1. CERTIFICATE OF SERVICE
      2. APPEARANCE
      3. Keller Oil Company / Sullivan Super K,
      4. PETITION FOR REVIEW OF ILLINOIS ENVIRONMENTALPROTECTION AGENCY DECISION
      5. Keller Oil Company / Sullivan Super K
      6. Springfield, illinois 62794-9276
      7. RE: LPC #1390305037—Moultrie County
      8. Dear Mr. Rothering:
    1. EXHIBIT
      1. CERTIFIED MAIL
      2. cc: CW3M CompanyDivision File
    2. EXI-HBiT
      1. 3Y:~_
      2. SPrin~~2~:~:
      3. Enclosure
      4. Springfield, illinois 62794-9276
      5. Rothering:
      1. Sincerely,
      2. RE~ LPC #1390305037—Moultrie County
    3. EXHIBIT

BEFORE THE POLLUTION CONTROL BOARD
R E
C
IE RI
~
OF THE STATE OF ILLINOIS
CLERK’S OFRCE
KELLER OIL COMPANY /
JAN
27
2C04
SULLI
VAN SUPER K,
)
STATE OF ILLINOIS
)
Pollution
Control
Board
Petitioner,
)
)
PCB04.~
____
)
(IJST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
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 January 27,
2004,
filed with the Clerk of the Illinois
Pollution
Control Board of the
State of Illinois
an original, executed copy of an Appearance and
Petition for Review ofIllinois Environmental Protection Agency Decision.
Dated:
January27, 2004
Respectfully
submitted,
Keller Oil Company / Sullivan Super
K,
By:
C~j~&~-’~
7~(LQA~-Q
One of Its At~rneys
Carolyn S. Hesse
Barnes & Thornburg
One North Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312)357-1313
202337v1
This
filing submitted
on recycled paper as defined in 35
III.
Adm. Code 101.2021

CERTIFICATE OF SERVICE
I,
on
oath
state that
I have served
the attached Appearance
and 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
27th
Day of January, 2004.
CarolynS.H
e
This
filing
submitted on
recycled paper as defined in 35
III.
Adm. Code 101.202
2

R E C E
V
CLERK’S
OFFICE
BEFORE THE POLLUTION CONTROL BOARD
JAN
2?
2~4
OF THE STATE OF ILLINOIS
STATE OF ILLINOIS
KELLER OIL COMPANY /
)
Pollution
Control Board
SULLIVAN SUPER K,
)
)
Petitioner,
)
)
v.
)
PCBO4-
I
)
(UST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
APPEARANCE
NOW
COMES
the
undersigned,
Carolyn
S.
Hesse,
and
enters
an
appearance
for
the
Petitioner, Keller Oil Company / Sullivan Super K, in the above captioned matter.
Dated:
January 27, 2004
Respectfully submitted,
Keller Oil Company / Sullivan Super K,
By:
_____________
One ofIts Atto~eys
Carolyn
S. Hesse,
Esq.
Barnes & Thomburg
One North Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312)357-1313
202335v1
lThis
filing submitted
on
recycled
paper as
defined
in 35
III. Adm.
Code 101.2021

BEFORE THE POLLUTION CONTROL BOARD
CLERK’S OFFICE
OF THE
STATE OF ILLINOIS
JAN
27
2004
KELLER OIL COMPANY /
)
STATE
OF ILU ‘1013
SULLIVAN SUPER K,
Pollution
Controi
Board
)
Petitioner,
)
)
v.
)
PCBO4-
/3
)
(UST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
PETITION FOR REVIEW OF ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY DECISION
Keller
Oil
Company
/
Sullivan
Super
K
(“Sullivan
Super
K”),
by
its
attorney,
Carolyn S. Hesse ofBarnes
&
Thornburg, 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.
Keller
Oil
Company /
Sullivan
Super K (“Petitioner”),
is
the
owner
of a
gasoline
service
station
located
104
South
Hamilton,
Sullivan,
Moultrie
County,
Illinois
(the
“Station”).
This
gasoline
service
station
had
underground storage tanks
(UST’s) on the property, which
stored gasoline
and diesel fuel.
2.
LUST
Incident
Number
992030
was
obtained
following
a
site
investigation.
The
site
has
also
been
assigned
LPC
#1390305037-
Moultrie
County.
lThis filing submitted
on
recycled paper as
defined
in 35
Ill. Adm. Code
101 .202j

3.
On June
5,
2001,
CW3M,
the
contractor
hired by
Sullivan
Super
K
to
assist
Sullivan
Super
K with
corrective
action
at
the
Station,
sent
to
the
Agency
a
Site
Investigation
Report
and
Corrective
Action
Plan
and
Budget to perform corrective action at the StatiOn.
(See
Exhibit
1.)
4.
On September 24, 2001, the Agency sent a letter to
Petitioner rejecting the
June 5, 2001, High Priority Corrective Action Plan and Budget.
The letter
included
a
list
of additional
information
requested
by
the
Agency
and
acknowledged
that
the
corrective
action
included
bioremediation.
(See
Exhibit 2.)
CW3M
provided the
additional
information requested by the
Agency on September 24, 2001
and on subsequent dates.
5.
By
letter
dated
June 7,
2002,
the
Agency
approved the
Amended
High
Priority Corrective Action Plan dated March
5,
2002,
but cut part of the
budget
for this
plan.
(See
Exhibit 3.)
On
behalf of Petitioner,
CW3M
submitted
on
July
5,
2002,
additional
information related
to
the
budget,
including
costs
for the
pilot
study
required for bioremediation
projects.
(See Exhibit 4.)
6.
On October
28,
2002,
the Agency
again requested
a
modification of the
proposed
budget
(See
Exhibit
5),
and
CW3M
provided
the
requested
information on November 22, 2002.
(See
Exhibit 6.)
7.
On February 24,
2003, the Agency approved the proposed budget subject
to
the Agency’s modifications to
the proposed budget.
(See
Exhibit 7.)
8.
By
cover
letter
dated
May
19,
2003,
CW3M
forwarded
on
behalf of
Petitioner
a
Phase
II
Corrective
Action
Plan
(CAP)
and
Budget
which
This
filing submitted
on
recycled
paper as
defined in 35
Ill. Adm. Code 101.202)
2

included
the
results
of the
in-situ
bioremediation
treatability
study
and
proposed full-scale implementation of
in-situ
bioremediation.
9.
On August
8, 2003 the Agency sent to Petitioner a letter rejecting the High
Priority
Corrective
Action
Plan.
The
letter
listed
five
questions/comments,
including
questions
about the
“exact specifications
of the
bioslurry
material,”
including
“manufacturer’s
specifications
and
amount
of oxygen
released
per
pound
of material.”
The
Agency
also
required that site names and IEPA generator numbers be provided for sites
for which
the proposed remediation
technology had
been approved.
(See
Exhibit 8.)
10.
In
response,
by
letter
dated
October
31,
2003,
CW3M,
on
behalf of
Petitioner,
provided to
the
Agency
information
relating to
the
bioslurry
material.
CW3M
also
responded
to
the
Agency’s
comments
and
provided a list of 161
site names and
generator numbers where the Agency
approved
bioremediation.
This
list
was
obtained
from
the
Agency’s
database.
(See
Exhibit 9.)
11.
On December 26, 2003,
CW3M received a letter dated December 24, 2003
rejecting the High Priority Correction Action Plan for the reason that
“the
method
of
remediation
cannot
be
approved.”
The
Agency
also
disapproved the budget to perform the work.
(See
Exhibit
10.)
12.
The
Agency’s
letter
of
December
24,
2003,
provides
no
additional
information regarding why
IEPA
disapproved
a
remediation
technology
that it had approved previously.
(This filing submitted
on
recycled paper
as defined in 35
Ill. Adm. Code
101.202(
3

