104(E) RESPONSE - BROWNING FERRISHein's (clothing) Illinois Bell Telephone Interstate Electric (electrical retail) J. Meyer Co. Jewel-Qsco Kalva Corp. (chocolate manufacturer) King's

8T7IIBROWNING-FERRIS INDUSTRIES

PO BOX 3151 • HOI STON. TEXAS 77253 - 713/870-7010

Robert L. GulleyAttorney

FEDERAL EXCESS

July 20, 1989

Ms. Carolyn D. BohlenSuperfund Program ManagementBranch 5HSM-12

U.S. Environmental Protection Agency230 South Dearborn StreetChicago, Illinois 60604

RE: Yeoman Creek Landfill

Dear Ms. Bohlen:

This letter responds to your CERdA Section 104 (e) Information Request(Request) received June 19, 1989 addressed to Browning-Ferris Industries ofIllinois, Inc. (BFTIL). The response to the Information Request receivedJune 15, 1989 has been submitted under separate cover.

BFTIL has responded to two previous 104 (e) Requests regarding the YeomanCreek Landfill (YCL). The first Request was dated March 24, 1987 and wasaddressed to BFI Waste Systems. The Response to that Request was submittedon May 21, 1987 on behalf of BFIIL, the appropriate legal entity, by Ms.Marina Bouley and is attached as Exhibit 1. The second Request was datedFebruary 7, 1989 and was addressed to Waukegan Disposal. The Response tothat Request was submitted on March 13, 1989 also on behalf of theappropriate legal entity, BFTIL, and is attached as Exhibit 2.

For your information, we provide the following corporate history of BFIIL.

o Browning-Ferris Industries, Inc. acquired National DisposalContractors, Inc. and National Disposal Service, Inc., and itssubsidiary, National Disposal Service of Illinois, Inc., on8/20/71.

o On 6/30/72, Waukegan Disposal Service, Inc. merged with NationalDisposal Service of Illinois, Inc..

o National Disposal Service of Illinois, Inc. changed its' name toBrowning-Ferris Industries of Illinois, Inc. on 11/20/72.

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CORPORATE OFFICES 757 N. ELD

Carolyn BohlenPage 2July 20, 1989

o National Disposal Contractors, Inc. and National DisposalService, Inc. merged into Browning-Ferris Industries of Illinois,Inc. on 10/29/76 and 3/7/79 respectively.

Below you will find a recitation of each individual Information Request,followed by a detailed answer to each request.

1. Did vou ever use, purchase, generate, store, treat, dispose, transportor otherwise handle anv naterials at the Site? If your answer to thisquestion is anything but an unequivocal no, answer the followingquestions:

Response; Based on information obtained through interviews withindividuals with knowledge of waste disposal practices during therelevant time period, two predecessors-in-interest to BFIIL havehandled materials at the YCL. These entities are Waukegan DisposalService, Inc. (hereinafter Waukegan Disposal) and National DisposalService of Illinois, Inc. (hereinafter National). Waukegan Disposalwas a transporter of both residential and ocnwercial waste to the YCL.National hauled residential waste, pursuant to contractual agreementwith the City of Waukegan, and comnercial waste to the YCL, as well asoperated the YCL. Based on interviews conducted with persons withknowledge of the YCL, National is believed to have operated the YCLfrom 1959 to 1969.

a. identify the cjy*n'ir l composition,, < v*racteristics. physicalstate fe.a.. solid, liquid). and trade or chemical name of eachmaterial;

Response: BFIIL has transported solid waste material consisting ofgeneral garbage and refuse and liquid materials contained in drums,buckets and pails to the YCL. BFIIL has been unable to determine thechemical composition and characteristics of these wastes.

b. state whether anv of these materials were or contained "hazardoussubstances" as defined bv CERdA Section 101(14). 42 U.S.C.Section 9601(14);

BBB2QD6S: BFIIL has been unable to determine the chemical compositionand characteristics of the wastes hauled to the YCL. Therefore, BFIILhas no knowledge that the waste materials referenced in response l(a)contained "hazardous substances" as defined by CERCLA Section 104(14),42 U.S.C. Section 9601 (14).

c. the person who supplied vou with each such material, disposed orotherwise handled by you;

Based on interviews conducted with individuals with knowledge ofthe relevant time period, known cornnercial customers of Nationalwhose wastes probably were transported to the YCL include:


Abbott Laboratories (Abbott Park)American Hospital Supply Corp. (now Baxter Riarmaceuticals)Anchor Hocking (glass manufacturer)Goodyear Tire & Rubber (tire manufacturer)J.C. Penney (retail department store)Lakehurst (retail department store)U.S.. Steel/U.S. cyclone (manufacturer of steel products)Weibolts (retail department store)Zayre (retail department store)

In addition to the commercial customers listed above, Nationaltransported waste fron various restaurants and large apartmentbuildings in the Waukegan, Illinois area.

