RECEiVED

BEFORE THE

ILLINOIS POLLUTION

CONTROL BOARD

CL~RK’5

OFF1~E

ESG WATTS,

INC.,

an

Iowa

corporation,

JUN

:162003

NOTICE OF

FILING

To:

Lisa Madigan, Attorney General

Attn:

Tom

Davis

Assistant

Attorney

General

Environmental

Bureau

500 S. Second Street

Springfield,

IL 62706

Carol Sudman

Board Hearing Officer

Illinois

Pollution

Control Board

600 S. Second

Street, Suite 402

Springfield, IL 62704

PLEASE TAKE NOTICE that on

this

date

I

mailed for filing with

the

Clerk of the

Pollution

Control

Board

of

the

State

of

Illinois,

RESPONDENT’S

SUPPLEMENTAL

PRODUCTION OF

EVIDENCE FOR HEARING,

a

copy of which

is attached hereto and

herewith served

upon you.

Lc~rvA. VUood~uct~td,

Larry A. Woodward, Attorney for Respondent

r

PEOPLE

OF THE STATE OF ILLINOIS,

V.

)

)

Complainant,

)

)

)

)

)

)

)

Respondent.

)

STATE OF ILLINOIS

Po!iutjo~

PCB NO.

01-167

---

CERTIFICATE OF

SERVICE

I hereby certify that

I

did on the

I

3th

day of June, 2003, on or before 6:00 p.m.

send

by First Class Mail, with

postage thereon fully prepaid, by depositing

in the

U.S.

mails a true and correct copy of the following instruments entitled NOTICE

OF

FILING

and

RESPONDENT’S SUPPLEMENTAL

PRODUCTION OF EVIDENCE

FOR

HEARING to the following

persons addressed as follows:

Lisa Madigan, Attorney General

Attn:

Tom

Davis

Assistant

Attorney

General

Environmental

Bureau

500 5. Second Street

Springfield,

IL 62706

Carol Sudman

Board Hearing Officer

Illinois Pollution Control Board

600 S. Second

St., Suite 402

Springfield,

IL 62704

and the original of said foregoing

instruments and ten copies thereof by First Class

Mail

with

postage thereon fully

prepaid to the following

person addressed as follows:

Dorothy Gunn, Clerk

Pollution Control

Board

State of Illinois Center

Suite

11-500

100 West Randolph

Chicago,

IL 60601

LcurrvA.

Wood~wc~,rd~

Larry A. Woodward,

Corporate Counsel

ESG Watts,

Inc.

525 17th Street

Rock Island,

IL 61201

309-788-7700

Dated: June

13, 2003

Larry A. Woodward, Attorney for Respondent

---

RE CE

~V E E

CLERICS

OFFtCE

BEFORE

THE

ILLINOIS POLLUTION

CONTROL BOARD

JUN

162003

PEOPLE OF THE

STATE OF ILLINOIS,

)

STATE OF IWNOIS

)

Pollution Control Board

Complainant,

)

)

vs.

)

No.01-167

)

(Land

—

Enforcement)

ESG WATTS,

INC.,

an

Iowa corporation,

)

)

Respondent.

)

Respondent’s Supplemental Production

of Evidence

for Hearing

Respondent,

ESG WATTS,

INC.,

by and

through

its

Corporate Counsel

Larry A.

Woodward,

pursuant

to

35

IlIAdmCode

§101.626

and

pursuant

to

agreement

of

the

parties

and

Hearing

Officer

ruling

hereby produces

the

following written

testimony for

admission into the

record.

The written testimony consists of the written testimony under

oath of Kenneth

Liss

and

it

is

tendered

pursuant to

35

IlIAdmCode

§101.626(d), which

provides

that

such

is

subject

to

objection

and

cross-examination;

Complainant

has

waived

its

right

of

cross-examination.

Complainant

has

reserved

the

right

to

make

certain

objections to said testimony in

its

written

briefs.

32.

The

written

testimony

of

Kenneth

Liss

and

exhibits

attached

thereto.

