hard

McGill-

RE:

Case#P

009-

09

ED

From:

“Kara

Magyar”

<KMagyarccaItd.com>

DECk

1

0

2008

To:

MCGILLR©ipcb.state.il.us

STATE

Date:

12/10/2008

4:09:55

PM

Z0IlUtr

Control

Subject:

RE:

Case #

R2009-009

Mr.

McGill,

RE:

Case

No: R2009-009

Case

Type:

Rulemaking

Media

Type:

Land

County:

Statewide

Case Name:

In

the

Matter

of:

Proposed

Amendments to

Tiered

Approach

to

Corrective

Action

Objectives

(35 III. Adm.

Code 742)

Board

Member:

Johnson,

T.E.

Hearing

Officer:

McGill,

R.

Status:

Board

Order

Our

company

has

been working

with the

IEPA

(Mr. Andrew

Frierdich)

regarding

the

proposed

amendments

to the

TACO

35 IAC

Code

742 regarding

Vapor

Intrusion.

We

are fully

aware

that

these

regulations

are under

review

and

may

undergo

some

modifications

but we

are

trying

to

get

a leg up

on

the

amendments

to better

serve

our

clients

for when

these

amendments

and their

modifications

are

passed.

A question

arose

between

our company

and another

environmental

consulting

firm

during

our evaluation

of

the IEPA

J&E

equations

and regulations

which

regarded

further

clarification

of the

soil

gas

infiltration

rate

(Qsoil).

We

wanted

to understand

more

fully the

reasoning

around

the

IEPA

assuming

the

value

of

Qsoil

being

zero

at

a distance

greater

than

5

feet.

It is

our

understanding

that the

controlling

mode

of

transport

is

by

diffusion

and not

advection

at

this distance,

but

by

doing this

are the

IEPA

regulations

stating

that

there

is no

potential

for gas

to

infiltrate

into the

building

structure

at

a

distance

greater

than

five

feet?

The

IEPA responded

to our

question

after

first recommending

that

we forward

this

question

to

your

attention

at the

Illinois

Pollution

Control

Board

(IPCB)

so

that

all

parties

can view

the question

and

the

IEPA’s

response.

Their

only

response

to

our question

was

that

Qsoil

is

considered

zero

at all

depths

when

pursuing

Remediation

Objectives

(ROs)

in

Tiers

1

and

2

and that

only when

pursuing

a

Tier

3

(742.935)

RO

does

the

5 foot

depth

come into

play.

Thank

you

for

your

time.

Sincerely,

Kara

Magyar

Kara

Magyar

Environmental

Geologist

Carnow

Conibear

Assoc.,

Ltd.

Environmental

Consulting

Services

300

W Adams

Street

Chicago,

Illinois

60606

312-762-2909