BEFORE THE ILL
1
IN THE MATTER OF:
AMENDMENTS TO REGULATION OF
PETROLEUM LEAKING UNDERGROUND
STORAGE TANKS:
35 ILL. ADM. CODE 732
REIVED
~OLBOARDCLERKS
OFFICE
MAR
2
9
2001
STATE OF IWNOIS
Pollution
Control Board
)
ROl-26
)
(Rulemaking
-
Land)
)
)
NOTICE OF FILING
To: See Attached Service List
PLEASE TAKE NOTICE that on behalf ofthe ILLINOIS PETROLEUM
COUNCIL,
I have filed with the Clerk ofthe Illinois Pollution Control Board the
ILLINOIS
PETROLEUM
COUNCIL’S MOTIONTO FILE TESTIMONY INSTANTER
and
TESTIMONY OF DAVID PIOTROWSKI ON BEHALF OF THE ILLINOIS
PETROLEUM
COUNCIL,
copies ofwhich are hereby served on you.
ILLINOIS PETROLEUM COUNCIL
Dated: March 29, 2001
ROSS & HARDIES
David L. Rieser, Esq.
Brian Marquez, Esq.
150
North Michigan Ave.
Chicago, Illinois 60601
(312) 558-1000
THIS FILING SUBMITTED ON RECYCLED PAPER
20476\00005\CH184007WPD
1
)
)
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
I’AAR 29
2001
STATE OF ILLINOI5
IN THE MATTER OF:
)
POllUtiOn Control Board
)
AMENDMENTS TO REGULATION OF
)
RO1-26
PETROLEUM LEAKING UNDERGROUND
)
(Rulemaking
-
Land)
STORAGE TANKS:
)
35
ILL. ADM. CODE 732
)
ILLINOIS PETROLEUM COUNCIL’S
MOTION TO FILE
TESTIMONY INSTANTER
The Illinois Petroleum Council, by and through its attorneys, Ross & Hardies, requests
permission to file the Testimony ofDavid Piotrowski On Behalfofthe Illinois Petroleum Council
instanter.
The Illinois Petroleum
Council was unable to file this testimony on the due date of
March 27, 2001
because ofconflicting schedules. No one will be prejudiced by this late
filing and
it will not delay the Board’s considerationofthese proposed rules.
Wherefore, forthe reasons stated herein, the Illinois Petroleum Council
respectfully requests permission to file this testimony instanter.
ILLINOIS PETROLEUM COUNCIL
DATED: March 29, 2001
ROSS
& HARDIES
David L. Rieser
Brian Marquez
150 N. Michigan
Chicago, Ii 60601
312/558-1000
31 646\00004\CH1 64898WPD
1
RECEIVED
CLERK’S OFFICE
ILLINOIS POLLUTION CONTROL BOARD
MAR
2
9
2001
IN THE MATTER OF:
)
STATE OF ILLINOIS
)
Pollution Control Board
PROPOSED AMENDMENTS TO
)
RO1-26
REGULATION OF PETROLEUM
)
(Rulemaking
-
Land)
LEAKiNGUNDERGROUM) STORAGE
)
TANKS
(35
lLL. ADM. CODE 732)
)
TESTIMONY OF DAVID PIOTROWSKI ON
BEHALF
OF THE ILLINOIS PETROLEUM COUNCiL
Introduction
My name is David Piotrowski.
I am an Environmental Business Manager with
BP Amoco.
I have been in my current position since March 1999.
My responsibilities include
managing various types ofremediation projects for BP Amoco and its subsidiaries, including
Amoco
Oil Company (“Amoco”).
A large portion ofthese projects involve remediation ofsites
in the Illinois leaking underground storage tank (“LUST”)program.
My responsibilities relating
to these LUST
sites include all aspects ofsuch remediation, including working with off-site
property owners to
obtain access for sampling and/or corrective action.
Prior to assuming my
current position, I was an Environmental Manager for
Amoco in Houston,
Texas from
1996 to
1999, where I managed remediation projects for
Amoco’s Refiningand Exploration & Production businesses.
Prior to that, I was a Liability
Manager for Amoco from 1992 to 1996.
One of my responsibilities in this positionwas to
manage LUST remediation projects for Amoco in Illinois.
