BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    IN THE MATTER OF THE )
    PROPOSAL OF: )
    CENTRAL ILLINOIS LIGHT COMPANY ) R 02-21
    FOR A SITE SPECIFIC RULEMAKING )
    AMENDING 35 ILL. ADM. CODE )
    214.561. )
     
     
     
     
     
     
    THE ILLINOIS POLLUTION CONTROL BOARD HEARING in
     
    the above-entitled matter, taken before me, Angela M.
     
    Jones, CSR-RPR, a Notary Public in and for the State of
     
    Illinois, at 202 Northeast Madison, in the City of Peoria,
     
    County of Peoria, and State of Illinois, on the 11th day of
     
    October, A.D. 2002, commencing at 10:00 a.m.
     
     
     
     
     
     
     
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    2
     
     
    1 APPEARANCES:
     
    2 ILLINOIS POLLUTION CONTROL BOARD
    JOHN C. KNITTLE, ESQUIRE
    3 Hearing Officer
    1717 Philo Road, Suite 25
    4 Urbana, Illinois 61802
    5
    ILLINOIS POLLUTION CONTROL BOARD
    6 THOMAS E. JOHNSON, ESQUIRE
    Board Member
    7 1717 Philo Road, Suite 25
    Urbana, Illinois 61802
    8
    9 ILLINOIS POLLUTION CONTROL BOARD
    ANAND RAO, ESQUIRE
    10 Board Member
    100 West Randolph Street, Suite 11-500
    11 Chicago, Illinois 60601
    12
    HOWARD & HOWARD, P.C.
    13 DIANA M. JAGIELLA, ESQUIRE
    JON S. FALETTO, ESQUIRE
    14 Attorneys at Law
    One Technology Plaza
    15 211 Fulton Street, Suite 600
    Peoria, Illinois 61602
    16 On Behalf of the Petitioner CILCO.
    17
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
    18 RACHEL L. DOCTORS, ESQUIRE
    Assistant Counsel
    19 1021 North Grand Avenue East
    Springfield, Illinois 62794
    20 On Behalf of the IEPA.
    21
    ALSO PRESENT:
    22
    MARK DAVIS, CILCO
    23 SANDY ISBELL, CILCO
    VIR GUPTA, EPA
    24 ROBERT KALEEL, EPA
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    3
     
     
    1 HEARING OFFICER: My name is John Knittle. I'm
     
    2 a hearing officer. Actually, I'm an attorney assistant.
     
    3 I'm the hearing officer for this rulemaking proceeding
     
    4 which is the petition of Central Illinois Light Company
     
    5 E.D. Edwards Generating Station for a site-specific air
     
    6 regulation, 35 Ill. Adm. Code 214.561. The Board has
     
    7 docketed this as R02-021.
     
    8 Sitting to my right is board member Tom Johnson
     
    9 who will be coordinating this rulemaking for the Board. We
     
    10 also have from the Pollution Control Board Anand Rao of our
     
    11 technical unit here today.
     
    12 As a little background on the proposal, Central
     
    13 Illinois Light Company, who I'm going to call CILCO from
     
    14 now on, operates the generating station near Peoria and
     
    15 Peoria County. The facility consists of three coal-fired
     
    16 boilers. CILCO received a variance from 35 Ill. Adm. Code
     
    17 214.141 in a board order issued on April 15th, 1999, and
     
    18 that variance is effective through July 31st, 2003.
     
    19 Boilers 1 and 3 are subject to a sulfur dioxide implement
     
    20 under site-specific rule at 35 Ill. Adm. Code 214.561.
     
    21 Boiler 2 is subject to a sulfur dioxide admissions limit
     
    22 under 35 Ill. Adm. Code 214.141.
     
    23 On February 28th, CILCO filed a petition -- and
     
    24 that's February 28th, this year, 2002 -- CILCO filed a
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    4
     
     
    1 petition for an adjusted standard pursuant to Section 28.1
     
    2 of the Environmental Protection Act. As a result of a
     
    3 board order, CILCO then filed a motion to file an amended
     
    4 pleading and proposal for site-specific rulemaking on
     
    5 April 26, 2002. CILCO seeks to make permanent the relief
     
    6 that was granted in the variance, which was PCB 99-80, by
     
    7 amending 35 Ill. Adm. Code 214.561 with respect to the
     
    8 requirements of the operation of boiler number 2.
     
    9 CILCO specifically requests that the Board
     
    10 repeal the text of 35 Ill. Adm. Code 214.561 and replace it
     
    11 verbatim with text from the variance order of April 15th,
     
    12 1999. CILCO asserts this language has already been
     
    13 reviewed and approved by the USEPA and incorporated into
     
    14 the Illinois SIP pursuant to the Clean Air Act.
     
    15 On May 2nd, 2002, the Board granted CILCO's
     
    16 motion to dismiss the petition for adjusted standard and
     
    17 opened a new regulatory docket, which I said is R02-21.
     
    18 This hearing was properly noticed pursuant to
     
    19 the Act and the Board's procedural rules. Both the Agency
     
    20 and the Petitioner have pre-filed testimony; and although
     
    21 that testimony was filed past the date originally set, the
     
    22 Board has accepted all the pre-filed testimony.
     
    23 This hearing not only is going to handle the
     
    24 site-specific rulemaking, it's also going to address the
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    5
     
     
    1 Department of Commerce and Community Affairs hearing that's
     
    2 necessary. Section 27(b) of the Act requires the Board to
     
    3 request that Department of Commerce and Community
     
    4 Affairs -- we'll call that DCCA, D-C-C-A -- to conduct an
     
    5 economic impact study on certain proposed rules prior to
     
    6 the adoption of those rules. If DCCA chooses to conduct
     
    7 the economic impact study, they have 30 to 45 days after
     
    8 such a request to produce a study of the economic impact of
     
    9 the proposed rules. The Board must then file the economic
     
    10 impact study or DCCA's explanation for not conducting the
     
    11 study, make available to the public at least 20 days before
     
    12 public hearing on the economic impact of the proposed
     
    13 rules.
     