13.
The Agency’s
December
24,
2003,
letter includes an
attachment labeled
appeal rights as the Agency’s decision is a final decision, appealable to the
Illinois Pollution Control Board~
14.
The
Agency
has
violated
35
Ill.
Admin.
Code
732.503(b)
because
the
Agency’s
December
24,
2003,
letter
did
not
provide Petitioner
written
notice with the following information:
(1)
An explanation of the
specific type of information,
if any,
that the Agency needs to complete the full review;
(2)
An explanation of the
Sections of the
Act
or regulations
that may be violated if the plan or report is approved; and
(3)
A statement of specific
reasons why the cited
Sections of
the Act or regulations may be
violated if the plan or report
is approved.
WHEREFORE, Keller Oil / Sullivan
Super K respectfully requests that the Board
enter an order requiring the Agency to
approve the Corrective Action Plan and Budget to
allow the
cleanup
to
proceed
at this
facility
and
for Keller
Oil
/
Sullivan
Super K’s
attorneys’ fees
and costs in bringing this appeal.
Respectfully submitted,
Keller Oil Company / Sullivan Super K
By:
~
One of Its Attor~ys
Carolyn.S.
Hesse, Esq.
Barnes & Thornburg
One North Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312) 357-1313
20233 lvi
This
filing submitted
on
recycled
paper as defined in 35
Ill. Adm. Code
101.202)
4

CViT
M
C0JJfl
ppny
701 W.
South
Grand A”e~
sPrin~~~6~
1
~
~
Environmental Consultint~Services
.
,.
June
5,
2001
Mr.
Scott
R. Rothering, Project Manager
LUST
Section,
Bureau of
Land
illinois Environmental
Protection Agency
1021
North
Grand
Avenue East
-
Springfield,
illinois
62794-9276
RE:
LPC #1390305037—Moultrie County
L.. Keller Oil
Properties,
Iuc./Snllivan Super K
104 South
ThLmiItofl
Incident
Number 99-2030
LUST
Technical
File—Site In!vestigation
Report
and Corrective Action Plan
Dear Mr. Rothering:
Enclosed, please find the Site Investigation Report
arid Corrective Action Plan arid
Budget for the
L. Keller Oil Properties,
Inc./Sullivan Super K,
located in Sullivan,
Illinois.
If you bave any
questions
or
require additional
information,
please
contact
Vince
E.
Smith or me at 217/522-8001.
Sincerely,
Carol
L.
Rowe, P.G.
Senior Environmental
Geologist
Enclosure
xc:
Mr.
Charles F.
Keller,
L. Keller Oil Properties,
Inc.
Mr.
WillIam
T.
Sinnott,
CWM Company, Inc.
1C99-2030/CAP\CAPcI
EXHIBIT
.0
.0
15

ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
217/782-6762
1021
NORTH GRAND AvEt.~uEEAST,
P.O.
Box
19276,
SPRINGFIELD.
ILLINOIS
62794-9276
~EP2 ~
2flfl’
L. Keller Oil
Companies
Attention:
Joe
Henry
#4
Avenue.of
Mid-America
Effinghain, IL
61920
Re:
LPC
#
1390305037
Moultrie
County
L. Keller Oil
Properties,
Inc. /
Sullivan SuperK
104 South Hamilton
LUST Incident No. 992030
LUST Technical File
DearMr.Heniy:
CERTIFIED MAIL
L~4~
7~~-7-~S
•...•~:
~
/~‘
~
The Illinois EnvIronmental Protection Agency (Illinois EPA)
has reviewed the High Priority
Corrective Action Plan and Budget submitted
for
the above-referenced incident.
This
information, dated June
5,
2001, was received by the Illinois EPA on June 7, 2001
Citations in
this
letter are
from the Environmental Protection Act (Act) and
35 Illinois
Administrative Code
(35
IAC).
Pursuant
to
35
IA~
Section
732.405(c)
and SectIon
57.7(c)(4)(D)
of the Act, the
High Priority
Corrective Action Plan is
rejected for the reasons listed in Attachment A.
Pursuant
to
35
IAC Sections 732.405(e)
and 732.503(b) and Sections 57.7(a)(1) and
57.7(c)(4)(D)
of the Act, the associated budget is rejected for the following reason(s):
The budget must be associated with an
approved plan.
Pursuant to
35
IAC Section 732.401, the
Illinois EPA requires
a revised High Priority Corrective
Action Plan and
budget if applicable be submitted
within
days
of
the
date of
this letter to:
Illinois Environmental Protection Agency
Bureau ofLand
-
#24
LUST Section
1021
North Grand Avenue
East
Post Office Box
19276
Springfield, Illinois
62794-9276
_________________
LBJ

Please submit all correspondence in duplicate and
include the “Re:”
block at the beginning ofthis
letter.
Within
35
days afterthe date ofmailing ofthis final decision, the owner or operator maypetition
for a hearing before the Illinois Pollution control Board (Board) to contest the decision ofthe
Illinois EPA.
(For information regarding the filing ofan appeal, please contactthe Board at
312/814-3620.)
However, the 35-day period for petitioning for a hearing may be
extended for a
period of time not to exceed 90 days by written notice provided to the Board from the owner or
operator and the Illinois EPA within the 35-day initial appeal period.
(For information regarding
the filing ofan extension, please contact the Illinois EPA’s Division ofLegal Counsel
at 217/782-
5544~)
If you have any
questions or need
further information, please contact
Scott
Rothering
at 2 17-785-
1858.
Sincerely,
Ct,$~’~
Clifford L.
Wheeler
Unit Manager
Leaking
Underground Storage
Tank Section
Division of
Remediation
Management
Bureau of
Land
Attachments. (1)
cc:
CW3M Company
Division File

