RECE~VED
CLERK’S OFFICE
BEFORE THE
ILLINOIS
POLLUTION CONTROL BOARD
SEP
22
200k
STATE OF ILLINOIS
ILLINOIS
ENVIRONMENTAL
)
Pollution Control Board
PROTECTION
AGENCY,
)
Complainant,
)
ç
ACO~
)
(IEPA No.
361-04-AC)
C.
JOHN BLICKHAN,
)
Respondent.
NOTICE OF
FILING
PLEASE TAKE
NOTICE that on this
date
I
mailed for filing with
the
Clerk
of the
Pollution
Control
Board
of the
State
of
Illinois
the
following
instruments
entitled Petition
for Review, Notice of Appearance and Certificate of Service.
Dated:
September 20, 2004
C.
JOHN BLICKHAN,Respoqdent,
~
Apthoi~y
~
Cameron,
//
His Attorney
ANTHONY
B.
CAMERON
-
374555
Attorney for Respondent
529 Hampshire Street
-
Suite
511
Quincy,
IL
62301
Telephone:
(217) 228-8669
Telefax:
(217) 228-2225
Our File No.
04-901
Presented on recycled bond
as encouraged by Rule
10.
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY,
Complainant,
V.
C.
JOHN BLICKHAN,
Respondent.
)
)
)
)
)
)
)
)
)
AC
(IEPA No. 361-04-AC)
RECE~VED
CLERK’S OFFICE
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
SEP
22200k
STATE OF ILLINOIS
)
Pollution Control Board
NOTICE OF APPEARANCE
NOW
COMES
Anthony
B.
Cameron,
Attorney
at
Law,
and
enters
his
appearance as counsel for
Respondent,
herein
praying this
Board
and counsel for
other
parties
that
notice
be
given
at
the
address
set
forth
below of
any
further
proceedings orfilings in the
instant cause.
ANTHONY B.
CAMERON
-
374555
Attorney for Respondent
529 Hampshire Street
-
Suite 511
Quincy,
IL
62301
Telephone:
(217) 228-8669
Telefax:
(217) 228-2225
Our File No.
04-901
Presented on recycled bond
as encouraged by Rule 10.
RECEIVED
CLERK’S
OFFICE
BEFORE THE
ILLINOIS POLLUTION CONTROL
BOARISEP
22200k
STATE OF ILLINOIS
Pollution Control Board
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
ACO~
v.
)
(IEPA No.
361-04-AC)
C. JOHN
BLICKHAN,
)
Respondent.
PETITION
FOR REVIEW
Now
comes
Respondent,
C.
John
Blickhan,
by
his
attorney,
Anthony
B.
Cameron,
and for his Petition for Review, states as follows:
(PUTATIVE)
FACTS
1.
Respondent
admits
he
is
the
currently
designated
operator
of
a
facility,
enclosure, located
at Lock &
Dam
Road,
Quincy, Adams County,
Illinois.
Respondent
further admits
that the
property is
known
in
IEPA
parlance as
the
“Quincy
Blickhan
landfill.”
In
further
answer,
however,
Respondent,
C.
John
Blickhan,
asserts
that neither
the
landfill
nor any
property
owned
by him
is
the
subject
of
the
entire
incident
report
and/or
violations
complained
of
in
the
Administrative Citation;
2.
Respondent
denies
each
and
every
allegation
of
Paragraph
2
of
said Administrative Citation;
3.
Respondent
denies
that
he
has
owned
or
operated
all
of
the
property complained of in the said Administrative Citation;
4.
Respondent
admits
that
one
Michelle
E.
Cozadd
claims
to
have
made an
inspection
on
some property
she describes
as set forth
in
Paragraphs
1,
2,
and
3
of
the
Administrative
Citation
and
denies
each
and
every
other
allegation of said Paragraph 4 of said Administrative Citation.
(PUTATIVE) VIOLATION
Respondent
denies
each
and
every
allegation
set
forth
in
the
lead
paragraph,
subparagraphs (1)
and
(2) of the instant Administrative Citation
and,
in further answer,
states there was no unlawful open dumping on
property owned
or operated by
him
and
certain other property
complained
of is
not
his property
and not his responsibility.
CLAIMED CIVIL PENALTY
Respondent admits
he has been advised of the contents of this subsection
of said
Administrative
Citation,
denies
each
and
every
other
allegation of said
subsections
of
said
Administrative
Citation
and
denies
the
balance
of
the
language set forth therein as moot.
PROCEDURE
FOR CONTESTING THIS ADMINISTRATIVE CITATION
Respondent
now
replies
within
the
time
set
forth
in
this
section,
denies
each and every remaining
allegation thereof and demands strict proof of any and
all
matters asserted in said Administrative Citation.
C.
JOHN BLICKHAN,
Respon
nt,
B~1tItorn~~ron,
STATE OF
ILLINOIS
COUNTY OF ADAMS
)
)
)
ss:
C.
John
Blickhan,
having
been first duly sworn upon
his oath,
deposes
and
says that he has read the foregoing
and has knowledge of the content thereof,
and
that
the
same
is
true
in
substance
and
in
fact
to
the
best
of
his
information,
knowledge and belief.
(~
~
/~\
~i///
1
7
~lickhan
Subscribed
and
sworn
to
before
me,
a
Notary
Public,
this
20th
day
of
September,
2004.
7~z~
Notary Public
ANTHONY B. CAMERON
-
374555
Attorney for Respondent
529 Hampshire Street
-
Suite 511
Quincy,
IL
62301
Telephone:
(217) 228-8669
Telefax:
(217) 228-2225
Our File No.
04-901
Presented
on recycled bond
as encouraged by Rule
10.
IL~U1~tUrLLLUrflLt
1~.
“OFFICIAL
SEAL”
LINDA
K.
MEA)Q
Notary
PubII~,State
of Illinois
My Comm~,~,
Expires O6/O7~8
~fltUi.i~~
~L1.i,uli
1L-
ttiji~
BEFORE THE
ILLINOIS
POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
AC
v.
)
(IEPA No.
361-04-AC)
C.
JOHN
BLICKHAN,
)
)
Respondent.
CERTIFICATE OF SERVICE
I,
Anthony
B.
Cameron,
hereby certify that
I
served
a copy of the foregoing
document
entitled
Notice
of Appearance,
Notice
of Filing,
Petition
for Review
and Certificate of Service
upon the following by depositing
a true and correct copy
of the same
in
a
United States
Post Office box located in
Quincy,
Illinois, first class
postage fully prepaid, enclosed
in an envelope plainly addressed as follows,
on the
20th day of September, 2004:
Illinois Environmental
Protection Agency
ATTN:
Division of Legal Counsel
1021
North Grand Avenue
East
P.
0. Box
19276
Springfield,
IL
61794-9276
/
//
//
,~
~
~4~Anthony
B. Cameron
ANTHONY B. CAMERON
-
374555
Attorney for Respondent
529 Hampshire Street
-
Suite 511
Quincy,
IL
62301
Telephone:
(217) 228-8669
Telefax:
(217) 228-2225
Our File No.
04-901
