BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
AMERICAN BOTTOM CONSERVANCY, )
Petitioner,
)
v .
) PCB No . 2006-171
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY, and UNITED
)
STATES STEEL CORPORATION -
)
GRANITE CITY WORKS,
)
Respondents
.
)
NOTICE OF FILING
To
:
Maxine I . Lipeles
Edward Heisel
Interdisciplinary Environmental Clinic
Interdisciplinary Environmental Clinic
Washington University School of Law
Washington University School of Law
One Brookings Drive - Campus Box 1120
One Brookings Drive - Campus Box 1120
St. Louis, MO 63130-4899
St. Louis, MO 63130-4899
Sanjay K. Sofat
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-92760
PLEASE TAKE NOTICE that on July 28, 2006 there was filed with the Clerk of the
Illinois Pollution Control Board of the State of Illinois an original, executed copy of United
States Steel Corporation's Opposition to Petitioner's Motion to Supplement the Record
.
Dated: July 28, 2006
Respectfully submitted,
U.S . Steel Corporation - Granite City Works
By :
Ql -\
One of Its At
eys
Erika K. Powers, Esq
.
Carolyn S . Hesse, Esq
.
David T. Ballard, Esq
.
Barnes & Thornburg LLP
One North Wacker Drive - Suite 4400
Chicago, Illinois 60606
(312) 357-1313
IThis filing submitted on recycled paper as defined in 35 111 . Adm. Code 101 .202/
RECEIVED
CLERK'S OFFICE
JUL 2 8 2006
STATE OF ILLINOIS
Pollution Control Board
CERTIFICATE OF SERVICE
I, on oath state that I have served the attached United States Steel Corporation's
Opposition to Petitioner's Motion to Supplement the Record by placing a copy in an envelope
addressed to :
Maxine I . Lipeles
Edward Heisel
Interdisciplinary Environmental Clinic
Interdisciplinary Environmental Clinic
Washington University School of Law
Washington University School of Law
One Brookings Drive
- Campus Box 1120
One Brookings Drive
- Campus Box
St. Louis, MO 63130-4899
1120
St. Louis, MO 63130-4899
Sanjay Sofat
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
from One North Wacker Drive, Suite 4400, Chicago, Illinois, before the hour of 5 :00 p.m ., on
this 28° Day of July, 2006
.
Carol
. Hesse
348373v1
(This riling submitted on recycled paper as defined in 35111
.Adm . Code 101.202
2
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
AMERICAN BOTTOM CONSERVANCY, )
Petitioner,
)
v .
) PCB No. 2006-171
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY, and UNITED
)
STATES STEEL CORPORATION -
)
GRANITE CITY WORKS,
)
Respondents .
)
RECEIVED
CLERK'S OFFICE
JUL 2 8 2006
STATE OF ILLINOIS
Pollution Control Board
UNITED STATES STEEL CORPORATION'S OPPOSITION
TO PETITIONER'S MOTION TO SUPPLEMENT THE RECORD
Respondent, United States Steel Corporation - Granite City Works ("U . S. Steel"), by its
attorneys, files its Opposition to Petitioner's Motion to Supplement the Record . In support of its
Opposition, U . S. Steel states as follows
:
U . S. Steel objects to supplementing the record with any of the documents attached to
Petitioner's Motion to Supplement the Record because such documents were not properly before
the Illinois Environmental Protection Agency ("IEPA") for its issuance of the NPDES Permit to
U. S. Steel for its Granite City Works facility on March 31, 2006 . In addition, U . S . Steel joins
IEPA's Motion to Amend Agency Record to the extent IEPA's Motion opposes supplementing
the record with the documents attached as Exhibits A and B to the Petitioner's Motion
.
Accordingly, U. S. Steel adopts herein the reasoning of IEPA's objection to supplementing the
record with Exhibits A and B
.
This filing submitted on recycled paper as defined in 35111 . Adm. Code 101.202
WHEREFORE, U. S. Steel requests that the Board deny Petitioner's Motion to
Supplement the Record and grant all other relief that the Board deems fair and just
.
Dated: July 28, 2006
Respectfully submitted,
U.S . Steel Corporation
- Granite City Works
By
:
C
s
-\ N`-aja
'~-
One of Its Attom s
Erika K. Powers, Esq .
Carolyn S . Hesse, Esq
.
David T. Ballard, Esq
.
Barnes & Thornburg LLP
One North Wacker Drive - Suite 4400
Chicago, Illinois 60606
(312) 357-1313
CHDS01 DTB 347159v2
This filing submitted on recycled paper as defined in 35 111 . Adm . Code 101.2021
2
