RER E
's
C
O
IVE
D
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MEMORIAL HOSPITAL
)
APR 4 2006
STATE OF
j
ILLINOIS
ILLINOIS
Pollution Control Board
Petitioner,
P
(Permit Appeal - Air)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
JOINT PETITION FOR EXTENSION OF TIME OF INITIAL APPEAL PERIOD
Petitioner, MEMORIAL HOSPITAL ("Memorial" or the "Hospital") and the ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY ("IEPA") submits this Joint Petition for
Extension of Tinme of Initial Appeal Period ('Joint Petition") pursuant to 415 ILCS 5/40 .2
relating to Memorials renewal application for a Clean Air Act Permit Program ("CAAPP")
permit. In support of this Joint Petition, MEMORIAL and IEPA state the following
:
On or about October 12, 2004, Memorial submitted to IEPA an application to
renew its CAAPP permit, which was received by IEPA shortly thereafter
.
2
.
Section 39.5(j) of the Illinois Environmental Protection Act ("Act") generally
provides, among other things, that IEPA has 18 months after the date of a complete renewal
CAAPP permit application has been submitted to issue or deny an applicant's CAAPP permit . If
]EPA has neither issued nor denied a CAAPP permit. the applicant may petition the Illinois
Pollution Control Board ("IP('B") to contest the IEPA's failure to take action . 415 ILCS 5/40.2
.
To date, IEPA has neither issued nor denied a renewal CAAPP permit to
Memorial based on its renewal APP permit application
.
Memorial and IEPA submit this Joint Petition to extend the 35 day initial appeal
period by 90 days. The parties request that the IPCB allow the Hospital until June 9, 2006, or as
otherwise provided in the Act, to file an appeal based on IEPA's action discussed herein
.
WHEREFORE, MEMORIAL and IEPA respectfully request the [PCB to grant an extension
of the initial appeal period as noted herein
.
Dated: April 14, 2006
Respectfully submitted,
MEMORIAL HOSPITAL
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
.l(6 fy l
Rohb H .
nan
Thor W. Ketzback, Esq
.
Bell, Boyd & Lloyd LLC
Three First National Plaza
70 West Madison Street
Chicago, Illinois 60602
Telephone: 312.372.1121
Facsimile : 312 .827.8000
MEMORIAL HOSPITAL
)
BELLEVILLE, ILLINOIS
)
Petitioner,
)
v
.
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent .
)
41
7564'E2
Thor W. Ketzback
Thor W. Ketzback, Esq
.
Bell, Boyd & Lloyd LLC
Three First National Plaza
70 West Madison Street
Chicago, Illinois 60602
Telephone: 312.372.1121
Facsimile : 312.827,8000
RER
:,EoVer)
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR
1 4 2006
STATE OF ILLINOIS
Pollution
Control
Board
NOTICE OF FILING
TO
:
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
PLEASE TAKE NOTICE that 1 have today filed with the Office of the Pollution Control
Board the JOINT PETITION FOR EXTENSION OF TIME OF INITIAL APPEAL PERIOD,
copies of which are herewith served upon you
.
(Permit Appeal - Air)
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached JOINT PETITION FOR
EXTENSION OF TIME OF INITIAL APPEAL PERIOD by depositing said document in the
United States Mail in Chicago, Illinois on April 14, 2006, upon : the following persons
:
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
417564/E)2
Thor W. Ketzba
