RECEaVED
CLERK’S 0FF~E
JUL
19
2OO~
STATE OF ILLIt’IOIS
Pollution ControlBoard
INFORMATIONAL NOTICE!
!
!
IT
IS
IMPORTANT THAT YOU READ
THE ENCLOSED DOCUMENTS.
NOTE:
This Administrative Citation refers to TWO separate State
of Illinois Agencies.
One
is the ILLINOIS POLLUTION
CONTROL BOARD located at State of Illinois
Center,
100 West Randolph
Street,
Suite 11-500,
Chicago,
Illinois
60601.
The other state agency is the ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
located at:
1021
North Grand Avenue
East,
P.O.
Box 19276,
Springfield,
Illinois 61794-9276.
If you elect to contest the
enclosed Administrative citation, you must
file a PETITION FOR REVIEW with thirty-five (35) days of the date
the Administrative Citation was served
upon you.
Any such Petition
for Review must be filed with the clerk of the Illinois Pollution Control
Board by either hand delivering or mailing to the
Board at the address
given
above.
A copy of the Petition for Review should
be either
hand-delivered or mailed to the
Illinois Environmental Protection
Agency at the address given above and should be marked to the
ATTENTION:
DIVISION OF LEGAL COUNSEL.
RECEIvE&~
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUL
192004
ADMIINISTRATIVE CITATION
STATE
OF ILLINWS
Pollution Control
~ar.’
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
0 ~
)
v.
)
(IEPA No. 330-04-AC)
)
TED HARRISON and GERALD S.
GILL,
)
)
Respondents.
)
NOTICE OF FILING
To:
Ted Harrison
Gerald S. Gill
P.O. Box 3185
100 Redbud Road,
P.O. Box 200
Quincy, Illinois
62305
Virginia, Illinois
62691
PLEASE TAKE NOTICE that on this date I mailed for filing with the~
Clerk ofthe Pollution
Control Board of the State ofIllinois the following instrument(s) entitled ADMINISTRATIVE
CITATION, AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST.
Respectfully submitted,
~
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated:
July
16, 2004
THIS
FILING
SUBMITFED ON RECYCLED PAPER
RECEIVED
CLERK’S OFFICE
JUL
19
2004
BEFORE THE
ILLINOIS POLLUTION
CONTROL BOARD
STATE OF ILLINOIS
ADMINISTRATIVE CITATION
Pollution Control Boarc;
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
V.
)
(IEPA No. 330-04-AC)
TED HARRISON
and GERALD S.
GILL
)
)
Respondents.
JURISDICTION
This
Administrative
Citation
is
issued
pursuant
to
the
authority
vested
in
the
Illinois
Environmental
Protection Agency by Section 31.1
of the Illinois Environmental Protection Act, 415
ILCS
5/31.1
(2002).
FACTS
1.
That Ted Harrison is the former owner and operator, and Gerald
S. Gill isthe current
owner
(collectively “Respondents”) of a facility located east of Gamer Road
in the SE quarter of
Section 35, T.
18 N, R lOW, in Sangamon Valley Township, Cass County, Illinois. The property is
commonly known to the Illinois Environmental
Protection Agency as Virginia/Ted
Harrison Oil.
2.
That
said
facility
is
an
open
dump
operating
without
an
Illinois
Environmental
Protection Agency Operating
Permit and is designated with Site Code No. 0170255004.
3.
That Respondents have
owned and/or operated said facility at
all times pertinent
hereto.
4.
That
on
May 26,
2004,
David
C.
Jansen of the Illinois
Environmental
Protection
Agency’s
Springfield
Regional
Office
inspected
the
above-described
facility.
A
copyof
his
inspection
report
setting forth
the
results of said
inspection
is
attached
hereto and
made
a part
hereof.
VIOLATIONS
Based upon direct observations made by David C. Jansen
during the course of his May 26,
2004
inspection
of
the
above-named
facility,
the
Illinois
Environmental
Protection
Agency
has
determined that
Respondents have violated the
Illinois
Environmental Protection Act (hereinafter,
the “Act”)
as follows:
(1)
That
Respondents
caused
or allowed
the
open
dumping
of
waste
in
a
manner
resulting
in
litter,
a
violation
of
Section
21(p)(1)
of
the
Act, 415
ILCS
512l(p)(l)
(2002).
(2)
That
Respondents
caused
or
allowed the
open
dumping
of waste
in
a
manner
resulting
in
deposition
of
general
construction
or
demolition
debris
or
clean
construction or demolition debris, a violation of Section 21(p)(7) of the Act,415 ILCS
5/21 (p)(7) (2002).
CIVIL PENALTY
Pursuant to Section 42(b)(4-5) of the Act, 415
ILCS 5/42(b)(4-5) (2002), Respondents are
subject
to
a
civil
penalty of
One Thousand
Five
Hundred
Dollars
($1 ,500.OO) for
each
of
the
viOlations identified above, fora total of Three Thousand
Dollars ($3,000.00).
IfRespondents elect
notto petition the Illinois Pollution Control Board, the statutory civil penalty specified above shall be
due and
payable no
later than
August 13, 2004,
unless otherwise provided by order of the Illinois
Pollution Control
Board.
If Respondents elect to contestthis Administrative Citation by petitioning the Illinois Pollution
Control Board in accordance with Section 31.1
of the Act, 415 ILCS 5/31.1(2002), and
if the Illinois
2
Pollution Control Board issues a finding of violation as alleged herein, after an adjudicatory hearing,
Respondents shall be assessed the associated hearing costs incurred by the Illinois Environmental
Protection Agency and the Illinois Pollution Control Board.
Those hearing costs shall be assessed
in
addition
to the
One Thousand Five
Hundred
Dollar
($1 ,500.00) statutory civil penalty for each
violation.
