ILLINOIS POLLUTION CONTROL BOARD
    September 15,
    1994
    IN THE MATTER OF:
    )
    REGULATION OF LANDSCAPE
    )
    R93-29
    WASTE COMPOST FACILITIES
    )
    (Rulemaking)
    35
    ILL. ADM. CODE 830—832
    )
    DISSENTING OPINION
    (by J. Theodore Meyer):
    I dissent from the majority’s action in sending these rules
    to second notice.
    I support the adoption of standards for
    landscape waste compost, but I believe that the rules are
    insufficient in two areas.
    First, the rules lack a minimum oxygen standard and
    associated testing.
    It would be relatively easy for an operator
    to test the compost daily, and to take corrective action, such as
    turning the pile, when the oxygen level fell below the standard.
    Adding such a requirement would work to eliminate odor problems
    by preventing the compost pile from going anaerobic.
    By simply
    requiring remediation of odor problems after they occur, the
    rules allow the creation of odor problems instead of preventing
    the odor.
    Additionally,
    an anaerobic pile will produce methane,
    which is a major contributor to the greenhouse effect.
    Finally,
    an anaerobic pile,
    when it becomes wet, will leach heavy metals
    from the pile to the ground, whereas an aerobic pile will not.
    All of these problems could be prevented,
    or at a minimum
    reduced, by establishing a minimum oxygen standard.
    Second,
    I share the concerns articulated by several
    different participants that the heavy metal standards,
    based on
    the federal 503 rules,
    are inappropriate for compost.
    The 503
    standards are substantially higher than the naturally-occurring
    heavy metals which are found in landscape waste.
    Therefore,
    I am
    concerned that an operator could blend other materials,
    containing substantial amounts of heavy metals,
    into the compost
    to “make up the difference” between the naturally—occurring
    levels and the 503 standards.
    I believe that the standards are
    much too lenient for compost.
    For these reasons,
    I dissent.
    J. ~eo~dore~eyer
    Boa~dMember
    2
    I, Dorothy M. Gunn,
    Clerk of the Illinois Pollution Control
    Board, hereby certify th~~theabove dissenting opinion was filed
    on the
    ~&/~-
    day of
    ((“~~--~
    ,
    1994.
    /
    Dorothy M. ~nn,
    Clerk
    Illinois Pollution Control Board

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