United States
                  Environmental Protection
                   Solid Waste and
                   Emergency Response
EPA 520-F-94-002
      Fall 1993
v>EPA       Super-fund  At Work
                  Hazardous Waste Cleanup Efforts Nationwide
         Site Profile
  Site Description:
  Asbestos dump and ponds
  Site Size: Approximately 120 acres
  Primary Contaminants:
  Asbestos, lead, chromium, arsenic,
  and volatile organic compounds
  Potential Range of Hearth Risks:
  Increased incidence of lung cancer
  and other respiratory disorders
  Nearby Population:
  200 residences within one mile
  Ecological Concerns:
  Wildlife along Lake Michigan and
  Illinois Beach State Park
  Year Listed on NPL: 1983
  EPA Region: 5
  State: Illinois
  Congressional District: 10
 Pipes, shingle rolls, and manufacturing waste were used to build up the side walls
 of a 33-acre settling basin where asbestos fibers formed a sludge.   	
Success In Brief

EPA and State Combine Tough

Enforcement with Careful Oversight

  At the Johns-Manville Superfund site, manufacturing wastes laden
with asbestos and toxic substances were dumped for more than 70
years into pits forming an enormous landfill. Industrial wastewater
pooled into acres of settling ponds. Airborne asbestos endangered
workers and threatened ecological habitat in an adjacent state park and
along Lake Michigan. With help from the State of Illinois, the U.S.
Environmental Protection Agency (EPA) negotiated with the Manville
Service Corporation for a comprehensive cleanup of the site. The       f
company was not always cooperative, however, and incurred substan-
tial penalties for violating cleanup agreements. Vigorous enforcement   ,
and constant oversight ensured the successful remediation of this site.
Overall efforts included:
  • Covering a three million ton landfill of asbestos, heavy metals,
    and other contaminants with a multi-layer cap;
  • Closing several wastewater settling ponds and placing a 6-foot
    layer of limestone along perimeters of active ponds; and
  • Cleaning up three additional areas of contamination discovered
    after completion of the original plan.

                              The Site Today
                                Schuller International purchased
                              Manville and continues to manu-
                              facture construction materials
                              at the same location outside
                              Waukegan, Illinois. EPA is moni-
                              toring the landfill's 24-inch cap
                              which has been planted with new
                              vegetation. Old wastewater settle- .
                              ment ponds were filled with
                              sludge and retired from use.
                              Measures were taken to prevent
                              wind and water erosion of the
                              interior slopes of the ponds that
                              remain in use. On-site air and sur-
                              face water, as well as ground water
                              down-gradient from the site, meet
                              state and federal safety standards.

                      • Superfund At Work  •  Johns-Manville Site, Waukegan, IL  •  Fall 1993
  The Johns-Manville site
covers approximately 120 acres
and is bordered by Lake Michi-
gan and a state park to the east
and north, respectively. The
City of Waukegan borders the
site to the east with a popula-
tion of 75,000. Approximately
200 residences are within one
mile of the site.
  In 1922, the Manville Service
Corporation began producing
construction materials includ-
ing low-temperature pipe
covering, asbestos roofing
products, cement pipe, cut
gaskets, wallboard, and glass
fiber shingles. Almost all of the
wastes generated since 1922
have been disposed of on site.
           A Site Snapshot

           The plant continues to produce
           construction materials, but
           asbestos and lead are no longer
           used in manufacturing these
             EPA studies found elevated
           levels of asbestos in the air and
                      Johns-Manville Site
                      Waukegan, Illinois
                         ground water on the site and in
                         Lake Michigan, as well as other
                         hazardous chemicals in the
                         ground water. The primary
                         contaminants included asbes-
                         tos, lead, arsenic, chromium,
                         and volatile organic com-
                            Asbestos fibers are easily
                         dispersed by the wind; inhala-
                         tion of these fibers causes a
                         wide variety of respiratory
                         problems, including lung
                         cancer. Those potentially
                         most affected were the 600
                         Manville employees and
                         visitors who frequented the
                         adjacent state park or beaches
                         for recreation.
    Site Timeline
  U.S. Environmental Protection Agency
  Region 5, Library (PL-12J)
  77 West Jackson Boulevard, 12th Floor
  Chicago, IL  60604-3590
                                          1 EPA begins comprehensive site studies
                                          > Manville agrees to complete studies

                                                   • Site listed on NPL A
                                                         • EPA confirms asbestos in air,
                                                          ground water and soil
         • Congress enacts Superfund
• EPA sets national emissions
 standards for asbestos
• Congress enacts Clean Air Act
              Early manufacturing
                activities begin

