RECEVED
    CLERK’S
    OFFICE
    BEFORE THE ILLINOIS
    POLLUTION
    CONTROL BOARD
    UNITED CITY OF
    YORKVILLE, A
    )
    MUNICIPAL
    CORPORATION,
    )
    Pt
    Control
    Board
    Petftioner,
    )
    )
    PCB No. 08-96
    v.
    )
    Enforcement-Land,
    Air, Water
    )
    ILLINOIS
    ENVIRONMENTAL
    )
    PROTECTION
    AGENCY, and
    )
    HAMMAN
    FARMS,
    )
    Respondents.
    )
    NOTICE OF FILING
    TO: SEE
    PERSONS ON
    ATTACHED SERVICE
    LIST
    PLEASE
    TAKE
    NOTICE that I
    have
    today filed with the
    Office of Clerk of the Illinois
    Pollution
    Control
    Board, an original and
    nine copies
    each of AMENDED COMPLAINT,
    copies of
    which are
    herewith served upon you.
    Respectfully
    submitted,
    UNITED CITY OF YORKVILLE,
    Petitioner,
    By
    rk
    One
    of
    its
    Attorneys
    Dated: May 7,
    2009
    Thomas G.
    Gardiner
    Michelle
    M.
    LaGrotta
    GARDINER
    KOCH &
    WEISBERG
    53 W
    Jackson
    Blvd., Ste. 950
    Chicago,
    IL
    60604
    (312) 362-0000
    Att ID:
    29637
    THIS
    FILING
    IS SUBMITTED ON RECYCLED
    PAPER

    CERTIFICATE
    OF
    SERVICE
    I,
    Michelle
    M.
    LaGrotta,
    the
    undersigned
    certify
    that
    on May
    7,
    2009,
    I
    have
    served
    the
    attached
    AMENDED
    COMPLAINT,
    upon:
    Mr.
    John
    T.
    Therriault, Assistant
    Clerk
    illinois
    Pollution Control
    Board
    100
    West
    Randolph
    Street
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    Chicago, Illinois
    60601-3218
    (via
    hand
    delivcry)
    Bradley
    P.
    Halloran
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson Center,
    Ste.
    11-500
    100 W
    Randolph Street
    Chicago,
    IL
    60601
    (via
    hand
    delivery)
    Charles
    F.
    Heisten
    Nicola
    A.
    Nelson
    Hinshaw
    &
    Culbertson
    100
    Park
    Avenue
    P.O.
    Box
    1389
    Rockford,
    IL
    61105-1389
    (via
    email
    to:
    NNelson@hinshawlaw.com
    and
    CHelstenhinshawIaw.com,
    and
    U.S.
    Mail)
    ,U
    Michelle
    1iZ
    M.
    LaGrotta

    RECEVED
    BEFORE THE
    ILLINOIS
    POLLUTION CONTROL
    BOARD
    CLEpc’
    OFFICE
    UNITED CITY OF YORK
    VILLE, A
    )
    MAY
    072009
    MUNICIPAL
    CORPORATION,
    )
    STATE
    OF
    ILLINOIS
    Complainant,
    )
    Pollution
    Control
    Board
    )
    PCB No. 08-96
    v.
    )
    )
    (Enforcement-Land,
    Air,
    Water)
    HAMMAN FARMS,
    )
    Respondents.
    )
    AMENDED COMPLAINT
    NOW
    COMES the
    Complainant, UNITED
    CITY OF YORK
    VII.T
    F,
    by
    its
    attorneys,
    GARDINER KOCH
    & WEISBERG, pursuant to Section 31(d) of the Illinois Environmental
    Protection
    Act (415
    ILCS 5/31(d)), and 35 Iii.
    Admin.
    Code
    §
    103.200,
    and for
    its Amended
    Complaint against
    HAMMAN FARMS, states
    as follows:
    GENERAL ALLEGATIONS
    1.
    Complainant, UNITED
    CITY
    OF
    YORKVILLE,
    (hereinafter referred to as
    “Yorkville”) is an
    Illinois municipal
    corporation
    in Kendall County, Illinois.
    2.
    At
    all times relevant, HAMMAN FARMS (hereinafter
    referred
    to
    as
    “HAMMAN”) is a
    farm, located on
    approximately twenty-two
    hundred
    acres of land in
    Kendall
    County.
    3.
    On
    this land,
    HAMMAN grows crops
    of soybeans, wheat and
    corn.
    4.
    Starting in
    or around 1993, HAMMAN
    registered with the Illinois Environmental
    Protection
    Agency
    (“Agency”)
    as
    an On-Site
    Compost Landscape Waste
    Compost
    Facility
    (hereinafter
    referred
    to as “Compost Facility”) pursuant to
    section 21(q)(3) of the
    Illinois
    Environmental
    Protection
    Act (hereinafter
    referred
    to as “Act”).
    I

