BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
IN
THE
MATTER
OF:
)
NOV
0
72008
NITROGEN
OXIDES
EMISSIONS
FROM
)
R0819
VARIOUS
SOURCE
CATEGORIES:
)
(Rulemaking
Polluon
Control
Board
-
Air)
AMENDMENTS
TO 35
ILL.
ADM.
CODE
)
PARTS
211
AND
217
)
,)
c
2
“)
NOTICE
TO:
John
Therriault
Assistant
Clerk
Illinois
Pollution
Control
Board
James
R.
Thompson
Center
100
West
Randolph St.,
Suite
11-500
Chicago,
IL
60601
SEE ATTACHED
SERVICE LIST
PLEASE
TAKE
NOTICE
that
I have
today
filed
with
the Office
of the
Clerk
of
the
Illinois
Pollution
Control
Board
the
POST-HEARING
COMMENTS
OF
THE
ILL1NOS
ENVIRONMENTAL
PROTECTION
AGENCY,
a
copy
of which
is
herewith
served
upon
you.
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
I
By:
‘
‘
/
Gina
Roccaforte
Assistant
Counsel
Division
of
Legal
Counsel
DATED: November
5, 2008
1021 North
Grand
Avenue
East
P.
0.
Box
19276
Springfield,
IL
62794-9276
THIS
FILING
IS
SUBMITTED
217/782-5544
ON
RECYCLED
PAPER
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD..
KVED
IN
THE
MATTER
OF:
)
OFPiC
NITROGEN
OXIDES
EMISSIONS
FROM
))
R08-19
MJV
072008
VARIOUS
SOURCE
CATEGORIES:
)
(Rulemaking
j
ILJJ,s
AMENDMENTS
TO
35
ILL.
ADM.
CODE
)
fltrog
8
OarcJ
PARTS
211
AND
217
)
POST-HEARING
COMMENTS
OF
THE
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
NOW
COMES
the
Illinois
Environmental
Protection
Agency
(“Illinois
EPA”),
by
its
attorneys,
and respectfully submits
its
post-hearing
comments
in
the
above
rulemaking
proceeding.
Though
the
Illinois
EPA
responded
to most
every
issue
raised
at
the first
hearing
in
this
matter
on
the
record
during
that
proceeding,
some
outstanding
issues
remain
to
be
addressed
in these
post-hearing
comments.
Responses
to
Questions
Raised
During
the
October
14,
2008,
Hearing
Question:
Directed
to
Mr. Kaleel,
Question
3 from
the
Illinois
Environmental
Regulatory
Group,
inquiring
about
other
states
‘ NOx
RACT
emission
limits
that
the
Agency
considered while
formulating
the
rulemaking
proposal.
Answer:
Please
see
Attachments
1
through
5 to
these
comments.
Question:
Directed
to
Mr.
Kaleel,
a
follow-up
question
to Question
12
from
the
Illinois
Environmental
Regulatory
Group,
inquiring
about
heat recovery
steam
generators.
If
a heat
recovery
steam
generator
recovering
heatfrom
the
exhaust
of
A,
process,
B,
turban
[sic],
or
C,
engine,
is
considered
a
boiler
for
proposed
—
for this
proposed
rule,
then
does
the
Agency
intend
to define
the
boiler’s
rated
heat
input
capacity
as
a
direct
heat
input
to
the
heat
recovery
steam
generator
from
combustion
offuel
in
the
heat
recovery
steam
generator
—for
example,
from
a
duct
burner
—
or does
it intend
to
also
include
the
heat
input
from
the
upstream
process
in
the
rated
capacity?
(Transcript,
p.
65)
Answer:
The
Illinois
EPA
reviewed
the
USEPA’s
regulations to
control
NOx
emissions
from
combined
cycle
turbines
where
the
exhaust
from
a turbine
is captured
in
the
heat
recovery
steam
generator
(see,
40 CFR
60,
Subparts
GG and
KKKK).
For
the
simplicity
of the
testing
and
monitoring
of
the
NOx
emissions,
the
Illinois
EPA
decided
to treat
a combustion
turbine
and heat
recovery
steam
generator
as
a
single
unit.
The
supplemental
heat
input
of
the
duct
burner/heat
recovery
steam
generator
will
be added
to the
heat
input
of
the turbine.
