&EPA
United States
Environmental Protection
Agency
Tell us what you think
EPA invites comments on its
proposed interim cleanup plan
for the "Ground Water South
of the Illinois River" portion of
the Ottawa Township Flat Glass
Superfund site. Public input helps
EPA determine the best course of
action.
EPA also encourages people
to attend the upcoming Public
Meeting on Wednesday,
August 26,2009, at La Salle
County's Etna Complex, 707 E.
Etna Road, Room 250, Ottawa,
111., starting at 7 p.m.
If you need special
accommodations at the public
meeting contact Cheryl Allen
(see contact information below).
Comments can be presented to EPA
from August 19 to September 18,
2009 in many ways:
Submit an oral or written
statement at the public meeting.
Send us a letter.
Fill out and mail the enclosed,
comment form.
Send us a comment via the
Web at: www.epa.gov/region5/
publiccomment/
Fax your comment to Cheryl
Allen at 312-408-2234.
On the Web
http://www.epa.gov/region5/sites/
naplate
Interim Clean Up for Polluted
Underground Water Supply
Ottawa Township Flat Glass Superfund Site
Naplate, Illinois
August 2009
U.S. Environmental Protection Agency is proposing to rework storm water
drainage patterns and impose institutional controls on lands south of the
Illinois River to help reduce arsenic levels in underground water supplies
and prevent human exposure to hazardous waste in a glass factory's former
sand quarries. The purpose of this proposed plan fact sheet is to provide
background information about the Ottawa Township Flat Glass (OTFG)
Superfund site, describe the various cleanup options that we've considered,
and identify EPA's suggested cleanup alternative.1
EPA typically breaks up complex cleanup sites into smaller parts called
"operable units" or OUs. Here, EPA has divided the OTFG site into four
OUs. The lands south of the Illinois River with glass-making waste material
in several former sand quarries and a polluted underground water supply
(ground water) beneath them are known as Operable Unit 3. EPA put together
this proposed cleanup plan for OU 3 to help protect people and wildlife
from exposure to the glass-making waste in the quarries while eventually
reducing arsenic concentrations in the ground water to make it safe enough
for drinking.
EPA considered six cleanup alternatives for OU3 and picked a variation of
Alternative 4 - costing $3 million - as its preferred cleanup plan. All the
cleanup options are described in more detail later in this fact sheet. The
modified Alternative 4 consists of engineering work to modify surface water
drainage pathways near the former quarries to lessen the rate that rainwater
and snowmelt soaks into the glass-making waste. That, in turn, will reduce
the amount of arsenic-contaminated water filtering through the waste into
and therefore polluting the ground water below. In addition, redirecting
the surface water away from the former quarries will help to speed up the
cleanup of the ground water by helping to cause the area ground water to
more directly discharge into the Illinois River. EPA plans to monitor the
arsenic concentrations in the ground water for many years. The modified
Alternative 4 also calls for alternate water supplies to be provided to
homes with private wells that are situated over or very near the mass of
contaminated ground water. EPA would also apply institutional controls
to the lands that would prohibit ground water use to prevent the use of
contaminated ground water for drinking purposes. The institutional controls
could be ordinances enacted by either the local municipalities or LaSalle
County or EPA could decide that the placement of deed notices or restrictions
on affected properties would be sufficient. A restrictive covenant would also
be placed on the quarry property to prevent the future residential re-use of
this land.
1 Section 117(a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA,
known as the Superfund law) requires EPA to provide an opportunity for pu blic input with a meeting and
comment period. It also requires a newspaper ad announcing the proposed cleanup plan. This fact sheet
summarizes EPA documents called the remedial investigation and feasibility study. The full studies and all
other official site documents can be found at the Reddick Library in Ottawa.
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Contact EPA
These EPA representatives are
available to answer questions and
provide more information.
Cheryl Allen
Community Involvement
Coordinator
Superfund Division (SI-7J)
312-353-6196
allen.cheryl@epa.gov
Kevin Adler
Remedial Project Manager
Superfund Division (SR-6J)
312-886-7078
adler.kevin@epa.gov
Region 5 address:
EPA Region 5
77 W. Jackson Blvd.
Chicago, IL 60604
Region 5 toll-free: 800-621-8431,
8:30 a.m. - 4:30 p.m., weekdays
Public comment
The public is encouraged to comment on this cleanup proposal. EPA will be
accepting comments starting August 19, 2009, through September 18, 2009.
