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MAY
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1997
SThTIz
0-
LL1NOIS
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD2TIO____
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
Complainant,
-vs
-
COMMUNITY
LANDFILL
COMPANY,
INC.,
an
Illinois
corporation,
Respondent.
PCB
No.
(1L
4
(Enforcement)
NOTICE
OF
FILING
TO:
Dorothy
Gunn,
Clerk
Illinois
Pollution
Control
Board
James
R.
Thompson
Center
100
West
Randolph
Street
Chicago,
Illinois
60601
Mark
A.
LaRose,
Esq.
Mark
A.
LaRose
Ltd.
734
North
Wells
Street
Chicago,
Illinois
60610
PLEASE
TAKE
NOTICE
that
on
May
1,
1997,
I
filed
with
the
Clerk
of
the
Illinois
Pollution
Control
Board
a
copy
of
the
following
instrument
entitled
COMPLAINT,
a
copy
of
which
is
attached
and
herewith
served
upon
you.
DATE:
May
1,
1997
c
\wpwin6O\wpdocs\u1ie\cotnmun
.nof
Respectfully
submitted,
JAMES
E.
RYAN
Attorney
General
of
the
State
of
Illinois
BY:
Q
JIJIE
D.
MELVIN/
$ssistant
Attor4ey
General
!Environmental
Bureau
100
West
Randolph
St.,
11th
Fl.
Chicago,
IL
60601
(312)
814-3369
THIS
FILING
IS
SUBMITTED
ON
RECYCLED
PAPER
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
B4RD
y
1
1997
PEOPLE
OF
THE
STATE OF ILLINOIS,
)
ILBOARD
ex rel. JAMES E. RYAN, Attorney
General
of
the
State of Illinois,
Complainant,
-vs
-
)
PCB
No.
7
(Enforcement)
COMMUNITY LANDFILL COMPANY,
INC.,
an Illinois corporation,
Respondent.
COMPLAINT
Complainant, PEOPLE OF
THE STATE OF ILLINOIS,
ex rel.
JAMES E.
RYAN,
Attorney
General
of
the State of Illinois,
on his own
motion
and
at
the request of the Illinois
Environmental Protection
Agency,
complains of Respondent, COMMUNITY
LANDFILL COMPANY,
INC., an
Illinois Corporation, as follows:
COUNT I
FAILURE
TO
ADEOUATELY
MANAGE REFUSE
ND LITTER
1.
This count is brought
on behalf of the PEOPLE
OF THE
STATE OF ILLINOIS, by JAMES E. RYAN, Attorney
General of
the State
of
Illinois, on his own motion
and at the request of
the Illinois
Environmental
Protection
Agency (“Agency”), pursuant
to Section 31
of
the Illinois Environmental Protection Act
(“Act”),
415 ILCS
5/31
(1994)
1
2.
At all times relevant
to
this
Complaint,
Respondent,
COMMUNITY LANDFILL
COMPANY, INC.,
(“CLC”),
an Illinois
corporation,
has operated a permitted landfill located
at 1501 Ashley
Road,
Morris, Grundy County, Illinois,
(“landfill”
or
“site”)
3.
The
landfill
consists of approximately 119
acres within
the Northwest 1/4 of Section 2 of
the Northeast 1/4 of
Section 3,
Township
33
North Range
7
East,
and in the Southeast 1/4
of Section
34
and the
Southwest 1/4 of
Section 35, Township 34 North
Range 7
East, all in the Third Principal Meridian, in Grundy
County,
Illinois.
4.
The landfill is divided into two parcels,
designated
Parcel A and
Parcel B.
5.
Parcel A is approximately
55
acres in size
and is
currently inactive.
6.
Parcel B is approximately 64 acres in size and
continues
to accept
waste.
7.
On
the following
dates the Agency conducted an inspection
of the site:
August 18, 1993, April 7, 1994,
March 22, 1995, May
22, 1995, November 7, 1995, and July 11, 1996.
8.
Section 3.08
of
the Act, 415 ILCS 5/3.08
(1994),
provides
the following
definition:
“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
2
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.
9.
Section 3.20 of the Act,
415 ILCS 5/3.20
(1994),
provides
the following
definition:
“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.
