IN
THE
MATTER
OF:
PROPOSED
RULES
ESTABLISHING
35
ILL.
ADM.
CODE
SUBCHAPTERS,
PART
840
AND SUBPART
A, SITE-SPECIFIC
RULES
PROVIDING
FOR
THE
CLOSURE
OF ASH
POND AT THE
HUTSONVILLE
POWER
STATION
John T.
Therriault, Clerk
Illinois
Pollution Control
Board
James
R.
Thompson
Center
Suite
11-500
100
W. Randolph
Chicago,
Illinois 60601
)
)
NOTICE
Virginia
Yang
General
Counsel
Illinois
Dept.
of
Natural
Resources
One Natural Resources
Way
Springfield,
Illinois 62702-127
1
CLERK’S
OFFICE
JUN
01200
STATE
OF
ILLINOIS
PUütj
Control
Board
Matthew
J.
Dunn,
Chief
Office of the Attorney
General
Environmental
Bureau,
North
69
West
Washington
St., Suite 1800
Chicago, Illinois
60602
Attached
Service List
Tim Fox,
Hearing Officer
Illinois
Pollution Control
Board
James
R. Thompson
Center
Suite
11-500
100
W. Randolph
Chicago,
Illinois
60601
PLEASE
TAKE NOTICE
that I have
today filed with the
Office of
the Clerk of the
Illinois
Pollution
Control Board the
Appearances of
Kyle Nash Davis
and
H. Mark
Wight
and
the Illinois
Environmental
Protection
Agency’s Response
to Motion for
Expedited
Review, copies of
which are
herewith
served upon
you.
ILLINOIS ENVRONMEN’FAL
PROTECTION
AGENCY
By:
lit!q/+
A1-
Mark Wight
Assistant
Counsel
Division
of Legal Counsel
DATE: May
28, 2009
1021 North
Grand
Avenue East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
(217) 782-5544
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
)
)
)
)
)
)
R09-21
(Site-Specific
Rulemaking
— Land)
THIS FILING
SUBMITTED ON
RECYCLED
PAPER
BEFORE
THE
POLLUTION
CONTROL
BOAR])
CER°KF”RE
OF
THE
STATE
OF ILLINOIS
CE
JUN
012009
IN
THE
MATTER
OF:
)
POllution
PROPOSED
RULES
ESTABLISHING
35
ILL.
)
ADM.
CODE
SUECHAPTERS,
PART
840
)
R09-21
AND SUBPART
A,
SITE-SPECIFIC
RULES
)
(Site-Specific
Rulemaking
— Land)
PROVIDING
FOR
THE CLOSURE
OF
ASH
)
POND AT
THE
HUTSONVILLE
POWER
)
STATION
)
ENTRY
OF
APPEARANCE
NOW
COMES
the
undersigned,
as
counsel for
and
on
the
behalf of
the
Environmental
Protection
Agency
of the State
of
Illinois,
and
hereby enters
his
Appearance
in
the
above
captioned
matter.
Respectfully
submitted,
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY,
By
Kyçhsl{Davis,
qiire
Ditision
of Legal/Coi4isel
Illiois EnvironrentaljProtection
Agency
1 02”Urth
Graid
Avdnue, East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
217/782-5544
217/782-9143
(TDD)
Dated:
May
28,
2009
This filing
submitted
on recycled
paper.
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOA
JUN
0
20g9
piTTE
OF
ILLINOIS
IN THE
MATTER
OF:
)
Utio
Controi
Board
)
PROPOSED
RULES
ESTABLISHING
35 ILL.
)
ADM.
CODE SUBCHAPTERS,
PART
840
)
R09-21
AND
SUBPART
A, SITE-SPECIFIC
RULES
)
(Site-Specific
Rulemaking
- Land)
PROVIDING
FOR
THE
CLOSURE
OF
ASH
)
POND AT THE
IIUTSONVILLE
POWER
)
STATION
)
APPEARANCE
I, the
undersigned,
hereby
file
my appearance
in
the above-titled
proceeding
on behalf of the Illinois
Environmental
Protection
Agency.
By:
Mark
J44AIJYk
Wight
iLL
Assistant
Counsel
DATE:
May28,
2009
H. Mark
Wight
Division
of Legal Counsel
Illinois
Environmental
Protection Agency
1021
North Grand
Avenue
East
P.O.
