RECEIVED

CLERK'S

OFFICE

DEC

1 3 2006

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

WEBB

& SONS, INC.,

)

Petitioner,

)

vs.

)

Respondent .

)

MOTION TO INCORPORATE DOCUMENTS BY REFERENCE

COMES NOW the Petitioner, WEBB & SONS, INC

. (hereinafter "Petitioner"),

by and through its attorneys, Harrington & Tock, and, pursuant to 35 Ill

. Adm. Code

101

.306(a), hereby requests permission to incorporate documents from records of other

Pollution Control Board dockets into this proceeding and, in support thereof, states as

follows

:

1

. 35 Ill. Adm. Code 101

.306(a) provides that, upon the written request of any

person, the Board or hearing officer may incorporate documents from the

record of another Board docket into any proceeding

. The person seeking

incorporation must demonstrate to the Board or the hearing officer that the

material to be incorporated is authentic, credible, and relevant to the

proceeding .

2

. The Petitioner seeks permission to incorporate the following documents from

the following Board dockets

:

a

. Petition For Review of Illinois Environmental Protection Agency's

Decision to Deny Petitioner's Budget For Site Investigation Activities

;

Webb & Sons, Inc . v . Ill. EPA

; PCB 05-183 ;

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

PCB 07-24

(UST Appeal)

Pollution

STATE OF

Control

ILLINOIS

Board

---

b.

Excerpts from Administrative Record filed by the Agency with the

Pollution Control Board on May 27 2005

; PCB 05-183 ;

c . Testimony Of Douglas W . Clay Regarding The Illinois Pollution

Control Board's Proposed 35 111 . Adm. Code 732.845 And 734.845 ; R

04-22(B) and R 04-23(B)

;

d. Excerpts from Testimony of Douglas W

. Clay In Support of the

Environmental Protection Agency's Proposal To Amend 35 Ill

. Adm

.

Code 732 (filed March 08, 2004) ; R 04-22 ; and

e

. Testimony of Harry A. Chappel, P.E. In Support of the Environmental

Protection Agency's Proposal To Amend 35 Ill . Adm. Code 732 (filed

March 08, 2004); R 04-22.

3

. Four copies of each of the above documents are attached hereto.

4

. The Petition in PCB 05-183 and excerpts of the Administrative Record were

copied from the files of the undersigned attorney and are true and accurate

copies of the Petition filed with the Pollution Control Board by Petitioner on

April 6, 2005 and the Administrative Record filed with the Pollution Control

Board by the Illinois Environmental Protection Agency on May 27, 2005

. All

other documents were obtained from the Pollution Control Board on-line e-

library of documents filed by the Illinois EPA in favor of proposed

amendments of 35 111. Adm

. Code 732 and 734 of Pollution Control Board

rule-making cases R 04-22(B) and 23(B) .

5

. All of these materials are relevant to the Petition to review the Agency's

denial of all personnel costs in Petitioner's CAP budget . All of the documents

---

Prepared by :

Jeffrey W

. Tock

Harrington & Tock

201 W. Springfield Ave .

PO Box 1550

Champaign, IL 61824-1550

(217) 352

.4167

from other Board dockets show the vast experience the Agency has obtained

from reviewing over 12,800 budgets in 15 years, and that was in 2004

. The

materials filed by the Agency in R 04-22(B) and 23(B) in support of lump

sum payments for personnel costs show the Agency's detailed analysis of

personnel costs required for the creation and implementation of all corrective

action plans .

6

. These documents from other Board records are relevant to show that the

Agency has such a vast knowledge of corrective action plan budgets that it

could have made a determination of the reasonableness of the Petitioner's

proposed personnel costs without requesting additional break-downs of the

hours to be expended by each person identified as having a role in the

preparation and implementation of the Petitioner's Corrective Action Plan .

WHEREFORE, for the reasons set forth above, Petitioner respectfully moves for

permission from the hearing officer in this matter to incorporate the above

described documents into this proceeding.

WEBB & SONS, INC ., Petitioner, by it

attom

H ' on & Tock

By:

Je fir

y

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

WEBB & SONS, INC.,

)

Petitioner,

)

vs.

PCBNo. oS--/83

)

(UST Appeal)

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

)

PETITION FOR REVIEW OF ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY'S DECISION TO DENY

PETITIONER'S BUDGET FOR SITE INVESTIGATION ACTIVITIES

NOW COMES the Petitioner, WEBB & SONS, INC

. (hereinafter "Petitioner"),

by and through its attorney's, Harrington & Tock, and, pursuant to Sections 40 and 57

.7

of the Illinois Environmental Protection Act

("Act") (415 ILCS 5/40, 5/57

.7), and 35 Ill .

Admin

. Code Part 105, hereby requests review of the decision by the Respondent, Illinois

Environmental Protection Agency ("Agency"), to not approve as submitted the

Petitioner's budget for Stage 2 site investigation activities

. In support of this Petition, the

Petitioner states as follows :

1

. Petitioner is the owner of certain property located at 1201 DeWitt Avenue,

Mattoon, Illinois, hereinafter referred to as "the Site"

.

2. Petitioner is the owner of underground storage tanks ("USTs") formerly located at

the Site .

3

. Petitioner has submitted to the Agency its Site Investigation Stage 1 Completion

Report (the "Report") dated January 18, 2005 .

4. Part 5

.0 of that Report contained a description of future investigation needed to

delineate soil

and ground water contamination (Site Investigation

- stage 2) . A

---

true and accurate copy of part 5

.0 of the Report is attached hereto and made a part

hereof as Exhibit "A".

5

. In conjunction with the Report, Petitioner also submitted to the Agency a Site

Investigation - Stage 2 Budget

. A true and accurate copy of the Site Investigation

-

Stage 2 Budget is attached hereto and made a part hereof as Exhibit

"B".

6

. By letter dated February 8, 2005, the Agency approved the site investigation plan

-

stage 2 contained in part 5

.0 of the Report, but modified the proposed budget

(Exhibit "B").

The Agency made the following deductions from the budget :

(a) $1,500.00 for a professional survey from Other Costs as not eligible

; and,

(b) $17,610.00

from Personnel Costs for lack of supporting documentation

.

The Agency requested further justification of personnel costs . (The

Agency's letter is attached as Exhibit

"C".)

7. By letter dated February 15, 2005, Petitioner submitted justification of surveying

costs and a breakdown and justification of personnel costs

. (The Petitioner's

letter is attached as Exhibit "D".)

8

. By letter dated February 25, 2005, Petitioner submitted a request that the Agency

reconsider its decision to modify the budget as submitted by Petitioner and

approve the budget as proposed

. (The Petitioner's letter is attached as Exhibit

"E".)

9

. By letter dated March 2, 2005, the Agency revised its February 5, 2005

modifications, stating that the Agency had made the following deductions

:

(a) $1,500 for a professional survey from Other Costs as not eligible

; and,

(b) $7,906 from Personnel Costs as unreasonable .

---

10. The Agency's March 2, 2005

letter further stated that "An underground storage tank

owner or operator may appeal this final decision to the Illinois Pollution Control

Board. . . within 35

days after the date of issuance of the final decision". The

Agency's March

2, 2005 letter is attached as Exhibit

"F"'.)

11

. The Investigation of the Site requires the installation of borings and wells on adjacent

properties

. It is, therefore, necessary to identify property boundaries accurately . In

addition, the legal description for the site will ultimately be required for corrective

action completion

. The only accurate and complete way to identify property

boundaries is to utilize a professional surveyor.

12 . All investigations, plans and reports under sec . 57 .7 of the Act shall be conducted or

prepared under the supervision of a licensed professional engineer. (415 ILCS

5/57.7 .)

A Site Investigation Completion Report must be signed and sealed by a

professional engineer and must contain the following statement: "To the best of my

knowledge and belief, this report, supporting documents and all attachments are true,

accurate and complete." The Professional Engineering Practice Act of 1989 states

:

The use ofa professional engineer's seal on technical submissions constitutes a

representation by the professional engineer that the work has been prepared by

or under the personal supervision ofthe professional engineer or developed in

conjunction with the use of accepted engineering standards. (225 ILCS 325/14)

This Act further states:

Signing, axing the professional engineer's seal or permitting the professional

engineer's seal to be axed to any technical submissions not prepared as

required by Section 14 or completely reviewed by the professional engineer or

under the professional engineer's direct supervision

isprohibited and may result

in loss

of license and/or civilpenalties. (225 ILCS 325/24)

13 . The Agency denied all professional engineer hours from the budget

. As stated

above, a professional engineer cannot certify a technical submission that has not

---

been prepared under the professional engineer's supervision and review

. The

professional engineer hours are necessary to comply with the requirements of the

Professional Engineering Practice Act of 1989 and with the requirements of the

Agency.

14. All project manager hours were denied by the Agency . The project manager is a vital

part of any project in the engineering and consulting industry

. The use of a project

manager is industry standard . Management personnel are utilized for personnel

scheduling, billing, technical reviews, and general project oversight . The use of

management hours is necessary to ensure a timely, cost-effective, and technically

accurate product .

15

. All work approved by the Agency in the Site Investigation Plan cannot feasibly be

completed by the number of hours in the amended budget . Personnel costs of

$12,816 were approved by the Agency on March 5, 2004 for the previous Site

Investigation Plan work which proposed 36 feet of soil borings and 60 feet of

monitoring wells to be installed on-site . This averaged $133 .50 per foot. The current

Site Investigation Plan dated January 18, 2005, approved by the Agency in a letter

dated February 8, 2005, proposed 132 feet of soil borings and 45 feet of monitoring

wells to be installed off-site . Off-site wells and borings require authorization of

adjacent property owners and city permits, which entails additional personnel hours

.

A total of 81 additional feet of soil borings and monitoring wells have been approved

by the Agency for this stage of site investigation which also entails additional

personnel hours

. The Petitioner requested $17, 610 for personnel costs related to this

stage of site investigation . This averages $99 .49 per foot - much less than previously

---

approved

. The Agency

March 2, 2005. This co

16

. Petitioner is seeking re

the budget for the above

arbitrary, capricious, an

WHEREFORE, for the

INC.,

respectfully requests

relief-

1

.

Find that the Agenc

without statutory au

2. Reverse the Agenc

3

. Remand this matter

4. Award Petitioner re'

this action.

5 . Award such further

Dated: April 5, 2005

Jeffrey W. Tock

Harrington & Tock

201 W

. Springfield Ave ., S7te 601

P

.O

. Box 1550

Champaign, Illinois 61824- 550

Telephone: (217) 352-4167

my

approved $9,704 of personnel costs in its letter dated

t averages $54.82

per foot, which is not reasonable

.

ew of the Agency's March 2, 2005, determination rejecting

referenced costs

. The Agency's determinations are

without statutory authority .

bove and foregoing reasons, Petitioner, WEBB & SONS,

the Illinois Pollution Control Board grant the following

's March 2, 2005 decision is arbitrary and capricious, and

ority.

s decision regarding the budget,

the Agency with instructions to approve the budget,

nable consulting fees and expenses incurred in bringing

lief as deemed just and equitable in these premises.

---

EXHIBIT "A"

---

HnCENGINEER

I N G

January 20, 2005

James Malcom

Illinois Environmental Protection Agency

Bureau of Land

Leaking Underground Storage Tank Section

P. 0. Box 19276

Springfield, IL 62794-9276

RE:

Site Investigation Stage 1 Completion Report & Stage 2 Budget

LPC # 0290255079

- Coles County

Mattoon / Webb & Sons, Inc.

1201 DeWitt Avenue

LUST Incident No .: 931126

LUST Technical File

Dear Mr. Malcom :

The Site Investigation Stage 1 Completion Report and Stage 2 Budget for the referenced

site are enclosed for your review

. If you have any questions or need additional

information, you may contact me at (217) 352-6976 or jason

.jones© hdc-eng.com .

Respectfully Submitted,

HDC Engineering

Jason Jones

Environmental Professional

cc:

Doris Webb

file

Enclosures

201 W. Springfield Ave ., Suite 300

P.O. Box 140

Champaign, Illinois 61824-0140

BUS. (217) 352.6976

FAX (217) 356-0570

---

Illinois Environmental Protection Agency

Leaking Underground Storage Tank Program

Site Investigation Stage I Completion Report

Site Location

Webb & Sons, Inc.

1201 DeWitt Avenue

Mattoon, Illinois

Coles County

IEMA Incident No

. 20021577

931126

Prepared For

Doris Webb

1201 DeWitt Avenue

Mattoon, Illinois 61938

Prepared by

HDC Engineering

201 West Springfield, Suite 300

Champaign, Illinois 61820

Phone: 217.352.6976

Fax: 217.356.0570

HDC Project No . 01323

January 18,

2005

ENGINEERING

HOC

ENGINEERS • SURVEYORS •

PLANNERS • ENVIRONMENTAL

---

75

w

Agcy is bdndada mwsm

th'e infmemm .i,t Sadm 4 ad 75M XN oflbe Pnviteemad Rowmior Act (4151LCS 5/4

.5/57- 57.17(. F~ha bdiedma this iebreveor

mgmashb .witpeakyofmam acrd 550,000

.00fadbviddo .madddmScivilpastyafawamedSIO

.Ota00Pote .dltyd i Sthihevw m (415

a.CS 5/43) . A.y pane who ~rr,7 make

shin

m.tid eh.saw a mpaeadm ie ay ltd. m .Mt, record. report emit a licma

. aahad

111.4 mohdbd a

usedfrroepeposeofrmwliaswithlidsSMca®bsCl

.4!dory.AeyracSaab.egomofaaaftera.ricd.h nmdab

.Clu3(doy(415a.CS5/5717)/tie

form hr bee

approved

by th4F.rnMayeae.Caa

.

Illinois Environmental Protection Agency

Leaking Underground Storage Tank Program

LUST Technical Form Cover Page

IEMA

Site

Incident

Name: Webb

#

:

&

20021577/931126Snns

. Inn .

IEPA LPC#

(lo-di,it) : 0290255079

Site Address

(Na.P.0 . B..)

: 1201 DeWitt Avenue

City:

Mattoon

County: Coles

ZIP Code: 61938

Please indicate below the type ofplan/report that is being submitted to the Illinois EPA at this

time

. This form must be attached to all plans and reports submitted to the Illinois EPA pursuant

to 35 Ill. Adm

. Code 731, 732 and/or 415 ILCS 5/57-57

.17. Please check all that apply.

20 Day Certification

45 Day Report

Free Product Removal Report

Owner/Operator Summary

Election to Proceed Under Title XVI

Initial

Amended

Submittal Submittal

Site Investigation Plan

Site Investigation Budget

l~

Site Investigation Completion Report

Site Classification Plan

Site Classification Plan Budget

Site Classification Completion Report

Groundwater Monitoring Plan (Low Priority)

Groundwater Monitoring Plan Budget (Low Priority)

Groundwater Monitoring Results (Low Priority)

Corrective Action Plan

Corrective Action Plan Budget (High Priority)

Corrective Action Completion Report

Professional Engineer Certification

IL 532 2369

Other (specify)

LUST Technical Form Cover Page

LPC 533 Rev

. June 2002

---

1 .0 Site History

3

2

.0

Site Description

3

3.0

Site Investigation Results

3

3 .1

Soil Investigation Activities

3

3.2

Groundwater Investigation Activities

4

3.3

Groundwater Elevation and Flow Direction

5

3.2

Groundwater Flow Velocity

5

3.3

Vapor Investigation Activities

5

3 .4

Community and Potable Well Survey

6

3.5

Surface Bodies of Water

6

4.0

Discussion of Subsurface Investigation

6

5.0

Future Investigation

6

Appendices

Appendix A

Appendix B

Appendix C

Appendix D

Appendix E

Appendix F

Appendix G

HDC Engineering

Project No .