Section 3.41 of the Act, 415 ILCS 5/3.41
(1994),
provides
the following
definition:
“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.
11.
Section
3.53
of the Act, 415 ILCS 5/3.53
(1994),
provides
the
following
definition:
“WASTE” means any garbage, sludge from a waste treatment
plant, or air pollution
control facility 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, but does not include solid or
dissolved material in domestic sewage, or solid or
dissolved
materials in irrigation return flows, or coal
combustion by-products as defined in Section 3.94, or
industrial discharges
which are point sources
subject to
permits under Section 402 of
the Federal
Water Pollution
Control Act, as now or
hereafter amended,
or source,
special nuclear, or by-product materials as defined by
3
the Atomic Energy Act of
1954, as amended
(68
Stat.
921)
or any solid
or dissolved material from
any
facility
subject to the Federal
Surface Mining
Control and
Reclamation Act
of 1977
(P.L. 95-87)
or
the rules and
regulations thereunder
or any law or rule
or regulation
adopted by
the
State of Illinois pursuant
thereto.
12.
During the April 7, 1994, inspection,
litter was
observed
in
the
perimeter drainage ditch
at
the southwest
portion
of Parcel B
and on the southwest slope of Parcel B.
13.
During
the March
22, 1995, inspection, the Agency
inspector observed refuse in a perimeter ditch and in
a retention
pond
at the
landfill and litter was observed
at
the
northeast
perimeter ditch
and fence line.
14.
During the May 22, 1995, inspection,
the Agency inspector
observed refuse and litter in the perimeter ditches.
15.
Also
during the May 22, 1995, inspection,
the Agency
inspector
observed three eroded
areas where leachate seeps
had
exposed previously
covered
refuse.
16.
Section
21(d) (2)
of the Act, 415 ILCS
5/21(d)
(2)
(1994),
provides
as
follows:
No person shall:
*
*
*
d.
Conduct any waste-storage, waste
treatment, or
waste- treatment, or waste-disposal
operation:
*
*
*
4
2.
In violation of any regulations or
standards
adopted by the Board under this Act;
or
*
*
*
17.
Section
21(o)
of the Act,
415
ILCS
5/21(o)
(1994),
provides, in pertinent part, as follows:
No person shall:
*
*
*
o.
Conduct a sanitary landfill operation which is
required to have a permit under subsection
Cd)
of
this Section
in
a
manner which results in
any
of
the
following conditions:
1.
refuse in standing
or flowing waters;
*
*
*
5.
uncovered refuse remaining from any previous
operating day or at the conclusion of any
operation day, unless authorized by permit;
*
*
*
12. failure
to
collect and contain litter
from the
site by
the end of each
operating day.
18. Section
807.306 of the Illinois Pollution
Control Board’s
(“Board’s”)
Waste
Disposal Regulations,
35
Ill. Adm.
Code 807.306,
provides as
follows:
All litter shall be collected from the sanitary landfill
site by the end of each
working
day and either placed in
the
fill and compacted and covered that
day,
or
stored in
a
covered container.
19.
By leaving refuse in perimeter ditches and the retention
pond on
March 22, 1995, and by leaving refuse in perimeter ditches
5
on May 22, 1995, Respondent has violated
Section
21(o) (1)
of the
Act, 415 ILCS 5/21(o)
(1) (1994)
20. By
allowing
leachate
seeps to
erode
areas of the
landfill
and
expose
previously covered refuse,
at least on May 22,
1995,
Respondent
has
violated
Section
21(o) (5)
of the Act,
415 ILCS
5/21(o)
(5)
(1994)
21. By allowing litter to remain exposed and
uncontained
around various areas of the site on April 7, 1994,
March 22, 1995,
and May 22, 1995,
the Respondent
has
violated
Sections
21(d)
(2)
and
21(o) (12)
of
the Act, 415 ILCS 5/21(o) (12)
(1994),
and Section
807.306
of the Board Waste Disposal Regulations, 35 Ill. Adm.
Code
807.306.
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS,
respectfully requests that the Board enter an
order against
Respondent, COMMUNITY LANDFILL COMPANY, INC., with
respect to
Count
I:
1.
Authorizing
a
hearing
in this matter at which
time the
Respondent will be required to answer the allegations
herein;
2.
