ERK’S
    OFFICE
    JUL
    2
    0
    2
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    OFFICE
    OF
    THE
    AfORNEY
    GENERAL
    STATE
    OF
    ILLINOIS
    Lisa
    Madigan
    ATTORNEY GENERAL
    July
    16,
    2009
    John
    T.
    Therriault,
    Assistant
    Clerk
    Assistant Clerk
    of the
    Board
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson Center,
    Ste.
    11-500
    100
    West
    Randolph
    Chicago,
    Illinois
    60601
    Re:
    People
    v.
    Richard
    King,
    et
    a!.
    PCB
    No.
    O9-2
    Dear
    Clerk:
    Enclosed
    for
    filing
    please
    find
    the
    original
    and
    ten
    copies
    of
    a
    Notice
    of Filing,
    Motion
    for
    Relief
    from
    Hearing
    Requirement
    and
    Stipulation
    and
    Proposal
    for
    Settlement
    in
    regard
    to
    the
    above-captioned
    matter.
    Please
    file
    the
    originals
    and
    return
    file-stamped
    copies
    to
    me
    in
    the
    enclosed envelope.
    Thank
    you
    for
    your
    cooperation
    and
    consideration.
    Very
    truly
    yours,
    Christine
    ktQ
    Zeivel
    &O
    Environmental
    Bureau
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    (217)
    782-9031
    CZ/pjk
    Enclosures
    500
    South
    Second
    Street,
    Springfield,
    Illinois
    62706
    • (217)
    782-1090
    • TFY:
    (877)
    844-5461
    • Fax:
    (217)
    782-7046
    100 West
    Randolph
    Street,
    Chicago,
    Illinois
    60601
    (312)
    814-3000
    • TTY:
    (800)
    964-3013
    • Fax:
    (312)
    814-3806

    BEFORE
    THE
    ILLINOIS POLLUTION CONTROL
    BOARD
    PEOPLE OF
    THE
    STATE
    OF
    ILLINOIS,
    Complainant,
    )
    vs.
    )
    PCB
    No.
    09-27
    )
    (Enforcement)
    RICHARD
    KING,
    KAY
    KING
    and
    )
    ISAAC
    KING,
    )
    )
    Respondents.
    NOTICE
    OF
    FILING
    CLERK’S
    OFFICE
    To:
    Hodge
    Dwyer
    &
    Driver
    JUL
    2
    1
    2009
    3150
    Roland
    Avenue
    P.O.
    Box
    5776
    STATE
    9aSrd
    Springfield, IL 62705-5776
    PollUt10’
    PLEASE
    TAKE
    NOTICE
    that
    on
    this date
    I
    mailed
    for filing
    with
    the
    Clerk
    of
    the
    Pollution
    Control
    Board
    of
    the State
    of
    Illinois,
    a
    MOTION
    FOR
    RELIEF
    FROM
    HEARING
    REQUIREMENT
    and
    STIPULATION
    AND
    PROPOSAL
    FOR
    SETTLEMENT,
    copies
    of which
    are
    attached hereto
    and
    herewith
    served
    upon
    you.
    Respectfully
    submitted,
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS
    LISA
    MADIGAN,
    Attorney
    General
    of
    the
    State
    of
    Illinois
    MATTHEWJ.
    DUNN,
    Chief
    Environmental Enforcement/Asbestos
    Litigati
    ivision
    BY:_______
    ‘CHRISTINE
    ZEWEL
    Assistant Attorney
    General
    Environmental
    Bureau
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    217/782-9031
    Dated:
    July
    16,
    2009

    CERTIFICATE
    OF
    SERVICE
    I hereby certify that
    I did
    on July
    16, 2009,
    send
    by First Class Mail,
    with postage
    thereon
    fully
    prepaid,
    by depositing ma
    United States
    Post Office Box
    a true and correct
    copy of
    the
    following instruments
    entitled NOTICE
    OF FILING,
    MOTION FOR RELIEF
    FROM
    HEARING
    REQUIREMENT
    and STIPULATION AND
    PROPOSAL
    FOR SETTLEMENT:
    To:
    Hodge
    Dwyer & Driver
    3150 Roland Avenue
    P.O. Box
    5776
    Springfield,
    IL 62705-5776
    and the original and ten
    copies
    by
    First Class
    Mail with
    postage thereon fully
    prepaid of the
    same
    foregoing instrument(s):
    To:
    John
    T. Therrault,
    Assistant Clerk
    Illinois
    Pollution Control Board
    James R.
    Thompson Center
    Suite 11-500
    100 West
    Randolph
    Chicago,
    Illinois
    60601
    A copy
    was also sent
    by First Class Mail with
    postage
    thereon fully prepaid
    to:
    Carol
    Webb
    Hearing
    Officer
    Illinois Pollution Control
    Board
    1021
    North Grand
    Avenue East
    Springfield,
    IL 62794
    CHRISTINE
    ZEIVEL
    Assistant
    Attorney
    General
    This
    filing is submitted on
    recycled
    paper.

