JAN
292009
PoUuto
STATE
OF
Control
ILLINOIS
SOard
OFFICE
OF
THE
ATTORNEY
GENERAL
STATE
OF
ILLINOIS
AIlORNEY
Lisa
Madigan
GENERAL
December
28,
2008
John
T.
Therriault,
Assistant
Clerk
Illinois
Pollution
Control
Board
James
R.
Thompson
Center,
Ste.
11-500
100
West
Randolph
Chicago, Illinois
60601
Re:
People
v. Pekin
Paperboard,
Co.
PCB
05-163
Dear
Mr.
Therriault:
This
letter
is
a
follow-up
to
our
telephone
conversation
on
Tuesday,
January
27,
2009.
As
I explained to
you
on
the phone,
I intended
to file
an
Amended
Complaint with
the
previously
filed
Stipulation
and
Proposal
for
Settlement in
the
above-captioned
matter. In inadvertently
mailed
the
Stipulation
without
the
Amended
Complaint.
Enclosed
for
filing
please
find
the
original
and
ten
copies
of
a Notice
of
Filing
and
Amended Complaint.
Please
file the
original
and
return
a file-stamped
copy
to
me
in
the
enclosed
envelope.
As
a
reminder,
this
is
not
a new
case.
The
Amended
Complaint
is to
be
filed
as
part
of the
previously
filed
Stipulation
and
Proposal
for Settlement
in
case
number
05-163.
I apologize for
this
oversight
and
any
inconvenience
it
may
have
caused.
Thank
you
for
your
cooperation.
Sincerely,
Andrew
J.
Nicholas
Environmental
Bureau
500
South
Second
Street
Springfield,
Illinois
62706
(217)782-9031
Enclosures
cc:
Jane
DiRenzo Pigott,
Respondent’s
Attorney
Carol
Webb,
Hearing
Officer
IPCB
500
South
Second
Street,
Springfield,
Illinois
62706
• (217)
782-1090
• TTY:
(877)
844-5461
•
Fax:
(217)
782-7046
100
West
Randolph
Street,
Chicago,
Illinois
60601
• (312)
814-3000
• TTY:
(800)
964-3013
• Fax:
(312)
814-3806
Iflfl
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BEFORE
THE ILLINOIS
POLLUTION
CONTROL BOARD
PEOPLE
OF
THE STATE
OF
ILLINOIS,
)
Complainant,
vs.
)
PCB No.
05-1 63
)
(Enforcement)
PEKIN PAPERBOARD COMPANY, L.P.,
a Delaware limited partnership,
)
Respondent.
ECEVED
NOTICEOF FILING
CLERKS OFFICE
JAN 2
2009
To:
Ms.
Jane DiRenzo Pigott
STATE
OF
ILLINOIS
Attorney at Law
Pollution
Control
Board
One N.
LaSalle
St.,
Suite 1904
Chicago,
IL 60602
PLEASE TAKE
NOTICE
that on this date I mailed for filing
with the Clerk of
the Pollution
Control
Board of the State of Illinois, an AMENDED COMPLAINT,
a copy of which is
attached
hereto
and
herewith served upon
you. -
Respectfully submitted,
PEOPLE
OF THE STATE
OF ILLINOIS
LISA MADIGAN,
Attorney General
of the
State of Illinois
MATTHEWJ. DUNN, Chief
Environmental
Enforcement/Asbestos
Litigation Division
BY:___
ANDREW . NICHOLAS
Assistant
Attorney
General
Environmental
Bureau
500
South
Second
Street
Springfield,
Illinois 62706
217/782-9031
Dated:
January 28,
2009
CERTIFICATE
OF
SERVICE
I
hereby
certify that
I did
on January
28, 2008,
send by First
Class
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
and AMENDED
COMPLAINT
To:
Ms. Jane
DiRenzoPigott
Attorney
at Law
One N. LaSalle
St., Suite 1904
Chicago, IL
60602
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
A copy was also
sent
by
First
Class Mail with postage
thereon fully
prepaid to:
Carol Webb
Hearing Officer
Illinois Pollution
Control
Board
1021
North Grand Avenue
East
Springfield,
IL 62794
Andrew
J.
l’ticholas
Assistant
Attorney
General
This filing is submitted
on recycled
paper.
