ILLINOIS POLLUTION CONTROL BOARD

April

 12, 1973

CITY OF MENDOTA,

Petitioner,

vs.

)

 PCB 72—486

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Edward

 H. Baker, Attorney for Petitioner

Steven C. Bonaguidi, Assistant Attorney General

 for the EPA

OPINION AND ORDER OF THE BOARD

 (by Mr. Henss)

The City of Mendota requests a variance from Section 9(c)

of the Environmental Protection Act,

 Rules 3.05 and 5.12(d)

of

the Rules and Regulations for Refuse Disposal Sites and Facilities,

and Sections 502(a)

and

(b)

 of the Pollution Control Board Regu-

lations Chapter

 2, Part V.

 The variance is requested for the

purpose of burning trees,

 sticks,

 limbs and other wood located

at an old dump site about one mile south of town.

 The Environ-

mental Protection Agency has recommended that the variance be

denied and that the City dispose of the material by using an

air curtain destructor

 or by burying the material at the landfill

site.

The Mayor, Street Superintendent and one of the aldermen

testified in favor of the variance petition.

 They stated that

most of the limbs,

 tree trunks and wood material

 caine from trees

in the City which had been damaged

 storm or had been killed

by the Dutch Elm Disease.

 They estimated that there were

50

or

 60 cubic yards of material to be burned.

 About

 6 or

 8 of

the stumps were so

 large and heavy that they could not be removed

from the site by the use of any City equipment.

 The tree removal

firm which had taken these large sturnDs to the site originally

is no longer in business.

They testified that the cost of an air curtain destructor

is prohibitive since Mendota is ope:~atingat

 a deficit and had

just borrowed $40,000 from local baxi~sto pay other City obli-

gations.

 The price of an air curtain dcstructor ranges from

$4300

 to $7700 and Petitioner status

 thai: i~tallationof concrete

pit and electricity would bring the total cost to around $12,000

$13,000.

 We suggest, however, that the concrete and electricity

might not be necessary for Petitioner’s purpose.

537

—2—

The City no longer uses this particular dump site but

hauls its garbage and debris

 to Peru about 18 or

 •20 miles

away.

 The City officials stated that some of the stumps

were too huge

 to be hauled to Peru;

 that the City did not have

the equipment for such

 a haul, and that the cost of that type

of an operation would be prohibitive.

They also testified that the trees,

 stumps, and limbs

could not be buried at the dump site since this old dump

had been used for some

 50 years and was full of debris of all

types which would interfere with the digging operation,

 i.e.

junked cars,

 metal appliances, wire,

 rock and concrete.

The City officials further stated that there was no material

on the site which was adequate for covering the logs and tree

stumps.

 There was no testimony regarding the availability and

cost of obtaining such cover material.

The City does not have

 a chipper but there has been some

discussion regarding the possible purchase of

 a chipper.

An EPA supervisor with the Land Pollution Control estimated

that the wood material consisted of some

 30 cubic yards.

He

agreed that it was not feasible for the City with its present

equipment to haul this material to the Peru landfill.

 However,

this sunervisor testified that based upon his knowledge of

dump and landfill areas it would be possible to excavate into

the landfill where the logs and stumps were located.

The City officials testified that there would be a recurring

need for burning in this area because storms would continue to

damage trees.

 They further testified that the stumps

in

particular did not burn well since they were so big and since

parts

 of the stumps were covered with dirt.

 The City plan is

to start the

fires

with fuel oil and let them smoulder.

 When

the fires go out they will be started again with fuel oil and

eventually after several weeks it is contemplated that the

stumps and logs will be completely burned.

 This dump is

situated in

 a farm area.

 The prevailing winds are from the

west, and the closest houses are located about one mile to the

east.

 City officials stated that burning would take place only

when the wind was coming from

the

right direction so th~smoke

would not blow into town.

We agree that the costs of removing this material to the

Peru landfill or of purchasing and installing

 an air curtain

destructor are prohibitive for the City of Mendota.

 The record

is inadecuate for us to determine whether the stumps could be

buried at the site where they are now located.

 Witnesses for the

Petitioner stated that excavation was not possible.

 The witness

—

538

—3—

for the Respondent stated that excavation was possible.

No

tests of the dump area had been made by either party and

there was no reference whatsoever

 to the possibility of

bringing cover material from another location.

Ordinarily we would not be overly concerned about a

one-time burning of

 30 cubic yards or

 50 or

 60 cubic yards

of accumulated wood since

 that is not the most offensive type

of open burning.

 However, inthis particular case we note

that, in burning the large stumps,

 fuel oil is

 a necessary

ingredient and that the fire will be

 a smouldering and long-

lasting fire which may continue through various wind shifts

and under various atmospheric conditions.

 We recognize that

it is more troublesome

 to dispose of huge stumps but at the

same time the emissions froin the burning of such stumps are

also more troublesome.

We allow the variance to burn the branches,

 logs, brush

and wood which can be consumed in one burning but deny

permission to burn the large stumps.

 We feel that the

Petitioner should further investigate the possibility of

disposing of the large stumps at the site where they are now

located by burying them or by reducing them in size with

power tools so that they may be burned in the same manner as

the smaller branches.

 Long smouldering fires

 should be avoided.

The burning should take place only when atmospheric conditions

will readily dissipate the contaminants.

ORDER

It is ordered that:

The Petition for Variance is allowed for the burning

of the branches,

 logs, brush and wood but is denied

with regard to the large stumps.

 The open burning

shall take place only under atmospheric conditions

which will readily dissipate the contaminants.

 Long

smouldering fires shall be avoided.

I, Christan L. Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion and Order was adopted

this

/~*‘~

 day of April,

 1973 by

 a vote of

-j

to

—

539