural habitats which might be influenced by the Site. Killbuck Creek and thecharacterize the natural habitats which might be influenced by the Site. Killbuck Creek and the nearby weflands were assumed to be the most sensitive ecological habitats near the landfill. Fishnearby wetlands were assumed to be the most sensitive ecological habitats near the landfill. Fish were considered the group of aquatic species that would be the most susceptible to chemicalwere considered the group of aquatic species that would be the most susceptible to chemical exposure in Killbuck Creek. Effects on are not expected based on the concentrations in theexposure in Killbuck Creek. Effects on fishfish are not expected based on the concentrations in the water in comparison to the Ambient Water Quality Criteria. Since this sensitive group ofwater in comparison to the Ambient Water Quality Criteria. Since this sensitive group of organisms appears to be safe from health effects, other aquatic ecosystem effects are notorganisms appears to be sa:fi~ from health effects, other aquatic ecosystem effects are not Pagel's Pit Site--Five-Year Review ReportPagel's Pit Site-Five-Year Review Report PagePage 1010 September 2012September 2012

anticipated.anticipated.

Because of the unacceptable risk levels revealed by the human health evaluation, aa remedy waswasBecause of the unacceptable risk levels revealed by the human health evaluation, remedy developed for the Site. The primary concems identified for the 1991 ROD were vinyl chloridedeveloped for the Site. The primary concerns identified for the 1991 ROD were vinyl chloride and arsenic in the groundwater. Containment of landfill gas also identified as problem.and arsenic in the groundwater. Containment of landfill gas waswas also identified as aa problem. Capping the landfill and the other measures taken (control of landfill gas pressure and reductionCapping the landfill and the other measures taken (control of landfill gas pressure and reduction of the leachate level in the landfill) have been intended to reduce the release of leachate andof the leachate level in the landfill) have been intended to reduce the release ofleachate and prevent possible contact with the wastes and leachate, contaminated groundwater, and landfillprevent possible contact with the wastes and leachate, contaminated groundwater, and landfill gas.gas.

IV. Remedial ActionIV. Remedial Action

Remedy SelectedRemedy Selected

The total remedy that has been selected for the Site (for both OU 1 and OU 2) as a result of theThe total remedy that has been selected for the Site (for both au I and au 2) as a result of the 1991 ROD and the 1999 ROD and ROD Amendment consists of the following components:1991 ROD and the 1999 ROD and ROD Amendment consists of the following components:

•• sanitary landfill cover for the waste disposal area;aa sanitary landfill cover for the waste disposal area; •• leachate extraction and transfer to the local publicly owned treatment works for treatment;leachate extraction and transfer to the local publicly owned treatment works for treatment;

gas extraction and of the gas or using it for fuel;•• gas extraction and flaringflaring of the gas or using it for fuel; •• monitored natural attenuation with aa contingency for the groundwater downgradient of themonitored natural attenuation with contingency for the groundwater downgradient of the

Site, the contingency (an active system to address groundwater by preventing the movementSite, the contingency (an active system to address groundwater by preventing the movement of the contamination downgradient and/or remove contamination in the contaminatedof the contamination downgradient and/or remove contamination in the contaminated groundwater downgradient of the landfill wastes, whichever is needed) to be used if thegroundwater downgradient of the landfill wastes, whichever is needed) to be used if the control of the contamination coming from the landfill wastes, the control of contaminationcontrol of the contamination coming from the landfill wastes, the control of contamination coming from upgradient of the Site, and the natural attenuation processes do not lead to thecoming from upgradient of the Site, and the natural attenuation processes do not lead to the eventual retum of downgradient groundwater to beneficial use, do not appear to be doing so,eventual return of downgradient groundwater to beneficial use, do not appear to be doing so, or if the contaminated groundwater becomes an immediate threat to downgradient wateror if the contaminated groundwater becomes an immediate threat to aa downgradient water supply;supply;

•• deed restrictions that protect the source control measures through restrictions on constmc­deed restrictions that protect the source control measures through restrictions on construc­tion and that prevent contact with contaminated groundwater through well installationtion and that prevent contact with contaminated groundwater through well installation restrictions in those areas containing contaminated groundwater, including areas west ofrestrictions in those areas containing contaminated groundwater, including areas west of Killbuck Creek; andKillbuck Creek; and Site monitoring, including monitoring of the groundwater in the southeast corner, and main­•• Site monitoring, including monitoring of the groundwater in the southeast comer, and main­tenance of all remedial action components.tenance of all remedial action components.

The remedy for OU 2, the groundwater in the southeast comer, was institutional controls, whichThe remedy for au 2, the groundwater in the southeast corner, was institutional controls, which consist of deed restrictions prohibiting the installation of water production wells in that area. Theconsist of deed restrictions prohibiting the installation of water production wells in that area. The groundwater will continue to be monitored as part of the operating permit for the landfill. It wasgroundwater will continue to be monitored as part of the operating permit for the landfill. It was determined that the contaminated groundwater in the southeast comer would move toward thedetermined that the contaminated groundwater in the southeast corner would move toward the west and join with the other contaminated groundwater, which was being addressed as part ofwest and join with the other contaminated groundwater, which was being addressed as part of OU and the current operating permit for the landfill. The original remedy for OU 1 includedOU 11 and the current operating permit for the landfill. The original remedy for au I included groundwater extraction along the west side of the site. This was replaced with monitored naturalgroundwater extraction along the west side of the site. This was replaced with monitored natural attenuation with contingency in the ROD Amendment because of the new informafion aboutattenuation with aa contingency in the ROD Amendment because of the new information about the groundwater discovered after the 1991 ROD was issued, which is discussed in the "Initialthe groundwater discovered after the 1991 ROD was issued, which is discussed in the "Initial Response" subsection above, and because lEPA favored the use of the GMZ under the operatingResponse" subsection above, and because IEPA favored the use of the GMZ under the operating

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permit for addressing the groundwater contamination. The remedy for au 11 is that listed abovepermit for addressing the groundwater contaminafion. The remedy for OU is that listed above for the total remedy minus only those institutional controls specifically for the southeast comer.for the total remedy minus only those institutional controls specifically for the southeast comer.