01323

Site Investigation Report Form

Site Map

Soil Boring Logs

Monitoring Well Construction Diagrams

Laboratory Reports and Chain-of-Custody Forms

Analytical Results Table

Hydraulic Conductivity Test Data

---

The PID readings do not appear to indicate elevated vapors due to the Site .

Additionally, to our knowledge, no petroleum vapors or odors have been reported in any

nearby buildings or utility conduits since the original report of the release.

3.4

Community and Potable Well Survey

The Illinois Environmental Protection Agency (IEPA), Bureau of Water, Division of Public

Water Supply, Illinois State Geological Survey (ISGS) and Illinois State Water Survey

(ISWS) were previously contacted to identify all community water supply wells within

2,500 feet and potable water supply wells within 200 feet of the former tank

. This

information was provided in the 45 Day Report, dated March 13, 2003, and received by

IEPA on February 3, 2003

. Refer to the 45 Day Report for the water well survey data .

The Village of Mattoon Public Works Engineering Department was contacted to

determine if a local ordinance or policy exists that regulates the use of potable water

supply wells

. David Wortman indicated that no local ordinance or policy exists that

regulates the use of potable water supply wells in Mattoon .

3.5

Surface Bodies of Water

A site survey was conducted to identify any surface bodies of water within 100 feet of the

UST system

. No such bodies of water were observed within the 100-foot radius

.

4.0

Discussion of Subsurface Investigation

The laboratory results of the soil and groundwater samples indicate the presence of

petroleum contamination at concentrations above the applicable Tier 1 Cleanup

Objectives at 131, B2, MW1, and MW3 see tables in Appendix F for specific data

. These

results provide evidence that there is migration of petroleum contamination through

natural and man-made pathways at the site

.

Petroleum vapors or odors have not been reported in nearby dwellings or utility conduits

since the original report of the release

. The storm sewer survey indicated no locations

with significant detectable organic vapors

. Based on this information, it appears unlikely

that an immediate threat to human health or safety, or a risk of explosions, exists at the

Site .

5.0

Future Investigation

Based on analytical results to date, soil and groundwater contamination has not been

fully delineated

. Current data suggest extensive soil contamination on-site

. It should be

HDC Engineering

Project No

. 01323

Results

of Subsurface Accesses Survey

Sampling Location

PID Reading (ppm)

storm sewer inlet (southwest comer of DeWitt and 12'" St

.) 1 .6

storm sewer inlet (southeast comer of DeWitt and 12 °i St .)

1

.9

storm sewer inlet (northeast comer of DeWitt and 12'" St

.) 1 .3

storm sewer inlet (northwest comer of DeWitt and 12'" St .)

1

.6

---

noted that the distance between and lack of data points on-site creates a large margin of

error when predicting contamination migration. Future investigation activities will focus

on minimizing this margin of error by increasing the number of data points, thereby

reducing the cost of remedial activities . Additional monitoring wells are required to

delineate BTEX contamination to the north and northeast of the site . Additional soil

borings are required to delineate on-site contamination

. MTBE contamination has been

fully delineated. Therefore, analysis of this constituent need not be addressed in this

stage of the investigation. Future investigation at the site will include the following :

•

Three monitoring wells will be installed to the north and northeast of the site to

delineate the contamination present in MW3

.

- MW5 will be installed off-site on the northwest comer of DeWitt Ave . and 12th

St.

-

MW6 will be installed off-site on the northeast corner of DeWitt Ave . and 12"'

St.

- MW7 will be installed off-site on the southeast comer of DeWitt Ave

. and 12"'

St.

• Groundwater samples will be collected from monitoring wells MW1 - MW7 and sent

to an accredited laboratory for BTEX analysis . A total of 7 groundwater samples will

be collected. One groundwater field blank will be collected and analyzed for BTEX.

• Eight soil borings will be advanced to a depth of 12 feet on-site and three soil borings

will be advanced to a depth of 12 feet off-site and sent to an accredited laboratory for

BTEX analysis . A total of 11 soil borings will be advanced to delineate contamination

of the site .

- B4 will be advanced approximately 40 feet west of PTS4

.

B5 will be advanced approximately 7 feet south of the north sidewalk and 118

feet west of the east sidewalk.

86 will be advanced approximately 20 feet east of B5 and 15 feet south of

MW2.

B7 will be advanced south of tank bed #5, approximately 40 feet east of the

west property boundary .

88 will be advanced 25 feet north of MW4

.

89 will be advanced approximately 15 feet west of MW4 and approximately

45 feet south of PTS1 .

B10 will be advanced approximately 20 feet east of MW1 .

811 will be advanced approximately 20 feet south of MW1 .

B12 will be advanced approximately 15 feet west of MW1 .

B13 will be advanced approximately 20 feet north of MW1

.

B14 will be advanced approximately 45 feet north of PTS2 on the north side

of DeWitt Ave.

•

In addition to the samples collected from soil borings B4 - B13, soil samples will also

be collected from MW5, MW6, and MW7 . The zone exhibiting the highest PID

reading from each boring will be selected for laboratory analysis

. A second sample,

deeper than the first, also will be selected for laboratory analysis in order to define

the vertical extent of contamination . In the absence of definitive PID readings,

samples will be collected based on similar depths of known contamination . Soil

sample collection will follow SW-846 Method 5035 for BTEX .

HDC Engineering

Project No . 01323

---

Permission to access adjacent properties to the north, northeast, and southwest for

investigation will be requested from the property owners . If access is granted

groundwater and soil investigation will be performed on these properties .

Soil borings, well installation, and sample collection will follow procedures described in

Section 3.0 of this report. Wells are expected to be 15 feet deep and soil borings are

expected to be 12 feet deep . However, depths may be increased based on field

screening results. Boring locations as shown in Appendix B are approximate . Actual

locations may vary based on physical barriers such as utility lines, utility poles, trees,

and ground cover (e.g., concrete drives) .

A budget for the next phase of delineation is being submitted with this plan .

If the data gathered from this proposed phase of investigation is sufficient to delineate

soil and groundwater contamination, a corrective action plan and budget will be

developed. If groundwater contamination is not fully delineated, an additional

investigation plan and budget will be submitted for approval .

HDC Engineering .

Project No. 01323

---

EXHIBIT `B"

---

Illinois Environmental Protection Agency

Leaking Underground Storage Tank Program

Site Investigation - Stage 2 Budget

Site Location

Webb & Sons, Inc .

1201 DeWitt Avenue

Mattoon, Illinois

Coles County

IEMA Incident No. 20021577

931126

Prepared For

Doris Webb

1201 DeWitt Avenue

Mattoon, Illinois 61938

Prepared by

HDC Engineering

201 West Springfield, Suite 300

Champaign, Illinois 61820

Phone : 217.352 .6976

Fax: 217.356.0570

HDC Project No. 01323

January 18, 2005

ENGINEERING

HOC

ENGINEERS

•SURVEYORS

•

PLANNERS

• ENVIRONMENTAL

---

LIST OF CONTENTS

Site Information Form

Proposed Budget Summary and Budget Total Form

Investigation Costs Form

Analysis Costs Form

Personnel Form

Equipment Costs Form

Field Purchases and Other Costs Form

Handling Charges Form

Owner/Operator and Professional Engineer Budget Certification Form

Eligibility and Deductibility Determination

---

A. SITE INFORMATION

Site Name: Webb & Sons. Inc

.

Site Address : 1201 DeWitt Avenue

City:Mattoon

Date

This

IEMA

ZipCounty

:

form

61938this

Incident

: Colesis

Form

being

was

No .

submitted

:

Prepared931126

:

and

asJanuary

a:

200215772005 IEPA

IEMA

Generator

Notification

No.: 0290255079Date

: May

7.1993

_

X Budget Proposal

Budget

Amendment (Budget Amendments must include only the costs

over the previous budget.)

Billing

Amendment

Package

Numberfor

costs

: incurred

pursuant to 35 Illinois Administrative

Code (IAC), Part 732 ("new program")

.

This form is being submitted for the Site Activities indicated below (check one)

:

Early Action

Site Classification

Low Priority Corrective Action

High Priority Corrective Action

X Other

(indicate activities)

Site Investigation- Stage 2

DO NOT

COSTS

SUBMIT

AT

"NEW

THE SAME

PROGRAM"

TIME,

COSTS

ON THE

AND

SAME

"OLD

FORMSPROGRAM"

.

A-1

This form must be submitted in duplicate

.

BUDGET AND BILLING FORM FOR

LEAKING UNDERGROUND STORAGE

TANK SITES

---

B.

PROPOSED BUDGET SUMMARY AND BUDGET TOTAL

Investigation Costs

: S 7,916.10

2.

3.

Analysis Costs

: S

2,143 .92

4.

Personnel Costs: $ 17.610 .00

5.

Equipment Costs: S 740.00

6.

Field Purchases and Other Costs

: $

2.650,00

TOTAL

Handling Charges

PROPOSED

: S 147.08

BUDGET

= S 31.207.10

S1

This form must be submitted in duplicate .

IEMA No. 931126, 20021577

---

E.

INVESTIGATION COSTS

IEMA No . 931126.20021577

Method I Method

II Method

III Not Applicable X

1.

Drilling Costs -

This includes the costs for drilling labor, drill rig usage, and other drilling equipment .

Borings which are to be completed as monitoring wells should be listed here . Costs associated with

disposal of cuttings should not be included here

. An indication must be made as to why each boring is

being conducted (i.e., classification, monitoring wells, migration pathways)

.

_borings to

15

feet =

45 feet to be bored for monitoring wells

11-borings to 12 feet =

144 feet to be bored for

borings

borings

_borings

Boringstototo

: 189 feet

feet

feet

=== Total

feet

x

Feet

$

to

14feet

feet

feet

.00be

to

to

to

Boredbe

be

be

bored

:

bored

bored

per

165forforforfoot =

$soil borings2,646.00 (or)

Hoursborings

: through ftx

Sof bedrock

= per

hour

Ft bedrock

= S to

be bored

borings through ft

of bedrock - Ft

bedrock to be bored

Total Feet bedrock to be Bored :

Borings: Ft

bedrock x $ per

ft bedrock = S (or)

Hours x S per

Hour = S

3 # of Mobilizations @ $ 250.00 per

mobilization = $ 750.00

Other Costs

decon equipment

- per day

decon/drumming labor -

per hour

per diem, 3 man crew -

per man-day

concrete cores - each, for wells

well installation - rig time

well installation

- labor, 2-man crew - per hour

E-1

This form must be submitted in duplicate .

Number

of Units

Unit Cost

Total Cost

3

$190.00

$570.00

5

$38.00

$190.00

3

$100.00

$300.00

I

$50.00

$50.00

3

$75.00

$225.00

3

$76.00

$228.00

---

IEMA No. 931126.20021577

2.

Professional Services

(e.g., P.E., geologist) -

These costs must be listed in Section 1, the Personnel

section of the forms

.

3.

Monitoring Well Installation Materials - Costs listed here must be costs associated with well casing,

well screens, filter pack, annular seal, surface seal, well covers, etc

. List the items below in a time and

materials format

4.

Disposal Costs -

This includes the costs for disposing of boring cuttings and any water generated

while

performing borings or installing wells

.

Transportation

Describe

Disposal

Disposal

how

of

of

CuttingsWaterthe

Costswater/soil

:

:

:

S 4 6 will

be

drums

drums

disposedx

x SS

:

220220removed

.00.00

by

per

per

licensed

gallon

drum

=

=

waste

SS

handler

1880.320.00.00 to

be

recycled .

Total Investigation

Incinerated orCostslandfilled

: S 7,916.10

E-2

This form must be submitted in duplicate

.

Material

Number

of Units Unit Cost

Total Cost

10' x 2" PVC screen

3

35 .00

105 .00

5' x 2" PVC riser

3

15 .60

46.80

2" PVC bottom plug

3

8.00

24.00

locking cap

3

17.60

52 .80

8" aluminum manway

3

82 .00

246.00

filter sand

21

8.00

168 .00

bentonite grout

6

12 .00

72 .00

concrete

5

8.50

42.50

---

F. ANALYSIS COSTS

1 .

Physical Soil Analysis - This must only include analysis

costs for classification of soil types at the site.

-Ex-situ

Soil

Moisture

Soil

Particle

Classification

Indicate

Hydraulic

Content

Size

method

samples

Conductivity/Permeabilitysamples

samples

to be

x

x

x

Sperformed$ S

: samples

per

per

per

sample

sample

sample

=

=

=

$$$

Rock Hydraulic

Indicate

Conductivity/Permeability

the method

x

to

S be

performed : samples

per sample = S

Natural Organic Carbon Fraction

x S (foc)

samples

per sample

- S

Indicate the ASTM or

x $SW-846 method

to be performedper

: sample

= $

2.

samples

samples

samples

samples

samples

x

x

x

x

x

SS$S$ per

per

per

per

per

sample

sample

sample

sample

sample=

=

=

=

-

$$S$$

Soil Analysis Costs -

This must be for laboratory an a sts only .

28 BTEX samples x S

48.75 per

sample = S 1 365 00

LUST

PNA samples

Pollutants

x Ssamples x

S per

sample =

per

$ sample

= $

F-I

This form must be submitted in duplicate

.

1EMA No . 931126.20021577

---

Lab

Flash

_pH-_-TCLP

_,_Paint

and/or

Point

Filter

Lead

Samples

Field

samples

samples

samples

x

Bank

$ x

x

x

samples

$S$ x

per

S sample

per

per

per

sample

sample

sample

= $ =

=

=

per

$$S sample

= $

28 Drv Weight samples x S

12.50 per sample = $ 350.00

_ 8 Handling & Disposal

samples

samples

x

x

$S3.00 per

per

per

per

sample

sample

sample

sample

=

=

=

=

$S$$ 84.00

3. Groundwater

Analysis

Costs -samples

samples

This must

x

x

$be

$ for

laboratory analysis only.

LUST

PNA

_7

samples

Pollutants

BTEx samples

x

samples

$x

$40.31x

$ per

per

sample

sample

=

=

per

$$ 282sample

.17 =

$

----pH Samples x $ per sample = $

Flash

_Lab Point

and/or

samples

Field Bank

x $samples samples

samples

samples

samples

x S38.75x

per

x

x

x

$$$ $ sample

3.00 =

per

$ sample

=

38.75

samples

samples x

x

S$

8Handling & Disposal

TOTAL ANALYSIS COSTS = $

2,143.92

F-2

This form must be submitted in duplicate .

IEMA No. 931126, 20021577

per sample = S 24.00

per

per

per

per

per

sample

sample

sample

sample

sample

=

=

=

=

=

$SSS$

---

G.

PERSONNEL

IEMA No .

931126. 20021577

All personnel costs that are not included elsewhere in the budget/billing form must be fisted here

. Costs must

be listed per task, not personnel type . The following are some examples of tasks : Drafting, data collection,

plan, report, or budget preparation for (i.e., site classification work plan, 45 day report, or high

priority corrective action budget), sampling, field oversite for (i.e., drilling/well installation,

corrective action, or early action), of maintenance of . The above list is not inclusive of all

possible tasks .

