BEFORE THE ILLINOIS POLLUTION CONTROL BOARD RECEIVED

CLERK'S OFFICE

IN THE MATTER OF

:

)

MAY 1 0 2006

PROPOSED AMENDMENTS TO

)

STATE OF

ILLINOIS

REGULATION OF PETROLEUM

)

R 04-22 (B)

Pollution Control Board

LEAKING UNDERGROUND STORAGE

)

(UST Rulemaking )

TANKS (35 ILL. ADM. CODE 732)

)

IN THE MATTER OF :

)

PROPOSED AMENDMENTS TO

)

REGULATION OF PETROLEUM

)

R 04-23(B)

LEAKING UNDERGROUND STORAGE

)

(UST Rulemaking )

TANKS (35 ILL. ADM. CODE 734)

)

Consolidated

NOTICE OF FILING

Dorothy Gunn, Clerk

Marie Tipsord

Illinois Pollution Control Board

Illinois Pollution Control Board

James R. Thompson Center

James R. Thompson Center

100 W. Randolph, Suite 11-500

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

Chicago, Illinois 60601

SEE ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that today I have filed with the Office of the Clerk of the

Illinois Pollution Control Board the Post-Hearing Comments of the Illinois Environmental

Protection Agency for the March 23, 2006, Hearing, a copy of which is herewith served upon

you .

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY

By : ~R .-

Kyle'Rominger

-

Assistant Counsel

Date :

May 8, 2006

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

---

RECeIVI

ED

IN THE MATTER OF

:

)

MAY 10 2006

PROPOSED AMENDMENTS TO

)

P STATE

ollution OF ILLINOIS

Control Board

REGULATION OF PETROLEUM

)

R 04-22 (B)

LEAKING UNDERGROUND STORAGE )

(UST Rulemaking )

TANKS (35 ILL. ADM. CODE 732)

)

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF

:

)

PROPOSED AMENDMENTS TO

)

REGULATION OF PETROLEUM

)

R 04-23(B)

LEAKING UNDERGROUND STORAGE

)

(UST Rulemaking )

TANKS (35 ILL. ADM. CODE 734)

)

Consolidated

POST-HEARING COMMENTS OF THE ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY FOR THE MARCH 23, 2006, HEARING

NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA"), by

and through one of its attorneys, Kyle Rominger, and submits the following post-hearing

comments for the March 23, 2006, hearing. The comments are divided into three

sections. The first section reviews the Illinois EPA's proposed revisions to the scope of

work for the lump sum payment amounts, its personnel/time breakdown for the scope of

work, and its proposed amendments to Sections 732 .845 and 734.845. Included in this

first section are some revisions that were not included in the Illinois EPA's previous

submissions. The second section of these comments reviews the amounts allowed for

professional consulting services under proposed Sections 732 .845 and 734.845. The third

section contains comments on specific issues raised in pre-filed testimony and the March

23, 2006, hearing

.

---

Some of the issues continuing to be raised in this Docket B, such as requiring She

Illinois EPA to develop and administer a cost database or to develop and use what

amounts to unpublished rate sheets, were raised and addressed in the Docket A portion of

this rulemaking. The Illinois EPA's positions on these issues has not changed . In the

interest of brevity, these issues will not be re-addressed in these comments except as

noted below .

Illinois EPA's Proposed Scope of Work Revisions, Personnel and Time

Breakdown, and Amendments to Sections 732 .845 and 734.845

As the Board requested, the Illinois EPA reviewed the Board's proposed scope of

work for the professional consulting services lump sum payment amounts and submitted

proposed revisions to the scope of work . See Exh. 116 (First column of Attachments I

and 2). The Illinois EPA also provided the requested breakdown of the personnel and

time needed to complete the scope of work. See Id. (Second and third columns of

Attachments 1 and 2). In the Illinois EPA's personnel/time breakdown all hours are

rounded up, and each personnel title listed is the highest paid title that would be

reasonable for the work being performed .

After reviewing the testimony pre-filed for the March 23, 2006, hearing, the

Illinois EPA proposed additional revisions to the scope of work and revised its

personnel/time breakdown to address some of the issues and concerns raised in the

testimony. These revisions were submitted at the hearing as Exhibits 117 and 118. The

lump sum payment amounts derived from the personnel/time breakdown were included

in the proposed amendments to Sections 732 .845 and 734.845 submitted as exhibits 121

2

---

and 1.22.' The lump sum payment amounts included in proposed Sections 732 .845 and

734.845 are based on the highest hourly rates allowed for each personnel title listed in the

Illinois EPA's personnel/time breakdown. As noted by Doug Clay, the Illinois EPA

often sees work performed by persons with lower pay rates than the titles assigned in the

Illinois EPA's personnel/time breakdown ; for example, a "Scientist" or "Technician"

often performs work that is assigned the title of "Project Manager" under the Illinois

EPA's personnel/time breakdown. Exh. 116 at 4; Tr. of March 23, 2006, hearing at 16-

17, 18-19 .

The proposed revisions to Section 732 .845 and 734.845 also included the

following changes to, inter alia, address comments and concerns raised in pre-filed

testimony :

1)

The addition of half-day unit rates for early action field work and field

oversight that was previously included in the lump sum for the preparation

and submission of the 20 and 45 Day reports. See Exhs. 121 (proposed

Sections 732.845(a)(2)(A), (B), and (F)) and 122 (proposed Sections

734.845(a)(2)(A), (B), and (F)). Moving this work to unit rates provides

consistency with other field work and field oversight

.

2)

The addition of language clarifying that costs associated with the

monitoring and mitigation of fire, explosion, and vapor hazards are to be

reimbursed on a time and materials basis . See Exhs. 121 (proposed

Section 732.845(a)(4)) and 122 (proposed Section 734 .845(a)(4)) .

Because these situations are rarely encountered, the Illinois EPA

anticipated that these costs could be addressed under the unusual or

extraordinary circumstances provisions of Sections 732 .860 and 734.860 .

This change helps clarify that the costs will be reimbursed on a time and

materials basis

.

3)

The addition of a lump sum payment amount for costs associated with

obtaining access to off-site properties that exceed the applicable

remediation objectives. See Exhs. 121 (proposed Section 732.845(d)(3))

'

The base text for the Illinois EPA's proposed revisions to Sections 732.845 and 734.845 is the text of

Sections 732 .845 and 734.845 as revised by the amendments proposed in the Board's January 6, 2006,

Opinion and Order. The Illinois EPA's proposed revisions to this base text are indicated by double

underline and double strike through

.

3

---

and 122 (proposed Section 734.845(b)(7)). The "best efforts" required, in

obtaining off-site access are set forth in 35 Ill . Adm. Code 732.411 and

734.350 .

4)

The addition of a lump sum payment amount for costs associated with the

preparation and submission of the Stage 3 site investigation plan . See

Exh. 122 (proposed Section 734.845(b)(5)). Providing a lump sum

payment amount for the Stage 3 site investigation plan provides

consistency with the corresponding site investigation plan under Part 732,

the high priority off-site investigation plan, and with other plans and

reports subject to lump sum payment amounts. Like the high priority off-

site investigation plan and the other plans and reports, the preparation and

submission of the Stage 3 site investigation plan is relatively standard . It

is not subject to such variability that payment on a time and materials

basis is necessary. Therefore, providing payment on a lump sum basis is

reasonable

.

In addition to the above, the Illinois EPA proposes the following new revisions to

address hours related to the preparation and submission of applications for payment for

site investigation costs . These revisions were inadvertently left out of the Illinois EPA's

earlier submissions .

1)

Consistent with the time allowed for applications for payment of site

investigation costs under Part 734, the Illinois EPA proposes to add eight

hours of Account Technician time to the work included under "Section

732.845(d)(1)(B) Preparation and submission of investigation plans for

off-site contamination for sites classified pursuant to 732 .307." This

change is shown on page 19 of Attachment A to these comments under

item 4 and new item 5 of "Section 732 .845(d)(1)(B) Preparation and

submission of investigation plans for off-site contamination for site

classified pursuant to 732 .307."

This change increases the lump sum payment amount for the preparation

and submission of off-site investigation plans under Section

732.845(d)(1)(B) from $3,650 to $4,090 . This increase is reflected in

Attachments C through F to these comments, which contain revised

summaries of the lump sum payment amounts and revised Sections

732.845 and 734.845

.

2)

Consistent with the above change and the time allowed for applications for

payment of site investigation costs under Part 734, the Illinois EPA

proposes to add eight hours of Account Technician time to the tasks listed

under "Section 732.845(d)(5) Preparation and submission of corrective

4

---

action plan (Conventional Tech) ." This change is shown on page 21 of

Attachment A to these comments under item 7 and new item 8 of "Section

732.845(d)(5) Preparation and submission of corrective action plan

(Conventional Tech)." Please note that if off-site investigation is not

required, and therefore no off-site investigation plan is submitted, these

hours will apply to the preparation and submission of the application for

payment of on-site investigation costs instead of off-site investigation

costs .

This change increases the lump sum payment amount for the preparation

and submission of conventional technology corrective action plans from

$5,230 to $5,670. This increase is reflected in Attachments C through F to

these comments .

3)

In addition to the above, the Illinois EPA proposes to amend the scope of

work for Part 734 to reflect the fact that the application for payment

addressed in line 7 of "Section 734.845(b)(9) Preparation and submission

of site investigation completion report" may not always be for costs

associated with the Stage 3 site investigation . The application for payment

will be for costs associated with a Stage 3 site investigation if a Stage 3

investigation is required . However, if a Stage 3 investigation is not

required, the application for payment will be for costs associated with the

Stage 2 investigation. Likewise, if a Stage 2 investigation is not required,

the application for payment will be for costs associated with the Stage 1

investigation. This revision is included on page 13 of Attachment B to

these comments. This revision does not cause a change in the lump sum

payment amounts

.

II . Amended Sections 732.845 and 734.845

As noted above, the lump sum payment amounts in the Illinois EPA's proposed

amendments to Sections 732 .845 and 734 .845 are based upon the highest pay rate for

each personnel title identified in the Illinois EPA's personnel/time breakdown. Under the

proposed amendments to Section 734 .845, the lump sum payment amounts alone provide

up to $27,795 for professional consulting services . In addition to the lump sum payment

amounts, proposed Section 734.845 provides the following on a unit rate basis

:

1)

Up to $1,170 for early action site visits. (proposed Sections

734.845(a)(2)(A), (B), and (F)) ;

2)

Up to $3,900 to oversee tank removal. (Section 734 .845(a)(2)(C)) ;

5

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basis :

3)

$390 to oversee a tank line repair . (Section 734.845(a)(2)(E)) ;

4)

$390 for each 225 cubic yards of soil, or fraction thereof, removed and

disposed of. (Sections 734.845(a)(2)(C) and (c)(2)(A)) ;

5)

$390 for every four borings that are drilled . (Sections 734.845(a)(2)(D),

(b)(2)(A), (b)(4)(A), (b)(6)(A), and (d)(1)(A));

6)

$390 for each half-day of free product removal oversight . (Section

734.845(a)(6)) ;

7)

$925 for each free product removal report . (Section 734.845(a)(7)) ;

8)

$390 for each monitoring well installed . (Sections 734.845(b)(2)(B),

(b)(4)(B), (b)(6)(B), and (d)(1)(B)) ;

9)

$400 for each off-site property requiring access. (proposed Section

734.845(b)(7))

;

10)

$800 for each Environmental Land Use Control and Highway Authority

Agreement. (Section 734.845(c)(3)); and

11)

Up to $300 per day for travel. (Section 734.845(e)) .

Section 734.845 also allows payment for the following on a time and materials

1)

Costs associated with monitoring and mitigating fire, explosion, and vapor

hazards. (proposed Section 734 .845(a)(4)) .

2)

Costs associated with the preparation and submission of free product

removal plans. (Section 734.845(a)(5))

.

3)

Costs associated with the installation of free product removal systems

.

(Section 734.845(a)(5))

.

4)

Costs associated with the preparation and submission of alternative

technology corrective action plans . (Section 734 .845(c)(1)) .

5)

Costs associated with alternative technology field work and field oversight

(e.g ., installation, operation, maintenance, etc.). (Section

734.845(c)(2)(B))

.

6

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• There have been arguments raised that Sections 732 .845 and 734.845 must

provide the same amount of payment as allowed in the past in order to be considered

reasonable. The Environmental Protection Act does not require payments from the Fund

to equal or exceed amounts paid in the past in order to be considered reasonable

.

However, the payment amounts provided under Sections 732 .845 and 734 .845 are

consistent with the amounts paid in the past. According to UST's additional testimony

submitted at the March 23, 2006, hearing, "[i]t is a fact, based upon USI's analysis of the

costs data related to the 69 sites that it reviewed in the summer of 2005[,] that the

historical costs of professional consulting services averages approximately twenty eight

percent (28%) of the total amount reimbursed per site." Exh. 129 at 9. As Doug Clay

testified in Docket A, the average total amount paid per site for sites closed during the

years 1997 through 2001 was the following

:

Year incident closed

7

Average of total amount paid per incident

Exh. 88 at 16-17. Based upon USI's analysis showing that professional consulting

services account for approximately 28% of the total costs paid per site, the average

amounts paid for professional consulting services during the years 1997 through 2001

ranged from $21,213 to $26,798 . The average paid for professional consulting services

over all of these years would have been approximately $24,233

.

The proposed lump sum payment amounts alone exceed the above historical

averages. The lump sum payment amounts can be considered the "base" amount allowed

for professional consulting services . Added to this base amount are all of the payments

1997

$86,266

1998

$95,707

1999

$82,819

2000

$75,759

2001

$92,190

---

provided on either a unit rate or a time and materials basis, such as the payments allowed

for costs associated with tank pulls, early action site visits, free product recovery, free

product removal reports, soil borings, monitoring well installations, soil excavation and

disposal, alternative technologies, travel, off-site property access, and institutional

controls

.

Like the rest of Subpart H, proposed Sections 732 .845 and 734.845 are structured

in a manner that allows payment from the Fund to be tailored to site-specific

circumstances . The lump sum payment amounts provide a base amount for work that is

relatively standard from site to site and where it is reasonable to assign lump sums

. The

payments amounts provided on a unit rate or a time and materials basis provide the

flexibility needed to address work that may vary more greatly from site to site and where

lump sums cannot easily be assigned. The Illinois EPA believes that the payment

amounts allowed under in proposed Sections 732 .845 and 734.845 will provide

reimbursement of reasonable costs for professional consulting services

.

III . Comments on Specific Issues

The following are comments on specific issues raised in pre-filed testimony or at

the March 23, 2006, hearing

:

A .

Sections 732.606(ddd) and (eee) and Sections 732 .630(aaa) and (bbb)

The Illinois EPA does not believe that any of the testimony submitted in this

Docket B requires the Board to reverse its adoption of Sections 732 .606(ddd) and (eee)

and 732.630(aaa) and (bbb). The following are comments on individual issues related to

these Sections

.

8

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1)

CW3M continues to assert that Sections 732.606(ddd) and 732.630(aaa)

force less stringent remediation objectives upon property owners. This issue was

raised and addressed in Docket A. See, e.g., PC #4 at 10-12 . In sum, the Tiered

Approach to Corrective Action Objectives regulations of 35 Ill . Adm. Code 742

("TACO") are designed so that remediation objectives developed under Tier 2 are

as equally protective as remediation objectives developed under Tier I or Tier 3

.

Tier 2 objectives, however, are generally less expensive to achieve

.

2)

Also carried over from Docket A is the implication that Sections

732.606(ddd) and 732.630(aaa) will not provide adequate protection of property

values. This issue was also raised and addressed in Docket A . See, e.g ., PC #4 at

11 . The Leaking Underground Storage Tank ("LUST") Program does not require

protection of property values. It requires remediation in accordance with TACO,

which is designed to protect human health, not property values. Additional

remediation that is conducted to protect property values or to make property more

marketable exceeds the minimum requirements of the LUST Program, and the

costs associated with such remediation are not eligible for reimbursement

.

