INFORMATIONAL NOTICE!!!
RECEIVED
MAY 0 9 2007
STATE OF ILLINOIS
Pollution Con" o Q and
IT IS IMPORTANT THAT YOU READ THE ENCLOSED DOCUMENTS
.
NOTE:
This Administrative Citation refers to TWO separate State
of Illinois Agencies
. One is the ILLINOIS POLLUTION
CONTROL BOARD located at James R
. Thompson
Center, 100 West Randolph Street, Suite 11-500,
Chicago, Illinois 60601 . The other state agency is the
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
located, at: 1021 North Grand Avenue East, P
.O
. Box
19276, Springfield, Illinois 61794-9276 .
If you elect to contest the enclosed Administrative Citation, you must
file a PETITION FOR REVIEW
with thirty-five (35) days of the date
the Administrative Citation was served upon you . Any such Petition
for Review must be filed with the clerk of the Illinois Pollution Control
Board by either hand delivering or mailing to the Board at the address
given above
. A copy of the Petition for Review should be either
hand-delivered or mailed to the Illinois Environmental Protection
Agency at the address given above and should be marked to the
ATTENTION
: DIVISION OF LEGAL COUNSEL .
Any person other than individuals MUST appear through an attorney-
at-law licensed and registered to practice law . Individuals may
appear on their own behalf, or through an attorney . 35 III . Adm. Code
101 .400(a).
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
V .
BERNARD KOTTER,
Respondent .
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ADMINISTRATIVE CITATION
To : Bernard Kotter
114 East 5`
h
Street
Karkak, IL 62956
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,
)
AC p~'S1
(IEPA No . 122-07-AC)
NOTICE OF FILING
Michelle M
. Ry
qqW
.4L a
THIS FILING SUBMITTED ON RECYCLED PAPER
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: May 3, 2007
RECEIVEDCLERKS
OFFICE
MAY 0 9 2007
Pollution
STATE OF
Control
ILLINOISBoard
RECEIVED
CLERK'S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAY 0 9 2007
ADMINISTRATIVE CITATION
STATE OF ILLINOIS
Pollution Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
V .
)
BERNARD KOTTER,
)
Respondent .
)
AC 0 1
(IEPA No
. 122-07-AC)
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 Bernard Kotter ("Respondent") is the present owner and operator of a facility
located at 114 East
5th
Street, Karnak, Pulaski County, Illinois
. The property is commonly known to
the Illinois Environmental Protection Agency as Kamak/Kotter, Bernard
.
2 .
That said facility is an open dump operating without an Illinois Environmental
Protection Agency Operating Permit and is designated with Site Code No
. 1530055006 .
3.
That Respondent has owned and operated said facility at all times pertinent hereto
.
4 .
That on March 22, 2007, Robert Mileur of the Illinois Environmental Protection
Agency's Marion Regional Office inspected the above-described facility
. A copy of his inspection
report setting forth the results of said inspection is attached hereto and made a part hereof
.
VIOLATIONS
Based upon direct observations made by Robert Mileur during the course of his March 22,
2007 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)
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) .
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
One Thousand Five Hundred Dollars ($1,500
.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
Mav 31, 2007,
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,
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
2
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
.
71 f
s t
DouglasDirector
4%
Illinois Environmental Protection Agency
Date :
513101
Prepared by
:
Susan E
. Konzelmann, 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
FACILITY:
Karnak/Kotter, Bernard
SITE CODE NO .:
1530055006
COUNTY:
Pulaski
CIVIL PENALTY :
$1,500.00
DATE OF INSPECTION
:
March 22, 2007
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
.
REMITTANCE FORM
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Complainant,
)
AC
V .
)
BERNARD KOTTER,
)
Respondent
.
)
5
(IEPA No. 122-07-AC)
RE
CLERKS
,EIVIED
MAY 0 9 2001
Pollution
STATE OF
Control
ILLINOISBoard
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY )
Complainant,
)
]EPA DOCKET NO .
v.
