RECEIVED
CLERK’S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
MAY
2
12003
IN
TEE
MATTER OF:
PROPOSED SITE-SPECIFIC
WATER POLLUTION
REGULATIONS APPLICABLE
TO
TIlE
CITY OF EFFINGHAM,
BLUE BEACON
INTERNATIONAL, INC.
AND
TRUCKOMAT CORPORATION
)
)
)
STATE OF ILLINOIS
Pollution
Control Board
R03-11
)
(Site Specific Rulemaking
-
Water)
)
)
)
)
NOTICE OF FILING
Dorothy M. Gunn, Clerk
Illinois PollutionControl Board
James R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois
60601
David M. Walter
N. LaDonna Driver
Hodge, Dwyer, Zeman
3150 Roland Avenue
Post Office Box
5776
Springfield, Illinois
62705-5776
JohnKnittle, Hearing Officer
Illinois Pollution Control Board
1717 PhiloRoad, Suite
25
Urbana, Illinois
61802
Matthew Hortenstine
122East Washington
Post Office Box 668
Effmgham,
Illinois
62401
PLEASE
TAKE
NOTICE
that
I have today filed with the Office ofthe Clerk ofthe
Pollution Control Board the POST-HEARING COMMENTS ofthe fllinois Environmental
Protection Agency, a copy ofwhich is herewith served upon you.
ENVIRONMENTAL PROTECTION AGENCY
OF
THE
STATE
OF ILLINOIS
Deborah J. Willia
s
Assistant Counsel
Division ofLegal Counsel
DATED:
May 19, 2003
Illinois Environmental Protection Agency
1021
North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
)
)
THIS
FILING
IS
SUBMITTED
ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ERTc’S
OFFir~
M~4y21
‘INTHEMATTEROF:
)
3
)
R
03-11
STATE OF
ILLINOIS
PROPOSED SITE-SPECIFIC WATER
)
(Site Specific
N&ki~g~tro/BoQrd
POLLUTION
REGULATIONS
APPLICABLE
)
Water)
TO
THECITY
OF EFFINGHAM,
BLUE.
)
•BEACON
INTERNATIONAL, INC. AND
)
TRUCKOMAT CORPORATION
)
)
POST-HEARING
COMMENTS OF THE
ILLINOIS ENVIORNMENTAL
PROTECTION AGENCY
INTRODUCTION
On October 22,
2002, the City of Effingham
(“City”),
Blue
Beacon
International,
Inc. (“BBI”),
and Truckomat Corporation (“Truckomat”)(referred to collectively as
“Effingham” or “Petitioners”) filed a site-specific rulemaking proposal with the
Illinois
Pollution Control Board (“Board”)
pursuant to Section 27 of the
Illinois Environmental
Protection Act (“Act”). 415
ILCS 5/27.
Effingham has proposed to change the fluoride
standard applicable to the discharge from the
City’s wastewater treatment plant from
1.4
milligrams per liter (“mg/L”) to 4.5 m~/L.Specifically, Petitioners have requested relief
from
35
Ill. Adm.
Code 304.105 as it applies to the water quality standard for fluoride at
35
Ill. Adm.
Code
302.208(g).
The Illinois EPAsupports the granting of regulatory relief,
but has recommended that relief be granted
instead from the general use water quality
standard
in 35
Ill. Adm. Code 302.208(g).
On April
11, 2003 a
hearing was
held
in the City of Effingham on the site-specific
rulemaking proposal.
Prior to the hearing,
pre-filed testimony was submitted by the
Petitioners and the
Illinois
EPA.
After submittal of the pre-flled testimony,
a hearing
officer order was
issued on March
21, 2003 containing questions the
Board
staff
intended to ask the Petitioners at the hearing.
On April 4, 2003, Petitioners submitted
written
responses to the Board’s questions.
At the April
11, 2003 hearing several
witnesses testified on behalf of the Petitioners
and Deborah Williams and Scott Twait
presented testimony and answered questions on behalf of the Illinois EPA.
Additional information was requested by the Board on some of the issues
discussed at the hearing.
Responses to these items are presented
in the Illinois EPA’s
post-hearing comments and attachments.
Upon review of the transcript, the Illinois EPA
feels there are also some
issues that merit additional clarification or discussion.
