IN

THE MATTER OF:

PETITION OF JOHNS MANVILLE

FOR AN ADJUSTED STANDARD FROM

35

ILL.ADM. CODE PART 814,

§~

811.310,

811.311, 811.318, 811.320

)

)

SEP302004

p~i~ti~

)

AS 04-04

)

(Adjusted Standard-Land)

)

To:

Attached Service List

NOTICE OF FILING

Johns Manville,

Petitioner.

Please take notice that on September 30, 2004, Johns Manville has filed the

attached amended petition for an adjusted standard with the Illinois Pollution Control Board, a

copy ofwhich is hereby served upon you.

Edward P. Kenney

Sidley Austin Brown &

Wood LLP

Bank One Plaza

10 South Dearborn Street

Chicago, Illinois

60603

(312) 853-7000

By:

One ofIts Attorneys

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

)

)

PETITION OF JOHNS MANVILLE

)

FOR AN ADJUSTED STANDARD FROM

)

35 ILL.ADM. CODE PART 814,

§~

811.310,

)

811.311,811.318,811.320

)

AS

04-04

)

(Adjusted Standard-Land

)

)

)

)

)

)

)

PETITIONER JOHNS

MANVILLE’S AMENDED PETITION FOR AN ADJUSTED

STANDARD FOR CERTAIN PROVISIONS OF 35 ILL.ADM.CODE, PARTS 814

AND

811

INTRODUCTION

Johns Manville (“JM”), a Delaware corporation, comes by its attorneys, and

pursuant to

Section 28.1 ofthe Illinois Environmental Protection Act (“the Act”),

415

ILCS

5/28.1

and

35 Ill.Adm.Code

§~

104.400 et seq., seeks an adjusted standard to

certain

requirements ofthe Pollution Control Board’s regulations governing on-site landfills, as will be

described below.

JM owns a facilityin Waukegan, Illinois located on a 350 acre tract on the

shore ofLake Michigan

(~

Figure

1).

JM previously filed a petition with the Board on June 30, 2004.

By Order dated

August

5,

2004, the Board found that petition to be deficient because the factors contained in

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Section 814.402(b)(3) had not been addressed.

The Board directed petitioner to address the

information requirements of Section 28.1 ofthe Act (415 ILCS

5/28.1)

and Section 104.406 of

the Board’s rules in

an amended petition.

After consulting with the Board’s staff attorneys, JM

is

submitting this amended petition.

The caption has changed slightly

to reflect an additional

related regulatory provision for which an adjusted standard is sought. Since the filing ofthe

original petition, JM has had additional discussions with the Illinois Environmental Protection

Agency concerning this proposed adjusted standard and is requesting the Agency’s concurrence

in this

amended petition.

JM filed a public

notice in

a

local newspaper shortly after filing the original

petition.

Because the language ofthe proposed adjusted standard requested in this amended

petition is somewhat different from that

in the original petition, JM intends to

file a new public

notice in accordance with 35

I11.Adm.Code

§

104.408.

Statement Describing Standards

FromWhich Adjusted

Standard

is

Sought, Pursuant to

35

I11.Adm.Code

§

104.406

JM is seeking an

adjusted standard to requirements contained in 35

Ill.Adm.Code

Part 814, which incorporates specific requirements of35 Ill.Adm.Code

§~

811.3 10,

811.3 11,

811.318,

and 811.320 concerning its onsite

landfill, which consists oftwo units:

1) the

miscellaneous disposal pit;

and 2) a portion ofthe collection basin.

These units are depicted in

Figure 2 (General Property Map and On-Site Landfill

Location).

The relevant rules became

effective September 18,

1990.

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Statutory Section 28.1(c) Factors

The regulations which

are the subject ofthis adjusted standard petitionwere

adopted by the Pollution Control Board In the Matter of:

Development of Operating and

Reporting Requirements for Non-Hazardous Waste Landfills, R88-7, and were effective on

September

8,

1990.

A review of the rulemaking record in that proceeding indicates that the

Board was attempting to update and expand its existing regulations

governing sanitary landfills

(Previously Chapter 7 ofthe Pollution Control Board’s regulations) to incorporate more modem

approaches for addressing a variety of industrial and municipal non-hazardous waste landfills.

In this rulemaking, the Board adopted different standards for landfills which were

going to remain open for short periods oftime, landfills that would remain open

for longer

duration, and for existing and new landfills.

The Board also adopted differing standards for inert

waste landfills (no leachate collection, no landfill gas collection, minimal cover, and no

groundwater monitoring requirements) than for landfills where chemical and putrescible waste

would be managed (leachate collection, more substantial final cover, gas collection and

monitoring, and groundwater monitoring) due to the greater likelihood that groundwater quality

could be adversely impacted by the latter category oflandfill.

The regulations were designed to

accommodate both permitted landfills and onsite landfills which were exempt from permit

requirements.

The JM landfill is

different from the landfills considered by the Board in a couple

ofrespects.

First, much ofthe waste in the landfill is virtually inert, being composed primarily

of calcium silicate and fiber glass-based roofing materials.

Although some of the waste in the

landfill may not meet the technical requirements in the inert waste regulations, JM’s landfill

differs from chemical and putrescible landfill in that very little landfill gas is generated.

The

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second major difference is that, unlike most landfills in Illinois,

the JM site was under intense

federal and state oversight since before the adoption of the Pollution Control Board’s solid waste

landfill regulations as a result of its inclusion on the Superfund National Priority List in

1983.

There is nothing in the rulemaking record

indicating that the Board considered situations similar

to that ofthe JM facility, where the facility as a whole was subject to a Superfund consent decree

which required the construction ofcover to

isolate asbestos that had been historically disposed of

on-site.

See the federal consent decree entered by the United

States District Court for the

Northern District ofIllinois in United States v. Manville Sales

Corporation, C.A. No.

88C 630.

At the time the rules were adopted in

1990, JM was well into the construction ofremedial

measures to isolate the asbestos on the site,

and was subject to a federal consent decree which

described in detail how these landfills were

to be constructed

and maintained,

under the close

oversight ofthe USEPA and IEPA.

After the adoption ofthe Board’s solid waste regulations, JM submitted an initial

facility report for the units (collection basin and miscellaneous disposal pit) which the consent

decree authorized to remain open.

In September

1992, JM submitted

an Initial Facility Report to

IEPA for these units.

Due to the nature ofthe waste, JM managed the landfills as inert waste

landfills.

Subsequent testing has verified that, despite the presence ofsmall amounts of

putrescible material, very little landfill gas is generated by decomposition ofthe wastes in the

miscellaneous disposal pit and the collection basin,

as is the case with inert waste landfills. (Gas

generation data is

included as Exhibit 1.) As a result, the gas collection and monitoring

requirements for chemical and putrescible landfills

do not fit the JM landfill.

Similarly,

percolation ofstormwater through the collection basin and miscellaneous disposal pit has not

resulted in the generation ofmuch leachate.

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Strict compliance with the Board’s solid waste regulations governing landfill gas

collection and monitoring and groundwater monitoring in this instance would involve drilling

gas collection wells and groundwatermonitoring wells through the closed Superfund cells.

This

presents the potential for disturbing the underlying Superfund waste,

and also

breaching the

Superfund cover.

There is no evidence in the rulemaking record that the Board addressed or

even considered a similar situation.

The JM landfill also

differs from the landfills considered by the Board in adopting

the rules in that the units subject to the groundwater monitoring requirements are surrounded by

units that were constructed pursuant to

a federal consent decree under federal and state oversight.

The operating and maintenance requirements imposed on JM through that decree restricts JM’s

ability to drill groundwater monitoring wells or gas wells

through engineered covers which

isolate asbestos.

Without obtaining the concurrence ofthe USEPA and JEPA, JM is not as able

to place groundwater monitoring wells

where required by the Pollution Control Board’s rules as

would be a landfill that does not have a remediated Superfund site surrounding the units to be

monitored.

In accordance with Section 28.1(c)(2), the existence ofthese different factors

justifies the issuance ofthe adjusted standard that JM is requesting.

JM is requesting an adjusted

standard to the landfill gas monitoring

and frequency requirements.

Because the JM

landfill is

different from the more typical chemical

and putrescible landfills at which the Board’s solid

waste landfill regulations were directed,

in that much less gas is

generated at the JM

landfill, the

landfill gas collection and monitoring program described in this

adjusted standard petition is

better tailored to this situation

than the one otherwise required by the regulations.

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Likewise, the risks associated with drilling groundwater monitoring wells through

Superfund cover and the underlying asbestos wastes are different from the landfills addressed by

the regulations, and justif~i

the groundwater monitoring program that JM is proposing.

JIM’s

proposed program would minimize the amount ofdisturbance to the Superfund remediated areas,

while providing for a protective monitoring program that will allow timely action in the event

that either ofthe Part 814 regulated landfill units adversely affects groundwater.

The requested adjusted standards will not result in environmental or health effects

that are substantially and significantly more adverse than the effects

the Board considered in

adopting the rules ofgeneral applicability.

In adopting the rules, the Board was trying to provide

for landfills in which waste would be isolated, and operated in such a way that migration of gas

or leachate to groundwater or to ambient air would not be a problem.

To the extent that landfill

gas wouldbe generated, the Board’s regulations provided for it to be monitored

and collected.

To the extent that a chemical and putrescible waste landfill (or later, a municipal solid waste

landfill) would present a potential adverse impact on groundwater, the regulations provided for

implementation ofa groundwater monitoring program that would provide for detection,

assessment and potentially corrective action if a regulated unit is adversely affecting the

groundwater.

The groundwater monitoring program presented in this adjusted standard petition

will similarly provide for detection ofpotential issues in a timely fashioned, allowing officials to

make decisions as to how to protect the groundwater.

Statement That Regulation of General Applicability

Was Not Promulgated to Implement

Federal Requirements Pursuant to 35 IlI.Adm.Code

§

104.406(b)

The regulations ofgeneral applicability that are the subject ofthis adjusted

standard petition were not promulgated to implement the requirements ofthe Clean Water Act,

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Safe Drinking Water Act, Comprehensive Environmental Response, Compensation and Liability

Act (CBRCLA), Clean Air Act, or the State programs

concerning RCRA, UIC, orNPDES.

The

regulations in question implement State, not federal requirements.

