1
1 BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
2
3 IN THE MATTER OF:
4
Petition of TAKASAGO )
5 INTERNATIONAL CORPORATION (U.S.A.) )AS-00-4
for an Adjusted Standard form )(Adjusted
6 Ill Adm Code 302.208 and 304.105 ) Standard-water.)
7
8
9 The following is a transcript of the
10 proceedings held in the above-entitled matter taken
11 stenographically before TERRY A. STRONER, CSR, a
12 notary public within and for the County of Cook and
13 State of Illinois, taken before, Amy Muran Felton,
14 Hearing Officer, at 698 Burnham Drive, University
15 Park, Illinois, on the 22nd day of December, A.D.,
16 1999, scheduled to commence at 10:30 o'clock a.m.,
17 commencing at 10:50 o'clock a.m.
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L.A. REPORTING (312) 419-9292
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1 A P P E A R A N C E S:
2 HEARING TAKEN BEFORE:
3 ILLINOIS POLLUTION CONTROL BOARD,
100 West Randolph Street
4 Suite 11-500
Chicago, Illinois 60601
5 (312) 814-4925
BY: MS. AMY MURAN FELTON
6 HEARING OFFICER
7 GARDNER, CARTON, DOUGLAS,
321 North Clark Street
8 Chicago, Illinois 60610
(312) 644-3000
9 BY: MS. ROBERTA M. SAIELLI
10 Appeared on behalf of Takasago,
11
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
12 1021 North Grand Avenue East
P.O. Box 19276
13 Springfield, Illinois 62795
(217) 782-9849
14 BY: MR. RICHARD C. WARRINGTON, JR.,
15 Appeared on behalf of the Illinois
Environmental Agency.
16
ILLINOIS POLLUTION CONTROL BOARD MEMBERS:
17
Ms. Marili McFawn
18 Mr. Anand Rao
Mr. Charles King
19
ALSO PRESENT:
20
Mr. James Kohl
21 Mr. Michael Klootwyk
Mr. Frank Jones
22 Mr. Michael Litton
Mr. Michael Grubermann
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L.A. REPORTING (312) 419-9292
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1 I N D E X
PAGES
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3 GREETING BY HEARING OFFICER.............. 3-7
4 OPENING STATEMENT OF ROBERTA SAIELLI..... 7-9
5 QUESTION AND ANSWER SESSION.............. 9-43
6 CLOSING COMMENTS BY HEARING OFFICER...... 43-46
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9 NO EXHIBITS WERE MARKED
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L.A. REPORTING (312) 419-9292
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1 MS. FELTON: Good morning and welcome. My
2 name is Amy Muran Felton and I am the hearing
3 officer with the Illinois Pollution Control Board.
4 I have been assigned to preside over this hearing
5 today in the matter of petition of Takasago
6 International Corporation U.S.A. for an adjusted
7 standard from 35 Illinois Administrative Code
8 302.208 and 304.105.
9 Today is Wednesday, December 22, 1999, and
10 it is approximately 10:45 a.m. I note that there do
11 not appear to be any members of the public here
12 today.
13 This hearing was scheduled as a result of
14 a public request for a hearing pursuant to Section
15 106.713. The hearing date was scheduled and noticed
16 pursuant to Sections 106.801 and 106.802 of the
17 Board's procedural rules.
18 The hearing will be governed in accordance
19 with the Illinois Environmental Act and the Board's
20 procedural rules. Sections 1 -- excuse me, 101.220
21 and 101.221 of the Board's procedural rules
22 regarding hearings will apply to these proceedings.
23 In addition, Sections 106.805 and 106.806 regarding
24 the conduct of hearings in adjusted standards apply
L.A. REPORTING (312) 419-9292
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1 to this hearing.
2 This hearing is intended to develop a
3 record for review of this adjusted standard
4 proceeding by the entire seven member -- at this
5 time, six member Illinois Pollution Control Board.
6 I would remind you that I will not be
7 deciding this case, rather the current six member
8 Pollution Control Board will be deciding this case.
9 They will review the transcript of this proceeding
10 and the remainder of the record and render a
11 decision in this matter.
12 My job is to ensure that an orderly
13 hearing and clear record develops so that the board
14 can have all the necessary information before it
15 when it is deciding this case. After the hearing,
16 the parties will have the opportunity to submit
17 posthearing briefs. These, too, will be considered
18 by the Board.
19 Any witnesses will be sworn and subject to
20 cross-examination. The parties may ask a question
21 of any witness. Any questions asked by the Board
22 members and/or Board staff and hearing officer are
23 not intended to express any preconceived notions or
24 bias, but only to build a complete record for review
L.A. REPORTING (312) 419-9292
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1 by the other Board members and staff who are not
2 present with us today.
3 Before we begin with the introduction of
4 the parties and opening statements, I would like to
5 introduce the other members and Board staff that are
6 present with us today. Seated to my left is Anand
7 Rao of the Board's technical unit, seated next to
8 Anand Rao is Board member Marili McFawn, and next to
9 Board member McFawn is her attorney assistant
10 Charles King, and also here with us today is our
11 chief hearing officer, John Knittle.
12 Does anyone have any comments that they
13 would like to present to the Board -- on behalf of
14 the Board or the staff before we proceed?
15 MS. McFAWN: No, not really, just to say hello.
16 I am just one of the six members so I always like to
17 point that out. All six of us make the decisions.
18 MS. FELTON: Good. Okay. Now, we'll proceed
19 with the introduction of the parties. Could we
20 please start with the petitioner, if you would mind
21 introducing yourself and who you have here with us
22 today?
23 MS. SAIELLI: I'm Roberta Saielli, I represent
24 Takasago International Corporation. I'm the
L.A. REPORTING (312) 419-9292
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1 petitioner in the case today.
2 MR. WARRINGTON: And my name is Richard
3 Warrington, I represent the Illinois Environmental
4 Protection Agency today.
5 MS. FELTON: Ms. Saielli, do you mind just
6 introducing who you have with you today?
7 MS. SAIELLI: Sure.
8 MS. FELTON: Thank you.
9 MS. SAIELLI: I have with me Frank Jones, who
10 is the plant manager at Takasago's University Park
11 plant, which is the subject of this petition. Mike
12 Klootwyk, who's the environmental safety training
13 manager with the plant, and then also, on behalf of
14 Takasago, we have Jim Kohl, who is a consultant with
15 URS Griener Woodward Clyde, you know, who is a
16 technical consultant on the petition.
