BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
IN THE MATTER OF:
)
R06-10
FEB 21 2006
PROPOSED AMENDMENTS TO
)
(Rulemaking-Land)
STATE OF ILLINOIS
TIERED APPROACH TO CORRECTIVE
)
Pollution Control Board
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
NOTICE
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
(Via First Class Mail)
Matt Dunn
Environmental Bureau Chief
Office of the Attorney General
James R. Thompson Center
100 W. Randolph, 12`h Floor
Chicago, Illinois 60601
(Via First Class Mail)
(Service List-Via First Class Mail)
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board the Agency'sSUPPLEMENTAL TESTIMONY OF
GREGORY DUNN, THOMAS HORNSHAW, AND LAWRENCE EASTEP and the
Agency's MOTION TO CORRECT THE TRANSCRIPT, a copy of each of which is
herewith served upon you
.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Kimberly
. Geving
Assistant ounsel
Division of Legal Counsel
DATE: February 17, 2006
Bill Richardson, General Counsel
Illinois Dept . of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
(Via First Class Mail)
Richard R. McGill, Jr .
Ill. Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite 11-500
Chicago, Illinois 60601
(Via First Class Mail)
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK'S OFFICE
FEB 21 2006
TIERED APPROACH TO CORRECTIVE )
ACTION OBJECTIVES: AMENDMENTS)
TO 35 Ill. Adm. Code 742
)
MOTION TO CORRECT THE TRANSCRIPT
NOW COMES the Illinois Environmental Protection Agency ("Agency") by one
of its attorneys, Kimberly A . Geving, and pursuant to 35 Ill. Adm. Code 101.604 moves
the hearing officer in this matter to correct the transcript of January 31, 2006 as follows :
IN THE MATTER OF
:
R06-10
(Rulemaking-Land)
1
STATE OF
ILLINOIS
Pollution Control Board
Paee
Line
Correction
3
22
Change "post" to "posed"
11
15
Change "modeled" to "model"
24
2
Change "states" to "sites"
27
8
Change "9061(a)" to "9060(a)"
27
22
Change "organ" to "organic"
28
4
Change "organ" to "organic"
28
5
Change "organ" to "organic"
28
11
Change "organ" to "organic"
28
13
Change "9060" to "9060(a)"
28
23
Delete the word "no"
44
11
Change "risk base" to "risk-based"
47
24
Change "three" to "there"
50
23
Insert "or" between "ingestion" and "inhalation"
55
3
Change "abbreviation" to "remediation"
55
12
Change "of' to "to"
56
14-15
Add a comma after "where" in line 14 and a comma after
64
19
"compound" in line 15, delete the period in 15, and make
the "the" lower case
Change "pHs" to "PARs"
77
2
Change "vain" to "vein"
90
17
Change "appendix D" to "appendix B"
Dated : February 17, 2006
1021 North Grand Ave. East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
2
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
B
j
/
IZAIJ611W
Kimberl A. Geving
Assistan Counsel
Division of Legal Counsel
THIS FILING IS SUBMITTED ON RECYCLED PAPER
IN THE MATTER OF
:
BEFORE THE ILLINOIS POLLUTION CONTROL BQ
12DC E 1 V E
ti
CLLERK'S OFFICE
FEB 21 2006
R06-10
STATE OF
ILLINOIS
(Rulemaki0g
tiEnan
C~pntrol Board
PROPOSED AMENDMENTS TO
)
TIERED APPROACH TO CORRECTIVE
)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
PRE-FILED SUPPLEMENTAL TESTIMONY
OF GREGORYW.DUNN
The Illinois Environmental Protection Agency (Agency) would like to provide a
response to questions raised during the January 31, 2006 Proposed Amendments to
Tiered Approach to Corrective Action Objectives (TACO) hearing concerning acceptable
detection limits (ADLs). One of the issues identified by the Illinois Association of
Environmental Laboratories (IAEL) consists of remediation objectives identified in
TACO that cannot be met with USEPA SW-846 test methods, routinely used by
environmental laboratories. Although a different SW-846 method could be used at a
higher cost to a laboratory client, the IAEL stated an ADL should be added for those
compounds where the routinely used SW-846 method cannot reach the soil and/or
remediation objective
.
The Agency is aware there are compounds for which the routinely used methods
cannot meet their respective remediation objectives established in TACO but believes
mechanisms already exist in TACO to evaluate these compounds
.
