BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
TODD’S SERVICE STATION,
)
V.
Petitioner,
)
)
)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
)
PCB No.
03-2
(UST Fund Appeal)
RECE!VED
CLERicS
OFFI(~’E
SEP
1
52003
STATE
OF
ILLINOIS
Pollution Control
Board
Respondent.
)
Dorothy M. Gunn, Clerk
Illinois Pollution Control
Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Carol Sudman, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue, East
P.O. Box 19274
Springfield, IL
62794-92 74
RobertM. Riffle
Elias, Meginnes,
Riffle & Seghetti, P.C.
416 Main Street
Suite 1400
Peoria, IL
61602-1611
PLEASE TAKE
NOTICE that
I have
today
filed with
the office of
the
Clerk
of the
Pollution
Control
Board
a
RESPONSE
TO
PETITIONER’S
POST-HEARING
BRIEF,
copies
of
which
are
herewith served upon you.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Assistant Counsel
Special Assistant Attorney General
Division of Legal Counsel
1021 North Grand Avenue, East
I~.O.Box 19276
Springfield, Illinois 62794-9276
217/782-5544
217/782-9143 (TDD)
Dated:
September
11, 2003
NOTICE
RECEiVED
BEFORE
THE
POLLUTION CONTROL BOARD
CLERK’S
OFRCE
OF THE STATE OF ILLINOIS
SEP
152003
TODD’S SERVICE STATION,
)
STATE OF ILLINOIS
Petitioner,
)
Pollution
Control Board
v.
)
PCB No. 03-2
ILLINOIS ENVIRONMENTAL
)
(UST Fund Appeal)
PROTECTION AGENCY,
)
-
Respondent.
)
RESPONSE
TO PETITIONER’S
POST-HEARING BRIEF
-
NOW
COMES the Respondent,
the
Illinois Environmental Protection
Agency (“Illinois
EPA”),
by
one of its attorneys,
Joim J.
Kim, Assistant
Counsel
and
Special
Assistant Attorney
General,
and,
pursuant to
an order
entered
by the Hearing Officer dated
July 28,
2003,
hereby
submits
its
Response
to
the
Petitioner’s
Post-Hearing
Brief to
the
Illinois
Pollution
Control
Board (“Board”).
I.
BURDEN
OF PROOF
Pursuant
to
Section
105.112(a)
of the
Board’s
procedural
rules
(35
Ill.
Adm.
Code
105.112(a)), the burden of proof shall be
on the petitioner.
The burden is
on the
applicant for
reimbursement
to
demonstrate
that
incurred
costs
are
related
to
corrective
action,
properly
accounted for,
and
reasonable.
Rezmar
Corporation v.
Illinois
EPA,
PCB
02-91
(April
17,
2003), p.
9.
Thus
Todd’s Service Station
(“Todd’s” or “the Petitioner”) must demonstrate to
the
Board that it has satisfied its burden before the Board can enter an order reversing or modifying
the Illinois EPA’s decision under review.
II.
STANDARD OF
REVIEW
Section
57.8(i)
ofthe Environmental Protection
Act (“Act”) grants an individual the right•
to appeal a determination ofthe Illinois EPA to the Board pursuant to Section 40 ofthe Act
(415
ILCS
5/57.8(i)).
Section 40 ofthe Act
(415
ILCS
5/40)
is the general appeal section for pennits
1
and has been used by the legislature as the basis
for this type of appeal to
the Board. Therefore,
when
reviewing
an
Illinois
EPA
determination
of
ineligibility
for
reimbursement
from
the•
Underground
Storage
Tank
Fund
(“UST
Fund”),
the Board
must
decide
whether or
not the
application,
as submitted to the Illinois
EPA, demonstrates
compliance with the Act
and Board
regulations.
Broderick Teaming Company v. Illinois EPA, PCB 00-187 (December 7, 2000).
In deciding
whether the Illinois
EPA’s
decision under appeal
here was appropriate, the
Board
must
look
to
the
documents within the
Administrative
Record
(“Record”),
along with
testimony
provided
at
the
hearing
held
on
July
15,
2003,
in
this
matter.1
Based
on
the
information within the Record and the testimony,
along with the relevant law, the
Illinois
EPA
respectfully requests that the Board enter an order affirming the Illinois EPA’s decision.
