(JThH\1
—..
:—
lj
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
)
Complainant,
)
AC
)
v.
)
(IEPA
No.
214-08-AC)
)
REYNOLDS
SERVICE
CO.,
1NC,
)
)
Respondent.
)
NOTICE
OF FILING
To:
Reynolds
Service
Co.,
Inc.
Attn:
Terry
Reynolds
2875
Route
146 West
P.O.
Box
786
Jonesboro,
IL
62952
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,
JNJUiJiiJ%
Michelle
M.
Ryan
Assistant
Counsel
Illinois
Environmental Protection
Agency
1021
North
Grand
Avenue
East
P.O.
Box
19276
Springfield, Illinois
62794-9276
(217)
782-5544
Dated:
September
9,
2008
THIS FILING
SUBMITTED
ON RECYCLED
PAPER
(Th
fl
(“
J
1 I
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
)
PROTECTIONAGENCY,
)
Complainant,
)
AC
q
1
Lt
“1%
)
v.
)
(IEPA
No.
214-08-AC)
)
REYNOLDS
SERVICE
CO.
INC.,
)
Respondent.
)
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
Reynolds
Service
Co.,
Inc. (“Respondent”)
is
the
presentownerand
operatorof
a facility
located
at the
following:
Section
23,
TWP
12, Rng
2W,
Part
of SE
corner
of
NE NE,
Union
County,
Illinois.
The property
is commonly
known
to
the Illinois
Environmental
Protection
Agency
as
Jonesboro/Reynolds
Service
Co.,
Inc.
2.
That said
facility
is an open
dump
operating
without
an
Illinois
Environmental
Protection
Agency
Operating
Permit
and is
designated
th Site
Code
No.
1818565001.
3.
That
Respondent
has
owned
and operated
said
facility
at
all times
pertinent
hereto.
4.
That
on August
4, 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.
VIOLATIONS
Based
upon
direct
observations
made
by
Sheila
Williams
during
the
course
of herAugust4,
2008
inspection
of the
above-named
facility,
the
lllnois
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)
(2006).
(2)
That
Respondent
caused
or
allowed the
open
dumping
of waste
in
a
manner
resulting
in proliferation
of
disease
vectors,
a
violation
of
Section
21(p)(5)
of
the Act,
415
ILCS
5121(p)(5)
(2006).
(3)
That
Respondent
caused
or allowed the
open
dumping
of waste
in
a
manner
resulting
in deposition
of
general
construction
or demolition
debris
or
clean
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),
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
Four
Thousand
Five
Hundred
Dollars
($4,500.00).
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
October
15, 2008,
unless
otherwise
provided
2
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(2006),
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
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
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
(2006).
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.
‘?
Date:
I
1o
Douglas. Scott,
Director
Illinois
Environmental
Protection
Agency
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,
)
Complainant,
)
AC
0
q
1
2
J-
v.
)
(IEPA
No. 214-08-AC)
REYNOLDS
SERVICE
CO.
INC.,
)
Respondent.
)
FACILITY:
Jonesboro/Reynolds
Service
Co.,
Inc.
SITE
CODE
NO.:
1818565001
COUNTY:
Union
CIVIL
PENALTY:
$4,500.00
DATE
OF INSPECTION:
August
4,
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
ILLINOIS
ENVIRONMENTAL
PROTECTION AGENCY
Open
Dump
Inspection
Checklist
County:
Union
LPC#:
1818565001
Region:
7 - Marion
Location/Site
Name:
Jonesboro/Reynolds
Service Co.,
Inc.
Date:
08/04/2008
Time: From
3:45
PM
To
4:55 PM
Previous
Inspection
Date: 08/23/2002
Inspector(s):
S.
Williams
Weather:
sunny,
humid,
—95 F.
No.
of
Photos
Taken:
# 31
Est. Amt.
of
Waste:
>2,984
yds
3
Samples
Taken:
Yes #
No
Interviewed:
Jeff Reynolds
&
Gladice
Jones
Complaint
#:
09-007M
Latitude:
37.46395
Longitude:
-89.28810
Collection
Point
Description:
Site Entrance
-
(Example:
Lat.:
41 .26493
Long.:
-89.38294)
Collection
Method:
GPS -
Responsible
Party
Mailing
Address(es)
and
Phone
Number(s):
SECTION
DESCRIPTION
VIOL
ILLINOIS
ENVIRONMENTAL
PROTECTIZ
.
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
4.
12(d)
CREATE
A WATER
POLLUTION
HAZARD
5.