Box 19276
Springfield,
Illinois
62794-9276
(217) 782-5544
Fax: (217) 782-9807
THIS FILING IS
SUBMITTED
ON RECYCLED
PAPER
BEFORE
THE
POLLUTION
CONTROL BOARD
OF
THE
STATE
OF
ILLINOIS
JUNü7
IN
THE MATTER OF:
)
J9
)
P,TTE0F
ILIJNOIS
PROPOSED
RULES
ESTABLISHING
35 ILL.
)
UtICfl
Controi
5
Or
ADM.
CODE SUBCHAPTERS, PART
840
)
R09-21
AND
SUBPART A, SITE-SPECIFIC
RULES
)
(Site-Specific Rulemaking — Land)
PROVIDING
FOR THE CLOSURE
OF ASH
)
POND
AT
THE HUTSONVILLE POWER
)
STATION
)
RESPONSE TO
MOTION
FOR
EXPEDITED REVIEW
NOW COMES the ENVIRONMENTAL
PROTECTION AGENCY of the State
of
Illinois
(“Illinois
EPA/Agency”),
by its attorneys,
Kyle Nash
Davis and
Mark Wight, and,
pursuant to
35
Ill. Adm. Code 101.500 (2006),
hereby submits this Response to Motion for
Expedited
Review
(“Response”)in response
to the Motion for Expedited
Review filed by the
Petitioner, AMEREN ENERGY GENERATING
COMPANY (“AmerenIPetitioner”). In
support
of this
Response, the Illinois EPA states
as follows:
1.
On May
19, 2009, Arneren
filed its Petition with the Board
for the above-
captioned
proceeding
seeking to amend the Board’s waste rules
by adding a new Part 840
for the
site-specific
closure
of certain surface impoundments for coal combustion
waste
(“CCW”). In
particular, Ameren
proposes
35 Iii. Adm. Code 840.Subpart A to
govern the closure of the
unlined
ash
impoundment
designated
as “Pond D” at Arneren’s Hutsonville
Power Station
in
Crawford
County.
The
proposal includes
a Motion for
Expedited
Review
(“Motion”)
pursuant
to
35 Ill.
Adm. Code
101.5
12. The Illinois EPA
received
service
of this pleading
on May 21,
2009.
1
2.
In its
Motion,
Petitioner
offers
two
reasons
for expediting
the
proceeding:
1)
Ameren
wishes
to
sell
the
Hutsonville
facility,
so the
closure of
the
facility,
or
the certainty
of the
steps
necessary
to achieve
closure,
would
make the
facility
more
attractive
to
potential
buyers;
and 2)
because”..,
public
and regulatory
interest
in
ash
ponds at
coal-fired power
plants
has
heightened
nationwide,
including
in
Illinois.”
(Motion
at 2,
par 3
and 4).
In the
Agency’s
view,
the
first
reason
does
not rise
to the level
of a material
prejudice
that would
justif’
accelerating
the
Board’s
usual
intention
to
proceed
as soon
as practicable,
and
thesecond
reason
is better
interpreted
as
a reason
why
a more
measured
pace is in
the public interest.
In addition
and
as
further
set
forth below,
an expedited
proceeding
may
prevent
the
Illinois EPA
from providing
the
Board with
the
level
of
analysis
that
the Illinois
EPA could
otherwise
provide
if the matter
proceeded
under
a
standard
rulemaking
schedule.
3.
Petitioner
generally
states that
it owns
a
facility it
intends to
sell and that
such
a
fact should
be
a
consideration
in expedition
of its Petition.
(Motion
at 2,
par 3 and 4)
Petitioner
claims
a
“material
hardship
so long
as
the parameters
under
which it may
close
Ash
Pond D
are
undecided.”
(Motion
at
3, par
7)
Yet,
if the desired
regulatory
certainty
suggested
within the
above
statement
is
to
be
considered,
it
would
be noteworthy
that expedited
consideration
is
claimed
upon the
basis of providing
for
a more
marketable
plant.
The
Agency
does not
dispute
this would
be of benefit
to
Petitioner;
however,
a decision
to offer
the sale
of its
plant is,
at
best,
a self-imposed
hardship.
The mere
fact
that
a
business
intends
to offer
its
facility”..,
on
the
market
for sale
to
reduce its costs
. . .“ and
place
a
waste
disposal
area”...
in
a
better
light to
a
potential
buyer . . .“
is not unique,
by any
means.
Indeed,
almost every
Petitioner
before
the
Board
may
claim similar
facts when
a sale
is considered.
Such
events
should
not, by
themselves,
be
dispositive
of a request for expedited
consideration.
4.
