BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
)
Complainant,
)
)
v.
)
)
PCB
(Enforcement)
No.
4.
MYERS
INDUSTRIES,
INC.,
)
)
Respondent.
)
NOTICE
OF
FILING
To:
MEYERS
INDUSTRIES,
INC.
do
Paul
E.
Presney
726
South
Second
Street
Springfield,
IL
62704
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.
1
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
MATTHEW
J.
DUNN,
Chief
Environmental
Enforcement/Asbestos
Litigation
Division
/
BY:
.,.
/_,___—
Stepfêi/J.
ii’anasie
Assistant
Attorney General
Environmental
Bureau
500
South
Second
Street
Springfield,
Illinois
62706
217/782-9031
Dated:
September
10,
2008
2
BEFORE THE ILLINOIS
POLLUTION CONTROL
BOARD
PEOPLE
OF
THE STATE
OF
ILLINOIS,
Complainant,
v.
)
PCBNo.
O-
/
MYERS INDUSTRIES, INC.,
)
Respondent.
COMPLAINT
Complainant, PEOPLE OF
THE STATE
OF
ILLINOIS,
by LISA
MADIGAN,
Attorney
General of
the State of Illinois,
complains of Respondent,
MIl, INC., as follows:
COUNT I
OPEN
DUMPING
1.
This count is brought on behalf
of the People of the State of Illinois,
ex rel. 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 (‘the
Act”), 415 ILCS 5/31 (2006).
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.
The
Respondent, MYERS
INDUSTRIES, INC. (“MIl”),
is a Delaware corporation
in
good standing.
Attorney Paul E. Presney,
726 South Second
Street, Springfield, Illinois
62704 is the company’s
registered agent.
4.
At all times relevant to this Complaint,
MII was the owner of
a
manufacturing
facility
(“facility”)
located
at
2200 West
th
5
Street Road, Lincoln, Illinois
62656. MIl
manufactured
store
fixtures and shelving of particle board,
wood, and laminates
at
the
facility.
5.
On September 7, 2006, Illinois EPA
performed an inspection of the facility.
1
6.
On September
7, 2006, the Illinois
EPA inspector
found
an
area of white, water-
based glue in
the bed of a railroad
spur
just
outside
the facility’s
loading dock door.
The area
of
glue
measured approximately
10 feet
by
8
feet
by 1 foot in size.
7.
On
September 7, 2006,
the inspector
also found
an
area of oil contaminated
soil
and gravel
along the railroad spur.
The
area
of contaminated
soil measured approximately
6
feet
by 4 feet by 1 foot.
8.
On September 7, 2006,
the
inspector
also found
discarded pallets,
cardboard,
wood
and other refuse in a
pile on
the east
side of the facility
grounds;
the
pile measured
approximately 15
feet by 8 feet by 2 feet.
9.
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:
(1)
Without a permit
granted by the
Agency or in violation
of
any conditions
imposed by such
permit
...;
or
(2)
In violation
of
any regulations
or standards
adopted
by
the
Board
under this
Act; or
*
*
*
(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 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 dump site:
(1)
litter;
2
*
*
*
10.
Section
3.305
of the Act,
415 ILCS 5/3.305 (2006)
provides as follows:
‘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.
11.
Section 3.385 of the Act,
415 ILCS
5/3.385 (2006) provides
as follows:
“Refuse” means waste.
12.
Section 3.445 of
the Act, 415 ILCS
5/3.445 (2006) provides
as follows:
“Sanitary landfill”
means a facility
permitted by the Agency
for the disposal of
waste on land
... 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
at the conclusion
of each day’s operation,
or by such other
methods and intervals as the Board
may provide
by regulations.
13.
Section
3.535 of the Act, 415 ILCS
5/3.535 (2006) provides
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 81 2.101 (a) of the Land
Pollution Regulations,
35111. Adm. Code
812.101 (a),
provides in pertinent part as follows:
All persons, except those specifically exempted
by Section 21(d) of the Act,
shall
submit to the Agency an application
for a permit to develop and operate
a
landfill....
15.
Section 3(a) of the Litter Control Act,
415 ILCS 105/3(a) (2006) provides in
pertinent
part as follows:
“Litter”
means any discarded, used or unconsumed
substance or waste. “Litter”
may
include,
but
is
not limited to, any garbage, trash,
refuse, debris. . oil.
. .or
anything else of an unsightly
or unsanitary nature, which
has been discarded,
abandoned or otherwise
disposed of improperly.