21(a)
CAUSE
OR
ALLOW
OPEN DUMPING
CONDUCT
ANY
WASTE-STORAGE,
WASTE-TREATMENT,
OR
WASTE-
DISPOSAL
6.
21(d)
OPERATION:
(1)
Without
a Permit
(2)
In
Violation
of
Any
Regulations
or
Standards
Adopted
by the
Board
DISPOSE,
TREAT,
STORE,
OR ABANDON
ANY WASTE,
OR
TRANSPORT
ANY
WASTE
INTO
THE STATE
ATITO
SITES NOT
MEETING
REQUIREMENTS
OF
ACT
7.
21(e)
AND
REGULATIONS
CAUSE
OR ALLOW
THE
OPEN
DUMPING
OF ANY WASTE
IN A MANNER
WHICH
RESULTS
8.
21
(P)
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
Reynolds
Service
Co.,
Inc.
Attn: Terry
Reynolds
2875
Route
146
West
P.O.
Box 786
Jonesboro,
IL
62952
Revised
6/21/2007
(Open
Dump
- 1)
LPC#
1818565001
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.
08/04/2008
Deposition
of: (i)
General
Construction
or Demolition
Debris
as
defined
in
Section
(7)
3.160(a);
or
(ii) Clean
Construction
or
Demolition
Debris
as defined
in Section
3.160(b)
9.
55(a)
NO
PERSON
SHALL:
(1)
Cause
or Allow
Open Dumping
of Any
Used
or
Waste
Tire
(2)
Cause
or Allow
Open
Burning
of
Any
Used or
Waste
Tire
El
35
ILLINOIS
ADMINISTRATIVE
CODE
REQUIREME
NTS
SUBTITLEG
FAILURE
TO SUBMIT
AN APPLICATION
FOR A
PERMIT
TO
DEVELOP
AND
10.
812.101
(a)
OPERATE
A LANDFILL
11.
722.111
HAZARDOUS
WASTE
DETERMINATION
12.
808.121
SPECIAL
WASTE
DETERMINATION
ACCEPTANCE
OF
SPECIAL
WASTE
FROM
A
WASTE
TRANSPORTER WITHOUT
A
WASTE
HAULING
PERMIT,
UNIFORM
WASTE
PROGRAM
REGISTRATION
AND
13.
809.302(a)
PERMIT
AND/OR
MANIFEST
OTHER
REQUIREMENTS
APPARENT
VIOLATION
OF:
(LI)
PCB;
(LI)
CIRCUIT
COURT
14.
CASE
NUMBER:
ORDER
ENTERED
ON:
OTHER:
Subject
to such
exemption
as expressly
provided
in
Section
21(e) (III.
Rev.
Stat. 1981,
ch. 111
1/2,
par.
1021(e))
of the Act
as to
the requirement
of
obtaining
a
permit,
no
person
shall
cause
or
allow
the development
of any
new
solid
waste
management
site
807.201
or
cause or
allow the
modification
of an
existing
solid
waste
management
site
without
a
15.
Development
Permit
issued
by the
Agency.
New
Solid
Waste Management
Sites.
Subject
to
such
exemption
as
expressly
provided
in
Section
21(e)
of
the Act
(Ill. Rev.
Stat.
1982,
ch.
111
1/2, par.
1021(e))
as to
the
requirement
of
obtaining
a permit,
no
person
shall
cause
or
allow
the use
or
operation
of
any
solid
waste
management
site for
which
a
Development
Permit
is required
under
Section
807.20
1
without
an
Operating
Permit
issued
by
the Agency,
except
for such
16.
807.202a
testing
operations
as
may be
authorized
by the
Development
Permit.
Revised
6/21/2007
(Open
Dump
- 2)
NARRATIVE
INSPECTION
REPORT
Date:
August
4, 2008
Inspector:
Sheila
Williams
Site
Code:
1818565001
County:
Union
Site
Name:
Jonesboro/Reynolds
Service
Co.,
Inc.
Time:
3:45
P.M. —
4:55
P.M.
GENERAL
REMARKS
On
August
4, 2008
I conducted
an
inspection
at
the Jonesboro/Reynolds
Service
Co.,
Inc.
site
as
the result
of
a
complaint.
This
site
is located
at 2875
Route
146
West
Jonesboro,
IL.
The
complainant
indicated
mobile
homes
are torn
down
&
burned
along
a
creek.
The
complainant
said
people
in
the area
have
asked
Terry
Reynolds
to stop
this
type
of
operation
for
the last
two
&
a
half
years.
At the
onset
of
the
inspection
I
spoke
with
a
man
who identified
himself
as
Jeff
Reynolds,
a
cousin
to Terry
Reynolds.
