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RECEIVEDD
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AUG 1 0 2006
1021 NORTH GRAND AVENUE EAST, P.O
. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276
- (
217) 782-
7
JAMES R
. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601 -(312) 814-
Ltion
ATE OF
Control
ILLINOIS
Board
ROD R . BLAGOIEVICH, GOVERNOR
DOUGLAS
P . SCOTT, DIRECTOR
'
(217) 782-9817
TDD : (217) 782-9143
August 8, 2006
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
. Matthew P . Bailey
IEPA File No
. 143-06-AC
; 1918085003-Wayne County
Dear Clerk Gunn :
Enclosed for filing with the Illinois Pollution Control Board, please find the original and nine
true and correct copies of the Administrative Citation 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 of entering a default judgment in the event the Respondent(s) fails or elects not to file a
petition for review contesting the Administrative Citation
.
If you have any questions or concerns, please do not hesitate to contact me at the number above
.
Thank you for your cooperation
.
Miche le M
. Ryan
Assistant 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 or 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, Collinsville, IL 62234 -(618) 346-5120
MARION-2309 W
. Main St
., Suite 116, Marion, IL 62959-(618) 993-7200
PRINTED oN RECYCLED PAPER
A
L 61
C)"'I

 
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
V .
MATTHEW P . BAILEY,
Respondent.
To :
Matthew P. Bailey
401 S . 15`h
Street
P.O. Box 34
Lawrenceville, IL 62439
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois the following instrument(s) entitled ADMINISTRATIVE
CITATION, AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST
.
Respectfully submitted,
L a.L A A~1001
Michelle M . Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P .O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated : August 8, 2006
RECEIVED
CLERICS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AUG 1 0 2006
ADMINISTRATIVE CITATION
STATE OF ILLINOIS
Pollution Control Board
)
AC
61
.01
(IEPA No . 143-06-AC)
NOTICE OF FILING
THIS FILING SUBMITTED ON RECYCLED PAPER

 
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ADMINISTRATIVE CITATION
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
j
Complainant,
)
AC U1
v.
)
(IEPA No . 143-06-AC)
MATTHEW P . BAILEY,
)
Respondent
.
)
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 (2004) .
FACTS
1
. That Matthew P . Bailey ("Respondent") is the present owner of a facility located
approximately 200 yards west of US Highway 45 and approximately one mile south of the City of
Fairfield, Wayne County, Illinois
. The property is commonly known to the Illinois Environmental
Protection Agency as Bamhill/Bailey, Fred .
2.
That said facility is an open dump operating without an Illinois Environmental
Protection Agency Operating Permit and is designated with Site Code No
. 1918085003
.
3.
That Respondent has owned said facility at all times pertinent hereto .
4.
That on July 19, 2006, Jay Winters and Garrison Gross of the Illinois Environmental
Protection Agency's Marion Regional Office inspected the above-described facility
. A copy of their
inspection report setting forth the results of said inspection is attached hereto and made a part
hereof.
RECEIVED
AUG 10 2006
Pollution
STATE OF
Control
ILLINOISBoard

 
VIOLATIONS
Based upon direct observations made by Jay Winters and Garrison Gross during the course
of the June 7, 2006 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)
(7)
That Respondent caused or allowed the open dumping of waste in a manner
resulting in litter, a violation of Section 21(p)(1) of the Act, 415 ILCS 5/21(p)(1)
(2004) .
That Respondent caused or allowed the open dumping of waste in a manner
resulting in deposition of general construction or demolition debris or clean
construction or demolition debris, a violation of Section 21(p)(7) of the Act, 415 ILCS
5/21 (p)(7) (2004).
CIVIL PENALTY
Pursuant to Section 42(b)(4-5) of the Act, 415 ILCS 5/42(b)(4-5) (2004), 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 penalty specified above shall be
due and payable no later than
September 30, 2006, unless otherwise provided by order of the
Illinois Pollution Control Board .
If Respondent elects to contest this Administrative Citation by petitioning the Illinois Pollution
Control Board in accordance with Section 31
.1 of the Act, 415 ILCS 5/31
.1 (2004), and if the Illinois
Pollution Control Board issues a finding of violation as alleged herein, after an adjudicatory hearing,
2

 
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) (2004), if Respondent fails
to petition or elects not to 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 .
If any 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 Respondent from 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 .
3