(Exhibits Group

17,

18,

Group

19,

and Group 20 are

attached hereto but

were admitted

at the

hearing held on June 3,

2003.)

WHEREFORE,

Respondent

moves

instanter

the

admission

of

the

above

referenced exhibits.

Respectfully submitted,

ESG WATTS,

INC.

By

Lct~rry

A.

Wood,wci~rd~

Larry A. Woodward, Corporate Counsel

Attorney for Respondent

525

17th

Street

Rock Island,

IL

61201

309-788-7700

Dated June

13, 2003

---

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

PEOPLE OF THE

STATE OF ILLINOIS

)

Complainant,

)

PCB No.

01 -1 67

V.

)

(Enforcement)

)

ESG WATTS, INC., an Iowa corporation,

)

Respondent.

)

WRITTEN TESTIMONY OF

KENNETH W. LISS

Respondent,

ESG

WATTS,

INC.,

an

Iowa

corporation,

provides

pursuant

to

Section

101.626(d) of the

Board’s

Procedural

Rules,

35

III. Administrative

Code

101.626(d),

the

written

testimony

of

Kenneth

W.

Liss

for

introduction

and

admission to the

record of the hearing

in the matter referenced

above.

Name and Address

Kenneth

W.

Liss,

L.P.G.,

Director,

Springfield

Office,

Andrews

Environmental

Engineering,

Inc.,

(Andrews

Engineering)

3535

Mayflower

Blvd.,

Springfield,

Illinois

62707.

Qualifications

My

qualifications

include

a

Bachelor

of

Science

(BS)

degree

in

geology,

approximately

fourteen

years

and

6

months

with

the

Illinois

Environmental

Protection Agency (IEPA)

in

hydrogeology, groundwater quality,

compliance

and

permitting

for hazardous and

non-hazardous solid

waste facilities.

I

have

been

working

as

a

consultant

at

Andrews

Engineering

doing

similar

work

for

approximately the past four years and 5

months.

Curriculum vitae

is attached.

Subject Matter of Testimony

The efforts

of Andrews Engineering to comply

with the

permit requirements of 35

Ill.

Adm. Code

Part 807 and Parts 810-814 as applied to the Taylor Ridge Landfill

on behalf of ESG WATTS, INC..

Factual Testimony

Andrews

Engineering

was

hired

in

February,

2000

by

representatives

of

ESG

Watts,

Inc.

(Watts)

to

prepare

technical

responses

to

the

IEPA

deficiencies

related to

closure of the Taylor

Ridge

Landfill

(landfill)

and the

preparation of

a

significant permit

application

pursuant to

the

requirements of

35

III.

Adm.

Code

Parts

807

and

810-814.

Concurrently Andrews Engineering

staff drilled

borings

1

---

and

installed additional

monitoring wells

at the landfill at the request of the

IEPA

and

approval of Watts.

Drilling

and

well

installation

was

completed

in

May of

2000.

An

assessment

monitoring

program

including

revised

background

standards

and

groundwater classification was

prepared

in

the

fall of 2000.

The

permit 2000-077SP was

issued

in December 2000.

Under

my

direction

and

based

upon

my

personal

knowledge

Andrews

Engineering

has

prepared

numerous

documents,

attended

meetings

or

conducted conference calls with

the

Illinois Environmental Protection Agency and

representatives of the

Office of

the

Attorney General

for

purposes of

resolving

the outstanding

permit issues at the Taylor Ridge Landfiil.

I

am

including two

memorandums prepared

by my staff documenting written

and

oral communications as indicated

above.

1)

Memorandum

dated

May

30,

2003

from

Bryan

Johnsrud

to

Kenn

Liss

titled Watts Landfill, Project summary,

3 pages; and

2)

Memorandum

dated

May

30,

2003

from

Bryan

Johnsrud

to

Tom

Jones,

ESG

Watts,

Inc., titled

Watts

Landfill, Significant

Modification Summary,

I

page.