I received a B.S. in
Geology from Illinois State University and a M.S. in Geology
from Western Michigan University.
My resume is attached.
Today, I will be testifying on behalfofthe Illinois Petroleum Council
(“IPC”)in
support of certain modifications to Illinois EPA’s proposedamendments to the Part 732 LUST
regulations.
My testimony will be limited to the off-site access issues that are contained in
Illinois EPA’sproposed Sections 732.404(c) and
732.411.
The IPC generally supports Illinois
EPA’s proposal toallow underground storage tank (“UST”)owners and operators the
opportunity to receive a No Further Remediation Letter where off-site contamination has not
been addressed due to the inability to obtain off-site access.
However, the IPC believes that
certain modifications should be made to Illinois EPA’sproposal.
The ll’C’sproposed
modifications to
Sections 732.404(c) and 732.411
are attached hereto in both a black-lined
version and
a clean version and are discussed in more detail below.
Amoco’sApproach to Working With Off-Site Property Owners
Amoco is the largest petroleum marketer in Illinois and, as a result, has the largest
number ofgasoline service stations
and the largest number of LUST sites.
Amoco has therefore
obtained a vast amount ofexperience in working with off-site property owners in attempting to
obtain access for investigation and/or corrective action. Based on our experience in working
with off-site property owners, we have discovered that many different types ofissues arise in
attempting to obtain access from an off-site property owner.
Some ofthese issues include:
• Thelevel ofunderstanding ofthe off-site property owners with regard to
environmental issues varies.
Some off-site owners are companies which,
like Amoco, have experience with environmental issues, while other off-
site owners are individuals or businesses with no
such experience.
• The reasonforthe off-site access can be different for each site.
Much of
the time,
off-site access is required for soil and/or groundwater sampling
to determine the extent ofthe impact.
However, off-site access may also
be required for traditional corrective action activities.
•
Sometimes,
there have been prior or subsequent releases at the service
station site for which Amoco
is not responsible.
In addition, there may
have been releases on the adjacent propertywhich the adjacent ptoperty
owner does not want investigated.
•
Some releases impact only one
adjacent property, while others
impact
several off-site properties and perhaps one or more roadways.
In the latter
case, it is often more efficient to conduct investigation activities
at
2
different off-site properties at the same time.
One property owner’s
refusal to grant access can hinder this effort.
• Off-siteimpacts can include soil only,
groundwater only, or both.
In
addition, in
some cases, off-site investigation may be a one-time event,
while in other cases additional
samples or borings may be required.
Given these different types ofissues that can and do arise, Amoco’s approachin
attempting to obtain
off-site access has been:
(i) to take a site-specific approach in
requesting
access; and (ii) to provide any information which the property owner needs to understand the
request for access and to feel comfortable with his or her decision regarding such request.
For
example,
in some cases,
Amoco will make phone calls to an off-site property owner if he or she
has not responded to a written request for access.
Amoco will also conduct a face-to-face
meeting if requested by a property owner. Amoco has found that property owners are much
more willing to grant access if the request is tailored to the specific situation and the property
owner understands the issues and the need for access.
Illinois EPA’sProposed Amendments
The IPC generally agrees with Illinois EPA’sproposal to allow UST owners and
operators to obtain
a No Further Remediation Letter where off-site contamination has not been
addressed due to the inability to obtain off-site access.
However, the IPC believes that certain
modifications should be made to Illinois EPA’s proposal in order to increase the chance of
success
in obtaining off-site access
and in resolving issues relative to off-site contamination.
First, the IPC believes that the contents ofthe letterto be sent to off-site property
owners as proposed by Illinois EPA in Section 732.411(b) should be revised. The contents ofthe
letter proposed by Illinois EPA are too specific, and, due to the different types ofsituations that
could arise for any given site, may actually be inaccurate.
For example, Illinois EPA’s proposal
that the letter state that the owner or operator “will return the property to its original condition
3
prior to entry” may not be accurate ifthe access involves installation ofan engineered barrier or
a corrective action system.
In addition, the letter proposed by Illinois EPA contains legal
admissions that are unnecessary, unfair, and
in some cases inaccurate.
