Camplin Report Holds Use of the Park’s Fishing Pier in Abeyance

Dunesland’s Health and Safety consultant and asbestos expert Jeffery Camplin produced the Camplin Report in 2003, identifying many dangerous, asbestos-contaminated areas throughout the park’s beaches and at the Johns-Manville Superfund site which is adjacent to our park’s Nature Preserve. One of the positive outcomes was the closing of the fishing pier and the parking lot adjacent to the Superfund site and the Midwest Generation power plant, located at the Greenwood Avenue street end. This area is known as Site 2 by the USEPA. Asbestos (some friable) has continually heaved out of the ground, or has been left on the surface; it had been identified by Mr. Camplin in his many inspections of the area.

Although the USEPA had stated that the site was cleaned up, it remains closed. During the claimed cleanup, Dunesland’s President Paul Kakuris visited the site and commented on the strong odor. The USEPA discovered that beneath the illegal asbestos debris, there was another landfill comprised of more contaminated materials. The USEPA covered it and left it there. The site is not really clean and remains closed. The USEPA has skewed and manipulated their testing protocols, but now seems to be backing off their claim that it is clear of asbestos and poses no health risks. Mr. Camplin discovered that the USEPA had released a statement cautioning that their own cleanup standards for asbestos did not protect the public from the potential health risks created by the presence of asbestos

On June 15, 2007, Dunesland learned that the Illinois State Legislature had passed Senate Bill 333 which allowed landowners to lease land to Illinois Department of Natural Resources (IDNR) without fearing liability for injuries to citizens who used the lands. Dunesland’s president, Paul Kakuris, immediately wrote a letter urging the legislature to reconsider and the governor to veto the bill because it favored special interest groups (large polluters) who may have contamination on their property. Absolving them of responsibility transfers that responsibility to taxpayers or individuals.

Erosion

Sand Pile on the North End Feeder Beach is Really Regulated Waste; Public Access Would Not Be Allowed Anywhere Else!

The purpose of the feeder beach sand pile at the north end of Illinois Beach State Park and the beach sand dumped offshore, both known as “beach nourishment,” is to ameliorate accelerated erosion caused to the park’s beaches by North Point Marina. Unfortunately, the sand is heavily contaminated with chunks of asbestos, asbestos fibers, and asbestos waste products. Over the years, the state has collected, transported and dumped this regulated asbestos-containing material (RACM) knowing that it contained this contamination. The original source of most of this RACM in the tainted sand is the Johns Manville Superfund site. In other words, government officials have knowingly moved this regulated or “special” waste from one contaminated site to a new site which has now become contaminated, thereby making the pile an open RACM dumpsite which then began to erode into Lake Michigan.

It's shocking and disappointing that state and federal agencies have illegally allowed a regulated material to erode into the navigable waters of the United States and the state of Illinois, maliciously allowing nature to do their dirty work. It certainly is an easy way for state and federal officials to "dispose" of a problem they created! It should have been appropriately disposed of as RACM years ago and put into a proper, hazardous waste landfill after it was dredged. Using it for beach “nourishment” to ameliorate the effects of erosion by North Point Marina was a preposterous idea from the beginning. Former Illinois Environmental Protection Agency warned IDNR against the idea as early as 1998. IDNR’s director and staff ignored the advice and proceeded, knowingly dumping asbestos-contaminated, dredged sand. Mary Gade is now the Region V USEPA Administrator.

The U.S. Army Corps of Engineers is also involved because they dredged the Waukegan Harbor approach channel which is contaminated with asbestos, PCB’s, and other chemicals; they dumped the dredgings just offshore of the park’s beach area. State and federal officials continue to cover-up and deny their wrong-doing. Anyone who knowingly dumps asbestos-contaminated material is violating state and federal criminal statutes. The public officials in charge (regulators) have diligently tried to cover up the fact that they were responsible for dumping a pollution control/industrial waste on the park's beaches.

Some material that was dumped on the beach was trucked from the Commonwealth Edison/Midwest Generation power plant dredgings to the sand pile at the park’s beaches. The power plant annually dredges offshore because they also need to remove sand that has accumulated offshore of their intake and discharge channels. The plant is adjacent to the Johns Manville Asbestos Superfund site which appears to be the main source of asbestos fibers and asbestos chunks. These chunks are fractured, weathered, and abraded manufactured asbestos-containing waste products. Some of the asbestos is friable and when picked up on the beach, easily releases the asbestos fibers when touched on the friable edges. Children often pick up chunks, thinking they are rocks.

It's a shame that public officials allowed the contaminated sand pile and part of the north section of the park's famous Nature Preserve and Federal Critical Habitat (valuable, virgin topland) to erode into Lake Michigan. Dunesland has sent letters of complaint for at least seven years about the sand pile. Finally, in the spring of 2007, the sand was trucked to a regulated landfill, filling hundreds of trucks over several weeks. However, by the state’s own admission, 99% of it had already eroded into the lake and washed onto the Camp Logan beach two blocks south during the years we have protested. That contamination had nowhere to go but to wash up on the North Shore beaches enroute to Chicago as the currents move southward. Since that time, a 2006/2007 secret draft report found that the above-mentioned Camp Logan beach sand had high readings of amphibole asbestos, the most virulent type.

