Electronic Filing: Received, Clerk's Office 7/26/2017

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IL PIT STOP, LLC, ) ) Petitioner, ) ) v. ) PCB 17-077 ) (UST Appeal) ILLINOIS ENVIRONMENTAL ) PROTECTION AGENCY, ) ) Respondent. ) NOTICE OF FILING To: Hearing Officer Carol Webb Patrick D. Shaw

Illinois Pollution Control Board Law Office of Patrick D. Shaw 1021 North Grand Avenue East 80 Bellerive Road P.O. Box 19274 Springfield, IL 62704 Springfield, Illinois 62794-9274 [email protected] [email protected]

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

Control Board the Certificate of Record on Appeal and the accompanying documents comprising the

entire record of the decision of the Illinois Environmental Protection Agency, a copy of which is

herewith served upon you.

Respectfully submitted,

Dated: July 26, 2017 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY, Scott B. Sievers Attorney Registration No. 6275924 Respondent, 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794-9276 BY: /s/Scott B. Sievers (217) 782-5544 Scott B. Sievers [email protected] Special Assistant Attorney General

Electronic Filing: Received, Clerk's Office 7/26/2017

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IL PIT STOP, LLC,

Petitioner,

v.

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

) ) ) ) ) ) ) ) ) )

PCB 17-077 (UST Appeal)

CERTIFICATE OF RECORD ON APPEAL

Pursuant to 35 Ill. Adm. Code I 05. I I 6(b) and I 05.410, the following constitutes an index

of documents comprising the record:

PAGES DOCUMENT DATE 001-082 Chase Stage 3 Site Investigation Plan and Budget 12/30/2016

083-084 Illinois EPA E-mail to Chase 04/ 13/2017

085-086 Chase E-mail to Illinois EPA 04/ 13/2017


090 Chase E-mail to Illinois EPA 04/ 14/2017

091 Chase E-mail to Jllinois EPA 04/ 13/20 t 7

092-098 Chase E-mail to lllinois EPA 04/ 14/2017


103-106 Illinois EPA LUST Technical Review Notes 04/20/2017

107-117 Illinois EPA decision letter 04/28/2017

I, ERIC KUHLMAN, certify on information and belief that the entire record of the

Respondent's decision, as defined in 35 Ill. Adm. Code I 05.41 O(b ), is hereby enclosed.

BY: Eric Kuhlman Project Manager/Environmental Protection Engineer Leaking Underground Storage Tank Section Illinois Environmental Protection Agency


.r f'cHASE

IL Pit Stop, LLC (PCB No. 17-077) R. 001

Environmental Group -.

L Waste Management • Remediation • Drilling Services

0650205017- Hamillon County IL Pi1 Stop, LLC

December 28, 2016

Illinois Environmental Protection Agency Bureau of Land LUST Unit P .0. Box 19276 Springfield, IL. 62794-9276

RE: LPC# 0650205017 - Hamilton County 11 Pit Stop 211 East Randolph JEMA # 20130569

Mr. Eric Kuhlman:

Incident # 20 I 30569 Leaking UST Technical File

EPA- DIVISION OF RECORDS MANAGEMENT RELEASABLE

MAY O 1 2017

~~~B1 DEC 3 0 2016

IEPA/BOL

Enclosed please find one original and one copy of the Stage 3 Site Investigation Plan and Budget for the above referenced site.

Should you have any questions or need additional infonnation, please contact Chase Environmental Group, Inc. at 618.533.6740.

Sincerely,

Chase Environmental Group, Inc.

Kelly Tensmeyer, LPG s~ProjectManager ·

418 South Poplar • P.O. Drawer AB • Centralia, IL 62801 • 618-533-6740 www.chaseenv.com



Stage 3 Site Investigation Plan

LPC #0650205017-Hamilton County JL Pitstop, LLC

2 Jl East Randolph McLeansboro, IL 62859

LUST Incident #20J30S69

CEG Project# Tl303020

Prepared For:

IL Pitstop, LLC PO Box 27

McLeansboro, IL 628S9

Prepared By:

Chase Enviroomcntal Group, Inc. PO Drawer AB

Centralia. Illinois 6280 I

November 2016

REC~JVED DEC 3 0 2016

IEPA/BOL



Illinois Environmental Protection Agency Bureau of Land • 1021 N. Grand Avenue e. • P.O. Box 19276 • Springfield • IUinois • 62794-9276

TMA9ency la aUlll<lll:IICJ tottqu""lllhl Inf_..." UIMlff S.etlon 4 Md nit XVI af lllt EnfflMllr'IIAI l'nltcc1lon Act (411 ILC:S 114, 1117 -17. 17). fellunl to dllc:loulllla lntom1t111oa me,,_.~ In & c1vt1,lfflll!J fll 11<11 Co ••i:ttd U0.000.00 l<WIM.....,. _ an elklllltft41 c:hl pc,,lflY ot not lo nU1NI $10.000.00 lot utll lltf °"""11 •1ct1 1M wlollllollW!IIIUle. 14tlfl.CS JU.ti, Any p- wtlo~lf 11m1M ahlMNlllll!•etc1111::M Ol'rto,aenlltloll,Gf1111 o,,ln~ tn lft)'lllld.m1t1llut."""'"'-r,po,1. ptfflll!.Otllc- ., ___ llletl,_ldorllmtlOl'IIII IMIHl$tof CO~I wllll tlle lM--· c:tea4fdony. MJ l«Olld orevllwqufflt .,..,... ••• _....,_ • .........,,.•an, ,sttta11y .. ,11Lcs 11/441111117.17). no rorm "*• !Ma "Pll"'wd ti,1h fonna 11,nag- c.ntw.

A.

B.

Leaking Underground Storage Tank Program Site Investigation Plan

Site Identification

!EMA Incident # (6- or 8- digit}: 20130569 IEPA LPC # (10-digit): 0650205017

Site Name: IL Pitstop, LLC

Site Address {not a P.O. Box): 211 East Randofph

City: McLeansboro County: Hamilton Zip Code: _6_285_9 ___ _

Leaking UST Technical Fite

Site Information

1.

2.

Will the owner or operator seek payment from the Underground Storage Tank Fund?

If yes, Is the budget attached?

@Yes O No

181 Yes 0No

C. Site Investigation

Provide the following:

RECE!VED 1. Stage of Investigation

a. Stage2 0 b. Stage 3 181 DEC 3 0 2016

2. Summa,y of Stage 1 D or 2 t8) site Investigation activities; IEPA/BOL 3. Characterization of site and surrounding area:

a. Current and projected poswemediation uses; b. Physical setting:

l. Environmental conditions; ii. Geologic, hydrogeologic, and hydrologie conditions; and iii. Geographic and topographic conditions;

4. Results of Stage 1 or 2 site investigation: a Map(s) showing locations of all borings and groundwater monitoring wells completed

to date and groundwater ffow direction; b. Map(s) showing locations of all samples collected; c. Map(s) showing extents of soil and groundwater contamination that exceeds the most

stringent Tier 1 remediation objectives; d. Cross-sed.ion(s) showing the geology and the horizontal and vertical extents or soil

and groundwater contamination that exceeds the most stringent Tier 1 remediation objectives;

e. Analytical results, chain of custody forms. and laboratory certifications;

IL532 2747 Site lnveStigation Plan LPC 619 Rev. July 2007 1 of 3



f. Table(s) comparing analytical results to the most stringent Tier 1 remediation objectives (include sample depth, date collected, and delection limits):

g. Potable water supply well survey (unless provided in previous plan): i. Map(s) to scale showing:

a} Locations of community water supply wells and other potable wells and the setback zone for each well:

b) Location and extent of regulated recharge areas and wellhead protecuon areas:

c) Extent or groundwater contamination exceeding 1he most stringent lier 1 remediation objectives; and

d) Modeled extent of groundwater contamination exceeding the most stringent Tier 1 remediation objectives (if performed as part of site investigation):

ii. Table(s) listing the setback zones for each community water supply well and other potable water supply wells;

iii. A narrative Identifying each entity contacted to identify potable water supply wells, the name and tl11e of each person contacted, and any field observations associated with any wells identified; and

iv. A certification from a Licensed Professional Engineer or Licensed Professional Geologist that the survey was conducted in accordance with the requirements and that documentation submitted includes Information obtained as a result of the survey;

h. Soil boring logs and monitoring well construction diagrams; i. Proposal for determining the following parameters:

I. Hydraulic conductivity (K); ii. Soil bulk density (Pt,): iii. Soil partide density (ps,); iv. Moisture content (w); and v. Organic carbon content {foe); and

j. Budget fonns of actual costs (documenting actual wort< pefformed during the previous stage).

S. Stage 2 or 3 sampling plan:

6.

a. Description of and justification for additional activities proposed as part of the plan:

b. Z,,r;;8P depicting locations of proposed borings and groundwater mffl:C'~ !VE c. Depth of borings/wells and construction details of s:iroposed borings and weUs; ... D

and DEC 3 O Z016

Site maps meeting the requirements of 35111. Adm. Code 734.440.

Continue onto next page.

Site lnvestigaUon Plan

2 of 3

IEPA/BOL



0. Signatures

A!l plans, budgets, and reports must be signed by the owner or operator and list the owner's or operator's full name, address, and telephone number.

UST Owner or Operator

Name: IL Pttstop, LLC

Contact RogerSwartz

Addtess: PO Box 27

City: McLeansboro

State: ..;IL;.._ __________ _

Zip Code: .;;.;62;:;;;8~5.;;;..9 ________ _

Phone: 618-924-0599

Signature: Jl.a: ~.6--::::::::' Date: fJ.-lO-i~

Consultant

Company: Chase Environmental Group, Inc.

Contaci: Marvin Johnson

Address: PO Sox AB

City: Centralia

State: IL ------------Zip Code: 62801 -----------Phone: 618-533-6740 ,L:;2~ Signature: ~--

Date: , 1, / z.r /; "1 '

I certify under penalty of law that ab activities that are the subject of this report were conducted under my supervision or were conducted under the supervision of another Licensed Professional Engineer or Licensed Professional Geologist and reviewed by me; that this report and all attachments were prepared under my supervision; that, to the best of my knowledge and belief, the work described in this report has been completed in accordance with the Environmental Protection Act (415 ILCS 5], 35111. Adm. Code 734. and generally accepted standards and practices of my profession; and that lhe infonnation presented is accurate and complete. I am aware there are significant penalties for submitting false statements or representations lo the Illinois EPtt,~ C nvE D but not limited to fines, imprisonment. or both as provided in Sections 44 and 57 .17 d t~ C \.,!1 ~_: U Environmental Protection Act [415 flCS 5144 and 57.171.

Licensed Professional Engineer or Geologist

Name: Kelly L. Tensmeyer

Company: Chase Environmental Group, Inc.

Address: PO Box AB

City: Centralia

Stale: IL ---------------Zip Code: 62801 -------------Phone: 618-533-6740

Ill. Registration No.: _19_6-0....,.0_12.;.;9_3 _____ _

license Expiration Oate: 03/31/2017 --------Signature: k~ 1~/L e:-

Oate: l t ., l-"J .,,, / P

Site Investigation Plan

3or 3

DEC 3 O 2016 L.P.E. or L.P.G. Seal



TABLE OF CONTENTS


3. Characterii.ation of site and surrounding area a. Current and projected post-remediation uses; b. Physical Setting

i. Environmental conditions; ii. Geologic, hydrogeologic, and hydrologic conditions; and iii. Geographic and topographic conditions;

4. Results of Stage I or 2 Investigation: a. Map{s) showing locations of all borings and groundwater monitoring wells completed to

date and groundwater flow direction; b. Map(s) showing locations of all samples collected; c. Map(s) showing extents of soil and groundwater contamination that exceeds the most

stringent Tier I remediation objectives; d. Cross-section showing the geology and the horizontal and vertical extents of soil and

groundwater contamination exceeding the most stringenl Tier I remediation objectives; e. Analytical results, chain of custody forms, and laboratory certifications; f. Table(s) comparing analytical results to the most stringent Tier 1 remediacion

objectives;3 g. Potable water supply well survey (unless provided in previous plan);

i. Map(s) to scale showing: a) Locations of community water supply wells and other potable wells and

the setback zone for each well b) Location and extent of regulated recharge areas and wellhead protection

areas; c) Extent of groundwater contamination exceeding the most stringent Tier I

remediation objectives; and d) Modeled extent of groundwater contamination exceeding thRi C F ~ V (ED

stringent Tier I remediation objec1ives; ......, ii. Table(s) listing the setback zones for each community water supply well ~!C 3 0 2016

other potable water supply wells; iii. A narrative identifying each entity contacted to identify potable wat<t mt,ID) I\. /8 Q L

wells, the name and title of each person contacted, and any field ob~&nn.l assodatcd with any wells identified; and

iv. A certification fonn a Licensed Professional Engineer or Licensed Professional Geologist that the survey was conducted in accordance with the requirements and the documentation submitted includes infonnation obtained as a result of the survey;

h. Soil boring logs and monitoring well construction diagrams; i. Proposal for determining the following parameters:

i. Hydraulic Conductivity (K); ii. Soil bulk density (Pt>); iii. Soil particle density (Ps); iv. Moisture content (w); and v. Organic carbon content (foe); and

j. Budget fonns of actual costs (documenting actual work performed during the previous stage).



TABLE OF CONTENTS (Continued)

5. Stage 2 or 3 sampling plan a. Description of and justification for additional activities proposed as part of the plan; b. A map depicting locations of proposed borings and groundwater monitoring wells; and c. Depth of borings/wells and construction details of proposed borings and wells; and

6. Site maps meeting the requirements of 35 Ill. Adm. Code 734.440.

Tables:

Table I : Early Action Soil Analytical Results Table 2: Sile Investigation Soil Analytical Results Table 3: Site Investigation Groundwater Analytical Results

Figures:

Figure I: Early Action Sample Locations Figure 2: Figure 3:

Site Investigation Sample Locations Groundwater Flow Map

Figure 4: Figure S:

Estimated Soil Contamination Estimated Groundwater Contamination

Appendices:

Appendix A: Appendix B: AppendixC: Appendix 0; Appendix E: Appendix F: Appendi>CG:

Boring Logs Well Completion Fonn Laboratory Reports. Chain of Custody Form & Laboratory Certification Sanders Property Access Agreement Stage 2 Site Investigation Actual Cost Summary Stage 3 Site Investigation Budget OSFM Eligibility and Deductibility Determination Letter

ii




Stage 3 Site lnvestigalion Piao IL Pitslop, LLC

McLeansboro, Illinois Incident #20130569

3. Characterization of site and surrounding area:

a. Current and projected post-remediation uses;

The subject property is currently operating as a gas station/convenience store. There are no immediate plans to develop/redevelop the property.

b. Physical Setting

i. Environmental conditions;

The quantity of gasoline released from a 2,000 gallon gasoline underground storage tank (UST) fonnerly operated at lhc ll Pitstop, LLC, 211 East Randolph, McLeansboro, Illinois facility is unknown. The release was reported to the IUinois Emergency Management Agency (IEMA} on Muy IS, 2013 and was assigned JEMA #20130569. The UST was decommissioned on June 10, 2013 in the presence of Office of the State Fire Marshall (OSFM) representative, Louis Herner. Closure samples were collected from the walls and floor of the excavation for comparison to Tier I Residential soil remediation objectives (ROs).

Laboratory analyses confinned contaminant concentrations exceeding Tier Residential Soil Component of the Groundwater Ingestion Exposure Route soil ROs at sample locations W-2, Pl-18, Pl-3A, Pl-3B, Pl-4A and Pl-48. The benzene concentration confinned at soil sample locations Pl-} 8 and PI-JA also ex.ceedcd the Tier l Outdoor Inhalation RO. Early Action sample locations are identified in Figure I.

Analytical results of soil samples collected during the July 2015 Stage I Site Investigation indicate the Tier I Residential benzene soil RO may be exceeded al the property boundary west of the north pump island and Early Action boring location Pl-4. As a result of sample dilution by the laboratory, the benzene and MTBE reporting limits (RLs) specific to soil sample BH-8A collecled at 2.5' below ground surface (bgs) at boring location BH-8 (advanced adjacent to the west property boundary) exceed the Tier I Residential soil ROs. It should be noted that analyses of soil samples Pl-4 and BH-7A did not require sample dilution and MTBE was not detected at either sample point. Therefore, based on a comparison of the MTBE concentration confinned at Early Action sample location Pl-4 to lhat con finned at Stage l Site Investigation sample locations BH-7 A and BH-8A, it is reasonable to conclude that the actual MTBE concentration at sample location SHSA does not exceed the Tier l Residential soil RO.



Stage 3 Site Investigation Plan IL Pitstop, LLC IEMA #20130569 Page2

Unfortunately, a similar comparison does not support the same conclusion in regard to the potential benzene impact to unsaturated soil at boring location BH-8.

Based on the location or the borings and monitoring wells advanced/installed during Early Action and Stage I Site Investigation activities compared to that of the fonner tankhold, product lines, dispensers and property boundaries, it was concluded that the ex.tent of groundwater contamination exceeding Class I Groundwater Standards as a result of IEMA #20130569 does not extend beyond the site property boundaries. Funherrnore, the only potential off-site impact to unsaturated soil exceeding Tier I Residential soil objectives appeared to be in the vicinity of the Stage I Site Investigation boring BH-8 advanced adjacent to the west property boundary. As a result, IL Pitslop, LLC concluded that additional on-site investigation {i.e., a Stage 2 Site Investigation) was not necessary and submitted a Stage 3 Site Investigation Plan proposing activities necessary to confinn the extent of benzene impact lo the adjoining property west of the IL Pitstop, LLC site for IEPA review/approval on October 9, 2016.

In a letter dated February 9, 2016, it appears IEPA attempted to modify the Stage 3 Site Investigation Plan by requiring a Stage 2 Site Investigation after allowing the 120 day review period to expire. Since the October 201 S Stage J Site Investigation Plan is considered rejected by operation of law (i.e., IEPAs attempt to modify the plan was made more than 120 days following its submittal), a Stage 2 Site Investigation Plan was submitted in response to the (EPA directive to complete additional on-site soil and groundwater investigation as described in its February 9, 2016 lener.

In accordance with the February 9, 2016 IEPA directive, six (6) additional soil borings were proposed be advanced in areas south of boring locations Pl-1 and BH-2, north and south of boring location BH-8, west of boring location BH-1 and between the two (2) on-site buildings. ln addition, a monitoring well was to be installed between the two (2) on-site buildings. It was IEPA's opinion that this scope of work is necessary to "define the extent of soil contamination in the northern portion of the subject property" and "the extent of groundwater contamination beneath the site". It was noted in the Stage 2 Site Investigation Plan that a UST system has been installed east of the northern building. USTs, a new pump island, product lines, electrical conduit and a leak detection system are located between the northern building and the east property boundaiy. As a result, it was anticipated that at least one (I) of the !EPA-required borings in this area would have to be eliminated to avoid damaging the existing UST system.

IEPA approved the Stage 2 Site Investigation Plan on May 20, 2016. However, IEPA modified the proposed Stage 2 Budget by reducing the Ground Penetrating Radar (GPR) Operating Technician rate to that of a Technician I as defined by Illinois Administrative Code (IAC) Section 734 Subpart H (i.e., Ma.ximum Payment Amounts). Use of GPR was proposed to locate the buried utilities and components of the operating UST system between the two (2) on-site buildings and between the store building and operating UST system in an effort to satisfy IEPA's directive to collect additional soil and groundwater samples in these areas. Although the May 20, 2016 IEPA decision approved the use of GPR, the



Stage 3 Site Investigation Plan IL Pitstop, LLC IEMA #20130569 Page)

modification to the Stage 2 Site Investigation Budget caused the actual use/benefit of the technology to be cost prohibitive. As a result, IEPA and IL Pit Stop, LLC agreed upon an a!temative location for the monitoring well south of the southernmost on-sile building and adjacent to the south property bounda,y with the understanding that doing so may require gaining access to the adjoining property and installing the well as pnrt of the Stage 3 Site Investigation.

Stage 2 Site Investigation soil borings BH-9 through BH-12 were completed on September 13, 2016. Mr. Roger Swartz, IL Pit Stop, LLC was also on-site. Mr. Swartz expressed significant concern regarding the advancement of the proposed boring between the east side of the store building and the operating UST as the underground vent lines, electrical conduit and leak detection system are located in this area. As anticipated, this boring location was eliminated from the Stage 2 Site Investigation.

It was also observed on this date that the alternative monitoring well location would allow for the on-site installation of monitoring well MW-6. However, due to the close proximity of the building to the south property boundary, the equipment necessary to collect soil cores needed to complete a Boring Log and the Stage 2 Site Investigation soil sampling and to install monitoring well MW-6 would have to travel on the adjoining property to access the alternative location. As a result, BH-13/MW-6 could not be completed on September 13, 2016.

One (I) soil sample was collected from each 5' interval as the borings progressed in accordance with the Stage 2 Site Investigation Plan. Soil samples collected above the depth at which groundwater was encountered during drilling were retained for BTEX and MTBE laboratory analyses. The soil samples were screened on-site for hydrocarbon content using a photoionization detector. The samples were contained in properly persevered sample vials and shipped to the laboratory in an iced cooler to control sample temperature. Unfortunately, the soil samples were delivered to the laboratory three (3) days later than anticipated. As a result, sample temperatures exceeded 6° Celsius upon arrival at the laboratory and the samples had to be discarded.

Research of property records at the Hamilton County Courthouse identified Harry and Debra Sanders as Owners of the adjoining property south of the IL Pit Stop, LLC site. Upon negotiating access to the adjoining property, Chase Environmental Group, Inc. (Chase) returned 10 the site on October 21, 2016 to complete soil boring BH-13 and install monitoring welt MW-6. Soil borings BH-9 thru BH-12 were also re-sampled on this date.

Monitoring well MW-6 was developed on October 24, 2016 by purging at least three (3) casing volumes of groundwater from the well. A groundwater sample was collected from monitoring well MW-6 for laboratory analyses on October 25, 2016. Well risers were also survey on this date such that relative riser and groundwater elevations could be calculated and MW-6 added as a data point in the detennination of groundwater flow direction and gradient.

Laboratory analyses of all Stage 2 Site Investigation soil and groundwater samples confinned contaminant concentrations below Tier 1 Residential soil ROs and Class



Stage 3 Site Investigation Plan IL Pitstop, LLC IEMA #20130569 Pagc4

I Groundwater Standards. Results of the Stage 2 Site Investigation confirm groundwater contamination resulting from IEMA #20130569 has not migrated beyond the IL Pit Stopt LLC property boundaries and reiterates the previous conclusion that the only potential off-site impact to unsaturated soil exceeding Tier I Residential soil objectives appears to be in the vicinity of the Stage I Site Investigation boring BH-8 advanced adjacent to the west property boundary.

Early Action and Site Investigation sample locations arc identified in Figures I and 2, respectively. Stage 2 Site Investigation Boring Logs are included in Appendix A. The MW-6 Well Completion Form is included in Appendix B. The Laboratory Reports, Chain of Custody fonn and Laboratory Certification are included in Appendix C. A copy of the Property Access Agreement negotiated with Harry and Debra Sanders is included in Appendix D.

ii. Geologic, bydrogeologic, and bydrologic conditions; and

The IL Pitstop, LLC site is located within a geologic sequence defined by Berg's "Potential for Contamination of Shallow Aquifers from Land Burial of Municipal Wastes" Map as type F. Type f is defined as "Shale or relatively impcnneable limestone within 20' of the surface; possibly overlain with till or other fine-grained materials." Laboratory analyses of a soil sample collected using a Shelby Tube has confirmed the following physical soil characteristics:

Bulk Density: I 04. 7 pcf Specific Gravity: 2.65 Moisture Content: 23.6%

Sieve size analysis results of the soil obtained from the Shelby Tube were correlated to the USDA Soil Classification System with the soil being classified as a Silt Loom.

Laboratory analyses confirm I EMA #20130569 has impacted groundwater quality in the vicinity of monitoring well MW-S and that the impact does not extend beyond the site property boundaries. A pump test was completed at groundwater monitoring well MW-3 to detennine the hydraulic conductivity at the site. The Bouwer & Rice Method was utilized to detcnnine the hydraulic conductivity lo be 9.44 x10·5 cm/sec.

Based on the analysis of soil sample BH-8A, a Stage 3 Site Investigation is necessary to better quantify the potential impact to adjoining property west of the IL Pistop, LLC site as a result oflEMA #20130569.

iii. Geographic and topographic eonditioas;

The area surrounding lhe site is a mixture of residential and commercial properties. The surface gradient at the IL Pitsop, LLC site is primarily east-southeast.



Stage 3 Site Investigation Plan lL Pitstop, LLC lEMA #20130569 PageS

4. Results of Stage l Investigation:

a. Map(s) showing locations of all borings aad groundwater monitoring wells completed to date and grouodwater flow direction;

