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April 2013 Update: The roof of the clubhouse building at Sportsman's Park is proposed to be replaced in 2013.
The Naperville Park District (NPD), in cooperation with the City of Naperville, has enrolled Sportsman’s Park in the Illinois Environmental Protection Agency (IEPA) Site Remediation Program (SRP) to secure IEPA oversight of an environmental assessment and remediation of the Sportsman's Park facility. The objective of these activities is to obtain a No Further Remediation (NFR) determination from the IEPA and to remove certain regulations, conditions and restrictions presently imposed upon the Facility in order to continue the current uses and programs at Sportsman’s Park, including trapshooting.
Background
Since 1988, the Naperville Park District (NPD) has managed Sportsman’s Park under a 99 year lease from the City of Naperville. Since approximately 1948, Sportsman's Park has been used for a variety of shooting sports activities, including programs conducted by the Naperville Sportsman's Club. In 1988, trapshooting at the facility became a Park District program offered through the assistance of the Naperville Sportsman’s Club. Participation in the program and use of the facility is open to the public.
In the late 1980s and mid 1990s, the NPD voluntarily commissioned multiple soil and groundwater investigations in order to understand the environmental risks associated with the property usage. The investigations included Sportsman's Park and adjoining public use properties including Von Oven Scout Reservation, Community Garden Plots and Knoch Park. These investigations were evaluated by the IEPA Pre-Notice Site Cleanup Program (now the Site Remediation Program).
In 1998, The IEPA issued a No Further Remediation (NFR) determination for lead for the Von Oven Scout Reservation, Community Garden Plots, Knoch Park and portions of Sportsman's Park currently accessible to the general public. In general, the NFR signifies that conditions at the aforementioned sites require no further action to protect human health or the environment. Similarly, based upon the results of multiple investigations over time, the Agency has determined that soil and groundwater conditions do not pose a threat to potable groundwater wells in the area.
Under the terms of a Settlement Agreement entered into by NPD, the City and other parties, NPD must operate Sportsman’s Park in accordance with the conditions of a National Pollutant Discharge Elimination System (NPDES) permit issued and administered by the IEPA. These conditions include preventative measures such as limiting access to the trapshooting areas, posting signage and implementing environmental best management practices at the Park (e.g., banning the use of lead shot and requiring the use of environmentally friendly steel shot and biodegradable targets).
Today, the Park District's stewardship philosophy has evolved to incorporate ecological sustainability and there's a commitment to the restoration of the remaining areas of Sportsman's Park for soils and groundwater by obtaining a no further remediation determination from the IEPA SRP.
Question & Answer:
1. What is the Illinois EPA Site Remediation Program?
The Illinois EPA Site Remediation Program is a voluntary program that allows the applicant to seek Illinois EPA review and, where warranted, regulatory approval of remedial actions. The objective of the site remediation activities is to receive a No Further Remediation determination.
2. What is a No Further Remediation determination?
The NFR letter signifies a release from further responsibilities under the Illinois Environmental Protection Act ("Act") and is considered prima facie evidence that the site does not constitute a significant risk of harm to human health and the environment, so long as the site is utilized in accordance with the terms of the NFR letter.
The IEPA has already issued NFR letters for lead to the Von Oven Scout Reservation, Community Garden Plots, Knoch Park and portions of Sportsman's Park current accessible to the general public.
3. What is the process for obtaining a no further remediation determination?
Regulations identifying Program procedures and standards are found in 35 Ill. Adm. Code 740 and 742. Obtaining an NFR determination is achieved through regulatory approval of four reporting milestones, briefly described below:
1) Focused Site Investigation Report (FSIR): In general, the FSIR report documents that the three dimensional extent of impact in soil and groundwater has been defined to the satisfaction of the Agency.
2) Remediation Objectives Report (ROR): In general, the ROR establishes the remediation objectives for exposure pathways, including soil ingestion, soil inhalation and groundwater ingestion.
3) Remedial Action Plan (RAP): In general, this report outlines the proposed remedial measures for obtaining the approved remedial objective.
4) Remedial Action Completion Report (RACR): In general, this report documents the remedial measure(s) and demonstrates that the site meets the conditions for an NFR determination.
The Illinois EPA provides information about the Site Remediation Program here:
http://www.epa.state.il.us/land/site-remediation/
The NPD recently received the Focused Site Investigation Report (FSIR) and submitted the report to the IEPA on 1/31/13. The graphic shown below summarizes the entire site remediation process , indicating what has been completed and what tasks remain.
4. When will the remediation be completed? How long will this process take?
At this time, there is not enough information to accurately predict the time required to obtain an NFR determination. Remedial planning activities are ongoing. The goal of the first phase of remediation will be to obtain an expanded NFR determination for the areas outside the existing fence.