Other
important
considerations
against expediting
the proceeding
include the
public
interest in conducting
a
proceeding
that
thoroughly
and
deliberately
evaluates
the proposal
(which
has implications
extending
beyond
the
Hutsonville
facility)
and Agency resource
limitations.
Matters
of fact set forth below
are stated
on information
and belief.
5.
On Thursday,
March
5, 2009,
the
Illinois
Pollution Control
Board (“Board”)
issued
its final
order
in the proceeding
In the
Matter ofi Petition
ofAmeren Energy
Generating
Companyfor Adjusted
Standards
from
35111.
Adm.
Code Parts 811, 814,
815, PCB
AS 09-1.
The Board
found
that promulgation
of a
site-specific
rule
is a more appropriate
way to
govern
the
closure
of ‘Pond D.”
6.
On
Tuesday, March
10, 2009,
Ameren
sent to
the
Illinois
EPA
via e-mail
a draft
ofproposed
legislation
that would be generally
applicable
to closures of
CCW impoundments
“when such facilities
are nolonger operated
pursuant
to water pollution control
permits
issued
by
the Agency
under
applicable Board
regulations.”
By Friday, March
13
th,
the Agency
had
hastily
assembled
a small workgroup
representing
the Bureaus of Water
and Land and
the Division
of
Legal
Counsel
to begin
evaluating the
proposal.
The
Agency had
reason to believe the
proposed
legislation
would
be filed as
soon
as
late March
or early April.
7.
On
Sunday,
March 22, 2009, Ameren
sent
to
the
Agency
via
e-mail the
Legislative
Reference Bureau
draft
of the legislation.
By Tuesday,
March
24
th
the Agency
workgroup
had identified
a
list of significant
questions
and
concerns
about
the legislation in
the
event
the draft proposal was
introduced
in the General
Assembly.
In addition
to specific
concerns,
the
two
overarching
concerns were:
1) that such
an important
piece
of
environmental
legislation
would
be rushed through
the legislative
process
with
little
time for deliberation
by the
Agency and other
interested
parties, and
2)
that federal
proposals
on
CCW
matters would
be
forthcoming
by
the
end of
2009, the
subsequent
adoption
of
which might be
necessary in Illinois
to maintain delegated,
authorized
or approved
federal
programs.
With regard to the
latter,
conflicting
legislation
would
be a significant
complication.
8.
Mid-afternoon
on Wednesday,
April
8, 2009,
Ameren sent to the
Agency
via e
mail
three
documents,
the generally
applicable
draft legislation, Ameren’
s draft site-specific
rule
for the closure
of Ash Pond
D, and a “Summary
Document
presenting
the
underlying
elements
of
the approach for
the closure of Ash
POnd
D. . . as
found in the draft rule.”
The message
reiterated that time
was
of the
essence
and that
legislation would have
to
go forward
within days
if the “[Agency
did
not]
believe we can
work on developing a
site-specific
rule. . . .“
9.
On Thursday,
April
9, 2009, the Agency conveyed
to Ameren
via telephone
message
its
preference
to work
on a site-specific rule
rather than legislation.
On or about
April
13
th
Ameren
proposed
a meeting
at Agency headquarters
in Springfield
the following
Thursday,
April
16
th
for the
purpose
of walking through
its proposal and supporting
documentation
and
receiving
the
Agency’s
comments on the
proposal.
Because
of insufficient
time
and
prior
commitments,
the Agency
could not
accommodate
this schedule,
but a meeting was
set
for
Tuesday afternoon,
April
21
st
The
Agency’s list of comments
on
the
proposal
and supporting
documentation
was
provided
to Ameren
on Friday, April
17
th,
so Ameren
could at least see the
nature of
the Agency’s
concerns before the
meeting. It was understood
by
both
parties
that the
Agency’s
comments
were
preliminary, not
a “full critique.” The
Agency
reserved
the right
to
4
revise and extend
its comments
as
the discussions
evolved.
It was
further
understood that
Ameren
had not yet
ruled
out proceeding
with
legislation.
10.
As
a result of the exchange
at
the meeting, Ameren
made
revisions
to its proposal.
On
Saturday, May 2, 2009,
Ameren
sent to the
Agency via
e-mail
its
revised
proposal
for a
site-
specific
rule.
The Agency
was unable
to divert resources
to the
task
of accelerated
review until
May
11
th•
On May
15
th,
Ameren
checked
on
the
Agency’s
progress via
telephone, but
the
Agency had not
yet compiled
a list of comments.
