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ILLINOIS STATE TOLL HIGHWAY
AUTHORITY,
Petitioner,
V .
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent .
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
PLEASE TAKE NOTICE that I have today filed with the office of the Clerk of the Pollution
Control Board a REQUEST FOR NINETY DAY EXTENSION OF APPEAL PERIOD, copies of which
are herewith served upon you
.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Respondent
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
Melanie A. Jarvis
Assistant Counsel
Special Assistant Attorney General
Division of Legal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
217/782-5544
217/782-9143 (TDD)
Dated: May 25, 2006
NOTICE
Karen Kavanagh Mack
Deutsch, Levy & Engel
225 West Washington Street
Suite 1700
Chicago, IL 60606
RECEIVED
CLERK'S
OFFICE
MAY 3 0 2006
STATE 00 ILLINOIS
Pollution Control Board
PCB No. 06-
(LUST Appeal
I
Ninety Day Extension)
 
CERTIFICATE OF SERVICE
I, the undersigned attorney at law, hereby certify that on May 25, 2006, I served true and
correct copies of a REQUEST FOR NINETY DAY EXTENSION OF APPEAL PERIOD, by
placing true and correct copies in properly sealed and addressed envelopes and by depositing
said sealed envelopes in a U.S. mail drop box located within Springfield, Illinois, with sufficient
First Class postage affixed thereto, upon the following named persons :
Dorothy M. Gunn, Clerk
Karen Kavanagh Mack
Illinois Pollution Control Board
Deutsch, Levy & Engel
James R. Thompson Center
225 West Washington Street
100 West Randolph Street
Suite 1700
Suite 11-500
Chicago, IL 60606
Chicago, IL 60601
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Respondent
Melanie A. Jarvis
Assistant Counsel
Special Assistant Attorney General
Division of Legal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
217/782-5544
217/782-9143 (TDD)
 
AUTHORITY,
)
Petitioner,
)
v
.
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
ILLINOIS STATE TOLL HIGHWAY
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
PCB No. 06-
1
11
(LUST Appea -Ninety Day Extension)
REQUEST FOR NINETY DAY EXTENSION
OF APPEAL PERIOD
NOW COMES the Respondent, the Illinois Environmental Protection Agency ("Illinois
EPA"), by one of its attorneys, Melanie A . Jarvis, Assistant Counsel and Special Assistant
Attorney General, and, pursuant to Section 40(a)(1) of the Illinois Environmental Protection Act
(415 ILCS 5/40(a)(1)) and 35 III . Adm. Code 105 .208, hereby requests that the Illinois Pollution
Control Board ("Board") grant an extension of the thirty-five (35) day period for petitioning for a
hearing to August 28, 2006, or any other date not more than a total of one hundred twenty-five
(125) days from the date of service of the Illinois EPA's final decision . In support thereof, the
Illinois EPA respectfully states as follows
:
On April 20, 2006, the Illinois EPA issued a final decision to the Petitioner .
(Exhibit A)
2
.
On May 22, 2006, the Petitioner made a written request via fax to the Illinois EPA
for an extension of time by which to file a petition for review, asking the Illinois EPA join in
requesting that the Board extend the thirty-five day period for filing a petition to ninety days
.
Tracking information from the Certified Mail number on the final decision indicates the final
decision was received on April 25, 2006 . (Exhibit B)
RECEIVED
CLERK'S OFFICE
MAY 3.0 2006
STATE OF ILLINOIS
Pollution Control Board
1
 
3 .
The additional time requested by the parties may eliminate the need for a hearing
in this matter or, in the alternative, allow the parties to identify issues and limit the scope of any
hearing that may be necessary to resolve this matter
.
WHEREFORE, for the reasons stated above, the parties request that the Board, in the
interest of administrative and judicial economy, grant this request for a ninety-day extension of
the thirty-five day period for petitioning for a hearing
.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Respondent
Melanie A. Jarvis
Assistant Counsel
Special Assistant Attorney General
Division of Legal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
217/782-5544
217/782-9143 (TDD)
Dated: May 25, 2006
This filing submitted on recycled paper
.
