1
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
2
CEVED
CLK’S
OFFICE
FEfl
2009
6
STATE
OF
ILLINOIS
7
IN
THE
MATTER
OF:
)
‘oUution
Control
Board
NITROGEN
OXIDES
EMISSIONS
)
8
FROM
VARIOUS
SOURCE
)
R08-19
CATEGORIES:
)
(Rulemaking
-
Air)
9
AMENDMENTS
TO
35
ILL.
ADM.
CODE
PARTS
211
and
217.
)
10
11
12
Hearing
13
Taken
February
3,
2009
14
15
16
17
18
19
REPORTER:
Bobbi
L.
Hamlin,
RNR
20
Illinois
License
#
084-002797
21
Keefe
Reporting
Company
11
North
44th
Street
22
Belleville,
Illinois
62226
23
24
1
Keefe
Reporting
Company
1
WHEREUPON,
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
OF
2
RECORD:
3
MR.
FOX:
Good
morning,
everyone
and
welcome
4
to
this
Illinois
Pollution
Control
Board
hearing.
5
My
name
is
Tim
Fox.
And
I’m
the
hearing
6
officer
in
this
proceeding
it
is
entitled
Nitrogen
7
Oxides
Emissions
From
Various
Source
Categories:
8
Amendments
to
35
Illinois
Administrative
Code
Parts
211
9
and
217.
The
board
docket
number
for
this
rule
making
10
is
R08—19.
11
The
Illinois
Environmental
Protection
12
Agency
filed
this
rule
making
proposal
on May
9th
of
13
2008
and
The
Board
accepted
it
for
hearing
in
an
order
14
dated
June
5th
of
2008.
15
We
are,
of
course,
holding
today
the
third
16
hearing
in
this
rule
making.
The
first
hearing
took
17
place
on
October
14th,
2008
in
Springfield
and
the
18
second
took
place
over
two
days
on
December
9th
and
19
December
10th,
2008
in
Chicago.
20
I want
to
take
just
a
moment
to
introduce
21
the
other
people
who
are
present
here
from
the board
22
with
me
today.
To my
immediate
left
is
board
member
23
Andrea
Moore,
who
is
the
lead
board
member
assigned
to
24
this
rule
making,
to
her
left
is
board
member
2
Keefe
Reporting
Company
1
Thomas
E.
Johnson
and
to my
right
is
Dr.
Anand
Rao.
We
2
also
refer
to
him --
refer
to you
that way,
apparently,
3
it’s
Mr.
Anand Rao,
who
of
course
is known
to many
of
4
you
from the
board
technical
and scientific
staff.
5
This
proceeding,
as
is all
other
rule
6
making
hearings,
is governed
by
The Board,
its
7
procedural
rules
and
applicable
information
that is
8
relevant
and that
is
not repetitious
or
privileged
will
9
be
admitted
into
the
record
of
this
hearing.
10
Please
note that
any questions
that
are
11
posed
either
by the
board members
or the
staff
are
12
intended
solely
to develop
a
complete
and clear
record
13
of this
proceeding
and
do
not
reflect
any prejudgment
or
14
any
conclusions
regarding
the
merits
of
the
agency’s
15
proposal
or
any
of the
testimony
offered
on
it.
16
The Board
did
receive
pre-filed
testimony
17
for the
second
hearing
from
the
Illinois
EPA
on,
I
18
believe,
January
20th
of 2009,
specifically
the
19
testimony
of
Mr.
Robert
Kaleel,
Mr. Michael
Koerber
and
20
Dr. James
Staudt.
21
And
in speaking
about
procedural
matters
22
with
Ms.
Roccaforte
before
hearing
I believe
she
23
intended
to
offer
those
three
witnesses
in
that
order.
24
And
I
see her
agreeing
that
that
is correct.
3
Keefe
Reporting
Company
1
In
addition
to
the testimony,
pre-filed
2
testimony,
from
the
three
witnesses
on
behalf
of
the
3
Environmental
Protection
Agency
The
Board
did
receive
on
4
Monday,
February
2nd
a
pre-filed
testimony
from
5
Mr.
Blake
Stapper
on
behalf
of
United
States
Steel.
And
6
the
hearing
officer
order
setting
this
hearing
date
and
7
the
order
for
hearings
did
contemplate
that
we
would
8
follow
the
pre-filed
testimony
with
the
testimony
of
any
9
other
witnesses
who
wish
to
testify,
including
those
who
10
did
not
pre-file
at
all.
So,
it’s
my
intention
at
the
11
conclusion
of
The Agency’s
testimony
by
it’s
three
12
witnesses
and
all
of
the
questions
based
upon
that
to
13
proceed
to Mr.
Stapper’s testimony
and any
questions
14
that
the
other
participants
may
have
on
that
testimony.
15
In
addition,
the
board
also
received
16
post-hearing
comments
from
the
Illinois
Environmental
17
Regulatory
Group
or
IERG.
And
I
understand
from
Ms.
18
Hodge
that
IERG
did
not wish
to
offer
any
testimony
19
today
on
the
basis
of
those
post-hearing
comments
from
20
the
second
hearing.
21
MS. HODGE:
That’s
correct,
but
IERG’s
22
counsel,
Alec
Davis,
and
executive
director
probably
23
have
some
questions
for
the
agency.
24
MR.
FOX:
Very
good.
Thank
you.
4
Keefe
Reporting
Company
1
Ms. Hodge,
we
also
received
post-hearing
2
comments
from
Saint-Gobain
from
Mr.
Smith.
3
And
it
was
my
understanding,
Mr. Smith,
4
that
you
did
not
wish
to
offer
testimony
either,
but
5
were
here
perhaps
to ask
some
questions
or perhaps
6
solely
to monitor
the
course
of
that
proceeding.
7
Does
that
sound
correct?
8
MR.
SMITH:
No.
Actually,
I’d
like
to
9
testify,
but
very,
very
brief.
10
MR.
FOX:
Very
good.
Perhaps
what
we
can
11
do
is
have
you
do
so
after
Mr.
Stapper
and
then
we
can
12
proceed
to you
as
soon
as
he’s
complete
and
the
13
questions
are wrapped
up.
14
MR.
SMITH:
Thank
you.
15
MR.
FOX:
Surely.
16
And
we
also
received
post—hearing
comments
17
from
ConocoPhillips.
And
I
believe
that
there
was,
18
while
no
intent
to
testify
on
their
part,
their
19
representatives
may
have
some
questions
that
they
wish
20
to
pose
of
The Agency
and
the
other
witnesses;
is
that
21
correct,
Ms.
Hodge?
22
MS.
HODGE:
That’s
correct.
23
MR.
FOX:
Very
good.
24
And
finally,
we
also
received
some
5
Keefe
Reporting
Company
1
supporting
materials
in
response
to
questions
from
2
The
Board
and
The Agency,
those
materials
from
3
United
States
Steel,
which
I believe
were filed
on
4
Friday
the
30th,
as
well
as I wanted
to
reflect
that
5
those
were part
of
The Board’s
records.
6
MS.
HODGE:
Thank
you.
7
MR.
FOX:
If --
if
any
other
participants
8
do
wish to
testify
and
doesn’t
need
be
right
away,
it
9
certainly
can
be
at a
break,
which
we probably
will
take
10
mid morning,
there
is a sign
up sheet,
it
will
be here
11
on the
counter
next
to
the
court reporter. If
you
would
12
like
to offer
testimony
and did
not
pre-file
it
or
if
13
you
would
like
to offer
a
comment
at the
conclusion
of
14
the
testimony,
please,
do so
just
as a housekeeping
15
matter
so
we can
keep track
of what
we need
to
expect
to
16
allow
time for
and
how long
this
hearing
may run.
17
At the
conclusion
of
the testimony,
18
pre—filed
and
otherwise, we
will,
as
time
allows,
19
provide
an opportunity
for
people
to
offer
comments
20
those,
of course,
are
not sworn
but we
will
make
21
every ——
make every
effort
to
include
an
opportunity
--
22
opportunity
for
people
to offer
those.
I
am
aware
of at
23
least
one
person
who would
like
to offer
a comment.
24
For the
benefit
of
the
court
reporter,
6
Keefe
Reporting
Company
1
finally,
who’s
transcribing
our
hearing
today,
please,
2
make
an
effort
to
speak
clearly.
We
can,
as I
said,
3
activate
the
public
address
system
if
that’s
helpful.
4
And,
please,
avoid
talking
at
the
same
time
as
any
other
5
person
I know
that
will
simplify
her
task
and
help
us
6
have
a
clearest
possible
transcript.
7
I do
want
to
take
care
of
just
one
or
two
8
quick
housekeeping
matters.
9
In
looking
over
the
transcript
of our
-—
10
our
last
hearing
on
December
10th
we had
in
the course
11
of
that
hearing
effectively
reserved
Exhibit
Numbers
15
12
and
16
for
two
USEPA
charts
that
related
to Midwest
13
Generations
Boiler
Number
3
and
Joliet
Number
71
Boiler
14
respectively.
Ms.
Bassi,
at
that
hearing
indicated
that
15
she
would
submit
those
into
the
docket.
I
believe
that
16
there
was an
issue
of
both
the
number
of
copies,
the
17
quality
of the
copies
and
the
availability
of
another
18
copy
that
did
have
the
USEPA
web
page
on
the document
19
all
of
which
would
help
make
it
a
little
clearer
and
a
20
little
more
useful
for
the
record.
Ms.
Bassi
had
21
indicated
that
she
would
submit
those
to
the
board
that,
22
quote,
improved
copy,
which
she promptly
did
in
a
file
23
on
December
19th
and
that
she
would
then
propose
24
admission
formally
into
the
record
under
the
exhibit
7
Keefe
Reporting
Company
1
numbers
that
we
had
set
aside.
2
And
Ms. Bassi,
that
sort of
sets you
up
for
3
any motion
that
you may
wish
to
offer.
4
MS.
BASSI:
Thank
you.
5
I would
move
to offer
Exhibit
Number
15
6
titled
Baldwin
3 and
Exhibit
Number
16
titled
Joliet
71
7
Boiler
into
the
record
as exhibits.
8
And
I would
like
to show
Baldwin
3 to
9
Mr.
Philbright
here,
who
is from
Baldwin.
10
MR.
FOX:
Mr.
Philbright
from --
11
MS.
BASSI:
Who
is from
Dynegy.
12
MR.
FOX: And
I
should
have noted
in
13
speaking
earlier
that
Ms.
Bassi not
only
had
served
14
those
on
The Board,
but on
the service
list.
15
MS. BASSI:
That’s
correct.
16
MR. FOX:
And
at
this point
I’ll
ask
I
17
can’t
recall,
Ms.
Bassi,
I’m
sorry
if you
had
formally
18
moved
to -—
those
into the
record.
19
Was there
any
objection
to
the
admission
of
20
those
documents
as Exhibits
Number
15 and
16?
21
(No
response.)
22
MR.
FOX:
Neither
seeing
nor
hearing
any,
23
Ms.
Bassi,
they will
be
admitted
under
those
docket
24
numbers
we
had
reserve
on
the
hearing
on December
10th.
8
Keefe Reporting
Company
1
MS. BASSI:
Thank
you.
2
MR.
FOX:
Secondly,
I
did
want
to note
also
3
I’m
sure
all
of you
are
aware
Friday,
January
30th,
2009
4
the
Illinois
Environmental
Protection
Agency
did
file
a
5
motion
to
amend
it’s
rule
making
proposal.
That
motion
6
is
directed
to
The
Board.
And
the
14-day
response
7
period
has
not
yet
run.
However,
that
motion
to
amend
8
is
in
the
record
in
these
proceedings
and
we
can
deal
9
today
with
any
questions
or
comments
that
may
arise
on
10
the
substance
of
this
motion.
Certainly,
The
Board
will
11
take
that
up
at
very
quick
opportunity
to
address
the
12
merits
of
that
motion.
13
Any
questions
about
our
procedures
or
any
14
procedural
issues
that
anyone
wishes
to
address
before
15
we
get
under
way?
16
MS.
ROCCAFORTE:
I
would.
17
MR.
FOX:
Ms.
Roccaforte?
18
MS.
ROCCAFORTE:
Good
morning.
19
My
name
is
Gina
Roccaforte,
assistant
20
counsel
one
behalf
of
the
Environmental
Protection
21
Agency.
And
with
me
today
are
Dana
Vetterhoffer,
22
assistant
counsel;
Shannon
Bilbrook,
legal
specialist;
23
Robert
Kaleel,
Manager
of
the
Air
Quality
Planning
24
Section
Division
of
Air
Pollution
Control
Bureau
of
Air;
9
Keefe
Reporting
Company
1
Mike
Koerber,
Executive
Director
Lake Michigan
Air
2
Directors
Consortium;
and Dr.
James
Staudt,
President
3
Andover
Technologies
Partners;
also
two
engineers
in
the
4
Bureau
of
Air
Vera
Hoopta
and
Hojin
Maji.
5
I’d
just
like
to
note
for the
record
that
6
the
agency
objects
to
the
pre-filed
testimony
of
7
Blake
Stapper
on
behalf
of
United
States
Steel
8
Corporation.
9
As
you indicated
pre-filing
deadline
for
10
this
testimony
was
January
20th,
20009
and
Mr.
Stapper’
s
11
testimony
was
filed
yesterday
and
we haven’t
had
12
adequate
time to
prepare
for
this
hearing.
13
And
I’d also
like
to note
for
the record
14
that
at
the December
10th hearing
information
was
15
requested
of United
States
Steel
Corporation
and
16
u.s.
steel
submitted
these
supporting
materials
last
17
Friday,
which
hasn’t
given
us much
time
to prepare,
but
18
we
will
do our
best.
19
Thank
you.
20
MR. FOX:
Very
good.
Thank
you,
21
Ms.
Roccaforte.
22
Any
—- any
further
comments
before
we
get
23
under
way
with
the substantive
testimony
and questions?
24
(No
response.)
10
Keefe
Reporting
Company
1
MR.
FOX:
Very
good
2
Ms.
Roccaforte,
you
had
indicated
that
it
3
made
the
most
sense
to
proceed
from
Mr.
Kaleel,
to
4
Mr.
Koerber,
to
Mr.
Staudt.
Does
it
make
the
most
sense
5
to
swear
them
all
in
at
once
and
simply
take
care
of
6
that
before
the
agency
begins?
7
MS.
ROCCAFORTE:
That
would
be
fine.
8
MR.
FOX:
Excellent.
9
WHEREUPON,
ROBERT
J. KALEEL,
DR.
JAMES
E.
STAUDT
AND
10
MICHAEL
KOERBER
WERE
FIRST
DULY
SWORN
AND
THEN
TESTIFIED
11
AS FOLLOWS:
12
MS.
ROCCAFORTE:
Forgive
me,
did
you
enter
13
the
testimony
--
14
MR.
FOX:
Yes.
I’m
sorry,
I
will
make
that
15
clear
that
under
The Board’s
procedural
rules
the
16
provision
is,
I
believe
it’s
in
Section
102424
F
of
17
The Board’s
procedural
rules
the
pre-filed
testimony
18
will
be
entered
as
if
read.
19
And
Ms.
Roccaforte,
if
you
wish
to
begin
20
with
a
brief
summary
or
any
other
introduction,
please,
21
feel
free
to do
that.
22
MS.
ROCCAFORTE:
I have
introduced
my
23
witnesses
and
I
believe
they
may
have
statements
-— I’ve
24
introduced
them
and
I
believe
they
will
each
make
a
1]
Keefe
Reporting
Company
1
brief
statement.
2
MR.
FOX:
Very
well.
3
Mr.
Kaleel,
it
looks
like
we’re
ready
for
4
you
if
you’re
set
to
begin.
5
MR.
KALEEL:
Thank
you.
6
I
appreciate
The
Boards’s
attention
to
this
7
matter
having
this
third
hearing.
We
--
we
hope
that
8
we’re
able
to
clarify
the
record
about
this
ongoing
rule
9
making.
10
The purpose
of
my
pre-filed
testimony
--
at
11
least
one
of the
purposes
was
to
explain
the
contents
of
12
the
amendment
that
was
recently
filed
with
The
Board.
13
At
the
time
that
I
wrote
that
testimony
we
were
still
14
working
on
an
amendment. And
in
fact,
we’re
continuing
15
to
work
with
affected
industries
and
anticipate
a
future
16
amendment
as
well.
17
There
are
a
couple
of
things
that
I’d
like
18
to
clarify
about
my
testimony
with
respect
to
what
19
either
was
included
in
the
amendment
or not
and
also,
20
some
additional
efforts
that
we have
with
the
group
of
21
stakeholders.
22
First
off,
I
think
my
testimony
had
23
mentioned
on
page
one
that
the
Illinois
EPA
was
24
recommending
a
compliance
date
for
refineries
to
12
Keefe
Reporting
Company
1
coincide
with
already
planned
maintenance
turnarounds.
2
That
language
was,
in
fact,
not
included
in
the
3
amendment,
so
I
just
wanted
to
note
that,
that
we
4
anticipated
we’d
be
able
to
include
language
in
our
5
amendment
and
we —-
we’ve
not
been
able
to
finalize
that
6
yet.
I
would
note
that
we
are
still
working
on
this
and
7
we
have
every
expectation
that
we’ll
be
able
to
work
out
8
this
issue
with
the
affected
industries,
but
that
9
amendment
is
not
--
that
language
is
not
included
in
the
10
amendment
that’s
now
before
The
Board.
11
Also
in
my
testimony
we
anticipated
12
continuing
to
work
with
two
companies,
Saint-Gobain
13
Containers
and
also
Midwest
Generation.
And
at
the
time
14
that
I
wrote
the
testimony
we
didn’t
really
have
those
15
discussions
completed.
I’m
pleased
to
report
to
16
The
Board
that
we
have
completed
discussions
with
these
17
companies.
I
guess
at
least
from
The
Agency’s
18
perspective
the
amendments
that
are
now
before
The
Board
19
resolve
the
outstanding
issues
or
comments
provided
by
20
both
of
those
companies.
21
So,
I
think
--
I
think
those
--
those
22
issues
are
resolved
by
this
amendment.
23
I
think
that
concludes
my
opening
24
statement.
13
Keefe
Reporting
Company
1
MR.
FOX:
Very
good.
Thank
you,
Mr.
2
Kaleel.
3
Were
there
any
questions
that
any
of
the
4
participants
had
for
Mr.
Kaleel
on
the
basis
of
his
5
statement
or
his
provided
testimony
here
today?
6
Ms.
Bassi,
I’m
sorry,
through
the
glare
I
7
didn’t
see
you
right
away.
8
MS.
BASSI:
Pm
I
out
of
the
glare?
9
Thank
you.
10
Do
you
--
how
would
you
like
us to
do
this?
11
Would
you
like
us
to
file
a
reply
to
this
testimony?
12
I’m
speaking
on
behalf
of Midwest
13
Generation.
14
Would
you
like
us
to
file
a response
to
15
this
motion
to
amend
or
would
you
like
us
to
just
16
express
our
response
today?
17
MR.
FOX:
If
there
was
a
response
that
you,
18
on
behalf
of
your
clients,
wish
to
make
either
opposed
19
to or
in
favor
of the
motion
you
certainly
would
be
free
20
to
do
that.
The
14-day
deadline
would
not
run
until
21
Friday
the
13th
of
February
that
certainly
would
be
22
in
--
in
order,
Ms.
Bassi,
if
that
answers
your
23
question.
24
MS.
BASSI:
My
client
is
not
here
today,
14
Keefe
Reporting
Company
1
but
we have
reviewed
this
motion
and
we do
accept
the
2
motion
as
far
as
it
applies
to Midwest
Generation.
And
3
we
would
waive
any
further
time
for
The
Board
to address
4
the
motion
at
least
as
far
as
Midwest
Generation
goes.
5
MR.
FOX:
So
noted,
Ms.
Bassi.
Thank
you.
6
MS.
BASSI:
Thank
you.
7
MR.
FOX:
I think
there
was
one other
--
8
very
good.
Thank
you.
9
Ms.
Hirner.
10
MS.
HIRNER:
Thank
you
very
much.
11
Deirdre
Hirner,
Executive
Director.
12
I’d
like
to
say
I think
the
IERG
and
it’s
13
members
are
reviewing
the
motion
that
was
submitted
by
14
The
Agency.
We think
it’s
--
we
appreciate
The
Agency’s
15
efforts
to
work
with
the
impacted
regulated
community.
16
And
we
think
it’s
a
good
step
in
the
right
direction,
17
but
we’re
still
reviewing
it
for
particular
impacts.
18
With
that
I
do have
some
questions
for
19
Mr.
Kaleel.
20
MR.
FOX:
Please
proceed,
Ms.
Hirner.
21
MS.
HIPNER:
I’m
going
to kind
of
tie
these
22
together
these
references,
the
bottom
of pages
two
and
23
the
bottom
of
page
three
of your
pre-filed
testimony.
24
We
have
some
specific
questions
that
we
may
follow
up
15
Keefe
Reporting
Company
1
on, but
in
light
of
some
of
the
proposed
changes
that
2
we’ve
seen
in the
motion
just
a
couple
just
to
clarify
a
3
bit
of
confusion
that
we
have
about
the purpose
of
this
4
proposed
rule.
5
So,
as we
look
at
the
language
of
the
rule
6
and
some
of
the other
issues
that
have
been
addressed
in
7
separate
regulatory
actions
by
the
agency,
more
8
specifically
those
that
deal
with
the
ozone
designation
9
and
maintenance
plan.
So,
the
qiiestion
I’m
going
to
ask
10
goes
to
the
purpose
of
the
proposed
rule.
Is
this
rule
11
before
us
intended
by
The Agency
to
be
a
NOx
RACT
rule
12
designed
to
achieve
a 1997
ozone
standard
and
the
old
13
PM
2.5
standard
or
is
the
purpose
of
this
rule
now
to
be
14
a
NOx
control
rule
that’s
designed
to
meet
some
yet
15
uncertain
emissions
levels
that
will
need
to
be
achieved
16
to
address
the 2006
PM
2.5
24-hour
standard
and
the
2008
17
ozone
standard?
18
MR.
KALEEL:
That’s
quite
a
question.
19
Maybe
I’ll
try
to
break
this
down.
20
I think
there’s
been
testimony
filed
by
me
21
and
also
answered
numerous
questions
on
this
in terms
of
22
the purpose
of
the
rule
making.
I
think
--
I
think
23
we’ve
been
clear
on
the
record
that
—-
that
this
rule
is
24
intended
to
address
the
requirements
for
NOx
RACT
16
Keefe
Reporting
Company
1
reasonably
available
control
technology
for
our
ozone
2
and
PM
2.5
non-attainment
areas
and
we
believe
that
this
3
requirement
will
do
that.
4
The
RACT
requirement
is
tied
to
the
1997
5
ozone
standard
and
also
tied
to
the
1997
PM
2.5
6
standard.
It
isn’t
the
same
question
that
we
are
7
relying
upon
these
reductions
to
attain
those
standards.
8
The
whole
purpose
of
a
control
program,
of
9
course,
is
to
reduce
emissions,
in
this
case
of
nitrogen
10
oxides,
that
will
achieve
or
is
intended
to
achieve
11
improvements
in
air
quality
both
in
the
non-attainment
12
area
and
downwind
of
the
non-attainment
area.
13
It
is
true
that
the
Chicago
area
is
14
attaining
the
1997
ozone
standard
based
on
the
three
15
most
recent
years
of
ozone
data
and
that
that
was
at
16
least
one
of
the
purposes
of
the
public
hearing
17
sponsored
by
the
agency
in
December
in
Chicago
was
to
18
present
the
maintenance
plan
as
required
by
USEPA
to
19
support
the
re-designation
petition
for
the
1997
20
standard.
21
Metro
East
area
does
not
attain
the
1997
22
standard
for
ozone
or
PM
2.5.
There
are
areas,
and
I
23
think
Mike
Koerber
will
address
this
in
his
testimony
as
24
well,
there
are
areas
directly
downwind
of
Chicago
that
Keefe
Reporting
Company
1
are
impacted
by Chicago
that
have
not
yet
attained
the
2
1997
standard
and
certainly
have
not
attained
the
new
3
recent
revised
ozone
standards.
4
So,
the
purpose
of
the
rule
is
to
achieve
5
improved
air
quality,
but
it
also
is
intended
to address
6
the
NOx
PACT
requirement.
We
don’
t
and
have
never
7
characterized
NOx
PACT
as
being
the
only
program
that
8
will
bring
us
into
attainment
of
any
of
these
standards.
9
It’s
one
element
of
a very
complex
suite
of
control
10
measures
that
the
agency
is
relying
on
to address
11
attainment
of
both
of
those
standards.
12
MR.
DAVIS:
Alec
Davis,
also
on
behalf
the
13
IERG.
14
Mr.
Kaleel,
you described
the new
standards
15
both
for
ozone
and
you
described
the
new
ozone
and
16
PM
2.3
standard
both
in
your
testimony
and
in
your
17
response
just
now.
18
When
will
the
Illinois
EPA
be able
to
make
19
a
determination
regarding
NOx
PACT
requirements
for
20
these
new
standards?
21
MR.
KALEEL:
Obviously,
we’re
just
now
22
beginning
on the
process
to
address
the new
standards.
23
As I
mentioned
in my
testimony
USEPA
just
in
December
of
24
2008
had
established
the
boundaries
for
PM
2.5
the
18
Keefe
Reporting
Company
1
24-hour
standard,
so
that
that’s,
obviously,
very
recent
2
development
ozone
standard
that
was
revised
last
year.
3
We
still
haven’t
even
made
a recommendation
to USEPA.
4
The
USEPA
has
not
acted
yet
establishing
non-attainment
5
boundaries.
We
do
know
that
the
Metro
East
area
and
the
6
Chicago
area
will
not
be
attaining
or
are
not
attaining
7
the
new
ozone
standard.
We
expect
that
USEPA
will
act
8
to
finalize
the
non-attainment
boundaries
some
time
in
9
2010.
If
they
do
that
we
would
be
required
to
provide
a
10
SIP
provision,
State
Implementation
Plan,
revision
three
11
years
after
that.
So,
that
would
be
some
time
in
2013.
12
I
don’t
know
exactly
when
a
RACT
demonstration
will
be
13
required
for
that
new standard.
We
know
that
there
will
14
be
a
requirement
to
address
RACT
for
the
new
standard.
15
The
RACT
requirement
is
--
is
hardwired
16
into
the
Clean
Air
Act,
so
we
know
that
there
will
be
a
17
RACT
requirement
for
these
non—attainment
areas
for
the
18
new
standards,
obviously,
with
a
—-
with
a
later
date
19
than
as
required
by the
1997
standard.
20
I
add
to
that
we
fully
expect
that
the
NOx
21
RACT
limits
that
we
are
proposing
today
would
be
22
adequate
and
we
would
support
this
before
USEPA
would
be
23
adequate
to
address
the NOx
RACT
requirement
for
the
24
future
standards.
So,
as
long
as
they
are
implemented
19
Keefe
Reporting
Company
1
in
time
The
Board
is
--
has
finalized
those
2
requirements,
we
believe
that
this
would
address
those
3
requirements
at
least
for
those
areas
and
those
sources
4
that
are
affected
by
this
proposal.
5
MS. HIRNER:
So,
if
I
could
please,
just
to
6
clarify,
you
said
this
NOx
PACT
rule
will
satisfy
NOx
7
PACT
for
the
future
rule,
the
new
standard,
I’m
sorry,
8
for
the
new
standards?
9
MR.
KALEEL:
I
don’t
think
I
said
it
quite
10
like
that,
but
that
would
be
our
contention.
If
11
there’s
--
if
there’s
a
breakthrough
in
technology
12
between
now
and the
time
that
we
have
to
address
the
13
eight-hour
standard
that
makes
a
different
control
level
14
reasonably
available
it’s
possible
that
we
would
need
to
15
amend
this
proposal,
but
we
believe
given
the
short
16
amount
of
time
that
we
have
that
this
requirement
would
17
satisfy
NOx
PACT
for
the
future
standards
for
the
areas
18
and
for
the
sources
that
are
affected
by
this
proposal.
19
MR.
DAVIS:
Thank
you.
20
I’d
like
to
know
has
the
Illinois
EPA
21
drafted
a
draft
NOx
PACT
--
NOx
PACT
SIP
for
these
22
current
standards?
23
MR.
KALEEL:
I
guess
I’m
not
quite
certain
24
the
nature
of
this
question.
20
Keefe
Reporting
Company
1
This
--
this
proposal
when
it
--
when
it’s
2
adopted
by
The
Board,
presuming
it
is
adopted
by
3
The
Board,
would
be
part
of
our
overall
attainment
4
demonstration
SIP.
We
would
--
we
would
submit
these
--
5
these
rules
when
finalized
along
with
other
supporting
6
documentation
to
USEPA
with
a
statement.
And
I
guess
7
this
is
what
you’re
asking
whether
the
statement
is
in
8
a
--
the
form
of
a
letter
saying
we’ve
adopted
NOx
RACT
9
and
this
constitutes
our
submittal.
I
mean,
it
could
be
10
just,
I
don’t
mean
to
be
flippant,
but
it
could
be
that
11
our
indication
USEPA
is
just
that
simple,
here’s
--
12
here’s
the
proposed
rule
or
here’s
the
final
rule,
13
here’s
--
here’s
the
evidence
that
we
have
all
the
14
technical
support
that
we
relied
upon,
here’s
the
15
evidence
of
hearing
I
mean,
these
are
the
kinds
of
16
things
that
USEPA
would
require
in
a
submittal.
So,
I
17
think
--
I
think
this
rule
making
constitutes
NOx
RACT.
18
I
don’t
know
if
I
exactly
answered
your
19
question.
20
MS.
HIRNER:
Just
again
to
clarify,
so
when
21
this
is
submitted,
and
we’re
thinking
about
this
in
the
22
context
of
the
--
the
federal
sanctions,
so
will
this
23
meet
a
deadline
to
prevent
possible
federal
sanctions?
24
MR.
KALEEL:
I
guess
--
I
guess
we
hope
so.
21
Keefe
Reporting
Company
1
Obviously,
we
—- we
don’t
--
we
don’t
set
The
Board’s
2
calendar.
We
can’t
predict
when
The
Board
will
take
3
action
on
this..
They
--
I
mean,
they
certainly
are
4
aware
of the
sanctions
issue
we’ve
--
we’ve
highlighted
5
that
in
our
statement
of
reasons.
So
-— so,
we
—— we
6
hope
it
does.
And
to
the
extent
that
the
--
the
rule
7
making
is
still
pending
at
the
point
that
the
sanctions
8
kick
in
I
think
at
that
point
we’d
have
some
discussions
9
with
USEPA
to
see
if
they’re
satisfied
that
we
made
10
enough
progress
to avoid
the
sanctions.
I
—- I
—- I
11
guess
it’s
--
given
that
it’s
statutory
I
--
I
--
I
12
don’t
know
whether
a pending
rule
would
be
sufficient
to
13
avoid
the
sanctions.
14
MR.
DAVIS:
Okay.
Thank
you.
15
My
last
question
I’d
like
to
ask
just
a few
16
really
quick
clarifications
regarding
the CAIR
Rule
17
Program
that
you
described
on
page
three
of
your
18
testimony.
19
You
state
that
the
Illinois
EPA
will
be
20
developing
a
regulatory
proposal
to
incorporate
non-EGUs
21
in
the
CAIR
Program
for
the
purpose
of non-EGUs
meeting
22
their
emission
budget
obligations
under
the
Federal
NOx
23
SIP
program.
24
Would
you
say
that’s
a
correct
22
Keefe
Reporting
Company
1
characterization
of
your
testimony?
2
MR.
KALEEL:
Trying
to
go
back
and
find
the
3
specific
language
in
my
testimony.
Excuse
me.
4
MR.
DAVIS:
It
1
s
the
first
paragraph
on
5
page
three.
6
MR.
KALEEL:
I
think
the
way
you
phrased
7
the
question
is
the
Illinois
EPA
working
on
a
proposal
8
to
include
the
non-EGUs
in
the
trading
program.
That
9
isn’t
what
my
testimony
says.
10
What
I
intended
to
say
is
that
the
NOx
SIP
11
Call
budget
that
was
established
for
the
non-EGUs
that
12
that
budget
still
applies
under
CAIR.
There
is
an
13
obligation
upon
the
State
of
Illinois
to
--
to
--
to
14
address
how
it
intends
to
ensure
that
that
budget
is
15
being
maintained
in
Illinois
given
that
the
NOx
SIP
Call
16
rules
will
soon
be
sunset
as
a
result
of
the
CAIR
Rule
17
making
we
--
we
know
that
we
need
to
address
that
both
18
sunsetting
the
CAIR
Rule
for
EGUs
and
to
address
in
some
19
fashion
the
budget
or
the
emission
cap
for
non-EGUs.
20
That
isn’t
the
same
thing
as
saying
that
the
non-EGUs
21
will
be
included
in
the
trade.
22
MR.
DAVIS:
What
is
the
current
23
compliance
-—
compliance
status
affected
units
that
are
24
subject
to
the
non-EGU
NOx
SIP
Call
Program
provided
for
23
Keefe
Reporting
Company
1
in
sub
part
U
that
is,
excuse
me,
are
affected
units
2
required
to
hold
allowances
for
the
2009
compliance
year
3
even
though
they
have
not
been
given
the
allowances
4
specified
by
sub
part
U?
5
MR.
KALEEL:
Well,
I
guess
I would
note
6
that
this
rule
--
this
rule
making
before
us
right
now
7
is
not
a
sub
part
U
rule
making.
My
--
my
understanding
8
and
I
did not
look
at
this
specifically,
but
my
--
my
9
understanding
is
that
--
that
the
rule
would
work
in
the
10
manner
that
--
that
you
described
and
we
understand
11
that
--
that,
because
the
non-EGU5
are
not
in
CAIR,
they
12
will
not
be
receiving
allocations
under
the
SIP
13
programs.
We
recognize
the
problem.
14
MR.
DAVIS:
Okay.
Thank
you.
15
That’s
all
from
us.
16
MR.
FOX:
Thank
you.
17
Any
further
questions
at
this
point
from
18
any
participant
for
Mr.
Kaleel?
19
Mrs.
Hodge?
20
MS.
HODGE:
Yes.
Okay.
I
have
just
a
21
couple
questions.
22
I
don’t
think
this
is
working..
Can
you
23
hear
me?
24
MR.
FOX:
You’re
quite
clear.
Yes.
24
Keefe
Reporting
Company
1
MS.
HODGE:
Okay.
Mr.
Kaleel,
when I
read
2
through
the
pre-filed
testimony
of The
Agency
for
3
today’s
hearing
I
noted
that The
Agency’s
witness,
4
Dr.
Staudt,
indicated
that
ConocoPhillips
has not
made
5
available
it’s
information
to support
the
cost
6
associated
with
recent
ultra
Low-NOx
burn
projects
at
7
the
Wood
River Refinery.
8
Are
you
aware
that
ConocoPhillips
submitted
9
cost
information
to
the agency
in
January
of
2008?
10
MR.
KALEEL:
Yes,
I am
aware
of that.
11
MS.
HODGE:
Has
the agency
reviewed
this
12
information?
13
MR.
KALEEL:
We
-- we
have
reviewed
it,
14
yes.
15
MS. HODGE:
Has
the
agency
made
it
16
available
to
Dr. Staudt
for
review?
17
MR.
KALEEL:
We
have
not
made
it
available
18
to
date.
19
We noted
in
that
the
information
was
20
provided
to the
agency
with
a claim
of confidentiality
21
and
we ——
we ——
we’ve respected
that.
We’ve
not
shared
22
it
with
Dr.
Staudt.
23
We have
requested
through
-- through
you
24
and ConocoPhillips
that
Dr.
Staudt
be
allowed
to review
25
Keefe Reporting
Company
1
this
information,
but
to date
he
has
not.
We’ve
not
2
received
it,
any assurance
from
you
or
ConocoPhillips
3
that
that
would
not
be
a
problem.
4
MS.
lIODGE:
And
when
did
the
agency
make
5
this
request?
6
MR.
KALEEL:
We made
the
request
after
the
7
December
9th
hearing.
I don’t
remember
the
specific
8
date.
9
We
also
weren’t
aware
before
the
10
December
9th
hearing
that
ConocoPhillips
would
be
filing
11
that
information
to The
Board
or
making
this
information
12
available
to
The
Board,
so
we
didn’t
really
see
a
need
13
to
share
that
information
with
Dr.
Staudt
prior
to the
14
December
9th
hearing.
15
We
--
we
fully
anticipated
and
still
16
anticipate
continuing
dialogue
with
ConocoPhillips
about
17
that
information
and
about
their
specific
concerns
with
18
the
rule.
We
weren’t
aware
that
they
were
going
to
19
actually
file.
20
MS.
HODGE:
Do you
think
it
was
on
or
about
21
January
the
19th
of
2009
when
The
Agency
made
that
22
request?
23
MR.
KALEEL:
I
--
I
don’t
recall
the
24
specific
date,
but
yeah,
it
was
in
January.
26
Keefe
Reporting
Company
1
MS.
HODGE:
Okay.
That’s
all
I
have.
2
Thank
you.
3
MR.
FOX:
Thank
you,
Ms.
Hodge.
4
Any
--
any
further
questions
for
Mr.
Kaleel
5
this
morning?
6
(No
response.)
7
MR.
FOX:
Seeing
--
seeing
none,
8
Ms.
Roccaforte,
it
looks
like
it’s
an
appropriate
time
9
to
go
to
Mr.
Koerber
if
he
had
a
brief
statement
or
10
summary
he
would
like
to
offer
it
appears
to
come
to
11
that
time.
12
Mr.
Koerber,
please
go
ahead.
13
MR.
KOERBER:
I
wish
to
emphasize
two
14
points
in
my
pre-filed
testimony.
Number
one:
My
15
testimony
summarizes
the
air
quality
analyses
performed
16
by
LADCO
and
it’s
contractors,
it
supports
data
and
17
implementation
plans
for
ozone
fine
particles
and
K’s
in
18
the
states
of
Illinois,
Indiana,
Michigan,
Ohio
and
19
Wisconsin.
The
variety
of
technical
analyses
provide
a
20
weight
of
evidence
approach
for
the
states
attainment
21
demonstration.
22
Number
two,
current
ozone
air
quality
23
monitoring
data
in
our
model
projections
show
that
one
24
location
in
the
Lake
Michigan
area
is
not
attaining
1997
27
Keefe
Reporting
Company
1
version
of the
eight-hour
ozone
standard
namely
Holland,
2
Michigan
on the
west coast
of Michigan.
Pursuant
to
the
3
Energy
Policy
Act of
‘05 EPA
is required
to address
the
4
Western
Michigan
ozone
problem.
My
written
testimony
5
anticipated
the
release
of EPA’s
Western
Michigan
ozone
6
study
report
that
did happen
on
January
2
1st.
And
I
7
brought
paper
copies
of
it
to
The
Board
today.
I want
8
to
hand
those
out.
I
don’t
know
how that
happens.
9
The
report
is available
electronically
on
10
EPA
Region
five’s
web site.
11
Two
key
findings
in
EPA’s
report
are
number
12
one,
Holland,
Michigan
does not
now
nor
will
by
it’s
13
attainment
date
meet the
1997
version
of
the
eight-hour
14
ozone
standard.
15
And
number
two,
shoreline
areas
in
Western
16
Michigan
like Holland
are
dominated
by
ozone
transport,
17
for
example,
the
technical
analyses
show
that
18
one—quarter,
25
percent,
of the
ozone
on
high
19
concentration
days at
Holland
is
from
Northeastern
20
Illinois.
21
Thank
you.
That
concludes
my
summary
of
my
22
testimony.
23
MS.
ROCCAFORTE:
I have
some
questions
for
24
Mr.
Koerber.
28
Keefe
Reporting
Company
1
MR. FOX:
Please,
go ahead,
Ms.
Roccaforte.
2
MS.
ROCCAFORTE:
Has
LADCO
conducted
any
3
sensitivity
analyses
using
the
air
quality
model
to
4
determine
whether
NOx
emissions
reduction
improved
ozone
5
in
2.5
air
quality?
6
MR.
KOERBER:
Yes.
The weight
of evidence
7
approach,
as
I
indicated,
includes
a
variety
of
8
technical
analyses.
One
of
the
technical
analyses
was
9
to
look
at
the
sensitivity
reducing
ozone
precursors
10
such
as
VOCs,
organic
compounds
or
oxidized
nitro
NOx.
11
The
technical
analyses
did
show
that
reduction
in
VOC,
12
reduction
in NOx,
would
improve
ozone
concentration
in
13
downwind
areas.
14
MS.
ROCCAFORTE:
In general
would
you
say
15
that
additional
NOx
reductions
yield
additional
air
16
quality
benefits?
17
MR.
KOERBER:
Sensitivity
analyses
did
show
18
that
more
emission
reduction
resulted
in
more
19
improvement
in
air
quality.
20
MS.
ROCCAFORTE:
Do
you
know
if
the
21
St.
Louis
Metropolitan
area
attained
the
1997
ozone
22
standard?
23
MR.
KOERBER:
Based
on
the 2006
to
2008
24
monitoring
data
it
has
not.
I
believe
there’s
at
least
29
Keefe
Reporting
Company
1
one
location
that
is
out
of
compliance
with
the
1997
2
version
of
the
standard.
3
MS.
ROCCAFORTE:
And
isn’t
it
true
that
4
USEPA
tightened
the
ozone
standards
in
2008?
