&EFA
     United States
     Environmental Protection
     Agency
  Share your opinions
  EPA invites your comments on its
  recommended plan for cleaning up
  contaminated paper waste at the
  Willow Boulevard/A-Site Landfill.
  Your input helps EPA determine
  the best course of action. You
  may fill out and return the
  enclosed form, submit comments
  electronically via the Internet at
  epa.gov/region5/publiccomment/
  or e-mail or fax your comments to:
  Shari Kolak
  Remedial Project Manager
  EPA Region 5 (SR-6J)
  77 W. Jackson Blvd.
  Chicago, IL 60604
  (800)621-8431  ext. 66151,
  weekdays 10 a.m. - 5:30 p.m.
  Fax:(312)353-1155
  epa.gov/region5/publiccomment
  Your comments must be
  postmarked by the last day of the
  comment period:
  July 15-Aug. 15, 2005
  You may also share your views
  by attending a public meeting and
  hearing.  During the meeting, EPA
  will give a presentation to explain
  the proposed plan and you will
  have a chance to speak for the
  public record during the hearing
  phase. You may also submit your
  written comments during the
  meeting.
     Contact information continues
          on the backpage.
EPA  Proposes  Cleanup  Plan for
Landfill  Paper Waste
                                      Allied Paper, Inc./Portage Creek/Kalamazoo River
                                      Willow Boulevard/A-Site
                                      Kalamazoo, Michigan
                                                       July 2005
U.S. Environmental Protection Agency Region 5 is proposing to oversee
the collection and disposal of contaminated paper waste at the Willow
Boulevard/A-Site landfills. The proposed cleanup will involve digging
up contaminated paper waste that has eroded from the landfills into
surrounding areas and placing the material into A-Site. The pollutant of
most concern is a chemical compound called polychlorinated biphenyls,
commonly called PCBs.  PCBs were a common byproduct of recycling
carbonless copy paper.

The Willow Boulevard/A-Site is one of four landfills located in the Allied
Paper/Portage Creek/Kalamazoo River Superfund site that begins at
Morrow Dam and stretches 80 miles downstream to Lake Michigan.

EPA is also currently negotiating an agreement for a separate cleanup action
at the former Georgia Pacific and Hawthorne mills.  The mills are located
north of the Willow Boulevard/A-Site, across the Kalamazoo River (see
map, Page 2). If an agreement is reached, part of the cleanup will involve
digging up PCB-containing paper waste and soil at the mills and then
placing this material into A-Site.  After all waste is placed into A-Site, a
protective cover will be placed on top of the Willow and A-Site landfills,
and ground water (underground source of water) will be monitored.

The purpose of this proposed plan fact sheet is to provide basic background
information about the landfills, describe the various cleanup options
considered, and identify EPA's preferred cleanup alternative.^ The public is
encouraged to comment on this proposal. EPA will be accepting comments
from July 15 to Aug. 15, 2005. See the adjacent box on how you can
provide comments to EPA. You can also attend and participate in a public
meeting/hearing at the Kalamazoo Public Library on Wednesday, Aug. 3.

The final cleanup plan for the Willow Boulevard/A-Site will be selected
by EPA in consultation with its state partner, Michigan Department of
Environmental Quality (MDEQ). This will occur only after review and
consideration of information provided by the public during the comment
period and public hearing.  The final cleanup proposal, which will be


•* Section 117 (a) of the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA known as the Superfund law) requires EPA provide an
opportunity for public input with a meeting and comment period. It also requires a
newspaper ad announcing the proposed cleanup plan.  Tins fact sheet summarizes
an EPA document  called a remedial investigation/feasibility study.  The full study
and all other official documents can  be found at libraries in Kalamazoo, Plainwell,
Otsego, Allegan and Douglas.

