RECEIVED
CLERK'S OFFICE
MAR 1 3 2008
STATE OF ILLINOIS
Pollution Control Board
Lisa Madigan
\ I I 0121N1.1 (1 NI 12 \I,
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
March 11, 2008
John T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 West Randolph
Chicago, Illinois 60601
Re:
People v. Dr. Charles R. Boyce
Dear Clerk:
Enclosed for filing please find the original and ten copies of a Notice of Filing, Entry of
Appearance and Complaint in regard to the above-captioned matter. Please file the originals and
return file-stamped copies to me in the enclosed, self-addressed envelope.
Thank you for your cooperation and consideration.
Very truly•rs,
500 South Second Street, Springfield, Illinois 62706 • (217) 782-1090 •
"rTY:
(217) 785-2771 • Fax: (2171 782-7046
oman
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
JLH/pk
Enclosures
IOU West Randolph Street, Chicago. Illinois 60601
?
•
(312) 814-3000
?
•?YIN: (312) 814-3374
•?
Fax: (312) 814-3806
1001 Fast
Main, Carbondale, Illinois 62901 • (618) 529-64011 •
TTY:
(618) 529-6403 • Fax: (618) 529-6416
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
-)odution air:roillicf3j
:01:alSrd
2(11)
PEOPLE OF THE STATE OF
ILLINOIS,
Complainant,
?
)
v..
?
?
PCB No.
_
(Enforcement)
DR. CHARLES R. BOYCE, d/b/a
CHATHAM VETERINARY CLINIC,
Respondent.?
)
NOTICE OF FILING
To:
?
Dr. Charles R. Boyce
d/b/a Chatham Veterinary Clinic
1500 North Main Street
Chatham, IL 62629
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 COMPLAINT, a copy of which is attached hereto and
herewith served upon you. Failure to file an answer to this Complaint within 60 days may have
severe consequences. Failure to answer will mean that all allegations in this Complaint will be
taken as if admitted for purposes of this proceeding. If you have any questions about this
procedure, you should contact the hearing officer assigned to this proceeding, the Clerk's Office
or an attorney.
MATTHEW J. DUNN, Chief
Environ?
stal Enforc ent/Asbestos
Litigation D
BY:
FURTHER, please take notice that financing may be available, through the Illinois
Environmental Facilities Financing Act, 20 ILCS 3515/1 (2006), to correct the pollution alleged in
the Complaint filed in this case.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
J. . Haman
(
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: March 11, 2008
2
J. Homan
Assistant Attorney General
RECEIVED
CLER$CS
OFFICE
MAR 1 3 2008
CERTIFICATE OF SERVICE
?
STATE
OF ILLINOIS
Pollution Control Board
I hereby certify that I did on March 11, 2008, send by certified 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, ENTRY OF APPEARANCE and
COMPLAINT:
To:?
Dr. Charles R. Boyce
d/b/a Chatham Veterinary Clinic
1500 North main Street
Chatham,IL 62629
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:?
John T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
This filing is submitted on recycled paper.
BEFORE THE ILLINOIS
0 C)
POLLUTION
I HA
P
CONTROL BOARD
PEOPLE OF THE STATE OF
ILLINOIS,
Complainant,
vs.
?
)?
PCB No.
eC
(Enforcement)
DR. CHARLES R. BOYCE, d/b/a
CHATHAM VETERINARY CLINIC,
Respondent.?
)
R
QatWED
en
'
OFFICE
MAR 13
2008
_STATE OF SLUNcts
Pollution Control Board
ENTRY OF APPEARANCE
On behalf of the Complainant, PEOPLE OF THE STATE OF ILLINOIS, J. L. HOMAN,
Assistant Attorney General of the State of Illinois, hereby enters her appearance as attorney of
record.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN,
Environ?
'tal Enfor
Lit?
'
on
?
sion
BY.
