RECE~VED
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
CLERK’S OFFICE
JAN
072005
1021
NORTH
GRAND AVENUE
EAST,
P.O.
Box
19276,
SPRINGFIELD, ILLINOIS
62794-9276, 217-782-3397
JAMES
R.
THOMPSON
CENTER,
100
WEST RANDOLPH,
SUITE
11-300;
CHICAGO,
IL 60601,
31 2-814-~~ATE
OF ILLINOIS
Pollution Control
Board
ROD R.
BLAGOJEVICH,
GOVERNOR
RENEE
CIPRIANO,
DIRECTOR
(217)782-9817
,
‘c~:~
TDD: (217) 782-9143
January 5, 2005
The Honorable Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R.
Thompson Center
100 West Randolph Street, Suite
11-500
Chicago, Illinois 60601
Re:
Illinois Environmental Protection Agency v.
Lawrence Krueger
JEPA File No. 647-04-AC; 0518085002—Fayette County
Dear Clerk Gunn:
Enclosed for filing with the Illinois Pollution Control Board, please find the original and nine
true and correct copies ofthe Administrati~eCitation Package, consisting of the Administrative
Citation, the inspector’s Affidavit, and the inspector’s Illinois Environmental Protection Agency
Open Dump Inspection Checklist, issued to the above-referenced respondent(s).
On this
date, a copy of the Administrative Citation Package was sent to the Respondent(s) via
Certified Mail.
As soon as I receive the return receipt, I will promptly file a copy with you, so
that the Illinois Pollution Control Board may calculate the thirty-five
(35)
day appeal period for
purposes ofentering
a default judgment in the event the Respondent(s) fails or elects not to file a
petition for review contesting the Administrative Citation.
Ifyou
have any questions or concerns, please do not hesitate to contact me at the number above.
Thank you for your cooperation.
Sincerely,
IJames M. Kropid
JAssistant Counsel
Enclosures
ROCKFORD
—4302
North Main Street, Rockford,
IL 61103 —(815) 987-7760
•
DES
PLAINES —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— (309) 693-5463
BUREAU
OF LAND
-
PEORIA —7620
N. University St.,
Peoria,
IL
61 614 —(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, Collinsville,
IL 62234
—
(618) 346-5120
MARION
—
2309 W. Main
St., Suite 116, Marion,
IL 62959
—
(618) 993-7200
PRINTED
ON
RECYCLED
PAPER
RECE~VED
CLERK’S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JAN
072005
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
)
LAWRENCE KRUEGER,
)
)
Respondent.
)
AC
(IEPA No. 647-04-AC)
STATE OF ILLINOIS
Pollution
Control Board
To:
Lawrence Krueger
RR #2, Box 20
Beecher City, IL
62414
NOTICE OF FILING
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board ofthe State ofIllinois the following instrument(s) entitled ADMINISTRATIVE
CITATION, AFFIDAVIT, and OPEN DUMP iNSPECTION
CHECKLIST.
IllinoisEnvironmental Protection Agency
1021
North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated:
January 5,2005
Complainant,
)
)
v.
)
Respectfully submitted,
Jamfs M. Kropid
SPDial AssistantAttorney General
THIS
FIIJNG
SUBM~ITED
ON
RECYCLED PAPER
AECE
WED.
CLERK’S OFFICE
JAN
07
2005
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
STATE OF ILLINOIS
ADMINISTRATIVE CITATION
Pollution Control
Board
AC
O3’~
(IEPA No. 647-04-AC)
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 Lawrence Krueger (‘Respondent”) is the present ownerof two tracts of
property
located on the westside of Illinois Highway 128
in rural Fayette County.
The property is commonly
known
to the
Illinois Environmental
Protection Agency as Beecher City/Krueger,
Lawrence.
The
legal description
is as follows:
Tract
1:
Beginning ata point 52 rods South of the Northeast cornerof Section
36, Township 9 North, Range 3 East of the Third Principal Meridian,
running thence West 16 rods, thence South 10 rods, thence East
16
rods,
thence
North
10 rods
to
the
place
of
beginning,
situated
in
Fayette County,
Illinois.
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
)
.
V.
)
)
LAWRENCE KRUEGER,
)
)
Respondent.
