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INFORMATIONAL NOTICE!!!
RECEIVED
CLERK'S OFFICE
APR 0 3 2006
STATE OF ILLINOIS
Pollution Contr I Board
cC
IT IS IMPORTANT THAT YOU READ THE ENCLOSED DOCUMENTS .
NOTE :
This Administrative Citation refers to TWO separate State
of Illinois Agencies. One is the ILLINOIS POLLUTION
CONTROL BOARD located at James R. Thompson
Center, 100 West Randolph Street, Suite 11-500,
Chicago, Illinois 60601 . The other state agency is the
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
located at: 1021 North Grand Avenue East, P.O. Box
19276, Springfield, Illinois 61794-9276
.
If you elect to contest the enclosed Administrative Citation, you must
file a PETITION FOR REVIEW with thirty-five (35) days of the date
the Administrative Citation was served upon you . Any such Petition
for Review must be filed with the clerk of the Illinois Pollution Control
Board by either hand delivering or mailing to the Board at the
address given above. A copy of the Petition for Review should be
either hand-delivered or mailed to the Illinois Environmental
Protection Agency at the address given above and should be marked
to the ATTENTION: DIVISION OF LEGAL COUNSEL .
Any person other than individuals MUST appear through an attorney-
at-law licensed and registered to practice law. Individuals may
appear on their own behalf, or through an attorney. 35 III. Adm .
Code 101 .400(a) .

 
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR 0 3 2006
ADMINISTRATIVE CITATION
STATE OF ILLINOIS
Pollution Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
(IEPA No. 73-06-AC)
CLIFFORD LAWSON,
)
Respondent .
)
NOTICE OF FILING
To :
Clifford Lawson
1086 Cordum Avenue
Gillespie, IL 62033
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois the following instrument(s) entitled ADMINISTRATIVE
CITATION, AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST
.
Respectfully submitted,
Michelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated :
March 31, 2006
THIS FILING SUBMI I FED ON RECYCLED PAPER

 
RECEIVED
CLERK'S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR 0 3 2006
STATE OF ILLINOIS
ADMINISTRATIVE CITATION
Pollution Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
V .
)
CLIFFORD LAWSON,
)
Respondent .
)
AC Vh
-
(IEPA No. 73-06-AC)
JURISDICTION
This Administrative Citation is issued pursuant to the authority vested in the Illinois
Environmental Protection Agency by Section 31 .1 of the Illinois Environmental Protection Act, 415
ILCS 5/31 .1 (2004)
.
FACTS
1
.
That Clifford Lawson ("Respondent") is the present owner and operator of a facility
located at 1086 Cordum Avenue, Henderson, Macoupin County, Illinois . The property is commonly
known to the Illinois Environmental Protection Agency as Henderson/Lawson
.
2 .
That said facility is an open dump operating without an Illinois Environmental
Protection Agency Operating Permit and is designated with Site Code No. 1178055008
.
3 .
That Respondent has owned and operated said facility at all times pertinent hereto
.
4 .
That on February 17, 2006, Charlie King of the Illinois Environmental Protection
Agency's Springfield Regional Office inspected the above-described facility . A copy of his
inspection report setting forth the results of said inspection is attached hereto and made a part
hereof .

 
VIOLATIONS
Based upon direct observations made by Charlie King during the course of his February 17,
2006 inspection of the above-named facility, the Illinois Environmental Protection Agency has
determined that Respondent has violated the Illinois Environmental Protection Act (hereinafter, the
"Act") as follows :
(1)
That Respondent caused or allowed the open dumping of waste in a manner
resulting in litter, a violation of Section 21(p)(1) of the Act, 415 ILCS 5/21(p)(1)
(2004) .
(2)
That Respondent caused or allowed the open dumping of waste in a manner
resulting in the deposition of general construction or demolition debris; or clean
construction or demolition debris, a violation of Section 21 (p)(7) of the Act, 415 ILCS
5/21 (p)(7) (2004) .
CIVIL PENALTY
Pursuant to Section 42(b)(4-5) of the Act, 415 ILCS 5142(b)(4-5) (2004), Respondent is
subject to a civil penalty of One Thousand Five Hundred Dollars ($1,500 .00) for each of the
violations identified above, for a total of Three Thousand Dollars ($3,000 .00). If Respondent elects
not to petition the Illinois Pollution Control Board, the statutory civil penalty specified above shall be
due and payable no later than Mav 15, 2006, unless otherwise provided by order of the Illinois
Pollution Control Board .
If Respondent elects to contest this Administrative Citation by petitioning the Illinois Pollution
Control Board in accordance with Section 31 .1 of the Act, 415 ILCS 5/31 .1 (2004), and if the Illinois
Pollution Control Board issues a finding of violation as alleged herein, after an adjudicatory hearing,
Respondent shall be assessed the associated hearing costs incurred by the Illinois Environmental
2