L, omen
nvironmental Bureau
A
ssistant Attorney General
500 South Second Street
Springfield, Illinois
62706
217/782-9031
Dated: March 11, 2008
ief
ment/Asbestos
RECEIVED
CLERK'S
OFFICE
MAR 13 2908
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Pollution
STATE
Confirm
OF ILUNO
PEOPLE OF THE STATE OF
?
Boa%
ILLINOIS,
Complainant,
?
)
vs.
?
No. Og
DR. CHARLES R. BOYCE, d/b/a
CHATHAM VETERINARY CLINIC,
?
)
Respondent.
COMPLAINT
The PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General of the State of Illinois, on her own motion and on behalf of the ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY, complains of the Respondent, Dr.
CHARLES BOYCE, d/b/a CHATHAM VETERINARY CLINIC, ("Boyce") as follows:
COUNT I
OPEN DUMPING VIOLATIONS
1.
?
This Complaint is brought on behalf of the People of the State of Illinois,
by Lisa Madigan, the Attorney General of the State of Illinois, on her own motion and at
the request of the Illinois Environmental Protection Agency ("Illinois EPA"), pursuant to
Section 31 of the Illinois Environmental Protection Act ("Act"), 415 ILCS 5/31 (2006).
1
2.
The Illinois EPA is an agency of the State of Illinois created by the Illinois
General Assembly in Section 4 of the Act, 415 ILCS 5/4 (2006), and charged,
inter alia,
with the duty of enforcing the Act.
3.
At all times relevant to this Complaint, the Respondent Dr. Charles R.
Boyce, d/b/a Chatham Veterinary Clinic ("Respondent" or "Boyce") is the owner and
operator of a facility located at 1500 North Main Street (the clinic) and 1300 North Main
Street (the garage and open lot), Chatham, Sangamon County, Illinois (collectively, the
"site"). Patricia Smith Boyce, wife of Dr. Charles Boyce, is the owner of the site.
4.
At all times relevant to this complaint, the Respondent has conducted
various operations at these sites. The Respondent calls his business at the site a
veterinary clinic.
5.
Section 21 of the Act, 415 ILCS 5/21(2006), provides in pertinent part as
follows:
No person shall:
(a)?
Cause or allow the open dumping of any waste.
(d)
Conduct any waste-storage, waste treatment, or waste-
disposal operation:
(2)
?
in violation of any regulations or
standards adopted by the Board under this
Act;...
(e)
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
2
meets the requirements of this Act and of regulations and
standards thereunder.
(p)
?
In violation of subdivision (a) of this Section, cause or allow the
open dumping of any waste in a manner which results in any of the
following occurrences at the at the dump site:
(1)?
fitter;
(3)?
open burning;
6.
Section 3.185 of the Act, 415 ILCS 5/3.185 (2006), provides:
"Disposal" means the discharge, deposit, injection, dumping, spilling,
leaking or placing of any waste or hazardous waste into or on any land or
water or into any well so that such waste or hazardous waste or any
constituent thereof may enter the environment or be emitted into the air or
discharged into any waters, including ground waters.
7.
Section 3.230 of the Act, 415 ILCS 5/3.230 (2006), provides in pertinent
part:
"Household waste" means any solid waste (including garbage, trash, and
sanitary waste in septic tanks) derived from households ....
8.
Section 3.305 of the Act, 415 ILCS 5/3.305 (2006), provides:
"Open dumping" means the consolidation of refuse from one or more
sources at a disposal site that does not fulfill the requirements of a
sanitary landfill.
9.
Section 3.385 of the Act, 415 ILCS 5/3.385 (2006), provides:
"Refuse" means waste.
10.
Section 3.445 of the Act, 415 ILCS 5/3.445 (2006), provides:
"Sanitary landfill" means a facility permitted by the Agency for the disposal
of waste on land meeting the requirements of the Resource Conservation
and Recovery Act, P.L. 94-580, and regulations thereunder, and without
creating nuisances or hazards to public health or safety, by confining the
refuse to the smallest practical volume and covering it with a layer of earth
3
at the conclusion of each day's operation, or by such other methods and
intervals as the Board may provide by regulation.
