-
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF
ILLINOIS,
VILLAGE OF SIMS, an Illinois
municipal
corporation;
FOLLOWELL
CONSTRUCTION COMPANY,
INC.,
an
Illinois
corporation;
and
LAMAC ENGINEERING
COMPANY,
an
Illinois
corporation,
Respondent.
)
)
)
)
)
)
)
)
RECEiVED
CLERt~’~
(~F~t’T
JUN
1
2
2003
NOTICE OF FILING
To:
Mr., Jay H.
Fyie,
Esq.
Fyie & Hawkins
Attorneys for the Village of Sims
Box 279
115
Northeast Third
Street
Fairfield,
IL 62837-0279
Mr.
Richard
L.
Kline,
Esq.
Attorney for Lamac Engineering
Co.
120
E.
Fifth Street
P.O.
Box Drawer 400
Mt.
Carmel,
IL 62863-0400
Mr.
John
S.
Brewster,
Esq.
Winters,
Brewster, Crosby
&
Schafer
Attorneys for Followell Construction Company,
Inc.
111
West
Main,
P.O.
Box 700
Marion,
IL 62959
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 MOTION FOR RELIEF FROM HEARING REQUIREMENT
and STIPULATIONAND PROPOSAL FOR SETTLEMENT WITH FOLLOWELL CONSTRUCTION
COMPANY,
INC.,
copies of which are attached
hereto and
herewith served upon you.
Respectfully submitted,
PEOPLE
OF
THE
STATE
OF
ILLINOIS
LISA MADIGAN,
Attorney General
of the
State of
Illinois
500 South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
June
9, 2003
MATTHEW
J.
DUNN, Chief
Environmental Enforcement/Asbestos
Litigation
Division
BY:
~
/
‘~
7
JANE
E.
McBRIDE
Assistant Attorney General
Environmental Bureau
Complainant,
vs.
PCB No. 03-224
(Enforcement)
STATE OF ILLINOIS
Pollution
Control Board
CERTIFICATE OF SERVICE
I hereby certify that
I
did
on June
9,
2003, send
by First
Class
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, MOTION
FOR RELIEF
FROM HEARING
REQUIREMENT and STIPULATION AND
PROPOSAL FOR SETTLEMENT WITH
FOLLOWELL CONSTRUCTION COMPANY,
INC.
To:
Mr. Jay H.
Fyie,
Esq.
Mr.
Richard
L.
Kline,
Esq.
Fyie & Hawkins
Attorney for Lamac Engineering Co.
Attorneys for the Village of
Sims
120
E.
Fifth
Street
Box 279
P.O.
Box Drawer 400
115
Northeast Third
Street
Mt. Carmel,
IL 62863-0400
Fairfield,
IL 62837-0279
Mr. John
S.
Brewster,
Esq.
Winters,
Brewster, Crosby
& Schafer
Attorneys for Followell Construction Company,
Inc.
111
West Main,
P.O.
Box 700
Marion,
IL 62959
and the original and ten copies by First Class
Mail with
postage thereon fully prepaid of the
same foregoing
instrument(s):
To:
Dorothy Gunn, Clerk
Illinois
Pollution Control
Board
State of Illinois
Center
Suite
11-500
100 West Randolph
Chicago,
Illinois 60601
-~
~‘•—-‘~
.J~eE.
McBride
Assistant Attorney General
This filing is submitted on
recycled paper.
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
CLERI’s
OFFICE
JUN
1
2
2003
PEOPLE OF THE STATE OF ILLINOIS,
-
)
STATE OF ILLINOIS
Poll~tj0,~
Contr0j Board
Complainant,
)
)
v.
)
PCB
NO.
03-224
)
(Enforcement)
VILLAGE OF SIMS, an
Illinois
)
municipal
corporation,
FOLLOWELL
)
CONSTRUCTION COMPANY,
INC.,
)
an
Illinois corporation,
and
)
LAMAC ENGINEERING
COMPANY,
)
an Illinois corporation,
)
Respondent.
