BEFORE THE
POLLUTION CONTROL BOAR)
OF THE STATE OF ILLINOIS
GLEN’S 66,
RECERV~D
)
CLERK’S OFFICE
Petitioner,
)
)
MAYH2004
)
PCBO4
____
STATE OF ILLINOIS
)
(UST Appeal)
Pollution
Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respon4ent.
)
NOTICE
OF FILING
TO:
John
Kim
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
PLEASE
TAKE
NOTICE
that
on
May
11,
2004,
filed
with
the
Clerk of the
Illinois
Pollution
Control
Board
of the
State
of Illinois
an
original,
executed
copy
of a
Petition
for
Review of Illinois Environmental Protection Agency Decision.
Dated:
May
11, 2004
Respectfully submitted,
Glen’s 66
By:
___________________
One of Its Attd~eys
Carolyn S. Hesse
Barnes & Thornburg LLP
One North Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312)357-1313
218315v1
This
filing submitted
on recycled paper as defined in 35
III.
Adm. Code 101.202
CERTIFICATE OF SERVICE
I,
on
oath
state
that
I
have
served
the
attached
Petition
for
Review
of
Illinois
Environmental Protection Agency Decision by placing a copy in an envelope addressed to:
John Kim
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O.
Box
19276
Springfield, Illinois 62794-9276
from
One North Wacker
Drive,
Suite 4400,
Chicago, Illinois,
before the hour of 5:00
p.m.,
on
this
11th
Day of May, 2004.
~
Carolyn
S.
Hes~T~
This
filing submitted on recycled
paper as defined in 35
Ill. Adm. Code
101.202
2
BEFORE THE POLLUTION CONTROL BOARD
OF THE
STATE OF ILLINOIS
GLEN’S66,
)
RECEIV~
CLERK’S OFFICF
Petitioner,
)
MAY
11280 ~
v
~
PCB 04-
~
STATE OF ILLlN~:.~
Pollution Control bc,~..rc
)
(UST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
PETITION FOR
REVIEW
OF ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY DECISION
Glen’s
66
(“Glen’s
66”), by its
attorney, Carolyn S. Hesse of Barnes
& Thornburg
LLP,
pursuant to
the Illinois Environmental Protection
Act,
415
ILCS
5/1
et.
seq.
(the “Act”) and 35
Illinois
Administrative
Code
Section
105.400
et.
seq.,
hereby appeals certain decisions
by
the
Illinois Environmental Protection Agency (the “Agency”).
1.
Glen’s 66
(“Petitioner”)
was the owner of a gasoline service
station
that
was
located
at
209
West
Main
Street,
Coffeen,
Montgomery
County,.
Illinois
(the
“Station”).
This
gasoline
service
station
had
underground
storage tanks (UST’s) on the property, which stored gasoline.
2.
LUST
Incident
Number
991539
was
obtained
following
a
site
investigation.
The
site
has
also
been
assigned
LPC
#1350155004-
Montgomery County.
3.
On January
23,
2003,
CW3M,
the contractor hired by
Petitioner to
assist
Petitioner with
corrective action at the Station,
sent to the Agency
a High
Priority
Corrective
Action
Plan
(“HPCAP”)
and
Budget
to
perform
EThis filing submitted on recycled paper
as defined in 35
III. Adm. Code 101.2021
corrective
action
at the
Station.
The
Agency
received
the
HPCAP
on
January 23, 2003.
4.
On
April
8,
2004,
the
Agency
sent
a letter to
Petitioner
modifying
the
January 23,
2003
High
Priority Corrective Action Plan and
Budget.
(See
Exhibit
A.)
The
letter
included
a
list
of modifications
made
by
the
Agency.
For the majority of the modifications, the Agency’s letter stated
that
modifications
were
made because the
“costs
were
not
reasonable
as
submitted.”
5.
It
appears
that,
when
determining
whether
to
consider
certain
costs
“reasonable,”
the
Agency
used
rate
sheets
even
though
the
Illinois
Pollution
Control Board
(the “Board”) had
earlier
decided
Illinois Ayres
Oil Company v.