17 MS. FELTON: Okay. Are there any additional
18 interested parties that would like to introduce
19 themselves? At this time seeing none, I will now
20 address any outstanding motions or prehearing
21 motions that are currently before us.
22 To my knowledge, there is only one
23 outstanding motion and that is the Illinois
24 Environmental Protection Agency's motion for leave
L.A. REPORTING (312) 419-9292
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1 to file instanter the agency's recommendation, which
2 was filed with the Board December 3, 1999. As there
3 were no objections filed with the Board during the
4 required time frame, the agency's motion to file
5 instanter, it's recommendation is granted.
6 Are there any other additional motions,
7 prehearing motions, that we need to address?
8 MR. WARRINGTON: No.
9 MS. FELTON: Thank you.
10 At this time now, we will proceed with
11 opening statements on behalf of the parties,
12 starting first with the petitioner, Ms. Saielli.
13 MS. SAIELLI: Takasago tends to stand on its
14 petition, we don't intend to offer any testimony
15 today, but I just wanted to give you a little bit of
16 background on why we're here and what we're asking
17 for.
18 Basically, there was an adjusted standard
19 granted for Deer Creek, which is where the Consumers
20 Illinois Water Company, which is the local waste
21 water treatment plant, it's a privately owned
22 treatment plant, discharges to Deer Creek. There
23 was an adjusted standard granted to them in 1990 by
24 the Pollution Control Board for total dissolved
L.A. REPORTING (312) 419-9292
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1 solids and it was granted at 2100 daily max and 1675
2 on the average milligrams per liter of TDS.
3 At that time, the Nutrasweet company owned
4 the plant that's currently owned and operated by
5 Takasago, and the companies are not related
6 companies, Takasago purchased the plant in 1996, and
7 at that time, Nutrasweet was given certain
8 limitations on the amount of pounds of TDS that they
9 could discharge to the CIWC plant, which then
10 discharged to Deer Creek.
11 So neither did -- Nutrasweet or Takasago,
12 as a direct discharger, they are indirect
13 dischargers to CIWC, and Takasago is here today to
14 basically change the name on the adjusted standard
15 to make the adjusted standard applicable to their
16 discharge, and basically the water that's being
17 discharged is from the same processes that water was
18 discharged at Nutrasweet.
19 When I say processes, I don't mean the
20 manufacturing process of the plant. The water is
21 discharged from the utility water treatment system.
22 When the water comes into the Takasago plant from
23 the public water supply, it's already high in total
24 dissolved solids inasmuch as 930 and some milligrams
L.A. REPORTING (312) 419-9292
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1 per liter, and they need to basically soften that
2 water so that they can use it for their utilities,
3 plant utilities, and also for water to use in the
4 processes. We do have pretreatment facilities,
5 which are described in the petition, and then the
6 water from that utility processes discharge to CIWC,
7 and so essentially, Takasago is asking for the same
8 relief that was previously granted to Nutrasweet,
9 and I believe the IEPA may make a statement, but
10 that's all we have to say today, and if you have any
11 questions, people from Takasago can answer them.
12 That's it. Thank you.
13 MS. FELTON: Thank you very much, Ms. Saielli.
14 Mr. Warrington?
15 MR. WARRINGTON: On behalf of the Agency, we
16 would waive an opening statement. By way of
17 introduction, we -- we'll rely on our
18 recommendation. The recommendation is that Takasago
19 should be substituted for the relief given to the
20 Nutrasweet company several years ago by the
21 Pollution Control Board with the same effluent
22 concentration and mass loading limits as that
23 previous adjusted standard. Leaving that, I'm
24 available for questions.
L.A. REPORTING (312) 419-9292
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1 MS. FELTON: Okay. Thank you. Ms. Saielli,
2 it's my understanding then you actually are not
3 offering any testimony?
4 MS. SAIELLI: No.
5 MS. FELTON: Okay. And that's true for you?
6 MR. WARRINGTON: Right.
7 MS. FELTON: Okay. And just for the record,
8 I'm going to ask if any interested party at this
9 time would like to offer any testimony? If there is
10 anyone, please speak now.
11 At this time, there does not appear to be
12 any interested party who would like to offer any
13 testimony on behalf of themselves with regard to
14 this petition for adjusted standard.
15 At this time, I ask if there's anyone here
16 that has any questions for either the petitioner or
17 the respondent?
18 MS. McFAWN: I do.
19 MS. FELTON: Please, Ms. McFawn.
20 MS. McFAWN: I'm probably more familiar with
21 the past records than today's records, so if it's
22 already answered in your petition, please forgive
23 me.
24 What I was wondering is, do you have an
L.A. REPORTING (312) 419-9292
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1 operating permit from the Agency?
2 MS. SAIELLI: The company has a construction
3 operating permit.
4 MS. McFAWN: For the waste water discharge?
5 MS. SAIELLI: For the discharge to CIWC for the
6 construction of pretreatment.
7 MS. McFAWN: Okay. Do you know offhand what
8 regulatory provision the Agency issues that under?
9 Do you know Mr. Warrington?
10 MR. WARRINGTON: On behalf of the Illinois
11 EPA, the Agency has authority to issue construction
12 and operating permits under 35 Illinois
13 Administrative Code Part 309, I believe it's
14 Subpart A, which are permit requirements for non --
15 national pollutant discharged elimination, or NPDS
16 permits. The NPDS permit is granted to a direct
17 discharger of waters of a state. There are
18 provisions in those Pollution Control Board rules to
19 issue permits for other -- for the construction and
20 operating of facilities that don't require an NPDS
21 permit.
22 In addition, the Illinois EPA administers
23 a pretreatment program on behalf of the United
24 States Environmental Protection Agency that
L.A. REPORTING (312) 419-9292
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1 regulates the internal discharge to waste water
2 treatment plants in cooperation with the waste water
3 treatment plant. Sorry, if that was too long.
4 MS. McFAWN: This last part you talked about,
5 the pretreatment program that you administer on
6 behalf of the US EPA, isn't that the NPDS program or
7 is that --
8 MR. WARRINGTON: No, no, it's a -- the
9 pretreatment program is a separate federal program
10 to regulate the -- what they call the indirect
11 dischargers to the waste water treatment plant. The
12 waste water treatment plant would be the last
13 treatment stage before the effluent reaches the
14 water in the state, and that is covered by the NPDS
15 program.