Ameren stated
its
intention to file
the
proposal
with the Board
the following week.
11.
On May
19, 2009, Ameren
called the Agency
to see if comments
were
available
and to confirm
the filing of its
site-specific proposal
with the
Board. Partial
comments had
been
assembled
but not reviewed
by the full
workgroup or management
and were not ready
for
discussion.
12..
As the foregoing
chronology
demonstrates,
the entire
process since the Board’s
decision
in PCB AS
09-1 has been driven
by haste. The Agency
does
not fault Ameren
for
proceeding in
the manner it believes
best protects its interests
nor does it mean
to diminish
the
importance
of
those
interests.
Nonetheless, the Agency
has repeatedly
been
placed in a
reactive
mode with little time
to fully evaluate the
proposal and its effects,
much less
for deliberation
about
how the
proposal
might be
improved to the
extent necessary.
The Agency
knew
these
circumstances
were not conducive
to
the
optimal
outcome,
but
it nonetheless
made
a
good faith
attempt
to participate and
to identify
and resolve
as
many
issues
as possible
before the proposal
was
filed
with the Board.
The Agency
did
so not
only because
it agrees
that a site-specific
rule
for
closure
and post-closure
is
appropriate
for
the
Hutsonville
ash
pond,
but also to head off
the
5
legislative
approach, which
would have
provided
even
less time
for deliberation and
was of even
greater
concern
because of
its general applicability.
Further, if
any
issues
could be
resolved
before
submission
to the
Board,
the
rulemaking
might
be
concluded more quickly
for all
concerned.
Ultimately,
the
Agency’s
capacity
to respond did
not
meet
Ameren’s expectations.
There
was no
“meeting
of the minds”
on this proposal
prior
to its filing
with the Board.
11
Now Ameren
continues to
push the
pace
by requesting expedited
review by the
Board.
The Agency’s
position
is that this proposal
is
too important
to rush. Because
of
significant
source control
and
surface
and groundwater
contamination
issues (on-
and
off-site),
it
is important
that
this
proposal.be
carefully and
thoroughly considered
in its own context.
However,
the importance
of
the proposal
extends well beyond
the
Hutsonville
facility. Amêren
itself has acknowledged
that it and
its affiliated companies
own seven
other facilities with similar
ash impoundments.
PCB
AS
09-1 at 5.
Moreover,
“Ameren [has
arguedj that its ‘closure
of
Pond
D will likely
serve
as
an
example
for
the closure
of
other
similarly-situated
ash
ponds
in the
future.” Id. The Agency
expects
that other
companies,
in
addition to Ameren
and its affiliates,
also
will use the results
of this
proceeding
as
a template for similar
closures.
In effect, the
Board
may well be
developing what
amounts to a
regulatory
program albeit in
the context
of
a
site
specific
rulemaking.
Were the Agency the proponent
of a rule with
similar broad
implications,
preparations would
begin
far sooner
than
the ten
weeks
prior to filing with
the Board
the
Agency
was
given to respond to
Ameren’s proposed
legislation
and site-specific
rule, and full
and
deliberate
consideration
still
would
be
required
during
the hearing
phase. As Ameren
has
noted
in its
Motion,
coal ash impoundments
are a
complex,
high profile matter
of
nationally-recognized
importance.
The Agency believes
it is not in
the public interest
to accelerate
this
proceeding.
6
14.
The timing
is further
complicated
by the
Agency’s limited
capacity to
respond
to
this
proposal in the
near
term. Ameren
cites In the Matter
ofi City of
Galva Site
SpecUIc
Water
Quality
Standard
for Boron
Discharges
to
Edwards
River and Mud
Creek,
PCB
R09-1 1
(February
5,
2009)
as an example
of setting
a
site-specific
proposal for First Notice
without
first
considering
the
merits of the proposal.
PCB
R09-1 1 at 3. What
is instructive
is that the Board
denies
Galva’s
motion for expedited
consideration. The
Board
takes
note
of its
workload
of
pressing
cases
and numerous
rulemakings demanding
immediate attention.
The Board
then
states:
Due to
attrition; Board
staffing
is at its
lowest
levels in some years.
Even if the
Board
were
to accept that
Galva’s claims
amount
to
“material
prejudice”,
the
Board’s
limited
resources in light of
its current and future
decision deadlines
render the
granting
of a
motion
for expedited review
unlikely in all
but the most
dire circumstances.
Id.
Similar resource
limitations
afflict
certain functions of
the
Agency.