IEPA,
PCB
03-214,
decided April
1,
2004.
In
Ayres,
the
Board
described
the rate
sheets
as
invalid rules
and
determined that
the
Board was not obligated to follow the rate sheets.
6.
The Agency’s April 8, 2004,
letter also
disapproved the proposed biomass
injection
trench
and
piping
even though
the
Agency
had
approved this
type of
in situ
treatment system on prior occasions.
The Agency’s April
8,
2004,
letter
failed
to
explain
why the
biomass
injection
trench
was not
approved.
7.
The Agency’s letter of April
8,
2004,
provides
no
additional information
regarding why IEPA
modified the HPCAP or believes
that costs
are not
reasonable.
This
filing submitted
on
recycled paper
as
defined in 35
Ill. Adm. Code 101.202
2
8.
Some
of
the
Agency’s
modifications
also
contained
the
following
sentence:
“Please
note
that
additional
information
and/or
supporting
documentation may be provided to
demonstrate the costs are reasonable.”
9.
However, the Agency’s April
8,
2004
letter also
states that
the Agency’s
decision
is
a
final
decision,
appealable
to
the
Illinois
Pollution
Control
Board.
Thus,
in
order
to
preserve
PetitiOner’s
rights
and
to
appeal
the
Agency’s decisions, Petitioner is appealing the Agency decisions set forth
in the Agency’s letter dated April 8, 2004.
WHEREFORE,
Glen’s
66
respectfully
requests
that
the
Board
enter
an
order
requiring the Agency to
approve the High Priority Corrective Action Plan and Budget to
allow the cleanup to proceed at this
facility and for Glen’s 66’s attorneys’ fees
and costs
in bringing this appeal.
Respectfully submitted,
Glen’s 66
By:
~
One ofIts Atto&~ys
Carolyn S. Hesse, Esq.
Barnes
& Thornburg LLP
One North Wacker Drive
Suite 4400
Chicago, Illinois
60606
(312) 357-1313
218439v1
-
IThis filing submitted
on recycled paper as
defined
in 35 III. Adm. Code
101.202
3
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
•0
1021
NoRTH
GRAND AVENUE
EAST,
P.O.
Box
19276,
5~RINCFIELD,ILLINOIS
62794-9276.
217-782-3397
JAMES
R.
THQ.\IPSQN CENTER.
100
WEST
R.ANDOLPN,
SLITE
1
1
-300,
CHICAGO.
IL 60601.
31 2-814-6020
Roo
R
BLAGOIEVICH,
GOVERNOR
RENEE
CIpRIANO,
DIRECTOR-
217/782-6762
APR
0
8
20D4
CERTIFIED MAIL
7UO~ 3150
0000
1257
O2~
Glen Crocks
900 East Columbia
Litchfield, IL
62056
Re:
LPC #1350155004
--
Montgomery County
CoffeenlGlen’s 66.
209 West Main Street
LUS.T Incident No. 991539
LUST Technical File
Dear Mr. Crocks:
J~TV~D
~P;.
~.
?D04
The fllinois
Environmental Protection Agency (illinois EPA) has re~riewed
the High Priority
Corrective Action Plan (plan)
submitted for the above-referenced
incident.
This plan, dated
January 23, 2003, was received by the flhinois EPA on January
23,
2003..
Citations in
this Jetter
are from the Environmental Protection Act (Act) and 35
illinois Administrative Code (35
111.
Adm. Code).
.
Pursuant to
Section
57.7(c)(4)
of the Act and 35
ill. Adm.
Code 732.405(c),
the plan is
modified.
The following modifications are necessary, in
addition to those
provisions already outlined in
the
plan, to
demonstrate compliance with Title XVI of the Act and
35
Ui. Adm.
Code 732:
1.
The installation of the biomass
injection trench and piping is not approved.
2.
Monitoring well MW-i
must be replaced upon completion of the
bacicuilling activities.
The replacement well must be sampled as part of the post-soil remediation
groundwater
sampling.
3.
Groundwater samples must be analyzed for lead.