                        Superfund At Work  • Johns-Manville Site, Waukegan, IL  •  Fall 1993'
 Asbestos Landfill Rises to 20 Feet,
 Prompting EPA Response
Asbestos Dumping Lasted
67 Years
   In 1922, the Johns-Manville
Sales Corporation opened a
manufacturing plant for the
fabrication of cement pipe and
asbestos roofing felt. Production
waste was regularly dumped in
disposal pits that currently en-
compass approximately 70 acres.
Over the years, sections of the
asbestos landfill reached over 20
feet in height.
   A wastewater facility encom-
passed an additional 50 acres, and
consisted of several large ponds
where asbestos and fibers settled
out of industrial wastewater. As
the ponds filled, the fibers were
dredged and placed in the ever-
                       growing landfill. Fabrication
                       waste such as shingle rolls and
                       asbestos-containing pipes were
                       used to build up the side walls of
                       the ponds that abutted the land-
                            "This place was an
                          engineering wonder."
                              — Brad Bradley,
                           EPA Remedial Project
                       The landfill in turn served as a
                       dyke for the wastewater system,
                       since all the ponds were eventu-
                       ally interconnected with the
                       landfill. Retired ponds were
filled with sludge and became
dry areas, contributing to dust
in the air under windy condi-

Manville First Regulated under
Clean Air Act
  In 1970, Congress passed
the Clean Air Act, establishing
EPA's first asbestos abatement
program. The Act required EPA
to set National Emission Stan-
dards for Hazardous Pollutants
(NESHAPs). In 1971, EPA deter-
mined asbestos to be a hazard-
ous air pollutant because of the
fibers' ability to cause serious
respiratory disorders, lung
cancer, and death.  In 1973,
EPA issued regulations to
' EPA selects cleanup approach after public comment

  /> • Manvife signs agreement with EPA, begins work plan
     * Manville pays $38,000 penalty for late submission of
      cleanup plan
     • Manville begins cleanup

            EPA, state discover additional contaminated areas
              \ •Manville pays $165,000 penalty for violating
              ^  cleanup procedures
                * Multi-layer cap over landfill and settling ponds completed
                               New areas cleaned up
                               Air, ground water and surface water
                               monitoring (on-going)
                                                           • Five-year review (projected)
  1987  1988  1989  1990  1991
                                           Page 3

                         Superfund At Work  •  Johns-Manville Site, Waukegan, IL  •  Fall 1993
control asbestos emissions from
manufacturing, milling, roadway
surfacing and demolition projects.
   Manville's waste disposal
practices first became a concern in
1973 when the Illinois Institute of
Technology Research conducted
air sampling at the site under
NESHAPs authority. Investiga-
tors found no conclusive evidence
of asbestos in the air at that time,
but worker exposure was not
measured. Asbestos tends to
break down into a dust
of tiny fibers that remain sus-
pended in the air for long periods
of time and are easily inhaled.
Because of their durability,
these fibers can remain in the
body for years. In general,
asbestos related diseases have a
latency period of 20 to 40 years
after exposure.
   In 1980, Congress established
the Superfund program within
EPA with a primary goal of
cleaning up the nation's hazard-
ous waste sites. Whenever pos-
sible, EPA locates those respon-
sible for the site contamination
and tries to negotiate the use of
private resources for cleanup.
   A 1985 Manville report
     counted more than
      3 million tons of
  contaminants at the site

  At the State of Illinois' request,
EPA collected more air samples in
1982, this time finding elevated
levels of asbestos in the air on site
and downwind. Additional
studies revealed arsenic and
asbestos in ground water, and
lead and asbestos in the road-
ways, sludge and waste materials.
Within a year, EPA officially
added the site to the National
Priorities List (NPL), EPA's roster
of hazardous waste sites requiring
cleanup under the Superfund

EPA Compels Manville to
Cover 3 Million Ton Landfill
  In 1984, EPA began comprehen-
sive site studies  to determine the
nature and extent of contamina-
tion at the site. In June, EPA and
Manville signed an agreement,
called an administrative order on
consent (AOC), under which the
company agreed to complete
these investigations.
  A 1985 Manville report counted
more than 3 million tons of asbes-
tos, lead, chromium, xylene, and
other contaminants at the site.
Several approaches were pro-
posed to clean up the site and
presented to the local community.
              continued on page 5
     "Asbestos" is the name for a
  group of naturally occurring
  minerals that separate into
  strong, aoiqEXBcopic fibers that
  are heM insistent, odorless, and
  veiy durable. These qualities
  have made asbestos extremely
  useful to the rortstraction
     Asbestos lias been used for
  thermal tnd acoustical insula-
  tion, fire-proofing, roofing and
  flooring felts, vinyl floor tiles,
  pipe insulation, cement piping,
  and in friction products such as
  brakes for trucks and automo-
  biles.  Friable (easily crushed or
  pulverized) asbestos emits
  microscopic fibers into the air

when even sigMy disturbed,
Ttiese fibers are easily inhaled
and can cause a host of respira-
tory disorders.
  Lung cancer is the most
frequently seen asbestos-caused
disease and is more likely to
occur if the exposed person is a
smoker. Asbestos also causes
asbestosis, a chronic disease of
the lungs that makes breaming
progressively more difficult and
can lead to death.
  EPA has taken numerous
actions since 1971 to regulate the
manufacture, use, removal,
transportation and disposal of
asbestos-containing products
and materials. EPA maintains a
toll-free number for citizen
concerns, questions and com-
plaints at l-8«K368-5888 (in
Washington, D.C. call 557-1938).
                                             Page 4

