RICHARD

DEl EEL

President

LANDFILL

33,

LTD.

1713 S.

Willow, P.O.

Box 703

Effingham, IL 62401

(217) 342-3713

January 2, 2003

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Illinois Pollution Control Board

-

James R. Thompson Center

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100W. Randolph St.,

Suite 11-500

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Chicago, IL

60601

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2003

RE:

PCB 03-43- Public Comment

STATE OF ILLINOIS

Pollution

Control Board

Dear Board Members

Please consider all the evidence presented as it relates to the nine criterion for transfer station

siting in your review of our appeal for the above mentioned case.

It appeared that some of our

County Board members put a lot ofweight on recycling and a fear ofrestricting free trade

when it came time to vote on the local

siting hearing.

The fact ofthe matter’ is

Sutter Sanitation was not participating in Effingham County’s

recycling effort until they petitioned for a transfer station, and then threatened to stop recycling

if they were not granted siting for the transfer station.

Sutter’s current recycling efforts account

for LESS THAN TWO TENTHS OF ONE PERCENT. (.00195) of Effingham County’s

current recycling rate of 28.

That ofwhich Landfill 33’s recycling effort has consistently

contributed approximately

5.5

annually and has been doing it for

15 years.

Additionally,

Effingham

County has existing buy back centers and drop offsites in town for most of the

items

Sutter’s are collecting at their remote rural

location.

While we

in no way hold this

against the board members, we realize they were voting based on

their limited exposure to the economics of solid waste management.

The reason for our appeal

was to•hãve the evidence reviewed by the panel ofexperts on the Pollution

Control Board who

posses an understanding of the economy of scales of Subtitle D landfllls.

Please know that Sutter Sanitation is allowed to

dump at Landfill 33.

Mr. Sutter’s

apparent

lack ofknowledge ofthe Solid Waste Industry beyond

collection routes has caused problems

that we have attempted to

rationally explain to

Mr. Sutter with little success.

One ofwhich

included Mr. Sutter detaining our landfill customers, on

our property, for the sake oftrying to

rally them to boycott

our price increases that we implemented to compensate for our transition

to

Subtitle P pits.

(Even though Landfill 33’s tipping fees remain below the state average.)

This was one of the most comprehensive changes in our industry’s recent history and he

appeared to have no knowledge ofthe changes

taking place

The consulting firm that ‘drafted the Effingham County

Solid Waste plan testified at this

transfer station

hearing in

opposition to the transfer stations compatibility with the county Solid

®

Recycled

Paper

---

Waste Plan.

The plan clearly stated “direct shipment ofwaste to in County or out ofCounty

Landfills.”

The feasibility or need of a transfer statiOn was never seriously considered based on

the population and waste volume ofEffingham County.

Primarily because there is a Subtitle D

landfill in Effingham County with long term disposal capacity.

Landfill 33

is a small volume

landfill in a county with a low volume of waste produced.

Beyond that, please seriously consider the following DESIGN flaws that do

not protect public

health and safety.

This facility was designed as a grain farm, not a solid waste transfer station.

POORLY DESIGNED TRANSFER STATIONS REQUIRE MORE LONG TERM “FIX UP”

SOLUTIONS THAN TRANSFER

STATIONS THAT WERE PROPERLY DESIGNED

FROM THE BEGINNING.

Ifwe really need

a transfer station in Effingham County (which

we do not)

it should

be designed to be as such.

Sutter’s proposed transfer facility has critical design

flaws in the following areas:

-

Ceiling Height

—

16’ when it should be 25’ minimum.

A transfer station would never

be designed with a

16’ ceiling.

-

Staging Area

—

with one truck on the scales there is no room for another truck to stage

and must wait on the road

-

Absence of push walls

—

this is

a pole barn which will allow for the accumulation of

debris along the walls

-

Turning radius

—

The turning radiuses from the scale and between the building

is

extremely tight.

-

Leachate Control

—

The flow ofleachate

has not seriously been tested and the floor was

not DESIGNED to

control leachate.

In Sutter’s presentation to the County Board, they

claimed leachate would not be present because the operation is indoors.

This is

purposely misleading because anyone in

the hauling business knows that when you

open the back of a garbage truck after dumping containers

full ofrainwater there canbe

up to 200 gallons ofwater that will pour out on the ground.

-

Lack of responsible on site manager.

-

There are two (2) residential homes

within

1000’ ofthe proposed site, one of which has

a built in swimming pooi.

Thank you

for your attention to

this matter.

A transfer station is not in the best interest of

Effingham County or is it designed to meet the demands of an Environmentally

sound facility.

Sincerely,

Landfill 33,

Ltd.