Remedy ImplementationRemedy Implementation

The remedy for OUI has been implemented. The remedy for au 2, the placement ofThe remedy for OUl has been implemented. The remedy for OU 2, the placement of institutional controls in the southeast comer, has not been implemented. Also, some additionalinsfitutional controls in the southeast comer, has not been implemented. Also, some additional institutional controls for OU 1, for the property on the west side of Killbuck Creek, still have toinstitutional controls for OLI 1, for the property on the west side of Killbuck Creek, still have to be implemented.be implemented.

The finalfinal cover waswas constructed in two phases. First, the cover was installed on the westernThe cover constructed in two phases. First, the cover was installed on the westem portion (approximately 16.6 acres) of the landfill after the wastes had reached the permitted ele­portion (approximately 16.6 acres) of the landfill after the wastes had reached the permitted ele­vation. This work was begun in July 1997. The design for this portion of the landfill was ap­vation. This work was begun in July 1997. The design for this portion of the landfill was ap­proved on August 8, 1997. Construction Quality Assurance Acceptance Report Pagel Landfillproved on August 8, 1997. Construction Quality Assurance Acceptance Report Pagel Landfill Final Construction, Western Portion, Febmary 1998, was submitted to lEP Bureau of Land,Final Construction, Western Portion, February 1998, was submitted to IEPAA ,, Bureau of Land, Permit Section on Febmary 23, 1998. The report was accepted on June 18, 1998.Permit Section on February 23, 1998. The report was accepted on June 18, 1998.

The construction of the finalfinal cover for the eastern portion of the landfill waswas begun in AugustThe construction of the cover for the eastem portion of the landfill begun in August 2000 after the wastes had reached the permitted elevation in the rest of the landfill. Construction2000 after the wastes had reached the permitted elevation in the rest of the landfill. Construction Quality Assurance Acceptance Report Pagel Landfill Final Cover Construction--Eastern Por­Quality Assurance Acceptance Report Pagel Landfill Final Cover Construction—Eastern Por­tion, September 2001, was submitted to IEPA, Bureau of Land, Permit Section in Septembertion, September 2001, was submitted to lEPA , Bureau of Land, Permit Section in September 2001. Following the submittal of some additional information, the report waswas accepted in May2001. Following the submittal of some additional information, the report accepted in May 2002.2002.

For both portions, the closure consisted of the following components:For both portions, the closure consisted of the following components:

• grading layer;aa grading layer; • 1-foot recompacted clay layer;aa I-foot recompacted clay layer;

40-mil membrane liner;• aa 40-mil flexibleflexible membrane liner; • drainage layer;aa drainage layer; • 2.5-foot protective layer;aa 2.5-foot protective layer; • 6-inch topsoil layer with fertilizer, seed, and mulch;aa 6-inch topsoil layer with fertilizer, seed, and mulch; • storm-water terraces, letdowns, ditches, and culverts;storm-water terraces, l{:tdowns, ditches, and culverts; • leachate extraction (leachate wells and pumps and associated piping) and conveyance sys­aa leachate extraction (leachate wells and pumps and associated piping) and conveyance sys­

tem; andtem; and gas collection system, including connection to system.•• aa gas collection system, including connection to aa flareflare system.

The gas collection and control system (GCCS) included 35 vertical dual leachate/gas extractionThe gas collection and control system (GCCS) included 35 vertical dual leachate/gas extraction wells, collection piping network, and leachate storage tanks. The collected gas beingwells, collection piping network, and leachate storage tanks. The collected gas waswas being directed to at the time of the 2007 review, but was soon to be used as fuel to generatedirected to aa flareflare at the time of the 2007 review, but was soon to be used as aa fuel to generate electricity. There are gas probes located outside the waste boundary, which are monitored andelectricity. There are gas probes located outside the waste boundary, which are monitored and evaluated under the current lEPA permit requirements.evaluated under the current IEPA permit requirements.

It necessary to perform additional work on the leachate extraction system followingIt waswas necessary to perform additional work on the leachate extraction system following constmction because of problems encountered with the in-well pumps. Consequently, theconstruction because of problems encountered with the in-well pumps. Consequently, the lowering of the leachate level in the landfill was initially slow in being accomplished. By thelowering of the leachate level in the landfill was initially slow in being accomplished. By the

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time of the 2007 review, the leachate levels were essentially at the pump intake levels.time of the 2007 review, the leachate levels were essentially at the pump intake levels.

There were problems with controlling the landfill gas after cover construction was completed. AAThere were problems with controlling the landfill gas after cover constmction was completed. larger capacity system for handling the landfill gas being extracted from the landfill gas/leachatelarger capacity system for handling the landfill gas being extracted from the landfill gas/leachate wells (2500 cfm versus the 1000 cfm system being used at the completion of the capping work)wells (2500 cfm versus the 1000 cfm system being used at the completion of the capping work) was installed in September 2002 to provide the required control of the landfill gas migration. Inwas installed in September 2002 to provide the required control of the landfill gas migration. In about mid September, the new system became operational and proper balancing begun.about mid September, the new system became operational and proper balancing waswas begun. Beginning in 2010 the 2500 cfm was moved to new location adjacent to the Energy CenterBeginning in 2010 the 2500 cfm flareflare was moved to aa new location adjacent to the Energy Center that is part of planned station with multiple that is designed to handle all of thethat is part of aa planned flaringflaring station with multiple flaresflares that is designed to handle all of the gas from the various disposal units. The station will also provide backup capacity in thegas from the various disposal units. The flareflare station will also provide backup capacity in the event of an outage of single The station currently has the 2500 cfm andevent of an outage of aa single flare.flare. The flareflare station currently has the 2500 cfm flareflare and aa temporary 2200 cfm In the fallIn the fall ofof 20201212 the 2200 cfm temporary flareflare will be replaced withthe 2200 cfm temporarytemporary 2200 cfm flare.flare. will be replaced with

new permanent 4000 cfmaa new permanent 4000 cfm flare.flare.