    BEFORE
    THE ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    PEOPLE OF THE
    STATE OF ILLINOIS,
    )
    Complainant,
    vs.
    )
    PCB No. 09-27
    )
    (Enforcement)
    RICHARD
    KING,
    KAY KING
    and
    )
    ECEVED
    ISAAC KING,
    )
    CLERK’S
    OFFICE
    Respondents.
    JUL
    2 02009
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    MOTION
    FOR
    RELIEF
    FROM HEARING
    REQUIREMENT
    NOW
    COMES
    Complainant,
    PEOPLE
    OF
    THE STATE OF ILLINOIS,
    by
    LISA
    MADIGAN,
    Attorney General
    of the State of
    Illinois, and
    pursuant to Section
    31(c)(2) of the
    Illinois
    Environmental
    Protection
    Act (“Act”),
    415 ILCS 5131(c)(2)
    (2006),
    moves
    that the Illinois
    Pollution
    Control
    Board grant the
    parties
    in the
    above-captioned
    matter
    relief from the
    hearing
    requirement imposed
    by Section
    31(c)(1)
    of
    the
    Act, 415 ILCS
    5/31(c)(1)
    (2006). In
    suppàrt
    of
    this
    motion,
    Complainant
    states as
    follows:
    1.
    The
    parties
    have reached
    agreement on
    all
    outstanding
    issues in this matter.
    2.
    This
    agreement
    is presented to
    the Board in a
    Stipulation
    and
    Proposal for
    Settlement,
    filed
    contemporaneously
    with
    this motion.
    3.
    All
    parties agree
    that a
    hearing
    on the
    Stipulation and Proposal
    for
    Settlement
    is
    not
    necessary,
    and
    respectfully
    request relief
    from
    such
    a hearing
    as
    allowed
    by
    Section
    31(c)(2) of
    the Act, 415
    ILCS 5131(c)(2)
    (2006).
    I

    WHEREFORE,
    Complainant,
    PEOPLE
    OF THE STATE
    OF ILLINOIS,
    hereby
    requests
    that
    the
    Board grant
    this motion for relief
    from
    the hearing
    requirement
    set forth in Section
    31(c)(1)
    of the Act, 415 ILCS
    5/31(c)(1) (2006).
    Respectfully submitted,
    PEOPLE
    OF THE STATE
    OF
    ILLINOIS
    LISA MADIGAN
    ATTORNEY
    GENERAL
    MATTHEWJ.
    DUNN,
    Chief
    Environmental
    Enforcement/Asbestos
    ,4i,Jigatio
    Division
    BY:__________
    CHRISTINE
    ZEIVEL
    Environmental
    Bureau
    Assistant
    Attorney
    General
    500 South Second
    Street
    Springfield, Illinois
    62706
    21 7/782-9031
    Dated:
    July 16, 2009
    2