    5.
    As part of
    HAMMAN’S
    farming
    operations,
    HAMMAN
    receives
    landscape
    waste
    from
    offsite. HAMMAN
    grinds the landscape
    waste
    in
    a tub
    grinder. HAMMAN
    then
    applies
    the landscape
    waste
    to
    farm fields.
    6.
    Sometime in or
    around 1992 to
    1993, HAMMAN
    applied
    to the Agency
    for
    permission to
    apply
    landscape
    waste
    at rates greater than
    the
    agronomic
    rate of twenty
    (20)
    tons
    per acre
    per
    year.
    The Agency denied
    Hamman’s request.
    7.
    Since
    registering with the
    Agency
    as
    a Compost
    Facility, HAMMAN
    has
    completed
    and
    filed
    annual
    reports
    as required under
    35 Illinois
    Administrative
    Code
    §830.1
    06(b)(2).
    8.
    HAMMAN certified
    that it received
    landscape
    waste in the
    amounts of 157,391
    cubic yards,
    174,630 cubic
    yards,
    266,441
    cubic
    yards, 192,532
    cubic yards,
    and 222,239 cubic
    yards for the
    years 2002, 2003,
    2004, 2005,
    and
    2006, respectively.
    9.
    Application
    of landscape
    waste
    at agronomic
    rates
    results in application
    measurements
    of
    three quarter of an
    inch. Application
    measurements
    of greater
    than
    three
    quarters
    of an
    inch signify that
    landscape waste
    is
    being applied
    at rates
    greater than
    the
    agronomic
    rate.
    10.
    Since
    registering
    as a
    Compost Facility,
    HAMMAN
    has applied
    landscape
    waste
    at rates
    resulting in application
    measurements greater
    than three
    quarters of
    one inch.
    11.
    On
    several
    occasions
    since registering
    as a
    Compost Facility,
    Agency inspectors
    have
    found
    litter mixed
    with
    the
    landscape waste in
    HAMMAN’s
    fields.
    12.
    Since HAMMAN
    began the application
    of landscape
    waste
    to its
    fields,
    the
    Agency
    has
    received
    complaints of strong
    and offensive
    odors around
    HAMMAN.
    2

    13.
    On
    October
    17,
    2007, Agency
    inspectors, Gino Bruni and Mark Retzlaff,
    conducted an inspection of
    HAMMAN.
    During
    the inspection, the inspectors
    observed
    the
    following:
    a.
    The application rate was
    two
    and
    one half inches to three inches
    thick
    using a
    ruler;
    b.
    Numerous flies were at the field where landscape waste
    had been applied; and
    c.
    General refuse
    was
    in the landscape waste.
    14.
    On November 15, 2007,
    the Agency issued
    HAMMAN
    a violation notice. The
    notice
    cited the
    following violations:
    a.
    Section 21(a) of the Act: HAMMAN openly dumped landscape waste and
    general
    refuse. HAMMAN did not apply landscape waste
    at
    agronomic rates.
    b.
    Section 21(d) of
    the Act: HAMMAN openly dumped
    landscape
    waste and
    general refuse. HAMMAN
    did not apply landscape waste
    at
    agronomic rates.
    HAMMAN conducted the aforementioned activities without a permit issued
    by the
    Agency.
    c.
    Section 21(p) of the Act: HAMMAN openly dumped litter,
    and
    litter was
    commingled
    with
    the landscape waste.
    d. 35
    Ill. Admin. Code
    §807.201:
    HAMMAN openly dumped landscape
    waste
    and general refuse.
    HAMMAN
    did not apply landscape waste at agronomic
    rates.
    HAMMAN conducted the aforementioned
    activities
    without
    a
    developmental permit granted by the Agency.
    e.
    35111. Admin. Code §807.202: HAMMAN openly
    dumped
    landscape waste
    and
    general refuse. HAMMAN did not apply landscape
    waste at
    agronomic
    3

    rates.
    HAMMAN
    conducted
    the
    aforementioned
    activities
    without
    a
    developmental permit
    granted
    by
    the
    Agency.
    15.
    The
    violation
    notice
    specified
    “suggested
    resolutions.”
    These
    included
    the
    following:
    a.
    Immediately
    cease
    all
    open
    dumping;
    b.
    Immediately remove
    all litter/general
    refuse
    from
    incoming
    loads
    of
    landscape
    waste
    prior
    to placing
    into
    the
    tub
    grinder.
    A
    second
    screening
    of
    the
    landscape
    waste
    must be
    conducted
    prior
    to
    being
    applied
    to
    the farm
    fields.
    If
    necessary,
    a
    third
    screening
    must
    be
    conducted
    prior
    to
    the landscape
    waste
    being
    tilled into
    the field;
    c.
    Immediately
    apply
    landscape
    waste at
    agronomic
    rates
    (three
    quarters
    of
    one
    inch
    in
    thickness).
    Daily
    written
    agronomic
    rate
    calculations
    must
    be
    maintained
    for
    three
    years;
    and
    d.
    Immediately calculate,
    on a
    daily
    basis,
    the
    percentage
    of non-landscape
    waste.
    These
    calculations
    must
    be maintained
    for
    three
    years.
    16.
    Following
    the
    violation
    notice,
    a
    violation
    notice
    meeting
    was
    held
    at the
    Agency’s
    Des
    Plaines
    office.
    At the meeting,
    DONALD
    J.
    HAMMAN
    admitted
    that
    HAMMAN
    was
    applying
    landscape
    waste
    at
    a
    rate
    greater
    than
    twenty
    (20) tons
    per acre
    per
    year.
    17.
    On
    March
    5,
    2008,
    the Agency
    rejected
    HAMMAN’s
    Compliance
    Commitment
    Agreement
    on the
    following
    bases:
    a.
    HAMMAN
    failed
    to agree
    to
    apply
    landscape
    waste
    at
    agronomic
    rates
    (twenty
    (20)
    tons
    per
    acre per
    year);
    and
    4