Construction completion for the Site waswas deemed to have been achieved with the issuance of theConstmction completion for the Site deemed to have been achieved with the issuance of the 1999 ROD on September 30, 1999, which acknowledged that U.S. EPA's response at the Site1999 ROD on September 30, 1999, which acknowledged that U.S. EPA's response at the Site was complete. All remaining constmction activity was to be completed by the operator of thewas complete. All remaining construction activity was to be completed by the operator of the landfill in accordance with the requirements of Operating Permit No. 1991-138-LF issued by thelandfill in accordance with the requirements of Operating Permit No. 1991-138-LF issued by the Division of Land Pollution Control, Illinois Environmental Protection Agency. The long-termDivision of Land Pollution Control, Illinois Environmental Protection Agency. The long-term groundwater monitoring requirements of the 1999 ROD were already specified in the 1993groundwater monitoring requirements of the 1999 ROD were already specified in the 1993 Consent Decree and were also required under the existing lEPA operating permit.Consent Decree and were also required under the existing IEPA operating permit.

Institutional ControlsInstitutional Controls

Institutional controls (lCs) are non-engineered instruments, such as administrative and legal con­Institutional controls (ICs) are non-engineered instmments, such as administrative and legal con­trols, that help to minimize the potential for exposure to contamination and that protect thetrols, that help to minimize the potential for exposure to contamination and that protect the integrity of the remedy. ICs are required to assure long-term protectiveness for any areas whichintegrity of the remedy. ICs are required to assure long-term protectiveness for any areas which do not allow for UU/UE.do not allow for UU/UE.

The deed restrictions for the waste disposal area and those areas nearby that were required underThe deed restrictions for the waste disposal area and those areas nearby that were required under the 1991 ROD were implemented. AA copy of the deed restriction form contained in the 1993the 1991 ROD were implemented. copy of the deed restriction form contained in the 1993 Consent Decree, notarized April 19, 1993, waswas filedfiled with the Recorder of Winnebago County onConsent Decree, notarized April 19, 1993, with the Recorder of Winnebago County on April 20, 1993. The document includes restrictions on the use of the upper aquifer, prohibitsApril 20, 1993. The document includes restrictions on the use of the upper aquifer, prohibits residential use of the property, requires that any changes to structures, roads, etc. be approved byresidential use of the property, requires that any changes to structures, roads, etc. be approved by U.S. EPA, prohibits tampering with or removal of any containment or monitoring systems orU.S. EPA, prohibits tampering with or removal of any containment or monitoring systems or other components of the remedial action unless authorized by U.S. EPA, and prohibitsother components of the remedial acfion unless authorized by U.S. EPA, and prohibits interference with the performance of the work or remedial action or with the maintenance ofinterference with the performance of the work or remedial action or with the maintenance of remedial measures. Additional restrictions as called for in the 1999 ROD need to beremedial measures. Additional restrictions as called for in the 1999 ROD need to be implemented.implemented.

The specific areas which do not allow for UU/UE are summarized in Table 11 on the followingThe specific areas which do not allow for UU/UE are summarized in Table on the following page.page.

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Tablle 1. Institutional Controls Summary TableTable 1. Institutional Controls Summary Table

Media, Engineered Controls, andMedia, Engineered Controls, and IC ObjectiveIC Objective Title of IC InstrumentTitle of IC Instrument Areas That Do Not SupportAreas That Do Not Support ImplementedImplemented UU/UE Based on CurrentUUIUE Based on Current ConditionsConditions

Constructed landfill cover andConstructed landfill cover and No residential use. Agricultural useNo residential use. Agricultural use Deed restriction, notarized AprilDeed restriction, notarized April surface area of property beyond thesurface area of property beyond the must be approved by U.S. EPA.must be approved by u.S. EPA. 19, 1993, and with the19, 1993, and filedfiled with the landfill cap required for OUlandfill cap required for au 11 Any installation, removal, orAny installation, removal, or Recorder of Winnebago County onRecorder of Winnebago County on

construction of any buildings,construction of any buildings, April 20, 1993April 20, 1993 wells, pipes, roads, ditches or anywells, pipes, roads, ditches or any other structures must be approvedother structures must be approved by U.S. EPA. Unless authorized byby U.S. EPA. Unless authorized by U.S. EPA, no one shall tamper withU.S. EPA, no one shall tamper with or remove any containment oror remove any containment or monitoring systems or anymonitoring systems or any components of the remedial action.components of the remedial action. There shall be no interference withThere shall be no interference with

the performance of the work orthe performance of the work or remedial action or with theremedial action or with the maintenance of remedial measures.maintenance of remedial measures.

On-Site Groundwater for OUOn-Site Groundwater for au 11 Prohibit use of groundwater whereProhibit use of groundwater where Deed restriction, notarized AprilDeed restriction, notarized April contamination exceeds cleanupcontamination exceeds cleanup 19, 1993, and with the19, 1993, and filedfiled with the standardsstandards Recorder of Winnebago County onRecorder of Winnebago County on

April 20, 1993April 20, 1993

Off-Site Groundwater for OU 1Off-Site Groundwater for au I Prohibit use of groundwater whereProhibit use of groundwater where NoneNone contamination exceeds cleanupcontamination exceeds cleanup standardsstandards

Groundwater for OU (southeastGroundwater for au 22 (southeast Prohibit use of groundwaterProhibit use of groundwater NoneNone comer)comer)

More detailed maps which depict the physical areas mentioned in Table will be developed asMore detailed maps which depict the physical areas mentioned in Table 11 will be developed as part of an IC study. The msips will include current conditions for the Site and areas which dopart of an IC study. The maps will include current conditions for the Site and areas which do notnot allow for UU/UE.allow for UU/UE.