3)

There have been assertions that the use of a groundwater ordinance in

accordance with TACO may result in persons being exposed to contamination

that TACO allows to be left in place . Scenarios given as examples include the

possible ingestion of contaminated groundwater that eventually finds its way into

drinking water and vapor hazards that may be caused by contaminated

groundwater

.

9

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The issue of whether a groundwater ordinance used in accordance with

TACO does or does not provide adequate protection of human health is an issue

to debate in a TACO rulemaking, not in a LUST rulemaking . If there is a desire

to see remediation of the contaminated groundwater that TACO allows to be left

in place, amendments to the TACO regulations should be sought. Any changes to

TACO will then apply to the remediation of

LUST

sites. Under the current

LUST

regulations, however, cleaning up contaminated groundwater that is not required

to be remediated under TACO exceeds the minimum requirements of the

LUST

Program. Therefore the costs of such clean up are ineligible for reimbursement

from the Fund. See 415

ILCS

5/57.7(c)(3) (as amended by P.A. 92-554) .

At the March 23, 2006, hearing, there was some discussion about the

possibility of vapor intrusion pathway requirements being added to TACO at

some point in the future and the subsequent impact on the

LUST

Program. As

Gary King noted at the hearing, the Illinois EPA has yet to develop a proposal for

such changes to TACO. See, e.g, Tr. of March 23, 2006, hearing at 102, lines 5-

11. At this time, any discussion of what the Board may or may not eventually

adopt as TACO amendments is pure speculation . Id. If at some point in the

future the Board adopts rules addressing vapor intrusion, and as a result the

existing payment amounts for professional consulting services need to be

amended, the Illinois EPA could address vapor intrusion costs under the unusual

or extraordinary circumstances provisions of Sections 732 .860 and 734.850 until

the

LUST

rules can be properly amended to address the costs . See, e.g ., Id . at

102, lines 12-22 (testimony of Doug Clay)

.

1 0

---

B .

•

Hours Certified by Harry Chappel

At the March 23, 2006, hearing USI presented testimony regarding personnel

hours certified by Harry Chappel while he was in private practice . See Exh. 129 at 10-

11, Attachment E. USI's testimony is offered to show that the number of hours certified

by Mr. Chappel for two incidents exceed the number of hours in the Illinois EPA's

personnel/time breakdown

.

Subsequent to the March 23, 2006, hearing Mr. Chappel reviewed the Illinois

EPA's files for both of the incidents cited by USI . Mr. Chappel could not recreate the

hours USI claims that he certified in a corrective action budget for Incident #960101, or

the hours USI claims that he certified in early action billing packages for Incident

#981263. Furthermore, Mr. Chappel could not find any corrective action billing

packages that he had certified for Incident #981263

.

Regardless of the number of hours certified by Mr. Chappel, a review of the work

associated with the hours he certified shows that UST's comparison is improper . The

corrective action budget hours that Mr . Chappel certified for Incident #960101 were for

alternative technologies. Under proposed Sections 732.845 and 734.845, professional

consulting services associated with alternative technologies are subject to payment on a

time and materials basis, not a lump sump basis. See proposed Sections 732 .845(d)(5)

and 734.845(c)(1) . Therefore, the hours certified by Mr . Chappel are not hours that

would be included in the "Subdocket A" or "Subdocket B" hours cited by USI in

Attachment E of Exhibit 129

(i .e., hours used to develop lump sum payment amounts)

.

The hours certified by Mr. Chappel for Incident #981263 were associated with

free product removal. Like alternative technologies, professional consulting services

I1

---

associated with free product removal are not subject to lump sum payment amounts

.

They are instead subject to payment on either a time and materials or a unit rate basis

.

Costs associated with free product removal plans and the installation of free product

removal systems are subject to payment on a time and materials basis . See Sections

732.845(a)(5) and 734.845(a)(5). Costs associated with free product removal field work

and field oversight, and costs associated with the preparation and submission of free

product removal plans, are subject to payment on a unit rate basis . See Sections

732.845(a)(6) and (7) and 734 .845(a)(6) and (7) . Again, the hours certified by Mr .

Chappel are not hours that would be included in the "Subdocket A" or "Subdocket B"

hours cited by USI in Attachment E of Exhibit 129 . USI is comparing apples to oranges .

Its comparison is therefore inappropriate .

C .

Use of Hourly Rates Alone

At the March 23, 2006, hearing, there was an implication that the rates adopted by

the Board in Docket A at Sections 732.Appendix E and 734 .Appendix E are all that the

Illinois EPA needs to determine whether professional consulting services costs are

reasonable. See Tr. of March 23, 2006, hearing at 89-90, 181 (questions by Jay Koch)

.

The hourly rates charged for professional consulting services are only a part of the

equation. The amount of time that can reasonably be billed for a particular activity is

also a factor. Both the hourly rates and the amount of time billed must to be taken into

account when determining whether the resulting costs are reasonable

.

Gary King noted at hearing that the Illinois EPA's lack of legal tools for

controlling costs being paid from the Fund have resulted in overpayments from the Fund

.

Tr. of March 23, 2006, hearing at 181 . While the regulations adopted in Docket A

12

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provide the Illinois EPA with tools to help control the payments for many costs, they do

not provide adequate tools to help control the payments for professional consulting

services. Proposed Sections

732.845

and

734.845

are needed to help ensure that

payments from the Fund for professional consulting services are for reasonable costs .

D .

Variability of Plans and Reports Between Sites

There have been assertions that the proposed scope of work does not adequately

take into account the variability that may exists between sites, such as the number of

tanks removed, the number of samples collected, the number of borings drilled, and the

number of wells installed. The proposed scope of work is used to develop lump sum

payment amounts. Therefore, it includes work that is sufficiently standard that a lump

sum payment amount is a reasonable method of providing payment . It does not include

work that is subject to such variability that payment on a unit rate or a time and materials

basis is necessary

.

Most of the scope of work deals with the preparation and submission of plans and

reports. Taking into consideration the lump sum payment amounts for the preparation

and submission of plan and reports, and all of the costs included in the lump sum

payment amounts, the time it takes to address variables such as the number of tanks,

samples, borings, or wells is negligible . For example, once a

45-

Day Report is prepared,

it takes little time to add tank-specific information for additional tanks . Likewise, once a

site map is created, it takes little time to add the location of additional borings or wells

.

The work required to prepare and submit a plan or report is sufficiently standard that a

lump sum payment amount is a reasonable method of providing payment . Furthermore,

by rounding up the hours in its personnel/time breakdown and basing lump sum payment

1 3

---

amounts on the highest pay rate for each personnel title, the Illinois EPA has proposed

lump sum payment amounts sufficient to cover the variables that exist in the preparation

and submission of plans and reports

.2

The Illinois EPA believes that, as a whole, the

payment amounts set forth in proposed Sections 732 .845 and 734.845 are sufficient to

account for the variability that exists between sites .

E

.

Work Not Included in the Proposed Scope of Work

In Attachment C to its pre-filed testimony USI identifies regulations that are not

explicitly covered by the proposed scope of work . See Exh . 128 at 25 . USI is correct

that the proposed scope of work does not address some of the regulations . This is

because the scope of work only includes items that are subject to lump sum payment

amounts. It does not include work that is reimbursed on a unit rate or a time and

materials basis . For example, items related to free product removal requirements are not

included in the scope of work because costs associated with free product removal are

subject to payment on a unit rate or a time and materials basis, depending on the work

being performed. See, e.g., proposed Sections 734 .845(a)(5) and (7)

. Likewise, items

related to alternative technologies are not included in the proposed scope of work because

costs associated with alternative technologies are subject to payment on a time and

materials basis . See, e.g., proposed Section 734 .845(c)(1) . USI's comments fail to

recognize that much of the work required to comply with the LUST regulations is subject

to payment on a unit rate or a time and materials basis, and therefore is not included in

the proposed scope of work used to develop the lump sum payment amounts

.

Z

Please note that the preparation and submission of plans and reports for free product removal and for

alternative technologies are not included in the proposed scope of work because of the greater variability

involved with these plans and reports

.

14

---

. In Attachment D to its pre-filed testimony USI provides four examples of work

required by the regulations but not explicitly referenced in the scope of work proposed in

the Board's January 5, 2006, Opinion and Order . See Exh. 128 at Attachment D

.

Payment for this work is addressed in the revisions proposed by the Illinois EPA :

1)

Payment for activities required under Section 734 .210(a), other than the

mitigation of fire, explosion, or vapor hazards pursuant to Section

734.210(a)(3), is addressed in proposed Section 734 .845(a)(2)(A)

.

Payment for activities associated with the mitigation of fire, explosion, or

vapor hazards pursuant to Section 734 .21 0(a)(3) is addressed in proposed

Section 734 .210(a)(4)

.

2)

Payment for activities required under Section 734 .210(b), other than

continued monitoring and mitigation of fire, explosion, or vapor hazards

pursuant to Section 734 .210(b)(3), is addressed in proposed Section

734.845(a)(2)(B). Payment for activities associated with continued

monitoring and mitigation of fire, explosion, or vapor hazards pursuant to

Section 734.210(b)(3) is addressed in proposed Section 734.845(a)(4)

.

3)

Work associated with the preparation and submission of applications for

payment is included in the Illinois EPA's proposed revisions to the scope

of work and in its personnel/time breakdown. Payment for this work is

included in the corresponding lump sum payment amounts

.

4)

Payment for conducting "best efforts" to obtain off-site access is

addressed in proposed 734.845(b)(7)

.

F .

Need for Scope of Work to Track the Regulations

There has been a call for the scope of work to track the requirements of the

regulations. The scope of work proposed by the Board does track the requirements of the

regulations. The items in the scope of work are organized according to the regulatory

provisions they help satisfy . Furthermore, many items are based upon LUST Program

forms. These forms describe the work an owner or operator must complete in order to

comply with the regulations. By completing the work required in the forms, an owner or

15

---

operator complies with the LUST regulations. Therefore, a scope of work keyed to the

LUST forms tracks the requirements of the regulations

.

The Illinois EPA believes the scope of work proposed by the Board is organized

in a reasonable and appropriate manner that allows payment from the Fund to track the

LUST regulations. It also allows payment to track the logical progression of LUST site

cleanups .

Conclusion

The Illinois EPA believes the payment amounts allowed under proposed Sections

732.845 and 734.845 will provide reimbursement of reasonable costs for professional

consulting services . The Illinois EPA respectfully requests that the Board proceed with

the adoption of Sections 732 .845 and 734.845 as proposed by the Illinois EPA, copies of

which are included in Attachments E and F of these comments

.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

16

Kyle Rominger

Assistant Counsel

DATED

: 6,

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

---

Sco a of Work

ATTACHMENT A TO IEPA's POST-HEARING COMMENTS

SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

Section 732 .845(a)(1) Preparation for the abandonment or removal of USTs

1. Project Management

All Project Management work is

identified under Personnel Column

as PM

.

2. Correspondence

a . Office of the Illinois State Fire Marshal (OSFM)

1 . Prepare and submit initial Notification Form for Underground Storage Tanks

2. Prepare Application for Permit for Removal/Abandonment of Underground Storage Tanks and

submit to owner/operator for signature

3. Submit Application for Permit for Removal/Abandonment to OSFM

4. Prepare and submit LUST Fund Eligibility and Deductibility Application

5. Prepare and submit amended Notification Form

Tech

1

2.a.1, 2, 3 & 5 are performed by

tank removal contractor and costs

are included in tank removal lump

sum .

b. Illinois Environmental Protection Agency (IEPA)

1 . Prepare and submit early action extension

2. Follow up

PM

1

Not required in all cases

.

c. Correspond with and update client

Not corrective action .

3. Waste Disposal

a. Determine early action excavation limits

PM

1

b. Prepare waste profile and arrange for landfill approval

Tech

2

See Section 732 .845(a)(2) for field

work .

c. Prepare waste manifests or tracking forms

PM

4. Plan and Report Preparation

a . Prepare site health and safety plan

PM

2

5. Resource Coordination

a . Arrange for subcontractors (e.g ., excavator, tank removal contractor, backfill, landfill)

b. Schedule project

PM

4

---

Sco a of Work

Personnel

Hour

2

c. Call J.U.L.I.E. and/or municipality to locate utilities

Task performed by tank removal

contractor. Cost included in tank

removal lump sum.

Section 732.845(a)(3) Preparation and submission of 20-day and 45-day reports

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a . already included in other line

items and 2.b. is not corrective

action .

3. Records Gathering

a. Obtain and review IEPA and/or OSFM records

b. Obtain and review well records from ISGS and ISWS

c. Obtain and review local information (e .g. Sanbom maps, aerial overlays)

3.a . and c included in hours for

preparation of 45-day Report. 3.b .

not required for preparation of 20

or 45-day Reports

.

4. Waste Disposal

a. Review disposal documentation

PM

1

5. Technical Evaluation

a. Prepare well location map (<25 records within 2500 feet)

b. Determine expected local site geology (subsurface soil conditions)

a. not required for preparation of

20 or 45-day Reports .

b. included in hours for

preparation of 45-day Report .

6. Plan and Report Preparation

a. Prepare 20-day Certification

PM

1

b. Prepare or revise site health and safety plan

Previously prepared under

732.845(a)(1) task 4 .a. No revision

necessary for preparation and

submission of 20 and 45-day

reports .

---

Sco a of Work

Personnel

Hours

Comments

3

c

. Prepare 45-day Report

1 . Provide information pertaining to

:

PM

8

A. Site Identification

B. Release Information

C. Early Action

D . Site Information

I . Nature and estimated quantity of release

2. Data concerning :

a. Surrounding populations

b. Water quality

c. Use and approximate locations of wells potentially affected by the release

d. Subsurface soil conditions

e. Location of subsurface sewers

f. Climatological conditions

g. Land use

3 . A discussion of what was done to measure for the presence of a release

4. Action taken to prevent further release of the regulated substance into the environment

5 . A discussion of the action taken to monitor and mitigate fire and safety hazards posed by

vapors of free product that has migrated from the UST excavation zone and entered

subsurface structures

E. Supporting Documentation

CAD Operator

8

1 . Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc .)

e. Nearby structures (buildings, roads, etc .)

f. Soil boring(s) (if present)

g. Monitoring well(s) and/or sumps (if present)

h. Property boundaries

i. Sample location points

2. Area map showing the site in relation to surrounding properties . This map should identify the

facilities on the surrounding properties

3. Cross-section, to scale, showing the USTs and the excavation

4. Analytical/screening results in tabular format, including the results of soil samples required

PM

2

pursuant to 35 III. Adm. Code 732.202(h) or 45 ILCS 5/57-57.17 .

---

Sco a of Work

4

5

. UST information in a tabular format, including

:

a. Total number of UST(s) on site

b. Volume of the UST(s) (in gallons)

c . The material stored in the UST(s)

d. Identification of UST system(s) that had a release

e. Identification of UST system(s) that were repaired, removed, or abandoned in-place

'..vuuucuw

UST information table included on

Agency forms under 6.c.1 .B

.

above (Release Information)

6. Copy of OSFM Permits or notifications

Admin Asst

1

6, 8 & 9 combined for total of 1

hour.

7. Narrative of tank removal and cleaning operations ; describe how wastes generated

during the tank removal were managed, treated, and disposed of

PM

1

8. Photographs of UST removal activities and the excavation

9 . Copies of waste manifests for soil and groundwater transported off-site

6, 8 & 9 combined for total of 1

hour .

d. Review and certification of 20-Day and 45-Day Reports and application for payment .

LPE or LPG

I

Certification added to IPCB's

proposal. PM/Senior staff

reference deleted. Added

reference to application for

payment .