11.
Section 3.470 of the Act, 415 ILCS 5/3.470 (2006), provides:
"Solid waste" means waste.
12.
Section 3.480 of the Act, 415 ILCS 5/3.480 (2006), provides:
"Storage" means the containment of waste, either on a temporary basis or
for a period of years, in such a manner as not to constitute disposal.
13.
Section 3.535 of the Act, 415 ILCS 5/3.535 (2006), provides in pertinent
part as follows:
"Waste" means any garbage ... or other discarded material, including
solid, liquid, semi-solid or contained gaseous material resulting from
industrial, commercial, mining and agricultural operations, and from
community activities....
14.
Section 3.540 of the Act, 415 ILCS 5/3.540 (2006), provides:
"Waste disposal site" is a site on which solid waste is disposed.
15.
On June 15, 2006, the Illinois EPA inspected the 1300 and 1500 North
Main Street sites. Upon arrival at the clinic, the inspector observed used sharps in two
cardboard boxes. Mrs. Boyce informed the inspector that the clinic had not retained a
service to remove and dispose of its potentially infectious medical wastes. East of the
clinic in a hay field the inspectors observed landscape waste and wood boxes piled in
an area of recent open burning. Scalpel blades, intravenous needles and vials were
found among the ashes. In the garage located at 1300 North Main Street, the
inspectors observed unused medicines and sharps alongside various miscellaneous
equipment. East of the garage the inspectors observed another open burning area with
needles and glass vials among the ashes.
4
16.
A subsequent review of records at the Illinois EPA revealed no permit for
either site.
17.
Scalpel blades, intravenous needles, vials, sharps, along with other
general refuse are "refuse" and "waste" as those terms are defined under Section
5/3.385 and 5/3.535 of the Act, 415 ILCS 5/3.385 and 3.535(2006).
18.
Since June 15, 2006, and continuing through approximately October,
2007, the Respondent has caused or allowed the open dumping of refuse and waste at
the sites. By causing or allowing the open dumping of refuse and waste, the
Respondent has violated Section 21(a) of the Act, 415 ILCS 5/21(a)(2006).
19.
Since June 15, 2006, and continuing through approximately October,
2007, the Respondent has caused or allowed the open dumping of waste in a manner
that has resulted in the accumulation of litter at the site. By causing or allowing the
open dumping of waste in a manner which has resulted in litter, the Respondent has
violated Section 21(p)(1) of the Act, 415 ILCS 5/21(p)(1)(2006).
PRAYER FOR RELIEF
WHEREFORE, Complainant, the PEOPLE OF THE STATE OF ILLINOIS,
respectfully request that the Board enter an order against the Respondent,
A.
Authorizing a hearing in this matter at which time the Respondent will be
required to answer the allegations herein;
B.
Finding that Respondent has violated the Act and regulations as alleged
herein;
5
C.
Ordering Respondent to cease and desist from any further violations of
the Act and associated regulations;
D.
Assessing against Respondent a civil penalty of fifty thousand dollars
($50,000) for each violation of the Act, and an additional penalty of ten thousand dollars
($10,000) for each day during which each violation has continued thereafter;
E.
Awarding to Complainant its costs and reasonable attorney's fees; and
F.
Granting such other relief as the Board may deem appropriate.
COUNT II
OPEN BURNING
1.?
Complainant realleges and incorporates herein by reference paragraphs
1-17 of the above Count I as paragraphs 1-17 of this Count II.
18.?
Section 9 of the Act, 415 ILCS 5/9 (2006), provides, in pertinent part, as
follows:
No person shall:
(a)
?
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.
(c)?
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; except that the Board may adopt
regulations permitting open burning of refuse in certain cases upon
a finding that no harm will result from such burning, or that any
alternative method of disposing of such refuse would create a
6
safety hazard so extreme as to justify the pollution that would result
from such burning.
19.