At this time, the
Agency does not anticipate providing any additional ADLs for compounds in TACO
.
The following provides an explanation of why the Agency will not propose additional
ADLs .
1
The Tier 1 remediation objectives established in Appendix B, Table A for residential
properties and Appendix B, Table B for industrial/commercial properties are numerical
concentrations representing a level of contamination at or below which there are no
human health concerns for the designated land use. As stated in the Illinois Pollution
Control Board's (Board) Opinion and Order of the Board dated April 17, 1997, the Tier 1
remediation objectives for individual chemical contaminants do not exceed an excess
cancer risk of 1 in 1,000,000 (or 1 x 10" 6) for carcinogens, or a hazard quotient of 1 for
non-carcinogens. The Agency contends the current remediation objectives identified in
TACO represent a concentration at which there are no human health concerns . The
Agency also contends that if a laboratory detection limit exceeds a risk-based remediation
objective for a certain chemical identified in TACO, there are numerous ways a person
can achieve compliance
:
1 . A Tier 2 evaluation can be completed on the contaminant of concern to achieve a
higher remediation objective for that compound . Equations in Appendix C, Table
A and Appendix C, Table C allow the use of site-specific information to
determine a site-specific remediation objective for the route (ingestion, inhalation,
soil migration to groundwater or groundwater ingestion) of concern
.
2. A Tier 3 option is also available, allowing a person to provide information to the
Agency documenting the exposure route of concern is not complete, the
remediation of this compound above the established remediation objective is
impractical, or any other situation allowed pursuant to Section 742.900 .
3. The exposure route of concern can be excluded pursuant to the requirements of
Sections 742.310, 742.315, or 742 .320. The use of institutional controls
(Environmental Land Use Controls, Highway Authority Agreements,
2
Groundwater Ordinances, etc .) or engineered barriers can be used to exclude the
route of concern.
4. An argument could be made to the Agency stating the chemical with the detection
limit exceeding the established remediation objective in TACO is not a
contaminant of concern at the site. The argument must include reasons why the
chemical would not be a contaminant of concern .
5. The Remediation Applicant, owner/operator, or anyone else using TACO could
petition the Illinois Pollution Control Board to request the use of an adjusted
standard pursuant to Section 28.1 of the Environmental Protection Act
.
In summary, the Agency understands there are compounds for which routinely used
methods cannot meet their respective remediation objective established in TACO, and the
Agency does not anticipate adding additional ADLs to the Tier 1 tables in TACO
.
This concludes my testimony .
THIS FILING IS SUBMITTED ON RECYCLED PAPER
3
BEFORE THE ILLINOIS POLLUTION CONTRO
IV E D
OFFICE
FEB 21 2006
STATE OF ILLINOIS
Pollution Control Board
IN THE MATTER OF :
)
PROPOSED AMENDMENTS TO
)
TIERED APPROACH TO CORRECTIVE
)
ACTION OBJECTIVES
)
(35 Ill. Adm. Code 742)
)
R06-10
(Rulemaking - Land)
PRE-FILED SUPPLEMENTAL TESTIMONY OF
THOMAS C. HORNSHAW, Ph.D.
This supplemental testimony is in response to two issues concerning chemical analysis
that arose during the first hearing in the above-captioned matter
.
The first issue concerns the
proposal in my testimony to list as an incorporation by reference a website citation for the
USEPA's SW-846 analytical methods (which is updated periodically) instead of a date-.certain
document, as required by the Illinois Administrative Procedures Act (5 ILCS 100). Upon further
consideration, it is now the Agency's belief that
such incorporation by reference
is not
appropriate ; therefore, I ask that this proposal be withdrawn from the record in this proceeding
.
The second issue pertains to the appropriateness of footnote "f' in Appendix B, Tables A
and B. In response to the Board's questions about whether this footnote, which reads
"Level is
at or below Contract Laboratory Program required quantitation limit
for Regular Analytical
Services (RAS)," is appropriate in regard to the Acceptable Detection Limits (ADLs) defined in
TACO, I researched some details of the Contract Laboratory Program (CLP)
.
In this research, I
reviewed the USEPA publication "User's Guide to the Contract Laboratory Program" (Office
of
Emergency and Remedial Response, Washington, DC. NTIS PB91-921278CDH, January 1991),
and discussed the CLP with Gary Germann and Celeste Crowley of the Agency's Division of
Laboratories
.
The CLP was developed to provide USEPA's Superfund Program with consistent
physical and chemical analytical data of known quality, and with a fast turnaround time .
