RE CE
~VE
D
CLERK’S
OFF1r~E
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC
2 32003
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIG.AN, Attorney General
)
STATE OF ILUNOIS
of the State of Illinois,
)
Pollution Control Board
Complainant,
V.
PCB i~o.
04
(Enforcement
-
Air)
IJUPAGE MACHINE PRODUCTS,
INC.,
a Delaware corporation,
Respondent.
NOTICE OF FILING
TO:
See Attached Service List
PLEASE TAKE NOTICE that on December 23~, 2003,
the Office
of the Illinois Attorney General
filed with the Illinois
Pollution Control Board a Complaint,
a true and correct copy of
which is attached and hereby served upon you.
Failure to file an answer to this complaint within 60 days
may have severe Consequences.
Failure to answer will mean that
all allegations in the complaint will be taken as
if admitted for
purposes of this proceeding.
If you have any questions about
this procedure, you should contact the hearing officer assigned
to this proceeding,
the Clerk’s Office or an attorney.
Respectfully submitted,
LISA MADIGAN
Attorney General
State
of Illinois
BY:
-
MITCHELL L.
CO EN
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th Floor
Chicago, Illinois
60601
(312)
814-5282
THIS
IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST
David R. Knuepfer
President
& Registered Agent
DuPage Machine Products,
Inc.
99 International Blvd.
Glendale Heights,
IL 60139-2092
Tracey
L. MJ.hel±c
Baker & McKenzie
One Prudential Plaza
130 East Randolph Drive
Chicago,
IL 60601
RECEIVED
CLERK’S
OFPT(~F
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 23
2003
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
STATEOFILLINOIS
by LISA MADIGAN,
Attorney
Pollution Control Board
General
of the State of Illinois,
Complainant,
PCB
No.04-i
v.
)
(Enforcement
-
Air)
DUPAGE
MACHINE
PRODUCTS,
INC.,
a
Delaware corporation,
Respondent.
COMPLAINT
Complainant,
PEOPLE OF THE STATE OF ILLINOIS, by LISA
MAJJIGAN, Attorney General of the State of Illinois,
complains of
,
DUPAGE MACHINE PRODUCTS,
INC.,
a Delaware
corporation,
as
follows:
COUNT I
FAILURE
TO MAINTAIN RECORDS
1.
This Count
is brought on behalf of the PEOPLE OF THE
STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General of the
State
of Illinois,
on her own motion and at the request
of the
Illinois Environmental Protection Agency
(“Illinois EPA’T),
pursuant to Section 31 of the Illinois Environmental Protection
Act
(“Act”)
,
415 ILCS 5/31
(2002)
2.
The Illinois EPA is an agency of the State of Illinois
created by the Illinois General Assembly in Section 4 of the Act,
415 ILCS 5/4
(2002)
,
and charged,
inter alia,
with the duty of
enforcing the Act.
3.
At all times relevant to the complaint,
Respondent,
DuPage Machine Products,
Inc.
(“DuPage”),
is and was a Delaware
corporation registered to do business in the State of Illinois.
4.
At all times relevant to this complaint, DuPage is and
was the owner and operator
of
the
plant
located
at
99
International Boulevard,
Glendale Heights, DuPage County,
Illinois
(“facility”)
.
DuPage’s president and registered agent
is
David
R.
Knuepfer.
5.
Section
3.315
of
the
Act,
415
ILCS
5/3.315
(2002),
provides
the
following
definition:
“Person”
is any individual, partnership,
co-partnership,
firm,
company, limited liability company, corporation,
association,
joint stock company,
trust,
estate, political
subdivision,
state agency,
or any other legal entity,
or
their
legal representative,
agent or assigns.
6.
DuPage
is
a
“person”
as
that
term
is
defined
in
Section
3.315
of
the
Act,
415
ILCS
5/3.315
(2002)
7.
DuPage manufactures a
variety
of
screw
products.
During the manufacturing process, cutting oil is applied to the
screw products.
The oil
is rinsed from the various screws in a
vapor degreaser.
8.
DuPage’s operation of its facility is subject to the
Act and the rules and regulations promulgated by the Illinois
Pollution Control Board
(“Board”) and the Illinois EPA.