BEFORE
THE ILLINOIS POLLUTION
CONTROL
BOARD
PEOPLE OF THE
STATE OF ILLINOIS,
)
Complainant,
v.
)
PCB
No. 05-163
)
(Water-Enforcement)
PEKIN PAPERBOARD COMPANY,
L.P.,
)
ECEVBD
a Delaware limited partnership,
)
CLERK’S
OFFICE
)
JAN
2
2009
Respondent.
STATE
OF
ILUNOIS
AMENDED
COMPLAINT
PollUt0fl
Control
Board
Complainant, PEOPLE OF THE STATE
OF
ILLINOIS,
by LISA MADIGAN, Attorney
General of the State of
Illinois, complains of
Respondent, PEKIN PAPERBOARD
COMPANY,
L.P., a
Delaware limited partnership, as follows:
COUNT I
NPDES PERMIT VIOLATIONS
1.
This Complaint is brought by the Attorney General on her own motion
and at the
request of the
Illinois Environmental
Protection
Agency
(“Illinois EPA”), pursuant
to the terms
and
provisions of Section 31 of the Illinois
Environmental
Protection Act (“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 a/ia, with the
duty of
enforcing
the Act.
3.
This Complaint is
brought pursuant to
Section 31 of the Act, 415 ILCS
5/31 (2006),
after
providing the
Respondent with notice and the opportunity
for a meeting with the Illinois
EPA.
1
4.
Pekin Paperboard
Company,
L.P. (‘Pekin
Paperboard”), is
a Delaware
limited
partnership authorized
to
do
business
in the State
of Illinois.
5.
Pekin Paperboard
manufactures
cereal
containers
using
recycled
materials
at
a
facility at
1525
South
Second Street, Pekin,
Tazewell
County, Illinois.
This facility
includes
a
wastewater
treatment plant (‘WWTP”)
which
receives and treats
process
wastewater
from
the
production operations.
The effluent
from
the WWTP
is discharged via
an outfall
designated
as
AOl
to
a
storm
sewer
which
discharges
to
a
ditch.
This “effluent
ditch”
flows
into
a canal
which
connects
Crystal Lake to the Illinois
River.
In addition
to
storm
water from
the facility site,
which
includes
storm water
from
the facility’s
waste and paper
storage and
handling
areas,
the
storm
sewer
also receives discharges
of non-contact
cooling water
from a turbine
generator and
well
water
storage tank
overflow via outfall
DOl, neutralized
zeolite softener
regeneration water
via
outfall COl,
boiler blowdown via
outfall B01, and acid
regenerated
demineralizer
column
wastewater
from a water
purification process.
The discharges
from the WWTP
and
the
designated
outfalls
are authorized
pursuant to National
Pollutant
Discharge
Elimination
System
(NPDES”)
Permit No. IL0037729.
6.
The
effluent ditch, the canal,
Crystal Lake,
and the Illinois
River are “waters”
of
the
State as that
term is defined
in Section
3.550 of the Act, 415
ILCS 5/3.550
(2006), as
follows:
“Waters” means all
accumulations
of water, surface and
underground, natural,
and
artificial,
public and private,
or
parts
thereof,
which
are wholly or partially
within,
flow
through, or
border
upon this
State.
7.
Section
3.545
of
the
Act, 415 ILCS 5/3.545
(2006), provides
the following
definition:
“Water pollution”
is such
alteration of the physical,
thermal,
chemical,
biological
or
radioactive
properties
of
any waters
of the
State,
or such discharge
of any contaminant
into any waters
of the
2
State,
as
will or
is
likely
to
create
a
nuisance or render
such
waters harmful or detrimental
or
injurious
to public health, safety
or
welfare,
or to domestic, commercial, industrial, agricultural,
recreational,
or other legitimate uses, or to
livestock,
wild animals,
birds, fish, or other aquatic life.
8.