    b. HAMMAN
    failed
    to calculate
    on a daily basis
    the
    percentage
    of non-
    landscape
    waste.
    18.
    On April 10, 2008,
    HAMMAN
    filed a request for
    permission to
    apply landscape
    waste
    at
    rates
    greater
    than the agronomic
    rate
    of twenty (20)
    tons per acre
    per year. HAMMAN
    included
    with
    its application
    the following
    documents:
    (1)
    Land Application
    Plan;
    (2)
    USDA
    Soil
    Conservation Service
    Soil Survey;
    (3)
    Chemical
    Analysis
    of
    Soil/Compost;
    (4)
    Calculations
    regarding
    Nitrogen
    Demand
    and
    Expected
    Nitrogen
    and
    Potassium
    Loading;
    and
    (5)
    Opinion of
    Dr.
    Razvi.
    19.
    The
    Chemical
    Analysis
    of Soil/Compost included
    four
    (4)
    soil samples
    and one
    (1) sample of
    leaves with
    mixed
    forage.
    Midwest Laboratories,
    who
    performed
    the tests,
    received
    the four soil
    samples conducted
    the analyses
    on December
    7, 2007.
    Midwest
    Laboratories’
    report did
    not identify the location
    from where
    the samples
    were taken.
    Midwest
    Laboratories,
    Inc.
    received
    the
    sample of leaves
    with
    mixed
    forage
    on December
    5,
    2007.
    20.
    The Illinois
    Agronomy Handbook
    recommends
    using
    a sampling
    of one
    composite from
    each
    two
    and one
    half
    (2
    ‘/2)
    acre areas when
    conducting
    soil
    test
    analysis. Mr.
    Gary
    Cima, an
    expert in landscape
    waste
    application
    and
    former
    Agency investigator,
    recommends
    using
    a sampling
    of
    two
    tests from each
    one
    acre
    area.
    21.
    On April 16, 2008, HAMMAN
    filed
    a
    supplemental
    application.
    22.
    On May 1,
    2008,
    the Agency approved
    HAMMAN’s
    request
    to
    raise
    the
    agronomic rate.
    COUNT I
    OPEN
    DUMPING
    VIOLATIONS
    23.
    Section 21
    of
    the
    Act,
    415
    ILCS
    5/21(2008),
    provides
    in
    pertinent
    part
    as
    follows:
    “No
    person shall:
    5

    (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...
    (2)
    in
    violation
    of
    any
    rcgulations
    or
    standards
    adopted
    by
    the
    Board
    under
    this
    Act;...
    (e)
    Dispose,
    treat,
    store,
    or
    abandon
    any
    waste,
    or
    transport
    any
    waste
    to
    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;...”
    24.
    Section 3.185
    of
    the
    Act,
    415
    ILCS
    5/3.185
    (2008),
    provides:
    “Disposal’
    means
    the
    discharge,
    deposit, injection,
    dumping,
    spilling, leaking
    or
    placing of
    any
    waste
    or
    hazardous
    waste
    into
    or
    on
    any
    land
    or
    water
    or
    into
    any
    well
    so
    that
    such
    waste
    or
    hazardous
    waste
    or
    any constituent
    thereof
    may
    enter
    the
    environment
    or
    be
    emitted into
    the
    air
    or
    discharged
    into
    any
    waters,
    including
    ground
    waters.”
    25.
    Section 3.230
    of
    the
    Act,
    415
    ILCS
    5/3.230
    (2008),
    provides
    in
    pertinent
    part:
    “Household
    waste’
    means
    any
    solid
    waste
    (including
    garbage,
    trash,
    and
    sanitary
    waste
    in
    septic
    tanks)
    derived
    from
    households...
    ‘—‘
    26.
    Section 3.270
    of
    the
    Act,
    415
    ILCS
    5/3.270
    (2008),
    provides:
    “Landscape
    waste”
    means all
    accumulations
    of
    grass
    or
    shrubbery
    cuttings, leaves,
    tree
    limbs
    and
    other
    materials
    accumulated
    as
    the
    result
    of
    the
    care
    of
    lawns, shrubbery,
    vines
    and
    trees.”
    6

    27.
    Section
    3.305
    of
    the
    Act,
    415
    ILCS
    5/3.305
    (2008),
    provides:
    “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.”
    28.
    Section
    3.385
    of the
    Act,
    415
    ILCS
    5/3.385
    (2008),
    provides:
    “Refuse’
    means
    waste.”
    29.
    Section
    3.445
    of
    the
    Act.
    415
    ILCS
    5/3.445
    (2008),
    provides:
    “Sanitary
    landfill’
    means
    a
    facility
    permitted
    by
    the
    Agency
    for
    the
    disposal
    of waste
    on
    land
    meeting
    the
    requirements
    of
    the
    Resource Conservation
    and
    Recovery
    Act,
    P.L.
    94-580,
    and
    regulations
    thereunder,
    and
    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 regulation.”
    30.
    Section
    3.470
    of
    the
    Act,
    415
    ILCS
    5/3.470
    (2008),
    provides:
    “Solid
    waste’
    means
    waste.”
    31.
    Section
    3.480
    of
    the
    Act,
    415
    ILCS
    5/3.480
    (2008),
    provides:
    “Storage’
    means
    the
    containment
    of waste,
    either
    on
    a temporary
    basis
    or
    for
    a
    period
    of
    years,
    in
    such
    a manner
    as
    not
    to
    constitute
    disposal.”
    32.
    Section
    3.535
    of
    the
    Act,
    415
    ILCS
    5/3.535
    (2008),
    provides
    in
    pertinent
    part:
    “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..
    33.
    Section
    3.540
    of
    the
    Act,
    415
    ILCS
    5/3.540
    (2008),
    provides:
    “Waste
    disposal
    site’
    is
    a site
    on
    which
    solid
    waste
    is
    disposed.”
    34.
    On
    October
    23,
    2007
    the
    Agency
    inspected
    HAMMAN
    and
    found
    refuse
    mixed
    in
    with
    the
    landscape waste.
    7

