RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
-5200k
STATE OF ILLINOIS
PEOPLE OF THE STATE OF
ILLINOIS,
)
Pollution
Control
Board
)
Complainant,
)
v.
)
PCBNO~I~3
)
(Enforcement-Air)
FELLOWES MANUFACTURING
COMPANY,
)
a/k/a FELLOWES, INC., an Illinois
)
corporation,
)
)
Respondent.
)
NOTICE OF FILING
TO:
Ms. Susan Harris
Sidley, Austin, Brown and Wood
Bank One Plaza
10 South Dearborn Street
Chicago, Illinois 60603
PLEASE TAKE NOTICE that I have today filed the Complaint with the Office of the
Clerk of the Illinois
Pollution Control Board, a true and correct copy of which is attached hereto
and herewith served upon you.
Pursuant to
35
Iii. Adm. Code
103.204(f), I am required to advise
you that 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
ofthis 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.
Pursuant to
415
ILCS
5131(c)(1),
I am required to advise you that financing may be available
through the Illinois Environmental Facilities Financing Act to
correct the violations.
PEOPLE OF THE
STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
of the State ofIllinois
BY:
______________
BRIDGET M. CARLSON
Assistant Attorney General
Environmental Bureau
188 West Randolph Street, Suite
2001
Chicago, Illinois 60601
(312)814-2069
Attorney No. 99000
•
RECEWED
CLERK’S OFFICE
MAY -6 2004
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
Pollution
Control
Board
Complainant,
)
v.
)
PCBN0.I
(Enfordement-Air)
FELLOWES
MANUFACTURING
COMPANY,
a/k/a
FELLOWES,
INC.,
an Illinois corporation,
Respondent.
COMPLAINT
Complainant, 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”),
complains of the Respondent,
FELLOWES MANUFACTURING COMPANY, a/k/a FELLOWES,
INC.,
as follows:
COUNT
I
FAILURE TO OBTAIN A CONSTRUCTION PERMIT
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
EPA, 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 this Complaint,
Fellowes
Manufacturing Company, a/k/a Fellowes,
Inc.
(“Fellowes”)
is and
was an Illinois corporation in good standing.
4.
At all times relevant to this complaint,
Fellowes
engaged
iii
the manufacture, assembly, and packaging of office
supplies,
as well as the manufacture of cardboard boxes with or
without printed images,
at its manufacturing plant located at
1789 NorWood Avenue,
Itasca,
DuPage County,
Illinois
(“facility”)
.
5.
Fellowes began operating its facility prior to 1990
on a date better
known
to it, and from that time operations at
the facility included 15 injection molding machines and two
flexographic printing lines.
Beginning in 1995,
Fellowes
operated two additional flexographic printing lines.
6.
Fellowes’ operation of
its 15 injection molding
machines and its four flexographic printing lines results in the
err~~issibnof volatile organic materials
(“VOMs”), also known as
volatile organic compounds
(“VOCs”)
.
7.
Respondent’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
Air Pollution Regulations”), and the Illinois EPA rules and
regulations for air pollution are found in Title 35, Subtitle B,
-2-
Chapter
II of the Illinois Administrative Code
(“Illinois EPA Air
Pollution Regulations”)
8.
Sections 9(b)
of the Act, 415 ILCS 5/9(b) (2002),
provide 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 designated by Board
regulations, without a permit granted by
the Agency,
or in violation of any
conditions imposed by such permit.
9.
Section 201.142 of the Board Air Pollution Regulations,
35
Ill. Adm. Code 201.142, provides as follows:
No person shall cause or allow the
construction of any new emission source or
any new air pollution control equipment,
or
cause
or allow the modification of any
existing emission source or air
pollution
control equipment,
without
first obtaining a
construction permit from the Agency,
except
as provided in Sections 201.146 or Section
201.170(b)
of this Part.
10.
Section 3.315 of the Act, 415 ILCS 5/3.315(2002),
contains the following definition:
“PERSON”
is any individual,
partiiership, 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.
11.
Respondent Fellowes,
is a “person” as that term is
-3-
defined
in Section 3.315 of the Act,
415 ILCS 5/3.315(2002).
12.
