| | - (PERSONS ON AflACIIEL) SERVICE LIST)
- P. 46
- P. 53
- L. 6 P.77
- P.27 LID P.56 L.9 PSI
- L20 R58 LX P.85 L24
- L. 16
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED. CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED, CLERK’S OFFICE JULY 19, 2005
- ELECTRONIC FILING, RECEIVED. CLERK’S OFFICE JULY 19, 2005
- (‘i.:RI’II:k’A’I’E DI’ sl:R\’IUI:
|
ELECTRONIC
FILING, RECEIVED,
CLERK’S OFFICE JULY
19,
2005
BEFORI:T
lIE
ILLI’..OIS
POlLUtION
(i)NTI(Ol.
I4O:~ltl)
IN iRE
MKFI’ER
OF:
)
l’ROPOSEI) AMILNDMENIS’I’O
EXEMVI’IONS FROM
STATE
)
It
05-24)
PERMI’I’TINC REQUIREMENTS
FOR PLASTIC INJECTION MoI~DlN(;
OPERATIONS
(35 III. Ad
Elfin. Code
201.146)
NoTICE
OF’ El LING
t(
):
Ms.
Dorothy
M
Goon
Clerk
of the
Board
I
Ii
00K Pollution
Control
Board
tOO
West
Randolph
Street
Suite
II —500
Chicago,
Illinois
60601
(V IA
F LECIRON iC
I”l 1.1 NC
I
(PERSONS
ON AflACIIEL)
SERVICE
LIST)
PLEASE TAKE
NOTICE
that
on
July
19,
2005,
I
filed with
the Office of
the
Clerk
of the
Illinois
Pollution
Control
Board
by
electronic
filing
the
CHEMICAL
INDUSTRY COUNCIL
OF ILLINOIS’
CORRECTIONS
TO TRANSCRIPI’ OF JULY
I. 2005
I IFARING,
a copy
of
which
is hereby served
upon
you.
Dated:
July
19, 2005
Respeelfully
submitted,
CHEMICAL
iNDUSTRY
COUNCIL
OF ILLINOiS
By:
Patricia F. $harkgy_~
One of its
Attorneys
Patricia
F.
Sharkey
Mayer,
Brown, Rowe
& Maw
LLP
71
South
Wacker Drive
Chicago,
Illinois
60606-4637
(312) 782-0600
ELECTRONIC
FILING,
RECEIVED,
CLERK’S OFFICE JULY
19, 2005
nl:FORF: ‘FIlE
ILLINOIS
N)lIAVFION
C
NEROI.
IIOARI)
IN
TElL
MATTER OF’:
PROPOSEJ)
AMENI)MENTS
TO
EXEMPTIONS
FROM STATE
PERMI’l’TING
REQUIREMENTS
fl)R
PLASTIC
INJECTION
MOLDING )
It 05 -20
OPERATIONS
(35
Ill.
Adniin.
Code
201.146)
ChEMICAL
INI)USTRY COUNCIL.
OF’
ILLINOIS’
CORREC’l’IONS TO TRANSCRIP’I’
OF’
JULY
I.
2005
HEAIUN(
‘Ihe
(‘hcniical
Industry
Council
of Illinois
(‘‘CICr)
liv its
attorneys Mayer.
Brown.
Rowe
&
Maw LI’,
hereby submits
its
proposed corrections to the
trariscri pt ol
the hearing held
in
this proceeding
on
July
I.
2005.
Une~ge
2
P.46
n~.
P
9
P.
II
P
II
L
12
Line
L.
2
P. 46
L.
I
I
L.
24
P.
47
P.
53
P.62
P.63
P.67
P71
P.25
P13
L.22
P.53
LX
L
IS
L.
23
L.
I
Line
L
IX
.24
L,
20-2
I
L
S
L.
1
P.55
P.77
L.
6
P.77
L.
3
L.
14
P.44
P.27
LID
P.56
L.9
PSI
-
L.lô
P.37
P.43
L20
R58
LX
P.85
L24
L.
16
LIX
P.59
Lii)
L.24
P.86
L.2
P.43
P.59
L.
12
P.62
L.