National also transported residential waste from the City ofWaukegan pursuant to Agreements with the City. Provided inExhibit 3 are Agreements between BFIIL entities and the City ofWaukegan. These Agreements describe procedures to be followedfor collecting and disposing of the city's residential garbageand rubbish.

National also transported residential and commercial waste fromthe City of North Chicago pursuant to Agreement. Based oninterviews conducted with individuals with knowledge of therelevant time period, waste hauled from the City of North Chicagowas taken to the YCL for disposal. Contained within Exhibit 4are the Agreements between BFIIL entities and the City of NorthChicago describing procedures to be followed for collecting anddisposing of the City's residential and commercial garbage. Alsoenclosed with Exhibit 4 are letters extending the terms of theAgreements.

Based on interviews conducted with individuals with knowledge ofthe relevant time period, known commercial customers of WaukeganDisposal whose wastes probably were transported to the YCLinclude:

Ace HardwareBelvidere Mall (approximately 30 stores)Boren's Having (storage warehouse)J. Blumberg FurnitureBlumberg ApplianceBuehler's FoodBurkhart's Bottle Shop (liquor store)Cadallac Packaging (paper packaging company)Caples fhotoCarriage HouseChandler's Office SupplyChuck nine's (men's clothing)Chuck Wagon (restaurant)Commercial Printers


Commonwealth Edison CompanyConvenient Food MartMidland DexterDOB'S LiquorsDominicksEagle FoodE.C.I. (Electronic Components, Inc.)Feinberg's Men's WearFeldco-MajorGlobe Store (retail store)Glen Pock BeverageGold Standard LiquorsGordons AutoGrand LiquorsHaese's FoodHandicap (molding company)Harmony Haven (musical appliance retail)Hein's (clothing)Illinois Bell TelephoneInterstate Electric (electrical retail)J. Meyer Co.Jewel-Qsco

Kalva Corp. (chocolate manufacturer)King's Furniturelake County Moverslake County PressLake County Office Supplylake Shore Harley DavidsonLanathon's (retail clothing)Larson & Peterson Paint StoreLeath FurnitureLittle Food StoreLittle Fort RestaurantMontgomery WardMordhorst Transfer & StorageMusiclandNarrod MoversNational Biscuit (warehouse)National Tea (supermarket)Northern Illinois WarehouseOpen IfentryPfanstiehl (chemical packaging plant)Pic-Way ShoesPlayback, Inc.Polk Bros.Potter PharmacyQuality BooksR&S LiquorsChas. J. Sach'sSample Furniture

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Schif f ShoesScott's BicycleSears, RoebuckStone ContainerSt. Theresa Hospital7-11- Food StoreChicago Sun-TimesTaylor FurnitureTed's Food MartTee-Pee LiquorsTom's LuggageU.S. Envelope (West Vaoco)V.R. Wesson/Fan SteelWalgreensWaukegan Bldg.White Hen PantryWoolworths

Waukegan Disposal also transported residential waste to the YCL.

d. how such Mforifllff were used, purchased, generated, stored,treated, transported. j T sed of or otherwise handled by you;

Response: Based upon interviews with individuals with knowledge as tothe type of containers materials were contained in when they werehauled, most commercial waste materials were contained in one yardcontainers during the late 1950's and early 1960's. Larger two tofour yard containers were used in the late 1960's. 55-gallon drums,barrels and 5-gallon pails and buckets were also used to containmaterials. Residential waste was contained in 30-gallon metalcontainers. All materials transported were hauled in 13 and 17 yardgarbage trucks. The method of disposal used at the YCL was openlandfilling.

e. when such materials were used, purchased, generated, stored,transport**?, <U?T?g?fl 9f or otherwise handled by you;

