BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

IN

THE

MATTER

OF:

PETITION OF

ARGONNE NATIONAL LABORATORY

FOR AN ADJUSTED STANDARD

FROM 35

HI. Adm. Code 218.182

)

)

)

AS 2003-04

)

(Adjusted Standard

-

Air)

)

)

WRITTEN TESTIMONY

•

OF

GREGORY BARRETT

ARGONNE NATIONAL

LABORATORY

September 2, 2003

/

---

WRITTEN

TESTIMONY OF GREGORY

BARRET1

This testimony

is submitted

pursuant to 35

III. Adm.

Code

§

103.205 and the July

8,

2003

Hearing

Officer Order entered

in

this

matter.

I,

Gregory

Barrett,

being

duly sworn upon oath, state as follows:.

Professional Experience and Embloyment

~

I.

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.

I

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 provisions of the permit.

•

.

.

BaôkqrOund

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.

---

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-third of 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 of Argonne’s mission.

Technical’Difficulties 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

research

results.

•

•

•

•

•‘~:‘.

~

•

~

‘/.~.‘

Administrative Difficulties with the CoId~Cte2(flii~q~R

~

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

---

•

•

‘

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

cuneat

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

—

EnvironmentalResearch

(Room 134)

Solvents are used for sample preparation.

Building 212

—

Energy Technology/Materials Science

(Rooms

106A,

110.

124,

130,

133,

216, 219,

235,

Solvents are used

for sample preparation.

Building

223

—

Materials Science

(RoomsA126, 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

Argonne National Laboratory-East

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 the period

1999

—

2001.

Solvent

Total Usage(lb/vear)

•

Estimated Usage for Cold Cleaning in.

Research Applications

(lb/yeañ

Ethanol

3,297

‘

1,099

‘

Hexane

‘

‘

‘

169

56.

Isopropanol

‘

•

971

324

Methanol

729

243

Toluene

266

89

---

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

IN

THE MATTER OF:

)

)

PETITION OF

)

AS 2003-04

ARGONNE NATIONAL

LABORATORY

)

(Adjusted Standard-Air)

FOR AN ADJUSTED STANDARD

)

FROM

35

III. Adm. Code2l8.182

)

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 of which

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:

~

LLA&,

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

---

BEFORE ,THE ILLINOIS POLLUTION CONTROL BOARD

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

Aftention:

Clerk

James R.

Thompson Center

100W. Randolph Street, Suite

11-500

Chicago, Illinois 60601-3218

I further certify that

I

have served

one

(1)

copy of the aftached 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

)

)

)

)

)

)

AS 2003-04

(Adjusted Standard

-

Air)

Date

I

---

ARGONNE

NATIONAL

LABOR&TORY

Argonne, Illinois 60439

Phone:

(630) 252-7300

Fax.

(630) 252-5966

September 2, 2003

Mr.

Bradley P. Halloran

SEP

0

3

2003

Hearing Officer

STATE OF ~LUNOtS

Illinois Pollution Control Board

~~TIONCO~R0~OAiiQi

James R.

Thompson Center

100 W. Randolph Street,

Suite 11-500

Chicago,

Illinois 60601

Dear Mr.

Halloran:

By

the

enclosed

letter

to

the

Clerk

of

the

Illinois

Pollution

Control

Board,

the

therein-

referenced

WRITTEN

TESTIMONY

and

associated

documents

are

being

filed.

Enclosed

herein

is one copy of each of Items

1-3 set forth

in that letter.

Sincerely,

/-~-4441~)),

L~~L

William D. Luck

Assistant General Counsel

Argonne National Laboratory

9700 S. Cass Avenue

Argonne, IL 60439

(630)252-7300

WDL\rb

Enclosures

Operated by The University of Chicago

ARGONNE

NATIONAL

LABORATORY

Argonne, Illinois 60439

Phone: (630) 252-7300

Fax:

(630) 252-5966

September 2, 2003

Ms.

DorothyM. Gunn

Clerkof the Board

Illinois Pollution Control

Board

James R.

Thompson Center

100

W.

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 WRITTENTESTIMONY.

3.

The original and ten (10) copies of the CERTIFICATEOF 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 ofChicago for

The United States Department of

Energy

---

FvIs.

Dorothy M. Gunn

• Clerk ofthe Board

Illinois Pollution Control Board

-2-

September 2, 2003

By separate cover,

I am sending one (1) copy ofeach 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 ProtectionAgency.

Please return a file-stamped copy of each

document

I have enclosed.

I am enclosing a self-

addressed stamped envelope for that purpose.

Sincerely,

1~-

‘~

LA44, L~

William D. Luck

Assistant General Counsel

Argonne National Laboratory

9700 S. Cass Avenue

Argonne, IL 60439

(630)252-7300

WDL\rb

Enclosures