ILLINOIS STATE TOLL HIGHWAY

AUTHORITY (Lincoln South HPCAP/B)),

Petitioner,

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY,

Respondent.

)

)

)

)

)

)

PCB-04-141

)

(UST Appeal)

)

)

)

)

RECEIVED

CLERK’S OFFICE

JUN

02

2004

STATE OF ILLINOIS

Pollution Control Board

NOTICE OF FILING

To:

Renee Cipriano, Director

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield,

IL

62794

John Kim, Esq.

Special Assistant Attorney General

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL

62794

PLEASE TAKE NOTICEthat on

__________,

2004 we filed with the Clerk of the Illinois

Pollution Control Board the originals and nine (9) copieseach, via personal delivery, of: (1) Motion

to File an Amended Petition for Review of Agency Modification of High

Priority Corrective

Action Plan and Budget and (2) Amended Petition for Review ofAgency Modification ofHigh

Priortiy corrective Action Plan and Budget

for filing the above-entitled cause, copies ofwhich

are attached hereto.

Kenneth W. Fu4ik

Special Assista4t Attorney General

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

V.

181540.1

---

CERTIFICATE OF SERVICE

The undersignedherebycertifies that true and correct copies ofthe Notice ofFiling, together

with copies of the documents described above, were served upon the above-namedRespondent by

enclosing same in envelope addressed to said Respondent, certified mail, return receipt requested,

and by depositing said envelopes in a U.S. Post Office Mail Box at Chicago, Illinois, with postage

fully prepaid on the

~‘~i

day of

Ja~ni.

,

2004

Kenneth W. Funk

Special Assistant Attorney General

Kenneth W. Funk, Esq.

Phillip

J.

Zisook, Esq.

Karen Kavanagh Mack, Esq.

Special Assistant Attorneys General

225

W.

Washington Street, Suite 1700

Chicago, IL

60606

(312) 346-1460

THIS FILING IS SUBMITTED ON RECYCLED PAPER

-

181540.1

---

RECEIVED

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

JUN

022004

STATE OF ILLINOIS

ILLINOIS STATE

TOLL HIGHWAY

)

Pollution Control

Board

AUTHORITY (Lincoln South HPCAP/B)),

)

)

Petitioner,

)

)

V.

)

PCB-04-141

)

(UST Appeal)

ILLINOIS ENVIRONMENTAL PROTECTION

)

AGENCY,

)

)

Respondent.

)

MOTION TO FILE AN AMENDED PETITION FOR

REVIEW

OF AGENCY MODIFICATION OF HIGH

PRIORITY

CORRECTIVE

ACTION PLAN AND BUDGET

Now

comes

the Petitioner, the

Illinois

State

Toll

Highway Authority (“ISTHA”)

by

its

attorneys, Kenneth W.

Funk, Phillip

J. Zisook,

and Karen Kavanagh Mack,

as

Special Assistant

Attorneys

General, and respectfully states as follows:

1.

On May 10, 2004, Petitionerfiled a Petition forReviewofthe Illinois Environmental

Protection Agency’s Modification ofPetitioner’s High Priority CorrectiveAction Plan and Budget.

2.

Petitioner inadvertently attached Exhibit B to thePetition.

Exhibit B was a document

relevant to

the Des Plaines Oasis

South,

and not relevant to

the Lincoln Oasis

South.

3.

Petitioner

seeks

leave

to

file an

Amended Petition

in

this

matter, omitting

any

reference

to

previously filed Exhibit

B,

and

substituting

in

place thereof the

amended petition

attached hereto.

4.

Counsel

for

Petitioner

has

spoken

with

Counsel

for the

Illinois

Environmental

Protection Agency (“IEPA”) regarding this Motion, and Counsel forthe JEPA has no objection to

this motion.

-

181540.1

---

WHEREFORE,

the

Petitioner,

the

Illinois

State

Toll

Highway

Authority,

respectfully

requests that this Board grant its Motion to file an Amended Petition for review in this matter.

Respectfully submitted,

THE ILLINOIS STATE TOLL HIGHWAY AUTHORITY

By:_________________________

One of their atjomeys

Kenneth W. Funk, Esq.

Phillip

J.

Zisook, Esq.

Karen Kavanagh Mack, Esq.

