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The annual rate of completion letters issued continued to
grow in 2000, with 172 letters issued (an 18% increase
over the previous year) bringing the total letters issued to
703.
The SRP issues two types of completion letters: a 4(y)
letter and a No Further Remediation (NFR) Letter. Prior
to 1996, the Illinois EPA was authorized only to issue
4(y) letters [415 ILCS 5/4(y)] to persons for completion
of voluntary cleanups. Since 1996, the Illinois EPA is
authorized to issue NFR Letters [415 ILCS 5/58.10]. The
Illinois EPA is still authorized to issue 4(y) letters, but
does so on a very limited basis.
A 4(y) Letter is specifi c to an action performed
A 4(y) letter merely denotes that a specifi c action (e.g.,
tank or drum removal, lagoon or chemical spill cleanup)
has been successfully completed. It does not denote that
all risks to human health and environment at a site have
been properly addressed.
An NFR Letter is specifi c to a defi ned property
The NFR Letter is prima facie evidence that a site
does not constitute a threat to human health and the
environment for contaminants addressed by the RA and
does not require further remediation under the Illinois
Environmental Protection Act as long as the site is used in
accordance with the terms of the NFR Letter (e.g., future
land use).
A “comprehensive” NFR Letter affi rms that all recognized
environmental conditions (releases or threatened releases
of contaminants) at a site have been addressed and do not
constitute a signifi cant risk of harm to human health and
the environment, so long as the site is used in accordance
with the terms and conditions of the NFR Letter.
A “focused” NFR Letter affi rms that a specifi c chemical
or set of chemicals (e.g., benzene, toluene, xylene) at a site
has been addressed and does not constitute a signifi cant
risk of harm to human health and the environment, so
long as the site is used in accordance with the terms and
conditions of the NFR Letter. A focused NFR Letter is
more limited than a comprehensive NFR Letter only in
terms of contaminants investigated and cleaned up.
Under TACO, the RA can chose the remediation
objectives based on the future use of the land
(industrial/commercial or residential), which in
turn infl uences the level of cleanup required.
Residential property is any real property that is
used for habitation by individuals or properties
where children have the opportunity for exposure
to contaminants through ingestion or inhalation
at educational factilities, health care facilities, child
care facilities or playgrounds.
Industrial/Commercial property is any real
property that does not meet the defi nition
of residential property, conservation property or
agricultural property.
Through December 2000, the remediation
objectives for over 59% of the NFR Letters issued
were based on an industrial/commercial land use.
The land use categories in TACO do not
necessarily correlate to local planning and zoning
codes (i.e., a site may be cleaned up to residential
land use standards under TACO, but the property
may be zoned for commercial use by the local
government).
Completion Letters
Future Land Use
0
50
100
150
200
1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
0 2
11
18
6
26
37
63
87
135
146
172
Completion
Letters Issued
