1
    1
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    2
    OF THE STATE OF ILLINOIS
    3
    December 22, 2004
    4 IN THE MATTER OF:
    )
    5
    )
    6 PETITION OF JO'LYN
    )
    7 CORPORATION and FALCON
    )
    8 WASTE AND RECYCLING INC., ) AS 04-2
    9 FOR AN ADJUSTED STANDARD ) (Adjusted Standard-Land)
    10 FROM 35 ILL. ADM. CODE
    )
    11 810.103, OR IN THE
    )
    12 ALTERNATIVE, A FINDING OF )
    13 INAPPLICABILITY
    )
    14
    15
    TRANSCRIPT OF PROCEEDINGS held in the
    16 above-entitled cause before Hearing Officer Amy C.
    17 Antoniolli, called by the Illinois Pollution Control
    18 Board, pursuant to notice, taken before Tamara
    19 Manganiello, RPR, a notary public within and for the
    20 County of Will and State of Illinois, at the McHenry
    21 County College, 8900 U.S. Highway 14, Crystal Lake,
    22 Illinois, on the 22nd day of December, A.D., 2004,
    23 scheduled to commence at 9:00 o'clock a.m.,
    24 commencing at 9:07 o'clock a.m.
    L.A. REPORTING (312) 419-9292

    2
    1 A P P E A R A N C E S:
    2
    3
    ILLINOIS POLLUTION CONTROL BOARD,
    100 West Randolph Street
    4
    Suite 11-500
    Chicago, Illinois 60601
    5
    (312) 814-3900
    BY: MS. AMY C. ANTONIOLLI, HEARING OFFICER,
    6
    MS. ALISA LIU, BOARD STAFF and
    MR. ANAND RAO, BOARD STAFF,
    7
    8
    SWANSON, MARTIN & BELL,
    One IBM Plaza
    9
    330 North Wabash, Suite 3300
    Chicago, Illinois 60611
    10
    (312) 923-8260
    BY: MS. ELIZABETH S. HARVEY,
    11
    Appeared on behalf of Jo'Lyn Corporation
    12
    and Falcon Waste and Recycling, Inc.;
    13
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
    14
    1021 North Grand Avenue East
    P.O. Box 19276
    15
    Springfield, Illinois 62794-9276
    (217) 782-5544
    16
    BY: MR. JOHN J. KIM,
    17
    Appeared on behalf of the Illinois
    Environmental Protection Agency.
    18
    19
    20
    21
    22
    23
    24
    L.A. REPORTING (312) 419-9292

    3
    1
    HEARING OFFICER ANTONIOLLI: Good
    2
    morning, everyone. My name is Amy
    3
    Antoniolli. Today, I am filling in for Brad
    4
    Halloran, who is the hearing officer assigned
    5
    to this matter but couldn't make it today
    6
    because he is sick as well as his family.
    7
    This matter is entitled Adjusted
    8
    Standard, it's docketed as AS 04-2 and the
    9
    title of it is, In The Matter Of: Petition
    10
    of Jo'Lyn Corporation and Falcon Waste and
    11
    Recycling for an adjusted standard from 35
    12
    Ill. Adm. Code, part 807, or in the
    13
    alternative, a finding of inapplicability.
    14
    We're here at the McHenry County
    15
    College and we appreciate them letting us use
    16
    their facility today. It's December 22nd,
    17
    2004. It's approximately five after 9:00,
    18
    and I do note that there are several members
    19
    of the public present, maybe 12 to 15 people
    20
    here from the public, and if they so choose,
    21
    anyone can make public comment. Members of
    22
    the public can also choose to testify about
    23
    this petition, but like all witnesses, anyone
    24
    who wishes to testify must be sworn in and
    L.A. REPORTING (312) 419-9292

