ILLINOI
NTAL PROTECTION AGENCY
Jason R. Boltz, Assist
ounsel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PROPOSED ADJUSTED STANDARD FROM
AMMONIA NITROGEN DISCHARGE LEVELS AT
35 Ill. Adm. Code 304.122 FOR CITGO PETROLEUM
AND PDV MIDWEST REFINING, L.L.C.
AS 2008-008
(Adjusted St
a
RECEIVED
CLERK'S OFFICE
JUL 2 1 2008
Hion
ATE
OF
Control
ILLINOISBoard
NOTICE OF FILING
TO: John
T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph, Suite.11-500
Chicago, Illinois 60601-3218
Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794=9274
Jeffery C. Fort
Ariel J. Tesher
Sonnenschein Nath & Rosenthal LLP
233 S. WackerDrive.
Chicago, IL 60606-6404
Bill Richardson, General Counsel
Depaitinent of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Matthew J. Dunn
Division Chief, Environmental Enforcement
Illinois Attorney General
100 W. Randolph Street, 12
th Floor
Chicago, Illinois 60601
PLEASE.
TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution Control Board the attached
NOTICE of WITHDRAWAL OF APPEARANCE,
APPEARANCE and MOTION FOR SUBSITUTION OF COUNSEL
of the Illinois
Environmental Protection Agency, a copy of which is herewith served upon you.
Dated: July 16, 2008
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
BEFORE THE. ILLINOIS POLLUTION CONTROL BO
IN THE MATTER OF:
PROPOSED ADJUSTED STANDARD FROM
AMMONIA NITROGEN DISCHARGE LEVELS AT
35 111. Adm. Code 304.122 FOR CITGO PETROLEUM
AND PDV MIDWEST REFINING, L.L.C.
CLERK'S
le.ceiveato
OFFICE
JUL
.
2
1 2008
STA
ion
Pollut
TE
Control
OF
ILLINOISBoard
AS 2008-008
(Adjusted Standard)
NOTICE OF WITHDRAWAL OF APPEARANCE
I hereby give notice of withdrawal of my appearance as representative of the Respondent,
Illinois Environmental Protection Agency in this proceeding.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
By:?
Sanjay K. Sofat
DATED: July 16, 2008
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
By.
Jason. R. Boltz, Assist
Division of Legal Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Reeive°
CLERK'S OFFICE
JUL' 2 1 2008
AS 2008-00g.
.rArg,OF
(Adjusted
Altwooft)Contro/
ILLI
NOIS
Board
IN THE MATTER OF:
PROPOSED ADJUSTED STANDARD FROM
AMMONIA NITROGEN DISCHARGE LEVELS AT
35 Ill. Adm. Code 304.122 FOR CITGO PETROLEUM
AND PDV MIDWEST REFINING, L.L.C.
APPEARANCE
Pursuant to 35 Ill. Adm. Code 101.400 (a), (b). and (c), the undersigned, as one of its attorneys,
hereby enters an
APPEARANCE
on behalf of Respondent, Illinois Environmental Protection
Agency. This Appearance is filed consistently and contemporaneously with the Motion of
Substitution of Counsel and Notice of Withdrawal of Appearance, wherein Mr. Sanjay Sofat will
no longer appear in a representative capacity for the Respondent and shall be hereafter
substituted for the undersigned attorney. •
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
DATED: July 16, 2008
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
sel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
LeFisK'S
OFF/FED
))
)
AS 20-008
P?
t
0 °I
IN THE MATTER OF:
n:UL
2 12008
o
sTuAtiToen
opnkrit
8
PROPOSED ADJUSTED STANDARD FROM
AMMONIA MTROGEN DISCHARGE LEVELS AT
)
(Adjusted Standard)
C CEIV
oard
35 Ill. Adm. Code 304.122 FOR CITGO PETROLEUM )
AND PDV MIDWEST REFINING, L.L.C.
)
MOTION FOR SUBSTITUTION OF COUNSEL
NOW COMES the, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY ("Illinois
EPA"), by and through its attorney, Jason R. Boltz, Assistant Counsel, sets forth its Motion for
Substitution of Counsel, herein states as follows:
1.
On May 5, 2008, Sanjay Sofat, Assistant Counsel, a properly licensed attorney employed by
the Illinois EPA, filed his Appearance on behalf of the Respondent.
2.
On or about July 16, 2008, Mr. Sofat was accepted a different position at the Illinois EPA in
which his responsibilities would no longer include acting as an attorney on behalf of the
Respondent for.the case at bar, and as such, filed his Notice of Withdrawal pursuant to,35 Ill.
Adm. Code 101.400(b) which is also filed herewith.
3.
As a result, Jason Boltz, Assistant Counsel, another properly licensed attorney (ARDC
#6269441) in the State of Illinois employed by the Illinois EPA was assigned to the handling
of this case and also filing herewith, an Appearance pursuant to 35 Ill. Adm. Code
101.400(a)(4) on behalf of the Respondent, Illinois EPA.
Jason R. Boltz
Assistant Counsel
Division of Legal Counsel
WHEREFORE, the Illinois EPA prays that the Hearing Officer hereby grant the Respondent's
Motion for Substitution of Counsel
Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
Respondent,
JASON R. BOLTZ, #6269441
Assistant Counsel
1021 N. Grand Ave. East
Springfield, Illinois 62794-9276
(217) 782-5544
STATE OF ILLINOIS
SS
COUNTY OF SANGAMON
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached
NOTICE of
WITHDRAWAL OF APPEARANCE, APPEARANCE, and MOTION FOR SUBSTITION
OF COUNSEL
upon the persons to whom it is directed, by placing a copy in an envelope
addressed to:
John T. Therriault, Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph Street
Chicago, IL 60601
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 N. Grand Ave. East
P.O. Box 19274
Springfield, IL 62794-9274
Jeffery C. Fort
Ariel J. Tesher
Sonnenschein Nath & Rosenthal LLP
'233 S. Wacker Drive
Chicago, IL 60606-6404
Bill Richardson, General Counsel
Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Matthew J. Dunn
Division Chief, Environmental Enforcement
Illinois Attorney General
100 W. Randolph Street, 12
th Floor
Chicago, Illinois 60601
and mailing it from Springfield, Illinois on July 16, 2008, with sufficient postage affixed as
indicated above.
SUBSCRIBED AND SWORN TO BEFORE ME
k
of
July 16,
2Q08.
k\kkes,_
Notary ublic
OFFICIAL SEAL
BRENDA BOEHNER
NOTARY PUBLIC, STATE
OF ILLINOIS
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