The
combined
heat
input
will
be subject
to the
applicable
NOx
emission
limit
for
turbines
under
Subpart
Q
of
Part
217.
Therefore,
the NOx
emissions
will be
tested/monitored
after
the
exhaust
from
the
heat
recovery
steam
generator
and
shall
comply
with
the
NOx
emission
limit
for
a
turbine.
However,
the
heat input
of
the
duct
burner/heat
recovery
steam
generator
shall
not
be
added
to the
heat
input
of the
turbine
to
increase
the
rated
capacity
of
the
turbine.
Accordingly,
the
Illinois
EPA
proposes
a
revised
defmition
of
the
term
“industrial
boiler”
to
exclude
a heat
recovery
steam
generator
that
captures
waste
heat
from
the
upstream gas
turbine
as
follows:
“Industrial
boiler”
means,
for
purposes
of
Part
217,
an
enclosed
vessel
in
which
water
is heated
and
circulated
either
as
hot
water
or
as
steam
for
heating
or
for
power,
or
both.
This
term
does
not
include
a
heat
recovery
steam
generator
that
captures
waste
heat
from
a
combustion
turbine
and
boilers
serving
a generator
that
has
a
nameplate
capacity
greater
than
25
MWe
and
produces
electricity
for
sale,
and
cogeneration
units,
as
that
term
is defmed
in
Section
225.130
of Part
225,
if
such
boilers
or
cogeneration
units
are
subject
to meet
the
applicability
criteria
under
Subpart
M
of
Part
217
the
CAIR
NOx
Trading
Programs
under
Subpart
I)
or E
of
Part
225.
(Please
note
this
revised
definition
includes
the
amendatory
provisions
in
response
to
Midwest
Generation’s
Question 20
directed
to
Mr.
Kaleel.)
Question:
Directed
to
Mr.
Kaleel,
a follow-up
question to
Question
12
from
the
Illinois
Environmental
Regulatory
Group,
inquiring
about
heat
recovery
steam
generators.
If
the
rated
heat
input
capacity
of
the
boiler
is
intended
to
include
energy
from
the
exhaust
of
an
upstream
unit,
then
how
does
the
Agency
anticipate
resolving
the
NOx
emissions
and
controls
from
the
unit
and
from
the
heat
recovery
steam
generator?
(Transcript,
p.
65)
Answer:
See
response,
above.
Question:
Directed to
Mr.
Kaleel,
a
follow-up question
to
Question
12 from
the
Illinois
Environmental
Regulatory
Group,
inquiring
about
heat
recovery
steam
generators.
[un
this
situation
where
you
would
have
a heat
recovery
steam
generator,
would
that
unit
be
regulated
under
this
proposal?
(Transcript,
p.
66)
Would
it
perhaps be
regulated
under
subpart
Q?
Would
it
be
regulated
here?
Would
it
be
regulated
both
places?
(Transcript,
p.
67)
Answer:
See
response,
above.
Question:
Directed
to
Mr.
Kaleel,
Question
12 from
the
Illinois
Environmental
Regulatory
Group,
requesting
Tables
C-2
and
D-1
ofthe
Technical
Support
Document
in
Microsoft
Excel.
Answer:
On
October
16,
2008,
the
Illinois
EPA
sent,
via
email,
Tables
C-2,
D-i,
E-1,
F-i,
G-
1,
H-i, and
1-1
of the
Technical
Support
Document
in
Microsoft
Excel
to
the
Clerk
of the
Illinois
Pollution
Control
Board.
Persons
interested
in
these
tables
in
Microsoft
Excel
format
are
directed
to
request
them
by
contacting
the
Clerk’s
office,
as
indicated
on
the
Board’s
web
site.
2
Question:
Directed
to Mr.
Kaleel,
from
the
illinois
Environmental
Regulatory
Group,
inquiring
about
modeling
information
and
what
emission
reductions
were
included in
the model
and
fthe
reductions
shown
on the
tables
(Tables
C-2
and
D-1)
were
included.
Answer:
The
attainment
demonstration
modeling
accounted
for
NOx
RACT
reductions
through
the
use
of
an emissions
model.
The
emissions
model
approximates
the
emission reductions
by
identifying affected
units
through
the
use
of Source
Classification
Codes
(SCC),
and
then
multiplying
the
base
emission
rate
by
a
control
factor.