Pursuantto Section 31.1(d)(1) of the Act, 415
ILCS
5/31.1(d)(1)
(2002), if Respondents fail
to petition or elect notto petition the Illinois Pollution Control
Board for review of this Administrative
Citation within thirty-five (35)
days of the date of service, the
Illinois
Pollution Control
Board shall
adopt
a
final
order,
which shall
include
this Administrative
Citation
and
findings
of violation
as
alleged herein, and shall impose the statutory civil penalty specified above.
When
payment
is
made,
Respondents’
check
shall
be
made
payable
to
the
Illinois
Environmental
Protection
Trust
Fund
and
mailed
to
the
attention
of
Fiscal
Services,
Illinois
Environmental
Protection Agency,
1021
North
Grand
Avenue East,
P.O.
Box 19276,
Springfield,
Illinois
62794-9276.
Along
with
payment,
Respondents shall
complete and
return
the enclosed
Remittance Form
to ensure proper documentation of payment.
Ifany civil penalty and/or hearing costs are not paid within the time prescribed by order of the
Illinois
Pollution
Control
Board,
interest on
said
penalty and/or
hearing
costs
shall
be
assessed
against the Respondents from the date payment is due up to and including the date that payment is
received.
The
Office
of the
Illinois
Attorney General may
be
requested
to
initiate
proceedings
against Respondents in Circuit Court to collect said penalty and/or hearing
costs, plus any interest
accrued.
3
PROCEDURE FOR CONTESTING THIS
ADMINISTRATIVE CITATION
Respondents
have
the
right
to
contest
this
Administrative
Citation
pursuant
to
and
in
accordance with Section 31.1
of the Act, 415
ILCS 5/31/1
(2002).
If Respondents elect to contest
this Administrative Citation, then
Respondents shall file a Petition for Review, incTuding a Notice of
Filing, Certificate of Service, and Notice of Appearance, with the Clerkof the Illinois Pollution Control
Board, State of Illinois Center, 100 West Randolph, Suite
11-500, Chicago, Illinois 60601. A copy of
said Petition for Review shall be filed with the Illinois Environmental Protection Agency’s Division of
Legal Counsel at 1021
North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276.
Section 31.1
of the Act provides that any Petition for Review shall be filed within thirty-five (35) days
of the date of service of this Administrative
Citation or the Illinois Pollution Control Board shall enter
a default judgment against the Respondent.
Re~,i~&~
C~t~o~
Date:
7/i’o/04
Renee
Cipriano,
Director
L1
~
Illinois Environmental
Protection
Agency
Prepared by:
Susan
E.
Konzelmann, Legal Assistant
Division of Legal Counsel
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O.
Box 19276
Springfield,
Illinois 62794-9276
(217) 782-5544
4
REMITTANCE
FORM
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
v.
)
(IEPA No.
330-04-AC)
TED
HARRISON and
GERALD
S.
GILL
Respondents.
)
FACILITY:
Virginia/Ted
Harrison
Oil
SITE
CODE NO.:
0170255004
COUNTY:
Cass
CIVIL PENALTY:
$3,000.00
DATE
OF INSPECTION:
May 26, 2004
DATE
REMITTED:
55/FEIN NUMBER:
SIGNATURE:
NOTE
Please enter the date
of
your remittance,
your
Social
Security
number
(SS)
if an
individual or
Federal Employer Identification Number (FEIN) if a corporation, and sign this RemittanceForm.
Be
sure
your
check
is
enclosed
and
mail,
along
with
Remittance
Form,
to
Illinois
Environmental
Protection Agency, Attn.:
Fiscal Services,
P.O.
Box 19276, Springfield,
Illinois
62794-9276.
5
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
AFFIDAVIT
IN THE MATTER OF:
)
Illinois Environmental
)
Protection Agency
)
)
vs.
)
IEPA DOCKET NO.
)
Ted Harrison,
and
)
Gerald S. Gill
)
)
Respondents.
)
Affiant,
David
C.
Jansen,
being
first duly sworn, voluntarily deposes and states as
follows:
1. Affiant is a Regional Manager and field inspector employed by the Division ofLand
Pollution ControlfField Operations Section ofthe Environmental Protection Agency and
has been so employed at all times pertinent hereto.
2.
On May 26, 2004 between
1:55
p.m.
and 3:05 p.m., Affiant conducted an inspection
of an open dump,
located in Cass County, Illinois and known
as
Virginia/Ted Harrison
Oil
by the Illinois Environmental Protection Agency.
Said site has been assigned site
code number LPC #0170255004 by the Agency.
3.
Affiant inspected said siteby an on-site inspection, which included walking and
photographing the site.
4.
As a result ofthe activities referred to in Paragraph 3 above, Affiant completed the
Jnspection Report form attached hereto and made a part hereof, which, to the best of
Affiant’s knowledge and belief, is an
accurate representation ofAffiant’s observations and
factual conclusions with respect to
said ope
dump.
~
Davi
C.J
en
Subscribed and Sworn
to Before
Me
this
~3~t
day
of~9~zL,
2004
EYP~Uc~~INO1S
Notary Public
My
Comm.
Expires
March
15,
2008
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Open Dump
Inspection Checklist
County:
CASS
LPC#:
0170255004
Location/Site Name:
VIRGINTNTED HARRISON
OIL
Date:
05/26/2004
Time:
From
1:55 pm
inspector(s):
DAVID C.
JANSEN, WILLIAM
ZIERATH
No. of Photos Taken:
#
15
Est. Amt. of Waste:
300+
yds3
Samples Taken:
Yes #
Interviewed:
No one
Complaint#:
Region:
5
-
Springfield
To
3:05 pm
Previous Inspection Date:
Weather:
70
F,
sunny,
muddy
Responsible Party
Mailing
Address(es)
and
Phone
Number(s):
SECTION
DESCRIPTION
ILLINOIS ENVIRONMENTAL
PROTECTION
ACT REQUIREMI
1.
