RECE~VED
CLERK’S OFFICE
BEFORE
THE
POLLUTION CONTROL BOARD
~
~
2004
OF THE STATE OF ILLINOIS
STATE
OF
ILLINOIS
Poflut!on Control Board
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO:
)
REGULATION OF PETROLEUM LEAKiNG
)
R04-22
UNDERGROUND STORAGE TANKS
)
(UST Rulemaking)
(35
ILL. ADM. CODE 732),
)
)
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO:
)
REGULATION OF PETROLEUM LEAKING
)
R04-23
UNDERGROUND STORAGE TANKS
)
(UST Rulemaking)
(35
ILL. ADM. CODE 734)
)
Consolidated
)
NOTICE OF FILING
TO:
ALL
COUNSEL OF RECORD
(Service List Attached)
PLEASE TAKE NOTICE
that on May 4, 2004, filed with the Clerk of the Illinois
Pollution Control Board ofthe State of Illinois an original, executed copy ofQuestions Pre-Filed
By CW3M in the above-captioned matter on behalfofCW3M Company.
Dated: May 4, 2004
Respectfully submitted,
CW3M Company
By:
(~~&—“~
(ii~eof Its Att~rneys
~
Carolyn S. Hesse, Esq.
Jonathan P. Froemel, Esq.
Barnes & Thornburg LLP
OneNorth Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312) 357-1313
21726 lvi
This filing submitted on recycled paper as defined in 35 Iii. Adm. Code 101.2021
CERTIFICATE OF SERVICE
I, on oath state that I have served the attached Questions Pre-Filed By CW3M by placing
a copy in an envelope addressed to the Service List Attached from CW3M Company, Inc., 701
West South Grand Avenue, Springfield, IL 62704 before the hour of 5:00 p.m., on this
5th
Day of
May, 2004.
~
(‘Q~w~
Carol Rowe
This filing submitted on recycled paper as defined in 35
III.
Adm. Code 101.202
2
Service List
Gina Roccaforte
Kyle Rominger
IEPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
217/792-5544
217/782-9807 (fax)
William G. Dickett
Sidley Austin Brown & Wood
Bank One Plaza
10 South Dearborn Street
Chicago, IL 60603
312/853-7000
312/953-7036 (fax)
Bill Fleischi
Illinois Petroleum Marketers Association
112 West Cook Street
Springfield, IL 62704
217/793-1858
Robert A. Messina
General Counsel
Illinois Environmental Regulatory Group
3150 Roland Avenue
Springfield, IL 62703
217/523-4942
217/523-4948
Lisa Frede
Chemical Industry Council ofIllinois
2250 East Devon Avenue
Des Plaines, IL 60018
(847)
544-5995
Thomas G. Safley
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
217/528-4900
217/523-4948 (fax)
Barbara Magel
Karaganis
&
White, Ltd.
414 North Orleans Street
Suite 801
Chicago, IL 60610
312/836-1177
312/836-9083 (fax)
Joe Kelly, PE
United Science Industries, Inc.
6295
East Illinois Highway 15
P.O. Box 360
Woodlawn, IL 62898-0360
618/735-2411
618/735-2907 (fax)
Kenneth James
Carison Environmental, Inc.
65
East Wacker Place
Suite 1500
Chicago, IL 60601
Michael W. Rapps
Rapps Engineering & Applied Science
821 South Durkin Drive
P.O. Box 7349
Springfield, IL 6279 1-7349
217/787-2118
217/787-6641 (fax)
I
Joel J. Sternstein, Assistant Attorney General
Matthew J. Dunn, Division Chief
Office ofthe Attorney General
Environmental Bureau
188 West Randolph,
20th
Floor
Chicago, IL 60601
312/814-2550
312/814-2347 (fax)
Dorothy M. Gunn, Clerk of the Board
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
100 W. Randolph Street, Suite 11-500
Chicago, IL 60601
312/814-3956
Scott Anderson
Black & Veatch
101 North Wacker Drive
Suite 1100
Chicago, IL 60606
Claire A. Manning
Posegate & Denes
111 North Sixth Street
Springfield, IL 62701
(217) 522-6152
Jonathan Furr, General Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, IL 72702-1271
217/782-1809
217/524-9640 (fax)
A.J. Pavlick
Great Lakes Analytical
1380 Busch Parkway
Buffalo Grove, IL 60089
847/808-7766
David L. Rieser, Partner
McGuire Woods LLP
77 West Wacker Drive
Chicago, IL 60601
312/849-8249
Tom Herlacher, P.E.
