F?K’
    OFFICE
    OF
    THE
    ATTORNEY
    GENERAL
    JIJj,
    STATE
    OF
    ILLINOIS
    C.
    20o,g
    Lisa
    Madigan
    UtlOfl
    ontrjOlS
    ATTORNEY
    GENERAL
    July 29,
    2009
    1
    John
    T
    Therriault,
    Assistan
    Crk
    01
    N
    ‘:
    Illinois
    Pollutiàn
    Control
    Board
    (
    James
    R. Thompson
    Center,
    Ste.
    11-500
    100 West
    Randolph
    Chicago,
    Illinois
    60601
    Re:
    People
    v.
    Waste
    Hauling
    Landfill,
    Inc.,
    et
    a!
    Dear Clerk:
    Enclosed
    for
    filing
    please
    find
    the
    original
    and
    ten
    copies
    of a Notice
    of
    Filing,
    Entry
    of
    Appearance
    and
    Complaint
    in regard
    to the
    above-captioned
    matter.
    Please
    file
    the
    originals
    and
    return
    file-stamped
    copies
    to
    me
    in
    the enclosed,
    self-addressed
    envelope.
    Thank
    you
    for
    your
    cooperation
    and consideration.
    Very
    truly
    yours,
    V
    4
    (2”
    Environmental
    Buu
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    (217)
    782-9031
    JLMfpjk
    Enclosures
    500
    South Second
    Street, Springfield,
    Illinois
    62706 • (217)
    782-1090
    • TrY:
    (877)
    844-5461
    • Fax: (217)
    782-7046
    100
    West Randolph
    Street,
    Chicago,
    Illinois
    60601
    • (312)
    814-3000
    • TTY:
    (800)
    964-3013
    • Fax:
    (312)
    814-3806

    BEFORE
    THE
    ILLiNOIS
    POLLUTION
    CONTROL
    BOARD
    WASTE
    HAULING
    LANDFILL,
    INC.,
    JERRY
    CAMFIELD,
    A.
    E. STALEY
    MANUFACTURING
    CO.,
    ARCHER
    DANIELS
    MIDLAND,
    INC.,
    ARAMARK
    UNIFORM
    SERVICES,
    INC., BELL
    SPORTS,
    INC., BORDEN
    CHEMICAL
    CO.,
    BRIDGESTONE/FIRESTONE,
    INC., CLIMATE
    CONTROL,
    INC.,
    CATERPILLAR,
    INC., COMBE
    LABORATORIES,
    INC., GENERAL
    ELECTRIC
    RAILCAR
    SERVICES
    CORPORATION, P &
    H
    MANUFACTURING,
    INC.,
    TRINITY
    RAIL
    GROUP,
    INC.,
    TRIPPLE
    S
    REFINING
    CORPORATION,
    and ZEXEL
    ILLINOIS,
    INC.,
    Respondents.
    CLERK’S
    OFFIC
    NOTICE
    OF FILING
    To:
    WASTE
    HAULING
    LANDFILL,
    INC.
    do Jerry
    Camfield,
    Sr.
    2938 Oakmont
    Drive
    Decatur,
    IL
    62521
    JERRY
    CAMFIELD,
    SR.
    2938
    Oakmont
    Drive
    Decatur,
    IL 62521
    A.
    E. STALEY
    MANUFACTURING
    Co.
    do C
    T
    Corporation
    System
    208
    South
    LaSalle
    St.,
    Suite
    814
    Chicago,
    IL
    60604
    ARCHER DANIELS
    MIDLAND,
    INC.
    c/o C
    T
    Corporation
    System
    208 South
    LaSalle
    St.,
    Suite
    814
    Chicago,
    IL 60604
    CLIMATE
    CONTROL,
    INC.
    do
    Charles
    A. Demirjian,
    R.A.
    225 N.
    Water
    Street
    Decatur,
    IL
    62523
    ARAMARK
    UN[FORM
    SERVICES,
    INC.
    C T
    Corporation
    System
    208
    South
    LaSalle
    St.,
    Suite 814
    Chicago,
    IL 60604
    BELL
    SPORTS,
    INC.
    do
    Illinois
    Corporation
    Service
    801
    Adlai Stevenson
    Dr.
    Springfield,
    IL 62703
    BORDEN
    CHEMICAL
    CO.
    do
    Prentice
    Hall Corporation
    33 North
    LaSalle
    St.
    Chicago,
    IL 60602
    BRIDGESTONE
    FIRESTONE,
    INC.
    c/o C
    T
    Corporation
    System
    208 South
    LaSalle
    St., Suite
    814
    Chicago,
    IL
    60604
    CATERPIILLAR,
    INC.
    do
    C
    T Corporation
    System
    208 South LaSalle
    St.,
    Suite 814
    Chicago,
    IL 60604
    PEOPLE
    OF THE
    STATE
    OF
    ILLINOIS,
    )
    )
    Complainant,
    )
    vs.
    )
    PCBNo.
    )
    (Enforcement)
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    JUL
    30
    20Q
    STPT°’
    ILUNOIS
    pajtiOfl
    Cofltr0
    board
    1