Finding
the
Respondent has caused or allowed
violations
of Section
21(d) (2),
21(o)
(1), (5),
and
(12)
of the Act,
and Section
807.306 of 35 111. Adm. Code;
3.
Ordering Respondent
to cease and desist from
any further
violations
of Sections
21(d)(2),
21(o)
(1), (5)
and
(12),
and Section
6
807.306 of
35
Ill. Adm.
Code;
4.
Assessing a civil penalty of Fifty
Thousand Dollars
($50,000.00) against Respondent for each violation
and an
additional
civil penalty of Ten Thousand
Dollars ($10,000.00) per
day for each
day of violation;
5.
Requiring Respondent
to pay all costs, including
expert
witness, consultant and attorney fees, expended by the
State in its
pursuit of
this action; and
6.
Granting such other
relief as the Board deems
appropriate.
COUNT II
FAILURE TO PREVENT OR CONTROL LEACHATE FLOW
1-16.
Complainant realleges and incorporates
by reference
herein paragraphs
1 through
16 of Count
I
as paragraphs 1 through 16
of this
Count II as if fully
set
forth herein.
17.
Section
21(o)
of the Act, 415 ILCS 5/21(o)
(1994),
provides, in pertinent part, as follows:
No
person shall:
**
*
o.
Conduct a sanitary landfill operation which is
required to have a permit under subsection
Cd)
of
this Section, in a manner which results in
any of
the following conditions:
*
*
*
7
2.
leachate flows entering waters
of the
State;
3.
leachate flows exiting
the landfill
confines
(as
determined by the boundaries
established
for the landfill
by a permit issued
by the
Agency);
*
*
*
18.
Section
807.314(e)
of the Board’s Waste
Disposal
Regulations provides as follows:
Except as
otherwise
authorized in writing
by the Agency,
no
person shall
cause or allow the development
or
operation of a sanitary landfill which
does not provide:
*
*
*
e)
Adequate measures to monitor and control leachate;
19.
During
the April 7, 1994, inspection,
the Agency
inspector
observed five leachate seeps along the northwest
perimeter
of Parcel B.
20.
During the March 22, 1995, inspection, the Agency
inspector
observed numerous leachate seeps at the northwest
perimeter of the landfill.
21.
During the May 22, 1995, inspection, the Agency inspector
observed numerous leachate seeps along the north slope of
the
landfill and along the north perimeter ditch which eventually drains
into
the
Illinois River.
22. By allowing leachate seeps to exit the landfill
boundaries and enter
waters
of the State, and by failing to control
8
leachate flow, Respondent has violated
Sections 21
(d) (2),
and
21(o) (2)
and
(3)
of the Act, 415
ILCS 5/21(d)
(2)
and 21(o)
(2)
and
(3)
(1994),
and Section 807.314(e)
of the Board’s Waste
Disposal
Regulations, 35
Ill. Adm.
Code
807.314(e).
WHEREFORE, Complainant, PEOPLE OF THE STATE
OF ILLINOIS,
respectfully requests that the Board enter an
order against
Respondent, CLC, with respect to Count II:
1.
Authorizing
a hearing in this matter
at
which
time the
Respondent
will be required
to
answer the allegations
herein;
2.
Finding that Respondent has caused or allowed violations
of Sections
21(d)(2), 21(o) (2)
and
(3),
and Section
807.314(e)
of
35
Ill. Adm. Code;
3.
Ordering Respondent to cease and desist from any further
violations
of
Sections
21(d) (2), 21(o) (2)
and
(3),
and Section
807.314(e)
of 35
Ill. Adm.
Code;
4.
Assessing a
civil
penalty of Fifty Thousand Dollars
($50,000.00) against Respondent for each violation, and an
additional
civil penalty of Ten
Thousand
Dollars
($10,000.00)
per
day
for each day of
violation;
5.
Requiring Respondent
to pay all costs, including
expert
witness,
consultant and attorney fees, expended by the
State in its
pursuit of this action; and
9
6.
Granting such other
relief as the
Board
deems
appropriate.
COUNT III
FAILURE TO PROPERLY
DISPOSE OF LANDSCAPE
WASTE
1-16. Complainant
realleges and incorporates
by reference
herein paragraphs 1 through
16 of Count I
as paragraphs 1
through 16
of
this Count III as if fully
set
forth
herein.