Principal Engineer
Herlacher Angleton Associates, LLC
8731 Bluff Road
Waterloo, IL 62298
618/935-2261
618/935-2694 (fax)
James E. Huff, P.E.
Huff& Huff, Inc.
512 West Burlington Avenue
Suite 100
LaGrange, IL 60525
Melanie LoPiccolo, Office Manager
Marlin Environmental, Inc.
1000 West Spring Street
South Elgin, IL 60177
847/468-8855
Brian Porter
Terracon
870
40th
Avenue
Bettendorf, IA 52722
563/355-0702
Glen Lee, Manager
Wendler Engineering Services, Inc.
1770 West State Street
Sycamore, IL 60178
815/895-5008
Joseph W. Truesdale, P.E.
CSD Environmental Services, Inc.
2220 Yale Boulevard
Springfield, IL 62703
217/522-4085
Monte Nienkerk
Clayton Group Services, Inc.
3140 Finley Road
Downers Grove, IL 60515
630/795-3207
S
2
Kurt Stepping
Director of Client Services
PDC Laboratories
2231 West Altorfer Drive
Peoria, IL 61615
309/692-9688
Daniel J. Goodwin
Secor International, Inc.
400 Bruns Lane
Springfield, IL 62702
Richard Andros, P.E.
Environmental Consulting & Engineering, Inc.
551
Roosevelt Road, #309
Glen Ellyn, IL 60137
Steven Gobelman
Illinois Department ofTransportation
2300 Dirksen Parkway
Springfield, IL 62764
Jennifer Goodman
Herlacher Angleton Associates, LLC
522 Belle Street
Alton, IL 62002
Ron Dye
President
Core Geological Services
2621 Monetga
Suite C
Springfield, IL 62704
(217) 787-6109
Erin Curley, Env. Department Manager
Midwest Engineering Services, Inc.
4243 W.
166th
Street
Oak Forest, IL 60452
708/535-9981
Thomas M. Guist, PE
Team Leader
Atwell-Hicks, Inc.
940 East Diehl Road
Suite 100
Naperville, IL
60563
630/577-0800
Dan King, Team Leader
United Science Industries, Inc.
6295 East Illinois Hwy 15
Woodlawn, Ii 62898
618/735-2411
Terrence W. Dixon, P.G.
MACTEC Engineering & Consulting, Inc.
8901 N. Industrial Road
Peoria, IL 61615
Collin W. Gray
SEECO Environmental Services, Inc.
7350 Duvon Drive
Tinley Park 60477
George F. Moncek
United Environmental Consultants, Inc.
119 East Palatine Road
Palatine, IL 60067
Tina Archer, Attorney
Greensfelder, Hemker & Gale
10 South Broadway
Suite 2000
St Louis, MO 63104
314/241-9090
Ken Miller, Regional Manager
American Environmental Corp.
3700 W. Grand Ave., Suite A
Springfield, IL 62707
217/585-9517
S
.4..
3
Russ Goodiel, Project Manager
Applied Environmental Solutions, Inc.
P.O. Box
1225
Centralia, IL 62801
618/533-5953
Eric Minder
Senior Environmental Engineer
Caterpillar, Inc.
100 NE Adams Street
Peoria, IL 61629
(309) 675-1658
208776v1
Jarrett Thomas
Vice President
Suburban Laboratories, Inc.