A determination about the groundwater
lead being the result of background will be made upon receipt of the post-soil remediation
groundwater sampling data.
4.
Corrective action plans
proposing bioremediation must taken into consideration
the
factors listed in
the attached illinois
EPA Fact Sheet “Feasibility and Design
Determination
for ~ioremediation” dated March 2004.
Rc~c~cc,w
—
4302
North
Main
Street,
Rocktord,
IL
61103 —481St 987-7760
•
D~s
PL,~INES
—
951
1
W.
Harri,on 5’.
De~PI~in~.
ft 60018— (84’)
29J-~000
ELCI’.
—
595
South
Stato,
EI~in,II. 60123
—
I8~7l608-3131
PEOR4A
5415
N.-Uni,ersity
St
Peoria,
IL 1,11,14
—
(309i 693-3483
8uRE~uOF
LSNO.
PErtsI.A
7620
N
University St..
Peoria,
IL
6161 ~
—
(309) 693-5-562
•
CH~MPACr~
—
3175
South
First Street, ChamoaiKn.
IL.
61530—
:21
—
4500
5. Sixth
Street
Rd.. SprlngfieldIL
62706—121
‘I
786-6892
•
COLLL\~VILLE
—
2009 “al)
Street,
Collinsville.
IL 62234
—
ElSt
~
5.1
2(3
MARION
—
2309 W.
MaIn
SL,
Suite
116, Marion.
IL 62959
—
(618) 993-7200
EXHIBIT
P’tIN
FE~QN
REc”-cLeo
PAPF,R
A
Page
2
Please note that all activities
associated with the remediation of this release
proposed in
the plan
must be executed in
accordance with all
applicable
regulatory and statutory requirements,
including compliance with the proper permits.
In addition,
the budget for the High Priority Corrective Action Plan is modified pursuant to
Section 57.7(c)(4) of the Act and
35
111. Adm. Code
732.405(c).
Based on the modifications
listed
in
Section 2
of Attachment A, the amounts listed in
Section
1
of Attachment A
are
approved.
Please note
that the costs must be incurred in accordance with
the approved plan.
Be
aware
that the amount ofreimbursement may be
limited by
Sections
57.8(e),
57.8(g)
and
57.8(d)
of the
Act,
as well as 35 flI.
Adm. Code 732.604, 732.606(s), and
732.611.
Please note that, if the owner or operator agrees with the illinois EPA’s modifications,
submittal
of an amended plan andior budget, ~fapplicable,
is not required (Section
57.7(c)(4)
of the
Act
and 35
111. Adm.
Code 732.503(f)).
Additionally, pursuant to Section 57.8(a)(5) of the
Act and
35
1.11. Adm.
Code
732.405(e),
if reimbursement will be sought for any additional
costs that may
be
incurred as a result of the illinois EPA’s modifications, an
amended budget must be
submitted.
NOTE:
Amended plans and/or budgets must be submitted and approved prior to
the issuance of
a No Further Remediation
(NFR) Letter,. Costs associated with
a plan orbudget that have not
been approved prior to
the issuance of an NFR Letter will not be reimbursable.
All future correspondence must be submitted to:
•
illinois Environmental Protection Agency
Bureau ofLand
-
#24
Leaking Underground Storage Tank Section
1021
North Grand Avenue East
Post Office Box
19276
Springfield, IL
62794-9276
Please submit all
correspondence in duplicate and include the Re: block shown at the beginning
of this
letter.
An underground storage tank system owner or operatormay appeal this
decision to
the. illinois
Pollution Control Board.
Appeal rights
are attached.
The development of risk-based remediation objectives may be appropriate to demonstrate
adequate protection ofhuman health and the environment for this LUST
incident.
Engineered
bamers, institutional controls which prohibit the use ofgroundwater as potable water, land use
restrictions, environmental land use controls, or highway authority agreements may be
appropriate at this facility to provide adequate protection for human health and the environment.
Personnel of the illinois
EPA
Leaking
Underground
Storage
(LUST) Section
would
be glad to
holda meeting or telephone conference with you
and
your environmental consultant to review
Page 3
the items discussed
in this
letter and to discuss corrective action options available
to you
pursuant to the Environmental Protection
Act (Act)
as amended by Public Act 92~O554
on June
24. 2002,
the LUST regulations
(35
Iii.