7. Resource Coordination

a. Call J .U.L.I.E. and/or municipality to locate utilities

Already done prior to tank

removal. Not required for

preparation and submission of 20

and 45-day reports

.

8 . Distribution

a. Deliver draft 20-day Certification and 45-Day Report and application for payment to

owner/operator for review and signature

b. Make copies of 20-Day Certification and 45-Day Report and application for payment for

distribution

c. Deliver completed 20-Day Certification and 45-Day Report and application for payment to IEPA

and owner/operator

Admin Asst

2

Covers all copying and delivering

costs. Added references to

application for payment .

9. Prepare applications for payment

Account Tech

8

This is added to IPCB's proposal

.

Section 732 .845(a)(6) Preparation and submission of free product removal reports

1. Project Management

All Project Management work is

identified under Personnel Column

as PM

.

---

Sco a of Work

Personnel

Hours

Comments

5

2 . Correspondence

a .

Correspond with and update Illinois Environmental Protection Agency (IEPA)

b. Correspond with and update client

2.a. already included in other line

items and 2.b. is not corrective

action.

3. Waste Disposal

a. Review disposal documentation

PM

1

4. Free Product Report Preparation

a. Prepare Free Product Removal Report

1 . Provide information pertaining to

:

A. Site Identification

B. Free Product Information

1 . Name(s) of person(s) responsible for implementing the free product removal measures

2 . Estimated quantity, type, and thickness of free product observed or measured in boreholes,

wells, excavation, etc

.

3 . The type of free product recovery system used and technical justification for the method

of

recovery chosen

4. Whether any discharge will take place on- or off-site during the recovery operation and

where this discharge (point) will be located

5 . Type of treatment applied to (the free product), and the effluent quality expected from any

discharge

6. Steps that have been taken or that are being taken to obtain necessary permits for any

discharge

7. The disposition of the recovered free product

PM

4

C. Supporting Documentation

1. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc .)

e. Nearby structures (buildings, roads, etc.)

f . Soil boring(s) (if present)

g. Monitoring well(s) and/or sumps (if present)

h. Locations where free product was encountered including its estimated thickness

i. Location of recovery points

j . Location of the treatment unit

k. Location of discharge points

1. Property boundaries

CAD Operator

I

Site map already prepared under

Early Action. Only modifications

required at this point

.

2. Table showing the dates that free product recovery was conducted and the amount of

free product recovered on each date

PM

1

---

Sco a of Work

6

'..vmwcuw

3

. Copies of waste manifests

Admin Asst

5. Review and certification of free product removal report

.

LPE or LPG

Added to IPCB's proposal

.

6. Distribution

a. Deliver draft free product removal report to owner/operator for review and signature

b . Make copies of free product removal report for distribution

c. Deliver completed report to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs .

Section 732.845(a)(7) Preparation and submission of reports submitted pursuant to Section

732.202(h)(3)

1 . Site characterization/narrative

2. Characterization/narrative of water encountered in UST excavation

3. Completion of Property Owner Summary Form

4. Recording NFR Letter

PM

Admin Asst

2

2

This report submitted as part of

45-Day Report. All other costs

related to this report are included

in costs for 45 Day Report (e.g .,

LPG/LPE certification,

distribution) . Reference in title to

"734.210(h)(3)" changed to

"732 .202(h)(3)"

Section 732.845(b)(1) Preparation and submission of site classification plans, site classification

preparation, fieldwork, field oversight, and the preparation and submission of the site classification

completion report

SITE CLASSIFICATION WORK PLAN

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a. already included in other line

items and 2 .b. is not corrective

action .

3. Technical Evaluation

a. Conduct fieldwork

b. Provide field oversight

'

PM

Geologist

Tech

10

10

20

These hours include field work

that is not covered under the half-

day rates. There are no half-day

rates for Site Classification field

work .

---

Scope ofWork

Personnel

Hours

Comments

7

4 . Plan Preparation

PM

8

Under 4.a . 1 .c .7 and 8, reference to

a. Prepare Site Classification Work Plan

LPG added .

I. Provide information concerning :

Under 4.a . 1 .c .7, reference to

A. Site Identification

"Class II" groundwater changed to

B. Site Information

"Class III".

C. Site Classification

Section 4.a.l .c.9 (Classification by

1 . Method of Physical Soil Classification

Exposure Pathway Exclusions) of

2. Number of soil borings to be advanced on-site

the Board's proposed scope of

3. Whether soil borings are proposed to be advanced for reasons other than Physical

work is deleted because

Soil Classification or investigation of migration pathways

classification by exposure pathway

4. Whether monitoring wells are proposed on-site

is no longer an option under Part

5. Physical Soil Classification

732

a. Scientific publications/geologic maps that will be reviewed to determine consistency

IEPA added new Sections 4.a.I .c.9

with Plate 1 of the Illinois State Geological Survey Circular 532

and 9.5 .

b. Drilling methods, auger types, sampling procedures and sampling devices that will be

used

c. Basis for determining the location (include number and spacing) of soil borings

d. How the proposed final soil boring configuration and boring depths will provide the

greatest likelihood of determining the geologic characteristics of the site

e . What will be done if auger refusal occurs or bedrock is encountered during drilling

f. What will be done if anomalies are encountered during drilling

g. What will be done to prevent cross-contamination between water-bearing units that

may be encountered during drilling

6. Groundwater Investigation

a. Drilling methods that will be used

b. Basis for determining the location and number of monitoring wells placed at the

site

c. Monitoring well installation procedures

d. Activities that will be taken to prevent cross-contamination during well installation

e. Basis for determining well construction material

f. Basis for determining the monitoring well-screen depth and screened interval

g. Monitoring well development procedures

h. Monitoring well sampling procedures

i. Activities that will be taken to prevent cross-contamination between groundwater samples

j. How the proposed final monitoring well configuration will provide the greatest likelihood

of detecting the migrations of groundwater contamination

k. Steps that will be taken to determine groundwater elevation and flow direction .

7. How the LPE/LPGwill verify whether Class III Special Resource

Groundwater exists within 200 feet of the UST system

8. How the LPE/LPG will identify and locate all community water

supply wells within 2,500 feet of the UST system and all potable water supply wells within

200 feet of the UST system, and determine if the UST system is within the regulated

recharge area of any community water supply well or potable water supply well

9. How the LPE/LPG will locate all surface water bodies within 100 feet of the UST system and

determine whether they have been adversely affected by the a sheen or free product

---

Sco a of Work

8

l U1111IRArt3

9.5

. How the LPE/LPG will determine whether there is evidence of petroleum or vapor

migration that threatens human health or safety or that may cause explosions in confined

spaces

10. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

f. Location of the proposed soil boring(s)

g. Location of the proposed monitoring wells (if required)

h. Property boundaries

i. 200-foot radius from the UST system

CAD Operator

2

Site map already prepared under

Early Action. Only modifications

required at this point

.

11 . Chart indicating the following

:

a. Boring identification

b. Depth of boring (in feet)

c. Number of samples from each boring that will be submitted for geotechnical analysis

d. Identification of geotechnical tests that will be performed on samples

PM

1

b. Prepare budget for site classification work plan

Account Tech

4

c . Review and certification of site classification work plan and budget .

LPE or LPG

2

PM/Senior staff reference deleted .

5 . Distribution

a. Deliver draft site classification work plan and budget to owner/operator for review and signature

b. Make copies of site classification work plan and budget for distribution

c. Deliver site classification work plan and budget to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs. Changed c to reference "site

classification work plan and

budget" instead of "completed

report" .

SITE CLASSIFICATION COMPLETION REPORT

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2 .b. is not corrective

action .

3. Technical Evaluation

a. Conduct fieldwork

b. Provide field oversight

Not required as part of preparing

and submitting Site Classification

Completion Report

.

---

Sco a of Work

Personnel

Hours

Comments

9

4

. Report Preparation

a. Prepare Site Classification Completion Report

I. Provide information concerning :

A. Site Identification

B . Site Information

C. Site Classification Summary

D. Site Classification by Methods One or Two

E. Site Evaluation

1 . Physical Soil Classification

a. Soil borings

I . A list of publications reviewed and preliminary conclusions concerning the site geology

2 . Soil borings logs

3 . Site map to scale and oriented north showing

:

i. Soil boring locations

PM

CAD Operator

8

4

Site map already prepared under

earlier plans/reports. Only

modifications required-at this

point .

ii. UST system(s)

iii. 200-foot radius from UST system

iv. Property boundaries

b. Method One soil properties test results (include calculations, methodologies, and complete

laboratory reports)

I . Soil particle analysis

2. Soil moisture content

3. Soil classification

4. Unconfined compression test

5 . In-situ hydraulic conductivity

6. Ex-situ hydraulic conductivity

c. Method Two soil properties test results (include calculations, methodologies,

and complete

laboratory reports)

1 . Soil particle analysis

2. Ex-situ hydraulic conductivity; and calculated yield of geological material

3. In-situ hydraulic conductivity and yield of geologic material

---

Sco a of Work

10

aa..avuuc.

AIUU13

I.VIrr111CILS

2. Groundwater Investigation

a. If groundwater investigation was required, provide the following

:

1 . Discussion of how the monitoring well configuration provides the greatest likelihood

of detecting migration of groundwater contamination

2. Monitoring well construction diagrams

3. Table showing static water elevations

4. Sample collection shipment and preservation information

5. Completed chain-of-custody form(s)

6. Copies of laboratory reports (include field and lab blanks)

7. Analytical results in tabular format

S . Site map to scale and oriented north showing

:

i. Monitoring well locations

ii. Potentiometric surface map

iii. Groundwater flow direction

iv. 200-foot radius from UST system and

v. Property boundaries

b. If no groundwater investigation was performed, provide the following

:

1. Demonstrate whether groundwater is present within the depth of boring used to perform

physical soil classification under the selected method (Method One under subsection (c)

or Method Two under subsection (d))

2. Demonstrate whether groundwater is withdrawn for potable use within 1000 feet of the

UST system and at what depths

3 . Demonstration whether seasonal fluctuation in groundwater could result in groundwater

contacting contaminated soil (e .g., historical records)

PM

CAD Operator

4

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point .

F. Water Well Survey

PM

4

Site map already prepared under

1 . Results of the survey conducted to identify all community water supply wells within 2,500

earlier plans/reports. Only

feet of the UST system and all potable water supply wells within 200 feet of the UST system

modifications required at this

(include copies of well logs and all correspondence to and from the Illinois State Water

point .

Survey and the Illinois State Geological Survey)

.

2. Local units of government contacted to determine if there is a local ordinance or policy

regulating the usage of potable water supply wells

3 . Site map to scale showing all of the community water supply wells within 2,500 feet of the

UST system and all potable water supply wells within 200 feet of the UST system (radii

of 200, 400, 1,000 and 2,500 feet from the UST system should be marked on the map)

4. Table indicating the setback zone for each community or potable water supply well and the

distance from the UST system to the well (the location of each well must be identified on the

map by numbers corresponding to information provided in the table)

5. The sources consulted in determining whether the UST system is within the regulated

recharge area of any community or potable water supply well

---

Scope ofWork

Personnel

Hours

Comments

it

G. Migration Pathways

1 . Discussion of the investigation conducted to identify all potential natural and man-made

migration pathway that are on the site, rights-of-way attached to the site, or in any area

surrounding the site that may be adversely affected as a result of a release of petroleum from

the UST system

2. Discussion of further investigations conducted to determine if there is evidence that migration

of petroleum or vapors along such pathways threatens human health or the environment or

may cause explosions in basements, crawl spaces, utility conduits, storm or sanitary sewers,

Vaults or other confined spaces

3 . Discussion of the findings based on the investigations peformed

.

4. Site map to scale and oriented north showing

:

a. The UST system(s) and excavation

b. Product and dispenser lines

c. Potential natural and man-made pathways on-site, in rights-of-way attached to the site or

in areas that may be adversely affected by the release

d. Soil boring locations

e. Property boundaries

PM

CAD Operator

3

I

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point .

H .

Class III Special Resource Groundwater

1 . Discussion of the steps taken to determine if Class III groundwater exists within 200 feet of

the site

2 . Site map to scale and oriented north showing

:

a. Location of Class II groundwater

b .

Radius of 200 feet from the UST system(s)

I. Surface Bodies of Water

1 . Discussion of the steps taken to locate all surface bodies of water on site and within 100 feet

of the site, and one located, the steps taken to determine if they have been adversely affected

by the presence of a sheen or free product layer resulting from a release of petroleum from

the UST system

2. Site map to scale and oriented north showing the locations of the surface bodies of water on

site and within 100 feet of the site

PM

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point .

J. Classification by Exposure Pathway Exclusion

No longer an option

Section J of the Board's proposed

scope of work is deleted because

classification by exposure pathway

is no longer an option under Part

732 .

K. Supporting Documentation

1 . Site map to scale oriented north showing

:

a. UST system(s) (former and existing)

b. Excavation limits (former and existing)

c. Product and dispenser lines

d. Pumps and islands

e. Underground utilities (sewer, gas, water, etc)

CAD Operator

4

Site map already prepared under

earlier plans/reports. Only

modifications required at this point

and drawing of geologic cross

section .

---

Sco a of Work

12

f

.

Nearby structures (buildings, roads, etc)

g. Location of the soil boring(s)

h. Location of the monitoring wells

i. Property boundaries

j. 200-foot radius from the UST system(s)

2. Horizontal cross section showing the various geologic units and the depth to groundwater

3. Laboratory certification(s)

This is provided by laboratory

along with laboratory results .

b. Review and certification of site classification completion report and application for payment .

LPE or LPG

2

PM/Senior staff reference deleted

.

Reference to application for

payment added.

5 . Distribution

a. Deliver draft site classification completion report and application for payment to owner/operator

for review and signature

b

.

Make copies of site classification completion report and application for payment for

distribution

c .

Deliver completed report and application for payment to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs. Reference to application for

payment added .

6. Prepare applications for payment

Account Tech

8

This is added to the IPCB's

proposal .

Section 732.845 (c)(1) Preparation and submission of low priority groundwater monitoring plan

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a. already included in other line

items and 2 .b. is not corrective

action .

3. Waste Disposal

a. Determine treatment type to be applied to any discharge and effluent quality expected

b. Obtain necessary permits for discharge

c. Determine final disposition of recovered free product

Not required for preparation and

submission of low priority

groundwater monitoring plan . 3 .c

not applicable at low priority sites

.

4. Technical Evaluation

Included in 5 below

.

---

Sco a of Work

Personnel

Hours

Comments

13

5 . Plan Preparation

a. Prepare groundwater monitoring plan

1. Provide information concerning

:

A. Site Identification

B. Site Information

C. Site Documentation

I . Proposed time table for well installation, all sampling events and report submittal

PM

8

Site map already prepared under

earlier plans/reports. Direction of

groundwater flow on Site map

added to IPCB's proposal .

2. Discussion of:

a. Monitoring well development procedures

b. Monitoring well sampling procedures

c . Activities that will be taken to prevent cross-contamination between groundwater

samples

3. Site map to scale and oriented north showing

:

a. UST system(s) and excavation

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc .)

e. Nearby structures (buildings, roads, etc .)

f. Location of the soil borings

g . Location of the existing monitoring wells

h. Property boundaries

i. Radius of 200 feet from the excavation

j. Direction of groundwater flow

4. Discussion of the adequacy of the final monitoring well configuration to detect the

migration of groundwater contamination

b. Prepare budget for groundwater monitoring plan

Account Tech

4

c. Review and certification of groundwater monitoring plan and budget

LPE or LPG

2

PM/Senior staff reference deleted.

6. Distribution

a. Deliver draft groundwater monitoring plan and budget to owner/operator for review and signature

b. Make copies of groundwater monitoring plan and budget for distribution

c. Deliver completed plan and budget to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs

.