According to 35

Ill.Adm.Code

§~

807.101,

811.101, the Board relied upon Sections

5,

21.1, 22, 22.17, 28.1

and

27 ofthe Illinois Environmental Protection Act in adopting the regulations from which the

adjusted standards are sought.

Level of Justification

35 Ill.Adm.Code

§

104.406(c)

The regulations for which the adjusted standards are sought do not contain

specified levels ofjustification, so the factors set forth in Section 28.1(c) ofthe Act apply to this

petition.

Those factors are discussed above.

As will be described in more detail below, JM can

establish that:

the factors relating to

its onsite landfill are substantially different from

the factors

relied upon by the Board in adopting the regulations ofgeneral applicability;

the existence of

these different factorsjustifies an adjusted standard;

the requested standard will not result in

environmental health effects more adverse than the effects considered by the Board in adopting

the rules ofgeneral applicability; and,

the adjusted standard is consistent with applicable federal

law.

BACKGROUND OF JOHNS MANVILLE’S ONSITE

LANDFILL

Description of Petitioner’s

Activities 35 I1l.Adm.Code

§

JM Facility Background and Regulatory History

JM owns a facility in Waukegan, Illinois in Lake County at which JM previously

manufactured building materials, including roofing and insulation products.

The facility is

located on a tract consisting ofapproximately 350 acres on the shore ofLake Michigan.

($~

Figure 1). The facility began operations

ca.

1920, and

employed several thousand employees at

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its peak. Historically,

asbestos-containing building materials were manufactured at the plant, but

all such manufacture ofasbestos-containing building materials ceased in

1985.

After a gradual

phaseout, all of the remaining manufacturing operations at the facility completely ceased in

1998,

and the manufacturing buildings (which represented over

1,700,000 square feet under

roof) were demolished in 2000-2001.

At present, only a few contract employees associated with

maintaining the site are located at the facility.

In 1983, relying on its authority in Section

105

of the Comprehensive

Environmental Response, Compensation and Liability Act (CERCLA), 42 USC

§

9605,

the

United States Environmental Protection Agency (USEPA)

placed a portion ofthe facility

(consisting ofapproximately 120 acres) on the National Priorities List (NPL), which is set forth

in 40

CFR Part 300, Appendix B, by publication at 48

Fed.Reg. 40658 (September

8,

1983).

On

June

14,

1984, JM and USEPA executed an Administrative Order on Consent, under which JM

conducted a Remedial Investigation /Feasibility Study (RIIFS), pursuant to

40 CFR

§

300.68.

The Remedial Investigation Report was submitted on July 3,

1985,

and the Feasibility Study

Report was submitted to

USEPA in December

1986.

USEPA adopted an Addendum to the

Feasibility Study Report on January 28,

1987.

After notice and public hearing, on June 30,

1987

USEPA issued

a Record ofDecision (ROD) in which the State ofIllinois concurred.

The ROD

provided for the placement ofcover over a number ofareas at which asbestos containing waste

materials had been disposed of at the JM

facility.

JM, USEPA and the State ofIllinois executed

a consent decree that implemented the ROD,

and that consent decree was entered by the United

States District

Court for the Northern District ofIllinois on or about March

18,

1988, in

United

States v. Manville Sales

Corporation, C.A. No.

88C 630.

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In addition to providing for cover ofhistorical disposal areas, the Consent Decree

contemplated that ongoing non-asbestos manufacturing operations at the JM site would continue.

The Consent Decree therefore provided for ongoing operation ofboth the wastewater treatment

system, which consisted ofa number ofsettling and retention basins,

as well as

the onsite

landfill.

JM conducted substantial remedial actions at the facility, placing cover over the historic

areas where asbestos containing waste materials had been disposed.

JM’s remedial activities

were largely completed in 1991.

USEPA issued two Explanations ofSignificant Differences (ESD), the first on

February

9,

1993, and the second on September 22, 2000.

The first ESD addressed primarily the

differences between the remedial action as described in the June. 1987 ROD and the remedial

action actually constructed as

necessitated by field conditions. The second ESD provided, in

light of cessation ofmanufacturing operations at the facility,

for closure ofboth the wastewater

treatment

system and the on-site landfill which is the subject ofthis petition.

This adjusted

standard and a amended federal consent decree (lodged in the United States District Court for the

Northern District ofIllinois and likely to be entered in the near future) are intended to implement

the second ESD.

The On-Site Landfill at issue in this petition is physically located on the tract

identified on the NPL, and it is located on and surrounded by units that were remediated under

CERCLA.

The On-Site Landfill at issue in this proceeding began operations

in

1992 and was

not used to

dispose of asbestos-containing materials.

The Illinois Attorney General’s Office and

Illinois Environmental Protection Agency have acknowledged that the landfill that

is subject to

this petition is an “existing landfill” and therefore

subject to 35

Ill.Adm.Code Part 814.

Specific

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requirements contained in 35

Ill.Adm.Code Part 811, including the provisions forwhich the

adjusted standards

are sought, are incorporated by 35

Ill.Adm.Code

§

8 14.302.

As Figure 2

shows, the On-Site Landfill is located within the areal limits ofthe

former Disposal Area landfill that was previously closed (completed in

1992) pursuant to

CERCLA through placement ofa two-foot engineered cover over both topographically flat areas,

as well as the steeply sloping sides ofthe original miscellaneous disposal pit. Figure 3

is a Site

Plan of the On-Site Landfill; Figures

4,

5,

and 6 are cross sections showing the vertical and

horizontal relationship between the On Site Landfill and the underlying “CERCLA” landfill.

Description

ofNature of

Efforts

Necessary

to Comply

With Regulations of General

Applicability, 35

I11.Adm.Code

§

104.406(e)

Because the onsite landfill is located in the midst of the CERCLA

NPL site, any

activities

relating to itmust be coordinated with both USEPA and IEPA.

The United States

Department ofJustice, USEPA, Illinois Attorney General’s Office, IEPA, and JM signed an

amended

federal consent decree which was lodged with the United States District Court for the

Northern District

ofIllinois on February 11, 2004 (Notice ofthat lodging was published at 69

Fed. Reg. 7982 (February 20, 2004)).

Comments have been filed, and

a responsiveness

summary was filed on or about July 16, 2004.

JM anticipates the federal amended consent

decree will be entered by the

Court in the near future.

The Illinois Attorney General’s Office,

JEPA and JM have

also signed a consent order that addresses the landfill units that are the

subject of this petition.

This consent order was submitted to the Lake County Circuit Court

for

approval, and is being evaluated by the Court.

It also allows for the filing ofthis petition.

Both the federal amended consent decree and the State consent order provide for

final closure ofthe landfill that

is subject of this petition, and this adjusted standard petition

should result in final closure in the most effective and expeditious manner.

JM advised the

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agencies ofthe probable need for this adjusted standard in the negotiations which resulted in the

federal amended consent decree, and the

State Consent Order, and each ofthese documents

specifically provides for the filing of an adjusted standards petition.

Therefore, this

adjusted

standard proceeding will not be contrary to either document when and if they are entered;

it will

in fact, assist in implementation ofthese documents.

JM’s On-site Landfill

JM’ s on-site landfill has always operated pursuant to the statutory permit

exception contained in Section

2 1(d) ofthe Act, 415 ILCS

5/21(d);

since JM has used the onsite

landfill to dispose ofonly that waste generated by its

own activities

at this location, JM has

neither received nor been required to hold an IEPA solid waste operating permit.

Pursuant to 35

Ill.Adm.Code

§

8 15.200 et ~q.,

JM submitted its initial facility report to

JEPA in September

1992.

As described in the initial facility report and as operated, the onsite landfill consisted of

two

areas:

1) the miscellaneous disposal pit, that was constructed on top ofclean fill that had

been placed during CERCLA remedial activities and 2) a portion ofthe collection basin.

These

units are depicted in Figure 2 (Site Plan).

The initial facility report filed in 1992 indicated JM’ s intention to operate the

onsite landfill as an inert waste landfill, based on leachate

data for the wastes that were intended

to

be placed in the onsite landfill.

During its operating history from

1992 to

1998, the

predominant waste that was placed in the landfill was calcium silicate, an inert, nonhazardous

material used by JM

to produce T- 12, a high temperature calcium silicate block insulation

material.

JM also disposed oflesser quantities of fiber glass-based roofing materials, wood

pallets,

paper, and cardboard packaging, materials that IEPA considers

to be putrescible wastes.

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Because the onsite landfill arguablymeets the definition of“existing facility or existing unit”

contained in 35

Ill.Adm.Code

§

8 10.103, the Onsite Landfill is subject to the standards for

existing landfills and units, set forth in 35

Ill.Adm.Code Part 814, pursuant to 35 Ill.Adm.Code

§

814.101.

In order to

accomplish the most efficient final closure that considers the landfill

contents and the landfill’s location on units previously remediated under CERCLA, JM is

seeking an

adjusted standard for (i) the Monitoring Frequency for Landfill Gas Monitoring

(35

Ill.Adm.Code

§

811.31 0(c)(1

)),

(ii) the requirements for implementing a Landfill Gas

Management System, specifically,

the provisions relating to detection distance for implementing

such a system

(35

Ill.Adm.Code

§

811.31 1(a)(1)),

and (iii) the Standards for the Location of

Monitoring Points found in 35

Ill.Adm.Code

§~S 81 1.318(b)(3), and 811.320,

specifically, the

requirement that monitoring wells shall be located within halfthe distance from the edge ofthe

potential discharge source to the edge ofthe zone ofattenuation.’

Narrative DescriptionofProposedAdjusted Standard, 35 Ill.Adm.Code

§

104.406(1)

PROPOSED ADJUSTED STANDARD

FOR LANDFILL GAS MONITORING

FREQUENCY REQUIREMENTS

In adopting its comprehensive regulations governing nonhazardous waste

landfills, the Pollution Control Board specifically addressed two broad types of landfills:

landfills for inertwaste, and landfills for chemical and putrescible wastes.2

The Board later

‘The costs ofcomplying with the regulations are very difficult to quantify because, as described

below, compliance with the regulations as adopted would involve drilling gas monitoring devices

and groundwater monitoring wells through engineered cover that was built pursuant to the

Superfund remedial activities at the site.

The motivation for this adjusted standard is not to

provide for lower costs, but to prevent the adverse effects that could result from installing the gas

monitoring and groundwater wells in locations that would damage the cover of the remediated

areas and potentially create pathways for migration of contaminants.