    35.
    Garbage
    and
    refuse
    mixed
    with
    the
    landscape
    waste
    constitutes
    waste
    under
    section 3.535
    of
    the
    Act.
    415 ILCS
    5/535.
    36.
    On
    several
    occasions
    since
    HAMMAN
    began
    applying
    landscape
    waste,
    garbage
    has been
    mixed with
    the landscape
    waste
    on
    HAMMAN
    fields.
    37.
    In
    allowing
    the garbage
    to be
    disposed
    of
    and
    remain on
    HAMMAN
    fields,
    HAMMAN
    allowed ‘open
    dumping”
    for purposes
    of 415
    ILCS 5/21(a).
    38
    Tn
    allowing
    the
    garbage
    to
    he
    disposed
    of and
    remain
    on HAMMAN
    fields.
    HAMMAN
    conducted
    waste-storage
    and
    waste-disposal
    operations,
    for
    purposes
    of
    415
    ILCS
    5/21(d)(1)
    and
    (2),without
    a
    permit
    and in
    violation
    of the
    Act
    and regulations.
    39.
    In
    allowing
    the
    garbage
    to
    be
    disposed
    of and
    remain
    on HAMMAN
    fields,
    1-IAMMAN
    became
    a
    waste disposal
    site for
    purposes
    of 415
    ILCS 5/21(e).
    At the time
    that
    HAMMAN
    allowed
    garbage
    to
    remain
    on
    HAMMAN
    fields,
    HAMMAN
    was
    not permitted
    for
    the
    disposal of
    waste,
    and
    thus
    does not
    meet
    the
    requirements
    of
    the Act or
    the regulations
    for
    purposes
    of 415
    ILCS
    5/21(e).
    40.
    In
    allowing
    the
    garbage
    to
    be
    disposed
    of and
    remain
    on
    HAMMAN
    fields,
    HAMMAN
    allowed
    “open
    dumping”
    of litter
    for
    purposes
    of 415
    ILCS 5/21
    (p)(I).
    41.
    HAMMAN’s
    failure
    to remove
    the
    waste
    is harmful
    to
    the
    environment
    and
    to the
    health
    and
    welfare of
    the
    people
    living
    and working
    near
    HAMMAN.
    42.
    Because
    of
    the aforementioned
    reasons,
    HAMMAN
    has
    violated
    sections
    21(a),
    21(d)(I)
    and
    (2), 21(e),
    and
    21(p)(l)
    of the Act.
    PRAYER
    FOR RELIEF
    WHEREFORE,
    Complainant,
    UNITED
    CITY
    OF
    YORKVILLE,
    respectfully
    requests
    that the
    Board
    enter
    an order
    against the
    Respondent:
    8

    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
    the
    Respondent
    to
    cease
    and
    desist
    from
    any
    further
    violations
    of
    the
    Act
    and
    associated
    regulations;
    F)
    Ordering
    the
    Respondent
    to
    pay
    a
    civil
    penalty
    of
    $50,000
    for
    each
    such
    violation,
    pursuant
    to
    Section
    42(a)
    of
    the
    Illinois
    Environmental
    Protection
    Act,
    415
    ILCS
    5/42(a);
    E.
    Ordering
    the
    Respondent
    to
    pay
    an
    additional
    civil
    penalty
    of
    $10,000
    for
    each
    day
    during
    which
    each
    such
    violation
    continued,
    pursuant
    to
    Section
    42(a)
    of
    the
    Illinois
    Environmental
    Protection
    Act,
    415
    ILCS
    5/42(a); and
    F.
    Granting
    such
    other
    relief
    as
    the
    Board
    may
    deem
    appropriate.
    COUNT
    II
    LANDSCAPE
    WASTE
    VIOLATIONS
    43.
    Section
    21
    of
    the
    Act,
    415
    ILCS
    5/21(2008),
    provides
    in
    pertinent
    part
    as follows:
    “No
    person
    shall:...
    (q)
    Conduct
    a
    landscape
    waste
    composting
    operation
    without
    an
    Agency
    permit,
    provided,
    however,
    that
    no
    permit
    shall
    be
    required
    for
    any
    person:...
    (2) applying
    landscape
    waste
    or
    composted
    landscape
    waste
    at agronomic
    rates;
    or
    (3)
    operating
    a
    landscape
    waste
    composting
    facility
    on
    a
    farm,
    if
    the
    facility
    meets
    all
    of
    the
    following
    criteria:
    (A)
    the
    composting
    facility
    is
    operated
    by
    the
    farmer
    on
    property
    on
    which
    the
    9

    composting
    material
    is utilized,
    and
    the
    composting
    facility
    constitutes
    no more
    than
    2%
    of the
    property’s
    total
    acreage...
    (C) all
    compost
    generated
    by the
    composting
    facility
    is
    applied
    at
    agronomic
    rates
    and
    used
    as mulch,
    fertilizer
    or
    soil conditioner
    on
    land
    actually
    farmed...
    (D)
    the
    owner
    or operator,
    by..
    January
    1
    of
    each
    year thereafter,
    (i) registers
    the
    site
    with
    the
    Agency,
    (ii)
    reports
    to
    the Agency
    on
    the
    volume
    of
    composting
    material
    received
    and
    used at
    the site,
    (iii)
    certifies
    to
    the
    Agency
    that
    the
    site complies
    with
    the
    requirements
    set forth
    in subparagraphs
    (A),
    (B)
    and (C)
    of this
    paragraph
    (q)(3),
    and (iv)
    certifies
    to
    the
    Agency
    that all
    composting
    material
    was
    placed
    more
    than 200
    feet
    from
    the nearest
    potable
    water
    supply
    well,
    was
    placed
    outside
    the
    boundary
    of
    the
    10-year
    floodplain
    or
    on
    a part
    of
    the
    site
    that
    is
    floodproofed,
    was
    placed
    at
    least
    1/4 mile
    from
    the nearest
    residence
    (other
    than
    a
    residence
    located
    on
    the same
    property
    as
    the
    facility)
    and
    there
    are
    not
    more
    than
    10
    occupied
    non-farm
    residences
    within
    1/2
    mile
    of
    the
    boundaries
    of the
    site on
    the date
    of application,
    and was
    placed
    more
    than
    5
    feet above
    the
    water
    table.
    For
    the
    purposes
    of
    this subsection
    (q),
    ‘agronomic
    rates’
    means
    the
    application
    of not
    more
    than 20
    tons
    per acre
    per
    year,
    except
    that the
    Agency
    may
    allow
    a higher
    rate
    for
    individual sites
    where
    the owner
    or operator
    has
    demonstrated
    to
    the Agency
    that
    the
    site’s
    soil
    characteristics or crop
    needs
    require
    a
    higher
    rate.”
    44.
    Section
    3.270
    of
    the
    Act, 415
    ILCS
    5/3.270
    (2008),
    provides:
    “‘Landscape waste’
    means
    all
    accumulations
    of
    grass or
    shrubbery
    cuttings,
    leaves,
    tree
    limbs
    and
    other
    materials
    accumulated
    as
    the
    result
    of the
    care
    of
    lawns,
    shrubbery,
    vines
    and trees.”
    10

