Oct 02 2004
    3:26AM
    Reserve i
    r
    309 688-0950
    p.2
    CL
    SIERRA
    jAN
    6
    101)
    N 1) 0 1892
    OIIU(fl
    C0flfrooard
    Heart of
    Illinois
    (roup
    P.O. Box 3593, Peoria, IL 61614
    2419 E. Reservoir
    Peoria, IL
    61614-8029
    January
    5, 2009
    Clerk ofthe Board
    IlLinois
    Pollution Control Board
    RE: Case
    Number. AS 08-10
    100
    W.
    Randolph Street, Suite
    11-500
    Chicago, IL 60601
    Additional Issues Regarding: Case AS 08-10
    Peoria
    Disposal Company RCRA Delisting Adjusted Standard, Electric Arc Furnace Dust
    Waste
    To
    the
    Members
    of
    the Illinois Pollution Control
    Board:
    The December 29, 2008,
    and
    the
    December 17, 2008, letters
    of Mr. Thomas P. McCullough regarding
    the Peoria
    Disposal Company application for delisting of
    Electric Arc
    Furnace
    Dust
    waste have raised
    new and troubling issues regarding the
    PDC application. Heart of
    Illinois Group Sierra
    Club
    asks
    the
    Illinois Pollution
    Control
    Board to
    closely review the points raised by Mr.
    McCullough.
    Mr.
    McCulloughts
    question asking if PDC would
    be
    allowed to alter their proposed treatment
    reagents,
    if they
    were to receive approval,
    is of great concern to us. This
    point raises new and grave
    worries for
    Heart of
    Illinois Sierra
    Club,
    who
    already sees contamination of
    Indian.
    Creek, next to the Hopedale
    Municipal
    Waste
    Landfill, and the
    Mackinaw River, in addition to
    area groundwater, major long-term
    impacts
    with this
    application.
    If PDC can alter their proposed treatment
    process, what
    testing
    will
    be
    required to insure
    that their claimed procedures work
    as they are
    supposed to? We are also greatly
    concerned that
    the frill specter of unintended consequences
    could
    ensue, with
    municipal
    waste
    residues,
    organics, and
    other
    landfill mixtures impacting the
    secret treatment
    process PDC proposes.
    The fact
    that
    this delisting
    would allow PDC to off-ship their treated EAF waste to unsuspecting
    municipal
    waste
    landfills
    located
    anywhere
    in
    flhlnois makes the issues in this delisting application of state-wide
    importance
    and impact.
    Questionable
    treatment
    processes are too great
    a risk.
    We are
    also
    wondering if PDC is
    actually inflinging on other patents, and
    if
    they
    receive delisting
    approval, will they
    have
    to find a different
    treatment
    process? Will they be allowed to off-ship treated
    EAF to
    municipal
    waste landfills
    in the interim?
    Will they have to
    submit
    a
    new delisting
    application
    and
    go
    through the
    filing process
    if
    they
    are indeed committing a
    patent infringement
    and have to
    change
    their
    planned
    treatment
    process?
    Heart
    of
    Illinois
    Sierra Club
    urges that
    this delisting application
    be denied.
    of Illinois
    Sierra

    Oct
    02
    2004
    3:26AM
    Reservoir
    30S
    S88-0S50
    p.1
    FAX TO:
    JAN
    95
    2009
    Clerk
    of
    the
    Board
    Pi
    OF
    ILLINOIs
    Illinois
    Pollution
    Control
    Board
    COntrol
    RE:
    Case
    Number.
    AS
    08-10
    Board
    100
    W.
    Randolph
    Street,
    Suitell-500
    Chicago,
    IL
    60601
    Additional
    Issues Regarding:
    Case
    AS
    08-10
    Peoria
    Disposal
    Company RCRA
    Delisting
    Adjusted
    Standard,
    Electric
    Arc Furnace
    Dust
    Waste
    FAX
    NUMBER:
    312-814-3669
    FROM:
    Joyce
    Blumenshine
    Heart
    of
    Illinois
    Group
    Sierra
    Club
    2419
    E.
    Reservoir
    Peoria,
    IL
    61614-8029
    TOTAL
    PAGES
    BEING
    SENT:
    2
    DATE:
    Jan.
    6,
    2009

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