ATTACHMENT A
Re:
LPC
#1390305037
-
Moultrie County
SullivanlSullivan
Super
K
104 South Hamilton
LUST Incideni No. 992030
LUST Technical File
NOTE:
Citations in this
Attachment are from the Illinois Environmental Protection Act (Act) and
35
illinois Administrative Code
(35
IAC).
1)
Prior to
the approval ofa Corrective Action Plan utilizing bioremediation, a pilot or
biofeasibility study must be performed.
This site specific study must include research or
sampling which evaluates the following:
A)
Soil types that occur within the
contaminated
aquifer.
B)
Hydraulic Conductivity within the contaminated aquifer.
C)
Dissolved Iron Concentrations within the contarnixiated aquifer.
D)
PH ofgroundwater within the coniaminated aquifer.
E)
Groundwater temperature within the contaminated aquifer.
F)
Background aerobic and heterotrophic bacteria
counts
within the contaminated
aquifer.
G)
Groundwater mineral content within the contaminated aquifer.
H)
Available concentrations ofammonia and nitrogen in the aquifer within the
contaminated aquifer.
I)
Argument
supporting
the biodegradability ofthe indicator contaminants within
the contaminated aquifer.
J)
Calculations
and testing which prove the amount of groundwater affected by
the
contamination.
K)
Design area
of
influence which
is an estimate of the
volume/area
ofaquifer to
which
an adequate
amount ofelectron acceptor and nutrient can
be supplied to
sustain microbial
activity.
Additionally, the
design radius of influence must be
shown for the site.
Together, these determine the practicality of the design.
(V~b

O
iLLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
1021
NogTH
GRAND AVENUE
EAST.
P.O.
Box
19276,
SPRINGFIELD.
tiii~Oii
627g4~g27b
RENEE
CIPRIANO,
DIRECTOR
217/782-6762
.
CERTIFIED
MAIL
~o\
;~s~o
-
ooo?~-~Bk-
‘~J11
JUN~7~OO’L
Keller Oil Company
.
-
Attention:
Joe
Henry
/
RECEI\TEI)
PD Box 70
1
JUN
s
2002
Effingham, Illinois
62401
/
Re:
LPC #1390305037
--
Moultrie County
Sullivan/Keller Oil Company
104 South Hamilton
LUST Incident No. 992030
LUST Technical File
Dear
Mr.
Henry:
The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the Amended High
Priority Corrective Action Plan (plan) (Bioremediation Feasibility Study)
submitted forthe
above-referenced incident.
This.plan,
dated March
5,
2002, was received by the Illinois EPA on
March 6, 2002.
Citations
in this letter are from the Environmental Protection
Act (Act)
and
35
Illinois Administrative
Code
(35
IAC).
.
.
Pursuant to
35
TAC Section 732 405(c) and
Section
57 7(c)(4) of
the Act, the
plan
is approved
The activities, proposed in the plan are appropriate to
demonstrate compliance with
35
lAO Part
732 and
Title XVI ofthe Act
Please note that all activities associated with the reme-dration 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 Illinois EPA is modifying the proposed budget forthe High Priority Corrective
Action Plan pursuant to
35
JAC
Section 732A05(c) and Section
57.7(c)(4)
of the Act.
Based. on
the modifications listed
in Section
2 ofAttachment A, the amounts listed
in
Section
1 of
Attachment A have been 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
35
IAC
Sections 732.604,
732.606(s),
and 732.611
as
well as Sections
57.8(e), 57.8(g)
and
57.8(d)
ofthe
Act.
EXI-HBiT
GEORGE
H.
RYAN,
GOVERNOR
.
.
-

Page 2
All future correspondence must be
submitted to:
Illinois Environmental
Protection Agency
Bureau ofLand
-
#24
LUST
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 ofthis letter.
An underground storage tank owner or operator may appeal this final decision to the Illinois
Pollution Control Board (Board) pursuant to
Section
57.7(c)(4)(D)
and Section 40 ofthe Act by
filing a petition for a hearing within
35
days after the date ofissuance ofthe final decision.
However, the 35-day period may be extended for a period oftime not to exceed 90 days by
written notice from the owner or operator and the.Illinois EPA within the initial
35-day appeal
period.
Ifthe owner or operator wishes to
receive a 90-day extension, a written request that
includes a statement ofthe date the fixial decision was received, along with a copy ofthis
decision, must be sent to the Illinois EPA as soon as possible.
For information regarding the filing ofan
appeal, please contact:
Dorothy
Gunn, Clerk
Illinois Pollution Control Board
State ofIllinois
Center
100 West Randolph, Suite 11-500
Chicago, IL
60601
312/814-3620
For information regarding the filing ofan extension, please contact:
Illinois Environmental Protection Agency
Division ofLegal Counsel
1021
North Grand Avenue East
Springfield, IL
62794-9276
2171782-5544

~cEiVEI5
Page3
JUN
82002
3Y:~_
If you have any questions or need further assistance, please contact Scott Rotheririg at 21
7-785-
1858.
Sincerely,
;~
~&
Clifford L. Wheeler
Unit Manager
Leaking Underground Storage Tank Section
Division ofRemediation Management
Bureau of
Land
CLW:SRR\992030HPCAP
Phase
1
Attachment;
Attachment A
cc:
CW3Company
Division File

Attachment A
Re:
LPC
#
1390305037— Moultrie County
SullivanlKeller Oil Company
104 South Hamilton
LUST Incident No. 992030
LUST Technical File
NOTE:
Citations
in this attachment are from the Environmental Protection Act (Act) and 35
Illinois Administrative
Code (35 IAC).
SECTION
1
The budget was previously approved for:
$6,615.00
Investigation Costs
$2,200.00
Analysis Costs
$0.00
Personnel Costs
$656.50
Equipment Costs
$0.00
Field Purchases and
Other Costs
$984.50
Handling Charges
The following amounts have been approved:
$4,185.00
Investigation Costs
$0.00
Analysis Costs
$2,506.00
Personnel Costs
$0.00
Equipment Costs
$1,338.98
Field Purchases and
Other Costs
$588.96
Handling
Charges
Therefore, the total cumulative budget is approved for:
$10,800.00
Iiivestigation Costs
$2,200.00
Analysis Costs
$2,506.00
Personnel Costs
$656.50
Equipment Costs
$1,338.98
Field Purchases and
Other Costs
$1,573.46
Handling Charges

SECTION 2
JUN
82002
Investi~ation
_____
Amount Cut:
$2000
Monitoring Well Installation Time
Analysis
Amount Cut:
$3500.00
Microbial Degredation laboratory costs
These charges must be
certified by laboratory prior to budget approval.
Personnel
Amount Cut:
$21,842.50
$15,591.50
Investigation and CAP
Development Charges
These costs must be broken out in specific tasks performed and time spent.
This
must be completed on Agency forms.
$6,128.00
-~
Reimbursement
These costs must be
broken out
ifl
specific tasks performed and time
spent.
This
must
be completed on Agency forms.
$45.00
excessive hourly charges Environmental Engineer (bioremediation pilot
study)
$60.00
excessive hourly charges
Environmental Engineer (bioremediation pilot
study)
$18.00
excessive hourly charges Engineering Technician (bioremediation pilot
study)
Equipment
Amount Cut
-
$0.00
Field Purchases and
Other Costs
Amount Cut:
$14.28
excessive costs, per mile rate
$12.24— Investigation & CAP Development
$
2.04
Bioremedjatjon Pilot Study
Handling Charges
Amount Cut:
$3500.00
previous cut for lab samples.
Deducted from amount eligible
for handling charges.
SRR\992030 budget amendment
1