Adrn. Code 731
and
732) and the Tiered Approach to
Corrective Action Objectives (TACO) rules
(35
111.
Adm.
Code 742).
Ifyou have
any questions or need further assistance, please contact the illinois EPA project
manager,
Steve Jones, at 217/524-1253.
Sincerely,
.
~j?Fr’~Tp~)~
~
Iny:P~
Hemando A. Albarracin
Unit Manager
L.eaking
Underground Storage Tank Section
Division of Remediation
Management
Bureau of Land
HAA:~Glen’s66(991539) CAP
1.doc
Attachments:
Attachment A
•
illinois EPA Fact Sheet “Feasibility and Design Determination
for
Bioremediation” dated March 2004
Appeal Rights
C:
CW3M Company, Inc.
Division File
Attachment A
Re:
LPC~#l350
155004
--
Montgomery County
CoffeerilG.len’s
66
209
West Main Street
LUST Incident No. 991539
LUST Technical File
Citations
in this
attachment
are
from the Environmental Protection Act (Act)
and
35
illinois
Administrative
Code
(35
1111.
Adm.
Code).
SECTION
1
The budget was previously approved for:
$12,274.00
Investigation Costs
$3,569.00
Analysis
Costs
$10,400.00
Personnel Costs
$535.00
Equipment Costs
$2,037.26
Field Purchases andOther Costs
• $1,837.12
Handling Charges
As a result of the illinois EPAs
modification(s) in Section
2
of
this
Attachment A, the following
amounts are approved:
$3,205.00
InvestIgation Costs
$3,853.00
Analysis Costs
$14,948.00
Personnel Costs
$807.00
Equipment Costs
$199,298.22
•
Field Purchases and
Other Costs
$9,723.06
Handling Charges
Therefore, the total cumulative budget is
approved for:
$15,479.00
Investigation Costs
$7,422.00
Analysis Costs
$25,348.00
Personnel Costs
$1,342.00
Equipment Costs
$201,335.48
Field Purchases and Other Costs
$11,560.18
Handling Charges
SECTION
2
1.
$10.00 for an adjustment in
mobilization costs.
The Illinois EPA
has
determined that
these costs are not reasonable as submitted (Section
57.7(c)(4)(C)
of the Act
and
35
111.
Page
2
Adm.
Code 732.606(hh)).
One of the overall
goals of the financial review
is
to
assure
that costs associated with materials, activities, and
~ervices are reasonable
(35
III. Adm.
Code
732.505(c)).
Please note
that additional information and/or supporting
documentation may be provided to demonstrate the costs are reasonable.
2
$122.00 for an adjustment in costs for monitoring well materials.
The Illinois
EPA has
determined that these costs
are not reasonable as submitted (Section 57.7(c)(4)(C) of the
Act and 35
Ill.
Adm.
Code 732.606(hh)).
One of the overall goals of the financial review
is to
assure that costs
associated with materials, activities,
and services are reasonable
(35
ill.
Adm.
Code
732.505(c)).
Please note that additional information andlor supporting
documentation may be provided to demonstrate the costs are reasonable.
3.
$5.00 for an adjustment in costs
for pH sample.
The illinois EPA has determined that
these costs are not reasonable
as submitted (Section
57.7(c)(4)(C)
of the Act
and 35 Ill.
Adm.
Code 732.606(hh)).
One ofthe overall
goals of the financial review is
to
assure
that costs
associated with materials, activities,
and services
are reasonable
(35
III. Adm.
Code 732.505(c)).
Please note that additional information and/or supporting
documentation may be provided to
demonstrate the costs are reasonable
4.
$7.00
for an
adjustment in costs for painter filter sample.
The Illinois
EPA has
determined that these costs are not reasonable
as submitted (Section
57.7(c)(4)(C)
of the
Act and
35
LU. Adm.
Code
732.606(hh)).
