Lisa Madigan
API'ORNEY GENERA .
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Center, Ste . 11-500
100 West Randolph
Chicago, Illinois 60601
Dear Clerk Gunn
:
Enclosed for filing please find the original and ten copies of a Notice of Filing, Motion for
Relief from Hearing Requirement and Stipulation and Proposal for Settlement in regard to the
above-captioned matter. Please file the originals and return file-stamped copies to me in the
enclosed, self-addressed envelope
.
Thank you for your cooperation and consideration
.
Very truly yours,
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
May 3, 2006
Re :
People v. Passavant
Area
Hospital
PCB No . 03-183
/?
N4,
owbo
r
ennifer onkowski
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
JB/pp
Enclosures
500 South Second Street, Springfield, Illinois 62706
•
(217) 78Z-1090
•
TTY, (217) 785-2771
•
Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601
•
(312) 814-3000
•
TTY. (312) 814-3374
•
Fax: (312) 814-3806
1001 East Main, Carbondale, Illinois 62901
•
(618) 529-6400
•
1 FY: (618) 529-6403
•
Fax: (618) 529-6416
RECEIVED
MAY - 4 2006
Pollut
on
Control Board
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAY - 4 2006
PEOPLE OF THE STATE OF ILLINOIS,
)
STATE OF ILLINOIS
Pollution Control Board
Complainant,
)
vs .
)
PCB No. 03-183
(Enforcement
- Air)
PASSAVANT AREA HOSPITAL,
)
an Illinois not-for-profit corporation,
)
Respondent .
)
NOTICE OF FILING
To
:
Babette P . Salus
Schwing & Salus, P.C .
1100 South Fifth Street
Springfield, IL 62703
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a MOTION FOR RELIEF FROM HEARING REQUIREMENT
and STIPULATION AND PROPOSAL FOR SETTLEMENT, a copy of which is 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 Enforcement/Asbestos
Litigati n Division
BY :
14
AJnufV
JENNI
R BONKOWSKI
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: May 3, 2006
CERTIFICATE OF SERVICE
I hereby certify that I did on May 3, 2006, 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
following instruments entitled NOTICE OF FILING, MOTION FOR RELIEF FROM HEARING
REQUIREMENT and STIPULATION AND PROPOSAL FOR SETTLEMENT :
To
:
Babette P. Salus
Schwing & Salus, P.C .
1100 South Fifth Street
Springfield, IL 62703
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
James R. Thompson 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 :
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Springfield, IL 62794
/prat ~Cl,
LIbC )
NNIFER 3ONKOWSKI
sistant Attorney General
This filing is submitted on recycled paper
.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
vs
.
)
PCB No. 03-183
(Enforcement - Air)
PASSAVANT AREA HOSPITAL,
)
an Illinois not-for-profit corporation,
)
Respondent .
)
MOTION FOR RELIEF FROM HEARING REQUIREMENT
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois, and pursuant to Section 31(c)(2) of the
Illinois Environmental Protection Act ("Act"), 415 ILCS 5/31(c)(2) (2004), moves that the Illinois
Pollution Control Board grant the parties in the above-captioned matter relief from the hearing
requirement imposed by Section 31(c)(1) of the Act, 415 ILCS 5/31(c)(1) (2004)
. In support of
this motion, Complainant states as follows
:
1
.
The parties have reached agreement on all outstanding issues in this matter
.
2
.
This agreement is presented to the Board in a Stipulation and Proposal for
Settlement, filed contemporaneously with this motion
.
3
.
All parties agree that a hearing on the Stipulation and Proposal for Settlement is
not necessary, and respectfully request relief from such a hearing as allowed by Section
31(c)(2) of the Act, 415 ILCS 5/31(c)(2) (2004)
.
1
RECEIVED
MAY - 4 2006
Pollution Control Boarrd
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS, hereby requests
that the Board grant this motion for relief from the hearing requirement set forth in Section
31(c)(1) of the Act, 415 ILCS 5/31(c)(1) (2004)
.
