BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
S&D
REALTY,
INC.,
)
V.
Petitioner,
)
)
)
PCB
09-33
)
(UST
Appeal)
ECfED
CLERK’S
OFFICE
NOV
022009
STATE
OF
ILUNOJS
oI1ut
EOfl
Control
Board
John
Therriault
Acting
Clerk
Illinois
Pollution
Control
Board
100
West
Randolph
Street,
Suite
11-500
Chicago,
Illinois
60601-3218
Mike
Abel
Cohen
and
Hussein,
P.C.
6901
West
111
th
Street
Worth,
Illinois
60482
Bradley
P.
Halloran
Hearing
Officer
Illinois
Pollution
Control
Board
100
West
Randolph
Street,
Suite
11-500
Chicago,
Illinois
60601-3218
PLEASE
TAKE
NOTICE
that
I
have
today
caused
to
be
filed
a
MOTION
IN
LIMINE
DIRECTED
TO
THE
HEARING
OFFICER
with
the
Illinois
Pollution
Control
Board, copies
of
which
are
served
upon
you.
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
James
G.
Richardson
Special
Assistant
Attorney
General
Dated:
October
29,
2009
1021
North
Grand
Avenue
East
P.O.Box
19276
Springfield,
Illinois
62794-9276
217/782-5544
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
Respondent.
)
NOTICE
THIS
FILING
IS
SUBMITTED
ON
RECYCLED
PAPER
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
S&D
REALTY,
INC.,
)
CLERK’S
OFp,ED
Petitioner,
)
)
PCB
09-3
3
STATE
OF
Qljçj
)
(UST
Appeal)
POljçJtj
Control
8od
)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
Respondent.
)
)
MOTION
IN
LIMINE
DIRECTED
TO
THE
HEARING
OFFICER
NOW
COMES
the
Respondent,
the
Illinois
Environmental
Protection
Agency
(“Illinois
EPA”),
by
one
of
its
attorneys,
James
G.
Richardson,
Assistant
Counsel
and
Special Assistant
Attorney
General,
and,
pursuant
to
35
Ill.
Adm.
Code
101.500
and
101.502,
hereby respectfully
moves
the
Hearing
Officer
to
enter
an
order
preventing
Eric
D.
Hasman
from
testifying
concerning,
or
the
Petitioner
presenting
any
other
form of
evidence
arising
from
or
related
to,
an
August
27,
2009
report
prepared
by
Hasman
concerning
the
UST
site
that
is
the
subject
of
this
appeal.
In
support
of
this
motion,
the
Illinois
EPA
states
as
follows:
I.
FACTS
AND
LAW
1.
On
September
3,2009,
pursuant
to
illinois
Supreme
Court
Rule
213(f)(3),
Petitioner
disclosed
Eric
D.
Hasman
as
a
retained
expert
in
this
UST
appeal,
advised that
he
“will
be
testifying
about
the
costs
for
the
work
that
was
completed
on
the
remediation
project
for
which
the
property
owner
does
not
have
the
physical
receipts,”
and
provided
a
copy
of
his
August 27,
2009
report
containing
his
1
conclusions,
opinions,
and
their
bases.
(See
Attachment
A).
2.
Item
2 of
the Accounting
Deductions
in
the
Illinois
EPA’s
October
10,
2008
decision
letter
indicates
that
$98,760.00
of
costs
were
deducted
from
Petitioner’s
claim
because
they
lacked
supporting
documentation.
(Note
—
This
number
and
$46,960.00
in
the
second
paragraph
of
Item
2
should
be
$92,221.50
and
$40,421.50,
respectively.
This
was
a
typographical
error
that
only
appeared
in
the
decision
letter.
The
amount
authorized
for
payment
by
the
Illinois
EPA
was
based
upon
the
correct
amounts).
Administrative
Record
(“AR”)
p.
2.
The
costs
that
Hasman
focuses on
are contained
within
this
deduction.
3. Petitioner
has
and
continues
to
acknowledge
that
it
does
not
have
the
necessary
supporting
documentation
for
these
costs.
