BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF THE
STATE OF ILLINOIS,
)
)
Complainant,
)
)
vs.
)
PCB No.10-9
)
(Cost Recovery)
WASTE
HAULING
LANDFILL,
INC.,
et al.,
)
Respondents.
)
L
‘62009
NOTICE
OF FILING
SThTE
To:
ARAMARK
UNIFORM
SERVICES,
INC.
rc
C
T Corporation System
208 South
LaSaile St., Suite
314
Chicago, IL 60604
BELL SPORTS,
INC.
do John E. Collins
Husch
Blackwell Sanders,
LLP
190 Carondelet
Plaza, Suite
600
St. Louis, MO 63105
A. E. STALEY
MANUFACTURING
CO.
do
Jeryl Olson,
James
Curtis
and Elizabeth
Leifel Ash
Seyfarth
Shaw
131 South
Dearborn St., Suite 2400
Chicago, IL 60603
BORDEN CHEMICAL
CO.
do
Matthew Larson
Shook Hardy
&
Bacon
2555 Grand Boulevard
Kansas
City, MO 64108
ARCHER
DANIELS MIDLAND,
INC.
do C T Corporation
System
208 South LaSalle St.,
Suite 814
Chicago,
IL 60604
CATERPIILLAR,
INC.
do
Kevin Desharnais
and Jennifer
Simon
Mayer
Brown LLP
71 South
Wacker Drive
Chicago,
IL 60606-4637
CLIMATE
CONTROL, INC.
do
Edward
Q.
Costa
Samuels,
Miller, Schroeder, Jackson
&
Sly
1
P.O. BOX 1400
225
N.
Water Street,
Suite 301
Decatur, IL 62525-1400
COMBE LABORATORIES,
INC.
do Theresa
Duckett
Locke, Lord
Bissell
& Liddell
111 5.
Wacker Drive
Chicago,
IL
60606
P
&
H MANUFACTURING,
INC.
c/o
Edward
Dwyer
Hodge Dwyer
&
Driver
3150 Roland Avenue
P.O. Box
5776
Springfield, IL
62705-5776
TRIPLE
S
REFINING
CORPORATION
do C T
Corporation
System
208 South
LaSalle
St.,
Suite
814
Chicago,
IL 60604
GENERAL ELECTRIC
RAILCAR
SERVICES
CORPORATION
c/o Illinois
Corporation
System
801 Adlai Stevenson
Drive
Springfield,
IL
62703
TRINITY RAIL
GROUP, INC.
do C T Corporation
System
208
South LaSalle
St.,
Suite 814
Chicago,
IL 60604
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
TO
AMEND COMPLAINT
and FIRST AMENDED
COMPLAINT,
a
copy of
which is attached hereto
and herewith served
upon you.
Respectfully submitted,
PEOPLE
OF THE
STATE
OF
ILLINOIS
LISA MADIGAN,
Attorney General
of the
State
of Illinois
MATTHEW
J, DUNN,
Chief
Environmental
Enforcement/Asbestos
Litigation Division
BY:
500
South Second
Street
Springfield,
Illinois
62706
217/782-9031
Dated:
September
14, 2009
JAMES L. MORGAN
Sr.
Assistant Attorney General
Environmental
Bureau
2
CERTIFICATE
OF
SERVICE
I hereby
certify
that
I
did
on the
14uI
day
of September,
2009,
send
by
First
Class Mail,
with
postage
thereon
fully prepaid,
a true and
correct
copy
of the instruments
entitled
Notice
of
Filing,
Motion
to
Amend
Complaint
and
First
Amended
Complaint
TO:
ARAMARK
UNIFORM
SERVICES,
INC.
C T Corporation
System
E
208
South
LaSalle
St., Suite
814
Chicago,
IL 60604
ST
1
qy.
2
0iItio,.,
C
0
JNOIs
BELL
SPORTS,
INC.
c/o
John
E.
Collins
Husch
Blackwell
Sanders,
LLP
190 Carondelet
Plaza,
Suite
600
St.
Louis,
MO
63105
A.
E.