The
Board’s regulations for air pollution are found in Title 35,
Subtitle
B,
Chapter
I of the Illinois Administrative Code
(“Board
2
~ir Pollution Regulations”),
and the Illinois EPA rules and
regulations for air pollution are found in Title 35, Subtitle B,
Chapter II of the Illinois Administrative Code
(“Illinois EPA Air
Pollution Regulations”)
9.
DuPage’s operation of its facility is subject
to
the rules and regulations promulgated by the United States
Environmental Protection Agency (“USEPA”).
The USEPA’s
regulations for National Emissions Standards For Hazardous Air
Pollutants for Source Categories for Halogenated Solvent Cleaning
(“USEPA
NESHAP
Regulations”)
are
found
in
Title
40,
Chapter
I,
Subchapter
C,
Part
63,
Subpart
T
Of
the
United
States
Code
of
Federal Regulations.
10.
DuPage was issued a Federally Enforceable State
Operating Permit
(“FESOP”)
no.
97050122 on December 22,
1997.
The FESOP was issued based on DuPage’s use of a hazardous air
pollutant
(“HAP”)
in its vapor degreaser, which
is subject
to the
USEPA NESHAP Regulations.
FESOP no. 97050122 expired on December
22,
2002. DuPage filed another FESOP application, and the
Illinois EPA granted the new permit March 31,
2003.
11.
On March 28,
2002,
the Illinois EPA’s Field Operations
Section inspected DuPage’s facility.
During the inspection
several violations of the USEPA NESHAP Regulations were noted.
12.
After another inspection on June
3,
2002,
the Illinois
EPA issued Violation Notice
(“VN”) A-2002-00152
to DuPage for
3
failure to maintain records of degreaser solvent usage,
failure
to submit annual reports for the degreaser for the calender years
1997 through 2001,
and failure to submit Annual Emissions Reports
(“AER5”) for the calender years 1997 through 2001.
13.
DuPage responded with a proposed Compliance Commitment
Agreement
(“CCA”)
on June 21, 2002.
In its CCA,
DuPage claimed,
without providing the Illinois EPA with supporting documentation,
that it was in compliance with the applicable regulations.
DuPage also requested a meeting with the representatives of the
Illinois EPA.
However,
the representatives of DuPage failed to
attend the meeting on the scheduled date.
14.
On August
29,
2002,
the Illinois EPA issued a Notice of
Intent to Pursue Legal Action
(“NITPLA”)
to DuPage.
DuPage
failed to respond to the NITPLA within thirty days.
By letter
dated October 25,
2002,
DuPage,
through a consultant,
requested
an extension of time to respond to the NITPLA and to meet with
the Illinois EPA.
By letter dated October 30,
2002,
DuPage
submitted a response to the VN and NITPLA.
This response was
late and insufficient.
15.
Section 9(b)
of the Act,
415 ILCS 5/9(b) (2002),
provides as
follows:
No person shall:
b.
Construct,
install, or operate any equipment,
facility,
vehicle, vessel or aircraft capable of
causing or contributing to air pollution or
designed to prevent air pollution,
of any type
4
designated by Board regulations, without
a permit
granted by the Illinois EPA,
or in violation of
any condition imposed by such permit.
16.
Section 9.1(d) (2)
of the Act,
415
ILCS 5/9.1(d) (2)
(2002)
,
provides,
in pertinent part,
as follows:
No person shall:
(2)
Construct,
install ,modify or operate any
equipment,
building,
facility,
source or
installation which is subject
to regulations under
sections 11,
112,
165 or 173 of the Clean Air Act,
as now or hereafter amended except in compliance
with the requirements of such sections and federal
regulations adopted pursuant thereto, and no such
action shall be undertaken without a permit
granted by the Agency or in violation of any
condition
imposed
by
such
permit.
17.
Section
63.467(b)
of
the
USEPA
NESHAP
Regulations,
40
C.F.R.
63.467(b)
(2003),
provides
as
follows:
(b)
Each owner or operator of a batch of vapor or in-
line solvent cleaning machine complying with
section 63.463 shall maintain records specified in
paragraphs
(b) (1)
through(b) (4)
of this section
either in electronic or written form for a period
of
5 years.