4140 Lift Drive
Hillside, IL 60162
(708) 544-3260
Daniel Caplice
K-Plus Environmental
600 West Van Buren Street
Suite 1000
Chicago, IL 60607
(312) 207-1600
I
4
REc~~~
CLERK’S OFFIC)E~
BEFORE THE POLLUTION CONTROL BOARD
MAY 04
OF THE STATE OF ILLINOIS
STATE
OF ILLINOIS
IN
THE MATTER OF:
)
PolIut~onControl Board
)
PROPOSED AMENDMENTS TO:
)
REGULATION OF PETROLEUM LEAKING
)
R04-22
UNDERGROUND STORAGE TANKS
)
(UST Rulemaking)
(35
ILL. ADM. CODE 732),
)
)
IN
THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO:
)
REGULATION OF PETROLEUM LEAKING
)
R04-23
UNDERGROUND STORAGE TANKS
)
(UST Rulemaking)
(35
ILL. ADM. CODE 734)
)
Consolidated
)
QUESTIONS PRE-FILED BY CW3M
Now comes CW3M, by and through its attorneys, Barnes & Thornburg, and pre-files the
following questions in the above-captioned consolidated rulemaking proceedings:
1.
734.855 Unusual or Extraordinary Expenses
—
“the Agency can allow
exceedances of the Subpart H amounts on a site-specific basis”
Since the Agency used until
recently a maximum rate sheet, for what percentage of situations where costs above the rate
sheets were requested, did the Agency agree that those requests were justified? Can you describe
any specific situations in which the Agency agreed costs above the maximum listed in the rate
sheets were allowed? For example, a series of USTs are located near each other and some, but
not all, are to be removed, and the remaining USTs are still in use so that shoring and hand-
digging was requiring to remove USTs, and would IEPA consider this a situation where higher
costs would be allowed? Ifnot, why not?
2.
734.865 Increase in Maximum Payment Amounts
--
From what time period was
the data which was evaluated when creating the rates obtained? Why wait two and a half years
to begin raising the rates for inflation? How was the Implicit Price Deflator for Gross National
This filing submitted on recycled paper as defined in 35 Ill. Adm. Code 101.202
Product selected as the inflation factor over other inflation factors such as the consumer price
index? Why is inflation capped at 5 percent? If the inflation rate is greater, why not pay the
actual rate? Ifthere was a 6 percent deflation would Agency still limit the change to
5
percent?
3.
In Doug Clay’s testimony in support of 732.605
—
“This limit is what the Agency
believes is reasonable for destruction or dismantling and reassembly of a structure reflects
historical practice”
On what data or information is this historical practice based? In
determining what the Agency considered is reasonable were any or all ofthe following variables
considered: size of structure, type of construction material, distance from landfill if building is
not to be re-assembled, removal and disposal of any hazardous materials contained within the
building such as asbestos, and the IEPA and U.S. EPA asbestos inspection, notification, removal
and disposal requirements?
4.
In Brian Bauer’ s Introductory Section
—
“these averages are consistent with the
Agency’s historical data”
To what specific historical data is Mr. Bauer referring? Is he
referring to historical rate sheets which IEPA stated have been used throughout the history of the
program? Why didn’t the Agency provide any of these rate sheets or any other historical data
with the Agency’s pre-filed testimony so that the Board and public may review them to verify
Mr. Bauer’s statements?
5.
In Brain Bauer’s testimony in support of 732.8 15
—
“survey of vacuum truck
contractors”
Please name each vacuum truck contractor contacted.
6.
In Brain Bauer’s testimony in support of 732.820(b)
—
The Agency is assigning a
directly proportional rate to well installation. However, isn’t the only difference between the
cost of a 15’ and 20 foot well the amount of riser pipe, sand and bentonite? Aren’t those 3
factors only 3 of the 11 factors used in calculating the well rate while the other factors are
This filing submitted on recycled paper as defined in 35 III. Adm. Code 101.202J
2
constant for each well? Why not propose a formula which had a constant for those factors that
are constant times the number of wells
+
a constant for the other variable factors times the
number of feet in the wells in order to more accurately account for the true costs? Was a formula
like the one described above considered when deriving the monitor well installation rates? Why
orwhy not?
7.
In Brain Bauer’s testimony in support of 732.820(d)
—
“the average costs to
abandon a groundwater-monitoring well is about $150”
How was this number derived? How
many budgets were evaluated and from what time period were they? Why was $1.50 per linear
foot in the original proposed amendments?
8.
In Brian Bauer’s testimony in support of 732.485(a)(2)
--
“one-half of the
average daily expenses”
Did the Agency do any calculations which leads to these rates? It
describes miscellaneous supplies as
“gloves, sampling jars, plastic bags, and all other incidental
materials
“,
a PID and vehicle are also included in the half-day rate, however the Agency has
historically also reimbursed equipment such as survey equipment and water level meter. Under
which ofthe proposed mechanisms are these costs covered?