ADDITIONAL INFORMATION REQUESTED BY THE BOARD
Permanency of site-specific relief and the Clean Water Act
After questioning by the Board staff and testimony from the parties
regarding the
proper format for the requested
relief, the hearing officer asked the parties
to address,.
in their post-hearing comments, the issue of the permanency of any relief granted and
the Board’s authority to grant permanent relief under the Clean Water Act
Transcript of
April
11, 2003 hearing (“Tr.”) at 74-75.
The Agency has argued in
its
pre-filed testimony
that relief from
35111.
Adm. Code 304.105,
as requested by the
Petitioners,
would be
inconsistent with the Clean Water Act.
33 U.S.C. ~1251-1387.
The basis for this
conclusion is that it would be an attempt to avoid the process for setting and gaining
approval from the United States Environmental Protection Agency (“U.S. EPA”) of water
quality standards.
In addition,
it would be granting a permanent license to violate the
water quality standards for which there
is
no comparab!e federal provision.
The
appropriate relief to grant in this matter is
in the form of a site-specific water
quality standard that would be sent to. U.S. EPA forapproval.
At this time and with the
2
scientific information available,
the
Illinois EPA believes this is a scientifiôally sound
standard that should apply permanently
to the applicable reach of stream.
The
Illinois
EPA does not believe there is any reason to limit the term of the relief granted
by a
sunset provision
and in that sense the Board has authorityto grant “permanent” relief.
However,
Section 303 of the Clean Water Act requires States to perform “triennial
reviews” of its water quality standards.
33 U.S.C.
§1313.
If, at some
point, one of these
reviews indicates that the science underlying this proceeding was faulty or outdated, the
Agency and the Board woUld be obligated to revisit the relief granted in this case.
The Agency is
also in agreement with the modeling conducted by the Petitioners
that demonstrates a water quality standard of 5.0 mg/L will not be violated with an
effluent limit of 4.5 mg/L and that 4.5 mg/L effluent limit will also ensure that the fluoride
level at the City of Flora public water supply intake will not exceed
2.0 mg/L.
However,
if additional sampling and the passage of time reveals that this information
is faulty and
those water quality standards are not, being met, the Agencywould also have to revisit
the issue either through the permit renewal process or possibly through finding the
water body impaired for fluoride which would require the Illinois EPA to establish
a load
limit that would bring the waterbody into attainment.
This process also might force
imposition of more stringent relief on the Petitioners than the relief granted by the
Board.
It is also possible that additional requirements could be adopted by the General
Assembly or
U.S.
EPA that would require a
revisiting of the relief granted
in this case.
The Illinois
EPA understands
Petitioners concerns that’ its
future expectations are
protected and
believes that the relief the Illinois EPA has recommended in this case will
protect those expectations to the greatest extent allowable by law.
3
Endangered or Threatened Species
The
Board inquired at the April
‘11, 2003 hearing whether Petitioners would be
willing to contact the Illinois Department of Natural Resources (“IDNR”) regarding any
potential impacts on any endangered or threatened species in the relevant stream
segment.
Tr.
at 81.
At that time the Illinois EPA offered to provide additional
information
in post-hearing comments regarding any consultations that may have been
conducted with
IDNR.
The Agency consulted with the IDNR and they replied on April
14,
2003, that there were no threatened or endangered species present in the affected
stream reach.
See Attachment A.
Notification to the City of Flora
Finally, the Board requested additional information
on how the
City of Flora
would
be, notified
if the water quality standard of 2.0 mg/L was being exceeded at its
public water supply intake.
Tr. at
64-65.
As discussed by the Agency in its testimony,
the
City of Effingham would have the obligation to prevent this situation from occurring
in the first place.
Monitoring would be conducted as low flow conditions are approached
and measures would be implemented to reduce fluoride concentrations prior to any
exceedances at Flora.
These affirmative steps on the part of the
City
and
its industrial
fluoride dischargers would be mandated by a speciaF condition of Effingham’s
National
Pollutant Discharge
Elimination System (“NPDES”) permit to decrease fluoride
concentrations at Flora.
In addition, the
Illinois EPA is willing to implement or require
Effingharn to implement appropriate notifications
tO the City of Flora
if
requested by the
Board.
4
CLARIFICATIONS OF HEARING TESTIMONY
The
Illinois
EPA would also
like to use these Post-Hearing
Comments as an
opportunity to clarify
some testirnbny by both the
Petitioners and the
Illinois EPA as the
April
11, 2003 hearing
with particular emphasis on
the
impact site-specific relief from the
general use water quality standard would have on other dischargers.