review of the institutional controls is needed to assure that the remedy is functioning asAA review of the institutional controls is needed to assure that the remedy is functioning as intended with regard to the ICs and to ensure effective procedures are in place for long-termintended with regard to the rcs and to ensure effective procedures are in place for long-term stewardship at the Site. The existing deed restriction must be evaluated and ICs must sfill bestewardship at the Site. The existing deed restriction must be evaluated and ICs must still be implemented for the addifional requirements made in the 1999 ROD for the southeast comer andimplemented for the additional requirements made in the 1999 ROD for the southeast comer and the dovmgradient groundwaiter. IC evaluation activities will include performing title work tothe downgradient groundwater. IC evaluation activities will include performing title work to verify ownership and whether prior-in-time encumbrances may interfere with the ICs, preparationverify ownership and whether prior-in-time encumbrances may interfere with the ICs, preparation of maps, and evaluation of whether additional ICs are needed. The IC evaluation activities willof maps, and evaluation of whether additional ICs are needed. The IC evaluation activities will also evaluate whether effective procedures are in place for long-term stewardship to assurealso evaluate whether effective procedures are in place for long-term stewardship to assure proper maintenance and monitoring of effective ICs. That would include regular inspection ofproper maintenance and monitoring of effective ICs. That would include regular inspection of ICs at the Site and annual certification to U.S. EPA that ICs are in place and effecfive. Once theICs at the Site and annual certification to U.S. EPA that ICs are in place and effective. Once the IC evaluation activities have been completed, an IC plan will be developed by U.S. EPA. TheIC evaluation activities have been completed, an IC plan will be developed by U.S. EPA. The Plan will incorporate the results of the evaluafion of activifies and plans for additional ICPlan will incorporate the results of the evaluation of activities and plans for additional IC activities as needed, including planning for long-term stewardship.activities as needed, including planning for long-term stewardship.

Pagel's Pit Site-Five-Year Review Report Page 14Page 14 September 2012Pagel's Pit Site--Five-Year Review Report September 2012

Systems Operation and Operation and MaintenanceSystems Operation and Operation and Maintenance

The landfill's operator performs the operation and maintenance required under the State's regula­tions for closed landfill. Mostly, this consists of: The landfill's operator performs the operation and maintenance required under the State's regula­tions for aa closed landfill. Mostly, this consists of:

•• groundwater monitoring;groundwater monitoring; •• cap inspection and maintenance;cap inspection and maintenance; •• operation and maintenance of the leachate extraction system, including leachate disposal tooperation and maintenance of the leachate extraction system, including leachate disposal to

the local publicly owned treatment works through aa force main to the sewer; and •• operation and maintenance of the landfill gas extraction system, which initially consisted of

the local publicly owned treatment works through force main to the sewer; and operation and maintenance of the landfill gas extraction system, which initially consisted of flaresflares for the disposal of the gas but now consists of combustion enginesengines that generatefor the disposal of the gas but now consists of combustion that generate electricity with the as backup.electricity with the flaresflares as aa backup.

As reported in the May 2012 report, Status Report and Evaluation ofGroundwater CorrectiveAs reported in the May 2012 report. Status Report and Evaluation of Groundwater Corrective Actions and Groundwater Management Zone, Andrews Engineering, Inc., the landfill facility hasActions and Groundwater Management Zone, Andrews Engineering, Inc., the landfill facility has an extensive system of groundwater monitoring wells from which groundwater data are obtained.an extensive system of groundwater monitoring wells from which groundwater data are obtained. The groundwater monitoring wells are divided into two networks, one for the Northern Unit andThe groundwater monitoring wells are divided into two networks, one for the Northem Unit and one for the Southern Unit. The Northern Unit network contains 333 groundwater monitoringone for the Southem Unit. The Northem Unit network contains 3 groundwater monitoring wells. Of those, fivefive are designated as upgradient wells, 14 monitor the zone of attenuation, andwells. Of those, are designated as upgradient wells, 14 monitor the zone of attenuation , and one is compliance boundary well at the edge of the zone of attenuation. Winnebago Landfillone is aa compliance boundary well at the edge of the zone of attenuation. Winnebago Landfill samples 13 additional wells on quarterly basis as part of the GMZ monitoring network. Thesamples 13 additional wells on aa quarterly basis as part of the GMZ monitoring network. The Southem Unit network currently contains 17 groundwater monitoring wells. Of these 17, six areSouthern Unit network currently contains 17 groundwater monitoring wells. Of these 17, six are designated as upgradient wells (two of which are Northem Unit upgradient wells) and 1 monitordesignated as upgradient wells (two of which are Northern Unit upgradient wells) and 111 monitor the zone of attenuation. Some data (i.e., groundwater elevations and analytical results) from thethe zone of attenuation. Some data (i.e., groundwater elevations and analytical results) from the NEU and Southem Unit have been used to characterize the hydrogeology for the Northem Unit.NEU and Southern Unit have been used to characterize the hydrogeology for the Northern Unit.

There are number of gas probes around the waste disposal area of the Northem Unit that areThere are aa number of gas probes around the waste disposal area of the Northern Unit that are sampled. Results are reported after the analytical results are available.sampled. Results are reported after the analytical results are available.

v. Progress Since the Last Five~Year ReviewV. Progress Since the Last Five-Year Review

The issues and the recommendations and follow-up actions listed in the 2007 reviewThe issues and the recommendations and follow-up actions listed in the 2007 five-yearfive-year review included the implementation of additional institutional controls as well as the verification of theincluded the implementation of additional institutional controls as well as the verification of the effectiveness of the existing controls. These issues and recommendations and follow-up actionseffectiveness of the existing controls. These issues and recommendations and follow-up actions are currently in process.are currently in process.

The landfill operator began placement of wastes in the area between the Northern Unit and theThe landfill operator began placement of wastes in the area between the Northem Unit and the Southern Unit in December 2005. This is the Southern Unit Expansion, which has beenSouthem Unit in December 2005. This is the Southem Unit Expansion, which has been permitted by the state.state. This area includes most of the southeast comer. Filling with wastes waspermitted by the This area includes most of the southeast comer. Filling with wastes was completed in 2010. The monitoring wells and gas probes that were in this area were abandoned.completed in 2010. The monitoring wells and gas probes that were in this area were abandoned. The vegetative soil of the Northern Unit cover was removed in the area where wastes were to beThe vegetative soil of the Northem Unit cover was removed in the area where wastes were to be placed; at least 22 feet of the protective soil layer of the cover for the Northern Unit was left inplaced; at least feet of the protective soil layer of the cover for the Northem Unit was left in place and lies below the liner system of the Southem Unit Expansion. However, at both ends ofplace and lies below the liner system of the Southern Unit Expansion. However, at both ends of this area the protective soil and the drainage layer of the Northem Unit were removed andthis area the protective soil and the drainage layer of the Northern Unit were removed and replaced by one foot of sand. The area where wastes were to be placed covered byreplaced by one foot of sand. The area where wastes were to be placed waswas covered by aa geosynthetic and clay liner overlain by drainage layer like that used for the Southem Unit; thisgeosynthetic and clay liner overlain by aa drainage layer like that used for the Southern Unit; this