For example, as noted
above, some sites have had prior or subsequent releases for which the UST owner or operator is
not legally responsible, and thus Illinois EPA’s proposal that the letter state that “the owner or
operator will conduct all remediation at its
own expense” would be unwarranted.
Second,
in
Section 732.411(d), Illinois
EPA attempts to define what constitutes
“best efforts” for attempting to obtain off-site access.
However, the factors listed have nothing
to do with an owner’sor operator’sattempt to obtain access.
Rather, the factors describe
generalized site conditions without establishing criteria for agency decision making.
As
a result,
Illinois EPA’s proposal does notadequately define the standard Illinois EPA will use when
deciding when a UST owner or operator will receive a No Further Remediation Letter where off-
site contamination has not been addressed due to the inability to obtain off-site access.
To the
extent that Illinois EPA intended to set such a standard in Section 732.41 l(d)(l) to (9), it did not
do so, but rather only listed a series offactors relating to possible
exposure scenarios.
Any
factors considered by Illinois EPA in deciding whether to grant a No Further Remediation Letter
should be done in the context ofa defined standard, such as whetherthe site poses an
imminent
threat ofharm to human health or the environment.
The IPC’sModifications to Illinois EPA’sProposal
The IIPC’s modifications to Illinois EPA’s proposal are set forth in the
attachments to this testimony. As discussed in more detail below, we believe that these
modifications address the deficiencies in Illinois EPA’s proposal that are noted above.
4
First, the TPC’smodifications to Section 732.411(b) address the letterto be sent to
the off-site property owner.
The contents ofthe letter proposed by the IPC are more general and
therefore allow the letterto be
more easily tailored to the site-specific situation, while still
providing a baseline for agency review.
In addition, the modifications omit the unwarranted
and/or inaccurate legal admissions.
The IPC’s modifications therefore make it more likely that
an off-site property owner will grant access to a UST owner or operator for investigation and/or
corrective action.
Second, the
ll’C’smodifications to Section
732.404(c), the 1IPC’s deletion of
Illinois EPA’sSection 732.41 l(d)(1) to
(9), the IIPC’s modification to Illinois EPA’sSection
732.411(e)
(which is the JIPC’s Section 732.411(d)), and the IPC’s additionofits Section
732.411(e) all make clear that the standard that Illinois EPA should use in
deciding whether to
issue the owner or operator a No Further Remediation Letter is whether the
contamination
remaining on the off-site property poses an imminent threat of harm to human health or the
environment.
In deciding whether such a threat exists, the
TPC’s Section 732.411(e) requires that
Illinois EPA should consider factors including but not limited to the following:
(1) the presence
offree product on the off-site property; (2) the presence offire, explosion, and vapor hazards
through natural or manmade pathways
on the off-site property; and
(3) the presence ofpotable
waterwells,
surface water, setback zones or regulated recharge areas on or adjacent to the off-
site property.
This imminent threat ofharm standard and the factors listed above are more
appropriate than Illinois EPA’s possibleexposure scenarios listed
in
Section 732.41 1(d)(1) to (9)
ofIllinois EPA’sproposal.
Given that the IPC’s modifications retained Illinois EPA’s language
stating that “[t]he
owner or operator is not relieved ofresponsibility to clean up a release that has
migrated beyond the property boundary even where off-site access has been denied” (this
5
language was moved from Section 732.411(a) to a new Section 732.41 1(f) for clarity purposes),
the proper standard for issuing a No Further Remediation Letter should be whether the off-site
contamination is posing an imminent threat ofharm to human health orthe environment,
as
opposed to only considering general factors based possible exposure scenarios.
Finally, the IIPC has deleted the “at aminimum” language in the introductory
sentence in Section 732.411(b).
This phrase is vague and seems
inconsistent with the “best
efforts” concept.
Forthe reasons set forth above, the IPC respectfully requests that the Board adopt
the modifications proposed by the TPC in the attachments to this testimony.
I intend to provide a
summary ofthis testimony at the
April 3, 2001
hearing in Chicago and would be happy to
answer any
questions about the TPC’smodifications.
