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2

-

4:

7:44PM

Sub:

Johns-Manvifle Petitio~’~4-~

Date:

1112212004

6:08:05 PM

~V~Standard

Time

From:

MUNDYCAMP

To:

crowlek@ipcb.S~ate,il.US,mailto:hallorab@ipcb.statejl.us

CC:

Pakcoastal

STATE OF ILLINOiS

Poflution Control

Boan~

Dear Ms. Crowley and

Mr. Halloran,

I have been asked by the Illinois

Dunesland.Preservation Society (The Society) to comment on the

above

reference petition which

will be heard tomorrow in front of the IPCB.

it is our

understanding that three main

issues regarding groundwater and

related contamination will

be addressed.

Our comments are as follows:

1.

Groundwater flows from the JM

site into the Federally Protected Critical Habitat and

State Dedicated

Nature

Preserve of Illinois Beach State Park (the

Nature Preserve).

This special property is under

several State and Federal protections.

The Society is currently seeking re-classification

of the

Nature

Preserve

to Class Ill Special

Resources groundwater.

We ask that the

IPCB consider the special

protections afforded

this property in consideration of future Illinois citizens.

2.

The JM

property is bordered on

the south by property leased to the IDNR as a public access

beach/fishing pier.

The property due west is currently under the

Illinois EPA SRP and will

be used by

the Waukegan

Park District as an

outdoor athletic field and sports complex specifically designed to bring

children into the area.

The property east is the navigable federal and state waters

of Lake Michigan.

The property directly north

is the Federally Protected Critical Habitat and State

Dedicated Nature

Preserve.

The areas

surrounding the JM

site have extensive public access and significant value to the

current and future

citizens of illinois.

We

ask that the

1PCB considerthe highly encouraged

use of the

public property surrounding these JM site when evaluating the adjustments requested in the petition.

3.

The land directly south of the JM site has

undergone recent remediation as “Site

2” of the JM Superfund

cleanup.

During this cleanup of asbestos contaminated

soil, the Society noticed non-asbestos

contamination in the area.

The USEPA investigated and

informed the Illinois EPA in 2002 that non-

asbestos pollution above

Illinois TACO

standards exists in this area.

The Society believes this pollution

mayexist under the JM

property as well.

To our knowledge there has not been any investigation into

this pollution by the Illinois EPA.

We believe this pollution

is

a contributing contaminant to the

groundwater that requires

proper monitoring

and remediation.

4.

The Superfund cleanup inside the JM property was at one time an issue to the State of Illinois.

In a

report of Significant Differences in the Amended Consent Decree, JM was allowed

to cap waste in the

JM site with two feet of clean fill.

The State objected stating a landfill in Illinois would require

more

cover.

The USEPA denied this request by stating the pressure of the additional coverwould force

asbestos contamination in sludge found at the site to enter the groundwater.

The Society is concerned

that the unlined JM

landfill is currently polluting the groundwater in the Nature Preserve.

We ask that the

IPCB review what limited testing has been done pf contaminants inside of the JM site

in soils, sludges,

sediments, and groundwater that enter the specially protected land

and groundwater of the Nature

Preserve.

We ask that proper testing for appropriate contaminants be conducted before considering the

petition.

5.

The Society is currently commenting on the State Consent Order and

is asking to intervene

on the

Federal Amended Consent Decree related to the JM

site.

We

believe that the remedies contained in

both the State and Federal actions are

not protective of human health nor the environment.

The Society

notes that the JM adjustment in the petition can not take place until both the federal and state cases

are

approved by the Courts.

The Society asks that the IPCB delay any decision on the JM

petition until the

State and Federal Courts rule on these issues in the

next few months.

Thank you for your consideration

of our concerns

in this important matter.

Documents in support of our position

are available through the Illinois

EPA.

The Society can produce these support documents upon request.

Cordially,

Jeffery C~

Camplin

1681 Verde Lane

Mundelein, IL 60060-4823

1-(847)-566-5608 Fax:

I -(847)-837-1 852

Cell:

I

-(708).-2 84-4563

---

4;

7:44PP1:

EC:~

I

HI~nois

Dunesland

Preservaflon Sóc~ely

P. 0.

Box 466

Zion,

IL 60099

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A FAX

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FAX Number:

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CLERK’S OFFICE

NOV 2~

2004

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Number:

312-332-3377

STATE OF ILLINOIS

Pollution Control Boar

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