5
MR.
KOERBER:
In
March
of
2008
Rob
Kaleel
6
did
indicate
the
EPA
lowered
ozone
standards
from
85
7
parts
billion
to
75
parts
per
billion.
8
MS.
ROCCAFORTE:
Is
the
Chicago
area
9
attaining
that
standard?
10
MR.
KOERBER:
The
new
lower
standard?
11
MS.
ROCCAFORTE:
Yes.
12
MR.
KOERBER:
It
is
not
attaining
the
new
13
75
EPA
standard.
14
MS.
ROCCAFORTE:
Do
you
know
if
the
15
St.
Louis
area
is
attaining
that
standard?
16
MR.
KOERBER:
It
is
not.
And
again,
that’s
17
based
upon
monitoring
data,
real
world
measurements,
18
collected
by
this
agency.
19
MS.
ROCCAFORTE:
Last
question:
Was
20
Illinois’s
NOx
RACT
proposal
included
in
the
2012
model
21
run
that
demonstrated
attainment
of
the
1997
ozone
22
standard
in
Holland,
Michigan?
23
MR.
KOERBER:
The
NOx
RACT
emission
24
reductions
were
included
along
with
a
nuitiber
of
other
30
Keefe
Reporting
Company
1
control
measures
there
are
a bundle
of
control
measures
2
this
were
included
in
this
modeling
in
order
to
show
3
what
the
future
air
quality
would
be.
4
MS.
ROCCAFORTE:
Thank
you.
5
MR.
FOX:
That’s
it?
6
Any
further
questions
for
Mr.
Koerber
this
7
morning?
8
Ms.
Hirner
or
Mr.
Davis,
I
see
both
of
you
9
indicating.
10
MR.
DAVIS:
Thank
you.
11
Mr.
Koerber,
I’d
like
to
ask
you
a
few
12
questions
about
the
role
that
base
year
choice
and
13
meteorology
played
in
the model
results.
14
You
state
that
meteorology
similar
to
2002
15
will
make
it
less
likely
that
the
ozone
standard
will
be
16
attained,
this
is
referring
to bottom
of
page
five
and
17
top
of
page
six
of
your
testimony.
18
Is
that
an
accurate
statement?
19
MR.
KOERBER:
Ozone
is
very
sensitive
to
20
two
primary
parameters,
the
emissions,
the
ozone
21
precursor
emissions
and
meteorology.
So,
hotter
summers
22
result
in higher
ozone
concentrations.
So
our
latest
23
modeling
analysis
was
included
in
our
technical
support
24
document
relying
on 2005
meteorology
we
found
to
be
31
Keefe
Reporting
Company
1
above
normal
based
on
statistical
analyses,
but
not
as
2
severe
in 2002.
2002
was
very
extreme
meteorology
and
3
resulted
in
much
higher
ozone
concentrations.
4
MR.
DAVIS:
Thank
you.
5
Could
you
elaborate
perhaps
a
little
bit
on
6
the
role
that
emissions
reductions
would
play
in
--
in
7
those
base
year
differences?
8
MR.
KOERBER:
Emissions
reductions
would
9
result
in
lower
estimates
of
future
year
air
quality,
10
but
with
2002
meteorology
the
models
projecting
somewhat
11
higher
future
year
air
quality
levels
compared
to
2005
12
meteorology.
13
MR.
DAVIS:
It’s
my
understanding
that
a
14
model
run was
performed
using
2002
base
year
with
future
15
years
emissions
reduction
included
and
it
did
not
show
16
attainment
for
ozone.
Is
that
accurate?
17
MR.
KOERBER:
As
I
indicated,
the
18
attainment
demonstration
was
based
upon
a weight
of
19
evidence
approach
where
we
considered
a
number
of
20
modeling
analyses,
a number
of emissions
analyses
and
21
analysis
of
ambient
monitoring
data.
And
it
was
the
22
collective
review
of
that
information
that
provided
the
23
foundation
for
the
state!s
attainment
demonstration
24
not
--
not
one
single
model.
32
Keefe
Reporting
Company
1
MR.
DAVIS:
I
see.
2
Is
--
is
it
also
true
that
an important
3
component
of modeling
protocol,
one
that
improves
the
4
model
accuracy,
is
to use
what
is
known
as
relative
5
reduction
factors
to
apply
against
actual
ozone
data
6
measured
in
base
year
to
predict
future
levels?
7
MR.
KOERBER:
Yes,
that
is
how we
actually
8
use
the
mathematical
computer
model
in
our
technical
9
analysis.
We
use
the
relative
change
in
air
quality
in
10
combination
with
observed
monitoring
data,
estimate
the
11
future
air
quality.
So,
you’re
absolutely
right
as to
12
relative
change
that
is
important
in
terms
of
model.
13
MR.
DAVIS:
Did
the
modeling
based
on the
14
2005
base
year,
essentially,
predict
the
ozone
15
attainment
levels
that
have
now
been
measured
in
the
16
Chicago
area
and
elsewhere and
isn’t
it
these
modeling
17
results
that
are
being
used
to
support
the
Illinois
EPA
18
rule
request
to
designate
Chicago
as
a
non-attainer?
19
MR.
KOERBER:
Yes,
our
model
projections
20
using
the
2005
meteorology
due
tend
to
agree
with
the
21
most
current
monitoring
data
and
that
is
not
surprising
22
given
that
meteorology
is
somewhat
similar
to
what
we’ve
23
observed
over
the
past
couple
of
summers
it
was
not
as
24
severe
as
what
we saw
in
2002.
33
Keefe
Reporting
Company
1
MR.
DAVIS:
Thank
you.
2
Have
you
evaluated
the PM
2.5
air
quality
3
data
through
2008
to
determine
the
status
of
attainment
4
of
PM
2.5
standard?
5
MR.
KOERBER:
I
do not
believe
states
have
6
certified
2008
monitoring
data,
so
no,
I’ve
not
reviewed
7
2008
final
data
submitted
by the
states.
8
MR.
DAVIS:
Thank
you.
9
What
about
based
on
the
‘06 and
‘07
data.
10
MR.
KOERBER:
Question
again,
based
on
2006
11
or
2005
to 2007?
12
MR.
DAVIS:
Whether
you
have
been
able
to
13
determine
status
of attainment
with
the
PM
2.5
standard.
14
MR.
KOERBER:
There
are
a
number
of
sites
15
that
are
not
in
compliance
based
on 2005
to
2007
data.
16
MR.
DAVIS:
Last
series
of
questions:
At
17
the
bottom
of
page
five
and
top
of
page
six
of
your
18
testimony,
again,
you
state
that
the
2006
PM
2.5
19
standard
and
2008
ozone
standard
were
not obtained
in
20
several
sites
in
the
Lake
Michigan
area.
Is
this
21
conclusion
based
on
using
‘05 base
year
in the
actual
22
PM
2.5
ozone
design
values
from
‘05?
23
MR.
KOERBER:
It
is
based
on
the modeling
24
using
the
2005
base
year
condition,
correct.
34
Keefe
Reporting
Company
1
MR.
DAVIS:
What
base
year
do
you
believe
2
will
be
used
for
the
PM
2.5
and
ozone
modeling
for
these
3
new
standards?
4
MR.
KOERBER:
That
question
is
currently
5
being
discussed
by
the
states
and
no
decision
has
been
6
made.
7
MR..
DAVIS:
Do
you
believe
that
a
more
8
current
base
year
and
more
current
air
monitoring
data
9
would
make
a
difference
in
your
conclusions?
10
MR.
KOERBER:
With
regard
to
the
1997
11
standards
or
the
2006
version?
12
MR.
DAVIS:
The
new
standards.
13
MR.
KOERBER:
Really
don’t
know
the
answer
14
to
that.
15
Certainly,
in
putting
together
our
protocol
16
for
the
next
round
of
state
implementation
analyses
we
17
will
look
at
the
most
current
air
quality
--
air
quality
18
information
we
want
to
use
the
most
up
to
date
19
information.
20
MR.
DAVIS:
Thank
you
very
much.
21
That’s
all
I
have.
22
MR.
FOX:
Very
good.
Thank
you,
Mr.
Davis.
23
Any
further
questions
for
Mr.
Koerber?
24
Ms.
Hodge,
I
see
your
hand.
35
Keefe
Reporting
Company
1
MS.
HODGE:
Thank
you.
I
have
just
a
few
2
questions..
3
Katherine
Hodge.
4
Mr.
Koerber,
did
LADCO
evaluate
the
amount
5
of
NOx
reductions
needed
to
meet
the
standards?
6
MR.
KOERBER:
We
did
not
use the
modeling
7
to
set
emission
reduction
targets
or
percent
control,
8
rather
we
evaluated
the
bundle
of
control
measures
that
9
were
required
of each
of
the
states
and
that
the
states
10
collectively
agreed
to
implement
in
order
to
improve
air
11
quality
in
the
region.
12
MS.
HODGE:
Thank
you.
13
Do
--
do
the
LADCO
models
reflect
any
14
recent
emission
controls
in
reduction
and
by
recent
I
15
mean
2005
by
various
industrial
categories,
for
example,
16
such
as
petroleum
refineries?
17
MR.
KOERBER:
With
respect
to petroleum
18
refineries
we
are
aware
there
were
a
number
of
federal
19
consent
decrees
that
were
incorporated
in
our
emission
20
inventories.
In
addition
to NOx
RACT
there
are
number
21
of
other
control
measures,
both
state
and
federal,
that
22
are
included
for
non-EGU
point
sources,
but
really
all
23
sectors
of
the
inventory
have
control
included.
24
MS.
HODGE:
Okay.
Just
to
clarify,
so
your
36
Keefe
Reporting
Company
1
model did
consider
the post
‘05
reductions
at
petroleum
2
refineries?
3
MR.
KOERBER:
The --
the inventory
-- when
4
we
project
future
year
air
quality
we start
with
the
5
base
year
inventories,
in this
case
‘05.
We
apply
6
various
growth
factors
by sector
for
mobile
sources,
7
point
sources,
utilities,
etc.
And
then on
top of
that
8
we
apply
all
of the
control
programs,
quantify
those
9
emission
reductions
and that’s
the
future
year
emission
10
estimate
that
we
have available.
That’s
the
inventory
11
we plug
in the
model
statement,
the future
air
quality.
12
MS. HODGE:
Okay.
So, would
the
-- the
13
petroleum
refinery
consent
decree
reductions
be
a factor
14
into
--
15
MR. KOERBER:
Yes.
16
MS.
HODGE
-- the
controls.
Yes?
17
MR. KOERBER:
Yes.
18
And we
have
a
contract
report
that
19
discusses
those
particular
consent
decrees,
as
well
as
20
other
consent
decrees
that
were
included
in
our emission
21
inventory.
22
MS.
HODGE:
Thank
you.
23
Could
you
tell
us
a
little
bit
about
how
24
you
consider
the
contribution
of
mobile
sources
in
doing
37
Keefe
Reporting
Company
1
this
model?
2
MR.
KOERBER:
We
actually
undertook
a
very
3
rigorous
approach
for
the
mobile
sector.
We
worked
with
4
the
transportation
agencies,
formally
CATS,
in
the
5
Chicago
area
with
link
base,
so
segments
of
roadway
got
6
information
on
the
amount
of
traffic,
the
speed
of
7
traffic,
over
each
--
much
of
those
links
as
a
function
8
of
day
of
week,
time
of
day.
So,
highly
detailed
9
emissions
inventory
for
on—road
mobile
sources
based
10
upon
our
consultation
with
metropolitan
planning
11
organizations
and
used
EPA’s
mobile
six
model
to
12
estimate
the
amount
of
emission
reduction
that
we
would
13
expect
as
a
result
of
a
nuniber
of
different
federal
14
control
programs
both
tailpipe
and
fuel
programs.
15
MS.
HODGE:
Okay.
Thank
you.
16
I
have
to
take
just
a
quick
break,
please.
17
WHEREUPON,
THERE
WAS
A
SHORT
PAUSE
IN
PROCEEDINGS;
18
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
19
OF RECORD:
20
MS.
HODGE:
That’s
all
I
have
for
21
Mr.
Koerber.
Thank
you.
22
MR.
FOX:
Thank
you,
Ms.
Hodge.
23
Any
--
any
further
questions
by
any
of
the
24
participants
for
Mr.
Koerber?
38
Keefe
Reporting
Company
1
MS.
ROCCAFORTE:
I have
a
few
follow
up.
2
Mr.
Koerber,
do
you
know
if
the
St.
Louis
3
area
has
attained
the
1997
PM
2.5 standard?
4
MR.
KOERBER:
I do
not
believe
it
has.
5
MS. ROCCAFORTE:
Do
you
know
if
it
will
6
attain
the
standard
by the
applicable
attainment
date?
7
MR.
KOERBER:
It
will
not
according
to
our
8
model
projections.
So,
my
understanding
is
based
on
the
9
most
current
air
quality
monitoring
data
based
on
our
10
model
projections
it
will
not
meet
the
PM
2.5
standard
11
by
it’s
by
the
applicable
attainment’..
12
MS.
ROCCAFORTE:
Thank
you.
13
I
have
nothing
further.
14
MR.
FOX:
Any
more
questions?
15
(No
response.)
16
MR.
FOX:
I understand
Mr.
Rao
has
a
17
question
for
Mr.
Koerber.
18
MR.
RAO:
One
question.
19
Mr. Koerber,
on
page
four
of
your
pre-filed
20
testimony
you
have
noted
that
you
did
not include
21
midwest
ozone
groups
modeling
as
part
of
the
weight
of
22
the
evidence
that
you
stated
that
several
reductions
23
were
made
by
midwestern
group
modeling
were
counter
to
24
USEPA
guidance.
Could
you,
please,
elaborate
on
what
39
Keefe
Reporting
Company
1
those
were?
2
MR.
KOERBER:
Right.
3
One
of
the
assumptions
that
were
counter
to
4
EPA
guidance
is
the
use
of ambient monitoring
data
that
5
EPA
specifies
procedure
for
averaging
ambient monitoring
6
data
with
the
modeling
as
part
of the
attainment
7
demonstration.
The
approach
that
they
use
was
not
8
consistent
with
EPA’s
procedure
for
using
monitoring
9
data.
Given
that
this
attainment demonstration
must
10
meet
EPA
guidelines
in
order
to
be
approved
by EPA
we
11
were
not
able
to include
that
analysis
in
our weight
of
12
evidence
demonstration.
We
nevertheless
did
meet
with
13
the
company.
We
did
discuss
their
information
and
14
pointed
out
our
concerns.
15
MR.
RAO:
Okay.
Thank
you.
16
MR.
FOX:
Ms.
Hirner?
Yes.
17
MS.
HIPNER:
Deirdre
Hirner
with
Illinois
18
Environmental
Regulatory
Group.
19
May
I ask
a
follow
up
though
to
clarify?
20
The
--
the
conclusions
reached
by
the
21
modeling
and
the
LADCO
modeling
after
the
two
groups
met
22
it’s
my understanding,
and could
you
clarify,
ended
up
23
in
kind
of
the
same
place?
24
MR.
KOERBER:
The
--
their
conclusions
was
40
Keefe
Reporting
Company
1
that
all
sites
would
be
in
compliance
with
the
ozone
2
standard.
3
Our
conclusion
was
that
we
still
had
4
residual
non-attainment
problems
in
western
Michigan.
5
MS.
HIRNER:
Okay.
Thank
you.
6
MR.
FOX:
Any
further
questions
for
7
Mr.
Koerber?
8
MS.
ROCCAFORTE:
I’d
like
to
move
that
the
9
Western
Michigan
ozone
study
draft
report
be
entered
as
10
an
exhibit.
I
forgot
to
do
so
before.
11
MR.
FOX:
My
--
my
next
question:
The
12
agency
had
kindly
circulated
copies
of
the
Western
13
Michigan
ozone
study
draft
report
dated
January
21st,
14
2009.
Is
that
the
correct
date,
Ms.
Roccaforte?
15
MS.
ROCCAFORTE:
Correct.
16
MR.
FOX:
Great.
17
And
move
that
that
be
admitted
into
the
18
record
of
proceeding
as
Exhibit
Number
19.
Was
there
19
any
objection
to
that
motion?
20
(No
response.)
21
MR.
FOX:
Neither
seeing
nor
hearing
any
it
22
will
be
marked,
Ms.
Roccaforte,
as
Exhibit
Number
19.
23
Thank
you.
24
MS.
ROCCAFORTE:
Thank
you.
41
Keefe
Reporting
Company
1
MR.
FOX:
Once
again,
any
further
questions
2
for
Mr.
Koerber
on
the
basis
of
his
testimony
or
his
3
answers
today?
4
(No
response.)
5
MR.
FOX:
Then,
Ms.
Roccaforte,
it
appears
6
we’ve
come
to
the
time
for
Mr.
Staudt
and
his
pre-filed
7
testimony
and
questions
if
he’s
prepared
to
offer
a
8
brief
introduction
or
summary
it
appears
that
would
be
9
in
order
right
how.
10
MS.
ROCCAFORTE:
Before
he
does
that
I
11
would
like
to
move
to
enter
four
exhibits
—-
four
or
12
five.
13
I
don’t
know
I
recall
the
number.
14
MR.
FOX:
We
can
take
a
second.
That’s
15
just
fine.
16
WHEREUPON, THERE
WAS
A SHORT
PAUSE
IN
PROCEEDINGS;
17
SUBSEQUENT
TO
WHICH THE
FOLLOWING
PROCEEDINGS
WERE
MADE
18
OF
RECORD:
19
MS.
ROCCAFORTE:
Five
tables
to
be
20
incorporated
into
his
pre-filed
testimony.
21
MR.
FOX:
Do
you
have
--
does
the
agency
22
have
copies
of
those?
23
MS.
ROCCAFORTE:
We
-
-
we
do.
24
MR.
FOX:
Very
good.
Thank
you
very
much.
42
Keefe
Reporting
Company
1
With
that
number
of
exhibits,
2
Ms.
Roccaforte,
without
proceeding
to
any
motion
to
3
admit,
why
don’t
we
preliminarily
at
least
give
them
4
some
exhibit
numbers
so
that
it’s
at
least
as
clear
as
5
possible
to
folks
exactly
which
ones
we
would
be
talking
6
about.
7
Do
you
have
in
front
of
you
one
that
you
8
might
name
as
the
next
Exhibit
Number
20?
9
MS.
ROCCAFORTE:
Calculation
of
available
10
COG,
which
stands
for
coke
oven
gas
after
consumption
11
and
reheat
furnaces.
12
MR.
FOX:
Is
there
a
date
or
any
source
13
that
might
help
distinguish
that?
14
MS.
ROCCAFORTE:
No.
15
MR.
FOX:
That
should
be
just
fine.
No
16
worries.
17
And
that
again,
would
be
number
20.
18
Preliminarily
would
there
be
a
next
exhibit
19
that
we
would
want
tentatively
to
assign
as
Number
21?
20
MS.
ROCCAFORTE:
Entitled
boiler
analysis.
21
I
need
to
clarify
that
one
from
the
other
ones.
This
22
one
is
boiler
analysis
calculation
of
Siebenberger
23
Exhibit
A
information
COG
burn
and
reheat
furnaces
per
24
Siebenberger’s
December
testimony.
43
Keefe
Reporting
Company
1
The
next
one
is
a
chart
titled
total
boiler
2
COG
usage.
3
MR.
FOX:
Again,
COG,
coke
oven
gas.
4
MS.
ROCCAFORTE:
Correct.
5
MR.
FOX:
Thank
you.
6
And
that
would
be,
of
course,
22
7
tentatively.
8
MS.
ROCCAFORTE:
Thank
you.
9
The
next
one
is
boiler
analysis
calculation
10
of
Siebenberger
Exhibit
A
information
with
2008
COG
rate
11
35-day
scrubber
maintenance.
12
And
the
final
one?
13
MR.
FOX:
Sorry
to
interrupt
that
14
proceeding
one,
Number
23;
and
this
one
Number
24.
15
Sorry
to
state
the
obvious.
16
MS.
ROCCAFORTE:
Thank
you.
17
This
one
is
boiler
analysis
calculation
of
18
Siebenberger
Exhibit
A
information
with
2008
COG
rate
no
19
COG
scrubber
maintenance.
20
MR.
FOX:
Thank
you
for
bearing
with
us
21
while
we
try
to
minimize
any
risk
of
misunderstanding
or
22
mislabeling.
23
The
Agency
is
passing
these
out.
They
24
should
be
in
your
hands
fairly
shortly
then
we
can
44
Keefe
Reporting
Company
1
proceed.
2
Ms.
Roccaforte,
thank
you
for
your
3
patience.
4
MS.
ROCCAFORTE:
That’s
all
I have.
5
MR.
FOX:
Thank
you once
again
to The
6
Agency
for
making
these
copies
available.
It
looks
like
7
they
are or
are very
nearly
distributed
to the
parties
8
here today.
9
You,
I can’t
recall,
Ms.. Roccaforte,
if
you
10
made
a
motion.
Something
I always
seem to
forget.
11
MS.
ROCCAFORTE:
I
believe
I
did,
but
I
can
12
do
so
again.
13
I move
that
these
tables
be
entered
as
14
exhibits
and
incorporated
into our
Dr.
Staudt’s
15
pre-filed
testimony.
16
MR.
FOX:
Thank
you very
much
for the
17
repetition..
18
Ms.
Roccaforte
has, of
course,
moved
that
19
these
exhibits
as
described
earlier
as
we
assigned
20
preliminary
exhibit
nwxibers
to
them,
Numbers
20,
21, 22,
21
23 and
24
be
admitted
into
the
record
as she
had
22
described.
23
Is
there
any
objection?
24
MS.
HODGE:
Mr.
Fox, Katherine
Hodge,
45
Kefe
Reporting
Company
1
United
States
Steel
Company Corporation.
2
I
-- I don’t
have
a firm
objection right
3
now,
but I
would ask
you to wait
to
rule
on her
motion
4
until
we do
have an
opportunity
to
review those
perhaps
5
at
the next break.
6
MR..
FOX: That
seems
fair under
the
7
circumstances.
8
Dr.
Staudt
is, of
course, here
and is,
I
9
believe,
perhaps
to offer
his
testimony.
10
MS.
HODGE:
I understand
that.
11
MR. FOX:
Make
himself
available for
12
questions.
I’ll
make
a note.
We can address
that.
13
In
the
meantime
they
are, of course,
in
14
front of
you for your
review.
15
MS.
HODGE:
Thank
you.
16
MR.
FOX:
With
that,
Ms. Roccaforte,
I
17
think we have
come
to the time
for
any summary
or
18
introduction
that Dr.
Staudt would
want
to offer,
unless
19
you
have something
else
you
wish
to address?
20
MS.
ROCCAFORTE:
No. I
will turn
it over
to
21
Dr.
Staudt.
22
MR. FOX:
Dr.
Staudt, good morning.
Thank
23
you for waiting.
24
DR.
STAUDT:
Thank
you.
46
Keefe
Reporting
Company
1
My
name
is
James
Staudt.
Thank
you
for
2
giving
me the
opportunity
to
come
here
to speak
before
3
this
board
again.
4
And
just
to
--
I
have
been
engaged
by the
5
Illinois
EPA
to
rule
making
as
since
the
last
hearing.
6
I did
pre-file
testimony.
Very
briefly
summarize
it.
7
MR.
FOX:
Dr.
Staudt,
before
you
do
that
if
8
you
could
pull
the
microphone
just
a
little
closer
to
9
your
face.
I’m
getting
the
sign
that
some
people
are
10
having
a
hard
time
hearing.
I
apologize.
Thank
you
for
11
that.
12
DR.
STAUDT:
Okay.
Thank
you.
13
Just
briefly
summarize
my
pre-filed
14
testimony.
At
the
last
hearing
U.S.
Steel
presented
15
arguments
for
why
they
felt
the
emissions
rates
proposed
16
in
the
rules
to be
increased
by
my
pre-filed
testimony
17
for
this
hearing
stated
that
I
found
their
argument
18
unconvincing
and
in
general
under
two
grounds.
One
is
19
that
my
opinion
was
that
there
was,
based
upon
some
of
20
the
conclusions
and
assertions
that
they
made,
there
was
21
inadequate supporting
information.
Second,
I
--
I
found
22
some
——
I
found
what
appears
to
be
some
errors
in
the
23
calculations
for
emission
estimates.
24
Some
things
have
happened
since
my
47
Keefe
Reporting
Company
1
pre—filed
testimony
as
already
has
been
discussed.
2
Friday
night
we
received
information
from
U.S.
Steel
3
that
we
requested
that
included
the
report
by URS
that
4
was
revised
on
January
19th,
2009.
It
was
a
proposal
5
from
Bloom
Engineering,
a
burner
supplier,
that
is
dated
6
January
22nd,
2009.
And
there
was
also
some
information
7
on
coke
oven
gas
usage,
historical
coke
oven
gas
usage
8
at
the
boilers
at
the Granite
City
site.
9
In
addition
to
that
I received
last
night
a
10
copy
of
Mr.
Stapper’s
testimony.
I’d
like
to
impress
11
upon
you
I
appreciate
this
information.
It
will
give
us
12
the
opportunity
to
take
a
close
look
at
it.
We
--
13
having
had
a
short
time
to
look
at
it
I
don’t
know
that
14
I’ve
been
able
to
fully
review
it,
but
there
are
a few
15
pieces
of
information
that
I
would
like
to
present
here
16
that
are
related
to
some
of the
information
I have
been
17
provided.
18
First,
I
would
like
--
like
to draw
your
19
attention
to
Exhibit
20.
It’s
the
table.
Exhibit
20
20
bears
very
similar
resemblance
to
table
five
of
my
21
pre-filed
testimony.
Just
as a
matter
of
introduction,
22
because
coke
oven
gas has
significant
amounts
of
fuel
23
bound
nitrogen
is
the
amount
of
fuel
--
amount
of
coke
24
oven
gas
that
is
fired
at
either
the
boilers
or
at
slab
48
Keefe
Reporting
Company
1
reheat
furnaces
is
significant
with
respect
to
the
2
amount
of
NOx
that
we generate.
3
And
what
we
show
here
on
Exhibit
20
there’s
4
information
that
was
taken
from
Mr.
Siebenberger’s
5
pre—filed
testimony, Exhibit
B,
which
is
total
heat
6
input.
Mr.
Sieberiberger
provided
us
in the
last
hearing
7
a
breakdown
of
their
assumed
percent
of coke
oven
gas
8
that
was
used
in
each
reheat
furnace
and
that
that
is
——
9
these
percentages
are
used
to
estimate
the amount
of
10
coke
oven
gas
used
in
his
assumptions
for
each
reheat
11
furnace.
12
In
my
pre-filed
testimony I
referred
to
13
information
provided
by
Mr.
Siebenberger
to Mr.
Kaleel
14
regarding
the
total
available
coke
oven
gas
and
that
is
15
shown,
see
line
total
available
coke
oven
gas of
three
16
million
830,400
million
BTUs
per
year.
That
is
based
17
upon
information
provided
by
Mr.
Siebenberger
and
18
Mr.
Kaleel.
Of
course,
if
you
have
the
amount
of coke
19
oven
gasses
you
can’t
burn
more
coke
oven
gas
than
is
20
available.
So
if,
assuming,
based
upon
the
amount
of
21
heat
that
Mr.
Siebenberger,
coke
oven
gas
that
is
used
22
in
reheat
furnaces
you
can
develop
total
amount
of
coke
23
oven
gas
that
is
used
in
those
reheat
furnaces,
compare
24
that
to the
available
coke
oven
gas
and
find
out
well,
49
Keefe
Reporting
Company
1
how
much
is
actually
available
to the
boilers,
Boilers
2
11 and
12.
And
you
can
find
that
balance
available
to
3
the
boilers
is
36,180
million
BTUs
per
year.
4
Now,
if
you
--
if
you
compare
that
to
the
5
amount
of
coke
oven
gas
that
is
estimated
to
be
used
as
6
part
inherent
to
Mr. Siebenberger’s
Exhibit
A
his
7
pre—filed
testimony
now
this,
of course,
is
something
8
that
I had
to
calculate
and
it
is
shown
in
my
pre-filed
9
testimony
how I
arrive
at
these.
You
can
see
the
total
10
whether,
coke
oven
gas
input,
you
see
it’s,
whether
you
11
assume
60
percent
usage
when
the
blast
furnace
is
down
12
or
40
percent
with
the
blast
furnace
gas down
either
way
13
you’re
been
1.4
million
Btu,
which
is
over
a
trillion.
14
So,
in
essence,
you
have
a
short
fall.
You
can’t
use
15
the
amount
of coke
oven
——
there
isn’t
enough
coke
oven
16
gas
available
to
satisfy
all
of
the
assumptions
that
17
Mr.
Siebenberger
uses
in
his
estimates
of
emissions.
18
Exhibit
21
actually
is
--
is
very
similar
19
to a
number
of
tables
that
are
in
my
pre-filed
20
testimony.
It,
essentially,
uses
the
same
--
many
of
21
same
assumptions
that
U.S.
Steel
used
in
order
to
come
22
up
with
their
emissions
estimates.
And
I
won’t
review
23
the
tables
that
are
--
that
are
in
my
--
my
pre-filed
24
testimony,
but
what
--
what
with
this
spread
sheet
50
Keefe
Reporting
Company
1
you’re
able
to
compare
what
-—
determine
what
the
annual
2
emission
rate
would
be.
And
if
you
use
assume
that
the
3
amounts
of
coke
oven
gas
that
Mr.
Siebenberger
testified
4
to
are
being
used
in
the
reheat
furnaces
and
therefore,
5
only
about
36,000
million
Btu’s
are
available
to
the
6
boilers
you
come
up
with
a
--
an annual
NOx
emission..
7
It’s
using
the very
same
emission
rates
per each
gas
as
8
provided
by
U.S.
Steel
and
it’s
consultants
come
up
with
9
annual
emission
rate
of
0.05,
which
is
under
the
—-
the
10
limit
that
is
proposed
for
the
rule.
11
Now,
the
numbers
Mr.
Siebenberger
assumed
12
in
his
--
in
his
testimony
for
it’s
usage
in
the
reheat
13
furnace
-—
reheat
furnaces
is
as
he
said
he
wanted
to
14
assume
the
maximum
both
reheat
furnaces
and
for
the
--
15
for
the
boilers.
They
don’t.
They
made
--
may
16
historically
--
they
have
--
perhaps
they
haven’t
used
17
quite
as
much
as
is
shown
there,
but
if
you
go to
18
Exhibit
22
based
upon
information
that
was
provided
19
Friday
night
it
showed
a
trend
of
coke
oven
gas
usage
in
20
the
boilers.
And
if
you
go back
to
--
if
you
can
see
21
based
upon
Exhibit
A
if
you
go
back
to
exhibit
or
excuse
22
me,
Exhibit
20,
the
assumptions
for
Mr. Siebenberger’s
23
emission
estimates
from
Boilers
11 and
12
or
U.S.
Steel
24
emission
is
based
on
about
1.4
million
--
million
Btu’s
51
Keefe
Reporting
Company
1
per
year.
And
as you
can
see
there
has not
been
that
2
much
——
we
have
not
seen
that
much
usage
since
at
least
3
back
2001.
4
So,
it’s
the
trend
over
the
last
-— since
5
2001
has
generally
been
downward.
As
you can
see
6
they’ve
been
using
less
and
less.
And
this
is
the
total
7
using
for
all
boilers
one
through
10,
11
and
12
8
recognizing
that
once
boilers
one
through
10 are
9
decommissioned
coke
oven
gas
that
would
have
been
burned
10
and
boiled
in
one
through
10 would
therefore
be
burned
11
in
Boilers
11
and
12.
12
So,
historically
we
see
the general
trend
13
downward
in
—- in
the
level
of
coke
oven
gas
that
is
14
used
in
--
in
the
boilers.
And
what
that
suggests
that
15
is
most
likely
being
used
in
the
reheat
--
increasingly
16
being
used
in
repeat
furnaces.
17
The
--
2008
was
roughly
450
thousand
18
million
Btu’s
were
actually
used
in the
coke
oven
to
19
coke
oven.
And
the
coke
oven
gas
was
actually
used
in
20
the
--
in
the
boilers.
If
you
use
that
the
two
--
the
21
2008
coke
oven
gas
usage
consumption
that
is
provided
——
22
that
was provided
to us
as
Attachment
C of
--
on Friday
23
of U.S.
Steel’s
submission
what
you’ll
see
is
that,
24
again,
using
the
emission
rates
assumed
by
—-
for
—-
for
52
Keefe
Reporting
Company
1
firing
gas
the
NOx
emission
rates
firing
associated
with
2
the
firing
coke
oven
gasses
that
--
that
are
-—
you
3
estimate
in
U.S.
Steel
you
end
up
with,
if
you
look
down
4
at
the
bottom
you
will
see
NOx
rate
under
annual
NOx
5
rate
0.083
pounds
per
billion
Btu’s,
again,
very
close
6
to
the
proposed
emission.
7
Finally,
if
you
perform
that
calculation
8
again
and
leave
out
—-
leave
out
the
-—
the
--
the
time
9
for
the
increased
emissions
due
to
scrubber
maintenance
10
you
would
see
that,
again,
going
down
to
what
that
NOx
11
emission
record
would
be
it
comes
to
0.074
parts
per
12
billion
Btu’s
under
the
emission
rate
proposed
in
the
13
rule.
14
And
again,
I
want
to
reaffirm
that
these
15
are
--
this
is
using
the
same
NOx
emission
rates
that
16
URS
has
provided
us
in
air
analysis.
So,
the
difference
17
is
we’re
-—
we’re
looking
at
the
actual
coke
oven
gas
18
usage
as
used
by
U.S.
Steel.
19
So,
as
I’ve
shown
here
our
calculations
20
show
that
it
is
possible
for
U.S.
Steel
to
achieve
the
21
proposed
emission
rate
for
Boilers
11
and
12.
22
MR..
FOX:
Does
that
wrap
up
your
--
23
DR.
STAUDT:
Thank
you.
24
MR.
FOX:
Didn’t
mean
to
rush
you.
I’m
53
Keefe
Reporting
Company
1
sorry..
2
Are
there
any
questions
for
Dr.
Staudt
on
3
the
basis
of
his
pre-filed
testimony
and
comments?
Is
4
there
anyone
who
wishes
to
pose
a
question
at
this
time
5
for
Dr.
Staudt?
Ms.
Hirner?
6
MS.
HIRNER:
Thank
you,
Mr.
Fox.
7
Dr.
Staudt,
just
a
couple
of
--
couple
of
8
questions.
9
And
the
first
one
is
with
regard
to
the
10
technical
support
document
on
page
five,
the
technical
11
support
document
with
reference
to
industrial
boilers.
12
MR.
FOX:
Ms.
Hirner,
just
for
13
clarification,
that’s
the
technical
support
document
14
originally
filed
by
The
Agency
with
it’s
proposal
in
15
this
hearing?
16
MS. HIRNER:
Yes,
it
is.
17
MR.
FOX:
Thank
you.
Sorry
to
interrupt
18
you.
19
MS.
HIRNER:
Thank
you.
20
Second
paragraph
referencing
combustion
21
modification
techniques:
These
techniques
are
often
22
less
expensive
than
most
combustion
techniques
such
as
23
SCR
and
SNCR.
However,
a
combination
of
combustion
and
24
post—combustion
control
can
sometimes
be
the
most
54
Keefe
Reporting
Company
1
effective
approach.
2
So,
should
I
read
that
statement
to
say
3
that
SNCR
is
appropriate
as
an
appropriate
control
for
4
purposes
of
achieving
NOx
RACT?
5
DR.
STAUDT:
Well,
it
is
my
opinion
it
has
6
been
used
for
NOx
RACT.
So,
I
think
that
that
pretty
7
much
states
that
it
is
appropriate
and
that’s
not
just
8
my
opinion
it’s
the
opinion
of
the
number
of
companies
9
that
have
selected
SNCR
for
NOx
RACT
compliance.
10
MS.
HIRI’iER:
Then
as
a
follow
up
to
that,
11
same
page
five,
third
full
paragraph,
second
sentence:
12
To
economically
control
NOx
RACT
or
NOx
emissions
from
13
such
boilers
the
-—
it
may
be
necessary
to
use
fuel
that
14
is
low
in
nitrogen
content
and
choose
combustion
15
conditions
that
generate
lower
amounts
of
NOx
during
16
combustion.
17
Should
I
read
that
to
say
that
you
believe
18
mandatory
fuel
switching
is
an
appropriate
means
of
19
control
to
achieve
NOx
RACT?
20
DR.
STAUDT:
No.
My
opinion
is
that
I
21
think
you’re
--
you’re
reading
something
into
that
that
22
is
not
intended.
Just
generalized
this
section
points
23
are
that
for
every
situation
you’re
going
to
have
a
24
unique
set
of
circumstances
that
need
to
be
evaluated.
55
Keefe
Reporting
Company
1
And
in
some
cases
someone
may
choose
combustion
control.
2
In
some
cases
someone
may
choose
combustion
control
and
3
post—combustion
controls.
In
other
cases
if
someone
has
4
the
ability
to
easily
switch
fuels
they
may
go
to
a
5
lower
--
they
go
may
to
lower
nitrogen
fuel.
So
that
6
this
is
not
to
state
that
any
specific
approach
should
7
be
defined
as
RACT.
As
we’ve
discussed,
testified
8
couple
of
times,
RACT
is
really
an
emission
rate
that
is
9
achievable
at
a
reasonable
cost
that
we
have
discussed,
10
not
a
specific
technology.
11
MS.
HIRNER:
So,
have
you
done
any
specific
12
evaluation
of
those
alternative
techniques?
13
DR.
STAUDT:
I’m
not
sure
what
you’re
14
talking
about
specific
to
a
particular
facility?
15
MS.
HIRNER:
Or
emissions,
yeah,
facility.
16
DR.
STAUDT:
Well,
I’ve
done
--
I’ve
done
17
it
for
other
--
other
clients,
but
not
--
not
specific
18
to
this
other
than
what
you
see
--
other
than
what
you
19
see
in
the
mechanical
support
document
that
that
--
20
that’s
what
was
provided.
I’m
not
sure
if
you
are
21
looking
for
a
specific
facility’s
--
22
MS.
HIRNER:
The
subject
facility’s
--
23
specific
to
the
facilities
that
are
subject.
24
DR.
STAUDT:
No.
As
I
testified
before
we
56
Keefe
Reporting
Company
1
did
not provide
--
we did not
do analysis
for
each
and
2
every
facility
in
Illinois.
3
MS.
HIPNER:
Did
you
do it for
any
of
the
4 facilities
in
Illinois?
5
DR.
STAUDT:
Well,
we’ve
been
taking
a look
6
at
Boilers
11 and
12
lately
based upon
some
-- some
of
7
the information
from
U.S. Steel,
but
-- but other
than
8
that
we have
-— we have
not been
examining
it, not
been
9
doing
unit
by
unit
type
of analysis.
10
MS.
HIENER:
May
I
ask another
question?
11
MR. FOX:
Please,
go ahead,
Ms. Hirner.
12
MS. HIRNER:
The
pages 43
and 44 of this
13
same original
technical
support
document
you
offer
a
14
description
of
a
range
of numbers,
a
range
of control
15
levels.
And
I’m uncertain
whether
this
question is
--
16
actually
can
be
answered
by Dr.
Staudt or it may
take
17
combination
of Dr.
Staudt and
the
agency
asking:
The
18
control
levels
that
were
selected
for
this particular
19
rule making
fall
-- tend
to fall
at the more
stringent
20
end of the
range.
Now,
did
The Agency
or how
did
21
The Agency working
with
Dr.
Staudt
or
did Dr.
Staudt
22
recommend
which
number within
the
range
to
choose?
23
DR. STAUDT:
Well, first
of all,
24
comments
-— it
comments
to these
tables and
what’s
in
57
Keefe
Reporting
Company
1
these
tables.
And
perhaps
maybe,
you
know,
in terms
of
2
how
the
emissions
was
developed
we
can
talk
about
that
3
further
with
The Agency.
4
This
table
is
actually
just
citing
data
5
sources.
Now,
you’ll
see
a
number
of
these
reference
6
one
reference
four,
etc.,
lot
of
them
are
reference
7
within
which
actually
is
the
--
the
ICI
Boiler
--
EPA’s
8
alternative
control
techniques
document,
which
I
believe
9
was
dated
in
1994,
which
is
pretty
--
for
the
most
part
10
is
dated
in
some
respects.
So,
while
it’s
useful
to
11
cite
this
I
think
it’s
useful
to
cite
it
to
show
that
in
12
1994
these
emissions
levels
were
being
achieved
with
13
these
technologies.
And
these
were
the
estimated
cost
14
effectiveness.
It’s
the range
—- the
ranges
are
because
15
in
some
cases
rather
than
having
reach
one
of
those
——
16
those
--
those
data
points
a
table
with
multiple
data
17
points,
because
sometimes
they
--
they
showed
different
18
usage
rates
for
or
capacity
levels,
what
have
you.
19
What
happened
is
we
condense,
just
to
be
20
able
to
cover
the
full
range
of
--
of
cost
effectiveness
21
shown
in
that
reference
and
of
course,
the
reference
is
22
cited
there.
People
can go
to
see
the reference
table
23
with
the information.
24
MS.