(~
4~’~1
\‘l
Cpni.pgny
.
.
701
W.
South
GrHnd Ave.
SPrin~~2~:~
:
I
Environmental Consulting Services
.
..
.
July
5,
2002
Mr. Scott R.
Rothenng,
Project Manager
LUST
Section, Bureau of Land
Illinois Environmental Protection Agency
1021
North Grand
Avenue East
Springfield,
Illinois
62794-9276
RE:
LPC #1390305037—Moultrie County
L. Keller Oil Properties, Inc./Sullivan Super K
104
South Hawilton
Incident Number 99-2030
LUST Technical File—Corrective Action Plan Budget Amendment
Dear Mr. Rothering:
Enclosed, please find a Corrective Action Plan Budget Amendment (CAP) for the L.
Keller Oil
Properties, Inc.fSullivan Super K,
located in Sullivan,
Illinois.
In response to your June 7,
2002 letter modifying the CAP budget, we have included
a
breakdown of the $21,719.50
cut from personnel.
The specific hours and tasks
for
investigation
and reimbursement preparation are included
in the “Investigation”
and
“Reporting” spreadsheets which follow
the
IEPA
forms
in the budget section.
The
investigation hours include field preparation, drilling plans,
utility locations,
mapping,
drilling, sampling,
surveying and obtaining
off-site access.
The other item included in
the budget is the estimated cost ofthe microbial degredation pilot
study.
Although the
letter requests certified costs
from a laboratory,
this
is not practical,
since the costs
incurred depend upon the results of the testing.
Ifadditional testing
is
needed, the
laboratory costs increase.
The $3,500 budgeted is a reasonable estimate of what the
testing could be.
We have included,
as Attachment
B,
a copy of the most recent price
schedule from Microbe Inotech Laboratories which
includes the rate of $1,620.00 for
an
aerobic bioremediatiori pilot study with nutrient chemistries.
At this
time,
that
is
also what is included as a budget number.
However, if the indigenous bacteria are
found to be inadequate, or the chemistry is
found to be
out of range,
a budget
amendment will be necessary to retest the samples using foreign bacteria or to
adjust
the nutrient levels.
The unit rates for the Environmental Engineer and
the-Engineering Technician have
been changed to reflect the rates used in the June 7,
2002 letter.
Depending upon
the
EXHIBIT
L~\

I
results of the treatabiity
study,
a CAP will be prepared to implement bioremediatiori,
or proposing soil
excavation and
groundwater treatment.
If you have
any questions or require additional information, please contact Vince E.
Smith or me at 217/522-8001.
Sincerely,
Carol
L. Rowe, P.G.
Senior Environmental
Geologist
Enclosure
xc:
Mr.
Charles F. Keller,
L.
Keller
Oil Properties, Inc.
Mr. William T.
Sinnott,
CWM
Company,
Inc.
K99-2O3Q/CAP\CAPBA2\CAP~1

,
tLLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
1021
NORTH
GRAr~D
AvENUR
EAST,
P.O.
BoX
19276,
SPRINGHELD,
ILLINOIS
627949276
JAMES
R.
ThOMPSON CENTER,
100
WEST
RANDOLPH,
SurrE
11-300,
CHIcAGo,
IL 60601
GEORGE
H
RYAN,
GOVERNOR
RENEE
CIPRIANO,
DRECTOR
217/782-6762
CERTIFIED MAIL
OCT
28
2U02
.
q~3~-~q
-~az.-S~k
Keller Oil Company
____
Attention:
Joe Henry
~~C.EIVED
POBox7O
.
.
OCT
2
9
2002
Effingham, Ilirnois
62401.
Re:
LPC #1390305037
--
Moultrie County
Sul1ivar~JKelle;
Oil Company
104 South Hamilton
LUST Incident No. 992030
LUST Technical File.
Dear Mr. Henry:
The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the High Priority
Corrective Action Plan Budget (bddget) submitted forthe above-referenced incident.
This
budget, dated July 5, 2002, was received by the Illinois EPA on July
5,
2002.
Citations in this
letter are from the Environmental Protection Act (Act) and 35
Illinois Administrative Code
(35
Ill. Adm.
Code).
The Illinois EPA is modifying the proposed budget pursuant to Section
57.7(c)(4)
of the Act and
35 Ill
Adm
Code 732
405(c)
Based on the modifications listed m Section
2 ofAttachment A,
the amounts listed in Section
1. of Attachment A have been,approved.
Please note that the costs
must be incurred in accordance with the approved plan
Be aware that the amount of
reimbursement’may be limited by Sections
57.8(e), 57.8(g)
and 57.8(d) ofthe Act, as well as
35
Ill. Adm.
Code 732.604, 732.606(s), and 732.611.
All ii.iture 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
ofthis letter.
-
Rooz~ow
4302 Norh Main
Street,
Rock~ord,
IL 61103—1815) 987.7404
D~
P
AINES
931
1
W. Harrison St.,
Des
Flames,
1L 60016—1847) 294-4073
ELGIN
595
South State,
Elgirt
60123
(847)
608.3131
PEORIA
5414N~
University
St.,
Peoria. IL 61614
—(309) 693-5462
CHN-IPAICN
2125
South First
Srreet. Champaign. II
61 620
—.1217) 333-6907
SP~INCflELD—45005.
Sixth
Street Rd., Springfield,
IL 62706— (217) 786-6892
COLLINSVIUE
2009
MaIl Street, Collinsville,
IL 62234
—(618) 346-51 20
MARION
2309 W. Main St.,
Suite
116. Marion, IL 62959 —(618) 993-7200
PRINTED ON
RECYCLED
PAPER

Page 2
OCT
292002
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)(D) ofthe Act by filing a petition
for a hearing within 35 days after the date of issuance ofthe final decision.
However, the 35-day
period may be exteuded for a period oftime not to exceed 90 days by
written notice from the
owner or operator and
the Illinois EPA
within the initial 35-day appeal period. Ifthe owner or
operator wishes to receive a 90-day extension, a written request that includes a statement ofthe
date the final decisionwas received, along with a copy ofthi.s decision, must be sent to the
Illinois EPA as soon as possible.
For information regarding the filing ofan appeal, please contact:
Dorothy
Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 WestRandolph, Suite 11-500
Chicago, XL
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
62 794-9276
217/782-5544

Page 3
,
~~PJED
001292002
Ifyou have any questions or need further assistance, please contact Scott Rothering
at 2l7~785-
1858.
Sincerely,
~
,~
~
Clifford L.
Wheeler
Unit
Manager
Leaking Underground Storage Tank Sectio~
Division of Remediation Management
Bureau of Land
CLW; SRR\992030
Attachment:
Attachment A
cc:
CW3M
Company
Division File

$0.00’
investigatIon Costs
$1,620.00
Analysis Costs
$220.25
Personnel Costs
$0.00
Equipment Costs
$0.00
Field Purchases and Other Costs
$194.40
r
Handling Charges
Therefore, the total cumulative budget is approved
for:
$10,800.00
Investigation Costs
$3,820.00
Analysis Costs
$2,726.25
Personnel costs
$656.50
Equipment Costs
$1,338.98
Field Purchases and Other Costs
$1,767.86
Handling Charges
ROCKF0W
4302 Norh Main Street.
Rock(ord.
IL
61103—
(815)
987-7404
DES
PLAINt,
9511
W. Harrison
St..
Des
Plaines.
IL
60016— (847) 294-4073
ELoN—595 SouthState.
Ejgin 60123—1847)608-3131
PcoR,A—5414 N.
UrtiversirySt.. Peoria, IL
61614—1309) 693-5462
CHAMpAIGN
—2125
South First Street,
Champaign, IL 61820—1217) 333-6907
SPRIN~PIELD
4500 S. Sixth
Street
Rd.,
Springfield,
IL 62706—1217
786-6892
CO11IP~svlLLE—2009
MalI Street, Coilinsvmlle.
1162234— (618) 346-5120
MMEION —2309W. Main
Sr.,
Suite
116, Marion,
IL
62959— (618) 993-7200
rr~
~

