To: Illinois Pollution Control Board

From: Tom L. Edwards

902 W. Moss Ave.

Peoria, IL 61606

RECEIVED

CLERK'S

OFFICE

JAN 0 7 2008

STATE

OF ILLINOIS

Pollution Control Board

January 1, 2008

(3 pages)

Re:

Addition

to my Dec.31 request for time extension to appeal IEPA permit to PDC

Who I am:

I have to get the essence of my appeal (below) of the IEPA permit to PDC in the mail to

meet the Jan. 1 appeal deadline date. Tomorrow I will send in more background material

-- and a copy of the bulky 197-page EPA decision. Briefly, I am an environmental

writer. Over the last 4 years I have researched and written 70 or 80 mostly one or two-

page papers regarding PDC' s hazardous waste landfill and its operation, and sent them

variously to Peoria County Board, EPA, Pollution Control Board, and other officials.

99% of the public knew nothing of the landfill's existence until I wrote an expository

petition (Jan., '04) and passed it out in the community to launch this campaign. Petitions

with 7,100 signatures were mailed back, some kind of a record. (Will send a copy.)

Moreover,

nobody

in the Peoria County administration or county board was even aware

that there was a state permit governing operation of PDC's landfill until this writer got

one from the state and presented it to the board 4 years ago (January, 2004).

Re: IEPA's Revised Permit to Peoria Disposal Co.

Note: IEPA' s cover letter sent out with its permit decision mistakenly states that the final

date for the public to submit appeals "is January 7,

2007."

Also,

none of the

forwarding letters or the decision are signed by the IEPA director, Doug Scott.

Missing from EPA's information is anything about the 1980 break at a PDC disposal cell

through which toxic waste poured lava-like down a hillside and 3-feet deep over Rt. 8,

and across a field down to Kickapoo Creek, said a witness. The road was closed. Federal

HazMat agency came in space-age garb and earthmoving machinery to deal with it.

Grounds for Appeal:

--

All major limitations in the original permit are gone:

1 --From its 1987 beginning PDC's permit was for 2.63 million cubic yards of toxic

waste to be put on its hilltop disposal site. That limitation still stands. But

both PDC and IEPA are saying that limit has not yet been reached after 20 years of

dumping via what was originally a 10-year permit

That is quite impossible. In tonnage 2.63 million cubic yards of toxic waste,

according to an expert, is equivalent to about 900,000 tons, given the loose, even fluffy

nature of much or most toxic waste. The waste comes in trucks from up to15 states.

2 -- The much extended, now also modified permit, was to expire in 2006. EPA

---

Page 2

summarily extended it to

2009

and says it will continue as long as the site has room.

3 --

The disposal area was original permitted for 64 acres. That has been expanded

by the EPA to near

75

acres.

4 --

A height limitation is still in effect. But PDC has requested permission to go

up another

45

feet

(5

stories) higher than the

4

to

5

stories high it already is. That would

make it the highest hill in that vicinity by far.

--

Overall, virtually all required data collection and reporting is left by the EPA for

PDC to do itself, then send reports to EPA.

-- Until now collection of test samples from the present

21

monitoring wells has been,

nominally,

done jointly by PDC and an EPA representative on a quarterly basis. (There

are

25

such well sites listed, but

4

are reported as never installed.)

However,

it is PDC that tells EPA on what day to be there for drawing samples.

-- Collection of samples from test wells, formerly done quarterly, are now to be collected

semi-annually, and a number only annually. (EPA staffers protested this change.) Leaks

could go on for half a year without being detected under this arrangement.

-- EPA says an inspector regularly visits the site.

But those visits are once, maybe twice,

a month, and are only visual. This procedure is not spelled out in the permit.

[During

city highway-sidewalk construction, inspectors are constantly present.]

--

Despite monthly "visits," the EPA had been firm in saying there is no air pollution

from the site.

HOWEVER, EPA was totally unaware that PDC has vents on the site to

release gaseous fumes to the air.

In an unauthorized visit, I found and smelled such vents

and reported their location to the EPA. (To his credit, when I told the site inspection

manager he acknowledged he was unaware of them, and asked me where they were.)

Now

the EPA is saying there is some dust around where the waste hauling trucks

unload, that it is largely captured, and that elsewhere on the site any

dust

pollution is

inconsequential.

BUT new research elsewhere shows

gaseous

toxic air pollutants from such landfills

are very consequential to unborn babies and older people.

--

The EPA has the bulk of the test well samples analyzed by PDC' s own laboratory, I

have been advised. This seems a rather incestuous arrangement.

-- The federal EPA authorizes

843

chemicals to be put in this landfill (plus some PCBs).

But checking for only

24 will

be required just semi-annually, under the revised pennit.

And other toxic chemicals may even be present as contaminants of these

24.

The

843

chemicals allowed are preponderantly

volatile, i.e.,

will evaporate.

---

Page 3

-- Testing for highly toxic and very volatile mercury is not included though it is

permitted in the landfill. Perhaps because it quickly evaporates off into the air.

-- The "barrel trench," i.e., toxic waste buried in metal barrels: It is highly unlikely that

not one barrel isn't disintegrating from rust, leaving its 50,000 tons of toxic waste free in

the soil just above the aquifer -- like the rest of the landfill -- from which the Peoria

area pumps most of its water.

-- All of the 5 barrel trench monitoring wells are listed in EPA's long existing permit as

"upgradient," meaning the groundwater is monitored going into the barrel trench rather

than after it comes out. EPA says it now will require a "downgradient" well be installed

to test groundwater traveling through the barrel trench into the city's water aquifer.

-- EPA says the flow rate of groundwater through the aquifer's sand soil is only 6 feet

per year! It doesn't give the source of that statistic. A new measurement is needed.