    14 In accordance with Section 27(b) of the Act,
     
    15 the Board has requested by a letter dated August 14th,
     
    16 2002, that DCCA conduct an economic impact study for this
     
    17 rulemaking. The request letter, referenced letter dated
     
    18 March 10th, 2000, from DCCA, in that letter, DCCA notified
     
    19 the Board that it would not be conducting economic impact
     
    20 studies on rules pending before the Board during the
     
    21 remainder of the fiscal year because of lack, among other
     
    22 things, of the financial resources to conduct such studies.
     
    23 In the request letter, the Board also asks that
     
    24 DCCA notify the Board within ten days of receipt of the
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    6
     
     
    1 request if DCCA intended to conduct an economic impact
     
    2 study on the proposed rules. The Board further stated if
     
    3 it is not notified within ten days, the Board would rely on
     
    4 DCCA's March 10th, 2000, letter as the required explanation
     
    5 for not conducting an economic impact study. If the ten
     
    6 days for DCCA to notify the Board have expired, we have not
     
    7 received any notification from DCCA that it will conduct
     
    8 the study on this rulemaking, accordingly, the Board must
     
    9 rely on the March 10th letter as DCCA's explanation for not
     
    10 producing a study.
     
    11 The Board is holding this hearing for public
     
    12 comment on DCCA's explanation for not conducting an
     
    13 economic impact study in this rulemaking, and any person
     
    14 who testifies will be sworn and subject to questioning.
     
    15 Is there anybody out here who would like to
     
    16 comment on DCCA's explanation for not conducting an
     
    17 economic impact study for the petition of Central Illinois
     
    18 Light Company E.D. Edwards Generating Station for a
     
    19 site-specific air regulation, 35 Ill. Adm. Code 214.561?
     
    20 Seeing nobody, we'll move on. Let's consider
     
    21 the matter at hand. Please note that there are sign-up
     
    22 sheets for this proceeding, service and notice list up
     
    23 front. There is also a witness sign-in sheet, not for the
     
    24 parties' witnesses; but if any member of the public wishes
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    7
     
     
    1 to come by and sign, they would be more than welcome to
     
    2 provide public testimony. Time-permitting, after the
     
    3 parties' testimony, we'll proceed with the testimony of
     
    4 persons who sign up in that order. I note for the record
     
    5 there are no members of the public here at this point in
     
    6 time. If any come in, of course, they will be given the
     
    7 opportunity to speak and also ask questions of the
     
    8 witnesses.
     
    9 Part 102 of the Board's rules govern this
     
    10 hearing. All information that is relevant and not
     
    11 repetitious or privileged will be admitted, and all
     
    12 witnesses will be sworn and subject to cross-examination.
     
    13 Today we're going to begin with the
     
    14 petitioner's testimony. After that, we'll hear the
     
    15 testimony of the Agency. Anyone may ask a question of any
     
    16 witness. If anybody has a question, please raise your
     
    17 hand; and we'll try to fight through the many people here
     
    18 to get to the right person asking the question.
     
    19 We're going to have opening and closing
     
    20 statements by both parties. I'm going to ask board member
     
    21 Johnson, coordinating board member of this rulemaking, if
     
    22 he has any remarks he'd like to make at this point in time.
     
    23 MR. JOHNSON: Briefly, on behalf of the Board,
     
    24 I want to welcome everybody to today's hearing and assure
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    8
     
     
    1 you that we understand the importance of this rulemaking
     
    2 and all rulemakings and give this matter the attention it
     
    3 deserves and issue an order in a timely fashion.
     
    4 HEARING OFFICER: That's all I have. Do we
     
    5 have any opening statements from the petitioner?
     
    6 MR. FALETTO: Yes. I have a brief statement
     
    7 for the record. Jon Faletto from the law firm of Howard &
     
    8 Howard. We're here representing Central Illinois Light
     
    9 Company. I apologize; there's a little bit of repetition
     
    10 in what Mr. Knittle has already stated.
     
    11 The Central Illinois Light Company, which I
     
    12 will refer to as CILCO, C-I-L-C-O, is an electric and
     
    13 natural gas utility located in Central Illinois. CILCO's
     
    14 electric production facilities include two coal-fired
     
    15 electric generating stations, the Duck Creek Generating
     
    16 Station located near Canton, Illinois, and the E.D. Edwards
     
    17 station located in Bartonville, Illinois. The Edwards
     
    18 Station will be referred to in testimony both pre-filed and
     
    19 in response to any questions as Edwards or Edwards Station.
     
    20 CILCO provides electric and gas service to
     
    21 approximately 172,000 residential customers and 170
     
    22 industrial customers. CILCO's electric and gas service
     
    23 territory includes multiple counties in Central Illinois.
     
    24 Edwards Station is located on the Illinois River in the
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    9
     
     
    1 Peoria major metropolitan area. 113 people are employed at
     
    2 Edwards Station which is staffed 24 hours per day, seven
     
    3 days per week. The Edwards Station consists of three
     
    4 boilers. All three boilers are coal-fired. Boilers number
     
    5 1 and 2 discharge through a common stack 503 feet in
     
    6 height. Boiler number 3 discharges through a separate
     
    7 stack which is also 503 feet in height. The combustion
     
    8 exhaust gases from all three boilers are ducted through
     
    9 electrostatic precipitators which are designed to remove
     
    10 particulate matter prior to releasing the exhaust gases
     
    11 through the stacks.
     