16 MS. FELTON: Ms. Saielli, do you have any
17 follow-up comments?
18 MS. SAIELLI: It's my understanding that
19 Illinois doesn't have the authority to administer
20 the pretreatment programs, but they have one in the
21 regulations, but they're -- what Takasago has is a
22 permit to own and operate a pretreatment system from
23 which they discharge to a treatment works that has
24 an NPDS permit with the state, is that correct?
L.A. REPORTING (312) 419-9292
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1 MR. WARRINGTON: That's correct. We're not
2 delegated to take over the entire pretreatment
3 program from the United States Environmental
4 Protection Agency. We do -- as a matter of -- I
5 believe it's a memorandum of agreement and part of
6 our working agreement with the United States
7 Environmental Protection Agency to administer a
8 program that accomplishes much of the same goals.
9 MS. McFAWN: Okay. So this is probably the
10 permitting scheme, and I'm not that familiar with it
11 so maybe you can just indulge me here. You issue
12 permit -- operating permits to companies such as
13 Takasago?
14 MR. WARRINGTON: Right.
15 MS. McFAWN: Because they're an indirect
16 discharger?
17 MR. WARRINGTON: Right. Because their
18 operation meets one of the categories that is
19 required to have a pretreatment permit under the
20 federal system.
21 MS. McFAWN: Do you know what category that is?
22 MR. WARRINGTON: No, not offhand. I'm sorry.
23 MR. RAO: Can I just ask a question here, a
24 clarification question? Does the pretreatment
L.A. REPORTING (312) 419-9292
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1 program, the federal program, does it apply only to
2 publically owned treatment works or both publically
3 and privately owned?
4 MR. WARRINGTON: The federal pretreatment
5 program only applies to dischargers to publically
6 owned treatment works.
7 MS. FELTON: Before we proceed, just since
8 we're having several questions at this time, I think
9 it might be appropriate if there's no objection from
10 Ms. Saielli to have Mr. Warrington sworn in to
11 provide the testimony on behalf of the Agency.
12 Ms. Saielli, you have no objection to that?
13 MS. SAIELLI: No.
14 (Witness sworn.)
15 MS. FELTON: Okay. I think the same would hold
16 true if there's any questions directed to
17 Ms. Saielli or unless you can also provide her
18 witnesses as well to answer those questions. Thank
19 you.
20 MS. McFAWN: Okay. So Mr. Warrington, if I
21 recall correctly, you just said that the
22 pretreatment program, and this would be the
23 pretreatment program that you issue permits on for
24 under a memorandum of the agreement, that involves
L.A. REPORTING (312) 419-9292
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1 only POTWs?
2 MR. WARRINGTON: That is correct.
3 MS. McFAWN: Okay. Now, as I understand it
4 CICW --
5 MR. WARRINGTON: CIWC.
6 MS. McFAWN: CIWC, thank you, is a --
7 publically regulated?
8 MR. WARRINGTON: Privately owned.
9 MS. McFAWN: Privately owned, but as the Board
10 would define it, a publically regulated treatment
11 works. So how does that fit into what you just
12 described as your delegated authority?
13 MR. WARRINGTON: I'm not sure. I would have to
14 speculate a little bit, but I believe that we treat
15 publically regulated treatment works such as
16 Consumers Illinois Water Company as a publically
17 owned treatment works for purposes of a pretreatment
18 program.
19 MS. McFAWN: Okay. The Board doesn't have a
20 regulation that says that operating permits are not
21 required for those pretreatment works or waste water
22 sources discharging to a sewer tributary to a
23 treatment works which will not, and then there's
24 three qualifying paragraphs, and if you come in
L.A. REPORTING (312) 419-9292
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1 within one of those three categories, you do not
2 need such an operating permit. This is that -- the
3 Board's Rule 309.204.
4 I was wondering if Takasago fits into one
5 of these three categories? Maybe -- do you want to
6 see a copy of the reg?
7 MR. WARRINGTON: I think we need a copy of the
8 reg.
9 MS. McFAWN: Okay. Here, you can even use mine
10 which is highlighted, and you might want to show
11 this to the people from Takasago. They might know
12 their plant operations.
13 MR. WARRINGTON: Sure.
14 MS. FELTON: We'll go off the record for just a
15 second.
16 (Whereupon, a discussion
17 was had off the record.)
18 MS. FELTON: We'll go back on the record. Sir,
19 if you're going to answer, I prefer if you were
20 sworn in, Ms. Saielli -- or can --
21 MS. McFAWN: Can one of your gentlemen --
22 MS. FELTON: Or can one of your witnesses
23 testify to that --
24 MS. McFAWN: Or do you feel this is maybe a
L.A. REPORTING (312) 419-9292
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1 legal --
2 MS. SAIELLI: That's what -- that's -- my
3 concern is that this is really a legal question.
4 MS. FELTON: Okay.
5 MS. SAIELLI: Nutrasweet had an operating
6 permit that was issued by the IEPA, and then
7 Takasago applied again.
8 They are subject to a categorical standard
9 under the US EPA's pretreatment regulations and, you
10 know, I think it's a legal interpretation of the
11 Agency as to whether this provision applies, but,
12 you know, we would be speculating as to why. So I
13 don't know necessarily if I can answer the question
14 for the Agency.
15 MS. McFAWN: So when you say that it is subject
16 to one of the categorical standards under the US EPA
17 regs, those would be the regulations that have to do
18 with POTWs?
19 MS. SAIELLI: No. Those would be regulations
20 for indirect discharges under the Federal Clean
21 Water Act Regulation. They're actually part of the
22 organic chemicals, plastic, synthetic fibers source
23 category, although none of this really has anything
24 to do with TDS, just so you're aware. In terms of
L.A. REPORTING (312) 419-9292
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1 the -- the fact that they're subject to this
2 categorical standard has nothing to do with the TDS.
3 That's the subject of this adjusted standard.
4 MS. McFAWN: Oh, that's an interesting point.
5 Okay.
6 MR. KING: Are there constituents of their TDS
7 admissions that are characteristic, i.e., that could
8 be traced back to this plant from beyond the
9 treatment works?