    45.
    Section
    830.102
    of
    the
    Illinois
    Administrative
    Code
    Title 35,
    ILL.
    ADMIN.
    CODE
    TIT.
    35, §830.102,
    provides
    in pertinent
    part:
    “Except
    as
    stated
    in
    this
    Section,
    the
    definition
    of each
    word
    or
    term
    used
    in this
    Part,
    35
    Iii.
    Adm.
    Code
    831
    and 35
    Ill.
    Adm.
    Code 832
    shall
    be
    the
    same
    as that
    applied
    to the
    same
    word
    or
    term
    in the
    Environmental
    Protection
    Act...
    ‘Agronomic
    Rates’
    means
    the application
    of
    not
    more
    than
    20 tons
    per
    acre
    per
    year,
    except
    that the
    Agency
    may
    allow
    a higher
    rate
    for
    individual
    sites
    where
    the owner
    or
    operator
    has
    demonstrated
    to the
    Agency
    that
    the site’s
    soil
    characteristics
    or
    crop
    needs
    require
    a higher
    rate.
    (Section
    2 1(q)
    of the Act.)...
    ‘Compost’
    means
    the
    humus-like
    product
    of the
    process
    of
    composting
    waste,
    which
    may
    be used
    as
    a soil
    conditioner.
    (Section
    3.70
    of
    the Act.)
    ‘Composting’
    means
    the
    biological
    treatment
    process
    by
    which
    microorganisms
    decompose
    the organic
    fraction
    of
    the
    waste,
    producing
    compost.
    (Section
    3.70
    of
    the
    Act.)
    Land
    application is
    not
    composting....
    ‘Land
    application’
    means
    the
    spreading
    of
    waste,
    at an
    agronomic
    rate,
    as
    a soil
    amendment
    to
    improve
    soil
    structure
    and crop
    productivity....
    ‘Landscape
    waste
    compost
    facility’
    means
    an
    entire
    landscape
    waste
    composting
    operation,
    with
    the xception
    of
    a garden
    compost
    operation.
    ‘On-farm
    landscape waste
    compost
    facility’
    means
    a
    landscape
    compost
    facility
    which
    satisfies
    all
    of
    the
    criteria
    set forth
    in Section
    830.106.”
    46.
    Section
    832.109
    of
    the Illinois
    Administrative
    Code
    Title
    35,
    ILL. ADMIN.
    CODE
    TIT.
    35,
    §832.109,
    provides:
    “The
    issuance
    and
    possession
    of
    a
    permit
    shall
    not
    constitute
    a
    defense
    to
    a
    violation
    of the
    Act
    or
    any
    Board
    regulations,
    except
    for
    the development and
    operation
    of
    a facility
    without
    a
    permit.”
    11

    47.
    Landscape
    waste
    constitutes waste
    under
    section
    3.535
    of
    the
    Act.
    415
    ILCS
    5/53
    5.
    48.
    Since
    HAMMAN
    began
    applying
    landscape
    waste,
    HAMMAN
    has
    applied
    landscape
    waste
    at
    rates
    greater
    than
    the
    agronomic
    rate
    of twenty
    (20)
    tons
    per
    acre
    per
    year.
    49.
    In
    applying landscape
    waste
    at rates
    greater
    than
    the
    agronomic
    rate
    of
    twenty
    (20)
    tons
    per
    acre
    per
    year,
    HAMMAN allowed
    “open
    dumping”
    for
    purposes
    of
    415
    ILCS
    5/21
    (a).
    50.
    In
    applying
    landscape
    waste
    at
    rates
    greater
    than
    the
    agronomic
    rate
    of
    twenty
    (20)
    tons
    per
    acre
    per
    year,
    HAMMAN
    conducted
    waste-storage
    and
    waste-disposal
    operations,
    for
    purposes
    of
    415
    ILCS
    5/21
    (d)(
    1)
    and
    (2),without
    a permit
    and
    in
    violation
    of
    the
    Act
    and
    regulations.
    51.
    In
    applying
    landscape
    waste
    at rates
    greater
    than
    the
    agronomic
    rate
    of twenty
    (20)
    tons
    per
    acre
    per
    year,
    HAMMAN became
    a
    waste
    disposal
    site
    for
    purposes
    of
    415
    ILCS
    5/21(e). HAMMAN
    was
    not
    permitted
    for
    the
    disposal
    of waste,
    and
    thus
    does
    not
    meet
    the
    requirements
    of
    the Act
    or
    the regulations
    for
    purposes
    of
    415
    ILCS
    5/21(e).
    52.
    In
    applying
    landscape waste
    at
    rates
    greater
    than
    the
    agronomic
    rate
    of twenty
    (20)
    tons
    per
    acre
    per
    year,
    HAMMAN
    does
    not
    meet
    the
    permit
    exemptions
    found
    in
    sections
    21
    (q)(2)
    and
    (3)
    of
    the
    Act.
    In applying landscape
    waste
    at
    rates
    greater
    than
    the
    agronomic
    rate
    of
    twenty
    (20)
    tons
    per
    acre
    per
    year,
    without
    a permit,
    HAMMAN
    violated
    section
    21(q)
    of
    the
    act.
    53.
    Because
    of
    the
    aforementioned
    reasons,
    HAMMAN
    has
    violated
    sections 21(a),
    21(d)(1) and
    (2),
    21(e), and
    21(q).
    PRAYER
    FOR
    RELIEF
    12