    BEFORE THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS,
    )
    )
    Complainant,
    )
    )
    v.
    )
    PCB
    NO.
    09-27
    ECEVD
    )
    (Enforcement
    -
    AiFcLERS
    OFFICE
    RICHARD KING,
    KAY
    KING
    &
    )
    JUL
    202009
    ISAAC
    KING
    )
    ri-r
    OF
    ILLINOIS
    Respondents.
    )
    pllutior1
    Control
    Board
    STIPULATION
    AND
    PROPOSAL FOR
    SETTLEMENT
    Complainant, PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS,
    by
    LISA
    MADIGAN, Attorney
    General
    of
    the
    State
    of Illinois,
    the Illinois
    Environmental
    Protection
    Agency
    (“Illinois
    EPA”),
    and
    Richard
    King,
    Kay
    King
    and
    Isaac
    King
    (“Respondents”)
    (“Parties to
    the
    Stipulation”),
    have
    agreed
    to
    the
    making
    of
    this
    Stipulation
    and
    Proposal
    for
    Settlement
    (“Stipulation”)
    and
    submit
    it
    to
    the
    illinois
    Pollution
    Control
    Board
    (“Board”)
    for
    approval.
    This
    stipulation
    of
    facts
    is
    made
    and agreed
    upon
    for
    purposes
    of settlement
    only
    and
    as a
    factual
    basis
    for
    the
    Board’s
    approval of
    this
    Stipulation
    and
    issuance
    of
    relief
    None
    of
    the facts
    stipulated
    herein
    shall
    be introduced
    into
    evidence
    in
    any
    other
    proceeding
    regarding
    the
    violations
    of
    the
    Illinois
    Environmental
    Protection
    Act
    (“Act”),
    415
    ILCS
    5/1 et
    seq.
    (2006),
    and
    the
    Board’s
    Regulations,
    alleged
    in
    the
    Complaint
    except
    as otherwise
    provided
    herein.
    It
    is
    the intent
    of
    the
    Parties
    to the
    Stipulation
    that
    it
    be a
    final
    adjudication
    of
    this
    matter.
    I.
    STATEMENT
    OF FACTS
    A.
    Parties
    1.
    On
    October
    22,
    2008,
    a
    Complaint
    was
    filed
    on
    behalf
    of the
    People
    of the
    State
    of
    Illinois
    by
    Lisa
    Madigan,
    Attorney
    General
    of
    the
    State
    of
    Illinois, on
    her own
    motion
    and

    upon the request of the Illinois EPA, pursuant
    to Section 3.1 of the
    Act, 415 ILCS 5/31
    (2006),
    against the Respondents.
    2.
    The Illinois
    EPA is an administrative agency
    of the State of Illinois, created
    pursuant to Section 4 of the Act, 415 ILCS
    5/4 (2006).
    3.
    At all times relevant to the Complaint, Richard
    and Kay King were the
    owners
    of
    a vacant three
    story building,
    formerly known
    as
    the Buck’s Building, located
    at 527 East
    Washington
    Street, Springfield, Sangamon
    County,
    Illinois
    (“Buck’s Building”).
    4.
    At all times
    relevant
    to the Complaint, Isaac King supervised and participated
    in
    renovation and
    restoration activities at the Buck’s Building.
    5.
    On
    January
    3,
    2007, Richard King
    applied
    for
    a
    building
    permit
    with the City
    of
    Springfield
    for demolition
    of the interior
    at the Buck’s
    Building.
    6.
    On January 4,
    2007,
    the City of
    Springfield
    issued
    Building Permit Number
    BP-2007-0030 to
    Richard and Kay King for
    demolition
    at
    the Buck’s Building.
    7.
    On a date better known to
    the Respondents, the Respondents commenced the
    removal of wall,
    ceiling and
    flooring material, including regulated asbestos-containing material
    within
    the Buck’s
    Building,
    without first notifying
    the Illinois EPA
    8.
    On January 12,
    2007, the
    Illinois EPA inspected the interior
    and
    entrance
    to
    the
    Buck’s
    Building.
    The building
    contained
    debris, including carpet, drywall
    joint
    compound,
    wallpaper
    and dimensional
    lumber in an
    open
    dumpster,
    located
    at
    the corner of Washington
    and
    Streets. In
    addition,
    there
    was
    broken
    suspect drywall and
    plaster at various locations
    on the
    ground
    adjacent
    to the
    dumpster and
    leading
    to
    the doorway
    entrance
    of
    the building and
    significant
    quantities
    of dry
    white
    dust
    coating the floor.
    2

