SIERRACLUB
FOUNDED 1892
Heart of Illinois Group
k1
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. Box 3593, Peoria, II. 61614
March 22, 2007
TO
: Illinois Pollution Control Board
Hearing Officer
100 W
. Randolph St ., Suite 11-500
Chicago, IL 60601
In the Matter of:
Proposed Amendments to Solid Waste Landfill Rules,
35 Ill. Adm. Code 810 and 811
IPCB Case : R07-08
Comments on behalf of
Heart of Illinois Group, Sierra Club
On behalf of the Heart of Illinois Group, Sierra Club, representing its 800 members in
central Illinois, I wish to comment that protection of the environment is of utmost
importance to the protection of human health and safety and for sustainable ecosystems
.
Our interest is in the essential importance of landfill regulations as part of protection of
the environment .
Non-hazardous solid waste management facilities can be a source of contamination and a
threat to water resources and public health over time
. Thorough, comprehensive, and
regular assessment and reporting of landfill leachate is in the public interest to provide a
current analysis of
an
aspect of landfill conditions and to build a data record for each
landfill site for analysis over the years of the site
.
In regard to the Proposed Amendments to Solid Waste Landfill Rules, 35 III
. Adm . Code
RECEIVEDCLERK'S
OFFICE
G ~ MAR 2 3 2007
Pollution Control
ILLINOISBoard
a
810 and 811, we wish to point out that environmental regulations should exist for the
protection of the environment and health and safety, and not primarily for the
convenience or money saving of the industries that are in the business of making profits
from these landfills .
While the proposed rule changes are stated to provide greater cost and personnel
efficiency to both the regulated community and to the Illinois EPA, we hope that the
overall concerns of the IPCB also relate to any improvements these regulation changes
make in the protection of the public health, safety, and welfare
. It is essential that
regulations for such landfills consider impacts not just for the current generation, but for
decades after these landfills may close, due to the many impacts they can have on area
water resources
. It could be hoped that these rule changes would be motivated to require
more protective engineering of MSW landfills
. Requiring multiple liners and complete
leak detection systems for MSW would be greater in the interests of protecting public
health and safety over the longevity of these landfills, and have better considerations for
the future impacts of these landfills on area water resources
. We hope that Illinois will
consider establishing a required and substantial perpetual care fund for MSW landfills, so
that the future impacts of these sites will have funding for remediation generations away
from closing
. A landfill fundamentally changes the hydrogeology of the site and the
significance of this impact must be recognized and given full consideration
.
The public right to know should be a major consideration in requiring continued detailed
reporting of leachate constituents
. Consistent and detailed data is essential to citizen
efforts to protect water resources . Permeable bedrock, sand and gravel, and alluvial units
with characteristics that suggest a potential to store or conduct groundwater and yield
potable water to wells and springs are widely distributed across Illinois, and are or will be
impacted by many of the landfills represented in this ruling
.
It needs to be emphasized and recognized that municipal waste landfills or non-hazardous
solid waste management facilities end up having a vast array of pollutants, which can
inadvertently or otherwise include toxics
. At the Peoria County local siting hearing
regarding the expansion permit application for Peoria Disposal Company Hazardous
Waste Landfill, February 21 5` though 27th,
2006, in Peoria, Illinois, professional witnesses
and staff for the Peoria Disposal Company Hazardous Waste Landfill, 4349 West
Southport Road, Peoria, 61615, commented with statements to the effect that municipal
waste landfill wastes or leachate are more dangerous than those of the PDC Hazardous
Waste Landfill
. A Peoria Disposal Company staff member commented on page 56 of the
Peoria County Hearing Transcript for February 21, 2006, that "wastes being land
disposed at PDC have been treated to limit the toxicity to extremely low treatment
standards, much lower in toxicity than are allowed to be disposed in municipal solid
waste landfills
." Expert witness for PDC, Ken Liss, stated as recorded on page 37 of the
Hearing Transcript for February 22, 2006, that leachate at the PDC Hazardous Waste
Landfill is, "in many cases, less toxic than the concentrations in municipal solid waste
landfill leachate
." Another expert witness for Peoria Disposal Company, Dr
. David
Daniels, stated at the hearing as recorded in the February 22, 2006, Hearing Transcript on
page 102, that, "I think you might well find that most ordinary municipal solid wastes
are, at least in many cases, more threatening in terms of what's in the leachate
." The full
transcripts from this hearing containing the quotes above are available via the Peoria
County Board website, http://www.co .peoria.il.us/
and click on Board Representatives,
and then the Landfill Expansion Application tab .
It would have been more reassuring in assessing these rule changes to see some overall
evaluation or assessment by an out-side, professional, independent evaluator to better
consider the full impacts of what the waste industry proponents are requesting
. We
appreciate that the IEPA has a great many responsibilities and that it would be eager to
have requirements that mean a savings in staff time and costs .
Our major concern regards what appears to be the leading nature of the proposed
regulation changes regarding declaring off-site sources the cause of contamination that is
identified in monitoring, and the stated procedures that follow
. Rather than wording that
emphasizes the due diligence to research the site for the cause of problems that are
identified through monitoring, the emphasis seems to be on adjusting the monitoring or
site plan and not a detailed list of priorities regarding investigation of on-site issues that
could be causing the contamination .
On behalf of Heart of Illinois Group, Sierra Club, we ask that the IPCB support the
conscientious application of regulations that are the most protective of our environment,
water resources, and the public health, safety, and welfare
.
oyce Blumenshine
Heart of Illinois Group Sierra Club
2419 E. Reservoir
Peoria, IL 61614-8029