10 MS. SAIELLI: I don't understand your question
11 because essentially total dissolved solids are
12 basically -- it's my understanding they're types of
13 salts, and I'm not testifying now, but with
14 incoming -- this is all in our petition, the
15 incoming --
16 MS. McFAWN: If you could, would you testify to
17 this about the plant and --
18 MS. SAIELLI: Can you explain where the TDS is
19 coming from? You're going to need to be sworn in.
20 MS. McFAWN: You're Mr. Jones, right?
21 MR. JONES: I'm Mr. Jones.
22 MS. FELTON: I'm just going to clarify to the
23 extent that either Ms. Saielli or Mr. Warrington
24 are giving legal arguments, then there's no need to
L.A. REPORTING (312) 419-9292
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1 have you sworn, but if you cross the line into a
2 factual sort of situation, I would ask that you were
3 sworn, so, yeah, that's fine. We can proceed with
4 your witness.
5 MS. SAIELLI: Okay. We're going to have Mike
6 Klootwyk.
7 MS. McFAWN: Okay.
8 MS. FELTON: Roberta, if you want to have him
9 come up and sit closer to you, that would be fine.
10 MS. SAIELLI: Yeah, do you want to come up,
11 Mike?
12 MR. KLOOTWYK: Okay.
13 MS. FELTON: Yeah, if you just want to raise
14 your hand to be sworn.
15 (Witness sworn.)
16 MS. FELTON: You can sit down next to
17 Ms. Saielli if you want, sir, that's fine.
18 MS. SAIELLI: Ask your question again.
19 MR. KING: Well, I guess another way to say it
20 would be what are the constituents of the TDS coming
21 out of the plant, if you know?
22 MR. KLOOTWYK: What are the breakdowns of the
23 TDS that are coming --
24 MR. KING: Yeah, just generally.
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1 MR. KLOOTWYK: Generally speaking, and we
2 talked about this this morning, primarily it's
3 coming off the softener systems, and so when you
4 regenerate a softener much like in your home, you
5 have a lot of salts that come out.
6 In Takasago's case, the salts coming in --
7 or the dissolved solids I should bring -- the
8 dissolved solids coming into the plant are
9 relatively high. We had the drinking water, if you
10 would, potable water tested both by ourselves,
11 Takasago, as well as CIWC from their well. Okay?
12 It's a raw-water well essentially. I don't know
13 what's the depth of that particular well, but the
14 results indicated that their total dissolved solids
15 that they're pulling up from the aqua filter below
16 is running over 900, and we've seen a peak as high
17 as 1,000, which at that point exceeded the State's
18 standard for TDS discharge of 1,000. So they were
19 delivering to us a quality of water that was very
20 high in TDS. I can't break those compounds down
21 because CIWC regulates that well and tests that
22 well. So essentially we're using that water --
23 MR. KING: So essentially if they were
24 discharging their well water straight out, that
L.A. REPORTING (312) 419-9292
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1 would potentially be in violation?
2 MR. KLOOTWYK: Pretty close.
3 MS. SAIELLI: They currently are operating
4 under 2100 milligrams per liter so --
5 MR. KING: Right.
6 MS. McFAWN: The waste water treatment, he's
7 talking about the fresh water.
8 MR. KING: Yeah, CIWC, but if CIWC was taking
9 water so that the water -- from what I hear you
10 saying, though, the water they were pulling out of
11 the ground is so high in TDS to start with --
12 MR. KLOOTWYK: The potable water, yes.
13 MR. KING: -- that if that just went straight
14 out with no treatment that it could potentially,
15 when it peaks, be violating the standard.
16 MR. KLOOTWYK: Yes, yes. Two years ago when we
17 first looked at this then, and then when Ukano
18 Foxworth, an EPA permit individual, he asked a
19 question about the potable water, and I expressed
20 that the TDS was so high that we could violate by
21 taking a garden hose, if you would, from the potable
22 water source and put it right to the discharge and
23 be in violation of the State's standards for TDS on
24 a straight pass through.
L.A. REPORTING (312) 419-9292
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1 MR. KING: Oh, that's interesting. So there's
2 not -- I guess what I was wondering is if there was
3 some constituent of the effluent from the plant that
4 would differentiate it from, say, municipal waste
5 water from the city, which I understand also goes
6 through this plant, through the CIWC treatment
7 works?
8 MR. KLOOTWYK: Restate that if you would?
9 MR. RAO: I think, basically, what Mr. King is
10 asking you is if you sampled the effluent discharge
11 coming out of the treatment plant of CIWC; is there
12 something that can tell you that, in a part, the
13 TDS is coming from either plant through the CIWC
14 plant, you know, like if there's a certain
15 characteristic of the TDS which can say well, you
16 know, this TDS is -- you know, is there anyway to
17 distinguish between the chemical breakdown in the
18 TDS to say whether it was coming from the plant or
19 from the other dischargers?
20 MR. KLOOTWYK: That's a difficult answer -- or
21 question to answer because I can say this. Before
22 we brought chemicals on the site, okay, we didn't
23 need to regulate it for water. All right. We were
24 doing the same things that we're doing today, but
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1 now because we brought a constituent on site that's
2 under the Federal Code of Regulations 414, we now
3 must look at pretreatment in a criteria under the
4 federal codes, okay, which now forces us to move
5 towards a pretreatment operating permit. All right.
6 So we went through a window and really did
7 nothing different at the plant other than the fact
8 that, yes, we do have this one constituent on site.
9 If we had a release of this constituent it could be
10 tied directly back to the facility, and that's what
11 414 is all about, to regulate those hazardous
12 pollutants. The industrial park, to my knowledge, I
13 don't believe there's anybody else using that
14 particular compound in reference to 414.
15 MS. SAIELLI: But you're not talking about the
16 TDS. What you're asking specifically is when the
17 water comes out of Takasago's plant to the CIWC is
18 there anything about TDS and the discharge that
19 would differentiate it from the TDS that's already
20 in our water coming in from somebody elses plant?
21 MR. KING: That's correct.
22 MR. KLOOTWYK: And I don't believe we could do
23 that.
24 MR. KING: Okay. I think you answered my
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1 query.
2 MS. FELTON: Mr. Warrington, did you have
3 anything you would like to provide in response?