One of the overall goals of the financial review
is to
assure that costs associated with materials, activities,
and services
are reasonable
(35
Ill.
Adm.
Code 732.505(c)).
Please note that additional information and/or supporting
documentation may be provided to demonstrate the costs
are reasonable.
5.
$5.00 for an adjustment in costs for flash point sample.
The illinois EPA has determined
that these costs are not reasonable as submitted (Section
57.7(c)(4)(C)
of the Act and
35
1.11.
Adm.
Code 732.606(hh)).
One of the overall goals of the financial review is to assure
that costs associated with materials, activities,
and services are reasonable (35
III. Adm.
Code 732.505(c)).
Please note
that additional
information and/or supporting
documentation
may be provided to demonstrate the costs are reasonable.
6.
$1,880.00 for an adjustment in
costs for biofeasibility sample testing.
The Illinois EPA
has determined that these Costs are not reasonable
a.s submitted
(Section
57.7(c)(4)(C)
of
the Act and
35
Lii. Adm.
Code 732.606(hh)).
One of the overall goals of the financial
review
is to assure that costs associated
with materials, activities,
and
services are
reasonable
(35
111. Adm.
Code 732.505(c)).
Please note that additional information
and/or supporting documentation may be
provided to
demonstrate the costs are
reasonable.
7.
$63.277.00 for an adjustment in personnel
costs.
The Illinois
EPA has d~.rxniri~d
that
P ~
0,~~~~
Page
3
these costs
are not
reasonable
as submitted
(Section 57.7(c)(4)(C) of the Act and 35
Ill.
Adm. Code 732.606(hh)).
One of the o~’erall
goals of the financial review
is
to
assure
that costs associated with materials, activities,
and services are r~asonab~e
(35
111.
Adm.
Code
732.505(c)).
Pleasenote that additional information and/or supporting
documentation may
be provided to demonstrate the costs arc reasonable.
8.
$175.00
for an
adjustment in PJD
(photoionization detector) costs.
The illinois EPA has
determined that these costs
are not reasonable
as submitted (Section 57.7(c)(4)(C) of the
Act and 35
DL Adm.
Code 732.606(hh)).
One of the overall
goals of the financial review
is to
assure that costs associated with materials, activities, and services are reasonable
(35
DL
Adm.
Code 732.505(c)).
Please note that additional information and/or supporting
documentation may be provided
to demonstrate the costs
are reasonable.
9.
$21.00 for an adjustment in
costs for measuring wheel.
The Illinois EPA has determined
that these costs are not reasonable as submitted (Section
57.7(c)(4)(C)
of the
Act and 35
UI.
Adm.
Code 732.606(hh)).
One of the overall goals of the financial review is
to assure
that costs associated with materials, activities, and services are reasonable (35 Ill. Adm.
Code
732.505(c)).
Please note that additional information and/or supporting
documentation may be provided to
demonstrate the costs are reasonable.
In addition,
these costs are indirect corrective action costs~Indirect corrective action costs for
personnel, materials, service, or equipment charged as direct costs
are ineligible for
payment from
the Fund (Section
57.5(a)
of the Act and 35
III. Adm.
Code 732.606(v)).
10.
$21.00 for an adjustment in
costs for Encore Sampler Tool.
The illinois
EPA has
determined that these costs
are not reasonable
as submitted (Section 57.7(c)(4)(C) of the
Act and 35
Dl.
Adm. Code
732.606(hh)).
One of the overall goals of the financial review
is
to
assure that costs associated with materials, activities,
and services are reasonable
(35
UI. Adm. Code
732.505(c)).
Please note
that additional information and/or
supporting
documentation may be provided to
demonstrate the costs are reasonable.
In addition,
these costs are ir~dircc~
corrective act~orjcosts.
Indirect corrective action
cOStS
for
personnel, materials, service, or equipment charged as direct costs
are ineligible for
payment from
the Fund (Section
57.5(a)
ofthe
Act and 35
111.
Mm.
Code 732.606(V)).
11.
$2,921.20 for an
adjustment in mileage costs.
