BEFORE THE POLLUTION CONTROL BOAR)OF THE STATE OF ILLINOIS
NOTICE
REQUEST FOR NINETY DAY EXTENSIONOF APPEAL PERIOD
Lake Forest/Lake Forest Oasis East
Tn-State Toliway (1-94), Northbound
Lust Incident Nos. 941628, 941813, 20011643, 20021646 and20030822

EXHIBIT
1. CERTIFICATE OF SERVICE

~C; E

CLERK’S OFACE

ILLINOIS STATE TOLL HIGHWAY

AUTHORITY (Lake Forest East CACR),

Petitioner,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

DorothyM.

Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph

Street

Suite 11-500

Chicago, IL 60601

Respondent.

Kenneth W. Funk

Deutsch, Levy & Engel

225 West Washington Street

Suite

1700

Chicago, IL

60606

OCT

20C3

PLEASE TAKE NOTICE that

I have

today

filed with the

office of the

Clerk of the Pollution

Control Board a REQUEST FOR NINETY DAY EXTENSION

APPEAL

PERIOD,

copies of which

are herewith served upon

you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,

Respondent

Assistant Counsel

Special Assistant Attorney General

Division of Legal

Counsel

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 62794-9276

217/782-5544

217/782-9143 (TDD)

Dated: October

13, 2004

BEFORE THE POLLUTION CONTROL BOAR)

OF THE STATE

OF ILLINOIS

)

STATE

OF ~LUNO~S

PoHution ContrO’ Board

PCB No. 05-

“7

(UST Appeal

—

Ninety Day Extension)

NOTICE

CLERK’S OFFic~

OCT

2063

BEFORE THE POLLUTION CONTROL BOARD

STATE OF

ILUNOiS

OF THE STATE OF ILLINOIS

Pollution

Contro’

Boarc~

ILLINOIS STATE TOLL HIGHWAY

)

AUTHORITY (Lake Forest East CACR),

)

Petitioner,

)

PCBNo.05-

ILLINOIS ENVIRONMENTAL

)

((JST Appeal

—

Ninety Day Extension)

PROTECTION AGENCY,

)

Respondent.

)

REQUEST FOR NINETY DAY EXTENSION

OF APPEAL PERIOD

NOW

COMES the Respondent, the Illinois Environmental

Protection

Agency (“Illinois

EPA”), by

one of its

attorneys, John J.

Kim,

Assistant Counsel

and

Special

Assistant Attorney

General,

and,

pursuant

Section

40(a)(I)

of the

Illinois

Environmental

Protection

Act

(415

ILCS

5/40(a)(1))

and

Ill.

Adm.

Code

105.208,

hereby requests

that

the

Illinois

Pollution

Control Board (“Board”) grant an extension ofthe thirty-five

(35)

day period for petitioning for a

hearing to January

12,

2005, or any other date not more than a total ofone hundred twenty-five

(125)

days from the date ofservice ofthe Illinois

EPA’s

final decision.

In support thereof, the’

Illinois EPA respectfully states as follows:

On September

1, 2004,

the Illinois EPA issued

a final decision to

the Petitioner.

(Exhibit A)

On September 30, 2004, the Petitioner made a written request to

the Illinois

EPA

for an

extension of time by which to

file

a petition for review,

asking the Illinois

EPA join

requesting that

the Board

extend the thirty-five

day

period for filing

a petition

ninety

days.

Documents

provided

the

Petitioner

represented

that

the

final

decision

was

received

September 8, 2004.

(Exhibit B)

The additional

time requested by

the parties may eliminate the need for a hearing

in this

matter or, in the alternative, allow the parties to identify issues and limit the scope ofany

hearing that may be necessary to resolve this matter.

WHEREFORE,

for the

reasons

stated above, the parties

request that

the Board,

the

interest of administrative and judicial

economy, grant this

request for a ninety-day

extension of

the thirty-five day period for petitioning for a hearing.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,

Respondent

Assistant Counsel

Special Assistant Attorney General

Divisionof Legal Counsel

1021 North Grand Avenue, East

P.O.Box

19276

Springfield, Illinois 62794-9276

217/782-5544

217/782-9143 (TDD)

Dated: October 13,-2004

This filing submitted on recycled

paper.