THIS FILING IS SUBMITTED ON RECYCLED PAPER
6
DAVID A. PIOTROWSKI
Environmental Business Manager
BP Amoco
28100 Torch Parkway, 3-S
Warrenville, IL
60555
Phone:
(630) 836-5674
SUMMARY
Fourteen years experience in health, safety and environmental management in industry and enviromnental
consulting.
This includes managing amajor oil company’s environmentahisk-consisting of financial and
technical management
of multiple consultants and contractors, contract negotiations with environmental
finns,regulatory compliance, and legal negotiations with thirdparties.
Has previously managed and
performed all aspects of petroleum hydrocarbon investigations and remedial actions
including:
groundwater monitoring,
subsurface investigations, remedial design,
operation & maintenance, and
emergency response activities at refinery, terminal, pipeline,
and service
station facilities.
EXPERIENCE
& ACCOMPLISHMENTS
BP Amoco,
1990 to Present
Environmental Business Manager. BPAmoco MidContinent Business Unit (MCBU 2/99
-
Present
Manage Illinois program including health& safety performance and annual & lifecycle environmental
costs
of retail and terminal facilities in Illinois.
Coordinate and support the MCBU asset management
team as theypursue property acquisitions and divestments.
Project Coordinator EH&S Amoco Worldwide Exploration Business Group
(WEBG) 2/98-2/99:
Provided
HSE support andguidance to various WEBG country teams including Venezuela, Algeria and Nigeria.
This included developmentof Safety Health & Environment Management Systems (SHEMS),
coordinating permit acquisitions, environmental consultant oversightfor assessment activities, landfarm
planning & development, andwaste treatment/disposal coordination.
Water Quality Engineer. EII&S Amoco Texas City Refinery.
11/95 to 2/98:
Responsible forproviding
HSE
support and guidance for refinery water and waste issues including:
wastewater treatment plant
permitting and reporting, landfarm permitting/operation/reporting,
deep well injection
permitting/reporting, spill response and reporting, groundwater/soil assessment andremediation, potable
water testing/reporting, andbeuzene
NESHAPcompliance. Worked closely with represented workforce to
meet compliance objectives.
Remediation Coordinator. EH&S. Amoco Marketing. St. Louis. Missouri.
1992 to 1996:
Responsible for
managing all
aspects of terminal and service
station environmental projects in Illinois, Missouri, Indiana
and Iowa.
This included consultant oversight forover
130
projects and management ofmulti-million
dollar annual budgets.
Project Engineer. EH&S.
Chicago. Illinois. 1990 to
1992:
Responsibleforterminal and pipeline
remediation projects in asix state region. Responsibilities included: project coordination and strategy
development, consultant oversight, budget management, project permitting, and regulatory negotiations.
DAVID
A.
PIOTROWSKI
Page
2
MAECORP Incorporated, Chicago, Illinois,
1987 to
1990
Project Manager.
1989 to
1990:
Enviromnental consultant responsible
for coordination and oversight of
underground storage tank andpipeline remediation projects for major oil and industrial clients.
Directly
responsible for managingproject level enviromnental staff.
Senior Hvdro~eo1ogist.
1988 to
1989:
Responsible for subsurface environmental investigations and
remediation projects.
Activities includedproposal preparation, project management, field work, and
report preparation.
Provided guidance to company field geologists.
Hydrogeologist.
1987 to
1988:
Hired as company’sfirst geologist.
Responsible for all aspects of
subsurface investigation andremediation projects.
Michigan Department ofNatural Resources, 1986 to 1987
Field Geologist. Plainwell. Michigan Field Office:
Responsible for conducting enviromnental
assessments, groundwater monitoring, and consultant audits.
EDUCATION
Master of
Science
-
Geology, 1987, Western Michigan University, Kalamazoo, Ivil
Research Fellowship
-
1986-1987
Graduate Teaching Assistant
-
1984-1986
Bachelor ofScience
-
Geology, 1984, Illinois
State University (ISU),
Nonnal,
Illinois
Undergraduate Teaching Assistant
-
1983-1984
General Assembly
Scholarship Recipient
ISU Hockey Team
Sigma Phi Epsilon Fraternity
Section 73 2.404 High Priority Site
(c)
The owner or operator is not required to perform corrective action on an adjoining or off
site property to meet the requirements ofthis Section,
even where complete performance
ofthe corrective action plan under (b)(1) or (b)(2) ofthis Section would otherwise require
such off-site action, if the Agency determines that the owner or operator is unable to
obtain access to the property despite the use ofbest efforts in accordance with the
requirements of Section 732.411 ofthis Part and the Aaencv has not
determined that any
contamination remaining on the off-site Dronertv Doses
an imminent threat of harm to
human health or the environment
Section 732.411
Off-site Access
a)
An owner or operator seeking to comply with the best efforts requirements of
Section 732.404(c) must demonstrate compliance with the requirements ofthis
Section.