Clarifications of Petitioners’ Testimony
At the hearing,
counsel for Petitioners discussed the reasoning behind their
conclusion that the site-specific relief granted by the Board should
inclUde the language
“subject to the averaging rule of Section 304.104.”
Tr.
at
15.
While the Illinois EPA is
not clear on the Petitioners’ position
regarding this
language,
it still does not think
inclusion of this language is appropriate or necessary.
As noted
in the Agency’s pre-
filed testimony on page
13, the Agency believes that the phrase “subject to the
averaging rule of Section 304.104” should
be. removed
from the language of the site-
specific rule.
It is the Agency’s opinion that this language does not provide any
additional relief to the Petitioners and would only serve to cause confusion.
Petitioners also testified that the Board
had authority to ‘grant relief from
35
III.
Adm.
Code 304.105 and the Illinois EPA
had authority to issue an NPDES permit
incorporating such
relief based on 40 CFR 131.13.
Tr. at 14.
Petitioner cites to this
section for the proposition that the Board has authority to grant relief from the
requirement that. one’s effluent not cause a violation of a water quality standard based
on its discretion under the federal regulations “regarding
implementation of its water
quality standards,
including how the standard applies during low flows.”
Tr. at
14.
The
Illinois EPA disagrees that the relief in this case applies or is
necessary only during low
5
flows.
In addition, the Board has established
its
implementation rules for low flows in
the mixing zone regulations found at 35
Ill. Adm. Code 302.102.
It is the requirement of
Section 302.102(b)(8) of the mixing zone regulations that no mixing zone
is available in
waters “which have
a. zero minimum seven day low flow which occurs once
in ten years”
(“7Q10”) which, in part, necessitates this rulemaking.
In
addition, the Board has
determined
in 35
III. Adm. Code 302.103 that water quality standards “apply at all times
except during periods when flows are less than the
7Q10.”
Therefore, the Illinois EPA
disagrees with Petitioners contention that 40 C.F.R. .131.13, gives the Board authority to
grant relief from Section 304.105.
,
The Illinois
EPA also disagrees with Petitioners’ interpretation of the letter from
‘U.S.
EPA to Illinois
EPA regarding the John Deere site-specific rulemaking that the only
concern expressed by U.S.
EPA was that they had
been unaware of the
relief.
Tr. at
14-15.
The
basis for U.S.
EPA’s concern about being unaware of the relief granted by
the Board was that relief from
304.105 was viewed as an attempt to avoid changing a
water quality standard that U.S.
EPA was entitled to review and approve.
It does not
make sense to suggest that U.S.
EPA would
not have objected
had
thOy merely
received’ notification ofthe relief from the Illinois EPA,
but not a chance to approve the
water quality standard change.
Impact
of relief from the water quality standard on other dischargers
A significant portion of the testimony and questioning at the April
11, 2003
hearing addressed the impact of granting relief from
35’ III. Adm.
Code 302.208(g) on
other dischargers.
Several aspects of that discussion merit clarification.
6
Counsel for Petitioners,
Mr. Walter, discussed the Petitioners’ view that relief
from
the water quality standard alone would result in providing the same relief to any
other discharger along the stream segment without that discharger presenting
a case to
the Board to justify such relief.
In support of this position, Petitioners quoted a
discussion of this issue in the Board opinion
In the Matter of:
Petition of Rhone-Poulenc
Basic Chemicals Company and Thorn Creek Basin
Sanitary District for an Adjusted
Standard from
35
Ill.
Adm. Code 302.208 and 304.105, AS 94-7 (June 23,
1994).
The
language quoted was as follows:
.
To understand the circumstance,
it is
necessary to recognize first that for water
at a concentration of “X,.” anyadditional amount ofwater at concentration “X”
may be added, and the resultant concentration will remain at “X.”
Thus, for
example, under the relief requested,
if TCBSD were discharging such as to
caUse Thorn Creek to have a 2,100
mg/L TDS concentration at water treatment
plant outfall,
all other sources of discharge between the TCBSD outfall and the
USGS gauge
at Thorn Creek could
have a TDS
concentration of 2,100’
mg/L, and
all the mixed concentration through the whole reach would remain 2,100
mg/I.
