ILLINOIS POLLUTION CONTROL BOARD
    January
    4,
    1979
    ILLINOIS ENVIRONMENTAL
    PROTECTION AGENCY,
    Complainant,
    v.
    )
    PCB 78—180
    BULK SERVICE CORPORATION,
    a
    Nevada corporation,
    Respondent.
    MR. STEPHEN T. GROSSMARK, ASSISTANT ATTORNEY GENERAL, APPEARED ON
    BEHALF OF THE COMPLAINANT.
    HUBACHEK,
    KELLY, RAUCH
    & KIRBY, ATTORNEYS AT LAW
    (MR. ROBERT 0.
    WIENKE*
    ,
    OF COUNSEL), APPEARED ON BEHALF OF THE RESPONDENT.
    OPINION AND ORDER OF THE BOARD
    (by Mr. Werner):
    This matter comes before the Board on the July
    3,
    1978
    Complaint brought by the Illinois Environmental Protection Agency
    (“Agency”).
    Count
    I of the Complaint alleged that the Respondent
    operated its rail hopper and choke unloading facility from
    February
    1,
    1973 until July
    3, 1978 without first obtaining an
    Operating Permit from the Agency in violation of Rule 103(b) (2)
    of
    Chapter
    2:
    Air Pollution Control Regulations and Section 9(b)
    of
    the Illinois Environmental Protection Act
    (“Act”).
    Count
    II of
    the Complaint alleged that Bulk Service Corporation
    (“Bulk
    Service”)
    emitted particulate matter into the atmosphere from the
    rail hopper and choke unloading facility
    in 1976 which were in
    excess of the allowable emissions
    in violation of Rule 203(b)
    of
    Chapter
    2:
    Air
    Pollution Control Regulations
    and Section
    9(a) of
    the Act.
    A hearing was held on November
    28,
    1978.
    The parties
    filed a Stipulation and Proposal for Settlement on December
    1,
    1978.
    *The Respondent was not represented by counsel at the hearing,
    but Respondent’s counsel was instead
    in communication with the
    Hearing Officer and had requested that the Stipulation and
    Proposal for Settlement be admitted into evidence.
    (Record, p.4).
    32—355

    —2—
    The stipulated facts indicate that Bulk Service was
    incorporated
    in Illinois on or about December
    6,
    1956.
    Nevada CID
    Corporation,
    a Nevada corporation,
    became qualified to do business
    in Illinois on or about March
    8,
    1977.
    Bulk Service merged into
    Nevada CID Corporation on or about March
    28,
    1977.
    Nevada CID
    Corporation changed its name to Bulk Service Corporation on or
    about May 26,
    1977.
    (Stipulation,
    p.
    2).
    Bulk Service Corporation has owned and operated a rail dump
    and choke unloading facility
    (the “facility”)
    in the Tn-City
    Regional Port District near Granite City in Madison County,
    Illinois,
    since at least April
    13,
    1972.
    (Stipulation,
    p.
    2—3)
    The facility consists of three choke pits which are used to
    transfer dry materials such as soybean meal, corn pellets,
    and
    soda ash from rail hopper cars to barges.
    These choke pits have
    been operated 24 hours per day
    (except for Christmas Day and New
    Year’s Day)
    ,
    7 days per week,
    and 52 weeks per year during each
    year since two choke pits were installed
    in 1969 and the third
    in
    1976.
    (Stipulation,
    p.
    3).
    Bulk Service transferred approximately 1,000,000 short tons
    of dry material in 1976;
    890,000 short tons in 1977; and 580,000
    short tons as of July 31,
    1978,
    at its facility.
    However, the
    Company has never possessed an Operating Permit from the Agency
    to operate any of the choke pits at the facility.
    Bulk Service
    applied for an Operating Permit on December
    5,
    1977.
    The
    application was returned for additional information on December 15,
    1977.
    A Notice of Violation was sent to Bulk Service on March 17,
    1978.
    (Stipulation,
    p.
    3)
    Three construction permits were issued to Bulk Service
    on
    July
    6,
    1978,
    to construct three different types of particulate
    control equipment on the choke pits.
    Construction pursuant to,
    and in compliance with, these Construction Permits was completed
    on August 14,
    1978.
    (Stipulation,
    p.
    3-4).
    It
    is stipulated that
    one method of particulate control constructed on one of the choke
    pits
    is preferable over the methods of control constructed on the
    other two choke pits and is capable of bringing the facility into
    compliance.
    (Stipulation,
    p.
    4).
    Accordingly,
    Bulk Service has
    agreed to install this more satisfactory method of particulate
    control on the remaining two choke pits.
    (Stipulation,
    p.
    4).
    The proposed settlement agreement also provides that Bulk
    Service Corporation:
    (1)
    admits that it has not had an Operating
    Permit since June
    1,
    1973,
    in violation of Rule 103(b) (2)
    of
    Chapter
    2:
    Air Pollution Control Regulations;
    (2)
    admits that
    in 1976
    it emitted particulate matter in excess of that allowable
    under Rule 203(b)
    of Chapter
    2:
    Air Pollution Control Regulations,
    in violation of that Rule;
    (3) agrees to promptly file Construction
    32—356

