BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
JUL 292005
STATE OF ILLINOIS
V.
)
Pollution Control Board
)
PCB 05-149
)
Enforcement
-
Air
TRUSERV CORPORATION, a Delaware,
)
corporation, d/b/a TRUE VALUE
)
MANUFACTURING COMPANY,
)
)
Respondent.
)
NOTICE OF FILING
To:
See attached Service List
PLEASE TAKE NOTICE that on the 29th day ofJuly, 2005, the People ofthe State ofIllinois,
filed with the Illinois Pollution Control Board, a MOTION FOR RELIEF FROM HEARING
REOUIREMENT and a STIPULATIONAND PROPOSAL FOR SEflLEMENT. trueandcorrect
copies ofwhich are attached hereto and is hereby served upon you.
PEOPLE OF THE STATE OF ILLINOIS,
cx reL
LISA MADIGAN, Attorney General
ofthe State ofIllinois
By:
_______
George
Theophilos
Assistant Attorney General
Environmental Bureau
188 West Randolph Street,
20th
Fl.
Chicago, IL 60601
(312) 814-6986
DATE: July 29, 2005
THIS FILING IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST
Mr. Bradley P. Halloran, Esq.
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, IL 60601
Ms. Maureen Wozniak, Esq.
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Ms. Cynthia Faur, Esq.
Sonnenschein Nath & Rosenthal
8000 Sears Tower
233 S. Wacker Dr., Suite 8000
Chicago, IL 60606
CERTIFICATE OF SERVICE
I, George D. Theophilos, an Assistant Attorney General, do certify that Icaused to be mailed,
this
29th
day o July, 2005, the foregoing MOTION FOR RELIEF FROM HEARING
REQUIREMENTand STIPULATION AND PROPOSAL FOR SETTLEMENT.totlmpersons
listed on said Service List by first class mail in a postage pre-paid envelope and depositing same with
the United States Postal Service located at 100 West Randolph Street, Chicago, Illinois 60601.
~
George D~~heophiIos
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
JUL 292005
STATE OF ILLINOIS
)
Pollution Control Board
v.
)
)
PCB 05-149
)
Enforcement
-
Air
TRUSERV CORPORATION, a Delaware,
)
corporation, d/b/a TRUE VALUE
)
MANUFACTURING COMPANY,
)
)
Respondent.
)
MOTION FOR
RELIEF FROM HEARING REQUIREMENT
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General ofthe State of Illinois, and hereby moves for relief from the hearing
requirement in this case pursuant to Section 31 (c)(2) of the Illinois Environmental Protection Act
(“Act”), 415 ILCS
5/31(c)(2)
(2002), and Section 103.300 of the Illinois Pollution Control Board
C’Board”) Procedural Rules, 35 Ill. Adm. Code 103.300. In support ofthis Motion, the Complainant
states as follows:
1.
Section 31(c)(2) of the Act allows the parties in certain enforcement cases to request
relief from the mandatory hearing requirementwhere the parties submit to the Board a Stipulation and
Proposal for Settlement. Section 31 (c)(2) provides as follows:
Notice; complaint; hearing.
***
(c)(2) Notwithstanding the provisions ofsubdivision (1)ofthis subsection (c), whenever
a complaint has been filed on behalfof the Agency or by the People of the State of
Illinois, the parties may file with the Board a stipulation and proposal for settlement
accompanied by a request for relief from the requirement of a hearing pursuant to
subdivision (1).Unless the Board, in its discretion, concludes that a hearing will be held,
the Board shall cause notice of the stipulation, proposal and request for relief to be
published and sent in the same manner as is required forhearing pursuant to subdivision
(1) of this subsection. The notice shall include a statement that any person may file a
written demand for hearingwithin 21 days after receiving the notice. Ifany person files
a timely written demand for hearing, the Board shall deny the request for relief from a
hearing and shall hold a hearing in accordance with the provisions ofsubdivision (1).
2.