Moreover,
it is within the mathematics ofthe situation that if’TCBSD were to
discharge so as to cause Thorn Creek to have a TDS
concentration below 2,100
mgIL,
the Agency would have TCBSD strive for all other sources of discharge
between the outfall, and the USG$ gauge could
have a TDS concentration above
2,100 mg/L without causing violation of a 2,100 mg/L in-stream
standard.
Tr.
at 47-48.
.
.
.
.
.
Although the
language quoted by Petitioners explains the basis for the Board’s
concerns over granting overly expansive relief,
there.are some technical deficiencies in
this analysis that should
be addressed.
This interpretation may be applicable for the
initial stream segment where
a site-specific water quality standard
is
in place, but
it is
not an accurate statement with regard to subsequent stream segments and the point
where the stream returns to the general use standard.
At the hearing, the Board asked
whether other dischargers would be allowed to take advantage of the relief
7
recommended by the Illinois EPA.
The Agency would like to supplement its testimony
with a more detailed explanation of if and when other dischargers could take advantage
of relief granted in the form of a site-specific Water quality standard for fluoride that
would be changed for specific stream reaches.
In addition to addressing whether a subsequent discharger would
be able to,
meet the water quality standard applicable at the point of discharge, the Agency is
required to assure that all other applicable water quality standards woUld continue to be
met in all affected stream, reaches.
If a discharger applied for a permit to the Agency to
discharge 0.95 million gallons per day with a cOncentration of 4.5 mg/L of fluoride, the
Agency would determine
if
the water quality standards would be met in Salt Creek at the
point of discharge and at points dOwnstream.
In this case, because of the limited
dilution available, the Agencywould determine that the water quality standards would
not be met and the discharger would be limited to a fluoride level that would assure that
the fluoride water quality standard would be t~net.This value may or may not be greater
than
1.4 mg/L.
On the other hand,
if a discharger applied for a permit to discharge 100
gallons per day with a concentration of 1.5 mg/L of fluoride, the Agency would again
look at all pertinent locations to determine
if the water quality standards would be
met.’
If it could
be’ shown that the water quality standards would be met,
and for this example
attainment is
likely, the Agency would permit the discharge.
The
operating criterion
is
the applicable water quality standard
in the receiving stream whether that be a site-
specific standard, a general use standard, or a public
and food processing water supply
intake standard.
.
.
8
This
is also why the Agency typically recommends that relief be granted
in the
form of a site-specific or adjusted water quality standard with’specific limitations
designated for various stream segments.
The three distinct stream’ segments outlined
in the Agency’s proposed
relief (see
below) are intended to guarantee
both that the
public water supply intake
is
protected at the City of Flora
~
that the relief is not.overly
expansive.
When the Petitioners suggest that a site-specific water quality standard
should
con’tain only two stream segments ratherthan the three segments contained in
the Illinois
EPA’s proposed
language, this would serve to grant more expansive relief
than necessary for a significant portion of the relevant ‘water body.
Tr.
at 52.
Impact of relief from the water quality standard
that is available only to
the
Petitioners
on other dischargers
At the hearing Mr.
Hortensihe, counsel for the City of Effingham, made the
following statement in reference to the scenario proposed by the ‘Board where relief
would be granted from the water quality standard
in Section 302.208(g) but apply only
to the Petitioners:’
As
I understand, you’re saying that the language that the Agency proposed
relative to the fact that a special condition would, be limited only to the City of
Effingham, and any other discharger of
any nature whatsoever in the stream
course would have to come back to the Board for further relief
if they discharge
fluoride?
Is that accurate?
(emphasis added).
To which Ms. Liu
of the Board ‘staff is ‘quoted as having
responded: “Yes.”
Tr. at 70..
The Illinois
EPA would like to take the opportunity to clarify that under the scenario
presented by the Board’s questioning, granting relief from the water quality standard
that was applicable only to the Petitioners,
it is possible there could be a. fluoride
discharger somewhere on the ‘length of stream impacted by this proceeding that could
meet the general
use water quality’ ‘standard.
That discharger would not need
9
regulatory relief.. As explained above,
in most hypothetical examples, a new discharger
would have the potential to cause a violation of the water quality standard at Flora.
But
in theory, if another discharger could comply with the
1.4 rng/L general
use water quality
standard
and
not cause a violation of 2.0 mg/L at Flora, they would not need to come to.
the Board for additional relief even under the scenario proposed by the Board where
relief would apply only to the. Petitioners.