Section 3.115 of the Act, 415 ILCS 5/3.115 (2006), provides that:
"Air pollution" is the presence in the atmosphere of one or more
contaminants in sufficient quantities and of such characteristics and
duration as to be injurious to human, plant, or animal life, to health,
or to property, or to unreasonably interfere with the enjoyment of
life or property.
20.
Section 3.300 of the Act, 415 ILCS 5/3.300 (2006), provides that "'[o]pen
burning' is the combustion of any matter in the open or in an open dump."
21.
Since on or before June 15, 2006, and continuing until approximately
October, 2007, the Respondent has caused, threatened or allowed emission of
contaminants into the environment so as to cause or tend to cause air pollution in
Illinois or so as to violate regulations or standards adopted by the Board under this Act,
in that the Respondent has caused or allowed the combustion of wastes, potentially
infectious medical wastes, and other refuse at the site.
22.
By causing, threatening or allowing the emission of contaminants into the
environment so as to cause or tend to cause air pollution in Illinois or so as to violate
regulations or standards adopted by the Board, the Respondent has violated Section
9(a) of the Act, 415 ILCS 5/9(a) (2006).
23.
Since June 15, 2006, and continuing through approximately October,
2007, the Respondent has caused or allowed the open dumping of wastes on site in a
manner resulting in open burning. By causing or allowing the open dumping of wastes
7
and refuse in a manner that has resulted in open burning, the Respondent has violated
Section 21(p)(3) of the Act, 415 ILCS 5121(p)(3)(2006).
24.?
Since June 15, 2006, and continuing through approximately October,
2007, the Respondent has caused or allowed the open burning of refuse at the sites.
By causing or allowing the open burning of refuse, the Respondent has violated Section
9(c) of the Act, 415 ILCS 519(c)(2006).
PRAYER FOR RELIEF
WHEREFORE, Complainant, the PEOPLE OF THE STATE OF ILLINOIS,
respectfully request that the Board enter an order against the Respondent,
A.
Authorizing a hearing in this matter at which time the Respondent will be
required to answer the allegations herein;
B.
Finding that Respondent has violated the Act and regulations as alleged
herein;
C.
Ordering Respondent to cease and desist from any further violations of
the Act and associated regulations;
D.
Assessing against Respondent a civil penalty of fifty thousand dollars
($50,000) for each violation of the Act, and an additional penalty of ten thousand dollars
($10,000) for each day during which each violation has continued thereafter;
E.
Awarding to Complainant its costs and reasonable attorney's fees; and
F.
Granting such other relief as the Board may deem appropriate.
COUNT III
POTENTIALLY INFECTIOUS MEDICAL WASTES VIOLATIONS
8
1.?
Complainant realleges and incorporates herein by reference paragraphs
1-17 of the above Count I as paragraphs 1-17 of this Count III.
18.?
Section 3.360 of the Act, 415 ILCS 5/3.360 (2006) provides in pertinent
part as follows:
(a)?
"Potentially infectious medical waste" means the
following types of waste generated in connection with
the diagnosis, treatment (i.e., provision of medical
services), or immunization of human beings or animals;
research pertaining to the provision of medical services;
or the production or testing of biologicals:
(1)?
Cultures and stocks. This waste shall include but
not be limited to cultures and stocks of agents
infectious to humans, and associated biologicals;
cultures from medical or pathological laboratories;
cultures and stocks of infectious agents from research
and industrial laboratories; wastes from the
production of biologicals; discarded live or
attenuated vaccines; or culture dishes and devices
used to transfer, inoculate, or mix cultures
(4)?
Used sharps. This waste shall include but not be
limited to discarded sharps used in animal or human
patient care, medical research, or clinical or
pharmaceutical laboratories; hypodermic, intravenous,
or other medical needles; hypodermic or intravenous
syringes; Pasteur pipettes; scalpel blades; or blood
vials. This waste shall also include but not be limited
to other types of broken or unbroken glass (including
slides and cover slips) in contact with infectious
agents.
(7
)
?
