May 5, 2009
    Mr. Richard McGill
    Illinois Pollution Control Board
    100 West Randolph Board
    Suite 11 -500
    Chicago, Illinois 60601
    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 Ill Adm. Code 742)
    Board Member:
    Johnson, T.E.
    Hearing Officer:
    McGill, R.
    Status:
    Board Order
    Dear Mr. McGill:
    Environmental Resources Management, Inc. (ERM) prepared this letter to
    comment on the subject case.
    It appears that the TACO equations J&E 1 and J&E 2 are not consistent with
    the USEPA’s equations because they do not include exposure time (ET) (
    8
    hr/24 hr for industrial-commercial worker or 24 hr/24 hr for residential
    ) in the
    denominator. Omission of this value in the industrial-commercial worker
    calculation will result in TACO Tier 2 indoor air remediation objectives that
    are lower than the USEPA worker ambient air screening values. In essence
    it allows the calculation of only residential remediation objectives.
    It is not clear if this is an oversight or intentional. If you have any
    questions, please feel free to contact me directly at 847-258-8983.
    Sincerely,
    Keith R. Fetzner, P.G.
    Senior Project Manager
    Electronic Filing - Received, Clerk's Office, May 5, 2009
    * * * * * PC # 1 * * * * *

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