IN THE MATTER OF
:
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVED
MAY 3.0
2007
-~,
STATE OF ILLINOIS
R07-~
Pollution Control Board
(Site-Specific Rulemaking
-
Water)
SITE SPECIFIC RULE FOR CITY OF
.IOLIET TREATMENT PLANT
FLOURIDE AND COPPER
DISCHARGES, 35 ILL . ADM.
CODE 303 .432
Petitioner,
)
TO:
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P
.O
. Box 19276
Springfield, IL 62794-9276
Office of Legal Services
Illinois Department of Natural Resources
524 S
. Second St.
Springfield, IL 62701-1787
Dated : May 30, 2007
Roy M
. Harsch, Esq.
Yesenia Villasenor-Rodriguez
DrinkerBiddleGardnerCarton
191 North Wacker Drive, Suite 3700
Chicago, Illinois 60606
(312) 569-1441 (Direct Dial)
(312) 569-3441 (Facsimile)
NOTICE OF FILING
By:_
Gm e f Its Attorneys
Illinois Pollution Control Board
Dorothy M . Gunn
100 West Randolph
Suite 11-500
Chicago, IL 60601
Division Chief of Environmental
Enforcement
Office of the Attorney General
188 West Randolph St ., 20th Floor
Chicago, IL 60601
PLEASE TAKE NOTICE that on May 30, 2007 we filed with the Office of the Clerk of
the Pollution Control Board an original and ten copies of the attached Joliet's Petition for Site-
Specific Regulation, Appearance of Roy M. Harsch and Yesenia Villasenor-Rodriguez, and
Joliet's Motion to Waive 200 Signatures a copy of each which is served upon you .
Respectfully submitted,
THE CITY OF JOLIET
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD E C E I V E D
CLERK'S OFFICE
IN THE MATTER OF :
MAY 3 ,
0 2007
SITE SPECIFIC RULE FOR CITY OF
STATE OF ILLINOIS
)
JOLIET
TREATMENT PLANT
Pollution Control Board
)
.~
FLOURIDE AND COPPER
)
R07-,?A
DISCHARGES, 35 ILL . ADM .
)
(Site-Specific Rulemaking - Water)
CODE 303 .432
)
CITY OF JOLIET'S PETITION FOR
SITE-SPECIFIC REGULATION
NOW COMES, THE CITY OF JOLIET (hereinafter, "Joliet"), by and through its
attorneys, Drinker Biddle Gardner Carton, and pursuant to 415 ILCS 5/27, 35 111 . Adm. Code
Sections 102 .208 and 102
.210, petitions the Illinois Pollution Control Board ("IPCB") for a site
specific copper and fluoride limits, as follows:
I.
PROPOSED SITE-SPECIFIC RULE
As proposed, the site-specific standard requested by Petitioners would provide as follows :
Section 303.432 Juncture of Hickory Creek and Des Plaines River
The general use water quality standards for copper (STORET
Number 01040) and fluoride (STORET Number 00951) found at
Sections 302.208 (e) and (g) and the provisions for determining
water quality based effluent limitations found at Section 304.105
shall not apply to that portion of the Hickory Creek downstream
from the Joliet Street bridge in Joliet, to the juncture with the Des
Plaines River that receives the discharge from the Joliet East
Side waste water treatment plant . Instead the Joliet discharge shall
comply with a copper limit of 0.15 mg/l and a fluoride limit of
3 .5 mg/1 as monthly average values .
As explained more fully herein, these copper and fluoride limits as applied to the
discharge into the designated receiving water will be protective of aquatic life, human health, and
the environment as a whole
. Moreover, adoption of these proposed site specific limits will allow
THIS FILING SUBMITTED ON RECYCLED PAPER
-1
socially and economically valuable services located in Joliet, Illinois to continue in conformance
with applicable requirements
.
11 .
STATEMENT OF REASONS
In accordance with the Board's procedural rules at 35 Ill
. Adm
. Code Sections 102 .202
and 102.210,
Joliet submits the information required to support this site specific petition
. The
information addresses the need for this requested site specific copper and fluoride limits
applicable to Joliet's Eastside waste water treatment plant ("Eastside WWTP"), the reason why
compliance with the general rule is not technically or economically reasonable, a description of
the area affected by the proposed site specific rule and the environmental impact of the proposed
copper and fluoride limits on the affected area
.
A.
