IN
    THE
    MATTER
    OF:
    PETITION
    OF
    AMEREN
    ENREGY
    GENERATING
    COMPANY
    FOR
    ADJUSTED
    STANDARD
    FROM
    35111.
    Adm.
    Code
    Parts 811,
    814 and
    815
    John Therriault,
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    100
    West
    Randolph
    Street
    Suite
    11-500
    Chicago,
    IL
    60601
    Carol
    Webb,
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    1021
    North
    Grand
    Ave East
    P.O.
    Box
    19276
    Springfield,
    Illinois
    62794
    CEVED
    CLERK’S
    OFFICE
    OCT
    20
    2008
    STATE
    OF
    WNOIS
    )
    PoUution
    Control
    Board
    )
    SchiffHardin,
    LLP
    Attn:
    Ms.
    Renee
    Cipriano
    and
    Amy
    Antoniolli
    233 South
    Wacker
    Drive
    6600
    Sears Tower
    Chicago,
    Illinois
    60606
    PLEASE
    TAKE
    NOTICE
    that I
    have
    today
    filed
    with
    the office
    of
    the
    Clerk
    of
    the
    Pollution
    Control
    Board
    an
    APPEARANCE and RESPONSE
    OF
    TIlE
    ILLINOIS
    EPA, copies
    of
    which
    are
    herewith
    served
    upon
    you.
    Respectfully
    submitted,
    Dated:
    October
    16,
    2008
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY,
    %L
    By:
    William
    D.
    Ingersoll
    Division
    of Legal
    Counsel
    1021 North
    Grand
    Avenue,
    East
    P.O.
    Box 19276
    Springfield,
    Illinois
    62794-9276
    217/782-5544
    217/782-9143
    (TDD)
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    AS
    09-01
    (Adjusted
    Standard—
    Land)
    )
    )
    )
    )
    NOTICE
    This filing
    submitted
    on
    recycled
    paper.

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    QC
    2.0
    2008
    IN THE
    MATTER
    OF:
    PETITION
    OF
    AMEREN
    ENREGY
    GENERATING
    COMPANY
    FOR
    ADJUSTED
    STANDARD
    FROM
    35
    Iii. Adm.
    Code
    Parts
    811,
    814 and
    815
    ENTRY
    OF
    APPEARANCE
    NOW
    COMES
    the undersigned,
    as counsel
    for
    and
    on the
    behalf
    of
    the Environmental
    Protection
    Agency
    of
    the
    State
    of
    Illinois,
    and
    hereby
    enters
    his
    Appearance
    in
    the above
    captioned
    matter.
    Dated:
    October
    16,
    2008
    Respectfhlly
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY,
    Respondent
    By
    1021
    North
    Grand
    Avenue,
    East
    P.O.
    Box
    19276
    Springfield,
    Illinois
    62794-9276
    217/782-5544
    217/782-9143
    (TDD)
    )
    Pollution
    STATE
    OF
    Control
    ILLINOIS
    Board
    )
    )
    AS
    09-01
    )
    (Adjusted
    Standard
    Land)
    )
    )
    William
    D.
    Ingersoll
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    This
    filing submitted
    on
    recycled
    paper.

    CLERK’S
    OFFICE
    BEFORE
    THE ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    ocr
    20
    2008
    IN THE
    MATTER
    OF:
    )
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    PETITION
    OF
    AMEREN
    ENERGY
    )
    AS 09-01
    GENERATING
    COMPANY
    )
    (Adjusted
    Standard
    — Land)
    FOR
    ADJUSTED
    STANDARD
    FROM
    )
    35111.
    Adm.
    Code
    Parts
    811,
    814
    and
    815
    )
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    RESPONSE
    TO
    BOARD
    ORDER
    OF
    SEPTEMBER
    16, 2008
    The
    ILLiNOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    (“illinois
    EPA”),
    by its
    attorney
    William
    D.
    Ingersoll,
    hereby
    submits
    its
    Response
    to
    the
    Illinois
    Pollution
    Control
    Board’s
    September
    16,
    2008,
    Order
    and questions
    contained
    therein.
    The
    Illinois
    EPA
    Responds
    as follows.
    I. INTRODUCTION
    1.