17.
Section
22.22(c)
of the Act, 415
ILCS 5/22.22(c)
(1994),
provides
as
follows:
c.
Beginning July 1,
1990, no owner or
operator of a
sanitary
landfill shall accept landscape
waste for
final
disposal, except that landscape
waste
separated from municipal waste
may be accepted
by a
sanitary landfill if
(1)
the
landfill provides
and
maintains for
that purpose separate landscape
waste
composting facilities
and composts all landscape
waste, and (2)
the composted waste is
utilized,
by
the operators
of the landfill or
by any other
person, as part of the final
vegetative cover
for
the landfill or
such other uses as soil
conditioning
material.
18.
During the August 18,
1993, and April 7,
1994,
inspections, the Agency inspector observed
that landscape
waste had
been deposited in the landfill area.
19.
By landfilling landscape
waste, Respondent
has violated
Section
22.2(c)
of the Act, 415 ILCS
5/22.22(c)
(1994).
WHEREFORE, Complainant
PEOPLE OF THE
STATE OF ILLINOIS,
respectfully requests that the Board
enter an order
against
10
Respondent, CLC, with
respect to Count III:
1.
Authorizing a hearing in this matter
at which time the
Respondent will be required to answer the allegations
herein;
2.
Finding that Respondent has caused or
allowed violations
of Section
22.22(c)
of the
Act;
3.
ordering
Respondent to cease and desist from
any further
violations of
Section 22.2(c) of the
Act;
4.
Assessing
a
civil penalty
of Fifty Thousand Dollars
($50,000.00) against Respondent for each violation,
and an
additional
civil penalty of Ten Thousand Dollars
per
day for
each
day of
violation;
5.
Requiring Respondent
to pay all costs, including
expert
witness,
consultant and attorney
fees,
expended by the
State in its
pursuit
of this action; and
6.
Granting such other relief as the Board
deems
appropriate.
COUNT
IV
FAILURE
TO PROVIDE AND MAINTAIN
ADEQUATE
FINANCIAL ASSURANCE
1-16. Complainant realleges and incorporates
by reference
herein
paragraphs 1 through 16 of Count I
as
paragraphs
1 through 16
of
this Count IV as if fully
set
forth herein.
11
17.
Section
21.1(a)
of the Act, 415 ILCS
5/21.1(a) (1994),
provides
as
follows:
a.
Except as provided in
subsection
(a.5)
no
person
other than the
State of Illinois, its
agencies and
institutions, or
a unit of local government
shall
conduct
any waste disposal operation
on or after
March 1, 1985, which requires
a permit under
subsection
(d)
of Section 21 of this Act,
unless
such person has posted with the Agency
a performance
bond or other
security for the purpose of
insuring
closure of
the site and post-closure care
in
accordance with
this Act and regulations
adopted
thereunder.
18.
Section
807.601(a)
of
the Board’s Waste Disposal
Regulations, 35 Ill. Adm. Code
807.601(a),
states
as follows:
No person shall conduct a waste disposal
operation or
indefinite storage operation which requires
a permit
under Section
21(d)
of the Act unless such
person has
provided financial assurance in accordance
with this
Subpart.
a)
The financial assurance requirement
does not
apply
to the State of Illinois, its
agencies and
institutions, or
to
any
unit of local government;
provided, however, that any other
persons who
conduct such
a
waste
disposal operation
on a site
which
may be owned or operated
by
such
a government
entity must provide financial
assurance for closure
and post-closure care of the site.
19.
Section 807.603(b)
(1)
of the Board’s Waste Disposal
Regulations, 35 Ill. Adm. Code
807.603(b) (1),
provides
as follows:
b)
The operator must increase the total amount of
financial assurance
so as to equal the current cost
estimate
within 90 days after any of the
following:
1)
An
increase in the current cost estimate;
12
20.
Section
807.623(a)
of the Board’s
Waste Disposal
Regulations, 35 Ill. Adm. Code 807.623
(a),
provides
as follows:
a.
The operator must
revise the current
cost estimate
at least once every
two years. The revised
current
cost estimate must
be
filed on or before
the
second
anniversary of
the filing or last revision
of the
current
cost estimate.
21.