Figure I identifies the Early Action sample locations. Figure 2 identifies the locations of all soil borings and groundwater monitoring wells completed during the Stage I and Stage 2 Site Investigations and the borings proposed in this Stage 3 Site Investigation Plan. Groundwater elevations and flow direction are identified in Figure 3.

b. Map{s) showing locations or all samples collected;

Please refer to Figures 1 and 2.

c. Map(s) showing extents of soil and groundwater contamination that exceed the most stringent Tier l remediation objedives;

The extent of soil con1amination exceeding Tier I Residential soil ROs is estimated in Figure 4 based upon cunent subsurface investigational results. The extent of groundwater contamination exceeding Class I Groundwater Standards based upon current groundwater sampling activities is estimated in Figure 5.

d. Cross--section(s) showing the geology and the horizontal and vertical extents of soil and groundwater contamination that exceeds the most stringent Tier 1 remediation objectives;

A geologic cross-section depicting the horizontal and vertical extent of soil and groundwater contamination will be provided in the Site Investigation Completion Report (SICR} upon completion of the Stage 3 Site Investigation west of the IL Pit Stop, LLC site.

e. Analytical results, chain or custody forms, and laboratory certifitations;

Laboratory reports, chain of custody r orms, and laboratory certifications specific to the analysis of soil and groundwater samples collected during the Stage 2 Site Investigation are included in Appendix C.

r. Table(s) comparing analytical results to the most stringenl Tier 1 remediation objectives;

Table I: Early Action Soil Analytical Results Table 2: Site Investigation Soil Analytical Results Table 3: Site Investigation Groundwater Analytical Results



Stage 3 Site Investigation Plan IL Pitstop, LLC IEMA #20130569 Page6

g. Potable water supply well survey (unless provided in previous plan);

i. Map(s) to scale showing:

a) Locations of community water supply wells and other potable wells and the setback zone r or esch well;

Please refer to the 45-Day Reporr.

b) Location and extent of regulated recharge areas and wellhead protection areas;

Please refer to the 45-Day Report.

c) Extent of groundwater contamination exceeding the most stringent Tier I remediation objectives; and

Please refer to Figure S.

d) Modeled extent of groundwater contamination e1ceeding the most stringent Tier 1 remediation objective,;

Contaminant transport models designed to estimate the potential migratory extent of groundwater contamination exc~ing Class I Groundwater Standards will be compleced once the full extent of the environmental impact resulting from IEMA #20130569 has been defined.

ii. Table(s) listing the setback zones for ncb comm.uity water supply well and other potable water supply wells;

Please refer to the 45·Day Report.

Iii. A narrative identifying each entity contacted to identify potable water supply wells, the name and title of each pcnon contacted, and any field observations associated with any wells identified; and

Please refer to the 45-Day Report.

iv. A certification form a Licensed Profes.donal Engineer or Licensed Professional Geologist that the survey was conducted in accordance with the requiremenls and the documentation submitted includes infonnation obtained as a result of the survey;

Please refer to the 45·Day Report.

b. Soil boring logs and monitoring weU construction diagrams;

Soil boring logs relative to lhe Stage 2 Site Investigation borings are included in Appendix A. The Well Completion Report documenting the construction of monitoring well MW-6 is included in Appendix B.



Stage l Site Investigation Plan IL Pitstop, LLC IEMA #20130569 Page7

i. Proposal for delcnnining the following parameters:

i. Hydraulic Conductivity (K);

A pump test was completed on July 31, 20 I 5 to detenninc the hydraulic conductivity at the site. The hydraulic conductivity was calculated using the Bouwer & Rice Method with a result of9.44 x Io·) cm/sec.

ii. Soil bulk density (Pb);

A soil bulk density of 104.7 pcf or 1.68 g/cm3 was detcnnined by laboratory analysis of the soil sample (ST -1) collected using a Shelby Tube.

iii. Soil particle density (p,,);

Physical analysis as confirmed a soil particle density of2.65.

iv. Moisture content (w); and

The moisture content of the ST-I soil sampte was 23.6%.

v. Organic carbon content (foe); and

Laboratory analysis of the BH-SB soil sample has detennincd a fractional organic carbon content of 0.56% or 0.0056 rJg.

j. Budget forms of actual costs (documenting actual work performed during the previous s1age).

A summary of the costs incurred to complete the Stage 2 Site Investigation are included in Appendix E.

S. Scage 3 sampling plan

a. Deseription or and justification for additional activities proposed as part of the plan;

Laboratory analyses indicate Tier I Residential soil ROs are exceeded at Site Investigation soil boring locations BH· 7 and BH-8. In addition, Class ( Groundwater Standards are exceeded at monitoring well location MW-S.

As part of a Stage 3 Site Investigation, one (I) soil boring will be advanced on adjoining property adjacent to the IL Pit Stop, LLC west property boundary in an cff ort to define the extent of soil contamination west of boring location BH-8.

Based on the soil conditions encountered during Early Action and the Stage I & 2 Site Investigations, it is anticipated that the proposed Stage 3 soil boring will not be advanced beyond i0' below ground surface (bgs). One ( I) soil sample will be collected from each unsaturated 5' interval as the proposed borings are advanced. The soil samples will be shipped to a NELAP accredited laboratory for BTEX and MTBE analyses.



Stage 3 Sile Investigation Plan IL Pitstop, LLC IEMA #20130S69 Page 8

Based on the results of the Stage I & 2 Site Investigations, the proposed Stage 3 Site Investigation does not include additional groundwater investigation activities.

Refer to figure 2 for the proposed location of the Stage 3 Site Investigation soil boring. The estimated costs to complete the proposed Stage 3 Site Investigation are summarized in Appendix F. A copy of the IL Pitstop, LLC OSFM Eligibility and Deductibility Determination Letter is included in Appendill G.

b. A map depicting locations of proposed borings and groundwater monitoring wells; and

Refer to Figure 2 for the location of the proposed Stage 3 Site Investigation soil borings.

~- Depth of borings/wells and construction details of proposed borings and wells; and

Soil cores will be collected at the proposed soil boring locations utilizing direct push technology and I ½" X S' continuous sampling tubes or equivalent drilling equipment. The boring will be geologically logged on the IEPA 's standardized boring log or a similar format which includes all information required on the JEPA 's standardized log. Detailed field description!.t'observations of the soils encountered during drilling will be documented on the boring log. Soil constituents, consistency, color, moisture, and any odors will be noted. Sand and/or gravel lenses/scams will be recorded if documented at one inch or more in thickness.

6. Slee maps meedng tbe requirements or 35 l1L Adm. Code 734.440.

Figure I: Figure 2: Figure 3: Figure 4: Figure S:

Early Action Sample Locations Site Investigation Boring & Well Locations Groundwater Flow Direction Estimated Soil Contamination Plume Estimated Groundwater Contamination Plume



IL Pi!SIOJI, LLC M,Lcaniboro, 11. IEMA #20130569

TABLE 1 Early Action Excavation Clo.sure Soil Analytical Summary

=ihs---' .. -"'-

Loc•lion Depth Date Benzene Ethytbeoieae Toluene

Tier I Residential Objectives - - 0.03 13 12

W•I T 6/11/13 <0.0009 <0.0044 <0.0044 W-2 T 6/11/13 <0.0801 <0.401 <0.401 W-3 7' 6/11/13 <0.027S <0.137 <0.137 W-4 1' 6/11/13 0.0065 <0.0047 <0.0047 F•I 10' 6/11/13 <0.0206 <0.103 <0.103 F-2 10' 6/11/13 <0.0206 <0.103 <0.103

Pl-IA 3' 6/13/15 0.003 <0.0046 <0.0046 Pl-1B 1' 6/13115 6,91 33.8 <11.6 Pl-2A 3' 6/13/15 0.0034 <0.0047 <0.0047 Pl-28 7' 6113/1S 0.0106 <0.0044 <0.0044 Pl•JA 3' 6113/IS 2.76 33.9 <9.7 Pl-38 7' 6113/IS 0.128 0.195 <0.107 Pl-4A 3' 6/13/15 0.303 <0.106 <0.106 Pl-4B 7' 611311S 0.788 0.881 0.209

'shad.i!!g '!!!!I !)old. Eireeds Tiu I Rcsille11ti1l ObJccllv~c ____ ·_-_::]__,

Xylene, MTBE

5.6" O.J2 <0.0044 <0.0017 <0.401 <0.160 <0.137 <0.055 0.0127 <0.0019 <0.103 <0.0412 <0.103 <0.0412 <0.0046 0.0695

146 <4.63 <0.0047 0.0334 <0.0044 0.013

14.l <3.88 <0.107 <0.0424

0 <0.0424 2.55 <0.0481



IL Pitstop, lLC M-:l.e:lnsboiv, IL IEMA #2.0l.l0569

TABLE2 Site Investigation Soil Analytical Summary

mlltl1ff!IOl1edi,,w,/ka

Loca1ion Depth Date Benzene Ethylbenzene

Tiu I Residential Objectives - - 0.03 13

BH-IA 2.5' 112211S 0.0038 ND BH-1B 7.S' 7/22/IS 0.0048 0.001 BH-2A 2.S' 7/22115 0.0011 ND BH-28 6.0' 7/22/1S ND ND BH-3A 2.5' 7/22/15 0.0013 NO 8H-4A 2.5' 7/22/15 ND ND BH-SA 2.S' 7/22/15 ND ND BH-58 6.0' 7/22/15 ND ND BH-6A 2 . .S' 7122/1.S 0.0023 ND BH-6B 6.0' 7/22/15 0.0008 ND BH-7A 2.5' 7/22115 0.103 0.079 BH.SA 2.5' 7/22/15 <0.189 <0.947 BH-9A 2.5' 10/21/16 0.0012 <0.0052 BH-98 T 10/21/16 <0.0008 <0.004 BH-10 3' 10/21/ 16 <0.0009 <0.0043

BH-1 IA 3' 10/21/16 <0.0008 <0.0038 BH·llB 5.5' 10/2)/16 <0.0007 <0.0037 BH-12 3' 10/ZJ/16 <0.0009 <0.0043 BH-13 3' 10/21/16 <0.001 I <0.0056

ND. NOi 01.'tc:ded ot Reporting Limit Below Tier I Residential Objective :s~dlnc a;!f &id: ~cetd!_Tler 1. f!~ldm!!!I 9bJ!fflV..!,_,:J CW • Construction Worker lnholorion Soil Objottivc pH• 6.7811 BH-l!A Foe:· 0.56 WI% u BH-SB

Tolutnct

12 ND

0.0041 0.0013

ND 0.0024

ND ND

0.0019 0.0012

ND 0.068

<0.947 <0.0052 <0.004 <0.0043 <0.0038 <0.0037 <0.0043 <0.0056

Xylenes MTBE

5.6'· 0.32 0.001.S ND 0.0058 ND 0.0013 0.0025

NO 0.0006 0.0014 0.0024

ND ND ND ND

0.001 ND 0.0059 0.0086 0.0013 0.0147 0.)83 ND 0.38 <0.379

<0.0052 <0.0021 <0.004 <0.0016

<0.0043 <0.0017 <0.0038 <0.001S <0.0037 <0.0015 <0.0043 <0.0017 <0.0056 <0.0022



IL Pitstop, LLC McLeansboro, IL IEMA #20130569

TABLE3 Site Investigation Groundwater Analytical Summary

=Its reported in mg/I.

Location Date Benzene Ethyl benzene Toluene Xylenes

Class 1 Slaodards - 0.005 0.7 1.0 10.0 MW-I 7/27/IS NO ND ND ND MW-2 7/27/15 NO ND ND ND MW-3 7/27/15 NO ND ND ND MW-4 7/27/lS ND ND ND ND MW-5 7/27/15 l.40 0.721 0.039 3.0700 MW-6 10/2S/16 ND ND ND ND

fsbadlng a·.;d·B;.d-:-E~c~ass 1 Groundwater Standard J ~-+-· ... -- -- - -

MTBE

0.07 NO

0.0032 0.0010 0.003 0.103 0.0048


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APPENDIX A Boring Logs

IL Pit Stop, LLC (PCB No. 17-077) R. 024 Electronic Filing: Received, Clerk's Office 7/26/2017


, ... ~ CHASE ENVIRONMENTAL GROUP, tNC.

~ Dn/lucA1kt,t,Jl,JAcGMC-.a.,n Soil Boring Log Paae 1 of 1 ~ ~IISo..ll>Pc,plar,C'allnli,,.n?inois 628ill

Prol@tt: Pit Stol> Borlna location: BH-9 OateDrined: 9/13/2016 Samollna Method: 2•xs•uners Date Com)lleted: 9/13/2015 Surface Elevation: NA Drillln11. Metlu:ld: Direct Push Total Oeoth l~I: 8 Drilling Company: E.lrth Services Geologist: Duane Doty ...

C g GI "' § s. ~ .g - .. 8 • § .t: Q. .D .g; e Geoloaic Description Q. ! E ~ '° ~ i 0 QI ..

j i:: Ill: 0 ... 0.0' - 1.0': Concrete and a-ushed stone

1

1.0' • 2.0': Brown & gray mottled silty clay 2

BK-9A 0 70% 2.0'-6.0': Blad( silty clay 3

4

s

5

100" 6.0' • 8.0': Brown sandy silty day

7 BH-98 0 Grwndwater at 7.5'

8 Refusal at 8' • End of Borfna



·---- CHAS£ £NvtROr-'!'tE.'(fAl. GROUP, INC.

~ bnllJ.rw.A~Acw,,C---. Soil Boring Log Page l or 1

411 Saud, P,,s,1.-. ~ W-... 62801

Proje<:t: Pit StOD Boring location: BK-10

Date Drilled: 9/13/2016 Sanu>limt Method: 2" • s· Uners

Date Comlll2ted: 9/13/2016 Surface elevation: NA

OriUln11 Method: OirectPush Total Depth (ft) : 8

Drillins Company: Earth services Geoloaist: Duane Doty

£ ~ I ?" C

~1 :, .2 8 :0

., 1i .c i § .S: > Geologic Descrfptlon a 8 E .,

"' z 1 0 ., 0

0 a: Cl: u.. m

0.0' • 1.0': Concrete and cru1hed stone

1 1.0' - 2.0': Brown & gray mottled silty clay

2

809' 2.0'·5.5': Slack silty day

3 8H-10 0

4

5 Groundwater at 5.0'

6 5.s'-8.0': Btown sandy, silty day

1001' 7

8 0 Refusal at 8' • End of Boring



·-----CHASE ENVIRONMENTAL CROUP, INC. ~- 1'tillUlfl.A it,n,,,,&!Affl-.C...,cur, Soil Boring Log Page 1 of 1 1-.t • 11 s.i..h Pvpw, C""1nlill. minob 62801

Prolect: Pit Stoo Boring Location: 6ti-11 Date Drilled: 9/13/2016 5ampling Method: 2• 1 S'Uners Date Completed: 9/13/2016 Surface Elevation: NA Drllllng Method: OlrectPum Total Depth (ftl: 8 DrlRlng Company: Earth Services Geologist: OuaneDoty

g t.i c e ~

C

8 . 0 Q. "' ';

s:. ~ ti "' Geologic; Description I E E J \0 e "' :, 0 t ... VI Z .£! ii: a:: :1. ID

0.0' • 0.5': Crushed stone 1 0.5'·6.0': Brown silty day

2

3 BH•llA 0 95'6

4

s

6 BH·118 0

Groundwater at 6'

80" 6.0' • 8.0': Brown sandy sHty day

7

8 ftefual at a·. Emf or Borfna



r~ (.'llASF. ENVIRO~ENTALGROUP', INC. ----l>ti/aJw.t /t"""1i,/Ado,, C'_..ctan Soil Boring Log Page 1 of l

~ ~•• SouillPOl)lw. CCllll'llil. lllinois 6il0 1

Proled: Pit Stoo Sarina location: Bti-12

Date Drilled: 9/13/2016 Sampl!ng Method: 2• x 5' Uners

Date Completed: 9/13/2016 Surface Elavation: NA

Drilling Method: Direct Push Total Oepth (ft): 9

o,mrna Company: Earth SeMces Geologist: Duane Doty

g JI ..; c I t ~ :,

Q..0 8 lo § Jr: ~ ~ .s "' Geologic Description

Q. 3: 0 ~ u .,. z Cl "' .2 C ii a:: a:

0.0'. 1.0': Crushed stone

l 1.0' • 9.0': 8rown silty clay

2

BH-12 0 80

3

4

5 Groundwater at 5.D'

6

7

8 0 100

9 Refusal at 9' • End of Boring



ceg CHAS£ ENVIRONMENTAL GROUP, INC. Drlllli,if & ~AeflM C _ _... Soil Boring Log ~ 1 of 1 "' Soda Poplar. c......i;.. mlnols 62101

Prolect: Pit Stop Borlna location: BH·l3 Date Drilled; 10/21/2016 Sampling Method: rxs·uners Dale ComDleted: 10/21/2016 Surface Elev;ition: NA Orlllirut Method; OlrectPu,h Total Depth 1ft): 10 OrUllng Company: Eimh Services Geologist: Duane Doty ..

C g 1.8 s . 1 ~ .!? s; I j Geologic Desctlption 1i e e ~l,D .. "' 0 ¥ ~ VI Z .2 ii:: a: :f.

CD

0.0' • 0.5': Dark brown top soil 1 0.5'-6.5': Brown silty clay

2

3 SH-13 0 BO

4

s Groundwater at 5.0'

6 80

7 0

65'•7.0': Weathered sandstone. Auger reruul at 7'. End of Boring



APPENDIXB Well Completion Fonn


It. $32-2274

Illinois Environmental Protection Agen<:y

Incident No.: ...,2:i.i0c.:;1""'30,.,.56:::,,:9x.-______ _ Site Name: IL Pi1stop. LLC

Drilling Contractor: Earth Services Driller: J Blair Drilling Method: _H ___ S'"""A _______ _

Annular Space Details

Type of Surface Seal: _c .. o __ n __ cr __ e=te ________ _ Type of Annular Sealant: .,;;;Be=nt:;:.o_nit=e ........ ___ _ Type of Bentonite Seal (Granular, Pellet): __ _ Medium Chip

Type of Sand Pack: Industrial Quartz

Well Construction Materials u u

]g_ Q. Q.

~ ~ ~~ ie ~ t1 ~ u ·c:; .. ·-c·u u u ·-... > 8. .I: u !! a. - Q. en en ~fl) 0 !;I)

Riser coo piing joint Threaded Riser pipe above w.t. Sch40 Riser Pipe below w.t Sdl40 Scn:cn Sch40 Couplingjoinl screen to riser Thll!llded

Protective casing Iron Flush Mount

Measurements to .Ot ft (where applicable)

Riser Pipe Length 3.53

Screen Length 5.00

Screen Slot Size 0.01

Protective casing length o.oo Depth to water 2.26

Elevation of water 92.71

Free Product rhickncss 0.00

Gallons removed (develop) 4.50

Gallons n:moved (purge) Othet

Completed by: _D __ . ..;;Oo~ty'----------

u>C 500 Rev Jur,e 2004


LUST Well Completion Report

Well No.: ... M ... W..:.:6..,.__ _______ _ Date Drilled Start: ....;1.;;.;0/..;;.21.;.;./1.;.;;6 ____ _ Date Completed: ___ 1 __ 012 ___ 11....,1sa...-___ _

Geologist: _.o ......... Oo~~--------Drilling Fluids (Type): _No_ne ____ _

Elevations - .01 ft. __ Top of Protective Casing

~ Top of Riser Pipe ~ Growid Surface __ Top of Annular sealant __ Casing Stickup

94.37 TopofScal

...!:fill Tocal Seal Interval

B.:!!,. TopofSand

.!JM. Top ofScn:cn

_!QQ_ Total Screen Interval

.!Mi. Bottom of Screen 8S.87 Bottom of Borehole



APPENDIXC Laboratory Reports, Chain of Custody Fonn & Laboratory Certification


November O I, 2016

Marvin Johnson Chase Environmental Group P.O. Drawer AB

Centralia, IL 6280 I TEL: (618) 533-6740 FAX: (618) 533-6741

RE: McLeansboro Pit Stop Tl303020

Dear Marvin Johnson:


http://www.teklabinc.com/

WorkOrdcr: 16101589

TEKLAB, INC received 8 samples on I 0/26/2016 4:52:00 PM for the analysis presented in the following report.

Samples are analyzed on an as received basis unless otherwise requested and documentt:d . The sample results contained in this repon relate only to the requested nnalytes of interest as directed on the chain of custody. NELAP accredited fields of testing are indicated by the letters NELAP under the Certification column. Unless otherwise documented within this report, Teklab Inc. analyzes samples utilizing the most current methods in compliance with 40CFR. All tests arc perfonned in the CoJlinsville, [L laboratory unless otherwise noted in the Cose Narrative.

AJI quality control criteria applicable to the test methods employed for this project hnve been satisfactorily met and are in accordance with NELAP except where noted. The following report shall not be reproduced, except in full, without the written approval ofTcklab, Inc.

If you have any questions regarding these tests results, please feel free to call,

Sincerely,

Marvin L. Darling

Project Manager (618)344-1004 ex 41

[email protected]

Pagt1J ofJ3


Cllent: Chase Environmental Group

Client Project: McLeansboro Pit Stop T1303020

This nponlni: package lndudcs tht foltowlag:

Cover Letter

Report Contents

Oelinillons

Case Nanatlve

Laboratofy R8$Ults

Recelvlng Chee!< Ust

Chain of Custody


Report Contents

2

3

4

5

13

Appended

htto;//www.teldabjnc.com/

Work Order: 16101589

Report Date: 01-Nov-16

PageZofJ3


Client: Chase Environmental Group

Cllent Project: McLeansboro Pit Stop Tl30302O

Abbr Definition

Definitions


httn;i /www.teklablnc.com/


Report Date: Ol·Nov-16

CCV Continuing calibration veriricatlon Is a check of a standard to delannlne the state of calibration of an Instrument between recallbtelion.

OF Dilution factor Is lhe dNutkm perlonnad durinii analysis only and does not take Into account any dilu11ons mad& dwtng sample pteparalion. n,e repotted rMult is final and Includes all dilutions factors.

DNI Old not Ignite

OUP Laboratory duplicate Is an aliquot of a sample taken from Iha ume ccntainer under laboratory conditions f-Or Independent P'0(:8$slng and analysl$ Independently or the original aliquot.

ICV lnl1J1I caUbratlon verillcatlon is a checl( of a standard to detannlne Iha s.tale of calibration of an lnsltument before ft&mpfe analysis Is Initiated.

1DPH IL Dept of Public Heallh

LCS Laboratory control sample, spilled with verified known amounls of analytes, is analyzed exadly Ute a sample 10 establish lntta-leboratory or analyst specific precision and bias or 10 assess the peiformence of ell or a portion of the measurement system. The a0C@lable raccver, range Is in the QC Package (provided upon request}.

LCSO laboratory control sample duplicate Is a replicate laboratory control sample that Is pnipat8d end analyzed In order lo determine the preciSlon or lhe approved test mettlod. The acceptable reawe,y range Is listed In Iha ac Packaoe (prowfed upon request).

M6LK Method blank is a sample of a matri~ slmil.ir to Iha hatch or associated sample (when avallabte) lhat Is free from the analyles of Interest and Is processed slmullaneously l'lilh and undet the same conditions as sample$ throvgh aQ steps of lhe analyllcal procedures, end In which no !argot analytaa or inlerfaranees should present at eoncenlra1ions lhal impact Iha analytical n1sulls for sample analyses.

MDL Method deleellon limit means the minimum concenuatlon of a substance Chat can be m1tasure<1 and repoited v.ith 99% conlidanee that Iha analyte cancentrallon Is greater than tero.

MS Ma1rtx spl>c& Is an aliquot or matrlJC fortified (spiked) with known quantities or specific analytes that is subjected to lhe entire analytlcal procedures In older 10 determine the effect or lhe matrb on an approved test mel!lod's recover, system. The acceptable recovery range Is listed in the QC Paekage (provided upon request).

MSD Matrix spike duplicate means a ntplrcata matrix spike 1h11 Is prepared and analyzed In Older to detennlne lhe ptecision or the epproved test method. The acceplable recovery range Is listed In the QC Packega (provided upon request).

MN MoleQJlarwelght

NO Not Detected Ill the Repcrting Umil

NELAP NELAP AceNtdlted

POL Praclfcal q11antllallon Umlt maans the lowest leV&I that can be renably achieved ....ilhln specified ~mils or p,ec:isiot'l and a<:euracy during roulloe labotatory (>pel'atlon conditions. The lkCOplable recoveiy range Is Usted In the QC Pack al}& {provided upon request).

RL The reporting limit the lowest level that the data is displayed In the final report The rel)Oftlng limit may vary acamfing to customer requw o, sample dilullon. 1lle repOl'tlng llmlt may not be less than the MOL.

RPO Relallve percent dlffetet1ca ls a calaJlated dltrerence between two recoveries (le. MSIMSO). Th& acceptable recovety llmll Is fisted In the QC Package (provided upcn request).

SPK l1le spike Is a known mess of target analyte added to a blank sample or sub-sample; used to determine recovery deficlenc:y or '°' other quality COl\llol purposes.

SI.In' Surrogates are compounds which are sim~a, to Ille ana1y1es or Interest In chemical composlll01'1 and behavior 111 lhe analylicat proc9$$, but which ere not normaWy found In environmental samples.

TIC Tentatively iden!lfied compound: Analytes tentatively identlfl8d In Ille 11mple by using II library searth. Only results not In the calibration standard wtll be repcl1ed as tentatively identified compounds. Results fot tentaUvely Identified compcunds that are not l)fesenl in the calibration standald, but are assigned a specific chemlcel name baaed upon t11e library search, are calculated using total peak areas from reainstnded Ion chromatog111ma and a rasponse factor of one. The nean1St rmemaJ Standard is used (Of tne calculation. The results Of any TICs ~t be considered 8$llmaled, and are flagged .,.,;1n a T. tr the estimated result Is above the calibnlllon range It Is nagged "ET"

TNTC Too numetOUS IO COU111 ( > 200 CFU )

#. Unknown hydroc:aJbon

E • Value above quanlllation range

I • Associated lnlarnal standard was outside method crl(erla

ND • Not Detected at the Reporting Llmll

S. Spika Re0CM1ry outside recover, limits

X • Value e~eds Maximum Contaminant level

Quallncrs B • Analyte d&teeled in assoeiated Method Blank

H • Holding limes exceeded

M • Manual Integration used to determine area response

R • RPO outside accepted l'&CO\lery fimit.,

T • TIC(Tentatively ldentifted ccmpcund)

P8gtJ3ofl3




Client Projctt: McLeansboro Pit Stop T1303O2O

Cooler Receipt Temp: 2.82 °C

Case Narrative

Locations and Accreditations

Colllnsvfllc Springfield Kon$asClry

Addtest 544S Hor,ahoc Lllkc Road 3920 Pin1ail Dr M21 Nie1111U1 Ro:id

Coliinsvittc. IL 62234• 7425 Springfield. lL 62711-9415 Lc:na:i, KS 66214

Phone (618) 344-1004 (217)698-1004 1913) 541-1998

Fu (618) 344-1005 (217) 698-1005 (913) 341-1998

http; 11www.teklablnc.com L


Rtpor1 Date: Ol·Nov-16

Colllns,illc Afr