    WHEREFORE,
    Complainant,
    UNITED
    CITY
    OF
    YORKVILLE,
    respectfully
    requests
    that
    the
    Board
    enter
    an
    order
    against
    the
    Respondent,
    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
    the
    Respondent
    to
    cease
    and
    desist
    from
    any
    further violations
    of
    the
    Act
    and
    associated
    regulations;
    D.
    Ordering
    the
    Respondent
    to
    pay
    a civil
    penalty
    of
    $50,000 for
    each
    such
    violation,
    pursuant
    to
    Section
    42(a)
    of
    the
    Illinois
    Environmental
    Protection
    Act,
    415
    ILCS
    5/42(a);
    E.
    Ordering
    the
    Respondent
    to
    pay
    an
    additional
    civil
    penalty
    of
    $10,000 for
    each
    day
    during
    which
    each
    such
    violation
    continued,
    pursuant
    to
    Section
    42(a)
    of the
    Illinois
    Environmental
    Protection
    Act,
    415
    ILCS
    5/42(a);
    and
    F.
    Granting
    such
    other
    relief
    as the
    Board
    may
    deem
    appropriate.
    COUNT
    III
    AIR
    POLLUTION
    VIOLATIONS
    54.
    Section
    9
    of
    the
    Act,
    415 ILCS
    5/9
    (2008)
    provides
    in
    pertinent
    part:
    “No
    person
    shall:
    (a)
    Cause
    or
    threaten
    or
    allow
    the
    discharge
    or
    emission
    of
    any
    contaminant
    into
    the
    environment
    in
    any
    State
    so
    as
    to
    cause
    or
    tend
    to cause
    air
    pollution
    in
    Illinois,
    either
    alone
    or
    in
    combination
    with
    contaminants
    from
    other sources,
    or
    so
    as
    to
    violate
    regulations
    or
    standards
    adopted
    by
    the
    Board
    under
    this
    Act.
    ..“
    55.
    Section
    3.115
    of
    the
    Act,
    415
    ILCS
    5/3.115(2008),
    provides
    13

    “‘Air pollution’ is
    the presence
    in
    the
    atmosphere
    of one or more
    contaminants in
    sufficient quantities
    and of
    such characteristics
    and
    duration as to be
    injurious
    to
    human,
    plant, or
    animal life,
    to health,
    or
    to
    property, or to unreasonably
    interfere
    with
    the enjoyment
    of
    life
    or
    property.”
    56.
    Section 3.165 of the Act,
    415 ILCS
    5/3.165
    (2008),
    provides:
    Contaminant’ is any solid, liquid,
    or gaseous
    matter,
    any
    odor, or
    any form of
    energy,
    from
    whatever
    source.”
    57.
    Under
    Section 3.165 of the Act, the
    odor that is
    emitted from
    HAMMAN’ s
    application of landscape
    waste is a
    contaminant.
    58.
    Under
    Section
    3.115 of the Act, the release
    of the odor,
    a contaminant, is air
    pollution that
    unreasonably
    interferes with the
    enjoyment
    of life
    or property.
    This
    odor
    unreasonably
    interferes
    with
    Yorkville’s residents’
    use and
    enjoyment of life
    and property.
    59.
    Specifically, the odor caused by Hamman
    Farms has substantially
    interfered with
    the Yorkville residents’
    rights to public health and comfort
    and to
    the quiet use
    and enjoyment of
    their
    land,
    in the following
    ways:
    a.
    It forces Yorkville
    residents
    to remain indoors;
    b. It
    prevents Yorkville residents from
    opening windows
    to cool
    their homes and
    causes
    them to
    use
    air conditioning
    instead;
    c.
    It precludes
    Yorkville residents
    from entertaining
    guests
    outdoors;
    d.
    It precludes
    Yorkville residents
    from using
    the outdoor
    portions of their
    property, including decks attached to
    their
    homes;
    e.
    It prevents Yorkville
    childrenTrom
    playing
    outdoors; and
    f. It
    occasionally causes nausea in the
    people who smell
    the odor.
    60.
    Joann
    Gilbert, who resides at
    8730 East
    Highpoint
    Road, Yorkville,
    Illinois,
    first
    noticed
    the
    odor caused by
    Hamman Farms
    during
    the summer
    of 1994.
    Ms. Gilbert found the
    14