    4
    1
    then subject to cross-questioning.
    2
    I will also note that from the
    3
    Board today there are two members here from
    4
    the technical unit, Mr. Anand Rao and
    5
    Ms. Alisa Liu.
    6
    The hearing is intended to develop
    7
    a more complete record for review for the
    8
    Illinois Pollution Control Board. I'm not
    9
    going to be making the ultimate decision in
    10
    this case, that decision is left up to the
    11
    five members of the Pollution Control Board.
    12
    They'll review the record, the transcript and
    13
    also the post-hearing briefs if they are
    14
    filed and render a decision in this matter.
    15
    My job is to ensure an orderly
    16
    hearing, a clear record and rule on any
    17
    evidentiary matters that may arise today.
    18
    I do note that we are going to run
    19
    this hearing pursuant to the Board's
    20
    procedural rules found at Section 104.400
    21
    through 104.428 of the Illinois
    22
    Administrative Code.
    23
    And, again, it's been noticed up
    24
    pursuant to Board regulations. With that
    L.A. REPORTING (312) 419-9292

    5
    1
    said, would the parties like to introduce
    2
    themselves?
    3
    MS. HARVEY: My name is Elizabeth
    4
    Harvey and I represent the petitioners,
    5
    Jo'Lyn Corporation and Falcon Waste and
    6
    Recycling Incorporated. I also have with me
    7
    Cathy Powles of those two entities. Thank
    8
    you.
    9
    HEARING OFFICER ANTONIOLLI: Thank
    10
    you.
    11
    MR. KIM: My name is John Kim,
    12
    attorney with the Illinois EPA.
    13
    HEARING OFFICER ANTONIOLLI: Thank
    14
    you. And with that I can turn it over to
    15
    Ms. Harvey to begin.
    16
    MS. HARVEY: Thank you, very much,
    17
    Madam Hearing Officer.
    18
    I just wanted to make a brief
    19
    opening statement, not to belabor the points,
    20
    but just to kind of set the stage a little
    21
    bit.
    22
    This is, as the Hearing Officer
    23
    mentioned, a hearing on the petition of
    24
    Jo'Lyn Corporation and Falcon Waste and
    L.A. REPORTING (312) 419-9292

    6
    1
    Recycling, Incorporated, for one of two
    2
    things. Either an adjusted standard from the
    3
    Pollution Control Board's waste regulation or
    4
    a determination that those waste regulations
    5
    are inapplicable.
    6
    Jo'Lyn and Falcon purchased a
    7
    material called granulated bituminous shingle
    8
    material or as we'll refer to it, GBSM, all
    9
    caps, which is a clean and consistent
    10
    pre-consumer material that is purchased from
    11
    the manufacturer of roofing shingles.
    12
    These are manufacturers'
    13
    residuals, if you will, small pieces of the
    14
    material, color and things that are wrong,
    15
    material that just simply cannot be packaged
    16
    and sold. These are not, for the record,
    17
    tear-off shingles that have already been used
    18
    by a consumer. Jo'Lyn and Falcon use the
    19
    GBSM after they purchase it to produce a
    20
    paving product which is called Eclipse Dust
    21
    Control. Eclipse Dust Control is a durable
    22
    product that is unique in the sense that it
    23
    requires no chemical binders and no hot mix
    24
    asphalt and no sealant on top of it. The
    L.A. REPORTING (312) 419-9292

    7
    1
    GBSM is shredded, those shredded pieces,
    2
    which we'll show you a sample of, are applied
    3
    to the end-user's location, whether it be a
    4
    driveway, a parking lot, bike paths, walking
    5
    paths, et cetera, that material is then
    6
    compressed using a very large, I believe,
    7
    ten-ton vibratory roller to compress the
    8
    material and then the sun does -- actually
    9
    completes the bonding process. The heat of
    10
    the sun just compresses those enough to form
    11
    a solid surface. IEPA has taken the position
    12
    that GBSM is a waste, which would require
    13
    Falcon and Jo'Lyn to comply with all the
    14
    waste rules applicable to landfills, transfer
    15
    stations and other waste facilities.
    16
    It is our position that the waste
    17
    regulations are inapplicable to this process
    18
    because GBSM is not discarded and therefore,
    19
    doesn't fit the statutory definition of
    20
    waste. So our position is it's not a waste.
    21
    The Illinois Appellate Court, in a
    22
    similar case, has ruled that a similar
    23
    material is not a waste, and recently the
    24
    Illinois Supreme Court agreed with that.
    L.A. REPORTING (312) 419-9292

