RECE~VED
CLERK’S OFFICE
BEFORE
THE ILLINOIS POLLUTION
CONTROL BOARD
JUL
08
2004
IN
THE
MATTER OF:
)
pn~iBoard
PETITION OF JO’LYN CORPORATION
)
and
FALCON WASTE AND RECYCLING)
AS
04-02
for an ADJUSTED
STANDARD from
)
(Adjusted Standard
—
Land)
35
ILL.ADM.CODE PART 807 or,
)
in the alternative, A FINDING
OF
)
INAPPLICABILITY.
)
NOTICE OF FILING
To:
(See attached Service
List.)
PLEASE TAKE NOTICE
that on this
8th
day of July 2004,
the following was filed
with
the
Illinois
Pollution
Control
Board:
Amended
Petition for
Adjusted
Standard,
which
is
attached
and
herewith
served
upon you.
JO’LYN
CORPORATION and
FALCON WASTE AND
RECYCLING
By:
~
EIiz~Jeth
S.
Harv~
“~4t~orney
for
Petitioner
Elizabeth
S. Harvey
SWANSON,
MARTIN & BELL
One IBM
Plaza, Suite 3300
330
North Wabash Avenue
Chicago,
Illinois
60611
Telephone:
(312)
321-9100
Firm I.D. No. 29558
CERTIFICATE
OF SERVICE
I,
the undersigned
non-attorney,
state
that
I
served
a copy
of the
above-described document to
counsel of record in the above-captioned
matter via
U.S.
Mail at One IBM
Plaza,
Chicago,
IL 60611
on or
before 5:00 p.m. on July
8, 2004.
•
,~‘.
~
(~~nett~-~M.
Podlin
x
Under penalties
as provided
by law
pursuant to
735 ILCS 5/1 -109,
I certify
that the statements set forth
herein
are true and correct.
Mr.
John
J. Kim
Division of Legal Counsel, IEPA
1021
North Grand Ayenue East
P.O. Box 19276
Springfield,
IL 62794-9276
SERVICE LIST
RECE
WED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
JUL
fiB
2004
STATE OF ILLINOIS
IN
THE MATTER OF:
)
Pollution Control Board
PETITION OF JO’LYN CORPORATION
)
and FALCON WASTE AND RECYCLING)
AS 04-02
for an ADJUSTED STANDARD from
)
(Adjusted Standard
—
Land)
portions of 35 Ill.Adm.Code 807.103 and
)
35 IIl.Adm.Code 81 0.103, or
)
in the
alternative, A FINDING
OF
)
INAPPLICABILITY.
)
AMENDED PETITION FOR ADJUSTED STANDARD
Petitioners
Jo’Lyn
Corporation (“Jo’Lyn”)
and
Falcon
Waste
Disposal
(“Falcon”)
(collectively, “petitioners”) hereby submit their amended petition for adjusted standard.
Backciround
On
April
21,
2004,
petitioners filed their
petition for
adjusted
standard, or
in
the
alternative,
a finding
of
inapplicability.
Petitioners
seek
a
determination
that the
raw
material
used
in their production process is not
a
“waste,” and that therefore they do
not
need waste permits
pursuant to the
Board’s
regulations.
In the
alternative,
if the
Board
disagrees
that the
material
used
is not
a waste,
petitioners seek an adjusted
standard
from
portions of the
Board’s waste regulations.
On
May 20, 2004,
the Board issued an
order
directing
petitioners
to
provide
additional
information
in
support
of the
petition.
This
amended
petition addresses the informational
issues identified
by the
Board
in
its
order,
and
is
intended to
be read
in conjunction with
petitioners’ April
21,
2004 petition.
(The sections below coincide with the
numbered paragraphs of the Board’s order.)
Petitioners
continue
to
believe,
as
demonstrated
in
the
adjusted
standard
petition,
that the
material
used
in
the
production
process
is
not a “waste.”
(See Petition
for
Adjusted
Standard,
pp.
3-7.)
The
Agency
determined,
in
1993,
that
the
same
material
used
by
petitioners,
generated
by
the
same
company
(IKO
Chicago)
from
which
petitioners
purchase
their
material,
is
not
a
waste.
(See
Petition
for
Adjusted
Standard,
Exhibit
D.)
Additionally,
the
material
does
not fit
the
regulatory definition of
“waste,”
and
thus
cannot.
be
regulated
as
such.
In
the
alternative,
petitioners
have
sought
an
adjusted
standard.
