3~40Finley Road
Downers Grove, IL 60515
630.795.3200
Fax: 630.795.1130
VIA U.S. MAIL
August 2, 2005
Marie E. Tipscord
Hearing Officer
Illinois Pollution Control Board
100
West Randolph, Suite 11-500
Chicago, IL 60601
Subject:
Dear Ms. Tipscord:
4Claytoif
GROUP SERVICES
RECEIVED
CLEBK’S OFFICE
AUG g3 2005
STATE OF ILLINOIS
Pollution control Board
Proposed Revisions to Leaking Underground Storage Tank Regulations at
Part 732 and New Regulations for Leaking Underground Storage Tanks at
Part 734, R04-22 and R04-23.
Clayton Group Services, Inc. (Clayton) has prepared this correspondence in regards to the
illinois Environmental Protection Agency’s proposed and new regulations referenced
above. Clayton has reviewed the proposed maximum payment amounts for eligible
corrective action costs and has found many of the amounts, especially subcontracted
services (e.g., UST removal, soil excavation and disposal), substantially lower than
competitive prices for the Chicago area. The bidding process described in the regulations
where three competitive bids from subcontractors or for portions of the work that cannot
be completed for the maximum amount would be an extremely cumbersome process. In
addition, it is unclear whether the costs associated with preparing the bid specifications,
conducting associated pre-bid site visits, and reviewing the bids would be eligible for
reimbursement. Clayton would not bid a LUST project if payment were based on the
maximum payment amounts or be subject to the bidding process. Clayton is an
environmental consulting firm that has been in business for over 50 years, and has been
operating in illinois since before the first illinois LUST regulations were enacted in 1988.
If you would like additional feedback, please contact me at 630/795-3209.
Sincerely,
Gary
It Pcrkowitz, P.G.
Manager
Environmental Services
7e.
LUST Reimbursentnt
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