IVIr. Brad Holloran

~

Illinois Pollution Control Board

Clerks Office

James R.

Thompson Center

S

S

Suite 11-500

100 W. RandoifStreet

Chicago, Illinois 60601

March

19, 2004

Subject:

Permit

(PCB 91-17) and AS

02-05)

Dear Mr. Holloran,

I am writing as a concerned citizen with regard to the Henry, IL Noveon, Inc

Plant NPDES permit appeal and adjusted standard application.

I have had the pleasure of

working at the Noveon plant since October 1993, mostly in the Engineering department,

but most recently as Operations Manager.

The plant has a long history ofsafety

excellence and community support.

As a plant, we strongly believe and practice

Responsible Care principals as part ofthe Chemical Industry.

There are many good

people at the plant working hard to keep the plant safe for all employees, for the

community and for the environment.

As an example, we are proud that we have recently

passed a milestone ofover

12 years without a lost time accident.

This is a great

accomplishment for any industry.

Our plant manufactures many useful products,

including additives that make

rubber cure faster, and antioxidants for rubber, plastic and petroleum products.

We also

make corrosion inhibitors, coatings for electronics, and most recentlypersonal care

products.

It’s great to be able to say that these useful products are

still manufactured here

in the United States.

It’s greatthat we still have the equipment assets here in America to

safely produce these products.

But our real assets at the Henry Plant are our people.

That is why I feel compelled to write you this letter.

We at Henry share your concern for the environment.

We have many outdoor

enthusiasts, fishermen, and folks who want their children to enjoy the planet for countless

generations to come.

We have worked hard on Pollution Prevention initiatives to reduce

lost materials to our wastewater treatment system.

In 2003, we received an award from

the Governor for Pollution Prevention.

It was the third suchaward in recent years.

We

believe these efforts make more sense than costly end ofpipe treatment systems.

The quality ofthe water leaving our wastewatertreatment system is monitored

closely.

I understand that

because ofa reversal in interpretation ofregulations, we are

being asked to meet a very stringent requirement on ppm ammonia.

I further understand

that to meet these requirements at our point ofdischarge would require millions and

millions ofdollars, both in term ofcapital and operating costs.

Such a cost would

likely

make it impossible to compete in our industry,

therefore probably causing a significant

cutback ofour greatest asset, our people.

Will the river benefit?

I understand, from the

---

many engineering studies done, that there would be little, if any benefit to the quality of

the water in the river.

Ifthe river does not benefit, then what is to be gained by imposing stiffer water

quality regulations?

The shutdown ofyet another chemical plant

in America?

Could our

products be made by foreign companies overseas?

Perhaps -if we don’t mind paying the

import cost.

Would these products be made in a safer or more environmentally friendly

manner for the planet?

I doubt it.

But I wonder what would happen to the 75

people

currently

employed on the Noveon side ofthe Henry Plant.

Will they be able to fmd

comparable jobs elsewhere in the community?

Instead ofimposing costly, end ofpipe regulations on the Henry Plant, I would

urge the government to work hand and hand with our industry to reduce pollution at the

point ofgeneration, as we have been doing with our Pollution Prevention program.

I

hope the great people ofthe Henry Plant have a chance to continue this effort and to

continue to support the community.

Sincerely,

Stephen W. Saunders

630 Timber Ridge Road

Princeton, IL