BFIIL has been unable to determine specific dates whenmaterials were transported by Waukegan Disposal and National to theYCL. However, based en interviews conducted with persons withknowledge of the YCL era, Waukegan Disposal and National hauled wasteto the YCL during much of its operative lifetime. BFIIL believes thatNational operated the YCL fron 1959 to 1969.

f. where such materials were used, purchagaari, generated, stored,treated, transported, <jj?pnged of or otherwise handled by you;

Response: Based upon our investigation conducted to date, suchmaterials mentioned in Response l(a) were transported from customerswithin the City of Waukegan and North Chicago, Illinois to the YCL.


g. the guant-jtv of such itaterials used, purchag** generated. stored.treated, transported ^isnsed of or otherwise handled by ou.

Response: Based on an interview with Mr. Marvin Powles, currentDistrict Manager with BFIIL's Waukegan District and formerly withNational , in the late 1960 ' s Marvin estimated that Nationaltransported to the YCL two 13-cubic yard truck loads per day from eachresidential route in Waukegan and North Chicago, Illinois. Heestimated there were six residential routes. He added that two17-cubic yard loads per day, from one commercial route was hauled tothe YCL. Based on an interview with Mr. Ole Kirkegaard, current SalesManager with BFIIL's Waukegan District and formerly with WaukeganDisposal, Mr. Kirkegaard estimated that Waukegan Disposal transportedapproximately 4 commercial loads and 2 residential loads on a dailybasis to the YCL in the early 1960's. In the late 1960's, early1970 ' s, Mr. Kirkegaard estimated that 12 commercial loads and 16residential loads were hauled to the YCL by Waukegan Disposal.

2. Describe the nature of the manufacturing and maintenance processes atyour operationfsl from 1959 to 1969. including:

Response: HFTIL assumes this request is directed towards generatorsof waste, and therefore, is not applicable to BFTIL. Moreover, BFIILhas no information responsive to this request.

a . a description of all materials purchaspd for use in youroperation f s ) inc J **3 ng the chemical identity and chemicalcomposition of all identified and the supplier;

Response: Not applicable.

b. a description of all manufacturing processes that generated anyor wastes;

applicable.

c. a description of all maintenance operation (si that generated anv; and

s: Not applicable.

d. a description of all products, by-products, and wastes generated.

Response; Not applicable.

3. Have vou or anv other person ever accepted materials fortransportation to the Site from anv person or transported materials tothe Site? If the answer to t*?1? question is anything but anunequivocal no. identify:

Response: Waukegan Disposal and National, twopredecessors-in-interest to BFIIL, have accepted materials for

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transportation to the YCL site. Regarding other persons acceptingmaterials, set forth in the response to Request 3(a) is a list ofcompanies for whom they transported materials to the YCL site. Allinformation below was obtained from interviews conducted withindividuals with knowledge of the YCL era.

a. the persons from whom you or such other persons acceptedmaterials for transport!

Response: Jensen Disposal ServiceT-K City Disposal Corp.Century Scavenger ServiceCity of WaukeganNorth Shore Waste Control CompanyAbbott LaboratoriesA&A Disposal ServicesSisson DisposalNorth Chicago DisposalLibertyville Disposal

b. every date on which materials were so accepted or transported;

Response: BFIIL has been unable to determine specific dates on whichmaterials were accepted or transported to the YCL by the entitieslisted in the response to Request 3(a).

c^ for each transaction or shipment, the nature of the materialsincluding the chemical content, characteristics, physical^ state(e.g., solid, liquid), the process for which the substance wasused or the process which generated the substance or whether thematerials came from a construction project;

Response: BFIIL has been unable to determine specific transactiondates on which materials were transported to the YCL. However, basedon interviews conducted with individuals with knowledge of the YCL erathe sources from which solid and liquid waste was hauled by Nationaland Waukegan Disposal and the available information regarding thenature of such waste is given below.

Known commercial customers of National whose wastes were probablytransported to the YCL include:

o Abbott Laboratories (Abbott Park) - dock service to the cafeteriaand laboratory buildings. The waste hauled consisted primarilyof empty shipping crates, corrugated boxes and garbage. Some ofthe waste was picked up in dock containers, however most wasloose material from the cafeteria and laboratory buildings.Marvin Powles specifically recalls one occassion in which whilepicking up waste from the laboratory, a live laboratory monkeywas noticed within one of the shipping crates and wassubsequently captured by AL employees and returned to thelaboratory.