9.
In Brian Bauer’s testimony is support of 734.845 (a)(2)(A)
—
“based on
conversations with UST removal contractors... consultants are not always present”
With which
UST removal contractors did IEPA personnel have these discussions? Which IEPA personnel
had these discussions? On what information did you determine that one half-day was adequate
for a consultant to be at a tank removal site? Do you feel this is adequate for a tank removal with
a total capacity of 75,000 gallons which takes two days? When asked if consultant’s were
present during UST removal, was the question specifically limited to UST removals where an
IThis filing submitted on recycled paper as defined in 35
III.
Adm. Code 101.202
3
incident for the subject tanks had been previously reported, or was it posed as a general question
for all tank pulls?
10.
In Brian Bauer’s testimony is support of 734.845(b)(2)
—
Your testimony provides
two-half days for one full day of drilling, how did the Agency arrive at the conclusion that
drilling only required one consulting personnel to be on-site? Were the increased sampling
requirements of 734 considered? Is one consulting personnel for drilling activities in line with
the number ofpersonnel proposed by CECI?
11.
In Brian Bauer’s testimony in support of Appendix E
—
“the reimbursed
personnel rate is based on the taskperformed, not necessarily the title of the person performing
the task”
Did the Agency consider if this provision discriminates against small businesses that
have only a few employees? I.e. a small firm cannot afford to hire a registered professional
because they do not have enough “registered professional work” for them to do and cannot
afford to pay them registered professional rates because they are required to bill them at a lower
rate for most of the tasks which they will need to perform.
12.
In Brian Bauer’s testimony is support of 734.840(a)
—
“square foot rates for the
installation of asphalt are from the 2003 National Construction Cost Estimator”
Did the
Agency review the introduction to the National Construction Estimator which explains how to
use the guide prior to utilizing its numbers? Was the required Area Modification Factor utilized?
Was the required Overhead and Markup Factor utilized? Was mobilization included? Was
supervision (foreman) included? For the asphalt replacement rate, was subgrade preparation
included? Is the rate used a residential or commercial construction rate? Why didn’t IEPA use
the rates for concrete listed in the quote?
This filing submitted on recycled paper as defined in 35 III. Adm. Code 101.202)
4
13.
In Harry Chappel’s Introduction
—
“Iwas in privatepractice as a co-owner in two
environmental consulting firms”
As a registered professional engineer, did you certify plan and
budgets for submittal to the LUST Section? Did you ever certify any budgets which exceeded
the maximum amounts listed in these amendments as being reasonable costs?
14.
In Harry Chappel’s testimony in support of 732.825
—
“historically allowed $55
per cubic yard”
When was the $55/yd3 figure derived by the Agency? Was the
$55
dollars per
cubic yard originally developed as a maximum amount or as a guideline above which a time and
materials review was necessary? What is the basis for this formula? How many times have
adjustments been made to the excavation and disposal and backfill figures?
15.
In Harry Chappel’s testimony in support of 732.825
—
‘7lufffactor of 5 percent”
How did the Agency determine the
5
percent “fluff’ factor? Is it a value that the Agency has
historically utilized? If not, what historical value was utilized and what was the reason for its
adjustment?
16.
In Harry Chappel’s testimony in support of732.825
—
“conversion factorfor tons
to cubic yards has been spec~fIed”
The specified conversion factor is l.5.tons per yd3. Is this
the conversion factor which is currently utilized by the Agency? Is the Agency aware that in the
previous revisions to 732, the Board specified that the conversation rate should be 2g/cm3 which
is equivalent to 1.68 tons per cubic yard? Is there a reason the Agency has chosen not to use the
Board specified conversion rate, which was established following public comment at the
previous rulemaking?
17.
In Harry Chappel’s testimony in support of 732.825
—
“This figure (for backfill)
does not include cost for a consultant’s oversight”
Are costs for a consultant’s oversight of
backfill operations included anywhere in Subpart H?
This filing submitted on recycled paper as defined in 35 Ill. Adm. Code 101.2021
5
18.