III.
THE PETITIONER MISREPRESENTED
THAT TIlE
HOURS FOR
WORK IN
THE
AMENDED BUDGET WERE APPROVED BY THE ILLINOIS EPA
In its Post-Hearing Brief (“Brief’), the Petitioner made statements that certain “facts” are
uncontested.
However, the statements are misleading at best.
For example, the Petitioner stated
that the Illinois EPA “orally authorized” Todd’s consultant (Midwest Environmental Consulting
&
Remediation
Services,
Inc.,
or
“Midwest”)
to
perform
additional
work
related
to
site
remediation.
Petitioner’s Brief, p.
2.
Presumably, this is supported by reference to conversations
that
took
place
between
James
Malcolm
of
the
Illinois
EPA
and
Todd
Birky
of Midwest.
Petitioner’s Brief, p.
3.
The Petitioner notes that Mr.
Birky testified that Mr. Malcolm made the
suggestion that off-site sampling be conducted.
14.
Relying on
this
testimony,
the Petitioner
argues that it
is
“undisputed” that
the hours of
work that
are the subject of the amended budget
(AR, pp.
114-126) were
reasonably necessary,
and
were
expended either
at the
direction of the
Illinois
EPA or with
the full approval of the
Citations
to the Administrative
Record will hereinafter be made as,
“AR,
p.
.“
References
to the transcript of
the hearing will be made as,
“TR,
p.
.“
2
Illinois EPA.
Petitioner’s
Brief, p.
7.
That is
a false and,
at best,
misleading
statement.
First,
there
is no
question
but
that the
hours set
forth
in the amended
budget
are
in
dispute, as that
-
forms the very
basis
for the
appeal.
What
may be
undisputed,
at
least from
the
Petitioner’s
perspective,
is
that
Midwest
billed
the Petitioner
for those hours
and
that
Midwest
claims
it
provided -work for all
those hours.
However, that
does not mean that the Illinois
EPA did not,
and
does not
now, find that those
hours were excessive for the work described.
Also, there is
clearly a question as to
whether those
hours
were reasonably necessary.
The Illinois
EPA has
taken the position, as memorialized in
its decision ofJune 7, 2002 (AR, pp.
136-139), that not all
of the
hours
included
in
the
amended
budget
were
reasonably necessary.
Rather, the
Illinois
EPA in
the
final decision and
in
testimony elicited
at the hearing described what
hours
it
did
believe to be reasonable.
-
The Petitioner also
argues that
the work related to
the hours in the amended budget was
performed
at
the
direction
of the
Illinois
EPA
or
with
its
full
approval.
Again,
that
is
a
misleading statement.
The Illinois EPA did
not approve any ofthe hours of work as listed in the
amended budget, since that
is the purpose of such an amendment itself, i.e., to seek approval for
the hours
of work listed.
In this
case, the amended budget
was submitted after the work itself
was performed, so the request for approval of a budget for the hours of that work post-dated the
performance
of the
work.
The
Petitioner
seems
to
be
claiming
that
conversations
between
representatives of Midwest and the Illinois EPA formed the basis for the claim that the work was
approved.
Pursuant to the Illinois Environmental
Protection Act (“Act”)2 and Section 732.503 ofthe
Board’s regulations
(35
Ill.
Adm.
Code
732.503),
the Illinois EPA must issue approvals ofplans
2
Because ofan unusual Spring
2003
legislative session, there
are
four Public Acts that
amendthe relevant provision
of the
Act.
Section
57.7(c)(4)
of the
Act
(415
ILCS
5/57.7(c)(4))
as was
effective on
July
25,
2002,
provides that
3
or budgets submitted for approval in writing within a specified time period.
In the present case,
the most
recent final decision issued
in response to the budget amendment is the decision under
-
appeal.
That decision
did
not
approve the
hours of the
work
in
question,
and
therefore
the
Illinois EPA did not approve the hours of the work in question.
It is erroneous to state otherwise,
as the Petitionerhas sought to do.
Also, even if the assertion that a member ofthe Illinois EPA made a suggestion as to how
the consultant for Todd’s should proceed, in the
end the Board must recognize that it is the role
of the consultant,
not the Illinois
EPA
staff,
to
determine
proposals for how corrective action
should
be
done
at
any
given site
requiring
corrective
action.