Petitioners
supply
this
additional
information
at
the
request of the
Board, to support that alternative request, without prejudice to petitioners’
demonstration that the material
is not a “waste.”
Paragraph one.
The
Board
asks
for
the
specific
sections
of
Part
807
from
which
an
adjusted
standard
is
sought,
and
whether
Parts
810
through
817
are
applicable to
petitioners’
operations.
Petitioners
sought
an
adjusted standard
from
all
of Part
807,
as that part
contains
permitting
and
other
requirements
for
solid
waste
management
facilities.
Because
it
is
petitioners’
position
that the
GBSM
should
not
be treated
as
a
“waste,”
petitioners
hereby
identify
the
definitions
of
“facility,”
“solid
waste,”
“solid
waste
management,” “waste,”
and
“unit” contained
in
Section 807.104,
as the
specific section
from
which
an
adjusted
standard
is
sought.
The
GBSM
should
not
be
treated
as
a
“waste,”
and
thus the facility
is
not
a
solid
waste management site.
If the
Board
grants
an
adjusted
standard
from
those
definitions
of
Section
807.104,
the
remaining
provisions of
Part 807 will
not
be
applicable to
petitioners’ facility,
as
it will
not
handle
“waste,”
and will not
be a
solid waste management site.
Petitioners
further
seek
an
adjusted
standard
from
the
definitions
of
“facility,”
“landfill,”
and
“solid
waste”
contained
in
Section
810.103
of
the
Board’s
rules.
Petitioners’
reasoning
is
the
same
as
its
request
for
an
adjusted
standard
from
the
2
enumerated definitions in Section 807.104.
The GBSM should
not be treated as a
“solid
waste,”
and
thus petitioners’
facility
is
not
a
“landfill.”
If the
Board
grants
an
adjusted
standard from
the
identified
definitions of Section 810.103,
the
provisions of Parts
811
through
817 are not applicable to petitioners’ facility.
The Board
also
inquired about the
applicability of 35
llI.Adm.Code
720.130 and
720.131.
These
sections
allow
the
Board
to
make
solid
waste
determinations
that
certain
types
of
reclaimed
and
recycled
materials
are
not
solid
wastes.1
Petitioners
have
not
specifically
pursued
such
a
determination
under
Sections
720.130
and
720.131,
because
those
determinations
are
valid
only
for
one
year,
and
must
be
renewed
each year
by
filing
a
new
application.
(35
lll.Adm.Code
720.131(a).)
For
a
small
business
such
as
petitioners,
pursuing
a
new determination
every
year
is
cost-
prohibitive,
and
results
in
continuing
uncertainty
about
whether
the
business
will
be
allowed
to continue
in
the
next year.
More importantly,
petitioners
have
demonstrated
that they should
be granted
an adjusted
standard from
the definitions of Parts 807 and
810,
as
outlined
above.
An
adjusted
standard
from
those
definitions
will
provide
petitioners with
a permanent solution.
Paragraph two.
The
facility
is
located
at
1200
North
Rose
Farm
Road,
Woodstock,
McHenry
County, Illinois.
Paragraph three.
1
In making those determinations,
the Board uses the adjusted standard procedures.
35 llI.Adm.Code 720.133.
3
The area
used
in petitioners’
processing
of the
GBSM
is
approximately the
size
of a football field.
The facility
has four employees.
There are two employees involved
in the
processing of the
material.
Additionally,
petitioners employ two drivers to haul the
material from
IKO Chicago to petitioners’ facility.
Petitioners
first
purchased
a
small
amount
of
GBSM
in
late
2000.
(See
paragraph
nine,
below.)
That
small
amount
was
stored
at
another
site
(2
Kennedy
Road,
Harvard,
Illinois)
over
the
winter
of
2000-2001.
Petitioners’
current
facility
opened on
February
1, 2001, and
is therefore
approximately three years old.
The only
necessary
pollution
control
equipment
is
the
muffler
on the
horizontal
grinder used
to
process the material.
Paragraph four.
The
Board
asks whether,
if the
GBSM
is
a
“waste,”
it
is
a
“special
waste”
and
thus
be
subject
to
the
special
waste
hauling
requirements of Part
809
of the
Board’s
rules.
GBSM
is not
a
special waste.
Under the former special waste rules, the Agency
declassified
IKO
Chicago’s
“roofing
product manufacturing
waste” as
a special
waste.