This
modeling
process
yields
emission
reductions
that
are
of
the
appropriate
magnitude
for
the
nonattainment
area,
but
may
not
reflect
the
reductions
shown
in Table
C-2
of the
TSD
for
each
emission
unit.
The
details
of
the
modeled
emission
reductions
are
available
on
LADCO’s
website:
www.ladco.org.
Question:
Directed
to
Mr.
Kaleel,
from
the
Illinois
Environmental
Regulatory
Group,
requesting identfication
of
other
categories
of
units
that
do
not
exist
in
the
nonattainment
areas.
Specifically,
could
the Agency
identify
any
other
categories
or
subcategories
for
which
units
do not
currently
exist
in the
non-attainment
areas?
(Transcript,
p.
114)
Answer:
To
confirm
what
was
stated
at
hearing,
cement
kilns
and
aluminum
furnaces
are
the only
two
categories
of
units
that
do
not
exist
in
the
non-attainment
areas.
Question:
Directed
to Mr.
Kaleel,
from
the
Illinois
Environmental
Regulatory
Group,
inquiring
about
whether
the
reductions
in Table
C-2
of
the Technical
Support
Document
include
units
complying
with
the
multi-pollutant
standard
or
combined
pollutant
standards under
Part
225.
Answer:
The
estimated
NOx
RACT
reductions
in Table
C-2
of the
Technical
Support
Document
are
based
upon
a
strict
application
of
the
proposed
RACT
emissions
limitations
for
units
in
the
non-attainment
areas.
Such
reductions
are
not
based
upon
application
of
the
multi-pollutant
standard
or combined
pollutant
standards
under
Part
225.
Question:
Directed
to Mr.
Kaleel,
from
the
Illinois
Environmental
Regulatory
Group,
requesting
that
all
attachments
to the
Technical
Support
Document
be ,nade
available
for
inspection
at
the
Agency.
Answer:
All
attachments
to
the
Technical
Support
Document
are
available
for
inspection
at
the
Illinois
EPA’s
Springfield office.
Question:
Directed
to
Dr.
Staudt,
Mr.
Dennis,
Archer
Daniels
Midland,
questioned
the
accuracy
of
the
response
to
Question
34
from
Midwest
Generation
as
it
relates
to
the
boilers
in terms
ofmmBtu
heat
input
capacity,
and
the
response
has
been
amended.
Answer:
So, 100-600
hp
boilers
are
in
the
range
of
3,347,500
Btulhr
to
about
20
million
Btulhr.
The
specific
reference
you
have
identified
is in
the section
on
combustion
tuning
(mostly
of interest
for small
boilers)
and
relates
to the
cost
of
oxygen
trim
systems
in the
range
of
$6000-$7000
for
boilers
of
that
size.
And,
as
noted
in
the
TSD,
for
larger
boilers
the
cost
would
be somewhat
higher.
Of
course,
100-600
hp
boilers
are
well
below
the
size
of
boilers
that
are subject
to
emissions
limitations.
However,
small
boilers
may
be
subject
to
the
combustion
tuning
requirement,
depending
upon
the
emissions
of
the
boiler.
Question:
Directed
to
Mr.
Kaleel,
from
Midwest
Generation,
inquiring
about
the
necessity
ofSection
217.141.
Answer:
Section
217.141
was
originally
promulgated
by
the Board
in 1972
as
Rule
207
and applied
to both
new
and
existing
sources.
(See,
R71-23).
The section
has
been
amended
and
was
recodified
in
1983.
The
NOx
limitations
under
Section
217.141
apply
to
any
existing
fuel
combustion
emission
source
with
an
actual
heat
input
equal
to
or greater
than
73.2
MW
(250
mmbtu!hr),
located
in
the
Chicago
or St.
Louis
(Illinois)
major
metropolitan
areas.
Currently,
sources
meeting
the
heat
input
criteria
and
located
in
these
areas
are
subject
to
these
NOx
limitations.
Accordingly,
these
limitations
appear
in sources’
permits.
Question:
Directed
to
Mr.
Kaleel, Question
13 from
Midwest
Generation,
inquiring
about
the
placement
ofthe
second
sentence
of
Section
21 7.152(b)
to
another
Section.
Answer:
The
Illinois
EPA
is in
agreement
that
it may
be
more
appropriate
to
place
the
sentence
in
another
section,
e.g.,
in
each
respective
subpart’s
emissions
limitations
section.
