September23,
2008
ECEVED
CLERK’S
OFFICE
Office
Pollution
of the
Control
Clerk
Board
SEP
2
6
2008
James
R.
Thompson
Center
STATE
OF
ILLINOIS
100
W. Randolph
St.,
Suite 11-500
Pollution
Control
Board
Chicago,
IL 60601
Re:Case#ASO8-10
Dear
Members
of the
Illinois
Pollution
Control Board:
I
am
writing
regarding
the proposed
delisting
of Electric
Arc Furnace
Dust
waste as
requested
by
Peoria
Disposal
Company.
After having
sat through
3
hours of
the public
hearing in
Peoria
regarding
this matter.
I
am
alarmed at
the
possibility of
this hazardous
waste becoming
delisted, transported
in
and out of
Peoria
County,
dumped into
municipal
waste landfills
in Central
Illinois, and
thereby putting
the Mahomet
Aquifer
at
risk for
contamination.
There
are many other
hazardous
waste landfills
operating
in the
US with
capacity
available.
Why even
consider delisting
a hazardous
substance
when
there is ample
space in
existing
hazardous
waste
landfills
to dispose
of it
as
intended
by RCRA
standards?
It seems clear
that the
treatment
process
that PDC
says will
“forever” stabilize
this hazardous
dust has
only
been
tested
for
a
short amount
of time
and
by
scientists
commissioned
by
PDC. There
has never
been
any long-term
study
of how waste
treated
by
this
process
will react
in the
real
world setting
of a
municipal
landfill.
No
independent
lab has conducted
tests on
the process.
The
public is
not
allowed
to examine
the
process
because
the
treatment
is
considered proprietary.
If
PDC and their
paid
scientists
are
wrong, the
result could
be
the contamination
of one of the
largest, cleanest
sources
of water
in the
US,
the
Mahomet
Aquifer. And
PDC has
only
one, very strong
motivation
for convincing
you
and me
that
their treatment
process is
infallible..,
money.
If you
approve
this delisting
you
are implying
that
the financial
success of
a
small,
private
company
outweighs
the
health
and safety
of the hundreds
of
thousands
of
Central Illinoisans
that
get their drinking
water
from the
Mahomet
Aquifer.
In addition
to
the
health
implications,
a
contaminated
aquifer would
ruin
the economies
of hundreds
of rural
communities
that
draw
their well
and municipal
water from
the
Mahomet.
Illinois businesses,
both
agricultural
and
industrial,
that depend
on water
from the
aquifer
would
suffer from any
form of
contamination
as well.
At the public
hearing
and in the
press, the
case
has been
made that
this
waste is
primarily
coming
from
Keystone Steel
and
Wire, a Peoria
company.
But when
looking
at
the list
of PDC
customers
(see
the
attached
chart) it
is apparent
that
the
majority
of this
EAFD
waste
is coming
from outside
Central Illinois,
primarily
from
out-of-state.
Wastes
from Iowa,
Indiana, Kentucky,
Wisconsin
and
Nebraska
make up
64%
of the
waste coming
into
PDC’s facility.
The rest
of
the waste
comes from
the
Chicago
and
St. Louis areas,
with only
18% of the
waste
coming from
Keystone
in Peoria
County. And
even
more
disturbing—46%
of
the waste
comes from
companies
that
are not even
US owned.
The
people of
Central
Illinois should
be
responsible
for
the waste
we produce.
But
we
should
not
be asked
to
bear the burden
of
steel mills
hundreds of
miles away,
owned
by foreign
companies
from
across
the
globe. Why
should
the
health
and
safety of
Illinois
citizens
and our
precious water
supply be
risked
on
what amounts
to a
grand
experiment?
The goal
of
the Environmental
Protection
Act
is
to protect
the
public
health
and
safety and
the
environment,
NOT
to
help private
companies
operate
as
profitably
as possible.
Your
job
is
to
protect the
interests
of
the citizens
of
Illinois,
NOT
to
protect
the
profits
of
companies
from
beyond our
borders.
Don’t
be
short-sighted. Don’t
risk our
health
and safety.
Don’t risk
our water supply. DO
NOT
allow this
delisting.
Tessie Bucklar
5045 North Bellevue Place
Peoria Heights, IL 61616
Enclosure: chart by Tracy
Meints Fox
analyzing PDC
T
s
EAFD waste customers
%
of
2007
Total
Loads
(per
RMT
Technical
Document
Table
5)
0.95%
European.
Subsidiary
of
Schmolz
+
Bickenbach
of
Dusseldorf,
Germany.
Per
2Q
earnings
announcement,
“the
first
half
of
2008
was
characterised
by
a
good
market
situation,
high
production
volumes,
and
increased
raw
material
costs.
It
brought
a
substantial
improvement
relative
to
the
second
half
of
2007.”
5.37%
Private.
Purchased
by
a
group
of
investors
after
bankruptcy.
