~ECE
lIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERKS OFTh1(~
PEOPLE OF THE STATE OF ILLINOIS,
)
JUL
3
0
2003
Complainant,
STATE
OF
ILLINOIS
Pollution Control Board
PCB 97
-
9
(Enforcement
-
Land)
C
&
S RECYCLING,
INC., an Illinois
corporation,
FLOOD BROTHERS
DISPOSAL COMPANY,
INC.,
an
Illinois Corporation, WILLIAM
FLOOD,
Individually, and as
treasurer of C & S Recycling,
and BRIAN FLOOD,
Individually,
and as president of C & S
Recycling,
Respondents.
NOTICE OF FILING
TO:
See Attached Service List
PLEASE TAKE NOTICE that today
I have filed with the
Pollution Control Board the following Stipulation and Proposal
for Settlement,
Request for Relief from the Hearing Requirement,
and Certificate of Service, on behalf of the People of the State
of Illinois,
a copy of which
is attached and hereby served upon
you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA
MADIGAN
Attorney General
State of Illinois
BY:
________________
JOEL
J.
STERNSTEIN
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th Floor
Chicago,
Illinois
60601
(312)
814-6986
DATE: July 30, 2003
THIS FILING
IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST
Mr. Brad Halloran,
Esq.
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street,
Suite 11-500
Chicago,
IL
60601
Mr. Peter Orlinsky,
Esq.
Illinois Environmental Protection Agency
9511 Harrison Street
Des
Plaines,
IL
60016
Mr. Harvey Sheldon,
Esq.
Hinshaw & Culbertson
222
N.
LaSalle
Street,
Suite
300
Chicago,
IL 60601-1801
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD CLERK’S OFFICE
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
JUL
3
0
2003
Comp1ainant~
)
SlATE OFILLINOIS
Pollutj~,~
Control Board
v.
)
PCB 97
-
9
(Enforcement
-
Land)
C & S RECYCLING,
INC.,
an Illinois
corporation,
FLOOD BROTHERS
DISPOSAL COMPANY,
INC.,
an
Illinois Corporation,
WILLIAM
FLOOD,
Individually,
and
as
treasurer
of
C
&.
S
Recycling,
and
BRIAN
FLOOD,
Individually,
)
-
and
as
president
of
C
&
S
Recycling,
Respondents.
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
(“Board”)
grant
the
parties
in the above-captioned matter 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.
The Complaint
in this matter alleges violations of the
Board’s
solid
waste
regulations
in
addition
to
Sections
21(a)
and
21(d)
of the Environmental Protection Act
(“Act”)
2.
Complainant
is
filing
this
Motion
and
a
Stipulation
and
Proposal
for
Settlement
with
the
Board.
3.
The parties have reached agreement on all outstanding
issues in this matter.
4.
This agreement
is
presented
to
the
Board
in
a
Stipulation and Proposal for Settlement which is filed
contemporaneously with this Motion.
5.
All parties agree that a hearing on the Stipulation and
Proposal
for
Settlement
is
not
necessary,
and
respectfully
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
State
of
Illinois
BY:
_______
JOEL J.
STERNSTEIN
Assistant Attorney General
Environmental
Bureau
188 W. Randolph St.,
20th Floor
Chicago, Illinois
-
60601
(312)
814-6986
DATE:
July 30, 2003
A.
BEFORE THE ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THF~STATE
OF
ILLINOIS,
)
CLERIcS OFFICE
Complainant,
)
JUL
3
02003
STATE
OF ILLINOIS
v.
)
PCB
97
-
9
1’OIlUtjOfl
Contro/ Board
(Enforcement)
C &
S RECYCLING,
INC.,
an Illinois
corporation,
FLOOD BROTHERS
DISPOSAL COMPANY,
INC.,
an~.
Ii~linoisCorporation,
WILLIAM
FLOOD,
Individually, and as
treasurer of C &
S Recycling,
and BRIAN FLOOD,
Individually,
and as president of C & S
Recycling,
Respondents.
STIPULATION
AND
PROPOSAL
FOR
SETTLEMENT
Com~1ainant, PEOPLE OF THE STATE OF ILLINOIS,
by LISA
MADIGAN, Attorney General of
the..Sta’t’e of Illinois,
at the
request
of
the Illinois Environmental Protection Agency
(collectively,
the “State”), and Respondents for purposes of this
Stipulation and Proposal fdr Settlement,
C & S RECYCLING,
INC.,
(“C & 5”)
and
FLOOD BROTHERS DISPOSAL COMPANY,
INC.
