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FEB28
2005
~AI’A
STATE OF
ILLINOIS
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Pollution Control B~,g~çJ
WAZTE
MANAGEMENT
WASTE
AGEMEPJT
Midwest Group
720 E. Butterfield Road
February 25,
2005
Lombard, IL 60148
(630)
572-8800
(630)
916-8182
Fax
M. McCambridge, Hearing Officer
Illinois Pollution Control Board
100 W.
Randolph Street
Suite 11-500
Chicago,
IL
60601
RE:
R05-1, Proposed
Rulemaking for RCRA Subtitle D Update, USEPA Regulations
-
(January 1, 2004,
through June 30, 2004)
Dear Hearing Officer McCambridge:
Thank you
for the opportunity to comment on R05-1,
the
identical-in-substance rulemaking
to update the
municipal
solid
waste
landfill
(MSWLF)
regulations
to
incorporate
the federal
regulations for temporary
research, development,
and demonstration
(RD&D) permits.
Waste
Management of
Illinois,
Inc.
(WMI)
supports this
rulemaking for
RD&D
permits
that will
allow for
exceptions
to limited
landfill
requirements for the
use of
innovative
technologies
at
landfills.
The
Board
has
specifically
requested
comments
on
two
issues:
(1)
rendering
the
decision
to
allow
alternative
practices
that the
Agency could
allow in
RD&D
permits
as
an
adjusted
standard
determination
and
(2)
providing
the mechanism of
an enforcement
action
for
Board
termination
of operations
under the
RD&D
permit is appropriate in the event the objectives of the permit are not achieved.
WMI
is submitting comments only on
the adjusted standard determination.
We believe that the
regulatory
amendment, as
proposed, does not provide any additional capability than what is already provided
in the
current system.
Under the current
system,
if a facility would
want to accept
liquid
wastes
or
install
an
alternate final
cover design, the facility would
need to
apply for an
adjusted
standard from
the
IPCB.
If
successful, the
facility would need to apply for a permit from the
IEPA, under the authority of the adjusted
standard.
Under
the
new
proposal,
the
facility
would
follow
the
identical
procedure.
Therefore,
for
purposes
of streamlining
and
eliminating
redundancy from
regulatory procedures, we
could
not support
the
IPCB proposal.
The
intent of the
USEPA rule
is to provide
a simple permitting mechanism for these
alternate technologies.
The current proposal does not do this.
Other
states
have
already
begun
accepting
applications
for
these
alternate
technologies
under
their
existing or modified
regulations.
We
would
support regulatory amendments
in
Illinois that
would
make
this possible, consistent with
other states
and, what we believe, is the USEPA’s intent.
Thank you for the opportunity to provide our comments.
Sincerely,
~
William
R. Schubert, P.E.
Director
—
Environmental Engineering