    On
    August
    11,
    2008,
    Ameren
    Energy
    Generating
    Company
    (“Petitioner”
    or
    “Ameren”),
    filed
    a petition
    for
    Adjusted
    Standard
    from certain
    standards
    set forth
    within
    35
    Ill.
    Adm.
    Code
    Parts
    811,
    814 and
    815 (“Petition”).
    (Pet.
    at
    1)
    2.
    According
    to the
    Petition,
    relief
    is
    sought
    to allow
    for closure
    of a
    unit
    created,
    operated
    and
    managed
    throughout
    its
    operating
    life
    as a surface
    impoundment,
    provided
    that
    such
    closure
    would
    not
    require
    that
    the facility
    comply
    with
    many
    of
    the
    solid
    waste
    landfill
    requirements
    contained
    within
    Parts
    811,
    814
    and 815
    and
    groundwater
    quality
    standards.
    (Pet.
    at
    2)
    3.
    On
    September
    16,
    2008,
    the
    Illinois
    Pollution
    Control
    Board
    (“Board”)
    issued
    an
    Order
    accepting
    Ameren’
    s
    petition,
    reserving
    the
    right
    to
    review
    the
    matter,
    and
    directing
    both
    Ameren
    and
    the
    Illinois
    EPA
    to
    answer
    certain
    questions
    posed
    within
    the Order.
    The
    Board
    also
    stayed
    the
    need
    for the
    illinois
    EPA
    to file
    a
    Recommendation
    pending
    its review
    of
    the
    threshold
    issues
    contained
    within
    the
    September
    16
    Order.
    II.
    QUESTIONS
    4.
    Tn
    its September
    16,
    2008,
    Order
    the
    Board
    posed
    three
    questions:
    (1)
    what
    authority
    exists
    for
    applying
    the
    Board’s
    landfill
    regulations
    to Pond
    D;
    (2)
    what requirements
    for
    closure
    of Pond
    D
    are
    addressed
    in
    the
    facility’s
    NPDES
    or other
    applicable
    permits;
    and
    (3) should
    the
    facts
    and
    circumstances
    presented
    require
    a
    site-specific
    rule?
    QUESTION
    1)
    What
    authority
    exists
    for
    applying
    the
    Board’s
    landfill
    regulations
    to
    PondD?
    RESPONSE:
    In
    short,
    and
    as more
    fully
    discussed
    below,
    the
    request
    to
    allow
    the
    waste
    to
    remain
    within
    Pond
    D require
    that
    the
    unit comply
    with
    the

    Board’s
    landfill
    regulations.
    5.
    Petitioner provides
    that
    “[a]ccording
    to
    the [Illinois
    EPA],
    the
    pond
    must
    now
    be
    closed
    consistent
    with
    the
    landfill
    regulations
    contained
    in 35
    Iii. Adm.
    Code
    Parts
    811
    through
    815, as
    they
    apply
    to the
    closure
    of Pond
    D.”
    (Pet.
    at
    1)
    Contrary
    to
    assertions,
    the Illinois
    EPA
    would
    frame
    the
    debate
    quite
    differently.
    More
    correctly,
    waste
    contained
    within
    Pond
    D
    may
    only
    be disposed within
    a permitted
    waste
    disposal
    site
    (of
    which
    Pond
    D
    is not)
    which
    may
    be
    a
    unit
    within
    the
    Ameren
    site
    or
    any other
    properly
    operating
    and
    permitted
    waste
    disposal
    site.
    If
    Pond
    D
    is
    the
    location
    for
    such
    disposal,
    then
    Pond
    D would
    have
    to satisfy
    the
    requirements
    for proper
    environmental
    control
    of
    potential
    contaminants.
    As
    constructed,
    Pond
    D
    does
    not
    qualify.
    It
    would
    be more
    correct
    to
    provide
    that
    wherever
    this
    waste
    is
    disposed,
    the unit
    must
    comply
    with
    applicable
    law
    and
    regulation,
    which
    are
    protective
    of
    human
    health
    and
    the
    environment.
    Petitioner’s
    assertion
    attributes
    to
    the
    Illinois
    EPA
    a
    conclusion
    that
    the
    waste
    must
    remain
    in
    place.