Board Procedural Rule 103.300 provides, in relevant part, as follows (emphasis in
original):
Request for Relief from Hearing Requirement in State Enforcement Proceediri&
(a)
Whenevera complaint has beenfiled on behaIfofthe Agency or by the People ofthe
State of Illinois, the parties may file with the Board a proposed stipulation and
settlement accompanied by a request for relieffrom the requirement of a hearing
pursuant to Section 31 (c)(2) ofthe Act...
3.
On February 9,2005, the Complaint in this matter was filed with the Board.
4.
Subsequently, the parties to this action reached agreement on a Stipulation and Proposal
For Settlement, which is being filed with the Board concurrently with this motion. No hearing is
cuaently scheduled in this case.
WHEREFORE, the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General ofthe State offllinois, respectfully moves forrelieffrom the requirement
of a hearing pursuant to Section 31(c)(2) ofthe Act and Board Procedural Rule 103.30(1.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
ofthe State of illinois
BY:~
‘GEORC#~D.THEOPHILOS
Assistant Attorney General
Environmental Bureau/North
188 West Randolph Street, Suite 2001
Chicago, Illinois 60601
DATE: July 29, 2005
312-814-6986
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
JUL 292005
Complainant,
)
STATE OF ILLINOIS
)
Pollution Control Board
)
)
PCB 05-149
v.
)
Enforcement
—
Air
)
)
)
TRUE VALUE COMPANY, a Delaware,
)
corporation, 17k/a TRUSERV
)
CORPORATION,
)
)
Respondent.
)
STIPULATION AND PROPOSAL FOR SETTLEMENT
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General ofthe State offllinois, the Illinois Environmental Protection Agency (“Illinois EPA”), and
TRUE VALUE COMPANY, 17k/a TRUSERV CORPORATION (“Respondent”), have agreedto the
making ofthis Stipulation and Proposal for Settlement (“Stipulation”) and submit it to the illinois
Pollution Control Board (“Board”) for approval. The parties agree that the statement of facts
contained hereinrepresents a fair summary ofthe evidence and testimony which would be introduced
by the parties if a hearing were held. The parties further stipulate that this statement offacts is made
and agreedupon forpurposes ofsettlement only and that neither the fact that a party has entered into
this Stipulation, nor any ofthe facts stipulated herein, shall be introduced into evidence in any other
proceeding regarding the claims asserted in the Complaint except as otherwise provided herein. If
the Board approves and enters this Stipulation, Respondent agrees to be bound by the Stipulation and
Board Order and not to contest theirvalidity in any subsequent proceeding to implement or enforce
their terms.
I.
JURISDICTION
The Board hasjurisdiction ofthe subject matter herein and ofthe parties consentinghereto
pursuant to the illinois Environmental Protection Act (“Act”), 415 ILCS
5/1 et seq.
(2002).
II.
AUTHORIZATION
The undersigned representatives foreach party certif~’that they are fully authorized by the
party whom they represent to enter into the terms and conditions ofthis Stipulationantito legally
bind them to it.
III.
STATEMENT OF FACTS
A.
Parties
1.
On February 9, 2005 a Complaint was filed on behalfof the People ofthe State of
Illinois by Lisa Madigan, Attorney General ofthe State offllinois, on her own motion and upon the
request ofthe Illinois EPA, pursuant to Section 31 ofthe Act, 415 ILCS 5/31(2002), against the
Respondent.
2.
The Illinois EPA is an administrative agency ofthe State ofillinois, created pursuant
to Section 4 ofthe Act,
415
ILCS5/4 (2002).
3.
At all times relevant to the Complaint, Respondent was and is a Delaware corporation
that is authorized to transact business in the State ofIllinois.
B.
Facility Description
2
1.
At all times relevant to the Complaint, Respondent owned and operated a paint
manufacturing facility located at 823 West Blackhawk, Chicago, Cook County, Illinois, 60618
(“facility”).
2.
Emission sources at the facilityinclude storage tanks, mixing tanks, holdingtanks,
grinding mills, and thinning operations.
3.
The facilityemits volatile organicmaterial (“VOM”) from the emission sourcesat its
facility.
4.