Section 3.165 of the Act,
415 ILCS 5/3.165(2002),
provides as follows:
“Contaminant” is any solid,
liquid, or
gaseous matter,
any odor,
or any form of
energy,
from
whatever
source.
13.
VOM is a “contaminant” as that term is defined in
Section 3.165 of the Act, 415 ILCS 5/3.165(200?).
14.
Section 201.102 of the Board Air Pollution Regulations,
35
ill.
Adm. Code 201.102, contains the following definitions:
“Emission source”: any equipment or facility
of a type capable of emitting specified air
contaminants to the atmosphere.
“Specified air contaminant”: any air
• contaminant as to which this Subtitle
contains emission standards or other specific
limitations and any contaminant regulated in
Illinois pursuant to Section 9.1 of the Act.
15.
VOM is
a “specified aircontaminant”
as that term is
defined in Section 201.102 of the Board Air Pollution
RegulationS,
35
Ill.
Adtn. Code 201.102.
16.
Fellowes’
15
injection
molding
machines and its four
flexographic printing lines are “emission sources)”
as that
term is defined in Section 201.102 of the Board Air Pollution
RegulationS,
35
Ill.
Adm.
Code
201.102.
17.
Fellowes,
on dates better known to it, installed four
flexograPhic printing lines and 15 injection molding machines
in
its facility in the late 1980’s or early 1990’s.
-4-
18.
Fellowes
did
not
obtain
construction
permits
from
the
•
Illinois
EPA
prior
to
installing any of its 19 emission sources.
19.
By failing to obtain construction permits prior to the
installation of its four flexographic printing lines and 15
injection molding machines, Fellowes violated Section 9(b)
of the
Act,
415 ILCS 5/9(b) (2002), and Section 201.142 of the Board Air
Pollution
Regulations,
35
Ill.
Adm. Code 201.142.
WHEREFORE,
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
respectfully requests that the Board enter judgment in favor of
Complainant and against Respondent,
FELLOWES MANUFACTURING
COMPANY,
a/k/a FELLOWES,
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 Section 9(b)
of
the Act, 415 ILCS 5/9(b) (2002),
and Section 201.142 of the Board
Air Pollution Regulations,
35 Ill. Adm. Code 201.142;
3.
Ordering Respondent to cease and desist from further
violations of Section 9(b) of the Act,
415 ILCS5/9(b) (2002), and
Section 201.142 of the Board Air Pollution Regulations,
35
Ill.
Adm. Code 201.142;
•
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
-5-
additional penalty of Ten Thousand Dollars
($10,000.00)
for each
day
during
which
each violation continues;
5.
Ordering Respondent
to pay all costs of this action,
includin~attorney, expert witness and consultant fees of the
State
ifl its pursuit of this action, pursuant to Section 42(f)
of
the Act,
415 ILCS 5/42(f) (2002);
and
•
6.
Granting such other relief as the Board deems
appropriate and just.
•
•
COUNT II
FAILURE TO OBTAIN A STATE OPERATING
PERMIT
1.
-
16.
Complainant realleges and incorporates by
reference herein paragraphs
1 through
8 and paragraphs
10 through
17 of Count las paragraphs
1 through 16 of this Count
II.
17.
Section 201.143 of the Board Air Pollution Regulations,
35 ill. Adm. Code 201.143, provides as follows:
No
person
shall
cause
or
allow the operation
of any new emission source or new air
• pollution control equipment of a type for
which
a construction permit
is required by
Section 201.142 without first obtaining an
•
operating permit from the Agency,
except for
such testingoperations as may be authorized
by the construction permit. Applications for
operating permits shall be made at such times
and contain such information
(in addition to
the
information
required
by
Section
201.157)
as
shall
be
specified
in
the
construction
permit.
18.
Since
sometime
prior
to
1990,
the actual dates being
better
known
to
Fellowes,
through
April
1,
2003,
Fellowes
has
-6-
been operating two flexographic printing lines and 15 injection
molding machines without the required State operating Permit.
19.
From 1995 through April
1,
2003,
Fellowes has been
operating an additional two flexographic printing lines without
the required State operating permit.
20.
