ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
1021
NORTH GRAND
AVENUE EAST,
P.O. Box
19276,
SPRINGFIELD,
ILLINOIS
62794-9276
- (21
JAMES
R.
THOMPSON CENTER,
100
WEST RANDOLPH,
SUITE 11-300,
CHICAGO,
IL
60601 - (312)
814-6026
PAT
QUINN, GOVERNOR
DOUGLAS
P. SLoll,
JIRECTOR
MAY29
2809
STATE
OF
ILLINOIS
Pollution Control
Board
(217) 782-9817
TDD: (217)
782-9143
May27, 2009
L1
John
Therriault,
Clerk
I
‘
Illinois
Pollution
Control
Board
James
R. Thompson
Center
100 West
Randolph
Street, Suite
11-500
Chicago,
Illinois
60601
-
Re:
illinois
Environmental
Protection
Agency
v. Ameren
Energy
Generating
Company,
Ameren
Corporation
and Jerry
Simpson
IEPA File No.
103-09-AC;
05702551
97—Fulton
County
Dear
Mr. Therriault:
Enclosed
for filing
with
the Illinois
Pollution
Control
Board,
please find
the original
and
nine
true and
correct
copies
of the
Administrative
Citation
Package,
consisting
of the
Administrative
Citation, the
inspector’s
Affidavit,
and the
inspector’s
Illinois Environmental
Protection
Agency
Open
Dump
Inspection
Checklist,
issued
to the
above-referenced
respondent(s).
On this
date, a copy
of the Administrative
Citation Package
was sent to
the
Respondent(s)
via
Certified
Mail. As
soon
as I receive
the
return
receipt,
I will promptly
file a
copy with
you,
so
that the Illinois
Pollution
Control Board
may
calculate
the thirty-five
(35) day
appeal
period
for
purposes
of
entering a
default
judgment
in the
event
the
Respondent(s)
fails
or
elects not
to
file a
petition
for review
contesting
the Administrative
Citation.
If you
have
any questions
or
concerns,
please
do not
hesitate to
contact
me
at the
number above.
Thank
you for
your cooperation.
JJJU
Michelle M.
Ryan
Assistant
Counsel
Enclosures
ROCKFORD
— 4302
North Main Street,
Rockford,
IL 61103
— (815)
987-7760
.
DES PU\INES
— 9511 W.
Harrison
St., Des
Plaines,
IL 60016
— (847) 294-4000
ELGIN
—595 South State,
Elgin, IL 60123
—(847)
608-3131
PEORIA
—5415
N. University
St., Peoria,
IL
61614 —(309)
693-5463
BUREAU
OF LAND-PEORIA
- 7620 N.
University St.,
Peoria,
IL 61614
-(309) 693-5462
CHAMPAIGN
—2125 South First
Street, Champaign,
IL 61820
-(217)
278-5800
COLLINSVILLE
— 2009
MalI
Street,
Collinsville,
IL 62234
— (618) 346-5120
.
MARION
— 2309
W. Main
St.,
Suite
116,
Marion,
IL 62959
— (618) 993-7200
PRINTED
ON
RECYCLED
PAPER
V.
AMEREN ENERGY
GENERATING
COMPANY,
AMEREN CORPORATION,
and JERRY
SIMPSON.
Respondents.
NOTICE
OF FILING
To:
Ameren Energy
Generating Company
James A. Tisckos,
Registered Agent
17751
North Cilco
Road
Canton,
IL 61520
Jerry
Simpson,
Certified
Operator
300
Sur
Woods Drive
Effingham, IL
62401
Ameren
Corporation
James
A. Tisckos,
Registered
Agent
1901
Chouteau
MC-602
St.Louis,MO
63103
Illinois
Environmental Protection
Agency
1021
North
Grand Avenue
East
P.O.
Box 19276
Springfield, Illinois
62794-9276
(217)
782-5544
Dated: May 27, 2009
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
RECEVED
CLERK’S
OFFICE
MAY29
2009
STATE
OF
ILLINOIS
Pollution
Control
Board
)
AC
)
)
(IEPA
No. 103-09-AC),—
1
1
r
)
)
)
)
)
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.
R pectfully
submitted,
Assistant
Counsel
THIS FILING
SUBMITI’ED ON RECYCLED
PAPER
CLERK’S
OFFICE
MAY
292009
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
STATE
OF
ILLINOIS
Pollution
Control
Board
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
)
PROTECTIONAGENCY,
)
)
—
Complainant,
)
AC
)
(IEPA No.
103-09-AC)
v.
AMEREN
ENERGY
GENERATING
)
COMPANY,
AMEREN
CORPORATION,
and
JERRY
SIMPSON.
)
Respondents.
)
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 (2006).
FACTS
1.
That Ameren
Corporation
is
the permitted
owner,
Ameren
Energy
Generating
Company
is the
permitted
operator,
and Jerry
Simpson
is the
Chief
Operator
in responsible
charge
(collectively
“Respondents”)
of
a
facility
located
at
17751 North
Cilco
Road,
Canton,
Fulton
County,
Illinois.
2.
That
said
facility
is a sanitary
landfill,
operating
under Illinois
Environmental
Protection
Agency
Permit No.
2005-121-LF,
and is
designated
with
Site
Code No.
0570255197.
The
facility
is
commonly
known
to
the
Illinois
Environmental
Protection
Agency
as
Ameren
Duck
Creek
Station
LF.
3.
That
Respondents
have
owned/operated
said
facility
at
all
times pertinent
hereto.
I
4.
That
on April 9,
2009, Robert
J.
Wagner
of the
Illinois
Environmental
Protection
Agency’s
Peoria
Regional
Office inspected
the above-referenced
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
Robert J. Wagner
during
the
course
of his
April
9,
2009
inspection
of
the
above-referenced
facility,
the
Illinois Environmental
Protection
Agency
has
determined
that
Respondents
violated
the Illinois
Environmental
Protection
Act
(hereinafter,
the
“Act”) as follows:
(I) That
Respondents
conducted
a
sanitary
landfill
in
a
manner
which resulted
in
acceptance
of wastes
without necessary
permits,
a violation
of Section
21 (o)(7)
of the
Act, 415
ILCS 5/21
(o)(7) (2006).
(2)
That
Respondents
conducted
a
sanitary
landfill
in a manner
which
resulted
in
deposition
of
refuse
in an unpermitted
portion
of the
landfill,
a violation
of Section
21 (o)(9)
of the
Act,
415 ILCS 5/21
(o)(9) (2006).
(3)
That
Respondents
conducted
a
sanitary
landfill
in
a
manner
which resulted
in
failure
to
submit
reports
required
by permits
or
Board
regulations,
a
violation
of Section
21
(o)(1 1)
of the Act,
415 ILCS
5/21
(o)(1
1) (2006).
CIVIL
PENALTY
Pursuant
to
Section
42(b)(4)
of the
Act,
415 ILCS
5142(b)(4)
(2006),
Respondents
are
subject
to a
civil penalty
of Five
Hundred Dollars
($500.00)
for
each of
the
violations
identified
above,
for a total
of
One
Thousand
Five Hundred
Dollars
($1,500.00).