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

1021

NORTH

GRAND

AVENUE

EAST,

P.O.

Box

19276,

SPRINGFIELD,

ILLINOIS

62794-9276,

21 7-782-3397

JAMES

THOMPSON

CENTER,

100

WEST

RANDOLPH,

SUITE

11-300,

CHICAGO,

IL 60601, 312-814-6026

ROD

BLAGOJEVICH,

GOVERNOR

RENEE

CIPRIANO,

DIRECTOR

217/782-6762

CERTIFIED MAIL

7002

3150

0000

1113

5Ei61

illinois State Toll Highway Authority

RECEIVED

Attention:

Jeffrey S. Dailey, P.E.

QCD

2700 OgdenAvenue

QLJ

2004

Downers Grove, IL 60515

OASIS PROJECT MGR.

Re:

LPC #0970805037--Lake County

Lake Forest / Lake Forest Oasis East

Tn-State Tollway (1-94), Northbound

LUST Incident No.

941628, 941813, 20011643,

20021646,

20030822

LUST Technical File

Dear Mr.

Dailey:

The Illinois

Environmental

Protection Agency (Illinois EPA) has reviewedthe Corrective Action

Completion Report submitted for the above-referenced incident.

This informationis dated April 22, 2004

and was received by the Illinois EPA

on May 7, 2004.

Citations in this letter are from the

Environmental

Protection Act (Act) and 35 illinois Administrative Code

(35

111. Adm. Code).

The High Priority Corrective Action CompletionReport and associated Professional Engineer

Certification indicate corrective action forthe

above-referenced site was conducted in accordance with

the Corrective Action Plan approved by

the illinois EPA.

The Corrective Action CompletionReport

demonstrates that the requirements ofSection

57.7(c)(l)(E),

of the Act and 35 ill. Adm. Code

732.409(a)(2) havebeen satisfied.

Based upon the certification by Jinan Yan, a Licensed Professional Engineer,

and pursuant to Section

57.10

of the Act (415 ILCS 5/57.10), your request for a no further remediation determination is granted

under the conditions and terms specified in this letter.

Issuance ofthis No Further Remediation Letter (Letter), based on the certification of the Licensed

Professional Engineer, signifies that:

(1) all statutory

and

regulatory corrective action requirements

applicable to the occurrence have beencomplied with;

(2) all corrective action concerning the

remediation of the occurrence has been completed; and (3) no further corrective actionconcerning the

occurrence

is necessary for the protection ofhuman health, safety, and the environment.

Pursuant

Section 57.10(d) ofthe Act, this Letter shall apply in favor of the followingparties:

Illinois

State Toll Highway Authority, the owner or operatorof the underground storage tank

system(s).

Any parent corporation or subsidiary ofsuch owner or operator.

R~KFORD

—4302

Noah Main S~et,Rockford,

IL 61103

—(815) 987-

arrison St.,

Des

Plaines, IL 60016— (847) 294-4000

ELGIN

—595 South State, Elgin,

IL 60123 —(847) 608-313

EXHIBIT

St.,

Peoria

IL 61614— (309) 693-5463

BUREAU OF

LAND

PEORIA

—7620 N. University

St.,

Peoria, IL 61614— (309)

outh First Street, Champaign,

IL 61820— (217) 278-5800

SPRINGFIELD

—4500 5.

Sixth

Street Rd., Springfield,

IL 62706 —(217)

all

Street, Collinsvi(le,

IL 62234

—

(618) 346-5120

MARION

—2309 W. Main

St.,

993-7200

Page2

‘

Any co-owner or co-operator,

either by joint tenancy, right-of-survivorship,

or any other party

sharing a legal relationship with the owner or operator to whoth~héLétter

is issued.

Anyholder of a beneficial interest of a land trust or inter vivos trust whether revocable or

irrevocable.

Any mortgagee or trustee of a deed of trustof such owner or operator.

Any successor-in-interest of such owner or operator.

Any transferee of such owner or operator whether the transfer was by sale. bankruptcy

proceeding, partition, dissolution of marriage, settlement or adjudication ofany civil action,

charitable gift,

or bequest.

Anyheir or devisee of such owner or operator.