)
MOTION
FOR RELIEF FROM
HEARING
REQUIREMENT
NOW COMES
Complainant,
PEOPLE
OF THE
STATE OF ILLINOIS,
by
LISA
MADIGAN, Attorney General of the State of Illinois, and
pursuant to Section 31(c)(2) of the
Illinois Environmental Protection Act (“Act”), 415 ILCS 5/31(c)(2)
(2002), moves
that the
Illinois
Pollution
Control
Board grant the Complainant and Respondent Followell Construction
Company,
Inc., (“Followell”) relief from the hearing requirement imposed
by Section 31(c)(1) of
the Act, 415 ILCS
5/31 (c)(1) (2002).
In support of this motion, Complainant states as follows:
1.
On June 9,
2003,
Complainant filed a Complaint with the Board,
alleging
violations by Respondent
Followell
in the installation of new water main requirements.
2.
The Complainant and
Respondent Followell
have reached agreement on all
outstanding issues
in
this matter.
3.
This agreement
is presented to the Board
in a Stipulation and
Proposal for
Settlement, filed
contemporaneously with this
motion.
1
4.
Complainant and
Respondent Followell agree that a hearing
on the Stipulation
and
Proposal for Settlement is not necessary, and
respecifully request relief from such a
hearing as allowed by Section
31 (c)(2) of the Act, 415 ILCS 5/31 (c)(2)
(2002).
WHEREFORE, Complainant, PEOPLE
OF THE STATE OF ILLINOIS, hereby requests
that the Board
grant this motion for relief from the hearing
requirement set forth
in
Section
31(c)(1) of the Act, 415
ILCS 5/31(c)(1)
(2002).
Respectfully submitted,
PEOPLE
OF THE STATE
OF ILLINOIS
LISA
MADIGAN
ATTORNEY GENERAL
MATTHEW J.
DUNN, Chief
Environmental Enforcement/Asbestos
Litigation
Division
BY:
~
~‘
~
—~
JANE
E.
McBRIDE
Environmental
Bureau
Assistant Attorney General
500
South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
~
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERFcS
OFFICE
JUN
1
2
2003
PEOPLE OF THE STATE OF
)
ILLINOIS,
)
-
STATE OF ILLINOIS
)
Pollution
Control Board
Complainant,
)
)
v.
)
PCB No.
03-224
)
(Enforcement)
VILLAGE OF SIMS, an Illinois
municipal
corporation; FOLLOWELL
CONSTRUCTION COMPANY,
INC.,
an
Illinois corporation; and
LAMAC
ENGINEERING COMPANY,
)
an
Illinois
corporation,
-
)
)
Respondents.
)
STIPULATION
AND PROPOSAL
FOR SETTLEMENT
WITH FOLLOWELL CONSTRUCTION COMPANY, INC.
Complainant,
PEOPLE
OF THE STATE
OF ILLINOIS,
by LISA MADIGAN, Attorney
General
of the State of
Illinois, at the request of the ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY (“Illinois
EPA”), and the Respondent FOLLOWELL CONSTRUCTION
COMPANY,
INC.
do hereby submit this Stipulation and
Proposal for Settlement.
The parties
stipulate that the Statement of Facts
contained
herein represents
a fair summary of the
evidence and testimony which would
be
introduced by the parties
if a full hearing
were held
on
those issues for which a settlement is proposed.
The parties agree that the purpose of this
Stipulation
and
Proposal for
Settlement is to resolve Complainant’s
claims against Respondent
Followell Construction
Company,
Inc.
as set forth
in the pending
Complaint.
The
parties further
stipulate that this Statement of Facts
is made and
agreed
upon for purposes
of settlement only
and
that neither the fact that a party has entered
into this Stipulation, nor any of the facts
stipulated
herein, shall be
introduced
into
evidence in this or any other proceeding except to
enforce the terms
hereof
by the parties to
this agreement.
Notwithstanding the previous
sentence,
this Stipulation and
Proposal for Settlement or Illinois
Pollution
Control
Board
(“Board”) Order accepting same may be used
in any future enforcement action
as evidence of a
past adjudication of violations, as
provided
in
Sections 39(i) and 42(h) of the Illinois
Environmental Protection Act (“Act”), 415
ILCS 5/39(i) and 42(h) (2002).
This agreement shall
be
null and void
unless the Board approves
and disposes of this matter on each and every one
of the terms and
conditions of the settlement set forth
herein.