At all times relevant to the Complaint, Respondent’s facility has been subject to
Federally Enforceable State Operating Permit (FESOP) No. 95020117 issued by illinois EPA.
FESOP No. 95020117 was issued February 1,2001 and expires on February 1,2006.
C.
Allegations of Non-Compliance
Complainant contends that the Respondent hasviolated the following provisions ofthe Act
and Board regulations:
Count I:
Failure to cover mixing and thinning tanks in violation of Section 218.624
ofthe Board AirPollution Regulations, 35111. Adm. Code 218.624, Section
9(a) ofthe Act, 415 ILCS 5/9(a)(2002), Section 9 ofRespondent’s Federally
Enforceable State Operating Permit (FESOP), and Section 9(b) ofthe Act,
415 ILCS 5/9(b)(2002).
Count II:
Failure to cover grinding mills in violation ofSection 218.625(a) and (b) of
the Board Air Pollution Regulations, Section 9(a) ofthe Act, Sections 10(a)
and 10(b) ofRespondent’s FESOP, and Section 9(b) ofthe Act
Count ifi:
Failureto maintain records about leaks and failure to repair leaks within 15
daysin violation ofSection 218.628 ofthe Board AirPollution Regulations,
Section 9(a) of the Act, Section 12 ofRespondent’s FESOP, and Section
9(b) ofthe Act.
3
Count IV:
Failure to properly cover orenclose equipment during cleaning in violation
of Section 218.630(a) ofthe Board Air Pollution Regulations, Section 9(a)
of the Act, Section 13(a) ofRespondent’s FESOP, and Section 9(b) of the
Act.
Count V:
Failure to submit accurate Annual Emissions Report (AER) for 2002 in
violation ofSection 201.302(a) ofthe Board AirPollution Regulations and
Section 9(a) ofthe Act, 415 ILCS 5/9(a)(2002).
D.
Admission of Violations
The Respondent neither admits nordenies the violations alleged in the Complaint filedinthis
matter and referenced herein.
E.
Compliance Activities to Date
Since the violations were notedin 2003, Respondent hascome into compliance with all ofthe
terms ofits FESOP, including, but not limited to, the following:
1.
Completely coveringthe mixing and thinning tanks at its facilitypursuant to Section 9
ofRespondent’s FESOP;
2.
Covering grinding mills pursuant to Sections 10(a) and 10(b) of Respondent’s
FESOP;
3.
Maintaining records about leaks and repairing leaks within 15 days pursuant to
Section 12 ofRespondent’s FESOP; and
4.
Properly covering orenclosing equipment during cleaning pursuant to Section 13(a)
ofRespondent’s FESOP.
4
F.
Value of Settlement and Resulting Benefits
Any economic gains that Respondent derived from noncompliance with the terms of its
FESOP, the Act, and the Board Regulations are reflected in the penalty payment. There is an
environmental benefit to the Respondent’s complete compliance with the terms ofits FESOP.
IV.
APPLICABILITY
This Stipulation shall apply to and be binding upon the Complainant and the Respondent, and
any officer, director, agent, or employee ofthe Respondent, as well as any successors or assigns of
the Respondent. The Respondent shall not raise as a defense to any enforcement action taken
pursuant to this Stipulation the failure of any of its officers, directors, agents, employees or
successors or assigns to take such action as shall be required to comply with the provisions ofthis
Stipulation.
V.
COMPLIANCE WITH OTHER LAWS AND
REGULATIONS
This Stipulation in no way affects the responsibilities ofthe Respondent to comply with any
other federal, state or local laws or regulations including, but not limited to, the Act and the Board
regulations, 35 ill. Adm. Code, Subtitles A through H.
VI.
IMPACT ON THE PUBLIC RESULTING FROM ALLEGED NON-
COMPLIANCE
Section 33(c) ofthe Act, 415 ILCS 5/33(c)(2002), provides as follows:
5
In making its orders and determinations, the Board shall take into consideration all
the facts and circumstances bearing upon the reasonableness of the emissions,
discharges, or deposits involved including, but not limited to:
1.
the characterand degree ofinjury to, or interference with the protection ofthe
health, general welfare and physical property ofthe people;
2.
the social and economic value ofthe pollution source;
3.
the suitability or unsuitability ofthe pollution source to the area in which it
is located, including the question ofpriority oflocation in the area
involved;
4.
the technical practicability and economic reasonableness of reducing or
eliminating the emissions, discharges or deposits resulting from such
pollution source; and
5.
any subsequent compliance.