_Proiect Manager(Title) :16 hours x S 99.00 per hour = $

1.584.00

Task to be performed for the above hours : project supervision, administration. and review

Professional Engineer :28

_ hours x S

90.00 per hour = $ 2,520.00

(Title)

Task to be performed for the above hours : PE

preparation and certification of reports, priect oversight

Environmental(Title)Professional IV :28 hours x $ 77.00 per hour= $ 2.156.00

Task to be performed for the above hours: work plan development, report preparation

Environmental

(Title)Professional

111

:

70 hours

x S 75.00 per hour = S 5,250.00

Task to be performed for the above hours : logging, soil and water sampling. survey. report writing

Environmental Professional II :90 hours x S 65 .00 per hour = S 5,850.00

(Title)

Task to be performed for the above hours: well development water samplingm survey

Draftsperson(Title)

:5 hours x S

50.00 per

hour = S 250.00

Task to be performed for the above hours: technical drawings for

report

(Title)

hours x S per hour = S

Task to be performed

(Title)

for the above hours

: hours

x S per hour = $

Task to be performed

(Title)

for the above hours

: hours

x $ per

hour = S

G-1

This form must be submitted in duplicate .

---

IEMA No. 931126 .20021577

Task to be performed for the above hours

: hours

x $ per

hour = S

(Title)

Task to be performed for the above hours

: hours

x $ per

hour = $

(Title)

Task to be performed for the above hours

: hours

x S per hour = $

(Tide)

Task to be performed for the above hours-

hours x $ per hour = $

(Title)

Task to be performed for the above hours :

hours x S per hour = $

(Title)

Task to be performed for the above hours

:

(Title)

hours x $ per hour = $

Task to be performed for the above hours :

hours x S per hour = $

(Title)

Task to be performed for the above hours-

(Title)

hours x S per hour= $

Task to be performed for the above hours :

TOTAL PERSONNEL COSTS: $17,610.00G-2

This form must be submitted in duplicate.

---

H. EQUIPMENT COSTS

All equipment used must be listed below in a time and materials format . Handling charges should not be

added here

; use Section J.

H-1

This form must be submitted in duplicate

.

IEMA No. 931126.20021577

Subtotal Page H-l : $740.00

Equipment

Own or

Rent? Time Used Unit Rate

Total

Cost/Item

Photoionization detector

own

3 days

$100.00

$300.00

Water level meter

own

2 day

$30.00

$60.00

Submersible Pump

own

2 days

$40.00

$80.00

Generator

own

lday

$100.00

$100.00

Survey Equipment

own

I day

$50.00

$50.00

Environmental Support Vehicle

own

3 days

$50.00

$150.00

---

Subtotal Page H-2 : $0 .00

Total (Pages H-l and H-2) : $740 .00

H-2

This form must be submitted in duplicate

.

IEMA No.

931126 .20021577

Own or

Total

Equipment

Rent? Time Used Unit Rate

Costlitem

---

I. FIELD PURCHASES AND OTHER COSTS

All field purchases must be listed below in a time and materials format . Handling charges must not be added

here

; an Section J, Handling Charges to calculate the handling charges .

Field Purchases

Quantity

Price/Item Total Cost

Do Handling

Charges

Apply?

Subtotal Page I-l : $0.00

I-1

This form must be submitted in duplicate

.

IEMA No . 931126 .20021577

---

TOTAL OTHER COSTS - S2,650.00

1-2

This form must be submitted in duplicate.

IEMA N0

.

931126, 20021577

Other Costs -

A listing and description of all other costs which will be/were incurred and are not specifically

listed on this form should be attached The listing should include a cost breakdown in a time and materials

format.

Subtotal Page 1-2 : $2,650.00

Total Pages I-1 and 1-2 : $2,650.00

Other Costs

Quantity Price/Item Total Cost

Do Handling

Charges

Apply?

Mileage- per mile

500

$0.38

$190.00

no

Disposable bailers - each

7

$10.00

$70.00

no

Drums

10

$60.00

$600.00

no

Prints

12

$1 .00

$12.00

no

Baggies - per box

$3.00

$6.00

no

lee - per bag

3

$2.00

$6.00

no

Latex gloves- per box

2

$10.00

$20.00

no

Tenacore samplers - each

28

$2.00

$56.00

no

Shipping (to client / IEPA)

4

$10.00

$40.00

yes

City Boulevard Cut Permit

3

$50.00

$150.00

yes

Survey

1

$1,500.00

$1,500 .00

no

---

J. HANDLING CHARGES

A. Subcontractor Charges

J-1

This form must be submitted in duplicate

.

IEMA No . 931126.20021577

Handling charges are eligible for payment on subcontractor billings and/or field purchases only if they are

equal to or less than

the amounts determined by the following table

:

Subcontractor

Western Environmental Services

RS Used Oil

Great Lakes Analytical

Section in these

Forms where

Cost is Listed

investigation

investigation

analysis

Subcontract Amount

$2,820.10

$2,200

$2,143 .92

Subtotal Page J-1

: $7,164 .02

Subcontractor or Field

Purchase Cost

Eligible Handling Charges as a

Percentage of Cost

$1-$5,000

12%

$5,001 -$15,000

$600 + 10% of amt Over $5,000

$15,001 - $50,000

$1,600

+ 8% of amt. Over $15,000

$50,001 - $100,000

$4,400 + 5% of amt Over $50,000

$100,001 -

$1,000,000

$6,900 + 2% of amt Over $100,000

---

B

. Field Purchase

Field Purchase

City of Mattoon

UPS

Field Purchase Amount

$150.00

$40.00

Subtotal Page J-2 : $190.00

Total Pages J-1 and J-2 : $7,354 .02

Handling Charge* : $147.08

*Use chart at top of Page M- I to calculate the allowable handling charge.

Copies of invoices for subcontractor costs and receipts for field purchases are required for billing submissions .

J-2

This form must be submitted in duplicate .

IEMA No.

931126. 20021577

---

Subscribed and sworn to before me the

~ b

'day of

(Budget

osals and

get Amendments must be notarized when the

Subscribed and sworn to

(Budget Pr .,,

als and Budget Ame

r

r•

~l.Udr.r~

(No

Public)

The Agen is au

orized to require this information under 415 JLCS 5

required .

ailure to do so may result in the delay or denial of any budg

Thrs form has been approved by the Forms Management Center

.

IL 532 2273

LPC 499 Rev. Mar-94

BB:jk\BUDCERT. WPD

Illinois Environmental Protection Agency

Owner/Operator and Professional Engineer Budget Certification Form for

Leaking Underground Storage Tanks Sites

In accordance with 415 ILCS 5/57, if an owner or operator intends to seek payment from the UST Fund, an

owner or operator must submit to the Agency, for the Agency's approval or modification, a budget which

includes an accounting of all costs associated with the implementation of the investigative, monitoring

and/or corrective action plans .

I hereby certify that I intend

activities

to seek

atpayment

Webb

from

& Sonsthe

.

UST

Inc

.

Fund

for

performing

LUST

Site Investigationsite

. I further

certify that the costs set forth in this budget are necessary activities and are reasonable and

accurate to the

best of my knowledge and belief

. I also certify that the costs included in this budget are not for corrective

action in excess of the minimum requirements of 415 ILCS 5/57 and no costs are included

in this budget

which are not described in the corrective action plan . I further certify that costs ineligible for payment from

the Fund pursuant to 35 Illinois Administrative Code Section 732

.606 are not included in the budget

proposal or amendment. Such ineligible costs include but are not limited to :

Costs associated with ineligible tanks.

Costs associated with site restoration (e.g.,

pump islands, canopies) .

Costs associated with utility replacement

(e.g., sewers, electrical, telephone, etc .).

Costs incurred prior to IEMA notification .

Costs associated with planned tank pulls

.

Legal defense costs

.

Costs incurred prior to July 28, 1989 .

Costs associated with installation of new USTs or the repair of existing USTs

.

Owner/Operat%.Dgs

Webb

Title : Owner

Signature:

G?.t~J

If .1

Date: 20

Q5.

t11111~t4/p~~''

f!'

REGISTERED00206SM

4

.41 Z

must

~yobe

notarized

Seal:

Date: //B

when

W. frc'

Z

20 6S .

---

o.In-era

TIT-7854910

Pet

2T?-M4019

knownsaNTIMAnew

.rna4

M7 7aMw

saalR ww Prices"

VSSSSLtWPFr7

FIREr17-730-3018vaavswrnw

unwAaaM§Krm

P17-715-OWM7Jnagra

re

W401'S.00100

HL&M

naeusca

M7dr4,e0e

reaawwet,awaraw"

Ow

r9-7asoueKr,o".4ea

orraraLarss7v

P1m0LAW W

vuuc

r77-7n4f

en wMtw

2rt-reMmr

we arts

. ..uw.a-w..

CERTIFIED MAIL - REC PT REQUESTED 07002 10006004 87416800

CORRECTED

July IA 2002

Webb A Soak Inc

.

1201 DawittAvmoe

Mottoes. IL 61938

In Re:.

Fa

ft

No . 4-028243

IEMA Eooldagt No. 93.1126

Webb A Sam, Inc.

1201 Dewitt Avenue

Mattooa, Colea Co., IL

Dear ApplicarK

The Relmburaemone Eligibility and Deductible AFpEcalion received on A m 12.2002 far the above

relkeced occurenca has been reviewed . The following detmlnatlons have been nude based apm

trim review.

It ha been dstmmined tbatyou see dlgiIL so seekpaymrmt of ensue in nuns af$15,000. Tfbcon

must be in response to the cons sncc referenced above and associated with the following tanks :

Eligible Tanks

Tank 110 00pllmDigel

Tank 2 S,W0 .galloatmwens

Tank 3 2,000-gafonBatmg Oil

Tank 4 2,000.yfoa Diesel

Tank S 4,000-ppmDlad

Tank 61,000-Sd1oarDfael

You mst owfaet the MWm Pnvl a meat

tl

Proteepaa Agency to reonlva a packet ofAgeney billing

Ibtma for aabmedng your request forpaymeot.

An owmr or operator Is cligibb

to aeon the Underground Storage Tank Fred If the eligibility

requfr mot are saddled

:

1.

Nehha the owner

mr the opantor is the ited Stain ClovewmaK

2.

The rank does not curtain drel that

is

exempt from the Motor Fuel Tax Law,

3.

The costs were taeurred as a result of a

confirmed

rslea of any of the following substances

:

'Fuel",

a deflued in Section 1 .19 of the Motor Fuel Tax Lew

Aviation fuel

1056 Slewneon Olin a

" Sprfggatti, gwtoj 927034260

hlnb4 on

cages Pww

a3-.-A3

---

Heating oil

XCOMMMOMPS

Und ad, which b a boom waned

Mom arado ad and in a mom vdkIe. asdefined in Sectiam

1.3 ofthe MomrPS Tax Law

.

4.

71a owner or opaaeare8lsaasd the corn and Paid all ibex

in accordance wi& the story

mud

regaidwy requirstacow of dw Ouolme Storage Act.

S.

71townDroropadww"W MORMNhwicis Rmvrpwy?AwaMwnMAVoqof moonfirmodrolowsk dw

coats was iaommd

.1W the mdAcatim

and S coats war a result of a

relaw of a Qrbaanca listed i n

Ibb Section. Cow ofamsectfro acorn or indmaniGovdam locunal before p*WdWg

end

noodbaWgUica

shell nor be eligible far paymaot

.

c

The corn bays to Wramtr been paid to do anvocr or opzsior under a pawn hwormove pohoy, odor

wAtion garocomoK or cut ads.

7.

The OWN lox anocitud win, worampro action".

7% commimaos the And

66MIn 10 11 To

to Your eligibility and deductibility.

We me" do teft to

change dododwAble --

- should addition bducamabo St wand dnqp the AnwMadon become

available

. A3m vadwround storage tank owner or opormar as appal the decision to the

MinaW PhoMadon,

Control Beat (Base, prewar to wan 573 (c) 040 An owner a opaator who

asks to appeal the decision

Shall file a petition for a W*&q bda the 2Momod vd&b 35 days of the date ofnaWmg of the coat dadtie PS

Mwok ARM&MUnUthe Code 105. 1 02(s) (2)).

Par JaROMMM1711 regarding tftb Aft of an appeal, plow contact

Daro6y 40M . Clerk

Illinois

Sam of11155s

PollutionCenterantol Baud

I00wcdRm,dDI* Suft 11-500

Mmqpt 113inois 60601

(312) 814-3=

Uyan have any qwmdow regarding the QW),or dodoodbGRI,(Manhwicam, picas cannot or Officest

(217) 785-1020 or CZ17) "S-5879 and ask forDnnu.

Lack

S&ca*.

--0,0J)t

Division

DivisioDhactor

of Molown and Cheadcst Safety

MIRMSAII

Ow EMERA

Facility File

---

EXHIBIT "C"

---

Dear Mrs. Webb:

The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the Site Investigation

Plan (plan) submitted for the above-referenced incident . This plan, dated January 18, 2005, was

received by the Illinois EPA on January 24, 2005

. Citations in this letter are from the

Environmental Protection Act (Act), as amended by Public Act 92-0554 on June 24, 2002, and

35 Illinois Admihistrative Code (35 111 . Adm . Code).

The Illinois EPA has determined that the activities proposed in this plan are appropriate to

demonstrate compliance with Title XVI of the Act (Sections 57

.7(a)(1) and 57.7(c) of the Act

and 35 111 . Adm. Code 732

.503(b)). Therefore, the plan is approved

.

In addition, the budget is modified pursuant to Sections 57 .7(a)(2) and 57.7(c) of the Act and 35

Ill. Adm

. Code 732.503(b) . Based or

, the modifications listed in Section 2 of Attachment A, the

amounts listed in Section 1 of Attachment A have been approved

.

Please note that the costs must

be incurred in accordance with the approved plan

. Be aware that the amount of reimbursement

may be limited by Sections 57

.8(d), 57.8(e) and 57 .8(g) of the Act, as well as 35 M. Adm. Code

732.606(s) and 732

.611 .

NOTE

: Amended plans and/or budgets must be submitted and approved prior to the issuance of

a No Further Remediation (NFR) Letter

. Costs associated with a plan or budget that have not

been approved prior to the issuance of an NFR Letter will not be reimbursable .

R,

.m, Rm-4111: Nlulh AUin Street, Rot Ward It 61101-181 .5, 98 :- :rwI

BUREAI .,I. ssu-PHEtras-

rcla-595 7620South

..\ . Unrvers'N

State

. ElginSt.,

. ILPeoria1,0121

. IL

-184-#,1104: Ia18-

. 1091

. I Illh9I-•

;462IN

cwm-

Ols Ptv,ts5415

N.,

. University

9511 W. HarrisonSt

. . PeoriaSL

.

. Des

IL 61614-(3091693-5463Plaines,

IL 60016-(847) 294-4000

SrRi~t .thin-4500S

.SixthStreet Rd .Spdnglield.I162 :1)6-,2171786-6892

CHS.wAR.H -

2125 South First Street, Champaign, IL 61820-(2171278-5800

.-MANN/ 2309 VV . Main St

. Suite I16

. Marion,

•C

IAUVSVREI-2009

IL 62959-(6181993-7200Mall

Street, Collinsville, IL 62234

- (618) 346-5120

PRrsnur"

Ku If unPAnR

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P .O. Box 19276, SPRINGFIELD, ILLINOIS

62794-9276, 217-782-3397

JAMES R. THOnwsGN CENTER, 100 WEST RANDOLPH, SUITE

11-300,

CHCAGO,

IL 60601, 312-814-6026

ROD R .