5445 Horseshl:lc Lake Ro.:id

Collinsvllle. IL 62234• 7425

(618) 344.1004

(618) J44, IOOS

Email jhriley@td:ltbinc.com [email protected]:om Ryoungs1roen@1cklllbi111:.com EHurloy@1ckl~binc.com

Slate Dept Cu1# NELAP £xp Dair Lab

lllinoiJ IEl'A 100226 NELAP 1/3112017 Collinsville

Kan14S KDHE £·10374 Nl!LAP 4/30/2017 Collbuville

Louiswia LDEQ 166493 NELAP 6130/l017 Collinsville

1.out,iua LDEQ 166518 NELAP 6/30/2017 Collinwitle

T~ TCEQ TI04704Sl5·12·1 NEL/J' 7/ll/2017 Collinsvinc

Arbnsa.s ADl:Q 88-0966 3/14/l017 Collinsville

lllinols IDrH 17584 5131/2017 Collinsville

Kcn!UCty KOEP 98006 121)112016 Collinsville

KcnlUCky UST 007J 1131/lOl 7 Collinsville

Missouri MDNR 00910 5/3112017 Collinsviltc

Missowi MDNR 930 1/31/2017 Collinsville

Olclalwma ODEQ 9978 8/3lll017 Collinsville

Page4ofJ3



Laboratory Results

Client: Olase Environmental Group

CUcnt Project: McLeansboro Pit Stop T1303020

Lab ID: 16101589-001

Matrix: SOLID

Analyses Certification EPA SW846 3550C, 5035A, ASTM D2974

RL Qual

Percent Moisture 0.1

SW-846 5035, 82608, VOLATILE ORGANIC COMPOUNDS BY GCIMS Benzene NELAP 1.0 Elhy1benzene NELAP 5.2 Melllyl te/1-butyl ether Toluene Xytenes. Total

Surr. 1.2-0lchlosoelhanM4 Surr: 4-Bromotlvorobenzene Surr: Dibromolluoromethane Sun: Toluene-di

NELAP NELAP NELAP

2.1 5.2 5.2

72.2·131 82.1-116 77.7-120

88-116

http;/ f www,teldab(nc;,comt


Report Date: Ol·Nov•16 Client Sampll? ID: BH-9A 2.5 ft

CoJJecllon Date: 10/21/2016 9:40

Result Units OF Date Analyz~ Batch

25.8 1012812016 14:56 R225204

1.2 µg/Kg-dry 10/2812016 5:19 123910 ND pg/Kg-dry 10/2812016 5:19 123910 ND Jjgll(g-<lry 10/2812016 5:19 123910 ND µgll(g-<lry 10/2812016 5:19 123910 NO 11gll(g.<fry 10/2812016 S:19 123910

110.8 %REC 10128/2016 5:19 123910 115.5 %REC 10/2812016 5:19 123910 10&.1 %~EC 10/28120 \6 5:19 123910 111.9 %REC 10/28/2016 5:19 123910

PageSoFJ.3


CUcnt: Chase Environmental Group


Lab ID: 16101589-002

M1cr1J: SOUD

Analyses Certlflcotfon

EPA SW846 3550C, 5035A, ASTM D2974 Percent Moisture


Laboratory Results http; 11www.teklabjnc,com l


Report Date: 01-Nov-16

Client Sample ID: BH·9B 7 ft

Co11ecllon Date: 10/21/2016 9:45

Rt.. Qual Result Units OF Date Analyzed 84tcb

0.1 15.0 % 1012812016 14:57 R225204

SW•846 5035, 82608, VOLATILE ORGANIC COMPOUNDS BY GCJMS Benzene NELAP 0.8 ND µg/Kg-dty 10/2812016 5:45 123910

Elhylbeniene Nl:LAP 4.0 ND i,g/Kg-dly 10/2812018 S:45 123910

Methyl ter1·bu1yl ether NELAP 1.6 ND i,g/Kg-dry 10/2812016 5:45 123910

Tol~ne NELAP 4.0 ND pg/Kg.dry 10/2812018 5:45 123910

Xy!enes. Total N!:LAP '4.0 ND 1,tg/Kg-<fry 10128120Hi 5:45 123910

Sun: 1,2.Dlc:hlofoelharie-<M 72.2-131 108.S %REC 10/2812018 5:45 123910

Surr. 4-Sromoftuorabenzere 8:U-116 93.9 %REC 10/28/2016 5:45 123910

Surr. Olbtcrnofluorometllane 77.7-120 101.7 %REC 10/2812016 5:4'5 123910

SUrr. Toluene-dB 86-116 9U %REC 10l2812016 5:45 1239t0

Page6ofJ3



Client Projffl: McLeansboro Pit Stop Tl303020

LablD: 16101589-003

Matrix: SOLID

An1ly5es Certification

EPA SW846 3550C, 5035A, ASTM D2974 Percent Molsture


Laboratory Results bltQi flwww.tekfabJnc.com/


Re-port Date: 0l-Nov-16 Client Sample ID: BH-10 3 ft:

Collection Date: 10/21/2016 9:49

RL Qual Result Units DF Date Analyzed Batch

0.1 16.0 % 10/28/20\6 14:57 ~225204 SW-846 5035, 82608, VOLATILE ORGANIC COMPOUNDS BY GC/MS

Benzene NELAP 0.9 ND µg/Kg-dfy 10l29/2016 10:32 123939 Etnytbentene NELAP 4.3 ND l,lg/Kg-dry 10/29/2016 10:32 123939 Metl\yl lert-bulyl elher NELAP 1.7 ND pg/Kg-dry 1012912016 10:32 123939 Toluene NELAP 4.3 ND IJg/Kg.d/y 10129/2016 10:32 123939 Xylenes, Tota! NELAP 4.3 ND llg/Kg-df)" 10/29/2018 10:32 123939

Surr: 1,2•Dlchloroelhane-d4 72.2-131 106.2 %REC 10/2912016 10:32 123939 Sutt: 4-Bromofluorobenzene 82.1-116 102.9 %REC 1 10129/2016 10:32 123939 Surr: Olllromolluoromelhane 77.7-120 109.2 %REC 1 10/2912016 10:32 123939 Surr: Toluene-d8 88-116 108.2 '!I.REC 10/2912018 10:32 123939

Page7ofJ.3



Laboratory Results

Cllent: Chase Environmental Group


Lab ID: 16101589-oo4

Marni: SOUO

Analyses Certification

EPA SW846 3550C, 5035A, ASTM 02974

RL Qual

Petc:ent Moisture 0.1

SW-846 5035, 82609, VOLATILE ORGANIC COMPOUNDS BY GCIMS Benzene NELAP 0.8 ett,ylbenzene Metl1yl lllft•bUlyl ether Toluene X)'lenes. 10111

&m: 1.2-0iel'ltaroethano-44 &Jrt: +Bromolluotobenzene Surr. Ol!)romolluoromelhane Surr. Toklene-<18

NELAP 3.8 NELAP 1.5

NELAP 3.8 NELAP 3.8

72.2-131 82.1-118 77.7-120

86-116

bttp;//www.tekJablnc.com/

Work Order: 16101S89

Report Date: Ol·Nov-16

Olenl Sample ID: BH·llA 3 ft

Collectlon Date: 10/21/2016 10:07

Result Units DF Dace Analyzed Bacch

15.9 % 1 10/281201814:58 R225204

ND Jl91Kg-dry 1°'2812016 6:37 123910 ND P91Kg-dry tQ/2812016 6:37 123910 ND pg/Klr(tiy t0/2812016 6:37 123910

NO JJg/Kg-dty 10(2812018 6:37 123910 NO J,lg/Kg-dly 10(2812016 8:37 123910

107.5 %REC 1°'2812016 6:37 123910 95.2 %REC 10/2812016 6:37 123910

10U %REC 10l2Bl20l6 6:37 123910 101.9 %R£C 10/28/2016 6:37 123910

Pag'180f~3



Laboratory Results



Lab ID: 16101589-005

Matrix: SOLID

Analyses CertJficaHon EPA SW846 3550C, 50354, ASTM 02974

RL Qual


SW-846 5035, 8260B, VOLATILE ORGANIC COMPOUNDS BY GC/MS 8entane NEl.AP 0. 7 eu,y11>enzene Methyl telt•bU¥ eltier Toluene Xytenes, Tola!

Svrr. 1,2·01chloroetllane-d4 Surr: •Bromofluorobemene Surt: Oibromolluorome!l\ane SUtr: Totuene-<13

NELAP Net.AP NELAP NELAP

3.7 1.5 3.7 3.7

72.2-131 82.1-116 77.7-120

8&-116

bttR; //www.teklabJnc,com t

WorkOrdcr: 16101589

Report Date; 0l·Nov-16

Client Sample JD: BH· 11B 5.5 ft

Collection Dace: 10/21/2016 10:11

Result UnUs DF Date Analyud Batch

14.8 % 1 10/2812016 14:58 R2252Q.4

ND ll9fl<g-dfy 10/2Bn016 7:03 123910 ND pg/Kg-dry 10/2812016 7:03 123910 ND µg/Kg-dry 1 10/2812016 7:03 123910 NO vgfl(g-dry 1 10/2812016 7:03 123910 ND f191K94Y 10128/2016 7:03 123910

107.3 %REC 10128/2016 7:03 123910 96.1 %REC 1012812016 7:03 123910

102.1 %REC 10/2812016 7:03 123910 102.2 %REC 10/2812016 7:03 123910

Pagt! 9 of .13



Laboratory Results


Client Projtct: McLeansboro Pit Stop T1303020

Lab ID: 16101589-006

Matrlx: SOLID

Analyses Certlflcadon EPA SW846 3550C, 5035A. ASTM D2974

Percent Moisture

RL Qua)

0.1

SW-846 5035, 82608• VOLATILE ORGANIC COMPOUNDS BY GC/MS Beru:ene NE\.AP 0.9

Ethyfbenzene NELAP 4.3 Methyl tert-butyl ether NEl.AP 1.7

To!Uene NELAP 4.3 X)'tentU, Totat NElAP 4.3

Sun: 1.2-0ldlloroelhane-<M 72.2·131

Surr: +BramoOuorobenzene 82.1-116 &nr: Oibromafhiaramethane 77.7-120 &nr: Toluene-<18 86-118

http;//www.teklablnc.com/


Rq>0r1 Date: Ol•Nov•16

Client Sample ID: BH·12 3 tt

Colledlon Date: 10/21/2016 10:21

Result Units DF Dite Anal)-zed B11telt

22.0 % 1 1012812016 14:59 R225204

HD 1,1g/K9-dly 1 1012812016 7;28 123910

HD µg/Kg-4!.ry 1 10/2812016 7:28 123910

ND 1,1911(g-dry 1 1012812016 7:28 123910

ND 1,1g/Kg-dly 1 10/2812016 7:28 123910 ND µg/Kg-c,y 1 1012812016 7:28 123910

107.8 %REC , 1012812016 7:211 123910 100.2 %REC , 10/2812016 7.28 123910 103.9 ·~REC 1 10/2812018 7.28 123910

104.4 %REC 1 10/2812018 7:28 123910

Pagezoon3



Laboratory Results

Client: Olase Environmental Group

Client Project: Md.eansboro Pit Stop Tl303020

Lab ID: 16101589--007

Matrix: SOUD

Analyses Certmcatlon

EPA SW846 3550C, 5035.A. ASTM D2974

RI, Qua)


SW-846 5035, 82608, VOLATILE ORGANIC COMPOUNDS BY GCIMS Benzene NELAP 1.1

Ethyl benzene NELAP 5.6

Melllyl tert-butyl elher NELAP 2.2 Toluene NEtAP 5.6 X~enes, Tolal NELAP 5.6

Surr. 1.2.l)lcljoroelhane-04 72.2.131 Surr: 4-Sromonuorobenzene SUtr: Olbramonuoromelhane Surr. Toluene-d8

82.1-118

n.1-120 81Mt6

http; t f www.teklabfnc.com I


Report Diite: Ol·N0\/·16 Client Sample ID: BH· 13 3 ft

Collrctlon Date: 10/21/2016 10:57

Re-suit Unils OF Date Analyzed Botch

21.7 10128/2016 14:59 R225204

ND µgll<g,dry 10/28/2016 7:54 123910 ND 1Jg/l<g4y 10128/2016 7:54 123910 HD pgll<g-dry 10128/2016 7:54 123910 HD pgll<g-dry 10128/2016 7:54 123910 ND pgll(g-d!y 10128/2018 7:54 123910

107.6 %REC 10128/2016 7:54 123910 98.8 %REC 1012812016 7:54 123910

101.4 %REC 10128/2018 7:54 123910 101>.1 %REC 10128/2018 7:54 123910

Page :t:t of J:J



Laboratory Results

Cllcat: Olase En\/lronmental Group

Client Project: Md.eansboro Pit Stop T1303020

Lab ID: 16101589·008

Matrix: GROUNDWATER

Analysts Certification RL Qual SW-846 5030, 82608, VOLATILE ORGANIC COMPOUNDS BY GCJMS

Benzene NEIAP 2.0

Elhylbenzene NElAP 5.0

Me!hyl ll!rt-butyt ether Toluene Xylenes, Total

Surr. 1,2-~thane-d4 Surr. 4-Bromonuorobentene surr. Dlllromofluoromelhane SUrr. Toluene-48

NElAP 2.0

NElAP 5.0

NElAP 5.0 74.7-129

86-119

81 .7-123

84.3-114

Client Sample ID: MW-6

bttP;t/www.teklablnc.com/


Report Date: 0l·Nov·16

Collection Date: 10/25/2016 7:39

R~ult Units DF Date Analyzed Batch

ND µgll 1013112016 16:48 123951

ND µg/1. 10/31/2016 16:48 123951

4.8 µgit. 1 1013112016 16:48 123951

N0 µgll t 10/31/2016 16:48 123951

NO 11gll 1 10/31/201816 :48 1239S1

91.6 '!!.REC 1 10/311201616:48 123951 94.5 %REC 10/3112016 16:48 123951

91.6 %REC 10131/2016 16:48 123951

101.2 '6REC 10/3112016 16:48 123951

Page 12 of 1.3



Receiving Check List

CUcnt: Clase Environmental Group

Client Projttt: Md.eansboro Pit Stop T1303020

Canler: MaN!n Johnson

Compkltd by: OD:

27-0c.H6 Kalyn Foecke

Received By: KF

Rt\'M!Wtd b1:

On: 27-0ct-16

Paaes co follow: Chain ol custody ! 1 Extra pages Included I 2

Shipping conlalnet/ccolet in good condl11on? Vas @ No 0 T~ or lharmal preservation? None O Ice S2l Ctlaln ol OJSIOdy present? Yes ~ No 0 Ctluln or custody slgn!d when rellnquiSlle4 and received? Yes li2l No 0 Ctlaln of custody agrees wilh sample labels? Yes 6!i No 0 Samples In !)(Opet containerlbo!Ua? Yes ~ No 0 Semple contalnets lmact? Yes ~ No 0 Sufficient sample volume f0t lndlcalltd test? Yea @ No 0 All samples received w!Ulln holding time? Vos lii:l Na 0 Reported liald parameters measured: Field O Lab 0 Contalnet/Tomp Blank temperature In compliance? Yes fi2l No 0

WMn lharmaf presSJVllfion is n,qlllted, samples are compfiant with .a tamperarure between o. 1 •c -e.o•c, or when samples are 19caived 011 lc& UM sam& day as collected.

Water- at least one vial per-sample has z:ara headspace? Yes

Waler - TOX containers have zero heapaca? Yes 0 Watet. pH acceptable upo11 receipt? \'es li2! NPOES/CWA TCN Interferences checkad/tntat11d In lh& !lel6? Yes 0

http;//www.tektablnc,comL


Report Datt: 01-Nov-16

Elizabeth A. Hurley

Not Present 0 B!uelee 0

No VOA vials 0 No TOX conlafners &!l

NAO NA~

Temp•c 2.82 Dry Ice 0

Any No 1'9SJ)Ol'l48S m11St be detalted below er on the COC. --------------------------------------------·

Paf/tf J:J of J3


· CHAIN OF CUSTODY pg . ..J_ of_\_ Work Order# h11Ql6K'j TEKLAB, INC. 5445 Horseshoe Lake Road- Collinsville, IL 62234- Phone: (618) 344·1004 -Fax : (618) 344-1005

i ..... }L :-½..-.-'! J,,..,_,...,..,._,._,.. . • •·· ····'··· ••••" .... )II 21 .).! .-c..· ,,._•;.•_•-•.-..• •. ..-..•.• • • --.. ... •:>._• ......... •1 ..... & .. Jr»J'n ... ,I

Client: l!IM.s6" ES'NVtl!,olJ MQ.l~ e:;q;,.,F; :HK« Address: ""Fb.1,.-=..:&..-u.X.:..1A~S~------------City I State/ Zip: Caut:8:A u,4; .rz_. (aZ.fJ;,I , Contact: MA,yllJ ,>"dH1SoJJ, Phone:fn/8-$5-'11'¢.0

E-Mail: Id~ €.Q#ku"'1'-', <=0"'1 . Fax: J .

• Are these samp le:$ 1m-,, to be 1-11volved In liUption? J! yes. a autdw'oe wm apply . 0 "!°" • ~ 11\Ue umptu known to be hau1dous7 0 Yes ~No • Ate ~here any ni,qulte<I n,ponlng limit& tot». met on~ rwq\lUted analyal•? If ye•, plfs&Se provide

limi ts in comment Hction. at vu a Ho

•A Project Name / Number , .. 1c.l.6~2o2o "Fir SrtJP

Sampte Collector's Name

et. 1:>"boTf )I . Results Requested )'\sundo«s a 1-2 Doy (100¾ Surc:~rge) I p a Otflff ___ o 3 Day (50% S1irchargej -pv../

Billing lnstn.H;Uons

~ti ~lJ.~~Pnf~ISample ldentlflcaUon I Datemme Sampled . ----------

-9A z.s·

#and T• of Conlalnen

0l6lgl..J % "'" u ;c z :;c ::z:: =1 gl ~Is ii ~ ~z~ :,a

I I z.: 1 1-i.

The individual signfng this agreement on behalf of dlent ackll0wfedg&$ that tie/sh9 has read and understand$ UIG tenns a-nd COflditlons ol lhis ag,eemenl, Oil th& reverse side, and tnat l'le/she has !tie autt10rlty to sign on beha'lf of die!Tl

HITE~LAB

r ""O ;:.: en -0 :0 r r 0 -""O 0 OJ z !) ..... .....,

I c:, ....., ..::::! ~ c:, .,:,.. a,



- Illinois Environmental Protection Agency Bureau of Land • 1021 N. Grand Avenue E. • P.O. Box 19276 • Springfield • Illinois • 62794-9276

The Agency la authorized to require this Information under Sec:Uon 4 end Tille XVI of the Envlronmenlaf Protection AtJ. (415 ILCS 514, 5157 - 67.17). Failure to disclose this lnfonna11on may reau?t In a c:ivll penalty of not lo exceed $50,000.00 lot the violation and an eddillonel civil penalty or not to exceed $10,000.00 for each day during which lhe violation contiiues (415 ILCS 5142). MY person who knowingly rnake9 a fal&e material statement or representation. orallY or in wrlUng, In any label, manifest. record, report, pennit, or license, or o1her document filed. maintained or used ror the purpose of compliance With Title XVI commits a Class 4 felony. Any $econd or &Ut>sequent offense after ainvidion hereunder Is a Class 3 felony (415 ILCS 5/44 end 57.17). This form has been approved by Iha Fo~ Management Center.

Leaking Underground Storage Tank Program Laboratory Certification for Chemical Analysis

A. Site ldenUflcatron

IEMA Sncldent # (6- or Mgit): 20130569 -------- IEPA LPC# (10-dlglt): _06_5_02_0_5_17 ___ _ S i1 e Name: IL Pltstop, LLC

Site Address (Not a P.O. Box): _21_1_e_a_st_Aa_n_do_.lph ___ S_tre_et ________________ _

ZIP Cede: 62859 City: Mcleansbom County: _H_am"""il-'lon ______ _ -------Leaking UST Technleal Fne

B. Sample Collector

I certify that:

1. Appropriate sampling equlpment/methotSs were utilized to obtain representallve sampfes.

2. Chain-of-custody procedures were followed in the field.

3. Sample Integrity was maintained by proper preservation.

-4. All samples were properly labeled.

C. Laboratory Representative

I c:ertify that 'l,\0\6'\ 1. Pror,er chaln-of<ustody procedures were fottowed as documented on the chaln-of-custody forms

2. Sample Integrity was maintained by proper preservation.

3. All samples were properly labeled.

-4. Quality assurance/quality control procedures were established and carried out.

5. Sample hddlng times were not exceeded.

IL5322283 I.PC 509 Rev. Merc:h 2006

Ulborato,y Cet1.llication for Chemicel Analysis

Page 1 of2

M ._..,a::,. (Initial)

/"'t LQU:.

(Initial)

Y'!'• '° ;a:: (lnitlal)

.,.., C. ,0 .:0::.. (lnlllan

mt-P'11:. (lnlllal)



lv1016iq 6. SW-848 Analytical Laboratory Procedure (USEPA) methods were used for the analyses. '""'<)-a:.

(Initial)

7. An accredited lab performed quantitative analysis using test mell\ods Identified in 35 IAC 186.180 (for samples collected on or after January 1, 2003).

m ,. o:JP(tnltlal)

D. Signatures

I hereby affirm that au infonnation contained In this form Is true and accurate to the best of my knowledge and belief. I am aware lhat there are significant ~natties for submitting false Information, Including the possibility of ftne and impriSCf'lment k>r knowing violations.

Sample Collector

Name Duane Ooty

Title St . PrcJect Manager

Company Chase Environmental Group, Inc.

Address PO Box AB

City CanCt'alla

State IL ---------------Zip Code ... 62:;;;;8.0.;..1 __________ _

~one 618-§;i? ~/ Signature ~ ~A _ Date ~

Laboratory Representative

Name --~m=~.;;.r_v.;;.:.;;.~__::::~--~/::,~9~~:....:.:l;~~~,~:P:::..==----Title f>r o i, r. 1' t".h. "'• ,,4,. ,-Company '"'"Tekl;;..;..;.a;;;:b•.;;.'nc.=---------Address 5445 Horseshoe lake Road

City Collinsville State .;..;;IL _____________ _

Zip Code 62234-7425

Phone 618-344-1004

Signature ~ t?~h~~ Date ----~".{.,I~(~~---------

Laboratory certif'icaUon r« Chemical Analysis

Page2of2



APPENDIX D Sanders Access Agreement



Offsite Access Agreement for the IL Pitstopt LLC site in McLeansboro, IL

~ will allow acces, fa< ,oH bcm!gs and/or ..,.nor well insrallarion and ,ampling in onler to define the extent or soil and groundwa1er contamination. Any additional work will be discussed prior to implementation.

I will not allow access for soil borings and/or monitor well installation and sampling in otder to def me the e>rtent of soil and groundwater contamination.

PROPERTY OWNER OF: 506 South Locust McLeansboro, IL 62859 Parcel JO Number: 08-15•30.5-010

Printed name: Ho..r-r-y Sa.ad.e,-..s Signature: ffef# >?L..JJ ~~

Phone Number: 6,/3-J!J($- 09/~ {to contact you prior to fieldwork)



APPENDIXE Stage 2 Site Investigation Cost Summary

~::-::cc~VED lf""\.f.-- ......... ..

DEC 3 O 2016

IEPA/BOL



Illinois Environmental Protection Agency Bureau of Land • 1021 N. Grand Avenue E. • P.O. Box 19276 • Springfield • IRinois • 62794-9276

General Information for the Budget and Billing Fonns

LPC #: 0650205017

City: McLeansboro

County: Hamilton --------------5 it e Name: IL Pit Stop, LLC

Sile Address: 211 E Randoleh

IEMA Incident No.: 20130569 20001319

IEMA Notification Date: May 15, 2013 Jul24,2000

Date this form was prepared: ..;.1.;..11_04.;..;/2;;;..;0_16.;.._ ______ _

This fonn is being submitted as a fcheck one, If applicable):

D Budget Prcposal

l8J Budget Amendment (Budget amendments mt.1st include only the costs over the previous budget.)

0 Billing Package

Please provide the name(s) and date(s) of report(s) documenting the costs requested:

Name(s): ---- ----- RECFI\IIED Date(s): ------ ------- DEC 3 0 2816

This package fa being submitted for the site activities indicated below:

35 Ill. Adm. Code 734:

0 Early Action

O Free Product Removal after Ear1y Action

r8'.I Site Investigation • • • • . . . . .. . • • . Stage 1: 0 O Corrective Action Actual Costs


0 Early Action

O Free Product Removal after Earfy Action

0 Site Classification

O Low Priority Corrective Actiol'l

0 High Priority Corrective Action


0 Site Investigation

0 Corrective Action

IL 532-2325 L?C 630 Rev. ti 2007

Stage 2: 181 Actual

IEPA/BOL

Stage3:0



General Information for the Budget and Billing Forms

The following address will be used as the mailing address for ched<s and any f111al determination letters regarding payment from the Fund.

Pay to the order of: .;.;IL_P_it'-S;;.;;top=,_L_LC ________________________ _

Send in care of: Chase Environmental Group, Inc.

Address: PO Box AB

City: Centralia

The payee ls the:

State: fl ------ Zip: 62801

Owner~ Operator 181 (Check one or both.)

W-9 must be submitted. Click here to print off a W-9 Fom,.

Number of petroleum USTs in tnlnois presently owned or operated by the owner or operator; any subsidiary, parent or joint stock company of the owner or operator; and any company owned by any parent, subsidiary or joint stock company of the owner or operator:

Fewer than 101: t8l 101 or more: D

Number of USTs at the site: .;;.5 __ _ (Number of USTs includes USTs presently at the site and USTs that

have been removed.)

Number of incidents reported to IEMA for this site: 2 ------------------1 n c id en t Numbers assigned to the site due to releases from USTs: 20130569 20001319

Please list an tanks that have ever been located at the site and tanks 1hat are presently located at the site.

Product StoNKI In UST Size Did UST have Incident No. Type of Release (gallons) a release? Tank leak/ OVerfill /

Piping leak

Gasoline 8,000 Yes~ No0 20001319 Tank Leak

Gasoline 4.000 Yes~ NoO 20001319 Tank Leak

Gasofine 2,000 Yes (8l NoO 20130569 Tank Leak

Gasoline 6,000 Yes D No (8l

Diesel 2,000 Yes 0 No 18)

YesO NoO

YesO No0

Yes O No0

YesO NoQ

j Add More Rows / Undo Last Add



Budget Summary

Choose the appJlcable regulation: <; 734 0 732

734 F,ee Produd Stage 1 Site Stage2 Site Stage 3Site Corrective Investigation Investigation Investigation Action

Orllllng and Monitoring WellCOS1sform s s $ 2,049.51 s s

Analytical Costs Form $ $ s 849.73 $ $

Remediation and $ $ 619.57 $ s Disposal Costs Form $

UST Removal and Abandonment Costs $ s $ $ $

F«m

Paving. Oemolltlon, and Well Abandooment Costs $ s $ $ s

Fo,m

Consulting Personnel s s $ 15,800.84 s s Costs form

Consultant's Materials CosuForm $ s $ 1,034.57 $ $

Handling charges wlll be determined at the time a bllllng package Is submitted to Handling Charges Form the Illinois EPA. The amount of allowable handling charges wtn be determined In

accordance with the Handling Charges Form.

Total s $ $ 20,354.22 $ $



. Drilling and Monitoring Well Costs Form

1. Drilling

Number of Type Depth (feel) Totaf Feet Borings to Be HSNPUSH/ of Each

Drilled Reason for Drilling Drilled Injection Boring

3 PUSH 8.00 24.00 BH-9, BH-10, BH-11

1 PUSH 9.00 9.00 BH-12

1 HSA 9.33 9.33 MW-6

Total Feet Rate per Foot (S) Total Cost($)

l8J Subpart H minimum payment amount appfies.

Total Feet via HSA:

Total Feet via PUSH: 9.33

33.00 Total Feet for ln~ction

via PUSH:

2. Monitoring / Recovery Wells

Number of Type of Wei Diameter of Well Wells HSA / PUSH / 4" or&• (Inches)

Recovery / 8'' Recovery

1 HSA 2.00

Well Installation Total Feet

Total Feet via HSA: 9.33

Total Feet via PUSH:

Total Feet of 4" or 6" Recovery:

T otaf Feet of 8'' or Greatet Recovery:

28.50 265.90

22.30 735.90

Total Drilling Costs: 1,858.71

Depth of Well Total Feet of Wells (feet) to Be Installed ($)

9.33 9.33

Rate per Foot($) Total Cost($)

20.45 190.80

Total Well Costs: 190.80

Total Drilling and Monitoring WeU Costs: $2,049.51



Analytical Costs Form

Laboratory Analysis Number of Cost($) per Total per Samples Analysis Parameter

Chemical Analysis

BETX Soil with MTBE EPA 8280 7 X 96.00 :, $672.00

BETX Water with MTBE EPA 8260 1 X 91.00 = $91.00

COO (Chemical Oxygen Demand) X = Corroslvity X = Flash Point or lgnltabiHty Analysis EPA 1010 X a

Fraction Organic Caroon Content (foe::) ASTM-0 2974-00 X = Fat. Oil. & Grease (FOG) X = LUST Pollutants Soil - analysis must Include volatile, base/ neulra~ polynudear aromatics and metals list in Sedion 732.

X Ill

Appendix B and 734.Appendix B Dissolved Oxygen (00) X = Paint Filter (Free Liquids) X = PCB / Pesticides (oornbination) X = PCBs X = Pesticides X = pH X = Phenol X • Polynuclear Aromatics PNA. or PAH SOIL EPA 8270 X Cl

Polynudear Aromatics PNA. or PAH WATER EPA 8270 X = Resctlvity X = svoc -soa (Semi-Volatile Organic Compounds) X C

svoc -Water (Seml-VolatBe Organic Compounds} X = TKN (Total Kjeldahl) "nitrogen" X Cl

TPH (Total Petroleum Hydrocarbons) X = voe (Volatile Organic COmpounds) - Soil (Non-Aqueous) X D

voe (Volatile Organic Compounds) - Water X c;

X a

X a

X = X = X =

Geo-Tedlnieal Analysis Soil Bulk Oensltv (Pb) ASTM 02937-94 X a

Ex•situ Hvdraulic Condudlvity I Permeabilitv X = Moisture Content {w) ASTM 02216-92 J 04643-93 X a

POC'O$ltv X = Rod< Hydraullt Conductivity Ex-situ X =

Sieve I Partlde Size Analvsis ASTM 0422-63 / 011-40-54 X = Soil C1assificali0n ASTM 02488-90 / 02487-90 X a

Soil Partlde Oensify (Pa) ASTM 0854-92 X = X ::I

X = X .,.




Metals Analysis

Soi1 nl1!1\:lration fee ror Metals TCLP Soil tooe fee cer soil samr;,le) X = Soil nl'l!n;lratlon fee fOf' Metals Totaf Soil lone fee -r soil samnle) X = Water rirenara1ion fee for Metals Water tone fee oer water salT11llel X =

Arsenic TCLP Soil X = Arsenic Total Soil X :::

Arsenic Water X = Barium TCLP Soil X • 8ariwn Total Soll X = Barium Water X = c.romium TCLP Soil X = Cadmium Total Soil X C

Cadmium Water X C