Item 3 of Respondent’s
supplemental permit
dated April
20, 1993, provided that financial
assurance was
to be maintained
in
an amount equal to $1,342,500.00.
22.
Item 3 of Respondent’s
supplemental permit
dated April
20, 1993, provided the Respondent’s
current cost estimate
was
$1,342,500.00.
23. Respondent failed to increase the
total amount
of
financial assurance to $1,342,500.00,
within 90 days after
the
Agency
approved its
cost estimate on April 20, 1993.
24.
Item 9 of Respondent’s
supplemental permit
dated April
20, 1993, provided that the next revised
cost estimate was
due
by
December 26, 1994.
25. Respondent failed to provide a revised
cost estimate
by
December 26, 1994.
26.
Respondent finally provided
a
performance
bond on
June
20,
1996.
27.
By failing to provide adequate financial assurance
Respondent has violated Section 21.1(a)of the Act, 415
ILCS
13
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807.601(a),
807.603(b) (1)
and
807.623(a)
of the
Board’s Waste
Disposal Regulations;
4.
Assessing
a civil penalty of Fifty
Thousand Dollars
($50,000.00) against Respondent for
each
violation,
and an
additional civil penalty of Ten Thousand Dollars
per
day
of
violation;
5.
Requiring
Respondent to pay all
costs, including
expert
witness, consultant and attorney
fees, expended by the
State in its
pursuit of this
action;
and
6.
Granting such other relief as the Board
deems
appropriate.
COUNT
V
FAILURE
TO FILE THE REQUIRED
APPLICATION FOR A SIGNIFICANT MODIFICATION
1l6.
Complainant
realleges and incorporates
by reference
herein paragraphs 1 through 16 of Count I
as
paragraphs
1 through
16
of this Count V as if fully
set
forth herein.
17.
Section 814.104 of the Board’s Waste
Disposal
Regulations, 35 Ill. Adm. Code 814.104, provides
as follows:
a.
All
owners
or operators of landfills
permitted
pursuant to Section
21(d)
of the
Environmental
Protection Act
(Act) (Ill.
Rev.
Stat. 1991,
ch. 111
1/2, par.
1021(d) [415
ILCS 5/21(d)]
shall file
an
application for
a
significant
modification
to their
permits for
existing units, unless the
units will be
closed pursuant
to Subpart E within two
years of the
effective date
of this Part.
15
b.
The owner or operator
of an existing
unit
shall
submit information
required
by 35 Ill. Adm.
Code 812
to demonstrate compliance
with Subpart B,
Subpart
C
or Subpart D of
this Part, whichever
is applicable.
c.
The application shall
be filed within 48
months of
the effective
date of this Part, or
at such earlier
time as the Agency shall
specify in writing
pursuant
to 35 Ill. Adm.
Code
807.209
or
813.201(b)
d.
The application shall
be made pursuant
to the
procedures of
35
Ill.
Adm. Code 813.
18.
The Respondent failed
to
file
the required significant
modification for Parcel B by June 15, 1993.
19. The Respondent filed a petition for variance
on April 26,
1995, which was
eventually
granted prospectively.
20. By failing to file the required
significant modification
for Parcel
B by June 15, 1993, the Respondent has violated
Section
21(d) (2)
of the Act, 415 ILCS 5/21(d)
(2) (1994),
and Section
814.104
of the Board’s
Waste Disposal Regulations,
35 Ill. Adm.
Code
814.104.
WHEREFORE, Complainant, PEOPLE OF THE STATE
OF ILLINOIS,
respectfully
requests that the Board
enter an order against
Respondent,
CLC, with respect to Count V:
1.
Authorizing a hearing in this matter at which
time the
Respondent
will
be
required
to answer the allegations herein;
2.
Finding that Respondent has violated
Section
21(d) (2)
of
the
Act and Section 814.104 of the Board’s Waste
Disposal
16
Regulations;
3.
Ordering Respondent
to cease and
desist from
any further
violations
of Section 21(d)
(2)
of the Act
or Section 814.104
of
the
Board’s
Waste
Disposal
Regulations;
4.
Assessing a civil penalty of Fifty
Thousand
Dollars
($50,000.00) against Respondent for each violation,
and
an
additional
civil
penalty of Ten Thousand Dollars
per day
of
violation;
5.
