III. COMMENTS ON CBE PROPOSAL
IV. CONCLUSION
PROOF OF SERVICE
THIS FILING IS SUBMITTED ON RECYCLED PAPER

iN THE MATTER OF:

SITE REMEDIATION PROGRAM

(AMENDMENTS TO

ILL.

ADM. CODE 740)

IN THE MATTER OF:

SITE REMEDIATION PROGRAM

PROPOSED

ILL. ADM. CODE

740.SUBPART Ii (PUBLIC SCHOOLS)

JAN ~ 2

2002

R01-27

STATE OF IWNOIS

(Rulemaking

LaiipIIUtIOfl

Control

Board

NOTICE OF

FILING

Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph,

Suite 11-500

Chicago, Illinois 60601

Amy Jackson, Hearing Officer

Illinois Pollution Control Board

600 S.

Second St.

—

Suite 402

Springfield, Illinois

62704

Attached Service List

Matthew J. Dunn, Chief

Environmental Bureau

Office of the Attorney General

JamesR.

Thompson Center

100 West Randolph,

12th Floor

Chicago, Illinois 60601

RobertLawley, Chief Legal Counsel

DepartmentofNatural ResOurces

524 South Second Street

Springfield, illinois 62701-1787

PLEASE TAKE NOTICE that today I have flIed with the Office ofthe Clerk of the Pollution Control

Board the Illinois Environmental Protection Agency’s First Notice Comments, acopy of which is herewith

served upon you.

Respectfully submitted,

ILLiNOIS ENVIRONMENTAL PROTECTION AGENCY

By:

1/I

MarkWight

Assistant Counsel

iiL

DATE: December 28, 2001

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544

REC~1VW

BEFORE

THE

ILLINOIS POLLUTION CONTROL

BOARDCL!RK’~

P1Cc

)

RO 1-29

(Rulemaking

Land)

(Consolidated)

THIS

FILING

IS SUBMITTED ON RECYCLED PAPER

IN THE MATTER OF:

SITE REMEDIATION PROGRAM

(AMENDMENTS TO

ILL.

ADM. CODE 740)

iN THE MATTER OF:

SITE REMEDIATION PROGRAM

PROPOSED

ILL. ADM. CODE

740.SUBPART H (PUBLIC SCHOOLS)

)

RO1-29

(Rulemaking

Land)

(Consolidated)

AGENCY’S FIRST NOTICE COMMENTS

The Illinois Environmental Protection Agency (“Agency”) respectfully submits its

comments in the above-titled matters to the Illinois Pollution Control Board (“Board”)pursuant

Ill. Adm.

Code 102.108 and the Board’s First Notice Opinion and Order of November 1,

2001.

OVERVIEW

On February 28 and April 4, 2001, the Board heldhearings in Springfield and Chicago on

the Agency’s proposed amendments to

Ill. Adm.

Code 740

and the proposal by Citizens for a

Better Environment (“CBE”) to add Subpart H: Requirements Relatedto Schools.

The

amendments proposed by the Agency are intended to: (1) Update incorporations by reference and

testing methods, and (2) Add or clarify provisions concerning the role ofLicensed Professional

Geologists in remediation activities, late-recorded No Further Remediation (“NFR”) Letters, and

•

.~M4

,~2

2002

BEFORE

THE

ILLINOIS POLLUTION CONTROL

)

R01-27

(Rulemaking

Land)

the recording ofNFR Letters issued to certain Illinois Department ofTransportation sites.

addition the Agency has proposed at leasttwo substantive changes to the rules: (1) Establishment

of“soil management zones,” and (2) Requirements that chemical analyses of environmental.

samples be performed by laboratories accredited under

Ill. Adm. Code

186.

During the

course of the hearings, the United States Department ofDefense

(“DoD”) and the General

Services Administration (“GSA”) also proposed procedures pertaining to the recording ofNFR

Letters issued to certain federally owned sites.

At the hearings, representatives ofthe Agency, CBE, DoD, GSA, the Site Remediation

Advisory Committee, the Illinois Environmental Regulatory Group, Chicago Public

Schools, the

Illinois

Society ofProfessional Engineers, and the Consulting Engineers Council ofIllinois

presented testimony.

Following the hearings, several participants submitted post-hearing

comments to the Board.