HIRNER:
On
Exhibit
1 to
Dave
Colaz’s
58
Keefe
Reporting
Company
1
pre-filed
testimony
submitted
November
25th,
2008
we
2
offered
--
IERG
offered
a
comparison
IEPA
emission
list
3
and
IERG’s
proposed
emissions
limits.
IERG’s
limits
4
falling
within
the
range
—-
range
—-
ranges
shown
on
5
page
43
and
44.
6
Then
if
I look
on
page
six
of
that
same
7
technical
support
document,
which
references
EGUs
low
8
emissions
unit,
can
you
point
to
some
place
in
the
9
technical
support
document
that
would
demonstrate
a
10
similar
level
of
detail
for
industrial
boilers
that
11
would
demonstrate
that
the
numbers
selected
by the
12
Illinois
EPA
are
better
than
the
limits
proposed
by
13
IERG,
those
numbers
falling
within
the
range?
14
DR.
STAUDT:
Well,
I
guess
--
I guess
you
15
have
to,
first
of
all,
define
what
you
mean
by
better.
16
I
think
your
--
perhaps
you’re
--
what
you
17
think
is
better
might
be
different
from
what
I think
is
18
better,
but these
—— these
emission
rates
were
—- were
19
developed
through
discussions
--
through
discussions
20
with
--
between
--
with
--
among
IEPA
people
and
myself.
21
And
they
were
- -
they
were
developed
based
upon
what
22
we
--
what
we
knew
current
technology
was
capable
of
23
doing,
not
necessarily
reflected
in
1994
EPA
control
24
techniques
document,
but
other
supporting
information
59
Keefe
Reporting
Company
1
that
is
provided in
here.
We
discuss
different
types
of
2
combustion
technologies
and
other
kinds
of
controls.
3
So,
whether
or
not
--
whether
or
not you
feel
that
4
that
--
I ‘m
sure
that
you
believe
that
your
--
your
-
5
table
here
is
better,
but
I don’t
know
of
a
--
I’m
not
6
aware
of
analysis
—-
there’s
no
analysis
that
I
7
performed
that
compared
these
numbers
to what
other
8
states
are
doing.
9
MS.
HIRNER:
Just
to
follow
up
on
that,
on
10
the
page
six
table,
21
A,
on
the
emission
requirements
11
of
proposed
industrial
and
small
EGU
boiler
RACT,
since
12
this
is
in
this
type
of support
document
would
it
be
13
correct
that
--
that
you proposed
those
emission
limits
14
and
if
so,
what
did
you
base
--
15
DR.
STAUDT:
No,
I do
not
propose
emission
16
levels.
I
don’t
have
that
authority
and
I
certainly
17
wouldn’t
want
them.
18
I
was consulted.
These
are
The
Agency’s
19
proposed emission
limits
or
what
—-
what
I can
say
is
20
they
consulted on
--
with
me
on
these.
These
are
not
--
21
you
know,
I don’t
have
the
authority
to
--
to propose
22
emission
levels.
23
MS.
HIRNER:
So,
what
would
have
been
the
24
technical
support
on
which
those
were
based?
60
Kefe
Reporting
Company
1
DR.
STAUDT:
Well,
you
--
you’ve
got
it
in
2
front
of
you
that
this
is
--
this
is
the
document.
3
MS.
HIRNER:
Okay.
If
--
the
document
4
proposes
a
range.
So,
maybe
I
guess
the
question
would
5
be
better
directed
to Mr.
Kaleel
as
to
why
they
would
6
have
recommended
those
numbers.
7
MR.
FOX:
Perhaps
Mr.
Kaleel
would
8
appreciate
a
repetition
or
rephrasing
of
your
question.
9
MS.
HIRNER:
On
the
emissions
requirements
10
of
the
proposed
industrial
small
EGU
boiler
PACT
on
page
11
six
there
are
proposed
emissions
limits.
And
then
on
12
pages
43
and
44
there
are
a
range
of
NOx
control
levels.
13
And
my
question would
be
what
was
the
--
what
was
the
14
basis
for
The
Agency’s
selection
of the
limits
it
chose
15
for
this
proposed
rule?
16
MR.
KALEEL:
Well,
I guess
I
would
agree
17
with
Dr.
Staudt’s
characterization
that
--
that
these
--
18
these
two
pages, and
there
may
be
other
information
19
that’s
supportive
of
this
summary,
but
that
these
two
20
pages
provide,
I
guess,
our ——
our
review
of the
21
available
literature
as
to
the
performance
of various
22
control
options
for
various
boiler
types
and
various
23
boiler
sizes.
And
we
did
cite
a
number
of
--
of
24
references
that
are
--
that
are
available
in
literature
61
Keefe
Reporting
Company
1
and
we
also
tried
to summarize
the
cost
effectiveness
2
numbers
that
have
been
published
in
those
references.
3
The
selection
of the
specific
emission
4
limit,
I
won’t
say
it’s
subjective,
but
I do
appreciate
5
that
there
are
different
control
levels
in
the
6
literature
that
are
cited.
I’m,
just
as an
example,
on
7
page
43
the
first
grouping
of
boilers
that
are
listed
8
are
the
natural
gas
fired
water
tube
single
burner
9
boilers
and
there
are numbers
listed
for
a number
of
10
different
unit
capacities.
We
did
not
generally
look
at
11
control
options
that
would
require
SCR,
for
example,
12
generally
believe
that
SCR
were
going
to
be too
13
expensive.
Although,
I
would
--
would
note
that
at
14
least
for
this
particular
category
of
boilers
the
--
15
even
the
SCR
costs
that
are
cited
there
are
generally
16
less
than
$3,000
a
ton and
in
some
cases
significantly
17
less
then
that.
18
But looking
at
the
performance
of
these
19
boilers
for
this
category
I
see
a number
of
boilers
20
that
--
with
Low-NOx
burners,
plus
flue
gas
21
recirculation
are
meeting
levels
of, you
know
.07,
maybe
22
in
some
cases
.08.
23
Need
to
refresh
my
memory
what
these
24
acronyms
mean
in terms
of
--
excuse
me
for
just
a
62
Keefe
Reporting
Company
1
minute.
2
WHEREUPON,
THERE
WAS
A
SHORT
PAUSE
IN
PROCEEDINGS;
3
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
‘WERE
MADE
4
OF
RECORD:
5
MR.
KALEEL:
I
need
to
refresh
my
memory
on
6
what
some
of
these
acronyms
mean.
Just
a
moment.
7
WHEREUPON, THERE
WAS
A SHORT
PAUSE
IN
PROCEEDINGS;
8
SUBSEQUENT
TO
WHICH THE
FOLLOWING
PROCEEDINGS
WERE
MADE
9
OF
RECORD:
10
MR.
KALEEL:
All
right.
I
apologize.
11
I
think
the
WI
refers
to
water
injection.
12
OT
is
oxygen
trim.
13
The
performance
of
these
particular
boilers
14
using,
for
example,
is
it
looks
to
be
well
below
the
.08
15
that
the
agency
recommended
as
it’s
emission
limit.
So
16
just
looking
at
the
information
on
this
table
it
looks
17
like
there’s
a
number
of
control
options
that
are
easily
18
within
the
control
cost
that
we’ve
used
in
our
analysis
19
that
could
meet
the
.08
emission
limit.
20
The
number
that
IERG
had
recommended
for
21
this
particular
source
category
is
.12
pounds
per
22
million
Btu.
That,
obviously,
is
at
the
upper
end
of
23
the
range.
In
fact,
it
--
it
doesn’t
even
appear
on
24
this
table.
I
mean,
certainly,
it’s
--
in
some
cases
63
Keefe
Reporting
Company
1
it’s
double
the
performance
of
--
of
what
these
control
2
technologies
would
achieve,
so
I
--
3
DR.
STAUDT:
If
--
I’d
like
to
add,
4
these
—-
these
tables
are
really
to
show
cost
5
effectiveness
estimates
of
certain
technologies.
And
in
6
the
balance
of
the
document
they
are
discussions
of
use
7
in
reference
citing
to the
use
of
these
technologies
8
that
have
——
that
are
more
current,
that
have
some
more
9
current
information
that
may
show
lower
emission
limits.
10
May
recall
one
of
the hearings
it
was
11
discussion
about
some
of
the
-—
some
of
the
gas
fired
12
boilers
and
in
many
--
but
in
those
cases
the
published
13
information
did
not
include
cost
effectiveness
14
calculation.
Well,
they’re
using
somewhat
the
same
15
technology
as
cited
here
just
that
it’s,
you
know,
is
16
more
technical
information
that
those
--
that
17
information
as
far
as
determining
emission
rates
is
not
18
just
facts
that
helped
us
determine
the
appropriate
19
emission
rates.
It’s
not
just
found
on those
tables.
20
It’s
found
throughout
this
document.
21
What
this
--
these
tables
do
is
just
give
22
us
—— give
us
some
ranges,
cost
effectiveness
in
large
23
variety
of
sources.
WAnd
that’s
what
this,
in
my
24
opinion,
fairly
compelling
about
some
of
these
64
Keefe
Reporting
Company
1
calculations.
Some
of these
estimates
is
that
you
find
2
large
variety
of sources
coming
up with
for
a
particular
3
control
technology
pretty
-- very
similar
cost
4
effectiveness
ranges.
So,
we have
another
source
where
5
they
show
it
for a particular
technology
emission
rate.
6
We
have
a sense
of what
that
cost effectiveness
would
7
be.
8
MS.
HIRNER:
Would
you
agree
that
there
9
are,
within
your tables
for
demonstration
purposes,
10
nearly
an
equal
amount
of units
that
are at
the high
end
11
as
are at
the low
end
of
the range?
12
DR.
STAUDT:
I’m not
sure what
you
mean
by
13
the
high
end versus
the
low
end. High
end
of what?
14
MS.
HIRNER:
Say, for
example,
that you
15
have
natural
gas fired
boiler
at
-- with
an ignition
16
rate of
1.5
versus
.06.
17
DR.
STAUDT:
Where?
You’re
talking
about
18
that
Low-NOx
burner
.15
down
there?
19
MS.
HIRNER:
Yes.
20
DR.
STAUDT:
Reference
one. And
reference
21
one
is
also
the
-- the
‘93 or
‘94 ACT
document,
so
--
22
MS. HIRNER:
.06 --
isn’t the
.06
also
23
included
in reference
one?
24
DR. STAUDT:
Yes.
So,
I’m not
sure
what
65
Keefe
Reporting
Company
1
your point
is.
2
I
mean,
the reference
one
had
had
a variety
3
of
different
-- different
pieces
of
information
there
4
and not
every
facility
is going
to
be, you
know,
exactly
5
the
same
and that’s
why,
that’s
as
Mr. Kaleel
stated,
we
6
had
to
use
a certain
amount
of
judgment
in
coming
up
7
with
the proposed
emission
rates.
8
MS. HIRNER:
Okay.
Thank
you.
9
I
don’t have
any
further
questions.
10
MR.
FOX:
Thank
you, Ms.
Hirner.
11
Any further
questions
for
Mr.
Kaleel
-- I’m
12
sorry --
for Dr.
Staudt?
My
mistake.
13
Ms.
Hodge?
14
MS. HODGE:
Yes,
I
have
a
few
questions.
15
Katherine
Hodge.
16
MR.
FOX:
Please,
go ahead.
17
MS.
HODGE:
And I am,
first
off,
on
behalf
18
of United
States
Steel.
19
And
the testimony
of Dr.
Staudt
gave
today
20
on
these
new
exhibits,
Exhibit
20 through
24,
as
I
said
21
we
really
need
a few
minutes
to
take a
look to
fully
22
understand
what
this
is, so
I don’t
have
any
questions
23
right
now.
24
Mr.
Larry
Sieberiberger
would
like
to offer
66
Keefe Reporting
Company
1
a
brief
statement
today
regarding,
you
know,
his
initial
2
thoughts
on these
and
-— and
we
would
ask
the
hearing
3
officer
that
we be
allowed
to do
that
at
or
about
the
4
same
time
that
Mr.
Stapper
offers
testimony
today.
5
MR.
FOX:
Very
good.
6
MS.
HODGE:
Now,
I
do have
just
some
more
7
general
questions
for
Dr.
Staudt
specifically
on
behalf
8
of
U.S.
Steel.
9
MR.
FOX:
We
have
been
at
it
for
nearly
two
10
hours.
Mr.
Johnson
has
a
wise
suggestion,
why
don’t
we
11
take
a break,
come
back
at
five
after
12
and
we
will
--
12
I’m
sorry,
my
mistake.
You’d
think
I could
read
a
13
clock.
We’ll
come
back
at
five
after
11 and
resume
for
14
some
time
before
we
take
a
break
for
lunch.
15
MS.
HODGE:
That’s
sounds
great.
16
MR.
FOX:
Thank
very
much.
17
WHEREUPON,
THE
PARTIES
TOOK
A
SHORT
BREAK;
SUBSEQUENT
TO
18
WHICH
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
OF
RECORD:
19
MR.
FOX:
And
when
we
broke
approximately
20
20
minutes
ago
for
a
break
I
think,
Ms.
Hodge,
we
were
21
at
the
point
where
you
were
preparing
to
begin
some
22
questions
of
Dr.
Staudt
and
if
that
matches
everyone’s
23
recollection,
why
don’t
we
just
get
right
into
that.
24
MS.
HODGE:
That’s
correct.
Thank
you
very
67
Keefe
Reporting
Company
1
much.
2
Dr. Staudt,
in
your
pre-filed
testimony
you
3
indicated
that
some
of
the
vendors
that
you
talked
with
4
said
that
system’s
economically
available.
Did
you
get
5
any
guarantees
or
warranties
from
these
vendors
on
6
performance?
7
DR.
STAUDT:
The
vendors
as
--
as,
in
fact,
8
Mr.
Stapper
points
out
in
his
testimony
is
not
possible
9
to
provide
a
guarantee
based
upon
what
--
what
limited
10
information
I had
access
to
and
was
able
to
provide
11
them.
12
The
main
purpose
of
my
exercise
was
to
-—
13
was
to
determine
if
some
of
these
burner
suppliers
did
14
have
experience
with
some
of
these
--
with
firing
15
multiple
--
multiple
fuels,
including
low
Btu
fuels
with
16
those
Low—NOx
burners,
because
Mr.
Stapper’s
testimony
17
suggested
that
--
that
that
wasn’t
--
that
wasn’t
18
available.
With
more
detailed
information
on
the
19
boilers
it
would
be
able
to
provide
guarantees.
20
MS.
HODGE:
Okay.
So,
you
would
agree
then
21
that
the
vendors’
guarantees
on
performance
that
would
22
be
dependent
on
site
specific
factors
for
a
particular
23
unit?
24
DR.
STAUDT:
Yes,
I
would
agree
with
that.
68
Keefe
Reporting
Company
1
MS.
HODGE:
Thank
you.
2
Did
any
of
the
reported
studies
that
were
3
included
in
the
TSC
for
industrial
boilers
involve
4
boilers
burning
refinery
fuel
gas?
5
DR.
STAUDT:
This,
again,
refinery
fuel
6
gas,
yes,
there
were
the
—-
there
was
a
LADCO
study
that
7
included
the
study
of
boilers
burning
refinery
fuel
gas.
8
MS.
HODGE:
Could
you
show
me
where
that
is
9
in
the
TSC?
10
DR.
STAUDT:
There
is
actually
a
typo
in
11
the
TSC.
12
These
are
actually
gas
fired
here
on
13
tables.
14
MS.
HODGE:
I
am
speaking
with
industrial
15
burner.
16
DR.
STAUDT:
Oh,
industrial
boiler
--
17
industrial
burners
firing
refinery
--
well,
that
18
would
--
that
would
be
burning
refinery
fuel
gas.
19
There
was
also
a
study
—-
we
have
natural
20
gas
fired
boilers.
Believe
that
was
probably
back
in
--
21
do
you
recall
such
—-
recall
such
information?
22
I
do
recall
seeing
it.
I
can’t
find
it
at
23
this
point,
so...
24
MS.
HODGE:
And
I
had
a
hard
time
locating
69
Keefe
Reporting
Company
1
it
too,
but
that’s
a question
that
we would
like
an
2
answer
to, you
know,
after
hearing
that
would
be
fine.
3
DR. STAUDT:
Yeah.
4
MS.
HODGE:
Isn’t
it
true that
it’s
well
5
recognized
that
refinery
fuel
gas
emits more
NOx
than
6
natural
gas would
burn
in the
same
unit?
7
DR.
STAUDT:
Well,
I
guess
it depends
upon
8
the
exact
constituents
within
the
refinery
fuel
gas.
9
My
-- but
whether
or
not
it
is higher
or
-- or
not
10
depends
upon
the
exact
constituents.
And
you can
see
if
11
you
-- it
was
a
paper
that
was included
in the
filing
by
12
Wibell,
have
to do
with burner
use
--
use
in --
in
this
13
case
for
—- for
refineries
by John
Zink.
And you
can
14
see
that --
go to
table,
see
-— you
would see
natural
15
gas.
You can
see a
range
of different
fuels
used there.
16
Some
cases
the
NOx is
higher.
In
some cases
it’s
about
17
the
same as
natural
gas.
So, it
will
depend
upon
what
18
the
--
what
the specific
makeup
of the
gas
is.
19
MS. HODGE:
Okay.
Okay.
Thank
you.
20
So,
is --
is it
accurate
to
say
though
that
21
the
TSC’s
analysis
of industrial
boilers
for
-- for
the
22
most
part
focus
on
the gas
fired,
focused
on burning
23
natural
gas?
24
DR. STAUDT:
Well,
with
regard
to
-- there
70
Keefe
Reporting
Company
1
was
probably
more
emphasis
on
gas
fired
boilers,
because
2
that’s
what
most
gas
fired
--
gas
fired
boilers
fire
3
natural
gas,
because
that’s
what
most
of them
do
fire.
4
MS.
HODGE:
Most
of
them
fire
natural
gas?
5
DR.
STAUDT:
Most
of
them
fire
natural
gas.
6
MS.
HODGE:
Okay.
Thank
you.
7
Are
you
aware
that
most
petroleum
8
refineries
consume
the
treated
refinery
fuel
gas
on
site
9
in
facility
heaters
and
boiler?
10
DR.
STAUDT:
Yes,
I
do.
11
MS.
HODGE:
If
a
refinery
cannot
consume
12
the
refinery
fuel
gas
what
impact
would
that
have
on
the
13
energy
efficiency
of
the
refinery?
14
DR.
STAUDT:
Well,
I
--
I presume
that
you
15
want
to
use
that
gas on
site,
because
——
because
you
16
would
otherwise
have
to
-—
have
to
purchase
fuel
17
otherwise.
18
MS.
HODGE:
Thank
you.
19
And
again,
if
they
didn’t
burn
the
refinery
20
fuel
gas
in
facility
heaters
and
boilers
what
would
your
21
thoughts
be about
how
the
refinery
fuel
gas
should
be
22
disposed
of?
23
DR.
STAUDT:
I
--
I
--
my
personal
view
is
24
that
it
makes
sense
to
--
to
burn
it
in
a
way
that
71
Keefe
Reporting
Company
1
utilizes
energy
efficiency.
2
MS.
HODGE:
Okay.
3
And
I have
just
a
few questions
too
on
your
4
testimony
about
comments
on
some
of
the
cost
information
5
that
was provided
by
ConocoPhillips.
6
And
you
state
that,
this
is
on
page
three
7
of
your
pre-filed
testimony,
that
the
assumptions
that
8
capital
cost
amortization
that
cost
to
actually
capital
9
charge
was
-—
assumes
initial
versus
the
final
and
10
that’s
--
and
so
forth.
11
Is
it
possible
to
arrive
at
a wide
range
of
12
cost
per
ton
per given
project?
Would
you
agree
that
13
that’s
the
case?
14
DR.
STAUDT:
It
depends,
as
I
pointed
out,
15
depends
on
the
assumptions
you
use.
You’re
able
to
--
16
if
you
make
assumptions
about
very
rapid
amortization
of
17
capital
or
you
make
assumptions
about
very
high
indirect
18
costs
these
—-
these
all
will
increase
cost.
Of course,
19
if
you
--
if
you
use
longer
amortization
capital
that
20
that
cost
effectiveness
will
go
down.
Point
being
that
21
when
--
when
you
prepare
the
-—
the
cost
estimates
that
22
were
provided
just
--
just
the
values
that
were
23
provided,
because
I haven’t
seen
the
estimates,
there
24
are so
much
higher
than
what
has
been
published
by
a
72
Keefe
Reporting
Company
1
wide
number
of different
sources
that
my point
is
that
2
there
has
to be something
very
different
or
unique
about
3
the way
that
estimate
was
crafted,
because
it’s
15
to 20
4
times
what
a
wide
range
of
other
-—
other
sources
have
5
arrived
at,
so -- and
that
is why
it’s
important
to
6
examine
the
assumptions
of
that
cost effectiveness
7
estimate.
8
MS.
HODGE:
Okay.
Thank
you..
9
And
in the
studies
that
you
reviewed
and
10
included
in the
technical
support
document,
do
you know
11
whether
the
cost
associated
that let’s
say
for Low-NOx
12
burner,
for
example,
is
that the
cost
for the
burner
and
13
it’s
installation
or
would
that have
been
the
total
14
project
cost?
15
DR.
STAUDT:
These
-- these
would
be
the
16
total
cost
associated with
-- with
-- with
the
-- I’m
17
not
sure
what
you mean
by
the
total
project
cost,
but
18
they
would
be the
total
cost
of
the
burner
and the
19
installation
and specific
costs
that
are associated
with
20
that
project.
21
There
may
be -—
there
may be
inhouse
22
engineering
costs,
things
like
that.
But
typically
it
23
would
include
all
of those
things.
It
would
include
24
amortization
of capital
taxes
and
other
things
73
Keefe
Reporting
Company
1
associated
with
the
program.
2
MS.
HODGE:
Okay.
Has USEPA
prepared
any
3
kind
of
methodology
that
it
points
people
to
in
4
calculating?
5
DR.
STAUDT:
Yeah,
that’s
used.
They
do
6
have
methodology
in
their
cost
estimated.
7
MS. HODGE:
And
would
that
be the
USEPA
Air
8
Pollution
Control
Cost
Manual?
9
DR.
STAUDT:
That
would.
The
information
10
should
be in
there,
yes.
11
MS.
HODGE:
Okay.
So,
if
a
facility
used
12
the
methodology
there
you
would
be comfortable
with
13
that?
14
DR.
STAUDT:
Well,
you
know,
there’s
--
the
15
cost
estimating
document
also
allows
a
fair
amount
of
16
latitude
in
some
things.
So,
the
--
it
would
depend,
17
again,
I’d
have
to
examine
the
specific
estimate
and
to
18
really
get
myself
some
confidence
that
--
of
how
it
was
19
being
done.
20
MS.
HODGE:
Okay.
21
And
--
and
I
believe
that
this
control
cost
22
manual
has
been
updated
several
times.
Are
you
aware
of
23
the
most
recent
version?
24
DR.
STAUDT:
I
the
link
I
provide
in
my
74
Keefe
Reporting
Company
1
testimony
I
presume
is
the
link
to
the
most
recent
2
version
on
the
EPA’s
web
site.
3
MS.
HODGE:
Okay.
Thank
you.
4
You
stated
earlier
today
that
NOx
RACT
is
5
not
a
specific
technology,
but
the
term
does
refer
to
6
technology,
reasonably
available
technology,
and
not
to
7
an
emission
rate.
And
maybe
this
is
appropriate
for
8
The
Agency,
as
well
as
Dr.
Staudt.
What
technology
is
9
reasonable
assuming,
you
know,
economic
as well
for
10
certain
applications?
And
did
you
look
at
any
specific
11
technologies
and
attempt
to make
that
assessment?
12
DR. STAUDT:
As
far
as
what,
you
know,
the
13
way
my
understanding
of
how we’re
--
we’re
looking
at
14
RACT
is
--
is
technology
that
can
be
--
achieve
NOx
15
reduction
within
a
——
here’s
an
economic
threshold
and
16
talking
about
is
3,000
--
as
high
as
3,000
maybe
3500
a
17
ton,
somewhere
in
that
range.
18
When
you
look
at
some
of the
TSD
that
shows
19
various
technology
that
have
been
used
you
can
see
that
20
large,
for
the
most
part,
combustion
control
fall
in
21
that
range,
that
would
be
Low-NOx
burners
who
fire
air
22
from
gas
or
circulation.
That
doesn’t
mean
that
these
23
are
-— these
are
specifically
technology
for
any
and
24
every
application,
they
might,
but
there
are
appropriate
75
Keefe
Reporting
Company
1
where
they
have
been
used.
2
As
SCNR
has
been
shown
to
fall
into
that
3
range
and
even
under
some
circumstances,
but
not
all
4
I
--
I
--
if
--
if
you’re
starting
at
a low
emission
5
grade
SCR
would
not
--
would
probably
be
above
that
6
threshold,
but
we
have
seen
SCRs
installed
that
that’s
7
been
documented
that
provide
emission
reductions
in
the
8
ranges
of
hundreds
of
dollars
per
ton
that
NOx
reduce
9
and
that
that’s
been,
but
those
coal
fire
units
higher
10
emission
rate.
11
So,
if
you
want
to
define
RACT
from
the
12
perspective
of
--
I’m
not
a
--
I’m
not
a
regulator.
So,
13
I’m
more
of
a
technology
guy.
So,
my understanding
of
14
the
way we’re
approaching
RACT
is
can
it
be done
at
a
15
reasonable
cost,
reasonably
available,
achievable
at
a
16
reasonable
cost.
If
there’s,
you
know,
there’s
another
17
reason,
there’s
another
definition
some
place
within
18
the,
you know,
the
CFR document
or something
like
that
19
I’m
not
sure
about
that.
That’s
what
we’ve
been
working
20
on.
21
MS.
HODGE:
Did
you
make
any
specific
22
recommendations
to
the
agency
as
to technologies
23
involving
RACT?
24
DR.
STAUDT:
It’s
not
--
it
doesn’t
--
no,
76
Keefe
Reporting
Company
1
not
specifically,
because
what
we
needed
to
do
and
you
2
can
——
there
——
there
are
some
things
that
you
could
see
3
from
my
original
pre-filed
testimony
from
the
October
4
hearing.
And
I
commented
on
the
type
of
technology
that
5
I
envisioned
potentially
being
used
for
different
types
6
of
sources.
But
it’s
not
——
it’s
not
for
--
the
7
objective
was
not
to
dictate
a
specific
technology
for
8
each
source.
The
objective
was
to
set
emission
limits
9
that
technologies
have
been
demonstrated
to
achieve
10
within
the
cost
--
within
the
cost
range
that
we’ve
been
11
looking
at
and
that
will
--
that
will
differ
from
one
12
application
to
another.
13
MS.
HODGE:
Okay.
Thank
you.
Thank
you.
14
And
again,
this
question
I
think
is
to
15
The
Agency,
as
well
as
Dr.
Staudt:
Did
The
Agency
and
16
Dr.
Staudt
in
preparing
the
TSD
consider
higher
emission
17
limits
than
those
proposed
in
the
rule
or
lower
limits?
18
And
can
you
share
what
factors
were
19
considered
in
the
selection
of
--
of
the
proposed
limits
20
here?
21
DR.
STAUDT:
Well,
you
know,
we
--
we
did
22
discuss
different
limits
and
what
we
looked
at
--
limits
23
were
discussed.
And
in
some
cases
the
feeling
was
in
24
some
cases
it
may
have
been,
you
know,
too
low
and
it
77
Keefe
Reporting
Company
1
may
sense
to
increase
it,
because
we
didn’t
feel
that
2
the
limit
would
be
achievable
without
--
without
using
3
something
that
would
likely
be
more
costly
than
what
we
4
envisioned.
You know,
when
my ——
my
——
my
——
my
5
involvement
mainly,
you
know,
involved
getting
my
6
opinion
on
some
of these
emission
levels.
And
in
some
7
cases
we
--
we
--
I’ve
provided
input
that
they
--
they
8
needed
to
be
adjusted
and those,
generally,
they
were
9
adjusted
and
in
other
cases
they
said
that
they
were
10
fine.
The
emissions
levels
that
are
in
the
new
proposed
11
rules
are
emissions
rules
that
I do
feel
comfortable
12
with
at
this
point.
13
MS.
HODGE:
Thank
you.
14
Mr.
Kaleel?
15
MR.
KALEEL:
I’m
not
sure
that
I
can
add
16
too
much
to
the
--
to the
comments
that
Mr.
Staudt
had
17
just
provided.
18
We,
you
know,
our
process,
you know,
it’s
19
been
described
already
on
the
record
was
to
identify
the
20
types
of emissions
sources
within
our non-attainment
21
areas
that
were
NOx emissions,
emission
units
that
22
existed
at
a
——
at
a major
source
within
the
23
non-attainment
area,
look
at
the
population
of
the
24
units,
whether
there
are
--
whether
they’re
boilers,
78
Keefe
Reporting
Company
1
whether
they’re
process
heaters,
whether
they’re
blast
2
plants,
whether
they’re
steel
furnaces,
what
--
what
are
3
the
emission
units
that
exist
in
Illinois
for
those
4
emission
units.
We
—- we
viewed
the
literature
in
terms
5
of
proven
control
technologies
for
a
wide
range
of
6
applications
and
what
were
their
associated
costs.
And
7
we
did
arrive
from
that
analysis
I think
--
I
think
the
8
example
that
Deirdre
K.
Hirner
was
pointing
us
to
a
9
moment
ago
was
an
example
of
that
was you
look
at
the
10
technologies
that
are
available,
again,
for
a
wide
range
11
of sources
and
see
if
--
if
they’re
cost
effective.
12
And
emission
limits
were
--
were
based
on
a
13
review
of
that
information.
I
would
point
out
that
I
14
don’t
perceive
it
to
be
the
agency’s
job
to
establish
an
15
emission
limit
that
works
for
every
unit
in
the
State
of
16
Illinois,
that
there’s
hundreds
of
NOx emission
limits.
17
And I
think
it
would
be
inappropriate
for
us
to
18
establish
a
limit
that
is
at
the
high
range
to
wherever
19
any
unit
in
the
state
can
easily
comply.
I
don’t
think
20
we
would
achieve
any
emission
reduction
or
very
little
21
emission
reduction
at
all.
22
I think
the
job
is
to
try
to
establish
an
23
emission
limit
that
we think
is
cost
effective
for
most
24
of
the
units
in
the
state
and
through
this
process
both
79
Keefe
Reporting
Company
1
our
own
outreach
process
and
the
regulatory
process
2
before
The
Board
to
identify
the
outliners.
And
I think
3
this
process
has
accomplished
that.
We’ve
heard
from
4
individual
industries
that
have
pointed
out in
unique
5
circumstances.
Certainly,
U.S.
Steel
is
here
today
as
a
6
unique
circumstance.
My
understanding
they’re
the
only
7
unit
within
the
State
of
Illinois
that
burns
coke
oven
8
gas
and
natural
gas
and
various
combinations.
That
is
a
9
unique
circumstance..
And we
envision
a dialogue
to
try
10
to
address
those
specific
circumstances,
but
the
rules
11
intend
to
provide
a
--
a
cost
effective
approach
that
12
works
for
most
industries.
And
again,
I think
we’ve
--
13
I
think
what
we’ve
proposed
does
that.
14
MS.
HODGE:
Thank
you.
15
You
--
you
said
that
in
doing
this
that
16
The
Agency
identified
the
subject
units
in
the
State
of
17
Illinois.
And
let’s
just
take
a look
at
industrial
18
boiler
and
process
heaters.
And
then
in
then
evaluating
19
RACT
was
there
any
consideration
of
alternative
fuels
in
20
setting
the
proposed
limits
here
for
gas
fired
21
industrial
boilers
and
for
process
heaters?
22
MR.
KALEEL:
Well,
certainly
in
the
case
of
23
industrial
boilers
our
--
our
technical
support
document
24
and
the
emission
limits
that
we’ve
proposed
envision
a
80
Keefe
Reporting
Company
1
variety
of
fuels.
There’s
emission
limits
proposed
for
2
natural
gas,
for
fuel
oil, for
solid
fuels.
So,
I
think
3
we
did
look
at that.
I
understand
the process
heaters
4
perhaps
as
smaller
population
of affected
units,
but
5
we --
we envision
that
these
will
apply
for
the most
6
part to
refineries.
And
we’re
certainly
aware
that
7
refineries
just
process
gasses
for
those
fuels.
And
we
8
believe
we’ve
identified
cost
effective
control
options
9
and
established
emission
limits
that
will work
with
the
10
types
of
fuels
that
are used
at
refineries.
11
We —— we
have
every confidence
that
12
we’ve
—— if
we’ve
overshot
the
mark
that we’re
going
to
13
hear
from
those
stakeholders
and,
in
fact, we
have.
And
14
we’ve
talked
about ways
to
be more
flexible
in the
15
application
of
-- of these
requirements.
We’ve
-- the
16
average
plant
is an
example
that
flexibility
where
a
17
company
would
have the
option
of
perhaps
controlling
18
first
those
units
that
are easiest
and
most
cost
19
effective
to
achieve
reductions
with
the idea
that
20
perhaps
other
units
that might
be
more
difficult
perhaps
21
don’t need
to be
controlled
at all
or would
be
22
controlled
as
a
lesser
level
as long
as
the
average
23
works
out.
And I
think
that
would satisfy
the
24
requirements
and
the rules
that
we’ve
-- we have
tried
81
Keefe Reporting
Company
1
to be
flexible
in
the approach.
2
MS.
HODGE:
And
I acknowledge
and
--
and
3
I’ll
tell
you
I
think
regulate
does
appreciate
that,
but
4
again,
I
just
want
to
clarify
in
--
in
setting
the
5
proposed
limit
here
.08
for
gas
fired
industrial
boilers
6
did
The
Agency
consider
the
use
of
alternative
fuels
7
such
as
refinery
fuel
gas
setting
that
limit
of
.08?
8
MR.
KALEEL:
We
--
I think
we
have
9
considered
whether
refinery
fuel
gas
is
being
used.
And
10
I
believe
that
we
have
seen
information
provided
to us
11
by
the
refineries
that
--
that
the
technologies
that
we
12
envision
within RACT
will
achieve
the
.08
limit
that
is
13
contained
in
the
rule.
We
understand
there
are
some
14
unique
circumstances
and
we
—— we
have
always
been
15
willing
to
talk
about
those
and remain
to be
willing
to
16
talk
about
those,
but
we
think
in
general
the
.08
limit
17
works
quite
well
for
processors.
18
MS.
HODGE:
So,
The
Agency
continues
to be
19
open
to
consideration
of
the
case
by
case
RACT?
20
MR.
KALEEL:
Absolutely.
I
don’t
know
case
21
by
case,
that’s
a
different
--
different
concept,
but
22
we’re
--
certainly
are
willing
to
continue
working
with
23
stakeholders
that
--
to
develop
an
approach
and
perhaps
24
pursue
an amendment
to
this
proposal
that
is
a
better
82
KeGfe
Reporting
Company
1
fit
for
unique
circumstances.
2
MS.
HODGE:
Okay.
Thank
you.
3
I
think
that’s
all
my
questions.
4
May
I
have
just
a moment?
5
MR.
FOX:
Yes,
that’s
fine,
Ms.
Hodge.
6
WHEREUPON,
THERE
WAS
A SHORT
PAUSE
IN
PROCEEDINGS;
7
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
8
OF
RECORD:
9
MS.
HODGE:
I
‘m
--
I don’
t
have
any
more
10
questions.
11
MR.
FOX:
Very
good.
Thank
you,
Ms.
Hodge.
12
Was
there
any
other
participant
that
had
13
questions
for
Dr.
Staudt
on
the
basis
of
his
pre-filed
14
testimony
at
this
point?
15
(No response.)
16
Seeing
that
there’s
no
indication
of any
17
follow
up
questions
for
Dr.
Staudt,
Dr.
Staudt,
thank
18
you
for
your
testimony
and
your
responses
to
questions
19
That
brings
us
to Ms.
Roccaforte’s
standing
20
motion
to admit
hearing
Exhibits
20 through
24,
which
21
were,
as
I
recall,
offered
as
attachments
or
supplements
22
to
his
pre-filed
testimony
and
we had
deferred
23
consideration
of
that
motion
specifically
at
your
24
request,
Ms.
Hodge.
Do
you
or
any
other
participant
83
Keefe
Reporting
Company
1
wish
to
be
heard
on
motion
to
admit
hearing
Exhibits
2
Number
20
through
24
as
attachments
to
Dr.
Staudt’s
3
pre-filed
testimony?
4
MS.
HODGE:
We
have
no
objection
as
5
U.S.
Steel,
but
we
will
be
making
some
brief
comments
6
today
and
we
do
expect
to
be
submitting
post
hearing
7
comments,
additional
comments
on
--
8
MR.
FOX:
We’ll
certainly
take
up
the
9
hearing
--
the
post—hearing
comments
and
those
deadlines
10
before
we
wrap
up
today.
11
Seeing
or
and
hearing
no
objection
to
the
12
admission
of
those
exhibits,
Ms.
Roccaforte,
they
have
13
been
marked
and
will
be
admitted
as
Exhibits
Number
20
14
through
24
corresponding
to
the,
of
course,
to
the
15
preliminary
numbers
that
we
had
assigned
to
them
16
earlier.
So,
we
have
addressed
those.
17
That
would
in
effect
bring
us
to
U.S.
18
Steel.
Noting
the
objections,
Ms.
Roccaforte,
you
had
19
made
The
Board
did
receive
pre-filed
testimony
from
20
Mr.
Stapper.
21
nd
Ms.
Hodge,
I
believe
you
had
indicated
22
that
Mr.
Siebenberger
wished
to
be
sworn
and
offer
a
23
brief
statement
or
summary
of
--
24
MS.
HODGE:
Yes.
84
Keefe
Reporting
Company
1
MR.
FOX --
of
the company’s
position.
Did
2
you
have
a specific
sense of
whether
you
prefer
to begin
3
with Mr.
Siebenberger
or Mr.
Stapper?
4
MS.
HODGE:
I think
we
prefer
to start
with
5
Dr.
Siebenberger.
6
MR.
FOX:
Why
don’t
we
do
this
then, why
7
don’t
we have
the
court
reporter
swear
both gentlemen
8
in.
9
And
Mr. Siebenberger,
if
you’re
ready
we
10
could
go ahead
with
a
statement
or summary
of
remarks
on
11
your
part
in
just a
moment
then.
12
WHEREUPON,
MR.
SIEBENBERGER
AND MR.
STAPPER
WERE
FIRST
13
DULY
SWORN;
AND THEN
TESTIFIED
AS
FOLLOWS:
14
MR. FOX:
Mrs.
Hodge,
please,
go
ahead
if
15
you
want
to make
any
introductions.
16
MS.
HODGE:
Thank
you so
much.
17
As Mr.
Fox indicated
we
did
file
this
18
pre—filed
testimony
of Mr..
Stapper
yesterday
afternoon.
19
We
did
serve
everyone
on
the
service
list electronically
20
so
they’d
have
a
copy,
but
I note
some
members
of the
21
public
here
today.
We do have
additional
copies
of
the
22
testimony
if anyone
wants
a copy.
23
MR.
FOX:
I appreciate
that,
Ms. Hodge.
24
MS..
HODGE:
And
I guess
before
we
get
85
Keefe
Reporting
Company
1
started
I
would
like
to move
for
the
admission
of
that
2
pre-filed
testimony.
3
MR.
FOX:
Do
you
have
copies
that
could
be
4
circulated,
Ms.
Hodge?
5
MS.
HODGE:
Yes.
How
many
do you
need?
6
MR. FOX:
Just
a
single
one,
frankly.
7
MS.
HODGE:
Okay.
8
MR.
FOX:
And
Ms.
Hodge
has moved
admission
9
into
the
record
of
Mr.
Stapper’s
pre-filed
testimony,
10
which
would
be
hearing
Exhibit
Number
25.
11
Is
there
any
objection
to
the
motion?
12
MS.
ROCCAFORTE:
I
indicated
at
the
13
beginning
of hearing
The
Agency’s
objection
to the
14
pre-filed
testimony
of
Mr. Stapper.
15
MR.
FOX:
Certainly
I
acknowledge
your
16
objections,
Ms.
Roccaforte.
17
I’ll
go ahead
and
admit
that
as I
indicated
18
as
Exhibit
Number
25.
19
Mr.
Stapper
certainly
is
available
here
and
20
has
been
sworn
and
will
be
available
for
questions
on
21
the
basis
of
that
pre-filed
testimony
today.
22
That
will
be,
as
I
said,
be
marked
as
23
Exhibit
Number
25.
24
And
Ms. Hodge,
thank
you
for
supplying
a
86
Keefe
Reporting
Company
1
copy
and
please,
go
ahead.
2
MS.
HODGE:
We’ll
do.
3
Also,
as
--
as
we’ve
discussed
4
Mr.
Siebenberger
has
a
brief
statement.
5
And then
as
to
Mr.
Stapper,
again,
since
6
this
was
filed
late
I would
like
him
to
read
some
of
7
this
into
the record,
not
all
of
it,
of
course,
but
just
8
so
folks
do
have
an
opportunity
to
--
to
hear
the
9
testimony,
but
--
10
MR.
FOX:
It
would
be
a
long
read
in
its
11
entirety.
If
in
your
judgment
there
are
some
select
12
portions
of
it
that
would
be
appropriate.
That
would
be
13
fine.
14
MS.
HODGE:
Okay.