    It is
    important
    to
    remember
    that
    the
    waste
    currently
    within
    Pond
    D could
    be
    moved
    to
    a compliant
    waste
    disposal
    unit,
    as opposed
    to
    remaining
    in
    place,
    as
    Petitioner
    intends.
    6.
    As
    the
    Board
    correctly
    phrases
    the
    issue,
    it
    is the
    fact
    that the
    landfill
    regulations
    become
    “applicable”
    to Pond
    D,
    not that
    these
    regulations
    were
    intended
    initially
    to apply
    to
    such
    a
    unit.
    7.
    How
    do the
    regulations
    become
    “applicable?”
    Petitioner
    itself
    concludes
    that
    it
    seeks
    relief
    “...
    from
    regulations
    drafted
    to manage
    solid
    waste
    landfills,
    many
    of
    the
    landfill
    regulations
    are
    not
    applicable
    to a previously
    operated
    surface
    impoundment,
    permitted
    as a
    water
    pollution
    control
    facility...
    .“
    (Pet.
    at 2)
    Of
    course,
    this
    realization
    is mostly
    true,
    as it
    is
    very
    instructive
    on
    the issue
    of the
    applicability
    of
    the
    Board’s
    regulations
    to
    this
    situation.
    Again,
    Petitioner
    is
    acknowledging
    that
    the
    many
    regulations
    applicable
    to
    a
    unit
    subject
    to the
    regulations,
    from
    which
    it
    now
    seeks
    relief,
    do not
    apply
    to its
    unit,
    unless
    and
    until
    they
    are
    deemed
    to be
    seeking
    final
    disposal.
    Yet,
    by
    admission,
    the
    unit is
    a
    nreviously
    operated surface
    impoundment.
    The
    definition
    of “surface
    impoundment” found
    within
    35
    Ill. Adm.
    Code
    810.103
    states
    that
    such
    a
    unit
    is
    “...
    a
    natural
    topographic
    depression,
    a man-made
    excavation,
    or
    a dike
    dares
    into
    which
    flowing
    wastes,
    such
    as
    liquid
    wastes
    or
    wastes
    containing
    free
    liquids,
    are placed.
    For the
    purpose
    of
    this
    Part
    and
    35 Ill.
    Adm.
    Code
    811
    through
    815,
    a
    surface
    impoundment
    is not
    a landfill.
    Other
    Parts
    of 35
    111.
    Adm.
    Code:
    Chapter
    I may
    apply,
    including
    permitting
    requirements
    of
    35 III.
    Adm.
    Code
    309.”
    This
    definition
    clearly
    takes
    an
    active
    surface
    impoundment
    out of
    the
    landfill
    regulations
    and
    would
    place
    such
    a unit
    under
    the
    Board’s
    water
    regulations
    and
    compliance
    with
    an
    NPDES permit
    requirements
    to insure
    any
    discharge
    would
    not
    be
    injurious
    to
    waters
    of the
    State.
    An
    active
    unit,
    a unit
    which
    has
    “flowing”
    wastes
    through
    it,
    would
    not be
    required
    to
    comply
    with
    landfill
    regulations,
    in
    that
    it
    would
    be
    regulated
    under
    differing
    areas
    of the
    regulations.
    However,
    where
    such
    a
    unit
    ceases
    to
    be actively
    used
    as
    a surface
    impoundment,
    the
    waste
    contained therein
    would
    be
    required
    to
    be
    disposed
    of
    within
    a
    permitted
    and
    compliant
    waste
    disposal
    site.
    As
    the
    definitions
    within
    the regulations
    point
    out, a
    “landfill”
    is
    a
    unit
    in
    or on
    which
    waste
    is
    placed
    and
    accumulated
    over
    time
    for disposal.
    (See:
    35
    Iii.
    Adm.
    Code
    810.103;
    See
    also:
    45
    2

    ILCS
    5/3.185) “Disposal”
    is defined
    as
    meaning
    the
    discharge,
    deposit, injection,
    dumping,
    spilling,
    leaking
    or
    placing
    of
    any
    solid
    waste
    into
    or
    on
    any
    land
    or
    water
    ....
    such
    that
    solid
    waste
    or
    any
    constituent
    of
    the
    solid
    waste
    may
    enter
    the
    environment
    (or
    discharged
    into
    any
    waters,
    including
    groundwater).
