INFORMATIONAL NOTICE!!!
REcEIvED
CLERK'S OFFICE
JUN 1 1 2007
Pollution
STATE OF
Control
ILLINOISBoar
U
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 .
MARCELO MENDOZA,
Respondent .
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK'S
RECEIVEDOFFICE
ADMINISTRATIVE CITATION
JUN 1
12007
To :
Marcelo Mendoza
East Side Mobile Home Village
1938 County Road
3000N- #10
Rantoul, Illinois 61866
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,
NOTICE OF FILING
Miche 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
Dated : June 7, 2007
THIS FILING SUBMITTED ON RECYCLED PAPER
Pollution
STATE OFControl
ILLINOIS
Board
AC D1
(IEPA No
. 165-07-AC)
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK'S OFFICE
ADMINISTRATIVE CITATION
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
V .
)
MARCELO MENDOZA,
)
Respondent .
)
AC
61
_~A
(IEPA No . 165-07-AC)
JUN 1 1 2007
STATE OF ILLINOIS
Pollution Control Board
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 Marcelo Mendoza ("Respondent") is the present owner of a facility located at
1938 County Road 3000N-#14, Rantoul, Champaign County, Illinois
. The property is commonly
known to the Illinois Environmental Protection Agency as Rantoul/East Side Mobile Home Village
.
2 .
That said facility is an open dump operating without an Illinois Environmental
Protection Agency Operating Permit and is designated with Site Code No
. 0198085002 .
3.
That Respondent has owned said facility at all times pertinent hereto
.
4.
That on May 17, 2007, Kenneth Keigley of the Illinois Environmental Protection
Agency's Champaign 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 Kenneth Keigley during the course of his May 17,
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).
(2)
That Respondent caused or allowed the open dumping of waste in a manner
resulting in the deposition of general construction or demolition debris ; or clean
construction or demolition debris, a violation of Section 21 (p)(7) of the Act, 41,5 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 July 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
2
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
cott, Director
wc.L
Illinois Environmental Protection gency
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
RECEIVEDCLERK'S
OFFICE
REMITTANCE FORM
JUN 1 1 2007
ILLINOIS ENVIRONMENTAL
)
STATE OF ILLINOIS
PROTECTION AGENCY,
)
Pollution Control Board
Complainant,
)
AC 61-G4
v
)
(IEPA No. 165-07-AC)
MARCELO MENDOZA,
)
Respondent.
FACILITY:
Rantoul/East Side Mobile Home Village SITE CODE NO
. : 0198085002
COUNTY
:
Champaign
CIVIL PENALTY : $3,000.00
DATE OF INSPECTION :
May 17, 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 .
5
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Open Dump Inspection Checklist
Latitude
: 40.31524
Longitude : -087 .08945
Collection Point Description
: Center of Site - error 27 .4
(Example : Lat . : 41 .26493
Long . : -89 .38294)
Collection Method
: GPS - Garmin GpsMap 76S
Responsible Party
Mailing Address(es)
and Phone Number(s):
Revised 10/ 5/2005
Mr. Marcelo Mendoza, Owner
East Side Mobile Home Village
1938 County Road 3000 N #14
Rantoul, IL 61866
phone number 217/892-9270
(Open Dump - 1)
SECTION
DESCRIPTION
ILLINOIS ENVIRONMENTAL PROTECTION ACT REQUIREMENTS
1, 9(a)
CAUSE, THREATEN OR ALLOW AIR POLLUTION
IN ILLINOIS
S
2
.
9(c)
CAUSE OR ALLOW OPEN BURNING
S
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
1113
6. 21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION :
(1)
Without a Permit
(2)
In Violation of Any Regulations or Standards Adopted by the Board
FN
7. 21 a
DISPOSE,
TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
WA T 1,, • T .
_
T • T N
•
T
.
•
;
I
-
~5
8.
21 '
CAUSE OR ALLOW THE OPEN DUMPING OF ANY WASTE
IN A
MANNER WHICH RESULTS
IN ANY • T
••
•
R
T .