Thank
you so
much..
15
And
then
let’s
--
let’s
start
with
16
Mr.
Siebenberger.
17
MR.
SIEBENBERGER:
Okay.
Thank
you.
18
We are
currently
reviewing
Dr.
Staudt’s
19
submittals
and
I’m
sure
upon
our
analysis
we
will
have
20
additional
comments
we
will
file
post
hearing,
but
at
21
this
point
in
time
I
just
had
a couple
of general
22
statements
I’d
like
to
make
regarding
our
analysis
thus
23
far.
24
First
of
all,
you
know,
I
do
not
disagree
87
Keefe
Reporting
Company
1
with Dr. Staudt’s
premise
that
we, obviously,
can’t
burn
2
more
coke
oven gas in
a given
year than
we produce
and I
3
think
it’s physically
impossible
and we
understand
that.
4
I
think though
that
what
Mr.
Staudt
is not
5
considering
is
that from
year
to year our operating
6
scenarios
that
we may
operate
our
facilities
under
can
7
change. And
as historically
you can
look
at
how
we’ve
8
operated our
facilities
where
we
were
operating
coke
9
ovens,
blast furnaces
and
steel
making
shops
and
10
finishing,
which
includes
our reheat
furnaces
all
at
the
11
same time.
But
as an example
of how what
can happen
12
going
forward
today
we
are operating
our
facility
with
13
just
the coke
ovens running
and our
boilers
running.
14
Our blast
furnaces
are idle.
Our steel
making
15
facilities
are idled
and reheat
furnace
is
idle.
And
we
16
cannot
at this
point in
time say that
we will
not
17
operate
this way
for the entire
year.
Market
conditions
18
will
dictate
that.
19
Under the
current
operating scenario
that
20
we’re under
the
only
place
we can
burn coke oven
gas
is
21
our boilers.
So we
cannot
consume
coke oven
gas in
our
22
reheat furnaces
and take
the remainder
to the
boilers.
23
And
I think
this is
just one example
of it’s
a changing
24
world
from
where
we’ve
operated
in the past.
And I
88
Keefe
Reporting
Company
1
think
we
will
be
required
to operate
our
facilities
2
under
different
operating
scenarios,
which
will
be
3
dictated
by market
in
our
--
in
U.S.
Steel’s
desire
to
4
be
competitive.
5
One
other
comment
I
would
make
that
I think
6
Dr. Staudt’s
assumption
that
we would
not shut
down
the
7
coke
oven
gas
sulfurization
for
maintenance
during
the
8
ozone
season. And
I
do not
believe
that
we
at
this
time
9
can
guarantee
that
we
will
not
have
to
do
that.
10
Obviously,
you
know,
we have
been
trying
to
schedule
11
this
outage,
but
the
condition
of
the
equipment
may
12
dictate
when
we
have
to
take
it
down
for
maintenance.
13
And
I
don’t
think
we
can
guarantee,
as
I
said,
that
--
14
that
we
would
not
have
shut
the
facility
down
during
the
15
ozone
season
and
that’s
built
into
your
assumptions
16
also.
17
And
that’s
really
all
I
have
to
say
at
this
18
time..
I
guess
I
think
we
will
have
some
additional
19
comments
once
we
finish
our
analysis.
20
Thank
you.
21
MR.
FOX:
Thank
you,
Mr.
Siebenberger.
22
And
as I
said
just
a moment
ago,
we
will
23
address
timeline
for
filing
post-hearing
comments.
We
24
will
get
that
issue
resolved
by
the
--
the
end
of
day.
89
Kfe
Reporting
Company
1
Was
there
any
question
on the
basis
of
2
Mr.
Sieberiberger’s
testimony
and
comment
today
that
--
3
that
they
would
like
to
pose
to
him?
4
(No
response.)
5
MR.
FOX:
Seeing
that
there
is
not
one,
6
Ms.
Hodge,
it
sounds
like
we would
be
in
order
to
7
proceed
to Mr.
Stapper
if
you
want
to
do
a
brief
8
introduction.
9
MS.
ROCCAFORTE:
I
--
I
just
have
one
quick
10
question.
11
MR.
FOX:
I’m
sorry,
Ms.
Roccaforte,
I
12
didn’t
mean
to
overlook
you,
of
course.
13
MS.
ROCCAFORTE:
Mr.
Siebenberger,
I
was
14
just
wondering
if
you
are
still
willing
to continue
15
discussions
with
The
Agency
on these
issues
that
are
16
outstanding?
17
MR.
SIEBENBERGER:
Yes,
absolutely.
We
18
were
attempting
to
get
together
before
the
hearing,
but
19
scheduling
did
not
permit
it.
We
would
be
happy
to
do
20
that.
21
MS.
ROCCAFORTE:
Thank
you.
22
MR.
FOX:
Any follow
up?
23
MS.
ROCCAFORTE:
That’s
it.
Thank
you.
24
MR.
FOX:
Sorry,
again,
for
overlooking
90
Keefe
Reporting
Company
1
you.
2
Ms.
Hodge,
I’m
sorry,
back
to you
if
you
3
had
a
brief
introduction
for
Mr.
Stapper.
4
MS.
HODGE:
Certainly.
5
As
I
said,
Mr.
Blake
Stapper
is
now
going
6
to
offer
some
testimony. And
Mr.
Stapper
had
testified
7
at
one
of
the
prior
hearings
in
Chicago
back
in
8
Deceiriber.
And
then
when
we
reviewed
Dr.
Staudt’s
9
pre-filed
testimony
U.S.
Steel
made
a
determination
that
10
it
wished
to,
you know,
offer
some
comments
on
that
11
today
as well.
12
And
again,
I
apologize
for
the
late
filing,
13
but
we
had
not
intended
initially
to
offer
testimony.
14
Mr.
Stapper
had
prepared
testimony
and
again,
because
of
15
the
late
filing
I
would
ask
that
he
be
allowed
to
read,
16
you
know,
some
of
it
into
the
record,
you know,
of
17
course,
summarizing
other
parts,
but
I
think
there
were
18
a
couple
of
typos
that
he
needed
to
correct
from
the
19
pre-filed
to
his
testimony
here
today.
20
MR.
FOX:
Very
good.
21
I should
have
emphasized,
Ms.
Hodge
and
22
Mr.
Stapper, under
The
Board’s
rules
pre-filed
testimony
23
is
entered
into
the
record
as
if
read
in
it’s
entirety,
24
so
while
there
may
be
corrections
or
other
issues
that
91
Keefe
Reporting
Company
1
would
be
best
addressed
by
reading
it
out
loud,
we
2
certainly
would
want
to
emphasize
in
the
interest
of
3
moving
forward
expeditiously
it
is
in
the
record
as
if
4
read
and
perhaps
lengthy
repetition
shouldn’t
be
5
necessary.
6
MS.
HODGE:
Thank
you.
7
MR.
FOX:
Please,
go
ahead.
8
MR.
STAPPER:
Again,
thank
you
for
allowing
9
me
to
speak
this
morning.
10
My
name
is
Blake
Stapper.
I’m
principal
11
engineer
for
URS
Corporation.
We
were
contracted
to
12
perform
a
study
for
U.S.
Steel
to
provide
our
13
reconunendations
for
burn
suitable
controls
to
apply
to
14
Boilers
11
and
12.
15
I
wanted
to
acknowledge
Dr.
Staudt’s
16
efforts
to
--
to
dig
into
the
particulars
of
his
17
applications
and
to
try
to
develop
further
information
18
to
help
us
all
come
to
a
better
understanding
of
Boiler
19
11
and
Boiler
12,
what
technologies
would
be
appropriate
20
there.
And
I
believe
that
his
efforts
have
head
us
down
21
a
road
that
we
will
be
able
to
better
illustrate
for
22
The
Board
what
the
considerations
are
for
this
23
particular
application
and
how
URS
arrived
at
it’s
24
recommendation
for
U.S.
Steel.
92
Keefe
Reporting
Company
1
Would
it
be
appropriate
to
--
in
the
2
pre-filed
testimony
there
is
one
paragraph
that
contains
3
a
number
of typos.
It
is
the
first
paragraph
on
page
4
six,
the
third
line
in
that
paragraph
should
read
5
40
percent
COG,
35 percent
BEG.
6
MS.
BASSI:
I’m
sorry,
I
didn’t
hear
that.
7
MR. STAPPER:
It
should
read
40
percent
COG
8
and 35
percent
BEG.
9
MS.
BASSI:
Thank
you.
10
MR.
STAPPER:
And
in
addition
down
on
the
11
sixth
line
that
begins
“blast
furnace
down”
the
blend
12
should
be
40
percent
NG and
60
percent
COG.
13
MR.
STAPPER:
And
that’s
the
extent
of
the
14
typos
that
I
am
aware
of.
15
MR.
FOX:
Very
good.
16
MR.
STAPPER:
If
--
and
if
it
pleases
17
The
Board
I
would
attempt
to
parcel
this
down
and
I
18
appreciate
-—
my
voice
appreciates
your
willingness
to
19
meet
in
the
middle
somewhere
maybe
reading
the
20
introductory
sections
that
--
that
speak
in general
21
about
our
study
and
then
skipping
the
details
of
the
22
specific
vendor
by
vendor
analysis
and
picking
it
up
23
again
with
the
conclusions
in
the
summary
statements.
24
MR.
FOX:
Why
don’t
we
start
and
see
where
93
Keefe
Reporting
Company
1
this takes
us,
Mr.
Stapper.
Why don’t
you go ahead.
2
MR.
STAPPER:
Okay.
3
Good morning.
My
name
is
Blake
Stapper.
4
am a principal
engineer
for URS
corporation.
And
I
5
previously testified
before
the
Illinois
Pollution
6
Control
Board in
this matter
on December
10th, 2008.
7
The
purpose of
my testimony
today is
to provide
8
information
in
support of
the reasonably
available
9
controlled
technology
determination
for Boilers
11
and
10
12 at U.S. Steel’s
Granite
City
Works. In particular
I
11
wish
to
respond
to the
comments
offered
by
12
Dr. James
E.
Staudt
in his
pre-filed
testimony filed
13
with The Board
on
January
20,
2009.
14
In
his
testimony
Dr.
Staudt contended
that
15
the URS study,
which
was
commissioned
by U.S. Steel,
is
16
suspect because
of
errors
and
inconsistencies
that he
17
identified
and
suggested
that URS
did not perform
a
18
complete diligent
analysis.
19
To
support
his
conclusions
he noted
that
20
URS
did not contact
any
burner
boiler
suppliers
directly
21
about
the application
of their
technologies
to Boiler
11
22
and 12.
Dr.
Staudt
disputed
URS’s claims
that
there
are
23
no Low-NOx
burners
suitable
for application
to Boilers
24
11 and 12
by referencing
communications
he had with
four
94
Keefe
Reporting
Company
1
burner
vendors
who
all
indicated
that
they
could
provide
2
Low—NOx
burners
for
multi-fuel
applications.
I would
3
like
to address
each
of
these
points
in
turn.
4
At
any
given
time
URS
is
executing
numerous
5
projects
to
implement
NOx
controls
on
industrial
6
boilers.
These
turnkey
projects
involve
engineering,
7
procurement,
construction,
and
start
up.
These
projects
8
included
burner
replacement
with
and
without
free
glass
9
circulation
or
FGR.
FGR
addition
to
existing
burners,
10
Selective
Catalytic
Reduction
installations,
and
a
few
11
Selective
Non-Catalytic
Reduction
installations..
The
12
contract
terms
generally
require
URS
to
provide
13
emissions
guarantees.
As
such,
URS
places
both
it’s
14
professional
reputation
and
it’s
financial
interest
at
15
stake
when
performing
these
projects,
and
we
work
16
diligently
to
protect
both.
17
The
success
of these
projects
requires
URS
18
to
have
relationships
with
a
number
of burner
19
manufacturers
and
boiler
suppliers.
As such
we
not
only
20
have
access
to
the
most
current
information
on
available
21
technologies,
but
we
also
have
practical
knowledge
of
22
how
such
technologies
perform
a
variety
of
real
world
23
applications.
As
a
result
of
our
ongoing
experience
24
with
these
installations,
it
is
not
necessary
for
us
to
95
Keefe
Reporting
Company
1
contact
vendors
when
we
conduct
a study
such
as
the
one
2
that
we
completed
for
U.S.
Steel.
3
MR.
FOX:
Mr.
Stapper,
you’ve
gone
on
to
4
describe
some
of
the
key
operating
circumstances
based
5
by
U.S.
Steel
and
your
--
you
go
on
to
address,
I
6
believe,
four
different
vendors.
Would
it
be
7
appropriate
to
summarize
any
conclusions
that
you
might
8
have
drawn
on
the
basis
of
these
operating
circumstances
9
and
those
four
vendors?
10
MR.
STAPPER:
If
you
would
like
I’ll
skip
11
down
to
our
conclusions.
12
MR.
FOX:
That
would
be
great..
Thank
you.
13
MR.
STAPPER:
In
summary,
of
the
four
14
burner
vendors
contacted
by
Dr.
Staudt
all
four
proposed
15
solutions
using
a combination
of
their
own
burners
with
16
FGR.
Three
of the
four
vendors
estimated
that
their
17
solution
would
result
in NOx
emissions
at
or
above
the
18
0.113
pound
per
million
Btu
level
that
U.S.
Steel
has
19
already
proposed
to
achieve
by
adding
FGR
to
it’
s
20
existing
burners.
The
fourth
vendor,
Coen,
while
21
suggesting
that
it
could
achieve
lower
NOx
emissions,
22
noted
that
the
burner
for
Boiler
11
would
have
to be
a
23
custom
design.
Coen
also
confirmed
that
it
does
not
24
have
a
single
application
in which
they
are
co-firing
96
Keefe
Reporting
Company
1
natural
gas,
coke
oven
gas
and
blast
furnace.
In
2
addition,
URS
contacted
a
widely
respected
expert
in
a
3
design
and
operation
of
SNCR
systems
who
stated
that
he
4
did
not
think
that
SNCR
would
be
able
to
achieve
NOx
5
RACT
emission
limits
proposed
by
the
Illinois
EPA,
6
either
as
a
stand-alone
solution
or
applied
in
7
combination
with
another
NOx
control
technology.
8
I
would
like
to
verify
that
URS
conducted
a
9
complete
and
diligent
analysis
of
the
available
NOx
10
control
technologies
for
Boilers
11
and
12
at
U.S.
11
Steel’s
Granite
City
Works.
Our
conclusions
were
based
12
on
decades
of
practical
experience
and
successfully
13
applying
NOx
controls
to
a
variety
of
combustion
14
equipment.
It
is
my
contention
that
this
experience
is
15
more
relevant
than
the
information
that
has
been
16
obtained
by
Dr.
Staudt
through
internet
searchs
and
via
17
brief
E-mail
exchanges
to
vendors
that
lacked
crucial
18
specifics
of
this
particular
application.
19
Thank
you
for
allowing
me
the
opportunity
20
to
present
my
statement
today.
I
would
be
happy
to
21
answer
any
questions.
22
MR.
FOX:
Thank
you,
Mr.
Stapper.
23
I
bet
there
are
at
least
a
couple
questions
24
and
you
can
proceed
to
those..
If
there
is
anyone
who
97
Keefe
Reporting
Company
1
wishes
to
pose
a
question
based
on
that
testimony.
2
MS.
VETTERHOFFER:
Dana
Vetterhoffer,
3
Illinois
EPA.
4
Mr.
Stapper,
at
the
December
9th,
2008
5
hearing
Mr.
Siebenberger
testified
that
Exhibits
A
and
B
6
to
his
pre-filed
testimony
were
based
on
an
evaluation
7
performed
by
URS.
At
that
time
The
Agency
requested
a
8
copy
of
the
evaluation,
which
Mr.
Siebenberger
agreed
to
9
provide.
10
Last
Friday
in
response
to
The
Agency’s
11
request
U.S.
Steel
filed
a
NOx
reduction
study..
I
12
believe
you
mentioned
it
was
part
of
the
materials
13
filed.
The
report
has
a
date
of
March
2008
on
it.
14
Was
a
report
originally
prepared
in
March?
15
MR.
STAPPER:
The
RACT
analysis
report
16
was
--
that
U.S.
Steel
based
it’s
calculations
upon
--
17
was
dated
March
2008.
18
MS.
1ETTERHOFFER:
As
far
as
you
know
that
19
version
of
the
report
was
relied
upon
by
U.S.
Steel
for
20
the
December
hearing,
correct?
21
MR.
STAPPER:
Yes.
22
MS.
VETTERHOFFER:
At
the
bottom
of
the
23
report
that
was
filed
with
U.S.
Steel
documents
it
says
24
REV1
January
19,
2009.
98
Keefe
Reporting
Company
1
Was
the
report
revised
after
the December
2
hearing
before
being
submitted
to
The
Board?
3
MR.
STAPPER:
Yes.
4
MS.
VETTERHOFFER:
Was
this the first
5
revision
that
you know of since
the
March
2008
date?
6
MR..
STAPPER: It
is the first
revision
that
7
I am aware
of.
8
MS.
VETTERHOFFER:
And why was
the report
9
revised
before being
submitted
to
The Board?
10
MR. STAPPER:
I believe
that there was
11
information
in the report
that
was
-- that
was believed
12
was
not necessary
to include
for
business
13
confidentiality
purposes.
There
may
have also
been some
14
clarifications
in the
original
language
in the report.
15
There
were no
substantive
changes
in the report.
16
MS. VETTERBOFFER:
So,
just to summarize,
17
you
may have
clarified
a few things
and
then a few
thing
18
were
redacted
under the
concept of
business
19
confidentiality;
is that
accurate?
20
MR.
STAPPER: That’s
correct..
21
MS.
VETTERHOFFER:
Is there any
way that
22
the revisions
could be
submitted
to The Board
perhaps,
23
you
know, under
business
confidentiality,
not
viewed
by
24
anyone
else
but
The Board and
The Agency?
We
would
just
99
Keefe
Reporting
Company
1
like
a
copy
of
the
original
version
of
the
report
as
it
2
existed
on
December
9th
and
10
from
the
last
hearing
3
took
place.
4
MR.
STAPPER:
Those
documents
are
owned
by
5
U.S.
Steel,
so.
6
MS.
HODGE:
We
will
certainly
entertain
7
your
request
and
speak
with
folks
at
corporate
and
we
8
will
respond.
9
MR.
FOX:
Just
for
the
record,
The
Board
10
has
it’s
own
procedure
for
submitting
privileged
11
documents
or
documents
that
would
be
except
from
12
disclosure,
which
may
not
be
precisely
the
same
as
the
13
Agency’s.
14
MS.
HODGE:
That’s
correct.
15
MS.
VETTERHOFFER:
Thank
you.
16
Similarly,
at
the
December
hearing
17
The
Agency
requested
a
copy
of
the
technical
proposal
18
U.S.
Steel
had
received
from
Bloom
Engineering
for
the
19
burners
on
reheat
furnaces.
The
documents
submitted
to
20
The
Board
as
attachment
F,
however,
is
dated
January
21
22nd,
2009.
22
When
exactly
did
U.S.
Steel
or
URS
first
23
obtain
the
proposal
from
Bloom?
24
MR.
STAPPER:
I
can’t
answer
that.
:ioo
Keefe
Reporting
Company
1
MS.
VETTERHOFFER:
Do
you
know
--
do
you
2
happen
to
know
if
U.S.
Steel
might
have
that
3
information?
4
MS.
HODGE:
We
will
be
happy
to
check
on
5
that.
6
MR.
STAPPER:
Again,
to
clarify
for
the
7
purposes
of
questions
for
me,
I
focused
on
the
two
8
boilers
so,
blast
furnaces
those
questions
will
be
9
better
directed
elsewhere.
10
MR..
FOX:
Mr.
Stapper,
we
lost
most
of the
11
volume.
12
MR.
STAPPER:
I’m
sorry.
I’m
trying
to
get
13
closer.
14
The
questions
as
they
pertain
to
me
--
my
15
role
in
this
analysis
was
really
two
boilers.
And
so,
16
the
questions
for
the
reheating
furnaces
should
go
17
elsewhere.
18
MS.
VETTERHOFFER:
Could
we
take
a
short
19
break?
The
laptop
computer
that
we’re
using
has
a
low
20
battery.
We
just
need
to
recharge
or
use
a
different
21
computer.
22
MR.
FOX:
That
would
be
fine.
23
Why
don’t
go
off
the
record.
24
WHEREUPON,
THE
PARTIES
TOOK
A SHORT
BREAK;
SUBSEQUENT
TO
101
Keefe
Reporting
Company
1
WHICH THE
FOLLOWING
PROCEEDINGS
WERE
MADE OF RECORD:
2
MR. FOX:
We are
back
on the record.
3
We
did want
to interrupt.
I
appreciate
4
The Agency’s
flexibility
on
this, the
order of our
5
proceedings.
6
We
have Ms.
Amy
Funk,
a member
of the
7
public,
who
has a comment
that she
has prepared
that
she
8
would like
to deliver.
9
And
please,
Ms.
Funk, when
you’re ready
10
proceed with
that.
Thank
you
for
your patience.
11
MS.
FUNK:
Well, I
should thank
you for
12
humoring me
and my
daughter
here. I’m
a little
-- this
13
is my first public
hearing
--
public hearing,
so I’m
a
14
little
out of my
element,
honestly.
So, I
do apologize
15
if this is
not
appropriate
for this
type of forum.
16
MR.
FOX:
Ms. Funk,
if I may
introduce
you.
17
You’re
doing fine.
If you
would
identify any group
or
18
organization
that
you might
represent.
19
MS. FUNK:
Yes.
Yes.
20
My
name is
Amy Funk.
And I
am a
21
stay-at—home
mom
of two children.
And
I am
also active
22
member
of the local
Sierra Club,
as well
as I’ve
started
23
local group
for
Mothers
on
Environmental
Issues locally.
24
Really
let
me
just
kind
of
get a brief
why
102
Keefe
Reporting
Company
1
I’m motivated
to be
here
and
sit
with
a
four-year-old
2
for
a
couple
of
hours.
Starting
at
a young
age
I
3
learned
from
my
father
the
impact
of
air
quality
on
4
one’s
health.
My
father
grew
up
in East
Chicago
and
he
5
had
asthma
the
first
18
years
of
his
life.
He
then
went
6
off
to college
and
asthma
stopped.
And
every
time
he
7
would
go
visit,
even
growing
up,
his
breathing
was
8
always
labored
every
time
he
would
visit
at
my
9
grandparents’
in
that
area.
And
he
also
attributed
it
10
to
the
pollution
in the
area.
And
it
seemed
like
a
11
reasonable
analysis
when
you
consider
where
we
lived
and
12
where
we went.
13
In
addition
to
that
I
lived
in
Hawaii
for
14
six
years.
My
husband
was
in the
military
and
we
have
15
since
moved
to
this
area.
And
I
remember
a few
summers
16
ago
when
I went
running
for
the
first
time
during
the
17
summer,
mid afternoon,
it
wasn’t
terribly
hot,
I thought
18
I
would
go
for
a
run.
Oh, my
breathing
was labored
and
19
I
had never
ever
experienced
that
until
I
moved
to
this
20
area..
I —-
I won’t
say
it’s
with
concrete
proof
that
21
it’s
directly
related
to
this
area,
but
I
do
think
it’s
22
a
bit
telling.
And
I
remember
the
doctor
telling
me,
23
giving
me times,
best
times
to run,
avoid
certain
times,
24
you
know,
pay
attention
to
the
news
and
the
air
quality
103
Keefe
Reporting
Company
1
updates
and
that
was very
telling
me
for.
2
And I
have
two
young
children,
so
my
3
primary
motivation
here
today
is
because
of them.
4
And John
Kennedy
once
said:
11
Children
are
5
the
world’s
more
valuable
resource
and
it’s
best
hope
6
for
the
future.!!
7
So,
basically,
I
am
compelled
to
speak.
8
The
fact
that
the
Metro
East
County
has
failed
to
meet
9
air
quality
standards
very
disturbs
to
me.
And
it
is
10
also,
I
think,
an
opportunity
for
us
to
put
over
three
11
million
children
ahead
of
special
interests
and
12
industry.
When
one
considers
the
costs
of
health
care
13
due
to
respiratory
illness,
time
missed
from
work
and
14
school,
along
with
impact
of
one’s
quality
of
life
the
15
answer
seems
pretty
easy.
16
I
understand
the
needs
of
business
to
17
operate.
They
serve
a
vital
function,
particularly
18
providing
jobs
for
the
community,
but
isn’t
the
health
19
of our
13
million
residents
here
in
Illinois
also
vital
20
to
our
—-
the
health
of our
economy?
21
Recently
my
father
lost
his
job,
as
so
many
22
others
have.
He
worked
a manager
for
the
car
industry.
23
You
know,
never
would
he
attribute
it
to the
company’s
24
having
to
meet
control
technology.
He
would
attribute
104
Keefe
Reporting
Company
1
it
to
the
short-sided
decision
making
on
the
side
of
2
both
business
and
government.
3
The
reasonably
available
control
technology
4
for
NOx
being
discussed
here
today
is
both
responsible
5
and
forward
thinking.
This
is
the kind
of
thinking
we
6
need
to ensure the
recovery
and
viability
of our
economy
7
and the
health
of
our
--
health
of
our
citizens
and
8
environment.
9
There’s
a Proverb:
“That
which
is
escape
10
now
is
pain
to
come.”
I
ask
you
to
consider
in
your
11
rule
making
that,
basically,
what
we
do
today
we
will
12
face
tomorrow.
13
I
could
stand
here
and
talk
about
the
long
14
list
of
health
impacts
on
NOx
and
particulate
matter,
15
but
all
of you
are
more
well-versed
in
that
than
me.
16
And
so
I’m,
basically,
here
holding
hope
for
my
17
children’s
future.
Hope
that
we
will
allow
or
will
not
18
allow
short-sided
decision
making
on
the
part
of
19
industry
to
jeopardize
the
environment
quality
of
our
20
health
of
our
children.
For
me
today
is
about
working
21
for
a
cleaner,
healthier
environment
for
the
nearly
13
22
million
Illinois
residents.
23
Lastly,
I
just
want
to
say
as
a
mother
I,
24
you
know,
make
sure
I
feed
her
healthy
foods.
I can
105
Keefe
Reporting
Company
1
make
sure
she
gets
exercise
and
can
keep
her
safe,
you
2
know,
teach
her
how
to
cross
the
road.
But
one
thing
3
that
is
beyond
my
control,
but
is
in
your
control
here
4
today,
is
the
air
she
breathes.
And
so,
basically,
I’m
5
here
just
asking
you,
you
know,
that
you
consider
that
6
in
your
decision
making.
7
And
thank
you
so
much
for
letting
me
kind
8
of
move
in
and
I
appreciate
your
time.
9
MR.
FOX:
Ms.
Funk,
thank
you
for
your
time
10
and
your
patience
today.
11
Of
course,
the
court
reporter
has
made
a
12
report
of
your
comment
that’s
now
part
of
the
record
of
13
this
proceeding
for
today,
so
thank
you.
14
MS.
FUNK:
Thank
you
very
much.
15
MR.
FOX:
Ms.
Vetterhoffer,
that
brings
us
16
back
to
you.
I
appreciate
your
patience
in
letting
us
17
break
our
order
to
get
here,
but
please,
feel
free
to
go
18
ahead
with
any
questions.
19
MS.
VETTERHOFFER:
I
do
thank
you
for
20
stopping
so
I
can
recharge
the
computer.
21
Before
we
left
off
I
had
asked
Mr.
Stapper
22
a
question
about
the
technical
proposal
from
Bloom,
23
forgetting
Mr.
Sieberiberger
is
also
sworn
in.
So,
I
24
know
we’re
directing
questions
to
Mr.
Stapper
now.
If
106
Keefe
Reporting
Company
1
it’s
all
right
I’d
like
to
direct
a
couple
quick
2
followup
questions
to
Mr.
Siebenberger.
3
MR.
FOX:
Certainly
that
would
be
4
appropriate.
Mr.
Siebenberger
indicates
he’s
available.
5
MS. VETTERliOFFER:
Mr.
Siebenberger,
at
the
6
December
9th and
10th
hearings
regarding
this
rule
7
making
did
you
--
I
believe
you
testified
that
you
had
8
relied
on a
mechanical
proposal
from
Bloom
or
at
that
9
time
you
had
a
technical
proposal
from
Bloom;
is
that
10
correct?
11
MR.
SIEBENBERGER:
Yes.
We
--
what
I had
12
was
the
guaranteed
values
or
the
values
that
Bloom
had
13
given
our
engineering
department
for
the NOx
levels
that
14
they
said
that
their
equipment
could
achieve
on
our
slab
15
furnaces.
16
MS.
VETTERHOFFER:
Do
you
recall
if
the
17
technical
proposal
that
was provided
with
U.S.
Steel’s
18
supplemental
materials
is
the
same
one
that
you had
at
19
the
time
of the
December
hearing?
20
MR.
SIEBENBERGER:
Well,
I
didn’t
actually
21
have
the
entire
proposal,
but
what
I
had
was
the
values
22
that
engineering
had
provided
to
me.
23
MS.
VETTERHOFFER:
And
I
know
Ms.
Hodge
had
24
said
that
she
would
follow
up
on
that,
but
do
you
recall
107
Keefe
Reporting
Company
1
or
in your
opinion
can
you
provide
a
copy
of what
you
2
did
have in
December?
Is that
something
you
can
submit
3
to
The
Board?
4
MR.
SIEBENBERGER:
Well,
I
think
it is
the
5
values
that
I used
in
the
calculations.
6
MS. VETTERHOFFER:
Right.
I’m just
--
7
MR.
SIEBENBERGER:
Without
looking
if
it’s
8
not in
my
exhibits
I’m
sure I
can provide
that.
I
think
9
it’s
already
in there,
but.
10
MS. VETTERHOFFER:
Okay.
Thank
you.
11
MR.
SIEBENBERGER:
Uh-huh.
12
MS.
VETTERHOFFER:
Back
to Mr.
Stapper,
13
your
testimony
today
is based
on,
in
large
part,
on
14
Dr.
Staudt’s
testimony
that
he pre-filed
on
15
January
20th,
correct?
16
MR. STAPPER:
Yes.
That’s
correct.
17
MS. VETTERHOFFER:
And
you
state
in
your
18
pre-filed
testimony
that
you
contacted
some
of the
same
19
vendors
that
Dr.
Staudt
did;
is
that
correct?
20
MR. STAPPER:
That’s
correct.
21
MS.
VETTEREOFFER:
And
in
your
testimony
22
you’ve
researched
a number
of
safety
issues
in
23
California,
correct?
24
MR. STAPPER:
Yes,
that’s
correct.
108
Keefe Reporting
Company
1
MS.
VETTERHOFFER:
And
since
January
20th
2
you’ve
updated
your
analysis
of
NOx
controls;
is
that
3
accurate?
4
MR.
STAPPER:
Are
you
referring
to
my
5
working
practical
experience
of
NOx
controls
or
are
you
6
referring
to
my
analysis
for
U.S.
Steel?
7
MS.
VETTERHOFFER:
For
U.S.
Steel
obtained
8
in
your
report
that
was
submitted
with
U.S.
Steel
9
supplemental
materials.
10
MR.
STAPPER:
I
have
not
updated
my
11
analysis
from
the
standpoint
that
everything
I
uncovered
12
in
following
up
on
Dr.
Staudt’s
contacts
with
vendors
13
supported
our
conclusions
as
such
our
recommendations
to
14
U.S.
Steel
have
not
changed.
15
MS.
VETTERHOFFER:
And
I
know
you
testified
16
when
exactly
your
testimony
was
filed
with
The
Board,
17
but
considering
The
Agency
has
only
had
less
then
18
24
hours
to
review
it
do
you
believe
that
provides
19
The
Agency
or
The
Board
sufficient
time
to
review
it
as
20
it
was
submitted
at
the
close
of
business
yesterday?
21
MS.
HODGE:
I’m
going
to
object
to
that
22
question.
We
filed
it
when
-—
as
soon
as
we
could
get
23
it
available
and
served
everyone
electronically.
And
24
the
hearing
officer
has
been
kind
enough
today
to
allow,
109
Keefe
Reporting
Company
1
you
know,
the
testimony
to
go
forward
today.
And
my
2
understanding
in my
practice
before
The
Board
is
the
3
standard
in
rule
making
is
relevancy.
His testimony
is
4
certainly
relevant.
5
MR.
FOX:
Ms.
Vetterhoffer,
did
you
wish
to
6
be
heard
on
—-
in
response
to Ms.
Hodge?
7
MS.
VETTERHOFFER:
No,
I
was
just,
again,
8
pointing
out
the
short
amount
of time
of
The
Agency
had
9
to
prepare.
10
MR.
FOX:
And
on
the
issue
of
adequate
time
11
for
The
Agency
or The
Board
I’m
not sure
that
12
Mr.
Stapper’s
opinion
is
relevant
or
has
basis
in
fact,
13
so
I
would
uphold
the
objection.
14
Ask
your
next
question,
please.
15
MS.
VETTERHOFFER:
Thank
you.
16
On
page
two
of
your
pre-filed
testimony
you
17
state
that
URS
provides
emission
guarantees
on
equipment
18
it
installs.
19
Isn’t
that
true
of
all
vendors?
20
MR.
STAPPER:
No,
thats
not
true.
21
MS.
VETTERHOFFER:
Is
that
true
of
some
22
vendors?
23
MR.
STAPPER:
Yes.
24
MS.
VETTERHOFFER:
Doesn’t
that
make
URS
a
110
Keefe
Reporting
Company
1
vendor
as well?
2
MR.
STAPPER:
For
some technologies
URS is
3
a
vendor.
4
MS.
VETTERHOFFER:
How
old,
if
you
know,
5
are
the existing
burners
on
Boilers
11
and 12
at
Granite
6
Steel
Works?
7
MR. STAPPER:
Just
off
the top
of my
head
I
8
don’t
recall
their
age.
The
age
of
the boilers?
Forty
9
to 50
years.
10
MS.
VETTERHOFFER:
And
again,
is
there
any,
11
if Mr.
Siebenberger
perhaps
knows
the
answer
to
the
12
question,
perhaps
he would
answer?
13
MR.
SIEBENBERGER:
No,
I
don’t
have
any
14
specific
knowledge
on that.
15
MS.
VETTERHOFFER:
Mr.
Stapper,
is there
16
any
other
reason
that
a
burner
might
be
replaced
besides
17
NOx
control
requirements?
18
MR.
STAPPER:
Yes.
19
MS.
VETTERHOFFER:
And
what
are
some
of
20
those
other
reasons?
21
MR. STAPPER:
Burners
wear
out
over
time,
22
so it’s
conceivable
that
somebody
would
replace
one
just
23
as
they
maintenance
replace.
24
MS.
VETTERHOFFER:
Or
perhaps
to
address
111
Keefe
Reporting
Company
1
safety
or
code reqi.iirements;
would
you agree
with
that?
2
MR.
STAPPER:
I
agree.
3
MS. VETTERHOFFER:
In the
event
that
4
U.S.
Steel
had
to
replace
their
burners
for reasons
5
other than
NOx
control
wouldn’t
it have
to work
with
6
burner
vendors
to do
that?
7
MR.
STAPPER:
Yes.
8
MS.
VETTERHOFFER:
Is
there a
chance
that
9
U.S.
Steel
would
face the
same problems
in
light of
age
10
of the existing
burners?
11
MR.
STAPPER:
Which
problems
are
you
12
referring
to?
13
MS.
VETTERHOFFER:
The
same
problems
14
discussed
in your
pre-filed
testimony
and
the
problem
15
regarding
your testimony
regarding
fitting
the burners
16
into
the
existing
boilers,
problems
associated
with
17
that?
18
MR.
STAPPER:
The
distinction
I’m trying
to
19
draw
is
that
there
are burners
suitable
for multi-fuel
20
applications.
There
are not
widely
available
21
commercially
developed
Low—NOx
burners
for
that
22
application.
If
they were
not
having
to replace
the
23
burners
for
purposes
of NOx
control
they would
be
able
24
to find
burners
that
were
more
proven,
more readily
112
Keefe
Reporting
Company
1
available
similar
to
the
ones
that
are
already
2
installed.
3
MS.
VETTERHOFFER:
And
I
believe
we
were
4
just
discussing
didn’t
U.S.
Steel
contact
Bloom
5
Engineering
about
their
reheat
furnaces?
6
MR.
STAPPER:
Again,
I’m
not
the
reheat
7
furnace
person.
8
MS.
VETTERHOFFER:
I
am
sorry.
I’ll
direct
9
that
to
Mr.
Siebenberger
as
well.
10
MR.
SIEBENBERGER:
Could
you
repeat?
11
MS.
VETTERHOFFER:
Sure.
12
Didn’t
U.S.
Steel
contact
Bloom
Engineering
13
about
their
reheat
furnaces?
14
MR.
SIEBENBERGER:
Yes.
15
MS.
VETTERHOFFER:
Okay.
Bloom
Engineering
16
is
a
vendor
as
well,
correct?
17
MR.
SIEBENBERGER:
I
believe
so,
yes.
18
MS.
VETTERHOFFER:
So,
would
you
agree
that
19
U.S.
Steel
has
relied
on
information
provided
from
20
vendors
in
making
it’s
own
decision
for
NOx
control?
21
MR.
SIEBENBERGER:
In
case
of
blast
22
furnaces,
yes.
23
MS.
VETTERHOFFER:
Mr.
Stapper,
on
page
24
four
of
your
testimony
you
stated
that
a
critical
113
Keefe
Reporting
Company
1
omission
in
Dr.
Staudt’s
correspondence
with
vendors
2
concerned
the
fuel
mix
to
be
burned
in
the
boilers.
3
This
included
35
percent
blast
furnace
gas,
25
percent
4
natural
gas
and
40
percent
coke
oven
gas
and
then
40
5
percent
natural
gas
and
60
percent
coke
oven
gas.
6
Wasn’t
this
information
provided
by
U.S.
7
Steel?
8
MR.
STAPPER:
These
average
plans
were
9
provided
by
U.S.
Steel
in
the
context
of
explaining
10
their
emissions
calculations.
I
don’t
believe
the
11
intention
was
to
represent
the
range
over
which
those
12
fuels
vary
and
how
they
operate.
13
MS.
VETTEROFFER:
Okay.
And
to
your
14
knowledge
has
U.S.
Steel
or
URS
ever
provided
that
15
information
to
The
Agency?
16
MR.
STAPPER:
No.
17
MS.
VETTERHOFFER:
You
--
do you
know
if
18
The
Agency
requested
that
information
at
the
last
19
hearing?
20
MR.
STAPPER:
I’m
not
aware
of
that
21
request,
no.
22
MS.
VETTERHOFFER:
The
Agency
did
request
23
information
concerning
the
fuel
mix
in
those
boilers
24
though;
is
that
correct?
114
Keefe
Reporting
Company
1
MR.
STAPPER:
I
don’t
recall
a
specific
2
request
of
that
nature,
no.
3
MS.
VETTERHOFFER:
On
page
five
of
your
4
testimony
you
discuss
limitations
regarding
the
size
5
required
for
the
Bloom
Low—NOx
burners.
And
you
state
6
that
these
are
too
large
for
Boilers
11
and
12.
7
How
was
the
information
you
base
this
8
opinion
regarding
boiler
dimensions
how
was
that
9
information
obtained?
10
MR.
STAPPER:
For
the
information
on
the
11
Bloom
1030
series
burner
that
information
for
the
12
specific
burner
series
was
contained
in
the
13
correspondence
between
Bloom
and
Dr.
Staudt.
The
14
specifics
of
the
burner
dimensions
I
obtained
from
Bloom
15
brochures.
16
MS.
VETTERHOFFER:
What
about
the
17
information
about
the
dimensions
of
the
boilers?
18
MR.
STAPPER:
That
information
I
obtained
19
from
drawings,
the
boiler
general
arrangement
drawings.
20
MS.
VETTERHOFFER:
Have
you
inspected
21
Boilers
11
and
12?
22
MR.
STAPPER:
Yes,
I
have.
23
MS.
VETTERHOFFER:
Do
you
know
if
24
Dr.
Staudt
had
those
drawings
that
you
just
mentioned
115
Keefe
Reporting
Coipany
1
available
to him?
2
MR.
STAPPER:
I
don’t
know.
3
MS.
VETTERHOFFER:
I’ll
just
ask
4
Mr.
Siebenberger.
5
Mr.
Sieberiberger,
are
you
aware
whether
6
that
information
was ever
provided
to
Dr.
Staudt
or
7
The
Agency?
8
MR.
SIEBENBERGER:
I
--
I don’t
believe
so.
9
MS.
VETTERHOFFER:
Would
the
information
be
10
available
to
The
Agency?
Would
you
be
willing
to
11
provide
it
--
and
to The
Board?
12
MR.
SIEBENBERGER:
Again,
assuming
I
guess
13
that
there’s
no
confidentiality
issues
with
it.
14
MS.
VETTERHOFFER:
Okay.
Thank
you.
15
And
isn’t
it
true
that
The
Agency
requested
16
an
opportunity
to
inspect
boilers
with
Dr.
Staudt
17
present
prior
to
this
hearing?
18
MR.
SIEBENBERGER:
Yes,
I
believe
19
Ms.
Roccaforte
requested
that
we
be
able
to
sit
down,
20
get
together
prior
to
the hearing
and
discuss
these
21
matters.