It
contains two levels of analytical services, RAS and Special Analytical Services (SAS). RAS
consists of a standardized list of analytical procedures addressing a selected group of analytes,
the Target Compound List (TCL), and also specifies quality control criteria and detection limits
that must be achieved by participating laboratories . The RAS methods are used for water, soil,
and sediment samples. SAS addresses procedures and circumstances that fall outside the scope
of RAS (e.g., faster turnaround or lower detection limits for TCL chemicals than specified for
RAS, analysis for non-TCL chemicals, or matrices other than water, soil, and sediment)
.
It
should be noted that the detection limits specified for RAS methods do not in all cases
correspond to detection limits specified in SW-846 methods addressing the same chemical . For
example, the RAS detection limits in soil for several polycyclic aromatic hydrocarbons (PAHs
are set at 330 ug/kg, whereas the corresponding PAH detection limits from Method 8270 are 660
ug/kg .
The PAH example was chosen purposefully, since it helps illustrate the Agency's
longstanding desire to ensure cleanup levels that are at or as close as possible to the risk-based
values. In the case of the carcinogenic PAHs benzo(a)pyrene and dibenzo(a,h)anthracene, even
the lower RAS soil detection limit still exceeds the residential risk-based soil objective of 90
ug/kg .
As I stated at the first hearing in response to questioning about ADLs, when the risk-
based objectives for PAH cleanups became effective, the Agency required that SW-846 Method
8310 be used for PAH cleanups since the detection limits for this Method for the carcinogenic
2
PAHs were lower than the risk-based cleanup levels
.
The Agency decided to force the use of
this Method, even though it was not widely available at commercial laboratories
at that time, in
order to drive cleanups as close to risk-based values as possible
.
Regarding the appropriateness of footnote
"f," in light of the above discussion the
Agency now believes that this footnote is not appropriate to the TACO soil objective tables .
This footnote was included in the initial version of TACO because it was one of the
footnotes
included in the table of generic USEPA Soil Screening Guidance soil objectives; the Agency
included the footnote because it was our intention to make the TACO rule
as similar to the
USEPA Soil Screening Guidance as possible
.
Since the RAS detection limits are not in some
cases consistent with the Agency's goal of trying to make cleanup objectives as close to the risk-
based concentrations as possible, we are now proposing to delete all references to footnote 'P' in
the TACO soil objective tables .
The proposed specific changes are included in Errata Sheet
Number 3 .
This concludes my supplemental testimony on analytical issues
.
THIS FILING IS SUBMITTED ON RECYCLED PAPER
3
PRE-FILED SUPPLEMENTAL TESTIMONY
OF LAWRENCEW.EASTEP, P.E .
During the January 31, 2006 hearing, several questions were raised by the Board
that require further discussion. Those questions were in regards to the applicability of
TACO, why the polynuclear aromatic hydrocarbon (PNA) background values were
included as footnotes in Appendix B, Tables A and B and linked to a new table, and
whether new appendices D, E, F, and H should be models or mandatory forms . I will
address each of those questions in the order in which they appear in the rules
.
First of all, there were a number of question at hearing as to whether the changes
in the first and second lines of Section 742.105(a) expanded the scope of TACO . The
purpose of these changes was not to expand the scope of TACO ; rather, it was to make
explicit those considerations that were already implicit from the structure of TACO
.
The scope of TACO does go beyond the specific programs listed in Section
742.105(b). In the original hearings on December 2, 1996, there was testimony relative
to whether sites other than those entered in the listed programs could utilize TACO . Mr .
King discussed how sites under enforcement (see December 2, 1996 transcript p . 76, lines
17-24 and p. 81) and how sites responding to some emergency release (Id. at 80) could
.
use the TACO rules. However, because the proposed new language in the first and
1
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDLERK'S OFFICE
IN THE MATTER OF
:
)
FEB 2 1 2006
TIERED APPROACH TO CORRECTIVE
)
R06-1 0
STATE OF ILLINOIS
Pollution Control Board
ACTION OBJECTIVES: AMENDMENTS)
(Rulemaking-Land)
TO 35 IIl. Adm. Code 742
)
second lines of Section 742 .105(a) raised some confusion rather than clarifying the intent,
we now propose to delete the new language in the first two lines
.
