BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RICHARD GOODEN, )
)
Petitioner, )
) PCB No.
vs. ) (UST Appeal)
)
ILLINOIS ENVIRONMENTAL )
PROTECTION AGENCY, )
)
Respondent. )
NOTICE OF FILING
TO: Ms. Dorothy Gunn John Kim, Esq.
Clerk of the Board Division of Legal Counsel
Illinois Pollution Control Board Illinois Environmental Protection Agency
100 W. Randolph Street 1021 N. Grand Avenue East
Suite 11-500 P.O. Box 19276
Chicago, IL 60601 Springfield, IL 62764-9276
PLEASE TAKE NOTICE that I have today filed with the Office of the
Clerk of the Illinois Pollution Control Board an original and nine copies of an
Entry of Appearance of Jeffrey W. Tock and Petition for Review of Illinois
Environmental Protection Agency’s Decision to Deny Petitioner’s
High Priority
Corrective Action Plan Budget
, copies of which are herewith served upon you.
Respectfully Submitted
RICHARD GOODEN,
Petitioner
BY: /S/
Jeffrey W. Tock
Dated: February 23, 2006
Jeffrey W. Tock
Harrington & Tock
201 W. Springfield Ave., Suite 601
P.O. Box 1550
Champaign, Illinois 61824-1550
Telephone: (217) 352-4167
vlb/Pleadings.jef/HDC/Gooden-NoticeFiling
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* * * * * PCB 2006-139 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RICHARD GOODEN, )
)
Petitioner, )
) PCB No.
vs. ) (UST Appeal)
)
ILLINOIS ENVIRONMENTAL )
PROTECTION AGENCY, )
)
Respondent.
)
ENTRY OF APPEARANCE OF JEFFREY W. TOCK
NOW COMES Jeffrey W. Tock, of the law firm of Harrington & Tock, and
hereby enters his appearance on behalf of Petitioner, RICHARD GOODEN, in the
above-referenced matter.
Respectfully Submitted
RICHARD GOODEN,
Petitioner,
By: /S/
Jeffrey W. Tock
Dated: February 23, 2006
Jeffrey W. Tock
Harrington & Tock
201 W. Springfield Ave., Suite 601
P.O. Box 1550
Champaign, Illinois 61824-1550
Telephone: (217) 352-4167
vlb/Pleadings.jef/HDC/Gooden-EntryApp
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1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RICHARD GOODEN, )
)
Petitioner, )
) PCB No.
vs. ) (UST Appeal)
)
ILLINOIS ENVIRONMENTAL )
PROTECTION AGENCY, )
)
Respondent. )
PETITION FOR REVIEW OF ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY’S DECISION TO DENY
PETITIONER’S HIGH PRIORITY CORRECTIVE ACTION PLAN BUDGET
NOW COMES the Petitioner, RICHARD GOODEN (hereinafter “Petitioner”), by
and through his attorney’s, Harrington & Tock, and, pursuant to Sections 40 and 57.7 of
the Illinois Environmental Protection Act (“Act”) (415 ILCS 5/40, 5/57.7), and 35 Ill.
Admin. Code Part 105, hereby requests review of the decision by the Respondent, Illinois
Environmental Protection Agency (“Agency”), to reject the Petitioner’s High Priority
Corrective Action Plan Budget. In support of this Petition, the Petitioner states as
follows:
1. Petitioner is the owner of certain real property located at 149 North Railroad
Avenue, Paxton, Illinois, hereinafter referred to as the “Site”.
2. Petitioner is the owner of underground storage tanks (“USTs”) formerly located at
the Site.
3. Petitioner submitted to the Agency his Corrective Action Plan (“CAP”) for the
Site in April of 2004 and the Agency approved that CAP on May 5, 2004.
4. On October 6, 2005, Petitioner, through HDC Engineering, submitted to the
Agency his High Priority Corrective Action Plan Budget (the “Budget”). A true
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and accurate copy of the Budget as submitted to the Agency is attached hereto and
made a part hereof as Exhibit “A”.
5. By letter dated January 20, 2006, the Agency rejected the Budget for the reasons
listed in Attachment A to that letter. The letter was signed by Harry A. Chappel.
A true and accurate copy of that letter, with attachments, is attached hereto and
made a part hereof as Exhibit “B”.
6. Also attached to the Agency’s January 20, 2006 letter was a page captioned
“Appeal Rights” which stated that “An underground storage tank owner or
operator may appeal this final decision to the Illinois Pollution Control Board…
within 35 days after the date of issuance of the final decision”.