In
2006
John
Simmons,
an
Alton
attorney
with
a
lucrative
trade
in
personal
injury
cases
specializing
in
asbestos
exposure,
bought
out
his
partners
for
a
90%
share.
CEO
featured
Illinos
steel
boom
article
(IBJ).
15.91%
Private.
Mainly
family-held.
Speaking
to
press,
CEO
John
Mellowes
projects
6-7%
growth
in
2008
(Sm
Biz
Times
Jan
08)
4.95%
Brazilian-owned
Canadian
company.
CEO
Marion
Longhi
in
2Q08
earnings
call
-
We
recorded
the
highest
quarterly
level
of
shipments,
revenue
and
earnings
in
the
history
of
Gerdau
Ameristeel
during
the
second
quarter,
attributable
to
the
successful
execution
of
our
strategic
plans
over
the
past
several
years.
32.35%
Swedish.
Plant
actually
located
in
Montpelier,
IA.
Division
of
SSAB
Stockholm,
Sweden.
Per
2Q08
earnings
announcement,
sales
up
64%,
profit
up
63%
and
after-tax
profit
up
34%.
6
Kentucky
Ashland,
KY
1.67%
Private.
Purchased
after
bankruptcy
by
RU
Holdings,
formerly
known
as
Youthstream
Media,
Electric
a
college-oriented
new
media
company.
7
Keystone
Peoria,
IL
18.65%
U.S.
public
(NYSE:KEY).
Keystone
Consolidated,
the
Dallas-based
parent
of
Keystone
Steel
&
Wire,
reported
a
2Q08
profit
of
$21.9
million,
or
$1.81
a
share,
during
the
quarter
that
ended
June
30.
That
was
about
27
percent
higher
than
2Q07.
8
Arcelor
East
8.24%
Western
European.
Conglomerate
of
Spanish-French-Belgiam-Luxemborg
Arcelor
and
Dutch
Mittal
Steel
Chicago,
IN
Mittal.
Per
2Q08
earnings,
sales
up
31%
and
net
income
up
65%.
1.18%
U.S.
public
(NYSE:NUE).
Per
2Q
earnings
report,
consolidated
net
earnings
up
68%
over
2Q07
and
up
42%
over
1Q08.
10.72%
U.S.
public.
Subsidiary
of
Leggett
&
Platt
(NYSE:LEG),
a
diversified
manufacturer
of
home
furnishings
and
industrial
goods.
Per
2Q
earnings
report,
Second
quarter
sales
were
$1.06
billion,
slightly
lower
than
last
year’s
sales
of
$1.07
billion.
CEO
comments
about
increasing
use
of
domestic
springs
and
capture
of
business
from
a
competitor
that
formerly
made
its
own
spring.
(Note:
Sterling
Steel
produces
wire
that
becomes
mattress
springs.)
Customer
1
A.
Finkl
&
Sons
2
Alton
Steel
Charter
ISteel
4
Gerdau
Ameristeel
5
IPSCO
Steel
Location
Chicago,
IL
Alton,
IL
Saukville,
WI
Wilton,
IA
Muscatine,
IA
9
Nucor
Steel
Norfolk,
NE
10
Sterling
Steel
Sterling,
IL
prepared
by
Tracy
Meints
Fox,
Chillicothe,
IL
August
21,
2008
Totals
by
Illinois
35.69%
Indiana
8.24%
Iowa
37.30%
Kentucky
1.67%
Nebraska
1.18%
Wisconsin
15.91%
Other
States
64.30%
Ownership
Non-U.S.
46.49%
U.S.
Public
30.55%
U.S.
Private-
Family
15.91%
U.S.
Private-
Holding
Company
7.04%
Incorrect
statements
in
the
Journal
Star
18-Aug-08
Bibo,
Crowd
Keystone
provides
the
bulk
of
the
EAF
dust
sent
to
PDC’s
hazardous
waste
landfill
near
Pottstown
Shows
Opposition
16-Aug-08
Bibo,
K061
EAF
dust
is
now
the
biggest
part
of
Pottstown’s
hazardous
waste
landfill
stream.
Most
of
it
comes
Hazardous
from
Keystone
Steel
&
Wire
Co.
Waste
Vote
a
Dust-Up
15-Aug-08
Sharp,
EAF
is
a
byproduct
of
companies
such
as
Keystone
Steel
&
Wire,
one
of
the
largest
customers
for
Peoria
County
Board
Disposal
Co.,
which
operates
the
hazardous
landfill.
Won’t
Weigh
In
3-Aug-08
Bibo,
Get
a
The
Heart
of
Illinois
Sierra
Club
has
said
that
de-listing
EAF,
a
by-product
of
companies
such
as
Keystone
Big
Whiff
Steel
&
Wire,
PDC’s
largest
customer,
is
just
a
way
to
get
around
that
decision.
prepared
by
Tracy
Meints
Fox,
Chillicothe,
IL
August
21,
2008
