KAN KAK E E
    Co U NTY
    2390 West Station
    I—I~*LT
    I—I
    Phone
    81
    DEPAflTIVIENT
    fax
    815-937-3568
    ti~gy~
    CLERK’S OFFICE
    May 20, 2004
    MAY
    2
    ~
    2004
    STATE OF ILLINOIS
    Pollution
    Control Board
    J. Philip Novak, Chairman
    IlIinois Pollution
    Control Board
    James R. Thompson Center
    100 W. Randolph, Suite 11-500
    Chicago, IL
    60601
    Dear Chairman Novak:
    RE:
    PCB Case
    03-235
    I am writing this letter to voice my concern regarding United Disposal ofBradley, Inc.’s
    transfer station permit modification request.
    In my capacity as Illinois EPA Delegated Authority in Kankakee County, I am very
    familiar with the rules and regulations governing pollution control facilities.
    It is clearly
    stated in the Illinois Environmental Protection Act that
    “any person conducting a waste
    storage, waste treatment, waste disposal, waste transfer or waste incineration
    operation for
    wastes generatedby such person ‘s own activities,
    when such wastes
    are
    stored, treated, disposed
    of,
    transferred or incinerated within the site or facility
    owned, controlled, or operated by such person or when such wastes are transported
    within or
    between sites or facilities owned,
    controlled or operated by such person”
    is
    not
    subject
    to
    local
    siting as
    a
    pollution control facility.
    However, in
    this case, United Disposal would
    not
    be generating, waste due to his
    own
    activ1ty
    United Disposal would be collecting and transfernng waste
    from
    sites outside
    the Village ofBradley, owned by other people, with wastes generated by other people’s
    activities.
    The facilitywould then become a pollution control facility by definition once
    ittakes wastes outside ofBradley, Illinois.
    Such amendment to its service area without
    going through local siting is
    a clear violation oflaw, and granting this permit
    modification request would set an undesirable precedent for other pollution control
    facilities to follow.
    As the delegated inspector for Kankakee County, I and the Des Plaines Regional
    Office
    ofthe IEPA are aware ofapparent violations at the site for which enforcement is being
    pursued.
    J.
    Phillip Novak
    May20, 2004
    Page 2
    While various appeals on the siting oftwo pollution control facilities (municipal solid
    waste landfills) within Kankakee County are pending and there is uncertainty as to the
    future plan for solid waste disposal within this County,
    this does not take away from the
    fact that United Disposal must go through local siting approval before receiving any
    permit to expand operations.
    It is my recommendation to deny the consideration to deviate from the original conditions
    ofthe permit without going through the proper process ofsiting and hearings for the
    public’s interest and
    concerns.
    Thank you in advance for the Board’s consideration ofmy comments.
    Sincerely,
    J
    J. Bevis
    IEPA Delegated Inspector
    Kankakee County Health Department
    JJB:scv
    Cc:
    Ed Smith, State’s Attorney Ofc.
    Mike Van Mill, Kankakee Co. Planning & Zoning

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