    odor so offensive
    that she
    called emergency
    services because
    she thought the odor
    resulted
    from
    an accident.
    Although
    police
    officers came out
    to
    investigate
    the odor,
    Ms. Gilbert did
    not
    learn
    the source of
    the smell until
    several weeks later.
    a.
    From 1994 until
    2006, Ms. Gilbert
    noticed the odor
    a several
    times per
    month
    from
    May
    until
    October.
    b. As a
    result of the
    odor, Ms. Gilbert
    began to
    use
    air
    conditioning
    instead of
    leaving the
    windows of
    her home
    open.
    c.
    In May 2008, Ms.
    Gilbert noted
    the odor on at least
    three occasions.
    Ms.
    Gilbert
    noted
    the odor again on at
    least four
    occasions
    in June 2008
    (on or
    about, June
    18th, 19th,
    20th,
    and
    30th) and once
    in July
    2008 (on
    or
    about,
    July 3
    1st).
    d.
    On those
    occasions,
    Ms.
    Gilbert
    informed the Illinois
    Environmental
    Protection
    Agency.
    61.
    Diane
    Pobol,
    a
    former Yorkville resident,
    resided on property
    surrounded
    by
    Hamman Farms
    from early
    2006
    until
    fall
    of 2008.
    a. Ms.
    Pobol
    noticed
    the
    odor for the first time
    in spring 2006. When
    Ms.
    Pobol
    first
    noticed
    the
    odor,
    she
    thought that there
    was
    a problem with
    the septic
    tank on
    her property.
    Ms. Pobol later learned
    that that the odor
    came from
    Hamman
    Farms.
    b.
    Ms. Pobol’s
    home
    did
    not
    have
    air
    conditioning,
    and she
    was forced
    to
    leave
    windows open
    despite
    the
    smell. As a result
    of the odor, Ms. Pobol’s
    eyes
    were
    often
    irritated
    and
    continually
    teared.
    15

    c.
    Prior
    to moving into
    her
    home,
    Ms.
    Pobol
    had
    entered
    negotiations
    to
    rent
    one
    of the
    barns
    on
    the
    property. The
    rental
    money
    was
    intended
    to
    help
    subsidize
    the
    mortgage
    payments.
    Following
    the
    potential
    renters’
    visit
    to the
    property
    in
    May
    2006,
    the
    potential
    renters
    refused
    to enter
    the
    lease
    due
    to
    the odor
    emanating from
    Hamman
    Farms.
    Ms.
    Pobol
    was
    never
    able
    to find
    a
    renter
    for
    the
    barn.
    d. Ms.
    Pobol
    tried
    to
    sell
    the
    property
    in
    2006.
    The
    odor,
    along
    with
    the
    garbage
    and
    flies
    lying
    in
    and
    around
    the
    fields
    of
    Hamman
    Farms,
    drove
    away
    potential
    buyers.
    Ms.
    Pobol
    was
    unable
    to sell
    the
    home.
    62.
    Todd
    Milliron,
    who
    has
    resided
    at 61
    Cotswold
    Drive,
    Yorkville,
    Illinois
    since
    in
    or
    around
    September 1996,
    noticed
    the
    odor
    immediately
    upon
    moving
    into
    his
    home.
    a.
    Mr.
    Milliron
    noticed
    the
    odor
    on
    an
    ongoing
    basis
    from
    mid-May
    until
    early
    October of each
    year
    from
    1996
    until
    the
    fall
    of
    2007.
    Although
    Mr.
    Milliron
    constantly
    noted
    the
    odor,
    the
    odor
    at
    times
    became
    especially
    intense
    when
    the
    wind
    blew
    in
    the
    direction
    of his
    home.
    b.
    Because
    of
    the
    ongoing
    odor,
    Mr.
    Milliron
    was
    forced
    to
    use
    air
    conditioning
    rather
    than
    leaving
    windows
    open.
    This
    caused
    Mr.
    Milliron
    to
    feel
    like
    a
    prisoner
    in
    his
    own
    home, unable
    to open
    the
    windows
    and
    get
    fresh
    air,
    or
    enjoy
    the
    exterior
    of
    his
    property.
    63.
    Robert
    and
    Lynn
    Smith, who
    have
    resided
    at
    9122
    Lisbon
    Road,
    Yorkville,
    Illinois
    since
    in or
    around
    1965,
    noticed
    the
    odor
    within
    the
    last
    ten
    years.
    16

    a.
    The
    Smiths
    notice
    the
    odor
    on
    a
    daily
    basis
    from
    April
    to
    November;
    however,
    they
    note that
    the odor
    can
    be
    particularly
    bad
    when
    the wind
    directs
    the
    odor
    toward
    their
    home.
    b.
    The
    Smiths
    describe
    the
    odor
    as a
    sour
    smell
    that
    is worse
    than
    typical
    farm
    smells.
    c.
    The
    Smiths
    held
    family
    reunions
    on
    their
    property
    annually
    over
    the
    last
    three
    years.
    Each
    year,
    approximately two thirds
    of
    their
    guests
    left early
    due
    to
    the
    odor.
    d.
    The
    Smiths
    find
    that they
    are
    unable
    to
    enjoy outdoor
    activities
    on
    their
    property
    and are
    unable
    to
    leave
    their
    windows
    open
    when
    they
    otherwise
    would.
    64.
    Larry
    Alex,
    who
    has
    resided
    at 2108
    Bernadette
    Lane,
    Yorkville,
    Illinois
    for
    the
    last
    two
    years,
    has
    noticed
    the odor
    since
    moving
    into his
    home.
    a.
    Mr. Alex
    finds
    the intensity
    of
    the odor
    is dependent
    upon
    the
    wind
    direction.
    b.
    Mr. Alex
    finds
    the odor
    particularly
    strong
    about
    two
    to three
    times
    per month
    during
    the
    months
    of April
    through
    November.
    c.
    The odor
    has
    negatively
    affected
    Mr.
    Alex’s
    outdoor
    activities.
    65.
    William
    Fowler,
    who has
    resided
    at
    8577
    W
    Highpoint
    Road,
    Yorkville,
    Illinois
    since
    1998,
    has
    noticed
    the odor
    every
    summer
    since
    moving
    into his
    home.
    a.
    Mr.
    Fowler
    finds
    the
    odor
    present
    from
    April
    to October
    or
    November.
    b.
    Mr.
    Fowler
    finds
    the odor
    to have
    a
    fowl,
    moldy
    grass
    smell
    that
    is
    not
    typical
    of farms.
    c.
    Mr.
    Fowler
    is unable
    to enjoy
    outdoor
    activities
    on
    his
    property.
    17

