RECEIVED

CLERK’S

OFF~C~

SEP

032003

ARGONNE

NATIONAL

LABORATOR’~~TATE

OF ILLINOIS

9700

South Cass Avenue

Pollution Control

Board

Argonne, Illinois 60439

Phone:

(630) 252-7300

Fax:

(630) 252-5966

September 2, 2003

Ms. Dorothy M. Gunn

Clerk of the Board

Illinois Pollution Control

Board

James

R.

Thompson Center

100W. Randolph Street, Suite 11-500

Chicago, IL

60601

Dear Ms. Gunn:

Enclosed for filing please find the following:

1.

The original and ten (10) copies of WRITTEN TESTIMONY OF GREGORY BARRETT,

submitted

on

behalf

of

Argonne

National

Laboratory,

as

represented

by

the

U.S.

Department of Energy and The

University of Chicago, Petitioners.

2.

The original and ten (10) copies of the NOTICE OF FILING associated with the above-

referenced WRITTEN TESTIMONY.

3.

The

original

and ten

(10) copies

of the CERTIFICATE OF

SERVICE associated with

the referenced WRITTEN TESTIMONY.

I

have

arranged

the

documents

in

Items

1-3

into

eleven

(11)

packages,

constituting

an

original

package and

ten (10)

copy packages,

each package

consisting of three documents,

one

document

from

each

of Items

1-3.

A

note

on the

original

package specifies

it

as the

original

package.

Operated by The University of Chicago for The United States Department of Energy

---

Ms. Dorothy

M. Gunn

Clerk of the Board

Illinois Pollution Control Board

-2-

September 2, 2003

By separate cover,

I

am sending one

(1) copy of each of items

1-3 to Mr.

Bradley P.

Halloran,

Hearing

Officer,

Illinois Pollution Control

Board.

Also by

separate

cover,

I

am sending

one

(1)

copy of each

of Items

1-3

to

the

Division of

Legal

Counsel,

Illinois Environmental Protection Agency.

Please return

a file-stamped copy of each document

I

have enclosed.

I am enclosing a self-

addressed stamped envelope for that purpose.

Sincerely,

William

D.

Luck

Assistant General Counsel

Argonne National Laboratory

9700

S. Cass Avenue

Argonne, IL

60439

(630)252-7300

WDL\rb

Enclosures

---

RECEIVED

•

CLERK’S

OFFI

BEFORE THE ILLINOIS

POLLUTION CONTROL BOARD

E

SEP

032003

IN THE MATTER OF:

)

STATE OF IWNOIS

PETITION OF

)

AS

200~’QJ~fition

ControlBoard

ARGONNE NATIONAL LABORATORY

)

(Adjusted Standard

-

Air)

FOR ANADJUSTED STANDARD

)

FROM

35

III. Adm. Code 218.182

•

•

)

WRITTEN TESTIMONY

OF

GREGORY BARRETT

ARGONNE NATIONAL LABORATORY

September 2,

2003

---

WRITTEN TESTIMONY OF GREGORY

EARREfl

This testimony is submitted pursuant to 35

III. Adm. Code

§

103.205 and the July

8,

2003

Hearing Officer Order entered

in this’miatter.

I,

Gregory

Barrett,

being

duly sworn

upon oath, state as follows:

Professional Experience and Em~Iovment

My

name

is

Gregory

Barrett

and

my

business

address

is

9700

South

Cass

Avenue,

Building

331,

Argonne,

Illinois

60439.

I

have

been

employed

in

the

group responsible for environmental compliance at Argonne National

Laboratory

(Argonne) for eleven

(11) years.

Prior to my employment at Argonne,

I worked in

various environmental and technical positions in the chemical

industry for thirteen

(13) years.

At Argonne,

my

primary

area of responsibility

is to

evaluate and

implement

all

federal

and

state regulatory

requirements

related

to the Clean Air Act to

which

Argonne

is

subject.

In

this

capacity

I

prepared

the Argonne

Title V air

permit

application.

I coordinate the exchange of information that bears on air regulatory

matters with the approximately 40 operating

divisions at the Laboratory,

passing

along

information

regarding

regulatory

requirements

and

receiving

information

regarding performance and compliance issues relative to those requirements.

In

this

capacity,

I

worked

with

the

operating

divisions

to

obtain

the

information

necessary to enable

me to prepare

the Argonne Title V air permit application.

continue

to work with

the

operating

divisions to

monitor and

verify

compliance

with the Title V permit’s terms

and conditions,

and to identify circumstances that

may require any modifications to the existing provisioris~of

the permit.