If Respondents
elect
not to
petition
the
Illinois Pollution
Control
Board,
the
statutory
civil
penalty specified
above
shall
be
due
and
payable
no later
than
June 30,
2009,
unless
otherwise
provided
by
order
of
the
Illinois
Pollution
2
Control Board.
If
Respondents
elect 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
(2006), and if the
Illinois
Pollution
Control
Board issues
a
finding
of violation
as
alleged
herein,
after
an
adjudicatory
hearing,
Respondents
shall
be
assessed the
associated hearing costs
incurred
by the Illinois
Environmental
Protection
Agency
and the Illinois
Pollution Control
Board.
Those
hearing
costs shall be
assessed
in addition
to the statutory
civil penalty.
Pursuant
to Section 31.1
(d)(1)
of the
Act, 415 ILCS
5/31.1 (d)(1) (2006),
if
Respondents
fail
to petition
or elect 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
a
finding of
violation
as
alleged
herein, and
shall impose the statutory
civil penalty
specified
above.
When payment
is
made,
Respondents’
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,
Respondents
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 Respondents
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 Respondents
in Circuit
Court to collect said
penalty
and/or
hearing
costs,
plus any
interest
accrued.
3
PROCEDURE
FOR
CONTESTING
THIS
ADMINISTRATIVE
CITATION
Respondents
have
the
right
to
contest
this
Administrative
Citation
pursuant
to
and
in
accordance
with Section
31.1
of
the Act,
415 ILCS
5/31/1 (2006).
If
Respondents
elect
to
contest
this
Administrative
Citation,
then
Respondents
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 Respondents.
Date
I2T]1D
Prepared
by:
Susan
E. Konzelmann,
Legal Assistant
Division
of Legal Counsel
1021
North
Grand
Avenue East
P.O.
Box 19276
Springfield,
Illinois
62794-9276
(217)
782-5544
• Scott,
Director
Environmental
Protection
Agency
4
REMITTANCE
FORM
292009
ILLINOIS
ENVIRONMENTAL
)
POlUtior)
r901S
PROTECTION
AGENCY,
)
arci
I
Complainant,
)
AC
)
(IEPA No.
103-09-AC)
v.
)
AMEREN
ENERGY
GENERATING
)
COMPANY,
AMEREN
CORPORATION,
and
JERRY
SIMPSON.
)
Respondents
)
FACILITY:
Ameren
Duck Creek
Station
LF
SITE
CODE
NO.:
0570255197
COUNTY:
Fulton
CIVIL PENALTY:
$1500.00
DATE
OF INSPECTION:
April 9,
2009
DATE
REMITTED:
SS/FEIN
NUMBER:
SIGNATURE:
NOTE
Please
enter
the date
of your remittance,
your
Social
Security
number
(SS)
if
an
individual
or
Federal
Employer
Identification
Number
(FEIN)
if a corporation,
and sign
this
Remittance
Form.
Be
sure
your check
is
enclosed
and
mail, along
with
Remittance
Form,
to
Illinois
Environmental
Protection
Agency,
Attn.: Fiscal
Seivices,
P.O.
Box
19276,
Springfield,
Illinois
62794-9276.
5
IED
MAY
2
9
2009
STATEO
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENC0IIUtiOfl
c,0IS
0
Board
AFFIDAVIT
IN
THE
MATTER
OF:
)
IEPA
DOCKET
NO
RESPONDENT
Affiant,
Robert
J.
Wagner,
being
first
duly
sworn,
voluntarily
deposes
and
states
as
follows:
1.
Affiant
is
a
field
inspector
employed
by
the
Land
Pollution
Control
Division
of
the
Illinois
Environmental
Protection
Agency
and
has
been
so
employed
at
all
times
pertinent
hereto.
2.
On
April
9,
2009,
between
8:58
a.m.
and
11:10
a.m.,
Affiant
conducted
an
inspection
of
the
landfill
in
Fulton
County,
Illinois,
known
as
Ameren
Duck
Creek
Station
LF,
Illinois
Environmental
Protection
Agency
Site
No.
0570255197,
operating
under
IEPA
Permit
#2005-l21-LF.
3.
Affiant
inspected
said
landfill
site
by
an
on-site
inspection,
which
included
walking
the
site
and
interviewing
personnel.
4.
Before
and/or
after
said
inspection
of
said
landfill
site,
Affiant
reviewed
Illinois
Environmental
Protection
Agency
permits
issued
to
the
subject
site
and
investigated
into
whether
or
not
required
documents
were
timely
filed
on
behalf
of
the
subject
site.
5.
As
a
result
of
the
activities
referred
to
in
Paragraphs
3
and
4
above,
Affiant
completed
the
Inspection
Report
form
attached
hereto
and
made
a
part
hereof,
which,
to
the
best
of
Affiant’s
knowledge
and
belief,
is
an
accurate
representation
of
Affiant’s
observations
and
factua.
conclusions
with
respect
to
Ameren
Duck
Creek
Station
LF.
Subscribed
and
me
this
EOFLSEA1E1
SHIRLEYMARIEFARMER
t
NOTARY
PUBLIC
STATE
OF
ILLiNOIS
MYCOMM$SION
EXPIRES
1116-2O1
Not
Public
day
of
Samples
Taken:
Yes
#
No
IJ
Facility
Phone
No.:
309/668-3883
Ameren
Corporation
One
Ameren
Plaza
1901
Chouteau
MC-602
St.
Louis,
MO
63103
Chief
Operator
Mailing
Address
Jerry
Simpson
300
Sur
Woods
Drive
Effingham,
IL 62401
Log
No.
OC-05006
AUTHORIZATION:
TYPE
OF
OPERATION:
Significant
Modification
Permit
No.:
Existing
Landfills
81
4-Subpart
C
El
Initial:
2005-121-LF
814-Subpart
0
Latest
2009-092
New
Landfills:
811
-Putres./Chem.
SECTION
DESCRIPTION
VIOL.
ILLINOIS
ENVIRONMENTAL
PROTECTION
ACT
REQUIREMENTS
1.
9(a)
CAUSE,
THREATEN
OR
ALLOW
AIR
POLLUTION
IN
ILLINOIS
2.
9(c)
CAUSE
OR
ALLOW
OPEN_BURNING
3.
12(a)
CAUSE,
THREATEN
OR
ALLOW
WATER
POLLUTION
IN
ILLINOIS
4.
12(d)
CREATE
A
WATER
POLLUTION_HAZARD
CAUSE,
THREATEN
OR
ALLOW
DISCHARGE
WITHOUT OR
IN
VIOLATION
5.
12(f)
OF
AN
NPDES
PERMIT
6.
21(a)
CAUSE
OR
ALLOW
OPEN_DUMPING
CON
DUCT
ANY
WASTE-STORAGE,
WASTE-TREATMENT,
OR
WASTE-
DISPOSAL
7.
21(d)
OPERATION:
Without
a
Permit
or
in
Violation
of
Any
Conditions
of
a
Permit
(See
Permit
(1)
Provisions)
(2)
In Violation
of
Any
Regulations
or
Standards
Adopted
by
the
Board
DISPOSE,
TREAT,
STORE,
OR
ABANDON
ANY
WASTE,
OR
TRANSPORT
ANY
WASTE
INTO
THE
STATE
ATITO
SITES
NOT
MEETING
8.