If the
Illinois
EPA staff were
imputed
to
have
that
responsibility,
then
the
burden
of
preparing
adequate
documents
for
approval could
also
be
transferred to
the Illinois
EPA
staff.
The
defined roles
for addressing
corrective
action
at
a
site
that
has
experienced
a
release
from
an
underground
storage
tank
(“UST”)
are
that
the
owner
or
operator
of the
UST
retains
a
consultant,
and
it
is
the
responsibility ofthe owner or operator and its consultant to formulate what they believe to be an
adequate and
reasonable
proposal
to
address the contamination.
It
is
the
responsibility of the
Illinois EPA to then review
and
either approve, disapprove or modify those proposals.
The
Petitioner
is
arguing
here
that
the
suggestion of the
Illinois
EPA,
while
certainly
noteworthy, is tantamount to a pre-approval ofthe underlying work.
That is not the
case, since it
is unclear from
the Record in
this
situation exactly what was said or understood by both parties.
Further,
it
is
the responsibility of the Petitioner to
present a~reasonableand
approvable plan or
budget,
-
even one
that
may incorporate a
suggestion from
a
staffer of the
Illinois
EPA.
If the•
Petitioner fails to meet
that burden,
then the alternate response that “the Illinois
EPA told me
to
the
Illinois EPA shall issue
approvals, disapprovals or modifications
of plans
(including
budgets) in
writing.
That
same requirement that approvals be issued in written
form
is also
found
in each of the four recent Public Acts that
amend Section 57.7 (P.A.
92-554,
P.A. 92-573, P.A. 92-651
and
P.A.
92-735),
thoughthe
specific citation varies.
4
do
so” is not sufficient.
The burden is
solely on the Petitioner to
submit approvable plans,
since
the Illinois EPA does not act as the consultant for the Petitioner.
The Illinois EPA strongly argues that the false and misleading assertions of the Petitioner
not
be given credence and should
not weigh in the Board’s consideration ofthe decision under
review.
II.
THERE IS A-CLEARLY DEFINED STANDARD
OF REVIEW
FOR REVIEWING BUDGETS
The
Petitioner
argues
that
the
Illinois
EPA
has
no
defined
standard
of
review
for
reviewing budgets,
and
that if there were
standard, and if that
standard were
followed, then the
Illinois
EPA would
be
entitled
to
some
deference.
That
statement
is
only partially correct,
as
there is a very clear standard set forth in the Act and Board regulations that
is applicable and
was
properly applied.
-
Section
57.7(c)(4)(C)
of the Act
(415
ILCS
5/57.7(c)(4)(C))3
provides
that the
Illinois
EPA shall determine, by a procedure promulgated by the Board,
that the
costs
associated
with
the plan (or budget) are reasonable, will be incurred in the performance ofcorrective action, and
will not be used for corrective action activities in excess ofthose required to meet the minimum
requirements
ofTitle XVI of the Act.
The procedure and
standard promulgated by the Board in
conjunction
with that statutory provision is
found at Section 732.505
of
the Board’s regulations
(35
Ill.
Adm.
Code
732.505).
Section
732.505
details
the
standards
-for
review
of plans
or
reports, included among which are budgets.
Even more guidance is
found in Section 732.606 of
the
Board’s regulations
(35
Ill.
Adm.
Code
732.606),
which
lists
costs
that
are
ineligible
for
payment from the UST Fund.
-
~This
is the citation
found in the final
decision
(AR,
p.
138) and refers to the version of the Act in effect at the time
of issuance ofthe decision.
5
The
Illinois
EPA’s
final
decision included
citations
to
these
statutory
and
regulatory
provisions.
The standards
were
thus
set forth,
as defined by the Act
and Board’s regulations.
-
The
Illinois
EPA
in
turn
made
its
decision
consistent
with,
and
through
application
of,
the
applicable
standards.
The Illinois EPA’s
final decision to
reduce the hour rate and
number of
hours ofcertain workers and work was done
based on a determination that the figures proposed
were unreasonable.
II.
THE ILLINOIS EPA PROPERLY REDUCEDTHE HOURLY RATES AT ISSUE
The Illinois EPA’s final decision under appeal consisted of two deductions that have been
challenged
by
the
Petitioner;
namely,
reduction
in
the
hourly
rates
for
certain
titles
-
and
a
reduction in the number of hours sought for a job title.