Existing Physical Conditions
Joliet provides wastewater collection and treatment to an approved service area of over
50.5
square miles with a current population of 143,000 and a projected population of 180,000
.
Joliet currently owns and operates three waste water treatment plants
. Of these three plants, only
the Eastside WWTP is the subject of this petition
. Joliet's Eastside WWTP is located at 1021
McKinley Avenue in Joliet, Illinois at latitude + 4130220 and longitude
-
08805320 . Joliet's
Eastside WWTP serves approximately 90,000 customers which are comprised of 26,123
residential, 1,620 commercial, and 57 industrial connections
. Flow to the Eastside WWTP is
approximately split between 80% residential and 20% commercial/industrial
.
Joliet has an
extensive approved pre-treatment program
.
The Eastside WWTP is a conventional activated sludge plant with anaerobic digesters
.
The plant was originally constructed in 1955 and has proceeded with upgrades and expansions
.
The most recent upgrade was completed on 1991
. As presently configured and permitted, the
THIS FILING SUBMITTED ON RECYCLED PAPER
-2
Eastside WWTP has a design average flow of 18
.2 million gallons per day
("mgd")
and a design
maximum flow of 45
.5 mgd.
The Eastside WWTP is designed to treat biological oxygen
demand ("BOD"),
solids, ammonia nitrogen, and bacteria .
Like most publicly owned waste
water treatment plants ("POTWs"), the Joliet Eastside WWTP was not designed to remove
soluble inorganic anions such as fluoride or cations such as copper
.
Joliet's Eastside WWTP discharges its wastewater pursuant to National Pollution
Discharge Elimination System ("NPDES") Permit Number IL0022519 issued by the Illinois
Environmental Protection Agency ("IEPA") on March 11, 2002
. Joliet timely filed a renewal
application prior to the expiration date of this permit of March 31, 2007
. Therefore this permit
remains effective until the IEPA issues a renewal permit
. As delineated in this NPDES permit,
Joliet discharges to Hickory Creek at the juncture with the Des Plaines River
.
The IEPA historically used the flow of the Des Plaines River for permitting purposes
.
Beginning with the NPDES permit issued on October 1, 1996, IEPA began to use the flow of
Hickory Creek to determine if the discharge from Joliet's Eastside WWTP would result in
violations of the general use water quality standards applicable to Hickory Creek as required by
35 111
. Adm . Code Section 304
.105 .
Accordingly, Joliet's present NDPES permit for the
Eastside WWTP contains water quality based effluent limitations for copper of 0
.0396 mg/l
monthly average and 0
.0671 mg/I daily maximum and 1
.4 mg/1 daily maximum for fluoride
. A
monthly average for fluoride was not provided in its NPDES permit
.
These limitations are based on the water quality standards set forth in 35 Ill
. Adm. Code
Sections 302
.208 (e) and (g).
On March 30, 2007, Joliet entered into a Consent Order in the
Circuit Court for the Twelfth Judicial Circuit in Will County, Illinois for case No
. 05 CH 593
with the Illinois Attorney General and the IEPA
. Section VIII C .1 and C
.3 of the March 30,
2007 Consent Order, imposed an interim daily maximum limit for copper of 0
.1156 mg/I and a
THIS FILING SUBMITTED ON RECYCLED PAPER
-3
daily maximum fluoride discharge limit of 3
.5 mg/l.
Under the terms and conditions of the
Consent Order it was envisioned that Joliet would pursue relief from the fluoride and copper
limits set forth in its NPDES Permit
. Pursuant to Section VIII C
.3 of said Consent Order, the
fluoride interim limit expires either on May 31, 2007 or on the date upon which a final decision
regarding same could not be appealed.
The Consent Order did not specify that the copper
interim would expire on May 31, 2007 but rather, when amended in its NPDES permit or on the
date upon which a final decision regarding same could not be appealed
. As previously set forth
in Section I of this Petition, Joliet is requesting permanent relief from the water quality based
effluent limitations that apply to Hickory Creek for copper and fluoride
.
B.
Affected Sources and Facilities and Character of the Area Involved
Joliet is the only source affected by this Site specific request as it is the only source that
discharges into Hickory Creek downstream from the Joliet Street Bridge to the juncture of the
Des Plaines River
. Additionally, there are no withdrawals of water by any users from this stream
segment
. Joliet has conducted investigations to determine whether any industrial users whose
discharges could significantly contribute to its excess copper and fluoride effluent discharge have
in actuality caused the same .
