1. NOTICE OF FILING
      2. • CERTIFICATE OF SERVICE
      3. MOTION TO CONSOLIDATE
GREAT LAKES DREDGE &
DOCK COMPANY, a New Jersey
Corporation,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
GREAT LAKES DREDGE &
DOCK COMPANY, a New Jersey
Corporation,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA FIRST CLASS MAIL)
Division ofLegal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
(VIA FIRST CLASS MAIL)
R
~JVED
CLt~9~?’~-QFFICE
MAR ~~O4
STATE OF ILUNOIS
PoUution Contro’ Board
Petitioner,
V
Respondent.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
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)
)
)
)
)
)
PCB No. 04-143
)
(UST Appeal)
)
)
)
)
PCB No. 04-145
(UST Appeal)
Petitioner,
V.
)
)
)
)
)
)
)
)
)
)
)
Respondent.
)
THIS FILING SUBMITTED ON RECYCLED PAPER
PLEASE TAKENOTICE that I have today filed with the Office of the Clerk of
the Illinois Pollution Control Board an original and nine copies ofa
MOTION TO
CONSOLIDATE,
copies ofwhich are herewith served upon you.
Respectfully submitted,
GREAT LAKES DREDGE &
DOCK COMPANY,
Petitioner,
By:_______________________
J. Ra1fdle Schick
Dated: March 26, 2004
J. Randle Schick
Of Counsel
HODGE DWYER ZEMAN
3150 Roland Avenue
• Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
•
CERTIFICATE OF SERVICE
I, J. Randle Schick, the undersigned, certify that I have served the attached
MOTION TO CONSOLIDATE upon:
Ms. Dorothy M. Guim
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
Division ofLegal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
by depositing said documents in the United States Mail in Springfield, Illinois, postage
prepaid, on March 26, 2004.
• J. R~idleSchick
GLDD:OO1/Fil/NOF
—
Motion to Consolidate
RECE~VEDCLERK’S
OFFIC
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAR
29 2OO~
GRE~J4\~REDGE &
)
a New Jersey
)
orporation,
)
)
Petitioner,
)
)
v.
)
PCB No. 04-143
)
(UST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
GREAT LAKES DREDGE &
)
DOCK COMPANY, a New Jersey
)
Corporation,
)
)
Petitioner,
)
)
v.
)
PCB No. 04-145
)
(UST Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
•
)
)
Respondent.
)
MOTION TO CONSOLIDATE
NOW COMES Petitioner, GREAT LAKES DREDGE & DOCK COMPANY
(“Petitioner”), by and through its attorneys, HODGE DWYER ZEMAN, and pursuant to
35 Ill. Admin. Code Part 10 1.406, hereby moves to consolidate an appeal (PCB 04-145)
that is being filed on this date with another appeal (PCB 04-143) ofthe Illinois
Environmental Protection Agency’s (“Agency”) determination that was filed on
February 23, 2004. In support ofthis Motion, the Petitioner states as follows:
1
1.
On February 23, 2004, Petitioner filed an appeal with the Illinois Pollution
Control Board (“Board”) regarding Petitioner’s leaking underground storage tank
(“UST”) facility at 9320 South Ewing Avenue, Chicago, Cook County, which the Board
assigned Docket Number PCB 04-143.
2.
One additional UST appeal arising from the same site is being filed at the
same time as this Motion to Consolidate.
• 3.
Both appeals involve an Agency denial ofcost reimbursement from the
Leaking Underground Storage Tank Trust Fund to perform corrective action activities in
regards to the same underground storage tanks formerly located at the above-referenced
facility and owned by Great Lakes Dredge & Dock Company.
4.
Both Agency determinations apply, therefore, to closely related facts.
5.
Because the factual basis of the two petitions are closely related,
consolidating both petitions will be more convenient to the Board, Agency and Petitioner.
Consolidation will also result in a more expeditious and complete determination ofthe
claims and would not cause material prejudice to any party. Further, consolidation ofthe
claims will provide for a more efficient administration ofjustice and reduce duplication
ofefforts that would be required if the appeals were handled separately.
2
WHEREFORE, Petitioner, GREAT LAKES DREDGE & DOCK COMPANY,
respectfully asks that the Illinois Pollution Control Board consolidate its two Petitions for
Review ofthe Illinois Environmental Protection Agency’s determinations.
Respectfully submitted,
GREAT LAKES DREDGE &
DOCK COMPANY,
Petitioner,
By:
J.
/4W
Randly~chick
Dated: March 26, 2004
J. Randle Schick
Of Counsel
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
GLDD:OOl/Fil/Motion to Consolidate
3

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