BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
v.
)
PCB No . 07-037
(Enforcement)
VILLAGE OF DORCHESTER,
)
an Illinois municipal corporation,
)
Respondent .
)
NOTICE OF FILING
RepCLERK'S
: -L=IVEDOFFICE
F L::
:3 2 8 2007
STATE OF
ILLINOIS
Pollution Control Board
To:
Mr. T
. Parrish
Strang & Parish, Ltd .
Attorneys at Law
108 N
. LaFayette Street
Jerseyville, IL 62062
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, copies of which
are 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
Litigation Divj ion
,,
BY. J
. L . HOMAN
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated : February 27, 2007
CERTIFICATE OF SERVICE
I hereby certify that I did on February 27, 2007, 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:
Mr. T. Parrish
Strang & Parish, Ltd .
Attorneys at Law
108 N
. LaFayette Street
Jerseyville, IL 62062
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
i/
.L . WOMAN
,Assistant Attorney General
This filing is submitted on recycled paper
.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RCLERK'SECEIVEDOFFICE
FE = 2 ~ 2007
PEOPLE OF THE STATE OF ILLINOIS, )
PollutionEnOFILLI
B
and
Complainant,
)
v.
)
PCB No. 07-037
(Enforcement)
VILLAGE OF DORCHESTER,
)
an Illinois municipal 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
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,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
ATTORNEY GENERAL
2
MATTHEW J
. DUNN, Chief
Environmental Enforcement/Asbestos
'tigation Division
BY
"J. L . HOMAN
Environmental Bureau
Assistant Attorney General
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated : February 27, 2007
9
CLERK'S
~CEIVED
OFFICE
P
I
:,'>
2
S
2007
PEOPLE OF THE STATE OF ILLINOIS,
Pollution
STATE OFILLINOIS
Control Board
Complainant,
)
PCB 07-037
v .
)
(Enforcement - )
VILLAGE OF DORCHESTER, an
)
Illinois municipal 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 VILLAGE OF
DORCHESTER, an Illinois municipal corporation ("Respondent"),
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 which 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
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
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 .
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 .
(2004) .
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 November 16, 2006, a Complaint was filed 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(2004), against the Respondent
.
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 (2004) .
3 .
At all times relevant to the Complaint, Respondent was
and is an Illinois municipal corporation that is authorized to
transact business in the State of Illinois .
B .
Site Description
1 .
At all times relevant to the Complaint, Respondent
owned and operated a public water supply which serves
approximately one hundred fifty residents located in the area of
Rock Road, a road which runs perpendicular to Spanish Needle
Road, Macoupin County, Illinois ("site") .
C .
Allegations of Non-Compliance
Complainant contends that the Respondent has violated the
following provisions of the Act and Board regulations
:
Count I :
Permit violations, in violation of Section 18(a)
of the Act, 415 ILCS 5/18(a) (2004), and 35 Ill
.
Adm . Code 653
.117(e) .
D .
Admission of Violations
The Respondent represents that it has entered into this
Stipulation for the purpose of settling and compromising disputed
claims without having to incur the expense of contested
litigation
. By entering into this Stipulation and complying with
its terms, the Respondent does not affirmatively admit the
allegations of violation within the Complaint and referenced
within Section III
.C herein, and this Stipulation shall not be
interpreted as including such admission
.
E .
Compliance Activities to Date
The Respondent has taken water samples as requested by the
Agency and submitted the samples for analysis
.
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
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 .
1 .
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
.
2 .
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, 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
.
3 .
The Respondent shall notify each contractor to be retained
to perform work required by any order accepting and adopting the
terms of this Stipulation of each of the requirements of said
Order relevant to the activities to be performed by that
contractor, including all relevant
. work schedules and reporting
deadlines, and shall provide a copy of this Stipulation and any
Order accepting and adopting the terms of this Stipulation to
each contractor already retained no later than 30 days after the
date of adoption of this Stipulation
. In addition, the
Respondent shall provide copies of all schedules for
implementation of the provisions of this Stipulation to the prime
vendor(s) supplying the control technology systems and other
equipment required by any order accepting and adopting the terms
of this Stipulation .