    COMBE LABORATORIES,
    INC.
    do
    C
    T Corporation
    System
    208 South
    LaSalle St., Suite
    814
    Chicago, IL 60604
    P & H MANUFACTURING,
    INC.
    604 S. Lodge
    P.O. Box
    549
    Shelbyville,
    IL 62565
    TRIPLE
    REFINING
    CORPORATION
    do
    C T Corporation System
    208 South
    LaSalle St., Suite 814
    Chicago,
    IL
    60604
    GENERAL ELECTRIC
    RAILCAR
    SERVICES
    CORPORATION
    do C T
    Corporation System
    208 South LaSalle
    St., Suite 814
    Chicago,
    IL 60604
    TRINITY
    RAIL
    GROUP, INC.
    do C T
    Corporation
    System
    208
    South
    LaSalle
    St.,
    Suite
    814
    Chicago, IL 60604
    ZEXEL
    ILLINOIS, INC.
    do Kathy Carter,
    R.A.
    625 Southside Drive
    Decatur,
    IL 62525
    PLEASE
    TAKE
    NOTICE
    that
    on this date I mailed
    for
    filing
    with
    the
    Clerk
    of the Pollution
    Control
    Board
    of
    the State of Illinois,
    a COMPLAINT,
    a copy
    of which
    is attached
    hereto
    and herewith
    served
    upon
    you. Failure to
    file
    an
    answer
    to
    this Complaint
    within
    60 days
    may have severe consequences.
    Failure
    to
    answer
    will
    mean
    that all
    allegations
    in this Complaint
    will
    be
    taken
    as
    if admitted
    for
    purposes
    of this
    proceeding. Ifyou
    have any
    questions about this procedure,
    you
    should contact
    the
    hearing officer
    assigned
    to
    this proceeding,
    the Clerk’s
    Office or an attorney.
    FURTHER,
    please
    take notice that
    financing
    may
    be
    available,
    through
    the Illinois Environmental
    Facilities
    Financing
    Act,
    20 ILCS
    35
    15/1
    (2006), to
    correct
    the pollution alleged
    in the Complaint
    filed in
    this
    case.
    Respectfully submitted,
    PEOPLE
    OF
    THE STATE
    OF ILLINOIS
    LISA MADIGAN,
    Attorney General
    of
    the
    State
    of Illinois
    2

    500 South Second Street
    Springfield, Illinois 62706
    217/782-9031
    Dated: July
    29,
    2009
    3
    MATTHEW J. DUNN,
    Chief
    Environmental Enforcement/Asbestos
    Litigation Division
    BY:&
    ///
    JAMES
    /A
    L. MORG
    (Z
    Sr.
    Assistant Attrn’
    General
    Environmental Bureau