2

The Pollution Control Board has also adopted special requirements for other types of landfills,

(e.g., landfills used for certain wastes from iron and steel manufacturing facilities and foundries

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adopted requirements for municipal solid waste landfills in order to

ensure that the state

regulations met the requirements for the Resource Conservation and Recovery Act (RCRA)

Subpart D program. Because the landfill in question here is not a municipal solid waste landfill

(and is therefore not addressed in the federal program), granting the petition sought here will in

no way be inconsistent with federal requirements3.

There are also no

federal procedural

requirements that would apply to this petition.

As discussed above, JM originally contended that its on-site landfill was properly

characterized as an inert waste landfill, because the wastes placed in the landfill were primarily

inert

(calcium silicate materials, concrete,

fiber glass, and similar materials)4.

However, IEPA

advised that the presence ofmaterials like wood, cardboard and paper in the landfill

in any

amount

meant that the landfill should be more properly characterized as a chemical and

putrescible waste

landfill.

The requirements in 35 Ill.Adm.Code

§

811.31 0(c)( 1) (applicable to chemical

and

putrescible landfills but not to inert waste landfills) specify that landfill gas monitoring devices

shall be operated to obtain

samples on a monthly basis for the entire

operating period and for a

(see 35 Ill.Adm.Code Part 817)).

These regulations contain three classes ofwaste,

and wastes

which present more potential to

generate potentially harmful leachate are subject to more

stringent requirements.

~Moreover, both the federal amended consent decree and the State consent order described

above contemplate final closure ofthe landfill that

is the subject of this petition.

~The requirements for inert waste landfills are considerably less stringent than those for

chemical and putrescible and municipal solid waste landfills, due to significant differences

betweenthe types ofmaterials disposed ofin each type oflandfill.

Unlike chemical or

putrescible landfills and municipal solid waste landfills, inert waste landfills need not have gas

collection systems, groundwater monitoring systems or leachate collection systems, on the

theory that the leachate generated by inert waste landfills

is so innocuous

in terms ofquantity

and constituents that such systems are not warranted.

Final cover for inertwaste landfills

consists ofa minimum three foot thick layer of soil capable of supporting vegetation.

In

contrast, final cover for chemical and putrescible landfills and municipal solid waste landfills

must consist of a low permeabilitylayer with a thickness ofat least three feet (or equivalent)

overlain by a protective layer with a thickness of at least three feet.

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minimum offive years afterclosure. Given the nature ofthe wastes disposed in the On-Site

Landfill, studies were undertaken to determine the general physical properties within the landfill

and whether landfill gas was currently present within or outside the landfill limits

in quantities

that might warrant the required level ofmonitoring.

Previous investigations of the On-Site Landfill gas determined that methane

generation was more consistent with an inert waste landfill, rather than a typical chemical and

putrescible landfill.

Specifically, the following observations were made:

•

Measured landfill gas temperatures (approximately

50°F)

were not typical oflandfill

gas temperatures in a solid waste landfill, which typically ranges from 100 to

130 °F

during substantial anaerobic activity and between

130 and 160 °F

during substantial

aerobic activity.

•

The vegetative grass cover over the landfill was intact, growing and healthy, and

showed no

signs ofbum-out, which is indicative ofmethane release to the landfill

surface. Moreover, there are no buildings, structures or utilities on or around the

landfill that could serve as a conduit

for relieving methane pressures.

•

Landfill gas pressures measured in monitoring wells were typically extremely low

(less than 0.01” ofwater). This indicates negligible gas generation.

•

No malodors were notedwithin the landfill at any time, indicating little or no landfill

gas generation.

•

The carbon dioxide levels in the On-Site Landfill were measured to be less than

1.

This is not consistent with an active chemical and putrescible landfill, where the

levels ofcarbon dioxide typically range from 40-48.

•

No methane was present above regulatory criteria

(50

ofthe Lower Explosive Level

(LEL)) outside the limits of the waste boundary, despite the lack of any landfill gas

collection system. Given that wastes have not been

added to

the On-Site Landfill for

almost six years,

and that very little additional wastes, if any, are expectedto be

added in the future, it

is unlikely that the landfill gas generation rate would increase,

thereby resulting in an increased potential to detect migrating landfill gas.

Copies of the July, August and

September 2004 landfill gas monitoring reports

are included as an Exhibit

1

to this Amended Petition.

These results, which confirm previous

observations were not particularly surprising,

in light ofthe relatively low percentage oforganic

material disposed in the landfill, and the relatively small size of the units. While the On-Site

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Landfill may technically meet the requirements for chemical and putrescible waste landfills, the

above-described data confirm that the landfill is actually more similar to the inert waste landfills

considered by the Board in adopting the regulations.

As a result, the frequency oflandfill gas

monitoring

as technically required by 35

Ill.Adm.Code

§

81 1.310(c)(l) is not necessary and

would not provide any additional degree ofprotection to

human health or the environment as

compared to

the proposed adjusted standard.

For

all ofthese reasons, JM is proposing the following adjusted standard:

“In

lieu

of compliance with 35 IlI.Adm.Code

§

811.310(c)(1)

as

applied to the

On-Site Landfill

at

its facility

in Waukegan, Illinois,

Johns Manville shall

operate all

gas

monitoring devices, including the ambient air monitors, such

that samples will be

collected on

a semi-annual basis for a period of five years

following

approval of this adjusted standard.

If, at the end of five years, the

requirements for implementing a Landfill Gas Collection System (35

Il1.Adm.Code

§

811.311) are not met, no further monitoring will be

conducted.

Based on the data collected, compliance with the proposed adjusted standard will

not have a more adverse effect on the environment than would compliance with the regulations.

PROPOSED ADJUSTED STANDARD FOR IMPLEMENTATION OF A LANDFILL

GAS MANAGEMENT SYSTEM

The regulations governing implementation ofa Landfill Gas Collection System

(35

Ill.Adm.Code

§

811.311 (a)(1))

contemplate detection ofelevated methane levels below the

“ground surface” at a distance of100

feet outside the edge ofthe unit, or at the property

boundary, whichever is closer. As the property boundary is further away, the distance of 100 feet

from the edge ofthe unit would appear to apply.

However, at this distance (100 feet) from the

edge of

the On-Site Landfill, the subsurface monitoring locations would fall withinthe area

where CERCLA wastes were covered.

Within the area adjacent to Miscellaneous Disposal Pit

(also called Fill Area #1), the lateral limits of waste material are substantially defined by the toe

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ofthe steep side slopes ofthe CERCLA landfill.

Adjacent to the Collectin Basin (also called Fill

Area # 2), seven soil borings were advanced in the area locatedbetween the eastern limit ofthe

On-Site Landfill (Fill Area # 2) and the perimeter road.

Figure 7 shows these boring locations;

the subsurface logs for these borings are also attached, as Exhibit 2.

As the

logs indicate, waste

materials (roofing, transite, and white granularmaterials) are present within the subsurface in

this area.

Based upon the history ofthe site, these waste materials are likely not present beneath

the surface in the area east ofthe perimeter road.

Landfill gas monitoring within these areas (west ofthe perimeter road)

would

require installation of wells

through the engineered coverplaced for closure ofthe CERCLA

landfill and

into the underlying waste materials. Installation, monitoring, and maintenance of

wells installed in these locations not only compromises the integrity ofthe CERCLA cover and

thereby triggers maintenance obligations not otherwise required, it also potentially exposes the

now-covered asbestos-containing waste materials to personnel collecting the air samplesandior

cause the release ofasbestos fibers to ambient air. Furthermore, it is not clear whether

monitoring for On-Site Landfill gas beneath the cover ofan adjacent landfill meets the intention

of “ground surface,” in that the goal is to detect whether elevated levels ofmethane generated

within the On-Site Landfill are migrating away from that unit. As

a result, locating the landfill

gas monitoring devices at a distance of 100 feet from the On-Site Landfill as technically required

by 35

Ill.Adm.Code

§

811.3 1l(a)(1) would be very burdensome, potentially harmful

to the

CERCLA remedy, and due to the extremely low levels ofgas being generated, would not

provide any additional degree ofprotection to

human health or the environment.

For all ofthese reasons, JM is proposing the following adjusted standard:

“In lieu of compliance with 35 Ill.Adm.Code

§

811.311(a)(1) as

applied to the

On-Site Landfill at its facility in Waukegan, Illinois, Johns Manville

shall

17

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install a gas management system if a methane concentration greater than

50

percent of the lower explosive limit in air,

is

detected below

the ground

surface by a

monitoring device or is detected by an ambient air monitor

located as close

as possible to, but outside the boundary line shown on Figure

7

or the property line, whichever is less.”

Based on the data collected, compliance with the adjusted standard proposed will

not have a more adverse effect on the environmentthan would compliance with the regulations.

PROPOSED ADJUSTED STANDARD FOR THE LOCATIONS

OF GROUNDWATER

MONITORING WELLS

The regulation governing the Design, Construction, and Operation of

Groundwater Monitoring Systems

(35

Ill.Adm.Code

§

811.31 8(b)(3)) contemplates locating

monitoring points for the On-Site Landfill (as Maximum Allowable Predicted Concentration or

“MAPC” wells) within one-halfthe distance from the edge ofthe potential source ofthe

discharge to the edge of the zone of attenuation downgradient, with respect to

groundwater flow,

from the source. Additionally, at least one monitoring well (as an Applicable Groundwater

Quality Standard or “AGQS” well) is required at the downgradient limit ofthe Zone of

Attenuation (35 Ill.Adm.Code

§

811.31

8(b)(5)).

However, at these distances from the edge ofthe

On-Site Landfill

(50

feet for “MAPC” wells and

100 feet for “AGQS” wells), the monitoring

locations

would fall within the areal limits ofwhere subsurface waste materials are present as

part of the now-closed

CERCLA landfill.

JM is therefore proposing to

move the Zone of

Attenuation a short distance (maximum of 115 feet) in the southeast corner ofthe Miscellaneous

Disposal Pit (Fill Area #

1) (See Figure 8).

In most cases, the distance will be approximately 50

feet beyond the regulatory limits.