21(e)
REQUIREMENTS
OF
ACT
AND
REGULATIONS
J
V
CLK’
OFFICE
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENC’Ay’
2g
2009
Pre-operation
Permit
Inspection
Checklist
STATE
OF
ILLINOIS
County:
Fulton
LPC#:
0570255197
Region:
Pollution
3
Cctrol.
-
Ieoria
Board
Location/Site
Name:
Canton/Ameren
Duck
Creek
Station
Landfill
Date:
04/09/2009
Time:
From
8:58a.m.
To
11:10a.m.
Inspector(s):
Robert
J. Wagner
Weather:
No.
of
Photos
Taken:
#
28
Interviewed:
See
narrative
Permitted
Owner
Mailing
Address
Previous
Inspection
Date:
08/08/2006
Sunny,
Dry
65
°F
—
Permitted
Operator
Mailing
Address
Ameren
Energy
Generating
Company
Duck
Creek
Power
Generating
Station
17751
North
Cilco
Road
Canton,
IL
61520
Certified
Operator
Mailing
Address
John
R. Barry
Kenneth
Sidwell
17751
North
Cilco
Road
17751
North
Cilco
Road
Canton,
IL
61520
Canton,
IL
61520
Revised
05/05/2009
(Pre-Op
1)
LPC#:
0570255197
Inspection
Date:
0410912009
CONDUCT ANY HAZARDOUS
WASTE-STORAGE,
HAZARDOUS
WASTE-TREATMENT
9.
21(f)
OR HAZARDOUS
WASTE-DISPOSAL OPERATION:
(1)
Without a
RCRA Permit
El
CONDUCT A
SANITARY
LANDFILL OPERATION
WHICH RESULTS IN
ANY
OF THE
10.
21(o)
FOLLOWING CONDITIONS:
(1)
Refuse in
Standing
or
Flowing Water
El
(2)
Leachate_Flows_Entering_Waters_of the_State
El
(3)
Leachate_Flows_Exiting_the_Landfill_Confines
El
(4)
Open Burning of Refuse in Violation of Section
9
of
the Act
El
Uncovered
Refuse Remaining
From
Any Previous
Operating
Day or
at the
El
(5)
Conclusion_of Any_Operating_Day
(6)
Failure_to_Provide_Final_Cover Within_Time_Limits
El
(7)
Acceptance_of Wastes
Without_Necessary_Permits
(8)
Scavenging as Defined by Board Regulations
El
(9)
Deposition of Refuse
in Any Unpermitted
Portion of the Landfill
(10)
Acceptance of Special Waste Without
a
Required
Manifest
El
(11)
Failure to Submit Reports Required by Permits or Board
Regulations
(12)
Failure to Collect and Contain Litter by the End
of each Operating
Day
El
Failure
to
Submit Any
Cost
Estimate, Performance
Bond or
Other Security for
El
(13)
the Site
CAUSE OR
ALLOW
A
LATERAL
EXPANSION OF A MUNICIPAL
SOLID
El
11.
21(t)
WASTE LANDFILL (MSWLF) UNIT WITHOUT A PERMIT
MODIFICATION
ACCEPTANCE OF
LIQUID
USED OIL FOR FINAL
DISPOSAL (EFFECTIVE
El
12.
21.6(b)
JULY 1, 1996)
13.
22.01
FAILURE
TO SUBMIT ANNUAL NONHAZARDOUS
SPECIAL WASTE
REPOR1
El
14.
22.22(c)
ACCEPTANCE OF LANDSCAPE WASTE
FOR FINAL
DISPOSAL
El
15.
22.23(f)(2)
CAUSE OR ALLOW THE DISPOSAL OF
ANY LEAD-ACID BATTERY
El
16.
22.28(b)
ACCEPTANCE OF WHITE
GOODS FOR
FINAL
DISPOSAL
El
ACCEPTANCE OF
ANY
USED
OR
WASTE TIRE FOR FINAL
DISPOSAL
El
17.
55(b)(1)
(UNLESS
LANDFILL
MEETS
EXEMPTION
OF 55(b)(1))
.
CAUSE
MEDICAL
ORWASTE
ALLOW THE DISPOSAL OF ANY POTENTIALLY
INFECTIOUS
El
1
19.
225
ILCS
CAUSING OF ALLOWING OPERATION
OF
A
LANDFILL
WITHOUT
PROPER
230I1
004
COMPETENCY CERTIFICATE
El
Revised 9/21/2005
(Pre-op - 2)
LPC#:
0570255197
Inspection Date:
0410912009
:.
35
IWNO)S
AtMIN1STRAT1VE CODEREQLIIREMENTS
SUBTITLE
G
;
..
PRIOR
CONDUCTCERTiFICATION REQUIREMENTS
S
20.
745.181
CHIEF
OPERATOR_REQUIREMENTS
21.
745.201
PRIOR
CONDUCT CERTIFICATION PROHIBITIONS
sPALwASTAuLINGREQUIREENTS
:•.
22.
809.301
REQUIREMENTS FOR DELIVERY OF SPECIAL WASTE TO HAULERS
121
23.
809.302(a)
REQUIREMENTS FOR ACCEPTANCE
OF SPECIAL
WASTE FROM
HAULERS
MANIFESTS,
RECORDS, ACCESS
TO RECORDS, REPORTING
REQUIREMENTS
AND
24.
809.501
FORMS
(a)
Delivery_of
Special_Waste to_Hauler
(e)
Retention of Special
Waste Manifests
NEW SOLID
WASTE LANDFILL
REQUIREMENTS
PART 811
GENERAL STANDARDS
FOR ALL LANtEILLS
.____ SLJBPARTA
.
.
.
..
.
.
..
.
25.
811.103
SURFACE WATER DRAINAGE
._______
(a)
Runoff from
Disturbed Areas
0
(b)
Diversion of
Runoff from Undisturbed Areas
LI
26.
811.104
SURVEY CONTROL
(a)
Boundaries Surveyed and Marked
0
(b)
Stakes
and Monuments Marked
LI
(c)
Stakes and Monuments Inspected
U
(d)
Control_Monument_Established_and_Maintained
U
27.
811.109
BOUNDARY CONTROL
(a)
Access
Restricted
0
(b)
Proper
Sign Posted
.
PART
811
PUTRESCIBLE
AND
CHEMICAL
WASTE LANDFILLS
.
.
SUBPARTC
.
.. .
.
..
.
28.
811.302
FACILITY LOCATION
(C)
Site Screening
(Does
Not
Apply
To
Part 814-Subpart
D
Sites)
El
29.
811.305
FOUNDATION CONSTRUCTION
El
30.
811.316
PLUGGING AND SEALING
OF
DRILL HOLES
El
SUBPART
D
MANAGEMENT OF SPECIAL
WASTES A1 LANDFILLS
31.
[
811.402
1
NOTICE TO GENERATORS
AND TRANSPORTERS
U
Revised
9/21/2005
.