9(a)
CAUSE, THREATEN
OR ALLOW AIR POLLUTION
IN ILLINOIS
2.
9(c)
CAUSE OR ALLOW OPEN BURNING
3.
12(a)
CAUSE, THREATEN OR ALLOW WATER POLLUTION IN ILLINOIS
4.
12(d)
CREATE AWATER
POLLUTION HAZARD
5.
21(a)
CAUSE OR ALLOW OPEN DUMPING
6.
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DiSPOSAL
21(d)
OPERATION:
(1)
Without a
Permit
(2)
In Violation
of Any Regulations or Standards Adopted by the Board
7.
21(e)
DISPOSE,
TREAT,
STORE,
OR
ABANDON ANY
WASTE, OR TRANSPORT
ANY
WASTE INTO THE STATE
AuTO SITES
NOT MEETING
REQUIREMENTS OF ACT
AND
REGULATIONS
8.
CAUSE OR ALLOW THE OPEN
DUMPING
OF
ANY
WASTE
IN A MANNER WHICH
RESULTS
IN ANY
OF THE
21(p)
FOLLOWING OCCURRENCES AT THE DUMP SITE:
(1)
Litter
(2)
Scavenging
(3)
~ Open Burning
(4)
Deposition of Waste
in
Standing or Flowing Waters
(5)
Proliferation
of Disease Vectors
(6)
Standing or Flowing
Liquid Discharge
from the Dump Site
12/03/2003
Ted
Harrison
Box 3185
Quincy,
IL
62305
217-228-7918
Gerald S. Gill
100
Redbud
Road
Box 200
Virginia,
IL
62691
217-323-2840
Revised 06/18/2001
(Open Dump
-
1)
LPC#
0170255004
(7)
Deposition of General Construction or Demolition Debris; or Clean Construction or
9.
55(a)
NO PERSON SHALL:
(1)
Cause or Allow Open Dumping of Any Used
or Waste Tire
~)
Cause or AVow Open Burning of Any Used or Waste T~e
-~
fl
35
ILLINOIS ADMINISTRATIVE CODE REQUIREMENTS
SUBTITLE G
10.
812.101(a)
FAILURE TO SUBMIT AN APPLICATION
FOR A PERMIT TO DEVELOP AND
OPERATEALANDFILL
11.
722.111
HAZARDOUS WASTE DETERMINATION
12.
808.121
SPECIAL WASTE
DETERMINATION
ACCEPTANCE
OF SPECIAL WASTE FROM A WASTE TRANSPORTER WITHOUT A
WASTE HAULING PERMIT, UNIFORM WASTE
PROGRAM REGISTRATION AND
~
LII
—-—.
OTHER
REQUIREMENTS
14.
APPARENT
VIOLATION
OF:
(LI)
PCB;
(LI)
CIRCUIT COURT
CASE NUMBER:
ORDER ENTERED ON:
15.
OTHER:
LII
LII
n
.
L~
,.
E
Sig
ature of Inspector(s)
Informational
Notes
Illinois
Environmental
Protection Act: 415 ILCS 5/4.
Illinois Pollution
Control Board: 35
III. Adm. Code, Subtitle G.
Statutory and regulatory references herein are provided for convenience only and should
not be construed
as legal
conclusions
of the Agency or as limiting
the Agency’s statutory or regulatory powers.
Requirements of some statutes
and regulations cited are in summary format.
Full text of requirements can .be found
in references listed in 1.
and 2.
above.
4.
The provisions of subsection (p) of Section
21
of the Illinois
Environmental Protection Act shall be enforceable either
by administrative citation under Section 31.1
of the Act or by complaint under
Section
31
of the Act.
5.
This inspection was conducted in accordance with Sections 4(c) and 4(d) of the Illinois
Environmental Protection Act:
415 ILCS
5/4(c)
and
(d).
6.
Items marked with
an “NE” were not evaluated at the time of this
inspection.
Inspection
Date:
05/26/2004
1.
2.
3.
Revised 06/18/2001
(Open Dump
-
2)
ILLiNOiS ENViRONMENTAL PROTECTION AGENCY
Soil
Treatment Facility Inspection Checklist
County:
CASS
LPC#:
0170255004
Region:
SPRINGFIELD
LocationlSite Name:
VIRGINIA/TED
HARRISON
OIL
CO.
Date:
05/26/2004
Time:
From
13:55
To
15:05
Previous Inspection
12/3/2003
________________________________________
Date:
Inspector(s):
David
C. Jansen,
William Zierath
Weather:
Sunny, 70°F,Muddy
No. of
Photos
Taken:
18
Samples
Yes#
No
X
Taken:
Interviewed:
No
one
Complaint
#:
Owner/Operator
TED HARRISON OIL CO., INC.
TED HARRISON
OIL CO., INC.
Mailing
49th
and Kochs Lane
49th
and Kochs
Lane
Address(es) and
P.O. Box 3185,
Quincy, IL 62305
P.O. Box 3185, Quincy, IL 62305
Phone Number(s):
217-228-7918
217-228-7918
PERMIT
No:
1995-084-DE/OP
& 1997-332
_____
SECTiON
DESCRIPTION
J_ViOL.
ILLINOI S
ENVIRONMENTAL PROTECTION
ACT REQUIREMENTS
1.
9(a)
~
CAUSE,
THREATEN OR ALLOW AIR
POLLUTION
IN
ILLINOIS
2.
9(c)
CAUSE OR
ALLOW OPEN
BURNING
.
3.
12(a)
CAUSE, THREATEN OR ALLOW WATER
POLLUTION
IN
ILLINOIS
4.
12(d)
CREATE
A WATER POLLUTION
HAZARD
5.