This

Letter and all attachments, including but not limited to the Leaking Underground Storage Tank

Environmental Notice, must be filed within 45

days of receipt as a single instrument with the Office of

the Recorder or Registrar of

Titles in the county in which the

above-referenced

site is located.

Thisj~etter

shall not be effective until officially recorded by the Office of the Recorder or Registrar of Titles of the

applicable county in accordance with Illinois law so it forms a permanent part of the chain oftitle for the

above-referenced property.

Within 30 days ofthis Letter being recorded,

an accurate and official copy of

this Letter,

as recorded, shallbe obtained and submitted to the Illinois EPA.

For recording purposes, it is

recommended that the Leaking Underground Storage Tank Environmental Notice of this Letter be the

firstpage ofthe instrument filed.

CoNDITIoNs

AND

TERMS

OF APPROVAL

LEVEL OF REMEDIATION

AND

LAND

USE

LIMITATIONS

The remediation objectives have been established in accordance with an industriallcommercial

land use limitation.

The remediation objectives for the above-referenced site, more particularly

described in the Leaking Underground Storage Tank Environmental Notice of this Letter, were

established in accordance with the requirements of the Tiered Approach to Corrective Action

Objectives

(35

Ill. Adrn.

Code 742) rules.

As a result ofthe release from the underground storage tank system(s)

associated with the above-.

referenced incident, the above-referenced site, more particularly described

iii

the attached

Leaking Underground Storage Tank Environmental Notice of this Letter,

shall not be used in a

manner inconsistent with the following land use limitation:

The landuse shall be

industrial/commercial.

The groundwaterunder the site shall not be used as apotable water

supply.

The land use limitation specified in this Letter may be revised if:

Further investigation or remedial action has been conducted that documents the

attainment of objectives appropriate for the new land use; and

Page 3

A new No Further Remediation Letter is obtained and recorded in accordance with Title

XVII of the Act and regulations adopted thereunder.

PREVENTIVE, ENGINEERING,

AND

INSTITUTIONAL CONTROLS

Preventive:

The groundwater under the site described in the attached Leaking Underground

Storage Tank Environmental Notice of this Letter shall not be used as apotable

supply of water.

No person shall construct, install, maintain, or utilize apotable

water supply well.

In accordance with Section 3.65 of the Act, “potable” means

generally fitfor human consumption in accordance with accepted water supply

principles and practices.

Engineering:

None.

Institutional:

This Letter shall be recorded as a permanent part of the chain of title for the

above-referenced site,’more particularly described in the attached Leaking

Underground Storage TankEnvironmental Notice ofthis Letter.

Failure to establish, operate, and maintain controls in full compliance with the Act, applicable

regulations, and the approved Corrective Action Plan, if applicable, may result in voidance of this

Letter.

OTHER TERMS

Any contaminated soil or groundwater removed or excavated from,

or disturbedat, the above-

referenced site,

more particularly described in the Leaking Underground Storage Tank

Environmental Notice ofthis Letter, must be handled in accordaiice with all applicable laws and

regulations under 35

Iii. Adm. Code Subtitle

Further informationregarding the above-referenced site can be obtainedthrough a written request

under the Freedom of Information Act

ILCS

140)

to:

flhinois Environmental Protection Agency

Attention:

Freedom ofInformatiOn‘Act Officer

BureauofLand

#24

1021 North

GrandAvenue East

Post Office Box 19276

Springfield, IL

62794-9276

Pursuantto

35 Ill. Adm. Code 732.704, should the Illinois EPA seek to void this Letter, the

Illinois EPAshall provide notice to the owner or operator of the leaking underground storage tank

system(s) associated with the above-referenced incident and the current title holder ofthe real

estate on whichthe tanks were located, at their last known addresses.

The notice shall specif~’

the

cause

for the voidance, explain the provisions for appeal, and describe the facts in support of the

voidance.

Specific

acts or omissions that may result in the voidance ofthis Letter include, but

shall not be limited to:

Page 4

Any violation of institutional controls or industrial/commercial land use restrictions;

The failure to operate and maintain preventive or engineering controls or to comply with

any applicable

groundwatermonitoringplan;

The disturbance or removal of contamination that has been left in-place in accordance

with the Corrective Action Plan or CompletionReport;

The failure to comply with the recording requirements for the Letter;

Obtaining the Letter by fraud or misrepresentation; or

Subsequent discovery of contaminants, not identified

as part of the investigative or

remedial activities upon which the issuance of the Letter was based, that pose a threat to

human health or the environment.