    CERTIFICATE
    OF
    SERVICE
    I hereby certify
    that I did
    on
    July 29,
    2009,
    send
    by
    certified mail, with
    postage thereon
    fully
    prepaid,
    by depositing
    in a United
    States Post
    Office
    Box a
    true and correct
    copy of the
    following instruments
    entitled
    NOTICE OF FILING,
    ENTRY
    OF APPEARANCE
    and
    COMPLAINT:
    To:
    WASTE HAULING
    LANDFILL,
    INC.
    do Jerry Camfield,
    Sr.
    2938
    Oakmont Drive
    Decatur,
    IL 62521
    JERRY CAMFIELD,
    SR.
    2938
    Oakmont Drive
    Decatur,
    IL
    62521
    A.
    E.
    STALEY MANUFACTURING
    CO.
    do C T Corporation
    System
    208
    South LaSalle
    St.,
    Suite
    814
    Chicago, IL
    60604
    ARCHER
    DANIELS
    MIDLAND, INC.
    do C T Corporation
    System
    208
    South LaSalle
    St., Suite 814
    Chicago, IL
    60604
    CLIMATE
    CONTROL,
    INC.
    do Charles A.
    Demirjian,
    R.A.
    225
    N.
    Water Street
    Decatur, IL
    62523
    COMBE
    LABORATORIES,
    INC.
    do
    C
    T Corporation
    System
    208
    South LaSalle
    St., Suite
    814
    Chicago, IL
    60604
    ARAMARK
    UNIFORM
    SERVICES,
    INC.
    C T
    Corporation
    System
    208 South LaSalle
    St.,
    Suite 814
    Chicago,
    IL 60604
    BELL
    SPORTS,
    INC.
    do
    Illinois
    Corporation Service
    801 Adlai Stevenson
    Dr.
    Springfield,
    IL 62703
    BORDEN CHEMICAL
    CO.
    do
    Prentice Hall Corporation
    33 North LaSalle
    St.
    Chicago, IL
    60602
    BRIDGESTONE
    FIRESTONE,
    INC.
    do C
    T Corporation
    System
    208 South LaSalle
    St.,
    Suite
    814
    Chicago, IL 60604
    CATERPIILLAR,
    INC.
    do
    C T
    Corporation
    System
    208
    South
    LaSalle St., Suite
    814
    Chicago, IL
    60604
    GENERAL ELECTRIC
    RAILCAR
    SERVICES
    CORPORATION
    do C T Corporation
    System
    208 South LaSalle
    St.,
    Suite
    814
    Chicago,
    IL 60604

    P & H MANUFACTURING,
    INC.
    604
    S.
    Lodge
    P.O.
    Box 549
    Shelbyville,
    IL 62565
    TRIPLE REFINING
    CORPORATION
    c/o C
    T Corporation
    System
    208 South LaSalle St., Suite
    814
    Chicago, IL 60604
    TRINITY
    RAIL GROUP, INC.
    do
    C T Corporation System
    208 South LaSalle
    St.,
    Suite
    814
    Chicago, IL
    60604
    ZEXEL ILLINOIS, INC.
    do Kathy Carter, R.A.
    625 Southsicle Drive
    Decatur, IL 62525
    and the original and ten
    copies
    by First Class Mail
    with postage thereon fully prepaid of the
    same
    foregoing instrument(s):
    To:
    John T. Therriault, Assistant Clerk
    Illinois
    Pollution Control Board
    James R. Thompson
    Center
    Suite 11-500
    100
    West Randolph
    Chicago, Illinois 60601
    ‘JAMES L.
    MORGAN/
    Sr.
    Assistant Attorney General
    This
    filing
    is submitted on recycled paper.

    BEFORE
    THE
    ILLINOIS
    POLLUTION CONTROL
    BOARD
    WASTE HAULING
    LANDFILL, INC.,
    JERRY
    CAMFIELD,
    A. E. STALEY
    MANUFACTURING
    CO.,
    ARCHER
    DANIELS
    MIDLAND,
    INC.,
    ARAMARK
    UNIFORM
    SERVICES, INC.,
    BELL
    SPORTS,
    INC.,
    BORDEN
    CHEMICAL
    CO.,
    BRIDGESTONE/FIRESTONE,
    INC., CLIMATE
    CONTROL,
    INC.,
    CATERPILLAR,
    INC., COMBE
    LABORATORIES,
    INC.,
    GENERAL
    ELECTRIC
    RAILCAR
    SERVICES
    CORPORATION,
    P &
    H
    MANUFACTURING,
    INC.,
    TRINITY RAIL
    GROUP,
    INC.,
    TRIPPLE
    S
    REFINING
    CORPORATION,
    and
    ZEXEL ILLINOIS,
    INC.,
    )
    Respondents.
    ENTRY
    OF
    APPEARANCE
    On
    behalf of
    the Complainant,
    PEOPLE
    OF
    THE STATE
    OF
    ILLINOIS,
    JAMES
    L.MORGAN,
    Sr.
    Assistant Attorney
    General
    of the State of
    Illinois, hereby enters
    his
    appearance
    as
    attorney of
    record.
    500
    South
    Second Street
    Springfield,
    Illinois 62706
    217/782-9031
    Dated:
    July 29,
    2009
    Respectfully
    submitted,
    PEOPLE
    OF THE
    STATE
    OF ILLINOIS,
    LISA MADIGAN
    Attorney
    General
    of
    the
    State
    of Illinois
    MATTHEW
    J. DUNN,
    Chief
    Environmental
    Enforcement/Asbestos
    Sr.
    Assistant
    Attorney
    General
    PEOPLE OF
    THE STATE OF ILLINOIS,
    )
    V
    )
    Complainant,
    V
    )
    )
    vs.
    )
    PCBNo.
    )
    (Enforcement)
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    L
    30200
    pollution
    cco4Lf
    N,
    Litigation
    Division