The list of communications includes extension requests to the

IEPA for purposes

of responding to verbal or written draft deficiency comments.

Andrews Engineering prepared

information documenting that the

landfill does

not

exceed

the

volume

constraints

of the

permit.

The

information

identifies

areas

where

waste

and

cover

material

(soil)

exceed

the

maximum

permitted

waste.

elevation

(vertical limits).

A proposal

to

leave

the waste

in

place

or

relocate

the

waste

to

other

areas

of

the

landfill

as

an

alternative

was

discussed

with

representatives of the

IEPA and AGO.

Both options were discussed

in favorable

terms.

Representatives of ESG Watts,

Inc.

indicated that they wanted to

present

the

proposal to

leave the waste in

place to the

Rock Island

County Board

(RICB)

if the

IEPA

and

AGO

were

not

opposed.

If the

IEPA or AGO

were

opposed

it

would

not

make

sense

to

expend

the

resources

presenting the

proposal

to

the

RICB.

At that time no opposition was voiced.

Andrews

Engineering

prepared

plans

and

information

for

the

waste

relocation

proposal

and

participated

in

meetings with

the

IEPA,

AGO and

the

Rock

Island

County Board

(RICB) for

this same purpose.

The RICB

was agreeable to leaving

the

overfill

in

place

with

final

cover

and

adequate

environmental

controls

(leachate and gas

management).

The

alternative would

be

relocating

approximately

34,100 cubic

yards of waste

over

5.9

acres,

28,500

cubic yards of

cover,

12,600

feet of gas

system

piping

and

1,240 feet of leachate system

piping.

It was the general opinion that moving

the waste to

areas below the maximum

permitted

waste

elevation

would

disrupt

2

---

the

current environmental controls

and

may disturb

approximately 16

total acres

of covered

waste

in

the

process.

However at

our final

meeting

with

RICB

we

were informed that AGO

contacted

the

RICB

and

recommended

that the

Board

not approve the

plan.

Andrews

Engineering

has

continued

to

work with

the

IEPA

on

the

alternative

plan,

relocation

of

the

projected

overfill,

in

order

to

resolve

the

issues

in

a

practical

and cost effective manner.

Our submittals

also include

information and

technical

proposals

to

address

run-off,

groundwater

monitoring,

groundwater

assessment and other issues related to closure and compliance.

Count

I

Andrews

Engineering

prepared

and

submitted

a

permit

application,

IEPA

Log.

No.

2001-459 to

revise

the

current

closure

plan

in accordance

with

discussions

and negotiations concerning the

technical requirements.

Count

II

Andrews

Engineering

has

prepared

and

submitted

information

to

the

IEPA

concerning

the

alleged odor

problems at the landfill including technical

proposals

for

the

purposes

of a

significant

modification

permit

IEPA

Log

No.

2001-168.

However the

current

contract with

Resource Technology Corporation

(RTC)

has

prevented

implementation

of any

immediate

remedies

to

control

odor

or

adjust

the gas recovery system.

Count Ill

Andrews

Engineering

has

prepared

and

submitted

information

to

the

IEPA

concerning

redirecting

the

stormwater

runoff

at

the

landfill

including

technical

proposals

for

the

purposes

of

a

significant

modification

permit

IEPA

Log

No.

2001-1 68 and IEPA Log No. 2001-459 for the

same.

Count IV

Andrews

Engineering

has

prepared

and

submitted

information

in

the

form

of

permit applications and discussion documents to the

IEPA concerning the

overfill

issue

at

the

landfill.

Included

in

the

documents

is

a

Health

and

Safety

Plan

(HASP)

for

the

relocation

of

the

waste.

The

HASP

includes

measures

to

adequately

protect

worker

and

property

owner

exposure

to

the

resulting

emissions

of

asbestos,

methane

and

hydrogen

sulfide

while

the

waste

is

exposed

and

moved

to

other

areas of

the

landfill.

IEPA

Log

No.

2001-459

specifically includes this information.