The owner or operator is not relieved of responsibility to
clean up a
release that has migrated beyond the property boundary even where off site
access aernep
b) In conducting best efforts to obtain off-site access, an owner or operator mustFat-a
n+mmtum
send a letter by certified mail to the owner ofany off-site property to
which access is required, stating:
1)
Citation to Section 57 of That the Act statii~g assigns the
legal
responsibility of the owner or operator te-i~emediate of a UST to address
the contamination
caused by the-i~e1ease
a release from that UST that
occurred during the time that UST was owned or oneratedby that owner
or onerator
2)
That, if the property owner denies access to the owner or onerator, the
owner or operator may seek to gain entry by a court order pursuant to
Section 22.2c ofthe Act;
3)
That, if the court approves an injunction pursuant to Section 22.2c ofthe
Act, the court will also prescribe the conditions ofentry and the amount of
monetary damages, if any, that
areto be paid to the property owner as
compensation forthe
entry
~ That in nerforming the reauested investigation, the owner or operator will
work so as to minimize any disruntion on the nronertv. will
maintain, or
its consultant will maintain.
anuropriate insurance and will renair any
damage caused by its investigation
4)
That the owner or operator, if allowed access, will return the property to
its original
condition prior to entry
5)
That the owner or operator will conduct all remediation at its own
e*pense
~ That if the investigation shows contamination resulting from
a release
from a UST for which the owner or onerator is resnonsible. the owner or
onerator will work to resolve issues
arising from that release with the off
site nronertv owner
6)
That threatsto human health and the environment and diminished property
value may result from failure to remediate contamination from the release
7)
That the owner or operatorwill maintain proper insurance, as applicable
including Worker’sCompensation, Commercial General Liability
Comprehensive Automobile Liability,
and Professional Liability for Errors
and Omissions forthe completion ofall work; and
~ A reasonable time to respond to the letter, not less than 30
days.
c)
An owner or operator, in demonstrating that the requirements ofthis Section have
been met, must provide to the Agency, as part ofthe Corrective Action
Completion Report, the following documentation:
1)
A sworn affidavit, signed by the owner or operator, identifying the
specific off-site property involved by address, the measures proposed in
the corrective action plan that require off-site access, and the efforts taken
to obtain access, and stating that the owner or operator has been unable to
obtain access despite the use of best efforts; and
2) A copy ofthe certified letter sent to the owner ofthe off-site property
pursuant to subsection (b) ofthis Section.
d~
In determining whether me efforts an owner or operator
I1u~
maue constitute best
efforts to obtain access, the Agency must consider the following factors
The physical and
chemical characteristics,
including toxicity, persistence
and potential migration, ofapplicable indicator contaminants at the
property boundary line;
The hydrogeological characteristics ofthe site and the surrounding area,
including the attenuation capacity and saturation limits of the soil at the
property boundary
line;
The nature and extent oflrnown contamination at the site, including the
levels ofapplicable indicator contaminants at the property boundary line;
1-)
2)
3)
2
4)
The potential effects ofresidual contamination on nearby surface water
5.)
The proximity,
quality and current
and future uses ofnearby surface water
and groundwater, including setback zones and regulated recharge areas of
potable water supply wells;
6)
Any known or suspected natural or man made migration pathways
existing in or near the suspected area of off site conta~nation;
7)
The nature and use of the part ofthe off site property that
is the suspected
area of contamination;
8)
Any existing on
site engineered barriers or institutional controls that might
have an impact on the area ofsuspected off site contamination, and the
nature and extent of such impact; and
9.)
Any other applicable information assembled in compliance with this Part.