(Pre-op - 3)
LPC#:
0570255197
Inspection
Date:
0410912009
PART
811
CONSTRUCTION
QUALITY
ASSURANCE
PROGRAMS
SUBPARTE
c
STRUCTURES
CONSTRUCTED
IN ACCORDANCE
WITH THE
32.
811.501
CONSTRUCTION
QUALITY
ASSURANCE PROGRAM
33.
811.502
DUTIES AND
QUALIFICATIONS
OF
KEY PERSONNEL
(a)
Duties
and
Qualifications
of
the Operator
LI
(b)
Duties and
Qualifications of the
CQA Officer
LI
34.
811.503
INSPECTION ACTIVITIES
(a)
CQA
Officer
Present
to
Provide
Supervision
and
Assume
Responsibility
LI
(b)
CQA Officer-in-absentia
Designated
LI
35.
811.504
SAMPLING
REQUIREMENTS
El
36.
811.505
DOCUMENTATION
(a)
Proper Daily
Summary Report Prepared
(b)
Proper Daily
Inspection
Report
Prepared
(d)
Proper
Acceptance
Reports
Submitted
37.
811.506
FOUNDATIONS
AND
SUBBASES
(a)
Requirements of the
CQA
Officer
(Proper
Site
Investigation)
LI
(b)
Requirements
of the
CQA
Officer (Proper
Documentation of joints,
fractures,
etc.)
LI
(c)
Requirements
of the CQA
Officer (Properly
remove
undesirable
materials)
LI
38.
811.507
COMPACTED_EARTH_LINERS
(a)
Requirements
for a Test
Liner
LI
(c)
CQA Officer
Inspects
Construction
and Testing
of Test Fills
LI
39.
811.508
CQA
OFFICER
CERTIFIES
PROPER
GEOMEMBRANE
INSTALLATION
(a)
Requirements of the
CQA Officer (Exercise
Professional
Judgement))
LI
(b)
Requirements of
the
CQA Officer
(Proper Adherence
to the Approved
Plan)
LI
(c)
Requirements
of the
CQA
Officer
(Proper Inspection
of
Structures)
LI
40.
811.509
CQA OFFICER
CERTIFIES LEACHATE
COLLECTION
SYSTEM
INSTALLATION
LI
SOLID WASTE
FEE SYSTEM
REQUIREMENTS
MAINTAINED,
RETAINED
& SUBMITTED
DAILY
& MONTHLY
SOLID
WASTE RECORDS
AND
QUARTERLY SOLID WASTE
SUMMARIES
WHERE
Part
858
INCOMING
WASTE IS WEIGHED
(LIST
SPECIFIC
SECTION
NO. OF
41.
Subpart
B
VIOLATIONS_IN_OTHER:)
MAINTAINED,
RETAINED
& SUBMITTED DAILY
& MONTHLY
SOLID
WASTE
RECORDS AND
QUARTERLY
SOLID
WASTE
SUMMARIES
WHERE
Part
858
INCOMING WASTE
IS NOT WEIGHED
(LIST
SPECIFIC
SECTION
NO. OF
42.
Subpart
C
VIOLATIONS_IN_OTHER:)
Revised
9/21/2005
(Pre-op -4)
LPC#: 0570255197
Inspection Date: 0410912009
OTHER
REQUIREMENTS
APPARENT
VIOLATION OF:
(Q)
PCB;
(Q)
CIRCUIT COURT
43.
CASE_NUMBER:
ORDER ENTERED ON:
44.
OTHER:
E
C
C
•.
PERMIT PROVISIONS
DESCRIPTION OF VIOLATION
(condition # of permit,
page #
of
permit,
and/or
page #
of approved application)
PERMIT
NUMBER
2005-121-LF
Special
Condition
I.
CONSTRUCTION
QUALITY
ASSURANCE 2. (page 3)
2005-121-LF
Special Condition
II.
OPERATING
CONDITIONS 3.f. (page 5)
2005-121-LF
Special Condition
II. OPERATING CONDITIONS 3.h. (page 5)
2005-121-LF
Special
Condition II. OPERATING CONDITIONS
3.j. (page 5)
2005-121-LF
Special Condition
VIII. GROUNDWATER MONITORING 3. (page
19)
2005-121-LF
Standard
Condition 2. (page 1 of Standard Conditions)
2005-121-LF
Standard
Condition 3. (page 1 of Standard Conditions)
2005-121-LF
Standard
Condition 6. (page 2 of Standard Conditions)
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 constwed 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
(0)
of
Section 21 of the
Illlinois]
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
9/21/2005
(Pre-op - 5)
0570255197 - Fulton County
Ameren
Duck
Creek
Station LF
FOS
Prepared By:
Robert J. Wagner
Inspection
Date:
April
9,
2009
Page
1
Narrative
On April
9,
2009, I
(Robert J. Wagner) conducted a
pre-operational pennit
inspection from
8:58 a.m. to 11:10 a.m. at Ameren Duck Creek Station LF (0570255197)
in Fulton County.
Permit No. 2005-121-LF
approved the development of a new
non-hazardous
coal combustion
waste
landfill by Ameren Corporation
as
owner and Ameren Energy
Generating Company as
operator. The landfill is located
on property at
17751 North Cilco Road, Canton,
Illinois. The
following
Ameren employees participated in
the
inspection:
Roger D. Garman ----Technical Services
Superintendent
Paul R. Pike
----Strategic Analyst
Environmental Safety
&
Health
John R.
Berry ----Certified Operator
Dave Boyce ----Ameren Ash
Management Project
Construction Manager
The purpose of the inspection was to verify claims made in permit Log No.
2009-092,
received
on
February 23, 2009 from
Hanson Professional Services Inc. This is a
significant modification
permit application containing acceptance
report for
operating in Cell 1A (waste disposal). The
inspection included
but was not limited to bottom liner, leachate drainage and
collection
system,
leachate management system,
and
groundwater monitoring system.
I met with Ameren personnel
at
the power plant office to discuss the
inspection.
Mr. Pike
said
that
Cell 1A had already taken several
loads
of fly ash generated from
Ameren Duck
Creek
Power Generating Station (0578010002).
According
to Mr. Garman, Cell
1A
received
approximately 3000 tons of fly ash on April 2, 2009. Mr. Garman said
they had no other place to
go
with the fly ash generated by the power plant.
Mr. Pike explained Ameren’s position that since the fly ash was generated on
site from Ameren
Duck Creek Power Generating Station that Cell 1A could fall
under Section 815 (TITLE 35:
ENVIRONMENTAL PROTECTION, SUBTITLE G:
WASTE DISPOSAL, CHAPTER I:
POLLUTION CONTROL BOARD, SUBCHAPTER i: SOLID
WASTE AND SPECIAL
WASTE
HAULING, PART 815 PROCEDURAL REQUIREMENTS FOR
ALL LANDFILLS
EXEMPT
FROM PERMITS.). According
to
Mr. Pike, Ameren can provide
documents proving
that
Cell
1
A is a Section 815 site. However,
at
the time of the inspection
Ameren
did
not
provide any
documentation concerning
the landfill’s
Section 815 status. Mr. Pike
explained
he
had sent an
email
correspondence
to
the Agency’s permit
section explaining Ameren’s current
position on Cell 1A. Mr. Pike said he received a letter back from the
Agency but the letter did
not
specifically address this issue with Cell 1 A.