In
the
June
13,
2008
cover
letter
to
the
reimbursement
package
underlying
this
case,
Hasman
writes that
a
previous
consultant,
Courtesy
Services,
Inc.,
“was
not
able
or
willing
to
provide
complete
invoicing
and
only
the
provided
excel
sheets
which
they
stated
was
their
invoice(s)
for
SD.”
AR
p.12.
In
concluding
his
August
27,
2009
report,
Hasman
states
“It
is
my
opinion,
based
upon
my
experience
and
upon
a
reasonable
degree
of geological
and
engineering
certainty,
that
the
above
mentioned
remediation
was
performed
on
the subject
property
and
that
costs
for
the above work,for
which
the
property
owner
does
not
have
the
physical
receipts,
totals
the
following”
and
references
a
Total
of
$86,694.14.
(Emphasis
added)
(See
Attachment
A).
4. Referencing
Hasman’s
breakdown
of this
$86,694.14, Illinois
EPA
comments
applicable
to
these
items
from
the
review
that
resulted
in
the
October
10,
2008
decision
letter
are as
follows:
$2,400.00
soil
disposal
— Hasman
contends
that
1050
cubic
yards
should
have
been
authorized
for
payment,
totaling
$21,000.00
(1050
x
$20.00
=
$21,000.00).
In
reality,
the
Illinois
EPA
authorized
payment
for
$21,300.00
for
soil
disposal
costs
to
Community
Landfill.
Supporting
documentation
appears
on
pages
45 and
46
of
the Administrative
Record.
However
in
preparing
this
Motion,
it was
discovered
that
the
Illinois
EPA
actually
overpaid
the
Petitioner
for soil
disposal
by
$9,100.00.
During
the
original
review,
the
reviewer
believed
that
the
units
2
referenced
on
pages
45
and
46
were
tons
instead
of
cubic
yards
as
tons
were
the
measurement
used
in
other
parts
of
the
package.
As
the
unit
of
measurement
is
really
cubic
yards,
only
610
cubic
yards
should
have
been
authorized
for
payment
(610
x
$20.00
=
$12,200.00)
since
this
is
the
maximum
amount
of
soil
allowed
for
payment
under
the
regulations
for
the
number
and
size
of
tanks
removed
at
this
site.
$33,004.03
backfill
—
The
Illinois
EPA
authorized
payment
of
$7,400.00
for
the
hauling
of
the
backfill
based
upon
an
invoice
on
pages
47
and
48
of
the
Administrative
Record.
No
additional
payments
were
authorized
since
there
was
no
supporting
documentation
as
to
the
cost
of
the
backfill
itself.
$2,097.00
acquiring permits—Appears
on
a summary
sheet
(AR
p.18)
but
there
is
no
supporting
documentation.
$6,872.80
concrete
removal
—
Appears
on
a
summary
form
(AR
p.22)
but
there
is
no
supporting
documentation.
$32,320.33
concrete
installation
—
Hasman
recalculated
this
figure.
In
the
original
reimbursement
package,
it
was
$34,927.20
on
a summary
form
(AR
p.
22
).
Again,
there
was
no
supporting
documentation.
$10,000.00
paving
and
installation
—
Appears
as
dismantle
& reassemble
gasoline
pumps
and
pipe
lines
on
a
summary
form
(AR
p.22).
No
supporting
documentation.
5.
In reimbursement
appeals,
the
applicant
for
reimbursement
has
the
burden
to
demonstrate
that
costs
are
related
to
corrective
action,
properly
accounted
for,
and
reasonable.
Rezmar
Corporation
v.
Illinois
EPA,
PCB
02-91
(April
17,
2003)
p.
9.
Tn
a
recent
appeal,
the
reimbursement
applicant
suggested
that
the
Part
732,
Subpart
H
rules
on
maximum
payment
amounts
eliminated
the
need
to
account
for
all
costs.
T-Town
Drive
Thru,
Inc.
v.
Illinois
EPA,
PCB
07-85
(April
3,
2008)
pp.