8
ELECTRONIC FILING,
RECEIVED,
CLERK’S OFFICE
JULY
19,
2005
See
ic~icioiis
as
slio’,vn
iii
the
itaulical
mark
up
ot
the
irailscript
pares
;uicl
lines
ic
crc
n cccl
ah,a se
-
Respcetlu
I
y
stihnii ited.
CI
IEMIC,-\l.
INDUSTRY COUNCIl.
OF IlLINOIS
I3y:
Is!
Patricia
F. Sharkey
0nc
of
Its
At toirl es—s
Dated:
July
19. 2005
Patricia
F.
Sharkev
\‘laver.
Bios~n. Ro~~c
&
Maw
LLP
7
I
S
nit
h
~Vacker Dii ye
Chicaro.
II
tiiiois
6060h—4637
(312)
782—060()
ELECTRONIC
FILING,
RECEIVED,
CLERK’S OFFICE JULY
19,
2005
p
riOt
certain
that
there
are
r.ot
corrpressioi~
LA~L
cQ
-
molders
4.-at
trenster
mcj_rllnrts
out
there
that
may
very
veil
qualify
for
an
exemption.
We
4
were
not
prepared
to
be
presentino
testimony
5
on
that
Ic.
this
proceeding,
so
we’ve
agree-ri
6
that
we’re
goino
to-
recomnend
deleting
7
comaureosion
and
transfer
molding
from
thi
a
8
lansuage.
Time
sec:oi,U
ciwocqe
you’ll
see
is
10
that
we-re
deleted
the
word
handling
and
11
we’ve
sort
of
unpacked
that
word
to
try
tc
12
wake
it clearer
~‘
what kinds of processes
13
and equipment
can octua 1 ly be covered in the
14
concept
of handling,
so we ‘we explained
that
15
that’s
loading,
unloading,
conveying,
mixing.
16
We’ve
eliminated
the
word
17
granulating
and
replaced
it
with
grinding
18
because grinding
is actually
a more generic
19
term for the
same
thing.
What we found in
20
talking to people in this business
is that
21
some people use the word granulating,
some
22
people use
the word grinding,
but
it’s
23
intended to be the same
thing,
so we’re using
24
the more generic word.
L.A. REPORTING
(312)
419—9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S OFFICE JULY
19,
2005
I
I
will oe
sub-nitting in
the
ce-cord when
2
Yr
-
Ferris testifies,
has
a reference
to
3
PlUG.
That
should have been a cefecence
to
total
pacticolate
and
its
referred
to
throughout
his
testimony
as
PM.
And
that
study
that
Mr
Ferris
is
referring
to
looked
F
at
total
particulate
rather
than
PM1O,
sc
P
this
would
correct
his
testimrony
to
clarify
10
that.
11
With that,
A4r~ThT-
Fearing Officer,
12
I
take
it
the
eximrhil
is
~i ready
in
the
13
re-curd,
but
that
is
what
the errata
she-ct
14
would
do,
so
the
prcpnsni
has
slightly
ii-
changed that’s before you.
3?
FEARING OFFICER AIITONIOLLI
:
Okay.
F,
MS.
SHARKEY:
The final
thing
I’d
like
IS
to
say is that our--as
a way of
19
introduction to
this hearing today is that
we
20
are
not going to be pruviding you with
21
information today on statewide
emission
22
levels.
We are discussing that with the
22
Illinois EPA because,
as we’ve
been working
24
on ~paring
for
this hearing,
it was
L.A.
REPORTING
(312)
419—9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19, 2005
1
.3
~ost wanted
~r
ewiew,
and
with
that,
pie-sent
the
C eat
i niony
of
in
C rodnce
to
you
us
today
Mm.
I-isa
regulatory
affairs
7
1 rmdostry
Council
of
tour years and has been
ii.
And Mr.
Lynne Harris,
who is with
the Plastics
Industry,
has
you
can
see from his
a
rmunber of
years, been
ating
a number of
——
involved
least
one of the studies
and
involved with other studies
21
The
final piece of testimony would
22
be my own on
--
just.~esig~-4o give the
23
Board some perspective on what
other
states
24
have done in terms
of regulating or exempting
1
4
6
to
give
you
that
I would like
tc
our witnesses and
who they
are.
We have with
Frede,
who
is
the
director
for
time
Cheo,i cai
Illinois.
Ms.