STALEY
MANUFACTURING
CO.
do Jeryl
Olson,
James
Curtis
and
Elizabeth
Leifel
Ash
Seyfarth
Shaw
131
South
Dearborn
St., Suite
2400
Chicago,
IL 60603
BORDEN
CHEMICAL
CO.
do
Matthew
Larson
Shook
Hardy
& Bacon
2555 Grand
Boulevard
Kansas
City,
MO
64108
ARCHER
DANIELS
MIDLAND,
INC.
do C T
Corporation
System
208
South
LaSalle
St.,
Suite
814
Chicago,
IL 60604
CATERPI
ILLAR,
INC.
do
Kevin
Desharnais
and Jennifer
Simon
Mayer
Brown
LLP
71 South
Wacker
Drive
Chicago,
IL
606064637
CLIMATE
CONTROL,
INC.
do
Edward
Q.
Costa
Samuels,
Miller,
Schroeder,
Jackson
&
Sly
P.O.
BOX
1400
225 N.
Water
Street,
Suite
301
Decatur,
IL
62525-1400
3
COMBE
LABORATORIES,
INC.
do Theresa
Duckett
Locke, Lord Bissell
& Liddell
111
S.
Wacker Drive
Chicago, IL 60606
P
& H MANUFACTURING,
INC.
c/o Edward Dwyer
Hodge
Dwyer
& Driver
3 150
Roland Avenue
P.O. Box 5776
Springfield,
IL
62705-5776
TRIPLE
S
REFINING CORPORATION
do C T Corporation
System
208 South
LaSalle St., Suite
814
Chicago, IL 60604
Carol
Webb,
Esq.
Hearing Officer
IPCB
1021 North
Grand Avenue
East
P.O. Box 19274
Springfield,
IL 62794-9274
Service
is currently
unavailable
for:
WASTE HAUL[NG
LANDFILL,
INC.
JERRY CAMFIELD, SR.
BRIDGESTONE
FIRESTONE, INC.
ZEXEL ILLINOIS,
INC
and the
original
and ten copies were sent
to:
John
T
Therriault
Illinois Pollution
Control
Board
James
R. Thompson
Center
100
W.
Randolph, Suite
11-500
Chicago,
IL
60601
GENERAL
ELECTRIC RAILCAR
SERVICES
CORPORATION
do
Illinois
Corporation
System
801 Adlai
Stevenson Drive
Springfield,
IL 62703
TRINITY
RAIL
GROUP,
INC.
do
C T Corporation
System
208 South
LaSalle
St.,
Suite 814
Chicago,
IL 60604
/
James
L.Mor
4
Assistant
Attorney
General
Environmental
Bureau/Springfield
500
South
Second Street
Springfield,
IL 62706
4
BEFORE
THE ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE STATE
OF ILLINOIS,
)
)
Complainant,
)
)
vs.
)
PCB No.10-9
)
(Cost
Recovery)
WASTE
HAULING
LANDFILL,
INC.,
JERRY
)
CO.,
CAMFIELD,
ARCHER
A.
DANIELS
E. STALEYMIDLAND,
MANUFACTURING
INC.,
)
)
CLER
c
oppjc
v
ARAMARK
UNIFORM
SERVICES,
INC.,
BELL
)
SPORTS,
INC.,
BORDEN
CHEMICAL
CO.,
)
r
16
2009
BRIDGESTONEIFIRESTONE,
INC.,
CLIMATE
)
STATE
OF
ILIJNOI
CONTROL,
!NC,
CATERPILLAR,
INC,
COMUF
)
POl1tj
Control
Boa%
LABORATORIES,
INC., GENERAL
ELECTRIC
)
RAILCAR
SERVICES
CORPORATION,
P
&
H
)
MAMJFACTURING,
INC.,
TRINITY
RAIL
)
GROUP,
INC.,
TRIPLE
S REFINING
)
CORPORATION,
and ZEXEL
ILLINOIS,
INC.,
)
Respondents.
MOTION
TO
AMEND
COMPLAINT
The
Complainant,
People
of the
State
of
Illinois,
by
Lisa
Madigan,
Attorney
General of
the State of
Illinois,
asks
the
Pollution
Control
Board
of the State
of Illinois,
for leave to
amend the
Complaint
and, in
support
thereof,
states as
follows:
1.
Since
the filing
of the
Complaint,
Petitioner
has learned
there
was
a typographic
error
in
paragraph 23
of the
Complaint.
2.
Paragraph
23
originally
alleged
that:
23.
Respondents
are
each a
responsible
party
as
described
in Section
22.2(0(1)-
(2)
of
the
Act, 41
5
ILCS
4/22
.2(f)( I
)-(2).