On November

1, 2001, the Board issued an Opinion and Order adopting

for First Notice the Agency’s proposal as modified by the Board based on the hearings and

comments.

The Board’s Opinion and

Order also presents the CBE’s modified proposal for

Subpart H and requests additional comment.

The Agency submits the following comments on

the Board’s November 1st Opinion and Order.

COMMENTS

BOARD’S REVISIONS

TO AGENCY PROPOSAL

The proposed rule substantially tracks the Agency’s proposal as originally submitted and

modified by the Agency during the course ofthe hearings.

The Board has proposed some

changes to the Agency’s proposal based on the record developed at the hearings.

Generally, the

Agency accepts the changes made by the Board but offers thefollowing specific comments as

well as suggestions for additional changes and a few corrections.

The Agency believes that all of

the revisions proposed in these comments are non-substantive and consistent with its original

proposal and testimony at hearing.

Section 740.120:

The Agency supports the Board’s decision not to include a definition ofsoil in the Part

740 regulations.

For the reasons stated in the record and the Board’s First Notice Opinion, this is

a decision better left to the Agency and the Remediation Applicant on a site-specific basis.

Significant disagreements generallywill find

avenues of appeal to the Board through denials of

Remedial Action Plans or Remedial Action Completion Reports.

Section

740A25(b):

The Agency notes that the Board has revised the Agency’s SW-846 amendment to

include the most recent update, lilA, as well as the earlier updates.

The Agency believes that it is

important to clarify that only the most recent method or procedure contained in those updates

will be accepted by the Agency.

For example, if a particular test method

is updated in Update

hA and again in Update lilA, only the test method provided in Update lilAwill be acceptable.

Section 740.405:

The Agency supports the Board’s decision to acknowledge the role ofLicensed

Professional

Geologists in environmental remediation activities under the

SRP.

Section 740.41 0(b)(4):

accompanythe amendments requiring analyses ofenvironmental samples by certified

laboratories, the Agency proposes a revisionto the certification statement signed by the

supervising Licensed Professional Engineer (“LPE”).

Laboratories are certified pursuant to 35

Ill. Adm. Code 186.

Under Section

186.190(n)(7), the laboratory must identify in its report any

sample results with failures or deviations from the approved test methods or quality control

criteria, such as data qualifiers.

However, the laboratory is not required to

determine whether the

data are usable.

That decision is left to the recipient ofthe data.

For example, soil

samples are

collected at a site and are to be analyzed for volatile organic compounds.

The soil samples are

placed on ice inside a cooler, and the cooler is sealed.

However, the samples do not reachthe

laboratory for three days, and the temperature inside the cooler is

7 degrees Celsius.

This is

above the 4 degrees Celsius specified in Section

186.1

85(c)(1)

and outside the acceptable range

of 0.1

to 6 degrees Celsius.

The laboratory contacts the client that the temperature ofthe cooler

is outside the requirements, but the client still requests the samples to be analyzed.

The data

would be qualified that the preservation requirements were not met.

It then would be up to the

LPE to evaluate the data and make a judgment with regard to its suitability.

The Agency proposes the following revisions to the certification language to affirm that

reports, including any qualified data, from the certified laboratory have been reviewedby the

LPE:

I attest that all site investigations or remedial activities, including review

oflaboratory data, that are the subject ofthis plan or report were

performed under my direction and this document and all attachments were

prepared under my direction orreviewed by me, and, to the best ofmy

knowledge and belief, the work described in the plan or report has been

designed or completed in accordance with the Act,

Ill. Adm. Code

740,

and generally accepted engineering practices, and the information

presented, including any qualified laboratory data, is accurate and

complete.

Section

740.415(d)(6):

The Agency supports the extension ofthe effective date to January

1, 2003, for the

requirementto

submit sampling data analyzed by accredited laboratories.

This extension also

found at Sections

740.425(b)(7), 740.435(b)(8)

and

740.455(a)(6).

The Agency notes that in a

similar proposal for amendments to

Ill. Adm.

Code 732: Regulation ofPetroleum Leaking

Underground Storage Tanks (PCB DocketNo. RO1-26), the Board has extended the effective

date to July 1,

2003.

The Agency will propose revisingthat extension to January

1, 2003,

so that

the two programs will have the same effective date for the requirement.

The Agency’s laboratory

personnel foresee no problem completing certifications by the January date if applications are

submitted in a timelymanner.