Frede
ham
P
t’eem;
t
lie-re
for
9
ccvern:nent
arid
onwi ran:ner,tal
roles
pr~or
to
IC’
that
11
12
12
14
15
16
17
IS
19
20
the Society
of
heem; there,
as
testimony,
f or
involved
in
crc
in creating
at
overseeing and
and
developing
emission
factors
for
the
plastics
industry and 25 years experience
in
the business.
L.A.
REPORTING
(312)
419-9292
ELECTRONIC FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19,
2005
i~
1
wam-
lush-led
o—fr,-t
\-uu ‘ye
received.
We
(rave
2
talke.d
cff
the record about
handling his
testimony
as
a
group
exhibit
because
there
4
are
some
11
exhibits
behind
his
prefi
led
S
testimony.
6
1
have
a package
in which we have
7
the
full
pro-filed testimony,
which we
can
S
curer
as.
dcl
Exhibit
3
if
you
would
like,
P
and then
I also have
a package with the
IC
indaw~c;ual
rxhihits
labeled
as
Harris
11
Group
Exhibits
1
thoc-ugh
11.
12
FEARING
OFFICER
ANTONIOLLI:
i,c-t’s
do
13
it
the latter way that
you had because
14
they’re marked well
and we can do it
then.
15
If there are
11 exhibits,
we can make
the-mn
-—
16
instead
of
ore
group
exhibit,
we
carl
just
17
make
therr3
through
13.
IS
MS.
SEARKEY:
Okay.
19
HEARING
OFFICER
ANTONIOLLI:
And
that
20
way they’re easy to refer
to
in future
21
citations;
is that okay?
22
MS.
SHARKEY:
The only thing that I’m
23
concerned about
is that
in Mr.
Harris’
24
prefiled testimony,
they’re referred to
as
L.A. REPORTING
(312)
419-9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19,
2005
would
like
to
re-fer
to then,
in which case we
2
would
be
happy
to
do
that
or
we
cculd
lust
2
simply
——
4
I:EARING (IFFICER IrNTONIGLLI
:
Since we-
5
have
it part
of
the record already,
let’s
keep
It
to
the
way
that
you ‘ye
marked
it
armd
7
if
you’re willing
to,
we
can enter that
into
F
the group exhibst.
9
MS.
EFAPFKEY:
Okay.
So this would he
10
entitled
——
what we would be offering~
then
11
is Harris group exhibits,
which
would consist
12
of prefiled
testimony end Harris Exhibits
I
13
through
12
and attachmnents?
14
HEARING OFFICER 7~NT0NI0LLl:
Can we go
15
off
the record far
one minute?
10
THE REPORTER:
Sure.
17
(Whereupon,
a discussion
18
was had
off
the record.)
19
HEARING OFFICER ANTONIOLLI:
And you
20
can come
around,
Mr.
Harris.
21
I have
in front
of
roe
the prefiled
22
testimony of Mr.
Lynne Karris on behalf of
23
the Society of Plastics
Industry,
Inc.,
as
it
24
was prefiled on dune
16,
2005.
If there’s no
L.A.
REPORTING
(312)
419-9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19, 2005
regulatory
authorities
as
defining
emission
factors
far
both
simple
extrusion
and
the
extrusion
process
utilized
in
PIN.
lihat
these
studies demonstrate
is
that
extru.Y-i
on
processing
of
different
resins
F
u,dez
varicus
cperat
ing
conditions
produces
7
different
types
and
an aunts
of
emissions.
P
nxhihit
9,at
t.ached
to
my
prefiled
testir;ony,
1
is
a
chart
summrar
1
zinri
the
emission
fart
ora
10
developed
ii,
the
SPA
studies
for
each
of
the
I:
errissiorms
of
intem
est
for
the
resins
studit-d.
12
The
infurrm,ation
in
this
chart
was
13
compiled from inforn,ation contained
in each
14
of
the SPI
studies to make
it easier to
15
review this data
in
this proceeding.
As
car,
16
be seen frcm this chart,
the emissions
of
17
interest
include
VON,
PM,
and
a
variety
of
18
HAPs.
19
The
type
and volune of emissions
20
varies from
a high
of approximately ~-Q4--,.
21
pounds of VON per
ton of resin processed
to a
22
low
of
approxImately
0.1
pound
per
ton
of
23
resin processed.