    Moreover,
    Section
    810.103
    clearly
    states
    that
    “[i]f
    the
    solid
    waste
    is
    accumulated
    and
    not
    confined
    or
    contained
    to
    prevent
    its entry
    into
    the
    environment,
    or there
    is
    no
    certain
    plan
    for its
    disposal
    elsewhere,
    such
    accumulation
    shall
    constitute
    disposal.”
    It
    is
    evident
    from
    this
    definition,
    that
    a
    unit
    such
    as
    Pond
    D,
    where
    waste
    has
    been
    allowed
    to accumulate,
    enter
    the
    environment,
    and
    for
    which
    Petitioner
    has
    no
    plan
    for
    disposal
    elsewhere,
    falls
    within
    the
    intent
    of
    applying
    regulations
    which
    consider
    its
    impact
    on
    the
    environment,
    and
    which
    consider
    techniques
    to
    be
    applied
    that
    are
    be
    protective
    of the
    environment.
    8.
    Furthermore,
    the
    illinois
    EPA
    agrees
    with
    the
    Board’s
    brief
    discussion,
    within
    the
    September
    16
    Order,
    of
    the
    facts
    and
    analysis
    ofPetition
    of
    Commonwealth
    Edison
    for
    an
    Adjusted
    Standard
    from
    35
    ill.
    Adm.
    Code
    Parts
    811
    and
    814,
    AS
    96-9
    (Aug.
    15,
    1996).
    This
    matter
    is
    significantly
    different
    than
    the
    facts
    in
    that
    Petition.
    However,
    should
    Pond
    D
    be
    a
    disposal
    site,
    and
    as
    such
    a
    landfill,
    Petitioner
    would
    need
    to
    insure
    that
    the
    facility
    complied
    with
    applicable
    landfill
    regulations.
    QUESTION
    2)
    What
    requirements
    for
    closure
    of Pond
    D are
    addressed
    in
    the
    facility’s
    NPDES
    or
    other
    applicable
    permits?
    RESPONSE:
    The
    Illinois
    EPA
    is not
    aware
    of
    closure
    requirements
    within
    the
    currently issued
    permits
    applicable
    to
    Pond
    D.
    9.
    The
    NPDES
    permit
    issued
    for
    this
    facility
    does
    not
    contain
    closure
    requirements
    relative
    to final
    disposal
    of
    the
    waste
    in
    place.
    The
    illinois
    EPA
    is
    unaware
    of
    any
    other
    permit
    issued
    for
    this
    unit
    which provides
    for closure
    of
    the
    waste
    in place.
    QUESTION
    3)
    Should
    the
    facts
    and
    circumstances
    presented
    require
    a
    site-specific
    rule?
    RESPONSE:
    The
    facts
    and
    circumstances
    of
    this
    Petition
    are
    more
    appropriately
    a rule
    than
    a
    request
    for
    relief
    from
    the
    landfill
    regulations.
    10.
    As plainly stated
    by
    Petitioner:
    “...
    the
    circumstances
    applicable
    to
    this
    ash pond
    are
    very
    different
    from
    those
    contemplated
    by
    the
    Board
    in
    adopting
    Parts
    811
    through
    815.”
    (Pet.
    at
    2,
    Emphasis
    added)
    It is
    also
    notable
    that
    Petitioner’s contention
    that
    this
    ash
    pond
    is very
    different
    from
    a
    typical
    solid
    waste
    landfill
    is
    the
    matter
    of
    fact
    that,
    this
    very
    type
    of unit
    was
    not
    contemplated
    for permitting,
    other
    than
    for
    permitting
    for
    its
    intended
    purpose,
    as
    a
    water
    pollution
    control
    facility.
    11.
    Petitioner appears
    to
    base
    its very
    justification
    for
    relief
    from
    the
    regulations
    upon
    the
    concept
    that
    this
    ash
    pond
    is very
    unlike
    the
    units
    regulated
    by
    the
    rules
    in
    question.
    This
    may
    be
    true,
    but
    misses
    the
    point.
    Generally
    speaking,
    Adjusted
    Standard
    petitions
    are
    filed
    requesting
    3

    specific
    relief
    from
    rules
    of general
    applicability
    which
    apply to
    such units.