By operating its
15 injection molding machines and the
four flexographic printing lines without a State operating permit
until April
1,
2003,
Fellowes violated Section 201.143 of the
Board Air Pollution Regulations,
35
Ill. Adm. Code 201.143.
21.
By violating Section 201.143 of the Board Air Pollution
Regulations,
35
Ill. Adm. Code 201.143, Fellowes violated Section
9(b)
of the Act, 415 ILCS 5/9(b) (2002).
WHEREFORE,
Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully’requests that the Board enter judgment in favor of
Complainant and against Respondent,
FELLOWES MANUFACTURING
COMPANY,
a/k/a FELLOWES,
INC.,
on this Count II and enter an
order:
1.
Authorizing ahearing in this matter at which time the
Respondent will be required to answer the allegations herein;
2.
Finding that Respondent has violated Section 9(b)
of
the Act, 415 ILCS 5/9(b) (2002), and Section 201.143 of the Board
Air Pollution Regulations,
35
Ill. Adm.
Code 201.143;
3.
Ordering Respondent to cease and desist from further
violations of Section 9(b)
of the Act,
415 ILCS 5/9(b) (2002), and
-7--
Section
201.143
of
the
Board
Air
Pollution
Regulations,
35
Ill.
Adrn.
Code 201.143;
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.
Ordering Respondent to pay all costs of this action,
including attorney,
expert witness and consultant fees of the
State in its pursuit of this action, pursuant to Section 42(f)
of
the Act, 415 ILCS 5/42(f) (2002);
and
6.
Granting such other relief as the Board deems
appropriate and just.
COUNT III
FAILURE TO SUBMIT A CLEAN AIR ACT PERMIT PROGRAM APPLICATION
1.
-
16.
Complainant realleges and incorporates by
reference herein paragraphs
1 through 8 and paragraphs
10 through
17 of Count
I as paragraphs
1 through 16
of this Count
III.
• 17.
Section 39.5(6)(b)
of the Act, 415 ILCS 5/39.5(6) (b)
(2002), provides as follows:
•
b.
After the applicable CAAPP permit or
renewal application submittal date,
as
specified in subsection
5 of this
Section,
no person shall operate
a CA~PP
source without a CAAPP permit unless the
complete CAAPP permit or renewal
application for such source has been
timely submitted to the Agency.
-8-
18.
Section
39.5(1)
of the Act,. 415 ILCS 5/39.5(1) (2002),
contains the following definition:
“Major source” means a source for which
emissions of one or more air pollutants meet
the criteria for major status pursuant to
paragraph 2(c)
of this Section.
19.
Section 39.5(2) (c) (iii) (A)
of the Act,
415 ILCS
5/39.5(2) (c) (iii)
(A)
(2002), provides,
in pertinent part as
follows:
c.
For purposes of this Section the term “major
source” means any source that
is:
*
*
*
A.
For ozone nonattainment areas,
sources with the potential to emit
100 tons or inore per year of
volatile organic compounds or
oxides of nitrogen in areas
classified as
“marginal” or
“moderate”,
50 tons or more per
year in areas classified as
“serious”,
25 tons or more per year
in areas classified as
“severe”,
and 10 tons or more per year in
areas classified as “extreme”
.
20.
DuPage County is designated as “severe” non-attainment
for ozone.
21.
Since at least March 1995,
the effective date of the
Clean Air Act Permit Program
(“CAAPP”), Fellowes has had the
potential to emit more than 25 tons per year of VOMs from its
facility.
22.
Fellowes’
facility isa
“major source”
as that term is
-9-
/
defined
in
Section
39.5(1)
of
the
Act,
415 ILCS 5/39.5(1) (2002).
23.
As a major source,
Fellowes was required to submit a
CAAPP permit application to the Illinois EPA no later than
September
1995,
but
failed
to
do
so until July 2002.
24.
By
failing
to timely submit an application for a CA~PP
permit,
Fellowes violated Section 39.5(6) (b)
of the Act, 415 ILCS
5/39.5(6)
(b)
(2002).
WHEREFORE,
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter judgment in favor of
Complainant and against Respondent, FELLOWES MANUFACTURING
COMPANY,
a/k/a FELLOWES,
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;
2.