Pagel's Pit Site--Five-Year Review ReportPagel's Pit Site-Five-Year Review Report PagePage 1515 September 2012September 2012

is the liner system for the Southern Unit Expansion in this area. Wastes were placed above theis the liner system for the Southem Unit Expansion in this area. Wastes were placed above the drainage layer. This method of construction resulted in the leachate generated by the wastesdrainage layer. This method ofconstruction resulted in the leachate generated by the wastes placed in the Southem Unit Expansion draining to the leachate collection system of the Southemplaced in the Southern Unit Expansion draining to the leachate collection system of the Southern Unit rather than draining into the Northem Unit. This promotes drainage of leachate to the newlyUnit rather than draining into the Northern Unit. This promotes drainage of leachate to the newly engineered waste unit. The Southem Unit and Southem Unit Expansion were capped in twoengineered waste unit. The Southern Unit and Southem Unit Expansion were capped in two phases, with the east half being completed in 2010 and the west half in 2011. The approval ofphases, with the east half being completed in 2010 and the west half in 2011. The approval of the constmction report is pending with lEPA.the construction report is pending with IEPA.

Integrys Energy Services armounced in December 2007 that all four combustion engines at itsIntegrys Energy Services announced in December 2007 that all four combusfion engines at its recently completed Winnebago Energy Center, landfill gas-to-electricity plant located at therecently completed Winnebago Energy Center, aa landfill gas-to-electricity plant located at the Winnebago Landfill, are now operational and supplying power to the grid. The landfill gas isWinnebago Landfill, are now operational and supplying power to the grid. The landfill gas is collected from the Winnebago Landfill, including the Northem Unit, and is being used as fiaelcollected from the Winnebago Landfill, including the Northern Unit, and is being used as aa fuel in these combustion engines that drive generators that produce the electricity. Integrys Energyin these combustion engines that drive generators that produce the electricity. Integrys Energy Services is the owner/operator of the Center. The previously used remain in service asServices is the owner/operator ofthe Center. The previously used flaresflares remain in service as aa backup for the engines to control the landfill gas when engines are not in service or the ofbackup for the engines to control the landfill gas when engines are not in service or the flowflow of gas is more than the facility can handle.gas is more than the facility can handle.

The May 2012 Status Report is aa five-yearfive-year evaluation of the groundwater management zone inThe May 2012 Status Report is evaluation of the groundwater management zone in accordance with condition of the landfill's permit. The report includes review of currentaccordance with aa condition of the landfill's permit. The report includes aa review of current groundwater remediation activities, groundwater quality of all groundwater monitoring wellsgroundwater remediation activities, groundwater quality of all groundwater monitoring wells contained within the GMZ, trend analysis data in graphical and tabular formats for all GMZcontained within the GMZ, trend analysis data in graphical and tabular formats for all GMZ parameters and wells, vertical and horizontal GMZ extent maps, cross-sections, potentiometricparameters and wells, vertical and horizontal GMZ extent maps, cross-sections, potentiometric surface maps, and recommendations for the GMZ, if necessary.surface maps, and recommendations for the GMZ, if necessary.

In the report, the extent of the upper and lower zones of the GMZs are shown for the years 1995,In the report, the extent of the upper and lower zones of the GMZs are shown for the years 1995, 2004, 2007, and 2012; the landfill applied to the state in 1995 for permission to create GMZ.2004,2007, and 2012; the landfill applied to the state in 1995 for permission to create aa GMZ. (See the "Initial Response" subsection above for discussion of the GMZ.) The 1995 GMZ was(See the "Initial Response" subsection above for aa discussion of the GMZ.) The 1995 GMZ was based on one sampling event and its depiction was made prior to the closing of the Northembased on one sampling event and its depiction was made prior to the closing of the Northem Unit. The extent and locafion of both the upper and lower GMZs for 1995 and 2004 are quiteUnit. The extent and location of both the upper and lower GMZs for 1995 and 2004 are quite similar. The GMZs are located to the west and the northwest of the waste boundary. The Statussimilar. The GMZs are located to the west and the northwest of the waste boundary. The Status Report concludes that the overall horizontal extent of the upper zone GMZ has not changedReport concludes that the overall horizontal extent of the upper zone GMZ has not changed significantly since 2007, although significant reduction in the recorded concentrations andsignificantly since 2007, ahhough aa significant reduction in the recorded concentrations and individual parameter extents is evident. The report says the same thing about the overallindividual parameter extents is evident. The report says the same thing about the overall horizontal extent of the lower zone GMZ. Figures and show the horizontal extents of thesehorizontal extent of the lower zone GMZ. Figures 22 and 33 show the horizontal extents of these two zones for 2012.two zones for 2012.

Besides the evaluations of the GMZ, the Status Report comments on various monitoring wellsBesides the evaluations of the GMZ, the Status Report comments on various monitoring wells and on various contaminants and the trends in their concentrations for the time since 2007. In theand on various contaminants and the trends in their concentrations for the time since 2007. In the table that presents the exceedances of AGQSs since 2007, there are very few reports for organicstable that presents the exceedances of AGQSs since 2007, there are very few reports for organics in the downgradient wells. At the time of the remedial investigation, elevated organicin the downgradient wells. At the time of the remedial investigation, elevated organic concentrations were major concem. There are now only few reports for organics in theconcentrations were aa major concem. There are now only aa few reports for organics in the upgradient wells in the southeast comer (G09M, G09D, G13S, and G13D) and in the monitoringupgradient wells in the southeast comer (G09M, G09D, G13S, and G13D) and in the monitoring well between the Northem Unit and the Acme Solvent (G20D).well between the Northern Unit and the Acme Solvent sitesite (G20D).