Section 732.845 (c)(3) and (c)(4) Preparation and submission of first and second year groundwater

monitoring reports

Hours listed are for each year's

groundwater monitoring report .

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

---

Sco a of Work

14

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

'.vuuucuw

2 .a. already included in other line

items and 2.b. is not corrective

action .

3. Technical Evaluation

Included in 4 below .

4. Report Preparation

a. Prepare groundwater monitoring report

1. Provide information concerning

:

A. Site Identification

B . Site Information

C. Assting Documentation

L Description of the implementation and completion of all elements of the groundwater

monitoring plan

2. Description of the well development procedures, sample collection, preservation, and

analysis

3. Analytical results in tabular format

4. Copies of laboratory results

5. Laboratory certification

6. Groundwater elevations in a tabular format

7. Monitoring well logs

8. Completed chain-of-custody form(s)

9. Owner/Operator Summary form

10. Site map to scale and oriented north showing

:

a. UST system(s) and excavation

b. Underground utilities (sewer, gas, water, etc .)

c. Product and dispenser lines

d. Pumps and islands

e. Nearby structures (buildings, roads, etc .)

f. Location of groundwater monitoring wells

g. Direction of groundwater flow

h. Property boundaries

i. Radius of 200 feet from the UST system

PM

CAD Operator

8

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point. 4.a.1 .C .10.c and d added to

IPCB's proposal.

b. Review and certification of groundwater monitoring report and application for payment

.

LPE or LPG

2

PM/Senior staff reference deleted .

Application for payment added

.

5. Distribution

Admin Asst

2

Covers all copying and delivering

a. Deliver draft groundwater monitoring report and application for payment to owner/operator for review

costs. Application for payment

and signature

added.

b. Make copies of groundwater monitoring report and application for payment for distribution

c. Deliver completed report and application for payment to IEPA and owner/operator

6. Prepare application for payment

Account Tech

4

This is added to IPCB's proposal

.

---

Scope of Work

Personnel Hours

Comments

1 5

Section 732.845(c)(5) Preparation and submission of low priority groundwater monitoring completion

report

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2.b. is not corrective

action .

3. Technical Evaluation

Included in 4 below .

4. Report Preparation

a. Prepare groundwater monitoring completion report

1. Provide information concerning :

A. Site Identification

B . Site Information

C. Assting Documentation

1. Description of the implementation and completion of all elements of the groundwater

monitoring plan

2. Description of the well development procedures, sample collection, preservation,

and

analysis

3 . Analytical results in tabular format

4. Copies of laboratory results

5 . Laboratory certification

6. Groundwater elevations in a tabular format

7. Monitoring well logs

8. Completed chain-of-custody form(s)

9. Owner/Operator Summary form

10. Site map to scale and oriented north showing :

a. UST system(s) and excavation

b. Underground utilities (sewer, gas, water, etc .)

c. Product and dispenser lines

d. Pumps and islands

e. Nearby structures (buildings, roads, etc .)

f. Location of groundwater monitoring wells

g. Direction of groundwater flow

h. Property boundaries

i. Radius of 200 feet from the UST system

PM

CAD Operator

8

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point. 4.a.1 .C.10.c and d added to

IPCB's proposal .

b. Review and certification of groundwater monitoring completion report and application for payment .

LPE or LPG

2

PM/Senior staff reference deleted

.

Application for payment added .

---

Sco a of Work

16

5 . Distribution

a. Deliver draft groundwater monitoring completion report and application for payment to

owner/operator for review and signature

b. Make copies of groundwater monitoring completion report and application for payment for

distribution

c. Deliver completed report and application for payment to IEPA and owner/operator

Admin Asst

2

t VIIII11CUW

Covers all copying and delivering

costs. Application for payment

added .

6. Prepare applications for payment

Account Tech

4

This is added to IPCB's proposal

.

Section 732.845(d)(I)(A) Preparation and submission of investigation plans for on-site contamination

for sites classified pursuant to Section 732 .307

Scope of work same as for Stage 2

site investigations under Part 734 .

All scope of work for this Section

732.845(d)(1)(A) added to IPCB's

proposal .

1. Technical Evaluation

a. Address the same items that are required for Part 734 sites under 35 IAC 734 .320(b)

b. Prepare or finalize field notes

c. Prepare and describe site investigation photos

PM

CAD Operator

16

8

These hours cover technical work

performed (vs. report preparation

hours which are included under 2

below) .

d. Prepare contingency scope of work for boring/monitoring well locations

Included under 2 below .

2 . Plan Preparation

a .

Prepare investigation plan for on-site contamination

1. Provide information concerning

:

A. Site Identification

B . Site Information

1. Will owner/operator seek reimbursement from the UST Fund?

2. If yes, is budget attached?

3. Is this an amended plan?

4. Identify the material released

5. Describe the activities that will be performed to determine the following

:

a. Degree of soil contamination

b. Extent of soil contamination (as defined to Tier I Residential remediation objectives)

c. The degree of groundwater contamination

d. Extent of groundwater contamination (as defined to Class I Remediation Objectives unless

otherwise approved by the Illinois EPA)

e. Direction of groundwater flow

f. Hydraulic conductivity of groundwater

g. Identification of Site features that may affect contaminant transport and risk to human

health and the environment .

b. The following parameters, if determined during on-site investigation

:

Hydraulic conductivity

Soil bulk density

PM

8

---

Sco a of Work

Personnel

Hours

Comments

1 7

Soil particle density

Moisture content

Organic carbon content

C. Site Investigation Summary Form

6. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e . Nearby structures (buildings, roads, etc .)

f. Location of the proposed/existing soil borings

g. Location of the proposed/existing monitoring wells

h. Property boundaries

Maps included under La: above

.

Site map already prepared under

earlier plans/reports . Only

modifications required at this

point .

b. Prepare budget

Account Tech

4

c. Review and certification of on-site investigation plan and budget

LPE/LPG

2

3. Resource Coordination

a .

Arrange for drilling

b .

Call J.U.L.I.E. and/or municipality to locate utilities

PM

2

4. Distribution

a. Deliver draft plan and budget to owner/operator for review and signature

b. Make copies of plan and budget for distribution

c. Deliver completed plan and budget to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs .

Section 732.845(d)(1)(B) Preparation and submission of investigation plans for off-site contamination

for sites classified pursuant to Section 732.307

Scope of work same as for Stage 3

site investigations under Part 734

.

All scope of work for this Section

732.845(d)(1)(B) added to IPCB's

proposal .

1. Technical Evaluation

a. Address the same items that are required for Part 734 sites under 35 IAC 734 .325(b)

b. Prepare or finalize field notes

c. Prepare and describe site investigation photos

PM

CAD Operator

16

8

These hours cover technical work

performed (vs. report preparation

hours which are included under 2

below)

.

d. Prepare contingency scope of work for boring/monitoring well locations

.

Included under 2 below

.

---

Sco a of Work

1 8

2 . Plan Preparation

a. Prepare investigation plan for off-site contamination

1. Provide information concerning :

PM

8

~.muu¢uw

A. Site Identification

B . Site Information

l. Will owner/operator seek reimbursement from the UST Fund?

2. If yes, is budget attached?

3 . Is this an amended plan?

4. Identify the material released

5 . Describe the activities that will be performed to determine the following

:

a. Degree of soil contamination

b. Extent of soil contamination (as defined to Tier I Residential remediation objectives)

c. The degree of groundwater contamination

d. Extent of groundwater contamination (as defined to Class I Remediation Objectives unless

otherwise approved by the Illinois EPA)

e. Direction of groundwater flow

f. Hydraulic conductivity of groundwater

g. Identification of Site features that may affect contaminant transport and risk to human

health and the environment .

h. The following parameters, if determined during off-site investigation :

Hydraulic conductivity

Soil bulk density

Soil particle density

Moisture content

Organic carbon content

C. Site Investigation Summary Form

6. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

f. Location of the proposed/ existing soil borings

g. Location of the proposed/existing monitoring wells

h. Property boundaries

Maps included under 2.a. above .

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point.

b. Prepare budget

Account Tech

4

c. Review and certification of off-site investigation plan and budget

LPE/LPG

2

---

Sco a of Work

Personnel

Hours

Comments

1 9

3

. Resource Coordination

a . Arrange for drilling

b. Call J.U.L.I.E. and/or municipality to locate utilities

PM

2

4. Distribution

a. Deliver draft plan and budget and application for payment to owner/operator for review and signature

Admin Asst

2

Covers all copying and delivering

costs .

b. Make copies of plan and budget and application for payment for distribution

c. Deliver completed plan and budget and application for payment to IEPA and owner/operator

5. Prepare applications for payment for on-site investigation

Account Tech

8

This is added to IPCB's proposal

.

Section 732.845(d)(3) Off-site property access

Correspondence and meetings with off-site property owners

PM

4 for each

off-site

property

4 hours total for each off-site

property to which off-site access is

sought. This work moved here

from the scope of work for Section

732 .845(d)(1)(B) above .

Section 732.845(d)(4) Well surveys conducted pursuant to Sections 732 .404(e)(1) and 734.445(b)

PM

Not required for all sites

.

Section 732.845(d)(5) Preparation and submission of corrective action plan (Conventional Tech)

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2.b. is not corrective

action .

3. Waste Disposal

a. Prepare waste profile (arrange for landfill approval)

Tech

4

These hours include field work

that is not covered under the half-

day rates .

b .

Determine limits of excavation

c. Estimate quantity of contaminated soil to be disposed of

d .

Mail waste profile to owner/operator for review and signature

e. Prepare waste manifests or tracking forms

PM

4

---

Sco a of Work

S

20

4. Technical Evaluation

a. Estimate quantity of "clean" overburden to be stockpiled (if any)

.

Included in 3.b above

b .

Prepare or finalize field notes

c

.

Prepare and describe remediation photos

This work part of preparation and

submission of Corrective Action

Completion Report. (see items 4.b

and c . under scope of work for

Section 732.845(d)(8))

.

5. Plan Preparation

a. Prepare or review site health and safety plan

Previously prepared under

732.845(a)(1), item 4a.

b. Prepare Corrective Action Plan

l. Provide information concerning

:

A. Site Identification

B. Site Information

C. Proposed Methods of Remediation

D. Soil and Groundwater Investigation Results

I . Description of investigation activities performed to define the extent of soil and/or

groundwater contamination

2 . Analytical results and cleanup objectives in tabular format

3. Laboratory results

4. Boring logs

5 . Monitoring well logs

6. Site maps to scale and oriented north showing

:

a. Soil sample locations

b. Monitoring well locations

c. Plumes of soil and groundwater contamination

PM

CAD Operator

2

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this

point .

E. Technical Information - Corrective Action Plan

I . Discussion of how the corrective action plan shall remediate the release

2. List of sampling parameters and corresponding remediation objectives

3. Basis for determining sampling parameters and remediation objectives

4. Media sampling plan to verify completion of remediation

5. Current and future use of the property

6. Proposed preventive, engineering and institutional controls

7. Schedule for implementation and projected completion of the plan

8. Engineering design specifications, diagrams, calculations, manufacturer's specifications,

systems analsyses, site maps, etc .

PM

16

c. Prepare budget for corrective action plan

Account Tech

8

d. Review and certification of corrective action plan and budget

LPE or LPG

4

PM/Senior staff reference deleted .

---

Sco a of Work

Personnel

Hours

Comments

2 1

6 . Resource Coordination

a. Schedule project

b. Arrange for subcontractors

c. Call J.U.L.I.E. and/or municipality to locate utilities

PM

16

Reference to individual

subcontracted activities changed to

"subcontractors."

7. Distribution

a. Deliver draft corrective action plan and budget and application for payment to owner/operator for

Admin Asst

2

Covers all copying and delivering

costs .

review and signature

b. Make copies of corrective action plan and budget and application for payment for distribution

c. Deliver completed corrective action plan and budget and application for payment to IEPA and

owner/operator

8. Prepare applications for payment for off-site

investigation,

or for on-site investigation if no off-site

Account Tech

8

This is added to IPCB's proposal

.

investigation is required .

Section 732.845(d)(7)(B) Development of Tier 2 or Tier 3 remediation objectives

PM

8

Section 732.845(d)(8) Environmental Land Use Controls and Highway Authority Agreements

PM

8

8 hours total for each ELUC &

HAA. Standardized documents

being proposed in separate TACO

rulemaking .

Section 732.845(d)(9) Preparation and submission of corrective action completion report

These tasks apply to Corrective

Action Completion Reports for

both conventional and alternative

technologies. IPCB's proposal

referenced only conventional

technologies .

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2 .b. is not corrective

action .

3. Records Gathering

a. Obtain legal description of property

b. Obtain property tax identification number

Included in hours for preparation

of Corrective Action Completion

Report .

---

Sco a of Work

Personn

22

4. Technical Evaluation

a. Address items in 35 IAC 734.345(a)?

b. Prepare and describe photos

c. Prepare or finalize field notes

Included in 5 below .

5. Report Preparation

PM

32

Professional engineer certification

a. Prepare Corrective Action Completion Report following items in 35 IAC 734 .345(a)

CAD Operator

8

included under 5 .b. below .

1 . Provide information concerning

:

Site map already prepared under

a. Site Identification

earlier plans/reports. Only

b . Site Information

modifications required at this

c. Completion Information

point .

I . Chronological narrative of corrective action activities

2 . Explanation of how the corrective action activities remediated the release

3. Discussion of how the remediation objectives were determined

4. Media sampling and analytical procedures to verify completion of remediation

5 . Analytical results and remediation objectives in tabular format

6. Laboratory results

7 . Soil boring logs

8 . Monitoring well logs

9. Laboratory certification

10. Applicable Professional Engineer Certification

11 . Site maps to scale and oriented north showing

:

a. Final soil sample locations demonstrating completion of remediation

b. Groundwater monitoring well locations

c. Groundwater recovery/discharge points

d. Plume of contamination as defined by laboratory analyses and

e. Area remediated

12. Property Owner Summary

13 . Photographs documenting corrective action activities

b. Review and certification of corrective action completion report and application for payment

.

LPE

4

PM/Senior staff reference deleted .

Reference to applications for

payment added.

6. Resource Coordination

Admin Asst

2

a. Record NFR letter

---

co a of Work

Personnel

Hours

Comments

23

7 .

Distribution

a .

Deliver draft corrective action completion report and application for payment to owner/operator

for review and signature

b. Make copies of corrective action completion report and application for payment for

distribution

c. Deliver completed corrective action completion report and application for payment to IEPA and

owner/operator

d. Make copies of recorded NFR letter for distribution

e. Deliver recorded NFR letter to IEPA and owner/operator

Admin Asst

3

Covers all copying, delivering

costs and recording of NFR letter

.

References to applications for

payment added.

8. Prepare applications for payment

Account Tech

8

This is added to IPCB's original

proposal .

732.845(l) Amendment of plan due to unforeseen circumstances and its associated budget

PM

6

Account Tech

2

---

Sco a of Work

ATTACHMENT B TO IEPA's POST-HEARING COMMENTS

SCOPES OF WORK FOR PART 734 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

Section 734 .845(a)(1) Preparation for the abandonment or removal of USTs

I. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Office of the Illinois State Fire Marshal (OSFM)

I. Prepare and submit initial Notification Form for Underground Storage Tanks

2. Prepare Application for Permit for Removal/Abandonment of Underground Storage Tanks and

submit to owner/operator for signature

3. Submit Application for Permit for Removal/Abandonment to OSFM

4. Prepare and submit LUST Fund Eligibility and Deductibility Application

5. Prepare and submit amended Notification Form

Tech

1

2.a.1, 2, 3 & 5 are performed by

tank removal contractor and

included in tank removal lump sum

.

b. Illinois Environmental Protection Agency (IEPA)

1. Prepare and submit early action extension

2. Follow up

PM

I

Not required in all cases .

c. Correspond with and update client

Not corrective action .