In Harry Chappel’s testimony in support of 732.835
—
“EPA instead opted to use
the average amounts provided on the IAEL data”
On what basis did the Agency determine that
50
ofthe rates submitted on the IAEL sheet were unreasonable?
19.
In Harry Chappel’s testimony in support of 732.845
—
“The hours estimatedfor
the various activities discussed were derived in consultation with the Consulting Engineers
Council of illinois”
Were the hours proposed for categories provided by the CECI lump sum
values or maximum allowable values? Did the Agency strictly adhere to the same scope of work
for which the CECI had proposed for various values, or did the Agency add to the scope ofwork
without increasing the number ofhours to do the work? For the personnel title breakdowns, did
the Agency adjust the CECI proposal in any way? Was reimbursement claim preparation
included by the CECI into each ofits reports or was it listed as a separate item with its own set of
hours?
20.
In Harry Chappel’s testimony in support of 732.845
—
“a workday of 10 hours
was assumed”
In the Agency’s experience or in the historical data which you state to have
reviewed, have the Agency ever seen instances where professional consulting services were
required for more than 10 hours in one day? Ifmore than ten hours of work are required in one
day then why does the Agency feel that consultants should not be paid for working longer than
10 hours in one day?
21.
In Harry Chappel’s testimony in support of 732.845
—
The average hourly wage in
Mr. Chappel’s section is for both professional field personnel and administrative office
personnel. Why does the Agency feel that it is appropriate to average the rate for office
personnel who never go to the field with hourly rates for field personnel? By setting the $30.00
This filing submitted on recycled paper as defined in 35 Ill. Adm. Code 101.2021
6
limit on mileage aren’t you in effect limiting owners and operators to hiring consultants who
have offices within 82 miles ofthe site (based upon IRS allowed rate of$0.365 per mile)?
22.
In Harry Chappel’s testimony: Attachment 2
—
Is the Agency aware that rates
included in Attachment 3 for Arizona which is labeled “2003 Cost Ceilings” are consistently
higher than the rates that are listed for Arizona in Attachment 2? What is the reason for this
discrepancy?
23.
In Harry Chappel’s testimony: Attachment 5
—
Are you aware that costs in this
section haven’t been effective since 2001? The current costs listed on the Colorado website are
higher than the ones presented in Attachment 5 and are listed as effective since 1/1/02. What is
the reason that the Agency chose to provide old data?
24.
In Harry Chappel’s testimony: Attachment 9
—
Who prepared this attachment?
How were the standard deviations calculated? Why did the Agency included only some of the
P
data points in its standard deviation calculations as opposed to all of the data points provided?
Please provide the specific sites and dates the reports were submitted in order to allow for a
Board or public inspection ofIEPA’s data collection?
.
25.
In Harry Chappel’s testimony: Attachment 12
—
Who prepared this attachment?
Explain the use ofnegative numbers in the 20&45 Day and oversight columns? Because of the
L
obvious errors in this document, please provide all ofthe spreadsheets upon which calculations
were conducted. Attachment 12 appears to indicate the costs included are all early action
consultant costs with the exclusion of any excavation oversight; is this correct? Based on
proposed Subpart H the total amount ofmoney that would be paid for the activities included on
this sheet, including any closure request, would be $6,760. Did the Agency determine how many
of the 15 sites that had their costs included in Appendix 12, would be approved under the
IThis filing submitted on recycled paper as defined in 35 III. Adm. Code 101.2021
7
proposed maximum allowable rates? Did the Agency intend that 9of the 15 sites would have
costs above the limits in Subpart H? Is the Agency aware that in the sample set collected,
consultants would have had unreasonable fees in 60 ofthe cases?
26.
Subpart H General
--
According to Mr. Bauer’s testimony, a number of sites were
reviewed and average costs of the data reviewed are listed. Please produce the supporting
documentation for all of the rates calculated in the form of spreadsheets in Appendices? For the
data selected in these calculations, what was the timeframe of the submitted reports from which
the data was selected and when was the data evaluation completed?
27.
Subpart H General
--
In some ofthe sections of Mr. Bauer’s testimony, it is stated
that IEPA utilized the average costs to calculate the maximum rates, why is it that you feel that
50 of consultants and their subcontractors have been submitting unreasonable rates? What
evaluation did the Agency do, if any, to determine that
50
of the consultants were
overcharging? Has the Agency testified in the past that the average plus one standard deviation
was (which covered 84 of costs) the method for determining maximum rates in its rate sheets?
