CHAPTER 4 - PARTNERSHIP EFFORTS WITH USEPA
The Illinois EPA, Federal Site Remediation Section and the U.S. EPA Region 5 Superfund Division
have an extremely close working relationship. This relationship has been effected by open
communication, the meeting of goals and commitments, the willingness of the Illinois EPA to
continue to place sites on the National Priorities List and the willingness of both agencies to pursue
mutual goals related to environmental remediation in the State of Illinois. Examples of this close
working relationship have been demonstrated by the Work Sharing Pilot Proposal and the Record
of Decision Review Protocol. The FSRS has also initiated a comprehensive program to incorporate
natural resource injury issues into the overall clean-up process.
THE WORK SHARING PILOT PROPOSAL
U.S. EPA Region 5 has long been recognized as having a very productive Superfund program. One
of the key reasons for this success has been Region 5’s recognition of the important role states
perform in support of the national Superfund effort. In that regard, Region 5 has invested
significant resources in developing and partnering with state programs. One of the key components
of this partnering effort has been work sharing.
During the past ten years, the Illinois EPA has undertaken several pilot initiatives with the U.S.
EPA. These pilot initiatives have enhanced the capability of Illinois to remediate NPL and "NPL-caliber"
sites. The goals of the Work Sharing Plot Proposal are to enhance Illinois EPA's and U.S.
EPA's capabilities to assure consistency with, and to effectively use CERCLA authorities at sites
subject to the work sharing agreements. Duplication of effort, which is often encountered when a
project is transferred from state enforcement leadership to federal enforcement leadership, is also
reduced by the work sharing agreements.
THE RECORD OF DECISION REVIEW PROTOCOL
In federal fiscal year 1999, a total of eight Superfund Records of Decision (RODs) were completed
for sites in Illinois. Of this total, the Illinois EPA was lead agency on four of the RODs, U.S. EPA
was lead agency on three of the RODs, and the U.S. Army was the lead agency on one of the
RODs. In order for the Illinois EPA to properly complete each ROD and meet the desired
deadlines, the Illinois EPA and U.S. EPA Region 5 jointly proposed that U.S. EPA Headquarters
staff be brought to the state offices to work directly with Illinois EPA project managers. It is
estimated this approach saved approximately four weeks in the overall review process. Illinois
signed three state-lead RODs and concurred with three federal-lead RODs on September 28, 1999.
THE ILLINOIS ECOLOGICAL RISK INFORMATION PILOT
The Illinois Ecological Risk Information Pilot (Pilot) is aimed at developing existing ecological risk
assessment data into a tool, much like the U.S. EPA Soil Screening Level Guidance (SSLG), or
Illinois EPA’s TACO. This tool would be used as a screening device to set ecologically-based
corrective action objectives for remediation projects.
The initial focus is to identify the existing habitats in Illinois and identify the most sensitive
organism within each habitat, based on the ingestion of contaminated soil and contaminated
groundwater and the bioaccumulation of contaminants in these various organisms. The Pilot will
look at aquatic, benthic and terrestrial organisms, including all species, and identify the most
sensitive organism or groups of organisms within each habitat. These organisms could then serve
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