Baókciround

A revised

Illinois regulation, which established new vapor pressure restrictions on

solvents

used

in

cold

cleaning,

became

effective

on

March

15,

1999.

In

preparation for the

implementation of that

regulation,

I

was involved

in efforts to

inform Argonne personnel

engaged

in

potentially

affected

activities

of the new

requirements to be

implemented.

I did this

by means

of quarterly meetings and

memoranda that

described

the

specific

requirements

of

the

revised

regulation

and

provided

information

on

alternative

solvents

that

would

comply

with

the

vapor

pressure

limits.

I

utilized

the

same

approach. in

preparation

for

the

regulation’s March

15,

2001

deadline, which further restricted the vapor pressure

for solvents employed

in cold cleaning.

---

It

became appareflLthat ~hiIe“rnaiflsfre~fn”

type’s

of cbId~

cleaning

activities at

Argonne

(e.g.,

automotive,

machine

shops)

and

some

research

activities

were

able

to

use

solvents

complying

with

the

vapor pressure

limits,

with

respect to

certain

research applications, due to the very stringent requirements of particular

types

of

research,

and

the~,Iimitátions.of

specific

equipment

involved

in

such

research,

it

would

be difficult to comply without compromising the quality of the

equipment

or the

validity

of the

research

results.

The

necessity

of

having the

flexibility

to

use

cold

cleaning

solvents

with

vapor

pressures

higher

than

the

current regulatory !imit in certain

research related applications forms the basis of

the subject Petition for an Adjusted Standard.

Argonne’s Research

Mission and the Anticipated Impact of the Proposed

•

Adjusted

Standard

As

one of the

laboratories

in the

national laboratory

system

owned

by the U.S.

Department of Energy, Argonne

National Laboratory occupies an important

and,

in

many cases,

unique

niche

in the many

branches

of basic energy and related

sciences

research

that

constitute

its

research

mission.

Many

of

Argonne’s

research facilities offer opportunities to the

international scientific community that

represent

state-of-the-art

and

developing

technologies,

which

might

not

otherwise

be

accessible.

The

construction and

operation of such facilities often

require maintenance of an extreme contaminant -free environment, and

methods

that maybe prove

sufficient when employed for cold cleaning

in the conventional

manufacturing

or

processing

sense

can

create

significant

technical

problems

when used

in these more specialized facilities.

Argonne

National

Laboratory

is

committed

to

furthering

its

important

research

mission

on

behalf

of

the

U.S.

Department

of

Energy,

while

complying

with

applicable

environmental

regulations

and

minimizing

the

environmental

impact

resulting from the execution of its

mission.

In my capacity as the coordinator with

the

operating

divisions

on

air

regulatory

matters,

I

directed

that

the

divisions

conduct a

review of their activities that need to

use

organic solvents that do

not

meet the cold cleaning vapor pressure limits.

This

resulted in the compilation of

Exhibit

2

to

the

Petition

for

an

Adjusted

Standard,

attached

hereto

to

my

testimony.

•

•

As

indicated

in

Exhibit

2, the

use of organic solvents

that

do

not meet the cold

cleaning

vapor

pressure

requirements

is

necessary for

cold

cleaning

activities

involving

the

preparation

of

sample

materials

and

associated

apparatus.

for

testing and analysis.

Such activities

include washing

and rinsing sIides~sample

preparation, specimen cleaning,

gel stain/de-staining, membrane rinsing,

and the

cleaning

of small parts

and equipment associated with the preparation of sample

materials for testing and analysis.

This

is the basis for the adjusted standard that

2

---

Argonne

is

proposing

in

the

Petition

for

an

Adjusted

Standard.

The

proposed

adjusted standard also provides that

it

would

not apply where solvents

meeting

the

regulatory

vapor

pressure

limits

can

be

used

without

compromising

the

quality of the equipment being

used or the validity of research results.

Based

on

the

input

I

received

I

also

prepared

Exhibit

3

to

the

Petition

for

an

Adjusted

Standard,

also

attached

hereto

to

my

testimony,

which

shows

the

Laboratory-wide average annual

usage, for the years

1999-2001, for the

organic

solvents

that

would

be

used

to

accomplish

cold

cleaning

under the

proposed

adjusted standard.