The Agency shall issue a No Further Remediation letter to an owner or operator
subject to this Section and otherwise entitled to such issuance only ifthe owner or
operatorhas, in accordance with this Section,
either
~fl
completed
any requisite off-site
corrective action or
demonstrated to the Agency’ssatisfaction an-inability that it has been
unable to obtain off-site access despite best efforts and the A~encv has not
found that the contamination remainiun off-site noses an imminent threat
ofharmto human health or the environment.
In evaluating whether the off-site contamination noses an imminent threat ofharm
the Aaencv shall evaluate factors including but
not limited to the following:
The presence offree nroduct on the off-site nronertv:
The nresenee offire. exnlosion. and vanor hazards throuah natural or
manmade nathwavs on the off-site nroDertv: and
The nresence ofnotable water wells. surface water. setback zones or
regulated recharae areas on or adjacent to the off-site nronertv.
The owner or onerator is not relieved of responsibility to
clean un a release that
has migrated beyond the nronertv boundary even where off.site access has been
denied.
3
Section 732.404 High Priority Site
(c)
The owner or operator is not required to perform corrective action on an adjoining or off-
site property to meet the requirements ofthis Section, even where complete performance
ofthe corrective action plan under (b)(l) or (b)(2) ofthis Section would otherwise require
such off-site action, if the Agency determines that the owner or operator is unable to
obtain access to the property despite the use ofbest efforts in accordance with the
requirements of Section 732.411 ofthis Part and the Agency has not determined that any
contamination remaining on the off-site property poses an imminent threat ofharm to
human health orthe environment.
Section 732.411
Off-site Access
a)
An owner or operator seeking to comply with the best efforts requirements of
Section 732.404(c)
must demonstrate compliance with the requirements ofthis
Section.
b)
In conducting best
efforts to obtain off-site access,
an owner or operatormust
send a letter by certified mail to the owner ofany off-site property to which
access
is required, stating:
1)
That the Act assigns the
legal responsibility ofthe owner or operator ofa
UST to address the contamination caused by a release from that UST that
occurred during the time that UST was owned or operated by that owner
or operator;
2) That, ifthe property owner denies access to the owner or operator, the
owner or operator may seek to gain entry by a court order pursuant to
Section 22.2c ofthe Act;
3)
That in performingthe requested investigation, the owner or operator will
work so as to minimize any disruption on the property, will maintain, or
its consultant will maintain,
appropriate insurance and will repair any
damage caused by its investigation;
4)
That ifthe investigation shows contamination resulting
from a release
from a UST forwhich the owner or operator is responsible, the owner or
operator will work to resolve
issues arising from that release with the off-
site property owner;
5)
A reasonable time to respond to the letter, not less than 30 days.
c)
An owner or operator, in demonstrating that the requirements ofthis Section have
been met, must provide to the Agency, as part ofthe Corrective Action
Completion Report, the following documentation:
1)
A sworn affidavit, signed by the owner or operator, identifying the
specific off-site property involved by address, the measures proposed in
the corrective action plan that require off-site access, and the efforts taken
to obtain access, and
stating that the owner or operator has been unable to
obtain access despite the use ofbest efforts; and
2) A copy ofthe certified letter sent to the owner ofthe off-site property
pursuant to subsection (b) ofthis
Section.
d) The Agency shall
issue a No Further Remediation letterto an owner or operator
subject to this Section ifthe owner or operator has, in accordance with this
Section,
either
1)
completed any requisite off-site corrective action or
2) demonstrated to the Agency’s satisfactionthat it has beenunable to
obtain
off-site access despite best efforts and the Agency has not found that the
contamination remaining off-site
poses an imminent threat ofharm to
human health or the environment.
e)
In evaluating whether the off-site contamination poses an imminent threat ofharm
the Agency shall evaluate factors including but not limited to the following:
1)
The presence of free product on the off-site property;
2) The presence of fire, explosion, and vapor hazards through natural or
manmade pathways on the off-site property; and
3) The presence ofpotable water wells,
surface water, setback zones or
regulated recharge areas on or adjacent to the off-site property.
f) The owner or operator is not relieved ofresponsibility to
clean up a release that
has migrated beyond the property boundary even wherei~ff-site access has been
denied.
