BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
)
RCRA DELISTING ADJUSTED STANDARD
)
PETITION OF PEORIA DISPOSAL
COMPANY)
)
AS 08-10
(Adjusted Standard - Land)
(RCRA Delisting)
Response
of Peoria Disposal Company
to Letter from Tracy Meints Fox, Dated August 11, 2008
NOW COMES Peoria Disposal Company ("PDC"), by its attorneys, Elias, Meginnes,
Riffle & Seghetti, P.C. and Brown, Hay & Stephens, LLP, and as and for its response to the
letter from Tracy Meints Fox, dated August 11, 2008, filed with the Clerk
of the Pollution
Control Board on August 13,2008, states as follows:
I.
In her letter dated August
II, 2008, Ms. Fox requests that the Pollution Control
Board release information in the Record regarding the geographic locations
of the ten steel mills
that ship K061 waste to PDC for treatment relevant to this case.
2.
As PDC did not identify the locations of the steel mills in its filing with the
Pollution Control Board, the information requested by Ms. Fox is not in the Record in this case.
In particular, the un-redacted version
of Appendix B does not list the geographic locations ofthe
ten steel mills that ship K061 waste to PDC for treatment relevant to this case.
Dated: August 14,2008
Respectfully submitted,
PEORIA DISPOSAL COMPANY,
Petitioner
BY~~
.
On~
attorne
~
THIS DOCUMENT IS BEING FILED ELECTRONICALLY.
Electronic Filing - Received, Clerk's Office, August 14, 2008
Claire
A.
Manning, Esq.
BROWN, HAY
&
STEPHENS, LLP
205 S. Fifth Street
Suite 700
Springfield, Illinois 6270 I
Telephone: (217) 544-8491
Facsimile: (217) 544-9609
Email: cmanning@bhslaw.com
908-0686
Brian J. Meginnes, Esq.
Janaki Nair, Esq.
ELIAS, MEGINNES, RIFFLE
&
SEGHETTI, P.C.
416 Main Street, Suite 1400
Peoria, Illinois 61602
Telephone: (309) 637-6000
Facsimile: (309) 637-8514
Emails:bmeginnes@emrslaw.com
jnair@ernrslaw.com
2
THIS DOCUMENT IS BEING FILED ELECTRONICALLY.
Electronic Filing - Received, Clerk's Office, August 14, 2008
CERTIFICATE OF FILING AND SERVICE
I certify that on August
14,
2008, I filed the foregoing document electronically with the
Clerk of the Illinois Pollution Control Board, and I served the foregoing document on all parties
hereto, by enclosing a true copy of same in an envelope addressed to the attorney of record of
each party or the party as listed below, with first class postage fully prepaid, and depositing each
of said envelopes in the United States Mail at 5:00 p.m. on said date:
William D. Ingersoll
Manager, Enforcement Programs
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
LynnBuhl
Regional Administrator
United States Environmental Protection
Agency, Region 5
77 West Jackson Boulevard
Chicago, IL 60604
Courtesy copy:
Tracy Meints Fox
15215 N. Ivy Lake Road
Chillicothe, IL 61523
Claire A. Manning, Esq.
BROWN, HAY
&
STEPHENS, LLP
205
S. Fifth Street
Suite 700
Springfield, Illinois 62701
Telephone: (217) 544-8491
Facsimile: (217) 544-9609
Email: cmanning@bhslaw.com
United States Environmental Protection Agency
Office
of Solid Waste and Emergency Response
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Brian J. Meginnes, Esq.
Janaki Nair, Esq.
ELIAS, MEGINNES, RIFFLE
&
SEGHETTI, P.C.
416 Main Street, Suite 1400
Peoria, Illinois 61602
Telephone: (309) 637-6000
Facsimile: (309) 637-8514
Emails:bmeginnes@emrslaw.com
jnair@emrslaw.com
3
THIS DOCUMENT IS BEING FILED ELECTRONICALLY.
Electronic Filing - Received, Clerk's Office, August 14, 2008