6322 N. Heather Oak Drive

Peoria, IL

61615

October 16, 2004

~ECE~VE~

Ms. Dorothy M. Gunn

CLERK’S OFFICE

ClerkoftheBoard

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202004

Illinois Pollution Control Board

James R. Thompson Center

STATE OF ILLINOIS

100 West Randolph Street

Pollution Control ~oarc

Suite 11-500

Chicago, Illinois 60601

RE:

Sutter Sanitation Services, Inc. vs. JEPA

Mason/Effingham County

Ladies and Gentlemen:

I am writing to support the denial ofthe transfer station permit by the Illinois EPA, which I

understand is the subject ofthe permit appeal the Illinois PCB is reviewing. Specifically, I am

writing to support two ofthe technical denial pointsof the Illinois EPA.

I have reviewed the Development Permit Application for Proposed Solid Waste Transfer Station,

Effingham County Illinois, dated September 29, 2003 and Revised December 12, 2003. The

permit application does not include design information for the facilities and structures which

would permit State ofIllinois to evaluate whether the proposed development will be protective of

the environment. The absence ofthis information is properly the basis for the denial ofthe

permit requested by Sutter Sanitation services by the Illinois EPA. The following information

should have been included in the permit application:

• Design details for the concrete slabs in the buildings, including the type and spacing of

reinforcing steel;

• Structural design calculations for the concrete slabs to demonstrate the capability to

support the anticipated structural loads;

• Design for containment ofliquids that penetrate the concrete slab, such as an

impermeable liner. The moisture barrier, that is reported to exist, would have been

designed for a much different purpose than containment ofleachate;

• Design calculations for the collection sump, including: capacity, structure, and

foundations;

U:/lsutter sanitation final 101604doc

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• Design details and specifications for liquid stops (water stops); these liquid stops are

required to prevent the seepage and leakage ofliquids at construction joints. Liquid stops

should be installed at all joints in the slabs and sump.

• Design for the containment and treatment of stormwater impacted by contact with

transport vehicles and tire drag out from the facility buildings; and

• Design details to demonstrate that liquids will be contained on the slab floors and will not

run offto the exterior ofthe building.

• Design to prevent leachate and chemical migration through the concrete; a treatment

should be applied to the concrete floor slab to prevent damage to the concrete and

migration through the concrete. The adequacy of the treatment product should be

evaluated as part of permit application review.

• The permit application did not include details on the management ofmaterials prohibited

from landfill disposal, or which require special handling, such as batteries, used tires,

landscape waste, PCBs, medical waste, and asbestos containing materials.

Based on the review ofthe application, it appears that the applicant intends to use existing

structures for the development and operation of the transfer station without performing the

required design. The concrete slabs may be inadequate for the planned use and could result in

releases to the environment. The application acknowledges the presence of shrinkage cracks and

that the cracks will be sealed. In the absence of adequate reinforcement, the cracks will continue

to expand due to the heavy loads associated with waste transfer. These cracks are significant for

the proposed activities at the facility due to potential environmental impacts. Design

requirements for the former use as a grain storage facility are much different than for the

proposed use for waste transfers and storage.

It is my professional opinion that the permit application submitted by Sutter Sanitation Services

was properly denied by the Illinois EPA, based on the inadequacy ofthe design and the lack of

required supporting calculations and management details. For these reasons, I urge you to

uphold the decision of the Illinois EPA which denied Sutter’s permit.

If you have any questions, please contact the undersigned at

309-693-5777.

Sincerely,

Michael J. Hoffman, P.E.

cc:

Joyce L. Munie, P.E., IEPA Bureau of Land, Manager, Permit Section

U://sutter sanitation final 101604.doc