Landfills were also discussed in 1996, and Mr . King stated that while it might not
be practical for landfills to try to use TACO, if they had complied with their other
regulatory obligations and were not prohibited by Section 58 .1(a)(2) of the Act, they may
be able to use TACO. Therefore, the intent behind the second change to Section
742.105(a) was to make it explicit that landfills could not use TACO in lieu of
requirements under 35 Ill. Adm. Code 807 or Parts 811-814
.
Also at the January 31, 2006 hearing, questions were raised as to why the
polynuclear aromatic hydrocarbon (PNA) background values were included as footnotes
in the Tier I and Tier 2 tables and linked to a new table. The Board asked whether the
PNA background numbers could have been incorporated as part of Sections 742 .405 and
742.415 - Determining Area Background. Questions were also raised as to the risk posed
by the PNAs and whether the PNAs posed an acute threat .
The purpose of incorporating the new PNA numbers as footnotes directing the
reader to a new table was to avoid the "area background" connotation. In the original
legislation, the concept of "area background" was needed to ensure persons remediating
sites were not required to clean up to levels lower than "background" while at the same
time protecting the public from increased levels of risk . This made sense when referring
to regulated substances in the vicinity of a site or an area local to the site. For example,
the steelmaking industry was prevalent around Granite City, southeast Chicago, and a
0
few other areas around the State . In the general area of these steel mills, slag was
frequently used for construction purposes, and regulated substances may have been
2
dispersed as a result of air emissions . Thus, many sites in the area of these mills would be
expected to be contaminated by releases from the mills . Section 58.5 of the Act states that
these sites do not have to clean up beyond what is considered "area background ."
However, the Act goes on to state that these sites can't be converted to residential use
unless the contamination meets risk-based residential standards. Thus, even though a site
might not have to be cleaned up to below background, it still can't cause the residents to
be subjected to excess risk .
In the original hearings on this matter in 1996, there was a lot of testimony on this
particular issue. This testimony revolved around the "area" concept and when and under
what conditions it might apply. Even though there was a subset of the area background
provisions dealing with "statewide approach," it was not really the same since, except for
arsenic (for which there was a subsequent rule amendment), there were no regulated
substances that existed at background levels greater that TACO Tier 1
.
Thus, if a site met
background, it did not have to worry about Tier 1 since all of the background levels
except for arsenic were below Tier 1 . Likewise, if it met Tier 1, background had no
significance. In the case of arsenic there was documentation that background levels were
greater than the 10'6 level statewide, and this meant that basically no site could meet the
arsenic standard. Arsenic was found to be present everywhere above the Tier 1 residential
objectives . It was in residential areas, natural areas, and many other uncontaminated
areas. The Agency determined that even though arsenic was above Tier 1 objectives, it
poses no additional (incremental) excess risk over what the public is exposed to every
.
day. The Agency dealt with arsenic by removing the Tier 1 objective and replacing it
with a footnote that directed the reader to the background table . The footnote did not
reference Section 742.405(b), nor was Table G limited to use with Section 742 .405(b) .
Thus, arsenic was not characterized as "area background" since it was a statewide
phenomenon and did not fit the statutory concept of area background
.
The Agency has proposed much the same with the PNAs . They are not
appropriate for "area background" since they are not being determined as part of some
local area around a site. PNAs have a statewide presence that residents are exposed to
everyday. The studies used for this rulemaking did not investigate all of the State, only
those locations in "populated" areas; however, the locations sampled did occasionally
extend out to relatively rural areas
.
The area background provisions also contain a prohibition from converting the
site to residential use. The Act and existing rules were written on the premise that there is
some sort of industrial nature to existing sites in these circumstances . However, the
background studies used only sites not impacted by industrial releases of PNAs
.
Therefore, there should be no assumption that these sites are contaminated. Many sites
undergoing remediation in the SRP are not necessarily industrial in nature to begin with
(e.g., commercial sites with historically contaminated fill, spill clean ups, etc .). Thus, the
"area background" concept does not apply, and these sites are not automatically subject
to Subpart D. As an aside, however, if a remedial applicant so chooses, Subpart D could
be used to determine a true "area background" for a site
.
It was suggested at the first hearing in this matter that another way of dealing with
high levels of PNAs would have been to make a site-specific determination that the PNAs
were not a constituent of concern. This might be an option at some sites, but it may not
4
be practical for many sites since there is not enough information to make a site-specific
determination to exclude PNAs, or there may be historical amounts present at the site
.