Special Assistant Attorneys General

225

W. Washington Street, Suite

1700

Chicago, IL

60606

(312) 346-1460

-

181540.1

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

JUN

02

2004

ILLINOIS STATE TOLL HIGHWAY

)

STATE OF

ILLINOIS

AUTHORITY (Lincoln South HPCAP/B)),

)

~OlIUtiOn

Control Board

)

Petitioner,

)

)

V.

)

PCB-04-141

)

(UST Appeal)

ILLINOIS ENVIRONMENTAL PROTECTION

)

AGENCY,

)

)

Respondent.

AMENDED PETITION FOR REVIEW

ACTION PLAN AND BUDGET

Petitioner, the Illinois State Toll HighwayAuthority(“ISTHA”)by its attorneys,Kenneth W.

Funk,Phillip J. Zisook, and Karen KavanaghMack, as Special AssistantAttorneys General~petitions

the Illinois Pollution Control Board, pursuant to 415

ILCS 5/57.7(c)(4)(D),

415 ILCS

57.8(I)

and

415

ILCS

5/40,

for review ofthe final determination of Respondent, the Illinois

Environmental

Protection Agency (the

‘Agency”), dated January 6, 2004,

with respectto Petitioner’s

High Priority

Corrective Action Plan

and

Budget, relating to

its

Lincoln Oasis

South

facility, and

in

support

thereof, states:

1.

ISTHA is the owner ofthe facility, including underground storage tanks and related

piping,

commonly

known as

the

Lincoln

Oasis

South

located at

milepost

1.1

on

Southbound

Interstate 294 in South Holland, Illinois.

2.

In 1994,

Wight and Company, on ISTHA’s behalf, notified the Illinois Emergency

ManagementAgency that gasoline, diesel and waste oiltarget analytes were detected above the Tier

I Remediation Objectives, to which the IEMA assigned Incident No. 94-1818.

-

181544.1

---

3.

Onor about September 5, 2003, ISTHA submitted a High Priority CorrectiveAction

Plan (“Plan”),

including a Budget, to the Agency; and,

on orabout January

6,

2004, the Agency

responded by materially modifying both the Plan and the Budget(the “Final Determination”). Atrue

and complete copy ofthat Final Determination is attached hereto as Exhibit

“A”.

4.

On or about January 27, 2004, ISTHA contacted the Agency by letter, and advised

the Agency that it contested the Agency’s modifications and requested a 90 day extension ofthe 35

day appeal period pursuant to

§40 ofthe Environmental Protection Act.

(415 ILCS

5/40(a)(l).)

5.

On

or

about

February

10,

2004,

the

Agency

filed

a

request

before

the

Board

requesting a 90 day extension ofthe 35 day appeal period.

6.

OnoraboutFebruary 19,2004, the Board granted theAgency’srequest and extended

the period within which Petitioner may file its appeal through and

including May

11, 2004.

7.

ISTHA requests that theBoard reverse theAgency’sFinalDeterminationwith respect

to its modification ofthe Lincoln Oasis South CorrectiveAc~tionPlan

and Budget, because

inter alia,

the Plan and

remedial activities described therein are necessary and

appropriate for the protection

ofhumanhealth and theenvironment and do not exceed theminimum necessaryrequirements ofthe

Act

or the regulations promulgated thereunder.

Additionally, the Budget included investigation

costs, analytical costs, personnel costs, equipment costs

and handling charges that were necessary

and reasonable to execute the approved Plan.

8.

With regard to the Plan, the Agency stated the following:

(1)

Additional informationneeds to be providedconcerning:freepmductrecovery

if product continues to be encountered at the site.

2

-

181544.1

---

(2)

The

owner/operator

needs

to

clarify

whether

or not

all

of the incidents

reported at the site are to be addressed at the same time.

(3)

It is

not

acceptable to

model

the extent of contamination to

surface water

quality standards. Tier2 calculations should be based on Class I groundwater

objectives. All modeled off-site exceedences based on a Class Igroundwater

designation must be addressed.

(4)

Tier2 migration to groundwaterobjectives should not be calculated based on

soil

inhalation and ingestion objectives.

(5)

All existing monitoring wells should be sampled six months afterexcavation

activities are completed to determine contaminant levels and verify that Tier

2 objectives will be

met.