Respondents
are each
liable
for
past,
present, and
future removal
costs,
as
defined
by
the
Act,
incurred
by
the
State
resulting
or
arising
out of the
releases
and
threatened
releases
at
the
Landfill.
3.
A
reference to
subparagraph
(3) of
Section
22.2(f)
of the
Environmental
Protection
Act
was
inadvertently
omitted.
That
subparagraph
imposes
liability
for response
and
removal
costs
upon
any
person
who by
contract,
agreement,
or
otherwise
arranged
for disposal
or treatment,
or arranged
with
a
transporter
for
transport for
disposal or
treatment,
of such
hazardous
substances
owned
or
possessed
by
such
person,
by any
other party
or entity,
at any facility,
*
*
*,
owned or
operated
by
another
party
or entity and
containing
such hazardous
substances,
*
*
*
1
That subparagraph
was
included
in
the excerpt
of
Section 22.2(f)
quoted in
paragraph
20
of
the Complaint.
Paragraph 23
should have provided
that:
23.
Respondents
are each
a
responsible
party
as
described
in Section 22.2(f)(1)-(3)
of
the Act, 41
5 ILCS
4/22.2(f)(1
)-(3).
Respondents
are each liable
for
past,
present,
and future
removal
costs,
as defined by the
Act,
incurred
by the State
resulting
or
arising
out
of the releases
and
threatened releases at
the
Landfill.
$
4.
Forfurther
clarification, paragraph
23
will now provide
that:
23.
Respondents
are each
a
responsible
party as described
in Section
22.2(0(1),
(2),
or
(3)
of the Act,
415
ILCS
4122.2(f)( 1), (2),
or
(3).
Respondents
are each
liable
for
past,
present, and
future
removal
costs, as defined by the
Act,
incurred
by the State resulting
or arising
out of the
jeleases and tiiicateiieu
ielees
at ii
Laiiai.
WHEREFORE,
Complainant prays
that
its
motion
be granted.
Respectfully
submitted,
PEOPLE
OF THE
STATE
OF ILLINOIS
LISA
MADIGAN,
Attorney General
of the
State
of
Illinois
MATTHEW
J.
DUNN, Chief
Environmental
Enforcement/Asbestos
Litigation
Division
BY:
7
JAMES L. MORJ4
Sr. Assistant
Attorney
General
Environmental Bureau
500 South
Second
Street
Springfield,
Illinois 62706
217/782-9031
Dated:
September
14, 2009
2
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
MACON
COUNTY,
ILLINOIS
PEOPLE
OF THE
STATE
OF
ILLINOIS,
)
)
Complainant,
)
v.
)
PCB NO.
10-9
WASTE
HAULING
LANDFILL,
INC.,
JERRY
)
(Cost
Recovery)
CAMFIELD,
A. E. STALEY
MANUFACTURING
)
CO.,
ARCHER
DANIELS
MIDLAND,
INC.,
)
ARAMARK
UNIFORM
SERVICES,
INC.,
BELL
)
SPORTS,
INC.,
BORDEN
CHEMICAL,
CO.,
)
ICE
BRIDGESTONE/FIRESTONE,
INC.,
CLIMATE
)
SEP
6
2009
CONTROL,
INC.,
CATERPILLAR
INC.,
COMBE
)
LABORATOIUES4NC,
GENERAL
ELECTRIC
)
OF
ILLINOIS
RAILCAR
SERVICES
CORPORATION,P
&
H
)
Ion
Control
8
oarcJ
MANUFACTURING,
INC.,
TRINITY
RAIL
GROUP,
)
INC.,
TRIPLE
S
REFINING
CORPORATION,
and
)
ZEXEL
ILLINOIS,
INC.,
)
)
Respondents.
)
FIRST
AMENDED
COMPLAINT
Complainant,
PEOPLE
OF THE
STATE
OF
ILLINOIS,
by
LISA
MADIGAN,
Attorney
General
of the
State
of Illinois,
complains
of Respondents,
WASTE
HAULING
lANDFILL,
INC.,
JERRY
CAMFIELD,
AE
STALEY
MANUFACTURING CO.,
ARCHER
DANIELS
MIDLAND,
INC.,
ARAMARK
U1’4IFORM
SERVICES,
INC.,
BELL
SPORTS,
INC.,
BORDEN
CHEMICAL,
CO.,
BRIDGESTONE/FIRESTONE,
INC.,
CLIMATE
CONTROL,
INC.,
CATERPILLAR
INC.,
COMBE
LABORATORIES,
INC.,
GENERAL
ELECTRIC
RAILCAR
SERVICES
CORPORATION,
P
&
H
MANUFACTURING,
INC.,
TRIPLE
S
REFINING
CORPORATION,
TRINITY
RAIL
GROUP,
INC.,
and
ZEXEL
ILLINOIS,
INC.
as follows:
COUNT
I: COST
RECOVERY
1.