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             GEORGIA/PACIFIC KALAMAZOO MILL
                                KPT-11
                           HESIPWllS IN ARFA EAST OF DAVIS CBEEK
Willow Boulevard/A-Site Operable Unit

presented in an EPA document called a record of decision
or ROD, could differ from this proposed plan depending
upon new information or comments EPA receives during
the public comment period.
The public is also encouraged to review the supporting
documents for the Willow Boulevard/A-Site.  The
information includes  a document called the remedial
investigation/focused feasibility study and the site-wide
human health and ecological risk assessment reports. The
remedial investigation studies the nature and extent of
contamination at the site, while the focused feasibility
study evaluates different cleanup options.  The risk
assessment evaluates potential risks to public health
and the environment from the contamination at the site.
The public can review these reports at the  information
repositories near the site: the Kalamazoo Public Library
or Western Michigan University's Waldo Library, both in
Kalamazoo,  and libraries in Plainwell, Otsego, Allegan
and Douglas. The addresses for each repository can be
found in a box on Page 7.
Site description and history
The Willow Boulevard/A-Site is located southeast of the
intersection of Business 1-94 and Highway M-96 (King
Highway) in Kalamazoo Township, Mich. The 32-acre
site is bordered by the Kalamazoo River on the north
and northwest; Davis Creek on the east; and Willow
Boulevard, the former Olmstead Creek and residential
areas to the south.
The site consists of two separate disposal areas,
Willow Boulevard and A-Site.  Willow Boulevard
occupies approximately 11 acres, while A-Site occupies
approximately 22 acres.  The site was used to dispose
of paper-making waste. The waste consisted mostly of
water, wood fiber and clay.  PCBs were introduced into
the waste between the 1950s and the 1970s as a result of
the recycling of PCB-containing carbonless copy paper at
the former Allied Paper King Mill and the Georgia Pacific
Kalamazoo Mill.  Over time, PCB-contaminated waste
eroded from the Willow Boulevard/A-Site and moved
nearby to areas outside the landfills.  These areas include

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a landscape feature called the Willow drainageway, as
well as the area south of the A-Site berm (a ledge at the
bottom of a bank used to catch material that may roll
or flow down the slope) and the land near a monitoring
well designated AMW-3A .  Sample results indicate that
nearby residential properties  do not have PCBs above
acceptable levels and therefore pose no health risk to
residents.  Another area east of Davis Creek is also
contaminated with PCBs.  This area received excess (or
"decant") water from A-Site.
The A-Site was originally a series of drainage (or
"dewatering") lagoons used by the Allied Paper
Co. 's King Mill. Waste from the King Mill recycling
operations was piped to the lagoons and water was
allowed to settle out. The A-Site lagoons were active
between 1960 and 1967.  Operations at King Mill
ended in 1971, and the mill was razed in 1978.  Georgia
Pacific purchased A-Site in 1975 and used it to dispose
of materials dug up from the King Highway drainage
lagoons  until  1977.  The King Highway drainage lagoons
were located north of Willow Boulevard/A-Site across
the Kalamazoo River on a property owned by Georgia
Pacific.  From 1977 to 1987, the A-Site received drained
paper-making waste from the Georgia Pacific filter
presses.  The A-Site ceased to be an active disposal
area in 1987,  when the King  Highway Landfill began
operations. In late 1998, a wall composed of a material
called "sheetpile" was installed along the length of the
Kalamazoo River, extending  about 150 feet up Davis
Creek. This wall was installed 2 feet above the 100-year
flood level and was intended to reduce the potential for
PCB-containing waste to be eroded from the landfill into
the river if the existing dikes should happen to fail.
The Willow Boulevard site was acquired by Georgia
Pacific from the Kalamazoo Paper Co. in 1967. The
site, which was built without a berm, received PCB-
contaminated paper-making waste from the King
Highway drainage lagoons from the mid  1960s until
disposal operations stopped in 1975.  This waste
contained  clay, paper fibers and PCBs and was placed
directly into the river.
In 1999-2000, Georgia Pacific dug up waste from the
river next to the Willow Boulevard site at the junction
of the former Olmstead Creek and the Kalamazoo River.
Georgia Pacific also constructed a berm along a portion
of the river edge and placed a temporary 6-inch sand
cover over the landfill.
Health risks studied
A study of potential risks to public health and the
environment was conducted for the Willow Boulevard/
A-Site.  Part of the Willow Boulevard/A-Site study
used the conclusions from the evaluation done for the
entire Kalamazoo River Superfund site. This site-
wide evaluation concluded the greatest health risk to
people and fish-eating animals comes from eating PCB-
contaminated fish from the Kalamazoo River.  One
way fish can become contaminated is from erosion and
movement of PCB-contaminated waste from the landfills
and areas near the landfills into the river. The  site-wide
evaluation also concluded that recreational activities in
the Kalamazoo River such as swimming, boating and
wading do not pose unacceptable PCB-related  health
risks to people. The complete results of this site-wide
evaluation can be found at the information libraries in
documents called Final (Revised) Human Health Risk
Assessment and the Final (Revised) Baseline Ecological
Risk Assessment.
                   Willow
                 Boulevard
                             A-Site
This site includes two disposal areas, the Willow Boulevard and
A-Site, which are located in Kalamazoo Township. PCB-contain-
ing paper waste from the former King Mill and the Georgia Pacific
Kalamazoo Mill was disposed of in the landfills.