BLAGOIEVICH, GOVERNOR

RENEE CIPRIANO, DIRECTOR

217/782-6762

CERTIFIED MAIL

7002 3150

0000 1253 3918

Mrs. Doris Webb

8687 E

. 150 N.

Lema, Illinois 62440

RECEIVED

Re:

LPC# 0290255079 -

Coles County

FEB

-

9 2005

Mattoon/ Webb & Sons, Inc

.

1201 DeWitt Avenue

LUST Incident No. 20021577 & 931126

HOC ENGINEERING

LUST Technical File

---

Page 2

Pursuant to Sections 57 .7(a)(5) and 57.12(c) and (d) of the Act and 35111. Adm

. Code 732.100

and 732

.105, the Illinois EPA requires submittal of a Site Investigation Completion Report

within 30 days after completing the site investigation to :

Illinois Environmental Protection Agency

Bureau of Land - #24

Leaking Underground Storage Tank Section

1021 North Grand Avenue East

Post Office Box 19276

Springfield,-IL 62794-9276

Please submit all correspondence in duplicate and include the Re : block shown at the beginning

of this letter.

If you have any questions or need further assistance, please contact James R. Malcom, III at

217/524-9140.

Sincerely,

Harry A. Chappel, P .E.

Unit Manager

Leaking Underground Storage Tank Section

Division of Remediation Management

Bureau of Land

HAC: jrm

cc :

HDC

Division File

---

Re:

LPC# 0290255079 - Coles County

Mattoon/ Webb & Sons, Inc .

1201 DeWitt Avenue

LUST Incident No. 20021577 & 931126

LUST Technical File

Citations in this attachment are from the Environmental Protection Act (Act), as amended by

Public Act 92-0554 on June 24, 2002, and 35 Illinois Administrative Code (35 III

. Adm. Code).

SECTION 1

As a result of the Illinois EPA's modification(s) in Section

.

2 of this Attachment A, the following

amounts have been approved

:

$7,916.10

Investigation Costs

$2,143.92

Analysis Costs

$0.00

Personnel Costs

$740.00

Equipment Costs

$1,150.00

Field Purchases and Other Costs

$147.08

Handling Charges

SECTION 2

I . S 1 .500.00 for surveying . These costs are for activities in excess of those required to meet

the minimum requirements of Title XVI of the Act (Section 57 .7(c)(3) of the Act and 35

III. Adm. Code 732.505(c) and 732.606(o)) .

The excessive costs submitted for surveying indicates that a professional surveyor is

being utilized which is not required by the Agency .

.

2 .

$17,610.00

for costs that lack supporting documentation (35 Ill . Adm. Code

732.606(gg)) . A site investigation plan budget must include, but not be limited to, an

accounting of all costs associated with the development, implementation, and completion

of the site investigation plan (Section 57 .7(a)(2) of the Act) . Since there is no supporting

documentation ofcosts, the Illinois EPA cannot determine if the minimum requirements

necessary to comply with Title XVI have been exceeded (Section 57

.7(c)(3) of the Act

and 35 111 . Adm

. Code 732.505(c) and 732 .606(o)) .

The Agency is requesting that the proposed personnel costs be further broken down to

provide sufficient justification for the proposed personnel cost . The Agency is requesting

information regarding the task performed by each person and the amount of time for each

task performed . The Agency is requesting justification for the estimated amount of time

to complete each task.

Attachment A

---

For example, the professional engineer is requesting 28 hours for P .E. preparation and

certification of reports and project oversight . The Agency is requesting justification as to

why it takes 28 hours to perform these tasks? If 28 hours is simply a budgeted guess,

why was 28 hours proposed?

TOTAL AMOUNT APPROVED FOR SITE INVESTIGATION AND CORRECTIVE

ACTION ACTIVTTES TO DATE :

$13,390.90

Investigation Costs

$5,029.67

Analysis Costs

$12,816.00

Personnel Costs

$1,574.00

Equipment Costs

$1,685.64

Field Purchases and Other Costs

$306.53

Handling Charges

---

EXHIBIT "D"

---

HcCENGINEERING

February 15, 2005

James Malcom

Illinois Environmental Protection Agency

Bureau of Land

Leaking Underground Storage Tank Section

P. 0. Box 19276

Springfield, IL 627949276

RE: Site Investigation Plan

Justification of Personnel Costs

LPC # 0290255079 - Coles County

Mattoon / Webb & Sons, Inc.

1201 DeWitt Avenue

LUST Incident No .: 931126

LUST Technical File

Dear Mr

. Malcom:

In response to your letter dated February 8, 2005, HDC Engineering (HDC) has prepared a

breakdown and justification of the personnel hours that were denied from the Site Investigation

Budget dated January 18, 2005. Please refer to Attachment A for justification of surveying costs

and Attachment B for a complete breakdown and justification of personnel hours .

HDC would like to point out that the IEPA increases personnel costs every time it requires HDC

to submit additional information

. The IEPA required HDC to justify every line item of the last

Site Investigation budget as well . Furthermore, the IEPA originally denied approval of the first

Site Investigation Plan, submitted in September 2003, stating that the number of borings was

unreasonable

. However, four of the borings included in the approved Stage 2 plan are in similar

locations on the Site as proposed in the denied plan, showing that the original plan was

reasonable in the first place. Costs for the project would have been reduced had the original

plan been approved in September 2003 .

HDC has a highly qualified staff of environmental professionals, with many years of experience

with underground storage tanks . This recurring requirement by the IEPA for

microjustification

of personnel costs is redundant and time consuming, and is viewed as an affront to HDC's

professionalism and experience

. It also has the unfortunate result of increasing the overall

costs and duration of the project. As your office has told HDC, one of the charters of the IEPA

is to ensure the LUST fund is well spent However, you consistently require HOC to duplicate

effort in justifying cost when, in fact, the cost and work are already justified and reasonable

.

201 W. Spiinq Sd Ave .. Suite 300

P.O

. Box 140

Chempeign, hinds 61824-0140

BUS . (217) 352-W6

FAX (217) 358-0570

---

James Malcolm

February 15, 2005

Page 2 of 2

If you have any questions I can be reached at 217.352.6976 or kevins@hdc-eng. com.

Respectfully Submitted,

HDC Engineering

/L---

Kevin Saylor, PE

Environmental Division Manager

cc:

Doris Webb

file

Enclosures

---

EXHIBIT "E"

---

H®CENGINEERING

February 25, 2005

James Malcom

Illinois Environmental Protection Agency

Bureau of Land

Leaking Underground Storage Tank Section

P. 0. Box 19276

Springfield, IL 62794-9276

RE: Site Investigation Plan

Justification of Personnel Costs

LPC # 0290255079 - Coles County

Mattoon / Webb & Sons, Inc .

1201 DeWittAvenue

LUST Incident No

.

: 931126

LUST Technical File

Dear Mr. Malcom:

201 W SpdngBeld Ave., Suits 300

P0 . Box 140

Champaign, Ilnois 618240140

BUS. (217) 352

.6976

FAX (217)356.0570

HDC Engineering (HDC) has been in contact with Sue Rennels of Representative Chapin

Rose's office. As you are aware, Ms . Rennels has been in contact with the IEPA on behalf of

Doris Webb, who is a constituent of Mr . Rose. In response to the recent Site Investigation (SI)

budget, Ms

. Rennels informed HDC that your office dog not intend to approve the personnel

requested as part of this budget, even considering the justification letter prepared by HDC and

dated February 15, 2005 . Ms . Rennels stated that your position is that SI personnel costs are

limited to a range around $12,000 .

HDC agrees that this amount of personnel costs, depending on the site-specific scope of work,

may be adequate for the first stage of St. However, many sites, such as Webb's, require

additional stages of St. Each stage of investigation will require additional personnel costs

. The

personnel costs for additional stages may be greater than the first stage of investigation, as the

work generally tends to incorporate adjacent properties, necessitating property boundary

identification and right-of-entry agreements . Additionally, subsequent costs and associated work

are not known until the each preceding stage is completed .

HDC would also like to point out that we have two other projects in the second stage of SI which

are under the review of other IEPA units . Personnel costs for both of these projects were

approved for each stage of SI as follows :

Stage 1

Stage 2

Total

$14,972

$16,710

$31,682

$13,974

$12,333

$26,307

---

James Malcolm

February 25, 2005

Page 2 of 2

It would appear that your unit's interpretation of SI is inconsistent with at least two other units

in

your section

.

HDC maintains that additional stages of SI logically require additional personnel

costs . The

personnel costs approved for the first stage of SI were to perform and report on the field work

for that stage, including three soil borings

and four monitoring wells .

The second stage will

include personnel costs to perform and report

on an additional eleven soil borings and

three

monitoring wells, several of which are off site . The technical portion of the work plan was

approved, as well as all investigation, analytical, equipment, and most other costs . It is not

reasonable that all of the work and non-personnel costs were approved, but the personnel costs

to actually perform the work was not .

Your review letter dated February 8, 2005, does not refer to itself as a final decision or state that

the decision can be appealed

.

HDC requests that you reconsider your decision and approve

the proposed costs . In lieu of approval, HDC requests that you issue a final decision letter with

the appeal attachment that is standard for budgets that have been approved with modifications .

If you have any questions I can be reached at 217 .352.6976 or Kevin® hdc-eng.com.

Respectfully Submitted,

HDC Engineering

Kevin Saylo

.r,r,~P`E~

Environmental Division Manager

cc:

Doris Webb

Sue Rennels

---

Attachment A

$1,500 were deducted from the budget for surveying costs with the reasoning that a

professional survey is not required by the Agency

. The requirements of Title XVI do not

specifically require a professional survey as part of a LUST incident . However, it has been

HDC's experience that professional survey's are ultimately necessary to delineate and obtain

No Further Remediation status for LUST projects .

During the course of delineation, it is necessary to identify the site's property boundaries

. The

location of these boundaries is used to identify the extents of the property and to place off site

boring locations.

The letter to request off site access to perform delineation and/or remediation on adjacent

properties is essentially a contract between the LUST owner/operator and the adjacent property

owner.

Therefore, a professional boundary survey is crucial in identifying the site's and

adjacent parcel's property limits to insure that the necessary access is obtained and that the

necessary involved parties are protected by the off site access letter .

The accurate location of property boundaries is necessary for the use of highway authority

agreements . These agreements require scaled maps identifying the impacted area and the

extents of the agreement

.

Environmental land use controls require the legal description of the property subject to the

control. The professional boundary survey is used for this purpose.

The Property Owner Summary required for corrective action completion also requires a legal

description

. Again, the professional survey Is used for this purpose .

In general, the reporting requirements of the LUST program require the accurate presentation of

the site and adjoining properties, including utilities, roadways, and property boundaries. To fulfill

these requirements, a professional survey is conducted . Sources such as county plat and aerial

composite maps are not always of sufficient detail to accommodate the requirements to close a

LUST incident

. In some instances, a foot can mean the difference between a highway authority

agreement and an environmental land use control . Additional land use controls requires a

significant amount of additional consulting time and additional liability for the owner .

Required technical reports, such as the Site Investigation Completion Report and the Corrective

Action Completion Report, require certification by a licensed Professional Engineer or

Professional Geologist. The certification includes the following statement

To the best of my knowledge

and belief, this report supporting documents and all

attachments

are true, accurate and complete.

The only accurate and complete way to identify property boundaries is to utilize a professional

surveyor.

Because of these reasons, HDC requests that the Agency approve the $1,500 for professional

surveyor's costs . These costs have been approved on numerous other LUST budgets and

billing packages .

---

Environmental Professional II (90 hours)

Work Description

Number of Hours

Work plan preparations (Stage 2 Site

22

Investigation Work Plan and Budget)

Sample and log soil borings

20 (one EPII for two 10 hour days)

Pre-drill / Post-drill

4

(JULIE locate, package and ship samples, etc .)

Of-site access

12

(Obtain property and adjacent property tax cards,

contacting and coordinating off-site access,

including both IDOT and city right of ways)

Well development and survey

18 (two EPII's for one 9 hour day)

Well purging and sampling

10 (one EPII for one 10 hour day)

Miscellaneous'

4

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc .)

Environmental Professional III (70 hours)

Work Description

Number of Hours

Prepare Site Safety and Health Plan

2

Pre-drill / Post-drill

(prepare soil log templates, load/unload sampling

supplies, jar samples, ship samples, etc .)

Monitoring Wei Installation

10

(Supervise subcontractor, sample and log soil,

etc.)

Well purging and sampling

10 (one EPIII for one 10 hour day)

Miscellaneous'

8

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc .)

Report writing (Stage 2 and Stage 3 Site

36

Investigation Work Plans and Budgets, including

soil boring logs, analysis tabulation, and

reimbursement)

Attachment B

---

Attachment B (continued)

Environmental ProfessionalN (28 hours)

Work Description

Budget

preparations

Number of Hours

12

Report preparation and oversight

8

Miscellaneous'

(Contact with client, IEPA, local municipality,

8

IDOT, subcontractors, laboratory etc.)

Project Manager (16 hours)

Work Description

Work plan preparation

Number of Hours

3

Budget preparation and review

2

Site Safety and Health Plan preparation and

review

1

Pre-drill oversight

1

Monitoring well drilling oversight

1

Report preparation and oversight

2

General project management 6

Project Engineer (28 hours)

Work Description

Number of Hours

Work plan preparation for Stage 2

4

Budget preparation for Stage 2

3

Technical supervision for field activities

5

Stage

reimbursement

3 Site Investigation

request)

Work Plan and Budget, 8

Miscellaneous'

8

(Contact with client, IEPA, local municipality,

[DOT, subcontractors, laboratory etc.)

---

*Miscellaneous time includes communication with the owner/operator, local municipality, IDOT,

subcontractors, and the IEPA which does not necessarily fall within a specific task . HDC has

and

found

justification

that many times,

for the

especially

approval

with

of budgets,

this site,

reimbursements

that the [EPA

and

requires

reportsadditional

. When the

informationIEPA

requests additional informationijustification, additional consultant fees are incurred . HDC feels

that the costs requested in this budget are reasonable and are consistent approved funds for

several other LUST projects.

---

EXHIBIT "F"

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P .O . Box 19276, SPRINGFIELD, ILLINOIS 627949276, 217-782-3397

JAMES R . THowwsoN CENTER, 100 WEST RANDOLPH, SurrE 11-300, CHIrwGO, IL 60601, 312-814-6026

ROD R . BLAGO)EvicH, GOVERNOR

RENEE CIPRIANO, DIRECTOR

217/782-6762

CERTIFIED MAIL

7002 3150 0000 1253 7084

MAR 0 2 20

Mrs. Doris Webb

8687 E. 150 N.

Lerna, Illinois 62440

Re:

LPC# 0290255079 -

Coles County

Mattoon/ Webb & Sons, Inc

.

1201 DeWitt Avenue

LUST Incident No . 20021577 & 931126

LUST Technical File

Dear Mrs . Webb :

The Illinois Environmental Protection Agency (Illinois EPA) has reviewed the amended Site

Investigation Plan Budget(budget) submitted for the above-referenced incident This budget,

dated February 15, 2005, was received by the Illinois EPA on February 16, 2005

. Citations in

this letter are from the Environmental Protection Act (Act), as amended by Public Act 92-0554

on June 24, 2002, and 35 Illinois Administrative Code (35 Ill. Adm. Code).