JURISDICTION
The Board
has jurisdiction of the subject matter herein and of the parties consenting
hereto
pursuant to
the Illinois
Environmental Protection Act, 415
ILCS 5/1
et seq.
(2002).
The
Complaint states a cause of action
upon which relief may be
granted.
II.
AUTHORIZATION
The authorized
representatives for each signatory to
this Stipulation and
Proposal for
Settlement certify that they are fully authorized
by the party whom
they represent to
enter into
the terms and
conditions of this Stipulation
and Proposal for settlement and to
legally bind that
party to
it.
Ill.
APPLICABILITY
This Stipulation and
Proposal
for Settlement shall apply to
and
be binding
upon the
Complainant and
Respondent Followell Construction Company, Inc.,
as well as the successors
and assigns of Respondent Followell Construction Company,
Inc. and
any of its officers,
directors,
agents,
employees or servants.
Respondent Followell Construction
Company,
Inc.
shall not raise as a defense to any action
undertaken to enforce the terms
and
conditions of this
Stipulation and Proposal
for Settlement or the
Board
Order approving
it, the failure of its
officers,
directors,
agents,
employees
or servants to take such
action
as shall
be required to
2
comply with the provisions of this Stipulation
and
Proposal for Settlement.
IV.
STATEMENTOF FACTS
Pursuant to the requirements of
35
III. Adm.
Code 103.302, the parties submit the
following stipulation of facts
pertaining to the
nature,
extent, and
causes of the violations and
the nature of Respondents’ operations and
control
equipment.
1.
The Complaint and this Stipulation and
Proposal for Settlement are brought
pursuant to
the statutory
authority of the Attorney General to prosecute civil actions
to
obtain
civil penalties
for violations of the Act, 415
ILCS 5/1
et seq.
(2000),
and
at the request of the
Illinois Environmental Protection Agency.
2.
Respondent Village of Sims (hereinafter, the “Village”) is an
Illinois municipal
corporation
located in
the county
of Wayne.
3.
Respondent
Followell Construction Company,
Inc.
is an
Illinois corporation
in
good standing, located in
Marion, Williamson County,
Illinois.
Its registered agent is Ben
Followell,
104-Water Tower Road,
P0 Box 756,
Marion,
IL 62959.
4.
Respondent Lamac Engineering
Company is an
Illinois
corporation in good
standing, located
in Mount Carmel, Wabash
County,
Illinois.
Its registered agent is Richard
L.
Kline,
120 E.
5th
Street,
Mount Carmel,
IL 62863-2120.
5.
Respondent Village owns and operates
a public water supply serving
its
residents.
6.
Respondent Village’s public water supply serves approximately 421
consumers
through
161
direct connections.
The Village obtains water from the Wayne City Public Water
Supply by way of a booster station, located
at the Wayne City Water Treatment Plant.
7.
On or about April
14,
1997,
the
Illinois
EPA issued Construction
Permit No.
3
I 204-FY 1997 to
the Village for the installation of new water main
in the Village.
On or about
March
19,
1999,
the Illinois
EPA issued an
operating permit to the Village for the new water
main.
8.
The Village employed
Lamac Engineering
Company to
perform certain design
work on the water main project.
9.
Respondent
Lamac Engineering Company prepared
plans and
specifications for
the water main
project.
10.
The Village employed
FolloweD
Construction Company,
Inc.
to construct the
water main
project.
11.
As owner of the water mains, Respondent Village had
direct responsibility for
supervising the water main
project.
12.
On
January 11, 2000,
a representative of the Village contacted
the Marion
Regional Office of the Illinois
EPA, and
stated that Followell Construction installed
a water main
that was not properly separated from the Village’s sewer system and that the contractor was
refusing to confirm that the systems were properly separated.
13.
On January
11,
2000,
a
representative of the
Illinois
EPA directed the Village to
expose the water main to determine its distance from the sewer system, and
to relocate the
water main
if it was within ten feet horizontal distance or eighteen
inches vertical
distance from
the sewer system.
14.