5. Are the NPD facilities safe?
Yes. All NPD operated areas accessible to the general public in the vicinity of the Sportsman's Park have received a No Further Remediation letter for lead from the Illinois EPA SRP, including Knoch Park, Von Oven and the Community Garden Plots. Publicly accessible portions of Sportsman's Park (the area outside the fence) have also received an NFR for lead.
The portion of the Sportsman's Park within the fence area remains safe for use for trapshooting activities and, until the NFR determination is received, will continue to be subject to the conditions imposed by the IEPA in the NPDES permit.
6. Is the Sportman's Park Clubhouse safe?
Yes. The vicinity of the Sportsman's Park Clubhouse has received an Illinois EPA NFR determination for Lead. The use of lead shot has been banned from Sportsman's Park since 2000. Since that time, the NPD has performed periodic lead wipe sampling events and groundwater sampling events at the facility. The results of the Clubhouse evaluation did not indicate a risk of exposure to Lead.
7. Is the groundwater in the vicinity of the Sportsman's Park suitable for public use?
Yes. In 1997, the Illinois EPA evaluated the results of soil and groundwater information regarding the Park and determined that the site conditions "did not indicate a groundwater contamination risk to surrounding wells. As outlined in the 2013 Focused Site Investigation Report, nine groundwater monitoring wells were sampled in 2012. The results indicated that Total Lead did not exceed groundwater or drinking water standards."
Following the EPA determination, the on-site potable well was tested for Lead in 2008 and 2011. The results of the evaluation indicated that the groundwater met the Federal requirements for groundwater resources.
In order to obtain an NFR determination, additional groundwater analysis will be required.
8. Will the remediation of soils require disturbance of the wooded areas of Sportman’s Park?
Disturbance, including limited smaller tree and vegetation removal is unavoidable. However, care will be taken to minimize tree and vegetation removal. In evaluating remedial options, preference will be given to alternatives that minimize disturbance to the wooded areas. In addition to assessing soil and groundwater impact values, the NPD is conducting natural resource due diligence activities including a wetlands survey, a tree survey, and threatened/endangered species consultation. In the process of the remediation activities, the NPD may consider the opportunity to enhance the landscape of Sportsman’s Park, with the selective removal of certain invasive or non-native species in order to promote a healthier and more diverse ecosystem.
9. Will the NFR determination include the natural resources areas of the park?
Yes. A Site Investigation Work Plan will be submitted to the IEPA SRP for review and includes soil, groundwater, surface water and sediment analysis.
10. Why is the NPD asking the City of Naperville to undertake this now?
The NPD is asking the City of Naperville to undertake this now as the logical next step in the stewardship of Sportsman's Park. A number of the preventative measures installed to protect the public and wildlife are nearing the end of their lifecycles and will, over the next 10 years, require extensive maintenance and replacement. Those resources are, instead, being devoted to studying and removing the underlying reasons for the existence of the preventative measures in the first place. Moreover, in the time since the preventative measures were first introduced, the science and techniques for understanding and remedying the issues have advanced so that they can now be undertaken with less impact on the public's use of Sportsman's Park or the surrounding facilities.
11. Where can I go for additional information about this project?
The NPD, which has asked the City of Naperville to voluntarily participate, is committed to communicating to the public in a variety of methods:
a) The NPD website will be periodically updated and will include downloads of all reports submitted to the Illinois EPA Site Remediation Program.
b) A repository of Site Remediation Program documentation is available for download from the website.
c) Hard copies of the documentation are available for public review at the following Park District facilities: Admin. Building at 320 W. Jackson Ave., Planning and Development Office at 425 W. Jackson Ave., and the South Maintenance Facility at 3415 Book Rd.
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Phase I: Environmental Site Assessment Document
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Section 1 (658 kb) 
Introduction, Site Description, User Provided Information, Records Review, Site Reconnaissance, Interviews, Findings, Opinions and Conclusions, Deviations and Data Gaps, Additional Services, Non-Scope Considerations, References
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Section 2 - Figures (2.8 mb) |
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Appendix A - Site Photographs (5.3 mb) |
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Appendix B - Previous Environmental Reports (97.9 mb) |
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Appendix C - 2011 Environmental Reports (2.0 mb) |
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Appendix D - EDR Radius Map Report (2.1 mb) |
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Appendix E - Aerial Photographs (10.6 mb) |
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Appendix F - City Directory Search (125 kb) |
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Appendix G - Historical Topographic Maps (2.4 mb) |
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Appendix H - Sanborn Map Report (101 kb) |
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Appendix I - FOIA Documentation (33.0 mb) |
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Appendix J - Qualifications of Environmental Professionals (237 kb) |
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Site Investigation Work Plan
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