The budget is modified pursuant to Sections 57

.7(a)(2) and 57.7(c) of the Act and 35111. Adm .

Code 732 .503(b)

. Based on the modifications listed in Section 2 of Attachment A, the amounts

listed in Section 1 of Attachment A have been approved

. Please note that the costs must be

incurred in accordance with the approved plan Be aware that the amount of reimbursement may

be limited by Sections 57.8(d),

57 .8(e) and 57.8(g)

of the Act, as well as 35 Ill . Adm. Code

732.606(s) and 732 .611.

An underground storage tank system owner or operator may appeal this decision to the Illinois

Pollution Control Board. Appeal rights are attached

.

ROCKFORD- 4302 North Main Street Rockrord, a 61103-1815) 987-7760 • Drs F1w*IES- 9511

w. Harrison A ., Des Plaines, IL 60016-1847) 294-4000

ELCJN - 595 South State, Elgin, IL 60123 -1847) 608-3131

PEoRN- 5415 N. University St.,

Peoria, IL 61614-(309) 693-5463

BURtwu or LAND- PtoRU-7620 N . University 5L, Peoria, IL 61614-(309) 693-5462

•

CNM4MJGN- 2125 South First Street, Champaign, IL 61820-1217) 278-5800

SPRINGERLD-4500 S . Sixth Street Rd., Springfield. IL 62706-(217) 786-6892 •

COLUNSVILLI- 2009 Mall Street, Collinsville, IL 62234- (618) 346-5120

MAwoN -2309 W. Main SL, Suite 116, Marion, IL 62959 -

(618) 993-7200

PRINTED oN RtcrrirD PArcR

---

Page 2

If you have any questions or need further assistance, please contact James R Malcom, III at

217/524-9140.

A Chappel, P.E.

Unit Manager

Leaking Underground Storage Tank Section

Division of Remediation Management

Bureau of Land

HAC: jrm

Attachment: Budget Modification

cc: HDC Engineering

Division File

---

Page 2

The following personnel work hours are being approved based on the work plan provided

in the plan received January 24, 2005 :

Environmental ProfessionalII

(82 Hours approved, 8 hours denied as unreasonable)

$5,330.00

approved in budget

The 4 hours for pre-drllllpost drill were deducted as these cost are considered part of

sample and soil boring log hours

. The 4 hours for miscellaneous task was deducted as

these tasks are being approved under Off-site

access hours.

Environmental Professional III (46 Hours approved, 24 hours denied as unreasonable)

$3,450.00 approve in budget

The hours associated with the safety and health plan were deducted as this task was

approved under the previous budget The hours for pre-drA4 post drill, well purging

and sampling, and miscellaneous were deducted as they were approved under the

Environmental Professional II hours.

Environmental Professional IV (12 Hours approved, 16 hours denied as unreasonable)

$924.000

The hours associated with report preparation & oversight and miscellaneous were

deducted as these tasks were approved under the Environmental professional IL

All hours associated with the project manager were deducted as these hours were

approved under the environmental professional II hours. All hours for the project

engineer were deducted as these hours were approved under the environmental

professional II . The costs for the stage III site investigation work plan and budget was

deducted as this report is not required at this time .

TOTAL AMOUNT APPROVED FOR SITE INVESTIGATION AND CORRECTIVE

ACTION ACTTVITES TO DATE

:

$13,390.90

Investigation Costs

$5,029.67

Analysis Costs

$22,520.00

Personnel Costs

$1,574.00

Equipment Costs

$1 ;685.64

Field Purchases and Other Costs

$306.53

Handling Charges

---

Page 3

Appeal Rights

An underground storage tank owner or operator may appeal this final decision to the Illinois

Pollution Control Board pursuant to Sections 40 and 57.7(c)(4)(D) 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, IL 60601

312/8143620

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, IL 62794-9276

217/782-5544

---

Re: LPC# 0290255079 -- Coles County

Mattoon/ Webb & Sons, Inc .

1201 DeWitt Avenue

LUST Incident No

. 20021577 & 931126

LUST Technical File

Citations in this attachment are from the Environmental Protection Act (Act), as amended by

Public Act 92-0554 on June 24, 2002, and 35 Illinois Administrative Code (35 Ill . Adm. Code) .

SECTION 1

As a result of the Illinois EPA's modification(s) in Section 2 of this Attachment A, the following

amounts have been approved

:

$0.00

Investigation Costs

$0.00

Analysis Costs

$9,704.00

Personnel Costs

$0.00

Equipment Costs

$0.00

Field Purchases and Other Costs

$0.00

Handling Charges

SECTION 2

1 .

$1,500.00 for surveying. These costs are for activities in excess of those required to meet

the minimum requirements of Title XVI of the Act (Section 57 .7(c)(3) of the Act and 35

Ill. Adm. Code 732.505(c) and 732 .606(o)) .

The excessive costs submitted for surveying indicates that a professional surveyor is

being utilized which is not required by the Agency . The Agency's February 8, 2005

decision

remains

in effect for this item.

2. $7,906 .00 for an adjustment in personnel costs. The Illinois EPA has determined that

these costs are not reasonable as submitted (Section 57.7(c)(3) of the Act and 35 Ill.

Adm. Code 732 .606(hh)) . One of the overall goals of the financial review is to assure

that costs associated with materials, activities, and services are reasonable (35131 . Adm.

Code 732.505(c)) . Please note that additional information and/or supporting

documentation may be provided to demonstrate the costs are reasonable .

Based on the amount of work proposed in the approved site investigation plan, the

Agency has reduced the proposed personnel costs by $7,906 .00.

Attachment A

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,

Respond t

BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

WEBB & SONS, INC.,

)

Petitioner,

)

v.

)

PCB No . 05-183

ILLINOIS ENVIRONMENTAL

)

(LUST Appeal)

PROTECTION AGENCY,

)

Respondent .

)

NOTICE

Dorothy M. Gunn, Clerk

Jeffrey W . Tock

Illinois Pollution Control Board

Harrington & Tock

James R. Thompson Center

201 West Springfield Avenue

100 West Randolph Street

Suite 601

Suite 11-500

Champaign, IL 61824-1550

Chicago, IL 60601

Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue, East

P.O. Box 19274

Springfield, IL 62794-9274

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

Control Board an ADMINISTRATIVE RECORD, copies of which are herewith served upon you . .

Respectfully submitted,

Jo

m

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, 2005

---

LUST TECHNICAL REVIEW NOTES

Reviewed by: James R. Malcom, III File Heading: LPC #0290255079- Coles County

Date Reviewed February 2, 2005

Mattoon/ Webb & Sons, Inc

1201 Dewitt Avenue

Incident No 931126 & 20021577

LUST Technical File

Document(s) Reviewed :

SIPLN & Budget

- January 24, 2005

General Site Information :

IEMA date(s)

: May 3, 1993 & October 30, 2002

Size .& Product of Tanks (1) 1,000 Gallon (1) 2,000 Gasoline (1) 10,000 Gallon Diesel (1)

4,000 Gallon Diesel (1) 5,000 Gallon Kerosene (1) 1,000 Gallon Kerosene (1) 2,000 Gallon

Heating Oil

System Removed (Y/N)

: Yes

Encountered Groundwater (YIN) : No

Free Product (Y/N) : No

Current/Past Land Use: Residential

Reimbursement (Y/N/unknown) : Yes

OSFM Fac Permit # 4-028243

Division File Information (Optional) : (Arranged chronologically)

See File

Review Notes

The SIPLN received September 14, 2004 was approved . The analytical results from the phase I

site investigation indicated soil contamination in MW#1, MW#3, B-1 and B-3

. Groundwater

contamination was noted in well #3 . The Phase II investigation plan proposes 3 additional

monitoring wells and 8 soil borings. The wells and soil borings will be used to define the extent

of contamination .

PMs Recommendation/Comments :

Approve plan, modify budget

Response Due

May 24, 2005

inn

23

REIJ ASABLE

FEB 0 4 2005

REVIEWER MM

---

Hoc

E N G I N E E R I N G

February 15, 2005

James Malcom

Illinois Environmental Protection Agency

Bureau of Land

Leaking Underground Storage Tank Section

P. 0. Box 19276

Springfield, IL 62794-9276

RE: Site Investigation Plan

Justification of Personnel Costs

LPC # 0290255079 - Coles County

Mattoon I Webb &Sons,

nc.

1201 DeWitt Avenue

LUST Incident No

.: 931126

LUST Technical File

12

201 W

. Springfield Ave.. Suite 300

P.O. Box 140

Champaign, Illinois 61824-0140

BUS . (217) 352-6976

FAX (217) 356-0570

Dear Mr. Malcom :

In response to your letter dated February 8, 2005, HDC Engineering (HDC) has prepared a

breakdown and justification of the personnel hours that were denied from the Site Investigation

Budget dated January 18, 2005

. Please refer to Attachment A for justification of surveying costs

and Attachment B for a complete breakdown and justification of personnel hours

.

HDC would like to point out that the IEPA increases personnel costs every time it requires HDC

to submit additional information

. The IEPA required HDC to justify every line item of the last

Site Investigation budget as well

. Furthermore, the IEPA originally denied approval of the first

Site Investigation Plan, submitted in September 2003, stating that the number of borings was

unreasonable

. However, four of the borings included in the approved Stage 2 plan are in similar

locations on the Site as proposed in the denied plan, showing that the original plan was

reasonable in the first place

. Costs for the project would have been reduced had the original

plan been approved in September 2003 .

HDC has a highly qualified staff of environmental professionals, with many years of experience

with underground storage tanks . This recurring requirement by the IEPA for micro justification

of personnel costs is redundant and time consuming, and is viewed as an affront to HDC's

professionalism and experience

. It also has the unfortunate result of increasing the overall

costs and duration of the project

. As your office has told HDC, one of the charters of the IEPA

is to ensure the LUST fund is well spent

. However, you consistently require HDC to duplicate

effort in justifying cost when, in fact, the cost and work are already justified and reasonable

.

RELEASABLE

MAR

0 1 2005

REVIEWER MM .

---

James Malcolm

February 15, 2005

Page 2 of 2

If you have any questions I can be reached at 217

.352.6976 or kevins© hdc-eng .com.

Respectfully Submitted,

HDC Engineering

A-

1-Kevin

Saylor, PE

Environmental Division Manager

cc:

Doris Webb

file

Enclosures

13

---

Attachment A

$1,500 were deducted from the budget for surveying costs with the reasoning that a

professional survey is not required by the Agency . The requirements of Title XVI do not

specifically require a professional survey as part of a LUST incident . However, it has been

HDC's experience that professional survey's are ultimately necessary to delineate and obtain

No Further Remediation status for LUST projects .

During the course of delineation, it is necessary to identify the site's property boundaries

. The

location of these boundaries is used to identify the extents of the property and to place off site

boring locations .

The letter to request off site access to perform delineation and/or remediation on adjacent

properties is essentially a contract between the LUST owner/operator and the adjacent property

owner.

Therefore, a professional boundary survey is crucial in identifying the site's and

adjacent parcel's property limits to insure that the necessary access Is obtained and that the

necessary involved parties are protected by the off site access letter.

The accurate location of property boundaries is necessary for the use of highway authority

agreements

. These agreements require scaled maps identifying the impacted area and the

extents of the agreement .

Environmental land use controls require the legal description of the property subject to the

control

. The professional boundary survey is used for this purpose .

The Property Owner Summary required for corrective action completion also requires a legal

description. Again, the professional survey is used for this purpose

.

In general, the reporting requirements of the LUST program require the accurate presentation of

the site and adjoining properties, including utilities

; roadways, and property boundaries

. To fulfill

these requirements, a professional survey is conducted . Sources such as county plat and aerial

composite maps are not always of sufficient detail to accommodate the requirements to close a

LUST incident

. In some instances, a foot can mean the difference between a highway authority

agreement and an environmental land use control . Additional land use controls requires a

significant amount of additional consulting time and additional liability for the owner

.

Required technical reports, such as the Site Investigation Completion Report and the Corrective

Action Completion Report, require certification by a licensed Professional Engineer or

Professional Geologist The certification includes the following statement

To the best of my

knowledge

and belief this report, supporting documents and all

attachments are true, accurate and complete

.

The only accurate and complete way to

identify property boundaries is to utilize a professional

surveyor.

Because of these reasons, HDC requests that the Agency approve the $1,500 for professional

surveyor's costs

. These costs have been approved on numerous other LUST

RJul

budgets

FEB 16

and

2005

,r,r 1M A

11M hl .

billing packages .

E_w„~,~ r

-n71

14

---

Environmental Professional II (90 hours)

Well development and survey

Well purging and sampling

Miscellaneous'

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc.)

Environmental Professional III (70 hours)

Work Description

Prepare Site Safety and Health Plan

Attachment B

Pre-drill / Post-drill

(prepare soil log templates, load/unload sampling

supplies, jar samples, ship samples, etc .)

Well purging and sampling

Miscellaneous*

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc

.)

Report writing (Stage 2 and Stage 3 Site

36

Investigation Work Plans and Budgets, including

soil boring logs, analysis tabulation, and

reimbursement)

,4nPvD

a'2 APP X.

Work Description

Number of Hours

Work plan preparations (Stage 2 Site

22

Investigation Work Plan and Budget)

Sample and log soil borings

20 (one EPII for two 10 hour days) oK

Pre-drill / Post-drill

(JULIE locate, package and ship samples, etc .)

Off-site access

12

die

(Obtain property and adjacent property tax cards,

contacting and coordinating off site access,

including both IDOT and city right of ways)

15

Monitoring Well Installation

10 OIL

(Supervise subcontractor, sample and log soil,

etc.)

iNGt

&oe-D 1

1

18 (two EPII's for one 9 hour day) Olt

10 (one EPII for one 10 hour day)

e'tZ-

/4

I

1v

c+, 066

S-82zS=/33f

t 0

Number of Hours

fi .r

11-0 11

Lt'lwp(ea /

CIO

N

t: 1 v 22®

--*(ene-EPffdrbhe-1'0-h60rday)

i P c t,R&Drkl)

pa

e

~t,~c~nGp

R.~ove

~~te

01t-

& 2

t*2 >< ro

5~/+R

_ ~I 3

3 0

'0 Hl1- V0-751N2

3, 4 SD

.

i Z h(G~

v ~~7Ib2

0

9 ~ n

a

C~ ~e

---

Environmental Professional IV

(28 hours)

Work Description

Budget preparations

Report preparation and oversight

Miscellaneous*

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc.)

Project Manager

(16 hours)

Work Description

Work plan preparation

Budget preparation and review

Site Safety and Health Plan preparation and

review

Pre-drill oversight

Monitoring well drilling oversight

Report preparation and oversight

General project management

Project Engineer (28 hours)

Work Description

Work plan preparation for Stage 2

Budget preparation for Stage 2

Technical supervision for field activities

Attachment B (continued)

12--

6 A0

Number of Hours

12

2'

A,4&0,k&

n

Number

OP

of Hours

AQ

reimbursement

Stage 3 Site Investigation

request)

Work Plan and Budget,

.80" OCT-

N

Miscellaneous`

(Contact with client, IEPA, local municipality,

IDOT, subcontractors, laboratory etc .)