“Roofing
product
manufacturing
waste”
was
defined
as
an
accumulation
of
nonhazardous
paper,
asphalt,
mineral,
and
glass
material,
kept
separate
from
the
shingles sold to the
end user.
(See the Agency’s January
14,
1994 letter, attached
as
Exhibit
H2.)
It
is
important
to
note
that,
while
GBSM
could
be
included
within
that
definition
of “roofing
product
manufacturing
waste,”
GBSM
is
merely
a
subset of that
“waste.”
GBSM
does
not contain glass or other “contaminants.”
2
Exhibit
H
is the first exhibit to this amended
petition.
Exhibits A through
G are attached
to the
original
petition for adjusted standard.
4
When the
Board amended
its
special waste rules
in
1999,
it included
a
provision
that all Agency declassifications would
remain effective for two years.
(35
Ill.Adm.Code
808.101.)
Thus,
the
Agency’s
declassification
of
the
“roofing
product
manufacturing
waste” (which includes GBSM) remained effective until July 1, 2001.
Under the current
“special waste” statutory and
regulatory scheme, the
GBSM
is
eligible
for
self-certification
by
the
generator
(for
example,
IKO
Chicago)
that
its
industrial
process
waste
is
not
“special
waste,”
pursuant to
Section
22.48 of the Act.
(415
ILCS 5/22.48.)
The GBSM,
even
if considered
industrial
process waste, does
not
fit
into any of the
categories
(i.e.,
liquid
waste,
contains
asbestos
or
PCBs,
delisted
hazardous waste, decharacterized
hazardous waste or a waste resulting from shredding
recyclable
metals) which would
prohibit the generator from
self-certifying
the waste as
non-special waste.
Petitioners will
utilize only GBSM which
has
a
certification from
the
supplier that the GBSM
is not special waste. The GBSM
is not
a special waste, and thus
is not subject to the
special waste hauling requirements.3
Paragraph five.
The
only air emissions at the
facility are
minimal
emissions from
the
muffler
on
the
grinder.4
The grinding
process
itself uses
a
light mist of water,
so
there
is
no dust
from the grinding.
~The definition
of “special waste”
in
Part 809
specifically exempts
industrial process wastes
certified
by
its
generator under Section
22.48 of the Act.
(35 III.Adm.Code 809.103.) Thus, because the GBSM
does
not fit the
regulatory or
statutory definition
of “special
waste,” the
special
waste
hauling
requirements
of
Part 809 are
not applicable.
~Petitioners
note that
they applied for an
air permit at the direction of the
Agency, and
did so after
being
told that no land permit was necessary.
See Petition for Adjusted Standard, pp. 2-3.
5
Paragraph six.
As noted
in
the
adjusted standard
petition,
petitioners currently purchase GBSM
~jy
from
IKO
Chicago,
Inc., which
is the
entity to
which the Agency’s
1993 solid waste
determination
was
addressed.5
Thus,
the only
GBSM
currently used
by petitioners
is
the
GBSM which was the
subject of the Agency’s solid waste determination.
Petitioners
would,
of
course,
like to
expand
their
business
at
the
conclusion
of this
process
by
seeking
to
contract
with
other
shingle
manufacturers
in
Illinois.
However,
petitioners
have
not
yet
pursued
contracts
with
other
manufacturers
while
petitioners
seek
resolution of this matter.
Any GBSM
pursued from other manufacturers
would be used
only if
it
met the
definition of GBSM
(see
paragraph
7),
so as
to ensure the
integrity of
the
process and to guard against “unsuitable applications resulting
in subsequent waste
problems.”
Petitioners
have
created
two
test
sections
to
demonstrate
the
product
performance of
Eclipse
Dust
Control
(the
market
name
for
the
GBSM
as
applied
by
petitioners’
process).
In
August 2001
petitioners
spread their first test section:
it has
maintained
durability,
even
though
the
installation
specifications
have
been
improved
since
the August
2001
pavement
was
installed.
The test
section
has
bonded
to
the
gravel
base
and
formed
a solid
road
base.
In
addition
to the
expected
elimination
of
dust on
the
road
surface,
petitioners
and
the
owner
of the
property were
pleased
to
learn that
the
product
also
virtually
eliminates
noise:
it
is
as
if
the trucks
using
the
surface travel
on
carpet.
The August 2001
test section
has now held
up through three
winters, even
with
plowing,
and shows no deterioration.
There is
no cracking or rutting
~That
GBSM
is
generated
at
IKO
Chicago’s Bedford
Park,
Illinois
facility,
as
approved
in
the
Agency’s
solid waste determination.