)
Bernard Kotter
)
Respondent.
)
AFFIDAVIT
Affiant, Robert Mileur, 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 March 22, 2007, between 1 :30 p .m
. and 1 :45 p .m., Affiant conducted an inspection
of a disposal site operated by Bernard Kotter, located in Pulaski County, Illinois, and known as
Karnak/Kotter, Bernard by the Illinois Environmental Protection Agency
. Said site has been
assigned site code number 1530055006 by the Agency .
3
. Affiant inspected said Karnak/Kotter, Bernard 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 Karnak/Kotter, Bernard
.
t
Subscribed and Sworn to before me
his ~0 day of i
,t aO /
/ , (((
Notary Public
GES
:RM:jkb/29991/04-17-07
"OFF T
r`rAU.
NotaMAn
r :.
:
I
;"H
I!'rIOI$
MY
pupas,:, c
,5;06/08
County
:
Pulaski
LPC#:
1530055006
Region:
7 - Marion
Location/Site Name
:
Karnak/Kotter, Bernard
Date
:
03/22/2007 Time : From 1
:30pm
Inspector(s) :
Robert Mileur
No . of Photos Taken : #
17
Est. Amt . of Waste
:
Interviewed :
Latitude : 37 .29144
(Example
:
Let
: 41 .26493
Responsible Party
Mailing Address(es)
and Phone Number(s)
:
Revised 10/5/2005
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Open Dump Inspection Checklist
Longitude
: -88 .97297
Long .: -89 .38294)
Bernard Kotter
114 East 5th Street
Karnak, IL 62956
To 1 :45pm
Previous Inspection Date
: 11/29/2006
Weather : Partly cloudy 65 degrees w/ light wind
600
yds3 Samples Taken
: Yes #
No
Complaint #
: C-07-024-M
Collection Point Description
: Site Entrance -
Collection Method
: GPS -
(Open Dump - 1)
SECTION
DESCRIPTION
VIOL
ILLINOIS ENVIRONMENTAL PROTECTION ACT REQUIREMENTS
1 . 9(a)
CAUSE, THREATEN OR ALLOW AIR POLLUTION IN ILLINOIS
2. 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
F~
6. 21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION :
(1)
Without a Permit
4
(2)
In Violation of Any Regulations or Standards Adopted by the Board
~0
7 . 21(e)
DISPOSE, TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
WASTE INTO THF STATE AT/TO SITFS NOT MFFTING REQUIREMENTS OF ACT
~~
8. 21(p)
CAUSE OR ALLOW THE OPEN DUMPING OF ANY WASTE IN A MANNER WHICH RESULTS
IN ANY OF THE FOLLOWING OCCURRENCES AT THE DUMP SITE
:
(1)
Litter
FIB
(2)
Scavenging
(3)
Open Burning
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
Standing or Flowing Liquid Discharge from the Dump Site
LPC # 1530055006
Inspection Date
:
03/22/2007
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 ILCS 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)
(7)
Deposition of General Construction or Demolition Debris
; or Clean Construction or
Demolition Debris
55(a)
NO PERSON SHALL :
(1)
Cause
or Allow Open Dumping of Any Used or Waste Tire
1161
(2)
Cause or Allow Open Burning of Any Used or Waste Tire
35 ILLINOIS ADMINISTRATIVE CODE REQUIREMENTS
SUBTITLE G
FAILURE TO SUBMIT AN APPLICATION FOR
A PERMIT TO DEVELOP AND
(4
10.
812 .101(a) OPERATE A LANDFILL
11 . 722 .111
HAZARDOUS WASTE DETERMINATION
12. 808 .121
SPECIAL WASTE DETERMINATION
13 . 809.302ja)
ACCEPTANCE OF
SPECIAL WASTE FROM A
WASTE TRANSPORTER WITHOUT A
WASTE HAULING PERMIT, UNIFORM WASTE PROGRAM REGISTRATION AND
PERMIT AND/OR MANIFEST
OTHER REQUIREMENTS
14.
