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CLERKS OFFICE
OCT
13200k
STATE OF ILLINOIS
OFFICE
OF THE AITORNEY
GENERAL
pollution Control Board
STATE OF ILLINOIS
Lisa Madigan
ATTORNEY GENERAL
October
8,
2004
Dorothy Gunn,
Clerk
Illinois Pollution
Control
Board
100
West Randolph
Street
Suite 11-500
Chicago,
Illinois
60601-3286
Re:
People v. Wood River Refining Co.
PCB No. 99-120
Dear Clerk Gunn:
Enclosed for filing please find
an original
and ten copies of a NOTICE OF FILING
and
COMPLAINANT’S RESPONSE TO REQUEST
FOR MODIFICATION OF ORDER with
regard
to the above captioned
matter.
Please return
a file-stamped
copy in the enclosed
self-addressed stamped envelope.
Thank you for your cooperation
and consideration.
Sincerely,
Thomas
Davis
Assistant Attorney General
500 South
Second Street
Springfield,
Illinois 62706
TD/pp
Enclosures
500 South
Second
Street,
Springfield,
1hl)nois
(2706
•
(217)
782—I0~,)0
•
‘I’TY: (217)
785—2771
•
Fax:
(217) 782-7046
100 West
Randolph
Street,
Chtcagii.
llhiiiok
60601
•
(3)2)
$14—300()
•
ITY:
(312)
514—3374
•
Fax:
(312)
814—3800
1001
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641(
BEFORE
THE
ILLINOIS POLLUTION
CONTROL BOARD
~~C~VED
RKS OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
OCT
13
2004
Complainant,
)
STATE OF ILLINOIS
Ollution
Control Board
v.
)
PCB
NO.
99-120
)
(Enforcement)
WOOD RIVER REFINING
COMPANY,
-
)
a Division of EQUILON ENTERPRISES,
LLC,
)
Respondent.
NOTICE
OF FILING
To:
Mr. Joseph A.
Girardi
Henderson & Lyman
175 West Jackson
Blvd.
Chicago,
IL
60604
PLEASE TAKE
NOTICE that on this
date
I
mailed for filing with theClerk of the Pollution
Control
Board
of
the
State
of
Illinois,
COMPLAINANT’S
RESPONSE
TO
REQUEST
FOR
MODIFICATION OF ORDER, copies of which are attached hereto and herewith served
upon you.
Respectfully submitted,
PEOPLE
OF THE
STATE OF ILLINOIS
LISA
MADIGAN
Attorney General of the
State of Illinois
MATTHEW J.
DUNN, Chief
Environmental
EnforcementlAsbestos
Litigation
Division
BY:_____________________
THOMAS
DAVIS
Assistant Attorney General
Environmental Bureau
500
South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated: October 8, 2004
People vs. Wood
River Refining Co.,
PCB
No. 99-1 20
CERTIFICATE
OF SERVICE
I hereby certify that
I did on October 8, 2004, send by First Class Mail, with postage thereon
fully
prepaid,
by depositing
in
a
United
States
Post
Office
Box
a true
and
correct copy
of the
foregoing
instrument
entitled
NOTICE
OF
FILING
and
COMPLAINANT’S
RESPONSE
TO
REQUEST FOR
MODIFICATION OF ORDER
To:
Mr.
Joseph A.
Girardi
Henderson
&
Lyman
175 West
Jackson
Blvd.
Chicago,
IL
60604
and the original and ten copies
by First Class
Mail with postage thereon fully prepaid of the same
foregoing
instrument(s):
To:
Dorothy Gunn,
Clerk
Illinois Pollution Control
Board
-
State of Illinois
Center
Suite
11-500
100 West Randolph
Chicago,
Illinois 60601
A copy was also
sent by First Class
Mail with
postage thereon fully prepaid
To:
Ms.
Carol Sudman
Hearing Officer
Pollution Control
Board
P.O.
Box 19274
Springfield,
IL
62794-9274
•
~
...
Thomas
Davis
Assistant Attorney General
Environmental Bureau
500
South Second Street
Springfield,
Illinois 62706
(217)
782-9031
BEFORE THE
ILLINOIS POLLUTION
CONTROL BOAR1~ECE~VED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
OCT
132004
-
Complainant,
)
STATE OF ILLINOIS
)
Pollution Control Board
vs.
)
No.
99-120
)
(Enforcement)
WOOD RIVER REFINING
COMPANY,
)
Respondent.
COMPLAINANT’S RESPONSE TO REQUEST FOR MODIFICATION OF ORDER
Complainant,
PEOPLE OF THE
STATE
OF ILLINOIS,
by LISA MADIGAN,
Attorney
General
of the State of Illinois, hereby concurs with
the Respondent’s Request for Modification
of Order,
and states as follows:
1.
The Proposal
for Settlement explicitly sets forth the applicable terms
and
conditions of the agreement between the parties.
2.
The Board
may accept, suggest revisions in, or reject the proposal for
settlement, but has no authority
to
unilaterally alter the agreed
upon terms and
conditions.
3.
The Complainant assumes that the inclusion of a cease and
desist provision
in
the Order resulted from
inadvertence rather than
disagreement with
the negotiated
resolution.
WHEREFORE,
Complainant
requests that the
Board
modify
its Order.
Respecifully submitted,
PEOPLE OF THE
STATE
OF ILLINOIS,
LISA MADIGAN
Attorney General
State
of Illinois
MATTHEW
J.
DUNN, Chief
Environmental Enforcement Division
BY _________________________
THOMAS
DAVIS,
Chief
Environmental Bureau
Assistant Attorney General
500 South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
October 8, 2004