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Based on the data collected and evaluated during the
remedial investigation, the Willow Boulevard/A-Site
study concluded soil on the surface of the Willow
Boulevard site does pose an unacceptable risk to people
and wildlife through swallowing or skin contact with
PCB-contaminated soil or inhaling PCB-contaminated air.
At A-Site, surface soil does not pose an unacceptable  risk.
However, if deeper soil at Willow Boulevard and A-Site
is dug up and brought to the surface, people and wildlife
could be exposed to PCBs.
Residential properties south of the landfills do not contain
PCBs above acceptable levels and therefore pose no
health risk to residents.
The Willow Boulevard/A-Site study also evaluated
exposure pathways (ways to come in contact with
pollution) for areas near the landfills.  These areas include
Davis Creek, the former Olmstead Creek, the Willow
Boulevard drainageway, the area east of Davis Creek, the
area south of A-Site berm, and the area near monitoring
well AMW-3A. For areas near the landfill, the evaluation
concluded:
 •  sediment (mud) in Davis Creek does not pose an
    unacceptable risk to people and wildlife through
    swallowing or skin contact with PCB-contaminated
    soils or inhaling PCB-contaminated air
 •  sediment in the former Olmstead Creek does pose
    an unacceptable risk to wildlife but not to people
    through swallowing or skin contact with PCB-
    contaminated soils  or inhaling PCB-contaminated air
 •  soil in the Willow Boulevard drainageway does pose
    an unacceptable risk to wildlife but not to people
    through swallowing or skin contact with PCB-
    contaminated soils  or inhaling PCB-contaminated air
 •  sediment in the area east of Davis Creek does pose an
   Evaluation criteria
   EPA uses nine criteria to evaluate and compare
   cleanup options. See the table Page 7 comparing the
   alternatives against these criteria.
    1. Overall protection of human health and the
      environment addresses whether an alternative
      adequately protects both human health and the
      environment.  This factor can be met by reducing
      or eliminating contaminants or by reducing
      people's exposure to them.
    2. Compliance with applicable or relevant and
      appropriate requirements (ARARs) assures that
      each cleanup alternative complies with federal,
      state and local laws and regulations.
    3. Long-term effectiveness and permanence
      evaluates how well a cleanup alternative will work
      in the long term, including how safely remaining
      contaminants can be managed.
    4. Reduction of toxicity, mobility or volume
      through treatment addresses how well the
      cleanup alternative reduces the harmful effects,
      movement and amount of contaminants.
    5. Short-term effectiveness compares the time
      needed to implement a cleanup alternative and
      the health risks posed to cleanup workers and
      nearby residents while the alternative is under
      construction.
 6. Implementability assesses how difficult the
    cleanup alternative will be to construct and
    operate, and whether technology, materials and
    services are readily available.
 7. Cost compares the expense of each alternative
    over time in a financial calculation called present
    worth. Cost includes capital expenditures such as
    buildings, machines  and wells plus operation and
    maintenance costs. Present worth cost is the total
    cost of an alternative over time in terms of today's
    dollar value.
  8. State acceptance is whether the state
    environmental agency, in this case Michigan
    Department of Environmental Quality, agrees or
    disagrees with EPA's recommended alternative.
    EPA evaluates state acceptance after it receives
    public comments on its preferred option.
 9. Community acceptance assesses any issues or
    concerns the community near the site  has with
    EPA's recommended alternative. EPA considers
    this factor after it evaluates the public comments.