Respectfully submitted,
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: May 3, 2006
2
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
ATTORNEY GENERAL
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigatio Division
BY:
/ll4 ~v
JENNI ER BONKOWSKI
Enviro mental Bureau
Assistant Attorney General
t
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
REC
EDVI
ED
PEOPLE OF THE STATE OF ILLINOIS,
)
>
MAY - 4 2006
Complainant,
)
STATE OF ILLINOIS
Pollution Control Board
PCB No. 03-183
V .
)
(Enforcement - Air)
PASSAVANT AREA HOSPITAL, an Illinois
)
not-for-profit corporation,
)
Respondent .
STIPULATION AND PROPOSAL FOR SETTLEMENT
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General of the State of Illinois, the Illinois Environmental Protection Agency ("Illinois EPA"), and
PASSAVANT AREA HOSPITAL ("Respondent" or "Passavant"), have agreed to the making of
this 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
herein represents a fair summary of the evidence and testimony that would be introduced by the
parties if a hearing were held . The parties further stipulate that this statement of facts is made
and agreed upon for purposes of settlement only and that neither the fact that a party has
entered into this Stipulation, nor any of the 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 their validity in any
subsequent proceeding to implement or enforce their terms
.
1
I .
JURISDICTION
The Board has jurisdiction of the subject matter herein and of the parties consenting
hereto pursuant to the Illinois Environmental Protection Act ("Act"), 415 ILCS 5/1 et seq. (2002) .
II .
AUTHORIZATION
The undersigned representatives for each party certify that they are fully authorized by
the party whom they represent to enter into the terms and conditions of this Stipulation and to
legally bind them to it
.
III
.
STATEMENT OF FACTS
A .
Parties
1
.
On April 8, 2003, the Complainant filed a Complaint on behalf of the People of the
State of Illinois by Lisa Madigan, Attorney General of the State of Illinois, on her own motion and
upon the request of the Illinois EPA, pursuant to Section 31 of the Act, 415 ILCS 5/31(2002),
against the Respondent. On November 20, 2003, the Complainant filed a Second Supplemental
and Amended Complaint on behalf of the People of the State of Illinois by Lisa Madigan,
Attorney General of the State of Illinois
.
2 .
The Illinois EPA is an administrative agency of the
State of Illinois, created pursuant to Section 4 of the Act, 415 ILCS 5/4 (2002)
.
3 .
At all times relevant to the Complaint, Respondent was and is an Illinois not-for-
profit corporation in good standing and authorized to transact business in the State of Illinois .
2
B
.
Site Description
1
.
At all times relevant to the Complaint, Respondent owned and operated a
medium hospital/medical/infectious waste incinerator (hereinafter "HMIWI") at its hospital
located at
1600
West Walnut Street, Morgan County, Illinois
.
2
.
On September
5, 2001,
the Illinois EPA inspected Passavant to determine
compliance with the Act, Clean Air Act Permit Program Permit ("CAAPP") permit no
.
00090039
and
35 III
.
Adm. Code Part
229
("HMIWI regulations")
3 .
On or about September
25
and
26, 2001,
Passavant conducted an annual
performance test to determine compliance with the Act, its CAAPP permit and the HMIWI
regulations
.
C
.
Allegations of Non-Compliance
Complainant contends that the Respondent has violated the following provisions of the
Act and Board regulations
:
Count I
:
Air Pollution and Permit Violations, in violation of Sections 9(a) and
39.5(6)(a) of the Act, 415 ILCS 5/9(a) and 39.5(6)(a) (2002), and 35 III
.
Adm. Code 201.141 and 35 III. Adm. Code 229.125(b) and CAAPP
permit condition 7 .1 .8 .