We
attempted
to
set
up
a
meeting
to
discuss
22
the
matter
further
and I
think
at
that
time
they
were
23
hoping
to be
able
to
go
out
and
view
the
boilers.
24
MS.
VETTERHOFFER:
Was
U.S.
Steel
and
116
Keefe
Reporting
Company
1
The
Agency
able
to
set
up
that
inspection?
2
MR.
SIEBENBERGER:
No,
due
to
scheduling
3
problems
we’re
going
to have
to reschedule.
4
MS.
VETTERHOFFER:
Back
to
Mr.
Stapper,
on
5
page
12
of
your
testimony
you
state
that
the
selective
6
non—catalytic
reduction,
SNCR,
could
not
be
used
to
7
reduce
emissions
on
Boilers
11 and
12
to below
.08
8
pounds
per
MtBtu;
is
that
correct?
9
MR.
STAPPER:
Yes.
10
MS.
VETTERHOFFER:
Didn’t
Dr.
Staudt’s
11
original
pre-filed
testimony
state
that
he did
not
12
envision
the
need
for
SNCR
on
any
gas
fired
facilities
13
subject
to the
proposed
rule?
14
MR.
STAPPER:
That
must
be a
matter
of
the
15
record.
I
can’t
speak
to
that.
16
MS.
VETTERHOFFER:
Okay.
Do
you
17
specifically
recall
that
testimony
personally?
18
MR.
STAPPER:
I
personally
do
not
recall
19
that
testimony.
20
MS. HODGE:
Mr.
Stapper
was not
present
at
21
the
first
hearing
in
this
matter.
22
MS.
VETTERHOFFER:
I
--
the
second
I asked
23
that
question
I
realized
that.
I’m
sorry.
24
Didn’t
Staudt’s
--
Dr.
Staudt’s
more
recent
117
Keefe
Reporting
Company
1
testimony
filed
regarding
this
hearing
discuss
SNCR
use
2
on
multi-fuel
and
no-bearing
heat
systems?
3
MR.
STAPPER:
May
I
have
just
a
moment
to
4
come
back
to
Dr.
Staudt’s
testimony.
5
MR.
FOX:
Yes.
Yes.
You
need
a
moment
or
6
two
that’s
fine.
7
WHEREUPON,
THERE
WAS
A
SHORT PAUSE
IN
PROCEEDINGS;
8
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
9
OF
RECORD:
10
MR.
STAPPER:
I
am
sorry.
Could
you
point
11
me
to
the
page
of
Dr.
Staudt’s
pre-filed
testimony?
12
MS.
VETTERHOFFER:
Just
one
moment.
13
MR.
STAPPER:
I
got
it.
14
Could
you
repeat
the
question?
15
MS..
VETTERHOFFER:
Sure.
16
I
simply
asked
if
you
had
seen
Dr.
Staudt’s
17
recent
testimony
in
this
hearing
concerning
SNCR
use
for
18
multi-fuel
systems?
19
MR.
STAPPER:
His
testimony
does
speak
to
20
multi-fuel
boiler
application
of
SNCR,
yes.
21
MS.
VETTERHOFFER:
Would
it
be
correct
to
22
say
that
the
co-firing
of
blast
furnace
gas,
coke
oven
23
gas
and
natural
gas
is
pretty
limited
to
the
steel
24
industry?
118
Keefe
Reporting
Company
1
MR. STAPPER:
Yes.
2
MS.
VETTERHOFFER:
You
testified
at
the
3
December
hearing
that
URS is
involved
in the
burner
4
retrofit
business
and
that experience
allows
URS
to
5
operate
without
contacting
the
vendors
for every
6
application.
7
How many
steel
mill
boilers
co-firing
8
natural
gas,
coke oven
gas
and blast
furnace
gas
has
URS
9
performed
Low-NOx
reduction
on?
10
MR. STAPPER:
I am
not aware
that
we
have
11
performed
any.
12
MS.
VETTERHOFFER:
To
your
knowledge
has
13
U.S.
Steel performed
emissions
tests
of
the reheat
14
furnaces
or Boilers
11
and
12?
15
MR.
STAPPER:
Could
you repeat
that,
16
please?
17
MS. VETTERHOFFER:
Sure.
18
To
your knowledge
has
U.S.
Steel
performed
19
emissions
tests
on it’s
reheat
furnaces
or
Boiler
11
and
20
12?
21
MR.
STAPPER:
I have
no knowledge
or --
22
MS. VETTERHOFFER:
Maybe
I
can
direct
that
23
question
to Mr.
Siebenberger.
24
MR.
SIEBENBERGER:
Yeah.
I
mean,
119
Keefe
Reporting
Company
1
historically
I think
there’s
been
some
analysis
or
some
2
testing
of
number
12
boiler
and some
limited
testing
of
3
number
four
reheat
furnace.
4
MS.
VETTERHOFFER:
Okay.
And
was
that
for
5
NOx
controls,
I’m
sorry,
NOx
emissions?
6
MR.
SIEBENBERGER:
I
--
yes,
I
believe
some
7
of
it
was
for
NOx
emissions.
8
MS.
VETTERHOFFER:
Can you
by
any
chance
9
recall
what
the
emissions
rates
were
for
the
different
10
fuels?
11
MR.
SIEBENBERGER:
No,
I
can’t
off
the
top
12
of
my
head.
13
MS.
VETTERHOFFER:
Would
you
be
willing
to
14
provide
a copy
of
the
test
results
to
us and
to
15
The
Board?
16
MR.
SIEBENBERGER:
Yeah,
assume
--
yeah,
I
17
think
so.
18
MS.
VETTERHOFFER:
Were
those
emissions
19
tests
used
in
formulating the
emissions
rates
for
the
20
cases
that
you
submitted
in
Exhibit
A to
your
pre-filed
21
testimony
for
December
9th
and
10th
hearing?
22
MR.
SIEBENBERGER:
Not
--
not
directly
in
23
determining
what
the
limit
was,
no.
24
I
think
--
well,
I know
in
both
cases
URS
120
Keefe
Reporting
Company
1
for
the
boiler
projected
what
they
thought
the
emission
2
rates
are
currently.
And
Bloom
did
the
same
thing
with
3
reheat
furnaces.
And
so,
that
was
——
then
they
used
4
that
in
their
analysis
to
determine
what
the
control
5
rates
could
be.
I
think
the
only
place
some
of
these
6
earlier
numbers
from
your
tests
are
used
was
in
any
7
emission
reports.
And
we
may
have
used
those
ni.unbers
to
8
reflect
——
and
typically
those
are
conservative
numbers.
9
And
we
may
have
used
those
numbers
to
reflect
what
the
10
Low-NOx
reductions
would
be
to
reflect
that
that
had
no
11
bearing
on
what
the
final
control
level
is.
12
MS..
VETTERHOFFER:
Okay.
Mr.
Stapper,
just
13
for
clarification
sake,
you
are
the
author
of
the
NOx
14
Reduction
Study
for
U.S.
Steel
that
was
submitted
to
15
The
Board
on
Friday;
is
that
correct?
16
MR.
STAPPER:
URS
authored
that
report.
I
17
am
not
the
sole
author
of
that
report.
18
MS.
VETTERHOFFER:
Did
you
help
author
that
19
report?
20
MR.
STAPPER:
Yes,
I
did.
21
MS.
VETTERHOFFER:
In
that
report
you
22
discuss
Low—NOx
burners
on
page
nine
of
the
report
you
23
state,
or
whoever
authored
the
document
with
your
help
24
states,
of
course,
a
Low—NOx
burner
combined
FGR
would
121
Keefe
Reporting
Company
1
produce
significant
NOx
reductions,
but
it
is
unlikely
2
that
the NOx
reduction
would
be any
greater
than
3
application
of FGR
to the
existing
burners.
4
This is
one of
the
reasons
that
URS
pulled
5
out
Low—NOx
burners;
is
that
correct?
6
MR.
STAPPER:
That’s
correct.
7
And
I
believe
that’s consistent
with
what
8
we in
response
received
from
the
burner
vendors.
9
MS. VETTERHOFFER:
In the
previous
10
paragraph
on
that same
page
URS
also discusses
the
11
possible
need
to
upgrade
burner
management
system,
which
12
would
add cost
to
the
project;
is that
correct?
13
MR. STAPPER:
Low-NOx
burners
generally
14
require
better
instrumentation,
because
they
have
15
tighter
operating
windows.
And
therefore,
Low-NOx
16
burner
retrofit
may
often or
even
an FGR
retrofit
may
17
often
require
instrumentation
upgrades
such
that
the
18
cost
of
the
instrumentation
even
exceeds
the
cost
of
the
19
burner
itself.
20
MS.
VETTERHOFFER:
So,
the
added
cost was
a
21
consideration
that
URS
considered?
22
MR. STAPPER:
URS
considered
what
the total
23
installed
cost
would
be.
It
would
be
necessary
to
24
install
and safely
operate
the equipment
we were
122
Keefe Reporting
Company
1
evaluating.
2
MS.
VETTERHOFFER:
Assuming
a
Low-NOx
3
burner
would
be
installed
on
Boilers
11 and
12
would
it
4
be
fair
to
say
that
Low-NOx
burner
in
combination
with
5
FGR
would
provide
reduction
that
is
at
least
as
good
as
6
FGR
alone,
perhaps
better?
7
MR.
STAPPER:
I don’t
believe
that
I have
8
seen
any
information
from
any
burner
vendor
that
would
9
suggest
that
they
have
a
burner
capable
of
exceeding
the
10
emissions
that
U.S.
Steel
has
proposed
with
the
11
installation
of
their
burner
in
combination
with
FGR.
12
am
aware
of no
existing
installations.
13
On
this
fuel
blend
and
the
feedback
I
14
received
as -—
as
is
included
in
the
testimony
that
was
15
presented
today
the
estimates
that
those
vendors
16
provided
with
their
Low-NOx
burner
in combination
with
17
FGR
are not
any
lower
than
what
U.S.
Steel
is
proposing
18
to
achieve
by
simply
adding
FGR
to
their
existing
19
burners.
20
And
the
point
I made
in
the
testimony
is
21
that
a burner
vendor
doesn’t
sell
FGR
projects.
They
22
sell
burners.
And
they
are
going
to
try
to
respond
with
23
their
best
burner
driven
solution.
24
MS.
VETTERHOFFER:
Is
there
significant
123
Keefe
Reporting
Company
1
fuel
NOx
produced
using
coke
oven
gas?
2
MR.
STAPPER:
The
scrubbed
coke
oven
gas
is
3
estimated
by
the
scrubber
vendor
to
contain
130
parts
4
per
million
hydrogen
cyanide,
which
would
add
5
approximately
.03
pounds
per
million
Btu
full
NOx
to the
6
overall
NOx
emissions
from
the
boiler.
7
The
un—scrubbed
coke
oven
gas
contains
1900
8
PPM
hydrogen
cyanide,
which
is
--
the
scrubber
is
9
estimated
to
reduce
93
percent
of
the
hydrogen
cyanide
10
from
the
coke
oven
gas.
So,
the
--
the
un—scrubbed
coke
11
oven
gas
would
have
a
very
significant
impact
on
the
NOx
12
emissions.
13
MS.
VETTERHOFFER:
And
FGR
does
not
reduce
14
fuel
NOx;
is
that
correct?
15
MR.
STAPPER:
That’s
correct,
nor
does
16
Low-NOx
burner,
just
to
clarify.
17
MS.
VETTERHOFFER:
Did
you
examine
with
any
18
calculations
the NOx
reduction
in
combination
of
Low-NOx
19
burner
and
FGR
might
achieve
versus
FGR
alone?
20
MR.
STAPPER:
Yes.
As
we’ve
stated
we
have
21
data
for
Low-NOx
burner
in
combination
with
FGR.
We
22
have
those
emissions
tests.
And
they
are,
essentially,
23
the
same
as
what
U.S.
Steel
is
proposing
to
achieve
with
24
just
FGR
applied
to
it’s
existing
burners.
124
Keefe
Reporting
Company
1
And
our
recommendation
to
U.S.
Steel
was
2
rather
than
to
go the
expense
of
rebuilding
their
3
boilers
and
buying
new
burners
and
installing
them
and
4
adding
FGR
that
it
would
be much
more
prudent
to
simply
5
add
FGR
to
obtain
the
same
NOx
emission
levels.
6
MS.
VETTERHOFFER:
Mr.
Stapper,
did
you
7
obtain
a
cost
estimate
for
FGR?
8
MR.
STAPPER:
Do
you
mean
did
I obtain
a
9
cost
estimate from
an
FGR
vendor?
10
MS.
VETTERHOFFER:
Or
did you,
yourself,
11
develop
a
cost
estimate?
12
MR.
STAPPER:
URS
did
develop
a
cost
13
estimate.
URS
does
sell
reinstallation
retrof
its.
14
And
-—
and
as
far
as
the
same
I
—- I
--
I’ve
prepared
15
one
within
the
last
month
for
a design
that
we’re
doing.
16
It’s
actually
matter
of the
public
record,
so
I
can
even
17
say
the
installation
is
NASA
Johnson
Space
Center,
so I
18
have
most
current
possible
cost
estimate
information
is
19
available.
20
MS.
VETTERHOFFER:
Just
one
moment.
21
WHEREUPON,
THERE
WAS
A
SHORT
PAUSE
IN
PROCEEDINGS;
22
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
WERE
MADE
23
OF
RECORD:
24
MS.
VETTERHOFFER:
Mr.
Stapper,
in your
125
Keefe
Reporting
Company
1
opinion
then
based
on
your
analysis
of
FGR
does
that
2
meet
RACT
requirements
or FGR
considered
RACT
in
your
3
opinion?
4
MR. STAPPER:
By
the definitions
of
cost
5
effectiveness
and
it’s availability
and
proven
record
6
I’m
agreeing
that FGR
is --
generally
qualifies
as RACT.
7
MS.
VETTERHOFFER:
Thank
you,
Mr.
Stapper.
8
I have
no
further
questions.
9
MR. FOX:
Are
there
any
other
questions?
10
(No response.)
11
Ms.
Vetterhoffer,
thank
you.
12
Were
there
questions
from
any
of
other
13
participants
for Mr.
Stapper
here
today?
14
Ms.
Hodge?
15
MS.
HODGE:
I have
just
one
full
up
16
questions
for
him,
if I
may?
17
MR.
FOX:
Please,
go
ahead.
18
MS.
HODGE:
Mr.
Stapper,
could
you
19
elaborate
a
bit
on
URS’ experience
with
evaluation
of
20
burner
application
with
various
fuel
blends?
21
MR.
STAPPER:
Yes.
22
The
question
was
asked
previously
if URS
23
had had
-- if
I was
aware
of URS
had
installed
burners
24
in
application
involving
blast furnace
gas,
coke oven
126
Keefe Reporting
Company
1
gas
and
natural
gas
and
my
answer
was
no.
But
URS
does
2
conduct
studies
of
-—
of sources
firing
a wide
variety
3
of
fuels,
including
blast
furnace
gas
and
coke
oven
gas
4
for
specific
burner
retrofit.
Our
experience
includes
5
units
firing
refinery
gasses
with
various
blends
of
6
hydrogen
and
other
hydrocarbons.
7
We
are
involved
in
——
we’ve
been
involved
8
in
retrofits
with
--
with
co-firing
low
Btu gasses
and
9
co—firing
other
waste
treatments
of
hydrocarbons
that
10
require
the
burner
to accommodate
swings
in
both
fuel
11
heating
value
and
--
and
the
load
range
of
the
firing
12
equipment.
So,
URS
does
have
extensive
experience
in
13
the
actual
installation
and
start
up
of a
variety
of
14
multi-fuel
boiler
applications.
15
MS. HODGE:
Thank
you.
16
MR.
FOX:
Any
other
questions
for
--
for
17
Mr.
Stapper?
18
Mrs.
Andria?
19
MS.
)NDRIA:
Am
I allowed
to
ask
a
very
--
20
it’s
very
brief?
21
MR.
FOX:
Yes.
22
MS.
ANDRIA:
Kathy
Andria,
A-N-D-R-I-A.
23
MR. FOX:
This
question,
Ms.
Andria,
is
24
directed
specifically
to
--
127
Kefe
Reporting
Company
1
MS.
ANDRIA:
Specific
to
what
you
just
said
2
--
Mr.
Stapper
just
said.
3
MR.
FOX:
Very
good.
Thank
you.
4
MS.
ANDRIA:
From
my memory
of
reading
the
5
transcript
of
the
previous
public
hearing
and
something
6
he
just
said
I
just
wanted
to
clarify
something
for
our
7
own purposes
or
our
comments:
URS
specializes
in
8
retrofit
burners,
not
new
burners;
is
that
correct?
9
MR.
STAPPER:
No.
We
--
we
--
we
supply
10
new
burners
for
retrofit
applications,
but
we
supply
new
11
burners
both
as
part
of
boiler
retrofits
and
as
part
of
12
new
boiler
installations.
13
MS.
NDRIA:
So, I’m
unclear.
I’m
not
a
14
technical
person
or
an engineer.
I am
unclear.
Are
you
15
a
vendor
or
are
you a
consultant
in
this
case?
16
MR.
STAPPER:
In
this
particular
case
URS
17
is
a
consultant
and
we
are
--
we
will
not
be
installing
18
whatever
solution
is
ultimately
implemented
by
19
U.S.
Steel.
20
MS.
ANDRIA:
But
you
are
recommending
21
equipment
that
you
sell;
is
that
correct?
22
MR.
STAPPER:
We’re
recommending
a
23
technology
that
we
--
we do
provide
to
clients,
yes.
24
MS.
ANDRIA:
That’s
all.
Thank
you.
128
Keefe
Reporting
Company
1
MR.
FOX:
And
Mrs.
Andria,
if
would
refer
2
to
comments,
could
you
just
mention
to
the
record
any
3
organization
or
group
on
whose
behalf
those
comments
4
might
be
filed?
5
MS.
ANDRIA:
Yes.
American
Bottom
6
conservancy
and
Sierra
Club.
7
MR.
FOX:
Thank
you,
Mrs.
Andria.
Should
8
have
taken
care
of
that
first.
9
That
appears
to
conclude
all
of
the
10
questions
for
Mr.
Stapper
on
the
basis
of
his
pre-filed
11
testimony.
12
There
was,
as
I
announced
at
the
top
of
13
hearing,
an
opportunity
for
anyone
to
sign
up
if
they
14
wish
to
testify
without
having
pre-filed
or
to
offer
15
comments
and
we
have
with
Ms.
Funk’s
comment
taken
care
16
of,
one
of
the
three
people.
17
Mr.
Smith,
I
think
you
had
indicated
and
18
forgive
me
if
I’m
mistaken,
you
merely
offered
-—
wanted
19
to
offer
brief
comment
rather
than
be
sworn
in
and
offer
20
testimony
and
be
subject
to
questions.
21
MR.
SMITH:
Just
a
brief
comment,
yes.
22
MR.
FOX:
Terrific.
I
think
we’ve
come
to
23
the
point
in
the
hearing
with
the
conclusion
of
those
24
questions,
for
any
comment
you
may
wish
to
offer.
I
129
Keefe
Reporting
Company
1
don’t
think
you
have
to
move
from
that seat,
but
if
you
2
could
use
the microphone
and
pull
it
down
to within
a
3
couple
of
inches
of your
chin
I think
the
court
reporter
4
and
the rest
of
us
here
can hear
you
just
fine.
Please,
5
go
ahead whenever
you’re
ready.
6
MR.
SMITH:
Okay.
Thank
you.
7
MR.
SMITH:
I
am Steven
Smith.
I
work
for
8
Saint-Gobain
Container.
And
I just
have
a brief
9
statement
with respect
so the
notice
filed
by
10
Gina
Roccaforte
January
——
11
MR. FOX:
Mr.
Smith,
maybe
it would
make
12
the
most
sense if
you
come
down two
rows in
front
of
you
13
to
an empty
seat
with
a
microphone
that
was
working.
I
14
hate
to ask
you to
do that,
but it
be
might
be
the
most
15
efficient.
16
MR.
SMITH:
Is this
one
working?
17
MR. FOX:
They
are.
Terrific.
Thanks.
18
MR. SMITH:
I
just have
a
brief
statement
19
with
respect
to
the
notice
filed
by
Gina Roccaforte
on
20
January
30th,
2009
on
the
motion
to amend
rule
making
21
proposal
Saint-Gobain
Containers
has been
working
with
22
the
Illinois
EPA
to
develop
specific
sessions
involving
23
glass
melting
furnaces
and we
support
that
motion.
24
MR.
FOX: Anything
further,
Mr.
Smith,
on
130
Keefe
Reporting
Company
1
behalf
of Saint-Gobain?
2
MR.
SMITH:
That’s
it.
Thank
you.
3
MR.
FOX:
Thank
you
for
patience
waiting
to
4
deliver
those
few
sentences
all
morning.
5
MR. SMITH:
No
problem.
6
MR.
FOX:
We had
one
other
person,
unless
7
there
was
further
interest
in
testimony
--
testifying
or
8
offering
comment
and
that
was
Ms.
Andria
on
behalf
of
9
she
had
mentioned
of the
American
Bottom
Conservancy
and
10
Sierra
Club.
11
Ms.
Andria,
if
you’re
prepared
to
offer
a
12
brief
public
comment,
please,
proceed
at
this
point
to
13
do
that.
14
MS.
ANDRIA:
Thank
you.
15
Mr.
Fox,
members
of The
Board.
Mr.
Rao.
16
My
name
is
Kathy
Andria.
I’m
president
of
17
American
Bottom
Conservancy
and
Conservation
Chair
for
18
the
Kaskaskia
Group
Sierra
club.
I
am
a member
of
the
19
Sierra
Club
National
Clean
Air
Team
and
an
active
20
participant
in
the
East/West
Gateway
Council
of
21
Government’s
Air
Quality
Advisory
Committee.
I
have
22
been
a
member
of
the
Illinois
EPA
Environmental
Justice
23
Advisory
Group
since
it’s
inception.
In
all
capacities
24
I
am
a
volunteer.
131
Keefe
Reporting
Company
1
We
want
to
thank
you
for
holding
a
thorough
2
hearing
on
this
matter
so
those
of
us
living
in the
3
Metro
East
are
able
to
comment
on
this
proposed
rule
4
making,
which
very
much
affects
us.
We are
surrounded
5
by
coal
fired
power
plants,
smelters,
chemical
plants,
6
steel
mills,
refineries,
a hazardous
waste
incinerator
7
and
other
facilities.
We
will
soon
have
a new
coke
8
plant.
We
also
have
a
massive
cement
kiln
that
is
being
9
built
right
across
the
river.
All
are
going
to or
will
10
and
have
contributed
to
our
air
quality.
11
I know
that
a
number
of
people
living
on
12
the
other
side
of
the
river
who
share
our
air
shed
also
13
wanted
to
come
today,
but
the
Missouri
Department
of
14
Natural
Resources
is
also
holding
an
air
quality
public
15
hearing
today
and
they
are
there.
I
hope
that
they
and
16
other
local
residents
who
are
unable
to
come
to
a
17
daytime
hearing
will
submit
written
comments.
18
Several
weeks
ago
in
anticipation
of
that
19
hearing
I
read
through
most
of
the
filings
on
the
rule
20
making
that
were
posted
on
The
Board
web
site
and
began
21
writing
my
comments,
some
of
which
address
concerns
I
22
found
in the
records
such
as
I
was
concerned
about
23
the
--
the
question
of
the recommending
something
they
24
sell
and
not
going
to be
able
to
go
--
to
get
questions
132
Keefe
Reporting
Company
1
answered
by
only
those
who
sold
new
boilers.
2
Unfortunately,
I
discovered
yesterday
that
my notes
on
3
that
were
among
those
lost
in
a
recent
computer
4
malfunction,
so
I
regret
that
my
comments
today
will
be
5
limited.
I
hope
to
reconstruct
my comments
and
submit
6
them
in
writing,
although
the
Illinois
EPA
has
done
much
7
of the
comments,
brought
up
questions
that
I
had.
8
We
want
to thank
Illinois
EPA
for
proposing
9
this
rule
making
and
for
the
work
they
have
put
into
10
seeing
that
it
is
adopted.
Those
opposing
this
rule
11
making,
the
industries
which
would
have
to
comply
with
12
it,
claim
that
adding
stricter
controls
is
unnecessary
13
because
our
air
is
getting
cleaner,
would
cost
too
much
14
and
the
deadline
is
too
soon.
That
is
all
the
argument
15
and
they
do
everything
they
can
to
delay,
delay,
delay
16
the
adoption
and
implementation
of any
rule
making
or
to
17
quash
it
altogether.
In
this
instance
they
hired
the
18
former
Chief
of
Illinois
Air
Bureau,
very
smart
tactic.
19
If
we
had
the
funds
those
of
us
worried
about
the
health
20
of
our
communities
might
have
done
the
same
thing
and
21
his
testimony
might
have
had
a very
different
focus.
22
I
am
not
a
technical
person.
I
am not
an
23
engineer.
I
am
not
a
health
professional,
but I
do
know
24
something
about
our
air
quality
and
our people
and
I
133
Keefe
Reporting
Company
1
know
a
bit
about
the
local
industries
that
would
be
2
affected
by
your
rule
making.
3
.merican
Bottom
Conservancy
and
Sierra
Club
4
have
been
actively
involved
in
air
permitting
issues
5
concerning
the
ConocoPhillips
Wood
River
refinery
and
6
the
U.S.
Steel
facility
in Granite
City.
Both
7
facilities
contribute
significant
emissions
of
8
pollutants
to
our
air
that
cause
our
status
as
9
non-attainment.
Both
facilities
will
be
affected
by
10
this
rule
making.
Both
facilities
are
opposing
it.
11
Neither,
apparently,
has
reached
an agreement
with
IEPA.
12
ABC
and
Sierra
Club
oppose
certain
recent
permit
13
decisions
by the
Illinois
EPA
regarding
the
two
14
facilities.
Both
resulted
in
settlement
agreements
that
15
would
keep
the
plants
operating,
the
workers
working
and
16
given
environmental
benefits
to
communities
such
as
17
increased
monitoring,
school
bus
and
public
building
18
energy
efficiency
retrofits.
19
The
Greater
St.
Louis
Metro
East
area
does
20
not
meet
federal
air
quality
standard
for
fine
21
particulates
being
2.5
in
our
ozone.
The Wood
River
22
Refinery
and
Granite
City
Steel
are
the
largest
Metro
23
East
contributors
to
that
numbers.
And
the
U.S.
Steel
24
facility
has
been
identified
as
largely
being
134
Keefe
Reporting
Company
1
responsible
for
our
PM
2.5
non—attainment
designation.
2
The
company
indicated
that
they
have
been
working
with
3
IEPA
for
the
last
year
on
controls,
yet
they
oppose
this
4
rule
making.
5
I grew
up
in
Granite
City.
My
father
6
worked
for
most
of
his
life
in
a
steel
mill.
He
was
a
7
union
pattern
maker
and
carpenter.
So,
I very
much
8
understand
the
importance
of
jobs
to
our
communities
and
9
to
our
families,
but
my
father
knew
firsthand
the
10
companies
could
do more,
much
more
to
control
their
11
pollution.
And
he
urged
me
to
work
to
help
clean
our
12
air.
My
father
had
heart
disease
and
emphysema.
My
13
mother
died
from
cancer.
All
three
diseases
can
be
14
caused
or
aggravated
by
poor
air
quality
by exposure
to
15
fine
particulates.
We
have
a very
high
cancer
rate
and
16
lung
disease
in
the St.
Louis
area.
St.
Louis
was
just
17
named
the
worst
city
in
2merica
for
asthma
by
the
Asthma
18
and
Allergy
Foundation.
Madison
County
and
St.
Clair
19
County
received
failing
grades
for
air
quality
annually
20
from
the
merican
Lung
Association.
The
asthma
rates
21
among
our
children
both
in St.
Louis
and the
Metro
East
22
are astronomical,
nurses
in the
local
schools
have
bags
23
of
inhalers
for
the
kids.
Children
must
limit
their
24
play
time
or
play
indoors.
135
Keefe
Reporting
Company
1
Illinois
EPA
is
trying
this
rule
making
to
2
make
our
air
cleaner
to
help
our
area
come
into
3
attainment.
ConocoPhillips
and
U.S.
Steel
are
fighting
4
it.
I
have
toured
both
facilities
and
know
there
is
5
much
each
can
do to
better
control
their
emissions.
6
And
I
don’t
know
for
sure,
but
I
think
7
that’s
Boilers
11
and
12 might
be
as
old
as
I
am,
which
8
is
not
40
or
50.
That
would
help,
if
they
do
the
9
control
their
emissions,
that
would
help
not
only
us
it
10
would
help
the
two
companies
to use
their
energy
more
11
efficiently
that
would
help
their
bottom
line.
12
Granite
City
Steel
is
currently
partially
13
idle
because
of
the
economy
as
Larry
Siebenberger
14
testified.
What
better
time
for
the
company
to
install
15
better
controls
reasonably
available
control
technology.
16
If
they
act
now
they
would
not
have
to
plant
--
idle
the
17
plant
when
the
economy
recovers
when
it
is
at
full
scale
18
production
and
they
could
put
some
of
their
laid
off
19
workers
back
to
work
installing
the
equipment.
20
President
Obama’s
stimulus
package
has,
21
presumably,
it
has
billions
of
dollars
targeted
for
22
infrastructure,
which
should
result
in
increased
need
23
for
steel.
Installing
better
controls
will
also
provide
24
jobs
to
workers
who
would
maintain
the
equipment.
136
Keefe
Reporting
Company
1
Building
control
equipment
also
provides
jobs.
We
would
2
hope
that
U.S.
Steel
would
use
this
opportunity
to
3
install
the
equipment
now
and
drop
their
opposition
to
4
the
rule.
5
ConocoPhillips
has
done
very
well
in
recent
6
years
with
the high
cost
of
oil.
The
Wood
River
7
refinery
is
poised
to
develop
30
tar
stands
that
will
8
result
in
even
more
pollutants
being
released
to
our
9
air.
They
too
should
drop
their
opposition
and
allow
10
rule
making
to
proceed.
Each
company
used
an end
run
11
around
having
better
controls
than
lower
emission
limits
12
in
their
recent
rule
making.
13
The
Board
is
charged
with
making
this
14
decision.
Are
you
going
to
listen
to
the
EPA,
the
15
Illinois
EPA,
the agency
charged
with
protecting
the
16
people
of
Illinois?
Will
you
decide
that
what
they
are
17
proposing
is
reasonable
or
will
you
listen
to
companies
18
who
might
never
control
air
pollution
were
they
not
19
required
by
law
to
do so,
to
companies who
try
to
delay
20
or
overturn
every
rule
proposed
by
the
state
or
federal
21
government
that
would
better
protect
the
public?
Will
22
you
rule
so
that
the
companies
affected
rather
than
23
spend
millions
on
pollution
controls
give
their
CEO’s
24
even
bigger
bonuses
and
their
shareholders
a few
more
137
Keefe
Reporting
Company
1
cents per
share.
The
companies
-—
the two
companies
I
2
referred
to are
based
in Pennsylvania
and
Texas.
The
3
shareholders
live
mostly
elsewhere.
Will
you protect
4
the
health
of the
children
such as
Diyosa,
who was
here
5
with
her mother,
my,
and their
parents
and
children
and
6
grandparents
who
live
here
in
Illinois?
As Ms.
Funk
7
said,
health
care
has costs
too,
big costs,
often
8
unreasonable
costs.
It
is
your decision,
but remember
9
you
are the
Illinois
Pollution
Control
Board.
10
I have
several
studies
that
I’ll
submit
11
electronically
to go
on record.
One
came out
in
the
12
Journal
--
New England
Journal
of Medicine
I believe
13
last
week.
Particulate
Air
Pollution
and Life
14
Expectancy
in
the United
States.
I
also
believe
there’s
15
another
one
and
this
was came
as a
total
surprise
to
me
16
I think
it
was
just two
weeks
ago in
a study
by Ohio
17
State
researchers
suggested
a connection
between
air
18
pollution
and
diabetes.
Who
would
have
thought
that?
19
Reminder:
President
Obama
said
his
20
administration
will
base
it’s
decisions
on sound
21
science.
The
scientific
advisory
board
recommended
22
standards
that
are lower
than
what
is currently
being
23
used
but
for both
ozone
and PM
2.5.
The new
standards
24
when
they
are revised
will
be
more protective.
It
will
138
Keefe
Reporting
Company
1
be
such
a nice
thing
if
these
industries
who
are
2
affected
by
this
would
have
a
leg up
on
better
controls.
3
Thank
you.
4
MR. FOX:
Thank
you
for
your
comments
and
I
5
think
that
leads
us
to
a
point
where
we
may
go
off
the
6
record
and
discuss
procedural
matters,
including
the
7
deadline
for
any
post—hearing
comments,
unless
before
8
then
anyone
have
any
final
questions or
other
issues
9
that
we wish
to
raise?
10
(No
response.)
11
MR.
FOX:
Let’s
go
off
the
record
then.
12
WHEREUPON,
THERE
WAS
A
SHORT
PAUSE
IN PROCEEDINGS;
13
SUBSEQUENT
TO
WHICH
THE
FOLLOWING
PROCEEDINGS
ERE
MADE
14
OF
RECORD:
15
MR.
FOX:
In
going
off
the
record
the
16
participants
here
today
discussed
procedural
issues
17
related
to
the
filing
specifically
of
post-hearing
18
comments.
Before
it
takes
action
on
The
Agency’s
19
proposal
The
Board
will
hold
open
a
post-hearing
comment
20
period
ending
on
Monday
March
23rd,
2009,
which
is
21
30
days
after
The
Board
expects
to
rule
upon
a standing
22
motion
to
correct
the
transcript
and
a
standing
motion
23
to amend
the proposal
and
by
which
time
The
Board
24
certainly
expects
to
have
a
transcript
of
this
hearing
139
Keefe
Reporting
Company
1
today
on
February
3rd.
Once
that
transcript
is
in
2
The
Board’s
hands
our
collection
office
will
place
it
on
3
line
very
quickly
where
it
is,
of
course,
available
to
4
be
viewed,
copied
and
downloaded
free
of
charge.
5
And
I
indicated
to
the
participants
in
6
going
off
the
record
once
the
hearing,
I’m
sorry,
once
7
the
post-hearing
comment
period
does
begin
I’ll
issue
a
8
brief
hearing
officer
order
simply
so
that
everyone
has
9
unambiguous
information
about
the
start
and
end
of
that
10
comment
period.
11
Finally,
anyone
including
participant
12
persons
who
have
not
participated
in
these
hearings
may
13
file
written
public
comments
with
the
clerk
of
14
The
Board.
They
can
be
filed
electronically
with
15
The
Board’s
clerk’s
office
and
any
questions
about
that
16
process
can
certainly
be
directed
to
our
assistant
clerk
17
John
Therriault,
who
I
know
has
assisted
many
of
you
18
with
various
questions.
19
Any
filings
with
The
Board
must
be
served
20
on
the
hearing
officer
and
on
the
service
list
and
that
21
service
list
is
also
available
on
The
Board
web
page
22
under
this
docket
number.
23
If
you
have
questions
about
procedural
24
aspects
of
the
rule
making
you
may
always
reach
me
140
Keefe
Reporting
Company
1
through
my
office
phone
number
or e-mail
address
that
2
are
listed
on
The
Board’s
web
page.
3
There
are,
of
course,
now
no
other
hearings
4
scheduled
in
this
rule
making
and
unless
there
are
any
5
other
issues
anyone
would
be
prepared
to
raise
and
6
address
we
can
certainly
adjourn
with
thanks
from
7
The
Board
members
and
The
Board
staff
for
all
of
your
8
time
an
effort
preparation.
9
Safe
travels
back
to
your
offices
and
home
10
and
thank
you
once
again.
11
We’re
adjourned.
12
SIGNATURE
WAIVED.
13
14
15
16
17
18
19
20
21
22
23
24
141
Keefe
Reporting
Company
1
STATE
OF MISSOURI
)
SS
2
COUNTY
OF
JEFFERSON
)
3
4
I,
Bobbi
L. Hamlin,
a Notary
Public
in
and
for
5
the
County
of
Jefferson,
State
of Missouri,
DO
HEREBY
6
CERTIFY
that
pursuant
to
agreement
of
the
parties
the
7
aforementioned
hearing
held
before
me on
February
3,
8
2009,
at
the
Madison
County
Administration
Building,
9
Edwardsville,
Illinois,
touching
upon
the
matter
in
10
controversy
aforesaid
so
far
as
the witnesses
should
be
11
interrogated
concerning
the
same;
that
the
witnesses
12
were
examined
and
said
examination
was
taken
down
in
13
shorthand
by
me
and
afterwards
transcribed,
not
being
14
signed
by
said
participants,
and
said
hearing
is
15
herewith
returned.
16
IN
WITNESS
WHEREOF,
I have
hereunto
set
my
17
hand
and
affixed
my
Notarial
Seal
this
10th
day
of
18
February,
2009.