On
February
1,
2000,
a representative of Lamac Engineering
contacted the
Illinois
EPA and
stated that
he was not aware of the location of the sewer system
and did
not
know whether
it was separated from the Village’s public water system.
15.
On February
1,
2000,
a representative of the Village contacted
the Illinois
EPA
and
stated that the Village had exposed the water main
near Lift Station
No.
3 and found
a
distance of four feet of horizontal distance between the water main and the manhole, six feet of
4
horizontal distance between the water main
and the lift
station,
and eight inches of vertical
distance between the sewer main
where the water main crossed
it.
16.
On
February 2, 2000,
representatives of the Illinois
EPA, the Village and
Lamac
Engineering visited the site of Lift Station
No. 3 on the sewer collection system,
located on the
west side of County Highway 900E at the intersection of Richardson Street.
The Illinois EPA
inspector confirmed the failure to provide adequate separation,
and
also observed
that the
water main and
sewer main appeared to lack adequate separation a distance of one half to
one
quarter mile from the
lift station.
-The inspector advised the Village to expose the lines leading
away from
the lift station to determine whether they were properly separated.
17.
At the time of the January 11,
2000, and
February
1
and 2, 2000,
discussions
between a representative of the Illinois
EPA and Respondents,
it was determined that
Respondent Lamac Engineering
had released
at
least three different versions of the plans
prepared for this project.
Each set differed and the three sets were
not in agreement as to
significant specific features on the system.
One or more set of these plans were utilized
by
Respondent Followell at the job site as
construction plans.
18.
On August 9,
2000,
representatives of the Illinois
EPA, the Village,
Lamac
Engineering,
and Followell Construction
met at the site and
discussed the various areas
throughout the project requiring
correction.
19.
Respondents Lamac and
Followell claim that
Respondent Village was
responsible for providing as-built plans showing the location of existing sewer
system prior to
installation but never did
so, and further claim that the Village still
had not supplied such
plans
as of August 9,
2000.
If this claim is taken as true,
knowing
that the as-built plans were not
available, Respondents
Lamac and
Followell proceeded with the installation without adequate
information to assure compliance with the Act and the Board’s public water supplies rules.
20.
On April
18,
2001, the parties completed work
to correct the separation
5
distances.
During the relocation
of the water main, the Illinois
EPA inspector noted the
following violations and corrective actions:
a.
At Lift
Station No.
3 on
the sewer collection
system, the water main was
cut on the west side of County
Highway 900E, where it crossed
under the
gravity sewer line.
The contractor relocated the water main twenty-five
feet to the south of the lift station.
b.
At
a location in
proximity to the Borah residence, the water main was
cased and
placed greater than eighteen
inches below the sewer service
connection.
c.
On
Robinson Street, the contractor cased
and installed the water main on
the south side
of the street,
locating it greater than eighteen inches under
each sewer service connection.
The contractor reconnected
the water
main at the north side of the street greater than ten feet from the sewer
manhole.
d.
On Moyer Street, the contractor relocated the water main and
hydrant
more than
twenty-five feet to
the west of Lift Station No.
5 on the sewer
collection system.
The contractor also relocated the water service line
and meter.
e.
At Lift
Station No.
I
on the sewer collection system, the contractor
relocated the water main twenty-five feet from the lift station.
21.
By causing or allowing installation
of new water main
in a manner so that the
installation
did not meet the horizontal
and vertical separation distances required by the EPA’s
Public Water Supplies rules,
Respondent Followell Construction Company,
Inc.
has violated
Sections
1 8(a)(1),
(2) and
(3) of the Act, 415 ILCS
5/18(a)(1),
(2),
(3)
(2000),
and
35
III. Adm.
Code 607.104(b).
22.
By failing
to comply with the conditions of its Construction
Permit #1204-FYI 997,
Followell Construction
Company,
Inc.
has violated
Section
15 of the Act, 415
ILCS 5/15
(2000),
and
35
III. Adm.
Code 602.101(b).
6
V.
FUTURE PLANS OF COMPLIANCE
The Respondent Followell Construction Company,
Inc.
shall diligently conform to the
Act, 415
ILCS 5/1
et
seq.
(2002),
and the Board’s regulations, 35
III. Adm.
Code, Subtitles A
through H.
VI.