16

oua

---

*Miscellaneous time includes communication with the owner/operator, local municipality, IDOT,

subcontractors, and the IEPA which does not necessarily fall within a specific task . HDC has

found that many times, especially with this site, that the IEPA requires additional information

and justification for the approval of budgets, reimbursements and reports . When the IEPA

requests additional informationfjustification, additional consultant fees are incurred . HDC feels

that the costs requested in this budget are reasonable and are consistent approved funds for

several other LUST projects.

17

---

LUST TECHNICAL REVIEW NOTES

Reviewed by

: James R . Malcom, III

File Heading : LPC #0290255079- Coles County

Date Reviewed February 25, 2005

Mattoon/ Webb & Sons, Inc

1201 Dewitt Avenue

Incident No 931126 & 20021577

LUST Technical File

Documents) Reviewed

:

SIPLN & Budget --

February 16, 2005

General SiteInformation :

IEMA date(s): May 3, 1993 & October 30, 2002

Size & Product of Tanks (1) 1,000 Gallon (1) 2,000 Gasoline (1) 10,000 Gallon Diesel (1)

4,000 Gallon Diesel (1) 5,000 Gallon Kerosene (l) 1,000 Gallon Kerosene (1) 2,000 Gallon

Heating Oil

System Removed (Y/N) : Yes

Encountered Groundwater (Y/N)

: No

Free Product (Y/N): No

Current/Past Land Use: Residential

Reimbursement (Y/N/unknown)

: Yes

OSFM Fac Permit # 4-028243

MAR 0 1 2005

Division File Information (Optionall

: (Arranged chronologically)

REVIEWER MM

See File

Review Notes

The phase

II

site investigation received January 24, 2005 was approved, the plan proposed the

installation of 3 monitoring wells and 17 soil

borings to define the extent of contamination

. The

plan was approved while the budget was approved with the following modifications :

I .

$1,500.00

for surveying

. These costs are for activities in excess of those required to meet

the minimum requirements of Title XVI of the Act (Section 57

.7(c)(3) of the Act and 35

Ill. Adm. Code 732 .505(c) and 732

.606(o)).

The excessive costs submitted for surveying indicates that a professional surveyor is

being utilized which is not required by the Agency

.

2.

$17,610.00

for costs that lack supporting documentation (35 III

. Adm. Code

732.606(gg))

. A site investigation plan budget must include, but not be limited to, an

accounting of all costs associated with the development, implementation, and

completion of the site investigation plan (Section 57

.7(a)(2) of the Act)

. Since there is no

8

---

Page 2

supporting documentation of costs, the Illinois EPA cannot determine if the minimum

requirements necessary to comply with Title XVI have been exceeded (Section 57 .7(c)(3)

of the Act and 35 Ill. Adm., Code 732 .505(c) and 732.606(o)).

The Agency is requesting that the proposed personnel costs be further broken down to

provide sufficient justification for the proposed personnel cost

.

The Agency is requesting

information regarding the task performed by each person and the amount of time for each

task performed . The Agency is requesting justification for the estimated amount of time

to complete each task .

For example, the professional engineer is requesting 28 hours for P

.E. preparation and

certification of reports and project oversight . The Agency is requesting justification as to

why it takes 28 hours to perform these tasks? If 28 hours is simply a budgeted guess, why

was 28 hours proposed?

The budget amendment received February 16, 2005 contains the hourly breakdown

for thepersonnel hours previously rejected by the .Agency

.

The following personnel and work hours are being approved :

Environmental ProfessionalII (82 Hours approved, 8 hours denied as unreasonable)

$5,330.00 ok

The 4 hours for pre-drill/post drill were deducted as these cost are considered part of

sample and soil boring log hours. The 4 hours for miscellaneous task was deducted as

these tasks are being approved under Off-site access hours

Environmental Professional Dl (46 Hours approved, 24 hours denied as unreasonable)

$3,450.00 ok

The hours associated with the safety and health plan were deducted as this task was

approved under the previous budget The hours forpre-drill, post drill, well purging

and sampling, and miscellaneous were deducted as they were approved under the

Environmental Professional ll hours.

Environmental Professional IV (12 Hours approved, 16 hours denied as unreasonable)

$924.00

ok

The hours associated with report preparation & oversight and miscellaneous were

deducted as these tasks were approved under the Environmental professional II

.

All hours associated with the project manager were deducted as these hours were

approved under the environmental professional H hours . All hours for the project

engineer were deducted as these hours were approved under the environmental

professional II

. The costs for the stage III site investigation work plan and budget was

deducted as this report is not required at this time .

9

---

Page 3

The decision on deducting the professional surveyor costs still stands as no other consulting form

uses professional surveyors.

PMs Recommendation/Comments :

Approve budget with modifications

Response Due

May 24, 2005

1rm

10

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF

:

)

PROPOSED AMENDMENTS TO

)

REGULATION OF PETROLEUM

)

R 04-22 (B)

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

TESTIMONY OF DOUGLAS W

. CLAY REGARDING

THE ILLINOIS POLLUTION CONTROL BOARD'S

PROPOSED 35 ILL

. ADM

. CODE 732 .845 AND 734 .845

My name is Doug Clay . I am the manager of the Leaking Underground Storage

Tank ("LUST") Section within the Bureau of Land of the Illinois Environmental

Protection Agency ("Agency"). I have been in my current position since September of

1994. This section is primarily responsible for reviewing the technical adequacy of

plans, reports and associated budgets for the remediation of releases from underground

storage tanks regulated under 35 111

. Adm . Code, Parts 731, 732 and 734 .

Prior to assuming my current position, I was the manager of the Disposal

Alternative Unit within the Permit Section of the Bureau of Land . I have also worked in

the Permit Section in the Bureau of Water

. I have been employed at the Illinois EPA

since 1983 following the receipt of a B.S

. degree in Civil Engineering from the

RECEIVED

CLERK'S OFFICE

MAR 01 2006

Pollution

STATE OF

Control

ILLINOISBoard

---

University of Illinois . I have been a Registered Professional Engineer in Illinois since

1989.

Today I will be testifying with regard to the Illinois Pollution Control Board's

("Board's'") proposed 35 Ill . Adm . Code 732 .845 and 734 .845 published for public

comment in the Board's January 5, 2006, Opinion and Order

. My testimony will address

issues raised in the Board's January 5, 2006, Opinion and Order as well as the Hearing

Officer's February 16, 2006, Order .

In answer to the Board's question about the Agency's LUST database, the

database does not contain adequate information to determine lump sum payments for

professional consulting services . As we stated in earlier testimony, we do not believe that

lump payment amounts for professional consulting services should be determined from

future reimbursement submissions over the next few years . Collecting this data,

breaking it down in great detail, as has been proposed at previous hearings would require

significant resources by the Illinois EPA, which we simply do not have . In addition,

accepting the costs as submitted without review (i.e. no quality control) would invite

inflated amounts knowing that these will be used to set future acceptable costs. Also, this

would require that every consultant that does LUST work in the State of Illinois adopt a

complicated, confusing, and overly burdensome reimbursement accounting system for

seeking corrective action costs that has been designed and proposed by just a few

consulting firms . This type of system would undoubtedly increase the costs for

preparation of budgets and reimbursement packages, thus increasing overall corrective

costs for each site

.

2

---

The Agency has reviewed the scope of work proposed by the Board, with a few

modifications, believes it to adequately represent the work required to remediate a

leaking underground storage tank release in Illinois . We do not believe that the scope of

work needs to be part of Board rules, and do not intend to propose Agency rules

regarding this issue

. Attached as part of my testimony (Attachments I and 2) are two

spreadsheets that include the scopes of work, the title of the personnel that may perform

the work, a reasonable number of hours for the identified personnel to perform the work,

and a comment field .

To develop this attachment the Agency convened a workgroup made up of the

five LUST Section unit managers, five senior LUST Section project managers, two senior

LUST Claims Unit reviewers, and myself. This workgroup has a combined 140 years of

experience reviewing and evaluating LUST sites

. The information in Attachments 1 and

2 represent the consensus of the workgroup . We grouped some scopes of work together

for the purpose of assigning hours and, where appropriate, made comments for additional

clarification. Where the hours field next to a scope of work has been left blank the

comments field provides an explanation of why . All time is rounded up to a full hour, so

the minimum amount of time assigned to a scope of work is 1 hour . The personnel and

hours assigned to each scope of work represents what the Agency believes to be a

reasonable amount of time for the identified personnel to perform the identified work .

Also attached as part of my testimony (Attachments 3 and 4) is a table

summarizing the lump sum amounts for each of the scopes of work from Attachments I

and 2. The table provides a lump sum range for each scope of work, based on the range

of the high and low rates for each personnel title. The high and low rates are taken from

3

---

Appendix E that was just adopted by the Board . It should be emphasized that we

identified a Project Manager, whose rate ranges from $90 to $100 per hour, as performing

most work . However, it is not necessary for a Project Manger to perform much of the

work. The Agency has observed that in most cases other personnel, such as geologists,

scientists, or technicians, perform much of the work

. Because these other personnel have

lower rates, the work can be performed well within the lump sum amounts.

The Agency believes that the unit rates for professional services (half-day rates

for field work and travel rates) continue to be appropriate and should remain in Sections

732

.845 and 734 .845 in addition to the lump sum amounts

. They should continue to be

directly linked to productivity numbers

(e.g. number of borings per half-day, excavation

quantity per half-day, etc .) as in the Board's proposed rules

. It is reasonable to expect a

certain level of productivity for these activities

. As with other costs in Subpart H,

payment from the Fund may exceed the lump sums and unit rates if the owner or operator

can demonstrate unusual or extraordinary circumstances under Section 732

.860 or

734.860.

As we testified during previous hearings, Illinois is not the first state to adopt in

regulations lump sums and unit rates for remedial work, including professional services

.

Many of the lump sums and unit rates proposed in Subdocket B are comparable to lump

sums and unit rates adopted in California, Louisiana, Massachusetts, Nevada, Tennessee,

and Texas

. Regulations from these states were previously submitted to the Board and are

already a part of the record

.

4

---

ATTACHMENT 1 SCOPES OF

WORN FOR PART

732 PROFESSIONAL CONSULTING SERVICas LUMP SUMS

Personnel

Hours

Comments

Section 732 .g45(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/Abandonmem to OSFM

4. Prepare and submit LUST Fund Eligibility and Deductibility Application

5. Prepare and submit amended Notification Form

'

Tech

I

2by

.a1,

tank

2,

removal

3 & 5

contractor=performed

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

I

Not required in all cases

.

a. CorrespondCorresppond 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

4

These hours include field

work that is not covered

under the half-day rates.

c . Prepare waste manifests or tracking forms

PM

1

4. Plan aid Report Preparation

a. Prepare site health and safety plan

PM

2

5 . Resource Coordination

L

Arrange for subcontmetdrs (e.g .,

excavator, tank removal contractor, backfill, landfill)

b

. Schedule project

PM

c. Call 7.U .L .LEa and/or municipality to locate utilities

-

Task performed by tank

removal contractor. Cost

included in tank removal

lump sum .

---

Scope of Work

A3TACIIMEN r I SCOPES OF WORK FOIL 1'Alrr 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Penonnel .

Hours

Comments

2

Section 732 .M45(a)(a) Preppratbnr pnd prrbrnlaphm of 211-Aa

pr rd 4{-day reports

I

. 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 IS WS

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

L Review disposal documentation

PM

1

S . Technical Evaluation

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

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

c

. Site visit for preparation of 20 and 45 Day reports

PM

6

a not required for

preparation of 20 or 45-day

Reports b. included in hours

for preparation of 43-day

Report. c includes field

work that is not covered

under the halfday rates

.

6 . Plan and Report Preparation

a Prepare 20day Certification

_

PM

1

b

. Prepare or revise site health and safety plan

Previously prepared under

732.E45(axl) task 4 .a. No

revision necessary for

preparation and submission

of 20 and 45-day reports .

---

Sco cot Work

ATTACHMENT

1 SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP Sums

Personnel

Hours

Comments

3

c

. Prepare

1

. Provide

45-day

information

Report

pertaining to :

A

. Site Identification

B . Release Information

C

D

.

.

Early

Site InformationAction

PM

8

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

a 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 haards posed by

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

subsurface structures

E.

Mating

1

. Site map

Documentto

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

CAD Operator

4

. Analytical/screeningresultsintabularformat,includingtheresultsofsoilsamplesrequired

PM

2

---

Sco a of Work

ATTACHMENT I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP Sums

PC

onn I

H n

0

e

4

pursuant to 35 111 . Adm . Code 732.202(h) or 45 ILCS 5/57-57.17.

S

. 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 stared in the UST(s)

d

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

c. 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

Administrative

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 I 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.LLEF

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

Administrative

Asst

2

Coven all Copying and

delivering costs . Added

references to application for

payment.

9. Prepare applications for payment

.

Account Tech

8

This as added to IPCB's

proposal.

---

Scope of Work

ATEACnMRNr I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LAMP SUMS

Personnel

Hours

Comments

5

Section 732.845(x)(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 .

3

. Waste Disposal

a Review disposal documentation

PM

i

4

. Free Product Report Preparation

a Prepare

I

. Provide

Free

information

Product Removal

pertaining

Reportto

:

A

B

.

Site

Free

IdentificationProduct

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 fee product recovery system used and technical justification for the method of

recovery chosen

4. Whether my discharge will take place on- or of -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 me being taken to obtain necessary permits for any

discharge

7 . The disposition of the recovered free product

PM

---

co

ATTACHMENT I SCOPES OF WORK FOR PART 732

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Aoun

Comments

6

C . Assting Documentation

I . Site map to scale and oriented north showing :

& UST systems) 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

1

. Location of recovery points

j . Location of the treatment unit

k. Location of

discharge points

I . Property boundaries

CAD Operator

Site map already prepared

under Early Action Only

modifications required at this

point

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

free product recovered on each date

I'M

I

3 . Copies of waste manifests

Administrative

Asst

I

5 . Review and

cation of free product removal report.

LPG or LPG

I

Added to IPCB's proposal .

6 . Distribution

a.

Deliver draft free product removal report to owaerloperator for review and signature

b . Make copica of flee product removal report for distribution

c. Deliver completed report to IEPA and owner/operator

Administrative

Asst

2

Covers all copying and

delivering costs .

---

Scope of Work

ATTACHMENT

1 SCOPES OF WORK POR PART

732

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

7

Section 732

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

732202(b)(3)

1 . Site characterization/narrative

2: Charactedzaion/narrative of water encountered in UST excavation

3 . Completion of Property Owner Summary Form

4 . Recording NFR Lette r

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

"7322 ) "

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

work

All Prois ject

identified

Managementunder

Personnel Column as PM .

2 . Correspondence

a- CorrespondwithAgency

b . Correspond with and update client

2.a already included in other

line items and 2h 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 of Work

ATTACIIMENT I SCOPES OF

WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES Lump Sums

Personnel

noun

Comments

8

4

. Plan Preparation

a Prepare Site Classification Work Plan

1 . Provide information concerning:

A. Site Identification

B . Site Information

C. Site Classification

I . Method of Physical Soil Classification

PM

8

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

reference to LPG added

.

Under 4.a1 .c.7, reference to

"Class II" groundwater

changed to "Class III".

Added 4al .c.9 and 10 .

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

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

Soil Classification or investigation of migration pathways

4 . Whether monitoring wells arc proposed on-site

5 . Physical Soil Classification

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

with Plate I of the Illinois State Geological SurveyCircular 532

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

c .

usedBasis

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 detennicilog 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 welt 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

---

See a of Work

ATTACHMENT 1 SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES

LUMP SUMS

Personnel

Hours

Comments

9

k

. Steps that will

be taken to determine groundwater elevation and flow direction .