.
)
1
Tract 2:
.
Beginning ata point 62 rods South of the Northeast corner of Section
36, Township 9 North, Range 3 East of the Third Principal Meridian,
running thence West 16
rods, thence
North 10 rods, thence West 24
rods, thence
Southl2, thence East 40
rods, thence North 2 rods to
the place of beginning
situated in
Fayette County
Illinois
2.
That
said
facility
is
an
open~dt~mp
operating
without
an
Illinois
Environmental
Protection
Agency Operating
Permit and is designated with Site Code No
0518085002
3.
That Respondent has owned and operated said facility at all times pertinent hereto.
4.
That on November 30, 2004, Kendall Couch of the Illinois Environmental Protection
Agency’s
Collinsville
Regional
Office
inspected
the
above-described
facility.
A
copy
of
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 Kendall Couch during the courseof his November
30, 2004 inspection
of the above-named facility
the Illinois Environmental Protection Agency has
determined that Respondent has violated the Illinois Environmental Protection Act (hereinafter, the
Act
)
as follows
(1)
That
Respondent
caused
or allowed
the
open
dumping
of
waste
in
a
manner
resulting
in
litter
a
violation
of
Section 21(p)(l) of
the Act
415
ILCS 5/21(p)(l)
(2002).
(2)
That
Respondent
caused
or allowed
the
open
dumping
of waste
in
a
manner
resulting
in
open
burning
a
violation
of
Section
21(p)(3)
of the
Act
415
ILCS
5/21(p)(3)
(2002).
.
2
CIVIL PENALTY
Pursuant
to
Section
42(b)(4-5) of the Act,
415
ILCS
5/42(b)(4-5)
(2002),
Respondent is
subject
to
a
civil
penalty of
One Thousand
Five
Hundred
Dollars
($1,500.00)
for each
of
the
violations identified above, for a total of Three Thousand Dollars ($3,000.00).
If Respondent elects
not to petition the Illinois Pollution Control
Board, the statutory civil penaltyspecified above shall be
due and payable no
later than February 15, 2005, unless otherwise provided by order of the Illinois
Pollution
Control Board.
IfRespondent elects 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
Pollution Control Board issues a finding of violation as alleged herein, after an adjudicatory hearing,
Respondent 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.
Pursuant to Section 31.1 (d)(1) of the Act, 415 ILCS 5/31.1 (d)(1) (2002), if Respondentfails
to petition orelects 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,
Respondent’s
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,
Respondent shall
complete and
return
the
enclosed
Remittance Form to ensure proper documentation of payment.
-
3
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 Respondentfrom 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 Respondent
in Circuit Court to collect said penalty and/or hearing costs,
plus any interest
accrued.
4
PROCEDURE FOR CONTESTING THIS
ADMINISTRATIVE CITATION
Respondent
has
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 Respondent elects to contest
this Administrative
Citation,
then
Respondent shall file a
signed
Petition for Review,
including
a
Notice
of
Filing,
Certificate
of
Service,
and
Notice
of
Appearance,
with the Clerk
of 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.
1~A~tQ
C
~144t..~*4~
Date:
/
SJd
c
Renee
Cipriano,
Director
-4
“-c--
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
5
CLERK’S OFFICE
JAN
072005
STATE OF ILLINOIS
REMITTANCE FORM
Pollution Control Board
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
‘V.
)
(IEPA No. 647-04-AC)
LAWRENCE KRUEGER,
)
Respondent.
)
FACILITY:
Beecher City/Krueger,
Lawrence
SITE
CODE NO.:
0518085002
COUNTY:
Fayette
CIVIL PENALTY:
$3,000.00
DATE OF INSPECTION:
November 30, 2004
DATE
REMITTED:
SS/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 Remittance Form.
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.
6
~FCF~VED
ILLINOIS ENVIRONMENTAL PROTECTION
AG~N~(s
OFFICE
Open Dump Inspection Checklist
JAN
072005
County:
Fayette
LPC#:
0518085002
~
Location/Site
Name:
Beecher City/Krueger,
Lawrence
.