16.
MIl
caused or allowed debris
and other wastes and refuse
to be disposed of
and/or
abandoned at
the facility, and
the facility is not permitted as
a disposal site and does
not
fulfill the
requirements
of
a
sanitary
landfill.
3
17.
By
causing or allowing the
open
dumping
of refuse and waste,
and by disposing
or abandoning
wastes at a site
that does not meet
the requirements
of the Act
and the
regulations
and
standards
thereunder, Mu has
violated
Sections
21(a) and 21(e)
of the Act,
415
ILCS 5/21(a),
21(e)
(2006).
18.
By conducting
a waste-storage
and/or waste-disposal
operation
without a permit,
Mu has violated Section
21(d)(1) of the
Act, 415 ILCS
5121(d)(1)(2006) and
Section 812.101(a)
of the Board’s
Waste
Disposal
Regulations, 35 III. Adm.
Code 812.101(a).
19.
By
causing or
allowing
open dumping
in a manner resulting
in litter, MIl
has also
violated
Section 21(p) of the
Act, 415 ILCS 5/21(p)
(2006).
PRAYER FOR
RELIEF
WHEREFORE,
the Complainant,
the People
of the State of Illinois,
respectfully
requests
that
this Board
grant the following
relief:
A.
Authorizing
a hearing in this
matter at which time the
Respondent
will be
required to answer
the
allegations
herein;
B.
Finding that
the
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.
Pursuant
to
Section
42(a)
of
the Act, 415 ILCS 5/42(a)
(2004), imposing
a civil
penalty of not
more than
the statutory maximum;
and
E.
Granting such other
relief as the Board
deems appropriate.
4
COUNT
II
HAZARDOUS
WASTE VIOLATIONS
1.
Complainant
realleges
and incorporates
herein by
reference paragraphs
1
through
5
and paragraph 13 of
Count I as paragraphs
I
through 6 of this
Count II.
7.
Mli’s
assembly
and
process operations
generated
between 100 kilograms
and
1000
kilograms of two types
of hazardous wastes
in
a
calendar
month.
8.
One
of these hazardous
wastes
is a paint
related
waste
solvent (“waste
solvent”),
containing acetone
and toluene
and is identified
with United
States Environmental
Protection
Agency
(‘USEPA”)
hazardous
waste
numbers
F003,
F005,
and DOOl.
9.
MIl generated
the waste
solvent in a parts
washer
and
in the paint
gun
cleaning
areas
of the facility.
10.
Mll’s assembly
and process
operations also generated
paint
cake sludge
(“sludge”); a waste
flammable
solid that
contains
methyl
ethyl ketone and
xylene
and is
identified
with USEPA hazardous
waste
numbers
F003, F005, DOOl,
D035,
and
D043.
11.
On September
7, 2006,
the Illinois EPA inspector
observed
an open drum used
for
satellite accumulation
of the waste
solvent
in
the facility’s paint vault
area. The
drum was
not
labeled
as containing hazardous
waste.
12.
On
September 7, 2006, the
inspector also
observed several
open plastic
buckets
and open
cans
containing
sludge. None
of these containers
were
labeled as containing
hazardous
waste.
13.
On September
7, 2006, the inspector
also observed
several unlabeled
drums
of
waste
solvent
in a
locked,
fenced-in area
outside on the
facility’s north side.
In the same area,
a
bag
of
sludge
was also not labeled.
14.
Section 3.220 of the
Act, 415 ILCS 5/3.220
(2006), provides
as
follows:
5
“Hazardous
waste”
means a waste,
or combination
of wastes,
which because
of
its
quantity,
concentration,
or
physical,
chemical
, or infectious
characteristics
may
cause
or significantly
contribute
to an increase
in mortality
or an
increase
in
serious,
irreversible,
or incapacitating
reversible,
illness;
or pose a
substantial
present
or potential
hazard
to
human
health
or the environment
when improperly
treated,
stored,
transported,
or
disposed
of, or otherwise
managed,
and
which
has
been identified,
by
characteristics
or listing, as
hazardous
pursuant
to
Section
3001 of the
Resource
Conservation
and
Recovery
Act of 1976,
P.L.
94-
580,
or
pursuant
to
Board regulations.
15.
Section
702.110
of the Board’s
RCRA
and UIC Permit
Programs
Regulations,
35
Ill. Adm.