(6)

The Owner/Operator Property Summary form included in the submittal was

for a different site.

On behalfofISTHA, Wight and Company submitted additional information to the Agency

on

February

20,

2004,

in

response to

the

Agency’s comments

regarding the

Plan.

Wight

and

Company responded that:

(1)

Any free product had been removed on

or before December 20,

2000;

no

free product was detected during

the UST removal in

September of2003.

(2)

The remediation activities would address all ofthe incidents.

(3)

Equation

R26

modeling

can

be

used

in

accordance

with

the

Tier

2

Groundwater Remediation Objectives in 35 Iii. Adm. Code 742.805 to show

that

the

concentration

of

any

contaminant

of concern

in

groundwater

discharging

into

a

surface

water will

meet

the

applicable

water

quality

standard under 35

Ill. Adm.

Code 742.805.

(4)

The

Tier

2

Remediation

Objective for

the migration

to

groundwater for

Benzene and Toluene were calculated independentlyofthe soil inhalationand

soil ingestionroutes.

Using the methods in the Plan, the calculated values of

the Migration

to

Class

I

Groundwater

for

Benzene

and

Tolue ne

were

determined to

be

less

stringent than those

established for the Ingestion or

InhalationRoute forIndustrial/Commercial orConstruction Workerstandard.

Therefore, the site would be remediated

to the Ingestionor InhalationRoute

3

-

181544.1

---

for

Industrial/Commercial

or

Construction

Worker

standards,

the

more

stringent ofthe remediation objectives.

(5)

The

existing

monitoring

wells

will

be

sampled

six

months

after

the

excavation.

(6)

Wight and Companyattached the correct Owner/OperatorProperty Summary

Form

to

the February

20, 2004 correspondence.

9.

ISTHA

also

appeals

the

Agency’s modifications.

to the

Budget that

found that

investigation, analysis, personnel and equipment costs were unreasonable.

ISTHA asserts that the

costs

for those categories were required to develop the Corrective Action Plan.

10.

ISTHA

further

appeals

the

Agency’s

modifications

to

the

Budget that

seek

to

apportion ISTHA’s corrective action costs.

The Agency’s

bases for apportionment were that (a)

ISTHA was deemed eligible

to

access the LUST

Fund for payment of corrective action costs

for

some,

but

not

all

of the

USTs

at the

site;

and

(b)

ISTHA

failed

to

justify that

all

costs

were

attributable to each eligible

UST at the site.

However, on information and belief, the amount of

contaminants from the eligible

USTs

exceeded the amount the Agency

approved as eligible

for

apportionment by the Agency.

Additionally, ISTHA demonstrated that the corrective action costs

it

incurred

were

attributable

to

the

eligible

USTs

at

the

site.

Accordingly,

ISTHA’ s

budget

information provided to

the Agency sufficiently demonstrated

the costs that were

necessary and

reasonable

to

execute

the

approved

Plan,

and

the

Agency

erroneously apportioned

ISTHA’s

corrective action costs.

Therefore, the Agency’s decision to apportionthe costs should be reversed.

11.

ISTHA reserves the right to present additional grounds for reversal ofthe Agency’s

determination, as they appear during the course of this Appeal.

4

-

181544.1

---

WHEREFORE,

the

Petitioner,

the

Illinois

State

Toll

Highway Authority,

respectfully

requests

that

this

Board

grant

a

hearing

in

this

matter,

reverse

the Agency’s January

6,

2004

determination

(modification) of ISTHA’s High Priority Corrective Action Completion Plan and

Budget for Lincoln Oasis South, and remand this matter to the Agency with instructions to approve

the Budget as aforesaid, and for any other relief as the Board deems just and appropriate.

Respectfully submitted,

THE ILLINOIS STATE TOLL HIGHWAY AUTHORITY

By:~~

.~

One of their attofn~ys

Kenneth W. Funk, Esq.

Phillip J. Zisook, Esq.

Karen Kavanagh Mack,

Esq.

Special Assistant Attorneys General

225

W.

Washington Street, Suite

1700

Chicago, IL

60606

(312) 346-1460

-

181544.1

---

o1/qs/2004

1@;55

B3ft-27i—7bb~3

LtLL’Nf-~I

LCcISL.