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    unacceptable risk to wildlife and to people through
    swallowing or skin contact with PCB-contaminated
    soils or inhaling PCB-contaminated air
 •  soil in the area south of the A-Site berm does pose
    an unacceptable risk to wildlife but not to people
    through swallowing or skin contact with PCB-
    contaminated soils or inhaling PCB-contaminated air
 •  soil in the area near monitoring well AMW-3A may
    pose an unacceptable risk to people and wildlife
    through swallowing or skin contact with PCB-
    contaminated soils or inhaling PCB-contaminated air,
    but this area needs further study
Another exposure pathway may exist in which people or
wildlife could be exposed to PCBs from the areas near
the landfills.  During  flooding, PCBs from these areas
may move or erode into the river. If PCBs end up in river
sediment, then the pathway that people or fish-eating
animals could be exposed to PCBs is by eating fish. It is
unclear whether this pathway actually exists, and it will
be studied carefully before the cleanup occurs.

Summary of cleanup  options
The goal for the cleanup at Willow Boulevard/A-Site
is to prevent the movement of PCBs from the landfills
and nearby areas into the Kalamazoo River. PCB
movement from the landfills can be reduced by taking
several actions including controlling erosion; limiting the
movement of PCB-contaminated paper waste and soil
from the  site through surface water; and reinforcing the
barriers that separate the contamination in the landfill
from the  Kalamazoo River.
EPA considered several ways to clean up PCB-
contaminated waste at the Willow Boulevard/A-Site.
The Agency evaluated each option against nine criteria
required by law. (See nine criteria explained in the box on
Page 4.)  The cleanup options include:
Alternative 1: No further action
EPA uses the no-action alternative as a basis for
comparison with other cleanup options. Since no
action would be taken, this option would increase the
potential  for human and ecological contact with the PCB-
containing waste and for waste to erode into the river.
Cost: $0
Alternative 2: Consolidation and containment of
select materials
This alternative is not a stand-alone option. It must
be paired with one of the bank stabilization measures
described under Alternatives 2A, 2B or 2C.
Alternative 2 involves digging up PCB-contaminated
waste from areas next to the landfill and placing the
material into A-Site. Approximate volumes that would
be dug up under this alternative are as follows: 7,000
cubic yards from the Willow drainageway; 2,900 cubic
yards from the area south of the A-Site berm (including
former Olmstead Creek); 3,800 cubic yards from the
area east of Davis Creek; and 100 cubic yards near
monitoring well AMW-3A. At the AMW-3A area, the
extent of soil contamination is not fully defined so the
volume of material to be dug up may increase. If an
agreement between EPA and Georgia Pacific is reached,
around 30,000 cubic yards of PCB-contaminated waste
at the former Georgia Pacific Mill and 5,000 cubic yards
at the former Hawthorne Mill properties will also be dug
up and placed into A-Site. After all waste is placed into
A-Site, a protective cover will be constructed on top of
both the Willow Boulevard and A-Site landfills.  Ground-
water monitoring will be conducted and the results will
be evaluated. If contaminants are present in ground water
at concentrations that present a risk to public health or
wildlife, then a ground-water cleanup remedy may be
required but that remedy will be done under a separate
EPA action.  Long-term maintenance of the cover and
institutional controls (restrictions on how the ground can
be used) will also be implemented.
Cost: $11.5 million to $13.3 million  depending on the
type of bank stabilization measures chosen
Alternative 2A:  Consolidation and containment of
select materials and install new sheetpiling at Willow
Boulevard
This option includes all components of Alternative 2 and
also includes the installation of new sheetpiling along the
perimeter of Willow Boulevard next to the Kalamazoo
River.  Under this option, 1,800 feet of sheetpile will
be installed and extend at least 2 feet above the 100
year flood level.  At A-Site, the existing sheetpiling will
remain in place and no additional sheetpiling will be
installed. Cost: $13.3 million.
Alternative 2B:  Consolidation and containment of
select materials, remove existing sheetpiling at
A-Site, regrade/stabilize banks with  a setback along
the Willow Boulevard/A-Site
This option includes all components of Alternative 2 and
requires the  existing sheetpiling at A-Site be removed or
cut off below the waterline.  The banks at both Willow
Boulevard and A-Site will be pulled back to create a