RAPs
ranged from a high of
24
approximately 0.3 pounds per ton of resin
L.A. REPORTING
(312)
419-9292
ELECTRONIC
FILING,
RECEIVED, CLERK’S OFFICE
JULY
19,
2005
1
cf
states
that have exempted plastic
2
injection molding.
As
I said earlier, we
3
actu4ily
found Michigan’s
to be simple and
4
aleai
and thought that
it covered what we
5
were concerned with.
6
I have attached to my testimony
the
language
from the Michigan exemption,
8
which
rimr!ply reads
——
it’s Michigan
DEQ
9
Regulation R336.l286(b),
which
states that a
IC
permit
to install
does not apply
to plastic
11
in7eol ion,
compression,
and transfer molding
12
equipment
and associated plastic resin
13
handling,
storage,
and drying equipment.
14
ke also looked at another
15
neighboring region five state
and
--
In Ohio,
16
and the
Ohio -ait~regolation is,
as
you can
17
see,
is a bit more
complicated.
Basically
18
ohio
has
said there
is ~p~mS-t~
what they
19
call a permanent exception
for plastic
20
injection molding as well
as compression
21
molding, by the
way,
for facilities
that
are
22
processing
a million pounds of resin or less
23
annually.
24
They also provide another
L.A.
REPORTING
(312)
419-9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19.
2005
cxcrrpticn
for
thcse
facilities that
are
2
r ocessing
ur.’ier
six
million
or less
and are
alsc using less
than
1000 pounds
of woiatile
4
crganic compound
ao an external mold release,
$
so
t
hey
hove
o cot
of
twa—tiered approach to
P
it
for the plastic inrection nolder with some
7
upper
limits in
terms
of what they were
8
looking
at.
9
Finally,
the Texas
administratiwe
1-7
code was most interesting in
that
it was
very
11
simple and they simply have
an exemptiun
fur
12
equipment
usAfor
compression
nmoiding and
12-
injection
molding
of
plastics and they have
14
got
that permitted
by rule.
15
We noted also that
Iowa,
another
18
neighboring state, while they haven’t adopted
17
an exemption right
now,
is looking at
--
has
18
announced that
they are going to be looking
19
at exempting plastic injection molding,
and
20
that’s
in Exhibit
4 to my prefiled testimony.
21
So we don’t
know the contours of
that
22
exception,
but
we do know
that they’re
23
looking
at it.
24
So Illinois is certainly not
alone
L.A.
REPORTING
(312)
419—9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19,
2005
06
1
about are emossions that are either out there
2
~
they’re not and they’re either
—
whether
3
they’re permitted or not,
they are
--
it’s
4
not
as
though somebody
is
not going
to
do
$
business because they have to get
a per:nit,
6
but it’s
a question of whether we’re going
to
7
be burdening this industry with these very
8
small
emn~ssior.swith that same permitting
9
process that w5 use
for sources with larger
10
emissions and whether we’re going to be
11
burdening Illinois EPA
with- that permit
12
processing.
13
And
that simply
-—
we’ve also then
14
nertioned in my testimony
that
there are
a
15
number
of other states
that
don’t
need a
16
categorical exemption
because
they have
17
exempted
these very small
emission sources
culL
-
18
across
the board w4~etea
de minimls
cutoff
19
that would have included facilities even
20
though
those facilities
were not otherwise
21
required to have
a
permit.
22
And so
it wouldn’t be surprising
23
not
to
find
a
categorical exemption
in
24
50 states because they simply wouldn’t need
L.A. REPORTING
(312)
419-9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S OFFICE JULY
19,
2005
it.
Ar:d
I
would he happy
to.
ajsxe-r
any
1
questions
regarding
our
research
into the
I
other
states’ ieguiatlons
and
1
—
stepping
4
,:ot
ci
role as a witne-ss,
I
would
be
happv——and
I dsn ‘t think
I was sworn
in
6
actually.
7
FEARING OFFICER ANTONTOLLI
Nc,
you
F
wem
Er:
‘t
thanks
for rewinding me.
we can
hove ycu sworn in now.
it
(CS.
SEARKEY:
I would be happy to be
11
s-worn
in.
12
((EARING OFFICEP: ANTONTOLLO
:
Okay.
