ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1 021 NORTH GRAND AVENUE EAST, P.O.
Box 19276, SPRINGFIELD, ILLINOIS
62794-9276 - ( 217) 782-3397
JAMES R.
THOMPSON CENTER, 100 WEST RANDOLPH, SUITE
11-300, CHICAGO, IL 60601 - (312) 814-6026
ROD
R.
BLAGOJEVICH, GOVERNOR?
DOUGLAS P. SCOTT, DIRECTOR
ORIGI \IAL
RECIEIV'D
CLERK;S OFFICE
APR 1 1
2008
STATE OF ILLINOIS
Pollution Control Board
(217) 782-9817
TDD: (217) 782-9143
April 8, 2008
John Therriault, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Re:
Illinois Environmental Protection Agency v. Joseph Cosentino and Rob Pinski
IEPA File No.52-08-AC; 1450200009
Perry County
Dear Mr.Therriault:
Enclosed for filing with the Illinois Pollution Control Board, please find the original and nine
true and correct copies of the Administrative Citation Package, consisting of the Administrative
Citation, the inspector's Affidavit, and the inspector's Illinois Environmental Protection Agency
Open Dump Inspection Checklist, issued to the above-referenced respondent(s).
On this date, a copy of the Administrative Citation Package was sent to the Respondent(s) via
Certified Mail. As soon as I receive the return receipt, I will promptly file a copy with you, so
that the Illinois Pollution Control Board may calculate the thirty-five (35) day appeal period for
purposes of entering a default judgment in the event the Respondent(s) fails or elects not to file a
petition for review contesting the Administrative Citation.
If you have any questions or concerns, please do not hesitate to contact me at the number above.
Thank you for your cooperation.
Michelle M. Ryan
Assistant Counsel
Enclosures
ROCKFORD -
4302 North Main Street, Rockford, IL 61103 – (815) 987-7760 • DES PLAINES - 9511 W. Harrison St., Des Plaines, IL 60016 – (847) 294-4000
ELGIN - 595 South State, Elgin, IL 60123 – (847) 608-3131
?• PEORIA - 5415 N. University St., Peoria, IL 61614 – (309) 693-5463
BUREAU OF LAND - PEORIA -
7620 N. University St., Peoria, IL 61614 – (309) 693-5462 •
CHAMPAIGN -
2125 South First Street, Champaign, IL 61820 – (217) 278-5800
SPRINGFIELD -
4500 S. Sixth Street Rd., Springfield, IL 62706 – (217) 786-6892 • COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 – (618) 346-5120
MARION - 2309 W. Main St., Suite 116, Marion, IL 62959 – (618) 993-7200
PRINTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOAR
CLERKS
leCeiVE
OFFICE
ADMINISTRATIVE CITATION
APR 1 1 2008
STATE OF ILLINOIS
Pollution Control Board
(IEPA No. 52-08-AC)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
v.
JOSEPH COSENTINO and ROB PINSKI, )
Respondents.
)
NOTICE OF FILING
To:
Joseph Cosentino
Rob Pinski
1043 N. Walnut Street
529 South Madison Street
St. Johns, IL 62832
DuQuoin, IL 62832
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,
Michelle . Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated: April 8, 2008
THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIIVTD
C
LERK'$ OFFICE
ADMINISTRATIVE CITATION
?
APR 1 1 2008
STATE OF ILLINOIS
Pollution Control Board
AC
0
e>
(IEPA No. 52-08-AC)
Respondents.
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 (2006).
FACTS
1.
That Joseph Cosentino is the present owner and Rob Pinski is the current operator
("Respondents") of a facility located at 1043 N. Walnut Street, St. Johns, Perry County, Illinois. The
property is commonly known to the Illinois Environmental Protection Agency as St. Johns/Cosentino-
P.and E. Construction, Pinski.
2.
That said facility is an open dump operating without an Illinois Environmental
Protection Agency Operating Permit and is designated with Site Code No. 1450200009.