3

---

Opinion and Conclusion of Testimony

Andrews

Engineering

has

prepared

numerous

documents

in

the

form

of

memorandums,

permit

applications

and

addendums

on

behalf

of

Watts

to

address

the

environmental

and

regulatory

issues

at

the

Taylor

Ridge

Landfill.

Since our initial

engagement to provide

services to Watts we have

been directed

to

provide technical

solutions to satisfy the issues surrounding the

landfill that are

feasible and

protective of the environment.

It

is my opinion

and

conclusion

that the

potential

adverse environmental

impact

associated with the relocation of waste does

more harm than good.

Disruption of

the

environmental

controls

and

exposing

the

waste,

which

includes

asbestos

material, will

not mitigate the

IEPA concerns of final cover and runoff.

Field

work

conducted

to

date

and

provided

to

the

IEPA

indicates

there

is

no

immediate

environmental threats

due

to

the

waste

identified

as

overfill.

The

plans

and proposals submitted to date were

modified to

incorporate the concerns

ofthe

IEPA,

AGO and adjacent property owners of the

landfill.

Based

on

my

experience

the

technical

remedies

prepared

by

Andrews

Engineering

on

behalf

of

Watts

appear

to

be

evaluated

under

a

more

conservative interpretation of the applicable regulations.

Verification

Upon

penalties

as provided by law pursuant to

Section

1-109 of the Code of Civil

Procedure,

I

KENNETH

W.

LISS,

certify

that

the

opinion

and

conclusions

testimony set forth

above

and the

recitation

OF

facts

in

the

record

are true

and

correct, to the best of my knowledge

and belief.

RESPEGIT~tj’LLY

SUB

TED,

4

---

A44

ANDREWS ENVIRONMENTAL

ENGINEERING

INC.

Kenneth W. Liss, P.G.

Principal-in-Charge

YEARS WITH ANDREWS

Mr.

Liss,

a

Licensed

Professional

Geologist,

joined

Andrews

Environmental

Engineering’s

Springfield

office

as

Director

of

Environmental

Services,

providing

a broad

range

of

environmental

YEARS WITH

OTHER FIRMS:

15

experience

to

industry,

government

and

individuals.

He

was

the

manager of the Groundwater Unit in

the Permit

Section of Bureau of

EDUCATION

Land at the Illinois

Environmental Protection Agency (IEPA) prior to

Bachelor of Science!Geoloey/lllinois State

...

.

.

University/ 1983

joining

Andrews.

His

experience

includes

permitting

for hazardous

and

non-hazardous

facilities;

determining

appropriate

responses

to

environmental

impacts,

and

responsibility

for

broad

regulatory

and

PROFESSIONAL REGISTRATION

legislative

issues

concerning

groundwater

at

the

state

and

national

Professional Geologist/IL’1997

levels.

He

was

appointed

to

the

first

Board

of

Licensing

for

OSHA Hazardous

Waste Site Worker Certification (40

hr)

Professional

Geologists in Illinois and is currently under appointment

from

the

Governor’s

office

to

the

Illinois

Site

Remedial

Advisory

OSHA Hazardous

Waste Site Worker Certification (8

~)

Comi’nittee.

He

has

held

both

a

technical

and

an

administrative

role

in

the

SPECIALTIES

.

.

.

development of new

le2islation and

rule

makiun

at the

‘state

level.

State and

Federal groundwater regulations and policies

Some

of these

roles

have included preparation

of dockets

for

risk-

Groundwater contaminations and geologic investigations

based

decision

making

(TACO)

and

for

utility

coal

combustion

Ne~otiatin~

solutions to regulatoiy issues

wastes,

modification to

existing

non-hazardous

landfill

rules

and the

Part

620

groundwater

rules.

He

currently

serves

on

a

1

0-member

Sitewide environmental remediation planning

rules

committee

under

appointment

from

the

Illinois

Governor’s

Program management for RCRA and state solid waste

office,

which is

modi~ingthe

TACO

Underground

Storage

Tank

permitting programs

(LUST) and Site Remediation Program (SRP) regulations.