J.
Reynolds
explained
they
fix up
mobile
homes
&
resale
them.
He
said
they do
not
burn
on
site.
Also,
he
added
they
reuse
almost
everything
that
is
brought
to
the
site.
It was
apparent
J. Reynolds
had
been
working
in
the large
pole
barn
when
I arrived.
This
appears
to
be where
the
majority
of
the
work
is
done.
Early
in the
inspection
I
spoke
with
a
woman
who
identified
herself
as
Gladice
Jones.
She
said
she
lives
in
a
mobile
home
at
the
site.
It is adjacent
to
the
mobile
home
designated
as
Area
A.
Ms.
Jones
said
her
son,
E.
Jones
works
in the
evenings
for
Terry
Reynolds.
She
said he
is
currently
working
on
the
mobile
next
to where
she
lives.
Other
than
scattered
debris,
five areas
of apparent
violations
were
observed.
These
have
been
designated
as
Area
A,
Area
B, Area
C, Area
D
&
Area
E.
Among
the
scattered
refuse
were
tires,
pipes,
general
refuse,
fabrics
& demolition debris.
Area
A
consisted
of
a
dilapidated
mobile
home.
Most
of the
outside
wall
running
lengthwise
on
one
side
of
the
mobile
home
was
missing.
Insulation,
as well
as
other
debris,
was
spilling
out
of the
mobile
home
onto
the ground.
Area
A was
visually
estimated
to
be
approximately
400
cubic
yards
(45’x20’x12’)
in
size.
Among
the
debris
in Area
B were
bicycles,
fabric, gas
containers,
cardboard,
kitchen utensils,
plastics,
wires, demolition
debris, tools
&
equipment.
Area
B was
estimated
to be approximately
seven
cubic
yards
(20’x5’x2’)
in size.
Waste
in
Area
C
included,
but
was not
limited
to, siding,
demolition
wood,
a
broken
door,
cardboard
& general
refuse.
In
the eastern
end of
Area
C,
concrete
with
protruding
metal
was
hovering
along
an
embankment
just
above
what
appeared
to be
an
intermittent
creek
bed
with
a
small amount
of water
in it.
Area
C was
estimated
to
be
approximately
73 cubic
yards (52.5’X15’x2.5’)
in size.
Area
D
consisted
of no less
than five
dilapidated
mobile
homes,
a
building
that appears
to
have
been
a house
at
one
time and
other
debris.
The
structures
were
open to
the
atmosphere
either
as
a
result
of broken
or
missing
windows
or doors
or the lack
of
whole
walls.
The structures
contained
a
wide
range of
waste
including,
but
not
limited
to
furniture,
tires,
demolition
debris
&
food condiments.
The structures
were
not in
use,
not useable
in
their
current
condition
&/or
not being
protected
for future
use.
Among
the
other
debris
in Area D
were
demolition
debris,
a toilet,
a
variety
of
metal,
clothing,
furniture,
an
undetermined
number
of tires
(due
to
extensive
vegetation),
a
drum
labeled
as
Rotella
T15 W-40
with
Advanced
Soot
Control
&
plastic
containers
holding
water.
I
observed
active
mosquito
larvae
in
one of the
containers.
Area
D was
estimated
to be
approximately
2500
cubic
yards
(135’xlOO’x5’)
in
size.
Area E
consisted
of
approximately
36
tires
amongst
vegetation.
Area E was
estimated
to be
approximately
four
cubic
yards
(10’x5’x2’)
in size.
A
review
of Agency
records
revealed
that
this
site
was
initially
inspected
on
July
27,
2000
at
which
time
apparent
violations
resulting
in litter,
open
burning &
the
deposition
of general
construction
or
demolition
debris
or clean
construction
or demolition
debris
were
observed.
Following
an
October 11,
2000 inspection
indicating
continuing
violations,
an Administrative
Citation
was
mailed
to
the attention
of
Terry Reynolds
of
Reynolds
Manufactured
Homes
&
Transport.
On
August
5,
2008
I
received
an
e-mail
from Michelle
Ryan,
JEPA
Division
of
Legal
Counsel,
that indicated
the civil
penalty
of
$1,500
was
never
paid.
2
The
State
of
Illinois’
corporation
file
detail
report
available
through
the Secretary
of
State’s
website
revealed
Terry
Reynolds
at 2875
Route
146
West Jonesboro, IL is
the
president
&
Linda
Reynolds
of
the
same
address
is
the Agent
for this
corporation.