    12 In recent years, CILCO has installed
     
    13 state-of-the-art controls on all three boilers to reduce
     
    14 the emissions of nitrogen oxides, which you'll hear
     
    15 referred to as NOx, NO sub X, referred to as low NOx
     
    16 burners. In addition, CILCO has installed and is operating
     
    17 continuous emission monitoring systems on all three boilers
     
    18 which directly measure sulfur dioxide, which you'll hear
     
    19 referred to as SO2, NOx, carbon dioxide, and opacity
     
    20 contained in the exhaust gases. The Continuous Emissions
     
    21 Monitoring Systems, which are also referred to as CEMS or
     
    22 C-E-M-S, are required by the federal Acid Deposition
     
    23 Control Program developed under the federal Clean Air Act.
     
    24 Boiler numbers 1 and 3 were historically
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    10
     
     
    1 subject to an SO2 emission limit of 6.6 pounds per million
     
    2 Btu pursuant to 35 Ill. Adm. Code Section 214.561. Boiler
     
    3 number 2 was subject to an SO2 emission limit of 1.8 pounds
     
    4 per million Btu pursuant to 35 Ill. Adm. Code Section
     
    5 214.141. Emissions from all three boilers collectively are
     
    6 subject to an overall plant-wide SO2 emission limit of
     
    7 34,613 pounds per hour established to ensure protection of
     
    8 the National Ambient Air Quality Standard for SO2 under 35
     
    9 Ill. Adm. Code Section 214.561.
     
    10 In 1999, CILCO elected to request relief from
     
    11 the 1.8 pound per million Btu SO2 limit applicable only to
     
    12 boiler number 2 through a petition for variance after
     
    13 recognizing that relief from the limit would reduce the
     
    14 economic hardship caused by purchasing more expensive
     
    15 low-sulfur coal and allow increased purchases of Illinois
     
    16 coal with no adverse impact to the environment. On
     
    17 April 15, 1999, the Illinois Pollution Control Board
     
    18 entered an order granting CILCO a variance from the 1.8
     
    19 pound per million Btu SO2 emission limit applicable to
     
    20 boiler number 2 for a five-year period beginning
     
    21 January 1st, 1999, through July 31, 2003. Under the
     
    22 conditions of the variance, CILCO was granted an average
     
    23 station-wide SO2 emission limit of 4.71 pounds per million
     
    24 Btu over all three boilers with a maximum SO2 limit of 6.6
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    11
     
     
    1 pounds per million Btu for each boiler.
     
    2 The variance further provided that boiler
     
    3 number 2 was not required to meet the 1.8 pound per million
     
    4 Btu SO2 emission limit established by 35 Ill. Adm. Code
     
    5 Section 214.141 during the period of the variance. CILCO's
     
    6 obligation to comply with all other applicable SO2 emission
     
    7 limitations remained unchanged. CILCO remained subject to
     
    8 the facility-wide limit of 34,613 pounds per hour of SO2
     
    9 for all three boilers which is imposed under 35 Ill. Adm.
     
    10 Code Section 214.561.
     
    11 In the increasingly competitive deregulated
     
    12 electric utility industry, the 1.8 pound per million Btu
     
    13 limit on SO2 emissions from boiler number 2 puts CILCO at a
     
    14 competitive disadvantage. Without permanent relief which
     
    15 will retain the operational flexibility provided by the
     
    16 existing variance, CILCO will once again be put at a
     
    17 competitive disadvantage. The unreasonableness of that
     
    18 economic hardship is underscored by the fact that these
     
    19 benefits did not come at an environmental cost. Under the
     
    20 variance, CILCO has continued to meet the short-term hourly
     
    21 SO2 emission limit established for Edwards Station by 35
     
    22 Ill. Adm. Code Section 214.561 and has actually reduced SO2
     
    23 emissions from all three boilers. As a result of the
     
    24 operational flexibility provided by the variance, CILCO has
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    12
     
     
    1 been able to reduce SO2 emissions by approximately 20
     
    2 percent. The SO2 emissions reductions were achieved in the
     
    3 most cost-effective and efficient way possible.
     
    4 Based on the benefits to CILCO and the absence
     
    5 of any adverse environmental impact, the Board granted the
     
    6 variance in 1999. For the same reasons which justified the
     
    7 grant of the variance, the operational flexibility should
     
    8 be granted on a site-specific, permanent basis through this
     
    9 rulemaking proceeding.
     
    10 The Board's order granting the variance
     
    11 provided the mechanism for CILCO to obtain this operational
     
    12 flexibility on a permanent basis. The order specified that
     
    13 CILCO notify the Illinois Environmental Protection Agency
     
    14 by January 31st, 2002, if CILCO decided to pursue permanent
     
    15 site-specific relief consistent with the variance. The
     
    16 order further required CILCO to file a petition for such
     
    17 relief with the Board by February 28th, 2002.
     
    18 By correspondence dated January 25th, 2002,
     
    19 CILCO notified IEPA, Illinois Environmental Protection
     
    20 Agency, of its intention to pursue permanent site-specific
     
    21 relief from the 1.8 pound per million Btu SO2 limit of
     
    22 Section 214.141. On February 28th, 2002, CILCO filed its
     
    23 petition for an adjusted standard pursuant to the Board's
     
    24 order of March 21st, 2002, and subsequent conferences with
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    13
     
     
    1 the hearing officer, CILCO filed a petition for
     
    2 site-specific rulemaking to obtain permanent relief
     
    3 consistent with the variance.
     
    4 We are here today to provide testimony in
     
    5 support of the site-specific rulemaking. We have two
     
    6 witnesses today. Our first witness is Mr. Mark Davis who
     
    7 is a CILCO employee responsible for environmental services
     
    8 and compliance for CILCO's Edwards Station. His testimony
     
    9 has already been pre-filed with the Board, and we heard
     
    10 from Hearing Officer Knittle that it has been accepted into
     
    11 the record. His testimony addressed the environmental
     
    12 aspects of the requested relief. Our second witness is
     
    13 Miss Sandy Isbell who is also a CILCO employee. She holds
     
    14 the position of fuel analyst/safety for Edwards Station.
     
    15 Her testimony has also been pre-filed and, through Hearing
     
    16 Officer Knittle, has been accepted as part of the record in
     
    17 this proceeding. Miss Isbell will address coal-cost
     
    18 savings that was made possible by the variance. Thank you
     
    19 very much.
     