Count II
:
Operating Violations, in violation of Sections 9(a) and 39 .5(6)(a) of
the Act, 415 ILCS 5/9(a) and 39.5(6)(a) (2002), and 35 III. Adm. Code
229.146, 229 .148, 229.152(a), 229.166(a), 229.170(a) and CAAPP
permit conditions 7.1 .6(a), 7.1.9(g), 7.1 .9(i), and 7.1.10(a) and (d) .
Count Ill
:
Record-keeping Violations, in violation of Sections 9(a) and
39.5(6)(a) of the Act, 415 ILCS 5/9(a) and 39.5(6)(a) (2002), and 35 III .
Adm. Code 229.182(a)(3), (a)(7), and (g) and CAAPP permit
conditions 5.6.1, 5 .6 .2(a), 7.1.10(d)(iv), 7 .1 .11(b), and 7 .1 .11(a)(iii) .
Count IV :
Annual Compliance Certification Violations, in violation of Section
39.5(6)(a) of the Act, 415 ILCS 5/39.5(6)(a) (2002), and CAAPP permit
condition 9.8 .
3
Count V
:
Annual Emission Report Violations, in violation of Sections 9(a) and
39.5(6)(a) of the Act, 415 ILCS 5/9(a) and 39 .5(6)(a) (2002), and 35 III .
Adm. Code 254.203 and 254.204 and CAAPP permit condition 9 .7
.
Count VI
:
Construction Permit Violations, in violation of Section 9(b) of the
Act, 415 ILCS 5/9(b) and 35 III . Adm. Code 201.142
.
D
.
Admission of Violations
The Respondent admits to the violations alleged in the Complaint filed in this matter and
referenced within Section III .C herein
.
E .
Compliance Activities to Date
On November 20, 2001, at the request of the Illinois EPA, Passavant ceased operation
of its HMIWI. Subsequently, Passavant attempted to comply with the HMIWI regulations by
installing and modifying a control device, but was never successful . On December 20, 2004, the
Passavant Board of Directors signed a Resolution to Discontinue Operation of Hospital
Incinerator, and on February 8, 2005, Passavant submitted a letter to the Illinois EPA seeking
withdrawal of its CAAPP permit
.
F .
Value of Settlement and Resulting Benefits
Passavant's commitment to permanently discontinue operation of the HMIWI will help ensure
that the hospital's medical waste disposal does not pose any unacceptable risks to human
health or the environment
.
IV .
APPLICABILITY
This Stipulation shall apply to and be binding upon the Complainant and the Respondent,
and any officer, director, agent, or employee of the Respondent, as well as any successors or
4
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 of this Stipulation
.
No change in ownership, corporate status or operator of the facility shall in any way alter
the responsibilities of the Respondent under this Stipulation and Proposal for Settlement . In the
event of any conveyance of title, easement or other interest in the facility, the Respondent shall
continue to be bound by and remain liable for performance of all obligations under this
Stipulation
.
In the event that the Respondent proposes to sell or transfer any real property or
operations subject to any Order accepting and adopting the terms of this Stipulation and
Proposal for Settlement, including the incinerator at issue in this matter, the Respondent shall
notify the Complainant 30 days prior to the conveyance of title, ownership or other interest,
including a leasehold interest in the facility or a portion thereof . The Respondent shall make the
prospective purchaser or successor's compliance with any Order accepting and adopting the
terms of this Stipulation a condition of any such sale or transfer and shall provide a copy of this
Stipulation and any Order accepting and adopting the terms of this Stipulation to any such
successor in interest. This provision does not relieve the Respondent from compliance with any
regulatory requirement regarding notice and transfer of applicable facility permits
.
V .
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Stipulation in no way affects the responsibilities of the 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 III. Adm. Code, Subtitles A through H
.
5
VI .
IMPACT ON THE PUBLIC RESULTING FROM ALLEGED NON-COMPLIANCE
Section 33(c) of the Act, 415 ILCS 5/33(c)(2002), provides as follows
:
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 character and degree of injury to, or interference with the protection of
the health, general welfare and physical property of the people
;
2
.
the social and economic value of the pollution source
;
3
.
the suitability or unsuitability of the pollution source to the area in which it
is located, including the question of priority of location 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
.