Pollu1~~’fl
Date:
11/30/2004
Time:
From
10:45am
To
11:00am
Previous Inspection Date:
07/16/2004
Inspector(s):
Kendall Couch
Weather:
Cloudy, rain, 48 degress F.
No. of Photos Taken:
#
4
Est. Amt. of Waste:
100
yds3
Samples Taken:
Yes #
No
~
Interviewed:
No one present
Complaint #:
C-2004-036
Responsible
Party
Mailing Address(es)
and
Phone
Number(s):
Lawrence
Krueger
.
RR#2Box2O
,
Beecher City,
‘
~
~D
.
No Phone
UEC
20
zoo4
.
I
‘~r/-~-~-”-’
DESCRIPTION
VIOL
ILLINOIS 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
L
4.
12(d)
.
CREATE AWATER POLLUTION HAZARD
1
5.
21(a)
CAUSE OR ALLOW OPEN DUMPING
.
6.
21(d)
CONDUCT
ANY
WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION:
(1)
T
Without a
Permit
(2)
In Violation
of
Any
Regulations or
Standards Adopted by the Board
.j.
7.
21(e)
DISPOSE,TREAT, STORE, OR ABANDON
ANY
WASTE, OR TRANSPORT
ANY
I
~
WASTE INTO THE STATE AT/TO SITES NOT MEETING REOUIREMENTS OF ACT
J~
.
CAUSE OR ALLOW THE
OPEN DUMPING OF
ANY
WASTE IN A MANNER WHICH RESULTS
8.
21(p)
(1)
IN ANY OF THE FOLLOWING OCCURRENCES AT THE DUMP SITE:
Litter
(2)
Scavenging
(3)
~Open
Burning
.
(4)
Deposition of Waste
in Standing or Flowing Waters
.
El
(5)
Proliferation
of Disease Vectors
LI
(6)
Standing or Flowing Liquid Discharge from the Dump
Site
.
LI
.~-r~A
!~I
flt’
Revised 06/18/2001
(Open Dump
-
1)
LPC#
0518085002
Inspection
Date:
Signature of Inspector(s)
Inforn~tionaINotes
1.
Illinois
Environmental
Protection Act: 415 ILCS
5/4.
2.
Illinois Pollution Control Board: 35 III. Adm. Code, Subtitle G.
3.
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 Actshall be enforceable either
by administrativecitation
under Section 31.1
of the Act or by complaint under Section
31
of the Act.
5.
This inspection was conducted in accordancewith Sections 4(c) and 4(d) of the Illinois
Environmental Prolection Act:
415 ILCS
5/4(c)
and (d).
6.
Items marked with an “NE” were not evaluated at the time of this
inspection.
04/09/2004
(7)
Deposition of General Construction or Demolition Debris; or Clean Construction or
Demnlitinn
Debris
El
9.
55(a)
NO PERSON SHALL:
(1)
Cause or Allow Open
Dumping of Any Used or Waste Tire
(2)
Cause
or Allow Open
Burning of Any Used or Waste Tire
.
L
El
•
.
...!
35 ILLINOIS ADMINISTRATIVE CODE REQUIREMENTS
SUBTITLEG
.
...
10.
812.1 01 (a)
FAILURE TO SUBMIT AN APPLICATION
FOR APERMIT TO DEVELOP AND
OPERATE A LANDFILL
El
11.
722.111
HAZARDOUS WASTE
DETERMINATION
El
12.
808.121
SPECIAL WASTE DETERMINATION
El
13.
809.302(a)
ACCEPTANCE
OF SPECIAL WASTE FROM AWASTE TRANSPORTER WITHOUT A
WASTE HAULING PERMIT,
UNIFORM WASTE PROGRAM REGISTRATION AND
PERMIT AND/OR MANIFEST
El
OTHER REQUIREMENTS
14.
APPARENT VIOLATION OF:
(J)
PCB;
(I)
CIRCUIT
COURT
CASE NUMBER:
ORDER ENTERED
ON:
El
15.
OTHER:
El
,
El
El
.
El
--
•
El
•
El
Revised 06/18/2001
(Open Dump -2)
LPC#-05 18085002-Fayette County
Beecher City/Krueger, Lawrence
.