EPA also encourages the public to attend and participate in a public meeting
at La Salle County's Etna Complex, 707 East Etna Road, Room 250, Ottawa,
111., on August 26, 2009. The meeting will be held at 7-9 p.m. (See the box
on P. 1 for ways to participate in the public comment process.) Your input is
important - EPA could alter its proposed plan or choose a new one based on
public comments received.
EPA also encourages the public to review the supporting documents for the
OTFG site which include the recently completed "remedial investigation"
and "feasibility study" reports. A remedial investigation is a study of the
nature and extent of contamination at a cleanup site whereas a feasibility
study evaluates proposed cleanup options.
These documents are available at the Reddick Library, 1010 Canal St.,
Ottawa, and at EPA Region 5's offices in Chicago.
About the Ottawa Township Flat Glass site
The OTFG site is located in LaSalle County, 111., and consists of the former
Libbey-Owens-Ford glass manufacturing facility (active Plant #5 and
inactive Plant #7) on 228 acres on the north side of the Illinois River and
former silica sand quarries and wastewater disposal areas on 122 acres
south of the river (see aerial photo below and on P. 7). Pilkington North
America Inc. (PNA) now owns the site. PNA signed a legal agreement with
EPA in 2001 in which PNA agreed to conduct a remedial investigation and
feasibility study under EPA supervision.
Figure 1 -Aerial photo of glass factory and nearby residential area.
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EPA divided the OTFG site into four operable units. The
OUs include the Residential Soils (OU1), Illinois River
Sediment (OU2), Groundwaterand Source Areas South
of the Illinois River (OUS), and Groundwater and Source
Areas North of the Illinois River (OU4). As mentioned
previously, this proposed plan fact sheet deals with OUS
only. Last year EPA announced proposed cleanup plans for
OUs 1 and 2 and the Agency issued a Record of Decision
to select the proposed plan. EPA is still investigating OU4
(on the north side of the river) and plans to propose a
cleanup plan for that area late next year.
The plant has been making glass products since about
1907. Arsenic trioxide was a minor ingredient in the
manufacturing process from 1907 until 1970 when its
use was discontinued. The final step in the fiat glass
manufacturing process involved grinding and polishing
the cast glass with fine silica sand and water. The
process generated waste in the form of a slurry (known
as "G&P shirty") consisting of mostly sand, water and
glass particles containing arsenic. The G&P slurry was
discharged into some of the former quarries (including
Quarry 1 in OUS) where the solids settled to the bottom
and the overflow water was discharged into the Illinois
River. The G&P slum' contains high levels of arsenic and
is considered the main source of arsenic contamination in
a ground water supply and also poses a potential exposure
threat to people and wildlife.
PNA purchased the glass manufacturing facility from
LOF in 1986, about 16 years after LOF had discontinued
the use of arsenic in the glass-making process.
OUS
PNA installed a number of ground water monitoring
wells in and around the OTFG site several years ago.
The company periodically takes water samples from
the monitoring wells along with nearby private wells
to determine the nature and extent of the arsenic
contamination in the ground water beneath the site. On
plant property, PNA also sampled surface soil, sediment
(mud) in drainage pathways and at the bottom of the
quarries, and surface water in the quarries to track the
levels of arsenic contamination in these areas.
Test data shows two ground water aquifers of immediate
concern lie below the site (aquifers are water-bearing rock
formations in the ground). The upper aquifer is called the
St. Peter Sandstone and is a regional unconfined aquifer
that has been affected by arsenic contamination from
the site. The lower aquifer, called the New Richmond
Sandstone, is not contaminated with arsenic. Between the
two aquifers lies the Shakopee Dolomite, a 150 to 200-foot
thick layer of rock that forms an effective barrier and
prevents arsenic contamination from moving between the
St. Peter Sandstone and New Richmond Sandstone.