IMPACT
ON THE
PUBLIC RESULTING FROM NONCOMPLIANCE
Section 33(c) of the Act, 415
ILCS 5/33(c)
(2002),
provides:
***
c.
In
making its orders and determinations, the Board shall take into
consideration all the facts and circumstances bearing
upon the
reasonableness of the emissions, discharges, or deposits involved
including,
but not limited
to:
the character and degree
of injury to, or interference with
the protection of the health,
general welfare and
physical
property of the people;
ii.
the social
and economic value of the pollution source;
iii.
the suitability or unsuitability of the pollution source to
the
area
in which
it is
located,
including
the question of priority
of location in
the area involved;
iv.
the technical
practicability and economic reasonableness
of reducing or eliminating the emissions, discharges or
deposits resulting from such
pollution source;
and
v.
any subsequent compliance.
In
response to these factors, the parties
incorporate by reference the Statement of Facts
and also state as follows:
1.
The injury to or interference
with thehealth, general welfare and
physical
property of the people
would be characterized
as
having the potential for contaminating the
public water supply of the Village of Sims
and
negatively impacting
public health by
potentially
7
causing disease.
The degree of injury would
be potentially severe.
2.
If installed with the proper separation
distance, the water and sewer line project
at issue is of social
and economic benefit to the Village of Sims.
3.
The water and
sewer lines,
if installed with the proper separation distance,
are
located
in
a suitable site for such lines and the site has
been found
suitable by the Illinois EPA
for such
use.
4.
Compliance with the Act
and
Board
regulations is techniOally practicable and
economically reasonable.
-
5.
The project has
been reconstructed
to bring
it into
compliance with the Act and
applicable regulations.
VII.
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Stipulation and
Proposal for Settlement in no way affects the responsibility of
Respondent
Followell Construction Company,
Inc.
to comply with any federal,
state, or local
laws
or regulations,
including
but not limited to the Act, 415 ILCS
5/1
et
seq.
(2002), and the
Board’s rules and
regulations,
35
Ill. Adm.
Code,
Subtitles A through
H.
VIII.
DETERMINATION OF APPROPRIATE CIVIL PENALTY
Section 42(h) of
the Act, 415
ILCS 5/42(h) (2002),
provides:
***
h.
In determining the appropriate civil penalty to
be
imposed under
subdivisions (a),
(b)(1), (b)(2), (b)(3) or (b)(5) of this Section, the
Board
is authorized
to consider any matters of record
in mitigation
or aggravation of
penalty, including,
but not limited to the following
factors:
(1)
the duration and gravity of the violation;
8
(2)
the presence or absence of due diligence on
the
part of the violator in attempting to comply with the
requirements of this Act and
regulations thereunder
or to
secure relief therefrom
as
provided by this
Act;
(3)
any economic benefits
accrued
by the violator
because of delay in compliance with
requirements;
(4)
the amount of monetary penalty which will serve
to
deter furtherviolations
by the violator and to
otherwise aid
in enhancing voluntary compliance
with this Act by the violator and other persons
similarly subject
to the Act; and
(5)
the number,
proximity in time, and
gravity of
previously adjudicated violations
of this Act by the
violator.
In
response to these
factors, the parties
incorporate by reference the Statement of Facts
and
also state as follows:
1.
The alleged violations required
reconstruction of portions of the project,
resulting
in
expenditure of approximately seven thousand five hundred dollars
($7,500.00) by
Respondent Followell Construction
Company,
Inc.
more than was
initially contemplated.
2.
Reconstruction
has
corrected the project so as
to
return it
to compliance.
3.
Respondents realized no economic benefit from noncompliance.
4.
Complainant has
determined,
in this instance,
that a penalty of five thousand
dollars ($5,000.00) will serve to deter future violations and
aid
in future voluntary enforcement
of the Act and applicable Board
rules and regulations.
5.
Complainant has also determined that Respondent Followell Construction
Company,
Inc.
has
no
known history of prior
adjudicated violations.
lx.
NONADMISSION OF LIABILITY
This Stipulation and
Proposal for Settlement is entered into for the purpose of settling
9
and
compromising disputed claims without the expense of contested
litigation.