It

is estimated that approximately one-thirdof the Laboratory-

wide

usage

of

these

solvents

would

be

for

cold

cleaning,

so

that

the

environmental

impact from

the

requested

adjusted

standard

is

expected to

be

negligible

(estimated

at

no

more

than

200

gallons,

or

approximately

•

1500

pounds,

on an annual

basis).

At the same time the inability to use such solvents

could

adversely

affect

or

possibly

render

inoperable

some

of

the

research

operations that constitute a major component ofArgonne’s mission.

TechnicalDifficulties with Wiping and Solvents Meeting the

Cold Cleaning

Rule

The very nature of volatile organic solvents with

higher vapor pressures,

namely

their

ability

to

evaporate

quickly,

is

the

characteristic

needed

to

perform

acceptable cleaning activities in certain

research applications.

In

such cases the

use

of

a

wiping

technique

or

the

use

of a

low

vapor

pressure

cold

cleaning

solvent

results

in the

presence of residues on

instrument and

sample surfaces.

Such

residues are unacceptable

in systems where

high vacuum conditions must

be

maintained

in order to ensure proper instrument operation and valid !esearch

results

•

~s~•-••

Administrative Difficulties with the CoId~CIea~1hiq’RUIe

While the major concern of Argonne is with the technical difficulties of complying

with the vapor pressure limit of the cold cleaning rule, the recordkeeping aspects

would

impose

a

significant

burden

on

the

Argonne

research

community

that

would appear to far outweigh any benefit.

Because of the small scale intermittent

use

of

common

laboratory

solvents

in

activities

meeting

the

definition

of cold

cleaning, the attempt to track these

usages as a subset

of total

sitewide solvent

usage would be an extremely difficult administrative task.

3

---

ConOlusion

•

Argonne

National

Laboratory

has

a

long

history

of

distinguished

scientific

achievement that

is

well

known

as

it

continues

its

mission

into the twenty-first

century.

I strongly believe that this petition for an adjusted standard

is very much

justified to enable the Laboratory’s important research activities to proceed.

G~egc~y

Bfrrett

vironmental Engineer

Argonne

National Laboratory

9700 S. Cass Avenue

Argonne, Illinois 60439

2.

2~OO3

Date

~

1

Subsc~ed

and Sworn to before me

this

6~—

dayof

~

,2003.

NOTARY PUBLIC

Of~c~I

Se~

M4dam R

Legen

Notery Pub’icState

0q Illinois

My

Commission Expires

10/09/07

4

---

Exhibit 2

Argonne National Laboratory-East

Summary ofCurrent Research-Related Cold Cleaning Activities

On

a

building-by-building

basis,

the

following

listing

sets

forth

information

regarding

current

research-related

use

by

Argonne

National

Laboratory-East research

divisions

of organic

solvents

(ethanol, hexane,

isopropanol, or methanol) for cold

cleaning .activities involving the preparation of

sample

materials

and associated apparatus for testing and analysis.

Such activities include washing

and rinsing

slides, sample preparation, specimen cleaning,

gel stain/de-staining, membrane rinsing,

and the cleaning of small parts and equipment associated with

the preparation of sample materials

for testing and analysis.

Building 200

—

Materials Science

(Rooms 114,

174)

Solvents are

used for

drying

glassware.

Building

202

—

Biosciences (Rooms 111, 210,218,226,254,301,362,366)

Alcohols

(ethanol,

isopropanol,

methanol)

are

used

in

gel

stain/de-staining

and

washing/rinsing

slides.

EthanOl also is used in sterilization.

Building 203

—

Environmental Research

(Room

134)

Solvents are used for sample preparation.

Building 212

—

Energy Technology/Materials Science

(Rooms

106A,

110, 124,

130,

133, 216,

219.

235,

2~fl

•

Solvents

are used for sample preparation.

Building 223

—

Materials Science (Rooms A126, B134. C137, B218,

C226’~

Alcohols

and

xylene

are used

for specimen

cleaning.

•

Building 360— Intense Pulsed Neutron Source

(Room 248)

Solvents are used for sample preparation.

•

Building 362

—

Advanced Photon Source

Experimental

Facilities/Energy Systems

(Rooms

002,

•

208,232)

These

divisions

use

solvents

for

sample

preparation,

glassware

cleaning

(immersion),

and

membrane

rinsing

(isopropanol).

Building

369

—

Energy Systems

Solvents

are

used in glassware cleaning (immersion).