In the case of the hourly rate deductions, Harry Chappel of the Illinois EPA testified that
the hourly rate for
an Environmental Hydrogeologist sought for approval in the
amended budget
was $98.00/hour, and that the rate was reduced to $85.00/hour in the final decision.
AR, pp.
55-
57,
119,
138.
In addition,
the requested hourly
rate for a
Senior Environmental
Manager was
reduced from $1 10.00/hour
to $100.00/hour
(TR,
pp.
77;
AR,
pp.
119,
138), and the requested
rate of $110.00/hour for a Professional
Geologist was reduced to
$100.00/hour.
AR,
pp.
119,
138;
Respondent’s
Exhibit
1.
Mr.
Chappel testified that the decision to
reduce the hourly rates
was not his, but that he left that portion ofthe amended budget’s review to Mr. Malcolm.
TR, p.
77.
However,
Mr.
Chappel
also
noted
that
the
decision
to
reduce
the
hourly
rate
for
an
Environmental Hydrogeologist from the $98.00/hour requested to
$85.00/hour was also made in
an earlier decision by the Illinois EPA.
TR, pp.
54-57.
In a decision dated November
1,
2000,
the
Illinois
EPA
decided
that
the
requested
rate
of
$98.00/hour
for
an
Environmental
Hydrogeologist (AR, p. 80) should be reduced to $85.00/hour.
AR, p.
100.
-
6
The burden for establishing
that
an
hourly rate
in
the
amended budget
is
reasonable
is
upon the Petitioner.
Here,
the Petitioner provided no
information within the amended
budget
-
that defined how the hourly rates sought for approval
were
arrived at.
In testimony at hearing,
Al Green of Midwest testified that it was his opinion that the requested rates were reasonable and
customary, but he did not provide any details as to how those particular rates were calculated and
submitted by Midwest
in the amended budget.
TR,
pp.
23-24.
Therefore,
there was absolutely
no
information
provided
in
the
amended
budget
documents
that
described
how the
rates
in
question were determined by Midwest.
The only information offered by the Petitioner in support
of those rates was provided at hearing, and then again no details on the manner in which the rates
were calculated were provided.
It cannot
be
enough for an applicant to simply offer a figure
or
rate with no
corresponding explanation and
expect that
the figure or rate will be
approved with
no further scrutiny.
Given this dearth of supporting information,
the Board
should find that the
Petitioner
has
failed
to
meet
its
burden
of demonstrating
how
the
rates
in
question
were
reasonable and why they should have been approved.
Mr.
Chappel testified that
the decision to
reduce that hourly rate was arrived at through
usage of a standard internal rate that was developed through taking a medium sic
and
adding a
standard deviation to a summary
of costs over several years.
TR, p.
75.
The use of such a rate is
not
inconsistent with
earlier Illinois
EPA usage of a
fixed
figure
for handling charges,
prior
to
those
particular
charges
being more
specifically defined in statute
and regulation.4
The use of
such
a rate as
a
guideline
is
not
impermissible
and, in the
face of no
other
documentation or
information from the
applicant, should not be
deemed
inappropriate.
Rather,
it is
an
effective
-
“For example, in
the caseof Chuck
and Dan’s
Auto
Service v.
Illinois
EPA, PCB
92-203
(August 26,
1993); the
Illinois
EPA
described
how
it
applied
a
figure
to
assist
in
determinations
of what
costs
or
dollar amounts
are
reasonable.
The
Board agreed
that
the
development and
use
of the
rate,
in
a manner
not
inconsistent
with
the
internal
rate described in Mr. Chappel’s testimony, was
acceptable.
7
tool by
which the Illinois
EPA can conduct reviews,
especially when the
applicant provides no
other related information.
Given
that
the
Petitioner
did
not
provide
any
accounting,
explanation
or
other
information
as
to
how it
calculated
the
hourly
rates
sought
for approval,
the
Illinois
EPA’s
decision to
reduce those
rates
to
figures
it believed to
be
reasonable based
upon
averaging of
related costs over several years was appropriate.
The Illinois EPA respectfully requests that the
Board affirm the Illinois EPA’s decision to reduce the hourly rates in question.
III.