12(f)
NPDES PERMIT
6.
21(a)
CAUSE OR ALLOW OPEN
DUMPiNG
7.
21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT,
OR WASTE-
DISPOSAL
OPERATION:
(1)
Without a
Permit
.
(2)
In
Violation
ofAny
Regulations
or
Standards Adopted by
the
Board
8.
21(e)
DISPOSE, TREAT,
STORE, OR ABANDON ANY WASTE,
OR
TRANSPORT ANY WASTE INTO THE STATE AT/TO SITES NOT
MEETiNG REQUiREMENTS OF ACT AND REGULATiONS
21(p)
CAUSE OR
ALLOW THE OPEN
DUMPU~JG
OF
ANY WASTE
IN
A
MANNER WHICH RESULTS
IN ANY OF THE
FOLLOWING
OCCURRENCES
AT THE
DUMP SITE:
9.
(1)
Litter
(2)
Scavenging
(3)
Open
burning
(4)
Deposition of
waste
in standing or flowing waters
(5)
Proliferation of disease Vectors
~______
(6)
Standing or flowing discharge from the dump site
(7)
Deposition of general or clean construction or demolition debris
.~
..
.
OTHER.REQUIREMENTS
10.
APPARENT VIOLATION
OF:
(
)
IPCB;
(
)
CIRCUIT
COURT
CASE NUMBER:
ORDER ENTERED ON:
11.
OTHER:
848.202(b)(5)
-
storing tires without preventing
accumulation of water within
14 days of receipt
X
55(c)
—
failure to
notify
of tire storage activities
-
X
55(d)
—
failure to register as a tire storage site
X
12.
PERMIT
CONDITION:
.
Permit No.
1997-332
-
Failure to meet clean up objectives
and complete closure of the facility
by November 1,
1998 in
accordance with Special Condition
31
of Permit No.
1995-
084-DEIOP
(as modified
and issued on
114196)
~
PERMIT
CONDITION:
Special
condition #15 of Permit No.
1995-084-DE/OP
& 1997-
332
-
Applying waste within 200 feet of a private well
.
PERMIT
CONDITION:
Special Condition
#4
of Permit No.
1995-084-DE/OP & 1997-
332
—
Soil exceeding clean
up objectives not
removed and
disposed at a permitted landfill
PERMIT
CONDITION:
.
Special
Condition #24 of Permit
No. 1995-084-DE/OP
&
Permit
No. 1997-332
—
failure to make facility operating
record immediately available upon
request (requested
1/4/01)
PERMIT
CONDITION:
Special Condition #18 of Permit No.
1995-084-DE/OP &
Permit
No. 1997-332
—
Failure to
bioremediate soil and
:
continue process
until cleanup objectives are met or soil
removal is required
X
.
PERMIT
CONDITION:
Special Condition #32 of Permit No.
1995-084-DE/OP
&
Permit No.
1997-332
—
modifying facility without submitting
application
for supplemental permit
X
The facility had
placed
“clean” soil in an area south of the
soil treatment area
instead of in the “clean soil area” as
specified
in their Permit No. 1995-084 application
-
The facility has not constructed a perimeter berm to a
height sufficient to
prevent run-on or run-off of surface
water as specified
in their application for Permit No.
1995-
084 DE/OP
Signature of Inspector(s)
~OZI(4
~
~
~g~tionalj4ot53
1.
lIlinois~Environmental Protection Act: 415
LCS 5/I et seq.
2.
Illinois Pollution Control Board: 35 It. Adm. Code, Subtitle C.
3.
Statutory and regulatory references
herein are
provided for
convenience Only and sh
d not be construed as legal conclusions of the Agency or as limiting the Agency’s statutory or
regulatory powers.
Requirements of some
statutes and regulations cited are
in summary format.
Full lest cfrequirements can be found in
references listed in 1. and 2. above.
4.
The
provisions of subsection (p) of Section 21
ofthe tltinoisi
Environmental Protection Act
shall be enforceable either by administrative
citation under Section 31.1
of the Act or
by
comptaint
under Section 31
of the Act.
5.
This inspection was conducted
in
accordance with Sections 4(c)
and 4(d) of the (lllinOis~Environmental Prctectton Act: 415 ILCS
5/4(c) and (d).
BOL/FOS
SPRINGFIELD REGION
MEMORANDUM
DATE:
June 23, 2004
TO:
DLPC/Division File
FROM:
David C.
Jansen, BOL/FOS Springfield Region Manager
SUBJECT:
LPC # 0170255004
-
Cass
County
Virginia/Ted
Harrison Oil
FOS File
On May 26, 2004, accompanied by Bill Zierath, BOLTFOS
Springfield Region, I
inspected the above site, which
contains an Illinois EPA permitted soil treatment facility,
and open dumped waste (see attached aerial photos, and
site diagram from the Log No.
1995-084 permit application for the site location).
We arrived at the north end ofthe soil
treatment portion ofthe site at about
1:55 p.m.
It was about, 70°F,sunny, and very
muddy in the treatment cell.
The gate to the soil treatment area was open, and no one
was on site when we arrived.
I noted that 2 truck trailers, a corn planter, and a blue Ford Pickup had been added to
the
area south of the gate, but north of the treatment area.
In this same area was a previously
seen
liH Fleet Star dump truck containing approximately 120 offrim used tires (see
attached photo # -001).
This truck had a new State of Illinois Antique Vehicle (AV)
plate,
# 85-983 AV, expiration date 12/04, on it. The off rim tires in this truck contained
water.
The tires inside this truck are shown in the attached photo # -003.
The blue Ford pickup truck was without rear tires, and was supported by a stack of4 on
rim used tires at each corner of its rear bumper.
2 on rim used tires were leaning against
the stacks oftires also (see attached photo
#
-002).