3. Waste Disposal

a. Determine early action excavation limits

PM

1

b. Prepare waste profile and arrange for landfill approval

Tech

2

See Section 734.845(a)(2) for field

work.

c. Prepare waste manifests or tracking forms

PM

1

4. Plan and Report Preparation

a. Prepare site health and safety plan

PM

2

5. Resource Coordination

a. Arrange for subcontractors (e.g ., excavator, tank removal contractor, backfill, landfill)

b. Schedule project

PM

4

c. Call J.U .L.I.E. and/or municipality to locate utilities

Task performed by tank removal

contractor. Cost included in tank

removal lump sum.

---

Scope of Work

Personnel

Hours

Comments

2

Section 734.845(a)(3) Preparation and submission of 20-day and 45-day reports

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a. already included in other line

items and 2.b. is not corrective

action .

3. Records Gathering

a. Obtain and review IEPA and/or OSFM records

b. Obtain and review well records from ISGS and ISWS

c. Obtain and review local information (e .g . Sanborn maps, aerial overlays)

3 .a . and c included in hours for

preparation of 45-day Report . 3.b .

not required for preparation of 20 or

45-day Reports

.

4. Waste Disposal

a. Review disposal documentation

PM

1

5. Technical Evaluation

a. Prepare well location map (<25 records within 2500 feet)

b. Determine expected local site geology (subsurface soil conditions)

a. not required for preparation of 20

or 45-day Reports

.

b. included in hours for preparation

of 45-day Report

.

6. Plan and Report Preparation

a. Prepare 20-day Certification

PM

1

b. Prepare or revise site health and safety plan

Previously prepared under

734.845(a)(1) task 4a. No revision

necessary for preparation and

submission of 20 and 45-day

reports .

---

Sco a of Work

Personnel

Hours

Comments

3

c. Prepare 45-day Report

1 . Provide information pertaining to :

PM

8

A. Site Identification

B. Release Information

C. Early Action

D. Site Information

1 . Nature and estimated quantity of release

2. Data concerning

:

a. Surrounding populations

b. Water quality

c. Use and approximate locations of wells potentially affected by the release

d. Subsurface soil conditions

e. Location of subsurface sewers

f. Climatological conditions

g. Land use

3 . A discussion of what was done to measure for the presence of a release

4. Action taken to prevent further release of the regulated substance into the environment

5 . A discussion of the action taken to monitor and mitigate fire and safety hazards posed by

vapors of free product that has migrated from the UST excavation zone and entered

subsurface structures

E. Supporting Documentation

CAD Operator

8

1. Site map to scale and oriented north showing:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc .)

e . Nearby structures (buildings, roads, etc .)

f. Soil boring(s) (if present)

g. Monitoring well(s) and/or sumps (if present)

h. Property boundaries

i. Sample location points

2 . Area map showing the site in relation to surrounding properties . This map should identify the

facilities on the surrounding properties

3 . Cross-section, to scale, showing the USTs and the excavation

4. Analytical/screening results in tabular format, including the results of soil samples required

PM

2

pursuant to 35 Ill. Adm. Code 734.202(h) or 45 ILCS 5/57-57.17

.

---

Sco a of Work

4

~e.ovuu..

•

uuul,

l.uIIIuIOnW

5 . UST information in a tabular format, including

:

a. Total number of UST(s) on site

b. Volume of the UST(s) (in gallons)

c. The material stored in the UST(s)

d. Identification of UST system(s) that had a release

e. Identification of UST system(s) that were repaired, removed, or abandoned in-place

UST information table included on

Agency forms under 6.c.1.B. above

(Release Information)

6. Copy of OSFM Permits or notifications

Admin Asst

1

6, 8 & 9 combined for a total of 1

hour.

7. Narrative of tank removal and cleaning operations ; describe how wastes generated

during the tank removal were managed, treated, and disposed of

PM

1

8 . Photographs of UST removal activities and the excavation

9. Copies of waste manifests for soil and groundwater transported off-site

6, 8 & 9 combined for a total of 1

hour .

d. Review and certification of 20-Day and 45-Day Reports and application for payment

.

LPE or LPG

1

Certification added to IPCB's

proposal. PM/Senior staff reference

deleted. Added references to

application for payment

.

7. Resource Coordination

a. Call J.U .L.I.E. and/or municipality to locate utilities

Already done prior to tank removal

.

Not required for preparation and

submission of 20 and 45-day

reports .

8. Distribution

a. Deliver draft 20-day Certification and 45-Day Report and application for payment to

owner/operator for review and signature

b. Make copies of 20-Day Certification and 45-Day Report and application for payment

for

distribution

c. Deliver completed 20-Day Certification and 45-Day Report and application for payment to IEPA

and owner/operator

Admin Asst

2

Covers all copying and delivering

costs. Added references to

application for payment

.

9. Prepare application for payment

Account Tech

8

This is added to IPCB's proposal

.

Section 734.845(a)(6) Preparation and submission of free product removal reports

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with and update Illinois Environmental Protection Agency (IEPA)

b. Correspond with and update Client

2.a. already included in other line

items and 2 .b. is not corrective

action.

---

Sco a of Work

Personnel

Hours

Comments

5

3 . Waste Disposal

a. Review disposal documentation

PM

1

4. Free Product Report Preparation

a. Prepare Free Product Removal Report

1 . Provide information pertaining to

:

A. Site Identification

B. Free Product Information

1 . Name(s) of person(s) responsible for implementing the free product removal measures

2 . Estimated quantity, type, and thickness of free product observed or measured in boreholes,

wells, excavation, etc

.

3 . The type of free product recovery system used and technical justification for the method of

recovery chosen

4. Whether any discharge will take place on- or off-site during the recovery operation

and

where this discharge (point) will be located

5. Type of treatment applied to (the free product), and the effluent quality expected from any

discharge

6. Steps that have been taken or that are being taken to obtain necessary permits for any

discharge

7. The disposition of the recovered free product .

PM

4

C. Supporting Documentation

I . Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

;

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc .)

e. Nearby structures (buildings, roads, etc .)

f .

Soil boring(s) (if present)

g. Monitoring well(s) and/or sumps (if present)

h. Locations where free product was encountered including its estimated thickness

i. Location of recovery points

j . Location of the treatment unit

k. Location of discharge points

1. Property boundaries

CAD Operator

I

Site map already prepared under

Early Action. Only modifications

required at this point .

2. Table showing the dates that free product recovery was conducted and the amount of

free product recovered on each date

PM

I

3. Copies of waste manifests

Admin Asst

1

5. Review and certification of free product removal report

.

LPE or LPG

1

Added to IPCB's proposal

.

---

Sco a of Work

6

a1.JV1111G1

noun

wiiiicents

6 .

Distribution

a .

Deliver draft free product removal report to owner/operator for review and signature

b . Make copies of free product removal report for distribution

c. Deliver completed report to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs .

Section 734.845(a)(7) Preparation and submission of reports submitted pursuant to Section

734.210(h)(3)

1 . Site characterization/narrative

2. Characterization/narrative of water encountered in UST excavation

3. Completion of Property Owner Summary Form

4. Recording NFR Letter Early Action Completion Report

PM

Admin Asst

2

2

This report submitted as part of 45-

day Report. All other costs related

to this report are included in costs

for 45-day Report (e.g ., LPG/LPE

certification, distribution)

.

Section 734.845(b)(1) Preparation and submission of stage I site investigation plan

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a. already included in other line

items and 2.b. is not corrective

action .

3. Technical Evaluation

a

.

Determine expected local site geology (subsurface soil conditions)

b .

Evaluate backftll/piping samples to Tier 1 remediation objectives

c .

Determine drilling locations for soil samples and monitoring wells

d .

Demonstrate if groundwater investigation is required (if applicable)

e .

Conduct initial water supply well survey per 734 .315(a)(3)

PM

g

4. Plan Preparation

a. Prepare Stage 1 Site Investigation Plan

1. Provide information concerning

:

A. Site Identification

B. Site Information

I. Will owner/operator seek reimbursement from the UST Fund?

2. If yes, is budget attached?

3. Is this an amended plan?

4. Identify the material released

5. Describe the activities that will be performed to determine the following

:

a. Degree of soil contamination

b. Extent of soil contamination (as defined to Tier 1 Residential remediation objectives)

c. The degree of groundwater contamination

Stage I Plan consists of a

certification in the 45-day Report

that the Stage 1 investigation will be

conducted in accordance with 35

IAC 734.315 (Stage I site

investigation requirements),

therefore time for preparation and

submission of the Stage 1 Plan is

included under Section

734.845(a)(3) (preparation and

submission of 20-day and 45-day

reports) .

---

Sco a of Work

Personnel

Hours

Comments

7

d . Extent of groundwater contamination (as defined to Class I Remediation Objectives unless

otherwise approved by the Illinois EPA)

e. Direction of groundwater flow

f Hydraulic conductivity of groundwater

g. Identification of Site features that may affect contaminant transport and risk to human

health and the environment

6. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

f. Location of the proposed/existing soil borings

g. Location of the proposed/existing monitoring wells

h. Property boundaries

b. Prepare or update site health and safety plan

Previously prepared under

734.845(a)(1) task 4a. Not required

for preparation and submission of

Stage 1 plan .

c. Prepare budget

No preparation of budget is

required. Stage 1 Budget consists of

a certification in the 45-day Report

that the Stage 1 investigation costs

will not exceed the cost set forth in

Subpart H .

d. Review work to be done by project manager or other senior staff

e. Prepare LPE/LPG certification

Stage 1 plan submitted as part of 45-

day Report. Review and

certification costs included under

45-day Report review and

certification costs

.

5. Resource Coordination

a .

Arrange for drilling

b .

Call J.U .L.I.E. and/or municipality to locate utilities

PM

2

6. Distribution

a. Deliver draft plan and budget to owner/operator for review and signature

b. Make copies of plan and budget for distribution

c. Deliver completed plan and budget to Agency and owner/operator

Stage 1 Plan submitted as part of

45-day Report. These costs

included under 45-day Report costs .

---

Sco a of Work

rs

8

Section 734.845(b)(3) Preparation and submission of stage 2 site investigation plan

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2 .a. already included in other line

items and 2 .b. is not corrective

action.

3. Records Gathering

a. Obtain local information (e .g., Sanborn maps, aerial overlays, etc .)

b. Determine extent of property boundaries

These tasks already performed as

part of 45-day Report preparation .

4. Technical Evaluation

a. Address items in 35 IAC 734.320(b)

b. Prepare or finalize field notes

c. Prepare and describe site investigation photos

PM

CAD Operator

16

8

These hours cover technical work

performed (vs. report preparation

hours which are included under 5

below)

.

d. Prepare contingency scope of work for boring/monitoring well locations

Included under 5 below

.

5 . Plan Preparation

a .

Prepare Stage 2 Site Investigation Plan addressing items in 35 IAC 734 .320(b)

1. Provide information concerning:

A. Site Identification

B. Site Information

1. Will owner/operator seek reimbursement from the UST Fund?

2. If yes, is budget attached?

3 . Is this an amended plan?

4 . Identify the material released

5 . Describe the activities that will be performed to determine the following

:

a. Degree of soil contamination

b. Extent of soil contamination (as defined to Tier 1 Residential remediation objectives)

c. The degree of groundwater contamination

d. Extent of groundwater contamination (as defined to Class 1 Remediation Objectives unless

otherwise approved by the Illinois EPA)

e. Direction of groundwater flow

f. Hydraulic conductivity of groundwater

g. Identification of Site features that may affect contaminant transport and risk to human

health and the environment

.

h. The following parameters, if determined during Stage 2 investigation

:

Hydraulic conductivity

Soil bulk density

Soil particle density

PM

8

5.a.1 .B.5 .h and 5.a. LC added to

Board's proposal

.

Maps included under 4.a. above .

Site map already prepared under

earlier plans/reports. Only

modifications required at this point

.

---

Sco a of Work

Personnel

Hours

Comments

9

Moisture content

Organic carbon content

6. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b . Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

I. Location of the proposed/existing soil borings

g . Location of the proposed/existing monitoring wells

h. Property boundaries

C. Site Investigation Summary Form

b. Prepare budget

Account Tech

4

c. Prepare or review site health and safety plan

Previously prepared under

734 .845(a)(1) task 4a.

d. Review and certification of Stage 2 Site Investigation Plan, Budget, and Stage

1 application for

payment .

LPE/LPG

2

PM/Senior staff reference deleted

.

Added reference to application for

payment .

6. Resource Coordination

a.

Arrange for drilling

b .

Call J.U.L.I.E. and/or municipality to locate utilities

PM

2

7. Distribution

a. Deliver draft plan and budget and application for payment to owner/operator for review and signature

b. Make copies of plan and budget and application for payment for distribution

c. Deliver completed plan and budget and application for payment to IEPA and owner/operator

Adntin Asst

2

Covers all copying and delivering

costs. Added references to

application for payment

.

8 . Prepare Stage I applications for payment

Account Tech

8

This is added to IPCB's proposal

.

734.845(b)(5) Preparation and submission of stage 3 site investigation plan

The following hours are proposed in

lieu of time and materials for Stage

3 Site Investigation

.

I . Records Gathering

a. Obtain local information (e.g., Sanbom maps, aerial overlays, etc .)

b. Determine extent of property boundaries

These tasks are already performed

as part of 45-day Report

preparation

.

2. Technical Evaluation

a. Address items in 35 IAC 734 .325(b)

b. Prepare or finalize field notes

c. Prepare and describe site investigation photos

PM

CAD Operator

16

8

These hours cover technical work

performed (vs. report preparation

hours which are included under 3

below) .

---

Sco a of Work

10

uvwJ

I,VIIIIIICIILB

d. Prepare contingency scope of work for boring/monitoring well locations

.

Included under 3 below

.

3 . Plan Preparation

a. Prepare Stage 3 Site Investigation Plan addressing items in 35 IAC 734 .325(b)

1. Provide information concerning

:

A. Site Identification

B . Site Information

1. Will owner/operator seek reimbursement from the UST Fund?

2. If yes, is budget attached?

PM

8

Maps included under 2.a. above .

Site map already prepared under

earlier plans/reports. Only

modifications required at this point

3. Is this an amended plan?

4. Identify the material released

5. Describe the activities that will be performed to determine the following

:

a. Degree of soil contamination

b. Extent of soil contamination (as defined to Tier I Residential remediation objectives)

c. The degree of groundwater contamination

d. Extent of groundwater contamination (as defined to Class I Remediation Objectives unless

otherwise approved by the Illinois EPA)

e. Direction of groundwater flow

f. Hydraulic conductivity of groundwater

g. Identification of Site features that may affect contaminant transport and risk to human

health and the environment

.

h. The following parameters, if determined during Stage 3 investigation

:

Hydraulic conductivity

Soil bulk density

Soil particle density

Moisture content

Organic carbon content

6. Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

f Location of the proposed/existing soil borings

g. Location of the proposed/existing monitoring wells

h. Property boundaries

C. Site Investigation Summary Form

b. Prepare budget

Account Tech

c . Review and certification of Stage 3 Site Investigation Plan and Budget and Stage 2 application for

payment.

LPE/LPG

2

---

Scope of Work

Personnel

Hours

Comments

11

4 . Resource Coordination

a. Arrange for drilling

b. Call J.U.L.I.E. and/or municipality to locate utilities

PM

2

5. Distribution

a. Deliver draft plan and budget and application for payment to owner/operator for review and signature

b . Make copies of plan and budget and application for payment for distribution

c. Deliver completed plan and budget and application for payment to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs .

6. Prepare Stage 2 applications for payment

Account Tech

8

Section 734.845(b)(7) Off-site property access

Correspondence and meetings with off-site property owners

PM

4 for

each

off-site

property

4 hours total for each off-site

property to which off-site access is

sought. This work moved here from

the scope of work for 734 .845(b)(5)

above .