The illinois EPA has determined that these
costs
are
not reasonable as submitted (Section 57.7(c)(4)(C) ofthe
Act
and
35
111.
Adm.
Code 732.606(hh)).
One of the overall goals of the financial review is to assure that costs
associated with materials7
activities,
and services are reasonable (35
ilL Adm.
Code
732.505(c)).
Please note
that additional
information and/or supporting documentation
may be provided to
demonstrate the costs
are reasonable.
12.
$400.00 for an
adjustment in costs for building demolition
and asbestos inspection.
The
Illinois EPA has determined that these costs
are not reasonable as submitted (Section
Page 4
57.7(c)(4)(C)
of the Act and 35
LII.
Adm.
Code 732.606(hh)).
One of the overall
goals of
the financial review is to
assure that costs associated with
materials. activities,
and
services are reasonable
(35
III. Adm.
Code 732.505(c)).
Please note that additional
information and/or supporting documentation
may be provided to
demonstrat~
the
costs
are reasonable.
13.
$3,015.10
for an adjustment in costs
for soil excavation, transportation and disposal.
The
Illinois EPA has determined that these costs
are not
reasonable as submitted (Section
57.7(c)(4)(C) of the Act and 35
IlL Adm.
Code 732.606(1±)).One of the overall goals of
the financial review is to
assure that costs
associated with materials, activities.
and
services are reasonable
(35
Dl.
Adm.
Code
732.505(c)).
Please note
that
additional
information and/or supporting documentation may be provided to
demonstrate the costs
are reasonable.
14.
$28,617.22 for an adjustment in costs for backfilling.
The Illinois EPA has determined
that these costs
are not reasonable as submitted (Section
57.7(c)(4)(’C)
of the Act and
35
Ill.
Adm.
Code 732.606(hh)).
One of the overall
goals of the financial review is
to assure
that costs associated with materials, activities, and
services are reasonable
(35
Iii. Adm.
Code 732.505(c)).
Please note
that additional information and/or supporting
documentation may be provided to demonstrate the
costs are reasonable.
15.
$1,500.00 for art adjustment in costs forbiomass injection
trench.
The
installation of the
biomass injection trench is not approved.
These costs are for activities in excess
of those
necessary to
meet the minimum requirements of Title XVI of the Act (Section
57.5(a)
of
the Act)
and 35
111.
Adrn. Code
732 (Section 732.505(c)).
Costs for corrective action
activities and associated materials or services
exceeding the minimum requirements
necessary to comply with
the Act are not eligible for reimbursement from the Fund
(35
ill.
Adm.
Code 732.606(o)).
S~len’s 66(991539) CAP
1.doc
jL3~:
.Ck
-~
Appeal Rights
An underground
storage tank owner or operator may appeal
this final decision
to the Illinois
Pollution Control Board pursuant to Sections 40 and
57.7(c)(4)(JD)
of the Act by filing
a petition
for a hearing within 35 days after the date of issuance of the final decision.
However, the 35-±iv
period may be extended for a period of time
not to exceed 90 days by
written notice from
the
owner or operator and the Illinois EPA within the initIal 35-day appeal period.
If the owner or
operator wishes to
receive a 90-day
extension, a written request that includes a statement of the
date the final decision was received, along with a copy of this decision, must
be
sent to
the
Illinois EPA as soon as possible.
For information regarding the filing
of an appeal, please contact:
Dorothy Gunn, Clerk
illinois
Pollution Control Board
State of
illinois
Center
100 West Randolph, Suite 11-500
Chicago,L
60601
312/814-3620
For information regarding the
filing of an extension, please contact:
illinois Environmental Protection Agency
Division ofLegal Counsel
1021
North Grand Avenue East
Post Office
Box
19276
Springfield,
IL
62794-9276
217/782-5544
Illinois
Bureau of Land
March
2004
S
Environmental
102~North Grand Avenue
East
Protection Agency
Springfield,
lUinois
62794-9276
Feasibility and Design
Determination for Bioremediation
Purpose
This document is designed to aid
in
the review of sites proposing biorernediation
as a means of corrective action.