Section 12 of
the
Act, 415 ILCS 5/12
(2006),
provide the following
prohibitions:
No person shall:
(a)
Cause or threaten or allow the
discharge
of any
contaminants into the environment in any State so
as to cause or tend to cause water
pollution
in
Illinois, either alone or in combination
with
matter
from other sources, or so as to violate
regulations
or standards adopted by the
Pollution Control
Board under
this
Act;
***
(f)
Cause, threaten
or allow
the
discharge of any
contaminant
into
the
waters
of
the State, as
defined herein,
including
but
not limited to, waters
to any sewage
works, or
into
any well or from any
point source
within
the
State,
without an NPDES
permit for point
source discharges issued by the
Agency under
Section
39(b) of this Act, or in
violation of
any term or condition imposed by
such
permit, or in
violation of any
NPDES permit filing
requirement established
under
Section 39(b),
or in
violation of any
regulations
adopted by
the Board
or of any order adopted by the
Board with respect
to the NPDES
program.
***
9.
Section 309.102(a) of the Board’s
Water Pollution Regulations, 35111. Adm.
Code
309.102(a) (2005),
provides:
a)
Except
as
in compliance with the provision of
the
Act, Board regulations, and the
CWA,
and the
provisions and conditions of the
NPDES permit
issued to the
discharger,
the
discharge
of any
contaminant or
pollutant
by
any person into the
waters
of the
State from
a
point source or into
a
well shall
be
unlawful.
3
10.
Section
304.141(a)
of the Board’s
Water Pollution
Regulations,
35 III.
Adrn.
Code
304.141
(a)
(2005),
provides:
a)
No person to whom
an NPDES
Permit has
been
issued may
discharge any
contaminant
in his
effluent
in
excess
of
the
standards
and limitations
for that
contaminant
which are
set forth
in
his
permit.
11.
Congruent
with
Section
304.120
of the
Board’s
Water
Pollution
Regulations,
35
Ill. Adm. Code 304.120
(2005),
Pekin
Paperboard’s
NPDES
Permit imposes
effluent
concentration
limitations
for total
suspended
solids
(“TSS”) and five-day
carbonaceous
biochemical
oxygen
demand (“CBOD
5
”),
each
of which is a “contaminant”
as that term is
defined
in Section 3.165 of
the Act, 415
ILCS 5/3.165
(2006). Discharge
Monitoring Reports
(“DMRs”) are submitted
monthly
in accordance
with the NPDES
Permit
to report
the
concentrations
of
contaminants
in
the
effluent.
12.
The effluent concentration
limitations
for CBOD5are
25
milligrams
per liter
(‘mg/I”)
on a
monthly
average
and
50
mg/I
for a daily maximum.
The concentration
limitations
for TSS are 30 mg/I
on a monthly average
and 60 mg/I
for a daily maximum.
13.
Pekin Paperboard
reported
in
its DMRs for the months
of January,
February,
and
March
of 2001; February,
March, April,
May, June, July,
August,
September,
October,
and
November of
2002;
January, February,
April, and
May of 2003;
November of 2005,
February,
April, May, October
and December
of 2006; January,
February,
March, April,
May, June,
July,
September,
October, November,
and December
of 2007;
and January, February,
March,
April,
August, September,
October,
and
November of 2008,
that
it had
exceeded
the
monthly average
effluent limitation
of 30 mg/I for
TSS.
14.
Pekin Paperboard
reported
in its DMRs for
the months
of March
of
2001;
4
February,
April, May,
June,
August,
September,
and October
of 2002; January,
and February
of
2003;
February,
April, May,
and December
of 2006;
January,
February,
March,
September,
and
December
of 2007; and
January,
February, March,
April, August,
September,
October, and
November
of 2008, that
it
had exceeded the
daily maximum
effluent limitation
of
60
mg/I
for
TSS.
15.
Special Condition
12
of Pekin
Paperboard’s
NPDES Permit
requires the
facility
to implement
the
provisions
of a storm
water
pollution
prevention
plan atthe facility.
The
storm
water
pollution prevention
plan must include,
among
other
items, storm water
management
controls
which
will
be
implemented
by the facility.
These controls
must
include
good
housekeeping and
storm
water management
practices
such as containment
and debris
control.
16.