Date ofInspection: November 30, 2004
Prepared by: Kendall Couch
DEc ~
Date: December 21,
2004
~
0 20~
I&~pI4
Narrative
GeneralRemarks
On November30, 2004, I went to the rural Beecher City, Illinois area to do
a follow-up
inspection at this
site.
No one was present during this
inspection. The weather was
cloudy, rain, and temperature was 48°F.
History
A complaint was received by the Agency stating that this site had a large accumulation of
tires on February 24, 2004. An Administrative Warning Notice (ACWN) was
sent to this
site on May20, 2004, and received by Lawerence Krueger on May 22, 2004.
The original ACWNwas sent to
Lorrence Hinds ofBeecher City. The Agency received
correspondence from Mr. Hinds and it was clear that the respondent’s legal name was
Lawerence Krueger. Mr. Krueger’s stepmother lived on this property prior to the original
inspection and the original complaint referenced her last name. This was the origin of
referencing this site to the last name ofHinds.
On June 21, 2004, the Agency received a response to the May 20, 2004 Administrative
Warning Notice Letter. The response stated that the tires, burn piles and trailers would be
cleaned up by September
1,
2004.
Inspection
OnNovember 30, 2004, I went to this site to conduct a follow-up inspection. I walked to~.
therear ofthis site. The bum piles and tires remained. There were several trailers being
dismantled with bum piles in their vicinity.
I again observed approximately 800 tires located on the west end ofthe property. The
tires were
95
car and light truck tires. Approximately
50
ofthe tires were still on
rims.
There was a grain elevator being cut up and salvaged on the southern end ofthis
site.
During this inspection the apparent violations of9(a), 9(c), 21(a), 21(d)(1), 21(d)(2),
21(e), 21(p)(1), 2l(p)(3)
and
55(a)(1)
ofthe Environmental Protection Act were again
observed.
•
cc:
DLPC/FOS- Collinsville Regional
State ofIllinois
Environmental Protection Agency
Facility Diagram
Date ofInspection:
November 30, 2004
Site Code:
0518085002
Site Name:
Krueger, Lawrence
,ll~
Inspector:
Kendall Couch
County:
Fayette
Time:
10:45am
E~1~
~II~®
LPC #0518085002 -Fayette County
Beecher City/Krueger, Lawrence
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
November 30, 2004
TIME:
10:45am-11:OOam
DIRECTION:
PHOTO by:
Kendall Couch
PHOTO FILE
NAME:
0518085002-41302004-001
COMMENTS:
DATE:
November 30, 2004
TIME:
10:45am-11:OOam
DIRECTION:
PHOTO by:
Kendall Couch
PHOTO FILE
NAME:
0518085002-41302004-002
COMMENTS:
LPC #0518085002 -Fayette County
Beecher City/Krueger, Lawrence
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
November 30, 2004
TIME:
10:45am-11:OOam
DIRECTION:
PHOTO by:
Kendall Couch
PHOTO FILE
NAME:
0518085002-4 1302004-003
COMMENTS:
DATE:
November 30, 2004
TIME:
10:45am-11:00am
DIRECTION:
PHOTO by:
Kendall Couch
PHOTO FILE
NAME:
0518085002-~4
1302004-004
COMMENTS:
~inted
12/21/2004
8:14AM by epa4224
p.
1/5
LPC
#0518085002
-Fayette County
Beecher Citylflinds, Lorrence
FOS File
DATE: May 14, 2004
TIME: 2:2Opm-2:45pm
DIRECTION:
PHOTO by: Kendall Couch
PHOTO
FILE NAME:
05
180S5002—05
142004-001
COMMENTS:
DATE: May
14, 2004
TIME:
2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall
Couch
PHOTO
FILE
NAME:
0518085002—05142004--002
COMMENTS:
DIGITAL PHOTOGRAPH PHOTOCOPIES
printed 12/21/2004
8:14AM by epa4224 p. 2/5
LPC
#0518085002
-Fayette County
Beether City/Hinds, Lorrence
FOS File
DATE: May 14, 2004
TIME: 2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall
Couch
PHOTO FILE
NAME:
0518085002~05
142004-003
COMMENTS:
DATE: May 14,
2004
TIME:
2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall
Couch
PHOTO FILE NAME:
0518085002—OS 142004-004
COMMENTS:
DIGITAL PHOTOGRAPH PHOTOCOPIES
1~~~~~~
—
-
.—.