7. This Petition to review the Agency’s rejection of the Budget is filed within 35
days from January 20, 2006.
8. Paragraph 1 of Attachment A to the Agency’s letter of January 20, 2006 states
that the Budget was rejected because it includes costs for per diem. The per diem
amounts shown on the Budget were included in the Budget in error and the
Petitioner agrees to strike any request for per diem reimbursement.
9. Paragraph 2 of Attachment A states as follows:
“The budget includes costs that lack supporting documentation (35
Ill.Admin.Code 732.606(gg)). A corrective action plan budget
must include, but not be limited to, an accounting of all costs
associated with implementation and completion of the corrective
action plan (Sections 57.7(b)(3) of the Act). Since there is no
supporting documentation of costs, the Illinois EPA cannot
determine that costs will not be used for activities in excess of
those required to meet the minimum requirements of Title XVI of
the Act (Section 57.7(c)(3) of the Act and 35 Ill.Admin.Code 732
505(c) and 732.606(o)).
The following items lack supporting documentation:
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A) Total personnel hours (The proposed costs/hours/persons for
the following appear to be excessive: staff on-site for
excavation and backfill activities, staff/hours required for the
preparation of a CAP & Budget, CACR, HAA, and ELUC. A
detailed breakdown of all hours associated with each task
proposed is being required.)
B) CAP mobilization
C) Excavation costs (Form L-1 proposes excavation costs to be
$8,125.00; however, form I-2 proposes excavation costs of at
least $14,115.00. Please explain the discrepancies.)
D) Excavation, transportation, disposal costs (These costs as a
whole appear to be excessive. Please provide a detailed
explanation for the amounts proposed for each individual task.)
E) Six inch thick concrete (Why does the concrete need to be six
inches thick?)”
10. The Agency states in paragraph 2A of Attachment A that the costs/hours/persons
for the tasks identified appear to be excessive and the Agency required the
Petitioner to file a detailed breakdown of all hours associated with each task.
(a) Page G-1 of the Budget contains a detailed breakdown of the costs,
hours and personnel associated with High Priority Investigation and
Preliminary Costs. That category is broken down among five different
personnel, a description of the specific task to be performed by each
person, the number of hours attributable to each person and the hourly
rate and total dollars allocated to each person.
(b) Page G-1 of the Budget contains a detailed breakdown of the costs,
hours and personnel associated with CAP Implementation (dig and
haul). That category is broken down among four different personnel, a
description of the specific task to be performed by each person, the
number of hours attributable to each person and the hourly rate and
total dollars allocated to each person.
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(c) Page G-2 of the Budget contains a detailed breakdown of the costs,
hours, and personnel associated with CACR Report/Reimbursement.
That category is broken down into six different personnel categories
with a description of the services to be performed by each person, the
number of hours allocated to each person and the hourly rate and the
total cost of services for each person.
(d) This detailed breakdown of the costs/hours/persons associated with
High Priority Investigation and Preliminary Costs, CAP
Implementation and CACR Report/Reimbursement is a method that
has been used by the engineers for the Petitioner on numerous projects
that have been approved by the Agency.
(e) It is arbitrary and capricious of the Agency to have rejected
Petitioner’s Budget based upon an alleged lack of a detailed
breakdown of all hours associated with each task given the level of
detail stated in the Budget.
(f) It is arbitrary and capricious of the Agency to have rejected
Petitioner’s Budget based upon the Agency’s objection to an alleged
lack of detail when the Agency has approved this same format used in
proposed budgets for other projects.
11. Paragraph 2B of Attachment A requires supporting documentation for CAP
mobilization.
(a) Page I-2 of the Budget contains a line item for CAP mobilization of a
lump sum dollar amount of $250.00.
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(b) This is a standard fee that represents the cost to deliver heavy
equipment to the Site.
(c) This CAP mobilization fee is a charge that has been used by the
engineers for the Petitioner on numerous projects that has been
accepted by the Agency for each of those projects and has never been
challenged prior to this Budget.
(d) It is arbitrary and capricious for the Agency to recognize this standard
mobilization in some budgets and reject it in others.
12. In paragraph 2C of Attachment A the Agency requires an explanation of an
alleged discrepancy between excavation costs of $8,125.00 as shown on page L-1
of the Budget and excavation costs of $14,115.00 as shown on page I-2 of the
Budget.