 
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 (2004)
. 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
.
Douglas P
.
ott, Director
..r-c.c
Illinois Environmental Protection gency
Prepared by :
Susan E
. Santarelli, 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
4
Date:
S
1gb6

 
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
V .
MATTHEW P . BAILEY,
Respondent .
RER
EoVIEID
REMITTANCE FORM
AUG 1 0 2006
Pollution OControl Board
j
AC
(IEPA No
. 143-06-AC)
FACILITY:
Bamhill/Bailey, Fred
SITE CODE NO . :
1918085003
COUNTY:
Wayne
CIVIL PENALTY:
$3,000.00
DATE OF INSPECTION :
July 19, 2006
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 .
5

 
Location/Site Name :
Barn hill/Bailey, Fred
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Open Dump Inspection Checklist
County
:
Wayne
LPC#
:
1918085003
Region : 7 - Marion
Date:
07/19/2006 Time: From 11
:23 AM To 11 :34 AM Previous Inspection Date: 05/12/2006
Inspector(s) :
Jay Winters and Garrison Gross
Weather: 97 degrees/sunny
No
. of Photos Taken : #
9
Est. Amt
. of Waste : 200
yds3 Samples Taken : Yes #
No
Interviewed :
Latitude : 38.34592
Longitude : -88.36177
Collection Point Description : Site Entrance -
(Example : Lat . : 41 .26493
Long . : -89 .38294)
Collection Method : GPS -
Responsible Party
Mailing Address(es)
and Phone Number(s) :
Bailey Wholesale
Attn
: Matthew P . Bailey
401 S. 15th Street
P .O. Box 34
Lawrenceville, IL 62439
Complaint # : C-03-031-M
Revised 10/5/2005
(Open Dump - 1)
SECTION
DESCRIPTION
1
VIOL
1 . 9(a)
CAUSE, THREATEN OR
ALLOW AIR POLLUTION IN ILLINOIS
12.
9(c)
CAUSE OR ALLOW OPEN BURNING
3. 12(a)
CAUSE, THREATEN OR ALLOW WATER POLLUTION IN ILLINOIS
4. 12(d)
CREATE A WATER POLLUTION HAZARD
5.
21 (a)
CAUSE OR ALLOW OPEN DUMPING
a
6. 21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION :
(1)
Without a Permit
03
(2)
In Violation of Any Regulations or Standards Adopted by the Board
a
DISPOSE, TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
re
7 . 21 e
,
_
, • ,
s A
, •
u
0
: u L
8 . 21
CAUSE OR ALLOW THE OPEN DUMPING OF ANY WASTE IN A
MANNER WHICH RESULTS
, ..,
1 \
. : ,
11
(1)
Litter
~~
(2)
Scavenging
(3)
Open Burning
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
(6)
Standing or Flowing Liquid Discharge from the Dump Site

 
LPC #
1918085003
Inspection Date :
07/19/2006
Deposition of General Construction or Demolition Debris ; or Clean Construction or
(7) Demolition
Debris
55(a)
NO PERSON SHALL :
(1) Cause or Allow Open Dumpinq of Any Used or Waste Tire
2
Cause or Allow O•en Burnin of An Used or Waste Tire
APPARENT VIOLATION OF : (0) PCB; (p) CIRCUIT COURT
14.
CASE NUMBER :
ORDER ENTERED ON :
15. OTHER :
E
El7
Informational Notes
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 Act shall be enforceable either
by administrative citation under Section 31 .1 of the Act or by complaint under Section 31 of the Act .
5 . This inspection was conducted in accordance with Sections 4(c) and 4(d) of the [Illinois] Environmental Protection Act
:
415 II-CS 5/4(c) and (d) .
6.
Items marked with an "NE" were not evaluated at the time of this inspection .
Revised 10/5/2005
(Open Dump - 2)

