Agreement with US Ecology Establishes Long-Term Stewardship Requirements at Facility in Illinois
On September 22, 2020, the U.S. Environmental Protection Agency (EPA) and US Ecology agreed to an administrative order on consent (AOC) under Section 3008(h) of the Resource Conservation and Recovery Act (RCRA) to ensure long-term stewardship (LTS) activities continue at the US Ecology’s facility in Sheffield, Illinois. The LTS plan provided for in the agreement includes maintenance of the engineered controls, semi-annual groundwater and surface water sampling, 5-Year Remedy Reviews with separate sampling requirements, statistical trend evaluations of the data, annual certification of institutional controls, a contingency plan, and financial assurance.
This new AOC provides EPA an enforceable mechanism to ensure LTS activities continue to protect human health and the environment in perpetuity at a facility where hazardous waste is contained. As this facility approaches its 30-year monitoring obligation under the state post-closure permit, and all other RCRA Corrective Action obligations are met, this AOC provides for all future requirements. This ensures proper oversight and eliminates the duplication of both an EPA AOC and an Illinois EPA (IEPA) permit, which is still in effect but defers entirely to the EPA’s AOC.
On this page:
- Information about US Ecology and its Facility
- Overview of RCRA § 3008(h) Administrative Order on Consent
- Contact Information
Information about US Ecology and its Facility
US Ecology is a waste management company that offers treatment, disposal, and recycling of hazardous, nonhazardous, and radioactive waste.
The US Ecology facility is a 46-acre permitted hazardous waste facility that operated from 1968 to 1983. The facility includes two hazardous waste landfills referred to as the Old Chem Site and the New Chem Site. During operations, the facility accepted industrial, laboratory, and agricultural hazardous wastes. Approximately 165,000 cubic yards of waste were reportedly disposed of at the two landfills (93 percent at the New Chem Site). The 46 acres of landfill is situated on US Ecology's 380-acre property that is entirely fenced.
Overview of RCRA § 3008(h) Administrative Order on Consent
The requirements of a 1985 RCRA AOC between the EPA and US Ecology are complete and more than 25 years of groundwater monitoring has occurred at the facility under both the agreement with the EPA and the state RCRA permit. The 2020 agreement is intended to memorialize the completion of the 1985 agreement’s requirements and capture the on-going requirements at the facility, focused on the remaining LTS needs.
The 2020 agreement creates LTS obligations for US Ecology which means that the post-closure care for this hazardous waste landfill will remain within the EPA’s Corrective Action program.
Long-term monitoring is intended to achieve the following objectives:
- Identifying contaminated groundwater migration beyond the facility boundary;
- Evaluating groundwater plume stability through constituents of concern (COC) attenuation;
- Mapping changes to the groundwater flow path;
- Assessing surface water quality at Trout Lake;
- Confirming integrity of the engineering/source controls;
- Certifying institutional controls and deed restrictions;
- Planning contingency actions; and
- Monitoring of groundwater and surface water semi-annually for volatile organic compounds (VOCs) and physical parameters.
US Ecology’s LTS obligations include:
- Maintenance of a conceptual site model that encompasses the full life cycle of monitoring and maintenance activities at the facility;
- Monitoring and maintenance of the engineering controls (landfill caps, barrier walls, leachate collection system, stormwater drainage, and perimeter fencing);
- EPA-approved statistical evaluation of groundwater trends;
- Landfill leachate management including volume tracking and off-site disposal;
- Annual LTS reporting to present data, trend evaluation, inspection/repair summaries, and leachate volume;
- Five-year remedy reviews to include a more robust sampling network, additional trend evaluation including natural attenuation parameters, and an assessment for the need to update the conceptual site model (CSM);
- Update institutional controls originally filed in 1981, updated in 1995 and 2000, and annual institutional controls certification;
- Contingency plan to identify metrics and trigger criteria for action; and
- Financial assurance.
Contact Information
For more information contact:
Shanelle Cooper
Project Manager
U.S. Environmental Protection Agency
Region 5 Office
77 West Jackson Boulevard
Chicago, IL 60604
312-886-6753
[email protected]
Hala Kuss
Attorney Advisor
U.S. Environmental Protection Agency
Region 5 Office
77 West Jackson Boulevard
Chicago, IL 60604
312-353-1377
[email protected]