    8
    1
    We believe that that's controlling
    2
    authority and that the Board should follow
    3
    that authority to determine that this product
    4
    is also not a waste.
    5
    We will address that and update
    6
    the status of that in our post-hearing briefs
    7
    that we will file after this hearing.
    8
    So our purpose today is two-fold.
    9
    First of all, we're going to supplement the
    10
    information that's already in the record.
    11
    We've already filed what's already been filed
    12
    in the record, so there will be additional
    13
    information placed in the record. And we
    14
    also want to take the opportunity to address
    15
    some specific questions that have been raised
    16
    by both the Pollution Control Board and by
    17
    IEPA, so we can perhaps address those issues.
    18
    I plan to call two witnesses,
    19
    Cathy Powles, on behalf of Jo'Lyn and Falcon
    20
    and I will also be calling Mr. David Foulkes,
    21
    who is a representative of IKO, who is the
    22
    entity from which we buy -- purchase the
    23
    GBSM. I don't know if Kim would like to --
    24
    MR. KIM: If I may, I just have a very
    L.A. REPORTING (312) 419-9292

    9
    1
    brief statement.
    2
    I just wanted to make clear that
    3
    the recommendation that's been filed thus far
    4
    by the Illinois EPA, which is to deny the
    5
    adjusted standard that's been presented, both
    6
    in its original and amended form, is not
    7
    reflective of any kind of judgment as to the
    8
    merits or benefits of the proposed operation.
    9
    It's simply the Illinois EPA's position that
    10
    based on the regulations and statutes that
    11
    are applicable -- that we believe are
    12
    applicable to the proposed facility and
    13
    proposed operation, the material that
    14
    Ms. Harvey just described, GBSM, is a waste
    15
    and therefore waste regulations must be
    16
    followed.
    17
    That being the case, the only
    18
    appropriate method for relief would be an
    19
    adjusted standard and we believe that there
    20
    are certain deficiencies that we brought to
    21
    the Board's attention that need to be
    22
    addressed before an adjusted standard could
    23
    be approved.
    24
    Ms. Harvey also mentioned a -- at
    L.A. REPORTING (312) 419-9292

    10
    1
    least one case that was issued by the
    2
    Illinois Supreme Court recently and I agree
    3
    with her that the case that she refers to may
    4
    have some direct impact on this case.
    5
    However, the Illinois EPA and
    6
    through the Illinois Attorney General's
    7
    office has asked the Supreme Court to
    8
    reconsider that decision, and therefore based
    9
    upon the Supreme Court's, to date, failure to
    10
    act upon that, we continue to take the
    11
    position that the material is a waste. That
    12
    may be amended. We may have to adjust our
    13
    position depending on what the Supreme Court
    14
    does down the road.
    15
    HEARING OFFICER ANTONIOLLI: Thanks
    16
    Mr. Kim and Ms. Harvey. At this point, does
    17
    anyone else have questions before we begin,
    18
    or comments? Okay. Would you like to call
    19
    your first witness?
    20
    MS. HARVEY: Yes, please. Are we
    21
    going to have the witness sit here?
    22
    HEARING OFFICER ANTONIOLLI: Whatever
    23
    is more comfortable for you both, really.
    24
    That's fine. As long as you talk loud enough
    L.A. REPORTING (312) 419-9292

    11
    1
    so that the public and the court reporter can
    2
    hear.
    3
    MS. HARVEY: Maybe we'll switch you
    4
    this way so -- but face and be sure that the
    5
    court reporter can hear you. That way she
    6
    can get down your every word. Thank you,
    7
    Madam Hearing Officer.
    8
    HEARING OFFICER ANTONIOLLI: Sure.
    9
    Would you please swear in the witness?
    10
    (Witness sworn.)
    11 WHEREUPON:
    12
    KATHY POWLES
    13 called as a witness herein, having been first duly
    14 sworn, deposeth and saith as follows:
    15
    DIRECT EXAMINATION
    16 BY MS. HARVEY:
    17
    Q. Will you state your name for the
    18 record, please?
    19
    A. Katherine Powles.
    20
    Q. And Kathy, what's your -- who are you
    21 here representing today?
    22
    A. Well, I am here representing Falcon
    23 Waste and Recycling, Inc., and Jo'Lyn Corporation.
    24
    Q. Okay. And what's your title with
    L.A. REPORTING (312) 419-9292