    BEFORE
    THE ILLINOIS POLLUTION CONTROL BOARD
    MACON
    COUNTY, ILLINOIS
    PEOPLE OF THE STATE OF ILLINOIS,
    )
    )
    Complainant,
    )
    v.
    )
    PCBNO.
    ‘i
    WASTE HAULING LANDFILL, INC., JERRY
    )
    (Cost Recovery)
    CAMFIELD, A. E. STALEY MANUFACTURING
    )
    CO., ARCHER DANIELS MIDLAND, INC.,
    )
    ARAMARK UNIFORM
    SERVICES,
    INC., BELL
    )
    SPORTS, INC.,
    BORDEN
    CHEMICAL, CO.,
    )
    BRIDGESTONE/FIRESTONE, INC.,
    CLIMATE
    )
    CONTROL, INC., CATERPILLAR INC., COMBE
    )
    LABORATORIES,
    INC., GENERAL
    ELECTRIC
    )
    R
    E
    C
    E
    V
    ED
    RAILCAR SERVICES
    CORPORATION,P
    &
    H
    )
    CLERK’S
    OFFICE
    MANUFACTURING, INC.,
    TRINITY RAIL GROUP,
    )
    .,nng
    INC., TRIPLE
    S
    REFINING CORPORATION,
    and
    )
    LUU
    ZEXEL
    ILLINOIS, INC.,
    )
    STATh
    OF
    ILLINOIS
    pollution
    Control
    Board
    Respondents.
    COMPLAINT
    Complainant,
    PEOPLE OF THE STATE OF
    ILLINOIS, by LISA MADIGAN, Attorney
    General
    of the State of
    Illinois, complains of Respondents,
    WASTE HAULING LANDFILL, INC., JERRY
    CAMFIELD,
    AE STALEY
    MANUFACTURING
    CO.,
    ARCHER DANIELS MIDLAND, INC.,
    ARAMARK
    UNIFORM
    SERVICES, INC., BELL SPORTS, INC., BORDEN CHEMICAL, CO.,
    BRIDGESTONE/FIRESTONE, INC.,
    CLIMATE CONTROL, INC.,
    CATERPILLAR INC.,
    COMBE
    LABORATORIES, INC.,
    GENERAL ELECTRIC RAILCAR
    SERVICES CORPORATION,
    P
    &
    H
    MANUFACTURING, INC.,
    TRIPLE S REFINING
    CORPORATION, TRINITY RAIL GROUP, [NC.,
    and ZEXEL
    ILLINOIS,
    INC. as follows:
    COUNT I:
    COST RECOVERY
    1.
    This
    Complaint is brought by the
    Attorney General on her own motion and at the
    request
    of
    the Illinois
    Environmental
    Protection
    Agency
    (“Illinois EPA”), pursuant to the terms and provisions
    of
    1