    20 HEARING OFFICER: Thank you, Mr. Faletto.
     
    21 Miss Doctors, do you have an opening statement?
     
    22 MS. DOCTORS: Yes, I do. Good morning. My
     
    23 name is Rachel Doctors. I am representing the Illinois
     
    24 Environmental Protection Agency in this matter.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    14
     
     
    1 Central Illinois Light Company Edwards Station
     
    2 has requested a site-specific rule for sulfur dioxide
     
    3 emissions. The site-specific rule would amend 35 Ill. Adm.
     
    4 Code Section 214.561 that limits sulfur dioxide emissions
     
    5 from boilers 1 and 3 to 6.6 pounds/mmBtu and would replace
     
    6 the applicable rule for boiler number 2, 35 Ill. Adm. Code
     
    7 Section 214.141 that limits sulfur dioxide emissions to 1.8
     
    8 pounds per mmBtu. Boilers 1, 2, and 3 would now be
     
    9 permitted to average sulfur dioxide emissions across the
     
    10 group and be limited to 4.71 pounds per mmBtu as a group.
     
    11 This site-specific rule replaces a prior
     
    12 variance, PCB 99-80, granted by the Pollution Control Board
     
    13 in 1999. This variance provided the same limits that allow
     
    14 for the average across the three boilers, lower the --
     
    15 excuse me -- and allowed for greater use of Illinois coal
     
    16 and provided the company with an opportunity to study
     
    17 compliance options for the federal Acid Rain Program as
     
    18 well as Illinois' NOx Trading Program. These options
     
    19 included purchases of allowances, purchase of low-sulfur
     
    20 Illinois coal, and installation of controlled equipment.
     
    21 Variance PCB 99-80 required CILCO to file quarterly reports
     
    22 evaluating these options. CILCO has complied with the
     
    23 requirements of the variance and has requested permanent
     
    24 relief.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    15
     
     
    1 Pursuant to the requirements of the Illinois
     
    2 Environmental Protection Act and the Board's procedural
     
    3 rules, a petitioner for site-specific relief must
     
    4 demonstrate the compliance with the rule of general
     
    5 applicability is not technically feasible or economically
     
    6 reasonable for the particular site as well as the
     
    7 environmental impact. The Agency believes that CILCO has
     
    8 demonstrated this by showing that Illinois low-sulfur coal
     
    9 will not be generally available and that compliance through
     
    10 use of other sources of coal will result in substantial
     
    11 savings annually. Further, the cost of installing
     
    12 additional control equipment would result in even greater
     
    13 expense.
     
    14 For these reasons, the Illinois EPA is
     
    15 recommending that the Board adopt CILCO's proposed change.
     
    16 With respect to air quality, the
     
    17 Peoria/Tazewell area has been nonattainment for sulfur
     
    18 dioxide and was redesignated by the United States
     
    19 Environmental Protection Agency in 1995 as attaining the
     
    20 standard and redesignated to a maintenance area. The
     
    21 maintenance plan for this area contains the above rules as
     
    22 part of the plan for maintaining the sulfur dioxide
     
    23 standard in this area. The proposed amendment is
     
    24 consistent with the plan for the area as CILCO's sulfur
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    16
     
     
    1 dioxide emissions have decreased, and it is also consistent
     
    2 with the requirements of the Acid Rain Program.
     
    3 What the proposal does represent is an
     
    4 amendment to the applicable state implementations made for
     
    5 the area. As such, the agency will need to submit a
     
    6 revision if the Board adopts CILCO's proposal. USEPA, as
     
    7 stated by CILCO, approved PCB 99-80 and has been given an
     
    8 opportunity to review CILCO's current proposal. They have
     
    9 not raised any issues.
     
    10 This hearing also fulfills the requirement for
     
    11 public hearing for hearings on SIP revisions pursuant to
     
    12 Section 110(a) of the Clean Air Act and 40 CFR, Code of
     
    13 Federal Regulations, Section 51.104.
     
    14 Today from the Illinois Environmental
     
    15 Protection Agency who are also present are Rod Kaleel, the
     
    16 manager for the Modeling Unit, Air Quality Planning
     
    17 Section, Bureau of Air. He's pre-submitted his testimony.
     
    18 And available for questions on technical aspects should the
     
    19 Board have them is Vir Gupta, an Environmental Protection
     
    20 engineer with our Air Quality Planning Section, Bureau of
     
    21 Air. Mr. Gupta did not present testimony but is available
     
    22 to answer any questions. Thank you.
     
    23 HEARING OFFICER: Thank you, Miss Doctors.
     
    24 Let's go off the record.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    17
     
     
    1 (Discussion off the record.)
     
    2 HEARING OFFICER: I want to note for the record
     
    3 again there are no members of the public here.
     
    4 Accordingly, we are going to swear in all witnesses and
     
    5 allow the agency -- not the agency -- the Illinois
     
    6 Pollution Control Board technical representative Mr. Anand
     
    7 Rao to ask any questions that he has. If either side has
     
    8 any questions or Mr. Johnson as well, now is the time.
     
    9 (Mark Davis, Sandy Isbell, Robert Kaleel
     
    10 and Vir Gupta sworn.)
     
    11 HEARING OFFICER: Does anybody have any
     
    12 questions for any of these witnesses -- before we get
     
    13 started, I do want to note that we are accepting the
     
    14 testimony and entering it into the record as if read, and
     
    15 it will be appended to the transcript.
     
    16 Any questions, Mr. Rao?
     
    17 MR. RAO: I have some questions for Miss Isbell
     
    18 basically regarding your cost figures that you had
     
    19 presented in the petition and also in your pre-filed
     
    20 testimony. First, I wanted to get some qualification as to
     
    21 the differences in the cost savings that was presented
     
    22 earlier to the Board in the petition which estimated the
     
    23 cost savings to be approximately in the range of $7
     
    24 million. In your pre-filed testimony, you have a different
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    18
     
     
    1 figure in the range of $3 million. Could you just clarify
     
    2 for the record?
     