Complainant contends that the injury to, or interference with, the protection of the
health, general welfare, and physical property of the People would be characterized as air
pollution. However, Passavant abated the threat to human health and the environment by
agreeing to cease operation of the HMIWI once aware of emissions exceedances and by
agreeing to permanently cease operation of its HMIWI
.
2 .
The parties agree that Respondent's not-for-profit hospital is of social and
economic benefit to the area
.
3
.
Respondent's hospital is suitably located in Jacksonsville, Morgan County,
Illinois
.
4
.
The parties agree that complying with the Act and regulations is technically
practicable and economically reasonable ; and
6
5 .
Respondent has subsequently complied with the Act and the Board Regulations
by permanently ceasing operation of its HMIWI .
VII
.
CONSIDERATION OF SECTION 42(h) FACTORS
Section 42(h) of the Act, 415 ILLS 5142(h)(2002), provides as follows
:
In determining the appropriate civil penalty to be imposed under
.
.
. this Section,
the Board is authorized to consider any matters of record in mitigation or
aggravation of penalty, including but not limited to the following factors
:
1
.
the duration and gravity of the violation
;
2
.
the presence or absence of due diligence on the part of the respondent in
attempting to comply with requirements of this Act and regulations
thereunder or to secure relief therefrom 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 of monetary 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 similarly subject to the
Act ;
5 .
the number, proximity in time, and gravity of previously adjudicated
violations of this Act by the respondent
;
6
.
whether the respondent voluntarily self-disclosed, in accordance with
subsection i of this Section, the non-compliance to the Agency ; and
7
.
whether the respondent has agreed to undertake a "supplemental
environmental project," which means an environmentally beneficial project
that a respondent agrees to undertake in settlement of an 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
:
1
.
From at least September 25, 2001, until November 20, 2001, Passavant operated
in non-compliance with the emission limitations for at least PM, HCI, Cd, and dioxins/furans
.
Passavant also operated in non-compliance with the emissions limitations on the limited days
7
that it conducted testing from November 2001
until the present. From at least April 2001 until
September 26, 2001, Passavant's HMIWI operators were not certified . Passavant's HMIWI
operators were also required to maintain their certification in the years 2002, 2003, and 2004
.
From at least September 15, 2001, until November 20, 2001, Passavant failed to successfully
complete the HMIWI annual compliance test
(i .e ., demonstrate compliance with the emission
limitations). Passavant also failed to complete an annual performance test in 2002, 2003, and
2004. From at least April 18, 2000, (date of initial performance test) until at least August 27,
2001, (date CEM was operational and calibrated) Passavant failed to continuously monitor CO
concentrations and maintain proper CEM calibration records
.
2
.
Since learning of the Illinois EPA's concerns, Passavant has been reasonably
diligent in addressing the violations alleged in the Complaint
.
Specifically, at the request of the
Illinois EPA, Passavant ceased operation of its HMIWI in November 2001 and thereafter
operated on limited dates solely for purposes of demonstrating compliance via compliance
testing. On December 20, 2004, the Passavant Board of Directors signed a Resolution to
Discontinue Operation of Hospital Incinerator .
3 .
Passavant expended substantial financial resources (in excess of $416,000 .00)
in an attempt to properly control emissions from its HMIWI
.
Ultimately, Passavant decided to
permanently cease operation of the HMIWI
.
4 .
Complainant has determined that a penalty is not warranted
is this matter, as
Passavant is an Illinois not-for-profit health care provider. In addition, Passavant has agreed to
permanently cease operation of its HMIWI
.
5 .
To Complainant's knowledge, Respondent has no previously adjudicated
violations of the Act
.
6 .
Passavant did not voluntarily self-disclose the non-compliance to the Illinois EPA
.
8
7
.
The settlement of this matter does not include a supplemental environmental
project .