    Title VIII
    (Sections 30-34)
    of the Illinois
    Environmental
    Protection
    Act (“Act”),
    415 ILCS
    5/30-34
    (2008).
    2.
    The
    Illinois
    EPA
    is
    an agency of
    the State
    of
    Illinois created
    by
    the
    Illinois
    General
    Assembly
    in Section 4
    of
    the
    Act, 415
    ILCS 5/4 (2008),
    and charged,
    inter alia,
    with the duty
    of
    enforcing
    the Act
    in proceedings
    before the Illinois
    Pollution
    Control Board
    (“Board”).
    3.
    This Complaint
    is brought
    pursuant
    to Section 22.2(f)-(k)
    of
    the Act, 415
    ILCS 5/22.2(f)-
    (k)
    (2008).
    4.
    Respondent,
    Waste
    Hauling Landfill,
    Inc.,
    is
    a
    corporation
    formerly
    authorized to
    do
    business
    in the
    State
    of
    Illinois
    and
    is a
    person
    as
    defined
    in Section
    3.315
    of the Act,
    415
    ILCS 5/3.315
    (2008).
    Waste
    Hauling Landfill,
    Inc., operated
    the Waste
    Hauling
    Landfill (the
    “Landfill”),
    a former
    sanitary landfill
    located
    in
    the Northwest
    Quarter
    of the Northwest
    Quarter
    of Section
    26, Township
    16
    North,
    Range
    1 East (Blue
    Mound Township),
    Macon
    County,
    Illinois.
    5.
    Respondent,
    Jerry
    Camfield,
    is an
    individual
    and
    is
    a
    person
    as defined
    in Section
    3.3
    15
    of the
    Act,
    415 ILCS 5/3.3
    15 (2008).
    Jerry Camfield
    owned
    Waste
    Hauling
    Landfill,
    Inc.,
    and personally
    directed
    itsoperations.
    6.
    Respondent,
    A. E. Staley
    Manufacturing
    Co.,
    is a
    corporation
    authorized
    to
    do business
    in the State
    of Illinois
    and is
    a
    person
    as
    defined in Section
    3.315
    of the Act,
    415 ILCS
    5/3.315
    (2008).
    A.
    E.
    Staley
    Manufacturing
    Co.,
    sent wastes
    to the
    Landfill
    during
    its
    operating
    life
    and those
    wastes
    contained
    hazardous substances.
    7.
    Respondent,
    Aramark
    Uniform
    Services,
    Inc.,
    is a
    corporation
    no longer authorized
    to
    do
    business
    in the
    State of Illinois
    and is a
    person as
    defined
    in Section
    3.3
    15 of the
    Act,
    415
    ILCS
    5/3.3 15
    (2008).
    Aramark
    Uniform Services
    is
    a
    successor
    to
    Means Uniform
    Services.
    Means
    Uniform
    Services
    sent wastes
    to
    the
    Landfill
    during its
    operating
    life and
    those wastes
    contained
    hazardous
    substances.
    2

    8.
    Respondent, Archer
    Daniels Midland,
    Inc.,
    is
    a
    corporation
    authorized
    to do
    business
    in
    the State
    of Illinois
    and is a person as
    defined in
    Section 3.3
    15 of
    the Act,
    415
    ILCS
    5/3.315
    (2008).
    Archer
    Daniels Midland,
    Inc., sent wastes
    to the Landfill during
    its operating life and those
    wastes
    contained
    hazardous substances.
    9.
    Respondent, Bell Sports,
    Inc., is a
    corporation authorized
    to do
    business in the
    State of
    Illinois
    and is
    a
    person as defined
    in Section 3.3 15
    of the Act, 415
    ILCS 5/3.3 15 (2008).
    Bell Sports,
    Inc., sent wastes to
    the
    Landfill
    during its operating life
    and those
    wastes
    contained
    hazardous
    substances.
    10.
    Respondent,
    Borden Chemical Co.,
    is
    a
    corporation
    authorized
    to do business
    in
    the
    State
    of Illinois and
    is
    a
    person
    as
    defined in Section 3.3
    15
    of the Act,
    415 ILCS 5/3.3 15 (2008).
    Borden
    Chemical
    Co.,
    sent wastes
    to
    the Landfill
    during its
    operating life and those
    wastes contained hazardous
    substances.
    11.
    Respondent,
    Caterpillar
    Inc., is
    a
    corporation
    authorized
    to do
    business in the
    State of
    Illinois
    and is
    a
    person as
    defined
    in Section 3.3 15
    of
    the Act, 415
    ILCS 5/3.3
    15
    (2008). Caterpillar
    Inc.
    sent
    wastes to
    the
    Landfill
    during
    its operating
    life
    and
    those wastes
    contained hazardous
    substances.
    12.
    Respondent, Climate
    Control,
    Inc.,
    is
    a
    corporation
    authorized
    to do business
    in the
    State
    of Illinois and
    is a
    person
    as
    defined in Section
    3.3
    15 of
    the Act,
    415 ILCS
    5/3.3 15 (2008). Climate
    Control,
    Inc.,
    sent
    wastes
    to the Landfill during
    its operating
    life and those
    wastes contained
    hazardous
    substances.
    13.
    Respondent, Combe
    Laboratories,
    Inc., is a
    corporation
    authorized to
    do
    business
    in the
    State of
    Illinois and
    is
    a
    person as defined
    in Section
    3.3 15
    of the
    Act, 415 ILCS 5/3.3 15
    (2008).
    Combe
    Laboratories,
    Inc.,
    sent wastes to
    the Landfill during its
    operating life
    and
    those
    wastes
    contained
    hazardous
    substances.
    3