(1)
The results of the control device monitoring
required under section 63.466.
(2)
Information on actions taken to comply with
section
63.463(e)
and
(f).
This
information
shall include records of written and verbal
orders for replacement of parts,
a
description
of
repairs
made
and
additional
monitoring
conducted
to
demonstrate
that
monitored
parameters
have
returned
to
accepted levels.
(3)
Estimates
of
annual
solvent
consumption
for
each
solvent
cleaning
machine.
(4)
If
a
carbon
absorber
is
used
to
comply
with
5
these standards,
records
of the dates and
results of the weekly measurement of the~
halogenated HAP carbon solvent concentration
in the carbon absorber exhaust as required in
section 63.466(e)
18.
Conditions
6(b) (v)
(A)
and
(B)
of DuPage’s FESOP no.
97050122 provide as follows:
v.
The Permittee shall maintain the following records
effective upon the issuance of this permit.
A.
Monthly and annual solvent usage in pounds or
tons.
B.
Which solvent is used.
19.
DuPage failed to maintain and keep the records that
were required by Section 63.467(b)
of the USEPA NESHAP
Regulations,
40 C.F.R.
63.467(b) (2003),
and conditions
6(b) (v) (A)
and
(B)
of FESOP no.
97050122.
The required records were not
available during the Illinois EPA’s inspection, nor were the
required records produced from the time of inspection until
October 30,
2002.
The records produced by DuPage on October 30,
2002 were inadequate,
because they were only summaries,
not the
complete records that were required.
20.
By failing to maintain and keep the required records,
DuPage has violated Sections 9(b) and 9.1(d) (2)
of the Act,
415
ILCS 5/9(b)
and 9.1(d) (2) (2002),
Section 63.467(b)
of the USEPA
NESHAP Regulations,
40 C.F.R.
63.467(b) (2003),
and conditions
6(b) (v) (A)
and
(B)
of FESOP no.
97050122.
WHEREFORE, Complainant,
the PEOPLE OF THE STATE OF ILLINOIS,
6
respectfully requests the Board find in favor of the Complainant
and against Respondent,
DUPAGE MACHINE PRODUCTS,
INC.,
on this
Count
I and enter an order:
1.
Authorizing a hearing in this matter at which time the
Respondent will be required to answer the allegations herein;
2.
Finding that Respondent has violated Sections 9(b)
and
9.1(d) (2)
of the Act,
415 ILCS 5/9(b) and 9.1(d) (2) (2002),
Section 63.467(b)
of the USEPA NESHAP Regulations,
40 C.F.R.
63.467(b) (2003), and conditions
6(b) (v) (A)
and
(B)
of FESOP no.
97050122;
3.
Ordering Respondent to cease and desist from further
violations of Sections
9(b)
and 9.1(d) (2)
of the Act,
415 ILCS
5/9(b) and 9.1(d) (2) (2002),
Section 63.467(b)
of the USEPA NESHAP
Regulations,
40 C.F.R.
63.467(b) (2003),
and conditions
6(b) (v) (A)
and
(B)
of FESOP no. 97050122;
4.
Assessing against the Respondent a civil penalty of
Fifty Thousand Dollars
($50,000.00)
for each violation of the Act
and pertinent regulations promulgated thereunder,
with an
additional penalty of Ten Thousand Dollars
($10,000.00)
for each
day during which each violation continues;
5.
Taxing against Respondent all costs of this action,
including attorney,
expert witness and consultant
fees expended
by the State in its pursuit of this action; and
7
6.
Granting such other relief as the Board deems
appropriate and just.
COUNT II
FAILURE TO SUBMIT ANWUAL REPORT
1.
-
16.
Complainant re-alleges and incorporates by
reference herein paragraphs
1 through 16 of Count
I as paragraphs
1 through 16 of Count
II.
17.
Section 63.468(f)
of the USEPA
NESHAP
Regulations,
40
C.F.R.
63.468(f) (2003), provides
as follows:
(f)
Each owner or operator of a batch vapor or in-line
solvent cleaning machine complying with the
provisions of section 63.463 shall submit an
annual report by February 1 of the year following
the one for which the reporting is being made.