Code 702.110,
provides
the following
definitions:
“Hazardous
waste
management
facility”
or “HWM facility”
means
all
contiguous
land
and
structures,
other appurtenances,
and improvements
on the land,
used
for
treating,
storing,
or disposing
of
“hazardous
waste”. A
facility may
consist
of
several
treatment,
storage,
or disposal
operational
units
(for example,
one
or
more
landfills,
surface impoundments,
or combinations
of
them).
“HWM
facility”
(RCRA)
means Hazardous
waste management
facility.
16.
Section
21 of the
Act, 415
ILCS 5/21
(2002), provides,
in
pertinent
part,
as
follows:
No person
shall:
*
*
*
e.
Dispose,
treat, store
or
abandon
any
waste. .
. except
at a site
or facility
which
meets the
requirements
of this
Act and
of
regulations
and
standards
thereunder.
*
*
*
f.
Conduct
any
hazardous
waste-storage,
hazardous
waste-treatment
or
hazardous
waste-disposal
operation:
1.
without
a
RCRA permit
for the
site
issued
by
the Agency
under
subsection
(d)
of
Section 39
of this Act,
or
in violation
of
any
condition
imposed
by such
permit, including
periodic
reports
and
full
access
to
adequate
records and
the inspection
of facilities,
as
may be necessary
to
assure compliance
with
this Act
and with
regulations
and
standards
adopted
thereunder;
or
2.
in violation
of any regulations
or standards
adopted
by the Board
under
this
Act; or
6
17.
Section
703.121
of the Board’s
RCRA
Permit
Program
Regulations,
35111.
Adm.
Code
703.121,
provides in
pertinent
part,
as
follows:
a)
No
person
may conduct
any hazardous
waste storage,
hazardous
waste
treatment,
or hazardous
waste
disposal
operation
as follows:
1)
Without
a RCRA
permit for
the HWM
(hazardous
waste
management)
facility; or
b)
An
owner or
operator
of a HWM
unit must
have permits
during
the
active
life (including
the
closure period)
of the
unit.
18.
Section
722.134
of the
Board’s Hazardous
Waste
Operating
Regulations,
35111.
Adm. Code
722.134,
provides, in
pertinent
part,
as follows:
a)
Except as
provided
in
subsection
(d),
(e), (f),
(g),
(h), or
(I)
of this Section,
a
generator
is exempt from
all
the
requirements
in
Subparts G
and H of
35
III.
Adm.
Code
725, except
for
35 III.
Adm.
Code 725.211
and
725.214,
and may
accumulate
hazardous
waste
on-site for
90 days
or less
without
a
permit or
without
having
interim
status,
provided
that
the following
conditions
are fulfilled:
***
3) While
being accumulated
on-site, each
container
and tank
is labeled
or
marked
clearly with
the
words
“Hazardous
Waste”;
and
**
*
c)
Accumulation
near the
point
of generation.
1) A
generator
may
accumulate
as much
as 55
gallons of
hazardous
waste or
one quart
of
acutely
hazardous
waste
listed
in
35 III.
Adm.
Code
721.133(e)
in containers
at or near
any
point of
generation
where
wastes
initially
accumulate
that is
under
the
control of
the
operator
of the process
generating
the
waste
without
a permit
or interim
status
and
without
complying
with
subsection
(a) of this
Section,
provided
the generator
does
the
following:
A)
The
generator
complies
with.
. .35
III.
Adm.
Code
725.273(a);
and
B) The
generator
marks
the
containers
either
with
the words
“Hazardous
Waste”
or
with
other words
that identify
the
contents
of
the containers.
2) A generator
that
accumulates
either
hazardous
waste
or
acutely
hazardous
waste
listed in 35
III. Adm.
Code
721.133(e)
in
excess
of
the
amounts
listed
in subsection
(c)(1)
of this Section
at or near
any
point
of
generation
must,
with
respect to that
amount
of excess
waste, comply
7
within three
days with subsection (a) of
this Section or other applicable
provisions of
this Chapter. During the three
day period the generator
must continue
to comply with subsection
(c)(1) of this Section. The
generator must
mark the container holding
the excess accumulation of
hazardous
waste
with the date
the excess amount began accumulating.
d) A
generator
that generates greater than
100 kilograms
but less than 1,000
kilograms of hazardous waste
in a calendar
month may accumulate hazardous
waste on-site for 180
days or less without a permit
or without having interim
status provided that the
following conditions are fulfilled:
*
*
*
2) The generator
complies with the requirements of
Subpart
I
of 35 III.