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

8

.

Groundwater

How the LPEILPG

exists

will

within

identify

200 feet

and locate

of the

all

UST

community

system

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 LP/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

10. How the LP/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

---

Sco a of Work

ATTACttMP.Kr 1 SCOPES OP WORK FOR PART 732 l'ICOFYSSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

10

9. Classification by Exposure Pathway Exclusion

a

. Disunion of due activities to

determine the full meet and concentrations of cootxmimnts

in wit andlor groundwater

exceeding the Tier 1 rmcdiation objectives

b . Discussion of the tats to be performed to determine whether or out the following

requirements

it be ma :

1 . Automation capacity of the soil will not be exceeded fm ay of the organic

coilm0W7

2. Soil amnem limit will not be exceeded for 1y ofthe organic eoets au

Classification by exposure

pathway is no

an

option rider Part

Part 732 per the

longer73

amendments just adopted by

the Board .

3 . Contaminated soils donotexhibit

my

ay

ofthereactivity characteristics

of

hansdous

warn per 35 111. Adm. Code 721.123

4. Contaminated Nib do not exhibits a PH 2.0 < or > 125

5

. CoommmMd solb which contain manic, barium, cadmium, donation, lead,

mmcay, selenium or silver (or their associated saha) do not exhibit ay of the

toxicity characteristics ofbamdous waste per 35 UL Adm Code 721 .124

c. Discussion ofhow the inhalation exposure mum will be evalvated

that

1 . An butimtiooal wool is in place that requires safety precautions for construction

worker population, and compliance with N2 below

2. Any contaminant of conemo within to (10) feet of land surface

or within tee (10)

feet of ay

marinade

pathway does not exceed Tier I

Radiation

objectives ; OR an

Agency approved engineered busier is in place

d . Discmsioo crime, the soil ingestion espouse rmoe will be evaluated m determine mat

1 . An intentional control is in place that requires safety p rations fm construction

worker populations end compliance with 92 below

2 Anycommunism! ofemome,withinben(10)feetoftandsurfeceorwithinduee(3)

feet ofny lad surface does not exceed to 1 remediation objectives

;

OR an

Agency appoved engineered barrier

la in place

a . Discussion of how the groundwater ingestion exposure route will be evaluelmd to

determine the following:

I . The comes of the release is not Round within the minimum/maimum setback

some or regulated recharge area of a potable water supply well

2 . Any wet within 2.500 feet from the source of the release S restricted iSa a local

cattleman which prohibits date wee ofgrgndwaa as a potable supply

3 . The eooceiatntim, of any cootatninent of concem in ginuodwata

within the

minimudmahnum setback sane of a potable water supply wall meets the applicable

Tiar I reeediaion objective

4 . The concentration of any

measurement

efweeern in groundwater discharging into a

surface water win

meet the applicable surface: water quality aadard per 35 Ill . Alan

Code 302

---

ATTACHMENT) SCOPES OF

WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Room

Comments

II

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 stmctures (buildings, roads, etc

.)

L Location of the proposed soil boring(s)

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

IL 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 LPO

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 elaiulficatlon work plan and budget for distribution

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

Administrative

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

l

. 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.

---

ATTACJIMENT I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LOMPSIIMS

e onnel

Hour ;

Comments

12

3 . Technical Evaluation

a

. Conduct fieldwork

b. Provide field oversight

Not required as pan of

preparing mid submitting

Site Classification

Completion Report

.

_

4 . Report Preparation

PM

8

Site map already prepared

a Prepare Site Classification Completion Report

CAD Operator

4

under Early Action . Only

I . Provide information concerning

:

modifications required at this

A. Site Identification

point

B . Site Information

C. Site Classification Summary

D. Site Classification by Methods One or Two

E. Site Evaluation

t . Physical Soil Classification

a

. Soil borings

l

. 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

:

1 . Soil boring locations

ii . UST system(s)

iii . 200-foot radius from UST systemm

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-sim 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

---

Sc a of Work

ATEACIIMENT I

SCOPES OF WORK FORPART 732 PROFESSIONAL CONSULTING SERvtcEs Lump SUMS

Personnel

Hours

Comments

13

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 (alt

., historical records)

PM

CAD Operator

4

2

Site map already prepared

under Early Action . Only

modifications required at this

point

F. Water Well Survey

PM

4

Site map already prepared

1. Results of the

survey

conducted to identify all community water supply wells within 2,500

under Early Action 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 them 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

---

Sea of Work

ATTACHMENT 1 SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

14

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

O . Migration Pathways

l

. 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 systems) 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 Early Action. Only

modifications required at this

point .

11. Class III Special Resource Groundwater

1 . DiiscussionofthestepstakentodetermineifClassIllgroundwaterexistswithin200feetof

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 systems)

L 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 EadyAction Only

modifications required at this

point .

---

Scope of Work

ATTACHMENT 1 SCOPES

OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

15

S . Classification by Exposure Pathway Exclusion

Classification by exposure

1 . Extent of contamination exceeding Tier I remediation objectives

pathway is no longer an

a Table showing the analytical results and depth of samples

option under Part 732 per the

b

. Site map showing the soil sample location points and groundwater monitoring well

amendments just adopted by

locations

the Board .

c

. Site map showing the extent of soil and/or groundwater contamination exceeding Tier 1

rcmediation objectives

d

. Cross-section of the site showing the areas of soil contamination exceeding Tier 1

rcmediaton objectives

2

. Physical soil characteristics

a Whether or

. not the concentration of any organic contaminants exceeded the attenuation

capacity of the soil

b

. Whether or not the organic contaminants exceeded the soil saturation limit

c. Whether or.not

the soils exhibited any characteristics of reactivity for hazardous waste

d . pH ofthe soils

e

. Whether or not contaminated soils exhibited any characteristics of toxicity for hazardous

waste

3, Inhalation exposure route

Demonstrate the following:

a An Agency-approved engineered bonier is in place

b

. Safety precautions for construction workers will be taken if Tier

1 remediation

objectives for construction workers are exceeded.

4 . Ingestion exposure mute .

Demonstrate the following:

a

. An Agencyapproved engineered barrier is in place •

b.

Safety precautions for construction workers will be taken if Tiff

I remediation

objectives for construction workers are exceeded

. -

5. Groundwater ingestion exposure route

Demonstrate the following:

a Source of the release is not located within the minimum or maximum setback zone or

regulated recharge area of a potable water supply well

b

. Any area within 2,500 feet from the source of the release is restricted under a local

•

ordinance which prohibits the use of groundwater as a potable supply

c . The concentration of any contaminant of concern in groundwater within the minimum or

maximum setback zone of a potable water supply well will meet the applicable Tier I

---

Sco of Work

ATTACHMENT 1 SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Person el

o n

remediation objective

d . Concentration of any contaminant of concern in groundwater discharging into a surface

water will meet the applicable surface water quality standard per 35 Ill

. Adm. Code 302

IC Assting Documentation

I . Site map to scale oriented north showing :

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

b . Excavation limits (former and existing)

c. Product and dispenser lines

d . Pumps and islands

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

f. Nearby etmetum (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

CAD Operator

4

She map already prepared

under Early Action. Only

modifications required at this

point and drawing of

geologic cross section .

3

. Laboratory certification(s)

This is provided by

laboratory along with

laboratory mull.

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

.

LPG or LPG

2

PM/Seniorstaff 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

Administrative

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 .

---

Scope of Work

ATTACHMENT 1 SCOPES OF WORK FOR PART732 PROFESSIONAL CONSULTING SERVICES

LUMP SUMS

Personnel

Hours

comments

17

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. Cot pond with and update client

2.a already included in other

line items and 2b. 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

. P

Included in 5 below

.

5. aPlan preparation tion

. 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

2. Discussion o£

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 systems) and excavation

b . Product and dispenser lines

c

. Pumps and islands

d . Underground utilities (sewer, gas, water, etb

.)

e

. Nearby structures (buildings, roads, etc .)

f

. Location of the soil borings

PM

8

Site map already preparedd

under

Direction

Eany

of

Actiongroundwater

.

flow on Site map added to

IPCB's proposal

.

---

ATTACHMENT I

SCOPES OF WORK FOR PART 732 PROFTJSIONAL CONSULTING

SERVICES LUMP SUMS

P n

Dun

Comments

19

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 fund 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 corn eted tan and bud pt to

IEPA and ownerloperator

Administrative

Asst

2

Covers all copying and

delivering costs .

---

Scope of Work

ATTACILMENr 1 SCOPES OP WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

19

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.

I, 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

2a 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:

AB

.

.

Site

Site IdentificationInformation

C. AsstingDocumentation

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

2.

momtomg

Description

Planof

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 chainof-custody form(s)

9 . OwnerOperaor 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

.)

PM

CAD Operator

8

2

Site map already prepared

under Early Action, Only

modifications required at this

point 4a l .C.10.e and d

added to IPCB's proposal

---

ATTACHMENT I SCOPES OF WORK FOR PART 732 PROFFSSIONALCONSULTINC

SanvicaS LUMP Sums

o a I

Houn

Comments

20

f

Location of groundwater monitoring wells

g. Direction of groundwater flow

It . Property boundaries

i . Radius of 200 feet from the UST system

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

- .

LPE or LPG

2

PM/Senior staff reference

deleted . Application for

eat added

.

5 . Distribution

a Deliver draft groundwater monitoring report and application for payment to ownerloperator for review

and signature

b

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

c. Deliver com .leted re . . rt and

• .

lication for

. .

cat to [EPA and owncr/ • • rator

Administrative

Asst

2

Covers all copying and

delivering costs. Application

for payment added

.

6 Prepare application for paymeo

Account

. Tech

4

This is added to IPCB's

proposal.

---

Scope of Work

ATTACHMENT

I SCOPES OF WORK FOR PART

732

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Room

Comments

21

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

2a already included in other

line items and 2.b. is not

corrective action.

3 . Technical Evaluation

Includeded 4 below.

i

in 4

4. Report Preparation

a. Prepare groundwater monitoring completion report

PM

CAD Operator

S

2

Site map already prepared

under Early Action Only

1 . Provide information concerning :

modifications required at this

A

. Site Identification

point 4.al

.C .10 .c and d

B . Site Information

added to IPCB's proposal

.

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

. Orouridwater 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.)

e. Product and, dispenser lines

d

. Pumps and islands

a Nearby structures (buildings, roads, etc

.)

f.

Location of groundwater monitoring wells

---

ATTACHMENT I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING Ssnvrces

LUMP

Sums

Personnel

Hours

Comments

22

g. Direction of groundwater flow

h . Property boundaries

i . Radius of 200 feet from the UST system

b

. Review and certification of groundwater monitoring completion report and application for payment . LPE or LPG

2

PM/Senior staff reference

deleted . Application for

a •entadded .

5. Distribution

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

ownedopemtor for review and signal=

b

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

distribution

c. Deliver cant

•

feted re . •

and

:

• •

lication for

• rot to lEPA and ownedo

•

; for

Administrative

Asst

2

Covers all copying and

delivering costs . Application

for payment added.

6 Prepare applications for payment

Account Tech

4

This is added to IPCB's

pro- .

---

Scope of Work

AnACRMENT I SCOPES OF WORN FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

23

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

732845(dXl)(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 horns which are

included under 2 below).

d. Prepare contingency scope of work for bonng(momtonn 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 toter 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 on-site investigation :

Hydraulic conductivity

Soil bulk density

Soil particle density

PM

---

See of Work

ATTACHMENT I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERvICKS LUMP SUMS

Personnel

Hours

Comments

24

Moisture content

Organic carbon content

C. Site Investigation Summary Form

r

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 propowdkxisting soil borings

g . Location of the proposed/existing monitoring wells

h . Property boundaries

Maps included under 1 A

above. Site map already

prepared under Early Action .

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 f r driling

b

. Call tULLE. and/or municipality to locate utilities

PM

2

4

. Distribution

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

b. Make copies of plan and budget for distribution

c . Deliver com leted plan and budget to IEPA and owner/operator

r Admtnistrative

Asst

i

2

Coven all copying and

delivering costs .

---

Scope of Work

ATTACRMENT I SCOPES OF

WORK FOR PART 732

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

Section 732.845(d)(1)(B)

Preparation and investigation plans for off-site contamination for sites

classified pursuant to Section 732307

Scope of work same as for

Stage 3 site investigations

under Part 734 . All scope of

work for this Section

732.845(dxl)(B) added to

IPCB's proposal

.

I . 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

e

. Prepare and describe site investigation photos

PM

CAD Operator

16

S

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 off site contamination

I . Provide information concerning :

AB .

.

Site

Site

IdentificationInformation

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 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)

c. 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

Ii The following parameters, if determined during off site investigation :

Hydraulic conductivity

Soil bulk density . .

Soil particle density

PM

8

---

ATTACIIMENT 1 SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Noun

Comments

26

'-_- '--^ Moisture content

Organic carbon content

C

. Site Investigation Summary Form

6

. Site map to ionic and oriented north showing:

a. UST systcm(s) and excavation limits

b . Product and dispenser lines

c- Pumps and islands

Maps included under 2 .a

above. Site map already

prepared under Early Action .

Only modifications required

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

at this point

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 budget

Account Tech

4

c. Review and certification of offsite investigation plan and budget

LPE/LPG

2

3 . Resource Coorduution

a. Arrange for drilling

b. Call l .ULI.E- and/or municipality to locate utilities

PM

2

4. Duhrbunon

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

Administrative

Asst

2

Covers all copying and

delivering costs

.

5

. Off-site access

Correspondence and meetings with off-site property owners

' PM

4 bours total for each off-site

property

Section 732 .84

Well so" conducted rsuant to Sections 732404

and 734A45

PM

Not

for all sites

---

Scope of Work

ATTACHMENT I

SCOPES OF WORK

FOR PART 732 PROFESSIONAL CONSULTING SERVICES

LUMP SUMS

Personnel

(fours

Comments

27

Section 732.845(d)(4)

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

.

aTechnical

. Estimate

Evaluationquantity

of "close overburden to be stockpiled (if any)

.

Included in 3

.b above

b . Prepare or finalise 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(dXS)).

S. Plan Preparation

a. Prepare or review she health and safety plan

Previously prepared under

732

.845(axl), item 4a

b. Prepare Corrective Action

. Plan

I . Provide information concerning

:

A. Site Identification

B. Site Information

C

. Proposed Methods of Remediation

D

. Soil and Groundwater Investigation Results

1

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

groundwater contamination .

2

. Analytical results and cleanup objectives in tabular format,

PM

CAD Operator

2

2

Site map already prepared

under Early Aehon. Only

modifications required at this

po int

---

Scope of Work

ATTACHMENT I SCOPES OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

28

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

E. Technical Information - Corrective Action Plan

I

. Discussion of how the corrective action plan th511 remediate the release

PM

16

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 remediarion•

5. Current and frture use of the property

6. Proposed preventive, engineering and institutional controls

7. Schedule for implementation and projected completionof the plan

8

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

systems analsyses, site maps, dc .

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

.

baResource

.

. Schedule

Arrange

Coordinationfor

projectsubcontractors

PM

16

changed

Reference

subcontracted

to

to

"subcontractors"individualactivities

c . Call LU,L .I

.E . sad/or municipality to locate idilities

7 .

baDistribution

.

.