(1)
Litter
(2)
Scavenging
(3)
Open Burning
N
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
(6
Standing or Flowing Liquid Discharge from the Dump Site
County :
Champaign
LPC# :
0198085002
Region
: 4 - Champaign
Location/Site Name :
Rantoul/East Side Mobile Home Village
Date :
05/17/2007 Time: From 2 :00 PM To 2 :30 PM
Previous Inspection Date
: 04/18/2002
Inspector(s) :
Kenneth Keigley
Weather
: sunny - 55 degrees
No
. of Photos Taken : # 16
Est. Amt . of Waste: 90
yds3
Samples Taken : Yes #
No
Interviewed :
No one present
Complaint #
: C07-180-CH
LPC #
0198085002
Inspection Date :
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
FAR
9. 55 a
NO PERSON SHALL :
Cause or Allow O.en
Dum'ine of An Used or Waste Tire
Fal
Cause or Allow O.en
Burnin, of An Used or Waste Tire
000
35 ILLINOIS ADMINISTRATIVE CODE REQUIREMENTS
SUBTITLE G
10 . 812 .101 a)
FAILURE TO SUBMIT AN APPLICATION FOR A PERMIT TO
DEVELOP AND
OPERATE A LANDFILL
11 . 722 .111
HAZARDOUS WASTE DETERMINATION
12. 808 .121
SPECIAL WASTE DETERMINATION
13. 809
.302 a
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 :
Illinois Environmental Protection Agency
Bureau of Land •Field
Operations Section *Champaign
0198085002 -
Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector
: Kenneth Keigley
Inspection Date
: May 17, 2007
Complaint Number : C07-180-CH
GIS Data : Latitude-N40
.31524°, Longitude-W-088 .089° error 27
.4 (Garmin GPSMap 76S)
General Comments
:
On May 17, 2007 at 02
:00 P.M.,
I conducted an inspection at the East Side Mobile Home Village
facility, located at 1938 County Road 3000 N -
#14, Rantoul, Illinoistl866, phone number 217/892-
9270
.
This inspection was conducted in response to a complaint that several mobile homes were removed
from the Mobile Home Park and pulled to the north side of the property, possibly to be burned
.
The purpose of this inspection was to determine regulatory status and evaluate compliance with the
Illinois Environmental Protection Act (Act) and Title 35 Illinois Administrative Code, Subtitle G
:
Land Pollution (Regulations)
. The inspection consisted of walking around the site, taking pictures,
and talking to Mr
. Marcelo Mendoza, the facility Owner, by telephone, on May 4, 2007, prior to the
inspection. The weather was sunny, the temperature 55 degrees
.
Background :
The facility was initially inspected on April 18, 2002, in response to a complaint that mobile homes,
tires, and other refuse was being open burned on site
. During the inspection widespread open
dumping of and open burning of refuse was observed
. An administrative Citation Warning Notice
dated May 14, 2002, was sent to Mr
. Marcelo Mendoza, the Owner of the Mobile Home Park
. Mr.
Mendoza replied in a letter received on June 5, 2002, saying that residents of the Mobile Home Park
were dumping on site without permission and that he would take steps to stop it and to remove and
dispose of the refuse by August 20, 2002 . Mr
. Mendoza's proposal was accepted by the Agency in a
letter dated June 11, 2002
.
I
Illinois Environmental Protection Agency
Bureau of Land •
Field Operations Section, Champaign
0198085002 - Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector
: Kenneth Keigley
Inspection Date : May 17, 2007
Complaint Number : C07-180-CH
GIS Data: Latitude-N40
.31524°, Longitude-W-088.089° error 27
.4 (Garmin GPSMap 76S)
Inspection :
When I arrived at the Mobile Home Park I drove to the north side of the property to an undeveloped
area
. I saw a large pile of refuse measuring approximately 60' x 60' x 2' which contained refuse in
the form of vinyl siding, dimensional lumber, asphalt shingles, plastic containers, metal, appliances,
mattresses, wooden and upholstered furniture, and used tires (see photos #1 through #7, #11, and
#13).
I also saw a large pile of soil-like material measuring approximately 8'x 25'x 4' that contained small
pieces of refuse consisting of plastic, glass, metal, and wood (see photo #2)
.