On
August
30, 2002,
the
Illinois
EPA inspected
the
WWTP
to evaluate
its
compliance
with the
NPDES Permit.
The Illinois
EPA inspector
observed that
there were at
least two storm
drains near
the
powerhouse
that receive paper
waste
runoff
and spillage
from
the
compactor
box
storage area. The
Illinois
EPA inspector
observed
paper waste on
the
ground
in this area,
covering one
of
the
storm inlets.
Paper waste
is
a “contaminant”
as
that
term is
defined in Section
3.165 of the Act,
415
ILCS
5/3.165
(2006).
17.
Pekin
Paperboard
has
caused or allowed
the discharge
of
contaminants
into
waters
of the State
in violation of
the terms
or
conditions
of its
NPDES
Permit
and
has thereby
violated Section
12(f) of the
Act,
415
ILCS
5/12(f) (2006).
18.
By
discharging contaminants
into waters
of the
State
in violation
of the terms or
conditions
of its
NPDES
Permit,
Pekin Paperboard
has thereby violated
Sections
304.120,
304.141(a),
and
309.102(a) of
the
Board’s
Water Pollution
Regulations, 35111.
Adm. Code
304.120,
304.141(a),
and 309.102(a) (2005).
19.
By
discharging
contaminants
into waters
of the State
so
as
to violate
regulations
5
or
standards
adopted
by
the Pollution Control Board under this
Act, Pekin
Paperboard has
thereby violated
Section 12(a) of the Act, 415
ILCS 5/12(a) (2006).
20.
By
failing to maintain
adequate storm water management
controls
at its facility
as required by its NPDES Permit,
Pekin
Paperboard
has caused, threatened
or allowed
the
discharge of any contaminant into the waters
of the State in violation
of
its
NPDES permit,
and
has thereby violated Section
12(f) of the Act, 415 ILCS 5/12(f) (2006).
PRAYER
FOR RELIEF
WHEREFORE,
Complainant, the PEOPLE OF THE STATE
OF ILLINOIS, respectfully
request that the Board enter an order against
the
Respondent
PEKIN PAPERBOARD
COMPANY, L.P.:
A.
Authorizing a hearing in this matter at which
time the Respondent will
be
required
to
answer the allegations herein;
B.
Finding that 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.
Assessing against Respondent a civil penalty of fifty thousand
dollars ($50,000)
for
each violation of the Act, and an additional penalty often thousand dollars
($10,000) for
each day during which each violation has
continued thereafter;
and
E.
Granting
such
other relief
as
the Board may
deem appropriate.
COUNT H
OPERATIONAL VIOLATIONS
1-10. Complainant realleges and incorporates herein by reference
paragraphs
1
through 10 of Count I as paragraphs 1
through
10 of this Count II.
6
11.
On August
30, 2002, the
Illinois
EPA inspected the VVWTP
to
evaluate
its
compliance with the NPDES Permit. The
effluent being discharged via outfall AOl
and the
water within the effluent
ditch were brown and turbid. The Illinois EPA
inspector noted that
sludge
had last been removed from the lagoon
in
1997.
There
were
paper
solids
and
wastewater sludge within
the
ditch. The lagoon
screens at the outfall were clogged, thereby
causing the lagoon to
be
overfilled.
12.
The Illinois EPA issued
a
violation
notice to Pekin
Paperboard
on September
30,
2002. A
meeting
was held on
November 25,
2002.
13.
On December 5, 2002, the Illinois EPA again inspected the WWTP to evaluate
its compliance with the NPDES Permit. The effluent being discharged
via
outfall AOl and the
water within the effluent ditch were brown and turbid. There were
additional paper solids
and
wastewater sludge
within
the
ditch.
14.
On January
29, 2003, the Illinois EPA conducted a reconnaissance inspection of
the
WVVTP. There were not only
solids and sludge in the ditch but
also wastewater. A
sample
of
the
effluent was
determined
to
contain 140 mg/I of TSS.
15.
On
March 5, 2003,
the
Illinois EPA conducted
another reconnaissance
inspection of the WVVTP. The
effluent
was
brown
and
turbid; the water in the effluent ditch
contained floating solids.
16.