VIII .
TERMS OF SETTLEMENT
A .
Compliance Plan
Passavant has committed to permanently cease operation of its HMIWI. To that end,
Passavant shall continue to take necessary actions to dispose of all hospital/medical/infectious
waste. Passavant shall remove the HMIWI or render it inoperable
.
B .
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 .F, below, the Respondent hereby agrees that this
Stipulation may be used against the Respondent in any subsequent enforcement action or
permit proceeding as proof of a past adjudication of violation of the Act and the Board
Regulations promulgated thereunder for all violations alleged in the Complaint in this matter, for
purposes of Section 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
.
9
C .
Cease and Desist
The Respondent shall cease and desist from future violations of the Act and Board
Regulations that were the subject matter of the Complaint as outlined in Section III .C
("Allegations of Non-Compliance") of this Stipulation
.
D .
Release from Liability
In consideration of the Respondent's completion of all activities required hereunder, to
Cease and Desist as contained in Section VIII.C and upon the Pollution Control Board's
acceptance and approval of the 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 and Board Regulations that were the subject matter of the
Second Supplemental and Amended Complaint herein, filed on November 20, 2003. In addition
to matters expressly specified in Complainant's Second Supplemental and Amended Complaint,
the release set forth above also extends to any matters involving the incinerator at issue herein,
through the date of the Board's entry of this Stipulation . The Complainant reserves, and this
Stipulation is without prejudice to, all rights of the State of Illinois against the Respondent with
respect to all other matters, 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 of the alleged violations ; and
d .
liability or claims based on the Respondent's failure to satisfy the requirements of
this Stipulation
.
Nothing in this Stipulation is intended as a waiver, discharge, release, or covenant not to
sue for any claim or cause of action, administrative or judicial, civil or criminal, past or future, in
10
law or in equity, which the State of Illinois or the Illinois EPA may have against any person, as
defined by Section 3 .315 of the Act, 415 ILCS 5/3 .315, or entity other than the Respondent
.
E
.
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 facility which is the subject of this Stipulation, at all reasonable times for
the purposes of carrying out inspections
.
In conducting such inspections, the Illinois EPA, its
employees and representatives, and the Attorney General, her employees and representatives
may take photographs, samples, and collect information, as they deem necessary
.
F
.
Correspondence, Reports and Other Documents
Any and all correspondence, reports and any other documents
required under this
Stipulation, except for payments pursuant to Sections
VIII.A ("Penalty Payment") and C
("Stipulated Penalties") of this Stipulation shall be submitted as follows
:
As to the Complainant
.
Jennifer Bonkowski
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62702
Chris Pressnall
Assistant Counsel
Illinois EPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
1 1
Babette P. Salus
Schwing & Salus, P.C
.
1100 S . Fifth St .
Springfield, Illinois 62703
G .
Modification of Stipulation
The parties may, by mutual written consent, agree to extend any compliance dates or
modify the terms of this Stipulation . A request for any modification shall be made in writing and
submitted to the contact persons identified in Section
VIII .F. 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 of each party, and then accompany a joint motion to the Illinois Pollution Control
Board seeking a modification of the prior order approving and accepting the Stipulation to
approve and accept the Stipulation as amended
.
H .
Enforcement of Board Order
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 of service of process
.
3
.
The parties agree that, if the Board does not approve and
accept this Stipulation
and Proposal for Settlement, then neither party is bound by the terms herein
.
As to the Respondent
1 2
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
.
1 3
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 of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
BY: - DATE
: ,
C
I
/~.70
THOMAS DAVIS, Chief
Environmental Bureau
Assistant Attorney General
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
BY :
RO
Chief Legal Counsel
PASSAVANT AREA HOSPITAL
BY :
Cfta
Name :
Babet.te P
. Sales
Title
: Counsel for Passavant Area Hospital
14
DATE
:
"I'2q(U t{
DATE
:
J /
(J,
)w6