Respectfully
submitted,
ILLiNOIS
ENVIRONMENTAL
PROTECTION
AGENCY
By:
Gina
Roccaforte
Assistant
Counsel
Division
of
Legal
Counsel
DATED:
November
5, 2008
1021
North
Grand
Avenue
East
P.
0.
Box
19276
Springfield,
IL
62794-9276
THIS
FILING
IS SUBMITTED
217/782-5544
ON
RECYCLED
PAPER
4
NOx
RACT
Limits
for
Industrial
Boilers
in
Illinois
and
Other
States
TSD/NOx
RACT
Regs-other
stales.xts/1
0-10-2008
The
limits
apply
to
boilers
>100
mmbtu/hour
(Unless
otherwise
specified)
Fuel/Unit
Type
wi
TX
MO
W1*
(Existing
WI
OH’
Houston/GaIv
South
Coast
San
.loaquin
.
IN
State
IL
units)
(Const.after
NOx
RACT
NOx
RACT
Attainment
SCAQMD
Volley
-
Phase
3
(Ozone
Season)
NY
)
Demo
O
3NAA)
Eff
tve
Register:
Register:
Register:
Register:
Adopted:
Adopted:
Amended
Filed
Effective:
Filed:
cc
i
Jan
2001,
Jan
2001,
July
2007,
12/12/2007,
4/27/2005,
Amended
9/13/2003,
8/26/05,
5/13/1996,
3/23/1998,
Final
Effective:
Dec.
20,
1993
1/19/94.
Date
of
Proposed
Effective
Effective
Effective
Effective
Effective
11/17/2000
Amended
Effective
Errata:
Rule
Effective
June
10-31-02
Operative:
Efective:
Regulations
Feb.1,
2001
Feb.1,
2001
Aug.2007
12/22/2007
5/19/2005
3/17/2005
5/30/06
12/12,
2002
‘
Jan.
23,
1994
2/18/94
217
Subpart
NR428
05
NR428
04
NR428
22(a)
3745
110
03
117
206c
5146
439
1OCSRIO
3261AC10
12991
12995
Env
A
1211
19727197
227
2
4
0.036
Gas
Fired
0.08
0.10
0.05
0.08
0.10
0.02
(>40
mmbtu/1
0.036
(>40
moth
NOx
Limit
for
OCt
Boilers,
lb/nimBtu
Other
Liquid
Fuels
(Residual
Fuel
etc.)
Distillate
Fuel
0.10
0,12
0.09
0.10
0.12
-0.013
0.15
0.20
Solid
Fuel-Wall
fired
100-280
0.15
0.15
0.25
0.23
0.30
Solid
Fuel-Vall
fired
>250
mnsbtu/hr
0.20
—0.014
0.18
0.036
(>40
mmbtu/hr)
0.15-0.17
(Depends
on
HRIS)
0.30
0.30
Solid
Fuel
Circulating
FBC
0.15
0.057
(coke)
0.10
0.1
0-0.
17
(Depends
on
lIRE
,
Size)
0.036
(540
mmbtu/hr)
0.20
0.30
0.20
See
Limits
for
Solid
Fuel
Solid
Fuel
Vall
Spreader
Stoker
fired
0,057
(coke)
0.10
0,036
(>40
mmbtu/Itr)
None
0.30
0.20
See
Limits
for
Solid
Fuel
Solid
Fuel
Wall-
Overfeed
Stoker
fired
0.057
(coke)
0.20-0.25
(Depends
on
Size)
0.036
(>40
mmbtu]br)
None
0.30
Solid
Fuel
Underfeed
Stoker
0.20
0.087
(coke)
See
Liusits
for
Solid
Fuel
Wall-
fired
0.20-0.25
(Depends
on
Size)
None
0.30
0.036
(>40
mnibtu/hr)
0.036
(>40
mmbtu/hr)
0.057
(coke)
0.20-0.25
(Depends
on
Size)
0.30
0.057
(coke)
See
Limits
for
0.10-0.15
0.036
Solid
Fuel-
0.057
Solid
Fuel
Wall-
0.30
0.20
(depends
on
0.30
(coke)
(>40
Tangential
fired
fired
Size)
mmbtulhr)
0.036
(>40
mmbtufhr)
HRR
=
Heat
Release
rate,
00i1,
G
=
Gas
Tcxas
NOn
limits
for
oil
are
translated
into
lb/mmtstu
for
comparison
*
Applicable
to
Non-Attainment
counties.