3.
That Respondents have owned/operated said facility at all times pertinent hereto.
4.
That on February 29, 2008, Sheila Williams of the Illinois Environmental Protection
Agency's Marion Regional Office inspected the above-described facility. A copy of
her inspection
report setting forth the results of said inspection is attached hereto and made a part hereof.
PROTECTION AGENCY,
?
ORIGINiAL
ILLINOIS ENVIRONMENTAL
Complainant,
?
)
v.?
)
JOSEPH COSENTINO and ROB PINSKI,
?
)
VIOLATIONS
Based
upon direct
observations made
by Sheila Williams during the
course
of her
February
29,
2008 inspection of the above-named facility, the
Illinois
Environmental
Protection
Agency
has
determined
that
Respondents
have violated the
Illinois Environmental Protection
Act
(hereinafter,
the
“Act”) as follows:
(1)
That Respondents 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
5121(p)(l)
(2006).
(2)
That Respondents
caused or allowed the open dumping
of
waste in
a manner
resulting in open burning, a violation
of Section 21(p)(3)
of the Act,
415
ILCS
5/21 (p)(3) (2006).
(3)
That Respondents caused or allowed the open dumping of waste in
a
manner
resulting
in deposition of clean
or general construction
or demolition
debris,
a
violation of Section
21 (p)(7) of the Act, 415 ILCS 5/21 (p)(7)(2006).
CIVIL PENALTY
Pursuant to
Section 42(b)(4-5)
of
the
Act, 415 ILCS 5/42(b)(4-5)
(2006),
Respondents
are
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 Four Thousand Five Hundred Dollars
($4,500.00).
If
Respondents
elect
not to petition the Illinois
Pollution Control Board, the statutory civil
penalty
specified
above shall be due and
payable
no laterthan May 15,2008, unless otherwise
provided
by
order of
the Illinois Pollution
Control
Board.
If
Respondents elect to contest this
Administrative Citation
by
petitioning
the Illinois
Pollution
2
Control Board in accordance with Section 31.1 of the Act, 415 ILCS 5/31.1 (2006), and if the Illinois
Pollution Control Board issues a finding of violation as alleged herein, after an adjudicatory hearing,
Respondents 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) (2006), if Respondents fail
to petition or elect 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, Respondents 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, Respondents 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 Respondents 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 Respondents in Circuit Court to collect said penalty and/or hearing costs, plus any interest
accrued.
3
P
6- ),-.75
Dougla P. Scott, Director
Illinois Environmental Protection Agency
PROCEDURE FOR CONTESTING THIS
ADMINISTRATIVE CITATION
Respondents have the right to contest this Administrative Citation pursuant to and in
accordance with Section 31.1 of the Act, 415 ILCS 5/31/1 (2006). If Respondents elect to contest
this Administrative Citation, then Respondents 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 Respondents.
Date:
41 VOS
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
REMITTANCE FORM
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
v.
Complainant,
?
?
ORIGINAL)
)
)
JOSEPH COSENTINO and ROB PINSKI,
?
)
lECEIVED
CLERK'S OFFICE
APR 1 1 2008
STATE OF ILLINOIS
Pollution Control Board
A
?
C?
'
4?43
(IEPA No. 52-08-AC)
Respondents.
FACILITY:
?
St. Johns/Cosentino- P&E Construction, Pinski
SITE CODE NO.:
?
1450200009
COUNTY:
?
Perry
CIVIL PENALTY:?
$4,500.00
DATE OF INSPECTION:
?
February 29, 2008
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
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR 1 1 2008
STATE OF ILLINOIS
Pollution Control Board
v.
Complainant,
OR S1NAL
Respondent.
)
)
/k
•?-(4
IEPA DOCKET NO.