Groundwater monitoring at these locations would require installation ofwells

either (i) on the steeply sloping sides ofthe CBRCLA landfill (Fill Area #1), (ii) through the

engineered cover placed

for closure ofthe CERCLA landfill (Fill Areas #1

and #2) and/or (iii)

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into and through the underlying “CERCLA” waste materials, prior to penetrating the underlying

groundwater-bearing zone (Fill Areas #1

and #2). Installation, monitoring, and maintenance of

wells installed in these locations is not desirable for the following reasons:

•

Drilling through waste materials prior to

installing a monitoring well within the

underlying groundwater increases the risk ofcross-contamination ofthat groundwater

either through (i) carrying contaminants vertically downward during the drilling

process and/or (ii) providing a conduit for ongoing vertical migration ofwaste

material leachate down an

inefficient annular seal within the borehole. It is

acknowledged that the final landfill cover is intended to minimize leachate generation

and that the use ofvarious drilling techniques

and grouts are available to minimize

the possibility ofcross contamination. However, these methods and their intended

application are not withoutrisk and thus, their use is not consistent with good

environmental management practices, provided that the applicable data maybe

obtained without substantial compromise.

•

In the case of Fill Area #1,

ongoing and repetitive

operations for many years on the

steeply sloping, more erosion-prone sides ofthe CERCLA landfill increases both the

cover maintenance obligations (as solely a cost-related issue) and the risk ofambient

release of asbestos fiber and subsequent exposure to surrounding populations from

incremental erosion events or catastrophic slope failure

(e.g.,

due to drilling

operations using heavy equipment).

•

As

specified in the Operating and Maintenance Manual governing closure ofthe

CERCLA

landfill, activities

that may result in penetration or damage to the existing

CERCLA cover must (i) be pre-approved by U.S.

EPA and IEPA, and (ii) must

adhere to Health and Safety protocols designed to

limit exposure to

asbestos.

As a result, locating groundwater monitoring wells at a distance of50 feet from

Unit #1, as technically required by 35

Ill.Adm.Code

§

81 1.318(b)(3) would be very burdensome,

would increase the risk of contaminating underlying groundwater, would increase the risk of

ambient release and human exposure to asbestos fiber through inadvertent and potentially

catastrophic failure ofthe CERCLA remedy, and would not provide any additional degree of

protection to human health or the environment.

For all ofthese reasons, JM is proposing adjusted standards to those regulations

governing the definition of the Zone of Attenuation and the location ofmonitoring points, as

follows:

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“In lieu of compliance with 35 Ill.Adm.Code.~811.320(c)(1) as

applied to the

On-Site Landfill at its facility in Waukegan, Illinois, the Zone ofAttenuation,

within which concentrations of constituents in leachate discharged from the

unit may exceed the applicable groundwater quality standard of this Section,

is

a volume bounded by a vertical plane located

as shown on Figure 8,

extending from the ground surface to the bottom of the

upperi~iiost

aquifer

and excluding the volume occupied by the waste.”

“In lieu of compliance with 35 Ill.Adm.Code

§

811.318(b)(3) as

applied to the

On-Site Landfill at its facility in Waukegan, Illinois, Johns Manville shall

install groundwater monitoring wells at the locations specified on the

attached Figure 8. Those monitoring wells located along the proposed Zone

of Attenuation boundary shall be considered Applicable Groundwater

Quality Standards

or “AGQS” wells consistent with the requirements of 35

Ill.Adm.Code

§

811.318(b)(5)”

The following additional clarifications to potentially applicable regulations are

offered, based on discussions with the IEPA:

The location ofthe bottom ofthe uppermost aquifer shall be determined in a

manner consistent with the requirements of35

Ill.Adm.Code

§

811.31 1(c)(2)(B).

Compliance with

35 Ill.Adm.Code

§

811.317(b) shall be assessed by modeling all

applicable

Zone ofAttenuation distances, as shown on Figure

8.

It is recognized that no

Maximum Allowable Predicted Concentration or “MAPC”

wells are beingproposed; all monitoring points

are considered Applicable

Groundwater Quality Standards or “AGQS” locations. As such, the obligations

described in 35

Ill.Adm.Code

§

81 1.319(b)(3) immediately apply, if the

concentration ofone or more constituents monitored at or beyond the Zone of

Attenuation, as shown on Figure 8,

is above the applicable groundwater quality

standards of Section 811.320

and is attributable to the On-Site Landfill.

These proposed adjusted standards are designedto implement the applicable

regulations in a manner that is consistent with maximizing protection ofthe environment without

increasing the potential accidental harm that might be caused inadvertently.

In reviewing any petition related to groundwater standards and the Zone of

Attenuation, the Board may adjust the compliance boundary based on a consideration ofthe

factors listed in

8 14.402(b)(3), as long as the alternative compliance boundary will not result in

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contamination of groundwater that

is or maybe needed for human consumption.

In its August

5,

2004 Order, the Board directed JM to

address these factors, and JIM addresses the applicable

factors below.

In this Amended Petition, JM has requested an adjusted standard to Section

811 .320(c)(1) by explaining that compliance with the applicable regulations may result in (i)

inadvertent impacts to underlying groundwater (814.402(b)(3)(F))

and (ii) exposure to asbestos

fiber present beneath the CERCLA cap, thus potentially impacting public safety

(814.402(b)(3)(G)).

Any adjustments to

the compliance boundary would not impact

groundwater that is

or maybe used for human consumption, because there are no existing

groundwater users in the immediate area, and because therewill be prohibitions

on the use of

groundwater on the JM property pursuant to the amended federal consent decree.

The proximity

ofthe facility to Lake Michigan makes it very unlikely that any adjacent properties would

attempt to use groundwater for human consumption.

Moreover, the following factors also

serve

to

show that

compliance with the adjusted standards proposed will not have a more adverse

effect on the environment than would compliance with the regulations:

•

Native soils

at the site consist ofmoderately sorted sand from the surface to

approximately 40 feet below grade (see attached well log for LMW-l 1). Below this

unit is a dry, lean clay that, based upon water production logs from the 1920s, is

approximately 45 to 75 feet in thickness (see attached well logs for JM Wells

1, 2, 3,

and 4). Confirmation of the thickness ofthe underlying clay will be conducted

pursuant to the requirements of 811.31 5(c)(2)(b). The consistency in the soil type and

the lack of intervening clay layers in the uppermost aquifer serves to minimize the

number ofpotential migration pathways that contaminants mightseek.

Therefore,

extending the Zone ofAttenuation laterally (by a maximum of 115

feet) will not

result in masking contaminants in the uppermost aquifer due to alternate migration

pathways.

•

Figure

8

also depicts the April 2004 groundwater flow contours in the vicinity ofthe

On-Site Landfill.

As would be expected, the flow direction is towards Lake Michigan,

at an average gradient of0.004 feet per foot. Figures

9,

10,

11,

and 12 depict the

groundwater elevations for April 2003, July 2003, December 2003, and April 2004,

respectively. As can be seen, the groundwater flow direction and gradient is very

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consistent during these 4 quarters ofdata. Therefore, moving the Zone of Attenuation

laterally will not result in masking contaminant transport due to an unexpected

change in the groundwater flow characteristics.

•

The proposed lateral adjustment to the location ofthe Zone ofAttenuation (maximum

of 115 feet in the southwest corner ofFill Area #1) is further mitigated by the deed

restriction requirement contained with the First Amended Consent Decree currently

lodged in District Court prohibiting use of the groundwater on the Johns Manville

property. As the proposed Zone of Attenuation boundary is still located on the JM

property, this will not result in any further limitations on the use ofgroundwater that

might be impacted within the Zone ofAttenuation.

Description of Impact of Compliance With General Standard

As Compared to Proposed

Adjusted Standard, and Justification, 35 Ill.Adm.Code

§~

104.4-6(g)-(h)

As has been described above, because ofthe presence ofthe adjacent remediated

Superfund cells, strict compliance with the regulations

could result in drilling through engineered

cover and waste, compromising the Superfund remedy.

On the other hand, compliance with the

proposed adjusted standard should meet the goals of the Board’s Solid Waste Regulations with

respect to

gas control and groundwater monitoring.

.JM’s proposed adjusted standard should

provide sufficient information with respect to gas generation and groundwater impact so that

future action can be taken, if necessary, under other provisions ofthe Board’s solid waste

regulations.

Compliance with the Proposed Adjusted Standard will be, at a minimum, equally

protective ofthe environment as would compliance with the regulations ofgeneral applicability.

JM believes that granting the adjusted standard would be justified for the reasons set

forth above,

and would create a lesser risk ofdamage to the remediated areas at the Superfund site.

The Board

May

Grant Adjusted Standard Consistent With Federal Law, 35 Ill.Adm.Code

§

104.406(i)

As

described above, if the Board were to grant the adjusted standard, it would

in

no way be contrary to federal statutory orregulatory requirements.

Moreover, the federal

consent decree described above, expressly contemplated that an adjusted standard petition could

22

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---

be filed, so granting the adjusted standard would not be inconsistent with any federal judicial

order or consent decree.

HearingRequested 35 Ill.Adm.Code 104.406(j)

JM has discussed these proposed adjusted standards with the Illinois

Environmental Protection Agency(IEPA), and is requesting the Agency’s concurrence.

If

Agency concurs with this petition, it may not be necessary to have a hearing (assuming that

members ofthe public do not request one.

Ifthe IEPA concurs with the petition, and

there are

no requests for a hearing from the public or other interested parties, JM can waive its request for

a hearing.

Documentation to Be Relied Upon, 35 Ill.Adm.Code

§

104.406(k)-(l)

JM has attached a number of documents, including gas generation data and chart

showing the locations ofSuperfund remediated areas in support ofthis petition.

Due to

the site’s

Superfund history, there is voluminous data and numerous reports concerning the conditions of

the

site prior to remedial activities, and the construction ofthe cap over the cells.

This

data can

be provided to the Board orto

the JEPA in the event that additional information is required.

CONCLUSION

For the reasons set forth above, JM respectfully requests that the Pollution

Control Board grant the adjusted standards to

35

Ill.Adm.Code Part 814, incorporating 35

Ill.Adm.Code

§~S

811.310, 811.311, and 811.318

as described in this petition, and as set

forth

below:

“In

lieu of compliance with 35

Ill.Adm.Code

§

811.310(c)(1)

as

applied to the

On-Site Landfill at

its

facility in Waukegan, Illinois, Johns Manville shall

operate all gas monitoring devices, including the ambient air monitors, such

that samples will be collected on

a semi-annual basis for a period of five years

following approval ofthis adjusted standard. If, at the end offive years, the

requirements for implementing

a Landfill Gas Collection System (35

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---

Ill.Adm.Code

§

811.311) are not met, no further monitoring will be

conducted.”