    12
    1 those two corporations?
    2
    A. Jo'Lyn Corporation, I am
    3 vice-president, and Falcon Waste and Recycling, I am
    4 president of.
    5
    Q. Okay. Tell me a little bit about your
    6 educational background. Did you graduate from high
    7 school?
    8
    A. Yes.
    9
    Q. Do you have education past the high
    10 school level?
    11
    A. Yes.
    12
    Q. What kind of education?
    13
    A. Just additional courses, just help my
    14 education, no degree or anything like that.
    15
    Q. College courses?
    16
    A. Correct.
    17
    Q. Okay.
    18
    A. And I've gone to several seminars and
    19 different things like that.
    20
    Q. What has the subject of the seminars
    21 been?
    22
    A. Most of them have dealt with recycling
    23 and asphalt pavement, beneficial uses for products,
    24 those are the relevant ones to this case.
    L.A. REPORTING (312) 419-9292

    13
    1
    Q. Okay. What year did you start your
    2 involvement with Jo'Lyn and Falcon?
    3
    A. Jo'Lyn started in 1997, and at that
    4 time I was a part of it. So did Falcon Waste and
    5 Recycling, however, they were of one entity at that
    6 time.
    7
    Q. Okay. Who else is an officer in
    8 Falcon and Jo'Lyn?
    9
    A. Donald Powles.
    10
    Q. Okay. Are you related to Mr. Powles?
    11
    A. Yes, he's my husband.
    12
    Q. Okay. Does Falcon and Jo'Lyn have
    13 waste disposal -- waste business experience prior to
    14 the formation of Falcon and Jo'Lyn in 1997?
    15
    A. Definitely. That was our whole
    16 purpose of getting involved in the industry. My
    17 husband, Don, used to work for BFI in Waukegan,
    18 Illinois. He worked just about every single facet
    19 of the industry there, in the landfill, on the back
    20 of the trucks, dispatch, managing the drivers,
    21 sales, and he was the recycling coordinator and he
    22 implemented the recycling curb side and drop off
    23 programs in Waukegan and Zion at the time.
    24
    Q. What did you do --
    L.A. REPORTING (312) 419-9292

    14
    1
    A. The first ever, I would like to add.
    2
    Q. Just briefly, what did you do before
    3 you worked with Jo'Lyn and Falcon? What was your
    4 work experience?
    5
    A. I was a stay-at-home mom to begin
    6 with. I had my children, raised the children and
    7 then I had my own sign business for 13 years, I was
    8 self-employed.
    9
    Q. And you've been involved with Jo'Lyn
    10 and Falcon since 1997; is that correct?
    11
    A. Yes, since the beginning.
    12
    Q. When Jo'Lyn was founded in 1997, what
    13 was the purpose of that business? What business did
    14 it practice?
    15
    A. Well, Jo'Lyn had two companies working
    16 underneath it, one was Klip Art Signs, which was a
    17 high sign company and we had billboards and signs.
    18 And then it was Falcon Waste and Recycling, we
    19 had -- we started with one roll-off truck and five
    20 dumpsters, that's how it started.
    21
    Q. You mentioned earlier that Jo'Lyn and
    22 Falcon are now two separate companies. Can you just
    23 explain a little bit about the division of
    24 responsibilities between the two entities?
    L.A. REPORTING (312) 419-9292

    15
    1
    A. Yes. Falcon pretty much does all the
    2 legwork and the trucking and those sorts of things,
    3 the paperwork, where Jo'Lyn more is the sales for
    4 the recycled product. The reason why we've kind of
    5 made that split was because it's been proven that if
    6 you put recycled commodity on your product, it sells
    7 less. They've done that in tests, so if we could
    8 keep recycling out of the name of products, it seems
    9 to work the best.
    10
    Q. So Jo'Lyn is essentially the marketing
    11 arm and the purchasing arm; is that correct?
    12
    A. Yes.
    13
    Q. And then Falcon would be responsible
    14 for that actual physical work?
    15
    A. Yes.
    16
    Q. But the two companies share the same
    17 ownership, correct?
    18
    A. Yes.
    19
    Q. Now, we're here today to talk about a
    20 process that Jo'Lyn and Falcon are involved in that
    21 uses GBSM to create a paving product.
    22
    How did you come from the waste
    23 disposal and recycling end of your business to
    24 looking into using GBSM as a paving product? When
    L.A. REPORTING (312) 419-9292