We
completed this part of the inspection at the power plant office and
proceeded to Cell 1A. At
Cell 1 A,
I walked and photographed the area accompanied by the
above-mentioned
individuals.
0570255197
-- Fulton
County
Ameren
Duck
Creek
Station
LF
FOS
Prepared
By: Robert
J.
Wagner
Inspection
Date:
April
9,
2009
Page
2
Photograph
1 shows
the
western
border of Cell
1A
(see
site sketch).
Photographs
2, 3, 4,
and 5
show
where the
fly
ash has been
dumped
in Cell IA.
Photograph
6
shows
the
southern
portion
of Cell
1 A. Photograph
7 shows
the
temporary
berm placed
on the
southern portion
of Cell 1
A.
Photograph
8
shows
the southwestern
view
of
Cell
1 A.
Photographs
9 and
10 show the
temporary
leachate
collection
tank
installed
near
the
southeast
corner
of Cell
1A.
According
to Ameren,
the
permanent
tanks
will
be
constructed
when
Cell 2
is
constructed.
Application
Log No. 2005-12
1 does
not include
a
design
of or
any
construction
quality assurance
documentation
for
the
temporary
leachate
storage
tank. The
design
must
be
demonstrated
to
comply
with the
requirements
of the design
approved
via the
issuance
of
Permit
No. 2005-121-LF.
The
application
does
not
identify
the specific
location
of
the temporary
tank.
Photographs.
11, 12,
and
13
show a spill
way located
in the
southeastern
corner
of
Cell 1A.
According
to
Ameren,
the
spiliway will
remain
during operation
of Cell 1 A
to safely
discharge
any
storm
water
that may
accumulate
in that location.
However,
upon commencement
of
waste
disposal
operations
in
Cell 1 A, all
storm water
within
the
limits
of Cell
1 A will
be
considered
leachate
and may
not
be discharged
as
proposed.
Photograph
14
shows
the 12-inch
leachate
lateral
pipe
with the temporary
leachate
collection
tank
in the
background.
Photograph
15
shows
the
groundwater
wells
constructed
along
the
eastern
boundary
of
Cell
lA. Photographs
16 and
17 show
the mid
section
of
Cell lA.
Photograph
18 shows the
location
of where fly
ash has
been deposited
in
Cell 1 A.
Photograph
19
shows groundwater
well
G14L.
The casing
was
caped and
locked.
It appears
that
all the groundwater
wells
have been
constructed
in
accordance
with
approved
plans.
According
to Permit
No.
2005-121-LF,
groundwater
sample results
for
January-February
must
be
submitted
to the
Illinois EPA
by
April
15,
2009 or
before the
placement
of waste.
On April
2, 2009,
fly
ash
was
placed
in
Cell
1 A. After
reviewing
the
file,
groundwater
results
were
not submitted
to the
Agency
until
April
15,
2009.
Photograph
20
shows
the
eastern
boundary
of Cell
1 A. Photographs
21,
22, 23,
24,
and 25
show
the
northern
portion
of Cell 1A.
Photograph
26
shows
the
northern
boundary
of
Cell
1A.
Photograph
27
shows
the northwestern
boundary of
Cell
1A. Photograph
28
shows
the western
portion
of
Cell
IA.
At
the
end of the
inspection,
Mr.
Pike wanted
to know
if Ameren
could
continue
to use
Cell
1A.
I told him
that
I did
not have
to authority
to
make that
decision.
The
following
alleged
violations
were observed
and
indicated
on the
Pre-operation
Permit
Inspection
Checklist:
1.
Pursuant
to
Section
12(a) of the
Act,
no
person shall
cause or
threaten
or allow
the
discharge
of
any contaminants
into
the
environment
in any State
so as to
cause or
tend
to
cause
water
pollution
in Illinois,
either
alone
or
in combination
with matter
from
other
0570255197
--
Fulton
County
Ameren
Duck
Creek
Station
LF
FOS
Prepared
By:
Robert
J. Wagner
Inspection
Date:
April
9,
2009
Page
3
sources,
or
so as
to
violate
regulations
or
standards
adopted
by
the
Pollution
Control
Board
under
this
Act.
A
violation
of Section
12(a)
of the
[Illinois]
Environmental
Protection
Act (415
ILCS
5/12(a))
is
alleged
for
the
following
reason:
Ameren
Corporation
as owner;
Ameren
Energy
Generating
Corporation
as operator;
and
Jerry
Simpson
as Chief
Operator
did
not
submit
to
the
Illinois
EPA
groundwater
sample
results
prior
to
the
placement
of
waste
as required
by Permit
No.
2005-121-LF,
Special
Condition
VIII.
GROUNDWATER
MONITORING
3.
2.
Pursuant
to
Section
12(d)
of the Act,
no
person
shall deposit
any
contaminants
upon the
land
in
such place
and
manner
so as
to
create
a
water
pollution
hazard.
A
violation
of
Section
12(d)
of
the [Illinois]
Environmental
Protection
Act
(415
ILCS
5/12(d))
is
alleged
for
the
following
reason:
Ameren
Corporation
as owner;
Arneren
Energy
Generating
Corporation
as
operator;
and
Jerry
Simpson
as
Chief
Operator
did
not
submit
to
the
Illinois
EPA groundwater
sample
results
prior
to
the
placement
of waste
as
required
by
Permit
No.
2005-121-LF,
Special
Condition
VIII.
GROUNDWATER
MONITORING 3.
3.
Pursuant
to Section
2l(d)(l)
of
the
Act,
in
relevant
part,
no
person
shall conduct
any
waste-storage,
waste-treatment, or
waste-disposal
operation
without
a permit
granted
by
the
Agency
or in violation
of any
conditions
imposed
by such
permit,
including
periodic
reports
and
full
access
to
adequate
records
and
the inspection
of
facilities,
as may
be
necessary
to assure
compliance
with
this
Act
and with
regulations
and standards
adopted
thereunder.
A
violation
of
Section
21(d)(1)
of
the
[Illinois]
Environmental
Protection
Act
(415 ILCS
5/21(d)(1))
is
alleged
for
the
following
reason:
Ameren
Corporation
as
owner;
Ameren
Energy
Generating Corporation
as operator;
and
Jerry
Simpson
as
Chief
Operator
failed
to comply
with
the
following
conditions in
Permit
No.
2005-121-LF.
Permit
No.
2005-121-LF,
Special
Condition
I. CONSTRUCTION
QUALITY
ASSURANCE 2. No
part
of
the
unit
shall
be placed
into
service
or accept
waste
until
an
acceptance report
for
all activities
listed
below
has
been
submitted
to
and
approved
by
the
Illinois
EPA
as
a significant
modification
pursuant
to 35
IAC, Sections
811.505(d)
and
813.203.
a.
Preparation of subgrade
and
foundation
to design
parameters;
b.
Installation
of
compacted
earth/synthetic
liner;
c.
Installation
of
the leachate
drainage,
collection,
and management
system.