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o American Hospital Supply Corp. (now Baxter Pharmaceuticals) -garbage only.

o Anchor Hocking - glass bottles that didn't meet specifications onpallets and general rubbish.

o Goodyear Tire & Rubber - primarily rejected rubber products,uncured rubber and general garbage.

o J.C. Penney - garbage only.

o Lakehurst Retail Stores - garbage only.

o U.S. Steel/U.S. Cyclone - attached as Exhibit 5 are PurchaseOrders with General Conditions attached from the U.S. SteelCorporation to National Disposal Service of Illinois for variousperiods during the 1960 *s. Individuals with knowledge ofNational's disposal practices during the periods covered by theP.O. 's, stated that U.S. Steel was hauled to the YCL. The natureand quantity of the materials hauled is not known.

o Weibolts Retail Store - garbage only.

o Zayre - garbage only.

National also transported residential waste to the YCL.

Known commercial customers of Waukegan Disposal whose wastes wereprobably transported to the YCL include:

Garbage Only

Ace HardwareBelvidere Mall (approximately 30 stores)Boren's Moving (storage warehouse)J. Blumberg FurnitureBlumberg ApplianceBuehler's FoodBurkhart's Bottle Shop (liquor store)Cadallac Packaging (paper packaging company)Caples PhotoCarriage HouseChandler's Office SupplyChuck Hine's (men's clothing)Chuck Wagon (restaurant)Commercial PrintersCommonwealth Edison CompanyConvenient Food MartDon's LiquorsDominicksEagle Food

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E.C.I. (Electronic Components, Inc.)Feinberg's Men's WearFeldco-MajorGlobe Store (retail store)Glen Rock BeverageGold Standard LiquorsGordons AutoGrand LiquorsHaese's FoodHandi-Tap (molding ccnpany)Harmony Haven (musical appliance retail)Hein's (clothing)Illinois Bell TelephoneInterstate Electric (electrical retail)J. Meyer CO.Jew2l-OscoK-MartKalva Corp. (chocolate nanufacturer)King's FurnitureLake County MoversLake County Presslake County Office SupplyLake Shore Harley Davidsonlanathon's (retail clothing)Leath FurnitureLittle Food StoreLittle Fort RestaurantMordhorst Transfer & StorageMosiclandNarrod MoversNational Biscuit (warehouse)National Tea (supermarket)Northern Illinois WarehouseOpen PantryPfanstiehl (chemical packaging plant)Pic-Way ShoesPlayback, Inc.Polk Bros.Potter PharmacyQuality BooksR&S LiquorsChas. J. Sach'sSample FurnitureSchif f ShoesScott's Bicycle7-11 Food StoreChicago Sun-TimesTaylor RornitureTed's Food MartTee-Pee LiquorsTom's luggage

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WalgreensWaukegan Bldg.Waukegan Jack DonelsonWaukegan MarineWaukegan Music MartWhite Hen PantryWoolworths

Garbage and Other Waste Materials

Larsen & Petersen Paint Store - paint in cans.

Midland Dexter - The exact nature of the waste materials hauled,quantity and time frame Midland Dexter's waste was hauled to theYCL is not known. However, Mr. Kirkegaard recalled hauling55-gallon drums filled and sometimes half-filled with paint andsolvents. He estimated the drums were hauled at a rate ofapproximately 20-30 per day to the YCL daring the early 1960*s.

Montgomery Ward - paint in cans.Sears, Roebuck - paint in cans.St. Theresa Hospital - ash.

Stone Container - five gallon pails 1/2 to 3/4 full of unknownmaterial hauled on a daily basis.

U.S. Envelope (West Vacco) - paper, glue and ink in bucketshauled on a daily basis.

V.R. Wesson/Fan Steel - metal dust, shavings and wood.

Waukegan News Sun - waste ink.

Waukegan Disposal also transported residential waste to the YCL.

Information responsive to Request 3(c) regarding the entities listedin the response to Request 3 (a) is listed below. This information isbaaed upon interviews conducted with persons with knowledge of the YCLera.