    9.
    On
    January
    12, 2007,
    the Illinois
    EPA
    collected
    a sample
    of friable
    suspect
    drywall
    from
    the
    ground
    adjacent
    to
    an open dumpster
    located
    outside of
    the building.
    It was
    capable
    of being
    crumbled,
    pulverized
    or
    reduced
    to
    powder
    by
    hand pressure.
    10.
    The
    sample
    drywall
    was tested
    and determined
    to
    contain
    a concentration
    of
    chrysotile
    asbestos
    ranging
    from
    1%
    to
    5%.
    Additional
    testing
    revealed
    an asbestos
    concentration
    in
    the amount
    of
    2.9%
    within the
    sample.
    11.
    On
    January
    29 and
    30, 2007,
    material samples
    were
    collected
    from within
    the
    facility
    during
    an
    asbestos
    survey
    performed
    by
    a contractor
    retained
    by the Respondents
    to
    identify
    the
    presence
    of asbestos-containing
    materials
    or asbestos
    contaminated
    debris.
    Data
    resulting
    from
    analytical
    testing of
    the
    samples,
    by an
    analytical
    testing
    laboratory
    utilized
    by
    the
    contractor,
    revealed
    the presence
    of
    asbestos
    concentrations
    within
    wall paper,
    paneling
    mastic,
    joint
    compound,
    floor
    tile,
    debris powder,
    wall
    plaster
    finish coat,
    and
    baseboard
    material
    greater
    than
    1%.
    In
    addition,
    the
    asbestos
    survey
    revealed
    the
    presence
    of asbestos
    within
    materials
    located
    on each
    floor
    and
    the
    basement
    of the building.
    B.
    Allegations
    of
    Non-Compliance
    Complainant
    contends that
    the
    Respondents
    have
    violated
    the following
    provisions
    of
    the
    Act,
    Board
    regulations
    and
    the
    NESHAP
    for asbestos.
    Count
    I:
    Air Pollution
    By failing
    to
    adequately
    wet
    all
    RACM
    removed
    during
    renovation
    activities
    and
    to
    deposit
    all RACM
    at a
    site
    permitted
    to
    accept such
    waste
    as
    soon as
    practicable,
    thereby
    causing
    or
    tending
    to
    cause
    air
    pollution
    in Illinois,
    the Respondents
    violated
    Section
    9(a) of the
    Act,
    415
    ILCS
    5/9(a)
    (2006)
    and
    Section 20
    1.141 of the
    Board’s
    Air
    Pollution
    Regulations,
    35
    Ill. Adm.
    Code
    201.141 (2005).
    3

    Count II:
    Failure
    to Inspect for Asbestos and Provide
    Notification
    of
    Demolition and Renovation
    By
    failing
    to thoroughly
    inspect the Buck’s Building for the
    presence
    and
    location
    of asbestos-containing material
    (“ACM”) prior to commencing
    asbestos
    removal
    and
    disposal
    activities at the
    facility,
    the Respondents
    violated
    40 C.F.R. 61.145(a),
    and therefore Section 9.1(d) of the Act,
    415
    ILCS
    5/9.1(d) (2006).
    By failing
    to notify the Illinois EPA of scheduled asbestos
    removal activities
    at
    the
    Buck’s
    Building,
    at least
    10
    working
    days
    prior
    to commencing such
    activities,
    the
    Respondents violated
    40 C.F.R. 61.145(b), and therefore
    Section 9.1(d) of the
    Act, 415 ILCS 5/9.1(d) (2006).
    Count III:
    Failure
    to
    Remove
    and Contain RACM in
    Compliance
    with
    NESHAP Requirements
    By failing to properly remove all regulated asbestos-
    containing material (“RACM”), from the Buck’s Building
    before
    commencing planned renovation activities, which
    broke
    up, dislodged and similarly disturbed the
    RACM, the
    Respondents violated 40 C.F.R. 61.145(c)(1), and
    therefore
    Section
    9.1(d) of the Act, 415 ILCS 5/9.1(d) (2006).
    By failing to adequately wet all
    RACM.
    and
    prevent damage
    or disturbance
    to
    the RACM
    during
    cutting
    or
    disjoining
    operations
    at
    the Buck’s
    Building,
    the Respondents violated
    40 C.F.R. 61.145(c)(2), and
    therefore Section
    9.1(d) of the
    Act, 415 ILCS 5/9.1(d) (2006).
    By failing to adequately wet
    and maintain wet all RACM
    and regulated
    asbestos-containing waste material at the
    Buck’s Building
    until collected and contained in preparation
    for disposal at a
    site
    permitted to
    accept such waste, the
    • Respondents
    violated
    40
    C.F.R. 61.145(c)(6), and therefore
    Section 9.1(d) of
    the
    Act,
    415 ILCS 5/9.1(d)
    (2006).
    By
    failing to have at least one
    representative
    at
    the Buck’s
    Building trained
    in
    the provisions of
    the NESHAP for
    4

