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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE
rif:
ILLINOIS ENVIRONMENTAL
)
Pollution Cü~ ~
PROTECTION AGENCY,
)
)
Complainant,
)
AC
05-08
)
y.
)
(IEPA
No. 330-04-AC)
)
TED
HARRISON AND GERALD S. GILL
)
)
Respondents.
)
RESPONDENT
TED HARRISON’S PETITION FOR REVIEW
NOW COMES Respondent,
TED HARRISON,
by and through his undersigned attorney,
and hereby files his Petition for Review ofthe Administrative Citation
issued by the Illinois
Environmental Protection Agency (IEPA) herein.
For
his Petition for Review, Respondent Ted
Harrison states as follows:
PETITION FOR REVIEW
1.
The IEPA alleges that Ted Harrison is a Respondent as the former owner and
operator of
the facility
located east of Garner Road in the southeast quarter section of Section
35,
T.
18 N, R
10 W,
in Sangamon Valley Township.
Cass County, Illinois.
The IEPA alleges that it
“commonly knows” the property as “Virginia/Ted Harrison Oil.”
2.
The IEPA alleges that the named Respondents
“have owned and/or
operated said facility
at all times pertinent hereto.”
3.
The IEPA alleges
that the Administrative Citation is based upon direct observations of
David C.
Jansen made on May 26, 2004.
4.
The IEPA alleges that the named Respondents have “caused or allowed the open
dumping ofwaste in
a manner resulting in litter; a violation of Section 2l(p)(l) of the Act, 415
ILCS 5/21 (p)(l) (2002).”
5.
The IEPA alleges that the named Respondents
have “caused or allowed the open
dumping ofwaste
in a manner resulting in deposition of general construction or demolition
debris or clean construction or demolition debris, a violation of Section 2l(p)(’7) ofthe Act, 415
ILCS 5/21
(p)(7) (2002).”
6.
Respondent Ted Harrison contests the aforementioned allegations, and specifically
denies
the allegations summarized in paragraphs one through five above.
WHEREFORE Respondent, TED HARRISON,
requests that this Board strike and
dismiss the Administrative Citation issued
against him,
and award to him such other and further
relief as this Board deems just and proper.
Respectfully submitted,
TED HARRISON,
Respondent,
By his attorney,
HEDINGER
OFFICE
By_______
Stephen ~4Iedinger
/
V
HEDINGER LAW OFFICE
2601
S. Fifth St.
Springfield, IL 62703
(217) 523-2753 phone
(217) 523-4366 fax
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY
v.
Complainant,
TED HARRISON AND GERALD S. GILL
Respondents.
)
)
)
)
)
AC
05-08
)
(IEPA No. 330-04-AC)
)
)
)
NOTICE OF FILING AND PROOF OF SERVICE
The undersigned certifies that an
original
and
nine copies of Respondent Ted Harrison’s
Petition for Review was served
upon the Clerk of the Illinois
Pollution Control Board,
and
one
copy
was
served
upon
the following
parties
of record
in
this
cause
by
enclosing
same
in
envelopes addressed to:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph St., Suite 11-500
Chicago, IL
60601
Michelle M. Ryan
Division ofLegal Counsel
Illinois Environmental Protection Agency
1021
N. Grand Ave. East
P.O. Box
19276
Springfield, IL 62794-9276
Gerald S.
Gill
100 Redbud Road,
P.O. Box 200
Virginia, IL 62691
with
postage fully prepaid, and by
depositing said envelopes in
a U.S.
Post
Springfield,
Illinois on the,~/~
day of August, 2004.
HEDINGER LAW OFFICE
2601
South Fifth Street
Springfield, IL 62703
(217) 523-2753 phone
(217) 523-4366 fax
This Pleading is being submitted on recycledpaper
Office Mail
Box in
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