Jensen Disposal Service - This company is owned by Mr. John Obenaufand was remembered by the individuals interviewed as havingtransported waste to the YCL. The nature, quantity and source of thematerial is unknown to BFIIL.

T-K City Disposal Corp. - T-K was owned by Henry Tewes andPeter Kirkegaard. Kirkegaard was the owner of Waukegan Disposal priorto merging with EFT. BFIIL believes T-K operated the YCL from early1969 until the site reached its capacity and closed. T-K is alsobelieved to have transported waste to the YCL. The nature, quantity


and source of the material is unknown to HETIL. T-K is believed tohave been consolidated into Waste Management Inc.

Century Scavenger Service (CSS} - CSS was remembered by theindividuals interviewed as having hauled waste for Outboard MarineCorporation during the YCL era. Marvin Pswles recalled that CSS wasbased in Kenosha and occasionally, perhaps once per week, he would seea CSS truck at the YCL. Marvin stated that CSS's waste seemed oily.

City of Waukeoan - Based on interviews conducted with individuals withknowledge during the YCL era, BFTIL believes the City of Waukeganhauled waste from their street sweeping operations to the YCL. Thequantity and nature of this waste is unknown to BFTIL.

North Shore Waste Control Company (NSWC1 - Based upon ourinvestigation to date, NSWC acquired T-K City Disposal Corp. sometimearound 1974. The nature and quantity of waste hauled by NSWC to theYCL is unknown to BFIIL.

Abbott Tahmpai-ories fALl - AL is believed to have hauled their owngarbage during the YCL era. See the Response to Requests l(c) and3(c) for additional infomation.

A&A Disposal Services - Based upon our investigation to date, A&ADisposal Services was owned by a man named Larson and A&A became NorthShore Waste Control Company. At the time, Mr. Larson owned A&A, theirwaste is believed to have been transported to the Zion landfill inZion, Illinois.

Sisson Disposal fSDl - Bnnnrl on interviews conducted with individualswith knowledge during the YCL era SD, owned by Mr. John Sisson, was aone truck operation who hauled residential and commercial waste to theYCL. BFIIL has no knowledge as to the nature and quantity of wastehauled on the time frame the wastes were transported to the YCL.

North Chicago Disposal ____QfCP) ~ Based on interviews conducted withindividuals with knowledge during the YCL era, NCD hauled waste intothe YCL. NCD was operated by two men whose biggest contract wasbelieved to be the Navy Center in North Chicago, Illinois. BFIIL hasno knowledge as to the nature and quantity of waste hauled or the timeframe the wastes were transported to the YCL.

Disposal nn\ — Based upon interviews conducted withindividuals with knowledge during the YCL era, LD hauled a commercialroute into the YCL. BFIIL has no knowledge as to the nature andquantity of waste hauled or the time frame the wastes were transportedto the YCL.

d. the owner of the gflfrfrjflls so accepted or transported;

Response: See the response to Request 3 (c) .


e. the giiap-t-ity of the materials involved (weight or volume) in eachtransaction or shipment and the total quantity for alltransactions or shipments;

Response: See the response to Request l(g).

f. all tests or analysis and analytical results concerning each ofthe materials;

Response: BFTIL has been unable to locate documents regardinganalysis of the materials described in the responses above.

a. the precise locations to which each material actually wastransported;

Response: The materials described in the responses above are believedto have been transported to the YCL. Precise location is not known byBFTIL.

h. the personfsl who selected the Site as the place to whichmaterials were to be transported;

Response: Exhibits 3 and 4 contain Agreements between BFTIL entities,the City of Waukegan, and the City of North Chicago which pertain toresidential and commercial garbage collection and disposal. TheAgreements with the City of Waukegan state that all garbage shall bedisposed of by the sanitary landfill method at the present site in theCity of Waukegan. The City of North Chicago Agreements state allgarbage should be disposed of outside of the city limits of the Cityof North Chicago.

BFTIL has no information regarding who selected the YCL for commercialtransactions.

i. the amount paid in connection with each transaction or shipment,the method of payment, and the identity of the person from whompayment was received;

BFTIL has been unable to locate any document that canassist in identifying the amount paid in connection with eachtransaction, the method of payment or the identity of the person fromwhom payment was received. However, Exhibits 3 and 4 do referenceamounts associated with disposal services.

i. where the person identified in i. above, intended to have suchmaterials transported and all evidence of this intent;

Response: See the response to Request 3(i).