0570255197
-- Fulton
County
Ameren
Duck
Creek
Station
LF
FOS
Prepared
By:
Robert
J. Wagner
Inspection
Date:
April
9, 2009
Page
4
d.
Placement of fmal
cover;
e.
Construction
of ponds,
ditches,
lagoons,
and
berms.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator; and Jerry
Simpson
as
Chief
Operator
began
the
disposal
of
waste
in Cell
1A
without
an approved operating
permit.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and Jerry
Simpson
as
Chief
Operator
placed
a temporary
leachate
storage
tank
into
service
without
filing
an
acceptance
report
and
without
prior
approval
by
the
Iffinois
EPA.
Permit
No.
2005-121-LF,
Special
Condition
II.
OPERATING
CONDITIONS
3.
The operator
of
this solid
waste
facility
shall
not
conduct
the
operation
in
a
manner
which
results
in
any of
the
following:
f.
acceptance
of waste
without
the
necessary
permits.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and
Jerry
Simpson
as
Chief
Operator
began
the disposal
of
waste
in
Cell 1A
without
an
approved
operating
permit.
Permit
No. 2005-121-LF,
Special
Condition
II.
OPERAT11TG
CONDITIONS
3.
The
operator
of
this
solid
waste
facility
shall
not
conduct
the
operation
in
a
manner
which
results
in
any of
the
following:
h.
deposition
of refuse
in
any
unpermitted
(i.e.,
without
an
Illinois
EPA
approved
significant
modification
authorizing
operation)
portion
of
the landfill.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and
Jerry
Simpson
as
Chief
Operator
began
the
disposal
of
waste
in
Cell
1A without
an
approved
operating
permit.
Permit
No.
2005-121-LF,
Special
Condition
II.
OPERATING
CONDITIONS
3.
The operator
of
this solid
waste
facility
shall
not
conduct
the
operation
in
a
manner
which
results
in any
of the following:
j.
failure
to
submit
reports
required
by
permits
of Board
Regulations.
Ameren
Corporation
as owner;
Ameren
Energy
Generating
Corporation
as
operator;
and
Jerry Simpson
as
Chief
Operator
did
not
submit
to
the
Illinois
EPA groundwater
sample
results
prior
to
the
placement
of
waste
as
required
0570255197
-- Fulton
County
Ameren
Duck
Creek Station
LF
FOS
Prepared
By:
Robert
J. Wagner
Inspection
Date: April
9,
2009
Page
5
by Permit
No. 2005-121-LF,
Special Condition
VIII.
GROUNDWATER
MONITORING 3.
Permit
No.
2005-121-LF,
Special
Condition
VIII.
GROUNDWATER
MONITORING 3.
Groundwater
monitoring
wells
shall
be
installed
in the
locations
shown
in Figure
10-1, of
the permit
application,
Log
No. 2005-121,
Addendum
No.
4 and screened
in the
hydrogeologic
unit(s)
identified
as
potential
contaminant
pathway(s)
within
the
zone
of
attenuation.
All wells
listed
in
Condition
VIII.9 must
be installed
so
that samples
may be
taken
during
the
months
of January-February
and the
results
submitted
to the
Illinois EPA
by
April 15,
2009 or
before the
placement
of
waste.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and
Jerry Simpson
as Chief
Operator
did
not submit
to
the
Illinois
EPA
groundwater
sample
results
prior
to the
placement
of
waste.
Permit
No.
2005-121-LF,
Standard
Condition
2. The
construction
or
development
of facilities
covered
by this permit
shall be done
in compliance
with
applicable
provisions
of Federal
laws
and regulations,
the Illinois
Environmental
Protection
Act, and
Rules
and
Regulations
adopted
by the
Illinois
Pollution
Control
Board.
Ameren
Corporation
as
owner; Ameren
Energy
Generating
Corporation
as
operator;
and Jerry
Simpson
as Chief
Operator
did
not comply
with
the
applicable
provisions
of the
Illinois
Environmental
Protection
Act and
Illinois
Pollution
Control
Board
Regulations
during
the
development
of
the
landfill.
Permit
No.
2005-121-LF,
Standard
Condition
3.
There
shall
be no
deviation
from
the
approved
plans
and specifications
unless
a written
request
for
modification
of the
project,
along
with
plans
and
specifications
as
required,
shall
have
been
submitted
to
the
Agency
and
a
supplemental
written
permit
issued.
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and Jerry
Simpson
as Chief
Operator
deviated
from
the approved
plans
and
specifications
without
a written
request
for
modification
submitted
to
the
Agency
and a supplemental
written
permit
issued.
Permit
No. 2005-121-LF,
Standard
Condition
6.
Unless
a joint
construction/operation
permit
has been
issued,
a
permit
for
operating
shall
be
obtained
from
the Agency
before
the
facility
or equipment
covered
by
this
permit
is
placed
into
operation.
0570255197
-- Fulton
County
Aineren
Duck
Creek
Station
LF
FOS
Prepared
By:
Robert
J. Wagner
Inspection
Date:
April
9,
2009
Page
6
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and
Jerry
Simpson
as
Chief
Operator
placed
the
landfill
into
operation
without
an
operating
permit
issued
by
the Agency.
4.
Pursuant
to
Section
21(d)(2)
of
the Act,
no
person
shall
conduct
any
waste-storage,
waste-treatment, or waste-disposal
operation
in violation
of
any regulations
or
standards
adopted
by
the
Board
under this
Act.
A
violation
of Section
21
(d)(2)
of the [Illinois]
Environmental
Protection
Act
(415
ILCS
5/21(d)(2))
is alleged
for
the
following
reason:
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as
operator;
and Jerry
Simpson
as
Chief
Operator
conducted
a waste-disposal
operation
in violation
of regulations
adopted
by the
Board.
5.
Pursuant
to
Section
2 1(e)
of the
Act, no
person
shall
dispose,
treat,
store
or abandon
any
waste,
or
transport
any
waste
into
this
State
for disposal,
treatment,
storage
or
abandonment, except
at a
site
or
facility
which
meets
the
requirements
of
this
Act
and
of
regulations
and
standards
thereunder.
A
violation
of Section
21(e)
of the
[illinois]
Environmental
Protection
Act
(415
ILCS
5/21(e))
is
alleged
for
the
following
reason:
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as operator;
and
Jerry
Simpson
as Chief
Operator
disposed
of waste
at
a
facility
which
does
not meet
the
requirements
of
the
Act
and
regulations.
6.
Pursuant
to Section
21(o)(7)
of the
Act,
no person
shall
conduct
a sanitary
landfill
operation
which
is required
to have
a
permit
under
subsection
(d)
of this
Section,
in
a
manner
which
results
in acceptance
of wastes
without
necessary
permits.
A
violation
of
Section
21 (o)(7)
of the
[Illinois]
Environmental
Protection
Act
(415
ILCS
5/21
(o)(7))
is
alleged
for
the
following
reason:
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as operator;
and
Jerry
Simpson
as
Chief
Operator
accepted
waste
for
disposal
in
Cell
1A
without
an
operating
permit.
7.