Finding that Respondent has violated Section 39.5(6) (b)
of the Act, 415 ILCS 5/39.5(6) (b) (2002);
3.
Ordering Respondent to cease and desist from further
violations of Section 39.5(6) (b)
of the Act, 415 ILCS
5/39.5(6) (b) (2002);
4.
Assessing against the Respondent a civil penalty of
Fifty Thousand Dollars
($50,000.00)
for eachviolation 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;
~10-
5.
Ordering
Respondent
to
pay
all
costs
of
this
action,
including attorney, expert witness and consultant fees of the
State in its pursuit of this action, pursuant
to Section 42 (f)
of
the Act, 415 ILCS 5/42 (f) (2002)
;
and
6.
Granting such other relief as the Board deems
appropriate, and just.
COUNT IV
CONSTRUCTION OF A MAJOR STATIONARY SOURCE
IN VIOLATION OF NEW SOURCE REVIEW
1.
-
18.
Complainant
realleges and incorporates by
reference herein paragraphs
1 through
8 and paragraphs
10 through
18 of Count
I,
and paragraph
21 of Count III as paragraphs
1
through 18 of this Count IV.
19.
Section 9(a)
of the Act,
415 ILCS
5/9(a) (2002),
provides as follows:
No person shall:
a.
Cause or threaten or allow the 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, or
so
as
to
violate
regulations
or
standards adopted by the Board under
this
Act.
20.
Section 203.201 of the Board Air Pollution Regulations,
35
Ill.
Adm.
Code
203.201,
provides,
in
pertinent
part,
as
follows:
-11-
In
any
nonattainment
area,
no
person
shall
cause or allow the construction of a new
major stationary source or major modification
that is major for the pollutant for which the
are is designated a nonattainment area,
except as in compliance with this .Part for
that pollutant.
In areas designated
nonattainment for ozone,
this prohibition
shall apply to new major stationary sources
of major modifications of sources that emit
volatile
organic
material
or
nitrogen
oxides....
21.
Section 203.206(b) (1) (C)
of the Board Air Pollution
Regulations,
35
Ill.
Adm.
Code
203.206(b)
(1)
(C),
provides,
in
pertinent part,
as
follows:
b.
The following constitute a major
stationary source:
•
1.
For an area designated as
nonattainment for ozone,
a major
stationary source is a stationary
•
source
which emits or has the
potential to emit volatile organic
material
in
amount
equal
to
or
greater
than
the
following:
*
*
*
C.
25
tons
per
year
in
an
area
classified as severe
nonattainment for ozone...
22.
•
Sometime during 1995,
on dates better known to it,
FelloWeS
constructed
two flexographic printing lines each with
the potential to emit greater than 25 tons per year of the
contaminant
VOM.
23.
The addition of Fellowes two additional flexographic
printing
lines
created
a
potential
net
emissions
increase
of
101
-12-
tons per year of the contaminant VOM.
24.
The two flexographic printing lines constructed by
Fellowes are major stationary sources as that term is defined in
Section 203.206(b) (1) (C)
of the Board Air Pollution Regulations,
35
Ill.
Adm.
Code 203.206(b) (1) (C).
25.
Fellowes constructed two major stationary sources
without
first
obtaining
a
construction
permit
and without
demonstrating compliance with the Board’s regulations pertaining
to New Source Review in violation of Section 203.201 of the Board
Air
Pollution
Regulations,
35
Ill. Adm.
Code 203.201.
26.
By violating Section 203.201 of the Board Air Pollution
Regulations,
35
Ill.
Adm.
Code
203.201,
Fellowes violated Section
9(a)
of the Act, 415 ILCS 5/9(a) (2002).
WHEREFORE,
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
respectfully requests that the Board enter judgment in favor of
Complainant and against Respondent,
FELLOWES MANUFACTURING
COMPANY,
a/k/a FELLOWES,
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 Section 203.201 of the Board
Air Pollution Regulations,
35
Ill. Adm. Code 203.201;
3.
Ordering Respondent to cease and desist from further
-13-
violations of Section 9(a)
of the Act, 415 ILCS 5/9(a) (2002),
and
Section
203.201 of the Board Air Pollution Regulations,
35
Ill.