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setback or protective buffer along the Kalamazoo River.
New dikes will be installed and stabilized using low-
profile techniques such as revetment blankets, geoweb
materials or articulated concrete systems.
Cost: $12.7 million
Alternative 2C:  Consolidation  and containment
of select materials, regrade/stabilize banks using
ecologically friendly options at  Willow Boulevard
(this is EPA'spreferred cleanup  alternative)
This option includes all components of Alternative 2.
Additionally, waste at Willow Boulevard will be pulled
back to create  a protective buffer as in Alternative 2B,
but a more ecologically friendly dike will be installed.
This dike will  be  constructed using materials such as
organic soil and native  plants to improve habitat quality.
Under this option, the existing sheetpiling at A-Site will
remain in place and no  new sheetpiling will be installed
at Willow Boulevard. Cost: $11.5 million
Alternative 3: Removal  and off-site disposal
This alternative involves removing all PCB-contaminated
waste from the Willow  Boulevard/A-Site and in
surrounding areas. Under this  alternative, approximately
634,300 cubic yards of material will be removed and
disposed of at  an  off-site  landfill. Waste will be drained
and stabilized  using fly ash prior to disposal. Adding fly
ash will increase the material handling volume to 762,200
cubic yards. All excavated areas will be backfilled,
graded, and restored to  match the surrounding land.
Cost: $46.1  million
Alternative 4: Removal  of residuals from Willow
Boulevard and consolidation at A-Site
This alternative involves removing all PCB-contaminated
materials from Willow  Boulevard and placing the
materials into A-Site. Contaminated areas near the
landfills will also be dug  up and placed into A-Site. The
existing sheetpiling  at the A-Site  will remain in place.
After waste is  placed into A-Site, a protective  cover
will then be  installed. All areas excavated under this
option will be  backfilled with clean soil and planted
with vegetation.  This alternative includes long-term
maintenance, ground-water monitoring and institutional
controls. Cost: $13.3 million

How do the options  compare?
EPA evaluated the cleanup options against seven of
the nine criteria.  The state and community acceptance
criteria will be evaluated  after public comments are
received by EPA. The  degree to  which the cleanup
options meet the evaluation criteria and how they
compare to other cleanup options are discussed below and
illustrated in a chart on Page 7.
Alternative 1 would not protect public health or the
environment. Under this  option no cleanup will occur.
The potential for human and wildlife contact with PCBs
would increase because waste would remain in place at
the landfill and surrounding areas. This option would
also result in the increased potential of PCBs to move
through erosion,  surface water runoff or by ground water
from the landfills into the Kalamazoo River.
Alternatives 2A, 2B, 2C,  3, and 4 would protect public
health and the  environment.  The potential for human and
wildlife contact would be reduced or eliminated because
PCB-contaminated waste  would be contained under a
protective cover  or removed from the site.  All of these
alternatives would be effective in reducing erosion and
movement of PCBs into the river.
Under Alternative 2A, sheetpiling would be an effective
barrier between the waste and the river but would
result in permanent habitat loss along riverbanks.  This
alternative would also cost more than Alternatives 2B and
2C.
Alternative 2B would provide a more esthetically pleasing
riverbank but would require more extensive waste
handling activities than Alternatives 2A and 2C. This
option would also cost more than Alternative 2C.
Alternative 2C, which is EPA's current preference, would
use more ecologically friendly measures to improve
habitat quality while controlling costs. This alternative
also costs less  than Alternatives 2A and 2B and would
result in less waste handling than under Alternatives 2B,
3, and 4.
Alternative 3 would provide the most long-term
protection.  This  alternative may, however, increase the
potential for PCB exposure to workers and possibly to the
local community if PCBs  become airborne during digging
or accidentally released during transportation off-site.
Controls would be put in  place to reduce these risks, but
these risks cannot be eliminated completely.  Alternative
3 would also cost significantly more than Alternatives 2A,
2B, 2C, and Alternative 4.
Alternative 4 would also increase the potential for PCB
exposure to  workers and possibly the local community
but to a lesser  extent than Alternative 3.