    14.
    Respondent,
    Bridgestone/Firestone
    Inc., is
    a
    corporation
    authorized to
    do
    business
    in
    the
    State
    of
    Illinois and
    is a
    person
    as
    defined
    in Section 3.3
    15 of the Act,
    415 ILCS
    5/3.3 15
    (2008).
    Bridgestone/Firestone
    Inc., is
    a successor
    to Firestone
    Tire
    &
    Rubber
    Company.
    Firestone
    Tire
    &
    Rubber
    Company,
    sent wastes
    to the
    Landfill during
    its operating
    life
    and those
    wastes contained
    hazardous
    substances.
    15.
    Respondent,
    General Electric
    Railcar
    Services
    Corporation,
    is
    a corporation
    authorized
    to do business
    in the State
    of
    Illinois
    and is a
    person
    as
    defined
    in
    Section
    3.315
    of the Act, 415
    ILCS
    5/3.3
    15 (2008).
    General
    Electric
    Railcar
    Services
    Corporation
    acquired
    the
    North
    American
    Car
    Corporation.
    The North
    American
    Car
    Corporation
    sent
    wastes
    to
    the
    Landfill
    during its
    operating
    life
    and those
    wastes
    contained
    hazardous
    substances.
    16.
    Respondent,
    Triple
    S
    Refining
    Corporation,
    is a corporation
    authorized
    to
    do business
    in
    the
    State
    of Illinois
    and is
    a person as
    defined in
    Section
    3.3 15 of
    the Act,
    415
    ILCS 5/3,3
    15 (2008).
    Triple
    S
    Refining
    Corporation
    is
    a
    successor to
    Kerr-McGee
    Refining
    Corporation.
    Kerr-McGee
    Refining
    Corporation
    sent wastes
    to
    the Landfill
    during its operating
    life
    and
    those
    wastes contained
    hazardous
    substances.
    17.
    Respondent,
    P & H Manufacturing,
    Inc.,
    is a corporation
    authorized
    to do
    business in
    the
    State of
    Illinois and
    is a
    person
    as defined
    in
    Section
    3.3 15 of the
    Act, 415 ILCS
    5/3.3 15
    (2008). P
    & H
    Manufacturing,
    Inc.,
    sent
    wastes to
    the Landfill
    during
    its operating
    life and
    those wastes
    contained
    hazardous
    substances.
    18.
    Respondent,
    Trinity
    Rail Group,
    Inc., is a
    corporation
    authorized
    to do business
    in the
    State of
    Illinois
    and is
    a
    person
    as defined
    in
    Section 3.3
    15 of the Act,
    415 ILCS
    5/3.3 15 (2008).
    Trinity
    Rail
    Group, Inc.,
    acquired
    Thrall Car
    Manufacturing
    Co.,
    which
    had previously
    acquired
    the rail
    car
    division
    of
    Portec,
    Inc.
    Thrall Car
    Manufacturing
    Co.
    and
    the
    rail car division
    of Portec,
    Inc.,
    sent wastes
    to
    the Landfill
    during
    its
    operating
    life
    and
    those wastes
    contained
    hazardous
    substances.
    4