In response to these factors, the parties state the following:
1.
The alleged recordkeeping violations interfered with the illinois EPA’s information
gathering responsibilities.
2.
There is social and economic benefit to the facility.
3.
Operation ofthe facility was suitable forthe area in which it is located.
4.
Respondent’s ability to follow the terms of its FESOP was both technically
practicable and economically reasonable.
5.
Respondent has subsequentlycomplied with the Act, the Board’sRegulations, and its
FESOP.
VII. CONSIDERATION OF SECTION 42(h) FACTORS
Section 42(h) ofthe Act, 415 ILCS 5/42(h)(2002), provides as follows:
6
In determining the appropriate civil penalty to be imposed under.
. .
this Section, the
Board is authorized to consider any matters ofrecord in mitigation oraggravation of
penalty, including but not limited to the following factors:
1.
the duration and gravity ofthe violation;
2.
the presence or absence ofdue diligence on the part of the respondent in
attempting to comply with requirements of this Act and regulations
thereunder or to secure relieftherefrom as provided by this Act;
3.
any economic benefits accrued by the respondent because of delay in
compliance with requirements, in which case the economic benefits shall be
determined by the lowest cost alternative for achieving compliance;
4.
the amount ofmonetary penalty which will serve to deter fUrther violations
by the respondent and to otherwise aid in enhancing voluntary compliance
with this Act by the respondent and other persons similarlysubjectto the Act;
5.
the number, proximity in time, and gravity of previously adjudicated
violations ofthis Act by the respondent;
6.
whether the respondent voluntarily self-disclosed, in accordance with
subsection i ofthis Section, the non-compliance to the Agency, and
7.
whether the respondent has agreed to undertake a “supplemental
environmental project,” which means an environmentallybeneficial project
that a respondent agrees to undertake in settlement ofan enforcement action
brought under this Act, but which the respondent is not otherwise legally
required to perform.
In response to these factors, the parties state as follows:
The
Respondent failed to follow the terms ofits FESOP. The violationibegan on or
around July 22, 2003, and were individually resolved at various times over the following five
months.
2.
Respondent was diligent in attempting to come back into compliance with the Act,
Board regulations and its FESOP, once Illinois EPA notified it ofits noncompliance.
7
3.
Respondentachieved an economic benefit by failing to comply with the terms ofthe
Act, the Board’s regulations, and its ownFESOP. The penalty paid is as great asor greater than the
economic benefit that Respondent achieved during the period ofnoncompliance.
4.
Complainant has determined, based upon the specific facts of this matter, that a
penalty ofthirty thousand dollars ($30,000.00) will serve to deter further violations and aid in future
voluntary compliance with the Act and Board regulations.
5.
To Complainant’s knowledge, Respondent hasno previously adjudicated violations of
the Act.
6.
Self-disclosure is not at issue in this matter.
7.
The settlement ofthis matter does not include a supplemental environmental project.
VIII. TERMS OF SETTLEMENT
A.
Penalty Payment
1.
The Respondent shall pay a civil penalty in the sum of thirty thousand dollars
($30,000.00) within thirty (30) days from the date the Board adopts and accepts this Stipulation..
The penalty described in this Stipulation shall be paid by certified check, money order orelectronic
finds transferpayable to the illinois EPA, designated to the illinois Environmental Protection Trust
Fund. A certified check or money order shall be submitted to:
/
Illinois Environmental Protection Agency
Fiscal Services Section
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
8
The name and number of the case and Respondent’s Federal Employer Identification Number
(FEIN), 36-2099896, shill appear on the check. If submitting an electronic funds transfer to the
illinois EPA, the electronic finds transfer shall be made in accordance with specific instructions to
be timely provided to Defendant prior to the date ofthe entry ofthe Consent Order.