Chromium TCLP Soil X = Chromium Total Soil X = Chromivm Water X = Cyanide TCtP Soil X = Cvanlde Total ScB X = Cvanide Waler X • Iron TCLP SoU X • Iron Total Soil X = Iron Water X = Lead TCLP Soil X = Lead Total Soil X = Lead Water X = Mercury TCLP Soil X • Mera.uy Total Soll X • Mercurv Water X • Selenium TClP Soil X • Selenium Total Soll X = Selenium Water X • Silver TCLP Soil X = Silver Total Soil X • Silver Water X • Metals TCLP Soil (a combination of an metals) RCRA X = Metals Total Soll (a combination ot aft metafs) RCRA X = Metals Water (a combination of all metals) RCRA X •

X = X = X Cl

X = Other

EnCore1P Sampler. purge-and-trap sampler, or equivalent sampling device

7 X 12.39 = $86.73

Sample Shipping per sampling event1 X = 1A sampling ewnt. e1 a minimum. ls all samples {soil and groun~let) collected in a calendar day.

Total Analytical Costa: S 849.73 __ ;.... __ _



Remediation and Disposal Costs Form

A. Conventional Technology

Excavation, Transportation, and Disposal of contaminated solt and/or the 4-foot backfill material removal during eartv action activities:

Number of Cubic Yards Cost per Cubic Yard($) Total Cost

Backfllllng the Excavation:

Number of Cubic Yards Cost per Cubic Yard ($) Total Cost

Overburden Removal and Retum:

Number of Cubic Yards Cost per Cubic Yard ($) Total Cost

B. Altematlve Technology

Alternative Technology Setecled:

Number of Cubic Yards of Soil to Be Remediated

Total Non-Consulting Personnel Costs Summary Sheet($)

Total Remediation Materials Costs Summary Sheet($)

Total Cost of the System



Remediation and Disposal Costs Form

C. Groundwater Remediation and/or Free Product Removal System

Total Non-Consulting Personnel Costs Summary Sheet($)

Total Remediation Materials Costs Summary Sheet($)

T otaJ Cost of the System

D. Groundwater and/or Free Product Removal and Disposal

D Subpart H minimum payment amount applies.

Number of GalJons Cost per Gallon ($)

e. Drum Disposal

f81 Subpart H minimum payment amount applies.

Number of Drums of Solid Waste Cost per Drum (S)

1 309.79

Number of Drums of Uqu!d Waste Cost per Drum ($)

T olal Drum Disposal Costs

Total Remediation and Oieposal Costs:

Total Cost($}

Total Cost($)

309.79

Total Cost ($)

619.57

$619.57



Consulting Personnel Costs Form

Employee Name 1 Personnel Title I Hours I Rate· ($) 1 Total Cos t

Remediation Category I Task

I Senior Admin Assistonl I 4 50

I $250 92

Stage 2-Plan I Prepare/submit Stoge 2 S,te lnvest19.i110n Pl.in to 0/0 and IEPA

1Seni01 Pro1ect Manager I I I 14 00 123 91 S1 734 74

Stage 2-Plan l Consult 0/0 regartt,ng proposed scope of wolll. projed Malus and lentative schedule

I Senior Acci. T cchnician I 6 00 I 68.141

Stage 1-Pay l P11:pare Stage 1 Site lnvesllgauon reimburument application

I Senior Proica Manager I 12 00 I 123 91 I $1 4!16 92

Stage 2·Plan I 01aft Stage 2 Site fnvesUgation Plan

I Senior Project Manager I 650 I 123 91 I sao5.4 l

Stage 2·8udget I Prepare Stage 2 Site lnlle$0gallon Budge\

I Seruor Adrrun Ass1s1an1 I 1 50 I 55_ 76 1 58364

Stage 1-Pay I Prepare/submit Stage 1 s,re lnveshgalion re,mbwsement applicauon to IEPA

I Semor Prof Geologist I 1 50 I 136 31 l $204.47

Stage 1-Pay I Reviewlcerofy Stage 1 Site ln,;eshga11on re,m~mcnt 11pplict1tron

I Senior Pro1ect Manager I I I -4 00 123 91 $495 6-4

Stage 2-Field I On-sr.c meeting wifh OJO to revicwievaluate !EPA re Quested Stage 2 bonog & weh locations

lSenior Proiect Manager I I [ 2 so 12J .91 $309 n

Stage 2-Plan I Revise site maps relledlve of IEPA mod1fic.&t,ons iltl lorwatd to Ckahsperson



Employee Name l Personnel Title

Remediation Category I J Hours I Rate·($) J Total Cost

Task

I Sennlc Or.lflperson/CAO I 5 00

I $371 70

Stage 2-Plan I Prepare m&ps/f.gU!l!s included in Stage 2 Site ln11estiga11on Plan

I Senior Prof GeologJSt I 200 l 136 31 I $272 62

Stage 2·Plan I Review/cethly Stage 2 S11e ln11es1Jga11on Pla11

I Senior Prof Geologist I 1 00 I $136 31

Stage 2-Sudget I Rcview/cer1ily Slage 2 Srte Investigation Plan Budget

I Senior Project Manager I 7 00 I

123 91 I

5867 37

Stage 2-Plan I Corresponoence/aimmuoica11ons with 0/0 & IEPA regarding buried ulilllies soulh of store bullding

Stage 2-Plan

ISeni0<ProiectManager j 4 00 J 125 isl S50060

I Co0llfina1e/11chedule Stage 2 Site lnveshgat,on field adrvities Secure drifting & analytlcal services

I SeniOt' Project Manager j 2 00

I S250 30

Stage 2-Plan I Consult 0/0 regarding revised saipe of wofk and field schedule

_] Senior Pro1ect Manager I 5 00 I 125 15 j SG25 75

Stage 2-Pian I Second on-srte meeting wirh 0/010 tl!111ew/evaluate IEPA suggesred alternate dnlfln9 locallons

j Senior Scenllsl I 4 00 I

106 381

S425 5Z

Stage 2-Results I Tr.insalbe Boring Logs & Well Completion Fonn Revrsed analytical summane:-.

I Senior Proiect Manager I 8 00 I 125 15 I $1 001 20

Stage 2-Field I Superviseldocumenl so~ bonng aCIMlies Sod hydrocarbon scr~n,ng & sample c.ollec.t,on mapping



Employee Name I Personnel Tlt!e I Hours I Rate• CS> I Tot.at Cost


I Geologls, Ill I 2.50 I 110.131 $275.32

Stage 2-Field I Prepare &Oil samples fOf shipment

I Senior Ptoject Manager I 5.00 I $625.75

Stage 2-Resulls I Compile/revlew/evafuate field dal.l and analytical results

I Senior Oraftperlon/CAO I .50 I 75.081 $37.54

Stage 2-Resulls I Rtvise site maps refledive of Stage 2 Site tnvesllgallon

I Senior Project Manager I 7.00 I 125.151 $876.05

Stage 2.Plan I Researdllnegoliate ac:oes1t to adjoining p,operty so drilling equipment could lnstan 8H6IMW6

I &:nlOf Project Managet I 3.00 I 12s.1sl $375.45

Stage 2-Plan I Coordinate/$Cl'ledule installation of BH6/MW6. Secure dlilling & analyllcal semces

I Senior Project Manager I 10.00 I 125.151 $1,251.50

Stage 2-Fleld I Dowment felld adivilies, 109 BH6, dOQlmenl irmallallcn of M\NG, soil sample colleMn, mapping

Seni<lt Project Manager 4.00 t25.t5 SSOQ.60

Stage 2-Fie!d Develop monitoring well MW-6

I Senior Proled Manager I 5.00 I $625.75

Stage 2-Field I su,wy well risers

I Senior Technician 3.00 81.341 Stage 2-Fleld I Survey weD risers



Employee Name I Personnel TIUe I Hours I Rate* ($) I Total Cost

Remedlatlon Category I Task

I Senior Aecl Technician l 5.00 I 68.831 $344 .15

Stage2-Pay I Prepare Stage 2 Site lnvestigellon adual CO$!. summa,y

f Senior Acct. Tecmician l 6_00 I 68

_83

J S4t2.98

Stage 2-Pay I Prepare Stage 2 Site lnwstlgation reimbursement application

*Refer to the appbble Maximum Pavment Amounts document.

I Total of Consulting Personnel Costs I $15,800.841



Consultant's Materials Costs Fonn

Materials, Equipment. or Field Purchase Time or

Rate (S) Unit Total Amount Used Cost

Remediation Category T Oescription/Justiflcatlon

Mileage I s2.ool .541 Milel s2aos

Stage 2.Pran l Onsite meeting with 0/0 to discuss/evaluate IEPA modified drilring locations

Digital Camera t 1.ool 30.ool Dayl $30.00

Stage 2-Plan 1 Photo-doa.imenl UST & buried utilitle& in relation to IEPA modified drifting locations

Pholionlzation Detector I 1.ool 13s.ool 0avl $135.00

Stage 2-Field f Sail hydrocarbon screening and sample ~n

Oigilal Camera I 1.ool 30.ool Davi $30.00

Slage 2-Fiefd I Photo-document Stage 2 drilling actlv!ties

Zip Lock Bags I a.ool .2sl Eachl $2.00

Stage 2-Retd r Soil hydrocarbcn saeening and sampte aillediOf'I

Latex Gloves I 2e.ool .401 Eachl $11.20

Stage 2-Field 1 Soil hydroealbon sc,een!ng and sample collection

Ice l 1.ool 1.s1 I LSI $1.81

Stage 2•Field I Soil sample preservation

Mileage I 10.ool .541 Mile' $37.80

Stage 2-Fietd ( Stage 2 driffing and soil sample collection

Mileage I s1.ool .541 Milel $27.54

S1age 2-Plan !Visit adjoining property & Hamilton Co. Courthouse to identify adjoining Property Owner



Materials. Equipment, or Field Purchase Timeor Total I Amount Used Rate($) Unft

Coat Remediation Category I Description/Justification

Pholoionizatlon Oetedor t 1.ool 13S.ool Oayl $135.00

Stage 2-Field I Soil hydrocarbon screening and sample collectlon at boring location BH-6

Digital Camera I 1.ool ao.ool Dayl $30.00

Slage 2-Field I Photo-document advancement of boring BH-6 and installation of monitoring well MW-8

Mileage I 98.ool .541 Milel $52.92

Stage 2-Field j Advancement of boring BH-6 and instalation or monitoring well MW-6

Zip Lock Bags I 8.001 .2sl Each! $2.00

Stage 2-Fiekf l Son hydrocatt>an saeening end sample collectlon at boring BH-6

Latex Gloves I 1e.00J .401 Eachl $6.40

Stage 2-Field I Soil hydrocarbon meening and sample collection at boring BH-6

water Level Indicator I 2.ooJ 30.ool Oayl $60.00

Stage 2-Fle!d I Well development and groundwater sample coflectlon

Sur.,ey Equipment I 1.ool 1so.ool oayl $150.00

Stage 2-Field I &lrvey well risers to indude MW-6 as data point in groundwater ftow dlredionlgradlent

Baier I 1.ooJ 2s.ool EachJ S2S.00

Stage 2-Field I WeJI development and groundwater sampfe collection at mon~oring well MW-6

Mileage I 213.ool .541 MRel $115.02

Stage 2-Field I Well development and groundwater sample collection at monitoring wen MW6 (2 trips)



Materials, Equipment, or Field Purchase Time or

Rate($) Unit Total Amount Used Cost

Remediation Category l OescriptJon#Justification

Latex Gloves I 12.00 I .40 I Each I $4.80

Stage 2-Fleld l Well development, groundwater sampte collection and groundwater survey

I Total of Consultant Materials Costs I $884.571



Owner/Operator and Licensed Professional Engineer/Geologist Budget Certification Form

I hereby certify that I intend to seek payment from the UST Fund for costs incurred while perfonning corrective action activities for Leaking UST incident 20130559 • I furthercer1ify that the costs set forth in this budget are for necessary activities and are reasonable and ac:eurate to the best ot 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 5157, no costs are included in this budget that a,e not described in the corrective action plan, and no costs exceed Subpart H: Maximum Payment Amounts, Appendix D Sample Handling and Analysis amounts, and Appendix E Personnel Titles and Rates of 35 Ill Adm. Code 732 or 734. I further certify that costs ineligible for payment from the Fund pursuant to 35 Ill. Adm. Code 732.606 or 734.630 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 fees or costs. Costs incurred prior to July 28, 1989. Costs associated with Installation of new USTs or the repair of existing USTs.

Owner/Operator: .;.;;IL;.;.P.;.;.it;...;S;;.;.to;;..i;p;.:., .:::.:Ll~C:;__ _______________________ _

Authorized Representative: Roger Swartz Title: {) u) [\ t, ,. ,...

S\gna~re: !'::··~-----------Date: f~-a,C-l~R[::C!!':.~VIE[) 7 DEC 3 0 2016

Subscribed and sworn to before me the izQ,H\.. day of _J~~-..-~~!!!!lial!!!!!!!il-iliilil~-.. ..... ~ t.1, Q Jill S PRINCE d I ( <k1~£:Cf t, w, ===~ ~ '!tfflD

BOL

fn addition, I certify under penalty of law that all activities that are the subject of this plan, budget, or report were conducted under my supervision or were conducted under the supervision of another Licensed Professional Engineer or Licensed Professional Geologist and reviewed by me; that this plan, budget, or report and all attachments were prepared under my supervision; that, to the best of my knowledge and belief. the work described in the plan, budget, or report has been completed in accordance with the Environmental Protection Act (415 ILCS 5]. 3511~~~~ 732 or 734, and generally accepted standards and practices of my profession; and that the lnform~~~~~@"'itr accurate and complete. I am aware there are significant penalties for submitting false statemen.._,...,, .. ,esentatio Q~ to the Illinois EPA. including but not timited to fines .• imprisonmen~ or both as provided in Secti . and 57.17 of th. ~ Environmental Protection Act (415 ILCS 5/44 and 57.17). f ;,a1y L tENSMMR o

a~ . c,

L.P.E.ll.P.G.: Kelly L. Tensmeyer L.P.E.ll.P.G. Seal: \ ~

L.P.E./L.P.G. Signature: ~ L~r Date: __,_,;_I ,_2.;;_.j,_-.:...giioe---'.lf+-wtm~'-,,,,r

Su cribed and sworn to before me the -\::h. day of 't:\u',) e;½._XJ_~ __ ·~-&J.,;;:::_:;;.._..,;; _;...i\~(o=:;;;;;;:;:;,-

~ Seal: \.,,,,,,,:::,,,,-4,/.'t,C~~...:...-_..::.....::~i........~~ ..... .-;;..,.J---

OFFICIAL SEAL GINA L GOODIEL

NOTARY PUBLIC-STATE OF IWNOIS MY COMMISSION EXPIRES~UAR'f 29,arll

The Illinois EPA is authorized to require this information under 4 tS ILCS 5/1. Disclosure of this Information is required. Failure to do so may result In the delay or denial of any budget or payment requested hereunder.



APPENDIX f Stage 3 Site Investigation Budget



Illinois Environmental Protection Agency Bureau of Land • 1021 N. Grand Avenue E. • P.O. Box 19276 • Springfield • Illinois • 62794-9276

General lnfonnation for the Budget and Billing Fonns

County: Hamilton LPC #: 0650205017

City: McleansbOfo --------------

Site Name: IL Pit Stop. LLC

Site Address: 211 E Randolph

IEMA Incident No.: 20130569 20001319

IEMA Notification Date: May 15, 2013 Jul 24, 2000

Date this fonn was prepared: 11/09/2016 -----------Thl& form fs being eubmitted as a (check one, if applicable):

l8l Budget Proposal

0

0

Budget Amendment (Budget amendments must include only the costs over the previous budget)

Billing Package

Please provide the name(s) and date(s) of repor1(s) documenting the costs requested: DEC 3 O ~016 Name(s}:

Oate(s}:

Thie package i8 being submitted for the site activities indicated below:

35 DI. Adm. Code 734:

D Early Aclion

O Free Product Removal after Eal1y Action

~ Site Investigation . • • . • • . . . . . . . . Stage 1: 0 O Corrective Action Actual Costs


O eany Action

0 Free Product Removal after Early Action

O Site Classification

0 low Priority Corrective Action

O High Priority Corrective Action


0 Site Investigation

O Corrective Action

IL 532-2825 LPC 630 Rev. 112007

Stage 2: 0

L.::PA/BOL

Stage 3: (8J Proposed



General Information for the Budget and Billing Forms

The following address will be used as the mailing address tot checks and any final determination letters regarding payment from the Fund.

Pay to the order of: ;.;;IL;..;.P...;;it;.;;S;.;.to;;.cp;:.., ;:;;LL;;;.;C;;._ _____________________ _

Send in care of: Chase Environmental Group, Inc.

Address: PO Box AB

City: Centralia State: IL =------ Zip: 62801

The payee is the: Owner 181 Operator 181 (Check one or both.)

Slgnat,n~otlheUSTf•)(nqulredJ

W-9 must be submitted. Click here to print off a W-9 Fom, .

Number of petroleum USTs In Illinois presently owned or operated by the owner or operator; any subsidiary, parent or joint stock company of the owner or operator. and any company owned by any parent. subsidiary or joint stock company of the owner or operator:

Fewer than 101: ~ 101 or more: D

Number of UST& at the slte: 5 .;;;... __ (Number of USTs includes USTs presently at the site and USTs that

have been removed.)

Number of rncidents reported to IEMA for this site: 2 ------------------1 n ci dent Numbers assigned to the site due to releases from USTs: 20130569 20001319

Please lisl ab tanks that have ever been located at the site and tanks that are presently located at the site.

Product Stored In UST Size Did UST have Incident No. Type of Release (gallons) a release? Tank Leak/ Overfill I

Piping Leak

Gasolirle 8,000 Yes 18] NoQ 20001319 Tank Leak

Gasoline 4,000 Yes 18] NoO 20001319 Tank Leak

Gasoline 2,000 Yes 18] No0 20130569 Tank Leak

Gasoline 6,000 Yes O No 181

Diesel 2.000 YesQ No 18]

YesO No0

Yes O No0

Yes O No0

YesO NoO

I Add More Rows I Undo last Add



Budget Summary

Choose the applicable reg\Jlation: @ 734 O 732

734 Free Product Stage 1 Site Stage 2 Site Stage 3Sile Corrective lnvestigatiOtl lrwesligation Investigation Action

Drlllln9 and Monitoring Well Costs Form $ $ s $ 1,501.84 $

Analytical Costs Form s $ $ $ 300.38 $

Remediation and DISIJ()Sal Costs Form s $ $ $ $

UST Removal and Abandonment Costs $ $ $ $ $

Farm

Paving, Demolition, and Well Abandonment Costs $ s

Foun $ $ $

Consulting Personnel $ $ Com Form s $ 14,392.16 $

Consultant's Materials Costs Form $ $ s s 646.70 s

Handling Chatges Form Handling charges wllt be determined at the time a billing package Is submitted to the llllnols EPA. The amount of allowable handling charges will be determined In accordance with the Handling Charges Form.

Total $ $ $ s 16,841.08 $



Drilling and Monitoring Well Costs Form

1. Drilling

Number of Type Depth (feet) Total Feel Borings to Be HSA/PUSH/ of Each Drilled

Reason for ormlng Drilled lnjecllon Boring

1 PUSH 10.00 10.00 Praoosed Stage 3 SCII BOlino

l8J Subpart H minimum payment amount applies.

Total Feet via HSA:


Total Feet

10.00

Total Feet for Injection via PUSH:

2. Monitoring / Recovery Wells

Number of Type of Well Diameter of Well Wells HSA / PUSH/ 4" or 6" (inches)

Recovery I 6" Recovery

Wen Installation Total Feet

Total Feet via HSA:


Total Feet of 4• or 6" Recovery:

Total Feet of 8" or Greater Recovery:

Rate per Foot ($) Total Cost($)

22.53 225.30

Total Drilling Costs: 1,501.84

Depth of Well Total Feet of Wells (feet) to Be lnstahed ($)

Rate per Foot ($) Total Cost($)

Total Well Costs:

Total Oriltlng and Monitoring Wei Costs: $1,501.84



Analytical Costs Fonn

laboratory Analysis Number of Cost($) per Total per Samples Analyals Parameter

Chemical Analysts

BETX Soil 'Mth MTBE EPA 8260 2 X 106.38 = $212.76 BETX Water with Mme EPA 8260 X = COD (Chemical Oxygen Oemand) X = Corrosillity X = Flash Point or lgnitability Analyif s EPA 1010 X = Fraction Organic Carbon Content (foe} ASTM-0 2974-00 X = FaL Oil, & Grease (FOG) X • LUST Pollutants Soil - analysis must indude volatile, base/ X = neulral, polynudear aromaUcs and metals list in Sedian 732. Appendix Band 734.Appencfrx B Dissolved Oxygen (00) X = Paint Filter (Free Liquids) X • PCB / Pesticides (combination) X ,::

PCBs X 0

Pesticides X = pH X = Phenol X • Polynudear Aromatics PNA. or PAH SOIL EPA 8270 X = PolynucJear Aromatics PNA, 0t PAH WATER EPA 8270 X = Relldivity X = SVOC - Soil (Semi-Volatile Organic Compounds) X a

SVOC • Water (semi-Volatile Organic Compounds) X = TKN (Total l<jefdahl} "nitrogen" X = TPH {Total Petroleum Hydrocarbons) X • voe (Volatile Organic Compounds) - SoM (Non-Aqueous) X • voe (Volatile Organic Compourws) - Water X =

X :I

X = X = X = X ::

Geo.Technical Analysis Soil Bulk Density {Dh) ASTM 02937-94 X • Ex-situ Hydraulic Conductivitv f Permeability X • Moisture Content (w) ASTM 02216-92 J 04643-93 X • Porosity X • Rock Hydraulic Conductivity Ex•situ X II

Sieve I Par11de Size Analysis ASTM 0422-63 f 01140-54 X Cl

Soil Classification ASTM 02-488-90 / D2487-90 X Q

Soil Particle Density {Ps} ASTN 0854-92 X = X = X a

X =




Metals Analysis

Soll rireor.itlon fee for Metals TCLP SOil {one fee ner soil samole) X = Soil on fee for Metals Total So~ {one ree nM soil samnlel X = Water nrenara1ion fee for Metafs Water Cone tee oer waler samolel X =

Arsenic TCLP SoH X = Arsenic Total Soff X = Arsenic Water X = Barium TCLP Soil X • Barium Total SOIi X = Barium Water X = Cadmium TCLP Soil X Q

Cadmium Total Soil X = cadmium Water X = Chromium TCLP Soil X = Chromium Total Soll X = Chromium Water X = Cyanide TCLP Soil X = cvanide Total Soil X = CVanide Water X a

Iron TCLP Soil X = Iron Total Soil X = Iron Water X = Lead TCLP Soil X • Lead Total Soil X a

Lead Water X = Mercury TCLP Soll X C

Mercury Total Soil X = MeroorvWater X = Selenium TCt.P Soil X = Selenium Total Soll X 1:1

Selenium Water X = Silver TCLP Soil X 0

Sliver Total Soil X = Silver Water X "' Metals TCLP Soil (a combination of au metals) RORA X = Metals Total Soil (a combination of an metals) RCRA X = Metals Water (a combination of all metals) RCRA X =

X = X = X = X =

Other EnCo,e1i) Sampler, purge-and-trap sampler, or equivalent 2 X 12.52 ::. $25.04

sampling device Sample Shipping per sampling event1 1 X 62.58 Q $62.58

1 A sampllng event. at a minimum. is aD samplu {soil and groundwater) co!lecled in a calendar /Jay.

Total Anatytic.l Costs: $ 300.31 _....;_ _____ _



Consulting Personnel Costs Form

Employee Name I Personnel Title I Hours I Rate•($) I Total Coat


I Senlof Project Manager I '4.00 I 125.151 SS00.60

Stage 2•Resutts I C&lwlate groundwater elevallons, Identify site map revisions

I Senior Project Manager l 2.00 I 125.151 $250.30

Stage 3-Plan . I Evaluate Stage 2 raStilt!l, detennlne Sta;e 3 scope of wod<

I Senior Project Manager I 16.00 I 125.151 $2,002.-40

Stage 3-Plan I Draft Stage J Site Investigation Plan

Senior Project Manager 8.00 125.15 $1,001.20

Stage 3-Budget Prep111e PfOf)O$ed 3 Sile rnvesligalion Budget

I Senior OraftpersonlCAD I 8.00 I 1s.oal $600.64

Stage 3-Plan I Prepare site mapsltlgures Included in Stage 3 Site lnwsligatlon Plan

I Sen/« Prof. Engln~ I 2.00 I 182.70 I S325.40

Stage 3-Plan I Rewiwtcel1lf>f amended Stage 3 Sile Investigation Plan

I Senior Prof. Engineer I 2.00 I 162.701 $325.40

Stage 3-Budget I Relliew/tettify Slage 3 Sile lnves11gation Bwget

Seni0f Admln. Assistant 6.00 56.32 $337.92

Stage 3-Plan Prepare/submit SU!ge 3 Site Investigation Plan to IL Pit Stop, lLC and IEPA

IGeologlstlJI I 10.00 I 110.131 St101.30

Stage 3-Field I Log aoa boring, 500 sample c:olledion & hydrocarbon screening, site mapplng (lndudea travel)



Employee Name

Remediation Category I I Personnel Title I Hour& I Rate• ($) I Total Cost

Task

I Senior Projed Manager I 16.00 I 125.151 $2.002.40

Stage 3-Fleld I Seaire drilling & enatytlcal ser.fccs. Caardinate/schedule/supe!",ise field aetivlties

I Senklr Scientist I 4.00 I 106.381 ~25 .52

Stage 3-Plan I Transcribe boring logs, ~se analyllcal summaries

I Senior Ptojed Manager I 16.00 I 125.151 $2,002.40

SICR loranStCR

I Senlof Aoct. Technldan I 16.00 I 68.831 s1.10U8

Stage3-Pay I Summarize Stage 3 Site Investigation actual costs

I Senior Prof. Engineer I 2.00 I 162.70 I $325.,(Q

SICR I Review/certify SICR

I Senior Prof. Engineer I 2.00 I 162.701 $325.40

Stage3-Pay I Review/oertify Stage 3 Site lnvesligaUon 1dual costs summary

I Senlol' Acd. Technician I 16.00 I 68.831 $1,101.28

Stage3-Pay I Prepare Stage 3 Sile lrwet.tlgation Relmb\Jl$et'l\ent Application

I Senior Prof. Engineer I 2.00 I 162,701 $325.40

Stage 3-Pay I RevieW/Cl!rtlty Stage 2 Site lfflesligation Reimbursement Application

I Senior Admln. Assistant I 6.00 I 56.321 $337 .92

Stage 3-Pay I Ptepare/SUbmit copies of St.age 3 Site lnveslfgation Reirnb\.lr$emeflt Application lo OJO & IEPA

•Rerer to the applicable Maximum Payment Amounts doa.tment

Total of Consulting Personnel Costs $14,392.16



Consultant's Materials Costs Form

Materials, Equipment, or Fleld Purchase I Tlmeor Amount Used Rate($) J Unit Total

Coat Remediation Category I DescrtptJon/Justlflcatlon

Coples I 3.ool ao.ool each I $90.00

Stage 3-Plan I Prepare copies ol Stage 3 Site Investigation Plan for 010 (1 copy) & IEPA (2 copies)

Postage I 1.ool 7.501 LSI $7.50 S1age 3-Plan I Submittal of Stage 3 Sde Investigation Plan to 0/0

Postage I 1.ool 12.sol LSI $12.50

Stage 3-Plan l Submittal of Stage 3 Site Investigation Plan to IEPA

Vehide I 1.001 110.ool oayJ $178.00

Stage 3-Fiefd I Slage 3 sail investigation

PIO I 1.ool 135.ool Oayl $135.00

Stage 3-Fteld -, Soil hydrocarbon screening & sample collection

Copies I 3.ool 30.ool eachl S90,00

SICR !Preparation of SICR for 010 (1 copy) and IEPA (2 copies)

1•~m~ 1.001 7.501 LSI $7.501 SICR I Submittal of srcR to 0/0 I