    asbestos and
    the
    means of
    complying
    with
    them, the
    Respondents
    violated
    40 C.F.R.
    61A45(c)(8),
    and
    therefore
    Section
    9.1(d)
    of
    the Act, 415
    ILCS
    5/9.1(d)
    (2006).
    Count
    IV:
    Improper
    Disposal
    of
    Regulated
    Asbestos-Containing
    Materials
    By
    failing
    to adequately
    wet
    and keep
    wet, containerize,
    and
    label
    all
    asbestos-containing
    material
    at the
    Buck’s Building,
    thereby
    causing
    or allowing
    the discharge
    of visible
    emissions
    to the outside
    air,
    the
    Respondents
    violated
    40
    C.F.R.
    61.150(a)(1)(iii),
    (iv) and
    (v), and
    therefore
    Section
    9.1(d)
    of the Act,
    415
    ILCS
    5/9.1(d)
    (2006).
    By
    failing
    to transport
    to
    a waste
    disposal site,
    or Illinois
    EPA-approved
    site that
    converts
    RACM
    and asbestos-
    containing
    waste material
    into non-asbestos
    material,
    and
    deposit
    as
    soon as practical
    all
    asbestos-containing
    waste
    material
    generated
    during
    asbestos removal
    activities
    at the
    Buck’s
    Building,
    the
    Respondents
    violated
    40 C.F.R.
    61.150(b),
    and
    therefore
    Section
    9.1(d)
    of the Act,
    415
    ILCS
    5/9.1(d)
    (2006).
    C.
    Non-Admission
    of
    Violations
    The Respondents
    represent
    that
    they have
    entered
    into this Stipulation
    for
    the purpose
    of
    settling
    and
    compromising
    disputed claims
    without
    having
    to incur the
    expense of
    contested
    litigation.
    By
    entering
    into this
    Stipulation
    and
    complying
    with
    its terms,
    the
    Respondents
    do
    not
    affirmatively
    admit
    the
    allegations
    of
    violation within
    the Complaint
    and
    referenced
    within
    Section
    I.B herein,
    and
    this Stipulation
    shall not be
    interpreted
    as including
    such admission.
    D.
    Compliance
    Activities
    to Date
    On
    March
    8,
    2007, the
    Respondents
    paid
    the
    required
    fees
    for
    asbestos demolition
    or
    renovation
    to the
    Illinois
    EPA.
    On
    March
    12,
    2007,
    the
    Respondents
    submitted
    an asbestos
    survey
    report to
    the
    Illinois
    EPA.
    5

    On
    March
    27,
    2007,
    the
    Respondents
    submitted
    an asbestos remediation
    design
    plan
    to
    the
    Illinois EPA. The
    design plan
    was accepted by
    the Illinois EPA
    on
    April 24,
    2007.
    On
    June 18,
    2007, the Respondents
    began
    asbestos remediation
    activities at
    the
    Buck’s
    Building.
    On July
    24, 2007,
    remediation of RACM
    and asbestos
    contamination
    at the
    Buck’s
    Building that
    is the
    subject of the complaint
    was completed.
    On July 31,
    2007, the Respondents
    submitted
    final test data to
    the Illinois EPA
    documenting
    remediation
    of
    all
    asbestos contamination
    consistent with the
    design
    plan
    requirements,
    which
    was accepted by the
    Illinois EPA.
    II. APPLICABILITY
    This Stipulation shall
    apply
    to
    and
    be
    binding
    upon the Parties
    to the Stipulation, and
    any
    agent or employee
    of the Respondents,
    as
    well
    as any
    successors
    or
    assigns
    of the
    Respondents.
    The
    Respondents shall
    not raise as a defense
    to any
    enforcement
    action
    taken
    pursuant to this
    Stipulation
    the
    failure of any of
    its agents, employees
    or successors or
    assigns
    to
    take
    such
    action
    as
    shall
    be
    required
    to
    comply with the
    provisions of
    this
    Stipulation.
    This
    Stipulation
    may
    be
    used
    against
    the
    Respondents
    in any
    subsequent
    enforcement action or
    permit
    proceeding as
    proof of a past
    adjudication
    of
    violation
    of the Act
    and
    the Board Regulations
    for all violations
    alleged in the
    Complaint in this
    matter, for
    purposes
    of Sections
    39
    and 42 of
    the Act, 415 ILCS
    5/39
    and
    42
    (2006).
    III.
    IMPACT
    ON
    THE PUBLIC
    RESULTING
    FROM ALLEGED
    NON-COMPLIANCE
    Section 33(c)
    of the
    Act, 415
    ILCS
    5/33(c)(2006),
    provides as
    follows:
    In
    making
    its orders and
    determinations, the
    Board shall take
    into consideration
    all
    the facts and
    circumstances bearing
    upon the reasonableness
    of the emissions,
    discharges,
    or deposits
    involved
    including, but not
    limited
    to:
    1.
    the
    character and degree
    of injury
    to, or
    interference
    with
    the
    protection
    of the
    6