15
(Witness
sworn.
14
MS.
SEARICEY:
At this point,
we would
1$
be happy
to answer any quest ions
the Board
a e
tm.cmhors
or
the staff may
have or anybody else
17
irom the public.
We wncld
also
--
of
course,
19
if
Mr.
Matoesian wants
to make
a statement
——
19
FEARiNG OFFICER ANTON1OLLI:
Would
you
20
like
to?
21
MR. MATOESIAN:
I
would
just
state
22
that
as mentioned
——
or eluded to earlier,
22
the ~6~nicai
staff
had scheduling
24
conflicts and were not able to attend today,
L.A.
REPORTING
(312)
419—9292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S OFFICE JULY
19,
2005
1
whatever the threshold
is ~zr~ae
major
2
source,
they need
to be considering whether
3
or
not they are
uriggering, dependrna on what
4
attainment
area
t hey’ re
in,
whether
they
are
5
triggering major
source status.
6
So thay are certainly responsible
7
for
their
emissions
in the same way that
they
H
4,~ would be
5.j tho’:t
a permit,
What
they
9
are
—-
whae
you
have
~5
1
think some
——
the
10
only reason we’re
talking about what are
the
II
statewide volumes
——
12
MR. MELAS:
Right.
13
MS.
SHARREY:
——
is,
frankly,
14
reflected
in the hearing
in R05-2O
in which
IS
there was
some concern and questions raised
1?
about
whot are
we talking
about in terms of
17
having a category or
a number of sources out
18
there
for whioh
we do not have
a permit,
how
19
concerned
are we,
what’s
the volume of
20
emissions
cut there.
21
And
it’s not that
the permitting
22
——
I believe Mr. Sutton testified to this
in
23
that hearing and
I
think we just wanted
to
24
make the
sante point
here that it’s
not
as
L.A.
REPORTING
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419-9292
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rE~xt wcek
or
in
two weeks.
2
MS.
SIARKEY:
if
I could add one
print
here,
1
want
to
n-Lake
it clear that
if you
roost
der
snat
a permit for these types e±
?tmim:nioc
sources
weuld
look like,
it would
6
not
have any indivrduoliaed emission limit~in/
7
it.
it would not have—— because
there
9
are
no
m
nd~viduaiired emission limitations
10
that
scold amply,
so there-would he
na~
11
leLierai
NSSHAF
I equirecents
or
feder~inew
12
oource
per
tor-mance
requi
roments,
teohnoicoy
13
r equi
r etrents,
pol luti
or:
control
requirements,
14
because these
are
de
minin:is
sources
that
--
15
if
any
ni
that
is
triggered,
your
categorical
16
exemption,
your
iangua~e
at
the
front
of
that
17
exemption states they would
not be eligible
18
for
the exemption.
19
So if there are any other
20
reQuirements
that would
actually be reflected
22
in
a permit that would require control,
they
22
will
--
this source will
not
be eligible
for
23
the exception.
So you’re talking about
a
24
category of sources which
are
--
you
can
L.A.
REPORTING
(312)
419—9292
ELECTRONIC
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OFFICE
JULY
19,
2005
5 6
ossue
cheo
a permit,
you can go through the
2
paperwork
of
issuing them
a permit,
but there
3
are
not
going to be any extra controls on
4
them.
5
It’s
oust
a
matter
of
whether or
6
not you’re going to have that paperwork in
7
Sprinofield on them.
The emission source
is
8
out
there one way
or
the other,
whether
it’s
9
exempt
or whether it’s Øamo3.~~+g. So it
to
isn’t
as though we are talking about
any
11
incre~sed level
of emissions,
we’re simply
12
talking about whether
the state
needs to have
13
that paperwork
on these sources.
14
And
I would point
out
that many
15
states as
you
—-
some
of which we’ve cited
16
htwe
a general permit,
o
permit by rule
so
17
that
they don’t
issue a permit,
they simply
18
say abide
by the
rules.
Illinois doesn’t
19
call
it permit by rule,
but,
obviously,
every
20
emission source in Illinois
is subject
to the
21
Pollution Control Eoard’s rules no matter
22
whether they have a permit or not.
23
NE.
JOHNSON:
Can
I
follow up on that,
24
Nick?
L.A.