Section

740.425(b)(2)(E):

Following recent communications with the DoD/GSAparticipants, the Agency has

agreed to propose additional language changes to provide consistency with the proposed

amendment at Section 740.622.

The first ofthese is

at subsection (b)(2)(E) where the Agency

proposes the following:

“A legal description or reference to a plat showing the boundaries ofthe

remediation site, or, fora Federal Landholding Entity,

a common address, notations in any

available facility master land use plan, site specific GIS or GPS coordinates, plat maps, or any

othermeans that identifies the site in questionwith particularity.”

This language tracks language

appearing at Section 740.622(a)(1)(A).

The DoD/GSAparticipants believe the flexibility

provided by this language is necessaryfor Federal Landholding Entities needing to describe a

parcel ofland.

This revision also should be made at Section

740.435(b)(2)(D).

Section 740.425(b)(7)(B):

To provide a more definite certification for the regulated community and the Agency, the

Agency proposes amending this subsection as follows: “Certification by an authorized agent of

the laboratory as follows:

‘I attest that all analytical results that are the subject ofthis report were

obtained b~

analyses performed by me or under my direction, and, to the best of my knowledge

and belief, the analyses and report have been completed in accordance with the requirements of

35 Ill. Adm.

Code 186 and the scope ofthis laboratory’s accreditation.’: that all analyses have

been performed in accordance with the requirements of35 Ill.

Adm.

Code 186 and the scope of

accreditation and”.

This revision also

should be made at Sections 740.43

5(b)(8)(B)

and

740.455(a)(6)(B).

Section 740.53

5(b):

This subsection sets forth eight “requirements” that must be satisfied for approval of a

request for a soil management zone (“SMZ”).

These requirements are a mix ofinformationthat

should be available and provided at the time of the request and information supporting proposals

for certain actions to be taken once the SMZ is approved and implementation begins.

However,

the Agency’s proposed language states that the Remedial Action Plan must demonstrate that the

requirements “will be satisfied,” possibly creating the interpreIation that site investigation

activities, definition ofthe dimensions ofthe

SMZ, and so forth may be provided after the SMZ

is approved.

To clarify that this type ofinformation must be provided at the time ofthe request

as part ofthe Remedial Action Plan, the Agency proposes the following change:

“.

shall be

classified as a soil management zone if the Remedial Action Plan provides the following

information and demonstrates that the following requirements will be satisfied:”.

Changes in the

original request forthe SMZ may be accomplished through an amended Remedial ActionPlan.

Section 740.53

5(b)(8):

The Agency’s views on this provision are well documented in the record and the Board’s

First Notice Opinion.

Section 740.535(d)(3):

Also to provide consistency with Sections 740.62 1

and

740.622, the Agency proposes the

following revision as agreed with the DoD/GSA participants: “Until the NFR Letter is perfected

in accordance with Sections Section 740.620, 740.621

or 740.622 ofthis Part.”

Section 740.535(f)(2):

correct an error in the Agency’s original proposal, the word “Objective” should be

revised to the plural, “Objectives.”

Section 740.53 5(g)(2):

Again, to provide consistency with Sections 740.621

and 740.622, the Agency proposes

the following revision as agreed with the DoD/GSA participants:

“A No Further Remediation

Letter addressing the contaminants that were the subject ofthe SMZ has been perfected under

Sections Section 740.620, 740.621 or 740.622 ofthis Part..

Section

740.605(d):

Once again forthe

sake ofconsistency, the Agency proposes the following revision as

agreed withthe DoD/GSA participants: “The corrected letter shall become effective and shall be

perfected as provided in Sections 74O.620~

ec 740.621

or 740.622 ofthis Part.

Section 740.610:

Subsection (a)(l) should begin with a capital “A.”

In subsection (a)(4),

“act” should be

capitalized.

In subsection (a)(9), the numeral

“9” should not be stricken, and “agency” and

“freedom ofinformation act” should be capitalized.

To provide consistency, the Agency

proposes amending subsection (a)(7) as follows: “The recording obligations pursuant to title

XVII ofthe Act and Sections Section 740.620, 740.621

or 740.622 ofthe Act.

Section 740.620(d):

The Agency proposes one fmal revision as agreed with the DoD/GSA participants: “The

certification shall be recorded in accordance with this Section or Sections

740.621

or 740.622 as

applicable, along with the No Further Remediation Letter or an affidavit.

