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Landfill on the shores of Lake Michigan at the former Fort Sheridan site.




Dear Lake Michigan Stakeholder:

I have been the main voice of opposition to the Army’s plan to cap Landfill
7 in place on the shoreline of Lake Michigan at the former Fort Sheridan.
The following is a quote from a 7/7/97 personal written communication from
William E. Muno, Director, Superfund Division, U.S.EPA Region 5:

"Based on current data available at this site, we believe that the Army’s
plan to cap the landfills is protective and appropriate, and is also
consistent with other U.S.EPA Superfund cleanups."

This goal of consistency is flawed in that it passes along previous
mistakes which were based on previous lack of knowledge to present
remediations to the detriment of the environment. I feel that it is wrong
to base the environmental health of our drinking water supply on our
ability to stop the powerful natural force of erosion.

According to the 2/12/98, Highland Park News regarding a similar lakeside
asbestos dump:

"The small pieces of asbestos that washed up on the beach’s shores may have
come from the nearby Johns-Manville Corp. asbestos plant in Waukegan. The
Environmental Protection Agency spent more than $3.5 million in Superfund
money in 1991 at the plant to cap 1 million tons of asbestos dumped within
50 yards of the lake."

The failure of the U.S.EPA to properly protect the Johns-Manville Superfund
site on Lake Michigan should make them rethink the notion of engineering
against erosion as proper remediation. Sadly, I feel their arrogance will
not allow them to admit their folly.

40 CFR 258 Floodplains.

(a) Owners or operators of new MSWLF units, existing MSWLF units, and
lateral expansions located in 100-year floodplains must demonstrate that the unit will not restrict the flow of the 100-year flood, reduce the temporary water storage capacity of the floodplain, or result in washout of solid waste so as to pose a hazard to human health and the environment. The owner or operator must place the demonstration in the operating record and notify the State Director that it has been placed in the operating record.

40 CFR 258.15 Unstable areas.
(a) Owners or operators of new MSWLF units, existing MSWLF units, and
lateral expansions located in an unstable area must demonstrate that engineering measures
have been incorporated into the MSWLF unit's design to ensure that the integrity of the structural components of the MSWLF unit will not be disrupted. The owner or operator must place the demonstration in the operating record and notify the State Director that it has been placed in the operating record.


The U.S.EPA and Army are riding roughshod over these laws by stating that
they are using the latest in erosion controls so they are confident in
their ability to protect the bluffs and shorelines and therefore the
landfills. This asbestos debacle gives the truth about our current
knowledge of bluff erosion. I propose that no amount of knowledge will
stop the forces of erosion in the long run. The EPA sanctioned landfills
along the eroding shoreline of Lake Michigan are a house of cards built on
the premise of consistency of previous cleanups. Now that the underlying
premise has been shown to be false, it is our responsibility to force them
to revisit the issue of appropriateness of landfilling along our primary
drinking water source.

Please help protect the citizens of Lake Michigan from the federal
government breaking their own federal laws to save themselves cleanup
money. Cost/effective cleanups need to consider effectiveness. Our
regulators need to be reminded of this before Lake Michigan can no longer
be used as a source of drinking water.

Sincerely,
Steven Pollack
steve@familyjeweler.com
<http://www.familyjeweler.com/fortweb.htm>http://www.familyjeweler.com/fortweb.htm

p.s. Historical documents show that Landfill 7 received untreated
infectious medical waste, liquids, radioactive materials, sewage treatment
plant sludge, and various other environmental hazards.