(“Flood
Brothers”)
do hereby’ agree to this Stipulation and Proposal for
Settlement
(“Agreement”)
.
The parties further stipulate that
this statement of alleged facts
is made and agreed upon for
purposes
of settlement only and that neither the fact that a
1
3
party has entered into this Agreement, nor any of the alleged
facts stipulated herein,
shall be introduced into evidence in
this or any other proceeding except to enforce the terms of this
Agreement.
Notwithstanding the previous sentence,
this Agreement
and any Illinois Pollution Control Board
(“Board”)
order
accepting same may be used in any future enforcement action by.
Complainant as evidence of a past adjudication of the Illinois
Environmental Protection Act
(“Act”),
415 ILCS 5/1
et seq.
(2002),
for
purposes
of Sections 39(1)
and 42(h)
of the Act,
415
ILCS 5/39(1),
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.
I.
JURISDICTION
The Board has jurisdiction of the subject matter herein and’
of the parties consenting hereto pursuant to the Act,
415 ILCS
5/1
et
seq.
(2002)
.
II.
AUTHORIZATION
The
undersigned rep~esentativefor each party certifies that
he or she
is fully authorized by the party whom he or she
2
represents
to
enter
into
the
terms of this Agreement and to
legally
bind them to
it.
III.
APPLICABILITY
This Agreement shall apply to and be bii~dingupon
Complainant and Respondents,
afld any officer, director,
agent and
employee or servant of Respondents,
as well as Respondents’
‘successors
and
assigns.
Respondents
shall
not
raise
as
a
defense
to any enforcement action
taken
pursuant
to this Agreement the
failure of their officers,
directors,
agents,
servants or
employees
to
take
such
action
as
shall
be required to comply with
the provisions of this Agreement.
IV.
STATEMENT OF FACTS
A.
Parties
1.
The
Attorney
General
of
the
State
of
Illinois
brings
this
action
on
her
own
motion
and
at
the
request
of
the
Illinois
Environmental Protection Agency
(“Illinois
EPA.”),
and
pursuant
to
the
statutory
authority
vested
in
her
under
Section 31 of the
Act, 415 ILCS 5/31
(2002)
2.
The Illinois EPA is an administrative agency in the
3
executive branch of the State government
of Illinois,
created
pursuant
to
Section
4
of
the
Act,
415
ILCS
5/4
(2002),
and
is
charged,
inter
alia,
with the duty
of
enforcing
the
Act.
3.
At
all
times
relevant
to
this
settlement,
Respondents
C & S and FLOOD BROTHERS were Illinois corporations
in good
standing.
4.
At all times relevant to
this’ settlement until 2002,
Respondents
have
been
engaged
in
the
operation
of
a
Site
located
at 4009
West
Taylor
Street,
Chicago,
Cook
County,
Illinois
(“Site”)
at
which
recyclable
and
non-recyclable
materials
are
received,
sorted
and
transferred
for
further
treatment
or
disposal.
5.
The Site
is not permitted by the Illinois EPA for the
operation of a solid waste management Site.
B.
Alleged
ViOlations
1.
In
its
Complaint,
Cot~nplainantalleges the following
violations
of
the
Act:
Count
I: Open dumping,
in violation of Section 21(a)
of
the
Act,
415
ILCS.5/2l(a)
(2002).
Count II: Development of a solid waste management
site
without a permit,
in violation of Section 21(d)
of the
Act,
415 ILCS 5/21(d)
(2002),
and 35
Ill. Adm.
Code
807.201.
0
4
Count
III: Operation of a solid waste nianagement site
without
a
permit,
in
violation
of
Section
21(d)
of
the
Act,
415 ILCS5/2l(d)
(2002), and 35
Ill. Adm.
Code
807.202.
2.
For purposes of this Settlement,
the Respondents do not
contest the alleged violations.
V.
IMPACT
ON
THE
PUBLIC
RESULTING
FROM
ALLEGED
NON-COMPLIANCE
Section 33(c)
of the Act,
415 ILCS 5/33 (c) (2002)
,
provides
as follows:
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:
1.
the
character
and
degree
of
injury
to,
or
interference
with
the
protection
of
the
health,
general
welfare
and
physical
property of the
people;
0
2.
the social and economic value of the pollution
source;
3.
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;
4.
the technical practicability and economic
reasonableness of reducing or eliminating the
emissions, discharges or deposits resulting from
such pollution source; and
5
5.
any subsequent compliance.
In response to these factors, the parties state the
following:
1.
Although human health and the environment were
potentially threatened and the Illinois EPA’s information
gathering responsibilities were hindered by RespOndents’
activities,
there is no evidence of actual negative impact to the
public
resulting
from
Respondents’
alleged
noncompliance.