22
-
23
.
The
Pollution
Control
Board
(“Board”)
declined
the
suggestion,
noting
the
requirement
of35
Ill.
Adm.
Code
732.601(b)(9)
that
a
complete
application
for
payment
must
include
“An
accounting
of
all
costs,
including
but
not
limited
to,
invoices,
receipts,
and
supporting
documentation
showing
the
dates
and
descriptions
of
the
work
performed”
and
the
fact
that
the
Illinois
EPA
had
historically
always
requested
such
information.
3
6.
Although
it
is
unfortunate
that
Petitioner
does
not
have
the
needed
supporting
documentation
for these
costs,
it
is
neither
the
first
nor
will
it
be
the
last
applicant
that
finds
itself
in
this
predicament.
The
Illinois
EPA
authorized
the
payment
of
costs
that
had
supporting
documentation.
But
expert
opinions
and
the
calculation
of
estimates
are
not
substitutes
for
supporting
documentation
that
identifies
specific
materials,
services,
quantities
and
costs.
The
Hasman
report
has no
probative
value
for
a
review
of
the
Illinois
EPA’s
October
10,
2008
decision.
7.
Let
alone
the
fact
that
the Hasman
report
does
not
change
the
status
quo,
another
basis
for
the
granting
of this
Motion
is
that
the
Hasman
report
was
not
considered
by the
Illinois
EPA
in
making
its
October
10,
2008
decision.
Like
the need
to account
for
all
costs,
another
historical
principle
concerning
UST
appeals
is
that
the
Board
will
not
consider
new
information
not
before
the
Illinois
EPA
prior
to
its
final
determination
regarding
the
issues
on appeal.
Kathe’
s
Auto
Service
Center
v. Illinois
EPA,
PCB
95-43
(May
18,
1995)
p.
14.
Dated
August
27,
2009,
the
Hasman
report
could
not
have
been
considered
by the
Illinois
EPA
in
making
its October
10, 2008
decision
and
therefore
should
not
be
considered
by
the
Board
in
this
appeal.
CONCLUSION
For
the
reasons
stated
herein,
the
Illinois
EPA
respectfully
requests
that
the
Hearing
Officer
grant
this
Motion
in
Limine
and
enter
an
order
preventing
Eric
D.
Hasman
from
testifying
concerning,
or the
4
Petitioner
presenting
any
other
form
of
evidence
arising
from
or
related
to,
an
August
27,
2009
report
prepared
by
Hasman
concerning
the
UST
site
that
is
the
subject
of
this
appeal.
Respectfully
submitted,
ILLINOIS
ENVONMENTAL
PROTECTION
AGENCY,
Respondent
Special
Assistant
Attorney
General
Dated:
October
29,
2009
5
LAW
OrncEs
OF
COHEN
&
HUSSIEN
A
PRossIoNAL
CoioRATIoN
6901
W.
111th
Street,
Worth,
IL
60482
Phone
708.361.3030
•
Fax
708.361.4207
attorneys
@cohenandhussien
.com
September
3,
2009
James
G.
Richardson
Illinois
Environmental
Protection
Agency
1021
North
Grand
Avenue
East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
RE:
S&D
Realty,
inc.
v.
lilinois
Environmental
Protection
Agency
PCB
09-33
Dear
Mr.
Richardson:
In
accordance
with
Illinois
Supreme
Court
Rule
213(f)(3),
please
be
advised
that
the
Petitioner
is
disclosing
Eric
D.
Hasman
as
a
retained
expert
in
the
above-
referenced
case.
Mr. Hasman
will be
testifying
about
the
costs
for
the work
that
was
completed
on
the
remediation
project
for
which
the
property
owner
does
not
have
the
physical
receipts.
Enclosed,
please
find
a
copy
of
Mr.
Hasman’s
report
for
this case,
which
details
his
conclusions
and
opinions
and
the
bases
therefor.
Also
enclosed,
please
find a
copy
of
Mr.
Hasman’s
resume.
Should
you
have
any questions,
please
feel
free
to
contact
me.