    health, general
    welfare
    and
    physical
    property
    of the people;
    2.
    the social and economic
    value
    of
    the
    pollution source;
    3.
    the suitability
    or unsuitability
    of the
    pollution
    source
    to
    the area
    in
    which
    it is
    located, including the
    question of priority
    of location
    in the area involved;
    4.
    the technical
    practicability
    and economic
    reasonableness
    of
    reducing or
    eliminating
    the emissions,
    discharges or
    deposits resulting
    from such
    pollution
    source; and
    5.
    any subsequent
    compliance.
    In response
    to
    these
    factors, the Parties
    to the
    Stipulation
    state the
    following:
    1.
    Human health
    and the environment were
    threatened
    and the
    Illinois
    EPAs’
    information
    gathering responsibilities
    hindered
    by the
    Respondents’
    violations.
    2.
    There is
    social
    and economic benefit
    to the
    facility.
    3.
    Operation
    of the
    facility was suitable
    for the area
    in
    which it occurred.
    4.
    Obtaining
    a permit
    prior
    to
    construction
    at the
    site and
    compliance
    with its terms
    is both
    technically
    practicable and
    economically
    reasonable.
    5.
    Respondents
    have completed
    the
    remediation of all
    regulated
    asbestos-containing
    waste
    material
    and asbestos
    contamination
    resulting
    from
    the
    improper
    asbestos
    removal
    activities that are
    the subject
    of the
    complaint.
    IV.
    CONSIDERATION
    OF
    SECTION
    42(h)
    FACTORS
    Section 42(h)
    of the Act,
    415
    ILCS
    5/42(h)(2006),
    provides
    as
    follows:
    In
    determining the
    appropriate
    civil penalty to
    be
    imposed
    under. .
    . this
    Section,
    the
    Board is
    authorized
    to
    consider any
    matters of
    record in
    mitigation
    or
    aggravation
    of
    penalty,
    including
    but not
    limited to the
    following factors:
    1.
    the
    duration
    and
    gravity
    of the
    violation;
    2.
    the
    presence or
    absence
    of
    due
    diligence
    on
    the part
    of
    the
    respondent
    in
    attempting
    to comply
    with
    requirements
    of this Act
    and
    regulations
    thereunder
    or to
    secure relief therefrom
    as
    provided by this
    Act;
    7

    3.
    any economic benefits
    accrued
    by the respondent
    because of delay in
    compliance with
    requirements, in which
    case the economic benefits
    shall
    be determined
    by the lowest
    cost alternative for achieving compliance;
    4.
    the amount
    of monetary
    penalty which will serve
    to
    deter further
    violations
    by
    the respondent and
    to otherwise aid in enhancing voluntary
    compliance
    with
    this Act by the respondent and
    other persons similarly subject
    to the
    Act;
    5.
    the number, proximity
    in time, and gravity
    of
    previously
    adjudicated
    violations
    of this Act by
    the
    respondent;
    6.
    whether the respondent
    voluntarily self-disclosed, in accordance with
    subsection i
    of this
    Section, the non-compliance
    to
    the Agency; and
    7.
    whether the respondent has
    agreed
    to undertake a
    “supplemental
    environmental
    project,”
    which means an
    environmentally beneficial
    project that
    a respondent agrees to undertake in settlement
    of
    an
    enforcement
    action brought under this Act, but which the respondent is not
    otherwise
    legally required to perform.
    In response to these factors, the
    Parties
    to the Stipulation state as
    follows:
    1.
    From a date better known by the Respondents, through at least
    January
    12, 2007,
    the Respondents
    failed to conduct asbestos removal activities in
    compliance with asbestos
    NESHAP notification,
    emission control and disposal
    requirements.
    The
    violations began on or
    around January 4,
    2007, and were resolved at
    various times during that same year.
    2.
    Once the
    Respondents were notified by the
    Illinois
    EPA of
    their non-compliance
    with
    the Act,
    Board regulations and applicable
    federal regulations, they demonstrated due
    diligence in attempting
    to comply with the Act,
    Board regulations, and the NESHAP for
    asbestos.
    3.
    The
    Complainant alleges
    the Respondents realized an economic benefit of non
    compliance
    by
    delaying and/or
    avoiding
    costs necessary to
    properly conduct asbestos
    removal
    8