    19.
    Respondent, Zexel Illinois,
    Inc., is a corporation authorized to do business in the State
    of
    Illinois
    and is a
    person
    as
    defined
    in Section 3.315 of the Act, 415 ILCS 5/3.315 (2008). Zexel Illinois,
    Inc., acquired Borg-Warner Corp. Borg-Warner Corp.
    sent
    wastes
    to
    the Landfill during its operating
    life
    and those
    wastes
    contained
    hazardous
    substances.
    20.
    Section 22.2 of the Act, 415 ILCS
    5/22.2
    (2008),
    provides that:
    ***
    f.
    Notwithstanding any other provision or rule of law, and subject only to the defenses
    set
    forth in subsection
    (j)
    of this Section, the following persons shall
    be
    liable for all costs of
    removal or remedial action incurred
    by
    the
    State
    of Illinois or any unit of local government
    as
    a
    result of a release or substailial threat
    oa
    release ofhazrdous substance
    or
    pesticide:
    1.
    the owner
    and operator of a facility or vessel
    from which
    there is
    a release or substantial threat of a release of a
    hazardous
    substance
    or
    pesticide;
    2.
    any person who at the time of disposal, transport, storage or
    treatment of a hazardous substance or pesticide owned or operated
    the
    facility or vessel used for such disposal, transport, treatment
    or storage
    from which there was
    a
    release or substantial threat of a release of a
    hazardous substance or pesticide;
    3.
    any person who
    by
    contract, agreement,
    or
    otherwise
    arranged
    for disposal or treatment, or arranged with
    a
    transporter for
    transport
    for
    disposal
    or
    treatment,
    of
    such
    hazardous substances owned or possessed
    by such
    person,
    by
    any other
    party
    or entity, at any
    facility,
    *
    *
    *,
    owned
    or operated
    by
    another party or entity and containing such hazardous
    substances,
    * **
    21.
    The wastes
    and
    other
    materials disposed of at the Landfill include hazardous substances
    as
    defined by 3.14 of the
    Act,
    415 ILCS
    5/3.14
    (2008).
    22.
    The State
    has incurred and will continue to incur removal costs, as defined by the Act,
    associated
    with the releases
    and
    threatened
    releases
    of hazardous substances
    at
    the Facility.
    23.
    Respondents
    are each
    a
    responsible
    party as
    described in Section 22.2(f)(1)-(2) of the
    Act,
    415 ILCS
    4/22.2(f)( 1 )-(2).
    Respondents
    are
    each liable for past, present, and future removal costs,
    as
    defined by
    the Act,
    incurred
    by the
    State
    resulting or
    arising out of the releases and threatened releases
    5

    at the
    Landfill.
    PRAYER
    FOR RELIEF
    WHEREFORE, Complainant,
    the PEOPLE OF THE STATE OF
    ILLINOIS, respectfully
    request
    that
    the
    Board enter an order against the Respondents:
    A.
    Authorizing
    a hearing in this matter
    at
    which time
    the
    Respondents
    will be required
    to
    answer the
    allegations herein;
    B.
    Finding the Respondents, Waste Hauling Landfill,
    Inc., Jerry Camfield, A E Staley
    Manufacturing Co.,
    Archer Daniels Midland,
    Inc., Aramark Uniform Services, Inc., Bell Sports, Inc.,
    Borden Chemical, Co., Bridgestone/Firestone Inc., Climate Control, Inc., Caterpillar Inc.,
    Combe
    Laboratories,
    Inc., General Electric Railcar Services Corporation, P
    &
    H Manufacturing,
    Inc., Triple
    S
    Refining Corporation,
    and Trinity Rail Group, Inc.,
    to be
    liable for
    past,
    present,
    and future removal
    costs, as
    defined by the
    Act,
    incurred
    by
    the Illinois EPA
    as a
    result of the releases
    and
    threatened
    releases of
    hazardous substances at the
    Facility;
    C.
    Finding Respondents, to be liable for damages equal to
    three times the
    past,
    present,
    and
    future
    removal costs, as
    defined by the Act, incurred by the Illinois EPA as a
    result
    of
    the releases
    and
    threatened
    releases
    of hazardous substances at the Facility; because
    of
    the
    Respondents’ refusal
    to
    perform
    the work set
    forth
    in the Section
    4(q)
    notice issued by
    Illinois
    EPA;
    D.
    Awarding
    to
    Complainant its costs; and
    6

    E.
    Granting such other relief
    as the Board may deem appropriate.
    Respectfully
    submitted,
    PEOPLE
    OF THE STATE OF
    ILLINOIS
    LISA MADIGAN,
    Attorney General
    of the
    State
    of Illinois,
    MATTHEW
    J. DUI’JN, Chief
    Environmental
    Enforcement/Asbestos
    Litigation
    Division
    BY:__________________
    THOMAS DAVIS,
    Chief
    Environmental Bureau
    Assistant Attorney General
    Of Counsel
    James L. Morgan
    Assistant Attorney
    General
    500
    South Second Street
    Springfield,
    Illinois 62706
    217/524-7506
    Dated:
    7

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