6
of the
surface.
(Please
see
letter from
the property owner of the test section, attached
as Exhibit
I.)
Petitioners’
second test
section
was applied
as
a
driveway
in
September 2002.
The
material
was
applied
to
current
installation
specifications
(see
paragraph
eight,
below,
for
current
installation
specifications),
but
the
GBSM
was
ground
to
a
smaller
size
(1/2 inch pieces) than currently used
(3 to 5
inch pieces).
There is
a
slight hairline
cracking
of the
surface
(which
was
the
reason
for
increasing
the
size
of
the
ground
pieces),
but
the
material
has
maintained
over
two winters.
(See
picture
attached
as
Exhibit J.)
These two test sections continue to
perform today.
The test
sections have
also
demonstrated
additional
benefits
beyond
the
expected
dust
and
mud
reduction.
The
test
pavements
have
dramatically
reduced
the
noise
from
vehicles
traveling
over
the
pavement.
Additionally,
the
material
is not as stiff as blacktop or concrete,
so it bends
and
molds
under
traffic.
While
heavy
trucks
can
crack
the
edges
of
concrete
and
blacktop,
Eclipse
Dust
Control
does
not
crack
due
to
the
resiliency
of
the
product.
When watching
a truck drive over
a surface, one
can literally see that the
Eclipse Dust
Control gives under the truck wheels,
and then returns to
its original position, leaving
no
ruts.
Finally,
some
customers
have commented
on
the
different
look of
Eclipse
Dust
Control.
While
it
appears
similar to
blacktop,
it
has
its
own
look.
Some
parties
are
interested
in
Eclipse
Dust Control
precisely for its different look.
In
short, the
material
and
installation specifications,
and the
excellent
results
on
petitioners’ test sections, demonstrate that the GBSM
is suitable for use
in
Eclipse Dust
Control applications.
7
Paragraph seven.
Petitioners propose the following amended
adjusted standard language:
Jo’Lyn
Corporation
and
Falcon
Waste
and
Recycling
are
hereby
granted
an
adjusted
standard
from
the
following
definitions
of
35
lII.Adm.Code
807.104:
“facility,”
“solid
waste,”
“solid
waste
management,”
“waste,”
and
“unit.”
Jo’Lyn
Corporation
and
Falcon
Waste
and
Recycling
are
further granted
an
adjusted
standard
from
the
following
definitions
of
35
lll.Adm.Code
810.103:
“facility,”
“landfill,”
and
“solid
waste.”
These
enumerated
definitions
do
not
apply
to
operations conducted by Jo’Lyn
and/or
Falcon
at the facility
in
McHenry
County,
Illinois, so long as:
1.
Jo’Lyn and Falcon
continue to use only clean
granulate bituminous shingle
material
(“GBSM”)
acquired
from
a
manufacturer
of
roofing
products
or
other source of clean
GBSM.
2.
For purposes of
this
adjusted standard,
GBSM
is
defined
as
“clean
and
consistent
post-production
material
generated
at
the
end
of
the
manufacturing
of
roofing
shingles,
such
as
tabs
or
punchouts,
and
miscolored
or
damaged
shingles.
GBSM
excludes
post-consumer
material or shingle tear-offs.”
3.
Jo’Lyn
and
Falcon
continue to
grind the
GBSM
into
uniform pieces, either
course ground or fine ground.
4.
Jo’Lyn and Falcon use the GBSM chips to form
paving
surfaces.
5.
Jo’Lyn
and
Falcon
operate the facility
in compliance with
other provisions
of the
Environmental
Protection Act.
Paragraph eight.
The
Board’s
order seeks
additional
information
regarding
product
performance.
First,
the
Board
asked
for
information
supporting
that
applying
GBSM
at
a
two
inch
thickness
is as effective as the
5 to 6 inch thickness specified
in the Agency’s 1993 solid
waste
determination.
Petitioners
do
indeed
apply
the
shingle
chips
at
a
4
to
6
inch
thickness,
prior to compacting.
The installation specifications for the
product,
Eclipse
Dust Control, are as follows:
8
a.
The
site
is
evaluated,
and
low
areas
are
filled
with
grade
9
stone
(approximately
3/4
inch driveway stone) to bring the surface to
a
level base.
A slight arch
is maintained for proper drainage.
b.
The ground
GBSM (ground to a 3 to
5
inch size)
is applied to the
surface,
at the
thickness
of 4
to
6
inches.