THE ILLINOIS EPA PROPERLY REDUCED THE HOURS OF WORK AT
ISSUE
In its June 7,
2002
final decision, the
Illinois
EPA
also
approved a reduced number of
hours
of work
compared
to
that
sought
by
the
Petitioner.
These
reductions
are
for
work
performed by
a
Senior Project Manager, Environmental
Hydrogeologist,
Senior Environmental
Manager,
Professional
Engineer,
Principal
and
Project
Manager.
AR,
pp.
119,
138;
Respondent’s Exhibit
1.
The
hours
requested
for those job
titles
were
provided
in
line
items
in
the
amended
budget proposal.
AR, pAl 9.
Included in the line
items were
short descriptions ofthe tasks to
be
performed
related to
the
requested
hours.
-
Similarly,
in
the
earlier
budget
submitted
by
the
Petitioner, short descriptions of the tasks to
be performed were included in the
line
items along
with the number ofhours sought for approval.
AR, p.
80.
Todd
Birky, an employee ofMidwest,
confirmed in the task descriptions for thejob title
line items,
there was
no
breakdown of how many hours
were attributable for each ofthe
listed
tasks.
TR, p. 47.
Indeed, except for the information found on those line items, there is
no further
-
description
in
the
proposed budget
amendment that
gives
any insight
as to
how those
figures
were
calculated or what
types of specific
actions were
included within the tasks.
For example,
8
six ofthe eight listed personnel titles have “CACR” listed
as a task.
AR, p.
119.
The acronym
“CACR” likely refers to
a Corrective Action Completion Report, but except for the
line for the
Professional
Engineer
(“CACR
review and certification”), there
is
no
way to
know how many
hours were
spent
on
the
CACR by
each personnel,
nor what they did
relative to
the CACR.
Similarly, for those
positions that have
an
entry of “highway authority
agreement,” there
is
no
information as to what was done relative to the highway authority agreement, or how many hours
were spent in so doing.
Mr. Chappel testified that the decision to reduce the number ofhours in question was his.
TR, p.
77.
He testified that there were no standard tasks or standard hours for tasks used by staff
at the Illinois
EPA, so that there
is
some
subjectivity
involved in
reviewing a budget proposal.
He explained that
since there
are
no
set
hours for any
given task,
he
would
review the hours
proposed for a
given task by taking into account three factors:
1) Experience that the reviewer
had
reviewing
submittals
for similar tasks;
2) Experience
gleaned
by
having personally d6ne
those tasks;
and
3) The specific information provided
in the application
given by the applicant.
TR,p.79.
-
-
As to-the specific reasons for imposing the reductions, he testified that,
in
comparing the
proposed budget amendment with the original budget (approved on November
1, 2000) (AR, pp.
98-101), he found certain tasks to have been already approved or referenced in part.
TR, pp. 67-
68; AR,
pp.
80,
119.
Since there was
no
explanation or description provided by
the Petitioner
when submitting the amended budget proposal,
and there were clearly duplicative acts between
the original budget and the amended budget.
Therefore, Mr. Chappel relied on his experience in
-
having
reviewed
submittals
for- similar
tasks
and
his
experience
at
having
personally
been
involved in such work.
He testified that such experience was in the hundreds ofsites, and
could
9
- .~,..-
be
close
to
a
thousand.
TR,
pp.
50-51.
Further,
as
described
above,
there was
no
specific
information within the proposed amended budget other than the short task descriptions.
The Petitioner and its
consultant had
the clear burden ofproviding an adequate package
for the amended
budget.
The
information
contained therein
was lacking
though,
and
did
not
have sufficient
information by
which
a
reviewer
could
determine who
did
what
and
for how
long.
In this
context,
Mr.
Chappel’s decision,
based on
his lengthy
experience and
the
lack of
information supplied by the Petitioner, was appropriate and resulted in a reasonable decision.
In its
brief, the
Petitioner
argued that
Mr. Chappel stated
he
had
no
evidence that
the
hours were not actually expended, and that he did not
know how many hours were expended by
Midwest
on
the
project.
Petitioner’s
Brief,
p.
8.
The
Petitioner
also
noted
Mr.
Chappel’s
testimony
regarding other site-specific
elements
of the corrective
action.
j~. This
testimony,
-
argued the Petitioner, is indicative ofthe Illinois EPA’s failure to articulate a valid reason for the
rejection ofcertain hours.