 
Illinois Environmental Protection Agency
1918085003 -- Wayne County
Bureau of Land
Barnhill/Bailey, Fred
Division of Land Pollution Control
FOS File
Inspection Date : 07/19/2006
Inspector(s) : Jay Winters and Garrison Gross
GPS Coordinates : 38 .34592°N, -88
.36177°W 13 .3' accuracy
Open Dump Inspection Report Narrative
Jay Winters-along with Garrison Gross-representing the Illinois Environmental
Protection Agency, inspected this site on July 19, 2006 as a follow-up to the previous
inspection on May 12, 2006
. The inspection was conducted in accordance with the
Illinois Environmental Protection Act : 415 ILCS 5/4(c) & 4(d) . The purpose of this
inspection was to determine compliance with the Environmental Protection Act and 35
Illinois Administrative Code Subtitle G : Waste Disposal Rules and Regulations of the
Illinois Pollution Control Board
.
Inspection Findings
Jay Winters (author) and Garrison Gross arrived at the site at approximately 11 :23 AM
on July 19, 2006 . The weather was 97°F and sunny . The site was located behind a row
of blue metal buildings along an unnamed paved alley approximately 200 yards west of
US Highway 45 approximately one mile south of Fairfield, IL. Upon arrival at the site, I
noticed that no action had been taken to remove any waste from the site since my last
inspection .
The waste was mostly concentrated along the edges and corners of the concrete slab, but
was also scattered throughout the weedy area just south of the slab (see site sketch)
. I
photographed an overview of the concrete pad from its east edge (Exposure #001) . The
waste previously observed in the southeast comer of the slab-which consisted of an
intermingled pile of various types of unprotected construction and demolition debris-
was again observed (Exposure #002) . The pallets of deteriorated metal containers
observed during the last inspection were again observed
. These deteriorated metal
containers had leaked and/or spilled their contents-which have solidified over time
(Exposure #s 003 and 004) . The deteriorated pallets containing rubber tubing that were
observed during the previous inspection were again observed (Exposure #005)
. The four
unlabeled black plastic drums at the extreme west end of the concrete slab also remained
at the site (Exposure #s 006 and 007) .
The weedy lot adjacent to the slab was still scattered with various types of open dumped
waste including, but not limited to, the following : waste tires, scrap metal, deteriorated
55-gallon metal drums, deteriorated one- and five-gallon metal containers, wooden

 
Illinois Environmental Protection Agency
1918085003 -- Wayne County
Bureau of Land
Division
of Land Pollution
Control
Barnhill/Bailey, Fred
FOS File
Inspection Findings (continued from previous page)
pallets, foam footballs and basketballs, and a partially burned semi-trailer full of rubber
pieces. The waste in this area had been discarded on the ground and was overgrown with
weeds and brush (Exposure #009) . The contents of some of the deteriorated metal
containers in this area had also leaked and/or spilled their contents-which have
solidified over time (Exposure #008) . These containers were not labeled and their
contents are unknown .
No response to the Administrative Citation Warning Notice has been received by the
Agency. No action has been taken to remove any of the waste at the site . I estimated the
total volume of waste at the site to be at least approximately 200 cubic yards
. The
inspectors left the site at approximately 11 :34 AM.

 
Illinois Environmental Protection Agency
1918085003 --
Wayne County
Bureau of Land
Barnhill/Bailey, Fred
Division of Land Pollution Control
FOS File
tN
07119/2006
Drawing Not To Scale
# #
Locations Are Approximate
40
006
*0007
Concrete
Slab
005
ca
CD
B
~-I
m .
Unnamed Paved Alley
009
Exposure Number
Position & Direction of Photograph
4-0008
C
Bm
Q
m
Q.
D
cn
To US
45~
I F~

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names : 191808500307192006-[Exp
. #] .jpg
Page 1 of5
LPC #1918085003 - Wayne County
Barnhill/Bailey, Fred
FOS File
Date
: 07/19/2006
Time: 11 :24 AM
Direction : W
Photo by
: Jay Winters
Exposure # : 001
Comments
:
Date: 07/19/2006
Time: 11 :24 AM
Direction
: SW
Photo by: Jay Winters
Exposure #: 002
Comments
:

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 1918085003-07192006-[Exp .
#].jpg
Page 2 of 5
LPC #1918085003 - Wayne County
Barn hill/Bailey, Fred
FOS File
Date: 07/19/2006
Time: 11 :25 AM
Direction: S
Photo by: Jay Winters
Exposure #: 003
Comments :
Date: 07/19/2006
Time: 11 :27 AM
Direction : SW
Photo by: Jay Winters
Exposure #: 004
Comments :

 
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names
: 1918085003--07192006-IExp . #].jpg
Page 3 of 5
LPC #1918085003 - Wayne County
Barnhill/Bailey, Fred
FOS File
Date: 07/19/2006
Time
: 11 :27 AM
Direction : SW
Photo by : Jay Winters
Exposure # : 005
Comments :
Date
: 07/19/2006
Time: 11 :27 AM
Direction: W
Photo by : Jay Winters
Exposure #: 006
Comments :