4 MR. WARRINGTON: All I can do is concur with
5 that testimony. The way I understand the federal
6 test procedure, 40 CFR 136, the test for total
7 dissolved solids involves a filtering sample,
8 weighing it, evaporating water, and weighing it
9 again so you wind up with a residue that is the --
10 it's a mixture of salts, primarily sodium chloride,
11 which is, I believe, indistinguisible for -- from
12 the result we get from testing the raw well water or
13 the discharge from any domestic water softener.
14 MR. KING: If I could clarify one thing that
15 you had said a moment ago, so the presence of the
16 compound that brought you within the federal
17 regulatory scheme is not tied to the processes that
18 are producing your waste water, it's just the fact
19 that it's there in the plant?
20 MR. WARRINGTON: That's correct.
21 MR. KING: Okay. Thank you.
22 MS. McFAWN: So the process, the manufacturing
23 process, doesn't contribute to the TDS?
24 MS. FELTON: Mr. Klootwyk, could you answer yes
L.A. REPORTING (312) 419-9292
26
1 or no?
2 MR. KLOOTWYK: The manufacturing -- we need to
3 define manufacturing. There's manufacturing of
4 processes of potable water that you can use for
5 utilities. That's defined here. Then there's
6 manufacturing of aroma chemicals. Okay.
7 Specifically does the aroma chemical manufacturer
8 contribute
9 to --
10 MS. McFAWN: The TDS?
11 MR. KLOOTWYK: No.
12 MS. McFAWN: Okay. Thank you, and thank you
13 for making that distinction.
14 Do you and do any of the people that have
15 testified or does anyone else know, I am not
16 familiar with CIWC, what other discharges does it
17 accept? Does it service all of University Park?
18 MS. SAIELLI: That's on the petition. They do;
19 the residences and approximately 60 industrial
20 dischargers.
21 MS. FELTON: Sir, just one second, sir. I just
22 want to note for the record that there do appear to
23 be two individuals here, perhaps from the community
24 and, sir, if you would like to respond, I'd ask you
L.A. REPORTING (312) 419-9292
27
1 to stand up and just please be sworn in.
2 MS. McFAWN: Your name is?
3 MR. GRUBERMANN: My name is Mike Grubermann.
4 I'm the village manager for the village of
5 University Park.
6 MS. FELTON: Thank you, and we'll ask the court
7 reporter to swear you in.
8 (Witness sworn.)
9 MS. FELTON: Thank you, sir. If you'd like to
10 respond, thank you.
11 MR. GRUBERMANN: Yeah. They service the
12 entirety of the village of University Park in
13 addition to certain unincorporated areas, which are
14 surrounded by but not incorporated in the village,
15 and also by contract service, the entire sewer
16 system from the village of Monee, which is
17 immediately south of our industrial park, and an
18 earlier question was in relation to -- somebody had
19 asked in relation to the depth of the wells, I
20 believe the majority of the wells here are about 490
21 feet at the water level and there is a high level of
22 dissolved solids, a lot of iron, limestone, so there
23 are -- there's a lot in there that needs to be --
24 that needs to be worked out if you're doing anything
L.A. REPORTING (312) 419-9292
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1 with the water. Most of us soften our own.
2 MS. McFAWN: We've learned then that there are
3 other manufacturing concerns that discharge to CIWC.
4 Would they -- any of them suffer the problem that
5 the raw water coming in contains such high solids
6 that they just pass it along to CIWC?
7 MR. GRUBERMANN: I would say so. Originally --
8 I mean, this is from Nutrasweet. Nutrasweet tested
9 their water and they actually discontinued
10 purchasing water -- water bottles. They
11 discontinued purchasing water that way. They
12 discontinued using drinking water directly to
13 faucets and ran their processed work to their
14 drinking fountains simply because of the fact that
15 they cleaned it up before it got used.
16 MS. McFAWN: So in layman's terms, they were
17 then using their water -- the water which had been
18 softened inside Nutrasweet?
19 MR. GRUBERMANN: Right. They were doing
20 reverse osmosis so they were using that as drinking
21 water inside of Nutrasweet because it was of better
22 quality than they could even buy from Hinckley &
23 Schmitt. For example, that way the crest around
24 your hot water spout, it's no different than what we
L.A. REPORTING (312) 419-9292
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1 are getting here.
2 MS. McFAWN: So if the manufacturing concerns
3 that discharge to CIWC accept the raw water from the
4 water supplier -- who is the water supplier, is it
5 CIWC?
6 MR. GRUBERMANN: Yes. They're the supplier.
7 MS. McFAWN: Okay. So if they accept the raw
8 water there, they, too, probably have to soften or
9 just use it --
10 MR. GRUBERMANN: Some do, some don't. We've
11 got a lot of -- probably 50 or 60 percent of the
12 homes here soften and that's all discharged. When
13 the softener regenerates, that's all discharged to
14 the system, but, you know, the industrial plants, a
15 lot of them don't bother treating it because they
16 might have, you know, ten, 15 employees and not
17 actually do anything -- anything that has to do with
18 water other than drinking it and flushing a toilet.
19 Ms. McFAWN: Okay. Good point. Thank you.
20 MR. GRUBERMANN: Most of them import water to
21 run their coffee for dissolved solids.
22 MS. FELTON: Thank you. Are there any further
23 questions for any of the witnesses or any of the
24 other parties?
L.A. REPORTING (312) 419-9292
30
1 MS. McFAWN: I kind of -- I wonder, do we have
2 a copy of your operating permit?
3 MS. SAIELLI: I don't believe we attached it to
4 the petition.
5 MS. McFAWN: Could we have a copy submitted to
6 the Board and just -- the Agency, of course, would
7 have a copy of that.
8 MR. WARRINGTON: We didn't bring one with us.
9 I'm sorry.
10 MS. McFAWN: That's okay.
11 MS. SAIELLI: I don't have a copy to give you.
12 We'll send you one.
13 MS. McFAWN: Okay. Fine. That would be fine.
14 Do you have a copy with you, though?
15 MS. SAIELLI: Yeah.
16 MS. McFAWN: Oh, could we take a moment to look
17 at it, please?
18 MS. SAIELLI: This is the original.
19 MS. McFAWN: We won't mark it up.
20 MS. McFAWN: All right. Could we just take a
21 few minutes off the record then?
22 MS. FELTON: Actually, before we go off the
23 record, I just want to confirm that the petitioner
24 will provide a copy to the Board of the operating
L.A. REPORTING (312) 419-9292
31
1 permit?