 
Protection Agency and the Illinois Pollution Control Board . Those hearing costs shall be assessed
in addition to the One Thousand Five Hundred Dollar ($1,500 .00) statutory civil penalty for each
violation .
Pursuant to Section 31 .1 (d)(1) of the Act, 415 ILCS 5/31
.1 (d)(1) (2004), if Respondent fails
to petition or elects not to petition the Illinois Pollution Control Board for review of this Administrative
Citation within thirty-five (35) days of the date of service, the Illinois Pollution Control Board shall
adopt a final order, which shall include this Administrative Citation and findings of violation as
alleged herein, and shall impose the statutory civil penalty specified above
.
When payment is made, Respondent's check shall be made payable to the Illinois
Environmental Protection Trust Fund and mailed to the attention of Fiscal Services, Illinois
Environmental Protection Agency, 1021 North Grand Avenue East, P.O. Box 19276, Springfield,
Illinois 62794-9276. Along with payment, Respondent shall complete and return the enclosed
Remittance Form to ensure proper documentation of payment
.
If any civil penalty and/or hearing costs are not paid within the time prescribed by order of the
Illinois Pollution Control Board, interest on said penalty and/or hearing costs shall be assessed
against the Respondent from the date payment is due up to and including the date that payment is
received. The Office of the Illinois Attorney General may be requested to initiate proceedings
against Respondent in Circuit Court to collect said penalty and/or hearing costs, plus any interest
accrued .
3

 
PROCEDURE FOR CONTESTING THIS
ADMINISTRATIVE CITATION
Respondent has the right to contest this Administrative Citation pursuant to and in
accordance with Section 31 .1 of the Act, 415 ILCS 5/31/1 (2004) . If Respondent elects to contest
this Administrative Citation, then Respondent shall file a signed Petition for Review, including a
Notice of Filing, Certificate of Service, and Notice of Appearance, with the Clerk of the Illinois
Pollution Control Board, State of Illinois Center, 100 West Randolph, Suite 11-500, Chicago, Illinois
60601 . A copy of said Petition for Review shall be filed with the Illinois Environmental Protection
Agency's Division of Legal Counsel at 1021 North Grand Avenue East, P.O. Box 19276, Springfield,
Illinois 62794-9276 . Section 31 .1 of the Act provides that any Petition for Review shall be filed within
thirty-five (35) days of the date of service of this Administrative Citation or the Illinois Pollution
Control Board shall enter a default judgment against the Respondent
.
i S
t'01+
Douglas P. Sc tt, Director
Illinois Environmental Protects
Agency
Prepared by:
Susan E. Konzelmann, Legal Assistant
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
4
Date :
3
/a l
10(o

 
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
V .
)
CLIFFORD LAWSON,
)
Respondent .
)
DATE OF INSPECTION
:
February 17, 2006
DATE REMITTED
:
SS/FEIN NUMBER
:
SIGNATURE
:
NOTE
Please enter the date of your remittance, your Social Security number (SS) if an
individual or
Federal Employer Identification Number (FEIN) if a corporation, and sign this Remittance Form
. Be
sure your check is enclosed and mail, along with Remittance Form, to Illinois Environmental
Protection Agency, Attn
.: Fiscal Services, P.O. Box 19276, Springfield, Illinois 62794-9276 .
REMITTANCE FORM
(IEPA No. 73-06-AC)
RECEIVED
CLERK'S
OFFICE
APR 0 3 2006
STATE OF
ILLINOIS
Pollution Control Board
5
FACILITY :
Henderson/Lawson
SITE CODE NO
.
:
1178055008
COUNTY :
Macoupin
CIVIL PENALTY :
$3,000.00