Building 400

—

Advanced Photon Source Operations

(Rooms MLC-1,

1-CR-A)

Solvents may be employed in sample preparation

and small parts cleaning.

Building

401

—

Advanced

Photon

Source

Experimental

Facilities

(Rooms

L0104,

L1103,

L1104,

L2104,L3104)

Solvents may be employed in sample preparation

and

small

parts cleaning.

Buildings 431-435

—

Advanced

Photon Source Users (Rooms 030,

A030, B030, C030,

D030, E030)

Solvents may be used on accelerator systems

and

for sample preparation.

---

Exhibit 3

•

•

1999-2001

Ethanol, hexane,

isopropanol, methanol, and toluene

are solvents identified as being used for cold

cleaning

in research activities

at

Argonne National Laboratory-East.

Although Argonne

can track

total usage of these

solvents, it is infeasible to

track only the

precise usage for cold cleaning.

It is

estimated that about one third ofthe total usage would be for cold cleaning.

The usage information

below is based on average overall annual usage ofeach solvent during theperiod

1999—2001.

Solvent

Total Usage(lb/year)

-

Estimated

Usage for Cold Cleaning in

•

Research Applications

(lb/year)

Ethanol

3,297

•

1,099

Hexane

•

169

56

Isopropanol

•

971

324

Methanol

729

243

Toluene

266

89

---

•

•

RECEIVED

•

CLERK’S

OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP

032003

IN

THE

MATTER

OF:

)

oTATE

/

Po1Iutj0,~Co

t

PETITION OF

)

AS 2003-04

ro~ Oard

ARGONNE NATIONAL

LABORATORY

)

(Adjusted Standard-Air)

FOR AN ADJUSTED STANDARD

)

FROM

35

III. Adm. Code 218,182

•

)

NOTICE OF FILING

PLEASE

TAKE NOTICE that

I

have today filed with the

Office of the Clerk of

the

Pollution

Control

Board

the

WRITTEN

TESTIMONY

OF

GREGORY

BARRETT, a copy ofwhich

is herewith served

upon you.

PLEASE

TAKE

NOTICE

ALSO

that

the

above-referenced

WRITTEN

TESTIMONY

has

been

printed

on

recycled

paper

meeting

the

terms

of the

Pollution Control Board’s regulation on that subject.

For THE UNIVERSITY OF CHICAGO:

~L~~kI/t4~),

L~tL

William

D.

Luck

Assistant General Counsel

Argonne National Laboratory

Operated by The

University of Chicago

For the

U.S. Department of Energy

9700

S. Cass Avenue

Argonne, Illinois 60439

(630) 252-7300

Date

---

IN

THE MATTER OF:

•

)

)

PETITION OF

ARGONNE NATIONAL

LABORATORY

FOR AN ADJUSTED STANDARD

FROM 35

III. Adm.

Code 218.182

CERTIFICATE OF SERVICE

I,

the undersigned,

certify that

I

have

served

the original

and

nine (9) duplicate

copies of

the

attached

WRITTEN

TESTIMONY

OF

GREGORY

BARRETT,

upon

the

following

person, by depositing it with

FEDERAL EXPRESS on this date:

Pollution Control Board

Attention: Clerk

James

R.

Thompson Center

100 W.

Randolph Street,

Suite 11-500

Chicago, Illinois 60601-3218

I further certify that

I

have served

one

(1) copy of the attached WRITTEN TESTIMONY OF

GREGORY BARRETT upon each of the following persons, by depositing it

with FEDERAL

EXPRESS on this date:

Bradley P. Halloran

Hearing Officer

Illinois Pollution Control

Board

James R.

Thompson Center,

100 West Randolph Street, Suite 11-500

Chicago,

Illinois 60601

Rachel Doctors

Division of Legal Counsel

Illinois Environmental

Protection Agency

1021

North Grand Avenue East

P.O.

Box 19276

Springfield,

Illinois 62794-9276

For THE UNIVERSITY OF CHICAGO:

William D.

Luck

Assistant General Counsel

Argonne National

Laboratory

Operated by The

University of Chicago

For the U.S. Department of Energy

9700 S. Cass Avenue

Argonne,

Illinois 60439

(630) 252-7300

~

2,vo~

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARDCI~RKS

OFFrCE

SEP

03

2003

STATE OF.IWNOIS

Pollution Control Board

AS 2003-04

(Adjusted Standard

-

Air)

)

)

)

)

Date

I