REPORTING
(312)
419—9292
ELECTRONIC FILING,
RECEIVED,
CLERK’S
OFFICE
JULY
19,
2005
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201,146
2:11
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0
i :,r:-,h:,-~i. f
you
cool
ti
try
rind
21
::t n:~Lghr
o.’i
owe
moo
——
Atotad
has
tr
I en
L:o
do
ft
22
ano)
hoc;
boon
nnah
Se
001
50
far
on
the
23
di
f for-once
bet.wee’i
——
wh,tt
ohm
pract
in;
24
dlttor-c,ico
Hi
oi
tOoL
exemption
LIS
an
actual
u:,A.*~-l°oHttNI;
(712)
119—9292
ELECTRONIC
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19,
2005
exemption
versus
the
201.270
insignificant
2
activities.
I
can’t
——
I’m
not
making
that
3
ieap
for
whatever
reason.
4
MS.
SHARKEY:
As
a
practical
matter,
5
if
I
am a large
source,
if
I’m already a
,ra~or
source
and
I
have
cmi
55;
ons
less
titan
7
.44
tons
per
year,
any
individual
etniss~ori
p
unit
at
that
source
less
than
.44
tons
is
9
osteqorized
as
an
insignificant
activity.
10
.ked
a
Title
V
permit
will
be
A
A
11
simply
listed
and
will
not
have
any
specific
12
control
requirements
applicable
to
it
if
it
13
qualifies.
Now,
again,
it
must
qualify
as
14
riot
having
a
federal
new
source
performance
15
star.dard
or
any
other
dsaft
requirement
or
16
NESHAP requirement.
17
In
that
instance,
it
will
simply
18
be listed in your
Title V permit under the
19
section of insignificant
activity.
And in
20
many
instances,
they
don’t
even
list
the
21
number,
so
you could
have
--
we’ve
seen
some
22
simply say plastic
injection.
They’ll simply
23
say extruders
or they’ll
say
—-
they’ll
check
24
off
a
list
and indicate that
they have
~1_
L.A. REPORTING
1312)
419-9292
ELECTRONIC
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CLERK’S OFFICE
JULY
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2005
din’
t
even
realize
they
didn’t
have
any
good
2
emission
factors
for
these.
They
didn’t
realize
there
woo
arty
substantial
amount
of
4
err.issiot:
at
all
from
these
facilities.
They
5
were
very
clean
facilities.
6
And
what
we
have
is,
as
science
7
has
gone
nit
and
we’ve
gotten
more
concerned
Pniy-SSi~fl1
9
about
~mr
hazar-dous
ee.,4.a..t-rvn-e,
particularly
we’ve
gone
and
we
bevin
to
study
in
more
10
depth,
and
1
would
suogest
to
you
that
there
11
are
many,
many
cmi ssion
sources
out
there
at
ii
these
very
tiny
enciission
levels
that
Illinois
13
right
now
is
not
regulating
and
that
what
we
14
have
is
an
ambiguous
situation
for
those
IS
parties
and
that
Illinois
needs
to
decide
16
whether
or
not
it
is
going
to
be
focusing
on
17
these
very
tiny
emission
sources
with
its
15
permitting
rescurces
-let
taking
and
looking
19
at
the
fact
that
it
doesn’t
have
Title
V
20
permits
that
are
out
and
revised
and
up
to
21
date
for
every
source
in
this
state
where
the
22
big
emissions
are.
23
And
if
I
could
just
say
one
more
24
thing,
what
we’re
trying
to
say
is
to
put
it
L.A.
REPORTING
312)
419-9292
ELECTRONIC
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2005
Ci
in
pierspect
ret,
the
states
and
1
think
that
2
the
Iil300is
environmental
regulatory’s
group
3
te-sticony
in
R05—1
9
and
my
testimony
in
this
4
prooeeding
is
that
other
states
have
provided
5
fur
bigger
exemptions
and
are
focusing
their
6
permitting
tescorces
right
now
on
the
big
7
emission
sources.
8
So
I
hope
that
answers
your
9
question,
bitt
the
thought
is
that
when
we
10
are
at
this
point
in
Illinois
focusing
on
11
some
very
small
stuff
and
perhaps
loosing
12
site
nf
the
bioger
of
——
where
the
ball
is
13
and
the
real
issue
here
is
that
——
14
Mr.