Submit an accurate and official copy of this Letter,

as recorded, to:

Illinois Environmental Protection Agency

Bureau of Land

#24

Leaking Underground Storage Tank Section

1021

North Grand Avenue East

Post Office Box 19276

Springfield,

62794-9276

If you have any questions or need further assistance, please contactthe Illinois EPA project manager,

Carol Hawbaker, at 217/782-5713.

any A. Chappel, P.E.

Unit Manager

Leaking Underground Storage Tank Section

Division of Remediation Management

Bureau of Land

IAC:CLH

Attachments:

Leaking Underground Storage Tank Environmental Notice

Wight

Division File

PREPARED

BY:

Name:

Jeffrey S. Dailey, P.E.

Illinois

State Toll Highway Authority

Address:

Tn-State Tollway (1-94) Northbound

Lake Forest, IL

60045

RETIJRN

TO:

Name:

Jeffrey S. Dailey, P.E.

Illinois

State Toll Highway Authority

Address:

2700 Ogden Avenue

Downers Grove, IL

60515

(TUE ABOVE

SPACE FOR RECORDER’S OFFICE)

LEAKING UNDERGROUND STORAGE TANK ENVIRONMENTALNOTICE

THE

OWNER AND/OR OPERATOR OF THE LEAKING UNDERGROUND STORAGE TANK SYSTEM(S)

ASSOCIATED WITH

THE

RELEASE REFERENCED BELOW,

WITHIN

DAYS OF RECEIVING

THE

FURTHER REMEDIATION LETTER CONTAINING THIS

NOTICE, MUST SUBMIT THIS NOTICE

AND THE

REMAINDER OF THE No FURTHER REMEDIATION LETTER TO THE

OFFICE OF THE RECORDER OR

REGISTRAR OF TITLES OF

LAKE

COUNTY IN WHICH

THE SITE DESCRIBED BELOW IS

LOCATED.

Illinois EPA Number:

0970805037

LUST Incident No.:

 941628, 941813, 20011643, 20021646 and20030822

Illinois State TollHighway Authority, the owner and/or operatorofthe leaking underground storage tank

system(s) associated with the above-referenced

incident, whose address is2700 Ogden Avenue, Downers

Grove,

IL 60515, has performed investigative and/or remedial activities forthe site identified

as follows:

Legal Description or Reference to a

Plat Showing the Boundaries:

That part of Sections 25 and

36 in Township 44 North Range

East of the Third Principal Meridian described as follows:

Commencing atthe southwest corner of the southwest quarter of said section 25; thence south 89

degrees 46’22” East of the south line of said Southwest quarter, 865.23 feet to the westerly right

of way of the Tn-StateTollway; thence north 44 degrees

 22’ 12” East 208.31 feet to point 125.00

feet west

as measured perpendicular to, the centerline of said tn-state tollway; thence north

degrees 17’

33” East 181.81

feet to the point of beginning; thence north

86 degreesl7’, 33” East

68.25

feet; thence south 44 degrees 07’ 38” east 602.43 feet, thence south 00 degrees 06’ 21” East

560.00 feet; thence south 46 degrees 01’ 37” west 317.64 feet; thence south 26 degrees 27’ 04”

west 246.04 feet; thence south 12 degrees 25’ 08” west, 230.57 feet; thence north 73 degrees

18’

24” west 94.18 feet; thence north 5 degrees 42’ 41” east, 42.95

feet, thence north 08 degrees 28’

58” east 51.26 feet; thence north 04

degrees 27’ 09” west

116.74. feet; thence north 00 degrees

06’ 21” west 1188.34 feet; thence north 01

degrees 23’ 00” west 182.70 feet; thence north 08

degrees 21’ 04” west 46.64 feet to the point ofbeginning in Lake County Illinois.

Common Address:

Tn-State Toliway (1-94) Northbound, Lake Forest, IL 60045

Real EstateTax Index/Parcel Index Number:

11-36-100-018-8001 and 11-36-100-018-8002

Site Owner:

illinois

State Toll Highway Authority

Leaking Underground Storage Tank Environmental Notice

Land Use Limitation: The land use shall be

industrial/commercial.