Deliver

Make copies

draft

.

of

correctivecorrective

action

action

plan

plan

and

and

budget

budget

to

for

owner/operator

distribution

for review and signature

AdministrativeAsst

2

delivering

Covers all

costscopying

.

and

c

. Deliver completed corrective action plan and budget

to IEPA and owner/operator

t Section732.345(d)(6)(B)DeveloptmentofTier2orTier3reroediationobjectives

PM

8

a

---

Sc

r

ATTACHMENT I SCOPES

OF WORK FOR PART 732 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

29

Section 732 .845(d)(7) Environmental Land Use Controls and

Highway Authority Agreements

PM

8

8 hours total for each ELUC

& HAA . Standardized

documents being proposed in

te TACO rulemaki

---

Scope

of Work

ATTACRMKNT 1 SCOFYS OF WORK FOR PART 712 PRO17!CSIONAI, CONSIILTINO SKRvlcts LUMP UMS

Personnel

Hours

Comments

30

Section 732.845(d)(8) 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

.

I . Project Management

All Project Management

work is identified under

Personnel CoRium as PM

.

2 . Correspondence

a . Correspond with Agency

b. Correspond with and update client

2 .s

. 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 in35IAC 734345(a)?

b . Prepare and describe photos

c . Prepare or finalize field note

Included in 5 below.

---

ATTACHMENT 1 SCOPES OF WORK FOR PART 732 PROFESSIONAL

CONSULTING SERVICES LUMP SUMS

men

31

scope or work

5 . Report Preparation -

a

. Prepare Corrective Action Completion Report following items in 35 IAC 734

.345(a)

1 . Provide information conccming

:

a Site Identification

b . Site lnfornation

c. Completion Information

1

. Chronological narrative of corrective action activities

2

. Explanation of how the corrective action activities remcdiated 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

PM

CAD Operator -

32

8

Professional engineer

certification included under

5 .b

. below.

Site map already prepared

underEarlyAction . Only

modifications required at this

point.

6. Laboratory results

' .

7. Soil boring logs

8 . Monitoring well logs

9

. Laboratory certification

10

. Applicable Professional EngineerCertifcation

It

. Site maps to scale and oriented north showing

:

a

. Final sell 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. At" remediated

12. Property Owner Summary

13 . -

PhotoPfaohs docaunentine,, 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

Administrative

2

a

. Record NFR letter

Asst

7. Distribution

Administrative

3

Covers all copying,

a

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

Asst

delivering costs and

for review and signature '

recording of NFR letter .

b

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

References to applications

distribution

for payment added

.

---

Sea of Work

ATTACHMENT I SCOPES OF WORK FOR PART

732

PROFESSIONAL CONSULTING SERVICRS LUMP SUMS

Personnel

Hours

Comments

32

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

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

8 . Prepare applications for payment

Account Tech

8

This is added to IPCB's

732 .845(1) Amendment of plan due to unforeseen circumstances and its associated budget

PM

Account Tech

---

Scope of Work

ATTACHMENT 2 SCOPES OF WORK FOR PART 734 PROFESSIONAL CONSULTING Snavicas LUMP SUMS

Personnel

Hours

Comments

i

Section 734.845(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 (OSFtvl)

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 RemovaVAbandonment 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 arc 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

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

4

These hours include field

work that is not covered

under the half-day rates .

c. Prepare waste manifests or tracking forms

PM

I

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, bill, landfill)

b

. Schedule project

PM

4

o. Call LU.L.LE- and/or municipality to locate utilities

.

Task performed by tank

removal contractor . Cost

included in tank removal

lump sum

---

Scope of Work

ATTACHMENT

2 SCOPES OF WORK FOR PART 734 PROFESSIONALCONSULTING

SERVICES LUMP SUMS

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

2a

. already included in other

line items and 2.b. is not

corrective action.

3

.

aRecords

. Obtain

Gatheringand

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 (Q5 records within 2500 feet)

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

c. Site visit for preparation of 20 and 45 Day reports

PM

6

a not required for

preparation of 20 or 45-day '

Reports b. included in hours

for preparation of45day

Report, c. includes field

work that is not covered

under the half-day rates.

6. Plan and Report Preparation

a Prepare 20-day Certification

PM

I

b

. Prepare or revise site health and safety plan

Previously prepared under

734.845(axl) task 4a No

revision nr •lsary for

preparation and submission

of 20 and 45-day reports.

---

ATTACKMENT 2 SCOPES OF WORK FOR PART 734 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

}lours

Comments

3

c . Prepare 45-day Report

1 . Provideinfonmtionpe ainingto :

A . Site Identification

B. Release Information

C. Early Action

PM

8

D . Site Information

f . 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 . Assting Document

I . Site map to scale and oriented north showing

:

a. UST system(s) and excavation limits

b . Product and dispenser lines

a Pumps and islands

d, Underground utilities

(sewer, gas, water, etc.)

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

£ Soil boring(s) (if present) .

g. Monitonng 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

CAD Operator 8

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

PM

2

---

ATTACHMENT 2 SCOPES OF WORK FOR PART

734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

on

ocope w nor,

Comments

pursuant to 35 Ill. Adm

. Code 732.202(h) or 45 ILCS 5/57-57

.17 . .

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 I lS'I'(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 fonts

under 6 .c. I .B, above

(Release Information)

6. Copy of OSFM Permits or notifications

Administrative

Asst

1

6, 8 & 9 combined for a total

oft 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

I

Certification added to

IPCB's

proposal. PM/Senior

staff reference deleted.

Added references to

application for payment

.

7 . Resource Coordination

a Call LU.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

]EPA

and owner/operator

Administrative

Asst

2

Covers all' copying and

delivering costs

. Added

ieferenc s to application for

payment

9. Prepare= application for payment

Account Tech

8

Ibis is added

to IPCB's

proposal.

---

Scope of Work

ATTACHMENT 2

SCOPES OP WORK FOR PART 734 PROPESSIONAL CONSULTING SERVICES

LUMP SUMS

Personnel

Hours

Comments

5

Section 734245(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.

3 . Wage Disposal

a. Review disposal documentation

PM

I

4

. Free Product Report Preparation

a. Prepare Free Product Removal Report

PM

4

1 . Provide information pertaining to

:

A . Site Identification

B : Free Product Information

I

. Name(s) of person(s) responsible for implementing the free product rernuvnl rneaaues

2

. lstimated 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 oft 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 am being taken to obtain necessary permits for any

discharge

7

. The disposition of the recovered free product

.

---

ATTACHMENT 2 SCOPES OF WORK FOR PART

734 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

6

C . Assting Documentation

I . Site map to stale 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)

It

. Monitoring wells) and/or sumps (If

present)

IL

Locations where fret product was encountered including its estimated thickness

i, Location of recovery points

j . Location of the treatment unit

k

1 .

Locationof

Property boundariesdischarge

points

CAD Operator

1

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

freeproduet recovered on each date

PM

1

. 3 . Copies of waste manifests

Administrative

Asst

I

5 . Review and certification of free product removal report

LPE orLPG

1

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 freeproduct removal report for distribution

c

. Deliver completed report to IRA and ownedoperator

Administrative

Asst

2

Covers all copying and

delivering costs .

BMW

Section 734.845(a)(7)

Preparation and submission of reports submitted pursuant to Section

734.210(h)(3)

d . Site charaeterization/narsative

2. Cbaracteriration/natrefive of water encountered in UST excavation

3. Completion of Property Owner Summary Form

4. RecordingNFR Letter Early Action Completion Report

J~ K(3

T

PM~

"

Admin Asst

2

2

This report submitted as part

of 45-day Report All otter "

costs related to this report are

included in costs for 45-day .

Report (e.g., LPG/LPE

certification, distribution).

---

ATfAcllMxNP 2 Scones OF WORK POit

PANT 734 PttorEsSIONAL CONSUL : INC SlatYtcEs LUMP SUMS

PC onael

Hours

Comments

7

Section 734945(6x1) Preparation and submission of stage I site investigation plan

I . Project Management

All Project Management

work is identified under

Personnel Column as PM.

2. Co

ndence

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)

6. Evaluate backfilllpiping samples to Tier I 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(aX3)

PM

8

4 Plan Preparation

No preparation of plan is

a . Prepare Stage I Site Investigation Plan

required. Stage I Plan

1

.

AProvide

information

d

concerning:

consists

the

of s, certification in

A .. Site Identification

45-day Report that the

B . Site Information

Stage 1 investigation will be

I . Will owner/ope+ator seek reimbursement from the UST Fund?

conducted in accordance

2 . If yes, is budget attached?

with 35 IAC 734315 (Stage

3 . Is this an amended plan?

I site investigation

4 . Identify the material released

requirements).

5. Describe the activities that will be performed to

determine the following :

& Degree of soil contamination

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

e . 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

6 . Site map to scale and oriented north showing :

---

ATTACIIMENT 2 SCOPES

OF WORK FOR PART 734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Hours

Comments

9

~~

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/existinil monitoring wells

h. Property boundaries

-

b. Prepare or update site health and safety plan

Previously prepared under

734.845(a)(1) task 4

. 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 I investigation costs

will not exceed the cost set

forth in Subpart lL

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

e

. Prepare LPFILPG 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 W.W .E

. and/or municipality to locate utilities

PM

2

6. Distribution

a. Deliver draft plan and budget to

owner/operator far review and signature

b

. Make copies of plan and budget for distribution

c Deliver co leted an and bud

to A

and owner/

for

Stage 1 Plan submitted as

part of

45-day Report These

costs included under

45-day

Re

It costs .

---

Scope of Work

ATTACHMENT 2 SCOPES OF WORK FOR PART 734 PROFESSIONAL

. CONSULTING SERVICES LUMP SUMS

Personnel

noun

Comments

9

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

_

l . Project Management

MI 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 . Sanbom 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

e Prepare and describe site investigation photos

PM

CAD Operator

16

8

These hours cover technical

work performed (vs . report

preparation boon which are

included under 5 below) .

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

Included under 5 below.

5 . PlanPreparsion

a Prepare Stage 2 Site Investigation Plan addressing items in 35 IAC 734320(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 :

L 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

PM

8

5a133S .band5aI .Cadded

to Board's proposal

---

ATTACHMENT

2 SCOPES OF WORK FOR PART 734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Hours

Comments

10

health and the environment

.

ii

. The following parameters, if determined during Stage 2 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

e

. 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 4 .a

above . Site map already

prepared under Early Action.

only modifications required

at this point

b. Prepare budget

Account Tech

4

Q

Prepare or review site health and safety plan

Previously prepared under

734.g45(a)(1)

task 4a

d

. Review and certification of Stage 2 Site Investigation Plan, Budget, and Stage I application for

payment

LPF/LPG

2

PM/Senior staff reference

deleted. Added reference to

application for payment

6. Resource Coordination

a.

Arrange for drilling

'

b . Call J.U

.LLE

. 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

Administrative

Asst

2

Covers all copying and

delivering costs. Added

references to application for

payment

& Prepare Stage 1 applications for payment

Account Tech

This is added to IPCB's

proposal.

---

Scope of Work

ATTACHMENT 2 SCOPES OF WORK FOR PART 734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hour,

Comments

II

734245(6)(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.

1

. Records Gathering

& 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

.

2 . Technical Evaluation

a . Address items in 35 IAC 734.325(b)

b . Prepare or fnalize 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)

.

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 35IAC 734 .325(b)

I . Provide information concerning :

A. Site Identification

B . Site Information

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

2 . If yes, is budget attached?

3 . Is this an amended plan?

4. Identify the material released

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

:

a. Degree of soil contamination

b

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

Q 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

PM

8

---

ATTACHMENT

2 SCOPES OF WORK FOR PART 734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

O

Comments

12

.a .apcar YTUIR

Soil bulk density

Soil particle density

Moisture content

Organic carbon content

C. Site investigation Summary Farm

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

Account Tech

4

Maps included under 4.a

.

above

. Site map already

prepared under Early Action

.

Only modifications required

at this point

b. Prepare budget

c

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

payment .

LPFJLPO

2

4 . Resource Coordination

-

a . Arrange for drilling

b. Call J .U .L.J.E

. and/or municipality to locate utilities

PM

2

5 .

a

DistributionDeliver

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

Administrative

Asst

2

Covers all copying and

delivering costs

.

.

6.

Correspondence

Of-site access

and meetings with off-site property owners

PM

4

4 hours total for.each off site

property

t 7

. Prepare Stage 2 applications for payment

Section 734.845(b)(7)

Well

surveys condueted-pursuant to Section 734.445(b)

Section 734 .845(b)(8) Preparation and submission of site investigation completion report

Account Tech

PM

L8

4

Not required for all sites

.

1 . Project Management

All Project Management

work is identified under

Personnel Column as PM.

---

ATTACHMENT 2 SCOPES OF WORK FOR PART

734

PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Comments

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., Sunburn 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(axb) and (c)

PM

16

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(bx2)-(4) that also

show:

I . Distance of at least 1,000 fat 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 relcusc

f.

Evaluate existing and potential migration pathways and exposure

routes

g. Compile information regarding site-specific sampling activities

and methods, including :

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

2 . Sample pteseryatlon 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

1.

Prepare

Prepare

or

and

finalize

describe

field

site

notesinvestigation

photos

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

well

a Provide description of physical features that may affect contaminant

transport

5 .

a

Report

Prepare

PreparationSite

Investigation Completion Report addressing items in 35 IAC 734

.330(aXb) and (c)

PMCAD

Operator

44

under

Site nap

Early

already

Actionpre

.

pOnlyared

1 . Provide information concerning

:

modifications required at this

A Siteldentification

point Site Investigation

B . Site Information

Summary Fore added to

C. Site Investigation Results

IPCB's proposal.

I . Site Histary/Executive Summary

2

. Narrative of field activities including sampling methods

3 . Discussion of development ofremediation objectives

---

ATrACi1MENT2 SCOPES OF WORK FOR PART 734 PROFESSIONAL CONSULTING SERVICES LUMP SUMS

Personnel

Hours

Comments

14

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

o. 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

98

.

.

Well

Laboratory

completion

Reports

reportsand

10. Laboratory Certification

D . Site Investigation Summary Form

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

. .

Included in 4 and 5 .a above.

a ReviewanduAifcationofsiteinvestigationcompletionreportandStage3applicationforpayment

L1'E or 120

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

Administrative

Asst

2

Covers all copying and

delivering costs

. Reference

to application for payment

added -

7

. Prepare Stage 3 applications for payment

Account Tech

8

This is added to IPCB's

ro

1.

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 .

---

Scope of Work

ATTAC11mENT 2 SCOPES OF WORK FOR PART 734 PROFESSIONAL CONSULTING SERVICES LUMP

SUMS

Personnel

Hours

Comments

15

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 Disposed

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

c. Prepare waste manifests or tracking forms .

PM

4

4 . Technical Evaluation

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

Included in 3 .b above

b. Prepare or finalize field notes

c . Prepare and describe remediation photos

This work part of preparation

Action

and submission

Completion

of'CorrectiveReport

.

(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

734.845(a)(1)prepared

. item 4aunder

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 m define the extent of soil

and/or

groundwater contnminailon

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 snmpc locations

PM

CAD Operator

2

2

Site map already prepared

under Early Action. Only

modifications required at this

point

---

ATrACRMENC

2 SCOPES OF WORK

FOR PART 734 PROFESSIONAL CONSULTING SERVICES LUMP

SUMS

on

Comments

16

oeope or worK

b. Monitoring Well locations

c . Plumes of soil and woundwater contamination