“In

lieu of compliance with

35 Ill.Adm.Cocle

§

811.311(a)(1) as

applied to the

On-Site Landfill at its facility

in Waukegan, Illinois, Johns

Manville shall

install a gas management system if a methane concentration greater than

50

percent of the lower explosive limit in air, is detected below the ground

surface by

a monitoring device or is detected by an ambient air monitor

located as close as possible.to the boundary line shown on Figure

7

or the

property line, whichever is less.”

“In lieu of compliance with 35 Ill.Adm.Code

§

811.320(c)(1)

as applied to the

On-Site Landfill at its facility in Waukegan, Illinois, the Zone of Attenuation,

within which concentrations ofconstituents in leachate discharged from the

unit may exceed the applicable groundwater quality standard of this Section,

is

a volume bounded by a vertical plane located as shown on Figure 8,

extending from the ground surface to the bottom ofthe uppermost aquifer

and excluding the volume occupied

by the waste.”

“In lieu of compliance with 35 Ill.Adm.Code

§

81 1.318(b)(3) as applied to the

On-Site Landfill at its facility in Waukegan, Illinois, Johns Manville shall

install groundwater monitoring wells

at the locations

specified on the

attached Figure 8. Those monitoring wells located along the proposed

Zone

ofAttenuation boundary shall be considered

Applicable Groundwater

Quality Standards or “AGQS” wells

consistent with the requirements of35

Ill.Adm.Code

§

811.318(b)(5)”

24

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Respectfully submitted,

Edward P. Keimey

Sidley, Austin, Brown & Wood LLP

10 South Dearborn Street

BankOne Plaza

Chicago, Illinois 60603

(312)853-2062

25

JOHNS MANVILLE,

By:

Petitioner,

One of Its Attorneys

THIS DOCUMENT IS SUBMITTED

ON RECYCLED PAPER

---

FIGURES

AND

EXHIBITS

Figure

1

Property Location Map

Figure 2

General Property Map and On-Site Landfill Location

Figure 3

On-Site Landfill Site Plan and Location ofCross Sections

Figure 4

On-Site Landfill West-East Cross Section, April 2003

Figure

5

On-Site Landfill, South-North Cross Section, April 2003

Figure 6

On-Site Landfill, West-East Cross Section, April 2003

Figure 7

On-Site Landfill, Soil Boring Locations and Proposed Landfill Gas

Monitoring Boundary

Figure 8

On-Site Landfill, Existing and Proposed GW Monitoring Wells and

Proposed Zone ofAttenuation

Figure 9

Groundwater Levels, Data Date April 2003

Figure 10

Groundwater Levels, Data Date July 2003

Figure

11

Groundwater Levels, Data Date December 2003

Figure 12

Groundwater Levels Data Date April 2004

Exhibit

1

On-Site

Landfill Gas Monitoring Forms

Exhibit 2

Boring Logs

Showing Waste Encountered on Site

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I-

---

Johns Manville. Waukegon. Illinois

Groundwater Levels

Data Date:

December 2003

IftCDRHL

GR~L

_Sd

~‘,

—

—

100

~)LFR

LEVINE.FRICKE

Figure 11

---

350 IllA

.

ANlAO

llJ1I~1

I

I

---

EXHIBIT

1

---

SETTLING

BASIN

elevation

of

water’s

edge

=

approximately

599.56

feet

Miscellaneious

Disposal Pit

(MDP)

FILL AREA #1-

Collection

Basin (CB)

04-91

:SMW~O9

SMW-08A

Mark ambient air methane

monitoring

locations on this drawing and

indicate

the wind direction

by drawing

an arrow

onthis

map.

Monitoring

Date:_07112104._

Personnel:

David Peterson_.._

Location

I

Methane

Level:

0

Location

2 Methane Level:_,__0

Location

3 Methane

Level:

0

Location 4 Methane Level:

0

Location

5 Methane Level:

0

Location

6 Methane Level:_,,0

*

GRAPHIC

SCALE

o~

Sole:

P5012

odopted bolt,

HeAd

Soroey

doted

1558.

geneloted by Holtlngtoe

A00010teo

JOHNS MAN

VILLE

Site Plan

On-Site

Landfill

Soil Borings andWell

Locations

~IJ~

WIND, 5mph

at 8:00

pm

---

Johns

Manville

—

Waukegan

On-Site

Landfill

Gas Monitoring

Form

Date:

7/14/04

Personnel:

David

Peterson

Ambient

Landfill Gas

Temperature:

76

deg. F

Instrument:

Landtec GA-90 (Rented from

F.E.l.)

Barometric

Pressure

Pressure:

29,87

in Hg

Instrument:

Magnehelic Gauges (0-1 and

0-10

in. water)

Water Level

Wind

Speed:

9

mph

Instrument:

Solonist

Wind

From the

Weather

Direction:

NW

Conditions:

Partly Sunny

.

Subsurface

Pressure

Location

CH4

Level

CO2

Level

()

-

Level

()

.

Depth

to

.

TOS

below

-

Top of

Screen

Elevft’

‘‘

Bottom

Screen

‘‘

‘

.

Interval

Description

:

0

55

0

0.6

38.03

Dry

11.00

622.67

597.67

In MDP waste

0

12.3

0

0.1

9.22

2.00

635.22

628.22

In MDP waste

0

0

0.1

19.8

34.71

37.50

582.99

577.99

WestofMDP

0.18

0

0

20.8

36.96

44.00

579.01

574.01

North

of MDP

0

0

6.8

9.4

10.19

5.00

586.28

576.28

EastofMDP

0

0

0.1

20.1

11.20

8.30

584.97

579.97

EastofMDP

0

0

0

20.6

10.88

8.60

583.87

578.87

EastofMDP

0

0

0

20.8

7.38

8.40

583.07

578.57

South of MDP

0

2.4

2.8

0.3

17.67

12.00

588.92

578.92

East of CB,

below asbestos

landfill

cap

0

3.2

0

15.6

16.89

13.50

587.38

582.38

In CB waste

CH4

Level

()

.

-

.

.

-

Sample Location Description

0

MDP

-

Sampled 07/12/04 at 8:00 pm, west side of landfill, south sample

0

MDP

-

Sampled 07/12/04 at 8:00 pm, west side of landfill, middle sample

0

MDP

-

Sampled 07/12/04 at 8:00 pm, west side of landfill,

north sample

0

CB

-

Sampled 07/12/04 at 8:10 pm,

west side of landfill, south

sample

0

CB

-

Sampled 07/12/04 at 8:10 pm,

west side of landfill, middle sample

0

CB

-

Sampled 07/12/04 at 8:10 pm,

west side of landfill, north sample

Note:

Surface methane levels measured with a MSA Microgard 02/LEL meter calibrated to

50

pentane, corrected for methane using

a

response factor of 0.5.

Water levels

collected on July

12,

2004

---

Johns Manville

—

Waukegan

On-Site

Landfill Gas

Optional Additional Data

Date:

7/14/04

Personnel:

David

Peterson

Ambient

Landfill

Gas

Temperature:

76

deg. F

Instrument:

Landtec GA-90 (Rented from

F.E.l.)

Barometric

Pressure

Pressure:

29.87

in Hg

Instrument:

Magnehelic Gauges

(0-1

and 0-10

in. water)

Water Level

Wind

Speed:

9

mph

Instrument:

Solonist

Wind

From the

Weather

Direction:

NW

Conditions:

Partly Sunny

.

Subsurface

Monitoring

Pressure

Location

(in. water)

V

.

CH4

Level

CO2

Level

02

Level

-

Depth

TS

below

Top of

..

Top’

Scree

EIev(

.

.

Bottom of

Screen

Elev. (ft)

V

V

-

Interval

Description

-

0

2.6

0

19.6

39.51

38.00

595.48

590.48

In MDP

waste

-0.18

15.4

2.2

9.1

38.00

596.37

591.37

In

MDP waste

0.50

0.1

0.2

19.0

56.39

59.00

582.22

577.22

Beneath MDP

0.52

0

0

20.9

10.05

6.00

588.62

583.62

South of MDP

NM

0

0

20.8

10.37

5.50

589.1 7

584.17

South of MDP

0.60

0

0

20.7

9.65

5.75

587.89

582.89

South of MDP

0.72

0

0

20.8

10.09

6.50

586.83

581.83

South of MDP

0.20

0

0

20.8

10.11

6.50

586.24

581.24

South of MDP

0.20

0

0.2

20.7

10.20

6.80

585.04

580.04

SouthofMDP

0

0

0.2

19.7

10.33

6.50

584.69

579.69

South of MDP

NM

0

0

20.6

13.45

9.00

585.76

580.76

South of MDP

0

0

3.6

16.6

5.98

4.80

0.8 ft

BGS

3.8 ft

BGS

50

ft E. of CB

NM

NM

NM

NM

Dry

at

4.75

0.75 ft

BGS

3.75 ft

BGS

100ff E. of

CB

NM

NM

NM

NM

Dry

at

4.64

0.1

ft

BGS

2.6 ft

BGS

140 ft

E. of CB

0

15

0.7

11.7

22.90

35.50

32 ft

BGS

37 ft

BGS

In MDP waste

NM

0

9.8

0.3

8.00

9.50

7.5 ft

BGS

12.5 ft

BGS

In CB waste

Note:

NM

=

not measured.

Water levels collected

on July 12,

2004

---

Johns

Manville

—

Waukegan

On-Site

Landfill

Gas Monitoring

Form

Date:

8/31/04

Personnel:

David

Peterson

Ambient

Landfill Gas

Temperature:

70

deg.

F

Instrument:

Landtec GA-90 (Rented from

F.E.l.)

Barometric

Pressure

Pressure:

30.24

in Hg

Instrument:

Magnehelic Gauges (0-1 and

0-10

in. water)

Water Level

Wind

Speed:

4

Mph

Instrument:

Heron (Rented from

F.E.l)

Wind

Weather

Direction:

From the

NE

Conditions:

Sunny and clear

.

