PEOPLE OF THE STATE OF ILLINOIS,Complainant,VS.) PCB No.
Respectfully Submitted,
PEOPLE OF THE STATE OF ILLINOISax rel.
ADM.
CODE 811.700(f).
1.
Respondent's denial of liability and Cross-Motion relies
entirely on its argument that it is not 'conducting a wastedisposal operation' at the Morris Community Landfill("Landfill") , and therefore is not subject to either 415 ILCS5/21(d) (2) (2004) or 35 Ill. See: Second Affidavitof Cristina Roque, attached hereto as Exhibit K. Copies of twoof these permits are attached to Complainant's motion for SummaryJudgment ("Complainant's Motion") as Exhibits A and B.4. The ...
Allowed
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