.TR~,CTJIVEil..)
001
2
9
2002
Section 2
BY:
Cuts from Budget Amendments
$20,649.00
Personnel Costs.
These costs must be
listed separately for each task.
The costs
which are listed for individual tasks have been approved.
SRR\99203Oh.pbudarnen2

701
W. Sooth
Grind
Ave.
_____
Sprin2fleld,
IL
62704
CW
M Comnanv
Environmental Consu1tin~Services
.
-
November 22,
2002
Mr.
Scott
R. Rothering,
Project
Manager
LUST Section, Bureau of Land
Illinois
Environmental
Protection Agency
1021
North
Grand Avenue East
Springfield,
illinois
62794-9276
RE:
LPC#1390305037—Moujtrie
County
L.
Keller Oil
Properties,
Inc./Sullivan Super K
104 South
Hamilton
Incident Number 99-2030
LUST
Technical
File—Corrective Action Plan
Budget Amendment
Dear Mr.
Rothering:
Enclosed, please find a Corrective Action Plan Budget Amendment (CAP) for the L.
Keller Oil
Properties,
Inc. /Sullivan Super K,
located
in Sullivan,
Illinois.
In response to your October 28,
2002 letter modifying the
CAP budget,
we have
included a breakdown of the personnel items.
The letter did not
specify which item or
items
went into the $220.25 which
was approved, ‘but it is
assumed that 0.25 hours for
Environmental Project Geologist
drilling plans,:and the 5.0 hours for Project
Manager
reimbursement claim review were
approved.
The specific hours
and tasks
for investigation
and reimbursement preparation are included in the JEPA
forms in the
budget section.
If you have
any questions or require additional information,
please contact me at
217/522-8001.
Sincerely,
VmceE. Smith,P.E.
Senior
Environmental Engineer
Enclosure
xc:
Mr.
Charles F.
Keller,
L. Keller Oil Properties,
Inc.
Mr.
William T.
Sinnott,
CW3M Company,
Inc.
EXHIBIT
O
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
1021
NORTH
GRAND AvENUE
EAST,
P.O.
Box
19276,
SPRINGFIELD,
ILLINOIS
62794-9276
JAMES
R.
TI-ioMPSoN
CENTER,
100 WEST
RA?’~DOLPH,
SuITE
11-300,
CHICAGo,
IL
60601
2171782-6752
Roo
R.
BLACO)EVICH,
GOVERNOR
RENEE
C,1~i?Fi~DA~IL
7002
2030
0001
187~
U~4~
FEB2~zoO3
Keller Oil Company
Attention:
Joe Henry
-
FEB
~ 6
POBox7O
Effingham, Illinois
62401
Re:
LPC
#1390305037
Moultrie
County
Sullivan/Keller Oil Company
‘104 South Namilton
LUST Incident No.
992030
LUST Technical
File
Dear Mr. Henry:
The Illinois Environmental Protection Agency (Illinois
EPA)
has reviewed the amended High Priority Work
Plan Budget (budget) submitted for the above-referenced incident.
This
budget, dated November 22, 2002,
was received by
the Illinois EPA on November 26, 2002.
Citations in this letter are from the
Environmental Protection Act (Act)
and
35
Jjjjnojs Administrative Code
(35
IAC).
The Illinois EPA is
modifying
the
proposed budget
(35
LAC
Section
732.305(c)
or
732.312(j) and Section
57.7(a)(1)
ofthe
Act).
Based
on
the modifications listed
in
Section
2
of Attachment
A.
the amounts listed
in Section
ofAttachment
A have been approved
Please note
that the costs must be incurred in
accordance with the illinois EPA approved
plan.
Be
aware
that the
amount ofreimbursement may be
limited
by
35
IAC
Sections 732.604,
732.606(s), and 732.611
as well as Sections
57.8(e), 57.8(g),
and
57.8(d) ofthe Act.
Pursuant
to 35 IAC Section
732.301
the Illinois EPA is
requiring a
Site
Classification
Completion Report
be submitted
within
90 days of the date of
this letter to:
Illinois Environmental Protection Agency
Bureau ofLand
-
#24
LUST
Section
1021 North Grand Avenue East
Post Office Box
19276
Springfield, IL
62794-9276
Please submit
all
correspondence
in duplicate
and include the
“Ret”
block shown
at the beginning ofthis
letter.
ROcEFORD
—4302
North
Main
Street,
Rockford,
Ii.
61103
—.(8151 987-7760
DES
PLA!NES
9511
W. Harrison St.,
Des
Plairies,
IL
60016
(1347)
294-4000
ELCIN— 59S
Souch SEate,
EIglr~IL 60123
—(547) 605-3131
PEORIA —‘5415
N.
Urti~ersity
Sr..
Peoria, IL 61614
309) 693-5463
SuREAu or LAND
-
PEORIA
7620 N.
University St..
Peoria,
IL
61614— (309) 693-5462
C1’IAMPAICN
—2125
South First
StrQet,
Champaign.
IL
61820
—(217) 278-5800
SPRlNC~lELD
4500 S. Sixth Sireet Rd., Springlield,
IL
62706— (2171
786-6892
CCWNSVILLE
2009
MalI
SEreeL Collirisville. It.
62234
1615)
34F~1 ~fl
MARI0N—2309
W.
Main
St., Sui~e116,
Marion,
IL 62959—1618)
993-7200
EXHIBIT
PRIN1-CD
ON
RECYCLED
PAPER

Page2
An underground storage tank
owner or operatormay appeal this final decision to the Illinois
Pollution
Control Board (Board) pursuant to Section 57.7(c)(4)(D) and Section 40 ofthe
Act by filing a
petition for a
hearing
within
35
days after
the date of issuance ofthe final decision.
However,
the 35~day
period
may be
extended for a period oftime not to exceed 90
days
by
written notice from the
owneror operatorand 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 irifonnation 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, IL
60601
312/814-3620
For information regarding the filing of an
extension,
please contact:
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
Springfield,
IL
62794-9276
2171782-5544
Ifyou have any questions orneed
further
assistance, please contact Scott Rothering at 217-785-1858.
Sincerely,
C~4~/
~z
tJ~4
Clifford L.
Wheeler
UnitManager
Leaking Underground Storage Tank Section
Division of Remediation Management
Bureau of
Land
CLW:SRR\992030amcap2
Attachment:
AttachmentA
cc:
CW3’M Company
Division
File