2
CERTIFICATE OF SERVICE
The undersigned hereby certifies that copies ofthe foregoing
ILLINOIS
PETROLEUM COUNCILS’MOTION TO
FILE TESTIMONY INSTANTER
and
TESTIMONY OF DAVID PIOTROWSKI ON BEHALF
OF THE ILLINOIS
PETROLEUM COUNCIL, were served on behalfofthe Illinois Petroleum Council
upon all the
parties on the attached Service List on or before 5:00 p.m.
on this
29TH
day of March, 2001, by
either first class U.S. mail, postage prepaid or by overnight UPS delivery.
SERVICE LIST
RO1-26
Scott Anderson
Black & Beatch
101
North Wacker Drive
Suite
1100
Chicago,
IL
60606
Christie
Bianco
Chemical Industry Council of Illinois
9801
W.
Higgins Road
Suite 515
Rosemont,
IL
60018
Cindy Consalvo
Pioneer Environmental
1000 N.
Halsted
Chicago,
IL
60622
Leo P.
Dombrowski
Wildman, Harrold, Allen & Dixon
225 W. Wacker Drive
Suite
3000
Chicago,
IL
60606
Judith S. Dyer
Assistant Counsel
Division of Legal Counsel
Illinois
Environmental
Protection Agency
1021
North Grand Avenue
East
P.O.
Box 19276
Springfield,
IL
62794-9276
Neil
F. Flynn
Attorney at Law
1035 South Second Street
Springfield,
IL
62704
Collin W.
Gray
SEECO Environmental Services,
Inc.
7350 Duvon Drive
Tinley Park,
IL
60477
James
E.
Huff,
P.E.
Huff& Huff, Inc.
512W.
Burlington, Suite 100
LaGrange, IL
60525
Garry Aronberg
Kuhlmann Design Group
15 East Washington
Belleville, IL
62220
Bruce Bonczyk
601 W.
Monroe
Springfield,
IL
62704
William G. Dickett
Sidley & Austin
Bank One Plaza
Chicago,
IL
60603
Ron Dye
CORE Geological Services,
Inc.
2621
Montego
Suite C
Springfield,
IL
62704
Lawrence W.
Falbe,
Esq.
Wildman, Harrold, Allen & Dixon
225 W. Wacker Drive,
Suite 3000
Chicago,
IL
60606-1229
Daniel J. Goodwin,
P.E.
Goodwin Environmental
Consultants,
Inc.
400
Burns Lane
Springfield,
IL
62702
Thomas L.
Herlacher
Herlacher Ang leton Associates, LLC
8731
Bluff Road
Waterloo,
IL
62298
Kenneth James
Carlson Environmental, Inc.
65
E.
Wacker Place,
Suite
1500
Chicago, IL
60601
20476\00005\CH184032.WPD
1
Kenneth W. Liss
Andrews Engineering, Inc.
3535
Mayflower Boulevard
Springfield,
IL
62707
Barbara Magel
Karaganis & White, Ltd.
Suite 810
414
N.
Orleans
Chicago,
IL
60610
Monte
M.
Nienkerk, P.G.
Senior Project Manager
Clayton Group Services, Inc.
3140
Finley Road
Downers
Grove,
IL
60515
Joel J. Sternstein
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Georgia Vlahos
Counsel
Naval Training Center
2501A Paul Jones Street
Great Lakes, IL 60088-2845
John Watson
Gardner, Carton & Douglas
321 N. Clark Street
Chicago, IL 60610
Pat Ludewig
Caterpillar
Tech Center
Building
F
Peoria,
IL
61656-1875
George
F.
Moncek
United Environmental
Consultants,
Inc.
119 East Palatine Road
Suite 101
Palatine, IL 60067
Wayne Smith
Pioneer Environmental
1000 N.
Halsted
Suite 202
Chicago,
IL
60622
David A.
Sykuta
Illinois
Petroleum Council
P.O.
Box 12047
Springfield,
IL
62791
Rodger Walker
Walker Engineering
500 W.
Herrin Street
Herrin,
IL
62448
Gary T.
Zolyak
U.S. Army Environmental Center
Northern
Regional
Environmental
Office
Building E-4480
Aberdeen Proving
Ground, MD
21010-5401
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