Mr. Liss has performed or managed regulatory and teclrnical oversight

for approximately

200

active

RCRA projects

with

corrective action,

closure,

CERCLA,

post-closure and permitting

issues.

He

has

also

managed or prepared non-hazardous

waste permits for more than

160

state facilities with a majority being solid waste landfills.

Mr.

Liss

was

an

expert

witness

for

the

Illinois

Environmental

Protection

Agency

as

part

of enforcement,

rule

making

and

public

hearing

proceedings.

He

continues

to

provide

expert

witness

testimony for clients concerning site

characterization and remediation

decisions.

He has also

worked with

the United

States Environmental Protection

Agency

as

a panelist

for

the

Managing

Corrective

Actions

RCRA

Petroleum Refineries

forum.

He

was

also

a member of the

RCRA

Permit

Quality

Review

Team

and

the

NEIC

Hazardous

Waste

Groundwater Task Force.

He also

assisted in the development of the

“RCRA Inspector’ s Guidance Manual.”

---

ANDREWS ENVIRONMENTAL ENGiNEERING INC.

2000-101/0008

3535

Mayflower Blvd.

Springfield,

IL

62707-9401

Tel:

(217)

862-2513

Fax:

(217)

787-9495

Email: bjohnsrud~andrews-eng.

corn

FAX TRANSMITTAL

Date:

May 30,

2003

To:

Tom Jones

ESG Watts,

Inc.

8400

-

77th

Street West

Taylor Ridge,

IL

61284

Tel:

(309) 798-2266

Fax:

(309) 798-2268

Email: tjmacaw~aol.com

From:

Bryan Johnsrud,

P.E.

Senior Project Engineer

-

AEEI

Subject:

Watts

Landfill

Significant Modification Summary

Here

is

a summary of the activities with

respect to the (only)

significant modification application

that Andrews Environmental

Engineering

Inc. (AEEI) has been involved with for Watts

Landfill:

1.

May

07,

2001

—

Significant

Modification

Application

submitted

by

AEEI

to

the,

Illinois

EPA

2.

May 08, 2001

—

Application was assigned Log

No. 2001-168 by the

Illinois EPA

3.

June 06,

2001

—

Determination of incompleteness

issued by

the Illinois EPA

4.

July 11,2001

—Addendum ito

Log

No. 2001-168 submitted

byAEEl to the

Illinois

EPA

5.

July26, 2001

—Addendum 2 to Log

No. 2001-168 submitted

byAEEI to the Illinois

EPA

6.

August

08,

2001

—

Determination

of

administrative

completeness

and

notification

of

intent issued by the Illinois

EPA

7.

August

29,

2001

—

Response

to

notification

of

intent

submitted

by

Gardner,

Carton

&

Douglas to the Illinois

EPA

8.

October 09,

2001

—

Application denial

issued by the

Illinois

EPA

It

is

our

understanding

that

three

other

significant

modification

applications

were

submitted

previously

and

subsequently

denied

by

the

Illinois

EPA.

They

included

Log

No.

1994-436

denied

February

16,

1995,

Log No~1996-385

denied

August 05,

1997,

and

Log

No. 1997-323

denied

on

July 24,

1998.

Please contact

us

if you

have any

questions.

Thank you.

Cc:

Kenn Liss

—

AEEI

Springfield

C:\Documents and Setfing&Andrews Engineering\Local Settings\Temporary InternetFiIes\OLK3F5\052903 Sig Mod

Summary. doc

Page

1 of I

---

ANDREWS ENVIRONMENTAL ENGINEERING INC.

2000-101/0008

3535 Mayflower Blvd.

Springfield,

IL

62707-9401

Tel:

(217) 862-2513

Fax:

(217)

787-9495

Email: bjohnsrudc~andrews-eng.

corn

MEMORANDUM

Date:

May 30,

2003

To:

Kenn

Liss

From:

Bryan Johnsrud

Subject:

Watts Landfill

Project Summary

.

.