Each feasibility and design criteria must be
considered in the design ofa
corrective actIon plan proposing bioremediation.
General Applicability
Contaminant Plurn~
Soil and groundwater contaminant plume should be defined.
Free Product:
Free Product should not be present in
area to be remediated
Hydraulic Conductivity:
-
Should
be greater than
1
X
1 0’.
All contaminated
saturated zones
must
be
tested.
pH Qfgroundwater:
Should be
between 6.0 and 8.0.
Tested from upper foot of groundwater, within
area ofhighest impact.
Total Microbial Plate
Count:
One soil sample must be taken
at or below the groundwater surface, located
in an
area oflittle
or no
impact.
Results should be
greater than
1,000 CPU
(colony
forming units).
Soil
Porosity:
One soil sample froi-n the contaminated zone should
be analyzed
to
determine
soil
porosity.
Heavy Metals:
Results for heavy metals should be below 10mg/I for iron;
20 mg/I fo~
copper: 20
mg/i for zinc, and 900 mg/I for lead.
Additionally,
total heavy metals
should
not
exceed 2500
mg/i.
Oxv~en
Demand:
For comaminani plumes
01
acre or less.
l\’e
borinus
should
be
mpl~t~d
~nd
groundwo~terand soil
samples
collected.
One horinu should
be
10c.neLl
at
the
highest gradient
of the plume. one from lowest
itradient. and three across
the
center of the
plume.
These
samples should be
tested
fbr Total
Petroleum
Hydrocarbon. Chemical
Oxygen Demand, and Heavy Metals.
Contaminant plumes
lar~er
than 1/2
acre
should add one more
boring
(OnC
soil
and one
groundwzaer
sample)
per additional
~
acre.
~
G~
~~-=-J
D~~n
Considerations
Determine
Mass
of Contaminants
•
The mass ofcontaminants (measured by the higher amount
ofTotal
Petroleum
-
Hydrocarbons (TPH) or Chemical Oxygen Demand (COD))
to
be treated
must be
determined in both soil arid groundwater.
Sampling will determine the
concentration of contaminants present in the soil and groundwater.
To
estimate
the total
amount of oxygen required to remediate the contaminants, the following
example
cart
be followed:
Assume average concentration in soil and
groundwater (TPH or COD)
=
10 ppm
Assume volumeofcontaminated mass (size ofplume) in
cubic yards
=
1,000 (cy)
A
cubic yard ofclay (saturated) weighs
118
#/ft3
=
3200#
A cubic yard
ofsand (saturated) weighs
124
#/ft3
=
3350~
The total mass of contaminants requiring treatment (clay):
10/(1
x
106) x 3200 #/cy x
1000 cy
32 #‘s
(lOppm
10/(1
x 106))
Estimate of Oxygen Requirement
Based
on th~extent of contamination and total mass of
contarriinants,
the required
oxygen
demand can be calculated.
COD or TPH need to be considered in
order to
determine the total amount of oxygen required for degradatIon of contaminants,
As
a rule of thumb,
3
lbs of oxygen
are required per lb of
hydrocarbon
to be
remediated.
Benzene can be used as an example to
determine the mass ratio of
oxygen to
hydrocarbon.
Oxidation
Equation: C6H6
+
7.5
02
=
6C07
+
3
H20
(~26)+(16)=78
7.5
(~6’2)—
240
Ifbenzene were the only contaminant present it would
take 240
lbs of oxygen
to
completely degrade
78
lbs of beozerie.
Meaning
3
lbs (240/78
3.08)
of oxygen
are required
to
completely degrade each lb ofbenzene.
For a leaking UST bite
we
must consider all
contaminants that
will
USC oxygen
in calculating the oxYgen
requirement.
Example:
Total
mass of
contaminants
from above
=
32
#
Required Oxygen~32 #
*
3#/#
—
96 lb.
If you assume the oxygen
delivery product provides
1 0
by weight
it
is capable
ofdelivering
.