    3 MS. ISBELL: Right. I think I can remember
     
    4 what that was about. The emission numbers I put together
     
    5 was based on the spot market in '01. If you're familiar
     
    6 with where pricing was going in '01 on the spot market,
     
    7 they were, in my opinion, run-away pricing last year due to
     
    8 the perceived shortage of coal. This latest filing that I
     
    9 put together, it was based on industry experts, I guess you
     
    10 would call it; and I went to them and asked them, if we had
     
    11 been under contract during that period, in their opinion,
     
    12 where would pricing have been? So it would spot during
     
    13 those market conditions as opposed to contract pricing.
     
    14 MR. RAO: Can you explain a little bit more as
     
    15 to how you purchase coal? Is it based on contract over a
     
    16 year or for a period of time?
     
    17 MS. ISBELL: In the past, we've done a
     
    18 combination of both. Routinely, not every year, routinely
     
    19 we've had 70 percent under contract and 30 under spot. But
     
    20 that hasn't been a hard-fast rule. This year we didn't buy
     
    21 any spot.
     
    22 MR. RAO: And based on the previous year's coal
     
    23 purchase, do these figures that you have given, do they
     
    24 reflect the actual cost savings that CILCO had maybe in the
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    19
     
     
    1 year 2000? Do you have that figure in terms of how much
     
    2 you spent on coal and what were the savings and actual
     
    3 costs instead of these estimations?
     
    4 MS. ISBELL: I have actuals. I don't believe
     
    5 it was part of the filing, but I do have actual costs, of
     
    6 course.
     
    7 MR. RAO: Just to get a comparison as to how
     
    8 the actual costs compare to the spot market or your
     
    9 contract costs, if it's possible for you to provide that as
     
    10 part of your comment, it will be helpful.
     
    11 MS. ISBELL: You want the '00 costs --
     
    12 MR. RAO: If you have a couple of years.
     
    13 MS. ISBELL: '99 to 2000, '01, something like
     
    14 that?
     
    15 MR. RAO: Yeah, that will be helpful.
     
    16 HEARING OFFICER: I have a question. Why no
     
    17 spot purchases this year?
     
    18 MS. ISBELL: Well, coming out of '01, there
     
    19 wasn't a whole lot of coal to be found. It was very short.
     
    20 So, when we purchased coal, we probably were looking at
     
    21 probably 80 percent of our requirements, what we thought
     
    22 was 80 percent of our burn. But we didn't have the burn
     
    23 that we anticipated the first quarter. The winter wasn't
     
    24 as cold as what we anticipated. So we have enough to get
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    20
     
     
    1 us through the end of the year.
     
    2 HEARING OFFICER: Thanks.
     
    3 MR. RAO: In your cost analysis to show how
     
    4 much you saved, do you also consider the impact of
     
    5 blending?
     
    6 MS. ISBELL: Right. And you can't overlook SO2
     
    7 credits also. It has to be the coal. Obviously the
     
    8 blending is the coal costs also, transportation and SO2
     
    9 costs.
     
    10 MR. FALETTO: Sandy, do you want to maybe
     
    11 explain with the variance how you were able to get more
     
    12 flexibility in your purchases of coal?
     
    13 MS. ISBELL: The biggest advantage of having
     
    14 the variance on unit 2, it allows us to utilize our lowest
     
    15 cost coal which is currently the Exxon Monterey coal in
     
    16 Southern Illinois. The reason we can use it, they
     
    17 guarantee annually 1.77 pounds of SO2; but per shipment,
     
    18 they cannot. It ranges from a 1.4 up to over 2 pounds. So
     
    19 the fact that we have that variance, we are able to blend
     
    20 that in unit 2; and again, being the lowest cost coal, it
     
    21 gives us that advantage. We don't have to worry about
     
    22 exceeding the 1.8.
     
    23 MR. RAO: I had a question pertaining to the
     
    24 variance conditions the Board had. I think the Board
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    21
     
     
    1 required CILCO to prepare a report to the IEPA evaluating
     
    2 strategies for compliance as one of the conditions. Has
     
    3 CILCO prepared such a report in evaluating the options like
     
    4 complying with the Acid Rain Program using different types
     
    5 of coals, purchases of allowances, or installation of
     
    6 scrubbers or other desulfurization systems? Did you
     
    7 prepare such a report?
     
    8 MS. JAGIELLA: Those reports are actually filed
     
    9 as part -- they're attached to Mr. Davis's testimony.
     
    10 MR. RAO: Those are the reports that you gave
     
    11 me today?
     
    12 MS. JAGIELLA: Yes.
     
    13 MR. RAO: Could you summarize what was reported
     
    14 to the agency in terms of evaluation compliance
     
    15 alternatives? Can you summarize the report?
     
    16 MS. ISBELL: I don't understand the question.
     
    17 I'm sorry.
     
    18 MR. FALETTO: Just to clarify, as part of the
     
    19 variance, there were certain requirements for filings with
     
    20 the Agency. Attorney Doctors has indicated for the record
     
    21 that those filings were made. He's now asking for someone
     
    22 to summarize the compliance options that CILCO has
     
    23 considered in terms of compliance with SO2 limits,
     
    24 reductions under the Acid Rain Program and a combination of
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    22
     
     
    1 trying to purchase the cheapest fuel which allows them to
     
    2 generate power most efficiently. So those are all the
     
    3 issues that were identified in the variance proceeding
     
    4 which are still, of course, variables in this proceeding as
     
    5 well.
     
    6 MR. RAO: Yeah. I know you did present some
     
    7 information during the variance proceeding. But when the
     
    8 Board granted a variance as a condition, they said you need
     
    9 to do further evaluations and report to the Agency.
     
    10 MR. FALETTO: Yes, sir.
     
    11 MR. RAO: What I'm basically asking is if, you
     
    12 know, if you did prepare such a report and submit it to the
     
    13 Agency, which you indicated that you did, then you provided
     
    14 a copy of that to the Board today. I wanted you to
     
    15 summarize it for the record as to what your findings were.
     
    16 MS. ISBELL: We did look at other alternatives
     
    17 other than our current scenario. One of them we looked at
     
    18 was Indiana low-sulfur coal. That should be 1.2 pounds as
     
    19 opposed to percent. Another alternative would be to go to
     
    20 Central Appalacia and to East Kentucky for 1.2 or Colorado
     
    21 coal would be the three options as part of the testimony.
     