-510


k. whether the materials involved in each transaction or shionentwere transshipped through . or were stored or held at . anvintermediate Site prior to final treatment or disposal;

Response: BFTIL has been unable to locate any information that isresponsive to this Request.

1. what was done to the materials once they were brought to theSite;

Response: Materials brought to the YCL by BFIIL were dumped from thetruck, oorrpacted by suitable heavy equipment, and covered daily withearth.

m. the firy^ disposition of each of the materials involved in suchtransactions or shipments?

Response: See the response to Request 1(1) .

n. the measures taken by vou to determine the actual methods, means.and Site of treatment or disposal of the material involved Ineach transaction or

Response: During the period in which National operated the YCL,National was bound by the language of the contractural agreements withthe City of Waukegan. Agreements within Exhibits 3 and 4 describe themeasures taken by BFIIL to ensure and determine that proper disposalmethods were used.

o. the type and number of containers in which the material werecontained when they ware accepted for transport, and subsequentlyuntil they *j?r? "fcpTJJWl at the Site and all markings on suchcontainers; and

Based upon interviews with individuals with knowledge as tothe type of containers materials were contained in when they werehandled, most commercial waste materials during the relevant timeperiod were contained in primarily one yard containers during the late1950 's and early 1960 's. larger two to four yard containers were usedin the late 1960's. 55-gallon drums, barrels and 5-gallon pails andbuckets were also used to contain materials. Residential waste wascontained in 30-gallon mpftal containers.

The trucks used to transport the materials were generally 13 and 17cubic yard trucks.

p. if the materials cam? fr?"* a construction or wrecking project,the location of the pro-feet, the type of project (e.g.,dismantling of a frjjldina. road building, etc.), the type ofmaterials (e.g. . brick, wood. etc.K the type of insulation


(** q , acthgstos. etc.}. the type of metal and a description ofany other material or waste.

Response: BFIIL has no information responsive to this Request.

4. Identify all persons, including yourself, who may have arranged fordisposal or treatment or arranged for transportation for disposal ortreatment of materials at or to the Site. In addition, identify:

Response: Responses to Requests 4(a) through 4(o) have been providedwithin Requests 1, 2, and 3.

a. the persons with whom you or such other persons made sucharrangements;

Response: See the preamble to Request 4.

b. every date on which such arrangements took place;


c. for each transaction, the nature of the materials jjvViiiHinq i-h*>chemical content, c rart t-istics. physical state fe.a.. solid.liquid^. and the process for which the substance was used or theprocess which generated the substance;


d. the owner of the materials so disposed or treated;


e. the quantity of the materials involved (weight or volume) in eachtransaction and the total crMnfi*"Y for all transactions;

See the preamble to Request 4.

Lysis apH analytical results concerning each of


a. the precise locations at which each material actually wasdisposed or treated;


h. the personfsl who selected the Site as the place at whichmaterials were to be disposed or treated;



i. the amount paid in connection with each transaction, the methodof payment, and the identity of the person frcm whom payment wasreceived;


i. where the person Identified in i. above, intended to have suchmaterials treated or disosed and all evidence of this intent;


k. whether the materials involved in each transaction weretransshipped through, 7T were stored or held at any intermediatesite prior f9 tinfll tT?flt?'ent: Qr


1. what was done to the materials once they were bought to the Site;


m. the f1"pl disposition of each of the materials involved in suchtransactions ;


n. the measures taken by you to determine the actual methods, means,and site of treatment ?r H gposal of the materials involved ineach transaction; and


o. the type and numfrer of containers in which the materials werecont jrefl when they ware accepted for transport, and subsequentlyuntil they were deposited at the Site and all markings on suchcontainers T

BnnnrnnQ; See the preamble to Request 4.

5. Provide copies of all contracts, shipping documents, or other businessdocuments jTyfliidlno receipts relating to the transportation, storageand/or disposal of wast materials at the above referenced Site.

Response: All documents located by BFIIL pertaining to transportationof materials possibly to the YCL are presented in Exhibits 3, 4, 5, 6,and 7. The documents within the exhibits are listed below.