What is the Agency’s rationale for the change from that method? When the average plus one
standard deviation was utilized, what was the reasoning for its selection?
28.
Subpart H General
--
Did the Agency review OSHA regulations (29 CFR 1926) in
conjunction with efforts to develop the field oversight rates and the number of consulting
personnel required for certain activities?
29.
Subpart H General
--
In the Agency’s testimony for Part 734, it describes how a
• consultant is paid half-days for drilling activities, yet there is no similar description in Part 732.
While I understand that drilling activities are included in the lump sums for site classification,
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8
don’t sites classified as High Priority require delineation of the plume following site
classification? How will these costs be funded?
30.
Subpart H General
--
Is the Agency aware that its proposed rates for personnel are
actually less than previously approved rates; for example the proposed rates are 26
less than
the personnel rates previously approved by the Agency for site classification ($13,400 previous
and $9,870 currently)? What new information led the Agency to make this adjustment?
31.
Subpart H General
—
Subpart H provides maximum costs for writing specific
reports, if the Agency requests additional information which is already present in the report or
requires revisions which exceed the minimum requirements of the Act, is there any mechanism
for payment of these costs. Even if the response is a one-page letter or a couple of phone calls
why should the owner or operator eat costs that were incurred due to errors by Agency
personnel?
32.
Subpart H General
--
The Agency has repeatedly stated recently that they cannot
complete reviews of costs based on time and materials without the assistance of some sort of
guidance rates. On that basis what criteria will the Agency use to determine reasonableness on a
time and materials basis for items such as alternative technologies and free product removal?
33.
Subpart H: General
--
The proposed maximum allowable rate for preparation of a
Corrective Action Plan is the same in Part 734 and Part 732. Aren’t the technical requirements
different since High Priority CAPs in Part 732 also require all of the site investigation and plume
delineation activities to be included in addition to the requirements of a CAP for Part 734? The
Agency conservatively allowed at least $4,800 for that type of work in Part 734 site
investigation, is there a reason that an additional $4,800 is not included in the CAP preparation
costs for Part 732?
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9
34.
Subpart H: General
--
Instead of setting lump sum rates, did the Agency consider
utilizing formulas, that took into account site-specific factors such distance from services. If so,
why was that idea rejected? If not, why not?
35.
Subpart H: General
--
The Agency provides costs for excavation and disposal and
then alternative technologies must be budgeted on a time and materials basis. The Agency also
requires cost comparisons to conventional technology for alternative technology proposals.
What is the Agency considering conventional groundwater treatment technology and what is its
mechanism forpayment?
36.
Subpart H: General
--
If the fuel tax exemption for off-road diesel is lifted,
excavation and backfill costs will increase. Is there any provision to raise rates if this or any
other factors outside normal inflation occur which directly cause an increase in costs?
37.
Subpart H: General
--
The regulations should include the methods and procedures
for setting rates, not the rates themselves. This way, factors outside the realm of normal
inflation, such as the fuel tax exemption for off-road diesel can be addressed more quickly.
What is the Agency’s reason for publishing the rates in the regulations as opposed to simply
calculating a method for determining the rates in which the rates can more easily be adjusted for
changing real world situations.
This filing submitted on recycled paper as defined in 35 Ill. Adm. Code 101.202
10
38.
March 15, 2004 Hearing (D. Clay)
--
Are you aware that some, but not all of the
LUST project managers are implementing the technical requirements of proposed 734, despite
your assertion that these rules are not yet being implemented?
Dated: May 4, 2004
Respectfully submitted,
CW3M Company
By:
~
~
C
C
and:
By:
E~~3~-~K-
~—‘~
~
-
One ofIts At~drneys
S
Carolyn S. Hesse, Esq.
Jonathan P. Froemel, Esq.
Barnes & Thornburg LLP
One North Wacker Drive
Suite 4400
Chicago, Illinois 60606
(312)357-1313
21721 5v 1
This filing submitted on recycled paper as defined in 35 Ill. Adm. Code 101.202
11