 
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AFFIDAVIT
IN THE MATTER OF
:
Illinois Environmental
Protection Agency
vs .
Clifford Lawson,
Respondent
.
Affiant, Charles W. King, Jr., being first duly sworn, voluntarily deposes and states as
follows :
1 . Affiant is a field inspector employed by the Division of Land Pollution Control/Field
Operations Section of the Illinois Environmental Protection Agency and has been so
employed at all times pertinent hereto
.
2. On February 17, 2006 between 8 :50 AM and 9:25 AM, Affiant conducted an
inspection of a disposal site operated without an Illinois Environmental Protection
Agency permit, located in Macoupin County, Illinois, and known as Henderson/Lawson
by the Illinois Environmental Protection Agency . Said site has been assigned site code
number LPC# 1178055008 by the Illinois Environmental Protection Agency
.
3. Affiant inspected said Henderson/Lawson open dump site by an on-site inspection,
which included walking and photographing the site
.
4. As a result of the activities referred to in paragraph 3 above, Affiant completed the
Inspection Report form attached hereto and made a part hereof, which, to the best of
Affiant's knowledge and belief, is an accurate representation of Affiant's observations and
factual conclusions with respect to said Henderson/Lawson open dump
.
Charles W. King, Jr .
Subscribed and Sworn To before me
This 9"'day of
?DOG
Notary Public

 
County :
Macoupin
LPC# :
1178055008
Location/Site Name
:
Henderson/Lawson
Date
:
02/17/2006 Time: From 0850
To 0925
Previous Inspection Date :
11/04/2005
ILLINOIS tNVIHUNMtN I AL PHU I tUTION AUtN( ;Y
Open Dump Inspection Checklist
Region
:
5 - Springfield
Inspector(s) :
Charl ie King
Weather :
Sunny, cold, 17 deg . F., WindsNW@10mph
No. of Photos Taken: # 10
Est. Amt. of Waste: 109
yds3
Samples Taken: Yes #
No
217/839-2993
Revised 06/18/2001
(Open Dump - 1)
SECTION
DESCRIPTION
VIOL
1 .
9(a)
CAUSE, THREATEN OR ALLOW AIR POLLUTION IN ILLINOIS
~~
2 .
9(c)
CAUSE OR ALLOWOPEN BURNING
1A
3 .
12(a)
CAUSE, THREATEN OR ALLOW WATER POLLUTION IN ILLINOIS
4 .
12(d)
CREATEAWATER POLLUTION HAZARD
5 .
21(a)
CAUSE OR ALLOWOPEN DUMPING
11
6 .
21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, ORWASTE- DISPOSAL
OPERATION :
(1)
Without a Permit
11
(2)
In Violation of Any Regulations or Standards Adopted by the Board
11
7 .
21(e)
DISPOSE, TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
WASTE INTO THE STATE AT/TO SITES NOT MEETING REQUIREMENTS OF ACT
AND REGULATIONS
OR
8.
21(p)
CAUSE OR ALLOW THE OPEN DUMPING OF ANY WASTE IN AMANNER WHICH RESULTS
IN ANY OF THE FOLLOWING OCCURRENCES AT THE DUMP SITE :
(1)
Litter
~~
(2)
Scavenging
(3)
Open Burning
11
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
(6)
Standing or Flowing Liquid Discharge from the Dump Site
Interviewed
:
Clifford Lawson
Complaint # :
Clifford Lawson
James Gucciardo
Responsible Party
1086
Cordum Avenue
Cahokia Township
Mailing Address(es)
and Phone
Gillespie, IL
62033
Road Commisioner
Number(s) :
217/839-3810
21117
Sunset
Litchfield, IL
62056

 
LPC #
1178055008
Inspection Date :
02/17/2006
Informational Notes
1
.
[Illinois] Environmental Protection Act: 415 ILCS 5/4 .
2 .
Illinois Pollution Control Board : 35 III. Adm . Code, Subtitle G .
3 .
Statutory and regulatory references herein are provided for convenience only and
should not be construed as legal
conclusions of the Agency or as limiting the Agency's statutory or regulatory powers . Requirements of some statutes
and regulations cited are in summary format . Full text of requirements can be found in references listed in 1 . and 2 .
above .
4 .
The provisions of subsection (p) of Section 21 of the [Illinois] Environmental Protection Act shall be enforceable either
by administrative citation under Section 31 .1 of the Act or by complaint under Section 31 of the Act
.
5 .
This inspection was conducted in accordance with Sections 4(c) and 4(d) of the [Illinois] Environmental Protection Act
:
415 ILCS 5/4(c) and (d) .
6 .
Items marked with an "NE" were not evaluated at the time of this inspection
.
Revised 06/18/2001
(Open Dump - 2)
(7)
Deposition
of
General Construction or Demolition Debris; or Clean Construction or
Demolition Debris
10
9 .
55(a)
NO PERSON SHALL :
(1)
Cause or Allow Open Dumpinq
of
Any Used or Waste Tire
10 .
2
812.101(a)
Cause or Allow O•
n Burnin .
of
An Used or Waste Tire
FAILURE TO SUBMITAN APPLICATION FOR APERMIT
OPERATEA LANDFILL
TO DEVELOP AND
~~
11 .
722 .111
HAZARDOUS WASTE DETERMINATION
12 .
808 .121
SPECIAL WASTE DETERMINATION
13 .
14 .
809.302 a
ACCEPTANCE OF SPECIAL WASTE
WASTE HAULING PERMIT, UNIFORM
PERMIT AND/OR MANIFEST
APPARENT VIOLATION OF :
(U)
PCB ;
CASE NUMBER :
FROMAWASTE TRANSPORTER WITHOUT A
WASTE PROGRAM REGISTRATION AND
( ) CIRCUIT COURT
ORDER ENTERED ON
:
15 .
OTHER
:

 
ILLINOIS ENVIRONMENTAL PROTECION AGENCY
MEMORANDUM
DATE :
March 8, 2006
TO :
Land Division File
FROM :
Charlie King, DLPC/FOS - Springfield Region
SUBJECT :
LPC # 1178055008 - Macoupin County
Henderson/Lawson
FOS File
NARRATIVE RE-INSPECTION REPORT DOCUMENT
The purpose of this memorandum is to serve as the Narrative Re-Inspection Report
Document on an inspection conducted at the subject site on February 17, 2006 from
approximately 8 :50 a.m. until 9 :25 a.m., by this author. No one accompanied me on the
re-inspection. The purpose of the re-inspection was to follow-up the initial site inspection
conducted on November 4, 2005 . That initial inspection was conducted because one of
the respondents, Clifford Lawson, was caught in the act burning wire on his property by
this investigator. An inspection was conducted and both Mr. Lawson, the property
owner, and Cahokia Township, where much of the waste is located on a township road,
were deemed the appropriate respondents at the site
.
As mentioned in the original Narrative Inspection Report Document Memorandum to the
Land Division File from this author, dated December 8, 2005, there was no initial outside
complaint . This inspector was in the process of inspecting a property on a health
department complaint across the street, when the resident respondent was observed
setting wire on fire just south of Mine Street in a grassy area . Mine Street is small and
unpaved in that area and could easily be mistaken as a separate driveway . This is because
Henderson is an unincorporated town. However, the respondent was firm that it was not
on his property and was partially on a continuation of Mine Street. Several old piles of
wastes extended eastward on the road and past it where the road ends under the wastes . It
is the belief of this inspector that respondent Lawson is indeed responsible for wastes on
the township property, as someone else would have to pass by his home and go around
two junk trucks that he has parked there, as well as other wastes of his that have been
strung over the Mine Street road and right-of-way . That initial inspection resulted in the
issuance of an Open Dump Administrative Citation Warning Notice issued to two
respondents. One was issued to the property owner, Clifford Lawson and the other to
Cahokia Township. Mr. Lawson never responded to the ACWN as required. The
Township responded, alluded to the wastes being open dumped by Mr . Lawson, and
requested our assistance in taking action against Mr . Lawson .