On
April 29, 2003, the Illinois EPA again inspected the
WWTP
to
evaluate
its
compliance
with the NPDES
Permit.
The
Illinois EPA determined that the permitted outfalls
BOl,
Cal, and
DOl were not being separately sampled as required by the NPDES Permit.
The
solids
and sludge
in the ditch had been removed. The water in the effluent ditch was brown.
17.
On May 29, 2003, the
Illinois EPA conducted
a
follow-up inspection and
observed
that the
water in
the
effluent ditch was brown.
7
18.
On
June 23, and
July
30, 2003,
the Illinois
EPA
again inspected
the
VVVVTP,
primarily
to
observe
the
dredging
of the lagoon.
On
the
latter
occasion,
the effluent
was
gray
with
a
strong
septic
odor; the
water in
the effluent
ditch was
also
gray with unnatural
algal
growth
and
sludge
deposits.
A sample
of
the
effluent taken
on
July
30,
2003, was
determined
to contain
190
mg/I of
BOD
5
.
19.
On August
28, and
September
18,
2003,
the
Illinois EPA
again inspected
the
VVVVTP
after
the
completion
of the
lagoon dredging.
On
both
occasions,
the
effluent
was
brown
with
a
slight
septic
odor.
20.
On
October
28, 2003,
the Illinois
EPA
conducted
a
reconnaissance
inspection
of
the WVVTP.
There
was
sludge
in a low
area
near
the access
gate
to the
lagoon.
21.
On July
15, 2004,
the Illinois
EPA again
inspected
the WWTP.
The lagoon
effluent
was
not discharging,
as the pump
was
air
locked. The
Illinois EPA
noted some
gray
sludge
deposits
present
in the
receiving
stream.
Paper
sludge
was
present in
the low area
downstream
of
the overflow
pipe.
22.
Section
306.102
of the
Board’s Water
Pollution
Regulations,
35 III.
Adm. Code
306.102,
provides:
System
Reliability
Malfunctions:
All
treatment
works
and
associated
facilities
shall
be
constructed
and
operated
as
to
minimize
violations
of
applicable
standards
during
such contingencies
as
flooding,
adverse
weather,
power failure,
equipment
failure,
or
maintenance,
through such
measures
as multiple
units,
holding
tanks,
duplicative
power
sources,
or
such
other measures
as may
be
appropriate.
Spills:
All
reasonable
measures,
including
where
appropriate
the
provision
of
catchment
areas,
relief vessels,
or entrapment
dikes,
shall be
taken
to prevent
any
spillage
of
contaminants
from
causing
water
pollution.
23.
By
failing
to sample
each of
the
permitted
outfalls
as
required
and
discharging
8
contaminants
into waters of the State in violation of
the terms or conditions of its
NPDES
Permit,
Pekin Paperboard has thereby violated
Section 12(f) of the Act,
415
ILCS
5/12(f)
(2006), and Section 309.102(a) of
the
Boards
Water Pollution Regulations,
35 III.
Adm.
Code
309.102(a)
(2005).
24.
By allowing
bypasses and overflows
of untreated wastewater to occur,
Pekin
Paperboard has
violated
Section 306102 of the Boards
Water
Pollution
Regulations,
35111.
Adm. Code 306.102 (2005).
25.
By discharging contaminants into waters
of the State so as
to
violate
regulations
or
standards adopted by the Pollution Control Board under
this Act, Pekin Paperboard
has
thereby
violated Section 12(a) of the Act, 415 ILCS 5/12(a)
(2006).
PRAYER
FOR RELIEF
WHEREFORE, Complainant,
the
PEOPLE
OF THE STATE OF ILLINOIS,
respectfully
request that the
Board enter
an
order against
the Respondent PEKIN PAPERBOARD
COMPANY, L.P.:
A.
Authorizing a hearing in this matter at which time
the Respondent will be
required to
answer
the
allegations herein;
B.
Finding that 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.
Assessing
against
Respondent
a civil penalty of fifty
thousand dollars
($50,000)
for
each violation of
the Act, and
an
additional
penalty
of ten thousand dollars
($10,000) for
each day during
which each violation
has
continued
thereafter; and
E.