Adm. Code 725 (35 Ill. Adm.
Code 725.276 and 725.278);
*
*
*
19.
Section 725.273 of the Board’s Hazardous
Waste Operating Regulations,
35
III.
Adm.
Code 725.273, provides, in pertinent part,
as
follows:
a)
A container holding hazardous waste must always be closed during
storage, except when it is necessary to add or remove waste.
*
*
*
20.
By
storing hazardous wastes without
a
RCRA permit, Respondent
has violated
Section 21(f)(1) of the Act,
415 ILCS 5/21(f)(1) (2006),
and
Section(s) 703.121(a) and
(b) of the
Board’s
RCRA Permit
Program Regulations,
35
III. Adm.
Code
703.121(a) and
(b).
21.
By storing
hazardous wastes in unlabeled containers, Respondent has violated
Section(s)
21(e) and
(f)(2) of the Act, 415 ILCS 5/21(e) and (f)(2) (2006), through Section(s)
722.134(a) and
(c) of the Board’s
Hazardous
Waste Operating Regulations, 35111. Adm. Code
722.134(a)
and (c)
and is not eligible for the permit exemptions provided by the same Board
Regulations.
22.
By storing hazardous
wastes
in the
pain vault
area
in open
containers,
Respondent
has violated
Section(s) 21(e) and (f)(2) of the Act, 415 ILCS 5/21(e) and (f)(2)
(2006),
through
Section 725.273(a) of the Board’s Hazardous Waste Operating Regulations,
35
Ill.
Adm. Code
725.273(a), and
is not eligible for the permit exemptions provide
by
Section(s)
8
722.134(c)
and (d)
of
the Board’s
Hazardous
Waste
Operating
Regulations,
35
III.
Adm. Code
722.134(c) and (d).
PRAYER FOR
RELIEF
WHEREFORE,
the Complainant,
the
People
of the
State of Illinois,
respectfully
requests
that
this Board grant the
following relief:
A.
Authorizing a hearing
in this matter
at which time
the Respondent
will be
required
to answer the allegations
herein;
B.
Finding
that the 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.
Pursuant to
Section 42(a) of the
Act, 415 ILCS
5/42(a) (2004),
imposing a civil
penalty of not more
than the statutory maximum;
and
E.
Granting
such other
relief as the Board
deems appropriate.
COUNT ill
NOISE VIOLATIONS
1.
Complainant realleges
and
incorporates
herein by
reference
paragraphs
I
through 4 of
Count I as
paragraphs I through
4 of this Count
Ill.
5.
Mli’s manufacturing
operations
create
increased sound
pressure
levels.
The
increased
sound pressure
levels emanate from
a number of
sources, particularly
continuous
exhaust
fan noise
and
frequent truck idling,
but also
backup beepers and
other associated
machinery
and
equipment.
6.
In June 2007, in
response to a citizen
complaint,
the
Office of the Attorney
General
contracted
with the professional
services of
Noise
Solutions
by Greg Zak, Inc.
(“Noise
Solutions”)
to
conduct sound level
measurements
of the facility.
9
7.
On June
14, 2007,
Noise
Solutions
performed sound
level measurements
during
daytime hours
at the residential
property nearest
to the facility,
with
the measurement
devices
directed
at the facility. The
measurement
devices
used,
along with
their
calibration
and
operation, were in
compliance with
the Board’s
required measurement
protocol,
the American
National
Standards Institute’s
requirements,
and
the International
Electro-technical
Commission’s
requirements.
8.
At all times relevant
to
this Complaint,
the facility
operated
on a 24-hour, 7
days a
week
basis.
Thus,
Noise
Solutions’s
measurements
are applicable
to the
Board’s
Noise
Regulations
for
both
daytime and nighttime
hours.
9.
At
all
times
relevant
to this
Complaint,
the
facility operated
on a
24-hour,
7 days
a
week
basis. Thus, Noise
Solutions was
unable to obtain
usable ambient
sound level
measurements.
As a result, Noise
Solutions followed
the Board’s
Regulations
for alternative
measurements
for ambient
sound
levels.
10.
Section
901.101(d)
of the Board’s Noise
Regulations,
35 III. Adm.
Code
901.101(d)
classifies the facility
as Class
C
Land.
Section 901.101(b),
35111. Adm.
Code,
classifies
the area residents’
property as Class
A Land.
11.