 
The original inspection report listed the name of the respondents, the location of the site,
at 1086 Cordum Avenue, Henderson (mailing address is the same street address in
Gillespie, IL 62033). Mr. Lawson's telephone number is 217/839-3810 . Mr. James
Gucciardo is the township road commissioner, 21117 Sunset, Litchfield, IL 62056 . His
telephone number is 217/839-2993. Information regarding the Quitclaim Deed, such as
ownership and legal description was presented with the original site inspection report and
will not be repeated herein . A copy of the Deed is in both the Division and DLPC/FOS -
Springfield Region files
.
Upon arrival at the site on the day of the re-inspection, the weather was sunny and cold
with an air temperature of approximately 17° F ., with northwesterly winds at
approximately 10 mph . Surface soil conditions were frozen .
During the re-inspection, 10 digital photographs were taken with a digital camera. They
show the conditions on the day of the re-inspection . From the digital photographs and a
previous inspection report sketch, this author developed a computer-generated sketch of
the site. It shows the approximate layout of the site, as well as the locations and
directions of the re-inspection photos. The digital camera assigns a three-digit number to
each photograph, i .e ., 001, 002 and 003. This is how the numbers of the photographs are
presented herein and in the Digital Photographs. To save space on the Site Sketch, real
numbers have been used,
i .e ., 1, 2, etc. Copies of the Digital Photographs and the Site
Sketch accompany this report
.
The Digital Photographs that were taken on February 17, 2006 show wastes still present
both on Mr. Lawson's property and on the adjacent Cahokia Township Mine Road and
Mine Road right-of-way. The 10 photographs are described as follows
:
Photo # 001 shows the site as seen from Mine Street, just east of the intersection with
Cordum Avenue .
Photo # 002 shows a cluttered yard in the foreground and waste in the background . A
wrecked Chevy S-10 pick-up truck has been placed on Mine Street, immediately south of
Mr. Lawson's property. He admitted it was his truck and that he had recently wrecked it .
Photo # 003 shows a burned spot south of Mine Street, immediately south of Mr
.
Lawson's property, which measured 3' x 3' . This was an area where Mr. Lawson was
caught burning wire during the initial site inspection . The burned wire had been
removed
.
Photo # 004 shows buckets of metals, some dumped on Mine Street, immediately south
of Lawson's property. Mr. Lawson admitted that those buckets and the metals were his
.
The apparently inoperable old green Chevy truck in the background reportedly also
belongs to Mr. Lawson
.
Photo # 005 shows another burned spot, also approximately 3' x 3', in grass immediately
south of Mine Street .
2

 
Photo # 006 shows the apparent junk truck that is the same shown in photo # 003 on
Mine Street
.
.
Photo # 007 shows waste metals, plastics and general household refuse to the north and
east of the junk green Chevy pickup truck shown in photo #s 004 and 006
.
Photo # 008 shows another burned spot on the ground
.
Photo # 009 shows general household refuse, metals, paper, cardboard, plastics and glass,
much of it burned, at the east end of Mine Street . The waste is the background has
vegetation growing in it and appears very old . Some of the waste in the foreground is
very recent
.
Photo # 010 shows the pile of the recently placed waste, shown in the foreground of
photo # 009. It is shown here from another angle, looking towards Mr . Lawson's
property .
During the inspection, apparent violations of the Act and the regulations, Title 35, Illinois
Administrative Code, Subtitle G (35 IAC) were observed. Those apparent violations of
the Act, include Sections : 9(a), 9(c), 21(a), 21(d)(1), 21(d)(2), 21(e), 21(p)(1), 21(p)(3)
and 21(p)(7). An apparent violation of the Act, Section 55(a)(1) that was alleged during
the initial site inspection is no longer alleged, because waste tires were not observed
during the re-inspection. Upon inquiry, Mr. Lawson stated that he put some of them in
his garage and doesn't know what happened to the rest of them . There were only about
10 used tires observed during the initial site inspection . An apparent violation of the
regulations, 35 IAC was Section 812 .101(a). The Open Dump Inspection Checklist that
accompanies this report provides additional information
.
OTHER COMMENTS
1. Upon arrival at the site, Mr . Lawson came outside of his home to find out what I
was doing. I told him I was re-inspecting the properties and asked why he had not
responded to the ACWN. He told me that he didn't know he had too. I told him
that his ACWN clearly states that he must respond in writing . He replied that he
didn't read very good. I told him then he should have had someone else read it to
him .
He was very adamant that wastes at the end of and around Mine Road were not
his, and that it was township property and he did not dump wastes there. I told
him that if someone else dumped there, they would have had to likely go past his
house. I asked why he would think that someone else would dump waste so close
to his house. He said he didn't know but it wasn't his. However, when I asked
who owned the two junk trucks on Mine road, next to his house, and who owned
the metal dumped from the five-gallon buckets that were there, he stated that
those were his
.
3

 
2. No one else approached me during the inspection
.
CK
cc: DLPC/FOS - Springfield Region
Macoupin County, Cahokia Township Road Commissioner, James Gucciardo
Verticchio & Verticchio, Attorneys at Law, Rick Verticchio
4

 
A digital camera was used for the Inspection photos . Distances are approximate -Not drawn to scale
Cordum Avenue
Lawson
home
10806 Cordum
Avenue
Garage
LEGEND
2->
- Denotes location and direction of photo
.
-
S.-W
veccrk
Open dumping
Open Burning
Mine Street
SITE SKETCH
Site name :
Henderson/Lawson
County :
Macoupin
LPC # :
1178055008
Date
:
February 17, 2006
Inspector :
Charlie King
Time :
8:50 a.m . - 9:25 a.m .