    and
    disposal
    activities in compliance
    with
    the
    Act,
    Board
    regulations,
    and
    the
    NESHAP for
    asbestos.
    4.
    Complainant
    has
    determined,
    based
    upon
    the
    specific
    facts
    of
    this
    matter,
    that
    a
    penalty
    of
    Seventy
    Thousand
    Dollars
    ($70,000.00)
    will
    serve
    to
    deter
    further
    violations by
    the
    Respondents
    and
    aid
    in
    enhancing
    voluntary
    compliance
    by
    the
    Respondents
    and
    other
    persons
    similarly subject
    to
    the
    Act,
    Board
    regulations,
    and
    the NESHAP
    for
    asbestos.
    5.
    To
    Complainant’s
    knowledge,
    Respondent
    has
    no
    previously adjudicated
    violations
    of
    the
    Act,
    Board
    regulations,
    or the
    NESHAP
    for
    asbestos.
    6.
    Self-disclosure
    is
    not at
    issue
    in
    this
    matter.
    7.
    The
    settlement of
    this
    matter does
    not
    include
    a supplemental
    environmental
    project.
    V.
    TERMS
    OF
    SETTLEMENT
    A.
    Penalty
    Payment
    I.
    The
    Respondents
    shall
    pay
    a
    civil
    penalty
    in the
    sum
    of
    Seventy
    Thousand
    Dollars
    ($70,000.00).
    The
    Respondents
    shall
    make
    three
    payments
    according to
    the
    following payment
    schedule:
    Payment
    Number
    1:
    $30,000.00
    within
    thirty
    (30)
    days
    of
    Board
    approval.
    Payment
    Number
    2:
    $20,000.00
    within
    ninety
    (90)
    days
    of
    Board
    approval.
    Payment
    Number
    3:
    $20,000.00
    within
    one
    hundred
    and
    twenty
    (120)
    days
    of
    Board
    approval.
    B.
    Interest
    and
    Default
    1.
    If
    the
    Respondents
    fail
    to make
    any
    payment
    required
    by
    this
    Stipulation
    on or
    9

    before the date upon which
    the payment
    is
    due, the Respondents shall be in default and the
    remaining unpaid balance
    of the penalty, plus any accrued interest, shall be due and owing
    immediately. In the event of default, the Complainant shall be entitled
    to
    reasonable
    costs
    of
    collection, including reasonable attorney’s fees.
    2.
    Pursuant to Section 42(g) of the Act,
    interest
    shall accrue on any penalty amount
    owed by
    the Respondents not paid within the time prescribed herein. Interest on unpaid
    penalties
    shall begin to accrue
    from
    the date such
    are
    due and
    continue
    to accrue to the date full payment is
    received. Where
    partial payment is made on any penalty amount that is due, such partial
    payment shall be first
    applied
    to
    any interest
    on
    unpaid penalties then owing.
    C.
    Payment Procedures
    All
    payments required
    by
    this Stipulation shall be made by
    certified check or money order
    payable to the
    Illinois EPA
    for deposit into the Environmental
    Protection
    Trust Fund (“EPTF”).
    Payments
    shall be
    sent
    by
    first class
    mail
    and delivered to:
    Illinois Environmental
    Protection
    Agency
    Fiscal
    Services
    1021 North Grand
    Avenue East
    P.O. Box 19276
    Springfield,
    IL 62794-9276
    The name,
    case number
    and the
    Respondents’ federal tax identification number
    shall
    appear on the face
    of the certified
    check or
    money order. A copy of the certified check or
    money
    order
    and
    any
    transmittal
    letter shall
    be
    sent to:
    Environmental Bureau
    Illinois Attorney
    General’s Office
    500 South Second
    Street
    Springfield,
    Illinois 62706
    10