Unused sharps. This waste shall include but not be limited to the
following unused, discarded sharps: hypodermic, intravenous, or
other needles; hypodermic or intravenous syringes; or scalpel
blades.
9
19.
?
Section 56.1 of the Act, 415 ILCS 5/56.1 (2006), provides, in pertinent
part:
(A)?
No person shall:
(a)?
Cause or allow the disposal of any potentially infectious
medical waste. Sharps may be disposed in any landfill
permitted by the Agency under Section 21 of this Act to
accept municipal waste for disposal, if both:
(1)
the infectious potential has been eliminated from the
sharps by treatment; and
(2)
the sharps are packaged in accordance with Board
regulations
(c)?
Beginning July 1, 1992, cause or allow the delivery of any
potentially infectious medical waste to a person or facility for
storage, treatment, or transfer that does not have a permit
issued by the agency to receive potentially infectious
medical waste, unless no permit is required under
subsection (g)(1).
(g)
?
Beginning July 1, 1992, conduct any potentially infectious
medical waste treatment, storage, or transfer operation:
(1) without a permit issued by the Agency that specifically
authorizes the treatment, storage, or transfer of potentially
infectious medical waste. No permit is required under this
subsection (g) or subsection (d)(1) of Section 21 for any:
(A)?
Person conducting a potentially infectious
medical waste treatment, storage, or transfer
operation for potentially infectious medical
waste generated by the person's own activities
that are treated, stored, or transferred within
the site where the potentially infectious medical
waste is generated.
10
(B)
?
Hospital that treats, stores, or transfers only
potentially infectious medical waste generated
by its own activities or by members of its
medical staff.
(c)
?
Sharps collection station that is operated in
accordance with Section 56.7.
20.?
Section 1420.104 of the Board's Biological Materials Regulations, 35 III.
Adm. Code 1420.104, incorporates the statutory prohibitions of Section 56.1 of the Act,
415 ILCS 5/56.1 (2006).
21.?
Section 1420.105 of the Board's Biological Materials Regulations, 35
III.Adm.Code 1420.105, states in pertinent part as follows:
(c)?
A person who conducts a PIMW treatment, storage, or transfer
operation is required to obtain a permit from the Agency, except:
1)?
Any person conducting a PIMW treatment, storage, or
transfer operation for PIMW generated by the person's own
activities that are treated, stored, or transferred within the
site where the PIMW is generated;....
22.?
Section 1421.111 of the Board's Biological Materials Regulations, 35 III.
Adm. Code 1421.111, provides in pertinent part as follows:
a)
?
Generators shall segregate PIMW as follows:
1)
Sharps,
2)
Oversized PIMW, and
3)
All other.
b)?
PIMW mixed with other waste is regulated under this Subtitle as
PIMW and the mixture is not exempt from any other applicable
regulations.
23.?
Section 1421.121 of the Board's Biological Materials Regulations, 35 III.
Adm. Code 1421.121, provides in pertinent part as follows:
11
a)?
PIMW, except for oversized PIMW, must be placed in a container,
or a combination of containers. Such container must be:
1)
Rigid;
2)
Leak-resistant;
3)
Impervious to moisture;
4)
Of a strength sufficient to prevent tearing or bursting
under normal conditions of use or handling; and
5)
Sealed to prevent leakage during transit.
b)?
Sharps, unless rendered unrecognizable pursuant to 35 III. Adm.
Code 1422.126(a), must be packaged in a container, or a
combination of containers, that is puncture-resistant and meets the
requirements of subsection (a) of this Section.
24.?
Section 1421.131 of the Board's Biological Materials Regulations, 35
III.Adm. Code 1421.131 provides in pertinent part as follows:
a)?
The exterior of the outer package must be marked as follows prior
to shipment:
1)
?
The generator shall:
A)
Mark on two opposite sides of the outer package in
lettering that is readable at a minimum distance of
five (5) feet:
I)
?
The International Biohazard Symbol as shown
in Illustration A of this Part and the word
"Biohazard"; and
ii)?
