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City of Kokomo, Indiana

Letter from Jerel Myers to XLC program

4000 Bank One Tower . 111 Monument Circle . P.O. Box 44363 . Indianapolis, Indiana 46244-0363
Telephone 317/630-4000 . Fax 317/236/9802
8900 Keystone Crossing . Suite 1046 . Indianapolis, Indiana 46240-2134 . Telephone 317/630-4000 . Fax 317/844-4780

Please reply to Bank One Tower address

February 26, 1996

Regulatory Reinvention Pilot Program
XL Community Pilot Program
FRL-5322-9, Water Docket Mail Code 4101
U.S. Environmental Protection Agency
410 "M" Street, S.W.
Washington, D.C. 20460

Re: City of Kokomo, Indiana

Project Proposal
Four County Landfill

Dear Sir or Madam:

On November 20, 1995 the City of Kokomo (the "City") submitted for consideration by U.S. EPA an XL Community Pilot Program project. The City's proposal called for the treatment of leachate generated at the Four County Landfill (the "Site") at the City's Wastewater Treatment Plant. Since the time of that submittal, the method of disposing of the leachate has changed from deep well injection at Vickery, Ohio to biological treatment at CID Recycling and Disposal Facility in Calumet City, Illinois. This change occurred during the second week of January 1996, and the City, as well as the Four County Landfill Group (the "Group") felt that it was important that you be made aware of this change.

The City also believes that it is important to emphasize that the preferred disposal option recommended in the City's proposal ("Kokomo Option") is still preferable and still meets the XL Community Pilot Program criteria. Each of these criteria is discussed below.

Environmental Results:

Both the present leachate disposal option and the Kokomo Option involve biological treatment. However, the Kokomo Option results in the organic solids being incorporated into the compost generated by Kokomo's new composting facility. The CID process results in the solids being disposed of in accordance with appropriate regulations. Therefore, the Kokomo Option has the advantage of utilizing the treated solids in a way that results in these solids being recycled for productive re-use.


The Kokomo Option continues to be the least expensive way of handling the leachate generated at the site. The present annual cost to the Group for the treatment of the leachate at the CID facility is $144,000.00. The cost of the Kokomo Option would be limited to the cost of transporting the leachate from the site to the Kokomo Wastewater Treatment Plant. Thus, the cost savings to the Group are substantial over the anticipated closure and post-closure period by utilizing the Kokomo Option.

Stakeholder's Support:

Obviously, the stakeholders continue to support the Kokomo Option due to the fact that the cost savings are substantial. Clearly, Kokomo has a substantial interest in the utilization of the Kokomo Option becuase it will greatly reduce the City's otherwise prohibitive contribution to the cost of remediating the Site.

Innovative/Multi-Media Pollution Prevention:

The Kokomo Option continues to be a multi-media pollution prevention project. Even though the CID Facility treats the leachate generated at the Site, the leachate solids are disposed as opposed to being recycled as part of the Kokomo compost program. In addition, the CID Facility, although closer than the Vickery facility, is still more than twice as far from the Site as the Kokomo Wastewater Treatment Plant. Therefore, significant air pollution is prevented due to the reduced truck mileage involved in transporting the leachate.


Obviously, the Kokomo Option is transferable to other sites where remediation of ground water, surface water or leachate is compelled or being carried out voluntarily. Allowing municipalities to accept the contaminated water as their contribution to site remediation has many advantages. Not only does the entity providing the treatment substantially reduce its costs, but resources of other responsible parties are also made available to be used for other environmental projects.


The change of the leachate disposal facility from the Vickery facility to the CID facility does not effect the feasibility of utilizing the Kokomo Option.

Monitoring, Reporting and Evaluation:

The change of the disposal facility does not effect monitoring, reporting and evaluation associated with the Kokomo Option.

Shifting of Risk Burden:

Likewise, the change of the disposal facility dose not affect the risks associated with utilization of the Kokomo Option.

The Group would like to begin implementation of the Kokomo Option as described in the City's XL Community Pilot Program proposal as quickly as possible. Therefore, the Group is hopeful that positive action on the proposal can be accomplished in the very near future. However, if you require any additional information, please do not hesitate to contact me. I will be happy to prove any information which will assist you in evaluating the City's proposal.

Very truly yours,

Verl L. Myers


cc: Mark Steger
Jeff Fort
Kenneth Ferries
Frank J. Deveau

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