Sutton’s
testirtLony
in
that
proceeding
15
told
you
that
something
like
90
percent
of
16
emissions-
in
the
state
of
Illinois
are
17
produced
by
.senrething
like
15
percent
of
the
is
emission
sources.
19
And
when
we
start
to
go
down
to
20
this
minutia
level,
we
have
to
ask
ourselves
21
as
policymakers,
as
the
Board
is
the
22
polioyanakers,
as
regulators
is
this
where
23
these
resources
should
be
going.
The
rest
of
24
the
states
in
region five had
no and
L.A.
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Is
thor-
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SO
UUL
00:10
ni
tho
oixt toro;e r
——
19
)0I.:-.-lnjeL..tinn
bo-::roj
ai:-s
o’oe
s-eon,
Sir.
loor-is
‘
tosoi:nnnv
is
that
~
/t
at
2i
essontiaiiy
is
w~..a
continor00000troioicr.
22
1-117317.153
0171171 tSR
ANTONIOLLi
Okay.
23
And,
Mr.
Harris,
do
you
have
any
diffierit-ig
24
-opInion
or
is
that
——
wortitl
you
aqtoo
with
1.3.
IOVFO7RTIN3
(312)
-119—9292
ELECTRONIC
FILING,
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CLERK’S OFFICE JULY
19,
2005
I
I
h:a
i.
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trot
-t
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th,: roI:!Set.n
last
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ti;i~..U‘o
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:
170:;
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Lvpc:of
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cli
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oc1t:ipnlc:rl:
j;;-;
siiql,Liy
13
(ii
f’tt’rnnb
t,uLwo:
call
7c.’t
50:-u
Lho
in f!35-:oatiola
lii
Of
whao
tho
dii
fe-cetct-s
arc:.
1.17-
517.
RAG:
Okay.
That
won;
Iho
16,
.00
IprIr
17
And
you
fio’zo
pr—ovb:ic;ri
a
di
aci ran
of
19
the
Pin
machine
that’s
in
1-Ixhibit.
1
and
9
tUsh
i
hi t~ 1.
1
l;aG
a
cluE-rot. ion
about:
whcero
the
20
VOM
emissions
occur,
is
it
——
c-art
you
show
us
21
on
rho
diagram?
22
MR.
HARRIS:
Sot.he
anlissions
would
23
come
—-
in
the
P1M
process?
24
MR.
RAO:
Yoah.
L.A.
R51J°CIPT1NG
(312)
419—9272
ELECTRONIC
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CLERK’S OFFICE
JULY
19,
2005
issue—-
pe-rl:aps
the
other
kind
oi
qtoestio’r.
2
tl:at
comes
op
with
handling
is
lust
this
3
slntqlrir:c
oft
of
tiny
jiartjc1os.~’
the
.1
I.~nd±irtcrof
these
rosIn
beods,
and
you’re
5
going
to
he
get
t
i
1,0
: one
more
infcrnatron
as
6
host
as
we
can
find
it.
7
we
have
to
tell
you
we
are
looking
B
for
emission,
factors
or
something
to
help
us
B
with
this-
because
they
really
uren’t
out
10
there
and
people
are
riot
foousong
on
these
11.
activiti
es.
lIe
7ust
want
to
make
suoe
——
12
we’re
all
quite
sure
that
the
emissrons
we’re
13
going
to
find
are
very
low
because
of
their
A
14
ciearr
operations
but
~b~tA
what
we
are
looking
15
for
is
a
way
to
give
you
an
understanding
of
16
something
concrete
and
obiective
to
17
understand
that.
18
HEARING
OFFICER
ANTONIOLLI:
Okoy.
19
MR.
RAO:
In
your
prefiled
testimony,
20
Mx,
Harris,
you
rioted
that
there
are
like
21
approximately
500
PIN
facilities
in
22
Illinois
——
23
MR.
HARRIS;
Yes.
24
MR.
RAG:
--
and
I
know
you’re
going
L.A.