Despite
diminished
resources,
the
Agency must respond
to a
multitude
of statutory
obligations and
demands from
parties
each of
whom also believes
its interests
are paramount and will
be
compromised
if the
Agency
does not
address them immediately.
15.
The Bureau of
Land’s
Permit
Section
Solid
Waste
Groundwater
Assistance
Unit,
the workgroup responsible
for
assessing
the
effectiveness
of Ameren’
s
groundwater monitoring,
assessment
and
response
provisions, is currently
understaffed
with no
immediate prospect
for
hiring. Remaining
employees
average
approximately
40 projects
per person, nearly
doubling the
average since
2008.
Most,
if not
all,
of
the projects
are various
forms of
permit
applications
for
waste
management facilities
(e.g.,
initial
applications,
modifications)
with statutory
deadlines for
7
completion.
Reviewers
with
expertise
and
experience
in
key
areas
afready
are working
overtime
to
complete
reviews.
16.
The
Toxicity
Assessment
Unit, the
workgroup
responsible
for
reviewing
Ameren’s
risk
assessment
document,
will
require
at least
30
days
and possibly
as many
as 60
days
to complete
a
review
of that
document,
depending
on
a
number
of
variables.
17.
Ameren
states
it “believes
it
has
addressed
most,
if not
all, of the
Agency’s
requests
and
has
prepared
this
proposal
and
supporting
technical
documents
to facilitate
prompt
review.”
(Motion
at
2, par
6) Ameren’s
representation
apparently
is
based
on
the revisions
made
following
the discussion
of the
Agency’s
preliminary
comments
on
the
first
draft of the
proposal.
There have
been
no
substantive
discussions
of
the second
draft, the one
submitted
to the Board.
The
Agency
continues
to have questions
and
significant
reservations.
To the
extent the Agency
has been
able
to
assess
the proposal,
it
has
identified
areas of concern
including,
but not
limited
to:
•
Groundwater
contamination
monitoring,
assessment
and
response:
Several
unclear,
open-
ended
and/or
inappropriate
provisions;
omissions
such
as
no clear
requirement
to
control
public or
private
uses
of contaminated
off-site groundwater;
•
Requirements
for final
slope
and
stabilization
and final
cover system;
•
Time
periods
for initial
implementation
and compliance;
•
Little
or
no
Agency
oversight
or
involvement
where provisions
propose
the flexibility
to
establish
or
alter elements
of
the
closure and
post-closure
plans,
or,
in
the alternative,
the
proposal
may
be insufficiently
prescriptive
to
support
effective field
inspections
and
enforcement
for non-compliance.
8
18
Some of these issues
may
require
resolution before
others can be addressed
Further
and as a part
of its participation,
the
Agency’s preference
would be
to
offer more than
criticisms
of the
proposal with the expectation
that
Ameren
would offer revisions until
the
proposal
is
deemed satisfactory. The
more effective, but time consuming,
method
of
participation would be for the Agency to identify
satisfactory
alternatives, consider amendments
to
the proposal or an
alternative
proposal
to implement
the
alternatives, and prepare
written
testimony
to
convey all this to the Board and participants.
In
the
end, it may be that the
differences between Ameren and the Agency
are not great, but
there must be sufficient time to
sort and
resolve
them. It also should be noted that Ameren
and
the Illinois EPA have expressed
to each
other a
willingness to continue informal discussions to reduce or eliminate
differences
of
opinion. This could be a
constructive alternative
to
expediting the proceeding.
19.
The Agency’s concern is that an expedited hearing schedule will
compromise
the
Agency’s capacity to
fully identify, address and express its
concerns
and proposed solutions.
This
would
constitute
material prejudice
to
the Agency’s ability to fully participate in the
proceeding. As of
the preparation of this Response,
the
Agency cannot
say precisely
when
it will
be
ready
for
hearing.
It is
currently considering whether resources outside the Bureau of Land
may be diverted to
assist in reviewing and
responding to Ameren’s
proposal. Assuming the
Board
accepts
the
proposal for hearing, the Agency
expects it will
be able to respond with more
specific
information in the
hearing officer’s status call for establishing a hearing
schedule.
Further, setting
the
proposal
for First Notice without
comment
on its merits still has the effect
of
starting the
time
clock and
reducing the Board’s
flexibility.
The Agency believes this step
should
be delayed until
the
nature and extent of the issues
are better
understood.
