The process for developing and implementing cleanup projects continually evolves as new issues and challenges arise. A decade ago, the cleanup model for MGP sites involved identifying the contamination and cleaning it up to background. Several changes are in store for the near future to make remediation more efficient and comprehensive. Risk techniques continue to gain acceptance for human health protection and are expected to expand to include protection of environmental resources. As utility companies demonstrate their willingness to voluntarily clean up MGP sites both State and federal regulatory systems will become more user friendly. Finally, public involvement will continue and they will demand to be more involved in decision making. After five years of using risk based corrective action, the Illinois Environmental Protection Agency (IEPA) is ready to start addressing ecological risk and natural resource restoration issues. IEPA has had experience over the years in it's role as a regulatory agency and natural resource trustee, under the Natural Resource Damages Act (NRDA), in working on many Superfund, Federal Department of Defense and State funded cleanup projects. However, to provide for a more consistent and effective program, the Agency will develop ecological risk and natural resource restoration procedures that will apply to all cleanup projects. USEPA and IEPA rules now allow RCRA permits to be issued for the management of hazardous waste on site. These permits are relatively uncomplicated and can be processed in a timely fashion, thus expediting the process. However, there are many elements of RCRA such as land disposal restrictions, or finding approved sites to manage MGP waste that can be difficult to overcome. Over the past several years, it has become evident that a few chemicals are consistently present in background samples at levels higher than risk based human health levels. Arsenic and polynuclear aromatic hydrocarbons (PNAs) seem to be present due to both naturally occurring and anthropogenic sources. Sufficient data were available to support a regulatory change for arsenic, but not for the PNAs. This situation may be resolved soon since the City of Chicago has received a Brownfield grant from the IEPA to conduct a citywide "background" study. Results of this study could also support a regulatory change. Community relations at MGP sites have become even more important than ever before. Public coalitions have become more sophisticated and knowledgeable, with citizens retaining consulting engineers and attorneys. Their demands, such as limiting the hours of operation of the cleanup activities, or prohibiting the use of trucks and requiring wastes to be hauled off by rail, are much more expansive than in the past.
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