Pursuant
to Section
21(o)(9)
of the
Act,
no
person
shall
conduct
a sanitary
landfill
operation
which
is required
to have
a
permit
under
subsection
(d) of
this
Section,
in
a
manner
which
results
in deposition
of
refuse
in any
unpermitted
portion
of
the
landfill.
A
violation
of
Section
21(o)(9)
of the
[Illinois]
Environmental
Protection
Act
(415 ILC5
5/21(o)(9))
is alleged
for
the
following
reason:
Ameren
Corporation
as
owner;
Ameren
Energy
Generating
Corporation
as operator;
and
Jerry
Simpson
as
Chief
Operator
deposed
of waste
in
Cell 1A
without
a
permit
for that
portion
of
the
landfill.
0570255197
-- Fulton
County
Ameren
Duck
Creek
Station
LF
FOS
Prepared
By: Robert
J. Wagner
Inspection Date: April
9, 2009
Page
7
8.
Pursuant
to Section
21(o)(11)
of
the Act, no person
shall conduct a sanitary
landfill
operation
which
is required
to
have a permit under
subsection
(d) of this
Section,
in
a
manner
which
results in failure
to submit
reports required by
permits
or Board
regulations.
A
violation of
Section 21(o)(1
1) of the [Illinois]
Environmental Protection
Act
(415 ILCS
5/2l(o)(1
1)) is alleged
for the
following reason:
Ameren Corporation
as owner;
Ameren Energy
Generating
Corporation
as operator; and
Jerry
Simpson
as
Chief
Operator
failed submit
to the Illinois EPA
the groundwater sample
results required
by Permit
No. 2005-121-LF,
VIII. GROUNDWATER
MONITORING
3. prior
to
the placement
of waste
in Cell
1A.
9.
Pursuant
to
35
Ill.
Adm.
Code
811.505(d),
upon completion
of the
construction
of each
major
phase,
the
CQA
officer shall submit
an acceptance
report to the
Agency. The
acceptance report
shall
be submitted before
the structure is
placed into service and
shall
contain
the
following:
1) a certification
by the CQA
officer that the construction
has
been
prepared
and
constructed in accordance
with
the
engineering
design; 2) As-built
drawings;
and
3) All daily
summary
reports.
A violation
of 35
Ill. Adm.
Code
811.505(d)
is alleged
for the following reason.
Ameren
Corporation
as owner; Ameren
Energy
Generating Corporation
as operator;
and
Jerry Simpson
as Chief
Operator
failed to submit to
the Agency any documentation
for the
construction
of the temporary
leachate storage
tank.
T
8
N
FE
El
J
WEST)
j
0570255197
-
Duck
Creek
Station
Landfill
j
CCW
Area
.;
—
a
I
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//
ii
r
/‘
11H
/
/1W
/
/
/
//
/
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//
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ii
jjcIE:
74
DIRECTION:
Photograph
taken
toward
thenorth.
PHOTOGRAPH
NUMBER:
1
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-00
1
.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
DATE:
April
9,
2009
TIME:
10:09AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
northeast.
PHOTOGRAPH
NUMBER:
2
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-002.jpg
COMMENTS:
The
photograph
shows
FLyash
generated
from
Duck
Creek
Power
Generating
Station
that
has
been
placed
in
Cell
1A.
DOCUMENT
FILE
NAME:
0570255
197’04092009.doc
DIRECTION:
Photographtaken
toward
the
east.
PHOTOGRAPH
NUMBER:
3
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-003
.jpg
COMMENTS:
The
photograph
shows
Flyash
generated
from
Duck
CreekPowerGenerating
Station
that
has
been
placed
in
Cell
1A.
DATE:
April
9,
2009
TIME:
10:11AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
thenorth.
PHOTOGRAPH
NUMBER:
4
PHOTOGRAPH
FILE
NAME:
0570255
19704092009-004.jpg
COMMENTS:
The
photograph
shows
Flyash
generated
from
Duck
CreekPower
Generating
Station
that
has
been
placed
in
Cell
1A.
DOCUMENT
FILE
NAME:
0570255
19704092009.doc
DIRECTION:
Photograph
taken
toward
the
northeast.
PHOTOGRAPH
NUMBER:
5
PHOTOGRAPH
FILE
NAME:
0570255
19704092009-005.jpg
COMMENTS:
The
photograph
shows
Flyash
generated
from
Duck
Creek
Power
Generating
Station
that
has
been
placed
in
Cell
1A.
DATE:
April
9,
2009
TIME:
10:11AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
west.
PHOTOGRAPH
NUMBER:
6
PHOTOGRAPH
FILE
NAME:
0570255
197—04092009-006.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
DOCUMENT
FILE
NAME:
0570255
197—-04092009.doc
..
toward
the
east.
PHOTOGRAPH
NUMBER:
7
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-007.jpg
COMMENTS:
The
photograph
showsCell
1A.
DATE:
April
9,
2009
TIME:
10:16AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photographtaken
toward
the
northwest.
PHOTOGRAPH
NUMBER:
8
PHOTOGRAPH
FILE
NAME:
05702551
97-04092009-008.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
The
photograph
Alsoshows
Flyash
generated
from
Duck
Creek
Power
Generating
Station
that
has
beenplaced
in
Cell
lA.
32.
DOCUMENT
FILE
NAME:
0570255
19704092009.doc
Page
DiRECTION:
PhotograPh
taken
the
northwest.
PhOTOGRAPH
NUMBER:
9
PHOTOGPH
FILE
NAME:
0570255
1
9704092009009
.jpg
COMMENTS:
The
photograph
shows
Cell
IA
and
a
collapsible
leachate
holding
tank.
DATE:
April
9,
2009
TIME:
i0:I6AM
PHOTOGRAPHED
BY:
Robert
3.
Wagner
DIRECTION:
photograPh
taken
toward
the
northwest.
PHOTOGRAPH
NUMBER:
10
PHOTOGRAPH
FILE
NAME:
057025519704092
O090jPg
COMMENTS:
The
photograPh
shows
Cell
IA
and
a
collapsible
leachate
holding
tank.
DOCUMENT
FILE
NAME:
05702551970409
2009.do
:
-
•..,.
-
..—.---
F
:
-
.
-
-
—
DIRECTION:
Photograph
taken
toward
the
east.
PHOTOGRAPH
NUMBER:
11
PHOTOGRAPHFILE
NAME:
05702551
97—04092009-0
11
.jpg
COMMENTS:
The
photograph
shows
the
leachate
collection
system
and
the
“spill
way”.
DATE:
April
9,
2009
TIME:
10:17AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
southeast.
PHOTOGRAPH
NUMBER:
12
PHOTOGRAPH
FILE
NAME:
0570255
197—04092009-0
12.jpg
COMMENTS:
The
photograph
shows
the
“spill
way”.
DOCUMENT
FILE
NAME:
0570255
197’04092009.doc
DIRECTION:
Photograph
taken
toward
the
southeast.
PHOTOGRAPH
NUMBER:
13
PHOTOGRAPH
FILE
NAME:
05702551
9T-M4092009-0
13
.jpg
COMMENTS:
The
photograph
shows
the
“spill
way”.
DOCUMENT
FILE
NAME:
0570255
197—04092009.doc
-
•
toward
the
west.