2
 
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 WESTRANDOLPH, Sum 11-300, Ct-uCAGO, IL 60601 -
(312) 814-6026
Roo R .
BLAGOJEVICH, GOVERNOR
DOUGLAS P. SCOTT,
DIRECTOR
217-782-6762
CERTIFIED MAIL
7004 2510 0001 8590 6518
APR 2 0 2006
Illinois State Toll Highway Authority
2700 Ogden Avenue
Downers Grove, Illinois 60515-1703
RE :
LPC 0434525056 - Cook County
Hinsdale -Amoco; Exxon Mobil Service Station 05-A4H (east) ;
Illinois State Toll Highway Authority Hinsdale Oasis (east)
Interstate 294, Mile Post 25 .2
LUST Incidents 860430, 890110 (east), 941726, 20040981 & 20041036
LUST TECHNICAL FILE
Gentlemen:
The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the High Priority
Corrective Action Plan & Budget & Completion Report submitted for the above referenced
incidents. This information, dated December 7, 2005, was received by the Illinois EPA on
December 30, 2005, and was prepared by Wight & Company. The report proposes the
information which is summarized in Attachment 1 . Citations in this letter are from the
Environmental Protection Act (Act) in effect prior to June 24, 2002, and 35 Illinois
Administrative Code
.
Pursuant to Section 57.7(c)(4) of the Act and 35 Illinois Administrative Code 732 .405(c),
732.409(c) and 732.503(b), the High Priority Corrective Action Plan & Completion Report is
rejected for the reasons which are explained in Attachment 2
.
Pursuant to Sections 57.7(aXI) and 57.7(c)(4) of the Act and 35 Illinois Administrative Code
732.405(e) and 732.503(b), the High Priority Corrective Action Budget is rejected for the reasons
which are explained in Attachment 3
.
The Illinois EPA also has additional comments . These comments are explained in Attachment 4,
An underground storage tank system owner or operator may appeal this decision to the IIlindtllt
Pollution Control Board . Appeal rights are explained in Attachment 5 .
ROCKFORD-4302 North Main Street, Rock(old, IL 61103-(815) 987-7760
•
DES PLAINES-9511 W. Harnson St., Des Plaines, IL 60016-(847)294-0000
FLCw - 595 South State, Elgin, IL 60123 -(847) 608-3131
•
PEORIA-541S
N. University St., Peoria, IL 61614 -(309) 693-5463
6UREAUOF LNVD-PEORIA-7620 N. University SL, Peoria, IL 61614-(309) 693-5462
-
GEMAFAIGN- 2125 South First Street, Champaign, IL 61820-(2171278-5'
SPRINGFIELD -4500 5. Sixth Street Rd., Springfield. IL 62706 - (2171786-6892
CoLUNSVILLu - 2009 Mat[ Street, Collinsville, IL 62234- (618) 346-ST 20
MARION- 2309 W. Main St., Suite 116, Marion, IL 62959 -(618) 993-7200
PRINTED ON RECYCLED
PAPER
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Any questions regarding this letter should be directed to Michael Piggush via phone
(217-782-3101), fax (217-524-4193), or e-mail ( epa4200@epastate.il.us) .
Michael T. Lowder
Unit Manager
Leaking Underground Storage Tank Section
Division of Remediation Management
Bureau of Land
Attachments (5)
:
1 .
Summary of Report Proposal .
2 .
High Priority Corrective Action Plan & Completion Report Disapproval Reasons .
3 .
HighPriority Corrective Action Budget Disapproval Reasons .
4.
Additional Comments .
5 .
Appeal Rights .
cc
:
Deutsch, Levy & Engel
Wight & Company
Division File
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ATTACHMENT I
SUMMARY OF REPORT PROPOSAL
RE :
LPC 0434525056 - Cook County
Hinsdale
- Amoco; Exxon Mobil Service Station 05-A4H (east)
;
Illinois State Toll Highway Authority Hinsdale Oasis (east)
Interstate 294, Mile Post 25.2
LUST Incidents 860430, 890110 (east), 941726, 20040981 & 20041036
LUST TECHNICAL FILE
The report proposes the following information :
1 .