Section 734.845(b)(8) Well surveys conducted pursuant to Section 734 .445(b)

PM

4

Not required for all sites .

Section 734.845(b)(9) Preparation and submission of site investigation completion report

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2 .b. is not corrective

action .

3. Records Gathering

a. Obtain local information (e.g ., Sanborn maps, aerial overlays, etc .)

b. Determine extent of property boundaries

These tasks are already performed

as part of 45-day Report

preparation

.

4. Technical evaluation

a. Address items in 35 IAC 734 .330(a)(b) and (c)

c. Describe methods for investigating site and surrounding areas

.

d .

Describe the observations made while investigating site and surrounding areas

e .

Prepare or revise site maps per 35 IAC 734 .330(b)(2)-(4) that also show :

1 . Distance of at least 1,000 feet around UST (scale > 1 :200)

2. Location of site with respect to section, township and range

3 . On-site and off-site injection and withdrawal wells affected by release

f

.

Evaluate existing and potential migration pathways and exposure routes

PM

16

---

Sco a of Work

12

g. Compile information regarding site-specific sampling activities and methods, including

:

1 . Sample collection information (date, time, method, location, sampler)

2. Sample preservation and shipment information, including QA/QC

3. Field and lab blank documentation

h .

Interpret the results of the site investigation

i .

Describe the release and evaluation exposure routes

j

.

Describe the nature, concentration and extent of indicator contaminants

k .

Prepare or finalize field notes

1. Prepare and describe site investigation photos

m. Provide analysis of hydraulic conductivity test data from a single well

n .

Provide description of physical features that may affect contaminant transport

~eavvuu~ .

•

1..V111111C111J

5. Report Preparation

a

.

Prepare Site Investigation Completion Report addressing items in 35 IAC 734 .330(a)(b) and (c)

1. Provide information concerning

:

A. Site Identification

B. Site Information

C. Site Investigation Results

1. Site History/Executive Summary

2 . Narrative of field activities including sampling methods

3 . Discussion of development of remediation objectives

4 . Analytical results and remediation objectives in tabular format

5. Conclusions

6. Site maps to scale

a. UST system(s) and excavation limits

b. Product and dispenser lines

c. Pumps and islands

d. Underground utilities (sewer, gas, water, etc)

e. Nearby structures (buildings, roads, etc .)

f . Location of the soil borings

g. Location of the existing monitoring wells

h. Property boundaries

7. Soil boring logs

8. Well completion reports

9. Laboratory Reports and

10 . Laboratory Certification

D. Site Investigation Summary Form

PM

CAD Operator

4

4

Site map already prepared under

earlier plans/reports. Only

modifications required at this point

.

Site Investigation Summary Form

added to IPCB's proposal

.

b. Prepare appendices containing references and data sources, log, lab reports, etc

.

Included in 4 and 5 .a above

.

---

Sco a of Work

Personnel

Hours

Comments

13

c .

Review and certification of site investigation completion report and Stage 3 application for payment .

LPE or LPG

2

PM/Senior staff reference deleted .

Reference to application for

payment added .

6. Distribution

a .

Deliver draft site investigation completion report and application for payment to owner/operator

for review and signature

b

.

Make copies of site investigation completion report and application for payment for distribution

c .

Deliver completed report and application for payment to IEPA and owner/operator

Admin Asst

2

Covers all copying and delivering

costs. Reference to application for

payment added .

7. Prepare Stage 3 applications for payment for last stage of site investigation

Account Tech

8

This is added to IPCB's proposal

.

Section 734.845(c)(1) Preparation and submission of corrective action plan (Conventional Tech)

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2.b. is not corrective

action.

3. Waste Disposal

a. Prepare waste profile (arrange for landfill approval)

Tech

4

These hours include field work that

is not covered under the half-day

rates .

b .

Determine limits of excavation

c. Estimate quantity of contaminated soil to be disposed of

d.

Mail waste profile to owner/operator for review and signature

e .

Prepare waste manifests or tracking forms

.

PM

4

4. Technical Evaluation

a. Estimate quantity of "clean" overburden to be stockpiled (if any)

.

Included in 3.b above

b .

Prepare or finalize field notes

c. Prepare and describe remediation photos

This work part of preparation and

submission of Corrective Action

Completion Report. (see items 4.b

and c. under scope of work for

Section 734.845(c)(4)) .

5 . Plan Preparation

a. Prepare or review site health and safety plan

Previously prepared under

734.845(a)(1), item 4a .