According
to
the Union
County
Supervisor
of
Assessments
Office,
the
real
estate
tax
bill
for
this
piece
of property
is
sent
to Terry
Reynolds
at
2875
Route
146
West
Jonesboro,
IL.
3
Jonesboro/Reynolds
Service
Co.,
Inc.
#1818565001
- Union County
Not
to Scale
Locations
are
Approximate
8/4/2008
ftA
Pcea B
S&
SLn.
nih
- mobile home
roll-off box
r
omh
occupied mobile
home
not all mobile honiex are depicted
•
Illinois
Environmental Protection Agency
Bureau of Land
Division of Land Pollution Control
LPC #1818565001
— Union
County
Jonesboro/ Reynolds Service
Co., Inc.
FOS
File
4
V
File
I
Names:
181856500108042008
- [Exp. #].jpg
/
‘
me
za’
a
s’
-.?_frt -
Yra4
fl
-It
Date:
8/4/2008
Time:
3:41 P.M.
Direction:
northwest
Photo by:
S.
Williams
Exposure
#: 001
Comments:
dilapidated
mobile
home with
debris
falling onto
the
ground
Date:
8/4/2008
Time: 3:44
P.M.
Direction:
northeast
Photo by:
S.
Williams
Exposure #:
002
Comments:
siding,
demolition
wood,
a
hose, lawn
chair
&
plastic
bottle
DIGITAL
PHOTOGRAPHS
Illinois Environmental
Protection Agency
Bureau of Land
Division
of
Land Pollution Control
LPC #1818565001
— Union
County
Jonesboro/
Reynolds Service
Co., Inc.
FOS File
Date: 8/4/2008
Time:
3:45 P.M.
Direction:
southwest
Photo by:
S.
Williams
Exposure
#:
003
Comments:
bicycles,
fabric,
gas
containers, kitchen
utensils, plastics,
wires,
tools
&
equipment
Date: 8/4/2008
Time: 3:49 P.M.
Direction: northeast
Photo by:
S.
Williams
Exposure #: 004
Comments: broken
door, demolition
wood & general
refuse
DIGITAL PHOTOGRAPHS
Names:
1’08042008 -
.. #].jpg
Illinois
Environmental
Protection
Agency
Bureau
of Land
Division
of Land
Pollution
Control
LPC
#1818565001
— Union
County
Jonesboro/
Reynolds
Service
Co.,
Inc.
FOS
File
Date: 8/4/2008
Time: 3:52
P.M.
Direction:
northeast
Photo
by:
S
Williams
Exposure
#:
005
Comments:
metal
&
concrete
on
the
creek embankment
Date:
8/4/2008
Time:
3:53
P.M.
Direction:
northwest
Photo by:
S.
Williams
Exposure
#:
006
Comments:
cooler,
gas
tank,
jacket,
toilet
&
tank
Illinois Environmental
Protection
Agency
Bureau of
Land
Division
of Land
Pollution
Control
LPC
#1818565001
—
Union
County
Jonesboro/
Reynolds
Service
Co.,
Inc.
FOS
File
Date:
8/4/2008
Time:
3:55
P.M.
Direction:
north
Photo by:
S.
Williams
Exposure
#: 007
Comments:
vehicle
containing
debris
flowing onto
the
ground
Date:
8/4/2008
Time: 3:56
P.M.
Direction:
northeast
Photo by:
S.
Williams
Exposure
#:
008
Comments:
tires
&
pipe
in vegetation
DIGITAL
PHOTOGRAPHS
Illinois
Environmental
Protection
Agency
Bureau
of Land
Division
of Land
Pollution
Control
LPC
#1818565001
—
Union County
Jonesboro/
Reynolds
Service
Co.,
Inc.
FOS File
Date:
8/4/2008
Time: 3:59
P.M.
Direction:
northwest
Photo by:
S.
Williams
Exposure
#:
009
Comments:
pipe,
demolition
wood
&
fabric
along
the
creek embankment
Date:
8/4/2008
Time:
4:01
P.M.
Direction:
northeast
Photo by:
S.
Williams
Exposure
#:
010
Comments:
toilet,
demolition
debris,
corrugated
metal,
propane tanks,
dilapidated
mobile
home,
fabrics,
ceiling
light
&
fan
r
T
qITAL
PHOTO
-
——-,----.,
Date: 8/4/2008
Time: 4:07 P.M.
Direction: northeast
Photo by:
S.
Williams
Exposure #: 011
Corn rnents:
dumpster
&
dilapidated building
Date:
8/4/2008
Time: 4:09 P.M.
Direction: southeast
Photo by:
S.