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 Ill
. Adm
. Code, Subtitles A through H .
VI
.IMPACT ON THE PUBLIC RESULTING FROM ALLEGED NON-COMPLIANCE
Section 33(c) of the Act, 415 ILCS 5/33(c)(2004), 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 .
Human health and the environment were threatened and
the Illinois EPA's information gathering responsibilities
hindered by the Respondent's violations
.
2 .
There is social and economic benefit to the facility
.
3 .
Operation of the facility is suitable for the area in
which it occurred .
4
. Obtaining a permit prior to construction at the site
and compliance with its terms was both technically practicable
and economically reasonable
.
5 .
Respondent has committed to subsequently comply with
the Act and the Board Regulations .
VII
.CONSIDERATION OF SECTION 42(h) FACTORS
Section 42(h) of the Act, 415 ILCS 5/42(h)(2004), 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 .
The Respondent failed to obtain a permit for
construction site activities prior to beginning construction
activities at the site, and violated provisions of its permit
once such coverage was obtained
. The violations began on or
around May 7, 2004 .
2 .
Once the Respondent was contacted by the Illinois
Attorney General's Office, the Respondent was diligent in
attempting to come back into compliance with the Act, Board
regulations and applicable federal regulations
.
3 .
There was economic benefit to the facility
.
4 .
Complainant has determined, based upon the specific
facts of this matter, that a penalty of three hundred dollars
($300
.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 has no
previously adjudicated violations of the Act
.
6 .
Self-disclosure is not an issue in this matter
.
7 .
The settlement of this 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
three hundred dollars ($300
.00) within thirty (30) days from the
date the Board adopts and accepts this Stipulation
. The
Respondent stipulates that payment has been tendered to
Respondent's attorney of record in this matter in a form
acceptable to that attorney
. Further, Respondent stipulates that
said attorney has been directed to make the penalty payment on
behalf of Respondent, within thirty (30) days from the date the
Board adopts and accepts this Stipulation, in a manner prescribed
below .
The
penalty described in this Stipulation shall be paid
by certified check, money order or electronic funds transfer
payable to the Illinois EPA, designated to the Illinois
Environmental Protection Trust Fund and submitted to
:
Illinois Environmental Protection Agency
Fiscal Services Section
1021 North Grand Avenue East
P .O . Box 19276
Springfield, IL 62794-9276
The name and number of the case and Respondent's Federal Employer
Identification Number (FEIN), shall appear on the check
. A copy
of the certified check, money order or record of electronic funds
transfer and any transmittal letter shall be sent to
:
Peggy Poitevint
Illinois Attorney General's Office
Environmental Bureau
500 South Second Street
Springfield, Illinois 62702
Joey Logan-Wilkey
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) of the Act, 415 ILLS 5/42(g)
(2004), 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
(2004)
. Interest on any unpaid payment shall begin to accrue
from the date the payment is due and continue to accrue 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, designated to the Illinois
Environmental Protection Trust Fund and delivered to the address
and in the manner described above .
3 .
For purposes of payment and collection, Respondent may
be reached at the following address :
Mr . T . Parrish
Strang & Parish, Ltd .
Attorneys at Law
108 N . LaFayette Street
Jerseyville, IL 62062
4 .
In the event of default of this Section VIII .A, the
Complainant shall be entitled to all available relief including,
but not limited to, reasonable costs of collection and reasonable
attorney's fees
.
B .