2 MS. SAIELLI: Sure.
3 MS. FELTON: Okay. And that -- as long as -- I
4 will just direct them to do that by the time that
5 the record closes in this record, which we'll
6 clarify that at the end. That will be a few weeks
7 after the transcript is available. Thanks. We'll
8 go off the record for a second.
9 (Whereupon, a discussion
10 was had off the record.)
11 MS. FELTON: Back on the record.
12 MS. McFAWN: Thank you for letting me take a
13 look at your permit and, as we agreed, we'll get
14 copies at the conclusion of this hearing.
15 I just have a couple questions about how
16 the permit works especially in conjunction with the
17 adjusted standard which was granted to Nutrasweet
18 and CIWC.
19 According to that permit, after reviewing
20 it, Special Condition No. 6 requires that you not
21 exceed 1,000 milligrams per liter on a daily maximum
22 limit of TDS and that you are to test three times a
23 week -- a daily sample three days a week for that,
24 is that right?
L.A. REPORTING (312) 419-9292
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1 MS. SAIELLI: It's subject -- it was subject to
2 the provisional variance -- upon expiration of the
3 provisional variance.
4 MS. McFAWN: Okay.
5 MS. SAIELLI: They were supposed to do that.
6 MS. McFAWN: Right. So I assume that that's
7 now how you're operating because the provisional has
8 expired?
9 MS. SAIELLI: Correct. We've asked that the
10 adjusted standard be made to apply to the
11 expiration.
12 MS. McFAWN: Okay. Now, if my familiarity with
13 the past adjusted standard tells me that these were
14 standard -- these were the conditions that
15 Nutrasweet also agreed to?
16 MS. SAIELLI: They did not agree to 1,000
17 milligrams per liter discharge. They agreed to
18 count not concentration limits, but pounds per day,
19 mass limit.
20 MS. McFAWN: Oh, okay. Well, thank you. I
21 thought this was what was agreed to. How come the
22 change?
23 MS. SAIELLI: I believe it might have been an
24 error on part of the IEPA, but I'm not sure.
L.A. REPORTING (312) 419-9292
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1 MS. McFAWN: An error now or as was now?
2 MS. SAIELLI: Now.
3 MS. McFAWN: Now? So you want to keep the mass
4 limit?
5 MR. WARRINGTON: They, I believe, do want to
6 keep the mass limit.
7 MS. SAIELLI: We requested the mass limit and
8 IEPA is agreeing.
9 MS. McFAWN: Okay. I see. All right. So
10 these types of conditions were also in the operating
11 permit that Nutrasweet held?
12 MS. SAIELLI: The mass limit.
13 MS. McFAWN: The mass limits, and that was
14 because of the adjusted standard?
15 MS. SAIELLI: Yes.
16 MS. McFAWN: So is that the only thing
17 obligating Nutrasweet or Takasago to do this or is
18 there a contractual obligation between CIWC and
19 Nutrasweet/Takasago?
20 MS. SAIELLI: I don't believe so.
21 MS. McFAWN: No?
22 MR. KLOOTWYK: No. We have no contractual
23 agreement between our company and CIWC.
24 MS. McFAWN: Concerning TDS?
L.A. REPORTING (312) 419-9292
34
1 MR. KLOOTWYK: That's correct.
2 MS. McFAWN: Do you have a contractual
3 agreement otherwise?
4 MR. KLOOTWYK: CIWC just bills us according to
5 the -- I believe it's the Illinois Commerce
6 Commission that sets the --
7 MS. McFAWN: The rates?
8 MR. KLOOTWYK: -- rates and loads.
9 MS. McFAWN: Okay.
10 MR. KLOOTWYK: And has that forwarded to us.
11 MS. McFAWN: Okay. All right. A little
12 earlier, I asked you to look at Section 309.204,
13 which is the operating permits for existing sources
14 and that it says that operating permits are not
15 required unless you discharge -- one of those
16 qualifying paragraphs was No. 2; unless you
17 discharge 15 percent or more of the total hydraulic
18 flow received by the treatment works. Would
19 Takasago contribute more than 15 percent of the
20 total hydraulic flow, do you know?
21 MR. KLOOTWYK: Their total flow -- their total
22 flow out of the plant?
23 MS. McFAWN: Received by the plant.
24 MR. KLOOTWYK: Received? I don't know what
L.A. REPORTING (312) 419-9292
35
1 their total flow received is. We only know the
2 information discharging out of the plant.
3 MS. McFAWN: Okay. All right. Mr. Warrington,
4 can you tell me -- I understand that Takasago has a
5 pretreatment permit because -- subject to the
6 categorical standards.
7 MR. WARRINGTON: Right. They fall into that
8 first exclusion from the exemption --
9 MS. McFAWN: Correct. Does the Agency -- can
10 you tell me has the Agency issued the operating
11 permits subject to Paragraph 2 or 3, one being the
12 15 percent or more of the total hydraulic flow
13 received and, one being 15 percent or more of the
14 total biological loading received?
15 MR. WARRINGTON: Not to my knowledge. From
16 reviewing that particular section of the
17 regulations, it appears that they are a source
18 that's regulated under Section 307 of the Clean
19 Water Act, which is, I believe, is the pretreatment
20 program or the categorical standards. We've heard
21 testimony today that they are regulated under 40
22 CFR, I believe, it's Part 414, is that correct?
23 MS. McFAWN: Okay. But my question was more
24 general. Have -- does the Agency -- you might not
L.A. REPORTING (312) 419-9292
36
1 know the answer, but what I'm curious about is the
2 Agency issuing permits to a waste water source
3 because it's discharge is more than 15 percent of
4 the -- 15 percent or more of the total hydraulic
5 flow received by a treatment works? Do you know of
6 any incidence of that?
7 MR. WARRINGTON: I recall that situation, but I
8 can't recall who it was or when it was. There are
9 cases where you have your relatively small
10 municipality with a publically-owned treatment works
11 and one or two large industrial contributors to that
12 system.
13 MS. McFAWN: But what we would need is a --
14 MR. WARRINGTON: A particular name that, you
15 know, would be that situation, I can't recall.
16 MS. McFAWN: What we would really need is that
17 situation where you have a publically regulated
18 treatment works as opposed to a POTW.
19 MR. WARRINGTON: Oh, okay. I couldn't
20 distinguish between the two in my memory. I don't
21 know.