)
)
)
)
AFFIDAVIT
Affiant, Sheila Williams, 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 February 29, 2008, between 12:40 p.m. and 1:05 p.m., Affiant conducted an
inspection of a disposal site operated by Joseph Cosentino and Robert Pinski, located in Perry
County, Illinois, and known as St. Johns/Cosentino-P. and E. Construction, Pinski by the Illinois
Environmental Protection Agency. Said site has been assigned site code number 1450200009 by
the Agency.
3.
Affiant inspected said St. Johns/Cosentino-P. and E. Construction, Pinski site by an
on-site inspection which included walking and photographing the site.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Notary Public
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 St. Johns/Cosentino-P. and E. Construction, Pinski.
Subscribed and Sworn to before me
thi ?
day of 771.6
,
-1,4
4
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SRW:jkb/34881/03-18-08
?
.1V35 IVI01330”
ILLINOIS ENVIRONMENTAL PROTECTION AGENManyF
v FD
E
Open Dump Inspection Checklist
APR 1 1 2008
County:
?
Perry
?
LPC#:?
1450200009?
Region
STAkednfilaINOIS
Location/Site Name:?
St. Johns/Cosentino - P. And E. Construction, Pinski?
Pollution Control
Board
Date:
?
02/29/2008 Time: From 12:40 PM To 1:05 PM?
Previous Inspection Date:
Inspector(s):?
S.
Williams & R. Mileur?
Weather: sunny, –55
No. of Photos Taken: #
?
18?
Est. Amt. of Waste: 43?
yds3 Samples Taken: Yes #
?
No
Interviewed:?
Ron Darnell, Officer & Rob Pinski, RP?
Complaint #: 08-147
Latitude: 38.02826
?
Longitude: -089.24184 Collection Point Description: Dump Location -
(Example:
?
Lat.: 41.26493
Long.: -89.38294)?
Collection Method: GPS -
Responsible Party
Mailing Address(es)
and Phone Number(s):
Joseph Cosentino
1043 N. Walnut St.
St. Johns, ILr•
6283
1J
RIOINAt
Robert Pinski
529 S. Madison
DuQuoin, IL
62832
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
ri
4.
12(d)
CREATE A WATER POLLUTION HAZARD
5.
21(a)
CAUSE OR ALLOW OPEN DUMPING
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
7.
21(e)
DISPOSE, TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
WASTE INTO THE STATE
AT/TO
SITES NOT MEETING 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
(2)
Scavenging
(3)
Open Burning
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
(6)
Standing or Flowing Liquid Discharge from the Dump Site
q
Revised 6/21/2007
(Open Dump - 1)
LPC
#
1450200009
Inspection Date:
?
02/29/2008
(
7
)
Deposition of: (i)
General Construction or Demolition Debris as defined in Section
3.160(a); or (ii) Clean Construction or Demolition Debris as defined in Section 3.160(b)
a
9.
55(a)
NO PERSON SHALL:
(2)(1)
Cause
Cause or
or
Allow
Allow Open
Open Dumping
Burning of
of
Any
Any
Used
Used
or
or
Waste
Waste
TireTire
ri
q
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
q
12.
808.121
SPECIAL WASTE DETERMINATION
q
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
q
OTHER REQUIREMENTS
14.
APPARENT VIOLATION OF:
(
q
)
PCB;
(
q
)
CIRCUIT COURT
CASE NUMBER:?
ORDER ENTERED ON:
ri
15.
OTHER:
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 6/21/2007
(Open Dump - 2)
NARRATIVE INSPECTION REPORT
Date: February 29, 2008
?
Inspector: Sheila Williams
Site Code: 1450200009
?
County: Perry
Site Name: St. Johns/Cosentino – P. And E. Construction, Pinski
Time: 12:40 P.M. – 1:05 P.M.
GENERAL REMARKS
On February 29, 2008 Rob Mileur & I conducted an inspection of the St. Johns/
Cosentino – P. And E. Construction, Pinski site. The inspection was conducted as the
result of a complaint that a house was being demolished in DuQuoin & the waste was
being relocated to a site at 1043 N. Walnut St. in St. Johns where it was being burned.