Attachment A
Re:
LPC # 1390305037
--
Moultrie County
Sullivan/Keller Oil Company
104 South Hamilton
LUST Incident No. 992030
LUST Technical File
t~
701fl
NOTE:
Citations in this attachment
are from
35
Illinois Administrative
Code
(35
IAC) and the
Environmental Protection Act.
SECTION
1
The budget
was
previously approved for:
$10,800.00
$2,200.00
$2,50600
$656.50
$1,338.98
$1,573.46
Investigation Costs
Analysis
Costs
Personnel Costs
Equipment Costs
Field Purchases and Other Costs
Handling Charges
The following amounts have been approved:
$0.00
$0.00
$14,917.50
$0.00
$0.00
so
Investigation Costs
Analysis Costs
Personnel Costs
Equipment Costs
Field Purchases and Other Costs
Handling Charges
Therefore, the total cumulative budget is
approved for:
$10,800.00
$2,200.00
$17,423.50
$656.3
$1,338.98
$1,573.46
Investigation
Costs
Analysis
Costs
Personnel
Costs
Equipment Costs
Field Purchases and Other Costs
Handling Charges

FEB267nO3
-
$ection
2
$3,722.50
CAP
Development, CAP Design, CAP Review costs;these costs are not
reimbursable until the entire CAP is proposed (with results from pilot study).
$2449.00
Reimbursement.Preparation, exceeds allowable costs
SRR\992030atta

e
iLLINOIS
ENVIRONMENTAL
PROTECTION AGENCY
1021
NORTH
GRAND AVENUE EAST,
P.O. 8o~
79276,
5PR11’JGFIELD,
LLINOIS
62794-9276. 217-782-3397
JAMES
R.
THOMPSON
CENTER.
100
WEST
RANDOLPH,
SUITE
11-300,
CHIcAC0,
IL 60601, 312-814-6026
ROD
R.
BLACOJEVICH,
GOVERNOR
RENEE
CIPRIANO,
DIRECTOR
2171782-6762
CERTIFIED MAIL
7002
3i~U 0000
~224
~?73
AUG
(38
2003
MIfl~
9
~OD3
~Keller
Oil Company
Attention:
Charles F. Keller
-
P0 Box 70
Effinghaxn, Illinois
62401
Re:
LPC #1390305037
--
Moultrie
County
SullivanlSüllivan Super K
104 South Hamilton
LUST Incident No. 992030
LUST Technica~File
Dear Mr. Keller:
-
The Illinois Environmental Protection Agency (illinois EPA) has
reviewed
he
High Priority
Corrective Action Plan (plan)
submitted for the above-referenced incident.
This information,
dated May 2003, was
received
by the Illinois EPA on May
19,
2003.
Citations in this letter are
from the Environmental Protection Act
(Act) and 35 Illinois Administrative Code
(35
Ill.
Adm.
Code).
Pursuant
to Section
57.7(c)(4)(D)
ofthe Act and
35
111. Adin.
Code
732.405(c),
the High Priority
Corrective Action Plan is rejected for the following reason(s):
1.
Exact
cpecificadcns of the
bioslurry material must be provided prior to
approval of the
Corrective Action Plan.
This
must include
manufacturer’s specifications and
amount of
oxygen released perpound of
material.
2.
Site names and IEPA Generator numbers must be provided for which the proposed
remediation technology has
been approved.
3.
Completion
report well diagrams indicate groundwater is located greater than
twenty feet
below grade.
However, the proposed delivery system delivers water at ten feet below
grade.
It is not apparent that the bioslurry will enter the groundwater sufficiently to
provide bioremediarion.
4.
The extent of contamination
does not
appear to be defined to the South.
Roc,c,oeo— 4302 North Main Street,
Rockford,
II. 61703— (815) 987-7760
Dts
PLAINES
.‘.
9511
W.
Harrizori
51,,
De~
PIairie~,IL 60016
~847)
294-4000
ELCIN -.595 South Staie.
EIgin,
IL 60123—1847) 608-3131
Pto~A
5415
N. Unkversi&y
St.,
Peoria,
It.
61614
(309) 693-5463
BUREAU
QF
L~o
-
Ptoa~
7620 N.
University Si.. Peoria, IL 61614 —1309) 693-5462
CAu~
2125 South
First Street, ChampaiRn
IL 6)820 —1217)
278-5800
SPRNcpIcLo
4500 5
Sixlh
Strect
Rd.. Springfield,
IL
62706
—(2171 786-6692
COLUNsvULLE
2009 MalI Street, CoIIin~vitIe,IL 62234
(618) J46~,i~
MARION
2309
W.
Main St.,
5uite
116, Marion, IL 62959
—(618) 993-7200
EXHIBIT
PRINT?O
ON
RRCYCL?D
PAPER

Page 2
5.
A monitoring well must be
placed to the West directly across Hamilton Street from the
tankbed to ensure contamination
is not being pushed off site.
Pursuant to Sections 57.7(a)(1) and 57.7(c)(4)(D) of the Act and
35
111. Adm.
Code
732.405(e)
and
732.503(b),
the associated budgetis rejected for the following reason(s):
The budget is not associated
with an approved plan.
Pursuant
to 35
Ill. Adm. Code 732.401, the Illinois EPA requires submittal of a revised High
Priority Corrective Action Plan,
and budget
if applicable, within
90 days of the date of this letter
to:
Illinois Errvironmental Protection
Agency
Bureau ofLand
-
#24
Leaking
Underground Storage Tank Section
1021
North Grand Avenue East
Post Office Box
19276
Springfield,
IL
62794-9276
Please submitall correspondence in duplicate and include the Re: block shown at the
beginning
of this letter.
An underground storage tank system owner or operator may appeal this decision to the Illinois
Pollution Control
Board.
Appeal rights
are attached,
If you have any questions or need further information, please contact Scott Rothering at 2 17-785-
1858.
Sincerely,
Clifford L. Wheeler
Unit Manager
Leaking
Underground Storage
Tank Section
Division of Reirtediation Management
Bureau of
Land
CLW:SRR\992030hapcaphase2den
C:
CW~MCompany
Division File

1
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)(D) of the
Act by filing apetition_
for a hearing within 35
days after the date of issuance of the final decision.
However, the 35-day
period may be extended for a period oftime not to exceed 90 days by written notice from the
owner or operator and the IlljnoisEPA within the
initial 35-day appeal period.
Ifthe 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
flhinois EPA
as sdon as possible.
For information regarding the filing ofan
appeal,
please contact:
Dorothy Gunn, Clerk
AUf
~1
~UO3
Illinois Pollution Control Board
State
ofillinois Center
100 West Randolph, Suite
11-500
Chicago,
IL
60601
312/814-3620
Forinformation regarding the
filing of an
extension, please contact;
illinois Environmental Protection Agency
Division
of
Legal
Counsel
1021 North Grand Avenue East
Post Office Box
19276
Springfield,
IL
62794-9276
217/782-5544