This report shall include requirements specified
in the paragraphs
(f)
(1)
through
(f) (3)
of this
section.
(1)
A signed statement from the facility owner or
his designee stating that
“
all operators of
the solvent cleaning machine have received
training on the proper operation of the
solvent cleaning machine and their control
devices sufficient to pass the test required
in section 63.463(d) (10)
.“
(2)
An estimate of solvent consumption for eadh
solvent cleaning machine during the reporting
period.
(3)
The reports required under paragraphs
(f)
and
(g)
of the section can be combined into a
single report for each facility.
18.
Condition 7(b)
of DuPage’s FESOP no.
97050122 provides
as
follows:
b.
The Permittee shall submit an annual report for
8
the batch vapor degreaser by February
1 of the
year following the one for which the report
is
being required pursuant to 40 CFR 63.468(f).
The
report shall include the following:
i.
A signed statement from the source owner or
his designee stating
“
All operators of the
solvent cleaning machine have received
training on the proper operation of the
solvent cleaning machine and their control
devices sufficient to pass the test required
in section 63.463
(d)
(10)
.“
ii.
An estimate of solvent consumption for each
solvent cleaning machine during the reporting
period.
19.
DuPage failed to submit annual reports for its solvent
usage and its operator training to the Illinois EPA for calendar
years 1997 through 2001.
Due to this lack of reporting,
the
Illinois EPA was unable to completely assess DuPage’s compliance
status.
20.
By failing to submit records for the years
1997 to
2001,
DuPage has violated Sections 9(b) and 9.1(d) (2)
of the Act,
415 ILCS 5/9(b)
and 9.1(d) (2) (2002),
Section 63.468(f)
of the
USEPA NESHAP Regulations,
40 CFR 63.468(f) (2003),
and condition
7(b)
of FESOP no.
97050122.
WHEREFORE,
Complainant,
the PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests the Board find in favor of the Complainant
and against Respondent,
DUPAGE MACHINE PRODUCTS,
INC.,
on this
Count
II and enter an order:
1.
Authorizing a hearing in this matter at which time the
Respondent will be required to answer the allegations herein;
9
2.
Finding that Respondent has violated sections 9(b)
and
9.1(d) (2)
of the Act,
415 ILCS 5/9(b)
and 9.1(d) (2) (2002),
Section 63.468(f)
of the USEPA NESHAP Regulations,
40 CFR
63.468(f) (2003),
and condition 7(b)
of FESOP no.
97050122;
3.
Ordering Respondent to cease and desist from further
violations of Sections 9(b)
and 9.1(d) (2)
of the Act, 415 ILCS
5/9(b) and 9.1(d) (2) (2002),
Section 63.468(f)
of the USEPA NESHAP
Regulations,
40 CFR 63.468(f) (2003),
and condition 7(b)
of FESOP
no.
97050122;
4.
Assessing against the Respondent a civil penalty of
Fifty Thousand Dollars
($50,000.00)
for each violation of the Act
and pertinent regulations promulgated thereunder, with an
additional penalty of Ten Thousand Dollars
($10,000.00)
for each
day during which each violation continues;
5.
Taxing against Respondent all costs of this action,
including attorney,
expert witness and consultant fees expended
by the State in its pursuit of this action; and
6.
Grantingsuch other relief as the Board deems
appropriate and just.
COUNT III
FAILURE TO SUBMIT SEMI-ANNUAL REPORTS
1.
-
16.
Complainant re-alleges and incorporates by
reference herein paragraphs
1 through 16 of Count
I as paragraphs
1 through 16 of Count
III.
10
17.
Section 63.468(h)
of the USEPA NESHAP Regulations,
40
C.F.R.
63.468(h) (2003),
provides,
in pertinent part,
as follows:
(h)
Each owner or operator of a batch or in-line
solvent cleaning machine shall submit an
exceedance report to the Administrator semi-
annually except when,
the Administrator determines
on a case-by-case basis that more frequent
reporting is necessary to accurately assess the
compliance status of the source, or an exceedance
occurs.
.
.
.Exceedance reports shall be delivered or
postmarked by the 30th day following each of the
calendar
half or quarter
as appropriate. The
exceedance report
shall include the applicable
information in paragraphs(h) (1)
through
(3)
of
this section.