 
Page 4 of 5
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names : 1918085003-07192006-iExp. #I .jpg
LPC #1918085003 - Wayne County
Barnhill/Bailey, Fred
FOS File
Date: 07/19/2006
Time: 11 :28 AM
Direction : W
Photo by : Jay Winters
Exposure # : 007
Comments :
Date: 07/19/2006
Time: 11:32 AM
Direction : W
Photo by: Jay Winters
Exposure # : 008
Comments :

 
Page5 of 5
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names: 1918085003--07192006-[Exp . #].jpg
LPC #1918085003 - Wayne County
Barnhill/Bailey, Fred
FOS File
Date: 07/19/2006
Time: 11 :32 AM
Direction : NW
Photo by : Jay Winters
Exposure # : 009
Comments :

 
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
)
Complainant,
)
IEPA DOCKET NO .
v .
)
Matthew P. Bailey
)
Respondent.
)
AFFIDAVIT
Affiant, Garrison Gross, being first duly sworn, voluntarily deposes and states as follows
:
1 . Affiant is a field inspector employed by the Land Pollution Control Division of the
Illinois Environmental Protection Agency and has been so employed at all times pertinent hereto
.
2
. On July 19, 2006, between 11 :23 a .m . and 11 :34
a.m., Affiant conducted an inspection
of a disposal site operated by Matthew P
. Bailey, located in Wayne County, Illinois, and known
as Barnhill/Bailey, Fred by the Illinois Environmental Protection Agency
. Said site has been
assigned site code number 1918085003 by the Agency
.
3
. Affiant inspected said open dump site by an on-site inspection which included
walking and photographing the site.

 
4
. As a result of the material actions referred to in paragraph 3 above, Affiant completed
the Inspection Report form attached hereto and made a part hereof, which, to the best of Affiant's
knowledge and belief, is an accurate representation of Affiant's observations and factual
conclusions with respect to said Site Inspection
.
Subscribed and Sworn to before me
this day
of
IZ ,?6,06
Notary Public
GG
:jkb/26531/07-24-06
"OFFICIAL
SEAL
Notary
My
MARCIACommission
hubs c
a
Expires
. -
:ate
FNGLISH
of
: 0306/08Illinois

 
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY )
Complainant,
)
IEPA DOCKET NO.
v.
)
Matthew P . Bailey
)
Respondent .
)
AFFIDAVIT
Affiant, Jay A . Winters, being first duly sworn, voluntarily deposes and states as follows
:
1
. Affiant is a field inspector employed by the Land Pollution Control Division of the
Illinois Environmental Protection Agency and has been so employed at all times pertinent hereto
.
2. On July 19, 2006, between 11 :23 a .m. and 11 :34 a.m ., Affiant conducted an inspection
of a disposal site operated by Matthew P. Bailey, located in Wayne County, Illinois, and known
as Barnhill/Bailey, Fred by the Illinois Environmental Protection Agency . Said site has been
assigned site code number 1918085003 by the Agency .
3
. Affiant inspected said open dump site by an on-site inspection which included walking
and photographing the site .

 
4. As a result of the material actions referred to in paragraph 3 above, Affiant completed
the Inspection Report form attached hereto and made a part hereof, which, to the best of Affiant's
knowledge and belief, is an accurate representation of Affiant's observations and factual
conclusions with respect to said Site Inspection .
Subscribed and Sworn to before me
this o~,~ day of
Notary Public
JAW:jkb/26531/07-24-06
441
"OFFICIAL SEAL'
MARCIA 4 'INGLISH
Notary
Public,:
. 'eiio of Illinois
My Commission
Expires 03/06/08

 
PROOF OF SERVICE
I hereby certify that I did on the 8th day of August 2006, send by Certified Mail, Return Receipt
Requested, with postage thereon fully prepaid, by depositing in a United States Post Office Box a true
and correct copy of the following instrument(s) entitled ADMINISTRATIVE CITATION,
AFFIDAVIT, and OPEN DUMP INSPECTION CHECKLIST
To :
Matthew P . Bailey
401 S . 15`h Street
P.O . Box 34
Lawrenceville, IL 62439
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 Control Board
James R . Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Michelle M . Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER

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