The groundwater under the

site

shall not be used

as a potable water supply.

See the attachedNo Further Rernediation Letter for other terms.

LeakingUndergroundStorage Tank EnvironmentalNotice

~.;,

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

1021

NORTH

GRAND AVENUE

EAST,

P.O.

Box 19276,

SPRINGFIELD,

ILLINOIS

62794-9276, 217-782-3397

JAMES

THOMPSON

CENTER,

100

WEST

RANDOLPH,

SUITE

11-300,

CHICAGO,

IL 60601, 312-814-6026

ROD

BLAGOJEVCH,

GOVERNOR

RENEE CIPRIANO,

DIRECTOR

RECORDING REQUIREMENTS

FOR

NO FURTHER REMEDIATION LETTERS

Introduction

The Illinois Environmental Protection Agency’s (Illinois EPA) Bureau ofLand/Leaking

Underground Storage Tank Section issues a No Further Remediation (NFR) Letter after a

demonstration of compliance with

Title XVI ofthe Environmental Protection Act and applicable

regulations is made.

The NFR Letter signifies that:

(1) all statutory and regulatory corrective

action requirements applicable to the occurrence have been complied with, (2) all

corrective

action concerning theremediation ofthe occurrence has beencompleted,

and

 (3) no

further

corrective action concerning the occurrence is necessary so long as the site is used in accordance

with the

terms and conditions of the NFR Letter.

Significance

When properly recorded, the NFR Letter holds legal significance for all applicable parties

outlined at Section 57.10(d) ofthe Environmental Protection Act. (See 415

ILCS 5/57.10(d).)

not properly recorded, the Illinois

EPA

will

take steps to voidtheNFR Letter

in accordance with

the regulations.

Duty

to Record

The duty to record the NFR Letter is

mandatory.

You

must

submit the NFR Letter, with a

copy of any applicable institutional controls proposed as part of a corrective action

completion report, to the Office of the Recorder or the Registrar of Titles ofthe county in

which the site is located

within 45 days after receipt ofthe NFR Letter.

You must record the

NFR Letter and

any attachments.

The NFR Letter shall be filed in accordance with Illinois

law so that it forms a permanent part of the chain of title to ensure current and future

users of the property will be informed of the conditions and terms of approval including

level of remediation; land use limitations;

and preventive, engineering,

and institutional

controls.

A certified or otherwise accurate and official copy of the NFR Letter and

any

attachments, as recorded, must be submitted to the Illinois EPA.

Failure to record the

NFR Letter

accordance with the regulations will make the NFR Letter voidable.

For More Information

Please refer to Tiered Approach to

Corrective

Action Objectives (TACO) Fact Sheet

 3 available

from the Illinois EPA by calling 1-888-299-9533 orby accessing it on the Illinois EPA Web site

at http://www.epa.state.il.us/land/taco/3-no-further-remediation-letters.html.

ROCKFORD

—4302

North Main Street, Rockford,

IL 61103

—

(815)987-7760

•

DES

PLANES

—9511

W. Harrison

St.,

Des Plaines, IL 60016 —(847) 294-4000

ELGIN

—

595

South State,

Elgin,

IL 60123 —(847) 608-3131

•

PEORIA

—5415

N. University St.,

Peoria,

IL 61614—1309) 693-5463

BUREAU

OF LAND

PEORIA

—

7620

N. University St.,

Peoria,

IL 61614 —(309) 693-5462

•

CHAMPAIGN

—

2125

South

First Street, Champaign,

IL 61820 —(217) 278-5800

SPRINGFIELD

—4500 S. Sixth Street Rd., Springfield,

IL 62706 —(217) 786-6892

•

COLLINSVILLE

—2009 Mall Street, Co!linsville, IL 62234 —(618)

346-5120

MARION

—2309 W. Main St.,

Suite

116, Marion,

IL 62959— (618) 993-7200

PQIMrrn

flNJ

Pcrvrr

cn I~~nro

EARL

DEUTSCH

PAUL

LEVY

TERRY

ENGEL

LAW

OFFICES

FRANK P. COHEN

JERRY

RUDMAN

MICHAEL

DEVINE

DEUTSCH, LEVY

ENGEL

STUART

SERKS

KENNETH

FUNK

CHARTERED

E-mail:

Iawyers@dlec.com

PHILLIP

ZISOOK

SUITE

1700

Website:

www.dlec.com

DENNIS

FRISBY

FACSIMILE,

(312)

34e-I,s5~

STEVEN

ISAACSON

225

WEST

WASHINGTON

STREET

_____

ALVIN

HELFGOT

CHICAGO,

ILLINOIS

60606

COUNSEL

JOEL

STEIN

MARSHALL D~KROLICK

BRIAN D.