22 MS. McFAWN: Okay. Do you know -- do you ever
23 issue permits to waste water sources?
24 MR. WARRINGTON: Well, yes.
L.A. REPORTING (312) 419-9292
37
1 MS. McFAWN: That are indirect dischargers?
2 MR. WARRINGTON: Correct. If they fall under a
3 categorical standard or if they're a large, either
4 organic contributor, or a hydraulic contributor,
5 then they are obligated to receive, upon
6 implication, an indirect discharger permit or a
7 construction and operating permit.
8 One example, I think, has come to mind is
9 that I believe it's a town that has a dairy. The
10 wash waters and waste waters from the dairy are
11 fairly high in organic loading such that we require
12 them to pretreat that waste water before it is sent
13 into the sewer through the waste water treatment
14 plant.
15 MS. McFAWN: Have you ever issued such a permit
16 to a company that doesn't -- or I mean to a
17 discharger, an indirect discharger, that doesn't
18 pretreat?
19 MR. WARRINGTON: It is possible. Under the
20 federal pretreatment program, there are options
21 where the receiving treatment works or the control
22 authority can make contractual or binding
23 obligations with an indirect discharger that
24 otherwise would have to limit the indirect
L.A. REPORTING (312) 419-9292
38
1 dischargers to a certain numerical or percentage
2 amount that the -- that nonetheless the receiving
3 waste water treatment plant can still accept them.
4 Usually, that means that the receiving waste water
5 treatment plant can more economically treat the
6 increased loading than the indirect discharger could
7 and usually you have a contract with financial
8 compensation to arrange for that.
9 MS. McFAWN: Okay. But then in that instance,
10 would the Agency issue an operating permit to the --
11 MR. WARRINGTON: They would still meet the
12 trigger of contributing no more than X amount of
13 hydraulic or organic loading. They still require a
14 construction permit or an operating permit if for no
15 other reason than they have a sewer constructed from
16 the indirect discharger to the treatment plant.
17 MS. McFAWN: Okay. So they would have to
18 trigger one of these requirements in 309.204?
19 MR. KLOOTWYK: That's correct.
20 MS. McFAWN: A question for Takasago, you
21 mentioned that you purchased the Nutrasweet facility
22 in 1996, was that correct?
23 MS. SAIELLI: Yes.
24 MS. McFAWN: And I was wondering what happened
L.A. REPORTING (312) 419-9292
39
1 between 1996 and this middle of this AS?
2 MS. SAIELLI: Mr. Klootwyk?
3 MR. KLOOTWYK: What happened between 1996
4 and --
5 MS. McFAWN: This middle of your adjusted
6 standard petition, when Takasago has owned it for
7 three years or about --
8 MR. KLOOTWYK: Yeah. In August -- roughly
9 around August 1st of 1996, Nutrasweet literally
10 handed over the plant keys, if you would, to
11 Takasago. Takasago then spent roughly two years
12 decommissioning, if you would, looking at
13 engineering, new facilities on the site. In
14 roughly, I believe it was mid-1998, they filed with
15 the air division in operating a construction permit
16 to commence construction at which time the plant
17 was -- 1997, okay. In 1997, they sought an
18 operating and construction permit in construction.
19 Upon receiving that permit, approval for operating
20 and constructing, they began building in
21 mid-December. Well, I should say September of 1997.
22 It was under construction until -- as of late --
23 actually, the actual first production facility was
24 brought on-line July of this year. Yeah, July of
L.A. REPORTING (312) 419-9292
40
1 1999.
2 MS. McFAWN: So between the purchase in July of
3 1999, you weren't producing?
4 MR. KLOOTWYK: There was a limited amount of
5 production water being generated and I'll clarify.
6 The building was still needing, for sanitary
7 purposes, restrooms. Water was still brought into
8 the plant for sanitary purposes. During the winter,
9 they had to fire up, if you would, a boiler -- a big
10 boiler unit because that was the only way to heat
11 the building, the office area. Okay?
12 So they did that for two winters where
13 they brought boilers up, and then brought them down,
14 but every time they brought that boiler up they had
15 to bring the pretreatment water -- pretreatment
16 processes up because you cannot feed that kind of
17 water into a boiler. It's very dangerous. It will
18 clog the tubes and you'll have a failure and cause a
19 significant explosion. So during the winter months,
20 they did that.
21 Outside of that, they did bring boilers
22 down and still ran raw water into the plant for
23 sanitary purposes, softened accordingly and for
24 drinking water purposes, they did send it through
L.A. REPORTING (312) 419-9292
41
1 what they call reverse osmosis. We won't let the
2 people drink the water, raw water.
3 MS. McFAWN: So you weren't producing a
4 product, you were just maintaining the offices?
5 MR. KLOOTWYK: We were just maintaining the
6 facilities.
7 MS. McFAWN: At that time, did you have an
8 operating permit from the Illinois EPA, a water
9 operating permit, or did that come because of the
10 new processes?
11 MR. KLOOTWYK: That became because of the new
12 processes.
13 MS. McFAWN: Okay. So, for example, when
14 Nutrasweet got the AS, they didn't get an operating
15 permit from the Illinois EPA?
16 MR. KLOOTWYK: I believe they had a
17 pretreatment permit in hand.
18 MS. McFAWN: Oh, they did?
19 MR. KLOOTWYK: Yes.
20 MS. McFAWN: Even though they weren't subject
21 to Part 414?
22 MR. KLOOTWYK: Nutrasweet was subject to 414.
23 Ms. McFAWN: Oh, okay. I misunderstood. I
24 thought maybe something new that was added by
L.A. REPORTING (312) 419-9292
42
1 Takasago triggered that.
2 MR. KLOOTWYK: No.
3 MS. McFAWN: Thank you. So the adjusted
4 standard, if memory serves me correctly, that
5 Nutrasweet got had them actually doing stream
6 monitoring as well for TDS, is that right? No?
7 MR. KLOOTWYK: Nutrasweet -- being a former
8 Nutrasweet employee, they did monitor for TDS.
9 Their monitoring conditions and our monitoring
10 conditions are virtually identical.
11 MS. McFAWN: Okay.
12 MS. SAIELLI: The actual opinion is Exhibit B
13 to the petition.
14 MS. McFAWN: Thank you.
15 MS. FELTON: Ms. Saielli, could you confirm
16 under which zoning classification the petitioner
17 cited?