The report proposes that LUST Incidents 860430, 890110, 941726, 20040981 &
20041036 represent releases from 20 underground storage tank systems containing
gasoline, diesel fuel, heating oil & waste oil. The report proposes that all of these
underground storage tank systems have been removed .
2 .
The report proposes that 4 new 15,000 gallon underground storage tank systems (3
containing gasoline & 1 containing diesel fuel) are currently in operation
.
3 .
The report proposes that the indicator contaminants would he the following: BETX &
PNAs
.
4 .
The report assumes a Class 1 groundwater designation, in accordance with 35 Illinois
Administrative Code 620.210 .
5
.
The report proposes that corrective action activities were performed from June 2004 -i
August 2004, as follows :
a .
The report proposes that 5,595 cubic yards ofcontaminated soil were excavated &
disposed of.
b .
The report proposes that 175,000 gallons of contaminated groundwater were
removed & disposed of.
c .
The report proposes that free product was not encountered .
d .
The report proposes that a total of 86 soil samples & 2 water samples were
obtained. The report proposes that the samples were analyzed for the following
:
BETX & PNAs .
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e .
The report proposes that the excavation areas were backfilled . The report
proposes that a total of 1,957.79 tons of backfill material were used
.
f
The report proposes that the potable water supply well for the site property was
abandoned. The report proposes that a total of 3,000 pounds of bentortite & 1,880
pounds of concrete were used .
6 .
The report proposes the use of the following restrictions
:
a.
The report proposes the use of an industrial / commercial land use restriction for
the site property .
b
.
The report proposes the use of a groundwater use restriction for the site property.
(The report proposes a maximum compliance distance of 5 .7 feet for groundwater
contamination)
.
7 .
The report requests approval of the following, in accordance with 35 Illinois
Administrative Code 732 :
a .
The report requests approval of a High Priority Corrective Action Plan
.
b_
The report requests approval of a High Priority Corrective Action Budget, for an
amount of $616,751 .35 .
c .
The report requests approval of a High Priority Corrective Action Completion
Report .
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ATTACHMENT 2
HIGH PRIORITY CORRECTIVE ACTION PLAN & COMPLETION REPORT
DISAPPROVAL REASONS
RE :
LPC 0434525056 - Cook County
Hinsdale -Amoco; Exxon Mobil Service Station 05-A4H (east) ;
Illinois State Toll Highway Authority Hinsdale Oasis (east)
Interstate 294, Mile Post 25.2
LUST Incidents 860430, 890110 (east), 941726, 20040981 & 20041036
LUST TECHNICAL FILE
The Illinois EPA does not approve of the High Priority Corrective Action Plan & Completion
Report, for the following reasons
:
.
1 .
The report proposes that LUST Incidents 20040981 & 20041036 apply to the 5-12,000
gallon underground storage tank systems which were installed in 1985 & removed in July
2004. The report also proposes that LUST Incidents 20040981 & 20041036 are a
re-reporting of LUST Incident 941726. It is not clear how it was determined that LUST
Incidents 20040981 & 20041036 are a re-reporting of LUST Incident 941726 . It is not
clear how it was determined that additional releases did not occur from the 5-12,000
gallon underground storage tank systems during the 10 years that the underground storage
tank systems were in operation since LUST Incident 941726 was reported
.
Please also note that LUST Incident 941726 was previously reported to apply to all 20 of
the underground storage tank systems located at the east Oasis, rather than just the
5-12,000 gallon underground storage tank systems which were installed in 1985 &
removed in July 2004 .
The Illinois EPA deems that LUST Incidents 20040981 & 20041036 constitute a new
occurrence .
2 .
