- BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Complainant,
v.
- NORTHERN ILLINOIS
SERVICE COMPANY,
Respondent.
- Adm.
- Code 101.500, replies to the Respondent's
Memorandum of Law in Response to Complainant's Motion for Summary Judgment
("Response") as follows:
I.
- NORTHERN'S ARGUMENTS CONCERNING INSPECTOR SHEHANE'S
METHODS AND CHARACTERIZATIONS OF TERMS FAIL TO CREATE
A GENUINE ISSUE OF MATERIAL FACT, AS NONE EXISTS.
- A. I observed waste on the ground.
Q. Is that enough for you to conclude that there's a landfill there? Illinois EPA
rests its right to summary judgment not upon Inspector Shehane's definitions or discretion in
detennining whethe...
AC 12-51,050214 IEPARplyRspndntMemoLaw Rspns Etc 