    22 Now, obviously, those are a lot farther from
     
    23 home than Southern Illinois, and that means increased
     
    24 transportation costs.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    23
     
     
    1 MR. RAO: Did you consider any of the other
     
    2 alternatives like installation of scrubbers or other
     
    3 desulfurization systems?
     
    4 MS. ISBELL: No. We did not include it.
     
    5 MS. JAGIELLA: It's in the report.
     
    6 MS. ISBELL: Not in my testimony.
     
    7 MS. JAGIELLA: That has remained unchanged, the
     
    8 costs associated with installation of a scrubber, plus the
     
    9 physical infeasibility of doing that at Edwards Station.
     
    10 And that's in the report. It was in the underlying
     
    11 variance testimony. It's in the reports. The facts
     
    12 surrounding that have not changed.
     
    13 HEARING OFFICER: That's attached to Mark
     
    14 Davis's report and testimony?
     
    15 MS. JAGIELLA: Correct. Those reports that
     
    16 went in to IEPA that reiterated what was in the underlying
     
    17 variance.
     
    18 HEARING OFFICER: It states in there that the
     
    19 facts are unchanged? I understand your representation, but
     
    20 you're an attorney who hasn't been sworn in. We want to be
     
    21 sure that's in the record.
     
    22 MR. FALETTO: Right. Mark can probably
     
    23 testify.
     
    24 Mark, you want to comment on that?
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    24
     
     
    1 MR. DAVIS: I believe it's in the -- we had
     
    2 submitted the semiannual variance reports --
     
    3 MR. RAO: I didn't get a chance to go over
     
    4 them. I just got it now. I just wanted you to summarize
     
    5 it for the record.
     
    6 MR. FALETTO: Mark, can you summarize just
     
    7 generally for the record -- Sandy has testified as to
     
    8 low-sulfur coal options. Can you testify as to the
     
    9 technical and/or economic feasibility of installing flew
     
    10 gas desulfurization at Edwards as to whether there's been
     
    11 any change?
     
    12 MR. JOHNSON: Or, alternately, we've heard from
     
    13 Miss Doctors that CILCO's been in full compliance, they've
     
    14 made the filings they're supposed to have made. If you
     
    15 would prefer to clarify this in the post-hearing
     
    16 comments --
     
    17 MR. RAO: That's fine, too.
     
    18 MR. JOHNSON: Rather than going through
     
    19 pell-mell your file and trying to drag that out, that's
     
    20 perfectly appropriate. I think most of it has already been
     
    21 incorporated in your testimony by reference, right?
     
    22 MR. FALETTO: Yes, it has.
     
    23 HEARING OFFICER: Miss Doctors? She was
     
    24 raising her hand.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    25
     
     
    1 MS. DOCTORS: Just to note that the agency
     
    2 received a discussion of this on April -- by letter of
     
    3 April 27, 2001. On the last page, it talks about
     
    4 installation of the scrubber or other desulfurization
     
    5 equipment, and that's what we were relying on when we were
     
    6 doing our evaluation.
     
    7 MR. FALETTO: Why don't you go ahead and
     
    8 summarize.
     
    9 MR. DAVIS: As we indicated in our interim
     
    10 variance report, we basically summarized the installation
     
    11 of a scrubber or other desulfurization equipment is the
     
    12 most expensive means of compliance. In addition, it's
     
    13 technically infeasible due to space limitations at the
     
    14 facility. We did run some numbers. The cost of installing
     
    15 the scrubber would exceed $40 million which would basically
     
    16 make it economically infeasible. That's essentially what
     
    17 we had provided in this report.
     
    18 MR. FALETTO: In terms of site, Mark, as I
     
    19 understand, there's also a NOx SCR control device being
     
    20 constructed now?
     
    21 MR. DAVIS: Correct.
     
    22 MR. FALETTO: In terms of site limitations,
     
    23 does that actually make it even more difficult to add
     
    24 desulfurization equipment at Edwards?
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    26
     
     
    1 MR. DAVIS: Yes, it would definitely make it
     
    2 more difficult.
     
    3 MR. FALETTO: And that's why?
     
    4 MR. DAVIS: Right.
     
    5 MR. RAO: Thank you. One of the things that
     
    6 the Board needs to do in a rulemaking is to make a finding
     
    7 on the technical feasibility and economic reasonableness,
     
    8 so that's the reason I just want to get this on the record.
     
    9 HEARING OFFICER: And feel free, if you think
     
    10 it hasn't been adequately explained here, feel free to
     
    11 address it in the public comments if you feel more
     
    12 comfortable doing that. You're definitely not prohibited
     
    13 from addressing anything you want.
     
    14 MR. FALETTO: Okay.
     
    15 MR. RAO: One final question. It's a minor
     
    16 clarification. On page 8 of the petition regarding
     
    17 allocation of allowances, you make a statement saying
     
    18 allowances are allocated based on the average of the base
     
    19 year's fuel consumption multiplied by the Clean Air Act's
     
    20 overall emission limit of 8.9 million tons of SO2 per year.
     
    21 Either there must be some typo or missing information in
     
    22 that statement. Could CILCO or the Agency clarify that
     
    23 statement?
     
    24 MR. FALETTO: Since it's our petition, I guess
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    27
     
     
    1 I can clarify. That is essentially intended to be a
     
    2 summary of what congress has implemented through the Acid
     
    3 Rain Deposition Program in terms of how -- and it's
     
    4 obviously a very simplified statement -- as to how the
     
    5 US Environmental Protection Agency has been tasked to
     
    6 determine how many allowances each of the affected units or
     
    7 affected facilities are going to be given under the Acid
     
    8 Rain Program. So we're only talking about affected
     
    9 facilities as that term is defined by the federal Clean Air
     
    10 Act and the USEPA's Acid Rain regulations which I think are
     
    11 at 40, part 72.
     