    A facility
    or
    person
    seeks relief,
    through
    Adjusted
    Standard,
    from
    regulations
    that were
    intended
    to apply to
    them,
    which
    regulations
    do
    not
    contemplate
    fully
    the
    specific
    facts
    or
    circumstances
    that
    effect
    their
    situation.
    Additionally,
    Petitioner
    will
    demonstrate
    that
    the
    alternate
    form
    of compliance
    is
    equivalent
    to that
    contained
    within
    the general
    rule. What
    Petitioner
    request
    in this
    pleading is
    for
    a
    waste treatment
    facility/unit
    to
    be
    “classified”
    as a non-compliant
    closed
    landfill.
    Such
    a stretch
    was
    not contemplated
    by
    the general
    regulations,
    since
    the
    general
    regulations
    were
    not
    meant
    to
    apply
    to units not
    intending
    to be regulated
    as
    a
    final
    disposal
    unit
    in
    the
    first place.
    Section
    102.210
    of
    the
    Board’s procedural
    rules does
    allow for
    a site-specific
    regulation(s).
    It would
    be
    the
    Illinois
    EPA’s contention
    that
    this procedure
    may
    be
    more
    appropriate
    for review
    of
    Petitioner’s
    request.
    However,
    it
    must
    be noted
    that it has
    been
    approximately
    18 years since
    the Board
    has,
    in
    general,
    considered
    this
    type of
    facility.
    In
    that time,
    considerable
    review
    has been
    had
    on the
    national
    level regarding
    coal
    ash
    disposal
    and
    environmental
    and
    health
    impacts
    from such
    activity.
    A significant
    number
    of units
    will likely
    fall within
    the category
    of
    sites
    where coal
    ash
    remains
    in
    regulated
    units,
    some
    of which
    are no
    longer accepting
    or
    processing
    waste. It
    may be
    appropriate
    (from
    an
    environmental,
    economic
    and policy
    standpoint)
    to review,
    this
    entire
    group
    of facilities
    as
    opposed to
    engaging
    in numerous
    site specific
    rulemakings.
    12.
    Within
    the Introduction,
    Petitioner
    provides
    that
    “.
    . .Ameren
    considers Pond
    D
    at
    closure
    as
    an “existing”
    facility
    because it
    accepted
    waste
    prior to
    September
    18, 1990,
    the
    effective
    date of
    the
    landfill
    regulations.”
    (Pet. at
    2)
    Significant
    debate
    has occurred
    relative
    to this
    issue.
    What
    can be said,
    in general,
    is that
    if Petitioner
    placed waste
    within
    a
    unit
    following
    1990
    and
    continued
    past
    1997, and
    IF the
    ash pond is
    to
    be
    a final
    waste disposal
    site,
    the regulations
    which
    would be
    applicable
    to
    such
    a
    landfill would
    be
    those
    of Parts
    811
    through
    815 as
    opposed
    to Part
    807.
    In
    Other words,
    if the
    Petitioner
    were
    to
    have a surface
    impoundment
    prior to
    1990,
    and
    continue use
    past
    1997, the
    resulting
    waste
    unit,
    under
    the landfill
    regulations,
    would
    be considered
    analogous
    to a
    landfill
    placing
    waste within
    an existing
    unit,
    and
    by
    comparison,
    the
    Petitioner’s
    unit would
    be
    considered
    an
    “existing”
    unit under
    the landfill
    regulations.
    13.
    It is
    very
    important
    to point
    out that discussion
    of the application
    of the
    landfill
    regulations
    to such units
    has
    concerned
    both
    the Illinois
    EPA
    and Board
    in
    the past.
    As
    noted
    in
    footnote
    2 of the
    Board’s April
    9,
    1992 Order
    in
    R
    90-25,
    the Board
    did
    not
    want
    the
    Utility
    Group’s
    deletion
    of “existing
    utility
    ash ponds”
    from
    the
    proposed
    rulemaking
    to be
    construed
    as a
    determination
    that such
    units
    “...
    do not
    become
    landfills
    upon
    closure.” The
    Illinois
    EPA
    would
    still agree
    with
    this statement,
    to the extent
    that
    it evidences
    a concern
    that such
    units
    not
    fall
    outside
    of
    regulations
    which
    apply to
    a disposal
    site designed
    to protect
    human
    health
    and
    the
    environment.
