May 11, 2006
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph, Suite 11-500
Chicago, IL 60601
Subject
:
0312615032 - Cook County
River Forest/Texaco Refining and Marketing
Site Remediation/Technical Report
Dear Sir/Madam:
Environmental Solutions, Inc
. has been retained by the Village of River Forest as the
environmental consultant for the above-referenced property . On behalf of the Village of
River Forest, we are submitting this letter to appeal the decision of the Illinois
Environmental Protection Agency (IEPA), as conveyed in their letter dated April 7, 2006
to the Village of River Forest . The letter was received by the Village of River Forest on
April 11, 2006.
In accordance with Section 40 of the Act (Section 58 .7(dX5) of the Act), the IEPA failed
to issue a final determination within the applicable review period and the Village of River
Forest has not agreed to a waiver of the deadline. The report entitled Remedial
Objectives Report and Remedial Action Completion Report -Revision 2 (the Reports)
were received by the ]EPA on
October 25, 2005. The IEPA did not issue their final
review decision until April 7, 2006, which is 162 days after receipt of the Reports .
In
accordance with Section 40 of the Act, we are submitting this appeal to contest the
decision of the Agency and request that the Reports be deemed as approved.
A copy of the Agency's April 7, 2006 is attached .
Please feel free to contact us should you have any questions regarding this appeal or
require any additional information .
Sincerely,
Environmental Solutions, Inc.
RECEIVED
CLERK'S OFFICE
MAY
1 8 2006
Pollution
STATE OF
Control
ILLINOISBoard
Environmental Solutions Inc
. 1502 West Jackson Blvd .
Chicago, Illinois 60607
312 .733 .2113
Mr. Charles Biondo
Village of River Forest
400 Park Avenue
River Forest, IL 60305
Refer to :
0312615032 -
Cook County
River Forest/Texaco Refining and Marketing
Site Remediation/Technical Report
Dear Mr
. Biondo :
The Illinois Environmental Protection Agency (Illinois EPA) has completed review of the
Report-
September
Revision
2004 report
2(the
titledReports)Remedial
. The Reports,
Objectives
submitted
Report
by
and
Environmental
Remedial Action
Solutions,
CompletionInc
. on
behalf of the Village of River Forest, were received by the Illinois EPA on October 25, 2005 (log
nocomments
. 05-27003)
:
. The Illinois EPA disapproves of the above Reports
. Please address the following
I .
The list of chemicals that will be covered in the No Further Remediation (NFR) Letter
should reflect the analytical analysis performed on the
soil and groundwater and
addressed in the Remediation Objectives Report
. This site can receive a NFR letter that
addresses more then benzene, ethylbenzene, toluene, xylene, polynuclear aromatic
hydrocarbons and lead, but the laboratory reports must be reviewed and a list provided
with the CAS numbers .
2. Section 3.5 R-26 and Groundwater Modeling
; This Report does not demonstrate how the
benzene exceedance in sample 0104 W W 1 is addressed
. Equation R-13 is not an
individual equation, it is to be used with equations R-12, R-14 and R-15
. A hypothetical
BUREAU
ROCKFORD-4302
OF LAND - PEORIA-7620
ELGIN-595
North Main
South
NStreet,
.