The
application
is
done
with
either
a
latent box (black top spreader) or
a
bobcat with
a blade attachment.
c.
The
GBSM
is
then
compacted
to
a
finished
2-3
inch
thickness.
Compaction
is done using
a
10-ton vibratory roller.
Thus, the
application of Eclipse
Dust Control
is done to the
same
specifications
as
approved
by
the
Agency
in
1993.
However,
to
ensure
the
cohesiveness
and
durability
of the
product
as
applied,
petitioners
go
one
step further,
and
compact
the
product
to
a
finished
2
to
3
inch
thickness.
As
petitioners’
test
results
show
(see
paragraph
six, above), the finished, compact paving product is durable and useful.
Second,
the
Board
asks for
performance
information
supporting
the
use of the
product
for
parking
lots,
driveways,
farm
lanes,
animal
feed
areas,
bike
and
walking
paths,
and other surfaces.
As the
Board noted,
the Agency’s determination, finding
that
GBSM
is not
a waste,
focused on the
application of GBSM to “unpaved, muddy,
soft or
dusty
roadways.”
Petitioners
note that the
uses enumerated
in
the
petition for adjusted
standard
(parking
lots,
driveways,
farm
lanes,
animal
feed
areas,
bike
and
walking
paths,
and
other surfaces)
are
essentially the
same as the
Agency’s approved
use of
“unpaved,
muddy,
soft
or
dusty
roadways.”
All
of those
uses
involve
the
paving
of
previously
unpaved
areas, to
reduce
dust and
provide
a consistent
and
even
surface.
Thus,
product performance
information
for
parking
lots,
driveways, farm
lanes,
animal
9
feed
areas,
bike
and walking
paths,
and
other
surfaces,
is
essentially the
same as for
roadways.
In fact,
in
some cases (for example,
bike
and
walking
paths),
any concern
about the
durability of the
surface should
be less than
any concern
about the
paving of
“unpaved,
muddy,
soft
or
dusty
roadways”
(as
already
approved
by
the
Agency
in
1993),
since the weight on
bike and walking
paths
is
less
than the
weight imposed
on
roadways.
Petitioners
are
confident that
application
of
the
product
on
surfaces
very
similar to the already-approved
roadways
is effective.
Paragraph
nine.
The Board seeks information regarding the
quantity of GBSM
purchased,
stored,
processed
and
sold
annually.
IKO
Chicago
(petitioners’
current
source
of
GBSM)
generates
approximately
8300
tons of
GBSM
per year.
However,
to
date,
petitioner
have never purchased or hauled
more than 2900 tons in a single year.
Petitioners
have
bought
and
hauled
5756.25
tons
of
GBSM
from
IKO
Chicago
over
the
years
2000
through
2003.6
The breakdown of petitioners’ annual purchases from
IKO is:
2000
92.46 tons
2001
2168.38 tons
2002
2825.52 tons
2003
669.89 tons
Total
5756.25 tons
Of
that
total,
petitioners
have
used
approximately
400
tons
in
their
test
applications
(see
paragraph
six
above),
leaving
a
current
supply
of
5356.25
tons.
However,
stockpiling of this amount of GBSM
would
not occur under “normal” working
conditions after
approval:
the
GBSM
is currently stored
while
petitioners seek approval
6
Petitioners did
not purchase GBSM in 2004, as they sought to obtain approval for their process from first
the Agency, and now the Board.
10
of the
process.
Essentially
all
of the
existing supply
is currently sold to customers,
with
installation of the
product delayed awaiting
environmental
approvals.
Petitioners
have
contracts with the following customers, committing to purchase GBSM:7
Hartland Township
500 tons
AlgonquinTownship
500 tons
Richmond Township
500 tons
Spring Lake Sand
and Gravel
2080 tons
Various Home Owners
1116 tons
Total Committed
4696 tons
Additionally,
petitioners had
an agreement with
Ben
Indurante for the purchase of
2288
tons.
However,
Mr.
Indurante
was
forced
to cancel
his
order while
petitioners’
operations are
on
hold
awaiting
the
environmental
approval
of the
process,
since
he
needed
the
dust control
immediately.
Thus,
petitioners
have
demonstrated that they
can sell the
material quickly,
resulting in very little, if any, material stored at the facility.
The
production
rate (grinding time)
is approximately 40 tons per hour.
During
an
eight-hour
working
day,
petitioners
are
capable
of
processing
320
tons
of
material,
which equates to
1600 tons per week, and 6400 tons per month.