Postage I 1.ool 12.sol LSI $12.50 S!CR l Submittal of SICR to tEPA

Coples I 2.ool 3o.ool eacnl $60.00

Stage3-Pay I Preparation of Stage 3 Site Investigation reimbursement application tor OIO & IEPA



Materials, Equipment. or Field Purchase I Timeor Rate($) Unit I Total Amount Used Cost

Remediation Category I Oeecriptlon/Juatification

Postage I 1.ool 7.501 LSI $7.50

Stage J..Pay I Submittal of Stage 3 Site lnvesligation reimbursement app&cation to 010

Postage I 1.ool 12.sol LSI $12.50

StageJ..Pay I Submittal of Stage 3 Site Investigation reimbursement application to IEPA

Digital Camera I 1.ool 3o.ool Oayl $30.00

Stage 3-Fleld I Document Sl.a9e 3 Site Investigation field activities

Latex Gloves I 8.001 .401 eac11l $3.20

Stage 3-Fleld J S011 hydrocatbon saeenlng and sample collection

Zip led( Bags I 2.ool .2sl Eachl $.50

Stage 3-Field I Soil hydrocarbon saeenlng and sample oolledion

I Total of Consultant Materials Costs $646.70 I



Owner/Operator and Licensed Professional Engineer/Geologist Budget CertificatJon Form

I hereby certify 1hat I intend to seek payment from the UST Fund for costs lnc\Jrred while perfonning corrective action activities ror Leaking UST incident 20130559 • J further certify that the costs set forth In this budget are for necessary activities and are reasonable and accurate to the best of my knowledge and belief. I also certify ttlat the costs included in this budget are not for correcti'le action in e,ccess of the minimum requirements of 415 II.CS 5157, no costs are included in this budget that are not described in the corrective action plan. and no costs exceed Subpart H: Maximum Payment Amounts, Appendix D Sample Handling and Analysis amounts, and Appendix E Personnel Titles and Rates of 35 Ill. Adm. Code 732 or 734. I further certify that costs Ineligible for payment from the Fund ptJrsuant to 35 Ill. Adm. Code 732.606 or 734.630 are not included in the budget proposal or amendmenL Such ineligibte 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 nolification. r.'>. r- ,_... r--Costs associated with planned tank pulls. r,,. ~ \.; ; . .:.: ~v ED Legal fees or costs. Costs incurred prior to July 28, 1989. DEC 3 O 2016 Costs associated with installation of new USTs or the repair of existing USTs.

IEPA/BOL Owner/Operator: .;.;:IL;..;P .... it;.,;S;;.;lo;;;.ip:;.:.,.;;;L.;;.LC;;.,_ _______________________ _

Authorized Representallve: R~5Warlz

SlgnaWre: ~ ~ Subscribed and sworn to before me the g· ~11· UL ,1,ttL

(Notary Public) Seal:

r.11e: _ _,O ........ u ..... )~ia ..... c_.~ .... ------

0ate: _.l-:..~--~al,..::o;....-~l Ip:,._ __ _

Jill S PRINCE Ofllclal se,1

Not11y Public • St1te or llllnola My Commission Eapltes Sep 1 s. 2020

l.P.E.IL.P.G. Seal:

The lnlnois EPA is authorized to reqtJire this information under 415 ILCS 5/1. Disclosure of this Information Is required. Fafture to do so may result In the delay or denial of any budget or payment requested hereunder.



APPENDIXG Eligibility & Deductible Dclennination


August 22. 2013


Office of the Illinois

State Fire Marshal "Partnering With the F11e Service to Protect ltrrnois·

cammo MAIL• REC'SIPT REQUESlED #7012 }010 0002 9120 6783

n. Pit Stop, LLC P.O.Box27 Mc:I.eansboro, D.. 628S9

Dear Applicant

In Re: Facility No. 7-006710 tEMA Incident No. J 3--0569 ll-PitStop 211 :£. Randolph McLeansboro, Hamilton Co., lL

The Reimbursement Eligil>ility and Deductible Application received 011 July 22, 2013 for the above refcccnced occum:ncc has been reviewed. The following dcttrn1inldicms have been made based upon this review.

Ct has been determined 1hat you are eligible 10 seek payment of costs in excess ofSS,000. Tho costs must be in response to the occum:nee referenced above and associated with the following tanks:

Ellgl°ble Tanks

Tank 3 2 ,000 gallon Gasoline

You must collt:aet the nlinois Envhontncntal Proll:Ction Agl:ncy to receive a padtet of Agency billing forms for submiaing your request for payment.

An owner or operator is eligible to access the Underground Stt>nige Tank Fund if1he eligibility requim'nents er,:

satisfied:

I. Neltber the owner nor the opcntor i$ the United S1'111tS Government,

l. The tank dots not contain fuel which is exempt from the Motor Fuel Tax Law.

3. The oosts were incu~ as a result cf a confimcd ~leas a of any of the follow.ins substaneeS:

"Fuel .. , as defined in Section 1.19 of the Motor fuel Tax Law

Aviation fuel

Heating oil

Kerosene

Used oil. wbicb bas been refined from crude oil used In II motor vehicle; as defined in Secrlon 1.3 of the Motor Fuel Tax Law.

1035 Stevenson Drive • Springfield, IL 62703-4259 PttlsdmReqdet!Pa,H



4. The owner or opcra!Or resistered the tank and paid all fees in accordance with the statutory and regulmory requirements of the G&SOline Storage Act.

S. The owner or operator 11otificd the llliaois Emergency Managamcnt Agency of a confirmed release, the costs wen: UIQUT'ed after the notification and the costs were a result of a release of a substance listed iii th is Section. Costs of corrective action or indemnification iDcumd before providing th8l nodficalion shall not be eligible for payment.

6. The C0.51s have nol aJn:ady been paid to the owner oroperuor under a private insurance policy. other wriucn aerecmcnt. or <:0urt order.

7. The ccsts were associated wilh "com:ctivc action".

This CO!lStitutcs the &at decision as it rclaU:s to your eligibility and deducn"bility. We n-:scrve the right to change lhe deducti"blc determination should additional information that would change the determination bea,mc available. An underground storage tank owner or operatl)r may appeal the decbion to the mtnols Pollution Control Board (Board), purs111Dt to Section 57.9 (c) (2) , An owner or operator who .seelc.s to appeal the decision shall file a petition fora hearing before the Board wi1hin JS days of the dm of malling of the final dc:c:ision,. (JS Tilinols Admlnisuativc Code 105J04(b)).

For information regarding the filing of an appeal, please conblct:

Clerk UJinols Pollution Control Board Stare oflllinois Center JOO West. Randolph. Suite 11-500 Chicago, OliDois 601501 (312) 814-3620

The following tanks uc also lisiod for this she:

Tuk 1 8,000 gallon Gasollac Tame 2 4,000 gaJlon Gasoline Tank 4 6,000 gallon OasoUoe Tank S 2,000 gallon Diesel Fuel Tank 6 6,000 gallon Diesel Fuel

Vom application indicates that there has not been a release from chese tanks under this incident number. You may be digible to seek payment of corm:tive action eosts esoc:iatcd with these tanks if it is cktcrmi.o.ed that 1lu:re has been a release from ooe or more of these tanks. Once It is determined that thc:TC: bas been a release fiom one or m01e or these tanks you may submit a separate application for an eligibility determination to seek corrective acdon costs usocl8ted with this/these tanks.

tf you have any questions, please oonlal:t our Office u (217) 78S-t 020 or (217) 715-5178.

Sinccn:ly.

Deannelcclc Adminisnlive Assistant Division of Petroleum and Chemical Safety

cc: !EPA Facility FIie


From: Marv in Johnson [mailto :[email protected] Sent: Thursday , April 13, 2017 12:48 PM To: Duane Doty <[email protected]>


Subject: Fwd: IL Pitstop in McLeansboro -- LUST Incident #2013 0569

Sent from my iPhone

Marvin Johnson Chase Environmental Group Cell: 618-322-8935

Begin forwarded message:

From: "Kuhlman, Eric" <[email protected]> Date: April 13, 2017 at 11:10:48 AM CDT To: Marvin Johnson <[email protected]> Subject: IL Pitstop in McLeansboro - LUST incident #2013 0569

Marvin, I'm in the process of reviewing your latest subm ittal for the above-mentioned site, I determined that you'll need to justify the following rates w ith additional documentation:

• PIO, • Water level indicator, • Survey equipment, and • Bailers

Please provide this documentation as soon as possible so I can continue my review.

Thanks in advance,

Eric Kuhlman

Environmental Protection Engineer Leaking UST Section

State of Illinois • CONFIDENT IALITY NOTICE: The informat ion conta ined in this communication is confidential, may be attorney -client privileged or attorney work product, may constitute inside informat ion or internal del iberative staff communicat ion, and is intended only for the use of the addressee. Unauthorized use. disclosure or copying of this communica tion or any part thereof is strictly prohibited and may be unlawful. If you have received this commun ication in error, please notify the sender immediately by return

3



e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does nol waive attorney-client privilege, attorney work product privilege, or any other exemption from disclosure.


Kuhlman Eric

From: Sent: To: Subject:

Marvin & Eric,


Duane Doty <[email protected]> Thursday, April 13, 2017 4:13 PM 'Marvin Johnson'; Kuhlman, Eric {External) RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

The rates relative to the equipment listed below were approved as a Stage 1 Actual Cost on February 9, 2016 except for the camera which was denied because no photos had been submitted to IEPA. The same rates were again approved on March 20, 2016 as part of a proposed Stage 2 Site Investigation Plan Budget. IEPA modified a Technician t hourly rate in its May 20, 2016 decision, but made no modification to any of the proposed equipment rates. The same rates were reimbursed as Stage 1 Site Investigation costs incurred on July 19, 2016. The rates included in the Stage 2 Site Investigation Actual Costs and

Stage 3 Site Investigation Plan Budget submitted on 12/30/2016 are consistent with the budgets, actual costs and reimbursed costs deemed reasonable by IEPA on February 2, 2016, May 20, 2016 and July 19, 2016. IEPA's action to deem the rates included in the 12/30/2016 submittal as reasonable and eligible for reimbursement three times in less than a year prior should provide ample justification.

In addition, in Knapp Oil Co. v. IEPA, PCB 16·103 (September 22, 2016) the Board ruled the $30/day camera rate is reasonable and does not violate the Act or Board regulations.

In Malkey v. IEPA. PCB 92-104 the Board ruled a PIO daily rate of $142/day is a reasonable cost for reimbursement from the Fund.

Hopefully, the above satisfies Eric's inquiry. If not, can you {Eric) offer some Insight regarding what kind of ''justification" you're looking for in regard to the 12/30/2016 submittal that wasn't offered In the previous budgets, actual cost summaries and claims IEPA approved/reimbursed in February, May and July of the same year?

I've noticed there have been multiple requests by IEPA lately to justify equipment rates it has considered reasonable for over a decade(s}. It's my understanding this has choked the docket with appeals concerning equipment rates and that the lack of such rates in Subpart H is routinely identified by IEPA as justification for the rash of requests. If the Issue is rooted in the lack of equipment rates in Subpart H, why isn't it be resolved through the rule making process instead of attempting to resolve it through the IPCB appeal process? Or, is it? It appears that if Subpart H were revised to include equipment rates, the issue would not only be resolved, but would also provide consistency for both the 0/0 and IEPA. However, I'm not aware of any such action. Is IEPA in the process of addressing this issue with the Board as a rule making effort?

Also, it's my understanding IEPA has determined a rate for each piece of equipment/material listed in the email below it {IEPA) will approve without justification from the 0/0 or its Consultant. If IEPA

already has a rate it's willing to approve as reasonable, why doesn't it (IEPA) just modify the rate like it modified the Technician I rate in its May 20, 2016 decision letter? Or somehow make these "new rates"



known so we (O/Os & IEPA) can be more streamlined In preparing, reviewing and approving budget,

actual costs and claims?

From: Marvin Johnson [mailto:[email protected]] Sent: Thursday, April 13, 2017 12:48 PM To: Duane Doty <[email protected]> Subject: Fwd: IL Pitstop in McLeansboro -- LUST incident #2013 0S69

Sent from my iPhone



From: "Kuhlman, Eric" <[email protected]> Date: April 13, 2017 at 11:10:48 AM CDT To: Marvin Johnson <[email protected]> Subject: IL Pitstop in McLeansboro - LUST Incident #2013 0569

Marvin, I'm in the process of reviewing your latest submittal for the above-mentioned site, I determined that you'll need to justify the following rates with additional documentation:

• PIO, • Water level indicator, • Survey equipment, and • Bailers

Please provide this documentation as soon as possible so I can cont inue my review.

Thanks in advance,

Eric Kuhlman Environmental Protection Engineer Leaking UST Section

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged or at1orney work product.

2



Kuhlman, Eric

From: Sent: To:

Duane Doty <[email protected]> Friday, April 14, 2017 11:18 AM Kuhlman. Eric

Cc: 'Marvin Johnson' Subject: RE: [External} RE: IL Pitslop in McLeansboro -- LUST incident #2013 0569

I'm not sure Chase provided II Pitstop a quote to complete the scope of work it (IL Pitstop) proposed in the CAP. I don't think that doing so is a common practice. Will a copy of an invoice documenting II Pitstop has recently incurred (and been reimbursed) the same rates suffice? That would certainly take less time than preparing a quote and a copy of a recent invoice from its Consultant documenting rates identical to those II Pitstop proposed in its budget should support that it's reasonable to conclude that these same rates will again be incurred to complete the scope of work proposed in the CAP. Or, is there some question that IL Pitstop will actually incur these rates during completion of the proposed scope of work?

I apologize for the confusion. Providing an 0/0 with a quote to complete a scope of work proposed in a CAP seems like an unusual request to me.

Thanks

From: Kuhlman, Eric [mailto:[email protected]] Sent: Friday, April 14, 2017 9:34 AM To: Duane Doty <[email protected]> Cc: Marvin Johnson <[email protected]> Subject: RE: [External] RE: IL Pitstop in McLeansboro·· LUST incident #2013 0569

Duane, all I need is a quote for your PID and your survey equipment?

From: Duane Doty [mailto:[email protected]] Sent: Thursday, April 13, 2017 4:13 PM To: 'Marvin Johnson'; Kuhlman, Eric subject: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Marvin & Eric,

The rates relative to the equipment listed below were approved as a Stage 1 Actual Cost on February 9, 2016 except for the camera which was denied because no photos had been submitted to IEPA. The same rates were again approved on March 20, 2016 as part of a proposed Stage 2 Site Investigation Plan Budget. IEPA modified a Technician I hourly rate in its May 20, 2016 decision, but made no modification to any of the proposed equipment rates. The same rates were reimbursed as Stage 1 Site Investigation costs incurred on July 19, 2016. The rates included in the Stage 2 Site Investigation Actual Costs and Stage 3 Site Investigation Plan Budget submitted on 12/30/2016 are consistent with the budgets, actual costs and reimbursed costs deemed reasonable by IEPA on February 2, 2016, May 20, 2016 and July 19,

1



2016. IEPA's action to deem the rates included in the 12/30/2016 submittal as reasonable and eligible for reimbursement three times in less than a year prior should provide ample justification.

In addition, in Knapp Oil Co. v. IEPA. PCB 16-103 (September 22, 2016) the Board ruled the $30/day camera rate is reasonable and does not violate the Act or Board regulations.

In Malkey v. IEPA. PCB 92-104 the Board ruled a PID daily rate or $142/day is a reasonable cost for

reimbursement from the Fund.

Hopefully, the above satisfies Eric's inquiry. If not. can you (Eric) offer some insight regarding what kind of "justification" you're looking for in regard to the 12/30/2016 submittal that wasn't offered in the previous budgets, actual cost summaries and claims IEPA approved/reimbursed in February, May and

July of the same year?

I've noticed there have been multiple requests by IEPA lately to justify equipment rates it has considered reasonable for over a decade(s). It's my understanding this has choked the docket with appeals concerning equipment rates and that the lack of such rates in Subpart H is routinely identified by IEPA as justification for the rash of requests. lf the issue is rooted in the lack of equipment rates in Subpart H, why isn't it be resolved through the rule making process instead of attempting to resolve it through the IPCB appeal process? Or, is it? It appears that if Subpart H were revised to include equipment rates, the issue would not only be resolved. but would also provide consistency for both the 0/0 and IEPA. However, I'm not aware of any such action. Is IEPA in the process of addressing this

issue with the Board as a rule making effort?

Also, it's my understanding IEPA has determined a rate for each piece of equipment/material listed in the email below it (IEPA) will approve without just ification from the 0/0 or its Consultant. If IEPA already has a rate it's willing to approve as reasonable, why doesn't it (!EPA) just modify the rate like it modified the Technician I rate in its May 20, 2016 decision letter? Or somehow make these "new rates" known so we {0/0s & !EPA) can be more streamlined in preparing, reviewing and approving budget,


From: Marvin Johnson [mailto:[email protected]]

Sent: Thursday, April 13, 2017 12:48 PM To: Duane Doty <[email protected]> Subject: Fwd: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Sent from my iPhone

Marvin Johnson Chase Environmental Group

Cell: 618-322-8935

Begin forwarded message: 2


From: "Kuhlman , Eric" <Eric.Kuhlman@ lll inois.gov> Date: April 13, 2017 at 11:10:48 AM CDT

To: Marvin Johnson <[email protected]>


Subject: IL Pitstop in Mc Leansboro - LUST incident #2013 0569

Marvin, I'm In the process of reviewing your latest subm ittal for the above-mentioned

site, I determ ined that you'll need to justify the following rates w ith additional documentation:

• PIO, • Water level indicator,

• Survey equipmen t, and • Bailers

Please provide this documentation as soon as possible so I can continu e my rev iew.

Thanks In advance,

Eric Kuhlman

Environmenta l Protection Engineer

Leaking UST Section

State of Illinois • CONF IDENT IALITY NOTICE: The information contained in this communication is confidential, may be attorney-c lient privileged or attorney work product , may constitute inside information or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthor ized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privi lege, attorney work product privilege, or any other exemption from disclosure.

J



Kuhlman, Eric

From: Sent: To:

Duane Doty <[email protected]> Friday, April 14, 2017 12:08 PM Kuhlman, Eric

Cc: 'Marvin Johnson' Subject: RE: [External] RE: IL Pitstop in McLeansboro •• LUST incident #2013 0569

Ok. There should be one in the reimbursement claim that IEPA reimbursed just a few months ago. I'll send you a copy

From: Kuhlman, Eric [mailto:[email protected]] Sent: Friday, April 14, 2017 11:38 AM To: Duane Doty <[email protected]> Subject: RE: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Even better, a copy of an invoice will do nicely. Thank you

From: Duane Doty [mailto:[email protected]] Sent: Friday, April 14, 2017 11:18 AM To: Kuhlman, Eric Cc: 'Marvin Johnson' Subject: RE: [External] RE: IL Pitstop in McLeansboro •• LUST incident #2013 0569

I'm not sure Chase provided If Pitstop a quote to complete the scope of work it (IL Pitstop) proposed in the CAP. I don't think that doing so is a common practice. Will a copy of an invoice documenting II Pitstop has recently incurred (and been reimbursed) the same rates suffice? That would certainly take less time than preparing a quote and a copy of a recent invoice from its Consultant documenting rates identical to those II Pitstop proposed in its budget should support that it's reasonable to conclude that these same rates will again be incurred to complete the scope of work proposed in the CAP. Or, is there some question that IL Pitstop will actually incur these rates during completion of the proposed scope of work?


Thanks

From: Kuhlman, Eric [mailto:[email protected]) Sent: Friday, April 14, 2017 9:34 AM To: Duane Doty <[email protected]> Cc: Marvin Johnson <[email protected]> Subject: RE: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Duane, all I need is a quote for your PIO and your survey equipment?


From: Duane Doty [mailto:[email protected]] Sent: Thursday, April 13, 2017 4:13 PM To: 'Marvin Johnson'; Kuhlman, Eric


Subject: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Marvin & Eric,

The rates relative to the equipment listed below were approved as a Stage 1 Actual Cost on February 9, 2016 except for the camera which was denied because no photos had been submitted to IEPA. The same rates were again approved on March 20, 2016 as part of a proposed Stage 2 Site Investigation Plan Budget. IEPA modified a Technician I hourly rate in its May 20, 2016 decision, but made no modification to any of the proposed equipment rates. The same rates were reimbursed as Stage 1 Site Investigation costs incurred on July 19, 2016. The rates included in the Stage 2 Site Investigation Actual Costs and Stage 3 Site Investigation Plan Budget submitted on 12/30/2016 are consistent with the budgets, actual costs and reimbursed costs deemed reasonable by IEPA on February 2, 2016, May 20, 2016 and July 19, 2016. IEPA's action to deem the rates included in the 12/30/2016 submittal as reasonable and eligible for reimbursement three times in less than a year prior should provide ample justification.

In addition, in Kna1;m Oil Co. v. IEPA. PCB 16-103 (September 22, 2016) the Board ruled the $30/day camera rate is reasonable and does not violate the Act or Board regulations.

In Malkey v. IEPA. PCS 92-104 the Board ruled a PIO daily rate of $142/day is a reasonable cost for


Hopefully, the above satisfies Eric's inquiry. If not, can you (Eric) offer some insight regarding what kind of "justification" you're looking for in regard to the 12/30/2016 submittal that wasn't offered in the previous budgets, actual cost summaries and claims IEPA approved/reimbursed in February. May and


I've noticed there have been multiple requests by IEPA lately to justify equipment rates it has considered reasonable for over a decade(s). It's my understanding this has choked the docket with appeals concerning equipment rates and that the lack of such rates in Subpart H is routinely identified by IEPA as justification for the rash of requests. If the issue is rooted in the lack of equipment rates in Subpart H, why isn't it be resolved through the rule making process instead of attempting to resolve it through the IPCB appeal process? Or, is it? It appears that if Subpart H were revised to include equipment rates, the issue would not only be resolved, but would also provide consistency for both the 0/0 and IEPA. However, I'm not aware of any such action. Is IEPA in the process of addressing this Issue with the Board as a rule making effort?