2.
There is social and economic benefit to the community
from the Site.
3.
Upon’ effectuating the changes as contemplated by this
Agreement,
the Site will be suitable for the area in which
it
operates.
Past Site operation has sometimes involved the receipt
of
garbage.
The Site does not currently meet the setback
requirements
now
imposed
by
law
for
garbage-related
solid
waste
management units.
4.
Obtaining the requisite permits prior to the
development and operation of the Site was both technically
practicable
and
economically
reasonable.
5.
Pursuant to this agreement,
Respondents have committed
to returning to compliance with the Act and the Board Regulations
6
by
agreeing to become a recycling center as that term is defined
at Section 3.375 of the Act, 415 ILCS 5/3.375
(2002).
VI.
CONSIDERATION OF SECTION 42(h)
FACTORS
Section 42(h)
of the Act,
415 ILCS 5/42(h) (2002),
provides’
as follows:
In determining the appropriate civil penalty to be
imposed
under
.
.
.
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;
2.
the
presence
or
absence
of
due
diligence
on
the
part of the violator in attempting to comply with
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 further violations 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 violatio~isof this Act by
the violator.
In response to these factors,
the parties state as follows:
7
1.
Respondents have operated a solid waste management site
without a permit from at least October 20,
19,92 until
200,2.
2.
Respondents were not. diligent in attempting to comply
with the Act, Board Regulations and applicable Federal
regulations.
3.
Respondents have realized an economic benefit from
their operation of the Site.
The amount of that benefit,
however,
is unquantifiable.
4.
Complainant has determined that a penalty of Forty-Five
Thousand Dollars
($45,000.00)
will serve to deter further
violations
and
aid
in
future
voluntary
compliance
with.
the
Act
and Board regulations.
5.
To.
Complainant’s
knowledge,
Respondents
have
committed
no previously adjudicated violations of the Act.
VII.
TERMS
OF SETTLEMENT
A.
Penalty
Payment
1.
Respondents
shall
be
jointly
and
severally
liable
for
and
pay
a
penalty
in
the
sum
of
Forty-Five
Thousand
Dollars
($45,000.00).
Respondents
shall
pay
the
Forty-Five
Thousand
Dollar
($45,000.00)
penalty
within
thirty
(30)
days
of
the
date
8
the Board adopts and accepts this Agreement.
The penalty
described in this Agreement shall
be’ paid by certified check
payable to the Illinois Environmental Protection Agency,
designated to the Illinois Environmental Protection Trust Fund
and submitted to:
Illinois
Environmental
Protection
Agency
Fiscal Services Section
1021 North Grand Avenue East
P.O. Box 19276
Springfield,
IL 6794-9276
The ‘name and number of the case and remitting Respondent’s
Federal Employer Identification Number
(FEIN)’,
36-3670247,
shall
appear on the check.
.
2.
Respondents shall secure a ‘letter of credit regarding
the $45,000.00 penalty.prior to the filing of this Stipulation
and Proposal for Settlement with the Board.
Respondents shall
provide the letter of credit to
Joel Sternstein
Assistant Attorney General
Environmental Bureau North
188 W. Randolph St.,
20th
Floor
Chicago,
Illinois 60601
3.
For purposes of payment and collection, Respondents may
be reached at the following addresses:
9
‘
C & S Recycling,
Inc.
4009
W.
Taylor
Street
Chicago,. IL
60624-3904
Flood Brothers Disposal Company,
Inc.
Attn:
Mr. Robert Flood’
17 W.
697 Butterfield Road,
Suite E
Oakbrook Terrace,
IL
60181
B.
Compliance
Respondent C &
S shall maintain compliance with the
prohibition against management of municipal solid waste without a
permit as follows:
1.
The Site shall not accept further recyclables until
Respondent
C &
S has made any necessary repairs,
installations
and arrangements for recycling prior to restarting Site
operation.
Respondents shall provide notice to Complainant at
least fourteen
(14)
days
in advance of their intended’ res’tart
date’ and shall allow inspection of the Site by Complainant to
confirm that necessary changes have occurred to enable lawful
unpermitted recyc~ingto occur.
2.
Respondent C
& S shall be allowed to accept at the
Site,
in accordance with City of Chicago license, ordinance, and
permit,
the following recyclable source-separated materials: dry
paper,
dry cardboard,
glass, plastics, wood and metals.
10
3.