Here

is

a

list of submittals

to,

meetings with, and calls

to,

the Illinois

EPA

or Attorney General’s

office (AGO)

on behalf of ESG

Watts,

Inc. for the Watts Landfill:

February 11, 2000

-

FOIA request was submitted

to the Illinois

EPA

February 29,

2000

-

Application (Log

No. 2000-077) was

submitted

to the Illinois

EPA

April 03, 2000 to September 06,

2001

-

Monthly

progress reports

were prepared

and forwarded

to

ESG Watts,

Inc.

for inclusion

in documents

being submitted

to the Illinois AGO.

May 12, 2000

-

Technical concerns response was submitted to the

Illinois AGO

May 25, 2000

-

Teleconference with the Illinois

EPA

May 26, 2000

-

Extension

to

Log No. 2000-077 was submitted to the

Illinois

EPA

June 20,

2000

-

Notification

of borrow area expansion was submitted

to the Illinois

EPA

June 22, 2000

-

Status letter was submitted

to the Illinois

EPA

June 30,

2000

-

Addendum

1

to Log

No. 2000-077 was

submitted

to the

Illinois

EPA

July

14,

2000

-

Teleconference with the Illinois

EPA,

Extension to

Log

No. 2000-077 was

submitted

to

the Illinois EPA

August 08, 2000

-

Extension

of Log

No. 2000-077 was

submitted

to the

Illinois EPA

August

09,

2000

-

Teleconference with the Illinois EPA

August 28, 2000

-

Extension

to

Log No. 2000-077 was

submitted

to

the

Illinois EPA

October 03, 2000

-

Application for NPDES

permit replacement was

submitted to

the Illinois EPA

October 04, 2000

-

Teleconference with the Illinois

EPA,

A Judgment and

Injunction Order

response was

prepared and

forwarded to

ESG Watts,

Inc.

for inclusion in

a document

being submitted

to

the Illinois AGO.

October 06, 2000

-

Extension to

Log

No. 2000-077 was submitted

to the

Illinois

EPA

October 11, 2000

-

FOIA request was submitted to the

Illinois

EPA

November 03, 2000

-

Regulated recharge areas

inquiry was submitted

to the Illinois EPA

November 08, 2000

-

Addendum 2 to

Log No. 2000-077 was submitted

to the Illinois EPA

December 08, 2000

-

Teleconference with the Illinois

EPA,

Extension to

Log

No. 2000-077 was

submitted to

the Illinois

EPA

December 12, 2000

-

FOIA request was

submitted

to the Illinois

EPA

January 05, 2001

-

Teleconference with the Illinois EPA

January 08, 2001

-

Letter of

Understanding was submitted

to

the

Illinois

EPA

April

06, 2001

-

Application (Log No.

2001-1 32) was

submitted

to

the

Illinois EPA

April

13, 2001

-

Quarterly groundwater monitoring review was

submitted to the

Illinois EPA

May 07,

2001

-

Significant Modification

Application (Log

No. 2001-068) was submitted

to the

Illinois

EPA

May

10,

2001

-

FOIA requests was submitted

to the

Illinois

EPA

June

04,

2001

-

Addendum to

Log No. 2001-132 was submitted

to the

Illinois EPA

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MEMORANDUM (CONTINUED)

June

12,

2001

-

NPDES clarification

was

submitted

to

the Illinois

EPA

June

18, 2001

-

Stormwater impacts

evaluation was

prepared

and forwarded

to

ESG Watts,

Inc.

for inclusion

in a document being submitted

to the Illinois AGO.

July 05,

2001

-

Teleconference with

the Illinois EPA,

Extension to

Log

No.