Also, it's my understanding IEPA has determined a rate for each piece of equipment/material listed in the email below it (IEPA) will approve without justification from the 0/0 or Its Consultant. If IEPA already has a rate it's willing to approve as reasonable, why doesn't it (IEPA) just modify the rate like it modified the Technician I rate in its May 20, 2016 decision letter? Or somehow make these "new rates" known so we {O/Os & IEPA) can be more streamlined in preparing, reviewing and approving budget.


2



Kuhlman, Eric

From: Sent: To:

Duane Doty <[email protected]> Friday, April 14, 20171:13 PM Kuhlman, Eric

Cc: 'Marvin Johnson' Subject: Attachments:

AE: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569 CEG Invoice #2401 O.pdf

Attached is a copy of the Chase Environmental Group, Inc. Invoice #24010 to IL Pit Stop, LLC for completion of the Stage 1 Site Investigation. The invoice was included in the reimbursement application !EPA reimbursed last July. You'll find the rates for PIO, water level indicator, survey equipment and bailers are the same as those summarized in the Stage 2 Site Investigation Plan Budget you modified on May 20, 2016 and the same as those summarized in the Stage 2 Cost Summary and proposed in the Stage 3 Budget received by IEPA on December 30, 2016 (currently under IEPA review). Therefore, it is reasonable to conclude that IL Pit Stop, LLC will incur costs based on the same rates to complete the scope of work proposed in the Stage 3 Site Investigation Plan you (IEPA) are currently reviewing (FYI-My reference to a CAP in the email below was in error. I should have referenced the Stage 3 Site Investigation Plan).

Thanks for your cooperation & have a great weekend.

From: Kuhlman, Eric [mallto:[email protected]] Sent: Friday, April 14, 2017 11:38 AM To: Duane Doty <[email protected]> Subject: RE: (External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569


From: Duane Doty [mailto:[email protected]] Sent: Friday, April 14, 2017 11:18 AM To: Kuhlman, Eric Cc: 'Marvin Johnson' Subject: RE: [External) RE: [L Pitstop in McLeansboro -- LUST incident #2013 0569

I'm not sure Chase provided II Pitstop a quote to complete the scope of work it (IL Pitstop) proposed in the CAP. I don't think that doing so is a common practice. Will a copy of an invoice documenting II Pitstop has recently incurred (and been reimbursed) the same rates suffice? That would certainly take less time than preparing a quote and a copy of a recent invoice from its Consultant documenting rates identical to those II Pitstop proposed in its budget should support that it's reasonable to conclude that these same rates will again be incurred to complete the scope of work proposed in the CAP. Or, is there some question that IL Pitstop will actually incur these rates during completion of the proposed scope of work?


1


Thanks

From: Kuhlman, Eric (mailto:[email protected] Sent: Friday, April 14, 2017 9:34 AM To: Duane Doty <[email protected]> Cc: Marvin Johnson <[email protected]>


Subject: RE: [External) RE: IL Pitstop in McLeansboro·· LUST incident #2013 0569


From: Duane Doty [mailto:[email protected]] Sent: Thursday, April 13, 2017 4:13 PM To: 'Marvin Johnson'; Kuhlman, Eric Subject: [External] RE: IL Pitstop in McLeansboro -- LUST Incident #2013 0569

Marvin & Eric,

The rates relative to the equipment listed below were approved as a Stage 1 Actual Cost on February 9, 2016 except for the camera which was denied because no photos had been submitted to IEPA. The same rates were again approved on March 20, 2016 as part of a proposed Stage 2 Site Investigation Plan Budget. IEPA modified a Technician I hourly rate in its May 20, 2016 decision. but made no modification to any of the proposed equipment rates. The same rates were reimbursed as Stage 1 Site Investigation costs incurred on July 19, 2016. The rates included in the Stage 2 Site Investigation Actual Costs and Stage 3 Site Investigation Plan Budget submitted on 12/30/2016 are consistent with the budgets, actual costs and reimbursed costs deemed reasonable by IEPA on February 2, 2016, May 20, 2016 and July 19, 2016. IEPA's action to deem the rates included in the 12/30/2016 submittal as reasonable and eligible for reimbursement three times in less than a year prior should provide ample justification.

In addition, in Knapp Oil Co. v. IEPA, PCB 16-103 (September 22, 2016) the Board ruled the $30/day

camera rate is reasonable and does not violate the Act or Board regulations.

In Malkey v. IEPA, PCB 92·104 the Board ruled a PIO daily rate of $142/day is a reasonable cost for


Hopefully, the above satisfies Eric's inquiry. If not, can you {Eric) offer some insight regarding what kind

of "justification" you're looking for in regard to the 12/30/2016 submittal that wasn't offered in the previous budgets, actual cost summaries and claims IEPA approved/reimbursed in February, May and


I've noticed there have been multiple requests by IEPA lately to justify equipment rates it has considered reasonable for over a decade(s). It's my understanding this has choked the docket with appeals concerning equipment rates and that the lack of such rates in Subpart H is routinely identified by IEPA as justification for the rash of requests. If the issue is rooted in the lack of equipment rates in Subpart H, why isn't it be resolved through the rule making process instead of attempting to resolve it through the IPCB appeal process? Or, is it? It appears that if Subpart H were revised to include equipment rates, the issue would not only be resolved, but would also provide consistency for both the

2



0/0 and IEPA. However, I'm not aware of any such action. Is IEPA in the process of addressing this issue with the Board as a rule making effort?

Also, it's my understand ing IEPA has determined a rate for each piece of equipment/mater ial listed in the email below it (IEPA) will approve without justification from the 0/0 or its Consultant. If IEPA already has a rate it's willing to approve as reasonable, why doesn't it (IEPA) just modify the rate like it modified the Technician I rate in its May 20, 2016 decision letter? Or somehow make these "new rates" known so we (0/0s & IEPA) can be more streamlined in preparing, reviewing and approving budget, actua l costs and claims?

From: Marvin Johnson [mailto :mjo [email protected]] Sent: Thursday, April 13, 2017 12:48 PM To: Duane Doty <[email protected]> Subject: Fwd: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Sent from my iPhone



From: "Kuhlman, Eric" <[email protected]> Date: April 13, 2017 at 11:10:48 AM CDT To: Marvin Johnson <miohnson@chaseenv .com> Subject: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Marvin, I'm in the process of reviewing your latest submittal for the above-mentioned site, I determined that you'll need to justify the following rates with additional documentation :

• PID, • Water level indicator, • Survey equipment , and • Bailers

Please prov ide this documentation as soon as possible so I can continue my review.

Thanks in advance,

Eric Kuhlman

3


Environmental Protection Engineer Leaking UST Section


State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attomey-clienl privileged or attorney work product, may constitute inside information or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any other exemption from disclosure.



<egCHASE Environmental Group JNc. Waste Management and Remediation Services

INVOICE

IN'CLUDE COPY OF INVOICE WITH REMilTANCE TO:

To: Il.. Pit Stop, I.LC Iuvoice# 24010 POBox27 P.rojcct# TJ303020 McLeansboro, IL 62859 McLeansboro Pit Stop

211 B. Randolph

.Dau:sof 07 /:13/2013 to 08/31/2015 McLeansboro, IL 62859

Wolk: Hamilitoa. County Tenns: NetSODays Date: 08/31/15

INCLUDE COPY OF INVOICE WITH REMl'fTANCE TO: P.O. Box AB Cent:Ialia, IL 62801

CEG Contact Person for This Project is Marvin Johttson.

1. Drilling Costs: 2. Analytical Costs: 3. Retnediatlon & Disposal Costs: 4. Consulting Personnel Costs - as broken down on the Coosul.l:hlg

Pci:soo.nd Costs fo.a:n. 5. Consultant's Mate.rial Costs - as brokexl down on the Consultants

Matetial Costs fo.tm. 6. Handling~

$3,189.11 $2.133.85 $1,548.95 $10,576.74

$1,015.41

$31.70

"1\n,ll Due : S IS,.t95.7<,

Payment Polley - Invoices not remitted by prescribed due date will be assessed a 1.5% late fee per month un1il payment is received.

We Appreciate Your Business I

www.chaseenv.com • 618 .533 .6740 • 618.533.6741 fax P.O Box AB • Centralia, n.. 62801



Consultant's Materials Costs Form

Materials, Equipment. or Flefd Purchase f Tlmeor I Rate($) I ·untt I Total Amount Used Cost

Ramedlation Category I Descriptlon/Justlftcation

M!leage I 444.ool .sel Milel $257.52

Slags 1-field j Stage 1 Site lnvesllgallon fleld adlviUes

PIO I 1.ool 1ss.ool oayl $135.00

Stage 1-Field I Soil hydrocarbon SC1'QE1nln9 and sample collection

water Level Indicator I 3.ool 30.ool Oayl $90.00

Stage 1-Field I Wei devefopmant. grounct-Nater sample collection. pump test (1 day each)

Survey Equipment I ,.ool 1so.ool Oayl $150.00

Stage 1-Fleld I wetl riser/groundWatW survey

Pump Test Eq\.lipment . ' I 1.ool 1so.ool oayl $150.00

Stage i-Fie!d I Pump test at monltortlng well MW-3

Ballar I s.ool 25.ool Eachl $125.00

St.age 1-Fiald I VVel! development and greundwal2r sample colleclfon

Zip Lode Bags ··1 12.00 I .251 Eadll $3.00

Stage 1-Fiekl { Soll hydrocamon screening

Latex Gloves I 82.001 .401 Eaehl $32.SO

Stage 1-Flold I Soil hydrcc:arbon sc:tNnlng, sample coPeclion, weD developm~ pc.imp test



Materials, Equipment, or Field Purchase I Tlmeor I Rate($} I Unit I Total Amount Used Cost

Remediation Category I Oescrlptlon/Justlflcatlon

Ice I 1.ool 12.ool LSI $12.09

Stage 1-Fleld I sample preservation and shipment

Coples I :tool 30.ool EacJil $60.oo

Stage 1-Pay I Prep. Stage 1 Site Investigation Relmbursement Application for 0/0 & !EPA (1 eael'I)

[ Total of Consultant Malerlals Costs I $1,015.41 I



Kuhlman, Eric

From: Sent: To:

Duane Doty <[email protected]> Friday, April 14, 2017 6:00 PM Kuhlman, Eric

Cc: 'Marvin Johnson' Subject: RE: [External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Chase does not rent or subcontract the equipment your questioning.

From: Kuhlman, Eric [mailto:[email protected]) Sent: Friday, April 14, 2017 1:33 PM To: Duane Doty <[email protected]> Subject: RE: (External] RE: IL Pltstop in McLeansboro -- LUST incident ff2013 0569

I misunderstood you, I thought it was an invoice from a subcontractor or a rental facility. The whole point of this exercise was to determine the fair-market rate for the use of your equipment, that's why I need a 3rd party estimate, invoice, or rental receipt.

From: Duane Doty [mailto:[email protected]] Sent: Friday, April 14, 2017 1:13 PM To: Kuhlman, Eric Cc: 'Marvin Johnson' Subject: RE: [External] RE: IL Pltstop in McLeansboro -- LUST incident #2013 0569

Attached is a copy of the Chase Environmental Group, Inc. Invoice #24010 to IL Pit Stop, LLC for completion of the Stage 1 Site Investigation. The invoice was included in the reimbursement application IEPA reimbursed last July. You' ll find the rates for PID, water level indicator, survey equipment and bailers are the same as those summarized in the Stage 2 Site Investigation Plan Budget you modified on May 20, 2016 and the same as those summarized in the Stage 2 Cost Summary and proposed in the Stage 3 Budget received by IEPA on December 30, 2016 (currently under IEPA review). Therefore, it is reasonable to conclude that IL Pit Stop, LLC will incur costs based on the same rates to complete the scope of work proposed in the Stage 3 Site Investigation Plan you (IEPA) are currently reviewing {FYI-My reference to a CAP in the email below was in error. I should have referenced the Stage 3 Site Investigation Plan).

Thanks for your cooperation & have a great weekend.

From: Kuhlman, Eric [mailto:[email protected]] Sent: Friday, April 14, 2017 11:38 AM To: Duane Doty <[email protected]> Subject: RE: (External] RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569


1


From: Duane Doty [mailto:[email protected]] Sent: Friday, April 14, 2017 11:18 AM To: Kuhlman, Eric Cc: 'Marvin Johnson'


Subject RE: [External) RE: IL Pitstop In McLeansboro·· LUST Incident #2013 0569

I'm not sure Chase provided II Pitstop a quote to complete the scope of work it (IL Pitstop) proposed in the CAP. I don't think that doing so is a common practice. Will a copy of an invoice documenting II Pitstop has recently incurred (and been reimbursed) the same rates suffice? That would certainly take less time than preparing a quote and a copy of a recent invoice from its Consultant documenting rates ident ical to those II Pitstop proposed in its budget should support that it's reasonable to conclude that these same rates will again be incurred to complete the scope of work proposed In the CAP. Or, is there some question that IL Pitstop will actually incur these rates during completion of the proposed scope of

work?


Thanks

From: Kuhlman, Eric [mailto :[email protected]) Sent: Friday, April 14, 2017 9:34 AM To: Duane Doty <[email protected]> Cc: Marvin Johnson <[email protected]> Subject: RE: [External) RE: IL Pitstop in McLeansboro -- LUST incident #2013 0569


From: Duane Doty [mailto:[email protected]] Sent: Thursday, April 13, 2017 4:13 PM To: 'Marvin Johnson'; Kuhlman, Eric Subject: [External] RE: IL Pltstop in McLeansboro -- LUST incident #2013 0569

Marvin & Eric,

The rates re lat ive to the equipment listed below were approved as a Stage 1 Actual Cost on February 9, 2016 except for the camera which was denied because no photos had been submitted to !EPA. The same rates were again approved on March 20, 2016 as part of a proposed Stage 2 Site Investigation Plan Budget. !EPA modified a Technician I hourly rate in its May 20, 2016 decision, but made no modification to any of the proposed equ ipment rates. The same rates were reimbursed as Stage 1 Site Investigation costs incurred on July 19, 2016. The rates included in the Stage 2 Site Investigation Actual Costs and Stage 3 Site Investigation Plan Budget submitted on 12/30/2016 are consistent with the budgets, actual costs and reimbursed costs deemed reasonable by !EPA on February 2, 2016, May 20, 2016 and July 19, 2016. IEPA's action to deem the rates included in the 12/30/2016 submittal as reasonable and eligible for reimbursement three times in less than a year prior should provide ample justification.

2



In addition, in Knapp Oil Co. v. IEPA. PCB 16-103 (September 22, 2016) the Board ruled the $30/day camera rate is reasonable and does not violate the Act or Board regulations.

In Malkey v. IEPA, PCB 92-104 the Board ruled a PIO daily rate of $142/day is a reasonable cost for reimbursement from the Fund.

Hopefully, the above satisfies Eric's inquiry. If not, can you (Eric) offer some insight regarding what kind of "justification" you're looking for in regard to the 12/30/2016 submittal that wasn't offered in the previous budgets, actual cost summaries and claims IEPA approved/reimbursed in February, May and July of the same year?

I've noticed there have been multiple requests by IEPA lately to justify equipment rates it has considered reasonable for over a decade(s). It's my understanding this has choked the docket with appeals concerning equipment rates and that the lack of such rates in Subpart H is routinely identified by IEPA as justification for the rash of requests. If the issue is rooted in the lack of equipment rates in Subpart H, why isn't it be resolved through the rule making process instead of attempting to resolve it through the IPCB appeal process? Or, is it? It appears that if Subpan H were revised to include equipment rates, the issue would not only be resolved, but would also provide consistency for both the 0/0 and IEPA. However, I'm not aware of any such action. Is IEPA in the process of addressing this issue with the Board as a rule making effort?

Also, it's my understanding IEPA has determined a rate for each piece of equipment/material listed in the email below it (IEPA) will approve without justification from the 0/0 or its Consultant. If IEPA already has a rate it's willing to approve as reasonable, why doesn't it (IEPA) just modify the rate like it modified the Technician I rate in its May 20, 2016 decision letter? Or somehow make these "new rates" known so we (O/Os & IEPA) can be more streamlined in preparing, reviewing and approving budget, actual costs and claims?

From: Marvin Johnson [mai1to:[email protected] Sent: Thursday, April 13, 2017 12:48 PM To: Duane Doty <[email protected]>

Subject: Fwd: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Sent from my !Phone



From: "Kuhlman, Eric" <[email protected]> Date: April 13, 2017 at 11:10:48 AM CDT

3



To: Marvin Johnson <[email protected]> Subject: IL Pitstop in McLeansboro -- LUST incident #2013 0569

Marvin, I'm in the process of reviewing your latest submittal for the above-mentioned site, I determined that you' ll need to justify the following rates with additional documentation :

• PID, • Water level indicator, • Survey equipment, and • Bailers

Please provide this documentation as soon as possible so I can continue my review.

Thanks in advance,

Eric Kuhlman Environmental Protection Engineer Leaking UST Section

State of Illinois - CONFIDENTIALITY NOTICE: The information contained in this communication is confidential, may be attorney-client privileged or attorney work product. may constitute inside information or internal deliberative staff communication, and is intended only for the use of the addressee. Unauthorized use, disclosure or copying ol this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify the sender immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Receipt by an unintended recipient does not waive attorney-client privilege, attorney work product privilege, or any other exemption from disclosure.

4



IEPA • DIVISION or-RECOROS MANAGEMENT REl.EASABLE

LEAKING UST TECHNICAL REVIEW NOTES MAY O 12017

Reviewed by: Eric Kuhlman

Dute Reviewed: 4-20-2017

Document(s) Reviewed:

S3 SIP/ S3 BUD/ S2 AC

General Site Information:

IEMA date(s): 5-15-2013 UST S).'.Stem removed? (YIN~: Y Encountered groundwater? (YIN/U):

Free product? (YIN/unknown}: N

Current/past land use: gas slation / convenience store

Re:

y

. f::?E\OEWER: ROH LPC #0650205017 ·- Haniirton C'ouncy Mcl.eanboro / IL Pitslop LLC 21 I East Randolph Leaking UST Incident No. #20130569 Leaking UST Technical File

1te su 11ect to: s· b' 734 Paxment from the Fund? (YIN/unknown): Y OSFM Fac.10#: 7-006710 SW AP mapping and evaluation completion date: 1-28-2016 Site placement correct in SWAP? (YIN): N

MTBE > 40 ppb in groundwater? (YIN/unknown): Y

Size & product of USTs: ( 1) 2,000-gallon gasoline Is Sile localed in EJ area? N Is investigation of indoor inhalation exposure

route reQuired? U

BOL File lnformation:(optional) (Arranged chronologicalJy):

On 7-24-2000, n release was reported to lEMA and assigned LUST Incident #20001390.

On 9-6-2000, two (2) underground storage tanks (USTs) were removed from this site, included one (I) 8,000-gallon gasoline rank and one (I) 4,000-gallon gasoline tank.

On 5-15-2013, a gasoline release was reponed to IEMA and assigned LUST Incident #20130569.

On 6-10-2013, one (I) 2,000-gallon gasoline tank was removed from the subject property.

Between 6-10-20 J 3 and 6-11-2013, approximately 527 tons (351 cubic yards) of contaminated backfill material was transported and disposed off site. Six (6) soil samples were collected from the excavation walls (W-1 thru W-4} and floor IF-1, F-2}. then submitted for BETX/MTBE analysis. Analytical results indicate COCs > Tier l SROs for SCGI in W-2 7'(B).

On 6-13-2013, four (4) soil borings { Pl-1 thru Pl-4 l were advanced lo depths of 8 feet bgs. due to auger refusal. Groundwater was encountered m 7-8 feet bgs. Four (4) soil samples were c'ollec,ed and analyzed for BETXIMTBE. Analytical results indicate COCs > Tier I SROs for



Page2

CW Inh in Pl-1B 7'(BX), Pl-3A 3'(BX); R Inh in Pl-1B 7'(8), Pl-3A 3'(B); SCGI in PJ-18 7'(BEM), Pl-3A 3'(BEM}, Pl-3B 7'(B), Pl-4A 3'(8), PJ-4B T(B).

Berg Circular 532 defined this area as type "P' soil, de~cribed as relatively impermeable bedrock within 20 feet of surface, mostly overlain by till or other fine-grained materials.

On 7-22-2015, eight (8) soil borings IBH-1 thru BH-81 were advanced to depths ranging from 7-10 feet bgs around the former pump islands and along the property boundaries, five (5) borings were completed as monitoring well (MW-1 thru MW-51. Groundwater was encountered al 4.5-6.5 feet bg~. Twelve (12) soil samples were collected and submitted for BETX/MTBE analysis. Analytical.results indicate COCs > Tier I SROs for SCGI in BH-7A 2.S'(B), BH-8A 2.5'(BM).

On 7-27-2015, groundwater samples were collected from MW-I thru MW-5 und submitted for BETX/MTBE una)ysis. Analytical resulls indicated COCs > Tier I GROs for WCGI in MW-5(BM).

On 7-31-2016, a pump test was conduc1cd on MW-310 determine the site hydrnulic conductivity using Bouwer & Rice Method. Results indicated a hydraulic conductivity of 9.44 x 10·:'i cm/sec.

Site Investigation Plan/Budget Review Notes:

On I0-21-2016, five {5) soil borings were advanced until auger refusal lo depths of7-9 feet bgs. Groundwater was encountered at 5-7.5 feet bgs. Seven (7) soil samples were collected and submitted for BET?(IMTBE analysis. Analytical results indicate COCs < Tier I SR Os.

Chase proposed one ( 1) soil boring be advanced on the western adjacent property to define the extent of the soil contamination west of soil boring BH-8. Soil samples will be collected from each 5-foot interval and analyzed for BETX/MTBE.

Illinois EPA Decision:

The PM recommends the S3 Sl.P and S3 BUD be denied, while the S2 AC be modified ...

Response Due:

7-2-2016

EK:P\


S2BUO

S2AC

DEDUCTIONS

SUBTOTALS

Re:

Drilling Analysis Remediation

$ 2,063.21 $1,745.95 $ 619.57

s 2,049.73 $ 849.73 $ 619.57

$ $ $ -

s 2,049.73 $ 849.73 $ 619.57

LPC #0650205017 - - Hamilton County McLeansboro/ IL PiL-;top, LLC 211 East Randolph Street Leaking UST Incident No. #20130569 Leaking UST Technical File

Demolition & UST Removal Well Abandonment

$ . $

$ . $

$ $

$ . $

Consulting Personnel Materials

$ · 15,838.10 $ 1,171.80

$ 15,800.84 s· 1,034.57

$ 3,751.55 $ 90.00

s 12,049.30 $ 944.57

$16,512.90 ----;-$ 1,734.74 $ 30.00 $ 495.64 $ 30.00 $ 867.37 I 30.00 $ 4.96 $ 90.00 $ 625 .75 $ 2.72 $ 6.20 $ 0.37 $ 6.20 $ 3.45 $ 4.14

$ 3,751.55

$21,438.63

$20,354.44

$ 3,841.55

$ 16,512.90

r ""O ;:.: en -0 :0 r r 0 -""O 0 OJ z !) .... .....,

I c:, ....., ..::::! ~ .... c:, en


ll Pit Stop, LLC (PCB No. 17-077) R. 106

LPC 0650205017 - Hamilton County McLeansboro / Illinois Pitstop, LLC 211 East Randolph Street

1EPA • DIVISION OF0

RECOROS MANAGEMENT RELEASABLE

Leaking UST Incident No. #20130569 Leaking UST Technical File MAY O 1 2017

Right-to-Know Evaluation REVIEWER: ROH The Bureau of Lund Sile identified above h.1S been reviewed. A check mork next to 11ny one of the following cri1cria indicates funher evaluation of the site is necessary.

CRITERIA: n

fJ

D

f] .

0

0

n