    d.
    Mr.
    Fowler
    finds
    the
    odor
    embarrassing
    when
    he has guests
    at
    his
    home and is
    compelled
    to
    explain
    the odor.
    66.
    In
    applying the
    landscape
    waste,
    HAMMAN
    is allowing
    the
    discharge
    of
    contaminant
    into the
    environment
    so as to cause
    air
    pollution
    under section
    9(a)
    of
    the
    Act.
    67.
    Because
    of the
    aforementioned reasons,
    HAMMAN
    has violated
    section 9(a) of
    the Act.
    PRAYER FOR RELIEF
    WHEREFORE,
    Complainant,
    UNITED
    CITY OF YORKVILLE,
    respectfully requests
    that the
    Board
    enter an
    order
    against the Respondent,
    A.
    Finding
    that the Respondent
    has violated the
    Act and regulations
    as
    alleged
    herein;
    B.
    Ordering
    the Respondent
    to
    cease and
    desist
    from
    any
    further
    violations
    of
    the Act
    and associated
    regulations;
    C.
    Ordering the
    Respondent
    to pay a civil
    penalty
    of
    $50,000
    for
    each
    such
    violation,
    pursuant
    to Section
    42(a)
    of
    the
    Illinois
    Environmental
    Protection
    Act,
    415
    ILCS 5/42(a);
    D.
    Ordering
    the
    Respondent
    to pay an additional
    civil
    penalty of
    $10,000
    for
    each
    day
    during which
    each such violation
    continued,
    pursuant to
    Section
    42(a)
    of
    the
    Illinois
    Environmental
    Protection
    Act,
    415 ILCS
    5/42(a);
    and
    E.
    Authorizing
    a
    hearing
    in this matter at which
    time
    the
    Respondent
    will be
    required
    to answer the
    allegations
    herein;
    F.
    Granting such
    other relief
    as the Board may
    deem
    appropriate.
    18

    COUNT
    IV
    WATER
    POLLUTION
    VIOLATIONS
    68.
    Section
    12
    of
    the
    Act,
    415
    ILCS 5/12
    (2008), provides
    in pertinent
    part:
    “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...
    (d)
    Deposit
    any
    contaminants
    upon the land
    in such place
    and manner
    so as to create
    a
    water
    pollution
    hazard.”
    69.
    Section 3.165
    of the Act, 415 ILCS
    5/3.165 (2008),
    provides:
    “Contaminant’
    is any solid,
    liquid,
    or gaseous
    matter, any odor,
    or
    any form
    of energy, from whatever
    source.”
    70.
    Section 3.545 of
    the Act, 415
    ILCS 5/3.545 (2008),
    provides:
    “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
    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.”
    71.
    Section
    3.550 of the Act,
    415 ILCS
    5/3.550
    (2008),
    provides:
    “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.”
    72.
    Under Section 3.165
    of the Act, the landscape
    waste
    that HAMMAN
    is
    applying
    is a
    contaminant.
    19

    73.
    Under
    Section
    3.545
    of the
    Act, HAMMAN’s
    application of
    landscape
    waste is
    water
    pollution
    in that the
    landscape waste is a contaminant which
    is being discharged into
    ground water.
    74.
    In applying the
    landscape
    waste,
    HAMMAN is allowing
    the discharge of
    contaminant
    into the
    environment so
    as
    to cause or tend
    to
    cause water
    pollution
    under
    section
    12(a) of the
    Act.
    75.
    In
    applying the landscape waste, HAMMAN is
    allowing the deposit of
    contaminants so as
    to create a
    water pollution
    hazard
    under section 12(d)
    of the Act.
    76.
    Because of the
    aforementioned reasons, HAMMAN
    has violated sections 12(a)
    and 12(d) of the
    Act.
    PRAYER FOR RELIEF
    WHEREFORE,
    Complainant, UNITED
    CITY OF YORKVILLE,
    respectfully requests
    that
    the Board
    enter an order against
    the Respondent,
    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 the Respondent to cease and
    desist from any further violations
    of
    the Act
    and associated regulations;
    D.
    Ordering the
    Respondent to pay
    a
    civil
    penalty of
    $50,000
    for
    each
    such
    violation,
    pursuant to
    Section
    42(a) of the
    Illinois Environmental
    Protection Act,
    415
    ILCS
    5/42(a);
    20

    E.
    Ordering
    the Respondent
    to
    pay
    an additional
    civil
    penalty
    of
    $10,000
    for
    each
    day
    during
    which
    each
    such violation
    continued,
    pursuant
    to
    Section
    42(a) of
    the Illinois
    Environmental
    Protection
    Act,
    415
    ILCS
    5/42(a);
    and
    F.
    Granting
    such
    other relief
    as
    the Board
    may
    deem
    appropriate.
    Respectfully
    submitted,
    UNITED
    CITY
    OF YORKVILLE,
    Complainant,
    By:
    7
    4
    //
    One
    of
    its Attorneys
    Dated:
    May
    7,
    2009
    Thomas
    G.
    Gardiner
    Kenneth
    M. Battle
    Michelle
    M.
    LaGrotta
    Gardiner
    Koch
    &
    Weisberg
    53 W
    Jackson
    Blvd.,
    Ste.
    950
    Chicago,
    IL
    60604
    (312)
    362-0000
    21

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