Just west of the Ford pickup was an old Ford fuel tanker truck
(see attached photo #
-
004), that was not plated.
Proceeding west ofthe fuel truck, and parked in the weeds
along the north edge ofthe soil treatment area were: a red Chevy dump truck, license
plate
85 984 AV, containing
5
on rim used tires; a red Ford dump
truck, license plate 85
-
985 AV, containing 18 offrim used tires, some ofwhich contained water (see attached
photo # -005); a red Chevy dump truck, license plate 85
980 AV, containing 9, offrim
used tires, a small tree growing through the bed, and miscellaneous junk; a brown Ford
pick up truck, license plate 85
982
AV,
containing a vehicle rear end,
and otherjunk (see
attachedphoto
# -006);
and a faded green Chevy truck, license plate 85 986 AV,
containing miscellaneous junk.
These old trucks have been seen during previous
inspections in the same location.
The trucks are parked right at the north edge ofthe bare
soil in the permitted soil treatment area (see attached photo # -007).
North ofthe aforementioned line oftrucks was a white Ford flat bed truck, that was not
plated; and a blue.and white Ford panel or step van, license plate 85
979 AV, containing
miscellaneousjunk.
All the antique vehicle license plates observed had not been seen
during previous inspections, looked new, and had expiration dates of 12/04.
There was
LPC # 0170255004
-
Cass County
VirginialTed Hariison Oil
Page 2 of
5
no indication that any ofthe trucks that now had antique plates had been recently worked
on, repaired, or moved.
North ofthe Ford panel van were 2 small pick up trucks and 2 small cars seen during
previous inspections in the same location.
At the west edge ofthe permitted soil treatment areawas the leachate tank, with its
attached fill pipe leading west from the treatment area, and an open standpipe in the
center ofthe tank (see attached photo # -008).
The tank was
full ofliquid,
as observed
through the standpipe.
Near the SW corner ofthe permitted soil treatment area was an area where drainage off
the treatment area to the west had eroded soil (see attached photo # -009), and exposed
the underlying plastic liner and
a rubber drain hose (see attached photo # -010).
There
was standing water in this south part ofthe treatment area, which was very muddy (see
attached photos # -011 & -012).
There were large rubber tire tracks visible in the bare
soil ofthe treatment area.
South ofthe permitted treatment area was a large area ofbare soil, where run-offdrains
toward a weedyravine
to
the south (see attached photo
#
-013).
There were large rubber
tire tracks visible in the soil.
Soil from the center ofthis area had eroded into the north
end ofa weedy ravine (see attached photo
#
-015).
To our recollection this area had not
been used previously for the deposit of soil removed from the treatment area.
This bare
soil area had the rough shape ofa bow tie.
A soil disc was parked on bare soil next to the rubber tired soil scraper that was located
south ofthe SW corner ofthe permitted soil treatment area (see attached photo # -014).~
The scraper is apparently usedto pick up presumably treated soil from the permitted
treatment area, and deposit it south ofthe permitted treatment area.
The disc
is
apparently used to till
the soil in the permitted treatment area.
The area where the disc
and scraper were parked has been used for the deposition ofsoil removed from the
permitted treatment area in the past. Most of it was weedy on this day.
Soil had eroded (see
attached photo # -016) near the NE edge ofthe bare soil area that
was shown in photo # -013.
The soil has been eroded by run-offfrom the SE
ôorner
of
the permitted treatment area (see attached photo # -017).
Drainage is down a ravine
toward a neighbor’s pond to the east.
Per the approved
1995-084 permit application, the treatment area was supposed to have
perimeter berms that were to be
“constructed to
a height sufficient to prevent run-on or’
run-off
ofsurface water.”
Photos # -009, -010, -016 &
-017 show that
run-off
from the
treatment area is not being prevented.
Soil erosion has also been noted on the slope
uphill ofthe leachate tank in the past.
Information about the run-offfrom the permitted
portion ofthe facility will be forwarded to the Illinois EPA’s Bureau ofWater for their
infonnation
and review.
LPC #0170255004
-
Cass County
Virginia/Ted Harrison Oil
Page 3 of 5
East ofthe NE corner ofpermitted soil treatment
area, approximately 60 feet away, is a
neighbor’s private well in the lawn (see attached photo
# -018). The lawn is down slope
of the permitted treatment area.
The neighbor’s fence is approximately
21
feet from the
edge of the bare soil.
According to the site permit, condition #
15, waste was prohibited
from being applied within 200 feet of any private wells.
The well will need to
be
sampled to verify whether it has been contaminated by any activities at the permitted
area.
Any recent activity at the illinois EPA permittedportion ofthe site appears to have been
limited
to tilling, removing and depositing soil.
The Illinois EPA has received no
analytical data from any recent sampling ofany soil in or outside the treatment area.
Information requested, and the work required to be performed by the site’s permit, as
outlined in Violation Notice L-2000-01410, dated January 4, 2001, have not been
submitted or completed.
It appears that soil has been recently removed from the
treatment area and placed in the aforementioned bare soil area that drains toward ravines
south ofthe treatment area.
Per the attached Illinois Secretary ofState Corporation File Detail Report, Ted Harrison
Oil
Co., Inc.
is in
good standing, and its registered
agent is Margaretta Harfjson.
We left the permitted treatment area at about 2:30 p.m., and went to the Gerald S. Gill
property (see attached aerial photo) formerly owned by Ted and Margaretta Harrison to
check on the progress of cleanup there.
During past inspections, I have found Mr.
Harrison at this location, removing wastes and other items, rather than at the permitted
portion ofthe site.
No one was at this locationwhen we arrived.
Per a Warranty Deed filed in Cass County on August
5,
2002, Ted and Margaretta
Harrison deeded this portion ofthe site to Mr. Gill on July 20, 2002.
