BEI<'ORETHE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF:
    RANDY GRANT
    DONALD GRANT
    PATRICIA WALLACE
    Complainants,
    v.
    MACH MINING LLC
    Respondent
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    ANSWER
    PCB 2007- I45
    NOW COMES Respondent MACH MINING LLC by and through its attorneys, Sorling,
    Northrup, Hanna, Cullen
    &
    Cochran, Ltd., Charles J. Northrup, of counsel, and hereby answers
    the Complaint in the above captioned matter.
    1.
    Introduction
    The Complaint filed in this matter is a form Complaint provided to Complainants by the
    Illinois Pollution Control Board. In certain respects the Complaint form and the manner in
    which it was completed does not facilitate the specific admission or denial
    of facts required by an
    Answer. Although Respondent will Answer eaeh
    of the numbered items in the Complaint, it
    must be made clear from the outset that Respondent specifically denies all allegations
    of
    violations.
    II.
    Answer
    I.
    Respondent neither admits nor denies the information set out at numbered item I
    as it has insufficient knowledge to form a belief as to accuracy.
    {S0551929,2 8/16/2007 CJN CJN}
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    Electronic Filing, Received, Clerk's Office, August 16, 2007
    2.
    Respondent neither admits nor denies the information set out at numbered item 2
    as it has insufficient knowledge to form a belief as to accuracy.
    3.
    Respondent admits that numbered item 3 sets out the correct address
    of Mach
    Mining LLC.
    4.
    Respondent admits that numbered item 4 sets out the type
    of business and activity
    of Respondent.
    5.
    Respondent denies that it has violated those sections
    of the Illinois Environmental
    Protection Act and associated administrative rules set out at numbered item
    s.
    6.
    Respondent denies the factual allegations of the "type of pollution" set out in
    numbered item 6.
    7.
    Respondent denies the factual allegations
    of the "duration and frequency of the
    alleged pollution" set out in numbered item 7.
    8.
    Respondent denies the factual allegations
    of "bad effects" of the alleged pollution
    set out in numbered item 8.
    9.
    Respondent denies the need for any
    "relief' sought by Complainant's as set out in
    numbered item 9.
    10.
    Respondent neither admits nor denies the information set out at numbered item
    10 as it has insufficient knowledge to form a belief as to accuracy.
    II.
    Respondent neither admits nor denies the information set out at numbered item II
    as it has insufficient knowledge to form a belief as to accuracy.
    12.
    (Numbered item 12 is blank and therefore Respondent makes no Answer as to it.)
    {S0551929.2 8//6/2007CJNCJN}
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    on Recycled Paper
    Electronic Filing, Received, Clerk's Office, August 16, 2007
    Ill.
    AFFIRMATIVE DEFENSES
    As
    Respondent's investigation into this matter proceeds it may identify affirmative
    defenses. Consistent with Board Rule 103.204(d), as affirmative defenses are identified they will
    be set out in a supplemental Answer prior to hearing. Accordingly, Respondent expressly does
    not waive any available affirmative defenses it may now, or in the future, have.
    Respeetfully submitted
    MACH
    MINING LLC
    One
    of its attorneys
    Sorting, Northrup, Hanna,
    Cullen
    &
    Coehran, Ltd.
    Charles 1. Northrup,
    of Counsel
    Suite 800 Illinois Building
    P.O. Box 5131
    Springfield, IL 62705
    Telephone: (217) 544-1144
    Facsimile: (2 I 7) 522-3173
    {S0551929.28/1612007CJNCJNj
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    Printed on Recycled Paper
    Electronic Filing, Received, Clerk's Office, August 16, 2007
    I)ROOF OF SERVICE
    The undersigned hereby certifies that a copy
    of Respondent's Answer to Complaint was
    served by U.S. mail addressed:
    Ms. Patricia Wallace
    17235 Liberty School Road
    Marion, IL 62959
    Mr. Randy Grant
    17235 Liberty School Road
    Marion, IL 62959
    Mr. Donald Grant
    17712 Dean Road
    Johnston City, IL 62951
    with all postage prepaid on the
    {S05519292 8/16/2007 CJN CJN}
    Ie:
    r~'-
    day of_---1'---
    , 2007.
    4
    Printed on Recycled Paper
    Electronic Filing, Received, Clerk's Office, August 16, 2007

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