REPORTING
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ELECTRONIC
FILING,
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ía
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r.ni nk
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14
tbiaa:isa+:
r
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water
itrvoi
wool
5
in
tI
o
pr::c+rso
/
ct
69
t~ic
r’nl’i
r,’-’’_’niaa:
:
,atc’r
——
an
‘4’
1
N 99113
or
asn,
1-/c;
t’
hon
Ic
hf:
;:‘o
LIti
t
t: I’
18
opo.o:ificat
ty
aSs:orr,iaLe;i
wi
211
plant
Jo
19
injection
ni:;iditig
.
Now,
again,
If
the
20
facii
ty
has
otho:n
operations,
they
may
have
21
thoso
typo_s
of
pormi
to.
22
MR.
RAG:
is
noise
an
issoro
with
those
23
machines?
21
MR.
MIILAS:
Pre
they
noisy?
L.A
.
BISPGRTING
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419—9292
ELECTRONIC
FILING,
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CLERK’S OFFICE
JULY
19, 2005
1:~5_i_It:
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1:11.11
PTINCI
(‘12)
119--°1292
ELECTRONIC
FILING,
RECEIVED,
CLERK’S
OFFICE JULY
19,
2005
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17
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laiD:
(lndicatin:-~.)
19
IIIAR1N’Il
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Okay.
ho
19
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do:
you
20
have
anything
further
at
this
time?
21
MS.
SIIARKEY;
No,
wodor
n’ t
.
We’ ro
22
happy
to’
provide
the
Board
with
additional
23
intormation.
We
appreciate
the
qoestions,
24
They’ve
been
very
helpful
for
:15
to
L.A.
REPORTING
(312)
Ii
Ob~4292
ELECTRONIC
FILING,
RECEIVED.
CLERK’S
OFFICE JULY
19,
2005
(‘i.:RI’II:k’A’I’E DI’ sl:R\’IUI:
I.
PalI’ic’ia
I.
Sharke
,
an
altoi’iicy. hereby certify
Lila!
I
lirIve
served
the
(.Tirei~iica!lraliistry
Council
it’
Illinois’
(‘on’eclions
to
‘transcript
tif
July
I.
2(105
I
learirig
upon:
s
-
Don
It
h
~ i’VI, C~
titlil
C
lci’k of
the
Board
111111015 Piilliition Control Bow’c!
IOU
\VcsI
Randolph
Stied
Sinte
li—Sot)
(,‘hicaotti.
IllIlIols
0O(i(.lI
(idcctI’tuilc
‘‘liii)
~~‘Itilthet~-
1)ulin,
(‘(liii
l)iv’ision
of
Eir\’ii’ollluent:rl
i’tnfoi’ecinerit
Office
of
lilt’
Attorney General
58
West
Randolph
Street.
20111 Floor
(‘hicatlo.
II
lillOiF
(tI)(,0
I
(.5.
Mail
Donald
Sutton
NI
a
ii
ager. Per ind
S
ecti on
Di Vision
of
Air
Pol mUon
I3tu’caa ot
Air
Illinois
Ellviroilnlental
Protection
A?ency
102!
Norh
Gi’and
Al-enue
12tst
Post
010cc
13o.x
19276
Springfield. Illinois
62794—9276
(U.S. Mail)
(i’hzir’les
i—.
\‘laloesian
Division
of
I
~egal
(Joiinsc
I
Illinois Environmental
Protection
Agency
1021
North (hand Avenue
East
Post
Office
I3ox
19276
Spi’iilgbcld. Illinois 62794-9276
(tI.S.
Mail
alki
E—Mail)
Office of
Legal Services
Illinois
Department
of’ Natural
Resources
One
Natural
Resources
\Vav
Spi’inefieid. Illinois 62702—
I 27
I
((IS,
Mail)
I
leidi
F.
Hanson
I
I
-
F.
!‘Iansun.
Escj.
P.C.
472
1
F’I’ailkl
I
il
A
\‘elltiC
Stnte
1500
~VesternSprings.
Illinois
60558-1720
(U.S.
Mail)
as
indicated
above, by
e— mai
and/or by
depositing said document in the United States Mail,
postage prepaid.
in Chicago,
III
inot
S on Jti
I
y
I 9.
2005.
Patricia
F.
Sharkey
Mayer,
Brown, Rowe
&
Maw
LLP
71
South
Wacker Drive
Chicago,
Illinois
60606-4637
(312) 782-0600
/s/ Patricia
F.
Sharkey
Patricia
F.
Sharkey
