RECEIVED

CLERK’SOFFICE

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

JUN

2

7

2001

June

25, 2001

STATE OF ILLINOIS

Pollution

Control Board

IN THE

MATTER

OF:

)

)

AMENDMENTS TO LIVESTOCK

)

RO1-28

WASTE REGULATIONS

)

(35 IL Adm.

Code

506)

)

ADDITIONAL POST-HEARING COMMENTS OF TERRY

FELDMANN,

P.E

The Department’s posthearing comments filed June

19,

2001

are welcome

clarifications to the Department’s proposal. However, additional comments seem

warranted to clarify one issue on which the Department commented.

Section

13 (b) (3) of the Act addresses the issue where aquifer material

is found within

5’ of the planned

bottom.

In the proposed

rules, section 506.310(b) specifies minimum

thicknesses of 5”for floors and

8”for walls.

This section

seems

to apply to all

types of

waste handling structures

using concrete including those that are used to transport

manure but not necessarily store it.

MWPS-36 uses 4” for floors and 6”for walls as the

minimum thicknesses for storage tanks which is consistent with

section 6.1

(Structural

Design) of ASAE EP393.3.

Note,

section 6.1

replaces section 4.1

ofthe older ASAE

EP393.2

standard with minor changes.

As

required by the Act,

I believe that the rule

must follow the “structural design” sectionof ASAE

EP393.3 or future updates.

It

outlines the

loads

(manure,

soil,

etc.) to be used for the design

and the design

standards for each material which must be followed (e.g., ACI-318 for concrete).

The Act requires that the facility design prevent seepage to ground water.

I contend

that the difference

in seepage potential of 4”versus 5”floors (slabs on grade) and 6”

versus 8”walls is negligible for typical livestock waste facilities.

There is little evidence

that the Department’sproposed thicknesses will reduce seepage potential over the 4”

and 6” minimums required by MWPS-36, ASAE EP393.3, ACI-318, and ACI-360.

Rather than spend

money on increased concrete thickness

(e.g., $4/pig space for an

additional inch on the pit floor of a typical swine finisher),

I suggest other measures

would better ensure against seepage.

For example, as alluded to in ASAE EP393.3

section

6.1.2.3.1, additional soil testing

and analysis such as soil type, soil strength,

seasonal

high water table

determination, etc. should

be required.

Designs should then

be based on actual site-specific data such as allowable soil bearing strength, soil

density, horizontal earth pressures, etc.

Site specific design data, rather than general

assumptions found

in

MWPS-36, would enable better, more accurate design to assure

against seepage to groundwater.

Thank youfor considering these comments.

Sincerely,

Terry Feldmann, P.E.