Sincerely,
\\C\:Q
C\.9i\
Michael
Abel
MLA/as
Enclosures:
RECE”
DivSiOfl
01
Legal
Counsel
SEP
0
2O
Environmeflt
ProtectiOfl
Agency
Edward
A.
Cohen
Sana’a
Hussien
Michael
L.
Abel
PARALEGALS
Maisoun
N.
Farhoud
Linda
C.
Moles
CHICAGO
OFFICE
30
N.
LaSalle
Street
Suite
2299
Chicago,
Illinois
60602
Phone
312.658.3406
Fax
312.658.3419
‘
c
ji,.
.
.1—
13
h’
ENRONMENTAL
ENGiNEERING
SERWCES
9914
DERBY
LANE,
WESTCHESTER,
IL.
60154-3768
TELEPHONE
708-345-9450
•
FAX
708-345-9460
August
27,
2009
Cohen
&
Hussien
6901
W.
11
.th
Street
Worth,
IL
60482
Attn.:
Mr.
Michael
Abel
RE:
Reimbursemennt
3935
S.
Archer
Avenue
Chicago,
Hllnois
60632
IEMA
#20041421
&
20050020
Dear Mr.
Abel:
The
following
is
a
summary
of
the
reimbursement
activities
that
were
not
covered
by
the
IEPA.
On
January
7,
2005
the
USTs
removed
and
disabled.
At
this
point
the
concrete
above
the
USTs
was
removed
and
transported
off-site.
In addition,
backfill soil
was
transported
off-site.
I
have
a
few
pictures
of
the
disabled
USTs
and
the
open
UST
excavation
area.
Based
upon
my
experience
it
is
required
for
the
site
to
be
secure when
tank
removal
/
replacement
is
occurring.
“Secure”
means
placing
temporary
fencing
around
the
project
area
to
limit
access.
According
to
the
“bill”
there
was
1
permit
issued
from
the
City
of Chicago
for
the
property for
the
cost
of
$1
,372
(fencing).
According
to
the
“bill”
there
were
2 permits
issued for
the
property
costing
of
$450
(expedite
permits)
and
$275
(expedite
permits).
It
is
my
opinion,
based
upon
my
experience
and
upon
a
reasonable
degree
of
geological
and
engineering
certainty,
these
costs
are
reasonable
for
the
time
required
for
a person
to
go
to the
City
of
Chicago
to
apply
for
the
permit and
the
costs of
the
permits.
On
January 10-11,
2005
contaminated
soils
were
taken
to
Community
Landfill
Corporation
in
Morris, Illinois.
According
to
records
obtained
from
the
landfill,
a
total
of 70
— 15
cubic
yard
(y
3
)
loads ($21000
for
a
total
of 1050
y3
)
from
the
site
were
disposed
at
the
landfill.
However,
only
manifests
for
62
loads
($18,600)
were
able
to
be
obtained
and
billed for
in
the
Early
Action
reimbursement
package.
Since
there
were
8
loads
not
billed
for
but
there
is
a
confirmation
from
the
landfill
that
8
additional
loads
were
accepted
by
the
landfill,
it
is
my
opinion
to
a
reasonable
degree
of
geological
and
engineering
certainty
that
there
should be
an
additional
$2,400
for
the
soil
disposal.
Based
upon
Section
732
Appendix
C
Backfill
Volumes
and
Weights
the
total amount
of
soil
that
is
allowed to
be
removed/excavated
is
610
y3
or
1,025
tons
for
2-8,000
gallon
USTs
and
1-
6,000
gallon
UST
(not
including
the
overburden
area
or
the
piping
excavation).
The
amount
of
soil
for
piping
removal
/
replacement
was
calculated
using
a
minimum
of
100
linear
feet
of
piping
x
3
feet
wide
x
4
feet
deep
which
equals
44.45
y3
or
66.67
tons.
The
total
amount
of
soil
removal
allowed
for
the
piping
and
USTs
is
1,091
.67
tons.
1
S
&
D
Realty
Reimbursement
3935
S.
