ILLINOIS POLLUTION CONTROL BOARD

October 24, 1985

IN

TEE

MATTER OF:

)

)

PETITION OF GIFFORD—HILL

)

AMERICAN LOCK JOINT

INC.

FOR

)

R84-45

SITE SPECIFIC RELIEF

FROM

)

35 ILL. ADM. CODE 807.305

)

PROPOSED RULE.

FIRST NOTICE.

PROPOSED OPINION

AND

ORDER OF

TEE

BOARD (by J. Anderson):

This matter comes before the Board on the December 20, 1984

petition of Gifford—Bill American Lock Joint,

Inc.

(GSA)

for site

specific relief from the daily, intermediate, and final cover

requirements of 35 Ill. Adm. Code 807.305 (a,b,c)

for its

disposal of concrete wastes at its South Beloit, Winnebago

County, reinforced concrete pipe manufacturing facility.

Hearing

was held on April 23, 1985, at which

GSA

presented testimony

and

exhibits, as well as an amendment to its request.

No members of

the public have participated in or made comments concerning this

proceeding.

The Illinois Environmental Protection

Act

(Agency)

filed comments in support of GSA’s request on July 5 and

August

13, 1985; GSA’s final contents were tiled August 20, 1985.

In

letters of June 13 and July 2, 1985, the Department of Energy and

Natural Resources made its determination that an Economic Impact

Study concerning this proposal was unnecessary on the basis that:

The net economic impact of the regulation is

favorable

and

the costs of compliance are small or

are borne entirely by the proponent of the

regulation.

Consequently, no economic hearings have been held.

GSA operates a plant involved in the manufacture of

reinforced concrete pipe.

This facility, located in Northern

Winnebago County, Illinois, spans 93 acres.

The facility employs

approximately 150 people.

In the course of a day, GSA uses approximately 120 tons of

sand, 90 tons of stone, and 45 tons of cement.

These materials

are mixed together with water to make concrete, which is then

placed in steel molds and cured.

After curing, the molds are

removed leaving a concrete pipe which is then used for water and

wastewater transmission.

Upon completion of a day’s production, there remains a

quantity of concrete to be disposed of.

Daily amounts will vary

from 2 to 4 tons.

This is a result from spillage, breakage and

waste.

The refuse to be placed in the landfill

is concrete

66-257

---

—2-

waste, cull pipe a d an occas~onLasteel rod embedded in the

concrete.

The material

is ron—putrescible and non—biodegradable.

The cover requirements of 35 Ill. Adm. Code 807.305 can be

briefly summarized as follois:

daily

—

6 inches, intermediate

—

12 inches,

final

—

2 feet.

Pursuar

to variances granted to GSA

and

its predecessor Interpace Corporation (see PCS 75—495, June

6, 1976;

PCB

77—274,

Dectwb

r

‘0

19

1,

PCS 79—206, December 13,

1979; and PCB 83—125, December

‘

1983) cover has been placed on

this material as follows,

daily

none, uintermediateu

—

1 foot

every 6 months, f4nal

—

2 fat

‘t°end of every variance

period, or

roughl., ‘-2 years

I

Us petition for site specific

rule change

(fii

c

1

rest

rs

t

a suggestion in the PCB 83—125

variance), GSA rc

..ts the ~o

a g cover requirements:

daily

—

none;

“incermec.

—

o

crn.~pe

veek; final

—

2 feet on

final sloping facn~6

i

tie

n

lat eurfaces used for

industrial

purpo.c

GSA

pr ~ seo cetent;on of other conditions

of the variance

i

dinj In

t

0

f the disposal area to one

acre, and of the

-o

1 te

at’

htt of the adjacent improved

terrain.

The concrete

‘E.

a

so

a

a is a 25 acre track located

to the north of t

riant, cance operations began on the site in

1952, 10 acres han

seen fiL ed

The life of the remaining 15

acres of the dispc ;l a

a.~. ~

.~

~npated to be a minimum of 20

years

(R.lS, 39—40

G

•

rear s

reighoor

to the north is a

quarry operation,

to the so t

t

tar tacturing facility, to the

east a closed landfill, t

e’t the City of South Beloit.

The nearest residential

dtcl

ii $ a e directly across the road

from the plant itself, or rougt’y

re

half

mile to the south of

the landfill area.

During the pest 10

eat’

d s1osal of the waste concrete

without daily cover purs ant

‘

vtriance has neither produced a

noxious odor nor harbore

ode

ftc.

Quarterly tests of water

quality on wells on GSA’. property hsve shown no change

and

the

Winnebago

Department

of

Public

Iealth

tests

show

the

water

is

safe

to

drink

(Group

bxh.

a

•

The Agency has inspected this

facility nine times bet

.en

918-1983 and found no environmental

problems resulting fro

eac

of daily cover during any of the

inspections (Group Sxh.

11)

Tte Agency has received no

complaints regarding

ocration of the site.

GSA asserts that a

tirLcd

‘wai er’ of the daily cover

requirements results in a

oct savings on the order of $300

$1600 per week

(11 47

and

Lxh

2).

The further modification of

the intermediate cover requ~rementetould be estimated to save an

additional $44,400 per year and

ma

cover requirements an

estimated $19,356 per yeir

C’

u

~,.