    16
    1 did that happen?
    2
    A. When we started the research or --
    3
    Q. Yeah. When did you start researching
    4 the idea?
    5
    A. It was --
    6
    Q. Approximately?
    7
    A. It was approximately 1999.
    8
    Q. Okay.
    9
    A. And we went to our first seminar -- I
    10 started research before that -- and then I was
    11 fortunate enough to go to a seminar put on by ARMA,
    12 Asphalt Roofing Manufacturers Association, and there
    13 we formed many contacts, actually I believe our
    14 manufacturer was there at the time, but it was --
    15
    Q. And when you say our manufacturer, who
    16 do you mean?
    17
    A. David Foulkes from IKO.
    18
    Q. IKO is from whom you buy the GBSM; is
    19 that correct?
    20
    A. Yes.
    21
    Q. Okay. Ms. Powles, I also forgot to
    22 ask you, I think you have some memberships in some
    23 organizations that are relevant when I asked you
    24 about your educational background. Do you have
    L.A. REPORTING (312) 419-9292

    17
    1 organizations that you belong to that have been --
    2 you've served on?
    3
    A. Yes. Currently we're in the Chambers
    4 with Harvard, Woodstock and Richmond-Spring Grove.
    5 In 1999 or 2000 -- I'm not sure on the year, excuse
    6 me -- I was president of the Richmond-Spring Grove
    7 Chamber. And I'm in the Lou Marchi Total Recycling
    8 Institute. I'm on the Solid Waste Committee for the
    9 McHenry County Defenders. I'm a member of the
    10 Illinois Recycling Association, a member of the
    11 Construction Materials Recycling Association, also
    12 known as CMRA, and I'm also a member of the Green
    13 Building Council.
    14
    Q. Thank you. How many employees does
    15 Jo'Lyn have?
    16
    A. Jo'Lyn has two.
    17
    Q. How about Falcon?
    18
    A. Currently we have about six or seven.
    19
    Q. Are those full-time positions?
    20
    A. Not all of them, no.
    21
    Q. Okay. Full-time year-round or
    22 full-time -- not full-time year-round or not
    23 full-time 40 hours a week?
    24
    A. Not full-time year-round.
    L.A. REPORTING (312) 419-9292

    18
    1
    Q. Okay.
    2
    A. The season typically slows down in the
    3 winter months.
    4
    Q. Okay. So we've talked about that the
    5 product that you use -- that you make from GBSM is a
    6 paving product. And what's the name of the paving
    7 product, what do you call it?
    8
    A. Eclipse Dust Control.
    9
    Q. And what kind of applications can you
    10 use the Eclipse Dust Control for?
    11
    A. Well, primarily for dust control and
    12 that's the best benefit for it, driveways, parking
    13 lots, bike paths, pretty much we've just had it in
    14 driveways currently. A lot of people use it in
    15 roadways for dust control, gravel roads, things like
    16 that.
    17
    Q. Okay. The GBSM that we're already
    18 bantering those letters about, I'd like to be able
    19 to show the Board and the people -- I think you
    20 brought a sample. Is this the GBSM?
    21
    A. Yes.
    22
    Q. Okay. Now, this is after it's been
    23 shredded at your facility, correct?
    24
    A. Correct.
    L.A. REPORTING (312) 419-9292

    19
    1
    MS. HARVEY: I guess I'd like to put
    2
    this into the record as Exhibit -- can we use
    3
    numbers -- 1.
    4
    HEARING OFFICER ANTONIOLLI: Please
    5
    do.
    6
    MS. HARVEY: I think that the exhibits
    7 to the petition are lettered.
    8 BY MS. HARVEY:
    9
    Q. This is the box that shows the GBSM
    10 after it is shredded. Can you tell us approximately
    11 the size of these pieces?
    12
    A. Yeah, they're a quarter inch by an
    13 inch and a half, two inches.
    14
    Q. Is this representative of the kind of
    15 thing you would use in your paving application?
    16
    A. Yes, it is.
    17
    Q. Okay.
    18
    MS. HARVEY: Let me show Mr. Kim so he
    19
    can see the GBSM.
    20
    So I'd like to introduce this as
    21
    Exhibit No. 1, I believe it would be.
    22
    HEARING OFFICER ANTONIOLLI: Okay.
    23
    (Document marked as Exhibit No. 1
    24
    for identification, 12/22/04.)
    L.A. REPORTING (312) 419-9292