Groundwater contamin:11ion is measured or modeled co excccd, within the setback zone or rcgululcd recharge are.i of a potable Community Water Supply (CWS) well. or setback r.one or a private well or non-CWS well. tither TACO Tier I groundwater remcdiiuion objcc1ivcs under Part 742, Appendix B. T:ihle E or Class I groundwater standards undt:r Pon 620; or O Five or fowcr pro~rtics O More than five properties

Measured off-site groundwa1cr contamination from volntilc chemicals from the site where 11 rekase occurred poses a threat of indoor inhalation exposure nbovc appropriate Tier I remediation objectives for the currcn1 use of the sih:; or D Fh·c or fewer propenies D More than five propcnics ·

Soil con111mina1ion exceeding applicahlc remediation objcc1ivcs for the soil component of the groundwater ingcscion route is modeled co exceed, within the setback zone or regulated recharge nrc::i of a pot.Jblc Community Water Supply (CWS) well, or setback zone of a private well or non-CWS well, either TACO Tier I groundwah:r remedial ion objectives under Pan 742. Appendix B. Table E or Class I groundwater standards under Pan 620; or ·o Five or fewer properties D More 1han live properties

Con1aminn1cd soil is measured off-si1c 10 exceed the appropriate Tier I remediation objectives based on the currenl use of the off-site propeny; or O Five or fewer properties D More 1hnn five pro.rxrtics

Measurc:d off-site soil gas con1amination from the site where the release occurred poses a threat of exposure above the appropriate Tier I rcmedi:ition objectives for the current use of 1hc site: or D Five or rewcr properties D More than live propenies

BOL refers o matter to the Division of Leg::il Counsel for enforcement under Section 43(a) of the Act: or

BOL refers a site to the Division of Legal Counsel for issuance of n scnl order under Section 34(a) of the Ac1.

CommenlS:

n Al least one of the above criteria is mc1 and the above-identified sire must be further evaluated.

Insufficient infonnntion submitted 10 mnke an adequa1c RTK decision.

[j None of the nbove cri1erin are met and 1he 11bove-iden1ilicd sire docs not wnmmt any funhcr evaluation.

Projecl Manager Signature:_1,,i~a::::"-'-l'~~e""'lt:!~1:::<;!:1!::• -=--- Da1e: '(- 2 0 .. ZOfr


•• IL Pit Stop, LLC (PCB No. 17-077) R. 107

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORlH GRAND AVENUE EAsT, P.O. Box 19276, SPRINGF1Et.O, ILtlNOIS 62794•9276 • (217) 782-3397

BRUCE RAUNER, GOVERNOR Alec MESSINA, DIRECTOR

217/524-3300

APR 28 2017

IL Pitstop, LLC Attn: Roger Swanz P.O. Box 27 McLeansboro, IUinois 62859

Re: LPC #0650205017 - Hamilton County McLeansboro / lL Pitstop, LLC 211 East Randolph Street Leaking UST Incident No.#20130569 Leaking UST Technical File

Dear Mr. Swartz:

CERTIFIED MAIL

701~ 2120 0002 3286 7449

The Ulinois Environmentnl Protection Agency (Ulinois EPA) has reviewed the Stage 3 Site Investigation Plan (plan) submitted for the above-referenced incident. This plan, daled December 28, 2016, was received by lhe Illinois EPA on December 30, 2016. Cilalions in this letter are from the Environmental Protection Act ( 4 l5 JLCS 5) (Act) l.lnd Title 35 of the Illinois Administrative Code (35 m. Adm. Code).

The plan and the assocfoted budget are rejected for the reason(s) listed in Attachment A and B, respectively (Sections 57.7(a)( I) and 57.7(c) of the Act and 35 Ill. Adm. Code 734.505 (b), 734.510(11) and 734.~ IO(b)).

The actual costs for Stage 2 are modified pursuant to Sections 57.7(a)(2) and 57.7(c) of the Act and 35 UL Adm. Code 734.505(b) and 734.SI0(b). Based on the modifications listed in Section 2 of Auachment C, the amounts listed in Section l of Attachment C are approved. Be aware that the amount of payment from the Fund may be limited by Sections 57.8(d), 57.8(e), and 57.B(g) of the Act. as well as 35 Ill. Adm. Code 734.630 and 734.655.

Pursuant to Sections 57.7(a) and 57. I 2(c) and (d) of the Act und 35 UI. Adm. Code 734.31 0, a revised plan and/or budget must be submitted within 60 days of the date of this leller to:

Illinois Environmental Protection Agency Bureau of Land - #24 Lenking Underground Storage Tunk Section l 021 North Gr.and A venue East Post Office Box 19276 Springfield, IL 62794·9276

.. l021'f, Moill 51.locktoNl, I~ 6ll0l(8 1S}911-1760 J95 5 . St-, l!fDlli, ll6012l IIM7}608-3131 21:is s. r.r11 s1.ch .... po1s,o,11.,112012,n2111..seoo 2CI09 .Moll s,.cor ....... 111,, It 6:12:M (618JJ.C6.Sl 20

9.'111 Hu,.._ St., Ou ,r....,._, n 60016 (84i'}29.C-4000 ,02 SWWo,lilftG'e,.St. Sult1 O,P•orio, It 6ld02(309)67 l.302.2 2JCW w. Mm si.. s,,11., t ,a, _,on, n. ~s, 1618)9PJ.noc> IOOW Qondo'..,., 51111110.l00,Gkooo,lt6060I



Page 2

Please submit all correspondence in duplicate and include the Re: block shown at the beginning of this letter.

An underground storage tank system owner or oper.ilor may appeal this decision lo the Ulinois Pollution Control Bourd. Appeal rights arc uttached.

If you have any questions or need further assistance, please contact the Illinois EPA project manager, Eric Kuhlman, al 2J7n85-5715.

Sincerely,

[ffV~~ Stephen A. Coluntino Acting Unit Manager Leaking Underground Stornge Tank Section Division of Remediation Management Bureau of Land

SAC:EK:P\

Attachment: A, B, C, Appeal Rights

c: Marvin Johnson, Chase Environmental Group. Inc. (e-copy)[email protected] BOL File



Attachment A

Re: LPC #0650205017 -- Hamilton County McLeansboro/ IL Pitstop, LLC 211 Ease Randolph Street Leaking UST Incident No. #20130569 Leaking UST Technical File

Citations in this attachment are from the Environmental Protection Act (415 ILCS 5) (Act) and Tille 35 of the Illinois Administrative Code (35 111. Adm. Code).

l. The Stage 2 site investigation must be designed to complete the identification of the extent of soil and groundwater contamination al the site that, as a result of the release, exceeds the most stringent Tier I remediation objectives of 35 Ill. Adm. Code 742 for the applicable indicator contamin.ints. The investigation of any off-site contamination must

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.· be conducted us part of the Stage 3 site investigation. (Section 57. l(a) of the Act and 35 Ill. Adm. Code 734.320)

Before any S11.1ge 3 sire i11ves1igatio11 should be conducred off-site to identify the ex1e11t of tile soil L·o111amirwtio11, additional soil sumpli11g .rho11/d be collected near the property boundary line in tire vicinity of soil bori11g BH-8 since the a11alyricai results/or BH-8 demonsmrred that tlie reporting limits were greater tlza11 the Tier J remediation objectives for rite applicable i11dicat0r coutamimmts. be11:.e11e a,u/ MTBE. Tlterefore, this /ocatio11 will need to be resampled to ,letermille if the 011sitc comamimuion has migmtcd offsite.

Please note thm any costs associated witlt tlte collection of this ,,d,litimwl soil sample are 11ot eligible for paymelll from the Fund since the original soil sample should !tave been at1alyt.ed using 1/ze approprime reportbig limit.'i.


IL Pit Stop, LLC (PCB No.17-077) R. 110

Attachment B

Re: LPC #0650205017 - Hamilton County McLeansboro/ lL Pitstop, LLC 211 East Randolph Street Leaking UST Incident No. #20130569 Leaking UST Technical File

Citations in lhis auuchmcnt are from the Environmental Protection Act (415 ILCS 5) (Act) and Title 35 of the Ulinois AdminisLmlivc Code (35 IIJ. Adm. Code).

I. Pursuant to Sections 57.7(c) of the Act and 35 Ill. Adm. Code 734.505(b), the associated budget is rejected for Lhc following reason:

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The Illinois EPA has not approved the plnn with which the budget is associated. Until such time as the plun is approved, a determination regarding lhe associated budget- i.e., u determination as to whether costs associated with materials, activities, and services arc reasonable; whether costs are consistent with the associated technical plan; whether costs will be incurred in the performance of corrective action activities; whether costs will not be used for corrective action activities in excess of those necessary to meet the minimum requirements of the Act and regulations, and whether costs exceed the maximum payment amounts sel forth in Subpart Hof 35 Ill. Adm. Code 734-cannot be made (Section 57. 7(c)(3) of the Act and 35 Ill. Adm. Code 734.SI0(b)).



Auachment C

Re: LPC #06502050)7 -- Hamilton County McLeansboro/ IL Pitstop, LLC 211 Eust Randolph Street Leaking UST Incident No. #20130569 Leaking UST Technical File

SECTION 1

ST AGE 2 Actual Costs

As a result of the Ulinois EPA's modifications in Section 2 of this Alt.tchment C, the following amounts ore approved:

$2,019.51 $849.73 $619.51

$0.00 $0.00

$12,049.30 $944.57

Drilling und Monitoring Well Costs Analytical Costs Remediation and Disposal Costs UST Removal and Abandonment Costs Paving, Demolition, and Well Abandonment Cosls Consulting Personnel Costs Consultant's Materials Costs

Handling charges will be determined at the time a billing package is reviewed by the Illinois EPA. The amount of allowable handling charges will be determined in accordance with Section 57. l (a) of the Environmental Protection Act (Act) and 35 Ulinois Administrative Code (35 Ill. Adm. Code) 734.635.

SECTION2

STAGE 2 Modifications

Note. Any costs associated with preparing, s11bmirti11g, reviewing, a11d certifyi11g the Stage I reimb11rsemem appficatio11 should not have been induded i11 the Surge 2 Ac:llml Costs.

1. $1.734. 74 for costs to consult 0/0 arc inconsistent with the associated technical plan. One of the overalJ goals of the financial review is Lo assure that costs associated with materials, activities, and services are consistent with the ussociated technical pion. Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 UI. Adm. Code 734.SIO(b).

Cm.·1s associated to co11s11lt tire 0/0 regard;,,g prosed scope of work, project stams and tentative sclredule were 1101 part of the msocit11ed plan. In llddi1io11, these casts are no1 rttasom1ble as submitted. Such costs t1re ineligible for paymelll from the Ftmd p11rs11m1t lo Secrio11 57. 7( c )( 3) of tlle Act m1d 35 Ill. Adm. Code 7 34.630( dd).



Besides. any costs related to activities, materials, or services not necessary to stop, minimize, eliminate, or clean up a rcrease of petroleum or its effects in accordance with the minimum requirements of lhe Act and regulations. Such costs are ineligible for payment from the Fund pursuant to 35 111. Adm. Code 734.630(y). In addition, such costs are not upproved pursuant to Section 57 .7(c)(3) of the Act because they are not site investigalion or corrective action costs.

Furthermore, the site investigation or corrective action costs to consult 0/0 that arc not reasonable as submitted. Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(dd).

2. $495.64 for costs for onsite meeting with 0/0 that are inconsistent with the associated plan. One of the overall goals of the financial review is to assure that costs associated with materials, activities, and services are consistent with the associated budget Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c){3) of the Act and 35 lll. Adm. Code 734.SI0(b).

Costs associated with o,1site 111eeti11g wirlt the 010 to reviewlevulrwte /EPA requested Stage 2 borfog & well /ocmio11s ivere not pan of the ussocimed plan. /11 addirion, these costs are not reasonable tis submitted. Such costs are ineligible for paymellt from the Fund pur.mcmt to Sectfou 57.7(c)(3J of the Acr ,md 35 Ill. Adm. Code 734.630(dd).

Besides, uny costs related co activities, materials, or services nol necessary to stop, minimize, eliminate, or clean up a release of petroleum or its effects in accordance with the minimum requirements of the Act and regulations. Such costs are ineligible for payment from the Fund pursuant to 35 UL Adm. Code 734.630{y). In addition, such costs are not approved pursuant to Section 57.7(c)(3) of the Act because they are not site investigation or corrective action costs.

Funhermore, the site investigation or corrective action costs to consult 0/0 that are not reasonable as submitted. Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(dd).

3. $867 .37 for costs for correspondence with 0/0 and IEPA that are inconsistent wilh the associated plan. One of the overall goals of the financial review is co assure that costs associated with materials, activities, and services are consistent with the associated budget Such costs are ineligible for payment from the Fund pursuanL to Section 57. 7( c )(3) of the Act nnd 35 Ill. Adm. Code 734 .5 J O{b ).

Costs associated will, correspo11de11ce with 010 cmd !EPA regardi11g buries utilities soml, of srore building were 1101 part of the ttssocia1ed pl,111. In addition. these ,·osJ.r are 1tot reC1som1b/e as submitted. Sue/, costs "re im:ligible for payme111 from 11,e Fune/ p11rs11t11ll 10 Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(ddJ.

Besides, any costs related 10 activities, materials, or services not necessary to slop, minimize, eliminate, or clean up a release of petroleum or its effects in accordance with



the minimum requirements of the Act and regulations. Such costs arc ineligible for payment from the Fund pursuum lo 35 UL Adm. Code 734.630(y). In addition, such costs are not approved pursuant to Section 57.7(c)(3) of the Act because they are not site investigation or corrective action costs.

Furthermore, the site investigation or corrective .iction costs to consult 0/0 that arc nOl reasonable as submiued. Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(dd).

4. The Senior Project Manager rate has been reduced to $123.91 per hour. The costs exceed the maximum payment amounts set forth in Subpan H, Appendix D, and/or Appendix E of 35 Ill. Adm. Code 734. Such costs are ineligible for payment from the Fund pursuant to 35 UL Adm. Code 734.630(zz). In addition, such costs arc not approved pursuant lo Section 57.7(c)(3) of the Act becnuse they nre not reasonable.

Based upon the above deduction, a total of$ 4.96 was deducted from Consulting Personnel Costs.

5. $250.30 for costs to consull 0/0 thut are inconsistent with the associated plan. One of the ovcrnll goals of the financial review is to assure that costs associated wilh materials, activities. and services are consistent wilh the associated budget. Such costs arc ineligible for payment from the Fund pursuant to Section 57. 7(c)(3) of the Act and 35 Ill. Adm. Code 734.5 IO(b).

Costs asl·ociated to consult the 0/0 reg(lrdiug revised scope of work a11d field schedule were not part of the associcued plcm. Ill c,ddi1io11, tlrese costs are 1101 reC1sollable as sttbmiued. S11ch costs are ineligible for payme11t from the F1111d pursuant to Section 57.7(c)(3) of the Act and 35 /JI. Adm. Code 734.630(dd).

Besides, any costs related to activities, materials. or services nol necessary to stop. minimize, eliminate, or clean up n release of petroleum or its effects in accordance with the minimum requirements of the Act and regulalions. Such costs are ineligible for payment from the Fund pursuant to 35 IJI. Adm. Code 734.630(y). In addition, such costs are not approved pursuanl lo Section 57.7(c)(3) of the Act because they are not site investigation or corrective action costs.

Furthermore, lhe site investigation or corrective action costs to consult 0/0 that are not reasonable as submiued. Such costs are ineligible for payment from the Fund pursu.inl to Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(dd).

6. $625.75 for costs for second onsite meeting with 0/0 that are inconsistent with the associated plan. One of the over.ill goals of the fimmciul review is to al:isure that costs associated with materials, activities. and services nre consistent with the associated budget. Such cosL~ are ineligible for payment from the Fund pursuant lo Section 57.7(c)(3) of the Act and 35 UL Adm. Code 734.5 IO(b).



Cost.,· e1ssociawd wiJ/1 a .fecmul 011site meeti11g with the 0/0 to reviewle1•a/1mte /EPA suggested altertutte drilling locatio11.,· were 1101 pan of tlte t1ssocil1ted p/<111. /11 addi1io11, tlresc costs are not reaso,wb/e ".s submitted. Sm:h costs are ineligible for paymem from 1/,e F1111d p11rs11a11110 Sectio11 57. 7(c)(3) of the Ac/ and 35 Ill. Adm. Cade 7 J4.630(dd).

Besides, any costs related to activities, materials. or services nol necessury to stop, minimize, eliminutc, or clean up a release or petroleum or its effects in occordunce with the minimum requirements of the Act and regulations. Such costs are ineligible for payment from the Fund pursuant to 35 IJI. Adm. Code 734.630(y). In addition, such costs are not approved pursuant to Section 57.7(c)(3) of the Act because they are not site investigation or corrective action costs.

Furthermore, the site investigation or correclivc action costs to consult 0/0 that are noL reasonable as submitted. Such costs ure ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 111. Adm. Code 734.630(dd).

7. The Geologist III rate has been reduced to$ I09.04 per hour. The costs exceed the maximum payment amounts set forth in Subpart H. Appendix D. and/or Appendix E of 35 Ill. Adm. Code 734. Such costs arc ineligible for payment from the Fund pursuant to 35 UI. Adm. Code 734.630(zz). In addition, such costs arc not approved pursuant to Section 57. 7(c)(3) of the Act because they are not reasonable.

Bused upon the above deduction, a total of$ 2.72 was deducted from Consulting Personnel Costs.

8 The Senior Project Manager ntte hus been reduced Lo $123.91 per hour. The costs exceed the maximum payment amounts set forth in Subpart H, Appendix D, nnd/or Appendix E of 35 lll. Adm. Code 734. Such costs are ineligible for paymcm from lhe Fund pursuant to 35 lll. Adm. Code 734.630(zz). In addition. such costs are nol upproved pursuant to Section 57.7(c)(3) of the Act because they are not reasonable.


9. The Senior Draftsperson/CAD r.ite has been reduced to $74.34 per hour. The costs exceed the maximum payment amounts set fonh in Subpart H, Appendix D, and/or Appendix. E of 35 Ill. Adm. Code 734. Such costs are ineligible for payment from the Fund pursuant to 35111. Adm. Code 734.630(zz). In addition, such cosLc; nre not approved pursuant to Section 57.7(c)(3) of the Act because they are not reasonable.

Based upon the above deduction. a total of$ 0.37 was deducted from Consulting Personnel Costs.

10. The Senior Project Manager rate has been reduced lo $123.91 per hour. The costs exceed lhe maximum payment amounts set forth in Subpart H, Appendix D, and/or Appendix E of 35 Ill. Adm. Code 734. Such costs are ineligible for payment from the Fund pursuant



to 35 Ill. Adm. Code 734.630(zz). In addition, such costs are not approved pursuant to Section 57.7(c)(3) of the Ac< because they nre not reasonable.

Based upon the above deduction, u total of$ 6.20 was deducted from Consulting Personnel Costs.

11. The Senior Account Technician rate has been reduced to $68.14 per hour. The costs e~ceed the maximum payment amounts set forth in Subpart H, Appendix D. and/or Appendix E of 35 Ill. Adm. Code 734. Such costs are ineligible for payment from the Fund pursuant to 35 111. Adm. Code 734.630(zz). In addition. such costs are not npproved pursuant to Section 57.7(c)(3) of the Act becuuse they ure not reasonable.


12. The Senior Account Technician rate has been reduced to S68. I 4 per hour. The costs exceed the maximum payment umounts set forth in Subpart H, Appendix D, and/or Appendix E of 35 llL Adm. Code 734. Such costs are ineligible for payment from the Fund pursuant to 35 Ill. Adm. Code 734.630(zz). In uddition, such costs are not upproved pursuant to Sec1ion 57.7(c)(3) of the Act because they are not reasonable.


13. .$90.00 for costs for digital camera that are inconsistent with the associated plan. One of the overall goals of the financial review is to assure that costs associated with materiuls, activities. and services are consistent with the associated lcchnical plan. Such costs are ineligible for payment from the Fund pursuant to Section 57.7(c)(3) of the Act and 35 m. Adm. Code 734.5 JO(b).

Co:ils Clssoci<ued with digiJa/ camera were 1101 part of the ussocimed plan. /11 e1ddition, these costs are 1101 reasonable as s11bmi1ted. Suclr costs ttre i11eligib/e for paymelll from the F1111d p11rs11a11t to Secao1157.7(c)(3) ofrhe Ac/ a11d 35 Ill. Adm. Code 734.630(dd).

Furthermore, the costs for the digiwl camem lack supporting documentation. Such costs .ire ineligible for payment from the Fund pursuant to 35 IJI. Adm. Code 734.630(cc). Since there is no supporting documenlalion of costs. lhe Illinois EPA cannot determine that costs will not be used for activities in excess of those necessary to meet the minimum requirements of Title XVI of the Act. Therefore, such costs are not approved pursuan, to Section 57.7(c)(3) of the Act because they may be used for site investigation or corrective action activities in excess of those required to meet the minimum requirements of Title XVI of the Act.

Pursuant to 35 UI. Adm. Code 734.850(b) costs associated with activities that do not have a maximum payment amount set forth pursuant to 35 IJI. Adm. Code 734 Subpan H must


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be detennined on a site specific basis and the owner/operator must demons1rate to the Agency the amounts sought for reimbursement are reasonable.

In addition. without supporting documentation the rutc requested the ,ligiwl cmnera is not rcnsonablc as submitted. Such costs arc ineligible for payment from the Fund pursuunt to Section 57.7(c)(3) of the Act and 35 Ill. Adm. Code 734.630(dd).



Appeul Rights

An underground stornge tank owner or opcr.ilor may appeal this final decision lo lhc Illinois Pollution Control Board pursuant to Sections 40 and S7.7(c)(4) of the Act by filing a petition for a hearing within 35 days after the date of issuance of the final decision. However. the 35-day period may be extended for a period of time not to exceed 90 days by written notice from the owner or operator and the Ulinois EPA within the initial 35-day appeal period. If the owner or opemtor wishes to receive a 90-day extension, a written requesc that includes a statement of 1he date the final decision was received, along with a copy of this decision, must be sent 10 the Illinois EPA as soon as possible.

For information regarding the filing of an appeal, please contact:

John Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, JL 6060 l 312/814-3620

For information regarding the tiling of an extension, please contact:

lllinois Environmental Protection Agency Division of Legal Counsel l021 North Grand A venue East Post Office Box 19276 Springfield, IL 62794-9276 211ns2-s544


CERTIFICATE OF SERVICE I, the undersigned, on affirmation state the following:

That I have served the attached CERTIFICATE OF RECORD ON APPEAL and the accompanying documents comprising the entire record of the Respondent’s decision by e-mail upon Patrick D. Shaw at the e-mail address of [email protected] and upon Hearing Officer Carol Webb at the e-mail address of [email protected]. That my e-mail address is [email protected]. That the number of pages in the e-mail transmission is one-hundred and twenty (120). That the e-mail transmission took place before 2:00 p.m. on the date of July 26, 2017. /s/Scott B. Sievers July 26, 2017


Documents

Electronic Filing: Received, Clerk's Office 7/26/2017