In accordance with 35 Illinois Administrative Code 732.310(b), for releases of gasoline
(from underground storage tank systems) which were reported to the Illinois Emergency
Management Agency on or after June 1, 2002, all samples must be analyzed for MTBE
(in addition to BETX & possibly Pb) .
Based upon the information which was provided in Item (1) above, LUST Incidents
20040981 & 20041036 constitute a new occurrence . Therefore, MTBE is an additional
indicator contaminant for these LUST Incidents . It does not appear that any of the
closure samples were analyzed for MTBE .
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3 .
Lead is an indicator contaminant for some of the underground storage tank systems . The
report does not mention anything regarding lead
.
4 .
The report does not contain the correct set of diagrams. The diagrams which were
included with the report are for the west oasis, rather than the east oasis
.
Please also note the following :
a_
The diagrams which were included with the report do not illustrate the complete
site property boundaries .
b
.
The diagrams which were included with the report did not contain any
cross-sections of any of the excavation areas
.
5 .
The tabular summary of sample analyses does not indicate which sample results were
subsequently excavated & replaced by other sample results
.
Based upon this, for purposes of this review, the Illinois EPA is assuming that, for
example, soil sample PP-29A is a replacement of soil sample PP-29 .
6 .
Corrective action is required for all contamination in excess of the most stringent
remediation objectives which are outlined in 35 Illinois Administrative Code 742
.
The report doess not demonstrate compliance with these requirements, for the
.following
reasons :
a.
The Tier I Class I groundwater remediation objective for benzo (a) anthracene
(0.000 13 mg/L) was exceeded for groundwater sample CTP-W (0 .000 15 mg/L) .
The report does not address this issue
.
7 .
The report proposes that the greatest remaining concentration of benzene (in soil) is at the
location of soil sample PP-29A (0.083 mg/kg). This is not correct. The remaining
concentration of benzene (in soil) is greater at the location of soil sample PP-35 (0 .120
mg/kg)-
8.
With regard to the proposed Tier 2 remediation objectives, the report states that the
source area is the area of the current tank field. This is not correct. The source area is the
area of the plume of contamination in excess of the most stringent Tier I remediation
objectives
.
9 .
With regard to Equation R26, the report states that the proposed value for hydraulic
conductivity (K) (0.0864 cm/day) was determined based upon an assumption . This is not
adequate. Hydraulic conductivity must be determined via site specific field
measurements
.
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10 .
Groundwater samples must be collected from either conventional monitoring wells,
pre-pack monitoring wells (for monitoring periods of up to 1 year), or screen point
samplers .
The report does not demonstrate compliance with these requirements, for the following
reasons :
a .
The 2 groundwater samples which were obtained for purposes of closure were
obtained from open excavation areas .
11 .
Logs must be provided for all soil borings & monitoring wells . Logs must illustrate the
following information (as applicable)
:
a .
Subsurface soil types
.
b .
Location of groundwater.
c
.
Soil boring recovery .
d .
Field screening measurements
.
e.
Location of sample collection
.
f.
Monitoring well construction.
Logs must be drawn to vertical scale .
The report does not demonstrate compliance with these requirements, for the following
reasons :
a .
The report does not contain the soil boring logs for soil borings SP-66 -. SP-69
(which were performed on May 5, 2003)
.
12 .
Chain of custody forms must be provided for all sample analyses.
The report does not demonstrate compliance with these requirements, for the following
reasons :
a .
The report does not contain the chain of custody forms for the soil samples which
were obtained from soil borings SP-66 -4 SP-69 (which were performed on May
5, 2003) .
13 .
The actual laboratory reports (from the laboratory) must be provided for all sample
analyses .
The report does not demonstrate compliance with these requirements, for the following
reasons :
a
The report does not contain the laboratory reports for the soil samples which were
obtained from soil borings SP-66 -+ SP-69 (which were performed on May 5,
2003) .
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14 .
35 Illinois Administrative Code 742 .320(c) & (e) effectively set forth well survey
requirements related to the exclusion of the groundwater ingestion exposure pathway
.