Archer
Avenue
LUST#
20041421
&
20050020
Chicago,
Illinois
60632
August
27,
2009
There
are
statements
from
KMW
Trucking
located
at
51
10
S.
Laramie,
Chicago
60638,
Jerzy
Rafacz
Trucking
located
at
5110
S.
Laramie,
Chicago
60638
and
J.M.S.
Trucking
Company
of
Illinois
located
at
8532
Thistlewood,
Darien,
Illinois
60561
that
show
they
transported
soil
and/or
fill
material.
The
statements
are
listed
below:
KMW:
transported
25
loads
of
contaminated
soH
($9375),
2
loads
of
concrete
($350)
and
I
load
of
CA-6
stone
($175).
JRT:
transported
12
loads
of
contaminated
soil
($4500)-not
sure
where
these
were
disposed
at,
2
loads
of
contaminated
soil-Morris
($450).
JMS:
transported
37
loads
out
($7400)
—
the
statement
does
not
say
soil
or
concrete.
Howell
Trucking
is
listed
on
manifests
but
there
is
not
a
statement
from
them.
In
my
experience,
the
same
trucking
companies
who
transport
the
soil
/
concrete
often
pickur backfill
stone
on
the
return
trip
from
the
landfill.
Based
upon
the
70
loads
(1050
y3
)
of
soil
disposed
at
the
Landfill,
Laicon
calculated
the
tons
which
is
1050
*
110
(lbs/cubic
feet
-
the
conversion
factor
for clay)
=
1,559
tons
of
soil
was
excavated
(1,091
.67
tons
for
piping/USTs
and
467.33
tons
for
overburden).
Laicon
surmised
that
a
minimum
of
1,559
tons
of
backfill
would
be
needed
to
fill
the
excavation
area
(1050
*
$21.17
=
$33,004.03).
Based
upon
Section
732
Appendix
C
Backfill
Volumes
and
Weights
the
total
amount
of
backfill
that
is
allowed
to
be
removed/excavated
is
1,235
tons
for
2-8,000
gallon
USTs
and
1-6,000
gallon
UST
(not
including
the
overburden
area
or
the
piping
excavation).
Based
upon
the
square
footage
of
the
land
(12,869
sf)
—
minus
the
square
footage
of
the
building
(2,166
sf)
and
landscaping
(1,750
sf)
which
equals
8,953sf
Laicon
calculated
the
amount
of
concrete
to
be
removed
and
disposed
of
8,953
*
1
.306
sf
=
$6,872.80
for
the
concrete.
The
square
footages
were
obtained
from
the
Cook
County
Assessor.
On March
5,
2005
framing
for
the
concrete
to
be
poured
on-site
was
occurring.
The
entire
site
except
where
the
building
stands
had
1”
stone
fill
visible
thus
indicating
that
the
excavation
area
(the
USTs
and
piping)
have
been
filled
in
with
stone.
In
my
experience,
excavations
are
filled
with
3”
stone
to
prevent
LfloatingY
and
topped
off
with
1”
stone
then
either
asphalted/concreted.
In
addition,
no
gasoline
pumps
or
pump
islands
were
on
the
site.
I
mention
this
because
the
pumps
/
islands
had
to
be
disabled/removed
in
order
to
install
new
piping,
pumps
and
islands.
The
concrete
was
poured
a
few
days
later.
I
have
pictures
of
the
site
showing
the
framing
and
pump
island
area.
On
August
23,
2005
monitoring
wells
MW1,
MW2,
MW3
and
MW4
were
installed.
MW1
and
MW3
were
installed
within
the
new
concrete
that
was
replaced
in
March
2005.
The
concrete
was
approximately
4”
thick
in
these
areas.
Based
upon
the
4”
thick
concrete
in
the
areas
of
MW1
and
MW3,
I
assumed
4”
thick
concrete
across
the
site
and
used
the IEPA
July 1,
2007
to
June
30,
2008
pay
rate
for
4”
concrete
of
$3.61
per
square
foot.
If
the
concrete
is
6”
thick
then
the
pay
rate
is
$4.62
per
sf.