(1)
Information on the actions taken to comply
with section 63.463(e) and
(f)
.
This
information shall include records of written
and verbal orders for replacement of parts,
a
description of repairs made and additional
monitoring conducted to demonstrate that
monitored parameters have returned to
accepted levels.
(2)
If an exceedance has occurred,
the reason for
the exceedance and a description of the
actions taken.
(3)
If no exceedance of a parameter has occurred,
or piece of equipment has not been
inoperative,
out of control,
repaired ,or
adjusted,
such information shall be stated in
the report.
18.
Condition 7(c)
of DuPage’s FESOP no.
97050122 provides,
in pertinent part,
as follows:
c.
The permittee shall submit an exceedance report
for the batch vapor degreaser to the Illinois EPA
semi- annually
40
CFR 63.468(h)
except when,
the
Illinois EPA determines on a case by case basis
that more frequent reporting is necessary to
accurately assess the compliance status of the
source,
or an exceedance occurs... .Exceedance
11
reports shall be delivered or postmarked by the
30th
day following
each of the calendar
half or
quarter
as appropriate.
The exceedance report
shall include the applicable information:
i.
The record required by condition 6(b) (iv).
ii.
If an exceedance has occurred,
the reason for
the exceedance and a description of the
actions taken,
to minimize or prevent future
exceedance.
iii.
If no exceedance of a parameter has occurred,
or piece of equipment has not been
inoperative,
out of control, repaired ,or
adjusted,
such information shall be stated in
the report.
19.
DuPage failed to submit semi-annual exceedance reports
to the Illinois EPA for the calendar years 1997 through 2001.
Due to this lack of reporting,
the Illinois EPA was unable to
completely assess DuPage’s compliance status.
20.
By failing to submit semi-annual reports for the years
1997 through 2001,
DuPage has violated Sections 9(b)
and
9.1(d) (2)of the Act,
415 ILCS 5/9(b)
and 9.1(d) (2) (2002),
Section
63.468(h)
of the USEPA
NESHAP
Regulations,
40
CFR
63.468(h)
(2003), and condition 7(c) of FESOP no.
97050122.
•
WHEREFORE,
Complainant,
the PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests the Board find in favor of the Complainant
and against Respondent,
DUPAGE MACHINE PRODUCTS,
INC.,
on this
Count III and enter an order:
1.
Authorizing a hearing in this matter at which time the
Respondent will be required to answer the allegations herein;
12
•.
Finding that Respondent has violated Sections
9(b) and
9.1(d) (2)of the Act,
415 ILCS 5/9(b) and 9.1(d) (2) (2002),
Section
63.468(h)
of the
USEPA NESHAP Regulations,
40 CFR 63.468(h)
(2003),
and condition 7(c)
of FESOP no.
97050122;
3.
Ordering Respondent to cease and desist from further
violations of Sections
9(b)
and 9.1(d) (2)of the Act,
415 ILCS
5/9(b) and 9.1(d) (2) (2002),
Section 63.468(h)
of the USEPA
NESHAP
Regulations,
40 CFR 63.468(h)
(2003),
and condition 7(c)
of FESOP
no.
97050122;
4.
Assessing against the Respondent a civil penalty of
Fifty Thousand Dollars
($50,000.00)
for each violation of the Act
and pertinent regulations promulgated thereunder, with an
additional penalty of Ten Thousand Dollars
($10,000.00)
for each
day during which each violation continues;
5.
Taxing against Respondent all costs of this action,
including attorney, expert witness and consultant
fees expended
by the State in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
COUNT IV
FAILURE TO TIMELY SUBMIT
COMPLETE AND ACCURATE ANNUAL EMISSION REPORTS
1.
-
16.
Complainant re-alleges and incorporates by
reference herein paragraphs
1 through 16 of Count
I as paragraphs
1 through 16 of Count
IV.
13
17.
Section 9(a)
of the Act,
415 ILCS 5/9(a) (2002),
provides as follows:
No person shall:
(a)
Cause or threaten to allow discharge or emission
of any contaminant into the environment in any
state so as to cause or tend to cause air
pollution in Illinois, either alone or in
combination with contaminants from other sources,
so as to violate regulations or standards adopted
by the Board under this Act.