The proposed amendments should have no impact in terms of excess risk to
residential users of remediated sites . Since the studies have shown PNAs to be ubiquitous
in Illinois, the use of a statewide background does not fit the concept of "area
background" provided in the Act and current rules . "Area background" was intended to
address specific areas contaminated by local activities of industry
. The residential
conversion prohibition is not relevant in these cases because there is no increase in risk to
people. Adopting the proposed amendments will encourage additional cleanup efforts
because the PNA issue has been an impediment to some cleanups . In some cases, the cost
to clean up PNAs that are not necessarily a constituent of concern can be excessively
high. The amendments would eliminate such hindrances
.
The third area that requires further discussion revolves around the Agency's
inclusion of new appendices D, E, F, and H. The Board questioned whether those new
forms should be used as models or whether their form and substance should be
mandatory, as proposed by the Agency. There was some discussion regarding who
would fill out the forms and whether it would be considered the practice of law to fill out
the forms .
The Agency contends that filling out the forms exactly as they are proposed in the
rules does not constitute the practice of law . The forms were prepared by Agency
attorneys to meet the four corners of the law, and simply having members of the
regulated community fill in the blanks with site specific information does not require any
legal expertise, nor does the Agency believe it constitutes the practice of law
. Forms are
.
5 '
widely used in every aspect of government and filled out by members of the public
without being classified as "the practice of law." The Agency sees no difference with
requiring these forms .
This concludes my supplemental testimony
.
THIS FILING IS SUBMITTED ON RECYCLED PAPER
6
STATE OF ILLINOIS
)
COUNTY OF SANGAMON
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached
SUPPLEMENTAL TESTIMONY OF GREGORY DUNN, THOMAS
HORNSHAW, AND LAWRENCE EASTEP and the Agency'sMOTION TO
CORRECT THE TRANSCRIPT upon the persons to whom they are directed, by
placing a copy of each in an envelope addressed to :
Dorothy Gunn, Clerk
Bill Richardson, General Counsel
Illinois Pollution Control Board
Illinois Dept. of Natural Resources
James R. Thompson Center
One Natural Resources Way
100 W. Randolph, Suite 11-500
Springfield, Illinois 62702-1271
Chicago, Illinois 60601
(Via First Class Mail)
(Via First Class Mail)
Matt Dunn
Richard McGill
Environmental Bureau Chief
Illinois Pollution Control Board
Office of the Attorney General
100 W. Randolph St
.
James R. Thompson Center
Suite 11-500
100 W. Randolph, 12`h Floor
Chicago, Illinois 60601
Chicago, Illinois 60601
(Via First Class Mail)
(Via First Class Mail)
(Service List-Via First Class Mail)
and mailing them from Springfield, Illinois on February 17, 2006, with sufficient postage
affixed as indicated above .
SUBSCRIBED AND SWORN TO BEFORE ME
This
17th_ day of
February, 2006 .
41
`~/!/ ',,A .
\ ..JAI
l.
OFFICIAL SEAL
BRENDA BOEHNER
$
NOTARY PUBLIC, STATE OF IWNO S {
IV COMMISSION EXPIRES 11 .3.2009
2
THIS FILING SUBMITTED ON RECYCLED PAPER
Printing Service List . . . .
Page 1 of 3
http://www.ipcb.state.il.us/cool/external/casenotifyNew.asp?caseid=1275 1¬ifytype=Se
. .. 2/17/2006
'
Party Name
Role
City & State
Phone/Fax
217/782-
I-EPA
1021 North Grand Avenue East Springfield
5544
Petitioner
P.O. Box 19276
IL 62794-9276
217/782-
9807
Kimberly A. Geving, Assistant Counsel
Annet Godiksen, Legal Counsel
217/523-
Hodge DwyerZeman
3150 Roland Avenue
Springfield
4900
Interested Party
Post Office Box 5776
IL 62705-5776 217/523-
4948
Christine G. Zeman
Karen L . Bernoteit
Katherine D. Hodge
Thomas G . Safley
312/853-
Sidley Austin LLP
Chicago
7000
Interested Party
One South Dearborn
IL 60603
312/853-
7036
William G. Dickett
EPI
Interested Party
16650 South Canal
South Holland
IL 60473
Bob Mankowski
217/523-
Illinois Environmental Regulatory
Springfield
4942
Group
3150 Roland Avenue
IL 62703
217/523-
Interested Party
4.948
Katherine D . Hodge, Executive Director
Thomas G . Safley
DesPlaines
Chemical Industry Council of Illinois
2250 E. Devon Avenue
Interested Party
Suite 239
IL 60018-4509
Lisa Frede
312/853-
Bellande & Sargis Law Group, LLP
19 South LaSalle Street
Chicago
8188
Interested Party
Suite 1203
IL 60603
312/782-
0040
Mark Robert Sargis
The Lammert Building,
7th
St. Louis
314/23
.1-
The Stolar Partnershi
,
Floor
MO 63101-
2800
Interested Party
911 Washington Avenue
1290
314/436-
8400
Musette H. Vogel
217/788-
Hanson Engineers, Inc
.