Immediately
up6n
filing
of
this
Agreement,
Respondents
shall
not
accept
any
“garbage”
at
the
Site
as
that
term
is
defined
in
Section
3.200
of
the
Act,
415
ILCS
5/3.20.0
(2002)
4,
Respondent,
C
&
S,
shall
diligently
inspect
all
future
incoming loads
of
materials
at
the
Site
to
determine
whether
any
garbage
or
garbage-contaminated
materials
have
been
accidently
included
in
any
load.
5.
Within
24
hours
of
starting
operations,
Respondent
C
&
S
shall
have
trained
its
employees
in
the
recognition,
proper
handling
and
disposal
of
garbage
and
garbage-contaminated
waste.
6.
If any garbage is received at the Site,
Respondent C &
S
shall, upon discovery,
remove it from
the
recycling
stream
along with any recyclables which it has visibly contaminated.
7.
‘Respondent C &
S shall, upon discovery,
place all
garbage and garbage-contaminated waste
in segregated containers,
remove
it
from
the
Site
within
twenty-four
(24) hours of receipt,
and
send
it’
to
a
landfill
permitted
to
accept
such
waste.
Garbage and garbage-contaminated recyclables or waste
so removed
shall not be deemed “accepted”
for purposes of this Consent
Order.
8.
Respondent C
.&
S
shall keep detailed records of any
11
garbage received at the Site including,
if determinable,
the
generator of the garbage,
the truck and driver that transported
the garbage to C &
5,
the type and amount of ~arbage in pounds
(lbs.), and the time,
method and location of disposal of the
garbage.
C.
Stipulated Penalties
1.
.
If Respondent C & 5:
a.
Fails to complete any activity by the date
specified in Section VII.B.
of this Consent Order; or
b.
Accepts any mate’rial at its Site which does not
comport with the definition of recycling center at Section 3.375
of the Act, 415 ILCS 5/3.375
(2002)
then Respondent C &
S shall
provide notice to Complainant of each failure to comply with this
Consent Order.
In addition, Respondent C &
S shall pay to
Complainant,
for payment into the Environmental Protection Trust
Fund,
stipulated penalties per violation for each day of
violation in the amount of One Thousand Dollars
($1,000.00)
until
such time that compliance is achieved.
2.
Following Complainant’s determination that Respondent C
&
S has failed to complete performance of any task or other
portion
of
work
or
failed
to
provide
a
required
submittal,
12
including any report or notification,’ Complainant may make a
demand for stipulated penalties upon Respondent C & S for its
noncompliance with this Consent Order.
Failure by Complainant to
make this demand shall not relieve Respondent C & S of the
obligation to pay stipulated penalties.
3.
‘
All penalties owed to Complainant under’ this section
of this Consent Order that have not been paid shall be payable
within thirty
(30)
days of the date Respondent
C & S knows or
should
have
known
of
its noncompliance with any provision of this
Consent Order.
4a.
All stipulated penalties shall be paid by certified
check or money order payable to the Illinois EPA f~rdeposit
in
the Environmental Protection Trust Fund and delivered to:
Illinois Environmental Protection Agency
Fiscal Services
1021 North. Grand Avenue East
P.O. Box 19276
‘
-
Springfield,
Illinois 62794-9276
4b.
The name and number of the case and Respondent C & S’s
FEIN shall appear on the face of the check.
A copy of the
check(s)
and the transmittal letter shall be sent to:
13
Joel Sternstein
Assistant Attorney General
Environmental Btu~eauNorth
188
W.
Randolph
St.,
20th
Floor
Chicago,
Illinois
60601
5.
The stipulated penalties shall be enforceable by
Complainant and shall be in addition to, and shall not preclude
the use of, any other remedies or sanctions arising from the
failure to comply with this Consent Order.
D..
Interest on Penalties
1.
Pursuant’
to
Section
‘42(g)
of
the
Act,
415
ILCS
5/42(g)
(2002),
interest
shall
accrue
on
any
penalty or stipulated
penalty amount owed by Respondents not paid within the time.
prescribed herein,
at the maximum rate allowable under Section
1003 (a)
of
the
Illinois
Income
Tax
Act,
35
ILCS 5/1003 (a) (2002)
2.
Interest
on
unpaid
penalty
or stipulated penalty shall
begin to accrue from the date the penalty is due and continue to
accrue
to
the
date
payment
is
received
by.
the
Illinois~
EPA.
3.
Where partial payment
is made on any penalty or
stipulated
penalty
amount
that
is
due,
such
partial
payment
shall
be first applied to any interest on unpaid penalties or
stipulated penalties then owing.
4.
All i.nterest on penalties or stipulated penalties owed
14
to Complainant
shall be paid by certified check or money order
payable to the Illinois EPA for deposit in the Environmental
Protection Trust Fu,nd at the above-indicated address.