    12 Does that sound right, Rachel?
     
    13 MR. GUPTA: 72 and 75, yes.
     
    14 MR. FALETTO: 72 and 75. That was essentially
     
    15 intended to be a summary of the Acid Rain Program to give a
     
    16 little background on the fact that Edwards Station is a
     
    17 phase two affected source and has been allocated SO2
     
    18 allowances under that program. That's all it was intended
     
    19 to be. So those numbers don't reflect anything that's site
     
    20 specific.
     
    21 MR. RAO: Okay. That's all I have.
     
    22 MS. DOCTORS: The agency has nothing to add.
     
    23 HEARING OFFICER: Anything further from the
     
    24 petitioners?
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    28
     
     
    1 MS. JAGIELLA: I'd like to get some
     
    2 clarifications on the information on the coal savings for
     
    3 Sandy. It is sometimes very difficult because there's so
     
    4 many variables. There's the spot-market costs. There are
     
    5 contract costs, and sometimes predicting what a contract
     
    6 cost might have been is virtually impossible because those
     
    7 are all confidential contracts and they're all separately
     
    8 negotiated by the coal companies.
     
    9 So I guess I have two questions. One, if we
     
    10 are submitting actual information, we have to submit it
     
    11 under some type of confidentiality. Beyond that, I guess
     
    12 I'm asking: What exactly are you looking for?
     
    13 MR. RAO: Basically, you know, the cost figures
     
    14 that were presented in the petition and in the testimony
     
    15 were so significantly different. And I know the
     
    16 spot-market prices vary considerably. So we wanted to get
     
    17 a better handle on what the actual cost savings were
     
    18 because it's hard for us to look at these numbers and
     
    19 figure out whether it's 10 million or 1 million savings.
     
    20 So just to get a better idea as to what the actual savings
     
    21 are.
     
    22 MS. JAGIELLA: Part of the problem is that
     
    23 changes over time. If you ask her eight months ago what it
     
    24 was and you ask her today, that will change because of the
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    29
     
     
    1 availability of the sources of coal, the spot-market prices
     
    2 that change, contract prices that change.
     
    3 HEARING OFFICER: Correct me if I'm wrong.
     
    4 You're asking for the actual cost of that particular year
     
    5 based on whatever the estimate was that was provided to us?
     
    6 MR. RAO: Yeah.
     
    7 MS. JAGIELLA: We can provide actual coal --
     
    8 we'd have to submit that under some order of
     
    9 confidentiality.
     
    10 HEARING OFFICER: Right. I'm looking right now
     
    11 under procedures for identifying articles that represent a
     
    12 trade secret. I think that would probably qualify.
     
    13 MR. FALETTO: It should fall under that.
     
    14 HEARING OFFICER: That would be something you'd
     
    15 have to address and see if it was going to fall under that.
     
    16 If it wasn't and you don't want to submit it, let us know
     
    17 that; and we'll consider that.
     
    18 MS. JAGIELLA: Maybe what we can do is submit
     
    19 it for 2001, which we've had enough time past 2001 it's
     
    20 probably less concern but then -- when you try to figure
     
    21 out what the actual cost savings are, it's important to
     
    22 understand it's all theoretical. It's theoretical based on
     
    23 whether you want to compare to the spot-market price or
     
    24 whether you want to compare to what you theoretically could
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    30
     
     
    1 have negotiated for that coal supply. That's part of the
     
    2 reason why the numbers change based on the time you put
     
    3 them in, and they are theoretical.
     
    4 Do you want to add --
     
    5 MS. ISBELL: No. You're explaining that.
     
    6 MR. JOHNSON: I'm sure the concern was the
     
    7 difference between the $7 million figure and the $3 million
     
    8 figure. Suffice it to say, it's a significant amount; and
     
    9 it's somewhere hypothetically in that range. And I assume
     
    10 that's why my power bill varies from year to year.
     
    11 MR. FALETTO: That's a good point. That's how
     
    12 I understood his question as well, Mr. Johnson, is that he
     
    13 would like some explanation of the difference between the
     
    14 number that was in the petition versus the number that was
     
    15 in the testimony.
     
    16 MS. JAGIELLA: It is based on timing and
     
    17 theoretical reasons. In fact, I saw Rachel raise her hand.
     
    18 MS. DOCTORS: Can we go off the record for one
     
    19 minute?
     
    20 HEARING OFFICER: Go ahead.
     
    21 (Discussion off the record.)
     
    22 HEARING OFFICER: We're back on the record.
     
    23 MS. DOCTORS: I would like to make a statement
     
    24 as to how the difference in the numbers come about between
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    31
     
     
    1 the original petition and what's been submitted in the
     
    2 testimony.
     
    3 HEARING OFFICER: And, of course, you're more
     
    4 than willing to make any statement that you want; but
     
    5 understand you're not sworn in and not testifying under
     
    6 oath. So, if one of your cohorts can do it, it might be
     
    7 better. If not, feel free to talk.
     
    8 MS. DOCTORS: We can try to do this through
     
    9 Mr. Gupta. Let me make a statement, and then I'll ask some
     
    10 questions of Mr. Gupta and see if we can do it that way.
     
    11 I'd like to say we received their petition; and
     
    12 it was reviewed by our utility expert, Mr. Gupta, and he
     
    13 raised the question to us concerning the difference in
     
    14 spot-market prices versus contractual prices. So let me go
     
    15 from there.
     
    16 Mr. Gupta, did you review the site-specific
     
    17 request from CILCO?
     
    18 MR. GUPTA: Yes, I did.
     
    19 MS. DOCTORS: And what issue did you raise with
     
    20 respect to cost, cost savings that they had indicated were
     
    21 7 million?
     
    22 MR. GUPTA: The first thing was, as she
     
    23 indicated, was the spot-market price. When I looked into
     
    24 that, when I said, you know, that this price seems to be so
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    32
     
     
    1 high, we have to be realistic because historically CILCO
     
    2 had not been purchasing the coal at the spot-market price,
     
    3 100 percent of the coal. So we should go back maybe a
     
    4 couple of years and see what was the listing number.
     