Acim.
Code 203.201;
•
4.
Assessing against the Respondent a civil ‘penalty of
Fifty Thousand Dollars
($50,000.00)
for each ylolation 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.
Ordering Respondent to pay all costs of this action,
including attorney,
expert witness and consultant fees of the
State in its pursuit of
this, action, pursuant to Section 42(f)
of
the Act, 415 ILCS 5/42(f) (2002);
6.
Granting such other relief as the Board deems
appropriate and just.
•
COUNT V
FAILURE’ TO SUBMIT ANNUAL EMISSIONS REPORTS
•
1.
-
17.
Complainant realleges and incorporates by
reference herein paragraphs
1 through 8 and paragraphs
10 through
17 of Count
I, and paragraph 19 of Count IV as paragraphs
1
through 17 of this Count V.
•
•
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 in this
Section,
shall submit to the Agency as a
-14-
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 where necessary to
accomplish
the
purposes
of the Act and
this Chapter.
19.
Section 254.132(a)
of the Illinois EPA 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 a
violation of this Part and 35
Ill.
Adm.
Code 201.302(a).
20.
Since
1992,
Fellowes as an owner operator, has been
required to submit Annual Emissions Reports
(“AERs”)
to the
Illinois EPA by May
1 of each year.
21.
Fellowes failed
to
submit
AER5 for calendar years 1992
through 2001, until October 14,
2002.
• 22.
By failing to timely submit AERs for the calendar years
1992
through
2001, Fellowes violated Section 201.302(a)
of the
Board Air Pollution Regulations,
35 Ill. Adm. Code 201.302(a)
and
Section 254.132(a)
of the Illinois EPA Air Pollution Regulations,
35
Ill. Adm.
Code 254.132(a).
23.
By violating Section 201.302(a)
of the Board Air
Pollution Regulations,
35
Ill.
Adm. Code 201.302(a)
and
Section
254.132(a)
of the Illinois EPA Air Pollution Regulations,
35
Ill.
Adm.
Code
254.132(a),
Fellowes
violated
Section
9(a)
of the Act,
-15-
415
ILCS
9
(a)
WHEREFORE,
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
respectfully requests that the Board enter judgment in favor of
Complainant and against Respondent,
FELLOWES MANUFACTURING
COMPANY,
a/k/a FELLOWES,
INC.,
on this Count V 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),
Section 201.302(a)
of the Board
Air Pollution Regulations,
35 Ill. Adm. Code 201.302(a),
and
Section
254.132(a)
of the Illinois EPA Air Pollution Regulations,
35 Ill. Adm. Code 254.132(a);
•
,
‘
3.
Ordering Respondent to cease and desist from further
violations
of Section 9(a)
of the Act,
415 ILCS 5/9 (a) (2002)
201.302(a)
of the Board Air Pollution Regulations,
35
Ill.
Adm.
Code 201.302(a)
and Section 254.132(a)
of the Illinois EPA Air
Pollution Regulations,
35
Ill. Adm. Code 254.132(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.
Ordering Respondent to pay all costs of this action,
-16-
including attorney,
expert witness and consultant fees of the
State in its pursuit of this action, pursuant
tO
Section
42(f)
of
the Act, 415 ILCS 5/42 (f) (2002)
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.
DUNN,
Chief
Environmental Enforcement/
Asbestos Litigation Division
By:
~
ROS~~~EAU,
~
Assf~tantAttorney General
Environmental Bureau North
Of Counsel:
BRIDGET
M. CARLSON
Assistant Attorney General
Environmental Bureau North
188 West Randolph Street,
Suite 2001
Chicago,
Illinois
60601
(312)814-0608
-17-
CERTIFICATE OF SERVICE
It
is hereby certified that a
true
and correct copy ofthe Complaint was sent by certified
mail with
return
receipt requested to each of the persons listed on the Notice ofFiling on May 6,
2004.
BY:
_________
BRIDGMM.
CARLSON
It is hereby certified that the originals plus nine (9) copies ofthe foregoing were hand-
delivered to the following person on May 6, 2004:
Pollution
Control Board, Attn: Clerk
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois
60601
BY:
________
BRIDGMT M. CARLSON