10

Concerning final cove

CS

~

ests,

in essence, that six

inches of final cover c rpc

.~.

salty sand which provides

good structural ~port

Ar

~

-

on with the landfilled

material

and win

I

‘~

attn

z

a ave cover

be permitted on

---

the reclaimed flat

(top)

of the landfill area

in lieu of the

normally mandated two feet of suitable cover

(usually capable

of

supporting beneficial vegetative cover).

GHA believes that

this

sand

is preferable

to conventional cover materials because

it

deters vegetative growth.

This is desirable given GHA~s

continuing

use of the finished flat top of the landfill area for

inventory storage, heavy equipment

(see photographs, Group Exh~

12) and, possibly,

the future site of additional production

buildings.

GHA agrees that

if and when such “industrial

uses”

cease,

the site will

be restored to more of

a natural

state,

including two feet of cover capable

of supporting vegetation~

GHA also agrees

to provide two feet of cover

capable of

supporting vegetation

to provide erosion control on the final

(east) slope

of the landfill and any other

“final sloping

faces.”

The Agency supports grant of the requested relief,

noting

that the compactible

nature of

the principal waste material——

concrete rubble——limits the effects of lack of daily cover, and

indeed, may be preferable

to other cover materials.

The only

material which potentially poses

even

a

de minimus

threat

of

water pollution

is the steel reinforcing baTi~fiT~h

have the

potential to create leachate problems.

Although stating that

this

is

sri

“unlikely prospect”,

the Agency urges inclusion of a

provision

in the rule requiring petitioner

to limit inclusion of

such wastes

in the landfill.

In this context, the Agency notes

that the Industrial Materials Exchange Service,

operated by the

Illinois State Chamber

of Commerce in cooperation with the

Agency, might be able

to find

a market for some of

the wastes

landfilled.

It

is the opinion of the Board

that the site—specific

relief

requested by GHA may be granted with minimal risk

to the

environment; based upon the communications from DEWR and the

other evidence

in

the public hearing record,

the Board

finds

that

grant of the request will have no adverse economic impact on

the

people of the State

of Illinois.

The Board

is therefore adopting

for first notice

a rule

substantially similar

to that suggested by GHA and the Agency,

as

outlined

in the attached Order,

Language revisions have been

necessary to convert the looser language used

in the variances

to

comport with requirements of

the Joint Committee

on

Administrative Rules.

In this context,

the Board

notes

that it

has not included the Agency~ssuggestion that GHA be ordered

to

minimize disposal

of metal~bearingwaste “to the extent

practicable” due

to inability to frame precise guidelines or

standards

for enforcement

for what

is essentially a variance—type

hortatory injunction.

Finally,

the Board will not adopt GHA~ssuggestion

that

the

rule provide that it need not provide an additional one and one-

half feet of

final cover

to the flat reclaimed area in the event

of

sale of the site

to another industrial user who also would

prefer that the area continue without vegetative cover.

Variance

---

and/or site~specificrelief would be the more appropriate

mechanism in that case,

to allow for determination by the Board

of

the similarity of the uses to which the successor

industry

would put the property and the resulting environmental impact.

ORDER

The Board hereby directs the Clerk

to cause

first notice

publication of

the following

regulatory proposal

in the Illinois

Register:

TITLE

3:

ENVIRONMENTAL PROTECTION

SUBTITLE

G:

WASTE DISPOSAL

CHAPTER

1:

POLLUTION CONTROL BOARD

SUBCHAPTHH

i:

SOLID

WASTE

AND SPECIAL WASTE HAULING

PART

807

SOLID WASTE

SUBPART

C:

SITE SPECIFIC RULES

AND EXCEPTIONS NOT OF GENERAL

APPLICABILITY

Section 8O7~7O0 Gifford—Hill American Lock Joint,

Inc.

~osalSite

aAdm~cOde807~3O5

~sitedisosalof

~ete

waste resultin

from the manufacturin

~ions

of Gifford-Hill American Lock

30mb,

Inc

at

its South Beloit,

WinnebaoCount,

lant

~

~alac~jvitiess~llmefolloy~n

~ements:

fl

~

~~~jrantedin

~

metal

~orcin

rods

embedded

in concrete.

GHA shall

reasonable

measures

to

minimize dis osal

~tals

as

waste

throuhuse

of

rec din

~

~halllimitt~xosed,activ~urfa~of

its

~~gsal

site

toaone

acre area, and the hei~htof

the

fill

in

the

active

area

to that of

ad~jacent

~

~

week,

GHA

shall

cover

the

ex osed, ac~3ve

~ace~sdis~osalsitewithacomactedlaer

of

at least

6 inches of earthen materiaL

~

~

in

creareac~!llro!~dean

final,

faces

of

~tsdisosal

site

with

at least

two

reet

of

rina~ cover

con

~n

of c~macted

---

a t ive

cover

5)

~

da

fc

ion

dig

al

ac

iviti e

~,

~

of

its

~sedforthestorae

or which

is

to be

~edb

buildin

s,

with at least

six in~

of

~ i

~

~erial,

However, within

60 dasof

cessation of

~ius~,~HA~p!ilrovideat

least an

addi

t io ria 1

18 inc~~nalcoyerm~eriala~ecifiedin

subsection

(b)(4)

above,

IT

IS SO ORDERED,

3.

T.

Meyer

dissented.

I, Dorothy

M.

Gunn,

Clerk

of

the

Illinois

Pollution Control

Board,

hereby certify that the above Proposed Opinion and Order

was adopted on

the ~

day of

_____

,

1985,

byavoteof~-/.

Dorothy M. Gunn, Clerk

Illinois Pollubion Control Board

66~261