Existing
units.
Ozone
season
Only.
Boilers
=
or
>100
mmBtu/hr.
30-day
rolling
average
**New
units
constructed
after
Feb.
1,
2001.
Non-Attainment
Counties.
Applies
all
year.
For
fuel
oil
or
gaseous
fuel
fired
boilers
limil
applies
to
or
>
25
rnmbtu/hr
Applies
to
NAA5
Only
Attachment
1
NOx
RACT Limits
for
Process
Heaters
in
Illinois
and
Other
States
TSD/NOx
RACT
Regs-other
states.xls/1
0-10-2008
State
IL
(Proposal)
Houston!
GaIv
SCAQMD
Sa;Jaquin
NJ
NY
WI
Attainment
Phase
3
Demo
Effective
Date
1/17/2003
12/20/1993
2/18/94
July
2007
Applicable
Rule
217
Subpart
117.206
1146
4306
197.27
227-2.4
NR
428.04W
Source
Category
Fuel?
Unit
Type
Draft
Type
NOx
Limit,
lb/minbtu
Process
Heaters
>100
0.025
0.036
0.011
Source
Specific
mmBtu/hr
Gas
Fired
Natural
Draft
0.07
(>40
mmbtu/hr)
(>40
mmbtulhr)
mmbtulhr)
0.20
PACT
0.10
0.011
Process
Heaters
>100
.
0.025
0.036
Source
Specific
Gas
Fired
Mech.
Draft
0.07
(>20
0.20
0.10
mmBtu/hr
(>40
mmbtu/hr)
(>40
mmbtu/hr)
mnsbtu/hr)
PACT
0.052
Process
Heaters
>100
.
0.025
0.036
Source
Specific
0.18
mmBtu/hr
Residual
Fuel
atural
Draft
0.10
(>40
mmbtu/hr)
(>40
mmbtu/hr)
mmbtu/hr)
0.20
PACT
(>65
mmBtu/hr)
0.052
Process
Heaters
>100
.
0.025
0.036
Source
Specific
0.18
mmBtu/hr
Residual
Fuel
Mech.
Draft
0.15
(>40
mmbtulhr)
(>40
mmbtu/hr)
mn’hr)
0.20
RACT
(>65
mmBtu/hr)
Process
Heaters
>100
Other
Liquid
Fuels
Natural
Draft
0.05
(>40
mmbtulhr)
(>40
mmbtu/hr)
mmhtu/hr)
0.20
Source
Specific
0.12
Process
Heaters
>100
Other
Liquid
Fuels
Mech.
Draft
0.08
(>40
mmbtu!hr)
(>40
mmbtu?hr)
mmbtu/hr)
0.20
Source
Specific
0.12
Attachment
2
NOx
RACT
Limits
for
Glass
Melting
Furnaces
in
Illinois
and
Other
States
TSD/NOx
RACT
Regs-other
states.xls/10-1O-2008
State
IL
WI
SJVUAJ’CD
SCAQMD
BAAQMD
CT
NJ
MO
Effective
Date
Proposed
July
2007
3/14/1995
12/31/2004
1/1/2001
5/31/1995
Proposed
5/1/2002
Reg.
Number
217
Subpart
F
428.22
(d)
4354
1117
Reg.
9,
Rule
12
22a-174-22
7:27-19.10
1OCSR
10-5.510
Category
NOx
Limit,
lb/Ton
Glass
Produced)
Container
Glass
5
00
2.0
5.5
(Const
<
Jan.99)
4
00
550
5
50
4
00
5
50
Melting
Furnaces
(>50
mmBtu/hr)
4.0
(Const
>
Jan.99)
Flat
Glass
Melting
790
2.0
7-9.2
5.50
5.50
9.20
Furnaces
(>50
rnmBtu/hr)
Other
Glass
Melting
00
2.0
5.5
(Const
<
Jan.99)
5
50
5
50
4
00
Furnaces
(>50
mmBtu/hr)
4.0
(Const>
Jan.99)
Attachment
3
NOx
RACT
Limits
for
Lime
Kilns
in
Illinois
and
Other
States
TSD/NOx
RACT
Regs-other
states.xls/1
0-1
0-2008
State
IL
Houston
Galv
Area
ME
SC
SJVUAPCD
Effective
Date
Proposed
1/17/2003
5/31/1995
5/25/2007
9/27/2003
Applicable
Rule
217
SubpartG
117.206
Chapter
138
62.5
Std.