This
Complaint
is
brought
by
the Attorney
General
on her
own
motion
and
at
the request
of
the
Illinois
Environmental
Protection
Agency
(“Illinois
EPA”),
pursuant
to
the
terms
and
provisions
of
1
Title
VIII
(Sections
30-34)
of
the
Illinois
Environmental
Protection
Act (“Act”),
415
ILCS
5/30-34
(2008).
2.
The
Illinois
EPA
is
an
agency
of
the State
of Illinois
created
by
the
Illinois
General
Assembly
in Section
4
of
the Act,
415
ILCS
5/4 (2008),
and charged,
inter
alia,
with
the
duty
of
enforcing
the
Act
in proceedings
before
the
Illinois
Pollution
Control
Board
(‘Board
t
).
3.
This
Complaint
is
brought
pursuant
to
Section
22.2(f)-(k)
of
the
Act,
415
ILCS
5/22.2(0-
(k) (2008).
1.
Pes”ornirf.
Waste
Ha’1in
I
atidf’lL
Joe..
is
cnrnoration
formerly
authori7ed
to
do
business
in
the
State
of Illinois
and
is a
person
as
defined
in
Section
3.315
of
the Act,
415
ILCS
5/3.315
(2008).
Waste
Hauling
Landfill,
Inc.,
operated
the
Waste
Hauling
Landfill
(the
“Landfill”), a former
sanitary
landfill
located
in the
Northwest
Quarter
of
the Northwest
Quarter
of Section
26, Township 16
North,
Range
1
East
(Blue
Mound
Township),
Macon
County,
Illinois.
5.
Respondent,
Jerry
Camfield,
is
an
individual
and
is a
person
as defined
in
Section
3.3
15
of the
Act,
415
ILCS
5/3.3
15
(2008).
Jerry
Camfield
owned
Waste
Hauling
Landfill,
Inc.,
and
personally
directed
its operations.
6.
Respondent,
A.
E.
Staley
Manufacturing
Co.,
is a
corporation
authorized
to
do
business
in
the
State
of
Illinois
and
is
a
person
as
defined
in
Section
3.315
of
the Act,
415
ILCS
5/3.315
(2008).
A.
E.
Staley
Manufacturing
Co.,
sent wastes
to
the Landfill
during
its operating
life
and
those
wastes
contained
hazardous
substances.
7.
Respondent,
Aramark
Uniform
Services,
Inc.,
is a
corporation no
longer
authorized
to
do
business
in the
State
of Illinois
and
is a
person
as defined
in Section
3.315
of the
Act,
415 ILCS
5/3.315
(2008).
Aramark
Uniform
Services
is
a
successor
to
Means
Uniform
Services,
Means
Uniform
Services
sent
wastes
to
the
Landfill
during
its operating
life and
those
wastes
contained
hazardous
substances.
2
8.
Respondent,
Archer
Daniels
Midland,
Inc.,
is
a
corporation
authorized
to
do business
in
the State
of Illinois
and is a
person
as
defined
in
Section
3.315
of
the
Act, 415
ILCS
5/3.3
15 (2008).
Archer
Daniels
Midland,
Inc.,
sent
wastes
to the
Landfill
during
its operating
life
and those
wastes
contained
hazardous
substances.
9.
Respondent,
Bell
Sports,
Inc.,
is
a
corporation
authorized
to
do
business
in the
State
of
Illinois
and
is
a
person
as
defined
in Section
3.3
15
of the Act,
415
ILCS
5/3.3
15
(2008).
Bell Sports,
Inc.,
sent wastes
to
the Landfill
during
its
operating
life and
those
wastes
contained
hazardous
substances.
10.
Respondent,
Borden
Chemical
Co.,
is
a
corporation
authorized
to do
business
in
the
State
of
Illinois
and is
a
person
as defined
in
Section
3.315 of
the
Act, 415
ILCS
5/3.315
(2008).