Based
upon
the
square
footage
of
the
land
(12,869
sf)
—
minus
the
square
footage
of
the
building
(2,166
sf)
and
landscaping
(1,750
sf)
which
equals
8,953sf
Laicon
calculated
the
amount
of 4”
concrete
used.
8,953
*
3.61
sf
=
$32320.33
for
the
concrete.
This
number
is
different
than
the
amount
submitted
in
the
original
EA
submittal
due
to
recalculating
and
basing
the
multiplier
on
4”
concrete
instead
of
6”
concrete.
2
S
&
D
Realty
Reimbursement
3935
S.
Archer
Avenue
LUST#
20041421
&
20050020
Chicago,
Illinois
60632
August
27,
2009
In
order
for
the
dismantling
of
the
pipe lines
and pumps
to
occur
the
concrete
had
to
be
broken,
removed
and
transported
which
it
was
as
based
upon
the
new
concrete
and
the
pictures.
It
is
my
opinion,
based
upon
my
experience
and
upon
a
reasonable
degree
of
geological
and
engineering
certainty
that
the
above
mentioned
remediation
was
performed
on
the
subject
property
and
that
costs
for
the
above
work,
for
which
the
property
owner
does
not
have
the
physical
receipts,
totals
the
following:
$
2,400
soil
disposal
$
33,004.03
backfill
$
2,097
acquiring
permits
$
6,872.80
concrete
removal
$
32,320.33
concrete
installation
$
10,000
paving
and
installation
$
86,694.14
Total
It
should
be
noted
that for
each
step of
the
tank
removal
and
installation
a
representative
from
the City
of
Chicago
Department
of
Environment
or
the
Fire
Department
is
onsite
to
document
or
inspect
the
removal
or
installation
of
the
USTs
and piping.
If
you have
any
question
regarding
the
above
or
the
enclosed,
please
feel
free
to
call
me
at
(708) 345-9450.
Prof
essional
Geologist
3
ERIC
D.
HASMAN,
L.P.G.
5140
Shadow
Creek
Drive
#5
Oak
Forest,
IL
60452
708-535-0260
PROFESSiONAL
EXPERIENCE
Laicon,
Inc.
-
Licensed
Professional
Geologist:
June
1993
to
Present
Responsibilities
include
generating
proposals,
budgets,
schedules
/
invoicing
and
involved
in
client
relations.
Performs
Phase
I
Environmental
Site
Assessments
and
Transaction
Screens
to
determine
environmental
liabilities
of
industrial,
commercial
and
residential
properties
throughout
the
United
States.
Engages
in
all
phases
associated
with
Underground
Storage
Tank
(UST)
removal
/
abandonment,
Leaking
Underground
Storage
Tank
(LUST)
and
Site
Remediation
Program
(SRP)
reporting.
Composes
45
Day,
Site
Investigation,
Corrective
Action
Plan,
Corrective
Action
Completion
Reports
including
Tiered
Approach
to
Cleanup
Objectives
(TACO)
Closure.
Completes
billing
I
budgeting
reimbursement
packages
associated
with
site
closures.
Other
tasks
include
investigation
and
selection
of
remediation
strategies
for
the
clean
up
of
sites.
Site
Supervisor
I
Professional
Geologist
for
the
installation
and
maintenance
LUST)SRP
remediation
technologies
such
as
air
sparging
/
vapor
extraction
systems,
bioremediation
/
biopiling
/
iandfarming
and
active
skimmer
systems.
Project
manager
and
on-site
Professional
Geologist
for
the
advancement
and
placement
of
soil
borings,
installation
of
monitoring
wells.
Conducts
and
directs
sampling
to
determine
extent
of
soil
I
water
contamination
of
LUST
I
SRP
/
non-
hazardous
or
hazardous
waste
sites.
Interprets
data
collected
andreports
findings.
Projects
have
been
completed
following
standards
as
provided
by
various
financial
institutions,
government
agencies,
and
ASTM
In
charge
of
sampling
for
disposal,
RCRA
landfill
or
incineration
permits
various
petroleum
materials
in
bulk
storage
tanks.
