ILLINOIS POLLUTION CONTROL BOARD
    July 11,
    1991
    CWN
    CHEMICAL SERVICES, INC.,
    )
    )
    Petitioner,
    )
    v.
    )
    PCB 89—177
    )
    (Permit Appeal)
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY and
    )
    PEOPLE OF THE STATE
    )
    OF ILLINOIS,
    Respondents.
    ORDER OF THE
    BOARD
    (by J. Theodore Meyer):
    This matter
    is before the Board
    on
    CWN
    Chemical
    Services,
    Inc.
    ‘5
    (CWM) June 3,
    1991 supplement to the record.
    Although there
    was no motion with the June 3 filing,
    CWM
    seeks to supplement the
    record submitted by the Illinois Environmental Protection Agency
    (Agency).
    On June 11,
    1991, the Attorney General, on behalf of the
    Agency and the People of the State of Illinois,
    filed a response
    to
    CWM’s
    supplement.
    CWN
    filed
    a
    “response”
    to the
    Attorney
    General’s filing on June 17,
    1991.1
    It is well-settled that the Agency record in a permit appeal
    consists only of the information which the Agency considered
    or
    should have considered in making its permitting decision.
    (Alton
    Packaging
    CoriD. v
    Pollution Control
    Board
    (5th Dist.
    1987),
    162
    Ill.App.3d 731,
    516 N.E.2d 275,280,
    114 Ill.Dec.
    120; Joliet Sand
    & Gravel v. Pollution Control Board
    (3d Dist.1987),
    163 I11.App.3d
    830,
    516 N.E.
    2c1
    955,
    114 Ill.Dec.
    800.)
    CWN
    seeks to supplement
    the
    Agency
    record
    with
    its
    March
    1985
    RCRA
    Part
    B
    permit
    application
    for the Chicago incinerator
    (1985
    application),
    its
    April 1987 RCRA Part B draft permit application
    for the Chicago
    incinerator (1987 application), and with 1987 revisions to the RCRA
    1
    Although captioned a
    “response”,
    CWM’s June
    17
    filing is
    really a reply to the Attorney General’s response.
    The Board notes
    that Section 101.241(c) of our procedural rules states that there
    is no right to reply to a response, except as allowed by the Board
    or hearing officer.
    CWM
    did not submit a motion for leave to file
    a reply.
    Ordinarily the Board would not allow the reply
    in the
    absence of a motion.
    However, because
    CWM
    did not articulate its
    reasons for the supplement in the initial filing, the Board will
    accept the reply so that it may make a fully informed decision.
    124—29

    2
    Part B draft permit application
    (1987
    revisions).
    The Attorney
    General objects to the inclusion of all but one of the documents
    which
    CWM
    seeks to add to the record.
    The Attorney General notes
    that on April
    28,
    1989,
    CWM
    submitted a revised
    Part
    B permit
    application (1989 application) to the Agency.
    In the cover letter
    to that application,
    CWM
    stated “This revised Part
    B application
    is
    intended
    to
    replace
    the
    previously
    submitted
    documents
    in
    entirety.”
    (Ex. A to Attorney General response; also included in
    the
    record at Book
    A,
    Volume
    8,
    pp.
    1448-1450.)
    The Attorney
    General states that the Agency, at CWM’s request in the April 28,
    1989 letter, did not consider the information which pre-dates the
    April
    1989 application.
    Therefore,
    the Attorney General
    argues
    that most of the documents which
    CWM
    seeks to add to the record
    (including
    the
    1985
    and
    1987
    applications,
    and
    most
    of
    the
    documents which make up the 1987 revisions) were not considered by
    the Agency,
    since it pre-dated the 1989 application, and therefore
    should not be part of the record.
    The Attorney General objects to
    the inclusion of an August 11,
    1989 letter from
    a
    CWM
    consultant
    to
    Gary Westefer
    at the United
    States
    Environmental
    Protection
    Agency
    (USEPA)
    on the grounds that this correspondence is not in
    Agency
    files,
    that
    there
    is
    no
    indication that the Agency
    was
    copied,
    and that the
    correspondence was not
    considered
    in
    the
    Agency’s permit decision.
    There are several documents in the 1987
    revisions which the Attorney General
    states are already
    in the
    Agency record, and one document
    (addenda and errata to August 25,
    1989 NOD responses) to which the Attorney General does not object.
    In
    its
    reply,
    CWM
    argues
    that
    the
    documents
    at
    issue
    constitute part of the RCRA permit appeal process and are therefore
    proper
    supplements to the
    record.
    CWN
    states that the permit
    application process which ended in the September 1989 denial of the
    permit
    (the decision which has been appealed to the Board)
    began
    prior to the April 1989 application.
    CWM
    contends that the earlier
    submittals,
    in combination with the. 1989 application, document the
    overall decisionmaking process.
    Therefore,
    CWM
    maintains that the
    earlier documents should be a part of the record.
    After
    a
    review
    of
    the
    documents
    submitted
    by
    CWM
    and
    consideration
    of
    the arguments made
    by the
    parties,
    the
    Board
    denies
    CWN’s request to supplement the record with the 1985 and
    1987 applications, and the 1987 revisions.
    The only exception is
    the August 25, 1989 addenda and errata sheet.
    The Board finds that
    because
    CWM
    stated in its April 28,
    1989 letter to the Agency that
    the 1989 application was intended to replace the earlier documents
    in entirety,
    CWM
    cannot now claim that the Agency did consider or
    should
    have
    considered
    the
    earlier
    documents
    in
    making
    its
    permitting decision.
    CWM’s
    contention that the earlier documents
    are part of
    a continuing process might carry weight in the absence
    of
    CWM’s
    clearly
    stated
    intention
    to,
    in
    effect,
    withdraw the
    earlier applications.
    This is not a situation where the applicant
    simply amended its application.
    The language of the 1989 letter
    clearly
    states
    that
    the
    1989
    application
    will
    replace
    the
    124—30

    3
    previously
    submitted
    documents,
    making
    the
    1989
    application
    in
    effect an entirely new application.
    CWM’s request to supplement
    the record
    is denied,
    with the exception of the August
    25,
    1989
    addenda and errata sheet.
    IT IS SO ORDERED.
    I,
    Dorothy M.
    Gunn,
    Clerk of the Illinois Pollution Control
    Board
    hereby
    ce
    ~fy,that the
    above
    Order was
    adopted on
    the
    //~
    day of
    _______________,
    1991, by a vote of
    7-&
    ~
    /~
    //~/
    Dorothy M.
    Gj4fin,
    Clerk
    Illinois PolMation Control Board
    124—3 1

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