The complainant indicated Rob Pinski, Billy Davis & two others were taking part in the
demolition. The complainant referred me to Ron Darnell who is the DuQuoin Animal &
Health Officer who was at the demolition site.
We initially went to the demolition site in DuQuoin. Some of the key people present
were Rob Pinski, Billy Davis, Ron Darnell, Dale Spence (Public Works Director), Hilda
Cook (owner), Kathy Epplin (neighbor to property & friend of Mrs. Cook) & Jason Van
Zandt (Perry County Solid Waste Management). I was informed by Officer Darnell that
the City had condemned the house. Mr. Pinski told me they had taken some of the
debris to the site in St. Johns, but they had not burned any of it. He said his brother
had been working on another demolition project & he had taken some of the waste to
the site in St. Johns where he burned it. Mrs. Cook provided me with two documents.
The first was a contract signed by Rob Pinski & Hilda Cook. "P. And E. Construction
542-4385" was written at the top of the page. The 618-542-4385 is listed as the
1
phone number for Billie & Lisa Davis at 622 E. Park St. in DuQuoin. The contract stated
that after tearing down four rooms of the house, the front porch & foundation, the
contractor was to clean the yard, remove all debris from the property & waste materials
were to be taken to the Perry County Landfill. The second document was a letter dated
February 29, 2008, addressed to Rob Pinski, care of P. And E. Construction from Aaron
Atkins, an attorney representing Mrs. Cook. Mrs. Cook explained that when she
became aware of the fact that the contractor was not hauling the debris to the
[permitted] landfill, she immediately contacted Mr. Atkins. According to the letter, Mr.
Pinski asked Mrs. Cook to rent a dumpster for the waste after the contract had been
signed. Mr. Atkins explained that in accordance with the contract, it is Mr. Pinski's
obligation to take the waste to the [permitted] landfill & if Mr. Pinski wished to rent a
dumpster, he had Mrs. Cook's permission but it would been done at his own expense.
Mr. Atkins went on to say that Mr. Pinski is to provide Mrs. Cook with receipts from the
landfill for all loads of waste. Mrs. Cook & Ms. Epplin said upon Mr. Pinski reading the
letter from Mr. Atkins, Mr. Pinski tore it up. No apparent violations were observed at
the demolition site in DuQuoin. We next went to the dump site in St. Johns.
Three areas of apparent violations were observed. These have been designated as
Area A, Area B & Area C. Among the waste in Area A were vinyl siding, demolition
wood, plastic, ash & metal. It was apparent open burning had taken place in Area A
due to the presence of charred material & ash in the central portion of the pile. Also,
some of the grass on the outer perimeter was charred as well as some tree branches
above the burn pile. Area A was estimated to be approximately 11 cubic yards
(20'x10'x1.5') in size. Area B consisted of pieces of dimensional lumber with metal
protruding from them. Area B was estimated to be approximately two cubic yards
(7.5'x5'x1.5') in size. Waste in Area C included, but was not limited to, a bowling ball,
mail addressed to Antony Cosentino, demolition wood, shingles (some were charred),
metal, broken glass, concrete & siding. Due to charred debris & charred ground, it was
apparent waste had been burned in Area C. Area C was estimated to be approximately
2
30 cubic yards (40'x10'x2') in size. Later on February 29, 2008 I received an e-mail
from Officer Darnell. There were pictures attached that showed Area A in flames.
According to the Perry County Supervisor of Assessments Office, Joseph Cosentino of
St. Johns receives the real estate tax bill for this piece of property on which this site is
located.
3
N
West Park St.
house being
demolished
house
535 West
Park
St. Johns/Cosentino — P. And E. Construction, Pinski
#1450200009 — Perry County
Not to Scale
Locations are Approximate
2/29/2008
fiMall1=111■1111■=g17
File Names: 1450200009"
,
02292008 - [Exp. #].jpg
Illinois Environmental Protection Agency
?