Just north of this main pile of refuse I saw another pile of refuse measuring approximately 10' x 1' x
2' that contained heat scorched metal, scraps of partially burned dimensional lumber, furniture, and
wiring (see photos #8, #10, #14, and #15)
. There was a large metal container that contained broken
glass and apparent ashes from open burning as well as small pieces of plastic, metal, and some
apparent landscape waste (see photos #9, #10, #14, and #15)
. The metal container also had ashes
around the base, apparently filtering from holes in the bottom of the container (see photo #14)
.
At the north east end of the property I saw a pile of approximately 100 used tires, some of them
containing water (see photo #12)
. 1 also noticed at least five used tires in the largest refuse pile (see
photo #11) and another 14 used tires sitting on a trailer on the west side of the field (see photo #16)
.
There were also three apparently uninhabited mobile homes, one partially dismantled (see photos #8
and #10) .
I left the site at 2:30 P.M.
Subsequent to receiving a complaint, On May 4, 2007 1 had a telephone discussion with Mr
.
Mendoza I advised him that none of the mobile homes could be open burned and must be properly
disposed .
2
Illinois Environmental Protection Agency
Bureau of Land* Field Operations Section *Champaign
0198085002 -
Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector: Kenneth Keigley
Inspection Date : May 17, 2007
Complaint Number : C07-180-CH
GIS Data: Latitude-N40
.31524°, Longitude-W-088.089°
error 27 .4 (Garmin GPSMap 76S)
Apparent violations observed during this inspection :
Environmental Protection Act . 415 ILCS 5/1 et
. seq . (formerly Ill . Rev. Stat
. Ch. 111 1/2, 1001
et. seq .) {hereinafter called the "Act"}
#1
Pursuant to Section 9(a) of the Act, no person shall cause or threaten or allow the
discharge or emission of any contaminant into the environment in any State so as to cause
or tend to cause air pollution in Illinois, either alone or in combination with contaminants
from other sources, or so as to violate regulations or standards adopted by the Board
under this Act .
A violation of Section 9(a) is alleged for the following reason
: evidence of open burning
of refuse, which would cause or tend to cause air pollution in Illinois was observed
during the inspection.
#2
Pursuant to Section 9(c) of the Act, no person shall cause or allow the open burning of
refuse, conduct any salvage operation by open burning, or cause or allow the burning of
any refuse in any chamber not specifically designed for the purpose and approved by the
Agency pursuant to regulations adopted by the Board under this Act
.
A violation of Section 9(c) is alleged for the following reason
: evidence of open burning
of refuse was observed during the inspection
.
#3
Pursuant to Section 21 (a) of the Act, no one shall cause or allow the open dumping of
any waste
.
A violation of Section 21 (a) is alleged for the following reason
: waste was open dumped
on the site.
3
Illinois Environmental Protection Agency
Bureau of Land •F
ield Operations Section* Champaign
0198085002
- Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector
: Kenneth Keigley
Inspection Date
: May 17, 2007
Complaint Number
: C07-180-CH
GIS Data
: Latitude-N40 .31524°, Longitude-W-088
.089° error 27
.4 (Garmin GPSMap 76S)
#4
Pursuant to Section 21
(d)(2) of the Act, no one shall conduct any waste storage, waste
treatment, or waste disposal operation in violation of any Regulations or Standards
adopted by the Board .
A violation of Section 21(d)(2) is alleged for the following reason
:
waste was disposed
at this facility in apparent violation of Regulations adopted by the Board
.
#5
Pursuant to Section 21(e) of the Act, no person shall dispose, treat, store or abandon
any waste or transport any waste into this State for disposal, treatment, storage, or
abandonment, except at a site or facility which meets the requirements of this Act and
of regulations and standards thereunder .
A violation of Section 21(e) is alleged for the following reason
: wastes were disposed
of at this site which does not meet the requirements of the Act and Regulations
thereunder.
#6
Pursuant to Section 21
(p)(1) of the Act, no one shall cause or allow the open dumping of
any waste in a manner, which results in litter at the dumpsite
.
A violation of Section 21(p)(1) is alleged for the following reason
:
waste and used tires
were open dumped at this site resulting in litter
.
#7
Pursuant to Section 21(p)(3) of the Act, no one shall cause or allow the open dumping of
any waste in a manner, which results in open burning
.
A violation of Section 21(p)(3) is alleged for the following reason
: waste
was open
dumped at this site resulting in open burning.