18.
Section 201.302(a)
of the Board Air Pollution
Regulations,
35
Ill. Adm. Code 201.302(a), provides as follows:
(a)
The owner or operator of any emission unit or air
pollution control equipment,
unless specifically
exempted under this Section,
shall submit to the
Agency as a minimum, annual reports detailing the
nature,
specific emission units and total annual
quantities of all specified air contaminant
emissions; provided,
however, that the Agency may
require more frequent reports
if necessary to
accomplish the purposes of this Act and this
Chapter.
19.
Section 254.132 (a)
of the Board Air Pollution
Regulations,
35 Ill. Adm.
Code 254.132(a), provides as follows:
(a)
Failure to file a complete Annual Emissions Report
by the applicable deadlines prescribed in Section
254.137(a)
of this Subpart shall be violation of
this Part and 35
Ill. Adm. Code 201.302(a).
20.
Section 254.137(a)
of the Board Air Pollution
Regulations,
35
Ill. Adm.
Code 254.137(a), provides as follows:
(a)
All Annual Emissions Report are due by May
1 of
the year following the calendar year in which the
emissions took place.
21.
DuPage failed to timely submit complete and accurate
14
AERs for calendar years
1993 through 2001.
The AER5 submitted by
DuPage did not contain annual HAP
emissions.
DuPage did not
submit revised AERs containing the required information until
October 30,
2002.
22.
By failing to timely• submit complete and accurate AERs,
DuPage has violated Section 9(a)
of the Act,
415 ILCS 5/9(a)
(2002), and Sections 201.302(a),
254.132(a), and 254.137(a)
of
the Board Air Pollution Regulations,
35
Ill. Adm.
Code
201.302(a),
254.132(a), and 254.137(a).
WHEREFORE,
Complainant,
the PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests the Board find in favor of the Complainant
and against Respondent,
DUPAGE MACHINE PRODUCTS,
INC., on this
Count
IV and enter an order:
1.
Authorizing a hearing in this matter at which time the
Respondent will be required to answer the allegations herein;
2.
Finding that Respondent has violated Section 9(a)
of
the Act,
415 ILCS 5/9(a) (2002),
and Sections 201.302(a),
254.132(a),
and 254.137(a)
of the Board Air Pollution
Regulations,
35
Ill. Adm.
Code 201.302(a),
254.132(a),
and
254.137 (a)
;
3.
Ordering Respondent to cease and desist from further
violations of Section 9(a)
of the Act, 415 ILCS 5/9(a) (2002),
and
Sections 201.302(a),
254.132(a),
and 254.137(a)
of the Board Air
Pollution Regulations,
35
Ill. Adm.
Code 201.302(a),
254.132(a),
15
and 254.137 (a)
4.
Assessing against the Respondent a civil penalty of
Fifty Thousand Dollars
($50,000.00)
for each violation of the Act
and pertinent regulations promulgated thereunder, with an
additional penalty of Ten Thousand Dollars
($10,000.00)
for each
day during which each violation continues;
5.
Taxing against Respondent all costs of this action,
including attorney, expert witness and consultant fees expended
by the State
in its pursuit of this action; and
6.
Granting such other relief as the Board deems
appropriate and just.
•
PEOPLE OF THE STATE OF ILLINOIS,
by LISA
MADIGAN,
Attorney General of the State
of Illinois
MATTHEW J.
DU1’~N, Chief
Environmental Enforcement
/
Asbestos Litigation Division
BY:_________
~OSEMARIE
CAZEAU,
~ief
‘~
Environmental Bure’~u
Assistant Attorney General
OF COUNSEL:
MITCHELL L.
COHEN
Assistant Attorney General
Environmental Bureau
188 W. Randolph Street,
20th Floor
Chicago,
IL
60601
(312) 814-5282
16
CERTIFICATE OF SERVICE
I, MITCHELL COHEN,
an Assistant Attorney General,
certify
that on the 23rd day of December,
2003,
I caused to be served by
First Class Mail the foregoing Complaint 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.
I
•
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