CW~M
Company
Environmental Consulting
Services
October 31,
2003
Mr. Scott R. Rotheriug,
Project
Manager
LUST
Section, Bureau of Land
Illinois
Environmental Protection Agency
1021
North Grand Avenue East
Springfield, Illinois
62794-9276
•• •
-
.
RE~
LPC #1390305037—Moultrie
County
L.
Keller
Oil Properties,
Inc./Sullivan
Super K
104 South Hamilton
-
Incident Number 99-2030
LUST
Technical
File—Corrective Action Plan Phase II
Dear Mr.
Rothering:
In response to your August
8,
2003 letter rejecting the Phase II Corrective Action
Plan
(CAP)
and Budget submitted May
19,
2003,
CW3M
is, providing the following
information and requesting a reconsideration of the rejection
Responses
to the
individual, items listed in the letter are addressed below.
Item
1.
Exact specifications for the bioslurry materials needed are not known, as each
injection batch will be unique.
The materials that will be or may be
used are listed
in
Section 6.1.3 of the CAP,
CW3M will design,
then either purchase or prepare each
batch individually,
depending upon the site
conditions determined from the previous
analytical data and past experience with the site.
As we have attempted to
explain in our previous
submittals,
the proposed technology
does
not
rely on oxygen,
which is
extremely difficult to produce and control throughout
the vadose and
saturated zones.
The proposed technology
uses the
same principle
as
oxygen
injection, but insteadrelies on controlling the carbon:
nitrogen:
phosphorous
ratio to
achieve the same results.
Although not
considered In the mix formulation as
an
active ingredient, the dissolved
oxygen content
iii fully-aerated 210
Celsius
water is
approximately 9.0 mg/L,
which
is equal
to
approximately 0.008 pounds of available
oxygen per pound of slurry.
Item 2.
The following
is
a list of
161
site names
and generator
numbers
where
the
Agency
has listed bioremediation in the alternative t~chnologycategory,
as obtained
from
the Agency’s LIT Database:
EXHIBIT

:
•~
~
-
SLID
Borden Chemical
j
N.A.?~
-
~k0Pi05
Ext.,
Inc.
~0311985184
Piasa
Motor Fuels
Jii 90455012
~Kosarek
Construction
~1194285028
Lloyd Weimann ice &
Fuel
‘1194285028
f~neseo
Shop
N Go
j0730500004
Harper Oil Ca.
10990855018
MartIn
CU
0310355018
ValleyView School
Ji
97090
5034
Harper
Oil Co.
-
0210600010
Martin
Service
Station
#121
10310035064
Harper Oil Co.
10490250013
Suburban
-
Moving & Storage
10314975126
CaldweH
Engineering Co.
11370200036
Pepsi Cola
Bottling
Co.
--
1:190105023
Etna Oil Co.
0990855039
Martin Oil
0310455088
Wareco Service inc.
0770150010
Interstate
Brands Inc.
137020002.1
Rockford Newspapers
Inc.
2010305078
Demsey Dodge
Chrysler
Plymouth
1050255007
Celozzi Eftieson Chevy
0430355017
Mobil Oil #O5AIQ
0312645015
Illinois Bell Telephone
-~
0190105067
Delta Sonic Car Wash
0314915036
Turtle Wax’ Car Wash
0971155061
Hahriaman Albrecht Inc.
‘1030305002
Kerr McGee SeMce Station
1470355011
Williamson County Airport
1990555032
Sycamore High School
-
0370555030
Contel
1890200002
Ubertyvllle Lincoln Mercury
0970905023
Larry’s
24 Hours
Gas
0971900044
Pluskota Electic Co.
Houff
&
Co.
0313365016
0430150002
Cave Auto Care Ctr.
0430600018
Busse Car Wash
0311980007
Williams, Forest
0972005023
Kinnamon Service Station
0570600002
Scotties
:10310570014
JM~ncarrs
Chry~Ier
Plymouth Inc.
10312220011
~moco Oil Co. #6470
10312665155

~‘:BLI
Raymond Truck Plaza
091 0550033
Carpentersvilie, Village of
0890205025
lfllnois Ayers
West Frankfort Interstate Shell
1671205208
~J0550705003
Burwell
CU Service
--
1794730005
Carpentersville, Village of
0890205025
Saul Rosen
Buick Mazda Honda
0971905069
MullerPinehurst Dairy Inc.
2010305437
illinois Road
Inc.
1370205041
SSCI Joint Venture
-
0316585036
Sugar Grove,
Village of
0890855004
Niantic Oil Co.
-.
1:150405002
Delta Sonic CarWash
0314915036
Illinois Central College
USI
Division-Tuscola Plant
.~
1790200023
j~i
8080002
Santa Fe Railway
0994905029
Wilson Sporting Goods
0312645006
Federated Paint Mfg.
0316005311
Lloyd Weimann
Ice
& Fuel
1194285028
Hicks
Bulk Dist.
Co.
0770155030
Granite
City, City of
1190405088
Granite City, City of
1190405067
Amoco
Oil #15116
-
~370105074
Pleasantview Fire Protection
--
0314195013
NokornisC.U.S.D. #12
1350455009
Tom
Todd Chevy
0314975054
~.D.
Petroleum
‘1971105021
Mercantile Bank per Rep. Guclder
1830455077
Emro Unit #7547
0770155022
Pickens Mobil
1950305017
Fruitbelt Service Co.
11270155011
IWaroco Service Inc.
l199040501~
Clerk Oil
& Refining
10312885197
fGriffith Labs USA
0310035911
Southwestern
Electric Coop
10050055003
Martin
Oil
J0314975129
JGr~hamCli Co.
0312883006
Stoner Ca.
0316225065
lpeoria Disposal
Co.
1430653007
Elgin, City of
los943eoo~
~MunieGarage
-
•j163110
J~7andeJia.City of
10510355024,
ISauk Valley Comm. College
~i0302O3~p~j

~‘
~
:‘,~Ag~
~
BLJDH~
E.A.
Raasch
Inc.
0971155095
IRoberts, Gemon
0190605002
fBeck Oil Co.
Mickeys
Tire
0110855036
1970455218
Illinois
Bell Telephone
1610455093
billow Brother
Service
-
1190555034
jAyerco 28 Super Center
11671205335
Clark Oil & Refining
I18309559~
Box Form
10316115055
JTrinity Motors Inc.
10210605027
Butler Mfg.
0950200009
KornerQuik Stop
Inc.
10010055007
Cooper Oil Co.
0770155046
Illinois State Toll Hwy. Authority
10310030024
Grave Mill. Garage
0430755009
Cooper Oil Co.
1210455033
Stonington
Grain Coop
-
.
0210555004
U Haul
Co. of Illinois
—.
1430655314
Delta Development
:
0311595076
Broadview U-Haul
0310305072
Rand McNally
-.
.
0312880033
Pioneer Hi-Bred International
9190905002
Rollins Leasing Corp.
1970200014
Oilman,
Ralph & Sue
0894385211
GTE North Inc.
.
0830255024
GTE
-
1130205048
Warehouse Management
0430055266
Holmes
Co.
0311655026
Jacoby~SchroederFuneral
Home
0830255025
AM
Carpentry & General Contractors
0310245065
Clark Oil & Refining
0310215054
~end Lease Trucks Inc.
0310755005
IG&G Car Wash
1190655027
I
H.A.
Niebruegge Garage
1330255002
ILake
Shore Petro Corp.
IHarper
Oil
Co.
0312885010
0290255077
Libertyville Citgo
0970905119
Dover, Bernard
1970055001
IstLienCo.
0971905213
Taylorviue, City of
02106050461
IHayes OK Service
0316695031
i~eanOil Co.
-
.
11
1.060505~
ITap
Beverages
.12010305916