Also,
if the Board decided to change the water quality standard
in the receiving
stream and
limit,the relief only to the Petitioners, there could be
a, circumstance where a
new discharger, who would normally be able to take advantage of mixing, would not be
able to do so as a result ofthe relief granted to the Petitioners.
If a discharger proposes
to discharge to a portion of the receiving
stream that has a flow rate greater than zero
and the background concentration was greater than
1.4 mg/L,
the discharger could not
take advantage of mixing.
.
.,
.
.
.
The
Illinois EPA
believes that the appropriate relief to grant to Petitioners
in this
matter is to ,grant relief from
302.208(g) for three distinct reaches of stream as provided
in the language below.
In addition, from
a
technical perspective, the Agency’does not
think there will be many,
if any, situations in Which other dischargers could take
advantage of relief granted to the Petitioners in this matter.
As Scott Twait ‘stated
in his
hearing testimony:
“If there was another discharger that would
like to discharge a larger
amount of fluoride to the receiving
stream, their additional amount would either change
the concentrations in the receiving
stream above what we’re granting and/or change the
length ,of the adjusted stream.”
Tr. at 46.
However, the Illinois EPA maintains the
position of its
pre-filed testimony that based on the nature of the relief requested (from a
10
water quality based effluent limit to a 7Q10 stream) and the type of technical
review’
conducted,
it.
is appropriate and preferable for the Board to g’rant relieffocusing on the
stream segment rather than
limiting the relief to the individual discharger.
As
Petitioners
pointed out, Section 27(a) of the Environmental
Protection Act gives the
Board authority to grant relief to individuals or sites.
In many cases
it is
more
appropriate to grant relief to individuals, but the Agency feels the most appropriate use
of the Board’s authority in this matter is to apply the relief granted to the “site” or the
stream segments’identified in the Agency’s recommended
language.
‘
Clarifications
of
Illinois
‘EPA’s Testimony
In the Illinois EPA’s hearing testimony, Scott Twait stated that the Board’s
fluoride water ‘quality standard was adOpted to protect aquatic life rather than to protect
public water supplies.
Tr.
at 91-92.
The
Illinois EPA would
like
clarify this statement by
drawing the Board’s attention to the petition for site-specific rulemaking in this matter in
which the Board’s 1972 opinion adopting a water quality standard of
1.4
mg/L for
fluoride is discussed (Section
D).
That
opinion
indicated that the fluoride general use
water quality standard was set’for aquatic life ‘protection and ‘would also assure
a
potable supply.
It does not ‘state specifically that the
1.4 mg/L was necessary to assure
a potable supply.
It is
the Illinois EPA’s opinion that some of the data that was relied
upon
in setting the original water quality standard decision
is outdated.
Finally, the Illinois EPA would like to point out either a typographical
error or a
misstatement by the Agency’s counsel on page
58 of the transcript that may make the
entire paragraph confusing.
Ms. Williams is
quoted as using the phrase “want to” where
it should
have been “would not.”
The
relevant sentence should
read:
“But when we
areS
11
.
doing our 305-B reports, when we go to determine whether the ‘water body
is
impaired,
we
would not
be forced to find this water body impaired for fluoride if the water quality
standard has been changed.”
Tr.
at 58.
Form of Relief and Suggested Language
The Agency’s pre-filed testimony focused primarily on whether relief should
be
granted to the Petitioners in the form of a site-specific water quality standard (relief from
35
III. Adm.
Code 302.208(g)) or relief from the requirement not to cause
a violation of a
water quality standard
(35
Ill. Adm.
Code 304.105).
In addition, the bulk of the Agency’s
testimony at the hearing addressed this topic.
The
Illinois EPA would
like to thank the
Board for the opportunity to express
in detail the basis for its position that permanent
relief from
304.105 would
be inconsistent with the Clean Water Act.
The Illinois EPA.
recognizes th’e Board’s concerns aboUt granting relief that is overly expansive and
beyond the justification presented by the Petitioners,
but’the Agency believes there are
technical reasons in this case why there
is little opportunity for other dischargers to take
advantage of the recommended
relief.