Williams
Exposure #: 012
Comments:
demolition
debris
spilling out of
building, oven
&
washing machine
Illinois Environmental Protection
Agency
Bureau of Land
Division
of
Land Pollution Control
-
L PHOTOGRAPHS
LPC #1818565001
— Union
County
Jonesboro/ Reynolds Service
Co.,
Inc.
FOS File
-“
----
1
•
Illinois
Environmental
Protection
Agency
Bureau of
Land
Division of
Land Pollution
Control
LPC #1818565001
— Union
County
Jonesboro/
Reynolds
Service
Co.,
Inc.
FOS File
Date:
8/4/2008
Time: 4:09 P.M.
Direction:
southeast
Photo by:
S. Williams
Exposure
#:
013
Comments:
cooking
pots, demolition
wood,
grill
&
plastic
container holding
water
Date:
8/4/2008
Time: 4:11
P.M.
Direction:
northwest
Photo by:
S.
Williams
Exposure #:
014
Comments:
plastic
container holding
water with
active
mosquito
larvae
DIGITAL
PHOTOGRAPHS
.James:
1818565001.08042008
-
Illinois
Environmental
Protection
Agency
Bureau
of
Land
Division of
Land Pollution
Control
LPC
#1818565001
— Union
County
)onesboro/Reynods Service
Co.,
Inc.
FOS
File
Date:
8/4/2008
Time:
4:12 P.M.
Direction:
north
Photo
by:
S.
Williams
Exposure
#: 015
Comments:
clothing,
demolition
debris
&
a
mattress
Date:
8/4/2008
Time:
4:14 P.M.
Direction:
southwest
Photo
by:
S.
Williams
Exposure
#:
016
Comments:
mattress,
demolition
debris
&
what
appeared
to be
carpeting
amongst
vegetation
DIGITAL
PHOTOGRAPHS
75
-.
5-
-
File Names:
181k
._.3-[Exp.#].jpg
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ILLiNOIS
ENVIRONMENTAL
PROTECTION
AGENCY
)
Complainant,
)
4c
q.
f
)
)
IEPA
DOCKET
NO.
Respondent.
)
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
August
4, 2008,
between
3:35
p.m.
and
4:55
p.m.., Afflant
conducted
an
inspection
of a disposal
site
operated
by Reynolds
Service
Co., Inc.,
located
in Union
County,
Illinois,
and known
as Reynolds
Service
Co.,
Inc.
by
the Illinois
Environmental
Protection
Agency.
Said
site
has been
assigned
site
code
number
1818565001
by
the
Agency.
3. Affiant
inspected
said
Reynolds
Service
Co.,
Inc. site by
an on-site
inspection
which
included
walking
and photographing
the
site.
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 Reynolds
Service
Co., Inc..
Subscribed
and
Sworn to
before me
this
of______________
Notary
Public
“OFFICIAL
SEALS
RONALD
E. MORSE
Notary
Public,
State of IIIinois
Commission
Expires: 2/21/10
SRW:jkb/37261/08-1
1-08
PROOF
OF
SERVICE
I hereby certify
that
I
did on
the
9th
day
of
September
2008,
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
ofthe
following
instrument(s)
entitled
ADMINISTRATIVE
CITATION,
AFFIDAVIT,
and
OPEN
DUMP
INSPECTION
CHECKLIST
To:
Reynolds
Service
So.,
Inc.
Attn:
Terry
Reynolds
2875
Route
146
West
P.O.
Box
786
Jonesboro, IL
62952
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
Therriault,
Clerk
Pollution
Control
Board
James
R.
Thompson
Center
100
West
Randolph
Street,
Suite
11-500
Chicago,
Illinois
60601
*
Michelle
iUr
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
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
(217) 782-9817
TDD:
(217) 782-9143
September
9,
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.
Reynolds
Service
Co.
IEPA File
No.
214-08-AC:
181565001—Union
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
0
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
MalI Street,
Collinsville,
IL 62234
—(618)
346-5120
MARION
—2309 W.
Main
St.,
Suite
116, Marion, IL
62959 —(618)
993-7200
1021 NORTH
GRAND
AVENUE
EAST, P.O.
Box
19276, SPRINGFIELD,
ILUNOIS
62794-9276
—(217)
782-3397
J,’MES R.
THOMPSON
CENTER, 100
WEST
RANDOLPH,
SUITE
1 1-300, CHICAGO,
IL
60601
— (31 2)
814-6026
Roo
R. BLAGOJEVICH,
GOVERNOR
DOUGLAS
P. SCOTT,
DIRECTOR
SEP
I
2008
STATE
Poiiuucj
4c
0
N
PRINTED
ON RECYCLED
PAPER