SAUCIER

ARTHUR

SABIN

JAMES

O’HALLORAN

(312)

346-1460

AARON

ZARKOWSKY

LEO

AUBEL

KAREN

KAVANAGH

MACK

JEFFREY

HORWITZ

MOVENDA

MUTHARIKA

KNAPP

DAVID J.

BEN-DOV

i-s

‘~A

CATHERINE

GLENN

JOELSON

L)epLemuer

..flJ,

GREGORY A.

FREZADOS

LEE

FARBMAN

Via Facsimile:

(217)782-9807

RECE~

And Regular U. S. Mail

bivisjo~

of’

Illinois Environmental Protection Agency

~P~I

DivisionofLegal Counsel

OCT

1021 NorthGrandAvenue East

z004

P.O. Box

19276

~flVironment

Springfield, Illinois62794-9276

Protectj0~

Attention:

John

 Kim, Esq.

9ency.

Re:

LFC #0970805037

Lake County;

Lake Forest/Lake Forest Oasis East

Tn-State Toliway (1-94), Northbound

Lust Incident Nos.

941628,

941813, 20011643, 20021646 and20030822

Dear Mr.Kim:

The undersigned, as a Special Assistant

Attorney

General, represents the Illinois

State

Toll

Highway Authority in

connection

with

the referenced

LUST

Incidents.

I have received

copy of the Agency’s letters, dated September

 1, 2004, modifying the Authority’s Corrective

Action Completion Reportpreviously submitted to the Agency. A copyofthat letter is enclosed.

Please be advised that the Authority does not agree with the Agency’s

decision as

set

forth in

 its letter of September

 1, 2004 nor with its decision

modifying

the

underlying High

Priority Action Plan and Budget;

however,

hopes

of resolving

the

open

issues

with

the

Agency, and avoiding the necessity of an appeal to the Illinois

Pollution

Control Board,

our

client

 hereby

 requests

an

 extension,

 pursuant

to

 Sections

40

and

 57.8

 of the

 Illinois

Environmental Protection Act, to extend the period within which

 it may appeal the Agency’s

decision foran additional ninety (90) days.

193295.1

EXHIBIT

IllinoisEnvironmental Protection Agency

September 30, 2004

Page Two

our

understanding

that

upon

receipt of this

letter

you

will

proceed to

prepare

the

necessary

 motion for filing with

Illinois Pollution

Control Board to effectuate the extension.

your understanding is other than as indicated herein or if I can provide any further

information,

 please let us know immediately.

Yourassistance and

cooperation is appreciated.

Very truly yours,

KWF/alj

Enclosures

cc:

 Victor Azar, Esq.

Mr.

Robin Martel

Funk

Kenneth

193295.1

CERTIFICATE OF SERVICE

I, the undersigned attorney at law, hereby certify that

on October

13, 2004,

I served true

and

correct

copies of a

REQUEST FOR

NINETY DAY EXTENSION

APPEAL PERIOD,

by placing true and

correct copies in properly sealed

and addressed

envelopes and by depositing

said sealed envelopes

in a U.S. mail drop box located within Springfield, Illinois, with sufficient

First Class postage affixed thereto, upon the following named persons:

Dorothy M.

Guim, Clerk

Kenneth W. Funk

Illinois Pollution Control Board

Deutsch, Levy &

Engel

James R. Thompson Center

225

West Washington Street

100 West Randolph Street

Suite 1700

Suite 11-500

 Chicago, IL 60606

Chicago, IL 60601

ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY,

Assistant Counsel

Special Assistant Attorney General

Division ofLegal Counsel

1021

North Grand Avenue, East

P.O.Box

19276

Springfield, Illinois 62794-9276

217/782-5544

217/782-9143 (TDD)