When Dunesland obtained a federal court order for Jeffery C. Camplin, Dunesland’s asbestos health and safety expert, to check the sandpile for asbestos before it was moved, he found friable chunks of asbestos lying in the open. After the trucks had finished the removal process several weeks later, he still found asbestos chunks lying on the beach. And we all know, that where there is visible asbestos in the open, there must be microscopic asbestos. Children are playing in those areas! Wake up, regulators!

Related erosion further south has already undermined and/or obliterated plants from at least two endangered or threatened species and their habitats, which is an apparent violation of the Endangered Species Act and the Nature Preserve Act. The area is also a Federal Critical Habitat. We hold the public officials who are charged with protecting these plants responsible for these apparent “takings” since they ignored many of Dunesland’s complaints. One of their responsibilities is to enforce these laws; not enforcing and ignoring complaints about takings should be cause for prosecution against those individuals. The Illinois Attorney General should investigate these apparent takings and enforce the laws she is charged to uphold.

IAG Lisa Madigan has often vigorously prosecuted citizens or smaller companies with small-time asbestos violations which are much less significant than these egregious violations. Will the IAG prosecute the public officials responsible for dumping the tainted sand at the park and put them in jail? These willful, flagrant violations have continued for years, despite Dunesland’s protests and complaints.

It is our understanding that in Fall 2006 and Winter 2007, the Army Corps started dumping the dredged material off the shores of Lake Bluff and Lake Forest because state and federal officials were tired of receiving formal complaints from Dunesland and were afraid of investigations for criminal prosecution for contaminating the Illinois shoreline. They evidently thought they were out of Dunesland’s sight a little further south.

If this were anywhere else, the contaminated areas would be covered, fenced off with proper signage, properly disposed of, and the violated statutes enforced. In Illinois, the government enforcers apparently have also become polluters. All the park's beaches should be immediately sealed off from park employees and the public to reduce the potential for asbestos exposure.

Beaches along the Illinois shoreline need to be further tested to determine their safety. Highland Park and Chicago’s Oak Street beaches were tested by the IAG’s Asbestos Task Force and found to be contaminated. The consultant for the Chicago Park District is also the consultant for Johns Manville; to Dunesland, that seems to us to be a severe conflict of interest. The Illinois Attorney General must protect the public as she is charged to do, not the illegal acts committed by her state agency clients.

Erosion

Sand Pile on the North End Feeder Beach is Really Regulated Waste; Public Access Would Not Be Allowed Anywhere Else!

Aerial View of Contaminated Feeder Beach Eroding into Lake Michigan North Point Marina causes severe wave action and erosion.

The U.S. Army Corps of Engineers is also involved because they dredged the Waukegan Harbor approach channel which is contaminated with asbestos, PCB’s, and other chemicals; they dumped the dredgings just offshore of the park’s beach area. State and federal officials continue to cover-up and deny their wrong-doing. Anyone who knowingly dumps asbestos-contaminated material is violating state and federal criminal statutes. The public officials in charge (regulators) have diligently tried to cover up the fact that they were responsible for dumping a pollution control/industrial waste on the park's beaches.

Some material that was dumped on the beach was trucked from the Commonwealth Edison/Midwest Generation power plant dredgings to the sand pile at the park’s beaches. The power plant annually dredges offshore because they also need to remove sand that has accumulated offshore of their intake and discharge channels. The plant is adjacent to the Johns Manville Asbestos Superfund site which appears to be the main source of asbestos fibers and asbestos chunks. These chunks are fractured, weathered, and abraded manufactured asbestos-containing waste products. Some of the asbestos is friable and when picked up on the beach, easily releases the asbestos fibers when touched on the friable edges. Children often pick up chunks, thinking they are rocks.

It's a shame that public officials allowed the contaminated sand pile and part of the north section of the park's famous Nature Preserve and Federal Critical Habitat (valuable, virgin topland) to erode into Lake Michigan. Dunesland has sent letters of complaint for at least seven years about the sand pile. Finally, in the spring of 2007, the sand was trucked to a regulated landfill, filling hundreds of trucks over several weeks. However, by the state’s own admission, 99% of it had already eroded into the lake and washed onto the Camp Logan beach two blocks south during the years we have protested. That contamination had nowhere to go but to wash up on the North Shore beaches enroute to Chicago as the currents move southward. Since that time, a 2006/2007 secret draft report found that the above-mentioned Camp Logan beach sand had high readings of amphibole asbestos, the most virulent type.

When Dunesland obtained a federal court order for Jeffery C. Camplin, Dunesland’s asbestos health and safety expert, to check the sandpile for asbestos before it was moved, he found friable chunks of asbestos lying in the open. After the trucks had finished the removal process several weeks later, he still found asbestos chunks lying on the beach. And we all know, that where there is visible asbestos in the open, there must be microscopic asbestos. Children are playing in those areas! Wake up, regulators!

