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
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