ILLINOIS POLLUTION CONTROL BOARD
    June
    4,
    1992
    COUNTY OF OGLE,
    )
    )
    Complainant,
    )
    v.
    )
    AC 91—45
    (91—R—1003)
    (Administrative Citation)
    ROCHELLE DISPOSAL SERVICE,
    )
    INC.,
    and CITY OF ROCHELLE,
    )
    ILLINOIS,
    )
    Respondent.
    ORDER OF THE BOARD
    (by J.C. Marlin):
    This action was initiated on September 27,
    1991 by the filing
    of an administrative citation
    (AC) by the County of Ogle (County).
    The AC charges Rochelle Disposal Services (Rochelle Disposal) and
    the City of Rochelle (City)
    with violation of Section 21(p) (5)
    of
    the Act..1
    Both respondents filed a petition for review on October
    11,
    1991.
    Hearing was held
    in this matter
    on April
    29,
    1992,
    despite the pendancy of
    several motions preliminary
    to hearing
    which
    are the
    subject
    of this
    Order.
    Pursuant
    to the parties
    request at hearing as repeated in the County’s Nay 15, 1992 motion
    to supplement and reserve ruling, the Board has delayed decision on
    the pending motions until its receipt of the hearing transcript and
    exhibits.2
    The pending motions
    are Rochelle Disposal’s
    April
    6,
    1992
    motion
    for
    leave
    to
    file
    instanter accompanied
    by
    a
    motion
    to
    strike and dismiss the complaint and its April
    8,
    1992 motion to
    supplement the April
    6 motion.
    The County filed motions to strike
    and dismiss Rochelle’s motions on April
    9 and 15,
    1992.
    On April
    15,
    1992,
    Rochelle
    Disposal
    moved
    for
    leave
    to
    respond
    to
    the
    County’s motions
    and
    also
    filed
    the
    response.
    Rochelle Disposal also filed a motion for summary judgment.
    The
    County filed a response in opposition on April 22.
    ~Section 21
    of
    the Act was
    amended
    by
    Public Act
    87-752,
    effective
    January
    1,
    1992.
    As
    a
    result,
    the
    two
    subsections
    enforceable through the administrative citation process have been
    changed from 21(p)
    and 21(q) to 21(o)
    and 21(p)
    respectively.
    21n the interests of consistency, the Board has also delayed
    decision on similar motions pending in two other appealed AC cases
    involving these parties:
    AC 91-32 and AC 92—26.
    134—107

    2
    The basis for Rochelle Disposal’s motion to dismiss is that it
    is not
    a proper
    party to this
    action.
    The County’s motion
    to
    strike
    is based on the allegation that the motion is not timely
    filed.
    The Board first addresses the County’s motion.
    Section
    103.140 provides that motions to dismiss
    shall
    be
    filed within
    14
    days after
    receipt of the complaint.
    Rochelle
    Disposal’s motion was not filed until some six months thereafter.
    Rochelle Disposal asserts that
    it had not previously
    filed
    the
    motion based on conversations and correspondence with the State’s
    Attorney to the effect that prosecution of this matter would be
    reviewed in
    light of IEPA v.
    City of Rochelle, AC 89-68,
    a case
    from which Rochelle Disposal had been dismissed as
    a respondent
    upon stipulation of the parties.
    The County does not dispute this
    contention,
    but
    states
    that
    “no
    specific
    statements
    were made
    waiving the time restrictions” pursuant to Board rules.
    The
    Board
    finds
    that
    under
    these
    circumstances
    Rochelle
    Disposal
    could
    reasonably
    have
    construed
    and
    relied
    upon
    its
    ongoing communications with the County as a waiver of any objection
    to late filing.
    Rochelle Disposal’s April
    6 motion for leave to
    file the motion
    to dismiss
    as well
    as
    its April
    8
    motion
    to
    supplement are hereby granted.
    The County’s motion to strike and
    dismiss is denied.
    Respondent’s April 15 motion for leave to file
    a response is hereby granted.
    The result of these rulings are that
    all filings are accepted.
    The Board now turns to the motions to dismiss and for summary
    judgment.
    As hearing has been held in this matter, the motion for
    summary judgment is denied.
    As to the motion to dismiss, Rochelle
    Disposal
    argues
    that
    it
    is
    not
    a
    proper
    party
    to this
    action
    because the City is the person which holds the permits for this
    site, and becaus~eit was previously dismissed as a party to AC 89—
    68 pursuant to stipulation.
    There
    is no dispute that the City
    holds all permits at the site, or that Rochelle Disposal conducts
    waste disposal operations at the site on the City’s behalf pursuant
    to contract.
    The County argues that Section
    21(p)
    of the Act,
    under which Rochelle Disposal
    is
    charged,
    is
    not
    by
    its terms
    limited to holders
    of
    permits.
    The
    Section
    in pertinent part
    provides that “no person (emphasis added)
    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 any of
    the following conditions”.
    The preamble to the contract between the City and Rochelle
    Disposal provides that it is “for the operation of the City owned
    landfill”.
    Article
    I goes on to provide that Rochelle Disposal is
    to “furnish all equipment and labor necessary for the collection of
    garbage within
    the City...together
    with the
    landfill operation
    necessary to dispose of all the solid waste in conformance with”
    the Act and Board regulations, as well as other requirements (City,
    April 22,
    1992 Response to Motion,
    Contract,
    p.
    1).
    134—108

    3
    The Board agrees with the County that, under the circumstances
    of this case, Rochelle Disposal is properly a party to this action
    as a person conducting a waste operation at a permitted site.
    The motion to dismiss is hereby denied.
    IT IS SO ORDERED.
    I, Dorothy H.
    Gunn,
    Clerk of the Illinois Pollution Control
    Board, hereby certi
    that the above order was adopted on the
    ~
    day of
    _________________,
    1992,
    by a vote of
    7~
    ~YT~4M~
    /~-~-‘~
    Dorothy M. 4tunn, Cerk
    Illinois P&llution Control Board
    134—109

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