Related erosion further south has already undermined and/or obliterated plants from at least two endangered or threatened species and their habitats, which is an apparent violation of the Endangered Species Act and the Nature Preserve Act. The area is also a Federal Critical Habitat. We hold the public officials who are charged with protecting these plants responsible for these apparent “takings” since they ignored many of Dunesland’s complaints. One of their responsibilities is to enforce these laws; not enforcing and ignoring complaints about takings should be cause for prosecution against those individuals. The Illinois Attorney General should investigate these apparent takings and enforce the laws she is charged to uphold.

IAG Lisa Madigan has often vigorously prosecuted citizens or smaller companies with small-time asbestos violations which are much less significant than these egregious violations. Will the IAG prosecute the public officials responsible for dumping the tainted sand at the park and put them in jail? These willful, flagrant violations have continued for years, despite Dunesland’s protests and complaints.

Aerial View from Nature Preserve Looking South toward Manville Lagoons and Commonwealth Edison/Midwest Generation Plant. Note the ditch that runs along the other side of the Nature Preserve’s fence toward the lake. It overflows into the preserve.

DNR knowingly allows demolition debris and asbestos materials to enter the Federal and State Navigable waters of Lake Michigan. Visible pieces of asbestos debris were noted in the eroded banks of this unrestricted public access area.

October, 2004 99% of Contaminated Sand (RACM) Erodes into Lake Michigan before 2007 “Removal”

It is our understanding that in Fall 2006 and Winter 2007, the Army Corps started dumping the dredged material off the shores of Lake Bluff and Lake Forest because state and federal officials were tired of receiving formal complaints from Dunesland and were afraid of investigations for criminal prosecution for contaminating the Illinois shoreline. They evidently thought they were out of Dunesland’s sight a little further south.

If this were anywhere else, the contaminated areas would be covered, fenced off with proper signage, properly disposed of, and the violated statutes enforced. In Illinois, the government enforcers apparently have also become polluters. All the park's beaches should be immediately sealed off from park employees and the public to reduce the potential for asbestos exposure.

Beaches along the Illinois shoreline need to be further tested to determine their safety. Highland Park and Chicago’s Oak Street beaches were tested by the IAG’s Asbestos Task Force and found to be contaminated. The consultant for the Chicago Park District is also the consultant for Johns Manville; to Dunesland, that seems to us to be a severe conflict of interest. The Illinois Attorney General must protect the public as she is charged to do, not the illegal acts committed by her state agency clients.

Budget Cuts

The Crown Jewel of the Park System is Being Tarnished by Incompetence and Neglect by State

Environmental Program Eliminated for Thousands of Students

• The park’s relatively new nature center is now shuttered.
• Important maintenance is being deferred.
• The park’s infrastructure is collapsing.
• Capital improvements have been eliminated or deferred.
• Staff has been drastically reduced and the park is operating at a skeletal level.
• Services to the community and education have been grossly curtailed.
• Imperative environmental studies have been severely limited.
• Two staff interpreters were removed so now there are none.
• Portions of the park and/or services have to be shut down if a staff member doesn’t come to work.
• Endangered species are threatened by poachers.
• Native American archaeological sites have been abused or desecrated.
• The park’s nature preserve is subject to careless pollution by public officials.
• Massive ecological burns have been illegally conducted by staff, knowing the areas contained asbestos demolition debris so staff could secretly cover-up the evidence of their careless disposal in the nature preserve and at Camp Logan.
• Does the Governor care what is happening? We have received no response to our protests over budget cutbacks.

This crown jewel has been abused, neglected, and kicked by the incompetence and lack of respect for the environment by upper management of IDNR. The shuttered Nature Center which serves the school districts of Lake and northern Cook County no longer offers its educational program. The two naturalists who ran the educational program at the park have left and their positions have not been filled by the state. This was a valuable part of the science curriculum of many school districts which bused their students to the interpretive center for classes. These gutted programs impact the education of minority students far more than students from many well-funded school districts.

Apparently, the state considered it more important to spend $31.5 million in state funds to open the World Shooting and Recreational Complex, a skeet shooting range, in Sparta than to keep the environmental education program that serves two counties operating. A great facility to boost tourism in southern Illinois should not wipe out educational programs and staffing budgets in other parts of the state. Our government seems to have very misplaced priorities.

Bob Grosso, former park superintendent, attempted to do the work of the approximately ten employees who were cut from the staff, leaving him without a fiscal assistant and secretarial help. The lack of maintenance workers and assistant managers has cut the park services to the point that we are concerned that health and safety at the park has become an issue. Current site superintendent Greg Behm is facing almost the same situation several years later.

Illinois Dunesland Preservation Society - Critial Issues

Camplin Report Holds Use of the Park’s Fishing Pier in Abeyance

Erosion

Erosion

Budget Cuts

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