RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
MAY
72004
PEOPLE OF THE STATE OF ILLINOIS,
)
STATE OF ILLINOIS
POIIUtIO~Control Board
Complainant,
PCB No.
02-3
v.
)
(RCRA
-
Enforcement)
CHEVRON ENVIRONMENTAL SERVICES
COMPANY,
a Delaware Corporation,
Respondent.
NOTICE OF FILING
TO:
ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that on May 7,
2004,
we filed with the
Illinois Pollution Control Board a ERRATA TO STIPULATION
AND
PROPOSAL
FOR SETTLEMENT a true and correct copy of which is attached and hereby
served upon you.
Respectfully submitted,
LISA
MADIGAN
Attorney General
State of Illinois
BY:
Chris opher
Perz
Assis an
ne
Ge
ral
Environmental Bureau
188 W. Randolph St.,
20th Floor
Chicago, Illinois
60601
(312)
814-3532
RECE~VED
CLERK’SOFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAY
72004
PEOPLE OF THE STATE OF ILLINOIS,
STATEOF ILLINOIS
Pollution Control Board
Complainant,
PCB No.
02-3
v.
)
(RCRA
-
Enforcement)
CHEVRON ENVIRONMENTAL SERVICES
COMPANY,
a Delaware Corporation,
Respondent.
ERRATA
TO
STIPULATION AND PROPOSAL FOR SETTLEMENT
NOW COMES the Complainant,
PEOPLE OF THE STATE OF ILLINOIS, by
LISA MADIGAN, Attorney General of the State of Illinois, and for its
ERRATA TO STIPULATION
AND
PROPOSAL FOR SETTLEMENT,
states as follows:
1.
On May
5,
2004 the Complainant filed a Stipulation and
Proposal for Settlement with the Board.
Certain copies in that
filing contained a copying error on page 4 of the Stipulation and
Proposal for Settlement.
The corrected page 4
is attached.
WHEREFORE,
the Complainant, PEOPLE OF THE STATE OF ILLINOIS,
requests that the Board incorporate the complete page in place of the
incomplete page.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
Office of the Attorney General
Environmental Bureau
188 W. Randolph Street,
~
Floor
Chicago,
Illinois 60601
312 814-3532
As
General
also requires Respondent to investigate and,
as necessary,
remediate
all environmental conditions at the Lockport site.
6.
On October
9,
2001,
Texaco Inc.,
the parent of TRMI,
became
ChevronTexaco Corporation (“ChevronTexaco”)
.
Upon an internal
reorganization following the merger,
Chevron Environmental Services
Company assumed ownership and operational. control of the former Texaco
Lockport Refinery.
The Illinois EPA approved a modification request
on May 15,
2002 to transfer owner and operator status under the RCRA
Permit to Chevron Environmental Services Company.
This case was
originally brought against TRNI,
a motion to amend the complaint to
change the Respondent’s name to Chevron Environmental Services
Company,
as successor to Texaco Refining & Marketing has been filed
concurrently with this Stipulation and Proposal for Settlement.
B.
ALLEGED VIOLATIONS
1.
Complainant’s Complaint alleges the following
violations:
COUNT
I:
Groundwater contamination in violation of Section
12(a)
of the Act,
415 ILCS 5/12(a)
(2000), and 35
Ill Adm.
Code 620.405.
COUNT II:
Caused or allowed open dumping of coke fines and
tar like material in violation of Section 21(a)
of the Act,
415 ILCS 5/21 (a)
(2000)
2.
The Complainant contends that the evidence introduced if a
hearing were held in this matter would demonstrate the presence of
contaminants
in the groundwater at the Facility each year,
beginning
in 1981 and continuing at least through the filing of this Stipulation
and Proposal for Settlement.
3.
The Respondent represents that it has entered into this
4
SERVICE LIST
Dorothy M. Gunn
John A.
Urban,
Civil Chief
Clerk of the Board
Will County State’s Attorney’s
Illinois Pollution Control
Office
Board
121 N. Chicago Street
100 W. Randolph St.,
11th
Floor
Joliet,
Illinois 60432
Chicago,
Illinois 60601
Barbara Magel
Karaganis,
White & Magel
North Orleans Street
Suite 810
Chicago,
Illinois 60610
CERTIFICATE OF SERVICE
~,
the undersigned,
on oath
or
affirmation
state that I have served
on the date of May
7,
2004,
the attached ERRATA TO STIPULATION
AND
pROPOSAL FOR SETTLEMENT,
by U.S. Mail upon the persons on the attached
Service List.
~ope.Perza~
Dated: May
7,
2004