LPC #1450200009 – Perry County
Bureau of Land?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
Date: 2/29/2008
Time: 12:15 P.M.
Direction: southeast
Photo by: S. Williams
Exposure #: 001
Comments: house
being demolished
Date: 2/29/2008
Time: 12:16 P.M.
Direction: southeast
Photo by: S. Williams
Exposure #: 002
Comments: license
plate of truck driven
by Rob Pinski
Page 1 of 9
Illinois Environmental Protection Agency
?
LPC #1450200009 – Perry County
Bureau of Land?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009 r
"02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:17 P.M.
Direction: northwest
Photo by: S. Williams
Exposure #: 003
Comments: house
being demolished
Date: 2/29/2008
Time: 12:20 P.M.
Direction: southwest
Photo by: S. Williams
Exposure #: 004
Comments: debris
from house
Page 2 of 9
Illinois Environmental Protection Agency
?
LPC #1450200009 – Perry County
Bureau of Land?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009"02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:21 P.M.
Direction: southwest
Photo by: S. Williams
Exposure #: 005
Comments: house
being demolished
Date: 2/29/2008
Time: 12:22 P.M.
Direction: northeast
Photo by: S. Williams
Exposure #: 006
Comments: house
being demolished
Page 3 of 9
St. Johns/Cosentino — P. And E. Construction, Pinski
#1450200009 — Perry County
Not to Scale
Locations are Approximate
2/29/2008
Illinois Environmental Protection Agency
?
LPC #1450200009 – Perry County
Bureau of Land
?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009'02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:45 P.M.
Direction: northeast
Photo by: S. Williams
Exposure #: 007
Comments: siding,
wood & ash
Date: 2/29/2008
Time: 12:45 P.M.
Direction: southeast
Photo by: S. Williams
Exposure #: 008
Comments: apparent
open burn area
Page 4 of 9
Illinois Environmental Protection Agency?
LPC #1450200009 — Perry County
Bureau of Land
?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009 ,-. 02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:46 P.M.
Direction: southwest
Photo by: S. Williams
Exposure #: 009
Comments: siding,
demolition wood,
cardboard & ash
Date: 2/29/2008
Time: 12:47 P.M.
Direction: northeast
Photo by: S. Williams
Exposure #: 010
Comments: vehicle
tracks leading up to
apparent open burn
pile
Page 5 of 9
Illinois Environmental Protection Agency?
LPC #1450200009 – Perry County
Bureau of Land
?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009
,‘,
02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:47 P.M.
Direction: northeast
Photo by: S. Williams
Exposure #: 011
Comments: charred
limbs over apparent
open burn pile
Date: 2/29/2008
Time: 12:48 P.M.
Direction: southeast
Photo by: S. Williams
Exposure #: 012
Comments: charred
ground at apparent
open burn pile
Page 6 of 9
Illinois Environmental Protection Agency?
LPC #1450200009 – Perry County
Bureau of Land?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
Date: 2/29/2008
Time: 12:50 P.M.
Direction: northwest
Photo by: S. Williams
Exposure #: 013
Comments: wood ties
with protruding metal
Date: 2/29/2008
Time: 12:51 P.M.
Direction: northwest
Photo by: S. Williams
Exposure #: 014
Comments: shingles,
dimensional wood &
metal
File Names: 1450200009",02292008 - [Exp. #].jpg
Page 7 of 9
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CREDIT PROTECTION
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A NATIONWIDE COLLECTION
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Antony C osentino
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Illinois Environmental Protection Agency?
LPC #1450200009 – Perry County
Bureau of Land
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St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control
?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009
,
-,
02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:55 P.M.
Direction: northwest
Photo by: S. Williams
Exposure
#:
015
Comments: mail to
Antony Cosentino at
the address of the
open dump site
Date: 2/29/2008
Time: 12:56 P.M.