Section 740.625(aXlO):

Section “740/622” should be revised to “740.622.”

Appendix A, Table A:

To correct an error in the Agency’s original proposal,

1,2-Dichioroethene (total) should

be deleted along with its soil number, “10.”

Appendix A, Table D:

To correct an error in the Agency’s original proposal, Method 6020 should be added to

barium.

III.

COMMENTS ON CBE PROPOSAL

At the Table ofContents for Subpart H, Section 740.820 should be changed to

“Establishment ofDocumentRepository.”

Section 740.805:

As a result of the adoption ofSB1 180 by the

92nd

General Assembly (P.A. 92-0151; eff.

July 24, 2001), there appears to be a conflict between this section and what is now required of

public schools

in counties with populations ofmore than 3,000,000 by Section

58.16

ofthe Act.

Section 58.16 prohibits commencement ofconstruction ofsuch schools unless the property has

been investigated for environmental contamination and enrolled in the SRP, if necessary, and has

received the Agency’s approval ofits Remedial Action Plan.’

Section

58.16

further prohibits

occupancy ofa building intended for use as a school unless the work required in the Remedial

Action Plan has been completed.

Completion ofthe work required by the Remedial Action Plan

is marked by the approval ofthe Remedial Action Completion Report (“RACR”) in accordance

with Sections

740.455,

740.505 and 740.525

and Section

58.7(e)(4)

of the Act wherein the

Agency is expressly authorized to determine when remedial activities have been completed in

accordance with the Remedial Action Plan.

The conflict arises because proposed Section

740.805 prohibits use by the public ofthe site or any buildings on the site before an NFR Letter

has been received from the Agency.

For public schools in counties with populations ofmore

than

3,000,000 this is more stringent than Section 58.16

because waiting for theNFR Letter may

add at least 30 days to the time when occupancy may begin.

See

35 Ill.

Adm. Code 740.605(a).

To reconcile this conflict with the Act and to clarify the point at which remedial action is

completed, the Agency suggests the following revisions:

“.

.shall not be made available for use

by children and the general public without first completing all

workpursuantto the its Remedial

Action Plan. and receiving a NFR Letter from the Agency.

Work pursuant to the Remedial

At this

point, proposed Section

740.805

is less stringent than Section

58.16

since

it applies

only

to sites

enrolledin

Action Plan is deemed completed on the date the Agency issues its written final determination

unconditionally approving the Remedial Action Completion Report.

This section shall not be

construed

to exempt a RA from any additional requirements set forth in Section 58.16

58.15

the Environmental Protection Act 415

JLCS

5/58.16

58.15.”

The words “children and” are

added to maintain consistency with proposed Section 740.800(a).

Section 740.810(a):

The certification statement need not be broken out into subsections.

Instead, it should be

combined into one paragraph beneath subsection (a)(2) and set offwith quotation marks.

The

lastphrase ofthe certification statement should read, “~the

information presented ~

in accurate

and complete.”

Also, there are two subsections (a)(2).

The second should be renumbered.

Section 740.810(b):

So as not to foreclose options such as opportunities to cure the failure to submit the report

or defects in engineered barriers or institutional controls, the Agency suggests modifying the

introductory language as follows:

“In addition to any other remedies that may be available, the

Agency may void the NFR Letter.

.“

In addition, itmay be

advisable to include a new

provision at Section 740.625(a)(12) adding this to the list ofreasons forvoidance ofNFR Letters.

Also, to

clarify that the report must be

submitted before every fifth anniversary and to maintain

consistency with Section 740.8 l0(a)(3), the Agency suggeststhe following:

“An LPE’s report is

not submitted to the Agency by every any fifth anniversary...

Section 740.810(d):

This provision would be more helpful if a time limit were provided.

The Agency

the

SRP

but does notrequire public school

sites to be enrolled in

the

SRP.

suggests: “If the site is transferred to a third-party, the transferor ofthe site

~fl

is required to

notify the Agency ofsuch changes within 30 days ofthe completion ofthe transfer.

Section 740.81

5(b)(6):

“Contaminant” should be plural.

Section 740.820:

To ensure that the record kept atthe document repository is complete, the Agency

proposes the following:”..

the RA shall establish a repository where

~ll

documents prepared by

the RA

for

the Agency and by the Agency for the RA may be viewed.