    —3—
    Permits with the Agency for construction
    of the agreed
    upon
    particulate control equipment on the remaining two choke pits;
    (4)
    agrees to complete construction of the particulate control
    equipment on the two remaining choke pits pursuant to the
    Construction Permits within 30 days of receipt by Bulk Service
    of Construction Permits issued by the Agency;
    (5) agrees to apply
    to the Agency for Operating Permits for the particulate control
    equipment on the three choke pits within two weeks of when
    construction of the control equipment is completed;
    and
    (6) agrees
    to pay a stipulated penalty of $500.00 for the violations admitted.
    In evaluating this enforcement action and proposed settlement,
    the Board has taken into consideration all the facts and circum-
    stances
    in light of the specific criteria delineated
    in Section
    33(c)
    of the Act.
    Incinerator,
    Inc.
    v.
    Illinois Pollution Control
    Board,
    59
    Ill.
    2d 290,
    319 N.E.
    2d 794
    (1974)
    .
    Accordingly,
    the
    Board accepts the Stipulation and Proposal for Settlement and finds
    that Bulk Service Corporation has violated Rule 103(b) (2)
    and Rule
    203(b)
    of Chapter
    2:
    Air Pollution Control Regulations and Section
    9(a)
    and Section 9(b)
    of the Illinois Environmental Protection Act.
    The Board imposes the stipulated penalty of $500.00
    This Opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    It is the Order of the Illinois Pollution Control Board that:
    1.
    Bulk Service Corporation has violated Rule 103(b) (2)
    and
    Rule 203(b)
    of Chapter
    2:
    Air Pollution Control Regulations and
    Section
    9(a) and Section 9(b)
    of the Illinois Environmental
    Protection Act.
    2.
    Within 35 days of the date of this Order, Bulk Service
    Corporation shall pay the stipulated penalty of $500.00
    ,
    payment
    to be made by certified check or money order to:
    State of Illinois
    Fiscal Services Division
    Illinois Environmental Protection Agency
    2200 Churchill Road
    Springfield,
    Illinois
    62706
    3.
    Bulk Service Corporation shall comply with all the terms
    and conditions of the Stipulation and Proposal for Settlement
    filed December
    1,
    1978, which
    is incorporated by reference as if
    fully set forth herein.
    Mr. Dumelle concurred.
    I, Christan
    L.
    Moffett, Clerk of the Illinois Pollution
    Control Board, herQby certify the above Opinion and Order were
    adopted on the
    s.J1’~
    day of
    -
    ,
    1979 by a
    vote of
    _________
    32—3 ~
    F
    ~
    Fc’ac

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