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 0178055008-02172006-[Exp . #I.jpg
Page 1 of 5
LPC # 1178055008- Macoupin County
Henderson/Lawson
FOS File
Date: February 17, 2006
Time: 9:06 a.m .
Direction: E
Photo by: Charlie King
Exposure #: 001
Comments: The site as
seen from Mine Street,
just east of the
intersection with
Cordum Avenue .
Date: February 17, 2006
Time: 9:13 a.m .
Direction: E
Photo by: Charlie King
Exposure #: 002
Comments: A cluttered
yard in the foreground
and waste in the
background. A
wrecked Chevy S-10
pick-up truck has been
placed on Mine Street,
immediately south of
Mr. Lawson's property .
He admitted it was his
truck and that he had
recently wrecked it .

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 0178055008-02172006-[Exp . #].jpg
Page 2 of 5
LPC # 1178055008- Macoupin County
Henderson/Lawson
FOS File
Date: February 17, 2006
Time: 9:14 a.m .
Direction : E
Photo by: Charlie King
Exposure #: 003
Comments: A burned
spot south of Mine
Street, immediately
south of Mr. Lawson's
property, measured 3'
x 3'. This was an area
where Mr. Lawson was
caught burning wire
during the initial site
inspection. The
burned wire had been
removed .
Date: February 17, 2006
Time: 9:14 a.m .
Direction: NE
Photo by: Charlie King
Exposure #: 004
Comments: Buckets of
metals, some dumped
on Mine Street,
immediately south of
Lawson's property. Mr.
Lawson admitted that
those buckets and the
metals were his. The
apparently inoperable
old green Chevy truck
in the background
reportedly also
belongs to Mr. Lawson .

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 0178055008-02172006-[Exp. #].jpg
Page 3 of 5
LPC # 1178055008- Macoupin County
Henderson/Lawson
FOS File
Date: February 17, 2006
Time: 9:15 a.m .
Direction: S
Photo by: Charlie King
Exposure #: 005
Comments: Another
burned spot, also
approximately 3' x 3',
in grass immediately
south of Mine Street .
Date: February 17, 2006
Time: 9:17 a.m .
Direction: E
Photo by: Charlie King
Exposure #: 006
Comments: The
apparent junk truck is
the same shown in
photo # 003 on Mine
Street .

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 017805500802172006-[Exp. #].jpg
Page 4 of 5
LPC # 1178055008- Macoupin County
Henderson/Lawson
FOS File
Date: February 17, 2006
Time: 9:17 a.m .
Direction : E
Photo by: Charlie King
Exposure #: 007
Comments: Waste
metals, plastics and
general household
refuse are shown to the
north and east of the
junk green Chevy
pickup truck shown in
photo #s 004 and 006.
Date: February 17, 2006
Time: 9:18 a.m .
Direction: W
Photo by: Charlie King
Exposure #: 008
Comments: Another
burned spot on the
ground .

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 0178055008-02172006-[Exp. #].jpg
Page 5 of 5
LPC # 1178055008- Macoupin County
Henderson/Lawson
FOS File
Date: February 17, 2006
Time: 9:19 a.m .
Direction: SE
Photo by: Charlie King
Exposure #: 009
Comments: General
household refuse,
metals, paper,
cardboard, plastics and
glass, much of it
burned, at the east end
of Mine Street The
waste is the
background has
vegetation growing in it
and appears very old .
Some of the waste in
the foreground is very
recent .
Date: February 17, 2006
Time: 9:20 a.m .
Direction: NW
Photo by: Charlie King
Exposure #: 010
Comments: The pile of
the recently placed
waste, shown in the
foreground of photo #
009, is shown here
from another angle,
looking towards Mr.
Lawson's property.

 
PROOF OF SERVICE
I hereby certify that I did on the 31st day of March 2006, send by Certified Mail, Return Receipt
Requested, with postage thereon fully prepaid, by depositing in a United States Post Office Box a true
and correct copy of the following instrument(s) entitled ADMINISTRATIVE CITATION,
AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST
To
:
Clifford Lawson
1086 Cordum Avenue
Gillespie, IL 62033
and the original and nine (9) true and correct copies of the same foregoing instruments on the same
date by Certified Mail, Return Receipt Requested, with postage thereon fully prepaid
To
:
Dorothy Gunn, Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
t
Michelle M Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois
62794-9276
(217) 782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER

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