Arsenic levels in ground water in the tainted St. Peter
Sandstone (in OUS) range from a few7 parts arsenic per
billion parts soil at the edges of the contaminant plume, to
about 350 parts per billion in the center of the plume. (A
plume is a mass of contaminated water. A part per billion
or ppb is a tiny amount equal to 1 second in 32 years.)
But even these small concentrations found in OUS are up
to 35 times higher than the safety standard for arsenic.
which is 10 ppb. The federal Safe Drinking Water Act
refers to the safety standard as "'maximum contaminant
level" or MCL.
The St. Peter Sandstone, however, is not currently used for
drinking water in the site area although some private wells
penetrate that layer. PNA currently supplies about five
residences with bottled water to help prevent consumption
of potentially contaminated water. The village of Naplate
draws its public water supply from the arsenic-free New
Richmond Sandstone aquifer. Ground water in the area
generally flows towards the Illinois River. The ground
water in the upper portion of the aquifer flows into the
river while ground water in the lower reaches of the aquifer
flows beneath the river toward the northwest (into OU4).
Quarry 1 in OUS was used from about 1954 until 1970 to
receive G&P slum' that was drained or "dcwatercd." When
use of the quarry was stopped the G&P slurry was covered
with sludge from a wastewater treatment plant and topsoil
and then seeded. The quarry contains more than 2 million
cubic yards of the slurry material. Much of it lies within
the water table and is considered to be the source material
for the arsenic-contaminated plume in the ground water of
the St. Peter Sandstone. Arsenic levels in the G&P slurry-
are high.
The other quarries were used as the facility's wastewater
retention ponds from time to time and may contain smaller
amounts of grinding and polishing slurry. The quarries
are no longer used to store wastewater discharges. But
they contain various amounts of surface water in them
that contain some arsenic. Sediment at the bottom of
these quarries as well as the adjacent drainage ditches and
surface soil also contain small amounts of arsenic.
to the
environment
Arsenic is a nutrient and very small amounts are needed
by the body for growth and for a healthy nervous system.
But too much arsenic can cause non-cancer conditions
in the body as well as potentially triggering lung or skin
cancers. Arsenic can be absorbed through skin contact,
breathing or by consuming arsenic-contaminated food or
water. EPA conducted a human health risk assessment to
determine whether the arsenic levels at OUS are present in
undesirable amounts in the soil, sediment, surface water
and ground water.
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Except for ground water, three exposure scenarios were
examined: A PNA employee working in the quarry area.
an adult trespasser (probably a hunter) and an adolescent
trespasser. EPA did not consider a residential exposure
scenario because OU3 is owned by PNA and the quarries
arc not suitable for home building. Exposure pathways
could include skin contact and swallowing or breathing
contaminated dust. For ground water, drinking water use
by nearby residents was assumed as a potential exposure
pathway because the contaminated underground plume has
moved beyond the PNA-owned property.
Area surface soils are not considered contaminated because
chemical levels are comparable to naturally occurring
arsenic concentrations in soil statewide. Quarry 1. however,
contains a 35 to 50-foot layer of G&P slurry mat is covered
by municipal sludge and topsoil. Quarry 3 holds a small
amount of G&P slurry as well. Although the Quarry 1
slum- contains hazardous amounts of arsenic, the material
is covered with a layer of soil and is not readily accessible
to PNA maintenance workers or trespassers. Quarries 2-4
are filled with open water at depths up to 10 feet or more.
Overgrowth and fencing generally restricts access, and the
depth of the surface water further helps shield the more
contaminated sediment beneath the water from someone
who falls or jumps in the quarry.
The health risk assessment concluded the risk of
contracting non-cancer illness and cancer from the soil.
sediment and surface water of OU3 was low and no
cleanup of those three areas is needed. However, the risk
study did conclude it would be beneficial to continue to
restrict access to soil, sediment and surface water in the
area to minimize future exposure to arsenic contamination.
The ground water contamination poses the most serious
problem, the health risk study concluded. As mentioned
before, the source of much of the arsenic in the ground
water supply is the thick layer of G&P slurry in Quarry 1.
Should the ground water in the St. Peter Sandstone aquifer
be used for drinking, unacceptable health risks would
occur over a lifetime of exposure to the arsenic pollution.
Because of these potential health risks, EPA is proposing
the cleanup plan contained in this fact sheet.