APPARENT VIOLATION OF
: ( ) PCB; ( ) CIRCUIT COURT
CASE NUMBER:
ORDER ENTERED ON :
15. OTHER :
LPC# 1530055006 -
Pulaski County
Karnak/Kotter, Bernard
Inspector(s) : Robert Mileur
March 22, 2007
FOS File
State of Illinois
ENVIRONMENTAL PROTECTION AGENCY
INSPECTION NARRATIVE
Inspection Report Narrative
Robert Mileur representing the Agency inspected this site on March 22, 2007
. This
inspection was conducted in accordance with Sections 4(c) and 4(d) of the Illinois
Environmental Protection Act
: 415 ILCS 5/4(c) & 4(d) .
The purpose of this inspection
was to determine compliance with the Illinois Environmental Protection Act and 35 Ill
.
Adm. Code, Subtitle G
: Waste Disposal Rules and Regulations
.
The inspection was a follow up to an inspection completed on November 29, 2006
. A
subsequent ACWN was issued and signed for on December 6, 2006 and there has been
no response from the responsible party
. The inspection consisted of walking and
photographing the site .
Inspection Findings
I arrived at the site at around 1
:30pm and found no one there at the time
. The property
appears to be divided by a large drainage ditch with similar materials found on both sides
of the drainage and an old bridge connecting the two areas
. There were abandoned
vehicles and semi trailers on both sides of the ditch
. Some of the semi-trailers had the
name, "Kotter" on them
. Much of the material was overgrown with trees and appeared to
be open dumped
. Several of the vehicles and old semi trailer units were in deteriorating
condition, not protected from the elements, and were easily visible from the roadway
.
Considering the location of the items and their condition, the site represents an urban
blight on the village of Karnak
. The items at the site mostly consisted of metal based
materials and have some value as salvage
. Also at the site, located in the woods on the
southeast side of the area, I found around 50 semi-trailer tires
. Some were on rims but
most were not and many were holding water
. I estimated that there is around 600 cubic
yards of waste material at the site
. Some of the semi trailers located on the north side of
the site was in reasonable condition but some, like the old stock trailers, were in bad
condition and may have value only as scrap
. There were some vehicles at the site that
might possibly be valuable as collector cars, but none of them were being stored with any
future intended use
. Many of them had their windows broken out with the interior
exposed to the elements
. Overall, the site contained a total of 11 semi trailer beds and
around 25 vehicles in varying states of disrepair
. Two of the flat bed semi trailers
contained dimensional lumber that had rotted and was no longer valuable as lumber
.
Mixed in the waste I observed several wet cell batteries that had been thrown on the
ground
.
I concluded my inspection at around 1
:45pm.
C
IsRh~,'.YShx
McKinley
Street
State of I linois
ENVIRONMENTAL PROTECTION AGENCY
SITE SKETCH
/ Lincoln Street
4
*Not to Scale
Semi Trailers
-
Cars
4
I
4
4
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names
: 1530055006-032220007-[Exp. #I.jpg
Page 1 of 9
LPC #1530055006- Pulaski County
KarnaklKotter, Benard
FOS File
Date: 3/22/07
Time: 1 :32pm
Direction : NE
Photo by : Robert Mileur
Exposure # : 001
Comments
: View of
Kotter property looking
NE from street .
Date : 3/22/07
Time: 1 :33pm
Direction : NE
Photo by : Robert Mileur
Exposure # : 002
Comments : Looking
northeast from road.
Abandoned itmes found
gown up on property.
File Names
: 1530055006-032220007-[Exp. #] .jpg
Page 2 of 9
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date : 3/22/07
Time : 1 :32pm
Direction : NE
Photo by
: Robert Mileur
Exposure # : 003
Comments
: Looking east
from street at abandoned
trailer and cars
.