September 2012Pagel's Pit Site--Five-Year Review ReportPagel's Pit Site-Five-Year Review Report PagePage 1616 September 2012

The May 2012 Status Report noted that the 1995 Permit Renewal incorporated the remedialThe May 2012 Status Report noted that the 1995 Pennit Renewal incorporated the remedial actions chosen to remedy Winnebago Landfill's impacted groundwater. The GIA included in theactions chosen to remedy Winnebago Landfill's impacted groundwater. The GIA included in the application was directed toward assessing the potential impacts of the facility after completion ofapplication was directed toward assessing the potential impacts of the facility after completion of the remedial activities and was used to evaluate the effectiveness of the remedial design. Finalthe remedial activities and was used to evaluate the effectiveness of the remedial design. Final cover was completed in July 2001 and the necessary upgrades to the leachate/gas extractioncover was completed in July 2001 and the necessary upgrades to the leachate/gas extraction system were completed in 2002, the approved remedial measures. The GIA stated thatsystem were completed in 2002, finalizingfinalizing the approved remedial measures. The GIA stated that the existing impacted groundwater would take an estimated to ten years to achievethe existing impacted groundwater would take an estimated fivefive to ten years to achieve background concentrations. It was inferred that this timeline would commence upon completionbackground concentrations. It was inferred that this timeline would commence upon completion of the remediation systems. Therefore, the effect of the remedial measures would becomeof the remediation systems. Therefore, the effect of the remedial measures would become apparent sometime between 2007 and 2012. Although few parameters are still detected atapparent sometime between 2007 and 2012. Although aa few parameters are still detected at concentrations above the AGQSs, significant improvements to groundwater quality are evident asconcentrations above the AGQSs, significant improvements to groundwater quality are evident as demonstrated by the decreases in individual parameter concentrations and GMZ extents. Indemonstrated by the decreases in individual parameter concentrations and GMZ extents. In addition, the organic constituents which prompted the remedial actions are typically not detectedaddition, the organic constituents which prompted the remedial actions are typically not detected in groundwater downgradient of the facility. Based on the number of wells in and surroundingin groundwater downgradient of the facility. Based on the number of wells in and surrounding the Northem Unit and their respective screened intervals and parameter lists, no additionalthe Northern Unit and their respective screened intervals and parameter lists, no additional investigations are proposed at this time. Evaluation of the GMZ should continue as previouslyinvestigations are proposed at this time. Evaluation of the GMZ should continue as previously permitted in Condition VIII.23 of Permit No. 1991-138-LF, Modification 53. The GMZ shallpennitted in Condition VIII.23 of Pennit No. 1991-138-LF, Modification 53. The GMZ shall continue to be monitored in accordance with current requirements. In the event modification tocontinue to be monitored in accordance with current requirements. In the event aa modification to the remedial performance monitoring program is necessitated, permit application will bethe remedial perfonnance monitoring program is necessitated, aa pennit application will be submitted identifying the subject changes.submitted identifying the subject changes.

VI. Five-Year Review ProcessVI. Five-Year Review Process

Administrative ComponentsAdministrative Components

The Illinois EPA and the landfill operator were fonnally notified about the review by U.S. EPA'sThe Illinois EPA and the landfill operator were formally notified about the review by U.S. EPA's Remedial Project Manager Bemard Schorle, who is conducting the review.Remedial Project Manager Bernard Schorle, who is conducting the review.

Community Notification and InvolvementCommunity Notification and Involvement

An ad appeared in the Rockford Register Star on May 25, 2012 informing the community thatAn ad appeared in the Rockford Register Star on May 25,2012 infonning the community that aa review was to take place, listing the major components of the remedy, and informing them wherereview was to take place, listing the major components of the remedy, and infonning them where additional documents could be found. The public waswas also told that they could submit commentsadditional documents could be found. The public also told that they could submit comments concerning the Site to U.S. EPA. One resident contacted the RPM by telephone and talked withconcerning the Site to U.S. EPA. One resident contacted the RPM by telephone and talked with him about landfills. Around the same time that this ad appeared there comment period inhim about landfills. Around the same time that this ad appeared there waswas aa comment period in progress regarding the proposed siting of new municipal landfill near the location of Pagel's Pitprogress regarding the proposed siting of aa new municipal landfill near the location of Pagel's Pit by the operators of Wirmebago Landfill. There had been public meeting in connection with theby the operators of Winnebago Landfill. There had been aa public meeting in connection with the comment period and the caller asked questions about Pagel's Pit and landfills in general. Nocomment period and the caller asked questions about Pagel's Pit and landfills in general. No comments about Pagel's Pit were made.comments about Pagel's Pit were made.

There is an infonnation repository for the Site located at the Rockford Public Library.There is an information repository for the Site located at the Rockford Public Library. Completed five-yearfive-year review reports can also be obtained through the Internet atCompleted review reports can also be obtained through the Intemet at epa.gov/region5/superfund. AA second notice announcing the completion of the five-yearfive-year reviewepa.gov/region5/superfiind. second notice announcing the completion of the review and the availability of the report will be issued once the report is signed.and the availability of the report will be issued once the report is signed.

Pagel's Pit Site--Five-Year Review ReportPagel's Pit Site-Five-Year Review Report PagePage 1717 September 2012September 2012

Document ReviewDocument Review

For the review, the monitoring reports from the landfill operator that provide the results of theFor the review, the monitoring reports from the landfill operator that provide the results of the groundwater monitoring and the evaluation of the results, which are also submitted to the state asgroundwater monitoring and the evaluation of the results, which are also submitted to the state as part of the requirement under the operating permit, have been reviewed. The main report thatpart of the requirement under the operating permit, have been reviewed. The main report that was consulted for this review was the May 2012 report. Status Report and Evaluation ofwas consulted for this review was the May 2012 report, Status Report and Evaluation of Groundwater Corrective Actions and Groundwater Management Zone, Andrews Engineering,Groundwater Corrective Actions and Groundwater Management Zone, Andrews Engineering, Inc. This report includes table that contains historical groundwater analytical data for the GMZInc. This report includes aa table that contains historical groundwater analytical data for the GMZ parameters in the GMZ wells beginning with the quarter of 1997 so that trends can easily beparameters in the GMZ wells beginning with the firstfirst quarter of 1997 so that trends can easily be seen.seen.