Discarded
wastes, including general refuse, lumber, scrap metal, old farm equipment, rusty tanks,
old trucks,
cars, and semi-trailers, old fuel pumps, a large number of used tires, concrete,
brick, and chemical wastes in drums and other containers were first observed by the
Illinois EPA on what is now the Gill property on May 30, 2002,
prior to the sale ofthe
-property.
As a result ofthat inspection,
a Violation Notice dated July
19, 2002 was sent to Mr.
Harrison.
Mr. Harrison’s
attorney, Stephen Hedinger, sent a September
5,
2002 response
to the VN to the Illinois EPA.
That response was rejected by the Illinois EPA in a letter
dated September
25,
2002.
Tn this letter, Mr. Hedinger was informed that the Illinois
EPA still held Mr. Harrison responsible for the waste that he left on the property.
This
responsibility to
finish clean up on the property was reiterated to Mr. Harrison in an
Illinois EPA letter to Mr. Harrison dated July 2,
2003, and in a letter to Mr. Harrison and
Mr. Gill dated December 19, 2003.
In the December
19, 2003 letter, Mr. Gill and Mr.
Harrison were also advised that Mr. Gill was also responsible for cleaning up any waste
on his property,
and that failure to
do so could result in an Administrative Citation against
both men.
No response to this letterhas been received.
LPC #0170255004
-
Cass County
Virginia/Ted Harrison Oil
Page 4 of 5
Much progress has been made removing the aforementioned wastes, but receipts or
manifests documenting proper disposal or recycling ofall
the wastes removed to date
have not been provided. In addition, much waste remains to be removed and properly
disposed, as noted below.
Upon arrival at Mr. Gill’s property, we noted an open dumped pile of about 20 cubic
yards in volume containing wood, metal, wallboard,
3 rolls ofwood fencing, clay tile, a
window frame, and concrete blocks located NE ofthe maintenance shed on the Gill
property (see attached photo # -019).
Near the aforementioned pile
on the ground were scattered wood and wallboard, a seat
cushion, metal, and insulation (see attached photo # -020) next to a semi-trailer,
which
was not plated, and had its tires partially buried in the ground.
Nearby, inside a rusty
semi-trailer that had no
roof, and which was not currently plated, were 4 old refrigerators,
a washer, a dryer, and other old equipment (see attached photo # -021).
Northeast ofthe semi-trailers, along
a weedy fence and tree line south ofthe access road
were discarded tire sidewalls, and cut sections ofused tires, some ofwhichwere holding
water (see attached photo # -022).
The tire sidewalls in this photo were also depicted in
photo # -003 taken on November 6, 2003.
I estimated there were approximately 10
to
20
cubic yards ofsidewalls and cut used tires here.
Following the fence and tree line further
to the northeast, were more discarded tire sidewalls, cut tire sections, used tires on rim,
treads, inner tubes, and some whole offrim used tires containing water.
I estimated there
were approximately 60 to
80 cubic yards ofused tires orparts of used tires scattered here
(see attached photos #
-023, -024, &
-025).
North ofthe aforementioned tires and access road, were a pile oflumber and drywall, a
stack of 10 used car tires offrim, a pile of
carpeting,
and a stack of 9 used spare car tires
and
1
used trucktire on rim, all
shown in attached photo #.-026.
Southwest ofthe maintenance shed on site wood chips have been discarded down the
slope ofthe ravine south ofroad near the site entrance (see attached photos # -027 &
-
030).
Other wastes such as lumber, metal, cardboard, and plastic have been observed
discarded in this ravine in the past, as noted in photos # -003 & -004 taken on December
17, 2002.
Thick weeds prevented us from seeing, or traveling safely to, the bottom of the
ravine.
West of this ravine, piled up outside the gate at the entrance was a
15-yard longby 12~
foot wide by 4-foot high pile containing concrete, brick, dirt, asphalt, wood and metal
(see attached photo # -028).
An old house trailer that was seen during previous
inspections parked north ofthe road at the site entrance was no longer present.
LPC
# 0170255004
-
Cass County
Virginia/Ted Harrison Oil
Page
5
of 5
North ofthe aforementioned ravine, a pallet and a pile ofwood chips (see attached photo
# -029) had been discarded at the top of and down the slope ofa ravine north ofthe
access road.
Running water could be heard down in the ravines on both sides ofthe
access road.
The flowing water, and whether any waste was in it, could not be seen due
to heavy vegetation.
Amidst tall weeds on the south side ofthe access road, south ofthe SW corner ofthe
maintenance shed, were an empty drum,
a drum with unknown liquid inside, and
discarded sheet metal (see attached photo #
-031).
It should be noted that drums and containers of unknown chemical wastes that were
first
discovered here during the May 30, 2002 inspection, and which were one ofthe subjects
ofthe Violation Notice dated July
19, 2002 sent to Mr. Harrison, have not been
accounted for.
Mr. Hedinger, in his September 5, 2002
response to
the VN, stated that
Harrison Oil had retained consultants to analyze the contents ofthe drums and containers,
and determine whether they were hazardous or special wastes (per 35
I.A.C. 722.111
and
808.12 1
requirements).
Those results have not yet been submitted,
and the disposition of
those
drums and containers and their contents has not been determined.
Near the NW corner ofthe maintenance shed were some piles containing discarded old
lumber, plastic pipe, and a blue drum with a hole in it (see attachedphotos # -032 &
-
033).
We left the site at about 3:05 p.m.
Apparent violations noted at the unpermitted portion ofthe site are listed in the attached
open dump inspection checklist.