    20
    1
    HEARING OFFICER ANTONIOLLI: I'll hold
    2
    this up for everyone. You can take a look.
    3
    If there are no objections, I will go ahead
    4
    and enter this box of GBSM into the record as
    5
    Hearing Exhibit 1. And seeing none, I will
    6
    enter that as Exhibit 1. Thank you.
    7
    (Whereupon, Exhibit No. 1 was
    8
    received in evidence by the
    9
    Hearing Officer.)
    10
    MS. HARVEY: Thank you, Madam Hearing
    11
    Officer.
    12 BY MS. HARVEY:
    13
    Q. When you purchase the GBSM, what does
    14 it look like?
    15
    A. Well, it looks similar to that, but
    16 they're longer tabs and we will also get sheet
    17 material which simply looks like a shingle for your
    18 home. It's the bigger, longer sheets.
    19
    Q. Okay. And am I correct that you
    20 actually purchase the GBSM?
    21
    A. Yes.
    22
    Q. And currently you purchase it from
    23 IKO?
    24
    A. Correct.
    L.A. REPORTING (312) 419-9292

    21
    1
    Q. The GBSM is -- explain to me a little
    2 bit about why one would have GBSM. What's the
    3 course of it, why is it not usable by the
    4 manufacturer?
    5
    A. Well, because of their quality
    6 control, I would say, for their product to be placed
    7 on to the roof of the material that they're selling.
    8 Am I answering your question?
    9
    Q. Yes, you are.
    10
    A. You know, either it has mis-colored
    11 rocks on top, or, you know, for whatever reason,
    12 they do not pass certain quality control, they will
    13 not put it on the market, so then we purchase it
    14 from them and it's a very valuable commodity.
    15
    Q. When you say that it doesn't pass
    16 quality control, you mean in terms of customer
    17 satisfaction for their customers, correct?
    18
    A. Right. Exactly. For their roofing
    19 shingle product. For their product that they're
    20 currently manufacturing.
    21
    Q. Has that GBSM been mingled with any
    22 other kind of waste at the facility to your
    23 knowledge?
    24
    A. No.
    L.A. REPORTING (312) 419-9292

    22
    1
    Q. Okay. Let's talk a little bit about
    2 some of the benefits of the GBSM -- or excuse me,
    3 about the Eclipse Dust Control after you apply it.
    4
    A. Okay.
    5
    Q. Why is this a product that is useful?
    6
    A. Well, it keeps mud down and it keeps
    7 noise down and it keeps the dust down. It's -- and
    8 it actually looks nicer. It helps ruts in your
    9 driveway, it elongates the life of gravel, it saves
    10 natural resources as a product, it would be for a
    11 nicer looking driveway, to not have to deal with the
    12 gravel all the time, and to have a nice, solid coat
    13 over the top. Basically the same reasons you would
    14 pave your driveway, it's the exact same type of
    15 thing, either blacktop or asphalt or even brick
    16 pavers, brick pavers are pretty nice looking, but,
    17 you know, it's the same type of reasoning.
    18
    Q. So you can essentially replace a
    19 blacktop or asphalt application with Eclipse Dust
    20 Control?
    21
    A. Yes.
    22
    Q. Okay.
    23
    A. And many people -- like, we've had a
    24 couple tours of our facility and our test sections
    L.A. REPORTING (312) 419-9292