The report does not address this issue. The report does not contain any well survey
information .
15 .
Waste manifests must be provided for all contaminated materials which are removed
off site .
The report does not demonstrate compliance with these requirements, for the following
reasons :
a.
The report does not contain all of the waste manifests for the 5,595 cubic yards of
contaminated soil which were excavated & disposed of. The report only contains
the waste manifests for 2,835 cubic yards of contaminated soil .
b .
The report does not contain the waste manifests for the 175,000 gallons of
contaminated groundwater which were removed & disposed of
.
16 .
Some areas of the legal descriptions make reference to the locations of highway rights of
way. This is not an acceptable legal description . If the locations of the highway rights of
way were to change, then the legal description would no longer be correct .
17-
The form does not contain the correct version of the Professional Engineer Certification
Form (for purposes of closure). The form which makes reference to 35 Illinois
Administrative Code 742 is the form which should be used
.
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5
.
Section (1) of the budget contains costs which are associated with the replacement of
concrete . The report does not indicate the thickness of the concrete
.
6 .
Section (E)(1) of the budget contains costs which are associated with 8 soil borings . It is
not clear which specific soil borings this is for.
7 .
Sections (E)(1) & (I) of the budget both contain $7,500.00 in costs which are associated
with abandonment of wells. It is not clear if these costs have been duplicated
.
8 .
Section (G) of the budget contains personnel costs which are associated with the
compaction of backfill material . In accordance with 35 Illinois Administrative Code
732.606(w), costs which are associated with the compaction & density testing of backfill
material are not reimbursable .
9 .
The report states that 5,595 cubic yards of contaminated soil were excavated & disposed
of. However, the proposed budget
is for 5,955 cubic
yards
of
contaminated soil. This
information is not consistent .
10 .
In accordance with 35 Illinois Administrative Code 732 .606(hh), all costs must be
reasonable .
The report does not demonstrate compliance with these requirements, for the following
reasons :
a.
The proposed cost for the Project Manager ($171.00 per hour) (Section (G) of the
budget) is not reasonable. The Illinois EPA dots not reimburse for these costs in
excess of $90 .00 per hour .
b.
The proposed cost for the clerical (S65 .78 per hour) (Section (G) of the budget) is
not reasonable. The Illinois EPA does not reimburse for these costs in excess of
$45.00 per hour.
c .
The proposed cost for backfill material ($28.85 per cubic yard & $22.65 per cubic
yard) (Section (1) of the budget) is not reasonable. The Illinois EPA does not
reimburse for these costs in excess of $20 .00 per cubic yard .
11
.
The Illinois EPA is concerned if the proposed cost for mobilization ($8,180 .00) (Section
(1) of the budget) is reasonable
.
12 .
Budget Certification Forms must be signed & notarized on the same date
.
The report does not demonstrate compliance with these requirements, for the following
reasons :
a .
With regard to the signature of the owner / operator of the underground storage
tank systems, the form was signed on September 23, 2005, but was notarized on
December 6, 2005
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ATTACHMENT 4
ADDITIONAL COMMENTS
RE :
LPC 0434525056 - Cook County
Hinsdale -Amoco; Exxon
Mobil
Service Station 05-A4H (east) ;
Illinois State Toll Highway Authority Hinsdale Oasis (east)
Interstate 294, Mile Post 25 .2
LUST Incidents 860430, 890110 (east), 941726, 20040981 & 20041036
LUST TECHNICAL FILE
The Illinois EPA has the following additional comments :
1 .
The tabular summary of sample analyses does not indicate the detection limits at which
some of the sample results were listed as being not detected
.
2 .
Please note that LUST Incident 890110 was previously reported to apply to
both
sides of
the tollway oasis. The report does not acknowledge this .