18 MS. SAIELLI: It's zoned industrial.
19 MS. FELTON: Thank you. We're going to take a
20 brief five-minute break, if that's okay. We'll
21 reconvene -- it's 11:40. We'll reconvene at 11:45.
22 Thanks.
23
24
L.A. REPORTING (312) 419-9292
43
1 (Whereupon, after a short
2 break was had, the
3 following proceedings
4 were held accordingly.)
5 MS. McFAWN: If I could get a copy of
6 Nutrasweet's operating permit and Takasago's and
7 have those submitted to the record, and
8 Mr. Warrington, if you could provide us a copy with
9 the permit for CIWC.
10 MR. WARRINGTON: The NPDS permit.
11 MS. McFAWN: Yeah., is it already in the
12 exhibit?
13 MS. SAIELLI: I think they just got reissued
14 the new one. The old one was --
15 MS. McFAWN: Depending on it's length, what
16 I'm most interested in, of course, I can't imagine
17 that's it's very lengthy, but I want to see how you
18 wrote the conditions for their AS is what I'd like
19 to see. You can submit that by mail, you know,
20 through the clerk's office with a copy to the
21 hearing officer, that would be helpful.
22 MS. SAIELLI: Just an original and one or --
23 MS. FELTON: Actually, original and nine and
24 then one to me. Thanks.
L.A. REPORTING (312) 419-9292
44
1 MR. WARRINGTON: Got it.
2 MS. FELTON: You can file a motion to waive
3 but --
4 MS. McFAWN: You don't have to do that today.
5 I meant this is more, you know, after the close of
6 the hearing, you can submit these.
7 MR. WARRINGTON: How many copies would you
8 like?
9 MS. FELTON: Original and nine.
10 MR. WARRINGTON: Original and nine?
11 MS. McFAWN: Right.
12 MS. FELTON: So basically I just confirmed that
13 copies of Nutrasweet's operating permit, Takasago's
14 operating permit, and CIWC's current permit will be
15 provided to the Board pursuant to our procedural
16 rules by the time that the record closes in this
17 matter, which we will establish in just a few
18 minutes.
19 Are there any other questions?
20 Ms. McFAWN: I don't have any questions, but I
21 do want to thank you for listening to my questions
22 and indulging me. I'm having a little trouble
23 getting the history on this and getting it current
24 so I certainly appreciate you supplying the
L.A. REPORTING (312) 419-9292
45
1 information.
2 MS. FELTON: Are there any other questions on
3 behalf of the Board or staff? All right. Are there
4 any other questions on behalf of any interested
5 parties?
6 Seeing as there do not appear to be any
7 with us at this time, we will proceed with closing
8 statements if the parties would like to make them.
9 If they would like to waive them, that's fine.
10 MS. SAIELLI: We'll waive.
11 MS. FELTON: Okay.
12 MR. WARRINGTON: The Agency will waive a
13 closing statement.
14 MS. FELTON: Okay. Are there any additional
15 motions that the parties would like to present to
16 the Board for its deliberation on behalf of the
17 petitioner or the respondent?
18 MR. WARRINGTON: No.
19 MS. FELTON: Okay. Let's just go off the
20 record just for a second.
21 (Whereupon, a discussion
22 was had off the record.)
23 MS. FELTON: We'll go back on the record.
24 Just to clarify, the parties have
L.A. REPORTING (312) 419-9292
46
1 expressed and represented that they will be waiving
2 the post-hearing brief schedule. Consequently, I
3 will set forth sort of the time frame for closing
4 the record in this matter.
5 It appears that the transcript in this
6 matter will be available on or about Monday, January
7 3rd, 2000. Based on that, all post-hearing comments
8 must be filed with the Board two weeks after the
9 transcript is available, which I deem to be January
10 17th, 2000.
11 However, if there are public comments, I
12 am going to set forth a briefing schedule for the
13 parties to respond to those comments in the event
14 that they are filed. If no comments are received by
15 January 17th, 2000, the record will close on that
16 date, and that's the time at which we would request
17 all of the permits be filed. However, if any public
18 comments are filed, the parties will adhere to the
19 following briefing schedule: Petitioner's would be
20 due on January 31st, 2000; and respondent's brief
21 would be due on February 14th, and if any comments
22 are filed and there is this briefing schedule, if we
23 proceed with the briefing schedule, the record will
24 close on February 14th, 2000, upon the date that the
L.A. REPORTING (312) 419-9292
47
1 respondent's brief is due.
2 Just to confirm and clarify, the mailbox
3 book rule as set forth at 35 Illinois Code 101.102 D
4 and 101 -- strike that.
5 101.144 C will apply to all posthearing
6 filings. All post-hearing comments must be filed in
7 accordance with Section 106.807 of the Board's
8 procedural rules. Mr. Warrington?
9 MR. WARRINGTON: Will the transcript be posted
10 on the Board's internet site?
11 MS. FELTON: It is my understanding that the
12 transcript will be posted on the Board's website and
13 now that we have somebody handling that full-time,
14 it should be fairly immediately available on their
15 website.
16 MR. WARRINGTON: Thank you.
17 MS. FELTON: Do you have our website address?
18 MR. WARRINGTON: We do.
19 MS. FELTON: Great. Okay. Are there any other
20 matters which need to be addressed at this time?
21 Seeing that there are no additional matters, this
22 hearing is adjourned and we thank you for your
23 attendance and participation in this matter and
24 happy holidays. Thank you.
L.A. REPORTING (312) 419-9292
48
1 MR. WARRINGTON: Thank you.
2 (Whereupon, no further
3 proceedings were had in
4 the above-entitled
5 cause.)
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L.A. REPORTING (312) 419-9292
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1 STATE OF ILLINOIS )
2 ) SS.
3 COUNTY OF C O O K )
4
5
6 I, TERRY A. STRONER, CSR, do
7 hereby state that I am a court reporter doing
8 business in the City of Chicago, County of Cook, and
9 State of Illinois; that I reported by means of
10 machine shorthand the proceedings held in the
11 foregoing cause, and that the foregoing is a true
12 and correct transcript of my shorthand notes so
13 taken as aforesaid.
14
15
16 _____________________
17 Terry A. Stroner, CSR
18 Notary Public, Cook County,
Illinois
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L.A. REPORTING (312) 419-9292