1. RECEIVED
P~2
Av~r—O9.O3 OB:36P
BEFORE
THE
ILLINOIS POLLUTION CONTROL BO~DCE~VEDCLERK’S OFFTC~E
CITY OF KANKAKEE,
)
~
-&~2OO3
Petitioner,
)
)
PCB
03-125
PollutionSTATE
OFControlILLiNOISBoard
COUNTY OF KANKAKEE,
)
(Third-Party Pollution Control Facility
COUNTY BOARD OF KANKAKEE,
)
Siting Appeal)
and WASTE MANAGEMENT OF
)
ILLINOIS, INC.
)
Respondents.
)
MERLIN KARIOCK,
)
Petitioner,
)
vs.
)
PCB03133
COUNTY OF KANKAKEE, COUNTY )
(Third-Party Pollution Control Facility
BOARD OF KANKAKEE, and WASTE )
Siting Appeal)
MANAGEMENT OF ILLINOiS, INC.
)
Respondents.
)
MICL~AELWATSON,
)
Petitioner,
)
vs.
)
PCB03-134
COUNTY OJ~KANKAKEE, COUNTY )
(Third-Party Pollution Control Facility
BOARD OF KANKAKEE, and WASTE
)
Siting Appeal)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents.
KEITH RUNYON,
Petitioner,
)
vs.
)
FCB03-135
COUNTY OF KANKAKEE, COUNTY
)
(Third-Party Pollution Control Facility
•ROARD OF KANKAKEE, and WASTE
)
Siting Appeal)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents.
)
WASTE MANAGEMENT OF ILLINOIS,)
INC.,
)
Petitioner,
)
vs.
)
PCB03-144
COUNTY OF KANKAKEE,
)
(Poltutlon Control Facility Siting Appeal)
Respondent.
)
Apr-09-03
08:37P
P.03 ~
KEITH RUNYON’S RESPONSE TO COUNTY OF KANKAKL1~S
~NS~RS
TO HIS INTERROGATORIES.
With the exception County’s reply to Interrogatory No. 1. the County’s replies to
Rtinyon’s Interrogatories numbered (2) two through(10) ten are non-responsive.
All Interrogatories are appropriate to discover the communications, as defined in
Runyon’s Interrogatory petition, consistent with his flhingwhich alleges that The
County and Waste Management failed to comply with the County’s Solid Waste
Management plan. A discovery of the complete information surrounding the
Public Comment statements entered into the Record by Lee Eddleinan of Waste
Management, on January 6, 2003 at approximately I:S4 P.M. and filed with the
Kanicakee County Clerk at the Office ofthe County Clerk. A copy of said document
is attached.
Waste Management opened this avenue to discovery by its tiling of said Statement
In the Public Comment period at such a time as to provide no opportunity for
discovery or cross examination.
It is therefore requested that both Waste Management of Illinois and the County of
Kankakee, honor Runyon’s interrogatories in full and completely
Respectfully ubmitted,
Keit~unyo~(T7
1165 Plum Creek Drive, Unit 0.
Rourbonnais, Illinois, 60914
81~
937
9838
Apr-09-03 08:37P
p~4
#~
~~3/~/a
FILED
WThMA*~IMENT
03 JAN —6 PH I:
WASTE MANAQEMENT
/7
Chicago
Market Area
/r2_~i~_~_
~
720 E. Butterfield Road
lnbar~,1L60148
t~AN1( ‘
(630) 572-5800
•
0
,.~
(630)2l~-J7LIP~
)anuary6, 2003
Mr. Bruce Clark
County Clerk
County
of
Kankakee
189 East
Court
Street
Kankakee,
Illinois 60901
Dear
Mr. Clark:
Waste Management
of Illinois, Inc would
like to take this opportunity to
stipulate
the
following information regarding contact with property owners surrounding the present
Kankakee County andfili and our proposed expansion of that site. During the recent
public hearings on the expansion of this facility, Attorney Kenneth Bleyer stated that
Waste Management had made no effort to comrniuiicate with area homeowners to inform
them of our expansion plans and offer them a forum for citizen InpuL This assertion
belies the facts of this matter and I offer the following information to refute this
erroneous
allegation.