(a) Page L-1 of the Budget refers to excavation of 1,769 cubic yards at
$4.59 per cubic yard for a total excavation cost of $8,125.00. Page I-2
of the Budget under the heading of “Costs for Excavation and Backfill
Activities” contains the following two line items: Excavator w/
operator $11,875.00; Skid Loader w/ operator $2,240.00. These two
line items when added together total $14,115.00. As noted by the
caption on page I-2, these costs are for both excavation and backfill
activities, not just excavation. The figure of $8,125.00 under
paragraph C on page L-1 only applies to excavation. Paragraph E on
page L-2 applies to Backfill Costs. The balance of the $14,115.00 is
included in paragraph E.
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6
(b) Part L of the Budget is a summary of costs based on a form provided
by the Agency. Any ambiguity as to the interpretation of the
information completed by the Petitioner on the form provided by the
Agency is a result of the Agency’s form, not any fault of the
Petitioner. The engineers for the Petitioner completed the Agency’s
budget form in the same manner as they have completed the same
budget form for other projects and as directed by the Agency to obtain
approval of those budgets.
(c) It is arbitrary and capricious of the Agency to reject Petitioner’s
Budget due to ambiguities in the Agency’s budget form and the
Agency’s past directions on how to complete the budget form.
13. Paragraph 2D of Attachment A states that the excavation, transportation and
disposal costs appear to be excessive and requires Petitioner to provide an
explanation for the amount proposed for each individual task.
(a) As shown on page L-1 of the Budget, the Petitioner’s excavation cost
was $4.59 per cubic yard, $13.23 per cubic yard for transportation, and
$39.49 per cubic yard for disposal. This is a total cost of $57.31 per
cubic yard for excavation, transportation and disposal.
(b) In 2004, the Agency proposed to the Illinois Pollution Control Board
(the “Board”) that the Board adopt certain new rules under Title 35,
Subtitle G, Chapter 1, Subchapter d, Part 732 of the Illinois
Administrative Code. Proposed Rule 732.825 pertained to soil
removal. Section 732.825(a) as proposed by the Agency states that
payment for costs associated with the removal, transportation and
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disposal of contaminated soil must not exceed a total of $57.00 per
cubic yard. The difference between the $57.31/cubic yard proposed by
the Petitioner and the $57.00 cap proposed by the Agency is
insignificant. The Agency cannot claim the costs proposed by
Petitioner are excessive when the Agency supported that same cost
before the Board.
(c) The Opinion And Order of the Board dated February 17, 2005
regarding the new rules proposed by the Agency contained the
following testimony of Harry Chappel in support of new rule
732.825(a):
“For Section 732.825/734.825, Mr. Chappel testified that
the rate for soil excavation, transportation and disposal was
developed using randomly selected projects. Exh. 11 at 3.
The maximum rate for the cost to excavate, transport, and
dispose (ETD) is the sum of costs for each activity plus one
standard of deviation rounded up to a whole dollar amount.
Id.
The result is $57 per cubic yard.”
True and accurate copies of relevant excerpts from the February 17,
2005 Opinion And Order are attached hereto as Exhibit “C”.
(d) The Agency, and Mr. Chappel in particular, cannot propose a rule that
allows a total removal, transportation and disposal cost of $57.00 per
cubic yard starting in 2004 and then pretend two years later that the
same cost appears to be excessive. To do so would be arbitrary and
capricious.
(e) The Board approved rule 732.825 on February 16, 2006.
14. In paragraph 2E of Attachment A the Agency has questioned why concrete to be
poured on site needs to be six inches thick.
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(a) The approved CAP included figures indicating that the site currently consists
of an office, a garage, and a concrete surface. Also included in the CAP were
soil boring logs indicating the presence of concrete at the Site that is a
minimum of six inches thick (borings B5, B6, B14, B15, and B16).
(b) The Board has now approved Rule 732.605 as proposed by the Agency. That
Rule states:
Section 732.605 Eligible Corrective Action Costs
a)16) Costs for destruction and replacement of concrete, asphalt, or
and paving to the extent necessary to conduct corrective action and if
the concrete, asphalt, or paving was installed prior to the initiation of
corrective action activities, the destruction and replacement has been
certified as necessary to the performance of corrective action by a
Licensed Professional Engineer, and the destruction and replacement
and its costs are approved by the Agency in writing prior to the
destruction and replacement. The costs for destruction and
replacement of concrete, asphalt, and paving must not be paid more
than once. Costs associated with the replacement of concrete, asphalt,
or paving must not be paid in excess of the cost to install, in the same
area and to the same depth, the same material that was destroyed (e.g.,
replacing four inches of concrete with four inches of concrete).
(c) It was arbitrary and capricious for the Agency to act contrary to its proposed
rule 732.605(a)(16) and reject the Petitioner’s Budget to replace six inches of
concrete with six inches of concrete.