19
20
21
22
23
24
142
Notary
Public,
CCR,
RMR
Illinois
License
#084—002797
My
Commission
Expires
June
26,
2009
Keefe
Reporting
Company
A
action
22:3
139:18
137:22
139:2
113:18
13:9,10,22
82:24
ABC
134:12
actions
16:7
affects
132:4
agreed
36:10
98:8
amendments
1:9
2:8
ability
56:4
activate
7:3
affixed
142:17
agreeing
3:24
126:6
13:18
able
12:8
13:4,5,7
active
102:21
aforementioned
agreement
134:11
America
135:17
18:1834:1240:11
131:19
142:7
142:6
Americanl29:5
48:14
51:1
58:20
actively
134:4
aforesaid
142:10
agreements
134:14
131:9,17
134:3
68:10,19
72:15
actual33:5
34:21
after5:11
19:11
ahead27:1229:1
135:20
92:21
97:4 112:23
53:17
127:13
26:6
40:21
43:10
57:11
66:16
85:10
among
59:20
133:3
116:19,23
117:1
actually5:8
26:19
67:11,1370:299:1
85:14
86:17
87:1
135:21
132:3,24
33:738:250:1,18
139:21
92:794:1
104:11
amortization72:8
about
3:21
9:13 12:8
52:18,19
57:16
afternoon
85:18
106:18
126:17
72:16,19
73:24
12:18
16:3
21:21
58:4,769:10,12
103:17
130:5
amount2O:1636:4
26:16,17,20
3
1:12
72:8
107:20
afterwards
142:13
air
1:8
9:23,24,24
38:6,12
48:23,23
34:9
37:23
43:6
125:16
again2l:20
30:16
10:1,4
17:11
18:5
49:2,9,18,20,22
51:5,2456:1458:2
addl9:2064:3
34:10,1842:1
19:1627:15,22
50:5,1565:1066:6
64:11,24
65:17
78:15
122:12
43:17
44:3
45:5,12
29:3,5,15,1931:3
74:15
110:8
67:3
70:16
71:21
124:4
125:5
47:3
52:24
53:5,8
32:9,11
33:9,11
amounts
48:22
51:3
72:4,16,17
73:2
added
122:20
53:10,14
69:5
34:2
35:8,17,17
55:15
75:16
76:19
81:14
adding96:19
123:18
71:19
74:17
77:14
36:10
37:4,11
39:9
Amy 102:6,20
138:5
82:15,16
93:21
125:4
133:12
79:10
80:12
82:4
53:16
74:7
75:21
analyses
27:15,19
94:21
105:13,20
addition4:1,15
87:5
90:24
91:12
103:3,24
104:9
28:17
29:3,8,8,11
106:22
113:5,13
36:20
48:9
93:10
91:14
92:8
93:23
106:4
131:19,21
29:17
32:1,20,20
115:16,17
132:22
95:9
97:2
103:13
101:6
110:7
132:10,12,14
35:16
133:19,24
134:1
additional
12:20
111:10
113:6
133:13,18,24
analysis3l:23
32:21
140:9,15,23
29:15,15
84:7
116:12
141:10
134:4,8,20
135:12
33:9
40:11
43:20
above
32:1
76:5
85:21 87:20
89:18
against
33:5
135:14,19
136:2
43:22
44:9,17
96:17
address7:39:11,14
age
103:2
111:8,8
137:9,18
138:13
53:16
57:1,9
60:6
absolutely33:11
15:3
16:16,24
112:9
138:17
60:6
63:18
70:21
82:20
90:17
17:23
18:5,10,22
agencies38:4
Alec4:22
18:12
79:787:19,22
accept
15:1
19:14,2320:2,12
agency2:124:3,23
Allergy
135:18
89:19
93:22
94:18
accepted2:13
23:14,17,1828:3
5:20
6:2
9:4,21
allocations24:12
97:9
98:15
101:15
access68:10
95:20
46:12,19
80:10
10:6
11:6
15:14
alLow6:16
105:17
103:11
109:2,6,11
accommodate
8923
95:3 96:5
16:7,11
17:17
105:18
109:24
120:1
121:4
126:1
127:10
111:24
132:21
18:10
25:2,9,11,15
137:9
Anand3:1,3
accomplished
80:3
141:1,6
25:20
26:4,21
allowances
24:2,3
Andover
10:3
according
39:7
addressed
16:6
30:18
41:12
42:21
allowed
25:24
67:3
Andrea
2:23
accuracy
33:4
84:16
92:1
44:23
45:6
54:14
91:15
127:19
Andria
127:18,19
accurate3l:18
adequate
10:12
57:17,20,21
58:3
allowing92:8
97:19
127:22,22,23
32:1670:2099:19
19:22,23
110:10
63:1575:876:22
allows6:1874:15
128:1,4,13,20,24
109:3
adjournl4l:6
77:15,1580:16
119:4
129:1,5,7131:8,11
achievable
56:9
adjourned 141:11
82:6,18
90:15
98:7
alone
123:6
124:19
131:14,16
76:15
78:2
adjusted
78:8,9
99:24
100:17
along
21:5
30:24
announced
129:12
achieve
16:12
17:10
AIIM
1:9
109:17,19
110:8
104:14
annual5l:1,6,9
53:4
17:10
18:4
53:20
administration
110:11
114:15,18
already
13:1
48:1
annually
135:19
55:19
64:2
75:14
138:20
142:8
114:22
116:7,10
78:19
96:19
108:9
another
7:17
57:10
77:9
79:20
81:19
Administrative2:8
116:15
117:1
113:1
65:476:16,17
82:12
96:19,21
admission7:24
8:19
137:15
aiternative56:12
77:12
97:7
138:15
97:4
107:14
84:12
86:1,8
agency’s
3:14 4:11
58:8
80:19
82:6
answer
35:13
70:2
123:18
124:19,23
admit43:3
83:20
13:17
15:14
25:3
although
62:13
97:21
100:24
achieved
16:15
84:1
86:17
60:18
61:14
79:14
133:6
104:15
111:11,12
58:12
admitted3:98:23
86:1398:10
altogetherl33:17
127:1
achieving
55:4
41:17
45:21
84:13
100:13
102:4
always
45:10
82:14
answered
16:21
acknowledge 82:2
adopted
21:2,2,8
139:18
103:8
140:24
21:18
57:16
133:1
86:15
92:15
133:10
aggravated
135:14
ambient
32:21
40:4
answers
14:22
42:3
acronyms
62:24
adoption
133:16
ago 67:20
79:9
40:5
anticipate
12:15
63:6
advisory
131:21,23
89:22
103:16
amend
9:5,7
14:15
26:16
across
132:9
138:21
132:18
138:16
20:15
130:20
anticipated
13:4,11
act 19:7,16
28:3
affected
12:15
13:8
agree
33:20
61:16
139:23
26:15
28:5
65:21
136:16
20:4,18
23:23
24:1
65:868:20,24
amendmentl2:12
anticipation
132:18
acted
19:4
81:4
134:2,9
72:12
112:1,2
12:14,16,19
13:3,5
anyone9:1454:4
1
Keefe
Reporting
Company
85:22
97:24
99:24
129:13
139:8
140:11
141:5
Anything
130:24
apologize
47:10
63:10
91:12
102: 14
apparently
3:2
134:11
appear
63:23
appears
27:10
42:5
42:8
47:22
129:9
applicable
3:7 39:6
39:11
application
75:24
77:12
81:15
92:23
94:21,23
96:24
97:18
112:22
118:20
119:6
122:3
126:20,24
applications
75:10
79:6
92:17
95:2,23
112:20
127:14
128: 10
applied
97:6
124:24
applies
15:2
23:12
apply
33:5
37:5,8
81:5
92:13
applying
97:13
appreciate
12:6
15:1448:11
61:8
62:4
82:3
85:23
93:18
102:3 106:8
106:
16
appreciates
93:18
approach
27:20
29:7
32:19 38:3
40:7 55:1
56:6
80:11 82:1,23
approaching
76:14
appropriate
27:8
55:3,3,7,18
64:18
75:7,24
87:12
92:19
93:1
96:7
102:15
107:4
approved
40:10
approximately
67:19
124:5
area
17:12,12,13,21
19:5,6
27:24
29:21
30:8,15
33:16
34:20 38:5
39:3
78:23
103:9,10,15
103:20,21
134:19
135:16
136:2
areas 17:2,22,24
19:17
20:3,17
28:15
29:13
78:21
argument
47:17
133:
14
arguments
47:15
arise
9:9
around
137:11
arrangement
115: 19
arrive
50:9
72:11
79:7
arrived
73:5 92:23
aside
8:1
asked
106:21
117:22
118:16
126:22
asking
21:7
57:17
106:5
aspects
140:24
assertions
47:20
assessment
75:11
assign
43:19
assigned
2:23
45:19
84:15
assistant
9:19,22
140:
16
assisted
140:17
associated
25:6
53:1
73:11,16,19
74:1
79:6
112:16
Association
135:20
assume
50:11
51:2
51:14
120:16
assumed
49:7
51:11
52:24
assumes
72:9
assuming
49:20
75:9
116:12 123:2
assumption
89:6
assumptions
40:3
49:10
50:16,21
51:22
72:7,15,16
72:17 73:6
89:15
assurance
26:2
asthma
103:5,6
135:
17, 17,20
astronomical
135
:22
attachment
52:22
100:20
attachments
83:21
84:2
attain
17:7,21
39:6
attained
18:1,2
29:21
31:16
39:3
attaining
17:14
19:6
19:6
27:24
30:9,12
30:15
attainment
18:8,11
21:3
27:20
28:13
30:21
32:16,18,23
33:15
34:3,13
39:6
39:11
40:6,9
136:3
attempt
75:11 93:17
attempted
116:21
attempting
90:18
attention
12:6 48:19
103
:24
attribute
104:23,24
attributed
103:9
author
121:13,17,18
authored
121:16,23
authority
60:16,21
availability
7:17
126:5
available
17:1
20:14
25:5,16,17
26:12
28:9
37:10 43:9
45:6
46:11 49:14
49:15,20,24
50:1,2
50:16
51:5
61:21
61:24
68:4,18
75:6
76:15
79:10
86:19
86:20
94:8 95:20
97:9 105:3
107:4
109:23
112:20
113:1
116:1,10
125:19
136:15
140:3,2 1
average
81:16,22
114:8
averaging
40:5
avoid
7:4
22:10,13
103:23
aware
6:22
9:3
22:4
25:8,10
26:9,18
36:18 60:6
71:7
74:22
81:6
93:14
99:7
114:20
116:5
119:10
123:12
126
:23
away
6:8
14:7
A-N-D-R-I-A
127
:22
B.
B49:5
98:5
back
23:2
51:20,21
52:3
67:11,13
69:20
9 1:2,7
102:2
106:16
108:12
117:4
118:4
136:19
141:9
bags
135:22
balance
50:2
64:6
Baldwin
8:6,8,9
base
31:12 32:7,14
33:6,14 34:21,24
35:1,8
37:5
38:5
60:14
115:7
138 :20
based
4:12
17:14
29:23 30:17
32:1
32:18
33:13
34:9
34:
10,15,2 1,23
38:9 39:8,9
47:19
49:16,20
51:18,21
51:24
57:6
59:21
60:24
68:9
79:12
96:4
97:11 98:1,6
98:16
108:13
126:1 138:2
basically
104:7
105:11,16
106:4
basis 4:19
14:442:2
54:3
61:14
83:13
86:21
90:1 96:8
110:12
129:10
Bassi
7:14,20
8:2,4
8:11,13,15,17,23
9:1
14:6,8,22,24
15:5,6
93:6,9
battery
10 1:20
bearing
44:20
121:11
bears 48:20
before
1:1 3:22
9:14
10:22
11:6 13:10
13:18
16:11
19:22
24:6
26:9
41:10
42:10
47:2,7
56:24
67:14 80:2
84:10
85:24
90:18
94:5
99:2,9
106:21
110:2
139:7,18
142:7
began
132:20
begin
11:19 12:4
67:21
85:2 140:7
beginning
18:22
86:13
begins
11:6 93:11
behalf
4:2,5
9:20
10:7 14:12,18
18:12
66:17
67:7
129:3
131:1,8
being 18:7
23:15
33:17
35:5
51:4
52:15,16
58:12
72:20
74:19
77:5
82:9
99:2,9
105:4
132:8
134:21,24
137:8
138:22
142:
13
believe
3:18,22
5:17
6:3
7:15 11:16,23
11:2417:220:2,15
29:24
34:5
35:1,7
39:4
45:11
46:9
55:17
58:8
60:4
62:12
69:20
74:21
81:8 82:10
84:21
89:8
92:20
96:6
98:12
99:10
107:7
109:18
113:3,17
114:10
116:8,18
120:6
122:7
123:7
138:
12, 14
believed
99:11
Belleville
1:22
below
63:14
117:7
benefit
6:24
benefits
29:16
134:
16
besides
111:16
best
10:18
92:1
103:23
104:5
123
:23
bet
97:23
better
59:12,15,17
59:18
60:5
61:5
82:24
92:18,21
101:9 122:14
123:6
136:5,14,15
136:23
137:11,21
139:2
between
20:12
59:20
115:13
138:
17
beyond
106:3
BFG
93:5,8
big
138:7
bigger
137:24
Bilbrook
9:22
billion
30:7,7
53:5
53:12
billions
136:21
bit 16:3
32:5
37:23
103:22
126:19
134:1
Blake4:5
10:791:5
92:10
94:3
blast
50:11,12
79:1
88:9,14
93:11 97:1
101:8
113:21
114:3
118:22
119:8 126:24
127:3
blend
93:11 123:13
blends
126:20
127:5
Bloom
48:5
100:18
100:23
106:22
107:8,9,12
113:4
113:12,15
115:5
115:11,13,
14
12
1:2
board
1:1
2:4,9,13
2:21,22,23,24
3:4
3:6,11,16
4:3,15
6:2 7:21
8:14
9:6
9:10 12:12
13:10
13:16,18
15:3 20:1
21:2,3
22:2
26:11
26:12
28:7
47:3
80:2
84:19
92:22
2
Keefe
Reporting
Company
93:17
94:6,13
99:2
131:17
134:3
69:1775:21
94:23
63:21
cite58:11,11
61:23
99:9,22,24
100:9
136:11
95:2,9
96:15,20
CATS
38:4
cited
58:22
62:6,15
100:20108:3
bound48:23
100:19111:5,21
causel34:8
64:15
109:16,19
110:2
boundaries
18:24
112:4,10,15,19,21
caused
135:14
citing58:464:7
110:11
116:11
19:5,8
112:23,24
115:5
CCR
142:20
citizens
105:7
120:15
121:15
break
6:9 16:19
121:22
122:3,5,13
cement
132:8
city
48:8
94:10
131:15
132:20
38:16
46:5 67:11
123:19,22
124:24
Center
125:17
97:11
134:6,22
137:13
138:9,21
67:14,17,20
125:3
126:23
cents
138:1
135:5,17
136:12
139:19,21,23
101:19,24
106:17
128:8,8,10,11
CEO’s
137:23
claim
25:20
133:12
140:14,19,21
breakdown
49:7
burning
69:4,7,18
certain
20:23 64:5
claims
94:22
141:7,7
breakthrough20:11
70:22
66:6 75:10
103:23
Clair
135:18
Boards’s
12:6
breathes
106:4
burns 80:7
134:12
clarification
54:13
Board’s6:5
11:15
breathing
103:7,18
bus
134:17
certainly6:9
9:10
121:13
11:17
22:1
91:22
brief5:9
11:20 12:1
business99:12,18
14:19,21
18:222:3
clarifications22:16
140:2,15
141:2
27:9 42:8
67:1
99:23
104:16
35:15
60:16
63:24
99:14
Bobbi
1:19
142:4
84:5,23
87:4
90:7
105:2
109:20
80:5,22
81:6
82:22
clarified99:17
boiled52:lO
91:3
97:17
102:24
119:4
84:886:15,1991:4
clarifyl2:8,18
16:2
boiler7:13,13
8:7
127:20
129:19,21
buying
125:3
92:2
100:6
107:3
20:6
21:20
36:24
43:20,2244:1,9,17
130:8,18
131:12
110:4
139:24
40:19,22
43:21
58:7
60:11
61:10
140:8
140:16
141:6
82:4
101:6
124:16
61:22,2365:15
briefly47:6,13
C52:22
certified34:6
128:6
69:1671:980:18
bringl8:884:17
CAIR22:16,21
CERTIFY142:6
cleanl9:16131:19
92:18,1994:20,21
brings83:19
106:15
23:12,16,18
24:11
CFR76:18
135:11
95:19
96:22
115:8
brochures
115:15
calculate
50:8
Chair
131:17
cleaner
105:21
115:19
118:20
broke67:19
calculating74:4
chance
112:8 120:8
133:13
136:2
119:19
120:2
brought28:7
133:7
calculation43:9,22
change33:9,12
88:7
clear3:12
11:15
121:1
124:6
BtuSO:13
63:22
44:9,1753:7
64:14
changedl09:14
16:23
24:2443:4
127:14
128:11,12
68:15
96:18
124:5
calculations
47:23
changes
16:1
99:15
clearer
7:19
boilers
48:8,24
50:1
127:8
53:19 65:1
98:16
changing
88:23
clearest
7:6
50:1,3
51:6,15,20
BTUs
49:16
50:3
108:5 114:10
characterization
cLearly
7:2
51:23
52:7,8,11,14
Btu’s51:5,24
52:18
124:18
23:1
61:17
clerk
140:13,16
52:20
53:21
54:11
53:5,12
calendar
22:2
characterized
18:7
clerk’s
140:15
55:13
57:6
59:10
budget
22:22
23:11
California
108:23
cliarge72:9
140:4
client
14:24
62:7,9,14,19,19
23:12,14,19
Ca1l23:11,15,24
charged
137:13,15
clients
14:18 56:17
63:13
64:12
68:19
buiLding
134:17
came
138:11,15
chart44:1
128:23
69:3,4,7,20
70:21
137:1
142:8
cancer
135:13,15
charts7:12
clock67:13
71:1,2,20
78:24
built
89:15
132:9
cap
23:19
check 101:4
close48:12
53:5
80:21,23
82:5
bundle
31:1
36:8
capable
59:22
123:9
chemical
132:5
109:20
88:13,21,22
92:14
Bureau
9:24
10:4
capacities
62:10
Chicago
2:19
17:13
closer47:8
101:13
94:9,23
95:6 97:10
133:18
131:23
17:17,24
18:1
19:6
club
102:22
129:6
101:8,15
111:5,8
burn
25:6 43:23
capacity
58:18
30:8
33:16,18
38:5
131:10,18,19
112:16
114:2,23
49:19
70:6 71:19
capital
72:8,8,17,19
91:7
103:4
134:3,12
115:6,17,21
71:24
88:1,20
73:24
Chief
133:18
coal
76:9
132:5
116:16,23
117:7
92:13
car
104:22
children
102:21
coast28:2
119:7,14
123:3
burned
52:9,10
care
7:7
11:5 104:12
104:2,4,11
105:20
code 1:9
2:8
112:1
125:3
133:1
136:7
114:2
129:8,15
138:7
135:21,23
138:4,5
Coen96:20,23
bonuses
137:24
burner
48:5
62:8
carpenter
135:7
children’s
105:17
COG
43:10,23
44:2
both 7:16
13:20
65:18
68:13
69:15
case 17:9
37:5
70:13
chin
130:3
44:3,10,18,19
93:5
17:11
18:11,15,16
70:12
73:12,12,18
72:1380:2282:19
choice3l:12
93:7,12
23:17 31:8
36:21
94:20
95:1,8,18
82:19,20,21
choose 55:14
56:1,2
coincide
13:1
38:14
51:14
79:24
96:14,22
111:16
113:21 128:15,16
57:22
coke43:1044:348:7
85:795:13,16
112:6
115:11,12
cases
56:1,2,3
58:15
chose6l:14
48:7,22,2349:7,10
105:2,4
120:24
115:14
119:3
62:16,22
63:24
circulated
41:12
49:14,15,18,19,21
127:10128:11
121:24122:8,11
64:1270:16,16
86:4
49:22,2450:5,10
134:6,9,10,14
122:16,19
123:3,4
77:23,24
78:7,9
circulation
75:22
50:15,15
51:3,19
135:21
136:4
123:8,9,11,16,21
120:20,24
95:9
52:9,13,18,19,19
138:23
123:23
124:16,19
Catalytic95:10
circumstance80:6,9
52:21
53:2,1780:7
bottom
15:22,23
124:21
126:20
categories
1:8 2:7
circumstances
46:7
88:2,8,13,20,21
31:1634:1753:4
127:4,10
36:15
55:2476:380:5,10
89:797:1
114:4,5
98:22
129:5
131:9
burners
62:20
68:16
category
62:14,19
82:14
83:1
96:4,8
118:22
119:8
3
Keefe
Reporting
Company
124:1,2,7,
10,
10
126:24
127:3
132:7
Colaz’s
58:24
collected
30:18
collection
140:2
collective
32:22
collectively
36:10
college
103:6
combination
33:10
54:23
57:17
96:15
97:7
123:4,11,16
124:18,21
combinations
80:8
combined
121:24
combustion
54:20
54:22,23
55:14,16
56:1,2
60:2
75:20
97:13
come
27:10
42:6
46:17
47:2
50:21
51:6,8
67:11,13
92:18
105:10
118:4
129:22
130:12
132:13,16
136:2
comes
53:11
comfortable
74:12
78:11
coming
65:2
66:6
comment
6:13,23
89:5
90:2
102:7
106:12
129:15,19
129:21,24
131:8
131:12
132:3
139:19
140:7,10
commented
77:4
comments4:16,19
5:2,16
6:19 9:9
10:22
13:19
54:3
57:24,24
72:4
78:16
84:5,7,7,9
87:20
89:19,23
91:10
94:11
128:7
129:2,3,15 132:17
132:21
133:4,5,7
139:4,7,18
140:13
commercially
112 :2
1
Commission
142:21
commissioned
94:15
Committee
13
1:21
communications
94:24
communities
133:20
134:16
135:8
community
15:15
104:
18
companies 13:12,17
13:20
55:8
135:10
136:10
137:17,19
137:22
138:1,1
company
1:21
40:13
46:1
81:17
135:2
136:14
137:10
company’s
85:1
104:23
compare
49:23
50:4
51:1
compared
32:11
60:7
comparison
59:2
compelled
104:7
compelling
64:24
competitive
89:4
complete
3:12
5:12
94:18
97:9
completed
13:15,16
96:2
complex
18:9
compliance
12:24
23:23,23
24:2
30:1
34:15
41:1
55:9
comply
79:19
133:11
component
33:3
compounds
29:10
computer
33:8
101:19,21
106:20
133:3
conceivable
111:22
concentration
28:19
29:12
concentrations
31:22
32:3
concept
82:21
99:18
concerned
114:2
132:22
concerning
114:23
118:17
134:5
142:11
concerns
26:17
40:14
132:21
conclude
129:9
concludes
13:23
28:2
1
conclusion
4:11
6:13
6:17
34:21
41:3
129 :23
conclusions
3:14
35:9
40:20,24
47:20
93:23
94:19
96:7,11
97:11
109:
13
concrete
103:20
condense
58:19
condition
34:24
89:11
conditions
55:15
88:17
conduct
96:1
127:2
conducted
29:2
97:8
confidence
74:18
81:11
confidentiality
25:20
99:13,19,23
116:
13
confirmed
96:23
confusion
16:3
connection
138:17
ConocoPhillips
5:17
25:4,8,24
26:2,10
26:16
72:5
134:5
136:3
137:5
consent
36:19
37:13
37: 19,20
Conservancy
129:6
131:9,17
134:3
Conservation
131:
17
conservative
12
1:8
consider
37:1,24
77:16
82:6
103:11
105:10
106:5
consideration
80:19
82:19
83:23
122:21
considerations
92:22
considered
32:19
77:19
82:9
122:21
122:22
126:2
considering
88:5
109:
17
considers
104:12
consistent
40:8
122:7
Consortium
10:2
constituents
70:8,10
constitutes
21:9,17
construction
95:7
consultant
128:15
128:17
consultants
51:8
consultation
38:10
consulted
60:18,20
consume
71:8,11
88:2 1
consumption
43:10
52:2
1
contact
94:20
96:1
113
:4,12
contacted
96:14
97:2
108:18
contacting
119:5
contacts
109:12
contain
124:3
contained
82:13
115:
12
Container
130:8
Containers
13:13
130:21
contains
93:2
124:7
contemplate
4:7
contended
94:14
content
55:14
contention
20:10
97:14
contents
12:11
context
21:22
114:9
continue
82:22
90:14
continues
82:18
continuing 12:14
13:12
26:16
contract
37:18
95:12
contracted
92:11
contractors
27:16
contribute
134:7
contributed
132:10
contribution
37:24
contributors
134:23
control
1:1
2:4 9:24
16:14
17:1,8
18:9
20:13
31:1,1
36:7
36:8,21,23
37:8
38:14
54:24
55:3
55:12,19
56:1,2
57:14,18
58:8
59:23
61:12,22
62:5,11
63:17,18
64:1
65:3
74:8,21
75:20
79:5
81:8
94:6
97:7,10
104:24
105:3
106:3,3
111:17
112:5,23
113:20
121:4,11
135:10
136:5,9,15
137:1
137:18
138:9
controlled
81:21,22
94:9
controlling
81:17
controls
36:14
37:16
56:3
60:2
92:13
95:5
97:13
109:2,5
120:5
133:12
135:3
136:15,23
137:11,23
139:2
controversy
142:10
copied
140:4
copies
7:16,17
28:7
41:12
42:22
45:6
85:21
86:3
copy
7:18,22
48:10
85:20,22
87:1
98:8
100:1,17
108:1
120: 14
corporate
100:7
corporation
10:8,15
46:1
92:11
94:4
correct
3:24
4:21
5:7,21,22
8:15
22:24
34:24
41:14
41:15
44:4
60:13
67:24
91:18
98:20
99:20
100:14
107:10
108:15,16
108:19,20,23,24
113:16
114:24
117:8
118:21
121:15
122:5,6,12
124:14,15
128:8
128:21
139:22
corrections
91:24
correspondence
114:1
115:13
corresponding
84:14
cost 25:5,9
56:9
58:13,20
62:1
63:18
64:4,13,22
65:3,6
72:4,8,8,12
72:18,20,21
73:6
73:11,
12,
14,16,
17
73:18
74:6,8,15,21
76:15,16
77:10,10
79:11,23
80:11
81:8,18
122:12,18
122:18,20,23
125:7,9,1
1,f2,18
126:4
133:13
137:6
costly
78:3
costs
62:15
72:18
73:19,22
79:6
104:12
138:7,7,8
Council
131:20
counsel
4:22
9:20,22
counter
6:11
39:23
40:3
County
104:8
135:18,19
142:2,5
142:8
couple
12:17
16:2
24:21
33:23
54:7,7
56:8
87:21
91:18
97:23
103:2
107:1
130:3
course
2:15
3:3
5:6
6:20 7:10
17:9
44:6
45:18
46:8,13
49:18
50:7
58:21
72:18
84:14
87:7
90:12
91:17
106:11
121:24
140:3
141:3
court
6:11,24
85:7
106:11
130:3
4
Keefe
Reporting
Company
cover
58:20
107:6,19
108:2
develop
3:12 49:22
90:15
70:3,7,2471:5,10
co-firing96:24
119:3
120:21
82:23
92:17
disease
135:12,16
71:14,23
72:14
118:22
119:7
decide
137:16
125:11,12
130:22
diseases
135:13
73:15
74:5,9,14,24
127:8,9
decision
35:5
105:1
137:7
disposed
71:22
75:8,12
76:24
crafted
73:3
105:18
106:6
developed
58:2
disputed
94:22
77:15,16,21
83:13
critical
113:24
113:20
137:14
59:19,21
112:21
distinction
112:18
83:17,17
84:2
85:5
cross
106:2
138:8
developing
22:20
distinguish
43:13
87:18
88:1
89:6
crucial
97:17
decisions
134:13
development
19:2
distributed
45:7
91:8 92:15
94:12
current
20:22
23:22
138:20
diabetes
138:18
disturbs
104:9
94:14,22
96:14
27:22
33:21
35:8,8
decommissioned
dialogue
26:16
80:9
Division
9:24
97:16
108:14,19
35:17
39:9 59:22
52:9
dictate77:7
88:18
Diyosal38:4
109:12
114:1
64:8,988:1995:20
decree37:13
89:12
docket2:9
7:15
8:23
115:13,24
116:6
125:18
decrees36:19
37:19
dictated89:3
140:22
116:16
117:10,24
currently
35:4
37:20
died
135:13
doctor
103:22
118:4,11,16
87:18
121:2
deferred
83:22
differ 77:11
document
7:18
draft
20:21
41:9,13
136:12
138:22
define
59:15
76:11
difference
35:9
31:24
54:10,11,13
drafted20:21
custom96:23
defined56:7
53:16
56:19
57:13
58:8
draw48:18
112:19
cyanide
124:4,8,9
definition
76:17
differences
32:7
59:7,9,24
60:12
drawings
115:19,19
126:4
different
20:13
61:2,3
64:6,20
115:24
—
D
Deirdre
15:11
40:17
38:13
58:17
59:17
65:21 73:10
74:15
drawn
96:8
Dana 9:21
98:2
79:8
60:1
62:5,10
66:3
76:18
80:23
driven
123:23
data
17:15 27:16,23
delay
133:15,15,15
66:3 70:15
73:1,2
121:23
drop
137:3,9
29:24
30:17
32:21
137:19
77:5,22
82:21,21
documentation
21:6
due
33:20
53:9
33:5,10,21
34:3,6
deliver
102:8 131:4
89:2
96:6 101:20
documented
76:7
104:13
117:2
34:7,9,15
35:8
demonstrate
59:9
120:9
133:21
documents
8:20
DULY
11:10
85:13
39:9
40:4,6,9
58:4
59:11
difficult
81:20
98:23
100:4,11,11
during
55:15
89:7
58:16,16124:21
demonstrated30:21
dig92:16
100:19
89:14
103:16
date 4:6
12:24
19:18
77:9
diligent
94:18
97:9
doing
37:24
57:9
Dynegy
8:11
25:18
26:1,8,24
demonstration
diligently
95:16
59:23
60:8
80:15
28:13
35:18
39:6
19:12
21:4
27:21
dimensions
115:8,14
102:17
125:15
41:1443:12
98:13
32:18,2340:7,9,12
115:17
dollars76:8136:21
E3:1
11:994:12
99:5
65:9
direct
107:1
113:8
dominated28:16
each
11:2436:938:7
dated2:1441:13
departmentl07:13
119:22
done56:11,16,16
49:8,1051:757:1
48:5
58:9,10
98:17
132:13
directed9:6
61:5
74:19
76:14
133:6
77:8
95:3 136:5
100:20
depend70:17
74:16
101:9
127:24
133:20137:5
137:10
daughter
102:12
dependent
68:22
140:16
double
64:1
earlier
8:13
45:19
Dave
58:24
depends
70:7,10
directing
106:24
down
16:19
50:11
75:4
84:16
121:6
Davis4:22
18:12,12
72:14,15
direction
15:16
50:12
53:3,10
easiest8l:18
20:19
22:14
23:4
describe
96:4
directly
17:24
94:20
65:18 72:20
89:6
easily
56:4
63:17
23:22
24:14
31:8
described
18:14,15
103:21
120:22
89:12,14
92:20
79:19
31:1032:4,1333:1
22:1724:1045:19
director4:2210:1
93:10,11,1796:11
Eastl7:21
19:5
33:13
34:1,8,12,16
45:22 78:19
15:11
116:19
130:2,12
103:4
104:8
132:3
35:1,7,12,20,22
description
57:14
Directors
10:2
142:12
134:19,23
135:21
day 38:8,8
89:24
design
34:22
96:23
disagree
87:24
downloaded
140:4
East/West
13 1:20
142:17
97:3
125:15
disclosure
100:12
downward
52:5,13
easy
104:15
days
2:18
28:19
designate
33:18
discovered
133:2
downwind
17:12,24
economic
75:9,15
139:21
designation
16:8
discuss
40:13
60:1
29:13
economically
55:12
daytime
132:17
135:1
77:22
115:4
Dr
3:1,20
10:2 11:9
68:4
deadline
10:9 14:20
designed
16:12,14
116:20,21
118:1
25:4,16,22,24
economy
104:20
21:23
133:14
desire
89:3
121:22
139:6
26:13
45:14
46:8
105:6
136:13,17
139:7
detail
59:10
discussed
35:5
48:1
46:18,21,22,24
Edwardsville
142:9
deadlines
84:9
detailed
38:8
68:18
56:7,9
77:23
87:3
47:7,12
53:23
54:2
effect
84:17
deal
9:8
16:8
details93:21
105:4
112:14
54:5,755:5,20
effective
55:1
79:11
decades
97:12
determination
18:19
139:16
56:13,16,2457:5
79:23
80:11
81:8
December2:18,19
91:994:9
discusses37:19
57:16,17,21,21,23
81:19
7:10,23
8:24
10:14
determine
29:4
34:3
122:10
59:14
60:15
61:1
effectively
7:11
17:17
18:23 26:7
34:13
51:1
64:18
discussing
113:4
61:17
64:3 65:12
effectiveness
58:14
26:10,14
43:24
68:13
121:4
discussion64:11
65:17,20,24
66:12
58:20 62:1
64:5,13
91:8
94:6
98:4,20
determining
64:17
discussions
13:15,16
66:19 67:7,22
68:2
64:22
65:4,6 72:20
99:1 100:2,16
120:23
22:8
59:19,19
64:6
68:7,24
69:5,10,16
73:6
126:5
5
Keefe Reporting
Company
efficiency
71:13
emphysema
135:12
50:20
124:22
exceeding
123:9
88:6,8,15
89:1
72:1
134:18
empty
130:13
establish
79:14,18
exceeds
122:18
117:12
132:7
efficient
130:15
end
53:3 57:20
79:22
Excellent
11:8
134:7,9,10,14
efficiently
136:11
63:22
65:10,11,13
established
18:24
except
100:11
136:4
effort
6:21
7:2
141:8
65:13,13
89:24
23:11
81:9
exchanges
97:17
facility
56:14,15
efforts
12:20 15:15
137:10
140:9
establishing
19:4
excuse23:3
24:1
57:2
66:4
71:9,20
92:16,20
ended
40:22
estimate
33:10
51:21
62:24
74:11
88:12
89:14
EGU
60:11 61:10
ending
139:20
37:10
38:12
49:9
executing
95:4
134:6,24
EGUs
23:18
59:7
energy
28:3
71:13
53:3
73:3,7
74:17
executive
4:22
10:1
facility’s
56:21,22
eight-hour
20:13
72:1
134:18
125:7,9,11,13,18
15:11
fact
12:14
13:2
28:1,13
136:10
estimated50:5
exercise68:12
106:1
63:23
68:781:13
either3:11
5:4
engaged47:4
58:13 74:6
96:16
exhibit7:11,248:5,6
104:8
110:12
12:19
14:1848:24
eiigineer92:1194:4
124:3,9
41:10,18,2243:4,8
factor37:13
50:12
97:6
128:14
133:23
estimates32:9
47:23
43:18,2344:10,18
factors33:537:6
elaborate
32:5
engineering
48:5
50:17,22
51:23
45:20
48:19,19
68:22
77:18
39:24
126:19
73:22
95:6
100:18
64:5
65:1 72:21,23
49:3,5 50:6,18
facts
64:18
electronically 28:9
107:13,22
113:5
123:15
51:18,21,21,22
failed
104:8
85:19
109:23
113:12,15
estimating74:15
58:2466:20
86:10
failing
135:19
138:11
140:14
engineers
10:3
etc37:758:6
86:18,23
120:20
fair46:674:15
element
18:9
102:14
England
138:12
evaluate
36:4
exhibits
8:7,20
123:4
elsewhere
33:16
enough
22:10
50:15
evaluated
34:2
36:8
42:11 43:1
45:14
fairly
44:24
64:24
101:9,17
138:3
109:24
55:24
45:19
66:20
83:20
fall 50:14
57:19,19
emission
22:22
ensure 23:14
105:6
evaluating
80:18
84:1,12,13
98:5
75:20
76:2
23:1929:1830:23
enterll:1242:11
123:1
108:8
falling59:4,13
36:7,14,19
37:9,9
entered
11:18
41:9
evaluation
56:12
exist
79:3
families
135:9
37:20
38:12
47:23
45:13
91:23
98:6,8
126:19
existed78:22
100:2
far
15:2,4 64:17
51:2,6,7,9,23,24
entertain
100:6
even
19:3 24:3
62:15
existing
95:9
96:20
75:12
87:23
98:18
52:24
53:1,6,11,12
entire
88:17
107:21
63:23
76:3
103:7
111:5
112:10,16
125:14
142:10
53:15,21
56:8 59:2
entirety
87:11
91:23
122:16,18
125:16
122:3 123:12,18
fashion
23:19
59:1860:10,13,15
entitled2:643:20
137:8,24
124:24
fatherl03:3,4
60:19,22
62:3
environment
105:8
event
112:3
expect
6:15 19:7,20
104:21
135:5,9,12
63:15,19
64:9,17
105:19,21
ever
103:19
114:14
38:13
84:6
favor 14:19
64:19 65:5
66:7
environmental2:11
116:6
Expectancy
138:14
February
1:13
4:4
75:776:4,7,10
4:3,169:4,20
every
6:21,21
13:7
expectation
13:7
14:21
140:1
142:7
77:8,16
78:6,21
40:18 102:23
55:23
57:2
66:4
expects
139:21,24
142:18
79:3,4,12,15,16,20
131:22
134:16
75:2479:15
81:11
expeditiously92:3
federal2l:22,23
79:21,23
80:24
envision
80:9,24
103:6,8
119:5
expense
125:2
22:22
36:18,21
81:1,9
97:5
110:17
81:5
82:12 117:12
137:20
expensive
54:22
38:13
134:20
121:1,7
125:5
envisioned
77:5
78:4
everyone
2:3
85:19
62:13
137:20
137:11
EPA3:17
12:23
109:23
140:8
experience68:14
feed 105:24
emissions
1:7
2:7
18:18
20:20
22:19
everyone’s
67:22
95:23
97:12,14
feedback
123:13
16:15
17:929:4
23:728:3,1030:6
everything
109:11
109:5
119:4
feel
11:2160:378:1
31:20,2132:6,8,15
30:13
33:1740:4,5
133:15
126:19127:4,12
78:11
106:17
32:20
38:9
47:15
40:10,10
47:5
evidence
21:13,15
experienced
103:19
feeling
77:23
50:17,22
53:9
59:12,23
97:5
98:3
27:20
29:6 32:19
expert97:2
felt47:15
55:12
56:15
58:2
130:22
131:22
39:2240:12
Expiresl42:21
few22:15
31:11
58:12
59:3,8
61:9
133:6,8
134:13
exact
70:8,10
explain
12:11
36:1
39:1
48:14
61:11
78:10,11,20
136:1 137:14,15
exactlyl9:1221:18
explaining
114:9
66:14,21
72:3
78:21
95:13
96:17
EPA’s
28:5,11
38:11
43:5
66:4 100:22
exposure
135:14
95:10
99:17,17
96:21
114:10
40:858:775:2
109:16
express
14:16
103:15
131:4
117:7
119:13,19
equal 65:10
examination
142:12
extensive
127:12
137:24
120:5,7,9,18,19
equipment89:11
examine73:674:17
extent22:693:13
FGR95:9,996:16
123:10
124:6,12
97:14 107:14
124:17
extreme32:2
96:19
121:24
124:22
134:7
110:17
122:24
examined
142:12
e-mail 97:17
141:1
122:3,16
123:5,6
136:5,9
127:12
128:21
examining
57:8
-
123:11,17,18,21
emits
70:5
136:19,24
137:1,3
example
28:17
124:13,19,19,21
emphasis
71:1
errors
47:22
94:16
36:15 62:6,11
F
11:16
100:20
124:24
125:4,5,7,9
emphasize
27:13
escape
105:9
63:14
65:14
73:12
face
47:9
105:12
126:1,2,6
92:2
essence50:14
79:8,981:1688:11
112:9
fightingl36:3
emphasized
91:21
essentially
33:14
88:23
facilities
56:23
57:4
file 7:22
9:4
14:11
6
Keefe
Reporting
Company
14:1426:1985:17
102:4
34:2243:2148:2,5
24:1727:431:6
88:295:4107:13
87:20
140:13
flexible
81:14
82:1
49:4 51:23
55:12
35:23
38:23
39:13
134:16
filed2:126:3
10:11
flippant2l:l0
57:7
59:17
68:5
41:642:1
58:3
giving47:2
103:23
12:12
16:20
54:14
flue
62:20
75:22
76:11
77:3,3
66:9,11
92:17
glare
14:6,8
87:6
94:12
98:11
focus
70:22
133:21
77:11
79:7
80:3
116:22
126:8
glass
95:8
130:23
98:13,23
109:16
focused
70:22
101:7
81:13
84:19
88:5
130:24
131:7
go
23:2
27:9,12
29:1
109:22
118:1
folks 43:5
87:8
88:24
91:18
100:2
future
12:15
19:24
51:17,20,21
56:4,5
129:4
130:9,19
100:7
100:11,18,23
20:7,17
31:3 32:9
57:11
58:22
66:16
140:14
follow
4:8 15:24
103:3
104:13
32:11,14
33:6,11
70:14
72:20
85:10
fihing26:10
70:11
39:1
40:19
55:10
106:22
107:8,9
37:4,9,11
104:6
85:14
86:17
87:1
89:23
91:12,15
60:9 83:17
90:22
109:11
113:19
105:17
92:7
94:1
96:5
139:17
107:24
115:14,19
121:6
101:16,23
103:7
filings
132:19
following2:1
38:18
122:8
123:8
124:6
103:18
106:17
140:19
42:1763:3,8
67:18
124:10125:9
gas43:1044:348:7
110:1
116:23
final2l:12
34:7
83:7
102:1
109:12
126:12
128:4
48:7,22,2449:7,10
125:2
126:17
