BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Complainant,

)

vs .

)

NORBERT and WILMA ADAMS,

)

Respondents .

)

ADMINISTRATIVE CITATION

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1

2006

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STATE OF ILLINOIS

Pollution control

Board

(IEPA No. 130-06-AC)

PETITION FOR REVIEW

NOW COME Respondents, NORBERT ADAMS and WILMA ADAMS, by their attorney, WILLIAM

R. KELLY, and for their Petition for Review state as follows

:

1

.

Respondents admit that they are the owners of the property described in paragraph

1 of the Citation

.

2

.

Respondents deny that the facility is an open dump

.

3

.

Respondents admit that they have owned the subject property, but deny that they are

operating it as an open dump .

4

.

Respondents are aware of the inspection report of R . Eugene Figge .

5

.

Respondents deny that they have violated the Illinois Environmental Protection Act in

any manner.

AFFIRMATIVE ALLEGATIONS

6 .

Respondents state that at the request of the Illinois Environmental Protection Agency,

they have completely cleaned the subject property ; that the materials thereon have been hauled

and deposited at the Tazewell Recycle and Disposal Facility, 3550 E . Washington Road, East Peoria,

Illinois; and that no pollution or hazard exists on their property

.

---

WHEREFORE, Respondents pray that the Administrative Citation filed herein be dismissed

.

William R. Kelly

Attorney for Respondents

4801 N . Prospect Rd

.

Peoria Heights, IL 61616

Telephone: (309) 685-9001

Facsimile : (309) 685-9008

PROOF OF SERVICE

Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure,

the undersigned hereby certifies that she mailed a true and correct copy of

PETITION FOR

REVIEW to the following persons listed below by placing same in the U .S. Mail, postage fully prepaid

this

10

,

day of August, 2006 .

Illinois Environmental Protection Agency

Division of Legal Counsel

1021 N . Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

NORBERT ADAMS and WILMA ADAMS, Respondents

By

: +1

Th

it Attorney

JE

ICA M. STOVALL, Legal Assistant

Law Office of William R. Kelly