CARLSON
ENVIRONMENTAL
December
15,
2008
Ci
62008
SThTE
Illinois
Pollution
Control
Board
?oiIutj
conjNo1S
100
West
Randolph
Board
Suite
11-500
Chicago,
Illinois
60601
RE:Case
No:
R2009-009
Case
Type:
Rulemaking
Media
Type:
Land
County:
Statewide
Case
Name:
In
the
Matter
of:
Proposed
Amendments
to
Tiered
Approach
to
Corrective
Action
Objectives
(35
Ill
Adm.
Code
742)
Board
Member:
Johnson,
T.E.
Hearing
Officer:
McGill,
R.
Status:
Board
Order
Dear
Mr.
McGill:
1)
If
I
have
soil
and
ground
water
issues
on
my
site,
in
addition
to
evaluating
indoor
inhalation
on
my
site
as
per
the
proposed
TACO
rules,
would
I
also
have
to
evaluate
potential
off-site
lateral
migration
of
measured
impacts
via
Equation
R-26
to
assess
the
potential
for
(ground
water
component
of)
indoor
inhalation
exceedances
on
my
neighbor’s
property
as
well?
As
an
alternative,
could
I
install
monitoring
wells
along
our
shared
property
boundary
to
measure
actual
ground
water
concentrations?
If
either
approach
results
in
potential
off-site
exceedances
of
the
ground
water
component
of
indoor
inhalation,
what
will
I
be
required
to
do
(neighbor
notification,
ELUC
requiring
installation,
operation,
and
maintenance
of
a
building
control
technology,
etc.)?
If
an
ELUC
is
required
on
my
neighbor’s
property
and
he
is
reluctant
to
comply,
can
I
still
get
my
NFR?
Is
it
reasonable
to
assume
that
only
ground
water
(not
soil)
transport
onto
adjoiners’
properties
will
require
evaluation?
2)
p.
9
of
Gary
King’s
Nov.
14,
2008
pre-filed
testimony
says,
“Building-specific
default
values
for
the
following
parameters..
.The
same
default
values
must
be
used
for
the
same
parameters
when
performing
Tier
2
calculations.
The
actual
values
of
these
parameters
do
not
have
a
great
impact
on
the
rernediation
objectives;
however,
the
default
values
are
based
on
a
conservative
representation
of
the
type
of
buildings
that
are
or
may
be
present
at
the
site
in
the
future.
Without
these
conservative
values,
restrictions
would
be
required
on
the
minimum
size
of
a
building
that
can
be
constructed
over
the
contaminated
area.”
I
understand
the
Illinois
EPA’s
institutional
control-related
challenge,
but
take
issue
with
the
defaults
not
having
a
great
impact
on
the
remediation
objectives.
In
our
preliminary
analysis,
we
are
finding
that
the
building
dimensions
can
significantly
alter
the
Tier
2
remediation
objectives.
Our
clients
are
industrial
users,
and
instead
of
65
feet
x
65
feet
x
10
feet
tall
(the
default
assumptions),
tend
to
have
buildings
that
are
500
ft
x
500
ft
x
25
ft
tall,
and
this
does
have
a
dramatic
effect
on
the
Tier
2
indoor
inhalation
remediation
objectives.
In
putting
together
our
SRP
reports,
we
will
run
the
Tier
2
calculations
using
the
building
dimension
defaults.
If
there
are
no
exceedances,
the
outcome
is
65
East
Wacker
Place•
Suite
1500•
Chicago,
Illinois
60601
Phone
(312)346-2140.
Fax
(312)
346-6956
w’.carIsonenvcorn
CARLSON
ENVIRONMENTAL
Mr.
McGill
Illinois
Pollution
Control
Board
December
15,
2008
Page
2
straightforward.
However,
if
the
Tier
2
remediation
objectives
using
the
default
building
dimensions
predict
an
exceedance,
our
inclination
is
to
also
run
the
Tier
2
calculations
using
the
existing
building-specific
dimensions,
and
present
both
outcomes.
If
no
exceedances
are
predicted
using
the
building-specific
dimensions,
is
there
a
proposed
institutional
control
option
that
would
allow
us
to
avoid
putting
in
a
(unnecessary)
building
control
technology
until
the
existing
building
is
demolished
and
a
future
building
is
constructed?
For
example,
perhaps
our
NFR
has
a
condition
that
requires
a
building
control
technology
or
max.
size
for
future
construction
(when
the
existing
building
is
torn
down).
Somehow
the
Illinois
EPA’s
approval
letter/NFR
will
acknowledge
that
the
current
building
conditions
are
acceptable.
Surely
no
one
thinks
it’s
a
good
idea
to
install
an
unnecessary
mitigation
system
(based
on
modeling)
in
an
existing
building
just
to
get
an
NFR.
Obviously
if
our
Tier
2
calculation
with
building-
specific
inputs
indicates
a
problem,
we
would
have
to
install
a
building
control
technology.
We
recognize
that
Tier
3
does
allow
for
use
of
building-specific
dimensions,
however,
are
finding
that
inclusion
of
the
advection
component
in
the
modeling
has
a
profound
effect
on
the
Tier
3
remediation
objectives.
In
some
instances,
it
overwhelms
the
benefits
of
the
larger
building.
In
general,
it
is
not
intuitive
that
a
larger
building
is
more
prone
to
cause
or
promote
the
advection
phenomenon.
3)
p.
15
of
Gary
King’s
pre-filed
testimony
notes
that
when
comparing
the
calculated
soil
gas
remediation
objective
to
soil
gas
samples
from
the
site,
Section
742.7
17(k)
instructs
site
evaluators
to
use
soil
gas
data
collected
at
a
depth
at
least
3
feet
below
the
ground
surface...”
Does
this
contradict
742.717(k)
where
it
discusses
the
need
for
soil
gas
samples
to
have
been
obtained
from
a
depth
of
5
feet?
4)
p.
1
8
of
Gary
King’s
pre-fi
led
testimony
says,
“It
is
possible
to
calculate
a
Tier
2
soil
remediation
objective
more
stringent
than
the
Tier
I
soil
remediation
objective
for
the
indoor
inhalation
pathway;
in
such
cases,
the
Tier
I
remediation
objective
applies.”
This
seems
to
contradict
742.717(1).
Respectfully
submitted,
CARLSON
ENVIRONMENTAL,
INC.
Gail
Artrip,
P.E.
Project
Director
65
East
V\/acker
Place•
Suite
1500
Chicago,
Illinois
60601
Phone
(312)346-2140.
Fax
(312)346-6956.
www.carlsonenv.com