Assuming
processing
over
a
five
month
period
(May
through
September),
petitioners
are
capable
of
processing
32,000
tons
of
GBSM.
This
capability
far
exceeds
the
supply
of
GBSM
available from
IKO Chicago (8300 tons per year).8
~ These
commitments were
obtained
~na very
short
period
of
time:
approximately
two
weeks
of sales
activity.
As
noted,
petitioners’ operations
are currently
“on
hold,” so
petitioners
have
not pursued sales
opportunities.
However,
petitioners continue
to receive
inquiries about the product, and will pursue those
opportunities and
more as soon as they receive the necessary approvals.
8
As noted
in the
petition for adjusted standard, while
petitioners currently contract only with IKO Chicago,
there
are
other
shingle
manufacturers
in
Illinois
who
are
also
potential
sources
of GBSM.
Petitioners
have not yet pursued
contracts with these other
manufacturers while they
seek resolution
of
this
matter.
Petitioners
would,
of
course,
be
limited
to
use
of
GBSM
which
meets
the
definition
contained
in
the
proposed adjusted
standard.
See paragraph
seven.
Additionally,
the
production
rates provided
are for
11
Because the
application
process
must
be
performed
in
the
summer,
petitioners
do
cease activity for
several
months
over the
winter.
Petitioners
could
theoretically
• have
a
supply of
1500 to
5000 tons of
unprocessed
material at their facility
over t•hat
short “shut down” period.
That supply would be quickly processed and used
as soon
as
the weather
allowed
in
the
spring,
so any
storage is temporary.
Petitioners
would
not
store
processed
material
over
the
winter
months,
because the
material
is
best
used
within two weeks of grinding.9
Even with
the
limited
purchases and
production that petitioners
have
been able
to do
to date
(while
pursuing environmental approvals),
petitioners
have
demonstrated
that they have the capability of purchasing,
selling, and
processing the
GBSM
in
a
short
period
of time.
The
GBSM
material
is
a
clean
and
consistent
pre-consumer
material,
and
contains
no
asbestos,
fiberglass,
nails,
wood
or other “contaminants” which
could
adversely
impact
the
environment
over
the
relatively
short
period
of
storage
of
the
product.
CONCLUSION
As demonstrated
in petitioners’ petition for adjusted standard,
the
GBSM
is
not
a
“waste.”
Thus,
petitioners’ process
is
not subject
to the Board’s
solid waste
rules, and
no adjusted standard
is necessary.
However,
in
the alternative and without
conceding,
if
the
Board
finds
that
the
GBSM
is
subject
to
the
waste
rules,
petitioners
seek
an
adjusted
standard
from
those
rules.
Compliance
with
the
rules
is
economically
unreasonable, and provides
no environmental or health benefit.
one grinder.
If supply
and demand warranted,
petitioners
could
add
additional
grinders,
to
increase their
production capacity and to further minimize the time the GBSM is on site.
~The
material
can
still
be
used
more
than
two
weeks
after
grinding
and
still
be
effective.
Using
the
material within
two weeks
is optimal, however.
12
Respectfully submitted,
Michael J. Maher
Elizabeth S. Harvey
Swanson,
Martin & Bell
One IBM Plaza, Suite 3300
330 North Wabash Avenue
Chicago,
IL 60611
312.321.9100
312.321.0990 (facsimile)
JO’LYN CORPORATION and
FALCON WASTE AND
RECYCLING
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EXHIBIT
b
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Unit Storage
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1!.;Kens~y.:Di1ve.
1~arvard,
lIJInbI5
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B15.94~-~6Z~
•
,i*tyn
Copbratjon
•D~.nF~Jes:
-
•
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.
This letter Is to
Inlorm your~ornp2n~
orour
~atpsfacbon
~4hcur driveway arid parkinO
lots
pe~formanoe
over the lest
three years
Until then thedust wasalrna~t
unbenrotile arid the mud, very annoying
Asyou kflow the drwe~y
~s
~rav~1ed
by both ~uI~ssiid heavy d*it~truok
use
Q~nsidentig
the
abaseand vutually no marntenance weeonoid~r
the
paving elteinative ‘Eclipae Dust Conirol
in
h~
~ sup.encr pr
ductand would jecomrrwund115 Use to otherswith
dust
and
mudproblenis
$ineerely,
V~e
Pres1d~nt
I~1ar!c~raned~ori~th
citi
it
Cd,, h~.
1:
—
EXHIBIT
ii
EXHIBIT
Ii