5.2
4313
Source
Category
NOx
Limit
Rotary
Coal
Fired
2.50
0.66
120.0
175
Kiln
blton
lb/ton
ppm
@10%02
ppm
@10%02
Rotary
Gas
Fired
2.20
0.66
120.0
175
0.10
Kiln
lb/ton
lb/ton
ppm
@10%02
ppm
@10%02
Iblmmbtu
Attachment
4
NOx
RACT
Limits
for
Cement
Kilns
in
Illinois
and
Other
States
TSD/NOx
RACT
Regs-other
states.xIsIl
0-10-2008
IL*
IN*
TN
TX
Ozone
M1*
SC
Ozone
State
IL
Ozone
Season
Ozone
Season
Ozone
Season
Season
Ozone
Season
Season
Effective
Date
Proposed
3/15/2001
8/17/2001
5/31/2004
3/27/2003
12/4/2002
5/31/04
Applicable
Rule
217
Subpart
G
Sut
T
326
JAC
10-3
1200-3-27-.04
R336.1817
61-62.99
Subpart
Source
Category
NOx
Limit,
lb/
Ton
Clinker
Produced
LNB
or
Mid
Kiln
LNB
or
Mid
Kiln
Long
Dry
Kiln
5.10
5.10
5.10
Firing
or
Similar
5.10
5.10
Firing
or
Similar
Controls
Controls
Short
Dry
Kiln
5.10
3
80
3
80
3
80
LNB
or
Mid
Kiln
3
80
3
80
LNB
or
Mid
Kiln
Firing
or
Similar
Firing
or
Similar
Preheater
Kiln
Controls
Controls
LNB
or
Mid
Kiln
LNB
or
Mid
Kiln
2.80
2.80
2.80
Firing
or
Similar
2.80
2.80
Firing
or
Similar
Preheater/Precalciner
Kiln
Controls
Controls
*
Limits
are
either
LNB
or
Mid
Kiln
Firing
or
30%
Reduction
from
Baseline
Attachment
5
STATE OF
ILLINOIS
)
)
SS
COUNTY OF
SANGAMON
)
)
CERTIFICATE
OF
SERVICE
I,
the
undersigned,
an
attorney,
state
that
I
have
served
electronically
the
attached
POST-HEARiNG
COMMENTS
OF
THE
ILLINOS
ENVIRONMENTAL
PROTECTION
AGENCY,
upon
the
following
person:
John
Therriault
Assistant
Clerk
Illinois
Pollution
Control
Board
James
R.
Thompson
Center
100
West
Randolph
St.,
Suite
11-500
Chicago,
IL
60601
and
mailing
it
by
first-class
mail
from
Springfield,
Illinois,
with
sufficient
postage
affixed
to the
following persons:
SEE
ATTACHED
SERVICE
LIST
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY,
.
Gina
Roccaforte
Assistant
Counsel
Division
of Legal
Counsel
Dated:
November
5,
2008
1021
North
Grand
Avenue
East
Springfield,
Illinois
62794-9276
(217)
782-5544
SERVICE
LIST
08-19
Timothy
J.
Fox
Hearing
Officer
Illinois
Pollution
Control
Board
100
W.
Randolph
St., Suite
11-500
Chicago,
IL
60601
Virginia
Yang
Deputy
Legal
Counsel
Illinois
Department
of
Natural
Resources
One Natural
Resources
Way
Springfield,
IL
62702-1271
Katherine
D. Hodge
Monica
T.
Rios
Hodge
Dwyer
Zeman
3150
Roland
Ave.
P.O.
Box
5776
Springfield,
IL 62705-5776
Matthew
Dunn
Chief
Environmental
Bureau
North
Office
of the
Attorney
General
69
W.
Washington
St., Suite
1800
Chicago,
IL 60602
Kathleen
C. Bassi
Stephen
J.
Bonebrake
SchiffHardin
LLP
6600
Sears
Tower
233
S.
Wacker
Drive
Chicago,
IL 60606-6473
Alec
M.
Davis
General
Counsel
Illinois
Environmental
Regulatory
Group
215 E.
Adams
St.
Springfield,
IL
62701