-
Unfortunately for the Petitioner,
the testimony
cited
to
has
no
bearing
on whether
the
hours
sought
for
approval
were
reasonable
as
submitted.
Whether
the
hours
were
actually
expended, or how many hours were actually expended,
is not relevant to the decision ofwhether
the hours presented in the budget were themselves reasonable.
If Midwest had spent three times
the
number of hours as
were presented,
and provided every scintilla of evidence
documenting
that they had been expended, would
that proof or knowledge thus
result in a conclusion that the
hours were
reasonable?
The answer is
no.
Even if Mr.
Chappel had complete knowledge that
the hours in the amended budget were actually expended, or that a greater number ofhours was
-
spent than was requested for approval, that still would not affect the decision here of whether the
hours actually presented in the budget are reasonable for the tasks described.
-
10
The Petitioner also
claims that there were difficulties inherent
in obtaining
the highway
authority agreements for the
site, and that Mr. Chappel’s testimony as to his personal experience
‘with
such documents should
weigh
in
favor
of the
Petitioner.
Petitioner’s
Brief,
p.
8.
The
Petitioner conveniently overlooks Mr. Chappel’s
other testimony that there was
no information
or
documentation
within
the proposed
amended
budget
that
described
any of the
difficulties
claimed by Midwest
at the hearing.
TR, p.
78.
As
seen
by the Record, the only time that the
Petitioner
or
its
consultant
provided
any
documentation
as
to
difficulties
in
obtaining
the
highway authority
agreements was in testimony at hearing, not
in the submission to
the Illinois
EPA that formed the basis for the final decision under appeal.
-
The lack of information provided by
the Petitioner regarding the tasks
and hours sought
for approval forthose tasks were the ultimate cause for the final decision here.
The actions taken
by the Illinois EPA were correct given that lack of information, and the decision was consistent
with
the standards
set
forth
in
the
Act
and
Board’s regulations.
The
Illinois
EPA
therefor~
respectfully requests that the Board affirm the decision to reduce the number ofhours as done in
the June 7, 2002 final decision.
V.
CONCLUSION
-
For all the reasons and arguments included herein, the Illinois EPA respectfully requests
that
the Board
affirm
its June 7,
2002
decision.
The
Illinois
EPA
acted appropriately
and in
conformity with
its statutory and
regulatory obligations and
guidelines,
while the Petitioner did
not
provide
near the
information
in
the
amended
budget needed
to
support
a
finding to the
contrary.
Based on the facts and legal arguments contained herein, the Illinois EPA asks that the
Board affirm the Illinois EPA’s decision dated June 7, 2002.
11
-
-
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Special Assistant Attorney General
Division of Legal Counsel
1021 North Grand Avenue, East
P.O. Box
19276
Springfield, Illinois 62794-9276
217/782-5544, 217/782-9143 (TDD)
Dated: September
11, 2003
This filing submitted on recycled paper.
12
Assistant Counsel
- .~- -
CERTIFICATE
OF SERVICE
I,
the undersigned attorney
at law,
hereby
certify that
on
September
11,
2003,
I
served
true
and
correct
copies
of a
RESPONSE
TO
PETITIONER’S
POST-HEARING
BRIEF,
by
placing
true
and
correct
copies in
properly
sealed and
addressed. envelopes and
by
depositing
said sealed envelopes in a U.S. mail drop box located within Springfield,
Illinois, with sufficient
First Class Mail postage affixed thereto, upon the following named persons:
Dorothy M. Gunn, Clerk
Robert M. Riffle
Illinois Pollution Control Board
Elias, Meginnes, Riffle &
Seghetti, P.C.
James R. Thompson Center
416 Main Street
100 West Randolph Street
Suite
1400
Suite 11-500
Peoria, IL
61602-1611
Chicago, IL 60601
-
Carol Sudman, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue, East
-
P.O. Box 19274
Springfield,
IL
62794-9274
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Respo
nt
-
Jo~m~Th
-
Assistant Counsel
Special Assistant Attorney General
Division ofLegal Counsel
1021 North Grand Avenue, East
P.O.Box 19276
-
Springfield, Illinois
62794-9276
217/782-5544
217/782-9143
(TDD)