Section 24 of the Act,
415 ILCS 5/24 (2006),
provides
as
follows:
No person shall
emit
beyond
the boundaries of
his property
any
noise that
unreasonably
interferes with
the enjoyment
of life or with
any lawful business
or
activity,
so as to violate any
regulation
or standard
adopted by the Board
under
this Act.
12.
Section 900.102
of the Board’s
Noise
Regulations,
35111. Adm.
Code, provides
as
follows:
Prohibition of Noise
Pollution
No
person shall cause
or
allow
the
emission of sound
beyond the boundaries
of
his property, as
property is defined
in
Section
25 of
the
Illinois
Environmental
10
Protection Act, so as to cause noise
pollution in Illinois, or
so as to
violate
any
provision of
this Chapter.
13.
Noise Solutions measurements
of the facility’s
sound
pressure
levels included
70
db at
the 63 Hz octave band center frequency
(“octave band”),
68 db at the 125 Hz octave
band, 66 db at the 250 Hz octave band, 55
db
at the 500 Hz octave
band, 56 db at the I KHz
octave band, 56 db at the 2 KHz octave
band, 51 db at the 4 KHz octave
band, and 47 db at the
8
KHz octave band.
14.
Noise Solutions measurements
of the facility’s sound pressure levels
show
violations of
Section 901.102(a) of the Board’s
Noise
Regulations, 35 III. Adm.
Code
901.102(a), for
sound emitted from
a
Class
C Land to a Class A Land during daytime hours
at
the 250
Hz, 1 KHz, 2 KHz, 4 KHz, and
8
KHz
octave bands.
15.
Noise Solutions measurements
of the facility’s sound pressure levels show
violations of Section
901.102(b)
of the Board’s Noise
Regulations, 35
ill.
Adm. Code
901.102(b),
for sound
emitted from
a Class C
Land
to a Class A Land during nighttime hours
at
63
Hz, 125 Hz, 250
Hz,
500
Hz, I KHz, 2 KHz, 4 KHz, and
8
KHz octave
bands.
16.
Noise Solutions measurements of the facility’s sound pressure levels also
show
a
prominent
discrete tone at the 250 Hz octave band, in violation of Section 901.106(a) of the
Board’s Noise
Regulations, 35 Ill. Adm. Code 901.106(a).
17.
Mli’s
violations of Section(s)
901.102(a)
and (b), as well as Section 901.106(a)
of
the
Board’s Noise
Regulations, represent
a
violation
of Section 24
of
the Act, 415 ILCS 5/24
(2006)
and
Section 900.102 of the Board’s Noise Regulations, 35111. Adm.
Code 900.102.
PRAYER
FOR RELIEF
WHEREFORE, the
Complainant,
the People of the State of Illinois, respectfully
requests
that
this Board
grant the following relief:
11
A.
Authorizing a hearing
in this matter at which
time the Respondent will
be
required to answer the allegations herein;
B.
Finding that the
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.
Pursuant to
Section
42(a) of the Act, 415 ILCS 5/42(a) (2004),
imposing a civil
penalty of not more than
the
statutory maximum; and
E.
Granting such other relief as the Board deems appropriate.
Respectfully submitted,
PEOPLE
OF THE STATE OF ILLINOIS,
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
Of
Counsel:
STEPHEN
JANASIE
Assistant
Attorney
General
500
South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:_______
12
CERTIFICATE
OF
SERVICE
I hereby
certify
that
I
did
on
September
10,
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:
MEYERS
INDUSTRIES,
INC.
do
Paul
E.
Presney
726
South
Second
Street
Springfield,
IL
62704
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
StephK/1a
asie
Assistant
Attorney
General
This
filing
is
submitted
on
recycled
paper.
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
Complainant,
)
)
SEP
2’OOh
v.
)
PCBNo.
-
IfC
CotIJN0
)
(Enforcement)
MYERS
INDUSTRIES,
INC.,
)
)
Respondent.
)
ENTRY OF
APPEARANCE
On
behalf
of
the
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
STEPHEN
J.
JANASIE,
Assistant
Attorney
General
of
the
State
of Illinois,
hereby
enters
his 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,
Chief
Environmental
Enforcement/Asbestos
Litigation
Djvjsiop
BY:__________
Stephex’J/faIe
Environmenta
Bureau
Assistant
Attorney General
500
South
Second
Street
Springfield,
Illinois
62706
217/782-9031
Dated:
September
10,
2008