44:12
72:9
121:11
118:8
125:22
130:1
135:13,20
49:14,15,19,21,23
130:5
132:24
139:8
139:13
141:6
49:24
50:5,10,12
138:11
139:5,11
finalize
13:5
19:8
FOLLOWS
11:11
front43:746:14
50:16
51:3,7,19
goes
15:4
16:10
finalized20:1
21:5
85:13
61:2
130:12
52:9,13,19,21
53:1
going
15:21
16:9
finally
5:24
7:1
53:7
followup
107:2
fuel38:1448:22,23
53:17
62:8,20
26:18
53:10
55:23
140:11
foods
105:24
55:13,18
56:5
69:4
64:11
65:15
69:4,6
62:12
66:4
81:12
financial95:14
forget45:10
69:5,7,1870:5,8
69:7,12,18,2070:5
88:12
91:5 109:21
find23:249:2450:2
forgetting
106:23
71:8,12,16,20,21
70:6,8,15,17,18,22
117:3 123:22
65:1
69:22
112:24
forgive
11:12
81:2
82:7,9
114:2
70:23
71:1,2,2,3,4
132:9,24
137:14
findings
28:11
129:18
114:23
123:13
71:5,8,12,15,20,21
139:15
140:6
fine 11:7
27:17
forgot
41:10
124:1,14
126:20
75:22
80:8,8,20
gone
96:3
42:1543:1570:2
forrn2l:8
127:10
81:282:5,7,988:2
good2:34:245:10
78:10
83:5
87:13
formally7:24
8:17
fuels56:468:15,15
88:20,21
89:797:1
5:23
9:18
10:20
101:22
102:17
38:4
70:15
80:19
81:1,2
97:1
114:3,4,4,5,5
11:1
14:1
15:8,16
118:6
130:4
former
133:18
81:7,1082:6
117:12
118:22,23
35:22
42:2446:22
134:20
135:15
formulating
120:19
114:12
120:10
118:23
119:8,8,8
67:5
83:11
91:20
finish
89:19
forth72:10
127:3
124:1,2,7,10,11
93:15
94:3
123:5
finishing
88:10
Forty
111:8
full
55:11
58:20
126:24
127:1,1,3,3
128:3
fire 71:2,3,4,5
75:21
forum
102:15
124:5
126:15
gasses
49:19
53:2
governed
3:6
76:9
forward88:1292:3
136:17
81:7127:5,8
governmentl05:2
fired48:2462:8
105:5
110:1
fully
19:20
26:15
Gateway
131:20
137:21
64:11
65:15
69:12
found3l:2447:17
48:14
66:21
gave66:19
Government’s
69:20
70:22
71:1,2
47:21,22
64:19,20
function38:7
general
29:14
47:18
131:21
71:2
80:20
82:5
132:22
104:17
52:12
67:7
82:16
grade
76:5
117:12
132:5
foundation
32:23
funds
133:19
87:21
93:20
grades
135:19
firing
53:1,1,2
68:14
135:18
Funk
102:6,9,11,16
115:19
grandparents
103:9
69:17
127:2,5,11
four39:1942:11,11
102:19,20
106:9
generalized55:22
138:6
firm
46:2
58:6
94:24
96:6,9
106:14
138:6
generally
52:5
62:10
Granite
48:8
94:10
first2:16
11:10
96:13,14,16
Funk’s
129:15
62:12,1578:8
97:11
111:5
134:6
12:22
23:4
48:18
113:24
120:3
furnace
49:8,11
95:12
122:13
134:22
135:5
54:9
57:23
59:15
fourth
96:20
50:11,12
51:13
126:6
136:12
62:766:1781:18
four-year-oldlO3:1
88:1593:1197:1
generate49:255:15
great4l:1667:15
85:12
87:24
93:3
frankly
86:6
113:7
114:3
Generation
13:13
96:12
99:4,6
100:22
free
11:21
14:19
118:22
119:8
14:13
15:2,4
greater
122:2
102:13
103:5,16
95:8
106:17
140:4
120:3
126:24
Generations
7:13
134:19
117:21
129:8
Friday6:49:3
10:17
127:3
gentlemen8s:7
grewl03:4135:5
firsthand
135:9
14:21
48:2
51:19
furnaces43:11,23
gets 106:1
grounds47:18
fit83:1
52:22
98:10
49:1,22,2351:4,13 getting47:978:5
group4:17
12:20
fittingll2:15
121:15
51:1452:1679:2
133:13
39:2340:18
five3l:16
34:17
froml:82:7,21
3:4
88:9,10,14,22
Gina9:19 130:10,19
102:17,23
129:3
42:12,1948:20
3:174:2,4,16,17
100:19101:8,16
give43:348:11
131:18,23
54:10
55:11
67:11
4:19
5:2,2,17
6:1,2
107:15
113:5,13
64:21,22
137:23
grouping62:7
67:13
115:3
8:9,10,11
11:3
113:22
119:14,19
given
10:17
20:15
groups39:21
40:21
five’s28:10
13:1724:15,17
121:3
130:23
22:1123:1524:3
growinglo3:7
flexibility8l:16
26:2
28:19
30:6
further
10:22
15:3
33:22
40:9
72:12
growth
37:6
7
Keefe
Reporting
Company
guarantee
68:9
89:9
87:20
90:18
98:5
26:4,20
27:1,3
136:16
64:13
73:23,23
89:13
98:20
99:2 100:2
35:24
36:1,3,12,24
idled
88:15
99:12
guaranteed
107:12
100:16
102:13,13
37:12,16,22
38:15
IEPA59:2,20
included
12:19 13:2
guarantees
68:5,19
107:19
109:24
38:20,22
45:24,24
134:11
135:3
13:9
23:21
30:20
68:21
95:13
114:19
116:17,20
46:10,1566:13,14
IERG4:17,18
15:12
30:24
31:2,23
110:17
117:21
118:1,17
66:15,17
67:6,15
18:13 59:2,13
32:15
36:22,23
guess
13:17
20:23
119:3
120:21
67:20,24
68:20
63:20
37:20
48:3
65:23
21:6,24,24
22:11
128:5
129:13,23
69:1,8,14,2470:4
IERG’s4:21
59:3,3
69:3,7
70:11
73:10
24:559:14,1461:4
132:2,15,17,19
70:19 71:4,6,11,18 ignition6s:15
95:8 114:3
123:14
61:16,2070:7
139:24
140:6,8,20
72:273:874:2,7
ILL 1:9
includes29:7
88:10
85:24
89:18
142:7,14
74:11,2075:3
Illinois
1:1,20,222:4
127:4
116:12
hearings3:64:7
76:21
77:13
78:13
2:8,11
3:17 4:16
including4:9
68:15
guidance
39:24
40:4
64:10
91:7
107:6
80:14
82:2,18
83:2
9:4
12:23
18:18
127:3
139:6
guidelines40:10
140:12
141:3
83:5,9,11,2484:4
20:20
22:19
23:7
140:11
guy 76:13
heart
135:12
84:21,24
85:4,14
23:13,15
27:18
inconsistencies
heat49:5,21
118:2
85:16,23,24
86:4,5
28:20
33:17
40:17
94:16
--
heaters
71:9,20
79:1
86:7,8,24
87:2,14
47:5
57:2,4
59:12
incorporate
22:20
Hamlin
1:19
142:4
80:18,21
81:3
90:691:2,4,21
79:3,1680:7,17
incorporated36:19
hand
28:8
35:24
heating
127:11
92:6 100:6,14
94:5
97:5
98:3
42:20
45:14
142:17
held
142:7
101:4 107:23
104:19
105:22
increase
72:18
78:1
hands44:24
140:2
help
7:5,19
43:13
109:21
110:6
130:22
131:22
increased47:16
happen
28:6
88:11
92:18
121:18,23
117:20
126:14,15
133:6,8,18
134:13
53:9
134:17
101:2
135:11
136:2,8,9
126:18
127:15
136:1
137:15,16
136:22
happened
47:24
136:10,11
Hojin 10:4
138:6,9
142:9,20
increasingly
52:15
58:19
helped
64:18
hold
24:2
139:19
Illinois’s
30:20
Indiana
27:18
happens
28:8
helpful
7:3
holding
2:15
105:16
illness
104:13
indicate
30:6
happy
90:19
97:20
her
2:24
3:24
7:5
132:1,14
illustrate
92:21
indicated
7:14,21
101:4
46:3
105:24
106:1
Holland28:1,12,16
immediate2:22
10:911:225:4
hard
47:10
69:24
106:2
138:5
28:19
30:22
impact
71:12 103:3
29:7
32:17
68:3
hardwired
19:15
hereunto
142:16
home
141:9
104:14
124:11
84:21
85:17
86:12
hate
130:14
herewith
142:15
honestly
102:14
impacted
15:15
18:1
86:17
95:1
129:17
having
12:7 47:10
high
28:18
65:10,13
Hoopta
10:4
impacts
15:17
135:2
140:5
48:1358:15
65:1372:1775:16
hopel2:721:24
105:14
indicatesl07:4
104:24
112:22
79:18
135:15
22:6
104:5 105:16
implement36:10
indicating
31:9
129:14
137:11
137:6
105:17
132:15
95:5
indication
21:11
Hawaii
103:13
higher
3
1:22 32:3
133:5 137:2
implementation
83:16
hazardous
132:6
32:11 70:9,16
hoping
116:23
19:10 27:17
35:16
indirect72:17
head
92:20
111:7
72:24
76:9
77:16
hot 103:17
133:16
individual
80:4
120:12
highlighted
22:4
hotter
31:21
implemented
19:24
indoors
135:24
health
103:4
104:12
highly
38:8
hours
67:10
103:2
128:18
industrial
36:15
104:18,20
105:7,7
him3:287:690:3
109:18
importance
135:8
54:11
59:10
60:11
105:14,20
133:19
116:1
126:16
housekeeping6:14
important33:2,12
61:10
69:3,14,16
133:23
138:4,7
himself46:11
7:8
73:5
69:17
70:21
80:17
healthier
105:21
hired
133:17
humoring
102:12
impossible
88:3
80:21,23
82:5
95:5
healthy
105:24
Hirner
15:9,10,11
hundreds
76:8
impress48:10
industries
12:15
hear
24:23
81:13
15:20,21
20:5
79:16
improve
29:12
13:8
80:4,12
87:8
93:6
130:4
21:20
31:8
40:16
husband
103:14
36:10
133:11
134:1
heard
80:3 84:1
40:17,1741:5
54:5
hydrocarbons
127:6
improved
7:22
18:5
139:1
110:6
54:6,12,16,19
127:9
29:4
industry
104:12,22
hearing
1:12 2:4,5
55:10
56:11,15,22
hydrogen
124:4,8,9
improvement29:19
105:19
118:24
2:13,16,163:9,17
57:3,10,11,12
127:6
improvements
information3:7
3:22
4:6,6,20
6:16
58:24
60:9,23
61:3
17:11
10:14
25:5,9,12,19
7:1,10,11,14
8:22
61:965:8,14,19,22
I
improves33:3
26:1,11,11,13,17
8:24
10:12,14
12:7
66:8,1079:8
IC! 58:7
inadequate47:21
32:22
35:18,19
17:16
21:15 25:3
historical48:7
idea
81:19
inappropriate79:17
38:6 40:13
43:23
26:7,10,14
41:21
historically5l:16
identified
80:16
inception
131:23
44:10,18
47:21
47:5,10,14,17
49:6
52:12
88:7
120:1
81:8 94:17
134:24
inches
130:3
48:2,6,11,15,16
54:15
67:2
70:2
Hodge4:18,21
5:1
identify
78:19
80:2
incinerator
132:6
49:4,13,17
51:18
77:483:2084:1,6
5:21,226:624:19
102:17
include6:21
13:4
57:758:2359:24
84:9,11
86:10,13
24:20
25:1,11,15
idle88:14,15
136:13
23:839:2040:11
61:18
63:16 64:9
8
Keefe
Reporting
Company
64:13,16,1766:3
introductionll:20
78:1780:1781:7
78:1882:2087:24
latest3l:22
68:10,18
69:21
42:8
46:18
48:21
82:4
83:4
85:11
89:10
91:10,16,16
latitude
74:16
72:4
74:9
79:13
90:8
91:3
86:6
87:7,21
88:13
98:18
99:5,23
law
137:19
82:10
92:17
94:8
introductions
85:15
88:23 89:22
90:9
101:1,2
103:24
lead
2:23
95:20
97:15
99:11
introductory
93:20
90:14
99:16,24
104:23
105:24
leads
139:5
101:3
113:19
inventories
36:20
100:9
101:20
106:2,5,24
107:23
learned
103:3
114:6,15,18,23
37:5
102:24 105:23
109:15
110:1
least
6:23 12:11
115:7,9,10,11,17
inventory
36:23
106:5
108:6
110:7
111:4
114:17
13:17
15:4
17:16
115:18
116:6,9
37:3,10,21
38:9
111:7,22
113:4
115:23
116:2
20:3
29:24 43:3,4
123:8
125:18
involve69:395:6
115:24116:3
120:24132:11
52:262:1497:23
140:9
involved
78:5
119:3
118:3,12
121:12
133:23
134:1
123:5
infrastructure
127:7,7
134:4
124:16,24
125:20
136:4,6
140:17
leave
53:8,8
136:22
involvement
78:5
126:15
128:1,2,6,6
knowledge
95:21
left 2:22,24
106:21
inhalers
135:23
involving
76:23
129:2,21
130:4,8
111:14
114:14
leg 139:2
inherent
50:6
126:24
130:22
130:18
135:16
119:12,18,21
legal 9:22
inhouse73:21
issue7:16
13:8
22:4
138:16
known3:3
33:4
lengthy92:4
initial
67:1
72:9
89:24
110:10
Justice
131:22
knows
111:11
less
31:15
52:6,6
initially
91:13
140:7
Koerber
3:19
10:1
54:22
62:16,17
injection
63:11
issues
9:14
13:19,22
11:4,10
17:23
27:9
109:17
input49:6
50:10
16:6 90:15
91:24
K79:8
27:12,13
28:24
lesser 81:22
78:7
102:23
108:22
Kaleel3:19
9:23
29:6,17,2330:5,10
let
102:24
inspect
116:16
116:13
134:4
11:3,9 12:3,5
14:2
30: 12,16,23
31:6
Letter
21:8
inspected
115:20
139:8,16
141:5
14:4
15:19
16:18
31:11,19
32:8,17
letting
106:7,16
inspection
117:1
18:14,21
20:9,23
33:7,19
34:5,10,14
let’s 73:11
80:17
install
122:24
21:24 23:2,6
24:5
34:23
35:4,10,13
87:15,15
139:11
136:14137:3
J11:9
24:1825:1,10,13
35:2336:4,6,17
level20:1352:13
installation
73:13
James
3:20
10:2
25:17
26:6,23
27:4
37:3,15,17
38:2,21
59:10
81:22
96:18
73:19
123:11
11:9
47:1
94:12
30:5
49:13,18
61:5
38:24
39:2,4,7,17
121:11
125:17
127:13
January3:189:3
61:7,1663:5,10
39:1940:2,2441:7
levels
16:1532:11
installations
95:10
10:10
25:9
26:21
66:5,11 78:14,15
42:2
33:6,15
57:15,18
95:11,24
123:12
26:24
28:641:13
80:22
82:8,20
K’s27:17
58:12,1860:16,22
128:12
48:4,6
94:13
98:24 Kaskaskia
131:18
61:12
62:5,21
78:6
installed
76:6
113:2
100:20
108:15
Katherine
36:3
78:10
107:13
122:23
123:3
109:1 130:10,20
45:24
66:15
L
1:19
142:4
125:5
126:23
Jefferson
142:2,5
Kathy
127:22
labored
103:8,18
License
1:20
142:20
installing
125:3
jeopardize
105:19
131:16
lacked97:17
life 103:5
104:14
128:17
136:19,23
job
79:14,22
104:21
Keefe
1:21
LADCO
27:16
29:2
135:6
138:13
installs
110:18
jobs
104:18
135:8
keep6:15
106:1
36:4,13
40:21
69:6
lightl6:1
112:9
instance
133:17
136:24
137:1
134:15
laid
136:18
like
5:8
6:12,13,23
instrumentation
John
70:13
104:4
Kennedy
104:4
Lake
10:1 27:24
8:8 10:5,13
12:3
122:14,17,18
140:17
key
28:11 96:4
34:20
12:17
14:10,11,14
intend80:11
Johnson3:1
67:10
kick22:8
language
13:2,4,9
14:15
15:12
20:10
intended3:12,23
125:17
kidsl35:23
16:523:399:14
20:2022:1527:8
16:11,24
17:10
Joliet
7:13 8:6
kiLn
132:8
laptop
101:19
27:10
28:16
31:11
18:5
23:10
55:22
Journal
138:12,12
kind
15:21
40:23
large
64:22
65:2
41:842:1145:6
91:13
judgment
66:6
74:3
102:24
105:5
75:20
108:13
48:10,15,18,18
intends23:14
87:11
106:7109:24
115:6
63:1764:3
66:24
intent5:18
June2:14
142:21
kindly4l:12
largely
134:24
70:1
73:22
76:18
intention
4:10
just
2:20
6:14
7:7
kinds
21:15
60:2
largest
134:22
86:1
87:6,22
90:3
114:11
10:5
13:3
14:15
knew
59:22
135:9
Larry
66:24
136:13
90:6
95:3 96:10
interest
92:2 95:14
16:2,2
18:17,21,23
know
7:5
19:5,12,13
last 7:10
10:16
19:2
97:8
100:1
102:8
131:7
20:5
21:10,11,20
19:16
20:20
21:18
22:15
30:19
34:16
103:10
107:1
interestsl04:11
22:15
24:2036:1
22:1223:1728:8
47:5,1448:949:6
likely3l:1552:15
interuet97:16
36:2438:1642:15
29:2030:1435:13
52:498:10
100:2
78:3
interrogated 142:11
43:15
47:4,8,13
39:2,5
42:13
48:13
114:18
125:15
limit5l:1062:4
interrupt
44:13
48:21
54:7,12 55:7
58:1 60:5,21
62:21
135:3
138:13
63:15,19
78:2
54:17
102:3
55:22 58:4,19
60:9
64:15
66:4
67:1
Lastly
105:23
79:15,18,23
82:5,7
introduce2:20
62:6,2463:6,16
70:2
73:10 74:14
late87:691:12,15
82:12,16
120:23
102:16
64:15,18,19,21
75:9,1276:16,18
lately57:6
135:23
introduced
11:22,24
67:6,23
72:3,22,22
77:21,24
78:4,5,18
later
19:18
limitations
115:4
9
Keefe
Reporting
Company
limited
68:9
118:23
77:17
96:21
135:4
136:1
measured
33:6,15
Mike
10:1
17:23
120:2
133:5
123:17
137:11
137:10,12,13
measurements
military
103:14
limits
19:21
59:3,3
138:22
140:24
141:4
30:17
miii
119:7
135:6
59:12
60:13,19
lowered
30:6
malfunction
133:4
measuresl8:1031:1
million49:16,16
61:11,14
64:9
77:8
Low-N0x25:6
management
122:11
31:1
36:8,21
50:3,13
51:5,24,24
77:17,17,19,22,22
62:20
65:18
68:16
manager
9:23
mechanical
56:19
52:18
63:22
96:18
79:12,16
80:20,24
73:11
75:21
94:23
104:22
107:8
104:11,19
105:22
81:1,9
97:5
137:11
95:2
112:21
115:5
mandatory
55:18
Medicine 138:12
124:4,5
line
49:15
93:4,11
119:9
121:10,22
manner
24:10
meet
16:14
21:23
millions
137:23
136:11
140:3
121:24
122:5,13
manual
74:8,22
28:13
36:5
39:10
mills
132:6
link38:5
74:24
75:1
122:15
123:2,4,16
manufacturers
40:10,12
63:19
minimize44:21
links
38:7
124:16,18,21
95:19
93:19
104:8,24
minute
63:1
list
8:14
59:2
85:19
lunch
67:14
many
3:3
50:20
126:2
134:20
minutes
66:21
67:20
105:14
140:20,21
lung
135:16,20
64:12
86:5
104:21
meeting22:21
62:21
mislabeiing44:22
listed
62:7,9
141:2
119:7
140:17
116:21
missed
104:13
listen
137:14,17
March
30:5
98:13
melting
130:23
Missouri
132:13
literature
61:21,24
made
2:1
11:3
19:3
98:14,17
99:5
member2:22,23,24
142:1,5
62:679:4
22:925:4,15,17
139:20
102:6,22
131:18
mistake66:12
67:12
little7:19,2032:5
26:6,21
35:6
38:18
mark8l:12
131:22
mistaken
129:18
37:23
47:8
79:20
39:23
42:17
45:10
marked
41:22
84:13
members
3:11
15:13
misunderstanding
102:12,14
47:20
51:15
63:3,8
86:22
85:20
131:15
44:21
live
138:3,6
67:18
83:7
84:19
market88:17
89:3
141:7
mix
114:2,23
lived
103:11,13
91:9
102:1
106:11
massive
132:8
memory
62:23
63:5
MMBtu
117:8
living
132:2,11
118:8
123:20
matches67:22
128:4
mobile37:6,2438:3
load
127:11
125:22
139:13
materials
6:1,2
mention
129:2
38:9,11
local
102:22,23
Madison
135:18
10:16
98:12
mentioned
12:23
model
27:23
29:3
132:16
134:1
142:8
107:18
109:9
18:23
98:12
30:20
31:13
32:14
135:22
main68:12
mathematical33:8
115:24
131:9
32:24
33:4,8,12,19
locally
102:23
mainly
78:5
matter
1:7
6:15
12:7
merely
129:18
37:1,11
38:1,11
locating
69:24
maintain
136:24
48:21
94:6
105:14
merits
3:14
9:12
39:8,10
location
27:24
30:1
maintained
23:15
116:22
117:14,21
met
40:21
modeling
31:2,23
Iong6:16
19:24
maintenance
13:1
125:16
132:2
meteorology3l:13
32:20
33:3,13,16
81:22
87:10
16:9
17:18
44:11
142:9
31:14,21,24
32:2
34:23
35:2
36:6
105:13
44:19
53:9
89:7,12
matters
3:21
7:8
32:10,12
33:20,22
39:21,23
40:6,21
longer72:19
111:23
116:21
139:6
methodology74:3,6
40:21
look
16:5
24:8
29:9
Maji
10:4
maximum5l:14
74:12
models
32:10
36:13
35:1748:12,13
major78:22
may2:124:145:19
Metro
17:21
19:5
modification54:21
53:3
57:5
59:6
make
6:20,21
7:2,19
6:16
8:3
9:9
11:23
104:8
132:3
niom
102:21
62:10
66:21
75:10
11:4,14,24
14:18
15:24
40:19
51:15
134:19,22
135:21
moment2:20
63:6
75:18
78:23
79:9
18:18
26:4
31:15
55:13
56:1,2,4,5
metropolitan29:21
79:9
83:4
85:11
80:17
81:3
88:7
35:9
46:11,12
57:10,16
61:18
38:10
89:22
118:3,5,12
looked77:22
72:16,1775:11
64:9,1073:21,21
Michael3:19
11:10
125:20
looking
7:9
53:17
76:21
85:15
87:22
77:24
78:1
83:4
Michigan
10:1
Monday
4:4
139:20
56:21
62:18
63:16
89:5
105:24
106:1
88:6
89:11
91:24
27:18,2428:2,2,4
monitor
5:6
75:13
77:11
108:7
110:24
130:11
99:13,17
100:12
28:5,12,16
30:22
monitoring27:23
looks
12:3
27:8
45:6
136:2
102:16
118:3
34:20
41:4,9,13
29:24
30:17
32:21
63:14,16
maker
135:7
121:7,9
122:16,16
microphone47:8
33:10,21
34:6
35:8
lost
101:10
104:21
makes20:13
71:24
126:16
129:24
130:2,13
39:9
40:4,5,8
133:3
makeup
70:18
139:5
140:12,24
mid
6:10
103:17
134:17
1ot58:6
making2:9,12,16,24
maybel6:1958:1
middle93:19
monthl25:15
loud
92:1
3:69:5
12:9
16:22
61:4
62:21
75:7,16
midwest7:12
13:13
Moore2:23
Louis
29:21
30:15
21:17
22:7
23:17
93:19
119:22
14:12
15:2,4
39:21
more
7:20
16:7
39:2
134:19
24:6,726:1145:6
130:11
midwestern39:23
29:18,1835:7,8
135:16,16,21
47:5
57:19
84:5
mean2l:9,10,15
might43:8,13
59:17
39:14
49:19
57:19
1ow55:1459:7
88:9,14
105:1,11
22:336:1553:24
75:2481:2096:7
64:8,8,1667:6
65:11,1368:15
105:18
106:6
59:1562:2463:6
101:2
102:18
68:1870:571:1
76:4
77:24
101:19
107:7
110:3
63:24
65:12
66:2
111:16
124:19
76:13
78:3
81:14
127:8
113:20
130:20
73:17
75:22
90:12
129:4
130:14
81:20
83:9
88:2
lower
30:10
32:9
132:4,20
133:9,11
119:24
125:8
133:20,21
136:7
97:15
104:5
55:15
56:5,5
64:9
133:16
134:2,10
means55:18
137:18
105:15
112:24,24
10
Keefe
Reporting
Company
117:24
125:4
NASA
125:17
36:22
59:13
60:761:6
24:2025:127:1
135:10,10
136:10
Nationall3l:19
non-EGUs22:20,21
62:2,984:15
121:6
36:2437:1238:15
137:8,24
138:24
natural62:8
65:15
23:8,11,19.20
121:7,8,9
134:23
40:15
41:5
47:12
morning2:3
6:10
69:19
70:6,14,17
24:11
numerous
16:21
61:3
66:8
68:20
9:18
27:531:7
70:23
71:3,4,5
normal32:1
95:4
70:19,19
71:672:2
46:22
92:9
94:3
80:8
81:2
97:1
North
1:21
nurses
135:22
73:8
74:2,11,20
131:4
114:4,5
118:23
Northeastern
28:19
75:3
77:13
83:2
most
11:3,4
17:15
119:8
127:1
Notarial
142:17
86:7 87:14,17
94:2
33:21
35:17,18
132:14
Notary 142:4,20
Obama
138:19
108:10
113:15
39:9
52:15 54:22
nature
20:24
115:2
note 3:10
9:2 10:5
Obama’s
136:20
114:13
116:14
54:24
58:9 70:22
nearly45:7
65:10
10:1313:3,624:5
object
109:21
117:16
120:4
71:2,3,4,5,7
74:23
67:9
105:21
46:12 62:13
85:20
objection
8:19
41:19
121:12
130:6
75:1,20
79:23
necessarily59:23
noted8:12
15:525:3
45:2346:284:4,11
old 16:12
111:4
80:12 81:5,18
necessary
55:13
25:19
39:20
94:19
86:11,13
110:13
136:7
95:20
101:10
92:5
95:24
99:12
96:22
objections
84:18
omission
114:1
125:18
130:12,14
122:23
notes
133:2
86:16
once
11:542:145:5
132:19
135:6
need 6:8,15
16:15
nothing39:13
objective77:7,8
52:8
89:19
104:4
mostly
138:3
20:14
23:17
26:12
notice
130:9,19
objects
10:6
140:1,6,6
141:10
mother
105:23
43:21
55:24
62:23
Noting
84:18
obligation
23:13
one
6:23
7:7
9:20
135:13
138:5
63:5
66:21
81:21
November
59:1
obligations
22:22
12:11,23
15:7
Mothers
102:23
86:5
101:20
105:6
NOx
16:11,14,24
observed
33:10,23
17:16
18:9
27:14
motion
8:3 9:5,5,7
117:12
118:5
18:6,7,19
19:20,23
obtain
100:23 125:5
27:23
28:12
29:8
9:10,12
14:15,19
122:11
136:22
20:6,6,17,21,21
125:7,8
30:1 32:24
33:3
15:1,2,4,13
16:2
needed36:577:1
21:8,17
22:22
obtained
34:19
39:18 40:3
43:7,21
41:1943:245:10
78:891:18
23:10,15,2429:4
97:16109:7115:9
43:2244:1,9,12,14
46:3
83:20,23
84:1
needs
104:16
29:10,12,15
30:20
115:14,18
44:14,17
47:18
86:11130:20,23
Neither
8:22
41:21
30:23
36:5,20
49:2
obvious
44:15
52:7,8,10
54:9
139:22,22
134:11
51:653:1,4,4,10
obviouslyl8:21
58:6,1564:10
motivated
103:1
never
18:6 103:19
53:15 55:4,6,9,12
19:1,18
22:1
63:22
65:20,21,23
66:2
motivation
104:3
104:23
137:18
55:12,15,19
61:12
88:1 89:10
77:11
86:6
88:23
move8:541:8,17
nevertheLess40:12
70:5,1675:4,14
October
2:17 77:3
89:5
90:5,991:7
42:1145:1386:1
new
18:2,14,15,20
76:878:2179:16
offl2:2266:17
93:296:1104:12
106:8
130:1
18:22
19:7,13,14
95:5 96:17,21
97:4
101:23
103:6
106:2
107:18
moved8:1845:18
19:18 20:7,8
30:10
97:7,9,13
98:11
106:21
111:7
111:22
118:12
86:8
103:15,19
30:12
35:3,12
105:4,14
107:13
120:11 136:18
122:4
125:15,20
moving92:3
66:20
78:10
125:3
109:2,5
111:17
139:5,11,15
140:6
126:15
129:16
much
10:17
15:10
128:8,10,10,12
112:5,23
113:20
offer3:23
4:18
5:4
130:16
131:6
32:3
35:20
38:7
132:7
133:1
120:5,5,7
121:13
6:12,13,19,22,23
138:11,15
42:24
45:16
50:1
138:12,23
122:1,2
124:1,5,6
8:3,5 27:10
42:7
ones43:5,21
113:1
51:17
52:2,2
55:7
news 103:24
124:11,14,18
46:9,18
57:13
one’s
103:4
104:14
67:16
68:1 72:24
next6:11
35:16
125:5
66:24
84:22
91:6
one-quarter28:18
78:1685:1687:14
41:1143:8,1844:1
no-bearingll8:2
91:10,13
129:14
ongoingl2:895:23
106:7,14
125:4
44:946:5
110:14
number2:97:13,13
129:19,19,24
only8:13
18:751:5
132:4133:6,13
NG93:12
7:168:5,6,20
131:11
80:688:2095:19
135:7,10
136:5
nice
139:1
27:14,22
28:11,15
offered
3:15 59:2,2
109:17
121:5
mnltiple58:16
night48:2,9
51:19
30:24 32:19,20
83:21
94:11
133:1
136:9
68:15,15
ninel2l:22
34:1436:18,20
129:18
on-road38:9
multi-fuel95:2
nitro29:10
38:13
41:18,22
offering
131:8
open
82:19
139:19
112:19
118:2,18
nitrogen
1:72:6
42:13
43:1,8,17,19
offers67:4
opening
13:23
118:20
127:14
17:948:23
55:14
44:14,14
50:19
office
140:2,15
operate88:6,1789:1
must 40:9
117:14
56:5
55:8
57:22
58:5
141:1
104:17
114:12
135:23
140:19
none
27:7
61:23
62:9,19
officer2:64:667:3
119:5
122:24
myself
59:20
74:18
non-attainer
33:18
63:17,20
73:1
84:2
109:24 140:8,20
operated
88:8,24
84:13
86:10,18,23
offices
141:9
operating
88:5,8,12
17:2,11,12
19:4,8
93:3 95:18
108:22
often
54:21 122:16
88:19
89:2
96:4,8
name
2:5
9:19
43:8
19:17
41:4
78:20
120:2,3
132:11
122:17
138:7
122:15
134:15
47:1
92:10
94:3
78:23
134:9
135:1
140:22
141:1
Oh
69:16
103:18
operation
97:3
102:20
131:16
non-catalytic
95:11
numbers
7:11
8:1,24
Ohio
27:18
138:16
opinion
47:19
55:5,8
named
135:17
117:6
43:4
45:20,20
oil 81:2
137:6
55:8,20
64:24
78:6
namely28:1
non-EGU23:24
51:11 57:14
59:11
Okay22:14
24:14
108:1 110:12
11
Keefe Reporting
Company
115:8
126:1,3
90:16
paper28:7
70:11
53:5,11
63:21
136:16,17
opportunity
6:19,21
oven
43:10
44:3
paragraph
23:4
72:12,12
76:8
plants
79:2 132:5,5
6:22
9:1146:4
48:7,7,22,2449:7
54:20
55:11
93:2,3
96:18
117:8
124:4
134:15
47:2 48:12
87:8
49:10,14,15,19,19
93:4
122:10
124:5
138:1
play
32:6
135:24,24
97:19
104:10
49:21,23,24
50:5
parameters
31:20
perceive
79:14
played
31:13
116:16
129:13
50:10,15,1551:3
parcel93:17
percent28:1836:7
please3:10
6:14
7:1
137:2
51:19
52:9,13,18
parents
138:5
49:7
50:11,12
93:5
7:4
11:20
15:20
oppose
134:12
135:3
52:19,19,21
53:2
part5:18
6:5
21:3
93:5,7,8,12,12
20:5
27:12
29:1
opposed
14:18
53:17 80:7
88:2,20
24:1,4,7
39:21
114:3,3,4,5,5
38:16
39:24
57:11
opposing
133:10
88:21
89:7
97:1
40:6
50:6
58:9
124:9
66:16
85:14
87:1
134:10
114:4,5
118:22
70:22
75:20
81:6
percentages
49:9
92:7
102:9
106:17
opposition
137:3,9
119:8
124:1,2,7,10
85:11
98:12
perform53:7
92:12
110:14
119:16
option8l:17
124:11
126:24
105:18
106:12
94:17
95:22
126:17
130:4
options6l:22
62:11
127:3
108:13
128:11,11
performance6l:21
131:12
63:17
81:8
ovens 88:9,13
partially
136:12
62:18
63:13
64:1
pleased
13:15
order 2:13
3:23
4:6
over
2:18
7:9 33:23
participant
24:18
68:6,21
pleases
93:16
4:7
14:22
31:2
38:7
46:20
50:13
83:12,24
131:20
performed
27:15
plug
37:11
36:10
40:10
42:9
52:4
104:10
140:11
32:14
60:7
98:7
plus
62:20
50:21
90:6
102:4
111:21
114:11
participants4:14
119:9,11,13,18
PM 16:13,16
17:2,5
106:17
140:8
overall2l:3
124:6
6:7
14:4
38:24
performing95:15
17:22
18:16,24
organic
29:10
overlook
90:12
126:13
139:16
perhaps
5:5,5,10
34:2,4,13,18,22
organization 102:18
overlooking
90:24
140:5
142:14
32:546:4,9
51:16
35:2 39:3,10
135:1
129:3
overshot8l:12
participated
140:12
58:1 59:16
61:7
138:23
organizations
38:11
overturn
137:20
particles
27:17
81:4,17,20,20
point
8:16 22:7,8
originals7:13
77:3
own80:1
96:15
particularls:17
82:2392:499:22
24:1736:2237:7
99:14
100:1
100:10
113:20
37:19
56:14
57:18
111:11,12,24
59:8
66:1
67:21
117:11
128:7
62:1463:13,21
123:6
69:2372:2073:1
originally
54:14
owned 100:4
65:2,5 68:22
92:23
period
9:7 139:20
78:12
79:13
83:14
98:14
oxidesl:72:717:10
94:1097:18
140:7,10
87:2188:16
0T63:12
oxidized29:10
128:16
permit90:19134:12
118:10123:20
other
2:21
3:5
4:9
oxygen
63:12
particularly
104:17
permitting
134:4
129:23
131:12
4:14
5:20
6:7 7:4
ozone
16:8,12,17
particulars
92:16
person
6:23
7:5
139:5
11:20
15:7
16:6
17:1,5,14,15,22
particulate
105:14
113:7
128:14
pointed
40: 14 72:14
21:5
30:24
36:21
18:3,15,15
19:2,7
138:13
131:6 133:22
80:4
37:2043:21
56:3
27:17,22
28:1,4,5
particulates
134:21
personal7l:23
pointing79:8
110:8
56:17,17,18,18
28:14,16,18
29:4,9
135:15
personally
117:17
points
27:
14
55:22
57:7
59:24
60:2,7
29:12,21
30:4,6,21
parties
45:7
67:17
117:18
58:16,17
68:8
74:3
61:18 73:4,4,24
31:15,19,20,22
101:24
142:6
persons
140:12
95:3
78:9
81:20
83:12
32:3,16
33:5,14
Partners
10:3
perspective
13:18
poised
137:7
83:24
89:5
91:17
34:19,2235:2
partsl:92:830:7,7
76:12
Policy28:3
91:24
111:16,20
39:21
41:1,9,13
53:11
91:17
124:3
pertain
101:14
pollutants
134:8
112:5
126:9,12
89:8,15
134:21
passing
44:23
petition
17:19
137:8
127:6,9,16
131:6
138:23
past
33:23
88:24
petroleum
36:16,17
pollution
1:1 2:4
132:7,12,16
139:8
patience45:3
37:1,13
71:7
9:24
74:8
94:5
141:3,5
102:10
106:10,16
Philbright8:9,10
103:10
135:11
others
104:22
package
136:20
131:3
phone 141:1
137:18,23
138:9
otherwise
6:18
page
7:18 12:23
pattern
135:7
phrased
23:6
138:13,18
71:16,17
15:23
22:17
23:5
PAUSE
38:17
42:16
physically
88:3
poor
135:14
out 13:7
14:8
28:8
31:16,17
34:17,17
63:2,7
83:6
118:7
picking
93:22
population
78:23
30:140:1444:23
39:19
54:10
55:11
125:21
139:12
pieces48:1566:3
81:4
49:24 53:8,8
68:8
59:5,660:1061:10
pay
103:24
place2:17,18
40:23
portions
87:12
72:14
79:13
80:4
62:772:693:3
pending22:7,12
59:8 76:17
88:20
pose
5:20
54:4 90:3
81:23
92:1
102:14
110:16
113:23
Pennsylvania
138:2
100:3
121:5
140:2
98:1
110:8
111:21
115:3
117:5
people2:21
6:19,22
places95:13
posed3:11
116:23
122:5
118:11
121:22
47:9
58:22
59:20
plan 16:9
17:18
position
85:1
138:11
122:10
140:21
74:3
129:16
19:10
possible7:6
20:14
outage89:11
141:2
132:11
133:24
planned
13:1
21:23
43:5 53:20
outliners80:2
pages
15:2257:12
137:16
planning9:23
38:10
68:872:11
122:11
outreach
80:1
61:12,18,20
per
30:7 43:23
49:16
plans27:17
114:8
125:18
outstanding
13:19
pain
105:10
50:3
51:7 52:1
plant8l:16
132:8
post37:1
84:6
87:20
12
Keefe
Reporting
Company
postedl32:20
25:227:1439:19
22:17,21,2323:8
48:1749:6,13,17
90:1,1098:1
post-combustion
42:6,20
45:15
23:24
74:1
51:8,18
52:21,22
106:22
109:22
54:2456:3
47:13,1648:1,21
programs24:13
53:1656:2060:1
110:14111:12
post-hearing
4:16
49:5,12
50:7,8,19
37:8
38:14,14
72:5,22,23
78:7,17
117:23
118:14
4:19
5:1,16
84:9
50:23
54:3
59:1
progress22:10
82:10
107:17,22
119:23126:22
89:23
139:7,17,19
68:2
72:7
77:3
project
37:4
72:12
113:19
114:6,9,14
127:23
132:23
140:7
83:13,2284:3,19
73:14,17,20
116:6
123:16
questions3:10
4:12
potentially
77:5
85:18
86:2,9,14,21
122:12
provides
109:18
4:13,23
5:5,13,19
pound
96:18
91:9,19,22
93:2
projected
121:1
110:17
137:1
6:1
9:9,13
10:23
pounds
53:5
63:21
94:12
98:6
108:14
projecting32:10
providing
104:18
14:3
15:18,24
117:8
124:5
108:18
110:16
projections
27:23
provision
11:16
16:21
24:17,21
power
132:5
112:14
117:11
33:19
39:8,10
19:10
27:4
28:23
31:6,12
PPM
124:8
118:11
120:20
projects
25:6
95:5,6
prudent
125:4
34:16
35:23
36:2
practical
95:21
129:10,14
95:7,15,17
123:21
public
7:3
17:16
38:23
39:14
41:6
97:12
109:5
pre-filing
10:9
promptly
7:22
85:21
102:7,13,13
42:1,7
46:12
54:2
practice
110:2
primary
31:20
proof
103:20
125:16
128:5
54:8
66:9,11,14,22
precisely
100:12
104:3
proposal
2:12
3:15
131:12
132:14
67:7,22
72:3
83:3
precursor3l:21
principal
92:10
94:4
9:520:4,15,18
134:17
137:21
83:10,13,17,18
precursors29:9
prior26:13
91:7
21:1
22:20
23:7
140:13
142:4,20
86:20
97:21,23
predict
22:2
33:6,14
116:17,20
30:20
48:4
54:14
published
62:2
101:7,8,14,16
prefer
85:2,4
privileged
3:8
82:24
100:17,23
64:12
72:24
106:18,24
107:2
prejudgment
3:13
100:10
106:22
107:8,9,17
pull
47:8
130:2
126:8,9,12,16
preliminarily
43:3
probably
4:22
6:9
107:21
130:21
pulled
122:4
127:16
129:10,20
43:18
69:20
71:1 76:5
139:19,23
purchase
71:16
129:24
132:24
preliminary
45:20
problem
24:13
26:3
propose
7:23
60:15
purpose
12:10
16:3
133:7
139:8
84:15
28:4
112:14
131:5
60:21
16:10,13,22
17:8
140:15,18,23
premise
88:1
problems4l:4
112:9
proposed
16:1,4,10
18:4
22:21
68:12
quick
7:8 9:11
22:16
preparation
141:8
112:11,13,16
21:12
47:15
51:10
94:7
38:16
90:9 107:1
prepare
10:12,17
117:3
53:6,12,21
59:3,12
purposes
12:11
quickly
140:3
72:21
110:9
procedural3:7,21
60:11,13,1961:10
17:1655:465:9
quitel6:1820:9,23
prepared42:774:2
9:14
11:15,17
61:11,1566:7
99:13
101:7
24:24
51:17
82:17
91:1498:14102:7
139:6,16140:23
77:17,1978:10
112:23128:7
quote7:22
125:14
131:11
procedure4o:5,8
80:13,20,24
81:1
pursuant28:2
142:6
141:5
100:10
82:5
96:14,19
97:5
pursue
82:24
___iL
preparing67:21
procedures9:13
117:13
123:10
putlO4:10133:9
RACT16:11,24
77:16
proceed
4:13
5:12
132:3
137:20
136:18
17:4
18:6,7,19
present
2:21
17:18
11:3
15:20
45:1
proposes
61:4
plEtting
35:15