Health risks were also calculated for birds, fish and land
animals as well as plant life in the area, but the assessment
found little effect from the arsenic because few organisms
live on the property.
Ground water in the St. Peter Sandstone aquifer under
the site is contaminated with arsenic levels above the
drinking water standard of 10 ppb. Therefore, a potential
adverse health risk exists should residents consume the
contaminated water. The objectives for a cleanup action at
OU3 would include:
* Prevent the drinking water use of ground water
contaminated with arsenic above 10 ppb.
* Reduce the concentration of arsenic in the ground
water over time to achieve a level of 10 ppb or less.
* Prevent people from coming in contact with the
G&P slum' material in Quanry 1 as well as arsenic-
tainted sediment in all of the quarries even though as
mentioned above current exposure risks are low.
EPA considered several options for containing and
reducing arsenic contamination on the OU3 site. Each
option was evaluated against nine criteria required by law
(see box on P. 5 for an explanation of the criteria). EPA's
proposals are designed to reduce health risks and meet
the cleanup goals. EPA believes its recommended cleanup
actions will protect human health and the environment.
Costs include construction of equipment and cleanup
systems as well as long-term maintenance and operating
expenses. Cost figures consider future inflation and are
given in a financial calculation called "present worth.'"
Full details are provided in the remedial investigation
and feasibility study reports at the Reddick Library. EPA
considered the following six cleanup alternatives:
Ground Water Alternative 1: No Action - EPA always
considers a no action option as a comparison point for the
other alternatives. Cost - $0
Ground Water Alternative 2: Alternate Water Supply,
Institutional Controls, and Monitored Natural
Attenuation - Under this option, EPA would take action
to ensure residences with private wells penetrating the
contaminated portion of the St. Peter Sandstone aquifer
would continue to receive an alternative water supply
until the arsenic levels in the aquifer decline to 10 ppb or
below. Institutional controls such as a ground water use
ordinance to restrict consumption would be pursued as
well. Under Alternative 2 deed restrictions on the PNA-
owned property to prevent its use as residential land would
also be implemented. The use of institutional controls and
alternate water supplies would help reduce the potential
health risks that could occur if contaminated ground water
were to be consumed.
EPA would also conduct a monitored natural attenuation
program at OU3 to track the arsenic contaminated plume
over time until concentrations no longer exceed the
standard of 10 ppb. Natural attenuation is a scientific term
for letting natural processes such as evaporation, decay
and dilution lower pollutant levels. This alternative would
require additional monitoring wells be drilled and then
periodically sampled for arsenic over a minimum 20-year
time frame until the health standard is met.
Cost-$1.45 million
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Ground Water Alternative 3: Plume Containment
via Pump and Treat, Surface Flow Measures and
Alternative 2 - Under this option, EPA would implement
the provisions of Alternative 2 plus take measures to
contain the arsenic plume in the area around Quarry 1 by
installing pumping wells and altering the surface water
drainage pathways around the quarries. The additional
work will help to change local ground water flow towards
the Illinois River and will also speed the rate arsenic levels
in most of the plume fall below 10 ppb. This alternative
would require additional monitoring wells be drilled and
periodically sampled for arsenic over a minimum 20 years
until the health standard is met. The use of institutional
controls and alternate water supplies would help reduce
potential health risks from drinking contaminated water.
Under Alternative 3, pumped water could either be
discharged to Quarry 4 without treatment, to the Ottawa
municipal treatment facility or treated on-site to remove
arsenic before discharging to the Illinois River.
Cost - $6.25 million (pump to Quarry 4) to $25 million
(on-site treatment)
Ground Water Alternative 4: Surface Flow and
Infiltration Reduction Measures and Alternative 2 -
Under Alternative 4, EPA would implement Alternative 2
plus take measures to reduce the rate of arsenic escaping
from the slurry material by altering the paths of surface
water drainage around Quarries 1 and 2. The surface
work will help reduce the rate of ground water recharge
in the quarries, which in turn slows arsenic movement
from the source material into the ground water below.