Borden
Chemical
Co.,
sent
wastes
to the
Landfill
during
its operating
life
and
those
wastes
contained
hazardous
substances.
11.
Respondent,
Caterpillar
Inc.,
is
a
corporation
authorized
to do business
in
the
State
of
Illinois
and
is a person
as
defined
in Section
3.315
of the
Act,
415
ILCS 5/3.315
(2008).
Caterpillar
Inc.
sent
wastes to
the
Landfill
during
its
operating
life
and
those
wastes
contained
hazardous
substances.
12.
Respondent,
Climate
Control,
Inc.,
is
a
corporation
authorized
to do business
in the State
of Illinois
and
is
a
person
as
defined
in
Section
3.3 15
of the
Act,
415 ILCS
5/3.3
15
(2008).
Climate
Control,
Inc.,
sent
wastes
to the
Landfill
during
its
operating
life
and those
wastes
contained
hazardous
substances.
13.
Respondent,
Combe
Laboratories,
Inc.,
is a
corporation
authorized
to
do
business
in the
State
of
Illinois
and is
a
person
as defined
in Section
3.315
of the
Act,
415
TLCS
5/3.315
(2008).
Combe
Laboratories,
Inc.,
sent
wastes
to
the
Landfill
during
its
operating
life
and
those
wastes
contained
hazardous
substances.
3
14.
Respondent,
Bridgestone/Firestone
Inc., is a corporation
authorized
to do
business
in the
State of Illinois
and
is
a
person
as
defined in Section
3,315 of the Act,
415 ILCS
5/3.315
(2008).
Bridgestone/Firestone
Inc., is a successor
to
Firestone
Tire
&
Rubber
Company. Firestone
Tire
&
Rubber
Company,
sent wastes to
the Landfill during
its operating
life and those wastes
contained hazardous
substances.
15.
Respondent, General
Electric
Railcar
Services Corporation,
is a
corporation
authorized
to do
business in the State of
Illinois and
is
a
person
as
defined in
Section 3.3
15
of the Act, 415 ILCS
5/3.3 15
(2008.
General
Electric.
Railcar Seryices
CorDoration.acquired
thern Noh
American
Car
Corporation. The
North American Car
Corporation
sent wastes to the
Landfill during its
operating
life
and those
wastes
contained
hazardous substances.
16.
Respondent,
Triple S Refining
Corporation,
is
a
corporation
authorized to do business
in
the State of
Illinois
and is a person as
defined in
Section
3.3
15 of
the Act,
415 ILCS
5/3.3 15 (2008).
Triple
S
Refining Corporation
is a
successor to
Kerr-McGee Refining
Corporation.
Kerr-McGee
Refining
Corporation
sent
wastes to
the
Landfill
during
its operating
life and those wastes
contained
hazardous
substances.
17.
Respondent,
P
&
H
Manufacturing,
Inc., is a
corporation authorized
to do
business
in the
State
of Illinois
and is a person as
defined in Section
3.315 of the
Act, 415
ILCS
5/3.315 (2008).
P
&
H
Manufacturing,
Inc.,
sent
wastes
to
the
Landfill
during its operating
life and those wastes
contained
hazardous
substances.
18.
Respondent,
Trinity
Rail Group, Inc., is
a
corporation
authorized
to do
business in the
State
of
Illinois
and is a
person as defined
in Section 3.315 of
the Act, 415
ILCS 5/3.315
(2008). Trinity
Rail
Group,
Inc.,
acquired
Thrall
Car
Manufacturing
Co.,
which had
previously
acquired
the
rail car
division
of
Portec,
Inc. Thrall Car
Manufacturing
Co. and the
rail car division
of Portec, Inc., sent
wastes
to the
Landfill
during
its
operating life
and
those wastes
contained
hazardous
substances.
4
19.
Respondent,
Zexel
Illinois,
Inc.,
is a
corporation
authorized
to do
business
in the
State
of
Illinois
and
is
a
person
as defined
in Section
3.315
of the Act,
415
ILCS
5/3.3
15 (2008).
Zexel
Illinois,
Inc.,
acquired
Borg-Warner
Corp.
Borg-Warner
Corp.
sent
wastes
to
the Landfill
during
its
operating
life
and
those wastes
contained
hazardous
substances.