-
print~d 12/21/2004
8:14AM by epa4224
p. 3/5
LPC #0518085002-Fayette County
Beecher
City/Hinds,
Lorrence
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
May
14,2004
TIME:
2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall
Couch
PHOTO
FILE
NAME:
0518085002~4)5
142004-005
COMMENTS:
DATE:
May 14,
2004
TIME: 2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall
Couch
PHOTO
FILE
NAME:
051
8085002—OS 142004-006
COMMENTS:
printed 12/21/2004 8:14AM by epa4224
p. 4/5
LPC #0518085002 -Fayette County
Beecher City/Hinds, Lorrence
FOS File
DATE:
May
14, 2004
TIME:
2:2Opm-2:45pm
DIRECTION:
PHOTO by: Kendall Couch
PHOTO FILE NAME:
0518085002~4)5
142004-007
COMMENTS:
DATE: May 14, 2004
TIME: 2:2Opm-2:45pm
DIRECTION:
PHOTO by: Kendall Couch
PHOTO FILE NAME:
051
8085002—OS142004-008
COMMENTS:
DIGITAL PHOTOGRAPH PHOTOCOPIES
printed 12/21/2004
8:14AM
by epa4224
p. 5/5
LPC
#0518085002-Fayette County
Beecher City/Hinds, Lorrence
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
May 14,2004
TIME: 2:2Opm-2:45pm
DIRECTION:
PHOTO by:
Kendall Couch
PHOTO
FILE
NAME:
051 8085002—OS
142004-009
COMMENTS:
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AFFIDAVIT
iN
THE MATTER OF:
)
)
IEPA DOCKET NO.
)
Beecher City/Krueger, Lawrence
)
Lawrence Krueger
)
)
Respondent.
)
Affiant, Kendall Couch, being first duly sworn, voluntarily deposes and
states as follows:
1.
Affiant is a field inspector employed by the Bureau of
Land ofthe Illinois Environmental Protection Agency and has been so employed
at all times pertinent hereto.
2.
On November 30, 2004, between 10:45am and 11:00am, Affiant conducted an
inspection ofthe open dump in Fayette County, Illinois, known as
Beecher City/Krueger, Lawrence, Illinois Environmental Protection Agency Site
No. 0518085002.
3.
Affiant inspected said Beecher City/Krueger, Lawrence open dump by an on-site
inspection which included walking the site and taking photographs.
4.
As a result ofthe activities referred to in Paragraph 3 above, Afflant assisted in
the completion ofthe Inspection Report form attached hereto and made a part
hereof, which, to
the best ofthe Affiant’ s knowledge and belief, is an accurate
representation ofAfflant’ s observation and factual conclusions with respect to
said Beecher City/Krueger, Lawrence open dump.
-
Subscribed and Sworn to before me
this 21st day ofDecember 2004
(?ckJe
O/~aC
Notary Public
I
~
-
“OFFiCiAL
~EALj’
Paula
Ottefismejer
~
Notary pubj~~~
~
of L1linoj~
My Commjssjo~Expires
--
a~,L
Kendall Couch
PROOF OF SERVICE
I herebycertify that I did on the 5th day ofJanuary 2005, sendby Certified Mail, ReturnReceipt
Requested, with postage thereon fullyprepaid, by depositing in a United StatesPost OfficeBox a true
and
correct
copy
of
the
following
instrument(s)
entitled
ADMINISTRATIVE
CITATION,
AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST
To:
Lawrence Krueger
RR
#2,
Box 20
Beecher City, IL
62414
and the original and nine (9) true and correct copies of the same foregoing instruments on the same
date by Certified Mail, Return Receipt Requested, with postage
thereon fully prepaid
To:
Dorothy Gunn, Clerk
Pollution ControlBoard
James
R. Thompson Center
100West Randolph Street, Suite 11-500
Chicago, Illinois 60601
-/~
Ja~esM.Kropid
-
Sp~cia! Assistant Attorney General
Illinois Environmental ProtectionAgency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