The engineering work will also help change the direction
of the ground water so it flows back towards the Illinois
River. The drainage alterations will thus speed the rate at
which the arsenic level in most of the plume falls below
10 ppb. As in the other options, institutional controls and
alternate water supplies would also help reduce health
risks. This alternative would require additional monitoring
wells be drilled and periodically sampled for arsenic over a
minimum 10 to 20 years until the drinking water standard
is met. Cost - $3 million
Explanation of evaluation criteria
EPA uses nine criteria to evaluate and compare cleanup options. See the table below comparing the options
against these criteria.
1. Overall protection of human health and the environment examines whether an option protects both human
health and the environment. This standard can be met by reducing or eliminating contaminants or by reducing
exposure to it.
2. Compliance with applicable or relevant and appropriate requirements (ARARs) ensures that each clean
up option complies with federal, state and local laws.
3. Long-term effectiveness and permanence evaluates how well an option will work over the long-term,
including how safely remaining contaminants can be managed.
4. Reduction of toxicity, mobility or volume through treatment determines how well the option reduces the
toxicity, movement, and amount of contaminants.
5. Short-term effectiveness compares how quickly an option can help the situation and how much health risk
there will be while the option is under construction.
6. Implementability evaluates how difficult the option will be to construct and whether materials and services
are available in the area.
7. Cost includes not only buildings, equipment, materials and labor but also the cost of maintaining the option
for the life of the cleanup. A cleanup is considered cost effective if its costs are proportionate to its overall
effectiveness.
8. State acceptance determines whether the state environmental agency - in this case Illinois EPA - accepts the
option. EPA evaluates this criterion after receiving public comments.
9. Community acceptance considers the opinions of nearby residents and other stakeholders about the proposed
cleanup plan. EPA evaluates this standard after a public hearing and comment period.
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Modified Ground Water Alternative 4: Surface Flow
and Infiltration Reduction Measures and Alternative 2
except for Monitored Natural Attenuation (this is EPA's
preferred alternative) - Under modified Alternative 4,
EPA would implement every part of Alternative 4
described above except for monitored natural attenuation.
EPA plans to re-examine the use of monitored natural
attenuation at OU3 because not enough information is
currently available to choose this approach as part of the
cleanup remedy. However, new monitoring wells would
be drilled and sampled as before, so the estimated cost to
implement the remedy remains the same - $3 million.
Ground Water Alternative 5: Ground Water Pump and
Treat plus Alternative 2 (without monitored natural
attenuation) - Under this option EPA would implement
Alternative 2 minus natural attenuation plus install a
ground water pump-and-treat system for the entire arsenic-
plume in OU3. Pumped water would be sent to the Ottawa
public treatment plant or treated on-sitc and discharged
to the Illinois River. About 600 gallons of water would be
pumped per minute until arsenic levels in the bulk of the
plume fall below 10 ppb. This alternative would require
additional monitoring wells be drilled and periodically
sampled for arsenic over a minimum of 10 years until the
drinking water standard is met on non-PNA property. As in
the other options, institutional controls and alternate water
supplies would also help reduce health risks. It is unknown
as to when the ground water cleanup level would be met
on PNA property because the arsenic source - the G&P
slum' - would remain as a source of contamination for
many years. Cost - $18 million (for water treatment at
the Ottawa facility) to $36 million (on-site treatment)
Ground Water Alternative 6: Source Material
Removal and Alternative 2 - Under this option. EPA
would implement Alternative 2 plus excavate the G&P
slurry material from Quarry 1 and dispose of it off-site.
Removal of the source material will shorten the time it
takes for arsenic levels in the bulk of the plume to fall
below 10 ppb. This alternative would require additional
monitoring wells and periodic sampling for arsenic over 10
to 20 years until the drinking water standard is met. As in
the other options, institutional controls and alternate water
supplies would also help reduce health risks. Quarry 1
contains about 2.1 million cubic yards of slum? that would
require two years of excavation and removal work.
Cost - $220 million
the
EPA compared the six cleanup options with the nine
federally mandated criteria and created the chart on P. 7.
EPA recommends Modified Ground Water Alternative 4
- Surface Flow and Infiltration Reduction Measures plus
Alternative 2 (except monitored natural attenuation) be
implemented at OU3. EPA likes this option because it
protects human health and the environment and reduces
the arsenic plume under non-PNA property within a
reasonable amount of time for a reasonable cost. More
information, however, is needed to address whether
monitored natural attenuation would be plausible for this
portion of the site.