9
WHEREFORE, the
Illinois
EPA respectfully
requests
that
the Board DENY Petitioner’s
Motion for
Expedited
Review
Respectfully
submitted,
ILLINOIS
ENVIRONMENTAL
PROTECTION AGENCY
By:
A4
4
Mark
Wight
/
kL
One of
its attom
CERTIFICATION
STATEMENT
V
In
accordance
with
35 Iii.
Adm. Code
101.504
and
under penalties
as provided by law
pursuant
to Section
1-109
of the Code of Civil
Procedure,
the undersigned certifies
that the statements
set
forth in
this
instrument
are true and
correct, except
as
to
matters therein
stated to be on
V
infOrmation
and belief
and as to such matters
the undersigned
certifies as aforesaid
that he verily
believes
the same
to be
true.
By:
IJ&
4kV
Mark Wight
/
Dated:
May 28,
2009
Kyle
Nash Davis
H. Mark
Wight
Division
of Legal
Counsel
Illinois Environmental
Protection
Agency
1021
North
Grand
Avenue East
P.O. Box
19276
Springfield,
IL 62794-9276
(217) 782-5544
Fax: (217) 782-9807
This filing
submitted
on recycled paper.
in
STATE OF
ILLINOIS
)
COUNTY
OF SANGAMON
)
)
PROOF
OF SERVICE
I, the undersigned,
on oath state
that
I have
served
the attached
Appearances
of
Kyle
Nash Davis
and H.
Mark
Wight
and
the
Illinois
Environmental
Protection
Agency’s
Response to
Motion for
Expedited
Review
upon
the
persons
to
whom
they
are
directed,
by
placing
a copy
of each
in
an envelope addressed
to:
John
T. Therriault, Clerk
Illinois
Pollution
Control Board
James R. Thompson
Center
Suite
11-500
100
W. Randolph
Chicago,
Illinois
60601
(First
Class Mail).
Matthew
J.
Dunn, Chief
Office of the Attorney
General
Environmental
Bureau, North
69
West
Washington St., Suite
1800
Chicago, Illinois
60602
(First
Class
Mail)
This3O
day of
Notary
Public
Virginia
Yang
General
Counsel
Illinois Dept. of Natural
Resources
One Natural Resources
Way
Springfield,
Illinois 62702-127 1
(First Class
Mail)
Tim
Fox, Hearing Officer
Illinois
Pollution
Control
Board
James
R. Thompson Center
Suite
11-500
100
W.
Randolph
Chicago, Illinois 60601
(First Class
Mail)
‘1
t&/
,2009.
-Nq/
OFFICIAL
SEAL
BRENDA
SOEHNER
t
NOTARV
PUBLIC,
STATE
OF
ILUMOLS
S
1
MY
COMMISSION
EXPIRES
11-3-2009
(Attached
Service List — First
Class
Mail)
and
mailing them from
Springfield, Illinois
on May
affixed
as indicated
above.
SUBSCRIBED AND
SWORN TO BEFORE
ME
THIS
FILING
SUBMITTED ON RECYCLED
PAPER
Illinois
Pollution
Control
Board
Service
List
Service
list
for
case
R2009-02
I
arty
Name
arty
Role
ddress
1
ddress
2
City
State
ip
hone
ax
erson
itle
arne
IEPA
espondent
1021
North
Grand
Avenue
.0.
Box
19276
Springfield
L
2794-9276
17/782-55
17/782-98
*
East
4
7
EPA
espondent
1021
North
Grand
Avenue
.0.
Box
19276
Springfield
IL
62794-9276
217/782-55
217/782-98
John
Kim
General
East
4
07
Counsel
ilinois
terested
One
Natural
Resources
Way
pringfield
62702
irginia
epartment
arty
ang
of
Natural
Resources
Office
of
the
Interested
Environmental
Bureau
North
69
West
Chicago
IL
60602
312/814-25312814-23
atthew
J.
Chief
Itorney
arty
ashington
Street,
50
7
unn
eneral
Suite
1800
SchiffHardin,
etitioner
6600
Sears
Tower
33
South
Wacker
hicago
60606-6473
3
12/258-55
12/258-56
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LLP
nyc
00
00
Cipriano
SchiffHardin,
etitioner
6600
Sears
Tower
233
South
Wacker
hicago
L
60606-6473
3
12/258-55
3
12/258-56
athleen
LLP
nyc
00
00
C.
Bassi
SchiffHardin,
etitioner
6600
Sears
Tower
33
South
Wacker
hicago
IL
60606-6473
12/258-55
312/258-56
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R.
LLP
nive
00
00
ore
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