Apparent violations noted at the permitted portion ofthe site are listed in the attached soil
treatment facility inspection checklist.
cc:
DLPC/FOS
—
Springfield Region
DWPCFOS
—
Springfield Region
DLC, Greg Richardson
IAGO, Del Haschemeyer
LPC # 0170255004
—
Cass
County
Virginia/Ted Harrison Oil Company
FOS File
April
5,
1998
USGS aerial photo
RAPPS
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HARRISON
OIL
CO.,
INC.
VIRGINIA, ILLINOIS
INCDENT
#920778
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil Company
FOS
File
April
5,
1998 USGS aerial photo
•
.
illinois Environmental Protection Agency
Bureau of Land
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
VirginiaiTed Harrison
Oil
FOS File
Date:
05/26/2004
Time:
1:57 p.m.
Direction: N
Photo by: D.C.
Jansen
Photo File
Name:
0170255004-05262004-001
Comments: III dump truck
containing approximately
120 off
rim
used
tires, 2 trailers,
and a
corn
planter
parked inside
gate
at
north
entranceto IL EPA permitted soil
treatment area
Date:
05/26/2004
Time:
1:58p.m.
Direction:
S
Photo by: D.C.
Jansen
Photo File
Name:
0170255004—05262004-002
Comments: Ford
pickup truck
without
rear tires, supported by a
stack of4 on
rim used tires at each
corner ofrearbumper, plus 2 on
rim
used tires
Page! of
19
•
Illinois Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison
Oil
FOS File
Date: 05/26/2004
Time:
1:59p.m.
Direction: W
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-003
Comments: uncovered used tires
inside
111 dump truck shown in
photo # -001; trucks containing
used tires in background
Date:
05/26/2004
Time: 2:00 p.m.
Direction:
S
Photo by: D.C.
Jansen
Photo FileName:
0170255004-05262004-004
Comments: north end of
permitted soil treatment area, Ford
pick up truck,
and old Ford fuel
truck
Page
2
of
19
•
Illinois Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison
Oil
FOS File
Date: 05/26/2004
Time:
2:06 p.m.
Direction: NE
Photo by: D.C. Jansen
Photo File Name:
0170255004—05262004-005
Comments: used
tires
containing
water at backendoftruck
Date:
05/26/2004
Time: 2:11
p.m.
Direction: N
Photo by: D.C.
Jansen
Photo File Name:
0170255004-05262004-006
Comments:
trucks
parkedjust
north ofNW
corner
ofpermitted
soil treatment area
Page
3
of
19
•
Illinois Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass
County
Virginia/Ted Harrison Oil
FOS File
Date: 05/26/2004
Time: 2:11
p.m.
Direction: NE
Photo by: D.C. Jansen
Photo File Name:
0170255004—05262004-007
Comments: trucks parked at north
edge of
permitted
soiltreatment
area
Date:
05/26/2004
Time:
2:13 p.m.
Direction:
W
Photo by: D.C. Jansen
Photo File Name:
0170255004—05262004-008
Comments:
leachate
tank
at west
edge ofpermitted
soil
treatment
area,
with attached fill pipe
at right
and
open stand pipe
in center of
tank
Page
4
of
19
Illinois
Environmental Protection Agency
Bureau ofLand
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time:
2:14 p.m.
Direction:
SW
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-009
Comments: area near SW corner
of
permitted
soil treatment area
where
drainage to
west
has eroded
soil and exposed plastic liner and
rubber drain hose
Date:
05/26/2004
Time:
2:15 p.m.
Direction: W
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-010
Comments: plastic liner
and
rubber drain hose exposed by
erosion at location shown in photo
#
-009
DIGITAL PHOTOGRAPHS
Page
5
of
19
•
Illinois Environmental Protection Agency
Bureau of Land
-
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 05/26/2004
Time:
2:15 p.m.
Direction: N
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-011
Comments: SW
corner
of
permitted
soiltreatment area
Date:
05/26/2004
Time: 2:15 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-012
Comments:
south half of
permitted
soil treatment area
Page6 of
19
DIGITAL
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 05/26/2004
Time: 2:15 p.m.
Direction: E
Photo by:
D.C.
Jansen
Photo File Name:
0170255004—05262004-011
-012 stitched
Comments: photos # -011
and
-012 stitched together
•
illinoisEnvironmental Protection Agency
Bureau ofLand
PHOTOGRAPHS
Page
l8of
19
•
Illinois Environmental Protection Agency
Bureau
ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time: 2:16 p.m.
Direction:E
Photo by: D.C.Jansen
Photo FileName:
0170255004—05262004-013
Comments: areaofbare soil south
ofpermitted soil treatmentarea
that
drainstowardweedy ravine at
right
Date:
05/26/2004
Time: 2:16p.m.
Direction:
S
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-014
Comments: discparked next to
soil scraperiocated south of
permitted soiltreatment area
Page
7
of
19
LI
•
illinois Environmental Protection Agency
Bureau of Land
DIGITAL PHO TOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted
Harrison Oil
FOS File
Date:
05/26/2004
-
Time: 2:19 p.m.
Direction: W
Photo
by: D.C. Jansen
Photo File Name:
0170255004—05262004-015
Comments: eroded area in bare
soil area shown in photo # -013;
soil scraper inbackground
Date: 05/26/2004
Time: 2:22p.m.
Direction: E
Photo by:
D.C.
Jansen
Photo File Name:
0170255004—05262004-016
Comments:
soil eroding nearNE
edgeofbare soil area. Drainage is
toward neighbor’s pond to east
~.1
Page
8 of
19
•
illinois
Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 05/26/2004
Time:
2:23 p.m.
Direction: N
Photo
by: D.C.
Jansen
Photo File Name:
0170255004—05262004-017
Comments: eroded
area also
shown in photo # -016, and SE
corner ofpermitted soil treatment
area
inbackground
Date: 05/26/2004
Time: 2:25 p.m.