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ATTACHMENT 5
APPEAL RIGHTS
An underground storage tank system owner or operator may appeal this final decision to the
Illinois Pollution Control Board pursuant to Sections 40 and 57 .7(c)(4) of the Act by filing a
petition for a hearing within 35 days after the date of issuance of the final decision . However, the
35 day period may be extended for a period of time not to exceed 90 days by written notice from
the owner or operator and the Illinois EPA within the initial 35 day appeal period. If the owner
or operator wishes to receive a 90 day extension, a written request that includes a statement of
the date the final decision was received, along with a copy of this decision, must be sent to the
Illinois EPA as soon as possible
.
For information regarding the filing of an appeal, please contact :
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
312-814-3620
For information regarding the filing of an extension, please contact
:
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
217-782-5544
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EARL A . DEUTSCH
TERRY L.ENGEL
FRANK R.COHEN
JERRYI,RUDMAN
MICHAEL 4. DEVINE
STUART BERKS
KENNETH S . FUNK
PHILLIP J. ZISOOK
DENNIS E . FRISBY
ALVIN J. HELF50T
JOEL A. STEIN
BRIAN D. SAUCIER
JAMES E . O"HALLORAN
AARON 9 2ARKOWSKY
LEO G AUSEL
KAREN KAVANAGH MACK
JEFFREY B .HORWIT2
MOYENPA MUTHARIKA KNAPP
DAVID J . BEN.DOv
LEE E.FAROMAN
MAUREEN C.DUFFY
HOLLACE C . MURPHY
LAW OFFICES
DEUTSCH, LEVY & ENGEL
CHARTERED
SUITE 1700
225 WEST WASHINGTON STREET
CHICAGO. ILLINOIS 60606
(312) 3n6-1460
May 22, 2006
Via Facsimile: (217)782-9807
And Certified U . S. Mail
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Attention: William Ingersoll, Esq .
Re:
LPC #0434525056 - Cook County
Hinsdale Amoco: Exxon Mobil Service Station 05-A4H (East);
Illinois State Toll highway Authority Hinsdale Oasis (East)
Interstate 294, Mile Post 25.2
LUST Incident Nos. 860430, 890110, 941726, 20040981 & 20041036
LUST Technical File
Dear Mr. Ingersoll
:
The undersigned, as a Special Assistant Attorney General, represents the Illinois State
Toll Highway Authority in connection with the referenced LUST Incident . I have received a
copy of the Agency's letter, dated April 20, 2006, regarding the Authority's High Priority
Corrective Action Plan, related Budget and Completion Report, dated December 7, 2005, for the
above referenced LUST Incident previously submitted to the Agency . A copy of that letter is
enclosed.
Please be advised that the Authority does not agree with the Agency's bases for rejecting
these submittals, as set forth in its letter of April 20, 2006 ; however, in hopes of resolving the
open issues with the Agency, and avoiding the necessity of an appeal to the Illinois Pollution
Control Board, our client hereby requests an extension, pursuant to Sections 40 and 57 .8 of the
Illinois Environmental Protection Act, to extend the period within which it may appeal the
Agency's decision for an additional ninety (90) days
.
-
2295481
\Et bi,+
A
E-mailt lawyers® dlec.com
Webs"l wWw.dlec.co1R
FACSIMILE' 13121 346.1656
COUNSEL
LEVY
MARSHALL 0 . KROLICK
Karen Kavanagh Mack
OPeclLine:312-8538441
DrOCIFm1'
.
312-8538471
E-mail :
mockOdlec.com
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William Ingersoll
Illinois Environmental Protection Agency
May 22, 2006
Page Two
It is our understanding that upon receipt of this letter you will proceed to prepare the
necessary motion for filing with Illinois Pollution Control Board to effectuate the extension
. By
my calculations, the extension request is due by May 25, 2006 . If your understanding is other
than as indicated herein or if I can provide any further information, please let us know
immediately .
I would greatly appreciate it if you would acknowledge receipt of this request by
telephone or e-mail, given the time sensitive nature of the matter
.
KKM
Enclosures
cc :
Victor Azar, Esq
.
Kenneth W. Funk, Esq .
Very truly yours,
EUTSCH L
ENGEL, CHARTERED
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