2001-1 32 was

submitted

to the

Illinois

EPA

July 11,

2001

-

Addendum ito

Log

No. 2001-1 68 was

submitted

to the

Illinois EPA

July 13,

2001

-

Quarterly groundwater monitoring

review was submitted

to the Illinois EPA

July 26, 2001

-

Addendum 2 to

Log

No. 2001-168 was

submitted

to the Illinois

EPA

August 21, 2001

-

Teleconference and

meeting with the

Illinois

EPA

September 04, 2001

-

Letter of Understanding was

submitted

to

the Illinois

EPA

October 29,

2001

-

Meeting

with the Illinois

EPA and AGO

October 31, 2001

-

FOIA request was

submitted

to the

Illinois

EPA

December 07, 2001

-

Application

(Log

No.

2001-459) was submitted

to

the Illinois

EPA

January 07, 2002

-

FOIA request was

submitted

to the

Illinois

EPA

January 22, 2002

-

Revised

closure plan was prepared

and forwarded to

ESG

Watts,

Inc.

for

inclusion in documents being

submitted

to the Illinois AGO.

March 01, 2002

-

Teleconference with the Illinois EPA

March

05, 2002

-

Teleconference with

the Illinois EPA

March

11, 2002

—

Extension

to Log

No. 2001-459 was

submitted

to the Illinois

EPA

March 25, 2002

-

FOIA request was

submitted

to the Illinois

EPA

April 04, 2002

-

FOIA request was submitted

to the

Illinois

EPA

April 09, 2002

-

FOIA

request was

submitted

to the Illinois

EPA

April 26, 2002

-

FOIA

request was submitted

to the

Illinois

EPA

August 26, 2002

-

Addendum

1

to Log

No. 2001-459 was submitted

to

the

Illinois EPA

August 28, 2002

-

Teleconference with the Illinois

EPA,

Extension to

Log

No. 2001-459 was

submitted

to

the Illinois EPA

October 31, 2002

-

Teleconference with

the Illinois EPA

November 01, 2002

-

Teleconference with the

Illinois EPA,

Extension

to

Log

No. 2001-459 was

submitted

to the

Illinois EPA

November

08, 2002

-

FOIA

request was

submitted

to the

Illinois

EPA

November

15, 2002

-

Teleconference with the Illinois EPA

November 22, 2002

-

Teleconference with the Illinois EPA,

Extension

to

Log

No. 2001-459 was

submitted

to the Illinois EPA

January 10,

2003

-

FOIA

request was submitted

to the

Illinois

EPA

January 15,

2003

-

Teleconference with

the Illinois

EPA,

Extension

to

Log

No.

2001-459 was

submitted

to the Illinois

EPA

January 24, 2003

-

Addendum

2 to

Log No. 2001-459 was submitted

to the

Illinois

EPA

March 13, 2003

-

Teleconference with

the Illinois

EPA

March 14, 2003

-

Teleconference

with

the Illinois

EPA,

Extension to

Log

No. 2001-459 was

submitted

to

the Illinois

EPA

March

19, 2003

-

Teleconference

with

the Illinois

EPA

March 24, 2003

-

Meeting Agenda was submitted

to

the

Illinois EPA

March 25, 2003

-

Meeting with

Illinois

EPA

March 28, 2003

-

Teleconference with

the Illinois EPA,

Extension

to

Log No. 2001-459 was

submitted

to the

Illinois EPA

April

15, 2003

-

FOIA request was submitted

to

Illinois EPA,

Teleconference

with the

Illinois

EPA

April 24, 2003

-

Teleconference with the Illinois

EPA

April

28, 2003

-

Teleconference

with the Illinois

EPA

April

29, 2003

-

Extension to

Log

No. 2001-459 was

submitted

to the

Illinois

EPA

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MEMORANDUM (CONTINUED)

May 21,

2003

-

Information request submitted

to the

Illinois

EPA,

Teleconferences with

the

Illinois

EPA

May 22,

2003

-

Information

request submitted

to the

Illinois

EPA

May 27,

2003

-

Information request submitted

to the

Illinois

EPA

There

are

undoubtedly

many

other calls

to

the

Illinois

EPA that

did

not warrant

documentation

in the project file.

There were also

correspondence and

teleconferences with

representatives

of

ESG Watts,

Inc.

and other agencies.

Please contact me

if you

have any

questions.

Thank you.

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