    III. CONCLUSION
    14.
    Petitioner
    seeks
    to transform
    an
    unlined
    wastewater
    treatment
    system
    into
    a
    fmal
    disposal
    site
    for
    solid
    waste.
    Petitioner
    seeks to
    construct
    a solid waste
    disposal
    unit
    without
    a
    permit;
    seeks
    relief
    from
    past activity
    applicable
    to such
    a
    unit; requests
    to forgo
    most,
    if not
    essentially
    all,
    of
    the leachate
    requirements;
    proposes
    to
    add additional
    waste
    and other
    materials
    to
    4

    create a
    cap; by
    omission
    seeks that financial assurance, closure plan perpetration
    and approval
    and
    post closure care requirements
    be
    forgone;
    and finally requests relief from groundwater
    standards
    applicable
    to the very contaminants commonly found
    (and indeed found in this case) within
    the
    waste
    proposed for final disposal.
    15.
    The constructed and closed facility
    that
    would
    result from the requested relief
    does
    not fit
    within the spirit nor intent of the solid waste landfill disposal
    regulations
    from
    which
    relief
    is
    sought and, more importantly, shoehoming
    this unit into such requirements is only less
    attractive
    than allowing
    for disposal absent most of the applicable
    regulatory requirements set in place
    to
    insure proper construction,
    operation and
    maintenance
    of final disposal units.
    16.
    Tn general, it may fairly be surmised
    that
    this
    Petition
    seeks relief from disposal
    of
    waste within a properly permitted facility
    by
    requesting
    to create by Adjusted Standard a new
    type
    of disposal site, absent many requirements
    on
    other
    disposal sites which insure protection
    of the
    environment and human health. Thus, this Petition
    sounds more similar to a proposed new class
    of
    general rule, and as such, general relief from more stringent
    and
    specific
    requirements
    should likely
    not be granted in this matter.
    WHEREFORE, in accordance with the Board’s September
    16,
    2008 Order in this
    matter,
    the
    Illinois EPA respectfully offers the forgoing review
    and analysis for the Board’s consideration.
    Respectfully submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION AGENCY
    By:
    DATED: October 16,
    2008
    1021 North Grand Ave. East
    P.O. Box
    19276
    Springfield, Illinois
    62794-9276
    217/782-5544
    William
    D. Ingersoll
    Division of Legal Counsel
    5

    CERTIFICATE
    OF SERVICE
    I, the
    undersigned
    attorney
    at law,
    hereby certify
    that on
    October
    16,
    2008 I
    served true
    and
    correct
    copies
    of
    an APPEARANCE
    and
    RESPONSE
    OF
    THE
    ILLINOIS
    EPA,
    by
    causing
    to be
    placed
    true and
    correct
    copies
    in
    properly
    sealed
    and addressed
    envelopes
    and
    by depositing
    said
    sealed envelopes
    in
    a
    U.S.
    mail
    drop box
    located
    within
    Springfield,
    Illinois,
    with sufficient
    postage
    affixed
    thereto, upon
    the
    following
    named
    persons:
    John
    Therriault,
    Clerk
    SchiffHardin,
    LLP
    Illinois Pollution
    Control
    Board
    Attn:
    Ms.
    Renee
    Cipriano
    and
    Amy
    Antoniolli
    James R.
    Thompson
    Center
    233
    South
    Wacker Drive
    100
    West
    Randolph
    Street
    6600
    Sears
    Tower
    Suite
    11-500
    Chicago, Illinois
    60606
    Chicago,
    IL
    60601
    Carol
    Webb,
    Hearing Officer
    flhinois Pollution
    Control
    Board
    1021 North
    Grand Ave
    East
    P.O. Box
    19276
    Springfield,
    Illinois
    62794
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY,
    Respondent
    By:
    William
    D.
    Ingersoll
    Division
    of Legal
    Counsel
    1021 North
    Grand
    Avenue,
    East
    P.O.
    Box 19276
    Springfield,
    Illinois
    62794-9276
    217/782-5544
    217/782-9143
    (TDD)
    This filing submitted
    on
    recycled
    paper.

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