CREATE Program Rail Projects
Phase I Project Report Procedures July 2016
Illinois Department of Transportation Page 41 of 59
Bureau of Freight Rail Management
land use are identified, continue to Step 4, for identification of unlisted
underground storage tanks within the limits of construction or noticeable
contamination in the form of discolored soil, seeping liquids, vegetation
damage from other than vegetative control activities, dead animals, suspect
odors, oil sheen, dead-end pipes, or abnormal grading, fills or depressions
within the limits of construction. If the response to Box C is no, continue to Box
D. Box D involves review of aerial photographs and web-based Geographical
Information Systems (GIS) aerials to identify special waste in the form of
storage tanks, drums, pits, ponds, lagoons, landfills, incinerators, or piping. If
the response for Box D is no, then a Determination of No Further Action may
be warranted. If the response for Box D is yes or do not know, continue to Step
4. Step 4 includes the identification of unlisted underground storage tanks
within the limits of construction or noticeable contamination in the form of
discolored soil, seeping liquids, vegetation damage from other than vegetative
control activities, dead animals, suspect odors, oil sheen, dead-end pipes, or
abnormal grading, fills or depressions within the limits of construction. If the
response to Step 4 is no, a Determination of No Further Action is necessary. If
the response to Step 4 is “yes” or “do not know”, a PESA would be required.
When completing Step 3 of the Form, if it is determined that all CERCLIS/
LUST sites within 500 feet are at a sufficiently lower elevation relative to the
work area construction limits, so that contamination is unlikely to migrate into
the construction limits, it is acceptable to respond “No” on the Form, with an
explanation in the Comment column. The same may be true if the LUST site is
separated by a valley or other physical gap that would preclude migration.
This decision must be approved by IDOT and FHWA on a case by case basis.
A No Further Action Determination shall have a completed Special Waste
Screening Form and report documenting the survey, due diligence methods,
and observations made. Alternately, if it is determined that further assessment
is required, this may be limited to the impacted work area(s), rather than the
entire CREATE Project.
If a design change is made after the completion of the Special Waste
Assessment which extends the construction limits beyond the environmental
survey limits, these areas must be addressed in a separate Special Waste
Assessment for the ESR Addendum area, incorporating the full Screening
Flowchart and Form.
Preliminary Environmental Site Assessment (PESA): If the Special Waste
Assessment concludes with a Further Assessment determination, then a PESA
is required for the project or impacted work areas. PESAs are conducted in
accordance with the American Society for Testing and Materials (ASTM)
Standard Practice for Environmental Site Assessments: Phase I Environmental
Site Assessments (ESA) Process Standard E 1527-13, and/or with USEPA’s
All Appropriate Inquiries (AAI) Final Rule 40 CFR Part 312. The USEPA AAI
ruling from 2005 coincided with the updated ASTM E 1527-05 Standard and
remains in force today even though the ASTM E-1527 Standard was updated
in 2013. The four components of a PESA, as it is for a Phase I ESA, are
historical records research, site reconnaissance, interviews with persons