Data ReviewData Review

The review consisted primarily of reviewing the reports that are submitted by AndrewsThe review consisted primarily of reviewing the reports that are submitted by Andrews Engineering, Inc. on behalf of the operator of the landfill. Most of these reports are documentsEngineering, Inc. on behalf of the operator of the landfill. Most of these reports are documents that the operator has to submit to lEP under the requirements of the permit. These reports arethat the operator has to submit to IEPAA under the requirements of the permit. These reports are reviewed by U. S. EPA. The results of this data review are discussed in the "Progress Since thereviewed by U. S. EPA. The results of this data review are discussed in the "Progress Since the Last Five-Year Review" section of this report. few parameters are still detected atLast Five-Year Review" section of this report. AA few parameters are still detected at concentrations above the AGQSs significant improvements to groundwater quality areconcentrations above the AGQSs butbut significant improvements to groundwater quality are evident as demonstrated by the decreases in individual parameter concentrations and GMZevident as demonstrated by the decreases in individual parameter concentrations and GMZ extents. In addition, the organic constituents which prompted the remedial actions are typicallyextents. In addition, the organic constituents which prompted the remedial actions are typically

detected in groundwater downgradient of the Site. Evaluation of the GMZ will continue andnotnot detected in groundwater downgradient of the Site. Evaluation of the GMZ will continue and the GMZ shall continue to be monitored in accordance with the current requirements.the GMZ shall continue to be monitored in accordance with the current requirements.

Site InspectionSite Inspection

Inspection of the Site waswas conducted on September 8, 2011 by the RPM, aa representative of theInspection of the Site conducted on September 8, 2011 by the RPM, representative of the landfill operator, and aa contractor for the operator. The purpose of the inspection was to observelandfill operator, and contractor for the operator. The purpose of the inspection was to observe the Site and check on those things that are not generally reported on. The Site appeared to be inthe Site and check on those things that are not generally reported on. The Site appeared to be in very good condition. The Winnebago Energy Center on the Site was also toured. The land northvery good condition. The Winnebago Energy Center on the Site was also toured. The land north of the Northem Unit is now accepting waste. The home that was on the east side of Lindenwoodof the Northern Unit is now accepting waste. The home that was on the east side of Lindenwood Road opposite the southeast comer had been removed but an out building is still there. TheRoad opposite the southeast comer had been removed but an out building is still there. The landfill operator had purchased this property.landfill operator had purchased this property.

InterviewsInterviews

No interviews with people not directly connected with the Site were conducted.No interviews with people not directly connected with the Site were conducted.

VII. Technical AssessmentVII. Technical Assessment

Question A. Is the remedy functioning as intended by the decision documents?Question A. Is the remedy functioning as intended by the decision documents?

Yes, the review of the available information indicates that the remedy is functioning as it wasYes, the review of the available information indicates that the remedy is fiinctioning as it was intended. Concentrations of contaminants have decreased over the years. However, even thoughintended. Concentrations of contaminants have decreased over the years. However, even though institutional controls specified by the 1999 ROD have yet to be implemented, the stated ICinstitutional controls specified by the 1999 ROD have yet to be implemented, the stated IC objectives are being met.objectives are being met.

Pagel's Pit Site-Five-Year Review ReportPagel's Pit Site--Five-Year Review Report Page 18Page 18 September 2012September 2012

Compliance with ICs is required to assure that the remedy continues to function as intended.Compliance with ICs is required to assure that the remedy continues to function as intended. Based on inspections and discussions, there appears to be compliance with the stated objectivesBased on inspections and discussions, there appears to be compliance with the stated objectives of the land and groundwater use restrictions. To assure that the remedy continues to function asof the land and groundwater use restrictions. To assure that the remedy continues to function as intended, les must be reviewed to assure their effectiveness, additional ICs must beintended, ICs must be reviewed to assure their effectiveness, additional ICs must be implemented, and the ICs must be monitored and maintained. To that end, an IC study will beimplemented, and the ICs must be monitored and maintained. To that end, an IC study will be prepared to study existing ICs and determine what additional ICs are needed. An IC plan will beprepared to study existing ICs and determine what additional ICs are needed. An IC plan will be prepared to incorporate the results of the study and plan for additional IC activities, as needed.prepared to incorporate the results of the study and plan for additional IC activities, as needed.

Question B. Are the exposure assumptions, toxicity data, clean-up levels, and remedialQuestion B. Are the exposure assumptions, toxicity data, clean-up levels, and remedial action objectives used at the time of the remedy selection still valid?action objectives used at the time of the remedy selection still valid?

Yes, there have been no major changes in the physical conditions of the Site that would affect theYes, there have been no major changes in the physical conditions of the Site that would affect the protectiveness of the remedy. The Site is being used as anticipated as part of aa landfillingprotectiveness of the remedy. The Site is being used as anticipated as part of landfilling operation so the exposure assumptions that were made do not need to be changed.operation so the exposure assumptions that were made do not need to be changed.

The remaining applicable or relevant and appropriate requirements (ARARs) that still have to beThe remaining applicable or relevant and appropriate requirements (ARARs) that still have to be attained deal with the quality of the groundwater. There are still exceedances of the AGQSs.attained deal with the quality of the groundwater. There are still exceedances of the AGQSs. The AGQSs were specified as cleanup standards in the RODs. However, the operator mustThe AGQSs were notnot specified as cleanup standards in the RODs. However, the operator must satisfy the conditions of the state operating permit which will require continued monitoring of thesatisfy the conditions of the state operating permit which will require continued monitoring of the GMZ. There has been one significant change in an MCL. The MCL for arsenic has beenGMZ. There has been one significant change in an MCL. The MCL for arsenic has been lowered to pg/1, which is also the value for the AGQS for total arsenic; it had been 50 pg/1lowered to 1100 ~gll, which is also the value for the AGQS for total arsenic; it had been 50 ~g/l

when the 1991 ROD issued. The cleanup standards will be reviewed in the fiiture since somewhen the 1991 ROD waswas issued. The cleanup standards will be reviewed in the future since some were based on risks calculated with data that may have been updated. No Site uses which arewere based on risks calculated with data that may have been updated. No Site uses which are inconsistent with the implemented ICs or the remedy's IC objectives have been noted during theinconsistent with the implemented ICs or the remedy's IC objectives have been noted during the Site inspection or discussions with the owner's representative.Site inspection or discussions with the owner's representative.