Compliance Plan
The Respondent will submit a completed application for
partial operating permit and receipt showing the length of the
water main installed to the Illinois Environmental Protection
Agency, provided the outstanding monthly operating reports for
the period March 2003 to June 2006, and provided water sample
test results for the samples taken on Monday, July 17, 2006, and
Tuesday July 18, 2006, within thirty days (30) of the date of
entry of this Order
. These items will be submitted to :
Bureau of Water
Illinois EPA
1021 North Grand Avenue East
P .O . Box 19276
Springfield, Illinois 62794-9276
Joey Logan-Wilkey
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P .O . Box 19276
Springfield, Illinois 62794-9276
The Respondent shall continue to timely submit monthly monitoring
reports and water quality sample test results .
C .
Stipulated Penalties
1 .
If the Respondent fails to complete any activity or
fails to comply with any response or reporting requirement by the
date specified in Section VIII .B ("Compliance Plan") of this
Stiulation, the Respondent shall provide notice to the
Complainant of each failure to comply with this Stipulation . In
addition, the Respondent shall pay to the Complainant, for
payment into teh EPTF, stipulated penalties per violation for
each day of violation in the amount of $25 .00 until such time
that compliance is achieved
.
2 .
Following the Complainant's determination that the
Respondent has failed to complete performance of any task or
other portion of work, failed to provide a required submittal,
including any report or notification, Complainant may make a
demand for stipulated penalties upon Respondent for its
noncompliance with this Stipulation
. Failure by the Respondent
to make this demand shall not relieve the Respondent of the
obligation to pay stipulated penalties
.
3 .
All penalties owed the Complainant under this section
of this Stipulation that have not been paid shall be payable
within thirty (30) days of the date the Respondent knows or
should have known of its noncompliance with any provision of this
Stipulation .
4 .
a
All stipulated penalties shall be paid by
certified check, money order or electronic funds transfer,
payable to the Illinois EPA for deposit into the EPTF and shall
be sent by first class mail, unless submitted by electronic funds
transfer, and delivered to
:
Illinois Environmental Protection Agency
Fiscal Services
1021 North Grand Avenue East
P .O
. Box 19276
Springfield, Illinois 62794-9276
b .
The name and number of the case and the
Respondent's FEIN shall appear on the face of the check
. A copy
of
the certified check, money order or record of electronic funds
transfer and any transmittal letter shall be sent to
:
Peggy Poitevint
Illinois Attorney General's Office
Environmental Bureau
500 South Second Street
Springfield, Illinois 62702
5
The stipulated penalties shall be enforceable by the
Respondent and shall be in addition to, and shall not preclude
the use of, any other remedies or sanctions arising from the
failure to comply with this Stipulation .
D .
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)(2004)
. 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
.
E .
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 .
F .
Release from Liability
In consideration of the Respondent's payment of the $300
.00
penalty and any specified costs and accrued interest, completion
of all activities required hereunder, to Cease and Desist as
contained in Section VIII
.E 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 Complaint herein
. The release set forth
above does not extend to any matters other than those expressly
specified in Complainant's Complaint filed on November 16, 2006
.
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 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 .
G .
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 .
H .
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
J . Homan
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62702
Joey Logan Wilkey
Assistant Counsel
Illinois EPA
1021 North Grand Avenue East
P .O . Box 19276
Springfield, Illinois 62794-9276
Bureau of Water
Illinois EPA
1021 North Grand Avenue East
P .O . Box 19276
Springfield, Illinois 62794-9276
As to the Respondent
Mr . T . Parrish
Strang & Parish, Ltd .
Attorneys at Law
108 N . LaFayette Street
Jerseyville, IL 62062
I .
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
.H .
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 .
J .
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 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
.
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 .
01/16/2087 17 :22
6184982488
PAGE 2=
.
WHEREFORE .
Complainant and Respondent request that the Board
adopt and accept the foregoing Stipulation and Proposal for
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
BY :
VILLAGE OF DORCHESTER
BY
: (' ~l 'LCL 'b'L6C
Y Q.
Name
: ยข'
Title :
G
rf- ~ Aenir1rd
DATE :
1/-~l
/e'
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 .
THOMAS DAVIS, Chief
DATE :
2
.
//(,-, /of
Environmental Bureau
Assistant Attorney General