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EPA's preferred cleanup alternative
Based on the analysis completed to date, EPA believes
the best cleanup option at the Willow Boulevard/A-Site
and surrounding areas is Alternative 2C. Alternative
2C includes the consolidation and containment of PCB-
containing waste, creating a protective buffer zone from
the river at Willow Boulevard, and using ecologically
friendly ways to restore the riverbanks and improve
habitat quality. Long-term maintenance and ground-water
monitoring will be conducted. Institutional controls (such
as a perimeter fence and land-use covenants) would also
be implemented to restrict public access to the site.
Read site-related documents
Kalamazoo Public Library
315 South Rose
Kalamazoo

Waldo Library
Western Michigan University
1903 West Michigan Avenue
Kalamazoo

Charles Ransom Library
180 South Sherwood
Plainwell

Allegan Public Library
331 Hubbard Street
Allegan

Otsego District Library
219 South Farmer Street
Otsego

Saugatuck-Douglas Library
10 Mixer Street
Douglas

When possible, Site information is also posted to:
epa.gov/region5/sites
Evaluation Criteria for
Willow Boulevard/A-Site
1. Overall Protection of Human
Health and the Environment
2. Compliance with ARARs
3. Long-Term Effectiveness
and Permanence
4. Reduction of Toxicity, Mobility,
or Volume Through Treatment
5. Short-Term Effectiveness
6. Implementability
7. Cost
8. State Acceptance
9. Community Acceptance
Cleanup Options
1
D
D
D
D
•
•
U
2A
•
•
•
D
•
•
$13.3 million
2B
•
•
•
D
•
•
$12.7 million
2C
•
•
•
D
•
•
$11. 6 million
3
•
•
•
D
*
•
$46.1 million
4
•
•
•
D
*
•
$15.8 million
Will be evaluated after the public comment period
Will be evaluated after the public comment period
                                     Fully meets criteria
-I* Partly meets criteria
Does not meet criteria

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&EPA
     United States
     Environmental Protection
     Agency

     Region 5
     Office of Public Affairs (P-19J)
     77 W. Jackson Blvd.
     Chicago, IL 60604
FIRST CLASS
          ALLIED  PAPER, INC./PORTAGE CREEK/KALAMAZOO RIVER
                           WILLOW BOULEVARD/A-SITE:
                     EPA Proposes Cleanup Plan for Landfill Paper Waste
                               This fact sheet is printed on paper made of recycled fibers.
                                Contact information continued from Page 1
                                   Wednesday, August 3, 2005
                                  6-7 p.m. - EPA presentation
                                  7 - 8:45 p.m. - public hearing
                        (Times are approximate; the hearing may end earlier
                        if all comments have been heard from those present.)
                                   Kalamazoo Public Library
                                 Van Dreesen Room, Third Floor
                                        315 S. Rose St.
                                         Kalamazoo
                     If you need special accommodations for the public meeting and
                     hearing contact Don de Blasio at the contact information above.
                     For more information
                     For scientific and technical questions about the landfill cleanup
                     you may contact EPA Remedial Project Manager Shari Kolak at
                     (312) 886-6151 ore-mailkolak.shari@epa.gov
                     When possible, site information is also posted on the Internet at
                     epa.gov/region5/sites

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Comment Sheet
U.S. Environmental Protection Agency is interested in your comments on the proposed cleanup plan for Willow
Boulevard/A-Site Landfill. EPA will consider public comments before selecting a final cleanup remedy for the Allied
Paper, Inc./Portage Creek/Kalamazoo River Willow Boulevard/A-Site. Please use the space below to write your
comments, then fold and mail this form. Comments must be postmarked by the last day of the comment period. If you
have general questions, contact Don de Blasio at (312) 886-4360, or through EPA's toll-free number at (800) 621-8431.
Those with electronic capabilities may submit their comments to EPA via the Internet at: epa.gov/region5/publiccomment.
                                                     Name
                                                     Address
                                                     City	   State.
                                                     Zip	

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Fold on Dashed Lines, Tape, Stamp, and Mail
Name	
Address
City	
ZIP	
State
                                              Shari Kolak
                                              Remedial Project Manager
                                              EPA Region 5 (SR-6J)
                                              77 W. Jackson Blvd.
                                              Chicago, IL 60604-3590

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