Joliet's investigations concluded that there are no significant
industrial sources that are contributing to Joliet's excess copper and fluoride limits
. However,
these sources are in areas of the city that are not tributary to Joliet's Eastside WWTP
. Further,
Joliet does not add fluoride to its water for dental health purposes
. Consequently, Joliet could
not determine any specific source(s) contributing to its fluoride discharge
. Joliet believes that
the fluoride levels in its effluent discharge are a direct result of the fluoride concentration in the
public water supply provided to the customers tributary to the Eastside W WTP
.
With respect to copper, Joliet consulted the services of Analytical Chemistry and
Environmental Services Inc
. ("ACES") to perform a study
. The results of this study are
THIS FILING SUBMITTED ON RECYCLED PAPER
-4
contained in a report "Hickory Creek and Copper Study" dated August 20, 2000
. According to
this study, it appears that the copper discharge excursions coincided with the implementation of
the Safe Drinking Water Act mandate in 1997
. Specifically, this act requires that cities
implement a corrosion prevention program to reduce lead and copper in their drinking supplies
.
Based on ACES investigations and testing of the Eastside's WWTP effluent, this very low
concentration limit for copper has been exceeded on an intermittent and infrequent basis
. After
extensive investigations, Joliet has been unable to determine the exact cause of its copper
excursions other than its initial conclusions that the exceedances appear to be related to the use
of a corrosion inhibitor that was used by Joliet's public water supply in order to comply with the
Safe Water Drinking Water mandate .
1 .
Affected Sources for Fluoride
As indicated previously, Joliet has been unable to identify any industrial users as the
primary sources of fluoride in Joliet's wastewater discharge
. Therefore, the only affected source
is Joliet's Eastside W WTP .
2.
Affected Sources for Copper
As indicated above, there are no sources of copper that would be affected by the proposed
site specific water quality standards other than Joliet's Eastside WWTP and Joliet could not
identify any industrial users that were significantly contributing to the excess copper
.
3 .
Users of Affected Water Segments
Waters from the Eastside WWTP are discharged into the Hickory Creek at the juncture of
the Des Plaines River.
However, other than the Joliet Eastside WWTP there are no other
discharges to the affected water quality segment
. Further, there is very little recreational use
that takes place
. There have been few, if any, observed recreational boating usages and only
occasional bank fisherman in this stream reach
.
THIS FILING SUBMITTED ON RECYCLED PAPER
-5
4.
Characteristic of Surrounding Land Use
Joliet's Eastside WWTP is located on a peninsula formed by Hickory Creek and the Des
Plaines River
. To the northeast of the plant there is a small residential area
. To the east of
Joliet's Eastside WWTP is the former site of the McKinley School which was closed and torn
down approximately 15 years ago
. To the west of the Eastside W WTP is the Des Plaines River
and Hickory Creek to the south
. Accordingly, the Eastside WWTP is essentially isolated
.
C.
Nature of the Receiving Body of Water
According to Joliet's NPDES Permit, the Eastside WWTP facility discharges into
Hickory Creek
. Hickory Creek is designated as a general use water body
. 35 Ill. Adm
. Code
Section 303
.201
. Notwithstanding such, Joliet has performed various conductivity tests and
based on these tests, it appears that the waters to which it discharges are those of the Des Plaines
River
. In order to understand how this has occurred, it is important to understand that over time,
Hickory Creek has undergone significant physical modifications for purposes of flood control
.
These modifications have included dredging, channelization, and modification of the bank along
near the Des Plaines River juncture
. Additionally, the flow control structures of the Des Plaines
River have changed the Des Plaines River including the area of this particular juncture
.
Consequently, as a result of these changes and as shown by the conductivity tests, in actuality the
discharge from its Eastside WWTP is into waters of the Des Plaines River
. Therefore, in reality
there is no impact to the waters of Hickory Creek resulting from the Eastside W WTP discharge
.
Further, if one uses the mixing zone dilution formula as applied to the Des Plaines River
flow and the size of the discharge, Joliet's copper and fluoride effluent values do not produce
values that would exceed the general use water quality standards
. However, if one uses the
mixing zone regulation as applied to a discharge to Hickory Creek, Joliet's WWTP effluent
values are in excess of water quality based effluent limitations as set forth in its NPDES permit
.