#8
Pursuant to Section 21(p)(7) of the Act, no one shall cause or allow the open dumping of
any waste in a manner, which results in deposition of general or clean construction or
demolition debris at the site .
4
Illinois Environmental Protection Agency
Bureau of Land •Field Operations Section *Champaign
0198085002 - Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector: Kenneth Keigley
Inspection Date : May 17, 2007
Complaint Number : C07-180-CH
GIS Data: Latitude-N40 .31524°, Longitude-W-088 .089° error 27 .4 (Garmin GPSMap 76S)
A violation of Section 21(p)(7) is alleged for the following reason : waste was open
dumped at this site resulting in deposition of general or clean construction or
demolition debris at the site.
#9
Pursuant to Section 55(a)(1) of the Act, no one shall cause or allow the open dumping of
any used or waste tire .
A violation of Section 55(a)(1) is alleged for the following reason :
used and/or waste
tires were open dumped at this site .
#10
Pursuant to Section 55(a)(3) of the Act, no one shall, except at a tire storage site which
contains more than 50 used tires, cause or allow the storage of any used tire unless the tire
is altered, reprocessed, converted, covered, or otherwise prevented from accumulating
water.
A violation of Section 55(a)(3) is alleged for the following reason : used tires at this site
were not prevented from accumulating water .
5
0198085002 - Champaign County
Rantoul/East Side Mobile Home Village
FOS
Inspector
: Kenneth Keigley
Date: May 17 , 2007
Not to Scale
Illinois Environmental Protection Agency
Bureau of Land
• Field Operations Section •
Champaign Region
16
1
Trailer with used
tires
ZZ
Site Sketch
Field
13
1
Mobile Home Park
W
Used Tire Pile
s
I
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 - Champaign County
Rantoul/EastSide Mobile Home Village
FOS File
DATE: 05-17-2007
TIME: 02 :10 PM
DIRECTION: Northwest
PHOTO by: Kenneth Keigley
PHOTO FILE NAME
:
0198085002 -05172007-001 .jpg
COMMENTS : Pile of refuse,
includes vinyl siding, asphalt
shingles, dimensional lumber, soil
contaminated with refuse
.
DATE: 015-17-2007
TIME: 02 :11 PM
DIRECTION: Northwest
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 -05172007-002 .jpg
COMMENTS : large pile of
apparent soil mixed with refuse
consisting of paper, scraps of
dimensional lumber, shingles,
plastic .
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 - Champaign County
RantoulIEastSide Mobile Home Village
FOS File
DATE: 05-17-2007
TIME: 02:11 PM
DIRECTION: North
PHOTO by: Kenneth Keigley
PHOTO FILE NAME:
0198085002 --05172007-003 . jpg
COMMENTS: Second pile of refuse
consisting of dimensional lumber,
landscape timbers, vinyl siding,
and a couch.
DATE: 015-17-2007
TIME: 02 :11 PM
DIRECTION: Northeast
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 -05172007-004 .jpg
COMMENTS : Third pile of refuse
consisting of plastic coolers,
Styrofoam, and dimensional
lumber.
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002
-
Champaign County
Rantoull astSide Mobile Home Village
FOS File
DATE: 05-17-2007
TIME
: 02
:12 PM
DIRECTION : North
PHOTO by : Kenneth Keigley
PHOTO FILE NAME
:
0198085002 05172007-005.jpg
COMMENTS : Third refuse pile
with plastic containers metal,
dimensional lumber, and used tires
included.
DATE: 015-17-2007
TIME: 02 :12 PM
PHOTO by: Kenneth Keigley
PHOTO FILE NAME:
0198085002 -05172007-006 .jpg
COMMENTS: Same refuse pile as
number photo 5, with metal,
couches, mattresses, and used
tires.
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 - Champaign County
Rantoul/EastSide Mobile Home Village
FOS File
DATE: 05-17-2007
TIME: 02 :12 PM
DIRECTION : North
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 . 05172007-007.jpg
COMMENTS : Pile of refuse with
metal, dimensional lumber,
furniture, and used tires.