Granting such other relief as the
Board may deem appropriate.
9
COUNT HI
WATER POLLUTION
1-8.
Complainant
realleges and incorporates herein by reference paragraphs 1
through
8
of Count I as paragraphs
1
through
8 of this
Count IlL
9-19. Complainant realleges and incorporates herein by reference paragraphs 11
through 21 of Count II as paragraphs
9
through 19 of this Count lii.
20.
Section
302.203
of the Board’s Water
Pollution Regulations, 35111. Adm. Code
302.203 (2005), provides:
Offensive
Conditions
Waters
of
the
State
shall
be
free from sludge or bottom
deposits,
floating debris, visible
oil,
odor,
plant or algal growth,
color
or
turbidity
of other
than natural origin. The allowed
mixing
provisions of Section
302.102
shall not be used to
comply with the
provisions of
this
Section.
21.
Section
304.105 of the
Board’s Water Pollution
Regulations, 35 Ill. Adm. Code
304.105 (2005),
provides:
Violations of Water Quality
Standards
In addition to the
other requirements of this Part, no
effluent shall,
alone
or in combination with other sources, cause a
violation
of
any
applicable water quality standard. .
22.
Section 304.106 of the Board’s Water
Pollution Regulations, 35 III. Adm. Code
304.106
(2005),
provides:
Offensive
Discharges
In
addition
to the
other
requirements of this
Part, no effluent shall
contain settleable solids, floating debris,
visible oil, grease, scum
or
sludge solids. Color, odor and
turbidity
must
be reduced to
below obvious levels.
10
23.
Pekin Paperboard
has
caused or allowed the discharge
of
effluent
in violation
of
Section 304.106 of
the
Board’s
Water Pollution
Regulations,
35
Ill. Adm.
Code 304.106 (2005).
Since these offensive discharges
resulted
in violations of water quality standards,
Pekin
Paperboard also
violated
Sections 302.203
and 304.105 of the Board’s Water Pollution
Regulations, 35 Ill. Adm.
Code
302.203,
304.105 (2005).
24.
By so violating the Board’s Water
Pollution Regulations, Pekin Paperboard
has
thereby violated Section 12(a) of the Act,
415 ILCS 5/12(a) (2006).
25.
Pekin
Paperboard
has caused, threatened
or allowed water
pollution
in that such
discharges of
contaminants
likely rendered
the
waters
of the State harmful or
detrimental
or
injurious to public health, safety or welfare, or
to
agricultural, recreational,
or other
legitimate
uses, or to livestock,
wild
animals, birds, fish or
other
aquatic life and have likely created
a
nuisance.
26.
By causing or allowing the discharge of contaminants
in
such
a
manner as
to
cause or threaten water pollution, Pekin Paperboard has violated Section 12(a) of the Act, 415
ILCS 5/12(a) (2006).
PRAYER FOR RELIEF
WHEREFORE, Complainant, the PEOPLE
OF THE STATE OF ILLINOIS, respectfully
request that
the
Board enter an order against the
Respondent PEKIN
PAPERBOARD
COMPANY, L.P.:
A.
Authorizing
a
hearing
in this
matter
at which time the Respondent will be required
to
answer
the allegations herein;
B.
Finding that 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;
11
D.
Assessing
against
Respondent
a civil
penalty
of
fifty
thousand
dollars
($50,000)
for
each
violation
of the
Act, and
an
additional
penalty
of
ten
thousand
dollars
($10,000)
for
each
day
during which
each
violation
has
continued
thereafter;
and
E.
Granting
such other
relief
as the
Board
may
deem
appropriate.
Respectfully
submitted,
PEOPLE
OF THE
STATE OF
ILLINOIS,
ox rol.
LISA MADIGAN,
Attorney
General
of
the
State
of
Illinois
MATTHEWJ.
DUNN,
Chief
Environmental
Enforcement/Asbestos
BY:
Litigatii
ANDREWJ.
ICHOLAS
Environmental
Bureau
Assistant
Attorney
General
Attorney Reg.
No.
6285057
500
South
Second
Street
Springfield,
Illinois
62706
217/782-9031
Dated:
January
28,
2009
12