Subsurface

Location

Pressure

(in. water)

CH4

-

Level

()

-

Level

~)

02

Level

()

Depth

Water

below

TOC

(ft)

below

Top of

casing

Top of

Screen

‘TOS’

El

~

Bottom

s

r

El

een

Screen

-

Interval

Description

-

-0.02

55

0.5

0.8

Dry

11.00

622.67

597.67

In

MDP waste

0

0.3

0.5

5.9

Dry

2.00

635.22

628.22

In

MDP waste

0

0

0.1

20.1

36.15

37.50

582.99

577.99

WestofMDP

-1.0

0

0

20.5

38.20

44.00

579.01

574.01

North ofMDP

-

0

0

0

20.7

10.66

5.00

586.28

576.28

EastofMDP

0

0

1.1

18.4

Dry

8.30

584.97

579.97

EastofMDP

0

0

0

20.6

11.51

8.60

583.87

578.87

EastofMDP

-0.04

0

0

20.5

8.52

8.40

583.07

578.57

South of MDP

0

0.7

3.2

0.4

18.88

12.00

588.92

578.92

East of CB,

below asbestos

landfill cap

0

27.0

1.9

2.3

17.70

13.50

587.38

582.38

In

CB waste

CH4 Level

()

V

.

-

.

V

-

Sample Location Description

0

MDP

-

south side of landfill, east sample

0

MDP

-

south side of landfill, middle sample

0

MDP

-

south side

of landfill, west sample

0

CB

-

south side of landfill, east sample

0

CB

-

south side of landfill, middle sample

0

CB

-

south side of landfill, west sample

Note:

Surface methane levels

measured with

a

Landtec GA-90.

---

Johns Manville

—

Waukegan

On-Site

Landfill

Gas Monitoring

Optional Additional

Data

Date:

Ambient

8/31/04

Personnel:

Landfill Gas

David Peterson

Temperature:

Barometric

70

deg. F

Instrument:

Pressure

Landtec GA-90 (Rented from F.E.I.)

Pressure:

30.24

in

Hg

Instrument:

Water Level

Magnehelic Gauges (0-1

and 0-10

in. water)

Wind Speed:

Wind

4

mph

Instrument:

Weather

Heron (Rented

from F.E.I)

Direction:

From the

NE

Conditions:

Sunny and clear

Monitoring

.

Subsurface

Pressure

CH4

Level

CO2

Level

()

Level

Depth

Water

TOCft

()

TOS

~

.

E’~i’~

(ft)

-

Screen

Description

LMW-02

0.20

2.1

0

19.9

39.56

38.00

595.48

590.48

In

MDP waste

LMW-03

-0.25

8.4

1.6

13.0

Dry

38.00

596.37

591.37

In

MDP waste

LMW-04

-1.2

0.1

0.4

18.6

57.55

59.00

582.22

577.22

Beneath MDP

P-87

0

0

7.6

3.9

11.35

6.00

588.62

583.62

South of MDP

P-88

0

0

6.4

5.1

11.61

5.50

589.17

584.17

SouthofMDP

P-89

NM

0

1.8

15.2

10.75

5.75

587.89

582.89

South of MDP

P-90

0

0

4.5

4.9

11.06

6.50

586.83

581.83

South of MDP

P-91

0

0.4

4.6

0.4

11.13

6.50

586.24

581.24

South of MDP

P-92

0

0

5.2

1.0

10.85

6.80

585.04

580.04

South of MDP

P-93

0

0

5.8

11.5

10.68

6.50

584.69

579.69

South of MDP

P-94

0

0

0

20.7

13.94

9.00

585.76

580.76

South of MDP

04-92

0

0

2.5

17.6

Dry

4.80

0.8 ft BGS

3.8 ft BGS

50 ft

E. of CB

04-89

NM

NM

NM

NM

Dry

4.75

0.75ff

BGS

3.75 ft BGS

100 ft

E. of CB

04-91

NM

NM

NM

NM

Dry

4.64

0.1

ft BGS

2.6ftBGS

140ff E.ofCB

LF-SBO2

NM

13

1.0

11.2

23.03

35.50

32ftBGS

37ftBGS

In

MDP waste

LF-SBO5

NM

0

1.1

19.3

12.11

9.50

7.5ftBGS

12.5ftBGS

lnCBwaste

Note:

NM

=

not measured.

---

V/I

1-0

/iI

/

I

1

l:V

i:I

:

//

;~

‘~:

—

I

//

~,

~

//

/:

,~_/O4-89/

/

;V

/VVV

/

I

I

‘1

+

~

04-91

;/I

I

LLMW-1O

LMWO8I

I

~-V-VVi)

II

I

II

~

\V~.

LF-SBO5

V-~

/

I

II

j

II

H

N

~--

111

1MW~7

~

:~e~

~

\\

—

—

—

—

+

/

~

~\.~II

—

/

~

•,SMW.09

I

~

~

-

-:

SMW~8A

/~

/

LMWO4

~—--

~

1iT~

~

/L~

-

-~

-~

\

•

LFSB02*0

*~

V

VVVV-V~-V~l

/

i

i

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——

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//~

iii:p.94

—-V

—V—-V

—

V~—

~__

—

——

—

——

—--VV-—-

/

-V-V V______

~VV’~’

#3

~

e~,_1

—--

VVVV.VV:VVVVVVV._

—

~

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~

~MW

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.1

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——

__-_____V~VV~5V7VV.~~_.____

P46

~_VV•VV_VVV•

..VVVVV..VV•VVV___V~VVVVVV_VVV

VVV_VVVVV

__

/

_SMW

12~MWj3

9

SETTLING

BASIN

elevation

of water’s

edge

=

approximately 59956

feet

FILL AREA

FILL

AREA #1

Mark ambient air methane monitoring

locations on this

drawing and

indicate

the wind direction by drawing an arrow

on this

map.

Monitoring

Date:_08131104__

Personnel:

David Peterson.V._

Location I

Methane Level:

0

Location

2 Methane Level:__0

Location

3 Methane Level:_.._0

Location 4 Methane Level:__.._0

Location

5 Methane LeveI:_.~.0

Location

6 Methane

Level:

0

*

GRAPHIC SCALE

0

lee’

LEGEND

—

—

—

PROPERlY LINE

—

—

—

—

BOUNDARY OF CLAY COVER

+

MONIFORING

WELL

4-

SOILEORING

3~

PIEZOMETER

Note:

Flgote edepted

hod, Aellel

Solody doted 1998.

getetoted by

Hoelnglott

A,n0010teL

4

JOHNS MANVILLE

Site Plan

On-Site

Landfill

Soil Borinas

and Well Locations

WIND, 4 mph

Collection

Basin (CB)

Miscellaneious

Disposal Pit

(MDP)

---

Johns

Manville

—

Waukegan

On-Site

Landfill

Gas Monitoring

Form

Date:

9/01/04

Personnel:

David

Peterson

Ambient

Landfill Gas

Temperature:

70

deg. F

Instrument:

Landtec GA-90 (Rented from

F.E.l.)

Barometric

Pressure

Pressure:

30.27

in Hg

Instrument:

Magnehelic Gauges (0-1 and

0-10

in. water)

Water Level

Wind

Speed:

1

mph

Instrument:

-

Heron (Rented from

F.E.l)

Wind

Weather

Direction:

From the

S

Conditions:

Sunny and clear

.

Subsurface

Location

Pressure

CH4

Leval

~)

CO2

-

Level

-

02

Level

V

Depth

TOS

below

Top of

(TOC)

Top of

Screen

(TOm

Elev.~

Bottom

of

S’~re~n

El

‘W

ev. ~

I

:

Interval

Description

V

0

52.6

0.7

0.8

Dry

11.00

622.67

597.67

In

MDP waste

0

0.2

0.6

4.2

Dry

2.00

635.22

628.22

In MDP waste

0

0

0.1

20.1

36.15

37.50

582.99

577.99

WestofMDP

0

0

0

20.6

38.19

44.00

579.01

574.01

North of MDP

0

0

4.4

14.8

10.73

5.00

586.28

576.28

EastofMDP

0

0

1.2

18.0

Dry

8.30

584.97

579.97

EastofMDP

0.12

0

0

20.6

11.56

8.60

583.87

578.87

EastofMDP

-0.60

0

0

20.6

8.48

8.40

583.07

578.57

South of MDP

0

0.6

3.3

0.4

18.88

12.00

588.92

578.92

East of CB,

below asbestos

landfill

cap

0

26.0

1.3

2.4

17.71

13.50

587.38

582.38

In CB waste

CH4

Level

()

.

.

.

V

V

Sample Location Description

0

MDP

-

north side of landfill, east sample

0

MDP

-

north side of landfill,

middle

sample

0

MDP

-

north side of landfill, west sample

0

CB

-

north

side of landfill, east sample

0

CB

-

north

side of landfill, middle sample

0

CB

-

north

side of landfill, west sample

Note:

Surface methane levels measured with

a

Landtec GA-90.

---

Johns

Manville

—

Waukegan

On-Site Landfill

Gas Monitoring

Optional Additional

Data

Date:

9/01/04

Personnel:

David

Peterson

Ambient

Landfill Gas

Temperature:

70

deg. F

Instrument:

Landtec GA-90 (Rented from

F.E.I.)

Barometric

Pressure

Pressure:

30.27

in Hg

Instrument:

Magnehelic Gauges

(0-1

and 0-10

in. water)

Water Level

Wind

Speed:

1

Mph

Instrument:

Heron (Rented from

F.E.I)

Wind

Weather

Direction:

From the

S

Conditions:

Sunny and clear

.

Subsurface

(in. water)

CH4

Level

()

-

CO2

Level

()

Level

()

Depth

TOC~ft)

lOS

below

Top of

Casing

(

,

(ft)

Top of

EI’ft’

Bottom of

Screen

Screen

Description

-

-0.04

1.9

0

20.0

39.51

38.00

595.48

590.48

In

MDP waste

-

-0.1

14.4

2.7

8.9

Dry

38.00

596.37

591.37

In

MDP waste

-

0.60

0

0.2

19.3

57.55

59.00

582.22

577.22

Beneath MDP

-

0

0

7.3

4.7

11.37

6.00

588.62

583.62

South of MDP

0

0

7.2

3.3

11.57

5.50

589.17

584.17

South ofMDP

NM

0

3.8

4.8

10.78

5.75

587.89

582.89

South of MDP

0

0

2.4

11.7

11.03

6.50

586.83

581.83

South of MDP

0

0.5

2.9

2.6

11.09

6.50

586.24

581.24

South of MDP

0

0

4.9

2.3

10.89

6.80

585.04

580.04

South of MDP

0

0

5.1

12.4

10.76

6.50

584.69

579.69

South of MDP

0

0

0

20.7

14.00

9.00

585.76

580.76

South of MDP

0

0

3.2

17.4

Dry

4.80

0.8 ft BGS

3.8 ft

BGS

50 ft

E. of CB

NM

NM

NM

NM

Dry

4.75

0.75ftBGS

3.75ftBGS

lOOftE.ofCB

NM

NM

NM

NM

Dry

4.64

0.1

ftBGS

2.6ftBGS

l4OftE.ofCB

NM

5.3

0.4

17.4

23.03

35.50

32 ft BGS

37ff BGS

In

MDP waste

NM

0

9.2

10.7

12.14

9.50

7.5 ft BGS

12.5 ft

BGS

In

CB waste

Note:

NM

=

not measured.