---

Sco a of Work

14

~~~ uvu.n

<.uulrucufl

b. Prepare Corrective Action Plan

1 . Provide information concerning

:

A. Site Identification

B. Site Information

C. Proposed Methods of Remediation

D

. ' Soil and Groundwater Investigation Results

I . Description of investigation activities performed to define the extent of soil and/or

groundwater contamination

2. Analytical results and cleanup objectives in tabular format

3 . Laboratory results

4. Boring logs

5 . Monitoring well logs ; and

6. Site maps to scale and oriented north showing

:

a. Soil sample locations

b. Monitoring well locations

c. Plumes of soil and groundwater contamination

PM

CAD Operator

2

2

Site map already prepared under

earlier plans/reports. Only

modifications required at this point

.

E. Technical Information - Corrective Action Plan

1 . Discussion of how the corrective action plan shall remediate the release

2 . List of sampling parameters and corresponding remediation objectives

3. Basis for determining sampling parameters and remediation objectives

4. Media sampling plan to verify completion of remediation

5. Current and future use of the property

6. Proposed preventive, engineering and institutional controls

7. Schedule for implementation and projected completion of the plan

8. Engineering design specifications, diagrams, calculations, manufacturer's specifications,

systems analsyses, site maps, etc

.

PM

16

c . Prepare budget for corrective action plan

Account Tech

8

d. Review and certification of corrective action plan and budget

LPE or LPG

4

PM/Senior staff reference deleted .

6. Resource Coordination

PM

16

Reference to individual

a. Schedule project

subcontracted activities changed to

b. Arrange for subcontractors

c. Call J.U.L.I.E. and/or municipality to locate utilities

"subcontractors ."

7 . Distribution

Admin Asst

2

Covers all copying and delivering

a. Deliver draft corrective action plan and budget to owner/operator for review and signature

.

b. Make copies of corrective action plan and budget for distribution

.

c. Deliver completed corrective action plan and budget to IEPA and owner/operator .

costs

.

---

Scope of Work

Personnel

Hours

Comments

15

Section 734.845(c)(3) Environmental Land Use Controls and Highway Authority Agreements

PM

8

8 hours total for each ELUC &

HAA. Standardized documents

being proposed in separate TACO

rulemaking .

Section 734.845(c)(4) Preparation and submission of corrective action completion report

These tasks apply to Corrective

Action Completion Reports for both

conventional and alternative

technologies. IPCB's proposal

referenced only conventional

technologies .

1. Project Management

All Project Management work is

identified under Personnel Column

as PM .

2. Correspondence

a. Correspond with Agency

b. Correspond with and update client

2.a. already included in other line

items and 2.b. is not corrective

action.

3. Records Gathering

a. Obtain legal description of property

b. Obtain property tax identification number

Included in hours for preparation of

Corrective Action Completion

Report .

4. Technical Evaluation

a. Address items in 35 IAC 734 .345(a)?

b. Prepare and describe photos

c. Prepare or finalize field notes

Included in 5 below.

5. Report Preparation

a. Prepare Corrective Action Completion Report following items in 35 IAC 734 .345(a)

1. Provide information concerning

:

a. Site Identification

b. Site Information

c. Completion Information

I . Chronological narrative of corrective action activities

2. Explanation of how the corrective action activities remediated the release

3. Discussion of how the remediation objectives were determined

4. Media sampling and analytical procedures to verify completion of remediation

5. Analytical results and remediation objectives in tabular format

6. Laboratory results

7. Soil boring logs

8. Monitoring well logs

9. Laboratory certification

10. Applicable Professional Engineer Certification

PM

CAD Operator

32

8

Professional engineer certification

included under 5 .b. below .

Site map already prepared under

earlier plans/reports . Only

modifications required at this point

.

---

Sco a of Work

16

11

.

Site maps to scale and oriented north showing

:

a. Final soil sample locations demonstrating completion of remediation

b. Groundwater monitoring well locations

c. Groundwater recovery/discharge points

d. Plume of contamination as defined by laboratory analyses

e. Area remediated

12. Property Owner Summary

13. Photographs documenting corrective action activities

b. Review and certification of corrective action completion report and application

for payment

.

LPE

4

PM/Senior staff reference deleted

.

Reference to applications for

payment added.

6. Resource Coordination

a. Record NFR letter

Admin Asst

2

7. Distribution

a. Deliver draft corrective action completion report and application for payment to owner/operator

for review and signature

b. Make copies of corrective action completion report and application for payment

for

distribution

c. Deliver completed corrective action completion report and application for payment to IEPA and

owner/operator

d. Make copies of recorded NFR letter for distribution

e. Deliver recorded NFR letter to IEPA and owner/operator

Admin Asst

3

Covers all copying, delivering costs

and recording of NFR letter

.

References to applications for

payment added.

8. Prepare applications for payment

Account Tech

8

This has been added to the IPCB's

proposal .

Section 734.845(d)(2) Development of Tier 2 or Tier 3 remediation objectives

PM

8

Section 734.845(f) Amendment of plan due to unforeseen circumstances and its associated budget

PM

Acct Tech

6

2

---

ATTACHMENT C TO IEPA'S POST-HEARING COMMENTS

SUMMARY OF PROFESSIONAL CONSULTING SERVICES LUMP SUMS FOR PART 732 *

Section/Title

Personnel/Hours

Total from Task

Breakdown

(Spreadsheet)

Amount

Proposed in

Subpart H

High

Low

732.845(a)(1) Preparation for the abandonment or

removal of USTs

Tech/3

PM/9

$1095'''

$945'''

$960'

732.845(a)(3) Preparation and submission of 20-day

and 45-day reports

PM/13

CAD/8

Acct Tech/8

Admin Asst/3

LPE/LPG/1

$2485'1''

$193712

2,3

$4800"2

732.845(a)(7) Preparation and submission of free

product removal reports

PM/6

CAD/1

Admin Asst/3

LPE/LPG/1

$925

$747

$1600

732.845(a)(8) Preparation and submission of reports

submitted pursuant to Section 732 .202(h)(3)

PM/2

Admin Asst/2

$290

$230

$500

732.845(b)(1) Preparation and submission of site

classification plans, site classification preparation,

fieldwork, field oversight, and the preparation and

submission of the site classification completion

report

PM/40

Geologist/10

CAD/13

Tech/20

LPE/LPG/4

Admin Asst/4

Acct Tech/12

$85401

$66082

$98702

732.845(c)(1) Preparation and submission of low

priority groundwater monitoring plan

PM/8

Acct Tech/4

LPE/LPG/2

Admin Asst/2

$1370

$1094

$3200

732.845(c)(3) Preparation and submission of first

year groundwater monitoring reports

PM/8

CAD/2

LPE/LPG/2

Admin Asst/2

Account Tech/4

$1490

$1174

$2560

732.845(c)(4) Preparation and submission of second

year groundwater monitoring reports

PM/8

CAD/2

LPE/LPG/2

Admin Asst/2

Account Tech/4

$1490

$1174

$2560

732.845(c)(5) Preparation and submission of low

priority groundwater monitoring completion report

PM/8

CAD/2

LPE/LPG/2

Admin Asst/2

Account Tech/4

$1490

$1174

$2560

732.845(d)(1)(A) Preparation and submission of

investigation plans for on-site contamination for

sites classified pursuant to Section 732 .307

PM/26

CAD/8

Account Tech/4

LPE/LPG/2

Admin Asst/2

$3650

$3034

$3200

---

In the IEPA's proposal preparation of Health and Safety Plan costs were included in the preparation of the 20 Day and 45 Day Report

cost. In this breakdown, preparation of Health and Safety Plan costs are included in preparation for the abandonment or removal of USTs

.

x In the IEPA's proposal potable water supply well survey costs were included in the preparation of the 20 Day and 45 Day Report costs

.

In this breakdown, potable water supply well survey costs are included in Site Classification costs

.

3

Early action field work previously included in these lump sums have been moved to field work and field oversight unit rates . See

proposed additions to Section 732 .845(a)(2) .

*Note: This summary includes only lump sum amounts for Professional Consulting Services. It does not

include professional consulting services costs reimbursed on a unit rate or time and materials basis

.

2

Section/Title

Personnel/Hours

Total from Task

Breakdown

(Spreadsheet)

Amount

Proposed in

Subpart H

High

Low

-

732.845(d)(1)(B) Preparation and submission of

investigation plans for off-site contamination for

sites classified pursuant to Section 732 .307

PM/26

CAD/8

Account Tech/12

LPE/LPG/2

Admin Asst/2

$4090

$3314

$3200

732.845(d)(3) Off-site property access

_

PM/4 per off-site

property

$400 per

off-site

property

$360 per

off-site

property

732.845(d)(4) Well surveys conducted pursuant to

Sections 732.404(e)(1) and 734 .445(b)

PM/4

$400

$360

$160

732.845(d)(5) Preparation and submission of

corrective action plan (Conventional)

PM/38

Tech/4

CAD/2

Account Tech/ 16

LPE/LPG/4

Admin Asst/2

$5670

$4658

$5120

732.845(d)(7)(B) Development of Tier 2 or Tier 3

remediation objectives

PM/8

$800

$720

$800

732.845(d)(8) Environmental Land Use Controls and

Highway Authority Agreements

PM/8

$800

$720

$800

732.845(d)(9) Preparation and submission of

corrective action completion report

PM/32

CAD/8

LPE/4

Admin Asst/5

Account Tech/8

$4865

$4045

$5120

732.845(f) Amendment of plan and its associated

budget

PM/6

Account Tech/2

$710

$610

$640

High Low

High

Low

LPE/LPG

$130

$92

CAD

$60

$40

PM

$100

$90

Admin Asst

$45

$25

Tech

$65

$45

Acct Tech

$55

$35

Geologist

$110

$70

---

ATTACHMENT D TO IEPA'S POST-HEARING COMMENTS

SUMMARY OF PROFESSIONAL CONSULTING SERVICES LUMP SUMS FOR PART 734 *

Section/Title

Personnel/Hours

Total from Task

Breakdown

(Spreadsheet)

Amount

Proposed in

Subpart H

High

Low

734.845(a)(1) Preparation for the abandonment or

removal of USTs

Tech/3

PM/9

$1095'°3

$945''3

$960'

734.845(a)(3) Preparation and submission of 20-day

and 45-day reports

PM/13

CAD/8

Acct Tech/8

Admin Asst/3

LPE/LPG/1

$2485123

$1937''' 3

$4800 12

734.845(a)(7) Preparation and submission of free

product removal reports

PM/6

CAD/1

LPE/LPG/1

Admin Asst/3

$925

$747

$1600

734.845(a)(8) Preparation and submission of reports

submitted pursuant to Section 734 .2 10(h)(3)

PM/2

Admin Asst/2

$290

$230

$500

734.845(b)(1) Preparation and submission of stage 1

site investigation plan

PM/10

$1000

$900

$1600

734.845(b)(3) Preparation and submission of stage 2

site investigation plan

PM/26

CAD/8

Acct Tech/ 12

Admin Asst/2

LPE/LPG/2

$4090'

$33141

$32001

734.845(b)(5) Preparation and submission of stage 3

site investigation plan

PM/26

CAD/8

Acct Tech/12

LPE/LPG/2

Admin Asst/2

$4090

$3314

$3200-

Agency

T&M -

Board

734.845(b)(7) Off-site property access

PM/4 per off-site

property

$400 per

off-site

property

$360 per

off-site

property

734.845(b)(8) Well surveys conducted pursuant to

Section 734.445(b)

PM/4

$400

$360

$160

734.845(b)(9) Preparation and submission of site

investigation completion report

PM/20

CAD/4

LPE/LPG/2

Admin Asst/2

Acct Tech/8

$3030

$2474

$1600

734.845(c)(1) Preparation and submission of

corrective action plan (Conventional)

PM/38

Tech/4

CAD/2

Acct Tech/8

LPE/LPG/4

Admin Asst/2

$5230

$4378

$5120

---

In the IEPA's proposal preparation of Health and Safety Plan costs were included in the preparation of the 20 Day and 45 Day Report

cost. In this breakdown, preparation of Health and Safety Plan costs are included in preparation for the abandonment or removal of USTs

.

2

In the IEPA's proposal potable water well survey costs were included in the preparation of the 20 Day and 45 Day Report costs

. In this

breakdown, potable water well survey costs are included in Stage 2 Site Investigation Plan costs

.

a Early action field work previously included in these lump sums have been moved to field work and field oversight unit rates

. See

proposed additions to Section 734 .845(a)(2) .

*Note: This summary includes only lump sum amounts for Professional Consulting Services. It does not

include professional consulting services costs reimbursed on a unit rate or time and materials basis .

2

Section/Title

Personnel/Hours

Total from Task

Breakdown

(Spreadsheet)

Amount

Proposed in

Subpart H

High

Low

734.845(c)(3) Environmental Land Use Controls and

Highway Authority Agreements

PM/8

$800

$720

$800

734.845(c)(4) Preparation and submission of

corrective action completion report

PM/32

CAD/8

LPE/LPG/4

Admin Asst/5

Acct Tech/8

$4865

$4045

$5120

734.845(d)(2) Development of Tier 2 or Tier 3

remediation objectives

PM/8

$800

$720

$800

734.845(f) Amendment of plan and its associated

budget

PM/6

Acct Tech/2

$710

$610

$640

High Low

High

Low

LPE/LPG

$130

$92

CAD

$60

$40

PM

$100

$90

Admin Asst

$45

$25

Tech

$65

$45

Acct Tech

$55

$35

Geologist

$110

$70

---

ATTACHMENT E TO IEPA'S POST-HEARING COMMENTS

PROPOSED SECTION 732.845

Section 732.845 Professional Consulting Services

Payment for costs associated with professional consulting services must not exceed the amounts

set forth in this Section. Such costs must include, but not be limited to, those associated with

project planning and oversight ; field work; field oversight; travel; per diem; mileage;

transportation; vehicle charges; lodging; meals; and the preparation, review, certification, and

submission of all plans, budget plans, reports, applications for payment, and other

documentation. The maximum payment amounts set forth in this Section are not subject to the

provisions of Section 732 .855 of this Part .

a) Early Action and Free Product Removal. Payment of costs for professional

consulting services associated with early action and free product removal

activities conducted pursuant to Subpart B of this Part must not exceed the

following amounts

:

1) Payment for costs associated with preparation for the abandonment or

removal of USTs, including the tasks listed in Appendix F of this Part,

must not exceed a total of $1,095 .00$940=90

.

2) Payment for costs associated with early action field work and field

oversight must not exceed a total of $390 .00 per half-day, plus travel costs

in accordance with subsection (e) of this Section . The number of half-

days must not exceed the following

:

One half-day for field work and field oversight required to comply

with Section 732 .202(a) of this Part other than the mitigation of

fire explosion, or vapor hazards pursuant to Section 732 .202(a)(3)

.

Activities associated with the mitigation of fire,

explosione

or

vapor hazards pursuant to Section 732 .202(x)(3) are subject to

subsection(a)(4)of this Section instead of this subsection

a()(2)(A)

.

B) One half-day for field work and field over sig htrequired to comply

withSection 732.202(h of this Part other than continued

monitoring and mitigation of fire, explosion, or vapor hazards

ur

nJ to Section 732.202(b)(3)_eActivities associated with

n i monitoring and mitigation of fire

explosionl

or vapor

hazards pursuant to Section 732 .202(b)(3) are subject to subsection

(a)!4

of this

ection instead of this subsection (a)(2__l(B)

QA4

Ifone or moreUSTs are removed, one half-day for each leaking

UST that is removed, not to exceed a total of ten half-days, plus

one half-day for each 225 cubic yards, or fraction thereof, of

visibly contaminated fill material removed and disposed of in

accordance with Section 732 .202(f) of this Part ;

---

D)B4

If one or more USTs remain in place, one half-day for every four

soil borings, or fraction thereof, drilled pursuant to Section

732.202(h)(2) of this Part;

EQ4

One half-day if a UST line release is repaired' and=

F_) One half-da_v for field work and field oversight required for the

preparation and submission of the 45-day report other than the

field work nd fie

•

'versi

ht re uired unde

ection 732.202

and (b) of this_Section._

3) Payment for costs associated with the preparation and submission of 20-

day and 45-day reports, including the tasks listed in Appendix F of this

Part:

. _ ;- == _ _=_= - = must

not exceed a total of $24,85.00$4 =Q .

4) Payment for costs associd with the monitoring _snd miti

tp ion of fire

explosion, or vapor hazards required under Sections 732.202(x)(31 and

(b)(3)of this Part must be determined on a time and materials basis and

mast not exceed the amounts set fo

h in

e tion 73.850 of this Part .

5)44

Payment for costs associated with the preparation and submission of free

product removal plans and the installation of free product removal systems

must be determined on a time and materials basis and must not exceed the

amounts set forth in Section 732 .850 of this Part .

6)$4

Payment for costs associated with the field work and field oversight for

free product removal must not exceed a total of $390.00 per half-day, plus

travel costs in accordance with subsection (e) of this Section . The Agency

must determine the reasonable number of half-days on a site-specific

basis .

P

7)64

Payment for costs associated with the preparation and submission of free

product removal reports, including the tasks listed in Appendix F of this

art must not exceed a total of

925.00 per re ort .

8)R4

Payment for costs associated with the preparation and submission of

reports submitted pursuant to Section 732.202(h)(3) of this Part must not

exceed a total of 290.00

.

2

---

b) Site Evaluation and Classification . Payment of costs for professional consulting

services associated with site evaluation and classification activities conducted

pursuant to Subpart C of this Part must not exceed the following amounts

:

1) For site evaluation and classifications conducted pursuant to Section

732.307 of this Part, payment for costs associated with the preparation and

submission of site classification plans, site classification preparation, field

work, field oversight, and the preparation and submission of the site

classification completion report, including the tasks listed in Appendix F

of this Part, must not exceed a total of $1 540.00 .

2) For site evaluation and classifications conducted pursuant to Section

732.312 of this Part, payment for costs must be determined on a time and

materials basis and must not exceed the amounts set forth in Section

732.850 of this Part. For owners and operators that elect to proceed in

accordance with 35 Ill. Adm. Code 734, costs incurred after the

notification of election shall be payable from the Fund in accordance with

that Part .

c) Low Priority Corrective Action . Payment of costs for professional consulting

services associated with low priority corrective action activities conducted

pursuant to Subpart D of this Part must not exceed the following amounts

:

1) Payment for costs associated with the preparation and submission of low

priority groundwater monitoring plans, including the tasks listed in

AppendixF ofthis Part, must not exceed atotal of

1.370.00

.

2) Payment for costs associated with low priority groundwater monitoring

field work and field oversight must not exceed a total of $390 .00 per half-

day, up to a maximum of seven half-days, plus travel costs in accordance

with subsection (e) of this Section

.

3) Payment for costs associated with the preparation and submission of the

first year groundwater monitoring report, including the tasks listed in

Appendix F ofthis Part, must not exceed a total of

1.490.00

.

4) Payment for costs associated with the preparation and submission of the

second year groundwater monitoring report, including the tasks listed in

Appendix F of this Part, must not exceed a total of $1,490.0® .

5) Payment for costs associated with the preparation and submission of low

priority groundwater monitoring completion report, including the tasks

listed in Appendix F of this Part, must not exceed a total of

$14 0 . 0

, . .

3

---

d) High Priority Corrective Action . Payment of costs for professional consulting

services associated with high priority corrective action activities conducted

pursuant to Subpart D of this Part must not exceed the following amounts

:

1) Payment for costs associated with the preparation and submission of

investigation plans for sites classified pursuant to Section 732 .307 of this

Part, including the tasks listed in Appendix F of this Part, must not exceed

the following :

A total of 50.00 for plans to investigate on-site

contamination in udin

't

heed

irt-Appsir~"

t

n

7

~ 6~#iG~F

B)

A totalofd 090 00 $for plans to investigate off-site

contamination

' tg

2) Payment for costs associated with field work and field oversight to define

the extent of contamination resulting from the release must not exceed a

total of $390.00 per half day, plus travel costs in accordance with

subsection (e) of this Section . The number of half-days must not exceed

the following :

A) One half-day for every four soil borings, or fraction thereof, drilled

as part of the investigation but not used for the installation of

monitoring wells. Borings in which monitoring wells are installed

must be included in subsection(d)(2)(B)of this Section instead of

this subsection(d)(2)(A);and

B) One half-day for each monitoring well installed as part of the

investigation

.

3L

Payment for costs associated with obtaining access to off-sit~ro .erties,

includin

he task listed in A

endix F of this Part must not exceed a

total of $400 for each off-site .ro.e o which access is sou

ht

41'

Payment for costs associated with well surveys conducted pursuant to

Section 732.404(e)(l) of this Part, including the tasks listed in Appendix F

of this Part must not exceed a to al of 400 00$x . Pa

ent for costs

associated with well surveys conducted pursuant to Section 732 .404(e)(2)

of this Part must be determined on a time and materials basis and must not

exceed the amounts set forth in Section 732 .850 of this Part .

514)

For conventional technology, payment for costs associated with the

preparation and submission of corrective action plans, including the tasks

listed in Appendix F of this Part, must not exceed a total of

5 67000 .For alternative technologies, payment for costs must

4

---

be determined on a time and materials basis and must not exceed the

amounts set forth in Section 732.850 of this Part .

6)_4