1
#‘s of oxygen. therefore:
Oxygen release
capability
=
10
Required chemIcals
•-
960ft
‘Fhe manu1~cturer’sinform~uionregarding
ox
gen release
capabililics
should
bc
followed
in
calculatinu required chemicals
A factor of sal’ctv
ol
~
ol
the
•
calculatcd
voLume
of material
r~c1uiredwill
h~
allowed.
Lay~ut
ofInfection Wells
Determining the location and number ofinjection wells required for a one
time
application is a critical
factor in the designing of in-situ bioremediation,
The
-
design
considerations are based
on
a one-time injection of oxygen.
InjectIon
wells galleries should
be
located
to provide distribution of the electron
acceptor
and nutrients throughout
the area targeted for remediation.
Amounts of material
injected
at each location should be
based in the estimated contaminant
levels to be
remediated.
Determining the area ofinfluence is a key parameter for proper distribution of the
product into the ground.
Injection pressure, hydraulic
conductivity (K),
hydraulic
gradient
(1) arid porosity (n) are important elements
to calculate an approximate
area of influence.
Darcy’s law can be used to estimate the area of influence.
The
injection pressure used will drastically change the hydraulic gradient in
the
vicinity of the
injection
point.
Assuming
the length (~1)
is half of the radius of
influence you
should
use the injection
pressure (psi) and
estimate of rh~
radius
ol’
influence to
determine if the amount of time to achieve
this radius of influence
makes sense.
An example follows:
v= K ~bJ~l, where v
Darcy Velocity
v~
=
Ki/n,
where,
va
Interstitial
Velocity, (ftlsec)
K
Hydraulic Conductivity,
(frlsec)
=
Hydraulic Gradient, dhldl (ft/ft)
n
Porosity of Aquifer Material,
()
Generally, the products are injected into the ground with
a
pressure rungin~
from
250
to
2500 psi.
To simplify the calculations, several assumptions are made
to
calculate the area ofinfluence and
interstitial velocity.
Assuming a pressure of
1500 psi, an approximate area ofinfluence 4 feet, and K
=
1
x
10”~
crnlsec.
Va
Ki/n
Kl*10~cm/sec
=
3.28* 10.6 ft/see
3.28*106
ft/sec*3846
~h= (1500 lb/in,2* 144 in2/ft2)/(62.4
lb/
ft3)=
3462
ft.
0.0 126
ft/sec
~1
2 ft. (halfofthe design influence)
0.75
ft/mitt
i
=
=
3462 ft/2
ft
=
1731
ft/fl
45°/o(assumed)
i/n
=
1731/0.45=
384(~
Based
on
the
assumptions.
it
is
revealed
that 4 feet (0.75
tiiinin.
*
5
mb.
=
3.75
4
feet)
of
radius
of
influence can be achieved in
5 minutes
with an
injection
pressure of 1500 psI.
You should then consider whether
it
is reasonable
to expect
the
design pressure (psi) to
be applied
for
the
required time (5
minutes) at
each
injection
point.
You can
decrease the time required by increasin~rthe
injection
pressure and/or reducing the design radius of influence.
Locaiion
of’ thc
injection
points should
maxi inizc
thc area
ol
in
11
ticOce
Ironi
each
niCelion
point
(i.e.. Wi’t
or
~uiggercd
cel1L’F~.
~
:.~i)i~
•
Monitoru~g
One round of groundwater samples should
be collected
and analyzed for all
contaminants ofconcern
and
TPH and COD prior
(within
one month)
to
injection
ofoxygenating compounds.
Six months after injection another round of
groundwater sampling
should be performed and results evaluated to
determine the
effectiveness ofthe oxygenating compound.
This
information should be
compiled in a status report and submitted to
the Agency
Closure
Sampling ofthe soil
and groundwater should show compliance with the
applicable 35
JAC Part 742
criteria.
Additional information may be obtained by
calling 21 7/782-6762 and
asking for the
Leaking Underground
Storage Tank Section Project Manager on
call or by visiUfl~
the
Illinois EPA’s Web site at
www.epa.state.iI.us.
rThe
Feasibijity and Design
for
Bioremediation Fact Sheet
is for general
information only and
is
not intended to
replace, interpret or modif~’
laws,
rules,
orregulations.
