The Illinois Site Remediation Program (SRP) is a voluntary cleanup program for brownfield sites administered by the Illinois Environmental Protection Agency (Illinois EPA). The SRP is authorized by Sections 4(y) and 58 - 58.12 of the Illinois Environmental Protection Act (415 ILCS 5/58 - 58.12). State rules concerning the SRP can be found in Part 35, Section 740 of the Illinois Administrative Code (35 IAC 740).
The SRP establishes investigation and cleanup guidelines for sites where there is a release or threatened release of hazardous substances, pesticides or petroleum. Once a site owner has completed the program, the Illinois EPA issues a "No Further Remediation" (NFR) Letter stating that the cleanup is satisfactory for the site's intended use and the owner has no additional responsibility for completing an approved cleanup plan. The Illinois EPA and U.S. EPA Region 5 have a formal agreement whereby the federal government also recognizes the NFR.
The SRP promotes risk-based, site-specific cleanup. This means that the cleanup objectives for a site can be derived from the intended use of the redeveloped site, the potential for exposure to contaminants, and actual site conditions. For instance, cleanup objectives for a site intended for a park or residential development would change if the same site were going to be redeveloped as a parking lot or industrial facility.
The guidelines for determining risk-based, site-specific cleanup objectives are given in the state's Tiered Approach to Corrective Action Objectives (TACO). State rules concerning TACO can be found in Part 35, Section 742 of the Illinois Administrative Code (35 IAC 742). In the first Tier of analysis (Tier 1), a site owner, with help from an environmental consultant and the Illinois EPA, compares sampling results to tables that show the strictest cleanup levels for all potential contaminants. If the sampling results exceed the values listed in the tables, the owner can either describe to the Illinois EPA the area of concern or move on to a Tier 2 analysis. Tier 2 involves calculating the human health risk posed by the sampling results. Tier 3, an even more sophisticated analysis, takes site-specific options into account. Which tier of analysis an owner uses depends on both the complexity of the environmental concerns and the cost of obtaining various levels of information about the site.
Supporting Risk-Based Site Cleanups
The City of Chicago enrolls its brownfield sites in the Illinois EPA’s SRP on a case by case review, generally dependent on historic site use and the proposed redevelopment. As a site owner, the City knows that developers and end-users who purchase these properties want the release from liability that is provided by the NFR. As a protector of human health and the environment, the City supports risk-based site cleanups and consistent review by the Illinois EPA. The City encourages private parties to enter sites in the Illinois SRP, too. For this reason, the City of Chicago has established two "institutional controls" allowed for by the TACO guidelines -- an ordinance restricting groundwater use and a model highway authority agreement.
For additional information about the Illinois EPA’s SRP, please visit the Illinois EPA’s website.