                         Superfund At Work  •  Johns-Manville Site, Waukegan, IL  •  Fall 1993


  Rises to 20 Feet

continued from page 4
  In June 1987, following a
period of public comment, EPA
selected the remedy for the site
consisting of the following ac-
tions: waste materials in the
landfill were to be "capped"
with a 24-inch protective cover
of sand, clay, and top soil.
Several of the wastewater settling
ponds also would be closed and
covered. The multilayer covers
would be monitored to ensure
that no asbestos reached the
surface. To prevent public access
to the site, warning signs were to
be posted and a fence constructed
on the eastern site boundary,
neighboring Lake Michigan.
  A 6-foot layer of limestone
"riprap" was to be imbedded in
the interior slopes of the ponds
that remained in active use to
prevent wind and water erosion.
  To further guarantee the
success of the cleanup efforts,
EPA would monitor ground and
surface water for 30 years, and
continue air monitoring for at
least 15 years. In addition, EPA
would review the site in five
years to determine the  effective-
ness of the protective covers and
other measures.

Cleanup Violations Result in
   In March 1988, EPA, the State
of Illinois, and the Department
of Justice successfully negotiated
another agreement, called a
consent decree, requiring
Manville to conduct the cleanup
  Trees and other vegetation covered many acres of the landfill before the cleanup;
  investigations revealed 3 million tons of asbestos wastes largely hidden from view.
under EPA and state supervision.
The company also agreed to
reimburse EPA for past cleanup
costs of $153,000.  Manville's
cleanup plans, however, were
submitted late to EPA and did not
incorporate some of EPA's previ-
ous recommendations. EPA fined
Manville $38,000, which the
company subsequently paid.
  Manville began the cleanup
under a revised workplan in late
1988, but once again violated the
terms of the consent decree. EPA
halted their work in January 1989
after discovering that Manville
graded more of the surface  than
allowed in the cleanup plan.
Preparation of the landfill for the
protective cover was intended to
flatten only the slopes that would
be difficult to maintain in the
future, while minimizing the
potential for asbestos releases to
the air. But Manville moved an
extra 25,000 cubic yards into a
settlement pond, risking a dan-
gerous air release.
  At other times, Manville's
actions caused visible emissions
of asbestos near Lake Michigan.
The company then failed to halt
work after the emissions oc-
curred. In response, EPA filed a
lawsuit against Manville, seeking
penalties for the cleanup viola-
tion. The suit was eventually
settled out of court, and Manville
paid a $165,000 fine in 1990.

Cleanup Complete, Monitoring
  Under EPA supervision, the
cleanup proceeded to completion
in May 1990, as required by the
consent decree. During the
course of the cleanup, however,
the Remedial Project Manager
suspected that asbestos had
spread much further around the
site.  The state provided quick
sampling and analysis, and the
community was informed that
Manville had much more work
to do. The cleanup plan was
              continued on page 6


continued from page 5
expanded to include two extra
wastewater ponds, a beach area,
a roadway, an old marina, and
an off-loading railroad station.
These areas were promptly
addressed, and cleanup was
completed in August 1991.
   In total, Manville spent $15
million remediating the site,
and paid $203,000 in penalties
for violating cleanup agreements.
The only activities remaining
are maintenance of the multi-
layer cover, and continued air,
surface water, and ground water
monitoring.  In 1996, EPA will
conduct a five-year review of
the site to confirm that cleanup
standards are still maintained.
                         Superfund At Work  •  Johns-Manville Site, Waukegan, IL  •  Fall 1993
      Success at Johns-Manville
  EPA used Superfund en-
forcement authorities to com-
pel Manville to cooperate in
cleaning up the site. With
assistance from the Depart-
ment of Justice, EPA exacted
penalties exceeding $200,000
from Manville for violating
terms of their negotiated
settlement. Manville later
completed work at the site and
voluntarily cleaned up newly
discovered areas of contamina-
tion. The state provided
valuable oversight of cleanup
operations, as well as timely
sampling and analysis of addi-
tional asbestos-contaminated
areas discovered during the
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