Requiring Respondent
to pay all costs,
including expert
witness, consultant and attorney fees,
expended by the
State in its
pursuit of
this action; and
6.
Granting such other relief
as
the Board
deems
appropriate.
COUNT VI
WATER POLLUTION
1-16. Complainant realleges and incorporates
by reference
herein, paragraphs 1 through 16 of Count I
as
paragraphs
1 through
16 of this
Count VI as if fully
set forth herein.
17.
Section
12(a)
of
the Act, 415 ILCS 5/12(a) (1994),
provides
as
follows:
No person shall:
a.
Cause or threaten or allow the discharge
of any
contaminants
in any State so as to cause
or tend to
cause
water
pollution in Illinois,
either alone
or
17
in
combination with matter
from other
sources,
or so
as to
violate
regulations
or standards
adopted
by
the Pollution
Control Board
under this
Act;
18.
Section 807.313
of the Board’s
Waste Disposal
Regulations, 35 Iii. Adm.
Code 807.313, provides
as follows:
No person shall
cause or allow operation
of a sanitary
landfill
so as to cause or threaten
or allow
the
discharge
of any contamination
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
the Act.
19.
During the May 22, 1995,
inspection, the Agency
inspector
observed leachate
in
the north perimeter ditch which
eventually
drains
into the Illinois River.
20. By allowing leachate to flow off site
toward the Illinois
River,
Respondent has violated
Sections
12(a)
and
21(d) (2)
of
the
Act,
415
ILCS 5/12(a) and 2l(d)(2)
(1994),
and Section
807.313
of
the Board’s Waste Disposal Regulations,
35
Ill.
Adm. Code
807.313.
WHEREFORE, Complainant, PEOPLE OF
THE STATE OF ILLINOIS,
respectfully
requests that
the Board enter an order
against
Respondent,
CLC, with respect
to Count VI:
1.
Authorizing
a
hearing
in this matter at which
time the
Respondent will be required to answer the allegations
herein;
2.
Finding that Respondent
has violated Sections
12(a)
and
21(d) (2)
of the Act and Section
807.313 of the Board’s Waste
18
Disposal Regulations;
3.
Ordering Respondent to
cease and desist from
any further
violations
of Sections
12(a)
and
21(d)
(2)
of the Act and
Section
807.313 of the Board’s Waste Disposal
Regulations;
4.
Assessing a civil penalty
of Fifty Thousand Dollars
($50,000.00)
against Respondent for
each violation,
and an
additional
civil penalty of Ten
Thousand Dollars per
day of
violation;
5.
Requiring Respondent to
pay all costs, including
expert
witness, consultant and attorney fees, expended
by the State in
its
pursuit of this
action; and
6.
Granting such other relief
as
the Board
deems
appropriate.
PEOPLE OF THE STATE OF
ILLINOIS,
ex rel. JAMES E.
RYAN, Attorney
General of the State of Illinois
MATTHEW
J.
DUNN,
Chief
Environmental
Enforcement/Asbestos
Litigation Division
By:_____
WILLIAM D. SEITH,
Chief
Environmental
Bureau
Assistant Attorney General
OF
COUNSEL:
JULIE
ID. MELVIN
Assistant Attorney General
100
West Randolph
Street,
11th Floor
Chicago, IL
60601
(312)
814-3369
C:
\wpwin6O\wpdocs\julie\comunt . cmp
19
CERTIFICATE
OF SERVICE
I, JULIE D. MELVIN,
an Assistant
Attorney
General
in this
case,
hereby
certify that
on the 1st
day of May,
1997 I
caused
to be
served,
by
U.S.
Mail,
the
foregoing
Notice of Filing
and
Complaint
upon:
Mark A. LaRose,
Esq.
Mark A.
LaRose
Ltd.
734 North Wells
Street
Chicago,
Illinois 60610
by placing same
in an envelope,
postage
prepaid, and
depositing
same
with
the
United States Postal
Service
at 100 West
Randolph
Street,
Chicago, Illinois;
and
Dorothy
Gunn,
Clerk
Illinois
Pollution
Control
Board
James R. Thompson
Center
100 West
Randolph Street
Chicago,
Illinois
60601
by hand
delivery.
/
JULIE
D.
MELN