19:12,14,15,17,21
48:15
97:20
90:7
97:24
102:10
proposing
19:21
19:23 20:6,7,17,21
116:17
117:20
131:12
137:10
123:17
124:23
20:21
21:8,17
presented
47:14
proceeding
2:6
3:5
133:8
137:17
qualifies
126:6
30:20,23
36:20
123:15
3:13
5:6
41:18
protect95:16
quality7:17
9:23
55:4,6,9,12,19
president
10:2
43:2
44:14
106:13
137:21
138:3
17:11
18:5
27:15
56:7,8
60:11
61:10
131:16
136:20
proceedings2:1
9:8
protecting
137:15
27:22
29:3,5,16,19
75:4,1476:11,14
138:19
38:17,1842:16,17
Protection2:114:3
31:332:9,1133:9
76:2380:1982:12
presumably
136:21
63:2,3,7,8
67:18
9:4,20
33:11
34:2
35:17
82:19
97:5
98:15
presume7l:1475:1
83:6,7
102:1,5
protective
138:24
35:17
36:11
37:4
126:2,2,6
presuming2l:2
118:7,8
125:21,22
protocol
33:3
35:15
37:11
39:9
103:3
raise
139:9
141:5
pretty55:658:9
139:12,13
proven79:5 112:24
103:24
104:9,14
range
57:14,14,20
65:3
104:15
process
18:22
78:18
126:5
105:19
131:21
57:22
58:14,20
118:23
79:1,24
80:1,1,3
Proverb
105:9
132:10,14
133:24
59:4,4,13
61:4,12
preveut2l:23
80:18,21
81:3,7
provide6:19
19:9
134:20
135:14,19
63:23
65:11
70:15
previous
122:9
140:16
27:19
57:1
61:20
quantify37:8
72:11
73:4 75:17
128:5
processors
82:17
68:9,10,19
74:24
quash
133:17
75:21
76:3
77:10
previously94:5
procurement9s:7
76:7
80:11
92:12
question
14:23
16:9
79:5,10,18
114:11
126:22
produce
88:2
122:1
94:7
95:1,12
98:9
16:18
17:6
20:24
127:11
pre-file4:10
6:12
produced
124:1
108:1,8
116:11
21:19
22:15
23:7
ranges58:1459:4
47:6
production
136:18
120:14
123:5
30:19
34:10
35:4
64:22
65:4
76:8
pre-filed
3:16
4:1,4
professional95:14
128:23
136:23
39:17,18
41:11
Rao3:1,3
39:16,18
4:8
6:18 10:6
133:23
provided
13:19
14:5
54:4 57:10,15
61:4
40:15
131:15
11:17
12:1015:23
programl7:8
18:7
23:2425:2032:22
61:8,1370:177:14
rapid72:16
13
Keefe
Reporting
Company
rate 44:10,18
51:2,9
53:4,5,12,21
56:8
65:5,16
75:7
76:10
135:15
rates 47:15
51:7
52:24 53:1,15
58:18
59:18
64:17
64:19 66:7
120:9
120:19
121:2,5
135
:20
rather
36:8
58:15
125:2
129:19
137 :22
reach
58:15
140:24
reached
40:20
134:11
read 11:18
25:1 55:2
55:17
67:12
87:6
87:10
91:15,23
92:4
93:4,7
132:19
readily
112:24
reading
55:21
92:1
93:19 128:4
ready
12:3 85:9
102:9
130:5
reaffirm
53:14
real 30:17
95:22
realized
117:23
really
13:14 22:16
26:12
35:13
36:22
56:8 64:4
66:21
74:18
89:17
101:15
102:24
reason
76:17
111:16
reasonable
56:9
75:9
76:15,16
103:11
137:17
reasonably
17:1
20:14 75:6
76:15
94:8 105:3
136:15
reasons
22:5
111:20
112:4
122:4
rebuilding
125:2
recall
8:17 26:23
42:13
45:9 64:10
69:21,21,22
83:21
107:16,24
111:8
115:1
117:17,18
120:9
receive
3:16
4:3
84:19
received 4:15
5:1,16
5:24 26:2
48:2,9
100:18
122:8
123:14
135:19
receiving
24:12
recent 17:15
18:3
19:1 25:6 36:14,14
74:23
75:1 117:24
118:17
133:3
134:12
137:5,12
recently
12:12
104
:2 1
recharge
101:20
106:20
recirculation
62:21
recognize
24:13
recognized
70:5
recognizing
52:8
recollection
67:23
recommend
57:22
recommendation
19:3 92:24
125:1
recommendations
76:22
92:13
109: 13
recommended
61:6
63:15,20 138:21
recommending
12:24
128:20,22
132 :23
reconstruct
133:5
record
2:2 3:9,12
7:20,24
8:7,18
9:8
10:5,13
12:8 16:23
38:19 41:18
42:18
45:21
53:11 63:4,9
67:18
78:19 83:8
86:9 87:7
91:16,23
92:3 100:9
101:23
102:1,2
106:12
117:15
118:9
125:16,23
126:5
129:2 138:11
139:6,11,14,15
140:6
records
6:5 132:22
recovers 136:17
recovery
105:6
redacted
99:18
reduce 17:9
76:8
117:7 124:9,13
reducing
29:9
reduction
29:4,11
29:12,18
32:15
33:5 36:7,14
38:12
75:15 79:20,21
95:10,11
98:11
117:6
119:9
121:14
122:2
123:5
124:18
reductions
17:7
29:15
30:24 32:6,8
36:5
37:1,9,13
39:22
76:7 81:19
121:10 122:1
refer
3:2,2 75:5
129:1
reference
54:11
58 :5,6,6,2
1,2 1,22
64:7 65:20,20,23
66:2
references
15:22
59:7
61:24
62:2
referencing
54:2
0
94:24
referred
49:12
138:2
referring
31:16
109:4,6
112:12
refers
63:11
refineries
12:24
36:16,18 37:2
70:13
71:8 81:6,7
81:10
82:11 132:6
refinery 25:7
37:13
69:4,5,7, 17,
18
70:5,8
71:8,11,12
71:13,19,21
82:7,9
127:5
134:5,22
137:7
reflect
3:13 6:4
36:13
121:8,9,10
reflected
59:23
refresh 62:23
63:5
regard
35:10
54:9
70:24
regarding
3:14
18:19 22:16
49:14
67:1 87:22
107:6
112:15,15
115:4,8
118:1
134:13
region 28:10
36:11
regret
133:4
regulate
82:3
regulated
15:15
regulator
76:12
regulatory
4:17
16:7 22:20
40:18
80:1
reheat 43:11,23
49:1
49:8,10,22,23
51:4
51:12,13,14
52:15
88: 10,15,22
100:19 113:5,6,13
119:13,19
120:3
12
1:3
reheating
101:16
reinstallation
125:
13
related
7:12
48:16
103:21
139:17
relationships
95:18
relative
33:4,9,12
release 28:5
released 137:8
relevancy
110:3
relevant
3:8
97:15
110:4,12
relied 21:14
98:19
107:8 113:19
relying
17:7
18:10
31:24
remain 82:15
remainder
8 8:22
remarks
85:10
remember
26:7
103:15,22
138:8
Reminder 138:19
repeat
52:16
113:10
118:14 119:15
repetition
45:17
61:8
92:4
repetitious
3:8
rephrasing
61:8
replace 111:22,23
112 :4,22
replaced
111:16
replacement
95:8
reply
14:11
report 13:15
28:6,9
28:11 37:18 41:9
41:13
48:3
98:13
98:
14, 15,19,23
99:1,8,11,14,15
100:1
106:12
109:8
121:16,17
121: 19,2
1,22
reported 69:2
reporter
1:19 6:11
6:24
85:7 106:11
130:3
Reporting
1:21
reports
121:7
represent
102:18
114:11
representatives
5:19
reputation
95:14
request
26:5,6,22
33:18
83:24
98:11
100:7 114:21,22
115:2
requested
10:15
25:23 48:3
98:7
100:17 114:18
116: 15, 19
require
21:16
62:11
95:12
122:14,17
127: 10
required
17:18
19:9
19:13,19
24:2
28:3
36:989:1115:5
137: 19
requirement
17:3,4
18:6
19:14,15,17
19:23 20:16
requirements
16:24
18:19
20:2,3
60:10
61:9
81:15,24
111:17 112:1
126:2
requires 95:17
reschedule 117:3
researched
108:22
researchers
138:17
resemblance
48:20
reserve
8:24
reserved
7:11
residents
104:19
105:22 132:16
residual
41:4
resolve
13:19
resolved
13:22
89:24
resource
104:5
Resources
132:14
respect
12:18
36:17
49:1
130:9,19
respected
25:2
1
97:2
respectively
7:14
respects
58:10
respiratory
104:13
respond 94:11
100:8
123 :22
response
6:1 8:21
9:6
10:24 14:14,16
14:17
18:17
27:6
39:15 41:20
42:4
83:15 90:4
98:10
110:6
122:8
126:10
139:10
responses 83:18
responsible
105:4
135:1
rest
130:4
result
23:16 31:22
32:9
38:13
95:23
96:17
136:22
137:8
resulted 29:18
32:3
134: 14
results
31:13 33:17
120: 14
resume
67:13
retrofit
119:4
122:16,16
127:4
128
:8,10
retrofits 125:13
127:8 128:11
134:
18
returned
142:15
review 25:16,24
32:22 46:4,14
48:14
50:22
6 1:20
79:13 109:18,19
reviewed
15:1
25:11
25:13
34:6 73:9
91:8
reviewing
15:13,17
14
Keefe
Reporting
Company
87:18
revised
18:3
19:2
48:4 99:1,9
138:24
revision
19:10
99:5
99:6
revisions
99:22
REV1
98:24
re-designation
17:19
right 3:1
6:8
14:7
15:16
24:6
33:11
40:2
42:9 46:2
63:10
66:23
67:23
107:1
108:6
132:9
rigorous
38:3
risk
44:21
river
25:7
132:9,12
134:5,21
137:6
RMR
1:19
142:20
road 92:21
106:2
roadway
38:5
Rob
30:5
Robert
3:19
9:23
11:9
Roccaforte
3:22
9: 16,17,18,19
10:21
11:2,7,12,19
11:22
27:8 28:23
29:1,2,14,20
30:3
30:8,11,14,19
31:4
39:1,5,12
41:8,14
41:15,22,24
42:5
42:10,19,23
43:2,9
43:14,20
44:4,8,16
45:2,4,9,11,18
46:16,20
84:12,18
86:12,16
90:9,11
90:13,21,23
116:19
130:10,19
Roccaforte’s
83:19
role 31:12
32:6
101: 15
roughly
52:17
round
35:
16
rows
130:
12
rule
2:9,12,16,24
3:5
9:5
12:8
16:4,5,10
16: 10,
11,13,
14,22
16:23
18:420:6,7
21:12,12,17
22:6
22:12,16
23:16,18
24:6,6,7,9
26:18
33:18
46:3
47:5
51:10
53:13 57:19
61:15 77:17
82:13
105:11
107:6
110:3
117:13
130:20
132:3,19
133:9,10,16
134:2
134:10
135:4
136:1 137:4,10,12
137:20,22
139:21
140:24
141:4
Rulemaking
1:8
rules3:7
11:15,17
21:5
23:16
47:16
78:11,11
80:10
81:24 91:22
run
6:16
9:7 14:20
30:21
32:14
103:18,23
137:10
running
88:13,13
103:
16
rush
53:24
R08-19
1:8
2:10
S
safe
106:1
141:9
safely
122:24
safety
108:22
112:1
Saint-Gobain
5:2
13:12
130:8,21
131:1
sake
121:13
same
7:4
17:6
23:20
40:23
50:20,21
51:7
53:15
55:11
57:13
59:6
64:14
66:5
67:4
70:6,17
88:11
100:12
107:18
108:18
112:9,13
121:2
122:10
124:23
125:5,14
133:20
142:11
sanctions
2 1:22,23
22 :4,7,
10,13
satisfied
22:9
satisfy
20:6,17
50:16
8
1:23
saw
33:24
saying
21:8
23:20
says
23:9 98:23
scale
136:17
scenario
88:19
scenarios
88:6 89:2
schedule
89:10
scheduled
141:4
scheduling
90:19
117:2
school 104:14
134: 17
schools
135:22
science
138:2
1
scientific
3:4 138:2
1
SCNR
76:2
SCR
54:23
62:11,12
62:15
76:5
SCRs
76:6
scrubbed
124:2
scrubber
44:11,19
53:9
124:3,8
Seal
142:17
searchs
97:16
season
89:8,15
seat
130:1,13
second
2:18
3:17
4:20
42:14
47:21
54:20
55:11
117:22
Secondly
9:2
section
9:24 11:16
55:22
sections
93:20
sector
37:6
38:3
sectors
36:23
see
3:24
14:7 22:9
26:12
31:8
33:1
35:24 49:15
50:9
50:10
51:20
52:1,5
52:12,23
53:4,10
56:18,19
58:5,22
62:19 70:10,14,14
70:14,15
75:19
77:2
79:11
93:24
seeing
8:22
27:7,7
41:21 69:22
83:16
84:11
90:5
133:10
seem
45:10
seemed
103:10
seems46:6
104:15
seen
16:2
52:2
72:23
76:6
82:10
118:16
123:8
segments
38:5
select
87:11
selected
55:9 57:18
59:11
selection
61:14 62:3
77:19
selective
95:10,11
117:5
sell
123:21,22
125:13
128:21
132
:24
sense 11:3,4
65:6
71:24 78:1
85:2
130: 12
sensitive
31:19
sensitivity
29:3,9,17
sentence
55:11
sentences
131:4
separate
16:7
series
34:16
115:11
115:
12
serve 85:19
104:17
served
8:13
109:23
140:
19
service
8:14
85:19
140:20,21
sessions
130:22
set 8:1
12:422:1
36:7
55:24
77:8
116:21
117:1
142:
16
sets
8:2
setting
4:6
80:20
82:4,7
settlement
134:14
several
34:20
39:22
74:22
132:18
138: 10
severe
32:2
3 3:24
Shannon
9:22
share
26:13
77:18
132:12
138:1
shared
25:2
1
shareholders
137:24
138:3
shed 132:12
sheet
6:10 50:24
shops
88:9
shoreline
28:15
short
20:15
38:17
42:16
48:13
50:14
63:2,7
67:17
83:6
101:18,24
110:8
118:7
125:21
139: 12
shorthand
142:13
shortly
44:24
short-sided
105:1,18
show 8:8
27:23
28:17
29:11,17
31:2
32:15
49:3
53:20
58:11
64:4,9
65:5
69:8
showed
51:19 58:17
shown
49:15
50:8
51:17
53:19
58:21
59:4
76:2
shows 75:18
shut
89:6,14
side 105:1
132:12
Siebenberger
43:22
44:10,18
49:6,13
49:17,21
50:17
51:3,11
66:24
84:22
85:3,5,9,12
87:4,16,17
89:21
90:13,17
98:5,8
106:23
107:2,4,5
107:11,20
108:4,7
108:11
111:11,13
113
:9, 10, 14,
17,2 1
116:4,5,8,12,18
117:2
119:23,24
120: 6, 11,
16,22
136:
13
Siebenberger’s
43:24
49:4
50:6
51:22
90:2
Sierra
102:22
129:6
131:10,18,19
134:3,12
sign
6:10 47:9
129:
13
SIGNATURE
141:
12
signed
142:14
significant
48:22
49:1
122:1
123:24
124:11
134:7
significantly
62:16
similar
31:14
33:22
48:20
50:18
59:10
65:3 113:1
Similarly
100:16
simple
21:11
simplify
7:5
simply
11:5
118:16
123:18
125:4
140:8
since
47:5,24
52:2,4
60:11
87:599:5
103:15
109:1
131:23
single
32:24
62:8
86:6
96:24
SIP
19:10
20:21
21:4
22:23
23:10
23:15,24
24:12
sit 103:1
116:19
site
28:10
48:8
68:22
71:8,15
75:2
132
:20
sites
34:14,20
41:1
situation
55:23
six
31:17 34:17
38:11
59:6
60:10
61:11
93:4
103:14
sixth
93:11
size
115:4
sizes
61:23
skip 96:10
skipping
93:2
1
slab
48:24
107:14
small
60:11
61:10
smaller
81:4
smart
133:18
snielters
132:5
Smith
5:2,3,8,14
129:17,21
130:6,7
130:7,11,16,18,24
13 1:2,5
SNCR 54:23
55:3,9
97:3,4
117:6,12
118:
1,17,20
sold
133:1
sole 121:17
15
Keefe
Reporting
Company
solely3:125:6
65:273:1,477:6
staiiding
83:19
75:12
76:2477:15
subject23:24
56:22
solid8l:2
78:2079:11
127:2
139:21,22
77:16,21
78:16
56:23
80:16
solution96:1797:6
Space
125:17
standpoint
109:11
83:13,17,1788:4
117:13
129:20
123:23
128:18
speak
7:2 47:2
92:9
stands
43:10
137:7
94:12,14,22
96:14
subjective
62:4
solutions
96:15
93:20
100:7
104:7
stand-alone
97:6
97:16
108:19
submission
52:23
some4:23
5:5,19,24
117:15
118:19
Stapper’s4:13
115:13,24
116:6
submit7:15,21
21:4
12:20
15:18,24
speaking
3:21
8:13
10:10
48:10
68:16
116:16
108:2
132:17
16:1,6,14
19:8,11
14:12
69:14
86:9
110:12
Staudt’s
45:14
133:5
138:10
22:8
23:18
28:23
special
104:11
start37:485:4
61:17
84:2
87:18
submittal2l:9,16
43:4
47:9,19,22,22
specialist
9:22
87:15
93:24
95:7
88:1
89:6
91:8
submittals
87:19
47:24 48:6,16
56:1
specializes
128:7
127:13
140:9
92:15
108:14
submitted
10:16
56:2
57:6,6
58:10
specific
15:24
23:3
started
86:1
102:22
109:12
114:1
15:13
21:21
25:8
58:15 59:8
62:16
26:7,17,2456:6,10
starting76:4103:2
117:10,24,24
34:759:1
99:2,9
62:22
63:6,24
64:8
56:11,14,17,21,23
state
19:1022:19
118:4,11,16
99:22
100:19
64:11,11,22,24
62:3
68:22
70:18
23:13
31:14
34:18
stay-at-home
109:8,20
120:20
65:1
67:6,14,21
73:19
74:17
75:5
35:16
36:21
44:15
102:21
121:14
68:3,13,1470:16
75:1076:21 77:7
56:672:679:15,19
steel4:56:3
10:7,15
submitting84:6
70:1672:474:16
80:1085:293:22
79:2480:7,16
10:1646:147:14
100:10
74:1875:1876:3
111:14115:1,12
108:17110:17
48:250:2151:8,23
SUBSEQUENT
76:17
77:2,23,24
127:4
128:1
115:5
117:5,11
53:3,18,20
57:7
38:18
42:17
63:3,8
78:6,6
82:13
84:5
130:22
121:23
137:20
66:18
67:8
79:2
67:17
83:7
101:24
85:20
87:6,11
specifically
3:18
138:17
142:1,5
80:5 84:5,18
88:9
118:8
125:22
89:1891:6,10,16
16:824:867:7
stated39:2247:17
88:1491:992:12
139:13
96:4
99:13
108:18
75:23
77:1 83:23
66:5
75:4
97:3
92:24
94:15
96:2,5
substance
9:10
110:21
111:2,19
117:17127:24
113:24124:20
96:1898:11,16,19
substantive
10:23
120:1,1,2,6
121:5
139:17
statement
12:1
98:23
100:5,18,22
99:15
132:21
136:18
specifics
97:18
13:24
14:5 21:6,7
101:2
109:6,7,8,14
success
95:17
somebody
111:22
115:14
22:5
27:9
31:18
111:6
112:4,9
successfully
97:12
someone56:1,2,3
specified24:4
37:11
55:267:1
113:4,12,19
114:7
sufficient22:12
something45:10
specifies4o:5
84:23
85:10
87:4
114:9,14
116:24
109:19
46:19
50:7
55:21
speed
38:6
97:20
130:9,18
118:23
119:7,13
suggest
123:9
73:2
76:18
78:3
spend
137:23
statements
11:23
119:18
121:14
suggested
68:17
108:2
128:5,6
sponsored
17:17
87:22
93:23
123:10,17
124:23
94:17
138:17
132:23
133:24
spread
50:24
states
4:5
6:3
10:7
125:1
128:19
suggesting
96:21
sometimes
54:24
Springfield
2:17
10:15
27:18,20
132:6
134:6,22,23
suggestion
67:10
58:17
SS
142:1
34:5,7
35:5
36:9,9
135:6
136:3,12,23
suggests
52:14
somewhat
32:10
St 29:21
30:15
39:2
46:1
55:7
60:8
137:2
suitable
92:13
94:23
33:22
64:14
134:19
135:16,16
66:18
121:24
Steel’s
52:23
89:3
112:19
somewhere75:17
135:18,21
138:14
94:1097:11
suitel8:9
93:19
staff
3:4,11
141:7
state’s
32:23
107:17
sulfurization
89:7
soon
5:12
23:16
stake
95:15
statistical
32:1
step
15:16
summarize47:6,13
109:22
132:7
stakeholders 12:21
status
23:23
34:3,13
Steven
130:7
62:1
96:7
99:16
133:14
81:13
82:23
134:8
still
12:13
13:6
summarizes27:15
sorry
8:17
11:14
stand
105:13
statutory
22:11
15:17
19:3
22:7
summarizing9l:17
14:6
20:7
44:13,15
standard
16:12,13
Staudt
3:20
10:2
23:12
26:15
41:3
summary
11:20
54:1,17
66:12
16:16,17
17:5,6,14
11:4,9
25:4,16,22
90:14
27:10
28:21
42:8
67:12
90:11,24
17:20,22
18:2,16
25:24
26:13
42:6
stimulus
136:20
46:17
61:19
84:23
91:2
93:6 101:12
19:1,2,7,13,14,19
46:8,18,21,22,24
stopped
103:6
85:10
93:23
96:13
113:8
117:23
20:7,1328:1,14
47:1,7,12
53:23
stopping
106:20
summer
103:17
118:10
120:5
29:22
30:2,9,10,13
54:2,5,755:5,20
Street
1:21
sumniers3l:21
140:6
30:15,22
31:15
56:13,16,2457:5
stricter
133:12
33:23
103:15
sort
8:2
34:4,13,19,19
39:3
57:16,17,21,21,23
stringent
57:19
sunset
23:16
sound5:7
138:20
39:6,1041:2
110:3
59:14
60:15
61:1
studies69:273:9
sunsetting23:18
sounds
67:15
90:6
134:20
64:3
65:12,17,20
127:2
138:10
supplemental
sourcel:82:743:12
standards
17:7
18:3
65:24
66:12,19
study28:641:9,13
107:18
109:9
63:21
65:4
77:8
18:8,11,14,20,22
67:7,22
68:2,7,24
69:6,7,19
92:12
supplements
83:21
78:22
19:18,24
20:8,17
69:5,10,16
70:3,7
93:21
94:15
96:1
supplier
48:5
sources20:3,18
20:22
30:4,6
35:3
70:24
71:5,10,14
98:11
121:14
suppliers
68:13
36:22
37:6,7,24
35:11,12
36:5
71:23
72:14
73:15
138:16
94:20
95:19
38:9
58:5 64:23
104:9
138:22,23
74:5,9,14,24
75:8
sub
24:1,4,7
supply
128:9,10
16
Keefe
Reporting
Company
supplying
86:24
support
17:19
19:22
21:14
25:5
31:23
33:17
54:10,11,13
56:19 57:13
59:7,9
60:12,24 73:10
80:23
94:8,19
130 :23
supported
109:13
supporting
6:1
10:16
21:5
47:21
59:24
supportive
61:19
supports
27:16
sure
9:3
56:13,20
60:4
65:12,24
73:17
76:19
78:15
87:19
105:24
106:1 108:8
110:11
113:11
118:15
119:17
136:6
Surely
5:15
surprise
138:15
surprising
33:2 1
surrounded
132:4
suspect 94:16
swear
11:5
85:7
swings 127:10
switch 56:4
switching
55:18
sworn
6:20
11:10
84:22
85:13
86:20
106:23 129:19
system
7:3
122:11
systems
97:3
118:2
118: 18
system’s 68:4
T
table 48:19,20
58:4
58:16,22
60:5,10
63:16,24
70:14
tables 42:19
45:13
50:19,23 57:24
58:1
64:4,19,21
65:9
69:13
tactic 133:18
tailpipe 38:14
take
2:20 6:9
7:7
9:1111:522:2
38:16
42:14
48:12
57:16
66:21
67:11
67:14 80:17
84:8
88:22 89:12
101:
18
taken
1:13 49:4
129:8,15
142:12
takes
94:1
139:18
taking 57:5
talk 58:2
82:15,16
105:
13
talked
68:3
81:14
talking 7:4
43:5
56:14 65:17
75:16
tar
137:7
targeted
136:2
1
targets
36:7
task
7:5
taxes
73:24
teach 106:2
Team 13 1:19
technical
3:4 21:14
27:19
28:17 29:8,8
29:11
31:23
33:8
54:10,10,13
57:13
59:7,9 60:24
64:16
73:10
80:23
100:17
106:22
107:9,17
128:14
133 :22
techniques
54:21,21
54:22
56:12 58:8
59:24
technologies
10:3
58:13
60:2
64:2,5
64:7
75:11
76:22
77:9 79:5,10
82:11
92:19 94:21
95:21
95:22 97:10
111:2
technology
17:1
20:11
56:10 59:22
64:15
65:3,5 75:5
75:6,6,8,
14,
19,23
76:13
77:4,7
94:9
97:7 104:24
105:3
128:23 136:15
tell
37:23 82:3
telling
103:22,22
104:1
tend
33:20
57:19
tentatively
43:19
44:7
term 75:5
terms 16:21
33:12
58:1 62:24
79:4
95:12
terribly
103:17
Terrific
129:22
130: 17
test
120:14
testified
11:10
51:3
56:7,24
85:13
91:6
94:5
98:5
107:7
109:15 119:2
13 6: 14
testify
4:9
5:9,18 6:8
129:
14
testifying
13 1:7
testing
120:2,2
tests
119:13,19
120:
19
121:6
124 :22
Texas 138:2
thanks
130:17
141:6
their
5:18,18
22:22
26:17
40:13,24
47:17
49:7 50:22
74:6
79:6
94:2
1
96:15,16
107:14
111:8 112:4
113:5
113:13 114:10
121:4
123:11,16
123:18,23
125:2
135:10,23
136:5,9
136: 10,11,18
137:3,9,12,23,24
138:5
Therriault
140:17
they’d 85:20
thing 23:20
99:17
106:2 121:2
133:20
139:1
things 12:17
21:16
47:24
73:22,23,24
74:16
77:2
99:17
think 12:22
13:2
1
13:21,23
15:7,12
15:14,16
16:20,22
16:22 17:23 20:9
21:17,17
22:8 23:6
24:22
26:20
46:17
55:6,21
58:11
59:16,17,17
63:11
67:12,20
77:14
79:7,7,17,19,22,23
80:2,12,13
81:2,23
82:3,8,16
83:3
85:4
88:3,4,23
89:1,5,13,18
91:17
97:4
103:21
104:10
108:4,8
116:22
120:1,17
120:24 121:5
129:17,22
130:1,3
136:6
138:16
139:5
thinking
21:21
105:5,5
third
2:15 12:7
55:11
93:4
Thomas
3:1
thorough
132:1
though 24:3
40:19
70:20
88:4
114:24
thought
103:17
121:1
138:18
thoughts
67:2
71:2
1
thousand
52:17
three
3:23
4:2,11
15:23
17:14
19:10
22:17
23:5
49:15
72:6 96:16
104:10
129:16
135:13
threshold
75:15
76:6
through
14:6 25:2
25:23,23
34:3 52:7
52:8,10
59:19,19
66:20 79:24
83:20
84:2,14 97:16
132:19
141:1
throughout
64:20
tie
15:21
tied
17:4,5
tightened
30:4
tighter
122:15
Tim
2:5
time
6:16,18
7:4
10:12,17 12:13
13:13 15:3 19:8,11
20:1,12,16
27:8,11
38:8
42:6
46:17
47:10
48:13
53:8
54:4 67:4,14
69:24
87:21 88:11,16
89:8,18
95:4 98:7
103:6,8,16
104:13
106:8,9 107:9,19
109:19
110:8,10
111:21
116:22
135:24
136:14
139:23
141:8
timeline
89:23
times
56:8
73:4
74:22 103:23,23
103
:23
titled
8:6,6 44:1
today
2:15,22
4:19
7:1 9:9,21
14:5,16
14:24
19:21
28:7
42:3
45:8
66:19
67:1,4
75:4
80:5
84:6,10
85:21
86:21
88:12 90:2
91:11,
19 94:7
97:20
104:3 105:4
105:11,20
106:4
106:10,13
108:13
109:24 110:1
123:15
126:13
132:13,15
133:4
139:16 140:1
today’s 25:3
together
15:22
35:15 90:18
116
:20
tomorrow
105:12
ton 62:16
72:12
75:17
76:8
top
31:17
34:17
37:7
111:7
120:11
129: 12
total 44:1 49:5,14,15
49:22
50:9
52:6
73:13,16,17,18
122:22
138:15
touching
142:9
toured
136:4
track
6:15
trade
23:21
trading
23:8
traffic
38:6,7
transcribed
142:13
transcribing
7:1
transcript 7:6,9
128:5 139:22,24
140:1
transport
28:16
transportation
38:4
travels
141:9
treated
71:8
treatments
127:9
trend
51:19
52:4,12
tried
62:1
81:24
trillion
50:13
trim
63:12
true 17:13
30:3
33:2
70:4 110:19,20,21
116: 15
try
16:19
44:21
79:22
80:9 92:17
123:22
137:19
trying
23:2
89:10
101:12
112:18
136:1
TSC 69:3,9,11
TSC’s
70:2
1
TSD
75:18 77:16
tube
62:8
turn
46:20
95:3
turnarounds
13:1
turnkey
95:6
two 2:18 7:7,12
10:3
13:12
15:22
27:13
27:22 28:11,15
31:20
40:21 47:18
52:20
61:18,19
67:9 101:7,15
102:21 104:2
110:16 118:6
130:12
134:13
136:10
138:1,16
type
57:9
60:12 77:4
102:
15
types
60:1
61:22
77:5
78:20
81:10
typically
73:22
121:8
typo 69:10
17
Keefe Reporting
Company
typos
91:18 93:3,14
U
U
24:1,4,7
Uh-huh
108:11
ultimately
128:18
ultra
25:6
unable
132:16
unambiguous
140:9
uncertain
16:15
57:15
unclear
128:13,14
unconvincing
47:18
uncovered
109:11
under
7:24
8:23
9:15
10:23
11:15
22:22
23:12
24:12
46:6
47:18 51:9
53:4,12
76:3
88:6
88:19,20
89:2
91:22
99:18,23
140:22
understand
4:17
24:10
39:16 46:10
66:22
81:3
82:13
88:3
104:16
135:8
understanding
5:3
24:7,9
32:13
39:8
40:22
75:13 76:13
80:6
92:18
110:2
undertook
38:2
Unfortunately
133:2
union
135:7
unique
55:24 73:2
80:4,6,9
82:14
83:1
unit
57:9,9 59:8
62:10
68:23
70:6
79:15,19
80:7
United
4:5
6:3 10:7
10:15
46:1
66:18
138:
14
units
23:23
24:1
65:10
76:9
78:21
78:24
79:3,4,24
80:16
81:4,18,20
127:5
unless
46:18
131:6
139:7
141:4
unlikely
122:1
unnecessary
133:12
unreasonable
138:8
until
14:20
46:4
103: 19
un-scrubbed 124:7
124:10
updated
74:22
109 :2,
10
updates
104:1
upgrade
122:11
upgrades
122:17
uphold
110:13
upper
63:22
urged
135:11
URS48:3
53:16
92:11,23
94:4,15
94:17,20
95:4,12
95:13,17
97:2,8
98:7 100:22
110:17,24
111:2
114:14
119:3,4,8
120:24
121:16
122 :4,
10,21,22
125:12,13
126:19
126:22,23
127:1
127:12
128:7,16
URS’s
94:22
usage
44:2 48:7,7
50:11
51:12,19
52:2,21
53:18
58:18
use 33:4,8,9
35:18
36:640:4,7
50:14
51:2 52:20
55:13
64:6,7 66:6
70:12
70:12
71:15
72:15
72:19
82:6
101:20
118:1,17
130:2
136:10
137:2
used
33:17 35:2
38:11
49:8,9,10,21
49:23
50:5,21 51:4
51:16
52:14,15,16
52:18,19
53:18
55:6
63:18
70:15
74:5,11
75:19
76:1
77:5
81:10
82:9
108:5
117:6
120:19
121:3,6,7,9
137:10
138:23
useful
7:20
58:10,11
USEPA
7:12,18
17:18
18:23
19:3,4
19:7,22
21:6,11,16
22:9
30:4
39:24
74:2,7
uses
50:17,20
using 29:3
32:14
33:20 34:21,24
40:8
51:7
52:6,7
52:24
53:15
63:14
64:14
78:2
96:15
101:19
124:1
utilities
37:7
utilizes
72:1
U.S
10:16
47:14
48:2
50:21
51:8,23
52:23
53:3,18,20
57:7
67:8 80:5
84:5,17
89:3 91:9
92:12,24
94:10,15
96:2,5,18
97:10
98:11,16,19,23
100:5,18,22
101:2
107:17
109:6,7,8
109:14
112:4,9
113:4,12,19
114:6
114:9,14
116:24
119:13,18
121:14
123:10,17
124:23
125:1
128:19
134:6,23
136:3
137:2
V
valuable
104:5
value
127:11
values
34:22
72:22
107:
12, 12,21
108:5
variety
27:19
29:7
64:23 65:2
66:2
81:1
95:22
97:13
127:2,13
various
1:8 2:7
36:15 37:6
61:21
61:22,22
75:19
80:8
126:20
127:5
140: 18
vary
114:12
vendor
93 :22,22
96:20
111:1,3
113:16
123:8,21
124:3
125:9
128: 15
vendors
68:3,5,7,2
1
95:1 96:1,6,9,14
96:16 97:17
108:19
109:12
110:19,22
112:6
113:20
114:1
119:5 122:8
123: 15
Vera 10:4
verify
97:8
version
28:1,13
30:2
35:11
74:23
75:2
98:19
100:1
versus
65:13,16
72:9
124: 19
very
4:24
5:9,9,10
5:23
9:11
10:20
11:1 12:2
14:1
15:8,10
18:9
19:1
31:19
32:2
35:20
35:22
38:2
42:24
42:24
45:7,16
47:6
48:20 50:18
51:7
53:5
65:3
67:5,16
67:24 72:16,17
73:2
79:20
83:11
91:20
93:15
104:1
104:9
106:14
124:11
127:19,20
128:3
132:4
133:18,21
135:7
135:15
137:5
140:3
Vetterhoffer
9:21
98:2,2,18,22
99:4
99:8,16,21
100:15
101:1,18
106:15
106:19
107:5,16
107:23
108:6,10
108: 12,17,2
1
109:1,7,15
110:5,7
110:15,21,24
111:4,10,15,19,24
112:3,8,13
113:3,8
113:11,15,18,23
114:
13,17,22
115:3,16,20,23
116:3,9,14,24
117:4,10,16,22
118:12,15,21
119:2,12,17,22
120:4,8,13,18
121:12,18,21
122:9,20
123:2,24
124:13,17
125:6
125:10,20,24
126:7,11
via 97:16
viability
105:6
view
71:23
116:23
viewed
79:4
99:23
140:4
visit
103:7,8
vital
104:17,19
VOC
29:11
VOCs
29:10
voice 93:18
volume
101:11
volunteer
131:24
‘V
wait
46:3
waiting46:23
131:3
waive
15:3
WAIVED
141:12
want
2:20
7:7 9:2
28:7
35:18
43:19
46:18
53:14
60:17
71:15
76:11
82:4
85:15
90:7
92:2
102:3 105:23
132:1
133:8
wanted
6:4
13:3
51:13
92:15
128:6
129:18
132:13
wants
85:22
warranties
68:5
wasn’t
68:17,17
103:17
114:6
waste 127:9
132:6
water
62:8 63:11
way
3:2
9:15
10:23
23:6
50:12
71:24
73:3
75:13
76:14
88:17
99:21
ways 81:14
wear 111:21
web
7:18
28:10
75:2
132:20
140:2
1
14
1:2
week
38:8 138:13
weeks
132:18
138:
16
weight
27:20
29:6
32:18
39:21
40:11
welcome
2:3
well 6:4
12:2,16
17:24
24:5
37:19
49:24
55:5 56:16
57:5,23
59:14
61:1
61:16
63:14
64:14
69:17
70:4,7,24
71:14
74:14
75:8,9
77:15,21
80:22
82:17
91:11
102:11,22
107:20
108:4
111:1
113:9
113:16
120:24
137:5
well-versed
105:15
went
103:5,12,16
were 2:1
5:5
6:3,5
11:10
12:13
14:3
26:18
30:24 31:2
34:19
36:9,18,19
37:20
38:18
39:23
39:23
40:1,3,11
42:17
52:18
57:18
58:12,13
59:18,18
59:21,21
60:24
62:12
63:3,8
67:18
67:20,21
69:2,6
72:22,22
77:18,23
78:8,9,21
79:6,12
79:12
83:7,21
85:12
88:8
90:18
91:17
92:11 97:11
98:6 99:15,18
102:1 112:22,24
113:3
114:8
116:22
118:8
120:9,18
122:24
125:22
126:12
132:20
133:3
18
Keefe Reporting
Company
137:18
139:13
112:5
130:7
133:9
0.0551:9
2.3
18:16
3rd
140:1
142:12
135:11
136:19
0.074
53:11
2.5
16:13,16
17:2,5
3,000
75:16,16
weren’t
26:9,18
worked
38:3
104:22
0.083
53:5
17:22
18:24
29:5
30
137:7
139:21
west
28:2
135:6
0.113
96:18
34:2,4,13,18,22
30th
6:4
9:3
130:20
western28:4,5,15
workers
134:15
03124:5
35:239:3,10
35 1:9
2:8 93:5,8
41:4,9,12
136:19,24
0528:334:21,22
134:21
135:1
114:3
we’ll
13:7
67:13
working
12:14
13:6
37:1,5
138:23
35-day44:11
84:8
87:2
23:7
24:22
57:21
0634:9
65:16,22,22
2043:8,17
45:20
3500
75:16
we’re
12:3,8,14
76:19
82:22
07
34:9
62:21
48:19,19
49:3
36,000
51:5
15:17
18:21
21:21
105:20
109:5
0862:22
63:14,19
51:22
66:20
67:20
36,180
50:3
53:17,17
75:13,13
130:13,16,21
82:5,7,12,16
117:7
73:3
83:20
84:2,13
-
76:14
81:6,12
134:15
135:2
084-002797
1:20
94:13
82:22
88:20
works79:15
80:12
20th3:18
10:10
4050:1293:5,7,12
101:19
106:24
81:23
82:17
94:10
108:15
109:1
114:4,4
136:8
117:3
125:15
97:11
111:6
158:24
2000910:10
4357:1259:561:12
128:22
141:11
world
30:17
88:24
1.4 50:13
51:24
2001
52:3,5
62:7
we’ve
13:5 16:2,23
95:22
1.565:16
200231:1432:2,2
4457:12
59:5
61:12
21:8
22:4,4
25:21
world’s
104:5
1052:7,8,10
100:2
32:10,14
33:24
44th
1:21
25:2126:133:22
worriedl33:19
lOth2:197:108:24
200531:2432:11
45052:17
42:656:757:5
worries43:16
10:14
94:6
107:6
33:14,2034:11,15
63:1876:1977:10
worst
135:17
120:21
142:17
34:24
36:15
80:3,12,13,24
81:8
wouldn’t
60:17
102424
11:16
2006
16:16
29:23
5th 2:14
81:12,12,14,15,24
112:5
1030
115:11
34:10,18
35:11
50111:9
136:8
87:3
88:7,24
wrap
53:22
84:10
111:2150:251:23
2007
34:11,15
124:20
127:7
wrapped
5:13
52:7,11
53:21
57:6
2008
2:13,14,17,19
-
6
129:22
writingl32:21
67:1392:14,19
16:1618:2425:9
6050:1193:12
WhEREOF
142:
16
133:6
94:9,21,24
96:22
29:23
30:4,5
34:3
114:5
while
5:1844:21
written
28:4
132:17
97:10
111:5
115:6
34:6,7,1944:10,18
62226
1:22
58:10
91:24
96:20
140:13
115:21
117:7
52:17,21
59:1
94:6
whole
17:8
wrote
12:13
13:14
119:14,19
123:3
98:4,13,17
99:5
___L
WI
63:11
136:7
2009
1:13
3:18
9:3
717:138:6
Wibell
70:12
12 50:2
51:23
52:7
24:2
26:21
41:14
75 30:7,13
wide
72:11
73:1,4
yeah26:24
56:15
52:11
53:21
57:6
48:4,6
94:13
98:24
79:5,10
127:2
70:3
74:5
119:24
63:21
67:11
92:14
100:21
130:20
-_--_
8
widely
97:2
112:20
120:16,16
92:19
94:10,22,24
139:20
142:8,18
830,400
49:16
willing82:15,15,22
yearl9:224:231:12
97:10
111:5
115:6
142:21
8530:6
90:14
116:10
32:7,9,11,14
33:6
115:21
117:5,7
2010
19:9
120:13
33:1434:21,24
119:14,20120:2
201230:20
---_-_--_
-
willingness
93:18
35:1,8
37:4,5,9
123:3
136:7
2013
19:11
9th2:12,1826:7,10
windows
122:15
49:16
50:3 52:1
13
104:19
105:21
2143:1945:20
26:14
98:4
100:2
Wisconsin
27:19
88:2,5,5,17
135:3
13th
14:21
50:18
60:10
107:6
120:21
wise67:1O
years
17:15
19:11
130
124:3
21st28:641:13
9365:21
124:9
wish4:9,185:4,19
32:15
103:5,14
14th2:17
2111:92:8
94 65:21
6:8
8:3 11:19
111:9
137:6
14-day
9:6
14:20
217
1:9
2:9
14:1827:1346:19
yesterdaylo:11
157:11
8:5,2065:18
2244:645:2051:18
84:1
94:11
110:5
85:18
109:20
73:3
22nd48:6
100:21
129:14,24
139:9
133:2
16
7:12
8:6,20
23
44:14
45:21
wished84:2291:10
yield29:15
18103:5
23rd139:20
wishes
9:14
54:4
young
103:2
104:2
1941:18,22
98:24
2444:14
45:21
98:1
19th 7:23
26:21
48:4
66:20
83:20
84:2
witness
25:3
142:16
1900
124:7
84:14
109:18
witnesses
3:23
4:2,9
Zink
70:13
1994
58:9,12
59:23
24-hour
16:16
19:1
4:12
5:20
11:23
1997
16:12
17:4,5
25
28:18
86:10,18
142:10,11
17:14,19,21
18:2
86:23
114:3
wondering
90:14
$3,000
62:16
19:19
27:24
28:13
25th
59:1
Wood
25:7 134:5,21
29:21
30:1,21
26142:21
137:6
-
-----
35:10
39:3
work
12:15
13:7,12
#084-002797
142:20
15:15
24:9
81:9
_--
--
3 1:13
7:13
8:6,8
95:15
104:13
2nd4:4
142:7
19
Keefe
Reporting
Company