A copy ofthe certifiedcheck, money order orrecord ofelectronic finds transfer and any transmittal
letter shall be sent to:
George Theophilos
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th
Floor
Chicago, illinois 60601
and
Maureen Wozniak
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
/
2.
Pursuant to Section 42(g) ofthe Act, 415 ILCS 5/42(g) (2002), interest shall accrue
on any payment not paid within the time period prescribed above at the maximum rate allowable
under Section 1003(a) of the Illinois Income Tax Act, 35 ILCS 5/1003 (2002). Interest on any
unpaid payment shall begin to accrue from the date the payment is due and continue toaccrue until
the date payment is received. When partial payment(s) are made, such partial payment shall be first
applied to any interest on unpaid payment then due and owing. All interest on payment owed shall
be paid by certified check, money order or electronic funds transfer, payable to the illinois EPA,
9
designated to the Illinois Environmental Protection Trust Fund and delivered to the address and in
the manner describedabove.
3.
For purposes ofpayment and collection, Respondent may be reached at the following
address:
Mary Gade orCynthia Faur
Sonnenschein, Nath & Rosenthal
8000 Sears Tower
233 5. Wacker Dr.
Chicago, IL 60606
4.
In the event ofdefault ofthis Section Vffl.A, the Complainant shall be entitled to all
available reliefincluding, but not limited to, reasonable costs ofcollection and reasonable attorney’s
fees.
B.
Compliance Plan
1.
For purposes ofthis Stipulation and Proposal for Settlement, True Value hasagreed to
provide, and the Illinois EPA has agreed to accept, a revised and signed Annual Emission Report for
calendar year 2002. The Parties agree that emissions shall becalculated based upon 7 dispersion
tanks, 17 thinning tanks, and 1 basket mill being noncompliant during the calendar year 2002 and
using emission estimates from USEPA’s Emission Inventory Improvement Program. This method of
calculating emissions is for purposes ofsettlement only, and True Value acknowledges that future
emissions shall be calculated in a fashion that is accepted by the Illinois EPA Bureau ofAir Permit
Section.
10
2.
The Annual Emission Report forcalendar year 2002 required by paragraph B. I. above
shall be provided to the illinois EPA within thirty (30) days from the date that the Board adopts and
accepts this Stipulation; and
3.
Respondent shall comply with the Act, the Board’s regulations, and the terms ofits
FESOP permit.
C.
Future Use
Notwithstanding any other language in this Stipulation to the contrary, and in consideration
of the mutual promises and conditions contained in this Stipulation, including the Release from
Liability contained in Section VIII.E, below, the Respondenthereby agrees that this Stipulation may
be used against the Respondent in any subsequent enforcement action orpermit proceeding asproof
ofa past adjudication ofviolation ofthe Act and the Board Regulations promulgatedthereunder for
all violations alleged in the Complaint in this matter, for purposes ofSection 39(a) and (i) and/or
42(h) of the Act, 415 ILCS
5/39(a)
and(i) and/or 5/42(h)(2002). Further, Respondent agrees to
waive any rights to contest, in any subsequent enforcement action or permit proceeding, any
allegations that these alleged violations were adjudicated.
IL
Cease and Desist
The Respondent shall cease and desist from future violations of the Act and Board
Regulations that were the subjectmatter ofthe Complaint as outlined in Section ffl.C (“Allegations
ofNon-Compliance”) ofthis Stipulation.
11
E.
Release from Liability
In consideration ofthe Respondent’s payment ofthe $30,000.00 penalty and any accrued
interest, completion of all activities required hereunder, commitment to Cease and Desist as
contained in Section Vffl.D and upon the Pollution Control Board’s acceptanceand approval ofthe
terms of this Stipulation and Proposal for Settlement, the Complainant releases, waives and
discharges the Respondent from any further liability or penalties for violations of the Act, Board
Regulations, and its FESOP that were the subject matter ofthe Complaint herein. The release set
forth above does not extend to any matters other than those expressly specified in Complainant’s
Complaint filed on February 9, 2005. The Complainant reserves, and this Stipulation is without
prejudice to, all rights ofthe State ofIllinois againstthe Respondent with respectto all othermatters,
including but not limited to, the following:
a.
criminal liability;
/
b.
liability for future violation of state, federal, local, and common laws and/or
regulations;
c.
liability for natural resources damage arising out ofthe alleged violations; and
d.
liability or claims based on the Respondent’s failure to satis& the requirements ofthis
Stipulation.