The no action alternative does nothing to protect human
health and the environment and was rejected. Although
it works, Alternative 2 alone is less desirable than
Alternative 4 because no action is taken to hasten the
reduction of arsenic levels in the plume areas beneath non-
PNA property. Alternative 3 does speed the cleanup pace
but is more costly than Alternative 4 and yields no time
advantage for the extra cost.
Alternatives 5 and 6 take the most action to reduce the
arsenic plume but are extremely costly. And the excavation
of the source material under Alternative 6 may have
adverse short-term effects because the work would run
over two years and excavated materials would have to be
trucked through Ottawa on the way to an off-site landfill
for disposal.
EPA will review comments received during the public
comment period before making a decision on the cleanup
plan. Based on new information in public comments,
EPA may change its proposed options or select another
alternative presented in this plan. EPA will respond to
comments in a "responsiveness summary." This will be
part of a document called an Interim "Record of Decision"
or ROD that describes the cleanup plan for the OU3
portion of the OTFG site.
EPA will announce the Interim ROD in a local newspaper,
and a copy will be posted on EPA's Web site and placed
in the Reddick Library in Ottawa. EPA will then negotiate
with PNA, the potentially responsible party, to conduct the
cleanup under Agency oversight. The cleanup will then be
designed and constructed.
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Evaluating the cleanup alternatives
Evasion C,«er,a *J
ltt ,,.,_ , Alternative 4 Alternative 5
Alternative 2 ,,.. .. . ... _ ,
... , , Alternatives Alter Pump & Treat
Natural _. T , _. . in,
... .. Pump & Treat Drainage w/o Natural
Attenuation Pathways* Attenuation
Alternative 6
Excavation
of Source
Material
Overall protection of human health and n
the environment
Compliance with ARARs D
Long-term effectiveness and D
permanence
Reduction of toxicity, mobility, or ._.
volume through treatment
Short-term effectiveness D
D
12 months to
complete
H
B
12 months to 12 months to
complete complete
12 months to
complete
28 months to
complete
Implementability
Cost (millions) $0
State acceptance
Public acceptance
Fully meets criteria
$1.45 million
H
$6 million - q,,
$25 million *J
Will be evaluated after the public
Will be evaluated after the public
Partially Meets Criteria
million
comment period
comment period
$18 million -
$36 million
$220 million
D Does not meet criteria
Figure 2 -An aerial view ofOU3 showing the four quarries. Quarry 1 in the middle of the lower half of the photograph is the main
source for arsenic contamination in the underground water supplies.
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EPA Proposes Cleanup Plan For
Underground Water Pollution
LaSalle County, Illinois
Public Comment Period
August 19 - September 18, 2009
Public Meeting
Wednesday, August 26, 2009
(details inside)
A snapshot of the cleanup proposal:
Alternate water supplies for private wells affected by arsenic contamination.
Restrictive covenants prohibiting use of underground water on-site and barring
residential construction on quarry land.
Altering drainage paths around quarries to limit rain and snowmelt infiltration.
Estimated total cost is $3 million.
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Fold on Dashed Lines, Tape, Stamp, and I
Name
Address
City
Zip
State
Cheryl Allen
EPA Community Involvement Coordinator
Superfund Division (SI-7J)
EPA Region 5
77 W. Jackson Blvd.
Chicago, IL 60604-3590
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Comment Sheet
EPA is interested in your comments on the proposed cleanup plan for the Ottawa Township Flat Glass OU3 site. You may
use the space below to write your comments. Submit them at the August 26, 2009 public meeting, or detach, fold, stamp
and mail to EPA Community Involvement Coordinator Cheryl Allen. Comments must be postmarked by September 18,
2009. If you have any questions, please contact Cheryl directly at 312-353-6196, ortoll free at 800-621-8431, 8:30 a.m. -
4:30 p.m., weekdays. Comments may also be faxed to Cheryl at 312-408-2234 or sent via the Web at cpa.gov/region5/
publiccomment/.
Name
Affiliation
Address
City State
Zip
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