Exhibit 3 - 1958 Contract Agreement between Barrington TruckingCompany, National's Barrington, Illinois operations and the Cityof Waukegan for garbage collection and landfill operations.


1959 and 1964 Contract Agreements between National DisposalService of Illinois, Inc. and the City of Waukegan for garbagecollection and landfill operations.

Exhibit 4 - Contract Agreements between Barrington TruckingCorpany, National Disposal Service of Illinois, Inc. and the Cityof North Chicago for garbage collection and disposal.

Exhibit 5 - U.S. Steel Corporation Purchase Orders for variousperiods during the YCL era.

Exhibit 6 - Indemnity Agreement dated July 31, 1964 between theBoard of Education, Waukegan Township High School and NationalDisposal Service of Illinois, Inc.

Exhibit 7 - Security Agreement dated January 31, 1969 between theCity of Waukegan and National Disposal Service, Inc.

6. Identify all liability insurance policies held by Respondent from 1959to 1969. In identifying such policies, state:

Response: See attached as Exhibit 8, a list of insurance carriersthat have isfayyl insurance policies and trtiich nay provide coverage toBFIIL.

a. the name ar*ft *fV*ress of each insurer and of the insured;

Response: See Exhibit 8.

b. the amount of coverage under each policy;


c. the cairoenccanent and expiration dates for each policy;

See Exhibit 8.

d. Khe*fr?r or not the policy contains a ''pollution exclusion"clause; and


e. whether or not the policy covers sudden, non-sudden or both typesof accidents.


Provide copies of all income t v returns sent to the Federal InternalRevenue Service in the last five years.


Response: BFTIL does not file a separate income tax return.Information on the parent's consolidated return would not break outspecific information regarding BFTIL.

8. Provide all financial statements for the past five fiscal years.including but not limited to those filed with the Federal and StateInternal Revenue Service and Securities and Exchange Commission.

Response: Exhibit 9 contains Browning-Ferris Industries, inc. 's Form10-K1 s submitted to the Securities and Exchange Commission datedSeptember 30 for each of the five preceding fiscal years.

9. Identify all of Respondent's current assets and liabilities and thepersonfsl who currently own or are responsible for such assets andliabilities.

Response: Exhibit 10 contains Browning-Ferris Industries, Inc. AnnualReports for each of the five preceding years.

10. Identify all subsidiaries and parent corporations of Respondent.

Response : BFIIL is a wholly owned subsidiary of Browning-FerrisIndustries, Inc. (Delaware).

11. Provide a OOPV of the nest current Articles of Incorporation andbv-laws of

Response; Exhibit 11 contains BFIIL 's most current Articles ofIncorporation and By-laws.

12. Identify the managers andnature of thej,r

ghain olders of Respondent and theh*»i d ,duties or amount of

13

respectively.

flggpaifre : The sole shareholder of BFIIL is Browning-FerrisIndustries, Inc. , a Delaware corporation.

If vcu have reason to believe that there mav be persons able toprovide a more defaced or complete response to any questionscontained herein or whf? may be able to provide additional responsivedocuments, identify sucfr p?rff s and the addj i""*! Information ordocuments that they may have.


14. For each and every cf.yggti contained herein, if information ordocuments responsive fr? flllff Information Request are not in vourpossession, custody or control, then identify the persons from whomsuch information or donrnventg mav be obtained.


Response: Bnsffd upon BFIIL's investigation to date, no information ordocuments responsive to this Request exists that are not in BFIIL'spossession. Should documents be discovered, subsequent to oursutniittal of this Response, such documents will be submitted to theUSEPA.

BFIIL has conducted a diligent search for all available documents andrecords in preparing its Response to this Request. In addition, BFIILinterviewed many individuals with knowledge of disposal practices duringthe relevant time period in which the YCL was operational. In the future,if additional information is discovered which supplements or modifies anyof the responses, BFIIL will voluntarily provide that information to theUnited States Environmental Protection Agency (USEPA).

Should you have any questions regarding this Response, please contact me at713/870-7010.

Sincerely,

on behalf of Browning-FerrisIndustries of Illinois, Inc.

Enclosure

Documents

104(E) RESPONSE - BROWNING FERRISHein's (clothing) Illinois Bell Telephone Interstate Electric (electrical retail) J. Meyer Co. Jewel-Qsco Kalva Corp. (chocolate manufacturer) King's