Springfield
2450
Interested Party
1525 South Sixth Street
.
IL 62703-2886 217/788-
2503
Tracy Lundein
773/380-
Conestoga-Rovers & Associates
8615 West Bryn Mawr Avenue
Chicago
9933
Interested
Party
IL 60631
773/380-
6421
Douglas G. Soutter
312/814 -
http://www.ipcb.state .il.us/cool/external/casenotifyNew.asp?caseid=1275 1 ¬ifytype=Se . .. 2/17/2006
Printing Service List . .
. .
Page 2 of 3
2550
Office ofthe Attorney General
Environmental Bureau
Chicago
312/814-
188 West Randolph, 20th Floor IL 60601
Interested Party
2347
Matthew J. Dunn, Division Chief
847/688-
Naval-Training Center
Great Lakes
4422
Interested Party
2601A Paul Jones Street
IL 60088-2845 847/688-
6917
Georgia Vlahos
312/814-
IllinoisPollution_ Control Board
100 W. Randolph St .
Chicago
3620
Interested Party
Suite 11-500
IL 60601
312/814-
3669
Dorothy M. Gunn, Clerk of the Board
Richard McGill, Hearing Officer
Commonwealth Edison
10 South Dearborn Street
Chicago
Interested Party
35FNW
IL 60603
Diane H. Richardson
Clayton GroupServices
Downers Grove
3140 Finley Road
Interested Party
IL 60515
Monte Nienkerk
Weaver Boos & Gordon
Springfield
2021 Timberbrook Lane
Interested Party
IL 62702
Elizabeth Steinhour
Andrews Environmental Engineering
Springfield
3535 Mayflower Boulevard
Interested Party
IL 62711
Mark Marszalek
Graef_Anhalt Schloe_mer &_ Associates
Chicago
IL 60631-2801
8501 West Higgins Road
Inc .
Suite 280
Interested Party
Dr. Douglas C. Hambley, P.E ., P.G
.
Midwest Engineerinq Services
Oak Forest
4243 West 166th Street
Interested Party
IL 60452
Erin Curley, Environmental Dept. Manager
Missman Stanley & Associates
333 East State Street
Interested Party
1rd
IL
IL
61
61110-0827
John W. Hochwarter
Jeffrey Larson
Trivedi Associates, Inc.
Naperville
2055 Steeplebrook Court
Interested Party
IL 605
IL 60565
Chetan Trivedi
217/782-
Illinois Department of Natural
Springfield
1809
Resources
One Natural Resources Way
IL 62702-1271
217/524-
Interested Party
9640
Stan Yonkauski
William Richardson, Chief Legal Counsel
Hillside
708-544-
an Laboratories,_ Inc .
_S_uburr
Interested Party
4140 Litt Drive
IL 60162
3260
Jarrett Thomas, V .P
.
Illinois_DeoartmentDTransportation
2300 S. Dirksen Parkway
Springfield
Interested Party
Room 330
IL 62764
Total number of participants : 38
http://www.ipcb.state.il.us/cool/external/casenotifyNew.asp?caseid=12751¬ifytype=Se
. . .
2/17/2006 -
Printing Service List
.
.
.
.
Page 3 of 3
Steven Gobelman
Thomas Benson
Mc__G_uire_Woo_ds LL_P_
77 W. Wacker
Chicago
312/849-
Interested Party
Suite 4100
IL 60601
8100
David Rieser
Reott LawOffices-,LC
35 East Wacker Drive
Chicago
Interested Party
Suite 650
IL 60601
Raymond T. Reott
Jorge T. Mihalopoulos
Chicago Department o_f_Law
30 N. LaSalle Street
Chicago
Interested Party
Suite 900
IL 60602
Charles A. King, Assistant Corporation Counsel
SRAC
2510 Brooks Drive
Interested Party
Harry Walton
Decatur
IL 62521