Northcord Inc.
-
BUD
1030105008
Martin Oil
-
0310355018
Gill,
Basil
.
2010305642
Steward
Elementary
School
~
1030455001
f
Mar~nOil
Pioneer Paint Products
-
0316165026
10311865023
Martin
OIl
-
-,
0430055328
Loves Park,
City
of
-—
2010155014
Norco
Fuels
Marttn Service Station #121
-
0110855044
0310035064
1090150009
I~P~s
Service
J’s
AutomotIve Repair
0971855055
IMartin
Oil
0430055328
MartIn
Oil
-
0430055328
Elmer Weber’s Farm Service
Johnson Oil Co.
Clark
Oil
& Refining
0150055001
1~i10855062
1150155305
Georges
66 Station
—-
0110855076
Emro Marketing
02901.05028
Svendsen’s Service Stations
11150150111
Pioneer Paint Products
.19311865023
Bartiow Bros. Inc.
~690205001
Lena Farmer’s Exchange
1770305015
Chicago
Golf Club
0431055102
Mitches Green Thumb Landscaping
-
0970255071
Dutton,
Harold
0690055010
Standard Forwarding
Co.
-
1610253006
VW Bowman Oil Co.
0770505054
Dutton Service Station
0690055010
Freedom
OIl Co.
1671205651
jO-Essence,
Ltd.
1950505089
Is~oot
Oil Co.
iö~ë10300019
LAbbo~
Labs
10971250004
Item
3.
All of the previously installed monitoring
wells have been completed at depths
greater than 20 feet.
Once fully developed,
the greatest
depth to
groundwater recorded
for a monitoring well has been approximately
8
feet.
The proposed delivery system
was
designed with a depth of 10 feet
in order to minimize
costs and treat both the
vadose and saturated zones.
During the installation,
if the proposed
10
foot depth does
not appear to
be
at or very near the water table,
the trench depth will be
increased to
assure that the injection system can treat both, the vadose
and saturated
zones.

.
ILLINOiS
ENVIRONMENTAL
PROTECTION
AGENCY
1021 NOkm
CRAt4D
AVENUE
EAST,
P.O.
BOx 19276,
SPRINGFIELD,
ILLINOIs
62794-9276,.
21
7-782-3397
JAMES
R.
T~-~Mp5oN
CENTER,
100
WEST
RAr’IDOLPH,
Suiit
11-300,
CHICAGO,
IL
60601,
312-314-6026
ROD
R.
BLAGOEVICH,
GOVERNOR
RENEE CIPRIANO,
DIRECTOR
217/782-6762
CERTIFIED
MAIL
-
.
7002
31.50
0000
1E27
4743
DEC
DEC
2003
Kefler
Oil Company
Charles F. Keller
P0 Box 70
Effingliam,IL
62401
Re:
LPC #1390305037
Moultrie Càunty.
Sullivan./Sullivan Super K
104
South
Hamilton
LUST Incident No. 992030
-
LUST
Technical File
Dear Mr.
Keller:
The illinois Environmental
Protection Agency (illinois EPA) has reviewed the High Priority
Corrective
Action Plan
(plan)
submitted for the above-referenced incident.
This information,
dated October 31, 2003,
was received by the illinois EPA on November 4,
2003.
Citations in this
letter are from the Environmental Protection Act (Act) and
35
illinois Administrative Code
(35
Ill. Adm.
Code).
Pursuant to Section 57,7(c)(4)(D) of the Act
and 35
111.
Mm.
Code
732.405(c),
the
High Priority
Corrective Action
Plan is rejected for the following reason(s):
The method
ofremediatiori can not be approved.
-
Pursuant
to Sections 57,7(a)(J) and 57.7(c)(4)(D) of the Act and
35
111. Mm. Code
732.405(e)
and
732.503(b),
the associated budget is rejected for the following reason(s):
The budget must be
associated with
an
approyed plan.
Rt)(~F,,KI~
-
431)2
N(~1hM~i~
SIrcel,
Rockiord.
IL 61103
fl
5)987-7760
DES
PLMNE~
~95I1
W.
Harri,on
St.. De~PIair,es.
II.
60016
—1847)
294-4000
595
South State,
EI~(in.IL 60123
.J7)
5Q~.3131
•.
Pto~t~
5115
N,
University St.,
Peoria.
11.61614
1309) 693.5463
BUREAL
()~
L~I).
PE.IIRtA
7620
N.
UniverSity
SI.,
Peoria. IL 61614—
309) 693.5462
—2125
South
First
Street. Cham~ai~n,
IL 61820
(21-7) 278-5800
5~R,,~CFlIti~
-
4300
S.
Sixth
5,reei Rd..
Spririg(ieId,
IL 62706
—12171
786-5892
Cou.,NSVILLE—
2009
MaIl Street. Collinsville,
IL
62234 —(610) 3465120
MA~(J~
2309 W.
Main
5).. Suite 116. Marion,
1.62959
—1618) 993-7200
EXHIBIT
PxNrEo
flr~~
RECYCLED
P,,pt~
10

Pa
2
DEC
26200~
Pursuant to 35 ill.
Adm.
Code 732.40 1,the Illinois EPA requires submittal of a revised
High
Priority Corrective Action Plan,
and budget if applicable, within 60 days ofthe date of this letter
to:
flhinols Environmental Protection Agency
Bureau ofLand
-
#24
Leaking Underground Storage Tank Section
102 1- 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 operator may appeal this decision to the illinois
Pollution Control Board.
Appeal rights are attached.
if you have any questions or need further information, please contact Scott Rothering at
217-785-
1858.
Sincerely,
C~$~/2
tJ’~&
Clifford L. Wheeler
Unit Manager
Leaking Underground Storage Tank Section
Division of Remediarion Management
Bureau of Land
CLW:SRR\l39O3OSO37hpcapden
Attachment:
Appeal Rights
C:
CW3M Company
Division File

DEC
2
6
2.00~
Appeal Rights
Au 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)(D) ofthe Act by filing a petition
for
a hearing within
35
days after the date ofissuance of the final decision.
However, the 35-day
period may be extended for a period oftime not to exceed 90
days by written notice from the
owner or operator and the Illinois EPA within the initial 35-day appeal period.
Ifthe owner or
operator wishes to receive a 90-day extension, a written request that includes a statement ofthe
date the final decision was received, along with a copy ofthis decision, must be sent to the
Illinois EPA as soon- as possible.
For information regarding the filing ofan appeal, please contact:
Dorothy Gunn, Clerk
Illinois
Pollution Control Board
State ofillinois Center
100 West Randolph, Suite 11-500
Chicago, IL
60601
312/814-3620
For information regarding the filing ofan extension, please contact:
illinois Environmental Protection Agency
Division of LegaJ Counsel
1021
North Grand Avenue East
Post Office Box
19276
Springfield,
IL
62794-9276
217/782-5544

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