L.)r.r

f~JV~o.

•

!LLLNOIS,ENVJRONMENTALPROTECTJON

AGENCY

1 021

NORTH GRAND

AVENUE

EAST,

P.O.

Box

19276,

Sr~1NCrIaD,

ILLINOIS

62794L9276, 217-782-3397

JAMES

R.

THOMPSON

CENTER,

100

WEST

RANDOLPH,

SUITE 11-300,

CHtCACO, IL

60601, 312-814-6026

•

ROD R.

BLAcoJ~vIcH,

GOvERNOR

RENEE

CIPRLANÔ,

D2~CroR

217/782-6762

_____

CER’IinbD MAlL

B150

flOflhl

IER?

S2REI

JANUB2004

Illinois State

Toll Highway

Authority

Attention:

Steve Giflen

2700 Ogden Avenue

.

.

.

Downers

Grove,

illinois.

60515

Re:

LPC410312975141—CookCounty

South

Holland

I

Lincoln Oasis

1-294,

East Bound

LUST

Incident

No.

941818

.

LUST

TecimicalPile

Dear

Mr. Gillen:

The illinois

Environáental Protection Agency (illinois

EPA)

has reviewed

the

High Priority

Corrective Action Plan (plan) submitted for the above-referenced mcident

This plan, dated

September 5,

2003, was received by the Illimois EPA on September

10, 2003

Citations in this

•

letter are

from the

Enviroinnental Protection

Act (Act)

and 35 lIjihois Aclnñnistrative

Code

(35

IlL Acm,

Code).

.

.

•

Pursuant to Section

57.7(~)(4)

of the Act

~nd

35111.

Adm.

Code

732.405(c),

the

plan

is

modified.

The

following modifications are necessary, in

addition to those

provisions already puth,ned

in the

plan,

to demonstrate

compliance

with

TitleXVIof th~

Act and

35 ilL

Adm.

Code

732:

1.

Additional

information

needs to

be provided concerning free product recovery if woduct

cOntinues

to

be

encountered

at this site.

2.

The owner/operator

needs

to

clarify whether

or not

all

of the incidents repOrtéd at the

subject

site are to be addressed at the

same time,

.

3.

Please note that itis not acceptaiMe to model the extent ofcontamination to

surfacewater.

quality standards.

Tier 2 calculations should be based on Class I groundwaterobjectives.

All

modeled off-site exceedences based on a Class.! groundwater designation must be addressed.

4.

Tier 2 migration to groundwater objectives should not be calculatedbased

on

soil inhalation

and ingestion objectives.

.

.

.

ROCKEORD —4302

North Main

Street, P~ockford,

IL 61103

—

(815)

•W.

Harrison

st-,

be~

Plalne,,

IL 60016— ~847)

294-4000

ELciN

—

595 South

State, Elgin,

IL 60123.— (347)

60

rslty St, Peoria,

11 61614 —(308)

695-5463

BUREAU OF LANO

-

PEaRL’.

—

Th20 N.

Unh~ersity

St.. Peoria,

1161614—

125

South

First

Street, champaign, It.

61820

(217) 276-5800

SPRINGnELD

4500 5.

Sixth

$treet

Rd.,

Springfleld,

11 62706— (2

09

MAIL Street, CoIIinsviIIe,

IL 62234— (618) 346-5120

MAFtION

—

2509 W. Mal

EXHIBIT

JAN.

09

‘04

(FBi)

09:55

~r~-~rr;1~s

PAGE.

2

---

01/09/2004

1U:bb

h3U—2ii—f~j

I_jLL~\.N

y

LL...4.-IL.

LL...J

I

Page

2

5.

AlA existing moniiozing wells

should be sampled six months after

excavation

activities are

completed to detertuine contaminant levels and verify,that Tier 2 objectives will be met.

6.

The Owner/Operator Property

Siithmaiy form ix~cluded

with

this

subipittal was

for a

different

site.

Please note‘that all. activijies assotiated with the remediation Of this releasp

proposed in the

plan

must be executed in accordance with

all applicable regulatory and statutory requirements,

including compliance with the pwper permits.,

.

•

.

.

.

•

!n addition, the budget for the High Priority Corrective Muon Plan is modified pursuant to

Sectioll57.7(c)(4) ofthe Act and

35111.