My initial communication efforts began in March of 2000 due to discussions with
the
Hamilton family regarding reinstating property options on parcels they owned adjacent to
the present Kankakee County landfill. Those exploratory discussions were initiated with
the Hamilton’s attorney, David J’affe. in 2001, those option discussionswere expanded to
include other substantial properties owned by Mrs. Meh.rer, Mr. Watson, Mrs. Dwan
(Ago Farm
Management),
Mr. Fager and Mr. Flageole. In addition, discussions with
individual single-family homeowners and commercial enterprises were begun in April of
2001 and continue until this day. More specifically, every single family domicile within
I ,500 feet of the proposed expansion has received notice of our intent to provide real
estate and well water protection guarantees if we are successful in permitting the
expansion of th~existing site. I also offer the following Information to substantiate my
efforts regarding communication with our neighbors, residents of Otto Township and
citizens ofKankakee County:
• I have had personal conversations with the majority of the homeowners on the
periphery of the proposed expansion, (Please See the attached partial list of
those contacts.)
• On or about January
15,
2002~ I conducted an evening informational
presentation for all of the property owners on 7500 South Rd. and 1000 East
Road at the home ofMike and Elese Smith. Seven neighboring families were in
attendance.
Apr-09-03
08:37P
P.05
W*WTE
MAMA~G~MINT
• Waste Management held an open house receptionlpresentation/tour at
the
Kankakee County landfill on June 13, 2002 for all of
our neighbors surrounding
the landfill
and
the proposed expansion. Thirty individuals attended this event.
(Please see the attachedphotographs.)
• Waste Management sponsored a Fall Festival picnic for residents of Otto on
November 2, 2002 at Rose Perkins home. Fifty adult~and children attended the
event
as well as the Otto Township
Fire
Department.
• T personally conducted three tours of the facility for Otto Township and
the
Chebanse school system in 2002.
• Waste Management has paid for advertisements in the Kanicakee
Daily
Journal
and the Herald newspapers explaining our intentions
to
expand the site. Also,
our
expansion efforts have been the topic of countless newspaper articles since
2001.
•
.1 have conducted numerous interviews with radio stations WKAN and WVLI to
discuss
this
matter. We have also sponsored weather
forecasts and salutations
to
local sports teams.
• We
have made formal presentations to the E~conomicDevelopment Council, the
River
Valley
Forum,
the
Kankakee Chamber of Commerce and
the Bradley!
Bourbonnais Chamber of Commerce.
• We’ve met with the County Engineer’s office, the SherifF’s Department~,the
County Health Department, the Otto Township Fire Department and the
Township Highway Commissioner.
• We even participated in the Kankakec County 4H livestock auction and
purchased an animal raised by Todd and Coleen Benjamin~s son.
The
Benjamins are one of our neighbors at the existing landfill,
These statements are a true and accurate representation ofWaste Management’s efforts to
inform and elicit comments from our neighbors and other interested parties throughout
Kankakee County. I pers’onafly engaged in these conversations, made the presentations,
conducted the open house, participated in the tours and foniiatted the advertisements that
I have described. I am confident that Waste Management of Illinois, Inc. has made every
possible effort to keep the community apprised ofour Intentions for this facility.
Sincerely,
Le Addleman
Vice PresidentlBusiness Development
Waste Management of Illinois, Inc.