By entering
into
this Stipulation and Proposal for Settlement and
complying with its terms,
Followell Construction
Company,
Inc.
does
not affirmatively admit the allegations of violation within the Complaint, and
this Stipulation and Proposal for Settlement shall not be
interpreted as including
such
admission.
x.
PROPOSAL FOR SETTLEMENT
1.
Respondent
Followell Construction
Company, Inc.
shall pay a penalty of five
thousand
dollars ($5,000.00),
within thirty (30) days
of the Board’s Order approving
this
Stipulation and
Proposal
for Settlement.
Payment shall
be
by certified
check made payable to,
“Illinois Environmental Protection
Agency, for deposit into the Environmental Protection Trust
Fund,” and
shall be submitted
to:
Illinois
Environmental Protection Agency
Fiscal
Services
Section
1021
North Grand
Avenue East
Post Office Box 19276
Springfield,
Illinois
62794-9276
The name, number of the case,
and the Respondent’s Federal Employer Identification
Number (“FEIN”) shall appear on the check.
Respondent Followell’s
FEIN is 37-1 286435.
A copy of the check and payment transmittal shall
be simultaneously submitted to:
Donna
Lutes
Illinois Attorney General’s
Office
Environmental Bureau
500
South
Second Street
Springfield,
Illinois 62706
2.
In the event the penalty is not paid
in a timely fashion,
interest shall accrue and
be paid by Respondent
Followell Construction Company Inc. at the rate set forth
in
Section
1003(a) of the Illinois
Income Tax Act,
35
ILCS 5/1003(a) (2002),
pursuant to
Section 42(g) of
10
the Act,415 ILCS 5/42(g) (2002).
3.
If Respondent
Followell Construction Company,
Inc.
fails to
comply with
any
material requirement set forth
in this Stipulation and
Proposal for Settlement, Respondent
Followell Construction Company,
Inc. shall pay
in liquidated penalties the sum of five
hundred
dollars ($500.00)
per month of noncompliance,
until such
time as the requirements
are
complied with, said
penalty to
be paid
to the Environmental Protection Trust
Fund in the manner
provided
above.
4.
Respondent Followell Construction Company,
Inc.
shall cease and
desist from
future violations of any federal,
state, or local environmental statutes and
regulations,
including,
but not limited to, the Act, 415
ILCS 5/1
et
seq.
(2002),
and the Board’s rules and regulations,
35
III.
Adm.
Code,
Subtitles A through
H.
Xl.
ABATEMENT
OF VIOLATIONS
This Stipulation
and
Proposal
for Settlement, upon
its adoption
by the Board, constitutes
an
order to abate violations of the Act
and regulations thereunder.
XII.
RELEASE FROM
LIABILITY
The Complainant shall release, waive and
discharge Respondent
Followell Construction
Company,
Inc.
from any further liability or penalties
for violations of the Act and
Board
regulations which were specifically the subject matter of the Complaint herein, upon
receipt by
Complainant of the payment required
in
Section
IX.1., and
upon compliance with
the terms of
this Stipulation and
Proposal for Settlement.
However, nothing
in
this Stipulation and
Proposal
for Settlement shall
be construed as a waiver
by Complainant of the right to
redress future
violations
or obtain
penalties with
respect thereto, nor shall anything contained
herein constitute
11
a waiver by Respondent to contest and defend any and all alleged future, violations or penalties.
WHEREFORE, Complainant and
Respondent Followell Construction Company,
Inc.
request that the Board
adopt and accept the foregoing Stipulation
and
Proposal
for Settlement
as written.
AGREED:
FORTHECOMPLAINANT:
LISAMADIGAN
Attorney General of the State of Illinois
MATTHEW J.
DUNN, Chief
-
Environmental Enforcement/Asbestos
Litigation
Division
BY: ___________________________
THOMAS
DAVIS, Chief
Environmental Bureau
Assistant Attorney General
DATED:
_____________
ILLI
S
ENVIRONM
NTAL PROTECTION AGENCY
BY:______________________
~ef Legal
‘~DA
DATED:__________________
FORTHE RESPONDENTS:
en Followell, President
FOLLOWELLCONSTRUCTION COMPANY,
INC.
DATED:
__________________
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