DATE: 015-17-2007
TIME: 02:113 PM
DIRECTION: Northeast
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 -05172007-008 .jpg
COMMENTS: Pile of refuse with
metal, charred dimensional
lumber, and couch .
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 - Champaign County
RantoullEast Side Mobile Home
Village
FOS File
DATE: 05-17-2007
TIME: 02 :13 PM
DIRECTION : East
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 -y 05172007-009
.jpg
COMMENTS : Inside metal
container showing broken glass,
small pieces of plastic, and ashes
from burning .
DATE: 015-17-2007
TIME: 02:13
PM
DIRECTION : North
PHOTO by: Kenneth Keigley
PHOTO FILE NAME:
0198085002 --05172007-010 .jpg
COMMENTS: Pile of refuse
showing metal bin depicted in
photo #9 with metal, ashes from
open burning, pieces of charred
dimensional lumber, and small
pieces of metal and plastic .
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 - Champaign County
RantoullEast Side Mobile Home Village
FOS File
DATE: 05-17-2007
TIME: 02 :18 PM
DIRECTION
: Southwest
PHOTO by : Kenneth Keigley
PHOTO FILE NAME
:
0198085002 -05172007-011 .jpg
COMMENTS : Pile of refuse
consisting of used tires, wooden
furniture, metal, furniture, and
plastic.
DATE: 015-17-2007
TIME: 02 :19 PM
DIRECTION
: Northeast
PHOTO by : Kenneth Keigley
PHOTO FILE NAME:
0198085002 -05172007-012
.jpg
COMMENTS: Pile of
approximately 100 used tires and
pieces of plastic plumbing .
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection
Agency
Bureau of Land
LPC # 0198085002 - Champaign County
Rantoul/EastSide Mobile Home Village
FOS File
DATE: 05-17-2007
TIME: 02:21 PM
DIRECTION
: Southwest
PHOTO by : Kenneth Keigley
PHOTO FILE NAME
:
0198085002 -05172007-013 .jpg
COMMENTS: Photo of waste pile
depicted in previous photos
.
DATE: 015-17-2007
TIME: 02:22 PM
DIRECTION : Northwest
PHOTO by
: Kenneth Keigley
PHOTO FILE NAME:
0198085002 -
0 51 72007-014 .jpg
COMMENTS: Second photo of
metal bin showing ashes, heat
scorched metal, and charred
dimensional lumber .
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0198085002 -
Champaign County
Rantoul/EastSide Mobile Home Village
FOS File
DATE : 05-17-2007
TIME: 02 :22 PM
DIRECTION
:
Northwest
PHOTO by
: Kenneth Keigley
PHOTO FILE NAME
:
0198085002 -05172007-015
.jpg
COMMENTS
: Refuse pile near
metal bin showing metal, furniture,
scraps of dimensional lumber, and
plastic.
DATE : 015-17-2007
TIME: 02 :23 PM
DIRECTION: South
PHOTO by
: Kenneth Keigley
PHOTO FILE NAME
:
0198085002 -05172007-016 .jpg
COMMENTS
: Trailer with
approximately 14 used tires piled
on it.
DIGITAL PHOTOGRAPHS
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AFFIDAVIT
IN THE MATTER OF
:
)
IEPA DOCKET NO .
Respondent
)
Affiant, Kenneth Keigley, being first duly sworn, voluntarily deposes and states as follows
:
I .
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 May 17, 2007, between 02 :00 P
.M . and 02 :30 P.M., Affiant conducted an inspection
of the site in Champaign County, Illinois, known as the East Side Mobile Home Village,
Illinois Environmental Protection Agency Site No
. 0198085002.
3
. Affiant inspected said East Side Mobile Home Village site by an on-site inspection, which
included walking the site .
4
. As a result of the activities 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 the East Side Mobile Home Village site .
Subscribed and Sworn to before me
this2007z
.
y\dday
of tla
Notary Public
OFFICIAL SEAL
SHARON L BARGER
NOTARY PUBLIC -STATE OF ILLINOIS
MY COMMISSION EXPIRES:09/16/10
PROOF OF SERVICE
I hereby certify that I did on the 7th day of June 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 :
Marcelo Mendoza
East Side Mobile Home Village
1938 County Road 3000N- # 10
Rantoul, Illinois 61866
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
~kLO-~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