THIS FILING SUBMITTED ON RECYCLED PAPER
-6
Joliet's proposed site specific limits as set forth herein, do not exceed the effluent limitations of
0.5 mg/l for copper and 15
.0 mg/1 for fluoride contained in 35 Ill
. Adm. Code Section 304.124
.
Joliet has conducted sampling and analysis of the Hickory Stream
. Samples were taken
twice per week from May 16, 2006 to June 9, 2006 upstream from the Joliet Street bridge at the
mid-point of the creek
; downstream before the creek enters the Des Plaines River approximately
fifteen feet from the shoreline
; and a third sample was taken from the Eastside WWTP discharge
area.
The sample from the discharge area was taken from the weir overflow just prior to
discharge into the Hickory Creek
. Based on the sampling results, the downstream copper ranged
anywhere from 0
.016 mg/1 to 0 .041mg/1 and fluoride 0
.60 mg/1 to 0 .90 mg/l. The upstream
sampling copper limits were found to be anywhere from 0
.013 mg/1 to 0
.025 mg/1 while fluoride
samples ranged from 0.30
mg/1 to 0 .45 mg/I
. The discharge at the Eastside WWTP showed
copper limits ranged from 0
.019 mg/1 to 0
.169 mg/1 while fluoride ranged from 1 .4 mg/1 to 2
.9
mg/1 .
D.
Available Treatment or Control Options
Joliet is not aware of any treatments or control options to reduce the level of copper or
fluoride in its effluent discharge that could be utilized to comply with the water quality based
effluent limits in its NPDES permit
. Notwithstanding such, there is one technical solution which
would consist of building a discharge structure to re-route the discharge from Joliet's WWTP to
the Des Plaines River at a distance of 100 yards at an estimated cost of $ 1,500,000
.
E.
Technical Feasibility and Economic Reasonableness of Reducing
Fluoride&Copper
The technical solution of re-routing the discharge from Joliet's Eastside WWTP while
technically feasible is not economically reasonable
. The conductivity studies support that the
Eastside W WTP discharge is in actuality being discharged to Des Plaines River waters therefore,
THIS FILING SUBMITTED
-7
ON RECYCLED PAPER
to re-route the Eastside's WWTP discharges to the same waters would be a wasted cost of
approximately $1,500,000 without any additional water quality improvements
.
F.
Other Similar Persons' or Sites' Ability to Comply with the General Rule
Joliet is unaware of any other persons or sites ability to comply with the general rule
.
G.
Economic Impact of the Proposed Rule
The economic benefit of the proposed rule is that it would save Joliet the cost of
$1,500,000 to relocate its discharge to the Des Plaines River
. This cost as explained previously
would be a wasted cost, because in actuality, the Joliet Eastside WWTP is discharging into Des
Plaines Rivers waters
. Moreover, the relocation of such discharge structure would do nothing to
improve the water quality
. Therefore, Joliet could best serve its customers by using its economic
resources to ensure continued compliance with the appropriate effluent limits proposed herein
.
H.
Detailed Assessment of the Environmental Impact of the Proposed Change
As provided herein, there would be no environmental impacts with the proposed change
.
First, conductivity testing has shown that the actual waters in which the Eastside WWTP is
discharging to are those of the Des Plaines River
. Second, using the mixing dilution formula as
applied to the Des Plaines River flow, Joliet's Eastside WWTP's effluent discharge and the
requested limitation will not exceed the general use water quality standards for either copper or
fluoride
. Third, the Eastside WWTP effluent is the only discharge in that segment of the Des
Plaines River juncture with Hickory Creek
. Fourth, there will be no impact to the minimal
recreational uses at said juncture .
III. SYNOPSIS OF TESTIMONY
Petitioners will call several individuals to testify in support of the facts set forth herein
.
Information regarding same will be provided prior to hearing
.
THIS FILING SUBMITTED ON RECYCLED PAPER
-8
IV.
MOTION FOR WAIVER OF SIGNATURE REQUIREMENT
In a separate motion filed simultaneous with this Petition, Joliet respectfully requests that
the Illinois Pollution Control Board waive the requirement set forth at 35 Ill
. Adm. Code Section
102
.202 (f) that requires a petition for rulemaking to be signed by at least 200 persons
.
V.
STATEMENT OF RECENCY
The rule proposed in this Petition does not amend any existing IPCB rules but, instead,
requests that the IPCB adopt the proposed limits for copper and fluoride notwithstanding the
calculation of water quality based effluent limitations based upon the water quality standards set
forth in Part 302
.208, by establishing the new site-specific rules proposed herein
. The new site-
specific rule to be added would amend the most recent version of Part 303 published on the
IPCB's website, which was last amended at 31 111
. Reg
. 4440, effective February 27, 2007.