    ft
    Future Compliance
    1.
    The
    Respondents shall
    ensure that
    the facility is at all
    times compliant with
    the
    NESHAP
    regulations.
    2.
    This Stipulation in
    no way affects the responsibilities
    of the Respondents
    to
    comply
    with any
    other federal,
    state
    or
    local laws
    or
    regulations,
    including
    but
    not
    limited
    to the
    Act,
    Board
    regulations and the
    NESHAP for asbestos.
    3.
    The
    Respondents
    shall
    cease
    and
    desist
    from future violations
    of the Act, Board
    regulations,
    and the NESHAP
    for asbestos that
    were the subject
    matter of the Complaint.
    E.
    Release
    from
    Liability
    In
    consideration
    of the Respondents’
    payment of
    the
    $70,000.00
    penalty, their
    commitment
    to cease
    and desist
    as
    contained
    in Section V.D.
    above,
    completion
    of all activities
    required
    hereunder, and upon
    the Board’s approval
    of this Stipulation,
    the Complainant
    releases,
    waives and discharges
    the
    Respondents from any
    further
    liability
    or penalties for
    the violations of
    the
    Act,
    Board
    regulations, and
    the
    NESHAP for asbestos
    that were
    the subject matter
    of the
    Complaint herein. The
    release set
    forth above does
    not extend to
    any
    matters
    other
    than
    those
    expressly
    specified
    in
    Complainant’s
    Complaint
    filed
    on October
    22, 2008. The Complainant
    reserves,
    and this
    Stipulation
    is without
    prejudice
    to, all
    rights of the
    State
    of
    Illinois against
    the
    Respondents
    with
    respect
    to
    all other
    matters,
    including but
    not
    limited to,
    the following:
    a.
    criminal
    liability;
    b.
    liability
    for future violation
    of state,
    federal,
    local, and
    common
    laws
    and/or
    regulations;
    c.
    liability for
    natural
    resources
    damage
    arising out
    of the alleged violations;
    and
    11

    d.
    liability or
    claims based on the
    Respondents’ failure
    to satisfy the
    requirements
    of this Stipulation.
    Nothing in this
    Stipulation is intended as
    a
    waiver, discharge, release, or covenant not
    to
    sue
    for any claim or
    cause of action,
    administrative
    or
    judicial, civil or criminal, past or future,
    in
    law
    or
    in equity, which the State of Illinois may have
    against
    any person, as
    defined
    by
    Section
    3.315 of the Act,
    415 ILCS
    5/3.3 15,
    or entity other than the Respondents.
    F.
    Enforcement and Modification of
    Stipulation
    Upon the
    entry of the
    Board’s
    Order approving
    and accepting this Stipulation, that Order
    is
    a
    binding and
    enforceable order of the Board and may
    be enforced as
    such through any and all
    available means.
    C.
    Execution
    of Stipulation
    The
    undersigned
    representatives
    for
    the Parties to the
    Stipulation certify
    that they are fully
    authorized
    by
    the
    party whom
    they represent to
    enter into
    the terms and
    conditions of this
    Stipulation
    and to
    legally bind them to
    it.
    12

    WHEREFORE, the Parties
    to the
    Stipulation
    request
    that
    the
    Board
    adopt
    and accept
    the
    foregoing
    Stipulation
    and
    Proposal
    for Settlement
    as
    written.
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS,
    THE
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    LISA
    MADIGAN
    Attorney
    General
    State of
    Illinois
    DOUGLAS
    P.
    SCOTT,
    Director
    Illinois
    Environmental
    Protection
    Agency
    MATTHEW J.
    DUNN,
    Chief
    Environmental
    Enforcement!
    Asbestos
    Litigation
    Division
    BY:
    BY:
    THOMAS
    DAVIS,
    Chief
    J€FfN
    J.
    IIM
    Environmental
    Bureau
    Chief
    Legal
    Counsel
    Assistant
    Attorney
    General
    DATE:___________
    DATE:
    BY:
    DATE:
    BY:_____
    KAY
    sJG
    (3
    DATE:
    II1O
    BY:
    ISAAC
    KINd
    DATE:
    13

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