In addition,
before recommending that the Board
grant relief from
a water quality ,based
effluent limit in a proceeding where the relief
,granted
has no time limitation,
it
is the obligation of the Agency to review the technical’
information submitted and
any other information available to determine whether granting
the
requested. relief will protect the existing uses of the receiving stream
and, should only
submit a favorable recommendation where sufficient’evidence is available to Justify a
revised water quality standard for the segment of stream impacted.
Based on the
analysis conducted, the
BOard should not be concerned about the possibility that other
dischargers may receive a benefit
from
relief granted.
12
To facilitate the Board’s decision-making
in this matter, the Illinois
EPA
resubmits
the suggested language
from
its
pre-filed testimony:
Section
303.XXX.
Unnamed Tributary of Salt Creek, Salt Creek, and
Little
Wabash
River.
The fluoride general use water quality standard of SeOtion
302.208(g) shall not apply to the waters of the State which are
located from the.
point of discharge of the
POTW
located at 903
E.
Eiche Avenue in Effingharri,
Illinois, owned by the City of Effingham, to an unnamed tributary of Salt Creek,
said point
being
located
in
Effingham County, T8N,
R6E,
Sec. 28,
Lat: 39°06’24”,
Long: 88°31‘55”, to the confluence of said unnamed tributary with Salt
Creek; to
the confluence of Salt Creek with the Little Wabash
River; to the confluence of
Buck Creek and the Little Wabash
River.
Fluoride levels in such waters shall
meet a water quality standard for fluoride (STORET Number 00951) as set forth
‘below:
‘
‘
‘
a)
From the
point of discharge of the City of Effingham
POTW
to the
unnamed tributary to the confluence of the unnamed tributary with Salt
Creek and from the confluence of the unnamed tributary With
Salt Creek to
the confluence of Salt Creek with the Little Wabash
River, the fluoride
‘water quality standard shall be 5.0 rng/L.
b)
From the confluence of Salt Creek with the Little Wabash River to a point
on the Little Wabash’River
located
2.8 miles downstream of Louisville,
Illinois, the fluoride water quality standard shall be
.2 mg/L.
c)
From a point on the Little Wabash River located
2.8 miles downstream of
Louisville,
Illinois to the confluence of Buck Creek and the Little Wabash
River, a point on the Little Wabash River located
approximately 9.8 miles
downstream of Louisville, Illinois, the fluoride water
quality standard shall
be2.0,mg/L.
‘
‘
Respectfully submitted,
BiJwJ\J()&JL~j4q&JTh
Deborah J. Williams
Assistant Counsel
Division of Legal
Counsel
Date:
May
19,
2003
‘
Illinois Environmental. Protection Agency
‘
.
‘
1021
North GrandAvenue East
‘
‘
‘
P.O.
Box 19276
‘
.
Springfield, Illinois 62794-9276
13
‘
,
.
‘
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01
J,np~i.ldnrJ,~r&jJ.~s/cr~p/urreJorrejw,ra
)
STATE OF ILLINOIS
COUNTY OF
SANGAMON
PROOF OF SERVICE
I, the
undersigned,
on oath state that I have served the attached
POST-HEARING
COMMENTS
of the Illinois Environmental Protection Agency, upon the person to whom it is directed, by placing a
copy in an enveldpe addressed to:
‘
V
Dorothy M.
Gunn,
Clerk
Illinois
Pollution Control Board
James R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois
60601
(FirstClass Mail)
N. LaDonnaDriver
David M. Walter
Hodge, Dwyer, Zenian
3150 Roland Avenue
Post Office Box
5776
Springfield, Illinois
62705-5776
.
V
(FirstClass Mail)
John
Knittle,
Hearing Officer
Illinois
Pollution Control Board
1717 Philo Road, Suite
25
Urbana,
Illinois
61802
(First Class Mail)
Matthew
Hortenstine
122 East Washington
Post Office Box 668
Effingham, Illinois
62401
(First Class Mail)
and mailing it from Springfield, Illinois
on May 19, 2003 with sufficient postage
affixed as indicated
above.
~
SUBSCRIBED
AN)
SWORN TO BEFORE ME
this
19th
day ofMay
2003.
:~
OFFICIAL
SEAL
~
CYNTHIA L WOLFE
:~
NOTARY
PUBLIC, STATE
OF
ILLINOIS ~
i
MY COMMISSION
EXPIRES
3~2O-2oo7
:~
SS
)
)
)
)
TilTS FILJJ~G
IS SUBMITTED ON RECYCLED PAPER