VI.
ATTACHMENTS
Attachments will be provided after petitioner has had the opportunity to meet with the
IEPA regarding the proposed site specific regulation and said documents will be presented at the
hearing in this matter.
VII. CONSISTENCY WITH FEDERAL LAW
The IPCB has previously recognized that it has authority and broad discretion consistent
with federal law, to adopt water quality and effluent standards that do not adversely affect the
designated uses of a water body
.
Generally, states must adopt water quality standards which
protect the designated use of interstate and intrastate
waters . 33 U .S .C
. § 1313 (c). The IPCB has adopted water
quality standards at 35 Ill. Adm
. Code § 302 .203 in
compliance with federal law
. States may also revise water
quality standards
. See 40 CFR § 131 .4.
THIS FILING SUBMITTED ON RECYCLED PAPER
-9
The IPCB has stated previously that federal directives give
it "broad discretion in determining the appropriate standard
of control to apply discharges from waste treatment plants
."
In re Site Specific exception to effluent standards for the
Illinois American Water Company, East St
. Louis
Treatment Plant (February 2, 1989), R85-1 1,
slip. op. at 10.
In the Matter of Petition of Illinois American Water Company's Alton
Public Water Supply Replacement Facility,
AS 99-66, 2000 WL 141967 at *25
(III
. PCB September 7, 2000) .
Therefore, the [PCB has authority pursuant to the broad discretion
provided it pursuant to federal directives, to determine that the site specific
effluent standards requested by Joliet is the appropriate standard to be applied,
and will be protective of the water bodies identified herein
.
VIII. CONCLUSION
Joliet respectfully requests that the IPCB grant the site specific relief
requested in this petition
. The water quality based effluent limits in Joliet's
NPDES permit ignore the actual amount of dilution of the waters to which Joliet's
Eastside WWTP's discharges . The site specific relief requested in this petition
addresses the discrepancy and provides the appropriate copper and fluoride
effluent limits that should apply to the Eastside WWTP
.
The conductivity studies have shown that the waters at this juncture are
those of the Des Plaines River and therefore, it is appropriate that the water
quality standards including the applicable mixing zone dilution formula be used to
calculate the need for water quality based effluent limit
. Further, there would be
no environmental impacts to the area in question or to the minimal recreational
uses.
THIS FILING SUBMITTED ON RECYCLED PAPER
-10
WHEREFORE, for the above and foregoing reasons, the Petitioner, Joliet
respectfully requests that the Illinois Pollution Control Board promulgate the site-
specific effluent limitation for copper and fluoride, as requested herein, and/or
grant such other relief as is appropriate and just .
Respectfully Submitted :
The City of Joliet
Dated: May 30, 2007
Roy M
. Harsch, Esq.
Yesenia Villasenor-Rodriguez, Esq .
DrinkerBiddleGardnerCarton
191 North Wacker Drive, Suite 3700
Chicago, Illinois 60606
(312) 569-1441 (Direct Dial)
(312) 569-3441 (Facsimile)
By:
On of its Attorneys
THIS FILING SUBMITTED ON RECYCLED PAPER
-11
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDCLERK'S
RECEIVEDOFFICE
IN THE MATTER OF
:
MAY 3.0
2007
STATE OF ILLINOIS
SITE SPECIFIC RULE FOR CITY OF
)
Pollution Control Board
JOLIET TREATMENT PLANT
)
FLOURIDE AND COPPER
)
R07- 4
DISCHARGES, 35 ILL
. ADM.
)
(Site-Specific Rulemaking
- Water)
CODE 303 .432
)
Petitioner,
)
APPEARANCE
Roy M
. Harsch and Yesenia Villasenor-Rodriguez of Drinker Biddle Gardner Carton
LLP, hereby enter their appearance in this m
on beha of Peti ioner, thA City of Jol t
.