Mm. Codei32,405(c).

Based on the modifications..

listed in Section

2 of

Attachment A, the amounts’ istedin Section

1 ofAttachnentA ate

approved.

Please note that

the

costs must be incurred in accordance with the approvedplan.

Be

aware that the amount ofreiinbursement’rnay be limited

by

Sections 57.8(e), 57.8&) and 57.8(d)

•

Ofthe Act, as well as 35 ill. At

Code 732.604,732.606(s), and 732.611.

•

Please note that, if the owner or operatoragrees with the Illinois EPA’s moçliflcations, submittal

of all

amended plan and/orbudget, if applicable,

is not

required (Section

57.7(c)(4)

ofthe Act

•

•

and ~

LU. Athn.

CQCIe 732.503(f)).

Additionally, pursuant

to

Section 57.8(a)(5) ofthe Act and,

35

111

Adm.

Code 732 405(e), if reimbursement will be sought for any additional costs that may

be incUrred as

a result

of the illinois EPA’s modifications, an amended budget must be submitted.

NOTE:

Amended plans and/or budgets must be submitted and approved prior

to the

issuance

of

a No Further Remed~ation

(NFR) Letter.

Costs assoqiated with a plan

or

budget that have not.

been approved prior

to the

issuance

of anNFR

Letterwill not 1$ reiinbuisable.

AU future correspondence must be submit

to:

flffiioi~

Environmental Protection Agency

Bureau

of

Land

#24

Leaking Underground Storage Tank Section

1021

North Grand Avenue East

Post Office Box

19276

Springfield, IL

62794-9276

Please submit all

correspondence in

duplicate and include the

Re: block shown at’the beginning

•of this letter.

‘

•

Anunderground storage tank system Owner oroperatornay appe.al this decisiOn

to the

Illinois

Pollution Control Board.

Appeal rights are attached.

JAN.09

‘04

(FRI)

09:56

COMMUNICATION

Na:25

PAGE.

3

---

e1e’t~I2ø84

‘i~:bb

.

.

.

H~JI~LwI’uI L-L.’.a-n..,

isa

.

. ...

Page3

•

If

yOu have

any

questions,

or

neeafurther assistance, please contactMelinda Friedel, PS. at

2171782-6762.

‘

.

•

•

‘

Sincerely,

‘

74~iLQ27tA~,’

Michael T. Lowder

•

‘

•

Unit Manager

Leaking Underground Storagelank Section

Division ofRextedladon Management

•

Bureau ofLand

Attachment:

Attachment A

•

,

•

Appeal Rights

,

‘cc:

Mary Krukl Wight&Coxnpany

.

.

Divisio~iFild

.

.

•

•

•

•

‘

.

‘.

JAN. 09

~04

(FRI)

09:56

COMMUNICATION No:25

PAGE.

4

---

530—271—7559

IULLWAY

Lb(~L Ltrt

I

‘ic_IL,,

c,I,-,,’

ci

I

O1/f3120’34

10:55

•

:

•

Attachment A

Re:

LPC#0312975141--CookCounty

South Holland

I

Lincoln

Oasis

•

F294,

East Bound

•

.

LUST Incident No. 941818.

• LUST

Technical File’

H

Citations in this attachmentare

from the

Environmental Pro’te~tionAct

(Act)

and

35

illinois

Admit strative

Code

(35

ill. Adm. Code).

•

•

I

,

SECTION*.

•

•

•

•

.

.

.

•

_

•

As a result

of the

flhjnois EPA’s modification(s) in Section 2 ofthis AttachmentA, the following

amounts are4çroved:’

•

$2,083.33

•

‘

Investigation Costs

_

•

•

$8,682.50

Analysis

Costs

$13,850.00

•

Personnel COsts

•

$4,461.67

‘

Equipment Costs

$284,949.58

Field Purôhases and Other Costs

$7,949.05

Handling Charges

•

•

SECTION:Z

“_

‘

‘‘

“.

:

•

‘‘•

,,,

•

_

_

‘

•

•

_

_

I.

$209,076. 18 for an a4ju.stment in iuvesçlgation, analysis, personnel, equipnint costs, tield

jurchases

and handling

charges.