The name,
case number; and remitting Respondent’s FEIN shall appear on the
face of the certified check or money order.
A copy of the
certified ch’eck or money order and the transmittal letter shall
be sent ‘to:
Joel Sternstein
Assistant Attorney General
Environmental Bureau
188
W. Randolph St., 2O’~~~
Floor
Chicago,
Illinois 60601
E.
Cease and Desist
Respondents shall cease and desist from future violations
of
the’Adt,
415 ILCS
5/1
et
seq.
(2002),
and the Board’s Rules and
Regulations,
35
Ill. Adm. Code Subtitles A through H,
including,
but not limited
to,
thos’e
Sections
of
the
Act
and
Board
Regulations that were. the subject matter of ‘the Complaint as
outlined in Section IV.B.
of this Agreement.
F.
Right of Entry
In
addition
‘to
any
other
authority,
t.he
Illinois
EPA,
its
employees and representatives,
the Illinois Attorney General, and
his/her agents and representatives,
shall have the right of entry
15
or access to the Site at all reasonable times,
for the purposes
of conducting inspections.
In
conducting
any
inspection
of
the
Site,
the
Illinois
EPA,
its employees and representatives,
the
Attorney General, and his/her agents and representatives, may
take any photographs,
samples and collect information as they
deem necessary.
Respondents shall never deny Complainant entry
or delay Complainant’s access to the Site at any time the Site
is
operating.
VIII.
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Agreement in no way affects the responsibility of
Respondents to comply with any Federal, State or local
regulations,
including but not limited to the Act, 415 ILCS 5/1
et seq.
(2002), and the Board regulations,
35
Ill. Adm. Code
Subtitles
A
through
H.
IX.
RELEASE FROM LIABILITY
In consideration of Respondents’ payment of the penalty
specified herein and compliance with the terms of this Agreement,
Complainant releases, waives and discharges Respondents from any
further liability or penalties for the alleged violations of the
Act and Board Regulations which are the subject matter of the
Complaint.
This release shall be effective upon receipt by
Complainant of all monies owing pursuant to Section VII.A.
of
16
this
Agreement
and
work
performed
thereunder.
Nothing
in
this
Agreement shall be construed as
a waiver by the Attorney General
or
the
Illinois
EPA
of the right to redress future or heretofore
undiscovered violations,
if any,
or to obtain penalties with
respect thereto.
X.
ENFORCEMENT
OF
SETTLEMENT
Upon the Board~sacceptance and entry of this Agreement,
Complainant, upon motion to the Board or Complaint to the
appropriate Circuit Court, may reinstate these proceedings solely
‘for
purposes
of
enforcing
the
terms
and
conditions
of
this
Agreement,
This
Agreement
is
a
binding
and
enforceable
Order
of
the Board and may be enforced. as such through any and all
available means.
17
‘WHEREFORE,
Complainant and Respondents request that the
Board adopt and accept the foregoing Stipulation and Proposal for
Settlement as written.
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
LISA
MADIGAN,
Attorney General
State, of Illinois
MATTHEW J.
DUNN,
Chief
Environmental Enforcement/
Asbest
Litigation Div
on
BY:
,
DATE:_______
Environmen
ureau
Assistant Attorney General
ILLIN9
ENVIRONMENTAL PROTECTION AGENCY
BY:
J SEPH E.
S
BODA
DATE:4~~_~3
ief Legal Counsel
C & S RECYCLING,’ INC.
BY:
__________________________
DATE:________
Name:
/.‘~‘,1~
Title:
Ppes;de,,~’r
‘
‘
.
FLOOD BROTHERS D SPOSAL COMPANY,
INC.
BY:
_____________________________
DATE:_________
Name~~ERf
FL~D
Title:
Pie~derr~
H:\common\Environmental\JOEL\Case Documents\C&S
.
Flood\stip-final.wpd
18
CERTIFICATE OF SERVICE.
I,
“JOEL J.
STERNSTEIN,
an Assistant Attorney General,
certify that on the ~
day of July,
2003,
I caused to be served
by First Class Mail the foregoing Stipulation and Proposal for
Settlement,
Request for Relief from the Hearing Requirement,
and
Notice of Filing to the. parties named on the attached Service
list,
by depositing same in postage prepaid envelopes with the
United States Postal Service located at 100 West Randolph Street,
Chicago,
Illinois 60601.
JOEL J. STERNSTEIN
H:\common\Environmental\JOEL\Case Documents\C&S
-
Flood\stip-notice-relief-hearing.wpd