PHOTOGRAPH
NUMBER:
14
PHOTOGRAPH
FILE
NAME:
0570255
197’-04092009-0
14.jpg
COMMENTS:
The
photograph
shows
main
leachate
collection
pipe
and
the
collapsible
leachate
holding
tank.
ii
...
:4J
.,
;
L.;$e;.,
.
I.,,:
-
Sc
:Lt4.
-..
I
DOCUMENT
FILE
NAME:
0570255
19704092009.doc
-1
%
—
-
.
-
-.
*
•*$!S•.:.
.57
S
5
--a
DIRECTION:
Photograph
taken
toward
thenorth.
PHOTOGRAPH
NUMBER:
15
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-0
15
.jpg
COMMENTS:
The
photograph
shows
Cell
1A
and
a
the
ground
water
monitoring
wells.
DATE:
April
9,
2009
TIME:
10:21AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photographtaken
toward
the
northwest.
—
—•--
—
1
PHOTOGRAPH
NUMBER:
16
.._____
PHOTOGRAPH
FILE
NAME:
0570255
197—04092009-016.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
‘-‘•
•<--“
.
-.
2
•
•
-I
-
-.-:.:
4:
“
7
?ti
4*’
--
--
-:
:.
4
-
-----
DOCUMENT
FILE
NAME:
05702551
97—04092009.doc
DATE:
April
9,
2009
TIME:
10:22AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
west.
PHOTOGRAPH
NUMBER:
18
PHOTOGRAPH
FILE
NAME:
05702551
97—04092009-0
1
8.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
DIRECTION:
Photograph
taken
toward
the
northwest.
PHOTOGRAPH
NUMBER:
17
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-0
1
7.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
.
DOCUMENT
FILE
NAME:
05702551
9704092009.doc
DIRECTION:
Photographtaken
toward
the
east.
PHOTOGRAPH
NUMBER:
19
PHOTOGRAPH
FILE
NAME:
05702551
97’-M4092009-0
1
9.jpg
COMMENTS:
The
photograph
shows
groundwater
monitoring
well
G14L.
:
r
t
•1’
A
‘:.
I.
•.
;‘\i;
:
•
h.
t
:..7
La.
•‘
‘:
*4
•
.:.,,:‘.
DOCUMENT
FILE
NAME:
05702551
97O4O92009.doc
‘ii
I
$
.
DOCUMENT
FILE
NAME:
05702551
9704092009.doc
E1
--
..
-
-
-
45-
:1....
12
Photograph
taken
toward
the
south.
PHOTOGRAPH
NUMBER:
20
PHOTOGRAPH
FILE
NAME:
05702551
97—04092009-O2Ojpg
COMMENTS:
The
photograph
shows
Cell
1A.
DATE:
April
9,
2009
TIME:
10:32AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
south.
PHOTOGRAPH
NUMBER:
21
PHOTOGRAPH
FILE
NAME:
057025519704092009-021
.jpg
COMMENTS:
The
photograph
shows
Cell
IA.
:.:...
DIRECTION:
Photograph
toward
the
southwest.
PHOTOGRAPH
NUMBER:
22
PHOTOGRAPH
FILE
NAME:
0570255
19T-04092009-022.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
j
—
—
.
,
—
_—
•“:—
.L
.4
-
—
J
;__
I;c_,_
—
—
..
.•-,
..
..
-
1
-
DOCUMENT
FILE
NAME:
05702551
97—04092009.doc
—
-
S
F
I
F
—
‘
:
-
L
-
e
F.
—
0
—
--.
;-
-
.e
—
—
.—.
‘
‘S.—
•
....--
•.-•..
.
>
-
-
‘
•4b:
-.
•...
:-
h.,
-.
--—-
I
‘.
DATE:
April
9,
2009
TIME:
10:32AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
southwest.
PHOTOGRAPH
NUMBER:
23
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-023
.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
L
:
.
-.---
--
I
—I.
L__IL-_
‘
1
-
-
-
I
I
W
)_h
:‘••
7...
1••4’
:
DOCUMENT
FILE
NAME:
05702551
97—M4092009.doc
taken
toward
the
southwest.
PHOTOGRAPH
NUMBER:
24
PHOTOGRAPH
FILE
NAME:
0570255
19704092009-024.jpg
COMMENTS:
The
photograph
shows
Cell
IA.
DATE:
April
9,
2009
TIME:
10:32AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
southwest.
PHOTOGRAPH
NUMBER:
25
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-025
.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
z
:‘‘
eIi_
—
_r_
-
1-
::..
....
.j’
.1:
?
A
.
.L_LL
-
.‘
/
‘:
:.:/1
:\
\
‘f
1
•
/
-
-
—
-
-•
..
..ce.:A---
...-..
.•,.—.
.‘
--.fr.
--.
DOCUMENT
FILE
NAME:
05702551
97-M4092009.doe
DIRECTION:
Photograph
taken
toward
the
west.
PHOTOGRAPH
NUMBER:
26
PHOTOGRAPH
FILE
NAME:
05702551
97-M4092009-026.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
DATE:
April
9,
2009
TIME:
10:35AM
PHOTOGRAPHED
BY:
Robert
J.
Wagner
DIRECTION:
Photograph
taken
toward
the
southwest.
PHOTOGRAPH
NUMBER:
27
PHOTOGRAPH
FILE
NAME:
0570255
19704092009-027.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
•
.
.
_
I
•...-t,
•
•
-
toward
the
southwest.
DOCUMENT
FILE
NAME:
05702551
97—04092009.doc
—
-
A.
L,.
v.e,bfl..t
PHOTOGRAPH
NUMBER:
28
PHOTOGRAPH
FILE
NAME:
05702551
9704092009-028.jpg
COMMENTS:
The
photograph
shows
Cell
1A.
p
—
H::
t,
I
I
ii
‘Ii
AFFIDAVIT,
and
OPEN
DUMP
INSPECTION
CHECKLIST
0
F?
/
C
I
Iv,,
L
To:
Ameren
Energy
Generating
Company
Ameren
Corporation
James
A.
Tisckos,
Registered
Agent
James
A.
Tisckos,
RegisteredAgent
17751
North
Cilco
Road
1901
Chouteau
MC-602
Canton,
IL
61520
St.
Louis,
MO
63103
-icc-i
qo
oooz.
--z4
4
(o
ioc
3ozO
ooa
i/l
Jerry
Simpson,
CertifiedOperator
300
Sur
WoodsDrive
Effingham,
IL
62401
7co1
O2O
OOb
3v4
4Z-
and
the
original
and
nine
(9)
true
and
correct
copies
of
the
same
foregoing
instruments
on
the
same
date
byCertified
Mail,
Return
Receipt
Requested,with
postage
thereon
fully
prepaid
To:
John
Therriault,Clerk
Pollution
Control
Board
James
R.
Thompson
Center
100
West
Randolph
Street,
Suite
11-500
Chicago,Illinois
60601
Assistant
Counsel
Illinois
Environmental
ProtectionAgency
1021
North
Grand
Avenue
East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
(217)
782-5544
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FILINGSUBMITTED
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