Section 740.825:

This section requires within ten days ofthe submission ofa Remedial Action Plan to the

Agency the mailing of a fact sheet providing a significant amount of site information and a

description ofthe steps proposed to address the contamination.

However, Remedial Action Plans

may be rejected or amended for a variety ofreasons, and this could change the information sent

in the original fact sheet.

The question is whether additional fact sheets will be required for

everyRemedial Action Plan, including amended plans, orjust the initial plan.

The Agency

suggests that the requirement be a one-time notice accompanyingthe initial plan.

This serves the

purpose ofnotifying the community ofthe general intent ofthe school system.

The Agency’s

final determination for the planand any amendments to the planmay be tracked through the

document repository.

The following change is

suggested: “No later than

days after

submission to the Agency ofthe initial a Remedial Action Plan for a remediation site intended

for future use as a school.

General Comment:

Several compliance issues are raised by Subpart H, but, except forthe engineered

barrier/institutional control reporting provision at Section 740.8 10, very little addresses standards

for compliance, confirmation ofcompliance, and consequences for non-compliance.

For

example, under Section 740.820 several questions could arise.

What if the document repository

is not established?

What if the repository is established but not until after the ten-day

requirement?

What if documents are omitted from the repository?

What if the repository is not

updated promptly and continuously?

What constitutes promptness in this case?

Similar questions

arise in other sections.

Arethese to

be considered program issues to be

evaluated by the Agency and affecting in some way the progress ofthe RA toward the NFR

letter, or are they compliance issues to be settled in actions before the Board brought by the

complaining parties?

IV.

CONCLUSION

The Agency has reviewed the Board’s First Notice Opinion and Order, and, with the

exception ofSection 740.535(b)(8) and the revisions proposed above, accepts and supports the

revisions to the Agency’s proposal as set forth by the Board.

The Agency has proposed at least

one substantive revision to the CBE proposal and raised at least one

question (the compliance

issue) the resolution ofwhich may have a significant impact on the administration ofSubpart H.

Others may do the same during this public comment period.

Because the proposal remains

unsettled, the Agency believes the dockets should be severed to allow the CBE proposal to

crystallize further in an additional hearing or a Second First Notice Opinion and Order subject to

public

comment, whichever the Board deems most effective for resolving remaining issues.

Unless substantive revisions are proposed by others and accepted by the Board, the Agency

proposal as revised herein is, in the Agency’s opinion, ready for Second Notice.

Date: December 28, 2001

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:

J~T~

Mark Wight

Assistant Counsel

THIS DOCUMENT SUBMITTED ON RECYCLED PAPER

STATE OF ILLiNOIS

COUNTY OF SANGAMON

)

PROOF OF SERVICE

I, the undersigned, on oath state that I have served the attached First Notice Comments ofthe

Illinois Environmental Protection Agency upon the persons to whom it is directedby placing copies in

envelopes addressed to:

Dorothy Gunn, Clerk

Illinois Pollution Control Board

James

R. Thompson Center

100 W. Randolph, Suite 11-500

Chicago, Illinois

60601

(FEDERAL EXPRESS

OVERNIGHT)

Amy Jackson, Hearing Officer

Illinois Pollution Control Board

600 S. Second St.

—

Suite 402

Springfield, Illinois 62704

(FIRST

CLASS MAIL)

Attached Service List

(FIRST

CLASS MAIL)

~~i)c~L’~

oA’c\~~

Notary Public

Matthew J. Dunn, Chief

Environmental Bureau

Office ofthe Attorney General

James R. Thompson Center

100 WestRandolph,

12th Floor

Chicago, Illinois 60601

(FIRST

CLASS MAIL)

Robert Lawley, ChiefLegal Counsel

Department ofNatural Resources

524 South Second Street

Springfield,

Illinois 62701-1787

(FIRST

CLASS MAIL)

OFFICIAL

SEAL

BRENDA BOEHNER

l~0I~’(

PUBLICS

STATE

ILLINOIS

~OMMISSION

EXPIRES

1l-14-2005t

and mailing them from Springfield, Illinois on

/c~—,)~Q

with sufficient postage affixed as

indicatedabove.

SUBSCRIBED AND SWORN TO BEFORE ME

this_~~~dayof

Ce1rt~O.~(,

2001.