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

There has been no other known information that could call into question the protectiveness of theThere has been no other known information that could call into question the protectiveness of the remedy.remedy.

VII. Technical Assessment SummaryVII. Technical Assessment Summary

According to the data reviewed, the Site inspection, and discussions with the owner'sAccording to the data reviewed, the Site inspection, and discussions with the owner's representative, the remedy is functioning as intended by the two RODs. There have been norepresentative, the remedy is functioning as intended by the two RODs. There have been no changes in the physical conditions at the Site that would affect the protectiveness of the remedy.changes in the physical conditions at the Site that would affect the protectiveness of the remedy. The Site is being used in manner consistent with the required use restrictions. The additionalThe Site is being used in aa manner consistent with the required use restrictions. The additional institutional controls required under the 1999 ROD, when put into place, will complete theinstitutional controls required under the 1999 ROD, when put into place, will complete the implementation of the remedy.implementation of the remedy.

Pagel's Pit Site-Five-Year Review Report Page 19 September 2012Pagel's Pit Site--Five-Year Review Report Page 19 September 2012

VIII. IssuesVIII. Issues

The issues identified during this review were:The issues identified during this review were:

Institutional Controls. The additional ICs specified by the 1999 ROD need to be1.1. Institutional Controls. The additional ICs specified by the 1999 ROD need to be implemented and existing ICs need to be reviewed.implemented and existing ICs need to be reviewed. 2. Institutional Controls. Along with assuring that effective ICs are in place for all areas that2. Institutional Controls. Along with assuring that effective ICs are in place for all areas that

do not support unlimited use, long-term stewardship must be assured, which includesdo not support unlimited use, long-term stewardship must be assured, which includes maintaining and monitoring effective ICs.maintaining and monitoring effective ICs.

IX. Recommendations and Follow-Up ActionsIX. Recommendations and Follow-Up Actions

1. Institutional Controls. The landfill owner will be directed to perform study of the ICs.1. Institutional Controls. The landfill owner will be directed to perform aa study of the ICs. 2. Institutional Controls. U.S. EPA will review the landfill owner's IC study and existing2. Institutional Controls. U.S. EPA will review the landfill owner's IC study and existing solid waste permit and develop an IC plan to identify required follow-up actions to assuresolid waste permit and develop an IC plan to identify required follow-up actions to assure that effective ICs are in place, to plan for implementation of additional ICs as needed, and tothat effective ICs are in place, to plan for implementation of additional ICs as needed, and to assure that effective procedures exist for long-term Site stewardship.assure that effective procedures exist for long-term Site stewardship.

a ee 22 ssues, R da IOns anan Follow-Up Actionsow- AcfIOnsTTablhI ; Issues, Recommendations: I ecommen f dd F II0 UIp

Affects Protectiveness?Affects Protectiveness? (Y/N)(YIN)

Recommendations/Recommendations/ PartyParty OversightOversight Mile-stoneMile-stone IssueIssue Follow-up ActionsFollow-up Actions ResponsibleResponsible AgencyAgency DateDate CurrentCurrent FutureFuture

ICs- TheICs-- The The landfill ownerThe landfill owner PRP/U.S. EPAPRP/U.S. EPA U.S. EPAU.S. EPA MarchMarch NN YY additional ICsadditional ICs will perform studywill perform aa study 20132013 specified by thespecified by the of the ICs.of the ICs. 1999 ROD need1999 ROD need to beto be implementedimplemented and existing ICsand existing ICs need to beneed to be reviewed.reviewed.

ICs—Along withICs--Along with U.S. EPA will reviewU.S. EPA will review U.S. EPA (withU.S. EPA (with U.S. EPAU.S. EPA June 2013June 2013 NN YY assuring thatassuring that the landfill owner's ICthe landfill owner's IC input theinput fromfrom the effective ICs areeffective ICs are study and existingstudy and existing Group)/ PRPGroup)/ PRP in place for allin place for all solid waste permit,solid waste permit, required areas,required areas, develop an IC plan todevelop an IC plan to long-termlong-term identify requiredidentifY required stewardshipstewardship follow-up actions tofollow-up actions to must be assured,must be assured, assure that effectiveassure that effective which includeswhich includes ICs are in place, andICs are in place, and maintaining andmaintaining and based on IC study,based on IC study, monitoringmonitoring PRP will implementPRP will implement effective ICs.effective ICs. ICs as needed, andICs as needed, and

assure that effectiveassure that effective procedures exist forprocedures exist for long-term Sitelong-term Site stewardship.stewardship.

Pagel's Pit Site--Five-Year Review Report Page 20 September 2012Pagel's Pit Site—Five-Year Review Report Page 20 September 2012

X. Protectiveness StatementX. Protectiveness Statement

The remedies for OU 11 and OU 2 are protective of human health and the environment in theThe remedies for OU and OU 2 are protective of human health and the enviromnent in the short term because the remedy is functioning as anticipated and exposure pathways that couldshort term because the remedy is functioning as anticipated and exposure pathways that could result in unacceptable risks are being controlled. Therefore the remedy for the entire Site isresult in unacceptable risks are being controlled. Therefore the remedy for the entire Site is protective in the short term. Long-term protectiveness requires compliance with effective ICs.protective in the short term. Long-term protectiveness requires compliance with effective ICs. In order for the remedies for OU 11 and OU 2 to be protective in the long term, additionalIn order for the remedies for OU and OU 2 to be protective in the long term, additional institutional controls are necessary and the effectiveness of the institutional controls and of theinstitutional controls are necessary and the effectiveness of the institutional controls and of the long-term stewardship procedures need to be evaluated. Long-term stewardship requires thatlong-term stewardship procedures need to be evaluated. Long-term stewardship requires that effective ICs will be maintained and monitored along with maintaining the Site remedy.effective ICs will be maintained and monitored along with maintaining the Site remedy.

XL Next ReviewXI. Next Review

The next five-yearfive-year review for the Pagel's Pit Site is required in September 2017, fivefive years fromThe next review for the Pagel's Pit Site is required in September 2017, years from the signature date of this review.the signature date of this review.

Pagel's Pit Site--Five-Year Review Report Page 21 September 2012Pagel's Pit Site-Five-Year Review Report Page 21 September 2012

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