Direction:N
Photo by:
D.C. Jansen
Photo File Name:
0170255004—05262004-018
Comments: NE
corner of
permitted
soil treatment area
showing neighbor’s fence, and well
approximately 60 feet down slope
to east
0
p
Page 9of 19
•
Illinois
Environmental Protection Agency
Bureau of Land
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 05/26/2004
-
Time: 2:35 p.m.
Direction: W
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-019
Comments: open dumped pile of
wood, metal, wallboard,
3 rolls of
wood fencing, clay tile, a window
frame,
and concrete blocks located
northeast ofshed on Gill property
Date: 05/26/2004
Time: 2:36 p.m.
Direction: W
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-020
Comments:
scattered wood,
wallboard,
a
seat
cushion, metal,
and insulation next to semi-trailer
also shown in
photo #-019
PagelOof 19
•
Illinois Environmental Protection Agency
Bureau
ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time: 2:39 p.m.
Direction: NE
Photo by:D.C. Jansen
Photo File Name:
0170255004-05262004-021
Comments:
rusty
semi-trailer
without a roof, containing
4
old
refrigerators,washer, dryer,
and
other old equipment
Date:
05/26/2004
Time: 2:43 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo FileName:
0170255004—05262004-022
Comments: tire sidewalls,
and cut
sections
ofused tires, some
holding water, discarded along
fence line
LI.
Page!! of19
Illinois Environmental
Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
-
Time:
2:46 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-023
Comments: tire sidewalls,
cut tires
sections, and
some whole offrim
used tires
discarded
along fence
line
Date: 05/26/2004
Time: 2:47 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-024
Comments: whole tires, on
and
off
rim, and tire sidewalls discarded
along fence line
Page 12of 19
•
Illinois Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time: 2:48 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-025
Comments: tire
inner tubes,
tire
sidewalls and wholeused tires
discardedalong fence line
Date: 05/26/2004
Time: 2:51 p.m.
-
Direction: NE
Photo
by: D.C. Jansen
Photo File Name:
0170255004—05262004-026
Comments: pile oflumber,
and
drywall,
stack of 10 offrim used
tires to
right
of lumber, pile of
carpeting,
and
stack of 9 spare on
rim
used tires and
1 used truck tire
on
rim
in background to left of
deadtree
/~,/_
Page
13 of
19
illinois EnvironmentalProtection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC #0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time: 2:56 p.m.
Direction: NE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-027
Comments:
wood
chips discarded
down slope ofravine south ofroad
near site entrance
Date: 05/26/2004
Time: 2:56p.m.
Direction: NE
Photo by: D.C.Jansen
Photo File Name:
0170255004—05262004-028
Comments: pile
containing broken
concrete, brick, dirt,
asphalt,wood
and
metal piled
near
site entrance
Page 14of 19
•
Illinois
Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
CassCounty
Virginia/TedHarrison Oil
FOS File
Date:
05/26/2004,
Time: 3:00 p.m.
Direction: W
Photo
by: D.C.
Jansen
Photo File Name:
0170255004—05262004-029
Comments:
pile ofwood chips
discarded
at top ofand down slope
ofravine north ofroad near site
entrance
Date:
05/26/2004
Time:
3:00 p.m.
Direction:
SW
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-030
Comments:wood
chips
discarded
downslope~ofravine south ofroad
near siteentrance
Page 15o1 19
•
illinois
Environmental Protection Agency
Bureau ofLand
DIGITAL PHOTOGRAPHS
Date: 05/26/2004
Time: 3:01 p.m.
Direction:
SE
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-031
Comments:
empty drum at
left,
drum
withliquid at right,
and
discarded
sheet metal,
all located
south ofroad near site entrance
Date:
05/26/2004
Time: 3:02 p.m.
Direction: SE
Photo by: D.C. Jansen
Photo File Name:
0170255004—05262004-032
Comments:
discarded old lumber,
and blue drum with hole in
it,
near
NW corner of
shed
LPC # 0170255004
—
Cass County
Virginia/TedHarrison Oil
FOS File
Page 16 of 19
•
Illinois Environmental Protection Agency
Bureau
ofLand
DIGITAL
PHOTOGRAPHS
LPC# 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOSFile
Date: 05/26/2004
Time: 3:02 p.m.
Direction: E
Photo by: D.C. Jansen
Photo File Name:
0170255004—05262004-032
-033 stitched
Comments: photos # -032 and
-033 stitchedtogether
0170255004—05262004.doc
Page
19
of 19
•
Illinois Environmental Protection Agency
Bureau of Land
DIGITAL PHOTOGRAPHS
LPC # 0170255004
—
Cass County
Virginia/Ted Harrison Oil
FOS File
Date:
05/26/2004
Time: 3:02
p.m.
Direction: E
Photo by: D.C.
Jansen
Photo File Name:
0170255004—05262004-033
Comments:
discarded old
lumber,
and
plastic pipe
near NW corner of
shed
Page
17 of19
PROOF OF SERVICE
I hereby
certify that I did on the 16th day ofJuly 2004, send by Certified Mail, Return Receipt
Requested, with postagethereon fullyprepaid, by depositing in a United States Post Office Box a true
and
correct
copy
of
the
fOllowing
instrument(s)
entitled
ADMINISTRATIVE
CITATION,
AFFIDAVIT, and OPEN DUMP iNSPECTION CHECKLIST
To:
Ted Harrison
Gerald
S. Gill
P.O.Box 3185
100 Redbud Road, P.O. Box 200
Quincy, Illinois
62305
Virginia, Illinois
62691
and the original and nine (9) true and correct copies ofthe same foregoing instruments on the same
date by Certified Mail, Return Receipt Requested, with postage thereon fully prepaid
To:
Dorothy Gunn, Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
ichel
M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021
North Grand Avenue’ East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)
782-5544
THIS
FILING
SUBMITTED ON RECYCLED PAPER