---

EXHIBIT 2

---

Log

of Borehole: 04-89

-

offñgShWgiis

Poorly Graded Sand (SP)

~,.

Dark gray; dry; loose.

Boxing

advanced with

a geoprobe

using a

4’

long

by 2” OD

macrotube

sampler.

CERCLA landfill cap

encountered at 0,25

ft.

(I~1

LFR

Client:

Johns

Manville

Project:

Landfill

ProjectNo:

009-07992-00

LEVINE~FRJCKE

Project Location:

Waukegan,

IL

Total

Depth:

12

(Elevation:

Date-Start: 5/10/04

Surface

Conditions:

Topsail

Date End:

5/1

0104

Drilling Contractor: Terra Trace

Driller:

Dennis

(Geologist/Engineer: W. Teskey

SAMPLE DATA

--

~U~SURFACE

PROFJL~

:-H

jr~

~

~,

~

Sail Description

Remarks

~

(I)

0)

C)

.

10

~

E

E

.~

o

—

—

10

10

10

—

(/)

(0

Z

EZ

.ET

~

II)

C)

.-

0

~

E

S

U)

(irouno ourrace

~1

Topsoil-Silty Sand (SM)

~Dar_kbr_od~l0,~’2roojs

Lean

Clay

(CL)

Brown;

dry;

stifti

Poorly Graded

Sand (SP)

Lean Clay(CL)

Gray;

dry;

stiff

5

with

fibrous

material.

Fibrous Material

Dark

gray;

white

fibers; moist;

15

paper, brown cardboard.

I

Tube

70

0

2

Tube

40

0.5

3

Tube

50

0.8

V3~

:1,

7I~

_,

H

~

Poorly

~sraded

sana (SF)

Black;

dry;

loose.

e

0

•~

~

Temporary

gas

monitoriji

v~11

installed:

1

inch

diameter PVC. Screened

from

1.Oto

4.0

ft.

~~e0

End

ofBorehole

---

:p’

2,

•

•$

••.

0

•

•00

0H

0

0

•0

+

0

0

H

0

$0,0

~~

000,

5

~

00

~H

•

0

•

04

0004

~0

•+•

• ~

0

+ 00

006k

0

‘

.:

0,

00+0

•

•

00

0000

0

Log of Borehole: 04-90

L~1

LFR

Client: Johns Manville

Project:

Landfill

—

LEVINE.rRICKL

Project Location:

Waukegan,

IL

Total Depth:

8

JGround Elevation:

Project

No:

009-07992-CC

Date

-Start:

5/10/04

Surface Conditions: Topsoil

Date

End:

5/10/04

Drilling

Contractor: Terra Trace

Drirler:

Dennis

(ceologistiEngineer:

W. Teskey

SAMPLE

DATA

SUBSURFACE PROFILE

r...

.2’

(0

II)

0

Iii

C)

$10

~‘

~

~.

‘~

~

~

.C

~D

~

~.

~.

(I)

(0

~.

CQ

C)

0)

..

Soil

Desenption

Remarks

iirouna

auriace

Boring advanced with

a

geoprohe using a

4’ long by

2’

OD

macrotube

sampler.

CERCLA landfill

cap

encountered

at

025

II.

I

-rn-’

Tube

25

0

2

Tube

60

0.4

To~olI-Silty

Sand

(SM)

-

Lean Clay (CL)

Brown; dry;

stitT

Roofing

Black; dry; hard; crushed shingle

material.

•-~g,i.

Black;

dry; dense;

fragments.

TnJA~i~

,_White; dry; crumbles;

trace

blue; no

fibers.

End

ofBorehole

6-

7—

8-.

9—

10—

11.~

l2.~

13—

14-

‘5.

---

Log of Borehole: 04-91

---

Log of Borehole:

04-92

---

Log of Borehole: 04-93

~J

Lean Clay (CL)

Drown;

dry; stiff;

10

roots at surface;

5

line

gravel.

-~

Poorly Graded Sand (SP)

4~r~

~rown;d~5flne

graveL

V

Silty Sand (SP)

3—...

~

Black;dr~.

~H

(‘rushed transite~

gray.

.4

4

4

oH

4-.l-’.~s-

~

Roofing

~o;

~~::

Black;

dry; sltmgles.

40

H0

5

~

:!~:

:~

::~-~

~~r~i~s

Green and gray; dry; loose.

V

0

0

Crushed transite;

gray;

dry.

7

I

End ofBorehole

I~J

LFR

Client:

Johns Manville

Project:

Landfill

LEVINC•FRICKE

Project Location: Waukegan,

IL

Total

Depth: 8

~

Elevation:

Project

No:

009-07992-00

Date

Stait 5/10/04

Surface Conditions: Topsoil/clay

Date End: 5/10/04

Drilling Contractor:

Terra Trace

f

Driller:

Dennis

I

Geologist/Engineer: W.

Teskey

SAMPLE DATA

SUBSURFACE PROFILE

Z

~—

“

.5?

~

~.

E

E

10

(0

(0

(1)

-~~=

~

ft

.

~.

(5

0

c

~

8

~

1SE

0)

—

0)10

Q~

0.

(0

V

—

~

~.

E

0)

,

~

Soil

Description

Remarks

I

I)

Ground

Surfbce

1

Tube

80

0.5

2

Tube

75

09

Boring

advanced

with

a geoprohe using a

4’ long by 2’ OD

macrotulje

sampler.

~ERCLA

landfill cap

encountered at

surthce.

Boring backtilled

to

surface

with

cuttings.

9—

10—

-0

11~4

l2.~

I3~

14-

IS.

---

Log of Borehole:

04-94

---

Log of Borehole: 04-95

0

1

UrOund

Suri~Ce

~

Lean Clay (CL)

Brown:

dry;

very stiff

4~

///~Ø

CERCLA landfill

cap

2

~

j

encountered at surface.

-

Poorly

Graded Sand (SF)

3~1ean~~aY(~L)

4

0

~

Fibrous rot~mg;black;

moist;

trace

tine

gramergray matcri~l.

End of

Borehole

5.9

Il-i

l2—~

13—

14—

l5.~l

L~1

L

FR

Client:

Johns

Manville

Project:

Landfill

I

Project No: 009-07992-00

LEVINE•FRICKE

Project Location: Waukegan,

IL

Total

Depth: ~

IGr0~d

Elevation:

J

Date

Staft

5/10/04

Surface Conditions:

Clay

Date End:

5/10/04

Drilling Contractor: Terra Trace

Driller:

Dennis

I

Geologist/Engineer: W.

Teskey

SAMPLE

DATA

V

SUBSURFACE PROFILE

E

~

~

‘

.2’

z

I-

~

I

Hi

II)

~1)

IC)

~5s)

E~

a

~a.

I

~

~

B

B

8

~

~5?E

a.

0)

0)10

0)

IX

0.

0)

C)

—

0

.0

B

.

Cl)

Soil Descrip~on

I

Remarks

I

VTube~

90

(1

Boring advanced

with

a

geoprobe

using a

long by 2” CD

ni

acrotube sampler.

Boring hacktilled

to

surface with

cuttings

V

---

Log of Borehole: LMW-11

-

.~///

Lean Clay (CL)

Dark

brown; slightly moist; moderately

stiff;

15

rootlets

i~7

Grading brown;

dry; very

stiff; compacted; 5

fine gravel

y

Sand (SP)

Brown;

dry: loose;

5-10

fine gravel

3;....

4~i:.

:.

V

Grading black with

5

roofing granules

Very moist:

10-15

roofing granules; poor recovery

V.

~

V

V V

V

-r

~..

V

V

l0~~V8.V

Dark gray: moderately dense; wet;

5

fine

gravel

~

_~V.5V

Sand (SP)

I l’y.•.y.

Dark gray: ~vet;moderately dense; medium

sand; 5

fine gravel

12—

I

lE~

L FR

Client:

Johns Manville

Project:

Landfill Well

Project No: 009-07992

1.EVIN E~FRlCKE

Project Location: Waukegan,

IL

Total Depth: 41’

IGro~nd

Elev.:

5

~

1...

Date

Start:

5/16/03

Surface Conditions: Topsoil

Date End: 5/16/03

Drilling Contractor: Mid-America

f

Driller:

Brian

I

Geologist/Engineer: W. Teskey

SAMPLE DATA

SUBSURFACE

PROFILE

a)

V

—

.0

•~-~

I

E

~3

~

(5

~

e_

V

cV

.~

ia-S

~5)

....

‘—

~E.

~

E

E

o

-

oo

c

CS

(5

(1)-

.

-

0

Cot?)

CrIZ~

,~

I

-

V

Soil Description

Remarks

~I

—-

V

-

a.

E

I

Hi:

~

,

-

(I

Ground ~urlace

-

-

I

CME

30

NA

NA

li~~1

-

V

-~

20

NA

NA

2

CME;

4

Bonn

advanced using

4.2

D hollow

stens

augers.

Sampled

using

3” diameter by

5’

long

I

CME spoons

or2”

2’ long split spoons.

Poor recovery:

5-10’.

Limestone

cobble

in

shoe of sampler.

Heaving sand

encountered while

drilling.

:

3

SS

50

~

~

I

:

NA

I

NA

I~

~

~

---

Log of Borehole: LMW-11

D

LFR

Client: Johns Manville

Project:

Landfill Well

Project No: 009-07992

LEVINE’FRICKE

Project

Location: Waukegan,

IL

Total

Depth: 41’

~Gr0und

Elev.:

Date Start: 5/16/03

Surface

Conditions: Topsoil

Date End: 5/16/03

Drilling Contractor:

Mid-America

Driller:

Brian

I

Geologist/Engineer: W.