State,
University
Rockford,
Elgin,
St.,
IL
Peoria,
IL
60123-(847)
61103-(815)
IL 61614-(309)
608-3131987-7760693-5462
• PEORIA-5415
•
DES PLAINES-9511
N
. University
W
. Harrison
St ., PeoriaSt.,
; IL
Des
61614-(309)
Plaines, IL
693-546360016
-(847) 294-4000
SPRINGFIELD-4500 S
. Sixth Street Rd ., Springfield,
MARION-2309
IL 62706-(217)
W
. Main St
.,
786-6892Suite
116,
••
Marion,
COLLINSVILLE-2009
CHAMPAIGN-2125
IL 62959-(618)
South
Mall
993-7200Street,
First Street,
Collinsville,
Champaign,
IL 62234
IL
-(618)
61820-(217)
346-5120278-5800
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GRAND AVENUE EAST,
P.O . Box
19276, SPRINGFIELD, ILLINOIS 62794-9276 - (
217) 782-3397
JAMES R . THOMPSON CENTER,
100
WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601
- (312) 814-6026
ROD R
. BLAGOJEVICH, GOVERNOR
DOUGLAS P
. SCOTT, DIRECTOR
217/785-9399
April 7, 2006
CERTIFIED MAIL
7004 2510 0001 8591 8214
groundwater concentration does not have to be calculated if the soil concentration is less
then the Tier 2 soil remediation objective
. The proposed altered R-13 equation is not
acceptable . Any alteration of equations must be explained, and demonstrated
. This was
not done. The parameter CtxyCso,,,ce (Steady-State Attenuation Along the Centerline of a
dissolved Plume) is one parameter, not two . CO, in the RBCA equations, is not a
calculated soil objective .
C.., is a groundwater concentration, not a soil concentration .
3 . Section 3 .6 Institutional Control - Groundwater Ordinance
; Requirement 35 Illinois
Administrative Code (IAC) 742 .805(a)(4) has not been met
. The referenced
Environmental Data Resources, Inc . (EDR) report was not provided in Appendix B . The
EDR reports do not search all of the required data sources for water wells . The following
data sources must be consulted and documentation (i
.e. letters, phone logs, and etc
.)
provided. This information shall be collected by the consultant, by contacting all of the
following sources: Illinois State Geological Survey
; Illinois State Water Survey ; Illinois
EPA Division of Public Water Supply ; Illinois Department of Public Health ; County and
Municipal Health Departments ; and Local water supply entity (i.e., public water districts,
public water supply companies)
.
4. Section 3 .6 Institutional Control - Groundwater Ordinance; Requirement 35 IAC
742.805(c) has not been met
. Toluene is a contaminant of concern, and is listed as a
similar-acting compound with Ethylbenzene.
5 . When submitting the required information, a currently certified copy of the groundwater
ordinance will be needed .
6. Figure 6; A scaled map delineating the boundaries of all properties under which
groundwater is located which exceeds the applicable groundwater remediation objectives
is required per 35 IAC 742 .1015(b)(3) . The properties are not delineated .
7. Tables 5, 6, and 7 ; Samples CY-3 and 1215W I contain mistakes. Please correct the
tables.
8. Appendix C ; Sample letter to the Off Site Property Owners ; The Sample letter provided
is for a different site . The sample letter must be for the Texaco Refining & Marketing
site, LPC# 031265032 . The list of off site owners who will be notified seems incomplete .
No addresses have been provided for the east side of Monroe Avenue south of Quick
Avenue and north of Lake Street
.
9. The distance that the groundwater contamination is modeled from the January 2004
report was 199 meters and the distance modeled in this report is 350 meters, however the
groundwater plume maps in the two reports appear very similar in size. Please provide
supporting documentation as to the area and distance that the modeled plume covers .
2
Attached is a draft No Further Remediation Letter, please review the letter for correctness
. If the
site owner is no longer the Village of River Forest, a revised DRM-1 form must be submitted
with the current owner or owners' signatures .
Please provide the Illinois EPA with two copies of any future information submitted regarding
the above referenced site. A DRM-2 form and a cover letter must accompany all submittals
.
If you have any question please feel free to contact me at the above telephone number or address .
Jennifer M . Seul, L.P .G.
Remedial Project Manager
Voluntary Site Remediation Unit
Remedial Project Management Section
Bureau of Land
cc:
Jack Hughes
Environmental Solutions, Inc.
1502 West Jackson Blvd .
Chicago, Illinois 60607
Carmen Yung
Environmental Solutions, Inc.
1502 West Jackson Blvd .
Chicago, Illinois 60607
3