Date : 3/22/07
Time : 1 :33pm
Direction : E
Photo by
: Robert Mileur
Exposure # : 004
Comments :
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names
: 1530055006-032220007-[Exp. #] .jpg
Page 3 of 9
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date: 3/22/07
Time: 1 :32pm
Direction:
Photo by: Robert Mileur
Exposure # : 005
Comments
: Standing in
street looking east
towards abandoned
vehicles.
Date: 3/22/07
Time: 1 :33pm
Direction : SE
Photo by
: Robert Mileur
Exposure # : 006
Comments : View of SW
corner of property
.
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names : 1530055006-032220007-[Exp . # 1.jpg
Page 4 of 9
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date : 3/22/07
Time : 1 :32pm
Direction : E
Photo by : Robert Mileur
Exposure #
: 007
Comments: Looking
eastward at abandoned
cars and items that,
judgeing by the vegetative
growth, have been there
for some time.
Date : 3/22/07
Time : 1 :33pm
Direction : N
Photo by : Robert Mileur
Exposure # : 008
Comments : View of
abandoned cars and semi-
trailers
. Note weeds and
tree growth.
File Names : 1530055006-032220007-lExp
. #].jpg
Page 5 of 9
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
1
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date
: 3/22/07
Time: 1 :32pm
Direction : E
Photo by : Robert Mileur
Exposure #
: 009
Comments : Picture of
abandoned car with trees
growing up around it.
Date
: 3/22/07
Time : 1 :33pm
Direction : NE
Photo by
: Robert Mileur
Exposure # : 010
Comments
: View of
abandoned stock trailer,
truck bed, and old cab for
eartly model truck
; All
overgrown with weeds
.
Page 6 of 9
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
tt
$
File Names : 1530055006-032220007-[Exp . #] .jpg
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date : 3/22/07
Time : 1 :32pm
Direction : N
Photo by : Robert Mileur
Exposure #
: 011
Comments : View looking
north . Abandoned flat
bed and stock trailers
noted at site.
Date : 3/22/07
Time : 1
:33pm
Direction : N
Photo by : Robert Mileur
Exposure # : 012
Comments
: View of old
semi-trailer loaded with
deteriorating lumber .
Trees showng growing up
around trailer .
Page 7 of 9
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
File Names : 1530055006--032220007-(Exp
. #].jpg
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date
: 3/22/07
Time: 1 :32pm
Direction : NW
Photo by : Robert Mileur
Exposure #
: 013
Comments : View looing
from road into the woods
.
Tires and debris noted
.
Date: 3/22/07
Time : 1:33pm
Direction : SW
Photo by
: Robert Mileur
Exposure # : 014
Comments : View of tires
found scattered in woods .
Page 8 of 9
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names
: 1530055006--032220007-[Exp . #I.jpg
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
Date: 3/22/07
Time: 1 :32pm
Direction : W
Photo by
: Robert Mileur
Exposure # : 015
Comments : view looking
west at debris piled in the
woods.
Date: 3/22/07
Time: 1:33pm
Direction : W
Photo by
: Robert Mileur
Exposure # : 016
Comments
: View of
abandoned manure
speader gown up in
weeds.
Illinois Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
DIGITAL PHOTOGRAPHS
File Names
: 1530055006032220007-[Exp . #].jpg
Page 9 of 9
LPC #1530055006- Pulaski County
Karnak/Kotter, Benard
FOS File
"?
Date: 3/22/07
Time: 1 :32pm
Direction : SW
Photo by: Robert Mileur
Exposure # : 017
Comments : View of
abandoned vehicles.
PROOF OF SERVICE
I hereby certify that I did on the 3rd day of May 2007,
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:
Bernard Kotter
114 East 5`h Street
Karkak, IL 62956
Cert #
7004 2510 0001 8587 8532
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
Cert # 7004 2510 0001 8587 8549
Michel e 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