THIS FILING IS SUBMITTED

ON RECYCLED PAPER

‘0

1’

t-J

‘0

I-

SERVICE LIST:

R01-27

and

RO 1-29

(consolidated)

IN THE

MATTER OF:

SITE REMEDIATION

PROGRAM:

AMENDMENTS TO

ELL. ADM. CODE 740

And

THE MATFER OF:

SITE REMEDIATION

PROGRAM:

PROPOSED

ILL.

ADM. CODE 740.SIJBPART

(SCHOOLS,

PUBLIC

PARKS,

AND PLAYGROUNDS)

November

15, 2001

Bernoteit

Karen L.

ERG

215

East

Adams Street

Springfield,

627111

Cipriano

ReLlee

Director,

JEPA

1021

North

Grand Avenue

East

Springfield,

62794-9278

P.O. Box

19276

Crivello

Lynn

CSA

Clark Street,

17th Floor

Chicago, 1L

60603

Curley

Edo

Midwest

Engineering

Services,

Inc.

4243

166th

Street

Oak

Forest,

60452

DiekeLt

William

Sidley &

Austin

South

Dearborn

Suite 5200

Chicago, IL

60603

Dunn

Matthew J.

Environmental

Bureau

188 Vt

Randolph,

20th Floor

Chicago, IL

60601

Fencili

Juan

Office

ol’

the

Attorney General

Chicago Park District

425

MoFecridge

Chicago,

60505

Gobelman

Steven

IDOl’,

Ed,

2300 South Dirksen Parkway

Springfield,

62764

Room 330

Goodwin, P. B.

Daniel

Goodwin Eriviroiunenlal Consultants

400 BrunsLane

Springfield,

62702

Gordon,

Fsq.

Holly D.

Chicago

Legal

Clinic

205 W.

Monroe

Sheet, 4th Floor

Chicago, IL

60606

Dunn

Dorttiiy

Clerk

100 W. Randolph,

Suite

1 1-500

Chicago, IL

60601

Harley

Hodge

Keith I.

Katherine

Illinois Pollution Control

Board

Chicago

Legal Clinic

lodge

Dwyer Zeman

205

Monroe

Street,

4th Floor

P.O.

Box

5776

Chicago,

Springfield,

60606

62705-5776

Kirsclrner

Stephen

Advanced GeoServices Corp.

Brandywine One,

Suite

202

Chadds

Ford,

19317

RL202&l.

Lawley

Maiming

Nienkerk

Robert

Brent

Monte

Department

Natural

Resources

Director

Department

of Natural Resources

Clayton

Group Services

524

South Second

Street

52.4 8.

Second Street, 4th Floor

3140 Finley

Road

Springfield,

Downers Grove, IL

62701-1187

62701

60515

Moe

Stefan

Citizens

for a Better Environment

205 W. MonroeScreet, 4th Floor

Chicago, IL

60606

Rapps

Mike

Rapps Engineering & Applied

Science

821

Durkin Drive

Springfield,

62704

Reiniana

John

IN DECK

600

N. Buffalo Grove Rd.

Buftirlo Grove,

61)089

Suite 300

Reiser

David

Ross

lard

ice

150

Michigan

Chicago, IL

60601

Ryan

Jim

Office

of the

Attorney General

100 W. Randolph

Chicago, IL

60601

Sassita

Ala

CCA

333

W. Wacker Drive, Suite

1400

Chicago,

60606

Smith

Suianne

Sonnensehein,

Nath

& Rosenthal

8000

Sears Tower

Chicago,

60606

Vlahos

Georgia

U.S. Navy

260 IA

Paullones St.

Great

Lakes, IL

60088-2845

SERVICE LIST:

RD L-27

and

ROl -29 (consolidated)

IN THE MATTER

OF:

SITE

REMEDIATION PROGRAM:

AMENDMENTS TG

ILL.

ADM

CODE

740

And

IN THE

MATTER OF:

SITE

REMEDIATION PROGRAM:

PROPOSED

ILL ADM. CODE 740.SUBPART I-I

(SCHOOLS.

PUBLIC

PARKS, AND PLAYGROUNDS)

November

15. 2001

Wight

Mark

1EPA

1021

North Grand Avenue East

Springfield,

62794-9278

P.O. Box

19276

‘0

I.-

‘0

-C

~-1

I—

-j

Cl)

-j