Performs
air
quality
testing
I
waste
water
sampling
at
commercial
and
industrial
buildings.
Additional
duties
include
writing
and
I
or
interpretation
of
Health
&
Safety
Plans,
Spill
Prevention
Control
and
Countermeasure
Plans
(SPCC).
Executes
asbestos
surveys
at
properties
and
completing
subsequent
sampling
reports
/
permitting.
Involved
in
sewer
flow
and
waste
water
treatment
investigations
and
design.
Independent
Contractor:
Duties
included
conducting,
writing
and
reviewing
Phase
I
Environmental
Site
Assessments.
Nova
Environmental
Services,
Inc.
-
Environmental
Specialist
II:
Responsible
for
completing
Phase
I
&
II
Environmental
Site
Assessments
and
UST
removal
throughout
the
United
States
for
commercial
and
residential
sites
and
composing
subsequent
reports.
Supervised
water
well
abandonment
projects
and
assisted
with
UST
closure
reports.
Responsible
for
Project
management
for
UST
and
asbestos
removal
projects,
collected
bulk
I
dust
/
air
quality
samples
and
analyzing
air
samples
during
asbestos
abatement
projects
in
schools
and
industrial
buildings
using
a
polarized
microscope.
Other
duties
included
writing
asbestos
(bulk
and
air)
sampling
reports.
In
addition,
supervised
training
of
employees.
Involved
in
client
relations,
scheduling
/
budgeting
and
invoicing.
PROFESSIONAL
REG!STRATION,’SPECIAL
TRAINING
Licensed
Professional
Geologist
#196-000793:
State
of
Illinois,
Department
of
Professional
Regulation
OSHA
40
Hour
Hazardous
Waste
Worker
I
Supervisor
Training:
Moraine
Valley
Community
College,
IESMC
refreshers
Illinois
Asbestos
Building
Inspector
(IDPH
#100-1483):
Midwest
Asbestos
Information
Center,
OTS
refresher
classes
Transportation
Workers
Identification
Card:
Transportation
Security
Administration
First
Aid
#6597:
American
Health
Care
Academy
Lead
Paint
Abatement
Training:
Midwest
Asbestos
Information
Center
Management
Planning:
Midwest
Asbestos
Information
Center
Contractor
Supervisor
Asbestos
Abatement:
Midwest
Asbestos
Information
Center
EDUCATION
Bachelor
of
Science
Northern
Illinois
University,
DeKaIb,
Illinois
Major:
Geology
Minor:
Biology
Geology
Field
Camp
South
Dakota
School
of
Mining
and
Technology,
Rapid
City,
South
Dakota
COMPUTER
SKILLS
Office
Professional,
WordPerfect,
Corel
Draw,
Super
Slug
and
AutoCad
LT.
CERTIFICATE
OF
SERVICE
I,
the
undersigned
attorney at
law, hereby
certify
that on
October
29, 2009
I served
true
and
correct
copies
of
a
MOTION
IN LIMINB
DIRECTED
TO
THE
HEARING
OFFICER
upon
the
persons
and
by
the
methods as
follows:
fist
Class
US.
Mail]
John Therriault
Acting
Clerk
Illinois
Pollution
Control
Board
100 West
Randolph
Street, Suite
11-500
Chicago,
Illinois
60601-3218
fist
Class
US.
Mail
and
by
Facsimile]
Mike
Abel
Cohen
& Hussein,
P.C.
6901
West
111
th
Street
Worth,
Illinois
60482
Bradley
P.
Halloran
Hearing
Officer
Illinois
Pollution
Control Board
100
West
Randolph
Street, Suite
11-500
Chicago,
Illinois
60601-3218
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
(
4mes
G.
\Sjpecial
Assistant
Attorney
General
bivision
of Legal
Counsel
1021
North
Grand Avenue
East
P.O.
Box 19276
Springfield,
Illinois 62794-9276
217/782-5544
TDD
217/782-9143
6