15. The Agency states in paragraph 3 of Attachment A that the CAP approved by the
Agency on May 5, 2004 proposed to excavate, transport and dispose of 1,684
cubic yards of contaminated soil, but the CAP Budget proposed costs for the
excavation, transport and disposal of 1,769 cubic yards. The Agency concluded
that the costs associated with materials, activities and services as stated in the
Budget were not consistent with the approved CAP. The Agency also stated that
a 1.5 conversion factor should be used when converting from cubic yards to tons.
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(a) The Corrective Action Plan (CAP) approved by the Agency on May 5,
2004 proposed to excavate, transport and dispose of 1,684 cubic yards
of contaminated soil. That was the estimated quantity of contaminated
soil as it existed in place (i.e.
in situ
) at the time the CAP was
submitted for approval.
(b) Once soil is removed from the ground, that soil no longer has the same
compaction as when it was
in situ
. The engineer for the applicant used
a factor of 5% as the increase in volume from the
in situ
material to the
excavated material. 105% of 1,684 cubic yards is 1,769 cubic yards,
the figure used by the Petitioner in his Budget.
(c) In 2004, the Agency proposed that the Board adopt certain new rules
under Title 35, Subtitle G, Chapter 1, Subchapter d, Part 732 of the
Illinois Administrative Code. Those rules were adopted by the Illinois
Pollution Control Board on February 16, 2006. Proposed Rule
732.825 pertains to soil removal. Section 732.825(a)(1) as proposed
by the Agency and as now approved states as follows: “Except as
provided in Subsection (a)(2) of this Section, the volume of soil
removed and disposed must be determined by the following equation
using the dimensions of the resulting excavation: (Excavation Length
x Excavation Width x Excavation Depth) x 1.05.” The Agency
proposed a 5% increase in the volume as a result of removal
(excavation) of the soil.
(d) The calculation used by the Petitioner to determine the volume of
contaminated soil after such soil is excavated is consistent with rule
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732.825(a) as proposed by the Agency in 2004 and as adopted by the
Board on February 16, 2006.
(e) Mr. Chappel testified in favor of this 5% “fluff” factor, as he referred
to it. (See Exhibit “C”.)
(f) Petitioner has used a quantity of 2,794 tons of contaminated soil to be
disposed in preparing page I-2 under the category Costs for Excavation
and Backfill Activities. The figure 2,794 tons is derived by
multiplying the number of yards as excavated (1,769) times a
conversion factor of 1.58 tons per cubic yard. Although the Agency
stated at paragraph 3 of Attachment A that the conversion should be
1.5 tons per cubic yard, the Agency approved the conversion of 1.58
tons per cubic yard as part of the Petitioner’s Corrective Action Plan
(CAP) that was approved by the Agency on May 5, 2004. A copy of
sec. 6.1 of the CAP contains the 1.58 conversion factor. A copy of
that sec. 6.1 is attached hereto and made a part hereof as Exhibit “D”.
(g) The Agency and the Board have approved a “fluff” factor of 5%. It
was arbitrary and capricious of the Agency to have rejected
Petitioner’s 5% fluff factor when the Agency had recommended it in
2004.
(h) The Agency approved a conversion factor of 1.58 in 2004. It was
arbitrary and capricious of the Agency to have rejected Petitioner’s
1.58 conversion factor when the Agency had approved it in
Petitioner’s CAP.
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11
16. Petitioner is seeking review of the Agency’s January 20, 2006 rejection of the
Petitioner’s Budget for the CAP that was previously approved by the Agency.
The Agency’s rejection of the Petitioner’s Budget was arbitrary, capricious and
without statutory authority.
WHEREFORE, Petitioner, RICHARD GOODEN, respectfully requests that the
Illinois Pollution Control Board grant the following relief:
1. Find that the Agency’s January 20, 2006 rejection of the Petitioner’s Budget was
arbitrary and capricious and without statutory authority;
2. Reverse the Agency’s decision rejecting the Petitioner’s Budget;
3. Remand this matter to the Agency with instructions to approve the Petitioner’s
Budget;
4. Award the Petitioner his engineer’s fees, attorney’s fees and expenses incurred in
bringing this action; and,
5. Award such further relief as deemed just and equitable in these premises.
RICHARD GOODEN,
Petitioner,
By: /S/
Jeffrey W. Tock
Dated: February 23, 2006
Jeffrey W. Tock
Harrington & Tock
201 W. Springfield Ave., Suite 601
P.O. Box 1550
Champaign, Illinois 61824-1550
Telephone: (217) 352-4167
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