Direction: southwest
Photo by: S. Williams
Exposure
#:
016
Comments: bowling
ball, siding, shingles,
paint can, demolition
wood
&
landscape
waste
Page 8 of 9
Illinois Environmental Protection Agency?
LPC #1450200009 – Perry County
Bureau of Land
?
St. Johns/Cosentino - P. And E. Construction, Pinski
Division of Land Pollution Control?
FOS File
DIGITAL PHOTOGRAPHS
File Names: 1450200009"02292008 - [Exp. #].jpg
Date: 2/29/2008
Time: 12:57 P.M.
Direction: northeast
Photo by: S. Williams
Exposure #: 017
Comments: variety of
metal, broken glass,
wood, concrete,
general refuse & ash
– much of which was
charred
Date: 2/29/2008
Time: 12:57 P.M.
Direction: east
Photo by: S. Williams
Exposure #: 018
Comments: partial
burn barrels, plastics,
cardboard, concrete
blocks & charred
shingles
Page 9 of 9
PROPOSAL
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and the above work to be performed in accordance with the drawings and specifications
submitted for above wok, and completed in a substantial workmanlike manner for the sum of?
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Respectfully submitted
Any alteration or deviation from above
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Note - This proposal may be withdrawn
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ACCEPTANCE OF PROPOSAL
The above prices, specifications and conditions are satisfactory and are hereby accepted. You are authorized to do the work
as specified. Payments will be made as outlined above.
Signature
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Very truly yours
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Aaron A. At
cc: Mrs. Hilda Cook
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ATTORNEY
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LAW
18 NORTH OAK STREET
P.O. BOX 1102
DU QUOIN, ILLINOIS 62832
TELEPHONE: 618-542-3118
FAX 618-542-6335
February 29, 2008
Mr. Rob Pinski
% P. & E. Construction
529 South Madison Street
Du Quoin, Illinois 62832
Re: Mrs. Hilda Cook
MAR
2
4 2008
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Dear Mr. Pinski:
Please allow this letter to advise you that I represent Mrs.
Hilda Cook. Mrs. Cook has consulted with me pertaining to the
contract dated February 25, 2008, which she has entered into with
you for demolition of the residence at 517 West Park Street, Du
Quoin, Illinois.
As I understand it, Mrs. Cook understood that you are
requesting that she hire a dumpster to facilitate the demolition
of the said residence. I have advised Mrs. Cook not to do so as
there is nothing in the contract which requires her to incur this
additional expense. The contract is quite clear in that you have
the obligation to remove the demolition debris to the Perry
County Landfill. There is no provision in the contract for her
to provide you with a dumpster, therefore, none will be provided
by her. If you desire to hire a dumpster at your expense, you
certainly have Mrs. Cook's permission to situate such a dumpster
on certain areas of the property, to be specified by Mrs. Cook,
for the duration of the demolition. However, the rental of such
a dumpster must be paid for entirely by you, and the dumpster
must be promptly removed after completion of the demolition work.
Accordingly, on behalf of Mrs. Cook, I herewith request that
you provide Mrs. Cook with receipts from the landfill for all
loads of demolition debris which you so remove to the landfill,
and for the dumpster, if you choose to hire same.
Should you have any questions or should anything further be
required, kindly so advise.
Thanking you for your kind assistance in this matter, I
remain...
1 I NA
Ft5FicTISYFW
APR 1 1 2008
PROOF OF SERVICE
STATE OF ILLINOIS
I hereby certify that I did on the 8th day of April 2008, send by CFRilliiretic?R/19in
g9Veceipt
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:
Joseph Cosentino
Rob Pinski
1043 N. Walnut Street
529 South Madison Street
St. Johns, IL 62832
DuQuoin, IL 62832
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:
John TheiTiault
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Miche e M. Ryan
Assistant Counsel
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