    23
    1 that we do have out there, and interestingly enough,
    2 a lot of the people commented on how they liked the
    3 different look. You know, they want variety, they
    4 don't what everybody else has. They like the
    5 different look and the quality of it because it does
    6 not crack.
    7
    Q. Okay. We're going to talk in a second
    8 about it in a little bit more detail about your
    9 operations and about how it's installed, but just
    10 generally speaking, can you give me an idea of how
    11 it goes from the larger the piece of the GBSM that
    12 you purchased from IKO, to how it gets to the
    13 Eclipse Dust Control. What do you do to it?
    14
    A. Well, it simply just gets ground in a
    15 horizontal grinder, it comes out the opening.
    16
    Q. And how about the installation?
    17
    A. The installation, it's simply just
    18 unloaded onto the pavement in different areas and
    19 there's two ways to apply it. It is spread in two
    20 different fashions and then it's rolled with a heavy
    21 duty ten-ton vibratory roller.
    22
    Q. Do you use any sealant on it?
    23
    A. No, we don't. That's what makes the
    24 product so great, it's just through the sun, we're
    L.A. REPORTING (312) 419-9292

    24
    1 not adding any chemicals, there are no residuals in
    2 our process. There's, you know -- so, here we're
    3 taking a product, we're making a new product, we're
    4 not creating any residuals. We're not using any
    5 other chemicals to add on to it. It's just -- it's
    6 a great thing.
    7
    Q. Okay. Let's talk a little bit in a
    8 little bit more detail. I want to -- I think you
    9 have a copy of this.
    10
    MS. HARVEY: I want to introduce this
    11
    as Exhibit No. 2, Madam Hearing Officer, what
    12
    I have provided to Mr. Kim and to I think all
    13
    of you, this is the operating manual for the
    14
    production and application of Eclipse Dust
    15
    Control for Jo'Lyn Corporation and Falcon
    16
    Waste dated this year. So I guess I would
    17
    ask that that be marked and admitted as
    18
    Exhibit No. 2.
    19
    (Document marked as Exhibit No. 2
    20
    for identification, 12/22/04.)
    21
    HEARING OFFICER ANTONIOLLI: Okay. And
    22
    I have that in front of me, and if there are
    23
    no objections, I will enter this operating
    24
    manual for production and application of
    L.A. REPORTING (312) 419-9292

    25
    1
    Eclipse Dust Control into the record as
    2
    Hearing Exhibit 2.
    3
    MR. KIM: I'm not going to object, but
    4
    I just want to note for the record that
    5
    Exhibit 1 and Exhibit 2 and probably some of
    6
    these other exhibits, the Illinois EPA hasn't
    7
    seen the documents yet, so the recommendation
    8
    that we filed thus far would not necessarily
    9
    make reference to these things and based upon
    10
    this information presented at hearing, we may
    11
    have to enter our post-hearing filing, revise
    12
    our comments.
    13
    HEARING OFFICER ANTONIOLLI: And
    14
    you'll have the option to file a post-hearing
    15
    brief if you wish to do that.
    16
    MR. KIM: Thank you.
    17
    HEARING OFFICER ANTONIOLLI: So I will
    18
    go ahead then and enter this operating manual
    19
    into the record as Exhibit 2.
    20
    (Whereupon, Exhibit No. 2 was
    21
    received in evidence by the
    22
    Hearing Officer.)
    23
    MS. HARVEY: Thank you, Madam Hearing
    24
    Officer.
    L.A. REPORTING (312) 419-9292

    26
    1 BY MS. HARVEY:
    2
    Q. Kathy, I just want to walk you a
    3 little bit through this so that we can explain to
    4 the Board and the Agency and the members of the
    5 public exactly where you are and what you do
    6 basically. The first portion of this operating
    7 manual just simply provides a site map. Where is
    8 your facility located?
    9
    A. We're in the city limits of Woodstock,
    10 it's located 1200 North Rose Farm Road. It is
    11 commercial or industrial zoned property, it's
    12 properly zoned.
    13
    Q. Okay. And I believe on Page 3 of this
    14 Exhibit, there is a map of your site?
    15
    A. Uh-huh.
    16
    Q. That indicates where specific
    17 activities are performed on your site?
    18
    A. Correct.
    19
    Q. Can you just walk us through a little
    20 bit for those of us who have the benefit of having
    21 copies what the major features of your facility are?
    22
    A. Well, I think one of the better
    23 features of our facility is it's very far away from
    24 any public view, it's one of the benefits. The road
    L.A. REPORTING (312) 419-9292