Nothing in this Stipulation is intended as a waiver, discharge, release, or covenant not to sue
for any claim orcause ofaction, administrative orjudicial, civil orcriminal, past oriuiture,in/lawor
in equity, which the State ofillinois or the Illinois EPA may have against any person, as defined by
Section 3.315 ofthe Act, 415 ILCS
5/3.315,
or entity other than the Respondent.
12
F.
Right of Entry
In addition to any other authority, the Illinois EPA, its employees and representatives,and the
Attorney General, her agents and representatives, shall have the right of entry into and -upon the
Respondent’s facilitywhich is the subject ofthis Stipulation, at all reasonable times forthe purposes
of carrying out inspections. In conducting such inspections, the Illinois EPA, its employees and
representatives, and the Attorney General, her employees and representatives mayiakephotographs,
samples, and collect information, as they deem necessary.
G.
Correspondence, Reports and Other Documents
Any and all coffespondence, reports and any other documents requiredunder this Stipulation,
except for payments pursuant to Sections Vffl.A (“Penalty Payment”) of this Stipulation shall be
submitted as follows:
As to the Complainant
George Theophilos
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th
Floor
Chicago, illinois 60601
and
Maureen Wozniak
Assistant Counsel
Illinois EPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
13
As to the Respondent
Mary Gade or Cynthia Faur
Sonnenschein, Nath & Rosenthal
8000 Sears Tower
233S. WackerDr.
Chicago, IL 60606
H.
Modification of Stipulation
The parties may, by mutual written consent, agree to extend any compliance dates or modii5’
the terms ofthis Stipulation. A request for any modification shall be made in writing and submitted
to the contact persons identified in Section Vffl.G. Any such request shall be made by separate
document, and shall not be submitted within any other report or submittal required by this
Stipulation. Any such agreed modification shall be in writing, signed by authorized representatives
ofeach party, and then accompany ajoint motion to the Illinois Pollution Control Board seeking a
modification ofthe prior order approving and accepting the Stipulation to approve and acceptthe
Stipulation as amended.
I.
Enforcement of Board Order
1.
Upon the entry of the Board’s Order approving and accepting this Stipulation and
Proposal for Settlement, that Order is a binding and enforceable order of the Illinois Pollution
Control Board and may be enforced as such through any and all available means.
2.
Respondent agrees that notice of any subsequent proceeding to enforce the Board
Order approving and accepting this Stipulation and Proposal for Settlement may be made by mail
and waives any requirement ofservice ofprocess.
14
3.
The parties agree that, ifthe Board does not approve and accept this Stipulation and
Proposal for Settlement, then neither party is bound by the terms herein.
4.
It is the intent of the Complainant and Respondent that the provisions of this
Stipulation and Proposal for Settlement and any Board Order accepting and approving such shall be
severable, and should any provision be declared by a court of competent jurisdiction to be
inconsistent with state or federal law, and therefore unenforceable, the remaining clauses shall
remain in full force and effect.
WHEREFORE, Complainant and Respondent request that the Board adopt
and accept the
foregoing Stipulation and Proposal for Settlement as written.
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General
State ofIllinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
BY:
____________
DATE~__________
ROSEMAIUIE CAZEAU, CSef
Environmental Bureau
Assistant Attorney General
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
BY:
DATE
:ji’4/(24C~
Acting ChiefLegal Counsel
15
TRUE VALUE
/
/
BY:
____________
_________
MICHAEL HAINING
Senior Vice President,
gistics and
Manufacturing
/
True Value Manufacturing Company
16