    5 So, based on that one, I think CILCO did
     
    6 provide yesterday what will happen, you know, if they buy
     
    7 the coal from different sources, from Illinois, Indiana,
     
    8 and I think from Appalachia and, under each scenario, what
     
    9 will be the cost savings.
     
    10 Second thing they provided was the boiler
     
    11 number 2 particularly is more efficient compared to boiler
     
    12 number 3 or boiler number 1. So, if they use boiler number
     
    13 2 proficiently compared to boiler 1 and 2 (sic), they have
     
    14 additional savings because of that.
     
    15 So third thing was about this -- what do you
     
    16 call it -- the managing differently. One is a high-sulfur
     
    17 coal; one is low-sulfur coal. So, with all these three
     
    18 different things, you can get different type of savings.
     
    19 Okay. Under this one, this is savings. The option number
     
    20 two, this is the savings. Option number three, this is the
     
    21 savings. So, with three different things, I think the
     
    22 savings were, again, in the range of about $1.5 million.
     
    23 That's what it is.
     
    24 HEARING OFFICER: Do you have anything else to
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    33
     
     
    1 add, Miss Doctors?
     
    2 MS. DOCTORS: Hence, it came about they figured
     
    3 the cost at our request from 7 million down?
     
    4 MR. GUPTA: Right.
     
    5 MS. DOCTORS: Because of the difference using a
     
    6 spot-market and an estimated contractual cost?
     
    7 MR. GUPTA: Right.
     
    8 HEARING OFFICER: How about this; I mean, I'm
     
    9 no economics major by any means. I was a biology major,
     
    10 and I'm a lawyer. So I have no idea what any of this
     
    11 means. However, we do want as much possible information on
     
    12 this as we can get for the Board before we reach a
     
    13 decision. That being said, if you have any further
     
    14 clarifications after you look at the transcript and see
     
    15 what was said, if you think there's something that needs to
     
    16 be said, I would request you send it in during your public
     
    17 comments.
     
    18 MR. FALETTO: Fair enough.
     
    19 HEARING OFFICER: Any other questions from
     
    20 either party?
     
    21 MR. RAO: I have one. This is regarding your
     
    22 statement about the reductions in SO2 that you achieve with
     
    23 the flexibility you had under the variance from the Board.
     
    24 You state that on a station-wide basis you're able to
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    34
     
     
    1 achieve an emissions limit of 4.71 pounds per million Btu
     
    2 with individual boilers not to exceed 6.6. Is this 4.71
     
    3 figure, is that some kind of a permit limit; or is it a
     
    4 voluntary deduction that you were able to achieve?
     
    5 MS. JAGIELLA: I think that actually goes to
     
    6 the relief, the actual relief that was granted. The 4.71
     
    7 is the legal limit.
     
    8 MR. FALETTO: I think that's the limit that was
     
    9 in the variance, and I believe that the record would
     
    10 reflect that the air quality analysis that was done was
     
    11 done at that number so as to be conservative in terms of
     
    12 the potential impacts. In reality, the pound per million
     
    13 Btu SO2 rate on these units has been less than that.
     
    14 MR. RAO: Okay.
     
    15 MR. FALETTO: I think that's where that number
     
    16 was derived from.
     
    17 MS. JAGIELLA: The 6.6 was eliminated as part
     
    18 of the variance. CILCO gave that up.
     
    19 MR. RAO: Okay. Thanks.
     
    20 HEARING OFFICER: Anything further from
     
    21 anybody?
     
    22 MR. JOHNSON: As remote a location as this is,
     
    23 I think 50 minutes is sufficient time for any member of the
     
    24 public looking to locate this hearing to have located it.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    35
     
     
    1 So we don't need to leave the record open.
     
    2 John, if you want to close this up.
     
    3 HEARING OFFICER: Sure. Off the record.
     
    4 (Discussion off the record.)
     
    5 HEARING OFFICER: Just procedurally, are there
     
    6 any closing statements either side wants to make?
     
    7 MR. FALETTO: No.
     
    8 HEARING OFFICER: Seeing none from the
     
    9 Petitioner --
     
    10 MS. DOCTORS: No closing statement from the
     
    11 Agency.
     
    12 HEARING OFFICER: If anyone has any questions
     
    13 about the rest of this rulemaking, please feel free to give
     
    14 me a call. The transcript of today's hearing ought to be
     
    15 available by October 21st. Copies of the transcript will
     
    16 be available shortly thereafter on the Board's website at
     
    17 ipcb.state.il.us, as will other board and hearing officer
     
    18 orders pertaining to this rulemaking.
     
    19 We've had an off-the-record discussion.
     
    20 Comments, public comments will be due on or before
     
    21 November 4th, 2002, and that is all I have. I want to
     
    22 thank everyone for participating today.
     
    23 Mr. Johnson, any final remarks?
     
    24 MR. JOHNSON: Nothing. Thank you for coming.
     
     
     
     
    L.A. REPORTING (312) 419-9292

     
     
    36
     
     
    1 HEARING OFFICER: Hearing is adjourned.
     
    2
     
    3
     
    4 HEARING ADJOURNED AT 10:50 A.M.
     
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    L.A. REPORTING (312) 419-9292

     
     
    37
     
     
    1 COUNTY OF TAZEWELL )
    ) SS
    2 STATE OF ILLINOIS )
    3
     
    4
     
    5 CERTIFICATE OF REPORTER
     
    6
     
    7 I, ANGELA M. JONES, CSR-RPR, Notary Public in
     
    8 and for the State of Illinois, do hereby certify that the
     
    9 foregoing transcript consisting of Pages 1 through 36, both
     
    10 inclusive, constitutes a true and accurate transcript of
     
    11 the original stenographic notes recorded by me of the
     
    12 foregoing proceedings had before Hearing Officer John
     
    13 Knittle, on the 11th day of October, 2002.
     
    14
    15 Dated this day of , 2002.
    16
    17
    18
    19
    Angela M. Jones, CSR-RPR
    20 Notary Public, CSR #084-003482
     
    21
     
    22
     
    23
     
    24
     
     
     
     
    L.A. REPORTING (312) 419-9292

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