Dated: May 30, 2007
Roy M. Harsch
Yesenia Villasenor-Rodriguez
DrinkerBiddleGardnerCarton
191 North Wacker Drive, Suite 3700
Chicago, Illinois 60606
(312)
(312)
569-1441
569-3441
(Direct
(Facsimile)Dial)
AA1
ly
!_ /' 'k V411
R: .rs
h t~Il.~
er -d~~
Ye nia Villasenor-Rodriguez
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL
CLERK'S
%
OFFICEI
V E D
IN THE MATTER OF
:
MAY 3.0
2007
SITE SPECIFIC RULE FOR CITY OF
STATE OF ILLINOIS
)
Pollution Control Board
JOLIET TREATMENT PLANT
)
.~~
FLOURIDE AND COPPER
)
DISCHARGES,
35 ILL
. ADM .
R07-_
)
(Site-Specific Rulemaking - Water)
CODE 303 .432
)
Petitioner,
)
MOTION TO WAIVE 200-SIGNATURE REOUIREMENT
NOW COMES, THE CITY OF JOLIET ("Joliet") by and through its attorneys,
DRINKER BIDDLE GARDNER CARTON LLP and requests that the Illinois Pollution Control
Board ("IPCB") waive the requirement to submit 200 signatures pursuant to 35 Ill
. Adm. Code
Section 102
.202 (g) in connection with its Petition for Site-Specific Regulations for copper and
fluoride
. In support of this Motion Joliet states as follows
:
Joliet operates a wastewater treatment plant ("Eastside WWTP") located in Joliet,
Illinois
. This treatment plant is known as its Eastside WWTP
. Joliet's Eastside WWTP serves
approximately 90,000 customers of which 26,163 are residential, 1,620 commercial and 57
industrial connections .
2 .
In connection with its Eastside WWTP, Joliet discharges effluent to Hickory
Creek at the juncture to the Des Plaines River pursuant to its National Pollutant Discharge
Elimination System Permit ("NPDES") No
. IL0022519
. Joliet's NPDES permit expired on
March 31, 2007
. However, Joliet timely filed its renewal NPDES permit
.
3 .
On March 30, 2007, Joliet entered into a consent decree by where its fluoride and
copper limits were amended in its NPDES permit for an interim period of time
. Currently, it is
THIS FILING SUBMITTED ON RECYCLED PAPER
technologically and economically unreasonable to require Joliet to abide by the original limits
imposed by its NPDES permit
. However, Joliet has been able to comply with the interim limits
imposed by the consent decree .
4.
Attached to this motion is a Petition for relief from the general water quality
standards set forth in 35 Ill
. Adm. Code 302 .208 (e) and (g) for copper and fluoride and the water
quality based effluent limitations found at 35 Ill
. Adm. Code 304 .105; and a request for a site
specific limit for copper of 0 .15 mg/I and a fluoride limit of 3
.5 mg/1 as monthly averages .
5.
The IPCB has waived the requirement for submission of 200 signatures in
connection with rule making of site specific regulation requests in the past including recently in,
In re
: Silbrico Corporation, R06-8 Ill
. PCB (September 1, 2005) .
6.
Granting this motion is in the public interest because Joliet's Eastside WWTP
serves a very important public and health interest to the residents, commercial and industrial
users.
WHEREFORE, The City of Joliet respectfully requests that the Illinois Pollution Control
Board grant this request to waive the requirement to submit 200 signatures in support of its
Petition for Site Specific Regulation
.
)i;3is
U ,
Y s is Villasenor-Rodriguez
Dated: May 30, 2007
Roy M. Harsch
Yesenia Villasenor-Rodriguez
DrinkerBiddleGardnerCarton
191 North Wacker Drive, Suite 3700
Chicago, Illinois 60606
(312)
(312)
569-1441
569-3441
(Direct
(Facsimile)Dial)
CH01/ 12509324 .4
THIS FILING SUBMITTED ON RECYCLED PAPER
-2
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached
Petition for Site-Specific
Regulations of Copper and Fluoride, Appearance of Roy
M. Harsch and Yesenia
Villasenor-Rodriguez, and Petition to Waive 200 Signatures
by First Class Mail, postage pre-
paid on May 30, 2007 upon the following
:
Illinois Pollution Control Board
Dorothy M
. Gunn
100 West Randolph
Suite 11-500
Chicago, IL 60601
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O
. Box 19276
Springfield, IL 62794-9276
Illinois Attorney General
Division Chief of Environmental Enforcement
Office of the Attorney General
188 West Randolph St . 20th
Floor
Chicago, IL 60601
Office of Legal Counsel
Illinois Department of Natural Resources
524 South Second Street
Springfield, IL 62701-1787
is Villasenor-Rodriguez
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