Payment for costs associated with high priority corrective action field

work and field oversight must not exceed the following amounts :

A) For conventional technology, a total of $390.00 per half-day, not to

exceed one half-day for each 225 cubic yards, or fraction thereof,

of soil removed and disposed, plus travel costs in accordance with

subsection (e) of this Section

.

B) For alternative technologies, payment for costs must be determined

on a time and materials basis and must not exceed the amounts set

forth in Section 732 .850 of this Part

.

Z)=!~

Development of Tier 2 and Tier 3 Remediation Ob 'ectives. Pa ent of

costs for professional consulting services associated with the development

of Tier 2 and Tier 3 remediation objectives in accordance with 35 Ill

.

Adm. Code 742 must not exceed the following amounts :

A) Payment for costs associated with field work and field oversight

for the development of remediation objectives must not exceed a

total of $390.00 per half-day, plus travel costs in accordance with

subsection (e) of this Section . The number of half-days must not

exceed the following :

i) One half-day for every four soil borings, or fraction

thereof, drilled solely for the purpose of developing

remediation objectives. Borings in which monitoring wells

are installed must be included in subsection (dy-7)f A)fii)

'a" of this Section instead of this subsection

(dl(7)(Al(il ( f~ ; and

ii) One half-day for each monitoring well installed solely for

the purpose of developing remediation objectives

.

B) Excluding costs set forth in subsection(d7 A) of this

Section, payment for costs associated with the development of Tier

2 or Tier 3 remediation objectives, including the tasks listed in

Appendix F of this Part, must not exceed a total of $800 .00 .

8),4

Payment for costs associated with Environmental Land Use Controls and

Highway Authority Agreements used as institutional controls pursuant to

35 Ill. Adm. Code 742, including the tasks listed in Appendix F of this

Part, must not exceed a total of $800 .00 per Environmental Land Use

Control or Highway Authority Agreement .

5

---

$~

Payment for costs associated with the preparation and submission of high

priority corrective action completion reports, including the tasks listed in

Appendix F of this Part, must not exceed a total of

$4,865 .0

0$x .

e) Payment for costs associated with travel, including, but not limited to, travel time,

per diem, mileage, transportation, vehicle charges, lodging, and meals, must not

exceed the following amounts . Costs for travel must be allowed only when

specified elsewhere in this Part

.

Distance to site Maximum total amount

(land miles) per calendar day

0 to

29

$140.00

30 to

59

$220.00

60

or more $300.00

Distances must be measured in ground miles and rounded to the nearest mile . If a

consultant maintains more than one office, distance to the site must be measured

from the consultant's office that is closest to the site

.

f) If a plan must be amended due to unforeseen circumstances, costs associated with

the amendment of the plan and its associated budget plan, including the tasks

listed in Appendix F of this Part, must not exceed a total of

710.0 .

6

---

ATTACHMENT F TO IEPA's POST-HEARING COMMENTS

PROPOSED SECTION 734.845

Section 734.845

Professional Consulting Services

Payment for costs associated with professional consulting services must not exceed the amounts

set forth in this Section . Such costs must include, but not be limited to, those associated with

project planning and oversight ; field work; field oversight; travel; per diem; mileage ;

transportation ; vehicle charges; lodging; meals; and the preparation, review, certification, and

submission of all plans, budgets, reports, applications for payment, and other documentation .

The maximum payment amounts set forth in this Section are not subject to the provisions of

Section 734.845 of this Part .

a)

Early Action and Free Product Removal. Payment of costs for professional

consulting services associated with early action and free product removal

activities conducted pursuant to Subpart B of this Part must not exceed the

following amounts

:

1)

Payment for costs associated with preparation for the abandonment or

removal of USTs, including the tasks listed in Appendix F of the Part,

must not exceed a total of

dam

.

2)

Payment for costs associated with early action field work and field

oversight must not exceed a total of $390 .00 per half-day, plus travel costs

in accordance with subsection (e) of this Section . The number of half-

days must not exceed the following

:

A) One half-day for field work and field oversight required to comply

with Section 734.210( a) of this Part other than the mitigation of

fire explosionror vapor hazards pursuant to Section 734 .210(4)f 3).

Activities associated with the mitigation of fire, explosion . or

vapor hazards pursuant to Section 734 .210(a)(3) are subject to

subsection (a)(41 of this Section instead ofthis subsection

a2A

.

Bl One half-day for field work and field over si

t re uired to com

y

with Section 734.210(b) of this Part other than continued

monitoring and mitigation of fire, explosion, or vapor hazards

pursuant to Section 734.210(b)(3-).Activities associated with

ccntinued monitoring and mitigation of fire, explosion, or vapor

hazards p rsuant to Section 734.210(b)(3) are subject to subsection

(a)(4)of this Section instead of this subsection (al(21(Bl

.

QA)

If one or more USTs are removed, one half-day for each leaking

UST that is removed, not to exceed a total of ten half-days, plus

one half-day for each 225 cubic yards, or fraction thereof, of

visibly contaminated fill material removed and disposed of in

accordance with 734.210(f) of this Part

;

---

If one or more USTs remain in place, one half-day for every four

soil borings, or fraction thereof, drilled pursuant to Section

734.210(h)(2) of this Part;

One half-day if a UST line release is repaired

.

FlOne half-da

for field work and field oversi ht re uired for the

preparation and submission of the 45-day report other than the

field work and field overs

ht

i ed under

on 7 4 210

3)

Payment for costs associated with the preparation and submission of 20-

day and 45-day reports and the Stage 1 plan certification required under

Section 734 .315(bl of this Part, including the tasks listed in Appendix F of

this Part

must not exceed a total of 2 485 .004 Ef9 ~.

4)

Payment for costs associated with the monitoring and mitigation of fire

explosion, or vapor hazards reauired under Sections 734 210(a)(3) and

(b)(3)of this Part must be determined on a time and materials basis and

must not exceed the amounts set forth in Section 734 .850 of this Part .

5)4)

Payment for costs associated with the preparation and submission of free

product removal plans and the installation of free product removal systems

must be determined on a time and materials basis and must not exceed the

amounts set forth in Section 734.850 of this Part .

Payment for costs associated with the field work and field oversight for

free product removal must not exceed a total of

90.00

per half-

day, plus travel costs in accordance with subsection (e)of this Section

.

The Agency must determine the reasonable number of half-days on a site-

specific basis .

Payment for costs associated with the preparation and submission of free

product removal reports, including the tasks listed in Appendix F of this

Part, must not exceed a total of 2.00

per report

.

054

Payment for costs associated with the preparation and submission of

reports submitted pursuant to Section 734.2 10(h)(3) of this Part, including

the tasks listed in Appendix F of this Part, must not exceed a total of

290.00$® .

2

---

.b)

Site Investigation. Payment of costs for professional consulting services

associated with site investigation activities conducted pursuant to Subpart C of

this Part must not exceed the following amounts

:

1)

Payment for costs associated with preparation for the implementation of

the Stage 1 site investigation

, including the

tasks listed in Appendix F of this Part, must not exceed a total of

$1,000.00

.

.

2)

Payment for costs associated with Stage I field work and field oversight

must not exceed a total of $390.00 per half-day, plus travel costs in

accordance with subsection (e) of this Section. The number of half-days

must not exceed the following

:

A)

One half-day for every four soil borings, or fraction thereof, drilled

as part of the Stage 1 site investigation but not used for the

installation of monitoring wells. Borings in which monitoring

wells are installed must be included in subsection (b)(2)(B) of this

Section instead of this subsection (b)(2)(A) ; and

B)

One half-day for each monitoring well installed as part of the Stage

I site investigation .

3)

Payment for costs associated with the preparation and submission of Stage

2 site investigation plans, including the tasks listed in Appendix F of this

Part, must not exceed a total of$4,090-04;-

.

240=90-

4)

Payment for costs associated with Stage 2 field work and field oversight

must not exceed a total of $390.00 per half-day, plus travel costs in

accordance with subsection (e) of this Section. The number of half-days

must not exceed the following

:

A)

One half-day for every four soil borings, or fraction thereof, drilled

as part of the Stage 2 site investigation but not used for the

installation of monitoring wells. Borings in which monitoring

wells are installed must be included in subsection (b)(4)(B) of this

Section instead of this subsection (b)(4)(A) ; and

B)

One half-day for each monitoring well installed as part of the Stage

2 site investigation

.

5)

Payment for costs associated with the-pre paration and submission of Stage

3

site investigation plans. including the tasks listed in Appendix F

f th s

Pa

must Uot exceed a total of $ ,,090.00 .

----- ---------

3

---

6)

Payment for costs associated with Stage 3 field work and field oversight

must not exceed a total of $390 .00 per half-day, plus travel costs in

accordance with subsection (e) of this Section . The number of half-days

must not exceed the following

:

A)

One half-day for every four soil borings, or fraction thereof, drilled

as part of the Stage 3 site investigation but not used for the

installation of monitoring wells . Borings in which monitoring

wells are installed must be included in subsection (b)(6)(B) of this

Section instead of this subsection (b)(6)(A)

; and

B)

One half-day for each monitoring well installed as part of the Stage

3 site investigation

.

7) Payment for costs associated with obtaining access to off-site properties

including the tasks listed in Appendix F of this Part, must not exceed a

total of $400 for each off-site property to which access is sought .

Payment for costs associated with well surveys conducted pursuant to

Section 734.445(b) of this Part, including the tasks listed in Appendix F of

this Part, must not exceed a total of

400.0

.

.

Payment for costs

associated with well surveys conducted pursuant to Section 734.445(c) of

this Part must be determined on a time and materials basis and must not

exceed the amounts set forth in Section 734.850 of this Part .

Payment for costs associated with the preparation and submission of site

investigation completion reports, including the tasks listed in Appendix F

of this Part, must not exceed a total of

03

.0

.

.

904

c)

Corrective Action. Payment of costs for professional consulting services

associated with corrective action activities conducted pursuant to Subpart C of

this Part must not exceed the following amounts

:

1)

For conventional technology, payment for costs associated with the

preparation and submission of corrective action plans, including the tasks

listed in Appendix F of this Part, must not exceed a total of

X5.230 .

i 0$`,

.

For alternative technologies, payment for costs must

be determined on a time and materials basis and must not exceed the

amounts set forth in Section 734.850 of this Part .

2)

Payment for costs associated with corrective action field work and field

oversight must not exceed the following amounts

:

A)

For conventional technology, a total of $390 .00 per half-day, not to

exceed one half-day for each 225 cubic yards, or fraction thereof,

4

---

of soil removed and disposed, plus travel costs in accordance with

subsection (e) of this Section .

B)

For alternative technologies, payment for costs must be determined

on a time and materials basis and must not exceed the amounts set

forth in Section 734 .850 of this Part .

3)

Payment for costs associated with Environmental Land Use Controls and

Highway Authority Agreements used as institutional controls pursuant to

35 Ill. Adm. Code 742, including the tasks listed in Appendix F of this

Part, must not exceed a total of $800.00 per Environmental Land Use

Control or Highway Authority Agreement

.

4)

Payment for costs associated with the preparation and submission of

corrective action completion reports, including the tasks listed in

Appendix F of this Part, must not exceed a total of S465

.0x .

d)

Development of Tier 2 or Tier 3 Remediation Objectives . Payment of costs for

professional consulting services associated with the development of Tier 2 and

Tier 3 remediation objectives in accordance with 35 Ill. Adm. Code 742 must not

exceed the following amounts

:

1)

Payment for costs associated with field work and field oversight for the

development of remediation objectives must not exceed a total of $390 .00

per half-day, plus travel costs in accordance with subsection (e) of this

Section. The number of half-days must not exceed the following

:

A)

One half-day for every four soil borings, or fraction thereof, drilled

solely for the purpose of developing remediation objectives .

Borings in which monitoring wells are installed shall be included

in subsection (d)(1)(B) of this Section instead of this subsection

(d)(1)(A) ; and

B)

One half-day for each monitoring well installed solely for the

purpose of developing remediation objectives

.

2)

Excluding costs set forth in subsection (d)(1) of this Section, payment for

costs associated with the development of Tier 2 or Tier 3 remediation

objectives, including the tasks listed in Appendix F of this Part, must not

exceed a total of $800 .00 .

5

---

e)

Payment for costs associated with travel, including, but not limited to, travel time,

per diem, mileage, transportation, vehicle charges, lodging, and meals, must not

exceed the following amounts . Costs for travel shall be allowed only when

specified elsewhere in this Part

.

Distance to site

Maximum total amount

(land miles)

per calendar day

0 to 29

$140.00

30 to 59

$220.00

60 or more

$300.00

Distances shall be measured in ground miles and rounded to the nearest mile . If a

consultant maintains more than one office, distance to the site shall be measured

from the consultant's office that is closest to the site

.

If a plan must be amended due to unforeseen circumstances, costs associated with

the amendment of the plan , including the tasks listed in An,endix F of this Part,

and its associated budget shall not exceed a total of

710.0

.

0

6

---

Printing Service List

.

.

.

.

Page 1 of 4

Party Name

Role

City & State

Phone/Fax

Ogle County State's Attorney Office

Ogle County Courthouse

Oregon

815/732-1170

Interested Party

110 South Fourth Street, P.O. IL 61061-

815/732-1170

Box 395

0395

http://www.ipcb .state .il.us/cool/extemal/casenotifyNew .asp?caseid=1286 1 &notifytype=Se .

.

.

4/26/2006

Michael C. Rock, Assistant State's Attorne

Brown, Hay & St hens LLP

700 First Mercantile Bank

Building

Springfield

IL 62705-

217/544-8491

Interested

Party

205 South Fifth St ., P.O. Box

217/241-3111

2459

2459

Claire A. Manning

IE_PA

217/782-5544

1021 North Grand Avenue

Springfield

East

IL 62794-

Petitioner

217/782-9807

P.O. Box 19276

9276

Gina Roccaforte, Assistant Counsel

Kyle Rominger, Assistant Counsel

Doug Clay

Hodge Dwyer Zeman

3150 Roland Avenue

Springfield

217/523-4900

Interested Party

Post Office Box 5776

IL 62705-

5776

217/523-4948

Thomas G. Safley

Sidled Austin LLP

One South Dearborn

Chicago

312/853-7000

Interested Party

Suite 2800

IL 60603

312/853-7036

William G. Dickett

Karaqanis, White &_Ma_g-e_I, Ltd .

414 North Orleans Street

Chicago

312/836-1177

Interested Party

Suite 810

IL 60610

312/836-9083

Barbara Magel

Illinois Petroleum Marketers Association

112 West Cook Street

Springfield

217/793-1858

Interested Party

IL 62704

Bill Fleischi

UnitedScience Industries, In_c.

P.O. Box 360

Woodlawn

618/735-2411

Interested Party

6295 East Illinois Highway 15 IL 62898-

618/735-2907

0360

Joe Kelly, PE

Illinois Environmental Regulatory Group

217/523-4942

3150 Roland Avenue

Springfield

Interested Party

IL 62703

217/523-4948

N. LaDonna Driver

Carlson Environmental, Inc

.

65 E. Wacker Place

Chicago

Interested Party

Suite 1500

IL 60601

Kenneth James

Chemical Industry Council of Illinois

2250 E. Devon Avenue

DesPlaines

IL 60018-

Interested Party

Suite 239

4509

Lisa Frede

Barnes & Thornburg

1 North Wacker Drive

Chicago

312/357-1313

Interested Party

Suite 4400

IL 60606

312/759-5646

Carolyn S. Hesse, Attorney

Rapes Engineering & ADD led Science

821 South Durkin Drive

Springfield

217/787-2118

IL 62791-

Interested

Party

P.O. Box 7349

217/787-6641

7349

Michael W. Rapps

Environmental Management &

2012 West College Avenue

Normal

309/454-1717

Suite 208

IL 61761

309/454-2711

Technologies

---

ruuuug service

LdSL .

.

.

.

rage L 01 4

Kurt Stepping, Director of Client Services

http://www.ipcb.state .il.us/cool/external/casenotifyNew.asp?caseid=1286 1 &notifytype=Se . . .

4/26/2006

Interested Party

Craig S. Gocker, President

Office of the Attorney General

Environmental Bureau

Chicago

312/814-2550

Interested Party

188 West Randolph, 20th

Floor

IL 60601

312/814-2347

RoseMarie Cazeau, Bureau Chief

Herlacher Angleton Associates,_

. LLC_

8731 Bluff Road

Waterloo

618/935-2262

Interested Party

IL 62298

618/935-2694

Tom Herlacher, P .E., Principal Engineer

Illinois--Pollution Control Board

100 W. Randolph St

.

Chicago

312/814-3620

Interested Party

Suite 11-500

IL 60601

312/814-3669

Dorothy M. Gunn, Clerk of the Board

Marie Tipsord, Hearing Officer

Huff & Huff, Inc

.

512 West Burlington Avenue

LaGrange

Interested Party

Suite 100

IL 60525

James E. Huff, P. E

.

Black _& Veatch

Interested Party

101 North Wacker Drive

Suite 1100

Chicago

IL 60606

Scott Anderson

Posega_te.& De nes

111 N. Sixth Street

Springfield

217-522-6152

Interested Party

IL 62701

Claire A. Manning

Marlin Environmental Inc

.

St. Charles

Interested Party

3935 Commerce Drive

IL 60174

847/468-8855

Melanie LoPiccolo, Office Manager

Illinois Department of Natural Resources One Natural Resources Way

Springfield

217/782-1809

Interested Party

1

1271

62702-

217/524-9640

William Richardson, Chief Legal Counsel

Burroughs

HepIer.Broo.1MacDo_nald

103 W. Vandalia Street

Edwardsville

618/656-0184

Heb

r& True

True

IL 62025

618/656-1801

Interested Party

Suite 300

Musette H . Vogel

EcoDigital Development LLC

PO Box 360

Woodlawn

(618) 735-

Interested Party

6295 East Illinois Hwy 15

IL 62898

2411

Joe Kelly, VP Engineering

Great Lakes Analytical

1380 Busch Parkway

Buffalo Grove

(847) 808-

Interested Party

IL 60089

7766

A.J Pavlick

CSDEnvironmental Services, Inc

Springfield

IL 62703

217-522-4085

2220 Yale

Interested Party

Boulevard

Joseph W. Truesdale, P .E .

CORE Geological Services, Inc

.

Springfield

217-787-6109

2621 Monetga, Suite C

Interested Party

II 62704

Ron Dye, President

Clayton Group-Services Inc

Downers

Interested Party

3140 Finley Road

Grove

630.795.3207

IL 60515

Monte Nienkerk

P.QC

Laboratories

Peoria

Peoria

309-692-9688

2231 W. Altorfer Dr

.

Interested Party

it 61615

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http://www.ipcb .state .il.us/cool/external/casenotifyNew.asp?caseid=1286 1&notifytype=Se . .. 4/26/2006

rrtntmg service List

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Page 3 of 4

CW3M Company, Inc

.

Springfield

217-522-8001

701 South Grand Ave. West

Interested Party

Jeff Wienhoff

IL 62704

Suburban Laboratories, Inc

.

Hillside

708-544-3260

4140 Litt Drive

Interested Party

Jarrett Thomas, V.P .

Environmental Consulting & Engineering,

IL 60162

Glenn Ellyn

551 Roosevelt Road

Inc .

#309

8901 N. Industrial Road

IL 60137

Peoria

Interested Party

Richard Andros, P.E

.

MACTECEngineering &

Consulting,

Inc,

Interested Party

Terrence W. Dixon, P .G

.

Illinois_ Department ofTransportation

2300 S. Dirksen Parkway

IL 61615

Springfield

Interested Party

Steven Gobelman

SEEC_O Environmental Services_FInc.

Room 330

7350 Duvon Drive

IL 62764

Tinley Park

Interested Party

Collin W. Gray

Herlacher Angleton Associates_ LLC

IL 60477

Alton

Interested Party

Jennifer Goodman

522 Belle Street

IL 62002

McGuire Woods L_LP

77 W. Wacker

Chicago

312/849-8100

Interested Party

David Rieser

Suite 4100

IL 60601

Greensfelder Hemker &Gale

10 S. Broadway

St. Louis

314-241-9090

Complainant

Tina Archer, Attorney

Suite 2000

MO 63104

Midwest Engineering Services, Inc .

4243 W. 166th Street

Oak Forest

708-535-9981

Interested Party

Erin Curley, Env. Department Manager

IL 60452

American EnvironmentalI_C_orp,

3700 W. Grand Ave

., Suite A Springfield

217/585-9517

Interested Party

Ken Miller, Regional Manager

IL 62707

Applied Environmental Solutions,Inc .

P 0 Box 1225

Centralia

6185335953

Interested Party

Delete Me 2

Se_corInternational, Inc .

IL 62801

Springfield

Interested Party

Daniel J. Goodwin

400 Bruns Lane

IL 62702

Caterpillar,Inc.,

100 NE Adams Street

Peoria

3096751658

Interested Party

Eric Minder, Sr. Environmental Engineer

IL 61629

K-Plus Environmental

Interested Party

Daniel Caplice

Suite 1000

Chicago

600 W. Van Buren Street

IL 60607

312-207-1600

Illinois Society_ of Professional Engineers

600 South Second Street

Springfield

217-544-7424

Interested

Party

Kim Robinson

Brittan Bolin

GEI Consultants, Inc

.

Suite 403

IL 62704

500 Chesterfield Center

St. Louis

217-525-6239

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rage

4 01 4

Interested Party

Suite 200

MO 63017-

314-569-9979

4823

Daniel J. Goodwin, P.E

.

Total number of participants : 50

http://www.ipeb .state.il.us/cool/external/casenotifyNew.asp?caseid=12861&notifytype=Se .

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4/26/2006