The illinois EPA

has detennineci that these costs are not

reasonabld as submitted. (Section

57.7(c)(4)(C)

ofthe

Act and

351111. Ada

COde

732L606(hh))~.One ofthe overall goals

ofthe

financial review

is to

assure

that costs

associated with matenals~

activities, and services are reasonable

(35

111

Adm

Code

732.505(c)).

Plea.se’note that additional information and/or supporting documetitation may

be provided

to

demonstrate the costs

are reasonable.

Investigation

costs

—.

•

$12,534.00

(adjustment

made

based on borings

for

•

•

site classification activities

that were not previously appro’ved;

approvabl&

axuounts were also exceeded)

_

Anelysis costs

--

•

$6, 182.00

(adjustment made based on costs forsite

classification activities, costs associated with bioreinediation,analyses, and

approvable amounts were exceeded~

PersonS

costs

•

$17,520.00

(excessive hours for the work being

• performed)

,

•‘

‘

•

Equipment costs

--

‘$7,092.00

(elxcessive tjme charged for

the work to be

• performed and approvable amounts were

exceeded)

Field purchases/other

—

$i62,133.00

‘(allowable

amount exdeeded

for ice

and

disposable gloves.:

$128,443

above the allowable rate for excavation

and

backfill activities.

$33620

-.

above the allowablerate

for pavement

removal/replacement activities.)

•

•

•

Handling charges

—.

$3,615.18

(adjustment made based on previous cuts)

JAN. 09

04

(FRI)

09:56

COMMUNICATION

Na:25

PAGE.

5

---

• s1/~sf2ee4 la:55•

bdt1—2(i—1bD~i

‘

.

IUL$..WMT

LI~cJnt..

sn_i

I

‘

I

‘Page2

‘

.

2.

•

$450,766.57 for an apportionment of costs.

The

Illinois EPA has determined

that the

•

‘apportionment shall be based

on seven ofthe

twelve

tJSTs listed for

this site

were deemed

•

ineligible

for reimbursement

(351111. Ada

Code 732.608(b)).

The Illinois EPA may

•

.

‘

apportion

payment of costs

for

plans submitted under, Seotion

57.7(c)(4X6)(W)

of the Act

•

,‘

if:

(1) the owner or operator was deemed eligible to access

the

Fund

for payment of~

•

,

corrective action costs for some, but not all, ofthe underground storage

tanks

at

the

site;

and

(2)

the

owner

or

operator failed to justify all costs attributable

to

each underground

•

storage tank

‘atth~

site

(Section

57:8(m)

of the Act and 35 III. Ada

Code 732.608).

JAN. 09

O4

(FRI)

09:57’

COIyO.IUNICATION Mo:25

PAGE.

6

---

01/09/2304

10:55

•

53U~2F1I’bb~

,

IULLWMT

Lt.US~

ptJ-j

‘

,,

..

‘.r..~.

Appeal Rights

An

underground

storage

tank owner or op~rator

may appeal this final decision to theillinois

Pollution Control Board pursuant

to Sections’40 and 57.7(c)(4)(D)of the

Act

by

filing

a.

pedtion~..

for

a

heating within 35 days after

the date of

issuance

of the

final decision.

However, the 35-day.

period maybeextended for a period of

time

not

to exceed90 days by written

notice

from the

owner

or

operator and

the’ illinois EPA within the initial

35-dat

appeal periocL,J.f the

owner or

operator wishes to receive a 90~dayextension, a written request that includes a statement ofthe

date the final decisionwas received; along with a copy of this

decision, must

be sent to the

illinois EPA as soon as possible.

‘

‘

.

.

‘

For information re~arding

the filing

of

an appeal, please contact:

•

Dorothy

Gnnn,

Clerk’

Illinois Pollution ConS

Board

“

State of Illinois C~nter

100

West Randolph,

SuIte

1 1-SOQ

Chicago, IL

312/814-3620

For

irtforniationregarding the filing

of an extension, please contact:

Bhinois’Erivirotithentál Protection Agency’

‘‘.

Division ofLegal Counsel

‘

.

1021

North Grand Avenue East

‘PostOffice Box

19276

‘

Springfield, IL”62794-9276

217/782-5544

‘

JAN.09

04

(FRI)

09:57

COIvOvtUNICATION NQ:25

PAGE.

7,