Teskey

SAMPLE DATA

SUBSURFACE PROFILE

—

:

-

Ii)

-

.0

E

~3

E

a

~

..

—

0)

C)

z

t—

~

.i~

.~

Ii)

~)

0

~

E

E

o

c~

E

CD

(5

0)

C

0

Cl)

c/)~z

~

I

:

I

Soil

Description

Remarks

~

—

0

I

.0

-

~.

E

(1)

,

-

0

Cl)

4

SS70NA~NA

.

H

-~

5

SS

7OVNA

NA

~.

6

SS-

70

NA

NA

7

SS

30

NA

NA

8

SS

70

NA

NA

9

SS

50

NA

NA

_•:.::~.:-

Sand(SP,J

—

y....

Dark gray; wet; moderately dense; medium

sand;

5

fine gravel

Increase to

I 0-12

gravel

13—~.:..V:.y.

14—.

:

.

.:

15.:

~

-:

16:~::

Grading grayish brown; decrease

to5

gravel

I

~

19_:..::

V

20_~~.

:

::

-.

21.—..

1/2” layer

silt;~ra~

dense

/

Sand~SP~J

Dark

gray: wet: moderately dense:

medium grained sand:

5

fine

gravel

23_:

.

.-

:

-

24—.

..

~.

:

---

25—

26—.

.1.:

27—..~.

28—:.

29—~.

‘:.

~

32—:

34_:

35—

36~:::.~

Log of Borehole: LMW-11

D

L FR

Client: Johns

Manville

Project:

LandfiU Well

LEVINE~FRICKE

Project Location:

Waukegan,

IL

To~lDepth:

41

~round Elev.:

Project No:009-07992

Date

Stag:

5/16/03

Surface Conditions: Topsoil

Date

End:

5/16/03

Drilling Contractor:

Mid-America

Driller:

Brian

J

Geologist/Engineer: W. Teskey

SAMPLE

DATA

SUBSURFACE

PROFILE

I

~

~:

=

E

a)

E

~

~

~

(I)

~,,

e

(1)

5)

Ia)

~

~

ID

0

~.

~

,•~

E

Eo

ca

E

a)

(a

a)

~

0

Cl)

(I)

‘

~

~

Soil Description

Remarks

‘~

.c

2

o-E

a)

,

Ccl)

10

SS

40NA

NA

I

11

SS

80

NA

~

NA

i~

~

~

:

!

12

SS

80

NA

:

.

!

NA

~\

!~

~

~

.~

~

~

!~

~

~

.

~

~

.~

I

i

I

~

~!

Sand

(SP~)

Dark

gray: ~vet;moderately dense;

medium

grained sand:

5

tine

gravel

Grading brown

Grading

to

fine

sand

Grading

brownish-gray

NA

:1——i:

13

SS

lOONA

:~____:

---

Log of Borehole: LMW-11

LFR

Client: Johns

Manville

Project:

Landfill Well

LEVINE•FRICKE

Project Location: Waukegan,

IL

Total Depth:

41’

IGround Elev.:

Project No: 009-07992

Date Start:

5/16/03

Surface

Conditions:

Topsoil

Date

End: 5/16/03

Drilling Contractor: Mid-America

f

Driller:

Brian

I

Geologist/Engineer: W. Teskey

SAMPLE DATA

SUBSURFACE PROFILE

-

a)

0.:=

.0

.-~

Es

E

~

(U_~

-

0)

-

0)

z

~

(D:C

G):Q)

11)

~.

Si

E-E

o

(S

CD

S

V

C

0

~

Z

I~

V

~

-

.

Soil Description

.

Remarks

~

—

-

.C

.0

-

-

a.

E

V

SI

01c,)

_r..:..5..y.

Monitoring well con-

structed

with stainless

-

steel riser and screen

on

5/16/03.

Screen

38—~

..

.

(0.010” slot) from

35’

to 40’. Silica sand

-

:

(#5)

from 32’ to4O’.

Cement

bentonite

grout: 2’ to 32.

39~..

::.

Bentonite chips from

0.S’to2’.

Concrete

-

pad

0to0.5’.

-

Above ground

V_s.

.

steel protective

40.—~.

;:.~

Casing

WI

locking cap.

—

-

Water level

on

41

~

:

5/19/03:

approximately

End ofBorehole

(irading brown

sn-gray

I::

HH~:

Th~

14

-

SS

90

NA

NA

:~H:::

IS

SS

100

NA

-

NA

42—

43-4

44—~

45~

46—~

47-.

48-.i

---

WELL

LOG

SUMMARY

V

~)

P~fl~4~c

-~4’

2-~,’~”~

-

~

Section

No.

/~~‘

WELL

~

OWNERS

NAME

p~

WEL~

TYPC0

LOCATION

OLPTI4

u~-r

INCH~

STATIC

~

Q

7~fl~

~si

LO~

OAIFT

~

REMARKS

/

LJMnS-4ftrnyl//e

~,‘/72~

S~S~5~J

/4Y

~5

~‘

£‘.IR

~~r,1!eJ/gzo

~‘

~

7~

“,~-

mQI~1,

“~

a~2S-m~?,1v,i/e

/7~9

~/73

3E9~

/~‘7

/3z-

—

g~

~i

c..,

~/k’djgz

~‘

•

Joh4~i?-ma,n/,//e

.

d

/9&o

-_~(

ct~k-’

,4~6~/ft~-~

-/

d/.

~

,~/

r~—~

~--

-

-

----~---

-

-

----

-—

-

~----—-

---

j,~aC.

).toor~

Cucpoiaci’~fl.

5oehesi~r,

i’l.Y.

ftjnde: ist

hole’

11

—1j~~)

P&tCnIe.1

iSOO.

3867g0

-

.

_

TOWN

TOWNSUW

‘—wan~e~an

Map

No.

~

co~&r~~

~o.

ii.

12

E.

s’aiuc

JOlms-Mariville

No.

1

~uo~i~

Supt.

._LJ.J.

ELEVATION

588

45

N.

_________

10

COLLECTOR

W.D .0.

DATZ

D~IIJ~~D

1920

-

CON1i~ID~NTXAL

.

~

~j

~.

COW~1Y

N(3./7~4fAT8.

~

-.. -.

Saxit3.

3O~

30

Hard

~an

25

Clay, bl-ue

50

105

Sand-

.-~

.

108

Bock

at

108’

t~o.

a~VELOPE

Couat~

LAXE

inãex

No.

0810

~.—DItILL

~ZCOBD

~

~5O83—a~—7-a1).~Z

IlUnel;

Gto~ogIcdSurvey,

Urbasa,

-

-

~

—~

—

~j--~___~

-

~

---

I ~

~-.

)tuor~

C,,rn,o~I,.,u

~

~

i~

.t

TOWN

TOWNSUZP~

egan.

COMPAN~

FAILM

rohns-Manvllle

AuT~OBITr

-

Supt.

~L3sVA~ON

588

co~c~ro~

W.D .G

•

DATZ rnuu~

C0NIrIDaNTIAL

N(~.

Sand.

Hard.

pan

Clay,

blue

Sand.

and.

gravel

Rock

NO

E~VELO1~E

County

T.—DIULL

UZCOED

No.

45N.

1920

Tbtckne~.

Feet

34

21

43

14

15

)~ftpNo.

8.

L

12 L

10

In..

Depth

3’

55

98

112

127

Index

No.

0810

1O-45N-12~

~n.

(.11

(3OS1~M_~31)

~,.s

lUtnoti

Gco~og8c;I

burvuy,

Urbau,

---

John~..

Moore

COCpOY*Ur.n.

ttOc~ut(1,

tLY.

ttodcr

u.o4lioles

in

Leive~

~

P~irneJ

1(Q6.

38G700

-V.

-

-

.

‘.

TOWN

TOWNSHIP

~

MiP

No.

8

No.

~.

12 B.

~

Johns

-Manville

~o.

3

T

£DT~OflIT~

Supt.

EL~VATlON

588

45

N.

__________

10

COLLECTOR

W.D.0.

DATE

DBILLBD

1920

CONFIDENTIAL

r~i

COUNTY

NO.

J’/~3~.A~

I~*.

Sand.

~0

30

Hard

pan

25

55

Clay, blue

47

102

Sand

and

gravei~

13

115

Rook

..

17

132

~4OEMVELO~

County

LA1~E

Iadex

No.

0810

T.—DRILL

RZCO~D

1O—46~—l2~

(3~—6a&—-7-34)

uu~s.

G,o5ogtc*~ 8ur~e~’1

~

---

,ta~r~

-

;k,o.

It

.

MS.

ic~lh

deS.

;Cr(Wd

3sa1~

TOWNS~ZP

egaxi

TOWN

-

COMPANY

F.AJLM

Johns-Manvi

lie

AUT~O~ITY

S~pt.

ELEVATION

588

COLLECTOR

.W.D.G,

DATE

DUILLED

CONFIDENTIAL

No.

Map

No.

d

E.

12

E.

NO

E~VE1OPE

County

L.A.KE

~ni1e~

No.

T.—DIZILL

UECORD

(3O61D—OM——~-31)

.~,2

Ililuoli

Geological

8urvoy,

Urbana.

No.

4

T

Sec.

45N

1920

No.

10

—I

Sand

-

-

Hard.

pan

Clay, blue

SaDcl

and

gravel

Rook

-

-

--

---

CERTIFICATE OF SERVICE

The undersigned, an attorney, hereby certifies that he caused the foregoing notice

and

amended petition for adjusted standard to be served upon:

Division of Legal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box

19276

Springfield, Illinois 62794-9276

Peter Orlinsky

Assistant Counsel, Northern Region

Illinois Environmental Protection Agency

9511

West Harrison Street

Des Plaines, Illinois 60016

Elizabeth Wallace

Assistant Attorney General, Environmental Law

188 West Randolph Street,

20th

Floor

Chicago, Illinois 60601

by placing the same in the United States mail, first-class postage prepaid, this

30th

day of

September,

2004.

Edward P. ~

CHI

3057722v1

September 30, 2004 (02:O6pm)

27

THIS DOCUMENT IS SUBMITTED

ON RECYCLED

PAPER

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~~~1~~~~

—~—-~---

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—--—-i-

----- ----

—-----

——--- -—---—