20.
Section
22.2 of
the Act,
415 ILCS
5/22.2
(2008),
provides
that:
f.
Notwithstanding any
other provision
or rule
of law, and
subject
onJy
to the
defenses
set
forth
in subsection
(j)
of this
Section,
the
following
persons
shall
be
liable
for
all costs
of
removal
orremedial
action
incurrdby
the
State of
Illinois
or
any
unit
of.local
government
as a
result
of
a
release
or
substantial
threat
of
a release
of a
hazardous
substance
or
pesticide:
1.
the owner
and
operator
of
a facility
or
vessel
from
which there
is
a release
or
substantial
threat
of
a release
of
a hazardous
substance
or
pesticide;
2.
any
person
who
at
the time
of disposal,
transport,
storage
or
treatment
of a hazardous
substance
or
pesticide
owned
or operated
the
facility
or vessel
used for
such
disposal,
transport,
treatment
or storage
from
which
there
was
a
release
or
substantial
threat
of
a
release
of
a
hazardous
substance
or
pesticide;
3.
any person
who by
contract,
agreement,
or otherwise
arranged
for disposal
or
treatment,
or
arranged
with
a
transporter
for
transport
for
disposal
or
treatment,
of such
hazardous
substances
owned
or
possessed
by
such
person,
by
any other
party
or entity,
at
any facility,
* *
*,
owned
or operated
by
another
party or
entity
and
containing
such hazardous
substances,
***
21.
The wastes
and
other
materials
disposed
of at
the Landfill
include
hazardous
substances
as
defined
by
3.14 of
the
Act, 415
ILCS
5/3.14
(2008).
22.
The
State
has
incurred
and
will continue
to
incur
removal
costs,
as
defined
by the Act,
associated
with
the
releases
and
threatened
releases
of
hazardous
substances
at the Facility.
23.
Respondents
are
each
a
responsible
party
as
described
in Section
22.2(f)(1),
(2),
or (3)
of
the
Act,
415
ILCS
4/22.2(0(1),
(2),
or
(3).
Respondents
are each
liable
for
past,
present,
and future
removal
costs,
as
defined
by
the Act,
incurred
by the
State
resulting
or
arising
out
of the releases
and
5
threatened releases at the Landfill.
PRAYER FOR RELIEF
WHEREFORE,
Complainant, the PEOPLE OF THE STATE
OF ILLINOIS,
respectfully
request
that the Board enter an order against the Respondents:
A.
Authorizing
a
hearing
in this
matter
at
which time the Respondents will be required
to
answer the allegations herein;
B.
Finding the Respondents, Waste Hauling Landfill,
Inc., Jerry Camfield, A E Staley
Manufacturing Co., Archer Daniels Midland, Inc., Aramark Uniform Services,
Inc.. Bell Sports, Inc.,
Borden
Chemical,
Co., Bridgestone/Firestone
Inc., Climate Control, Inc., Caterpillar
Inc.,
Combe
Laboratories, Inc., General Electric Railcar Services Corporation, P &
H Manufacturing, Inc.,
Triple
S
Refining Corporation, and
Trinity
Rail Group,
Inc.,
to
be liable for past, present,
and future removal
costs, as
defined
by
the Act, incurred by the
Illinois EPA
as a
result of the releases and
threatened
releases
of hazardous substances at the Facility;
C.
Finding Respondents, to be liable
for damages equal to three times
the past, present, and
future
removal costs, as defined by the Act,
incurred
by
the Illinois EPA as a
result of the releases and
threatened
releases of hazardous substances at
the Facility; because of the
Respondents’
refusal
to
perform
the work set forth in the
Section 4(q) notice issued by
Illinois EPA;
D.
Awarding
to
Complainant its
costs; and
6
E.
Granting
such
other
relief
as
the
Board
may deem
appropriate.
Respectfully
submitted,
PEOPLE
OF
THE
STATE
OF
ILLINOIS
LISA
MADIGAN,
Attorney
General
of the
State
of Illinois,
MATTHEW
J.
DUNN,
Chief
Environmental
Enforcement/Asbestos
Litigation
Division
/1
/ii
r’:___________
F
Assistant
James L.
Morgan
Attorney
f
General
Environmental
Bureau
500
South
Second
Street
Springfield,
Illinois
62706
217/524-7506
Dated:
7_’Y—
7