The word "sharps", if the package contains
sharps.
B)
Mark with indelible ink in lettering that is legible on a
water-resistant label or tag securely attached to or
marked on the outer package:
12
I)?
The generator's name,
ii)
The generator's address, and
iii)
The generator's phone number (a 24-hour
phone number, if available).
2)?
The transporter shall mark with indelible ink in lettering that is
legible on a water-resistant label or tag securely attached to or
marked on the outer package:
A)
The transporter's name,
B)
The transporter's permit number,
C)
The transporter's address,
D)
The transporter's phone number (a 24-hour phone number,
if available), and
E)
For each PIMW package, the shipment date when PIMW
initially left the generator's site; or for each shipment, a
unique identification number which directly corresponds to
the initial date of shipment.
25.?
During the June 15, 2006, inspection, used sharps were observed in
cardboard boxes, and a representative of the Respondent informed the inspectors that
the clinic had not retained a service to remove and dispose of PIMW, nor did the
Respondent demonstrate the capacity to properly store, transport and dispose of PIMW
himself. Scalpel blades, intravenous needles and vials were observed among the
ashes from a previous burning in the adjacent field. The garage at 1300 North Main
Street contained unused medicines, sharps and miscellaneous equipment. East of that
garage was another open burning area where needles and glass vials were observed in
the ashes.
13
26.
Since on or before June 15, 2006, and continuing until approximately
October, 2007, the Respondent caused or allowed the storage and disposal of PIMW,
including used sharps, vials, scalpels, and other miscellaneous PIMW at both the 1300
and 1500 North Main Street locations. This PIMW was stored and/or disposed of in
containers that were not properly marked, leakproof, rigid, and impervious to moisture.
27.
By causing or allowing the open dumping, storage and disposal of PIMW,
including used sharps, vials, scalpels and other miscellaneous PIMW, by failing to
segregate, contain, and label the PIMW, the Respondent violated Section 56.1 of the
Act, 415 ILCS 5/56.1(2006), and Sections 1420.104, 1421.111, 1421.121 and 1421.131
of the Board's Biological Materials Regulations, 35 III. Adm. Code 1420.104, 1421.111
1421.121 and 1421 131.
28.
Subsequent review of Illinois EPA records revealed that the Respondents
did not have a permit to operate a PIMW treatment, storage, or transfer operation at the
sites.
29.
Since on or before June 15, 2006, and continuing until approximately
October, 2007, the Respondent conducted a PIMW treatment, storage or transfer
operation without a permit from the Agency.
30.
By conducting a PIMW treatment, storage, or transfer operation without a
permit from the Agency, the Respondents have violated Section 1420.105 of the
Board's Biological Materials Regulations, 35 II.Adm. Code 1420.105.
PRAYER FOR RELIEF
WHEREFORE, Complainant, the PEOPLE OF THE STATE OF ILLINOIS,
14
respectfully request that the Board enter an order against the Respondent,
A.
Authorizing a hearing in this matter at which time the Respondent will be
required to answer the allegations herein;
B.
Finding that Respondent has violated the Act and regulations as alleged
herein;
C.
Ordering Respondent to cease and desist from any further violations of
the Act and associated regulations;
D.
Assessing against Respondent a civil penalty of fifty thousand dollars
($50,000) for each violation of the Act, and an additional penalty of ten thousand dollars
($10,000) for each day during which each violation has continued thereafter;
E.
Awarding to Complainant its costs and reasonable attorney's fees; and
F.
Granting such other relief as the Board may deem appropriate.
Respectfully Submitted,
PEOPLE OF THE STATE OF ILLINOIS,
ex rel.
LISA MADIGAN, Attorney General
of the State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/ Asbestos
Litigation Division
By?
THOMAS DAVIS, Chief
Assistant Attorney General
Environmental Bureau
15
J. L. HOMAN
Assistant Attorney General
500 South Second Street
Springfield, Illinois 62706
217/782-9031
?
,
Dated 3// 60) cr
-
16