Apr~-09-03 08:38P
P.06
Ruby Sparenberg
875 E. 6000 S. Road
Chebanse, IL 60922
Mrs. Mehrer
487 W. Chebanse Avenue
Chebanse, IL 60922
Todd Benjamin
768 E. 6000 S. Road
Chebanse, IL 60922
E. Ray Stanley
.6563-A S. Rt. 45-52
Chebanse, IL 60922
Agro Farm Management P.O. Box 335
Osage, IA 50461
Cliff Schroeder
6725 S. Rt. 45-52
Chebanse, IL 60922
Carlos Cooley
1260
North
Convent
Bourbonnais, IL 60914
Leland Milk
6930 S. Rt. 45-52
Chebanse, IL 60922
Elmer Fagor
3304 West 6000 S. Road
Chebanse, IL 60922
Joseph CuIk~n
7426 S. Rt. 45-52
Chebanse, IL 60922
Albert Cote
271 E. 7500 S. Road
Chebanse, IL 60922
Doug Flageole
427 E. 7500 S. Road
Chebanse, IL 60922
Edwin Hamilton
P.O. Box 426
Bourbonnais, IL 60914
Pat Buescher
600 E. 7500 South Road
Chebanse, IL 60922
Don & Diane Macaluso . E. 7500 South Road & 1000 East Road
Mike & Elese Smith
E. 7500 South Road & 1000 East Road
Apr-09-03 O8:38P
P.07
~~DAVIT OF SERVIc.E
The undersigned. pursuant to the provisions of Secton 1-109 of the Illinois Code of
Civil Procedure, hereby under penalt.y perjury under the Laws of the United States of
America, certifies that on April JO , 0:3 was served a copy of the foregoing was served
upon via Facirnile Transmission and by letter:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago. 11 60601-3218
Attorney George Mueller
501
State Street
Ottawa,
11 61350
815
433 4705
Fax 815 422 4913
Donald 3. Moran
Perterson & Houpt
161
North
Clark Street,
Suite 3100
Chicago, II
60601-3242
312261 2149
Fax312 261 1149
Flizabeth Harvey, Esq.
Swanson,
Martin, & Bell
One IBM Plaza,
Suite
2900
330
North Wabash
Chicago, 11 60611
312321 9100
Fax312 321 0990
Kenneth A Leshen
One Dearborn Square, Suite
550
Kankakee, 11.
60901
815 933
3385
Fax 933 3397
L.
Patrick Power
956
North
Fifth Avenue
Kankakee, 11
60901
815
937 6937
Fax 937 0056
Apr-09—03 08~38P
P.08
Jennifer
J. Sackett Pohlenz
175 W. Jackson Boulevard
Suite 1600
Chicago, 11 60604
3125407540
Fax 312 540
0578
Kenneth
A. Bleyer
923
Gordon
Terrace, #3
Chicago, II
60613
773 348 4005
Fax
773 527
2873
•
Mr.
Brad
1-lalloran
Heating Officer
Tilinois Pollution Control Board
I 0() West.Randolph, I i~’
Floor
Chicago, 11. 60601
3128148917
Fax 814 3~9
By depositing a copy thereof, enclosed
in an envelope in the United States Mail at
kockiord, Illinois, proper
postage prepaid, before the hour of
5:00 P.M., addressed as
above.
)
,~-.
-‘--I--.-
~..
t•
~
~
Keith
Runyon
1 165 Plum Creek
Dr.
Unit D.
Bourbonnais, IL 60914
8159379838
Apr-09-03 08:36P
P.01
Fax Numbers
Attorney George Mueller
f
433 4913 phone 433 4705
Donald J.
Moran f
312 261 1149 phone 312 261 2149
Elizabeth Harvey f 312 321 0990 312 321 9100
KennethLeshen f9333397phone933 3385
L. Patrick Power f 937 0056 phone 937 6937
Jcnneifcr Sackett Pohlenz 312 540 0578 phone 312 540 0578
312
54()
7619 Legal Secretary.
Kenneth Bleyer fax 773
527
2873
PatOdell
Mr. Brad Halloran Hearing Officer f312 814 3669 phone 312 814 8917
Heisten and Porter f81 5 490 4901 phone 490 4900
RECEIVED
CLERK’S OFFICE
/~Pi? 92003
STATE OF IWNo~
Pollutj0,~Contro/
Board
FROM:
KEITH RUNYON FAX
815 937
9164
PHONE
815
937 9838

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