    27
    1 is all the way -- well, you see on the bottom if you
    2 hold your paper upright -- the road is down there,
    3 Rose Farm Road, it's surrounded with trees and it's
    4 just very nice and mature.
    5
    Q. So when you go up the driveway, what
    6 are there storage areas, is there parking? What's
    7 at your facility when you come up that driveway from
    8 Rose Farm Road?
    9
    A. Well, when you come up the driveway
    10 right in front of you are the stockpiles of the
    11 GBSM.
    12
    Q. Okay.
    13
    A. To the right, we have parking and
    14 storage area and our office building.
    15
    Q. Where does the grinding actually
    16 occur?
    17
    A. Right in between the two piles of
    18 GBSM. I know it's hard to see, but X marks the
    19 spot. Which we'd relocate according to which part
    20 of the pile that we'd be grinding at that time.
    21
    Q. So the grinder is movable?
    22
    A. Right. It's portable, so the
    23 operation would be portable.
    24
    Q. Okay.
    L.A. REPORTING (312) 419-9292

    28
    1
    A. But at that location specifically.
    2
    MR. RAO: Ms. Harvey, may I?
    3
    MS. HARVEY: Please.
    4
    MR. RAO: In this Figure One, does it
    5
    also show your property boundary lines?
    6
    THE WITNESS: Pretty much it does,
    7
    yes. This is actually a property map, but I
    8
    don't have it all in here.
    9
    MS. HARVEY: I will tell you, it is
    10
    not exactly to scale because when we
    11
    reproduced it it smooshed it a little bit,
    12
    but it's still representative of the site.
    13
    MR. RAO: Does the property boundary
    14
    go all the way up to the working railway
    15
    line?
    16
    THE WITNESS: Yes, it does.
    17
    MR. RAO: Okay. And what is the
    18
    zoning of this area?
    19
    THE WITNESS: It is commercial or
    20
    industrial, I'm not -- you know, sometimes
    21
    they change, depending on where you're at,
    22
    and quite frankly it is properly zoned. They
    23
    have zoned it research and development,
    24
    whatever it's commercial or industrial. I do
    L.A. REPORTING (312) 419-9292

    29
    1
    believe it's industrial.
    2
    MS. HARVEY: There is information in
    3
    our petition about the zoning of this site.
    4
    MR. RAO: Thanks.
    5
    MS. HARVEY: Sure.
    6 BY MS. HARVEY:
    7
    Q. Do you store the finished product
    8 after -- and by the finished product, I mean after
    9 you've shredded the GBSM -- do you store the
    10 finished product on-site?
    11
    A. No. We really -- we haven't been able
    12 to grind, but we feel it is absolutely the best
    13 service to our customers, and just the application
    14 of the whole procedure, we grind it and place it
    15 right into a receptacle that then gets transported
    16 to the customer.
    17
    Q. So you don't grind it until you have
    18 an order ready to grinding?
    19
    A. Correct.
    20
    Q. Let's move on and I want to talk a
    21 little bit about your operating manual provides a
    22 list of the equipment that you use at your facility.
    23 Can you just go through those real quickly so that
    24 the Board has an idea of what's used out there?
    L.A. REPORTING (312) 419-9292

    30
    1
    A. Okay. Yeah. We have the grinder,
    2 that's what actually does the grinding. It's a
    3 horizontal grinder. It's pretty -- it's a portable
    4 horizontal grinder. We have a link belt excavator
    5 on tracks, so that moves around when we stockpile
    6 the material when it needs to be. We also have a
    7 bobcat. We don't really use that to move the
    8 shingles. Shingles are very difficult to move so
    9 the bobcat really won't --
    10
    Q. When you say shingles, you mean the
    11 GBSM?
    12
    A. Correct, excuse me.
    13
    Q. That's okay.
    14
    A. So the bobcat is basically used for
    15 when we spread it and apply it, and we have the
    16 truck and a trailer for hauling the material and
    17 several roll-off receptacles.
    18
    Q. Okay. Now, this operating manual also
    19 contains, I believe, it's about two-and-a-half
    20 almost three pages of your operating procedures. We
    21 won't take the time of the Board and the Agency to
    22 go through every detail, but let's hit on the
    23 highlights of what it breaks down to. The first
    24 category, I believe, is the trucking. How do you
    L.A. REPORTING (312) 419-9292

    31
    1 know when to go to IKO to make a pick-up for
    2 shingles or GBSM?
    3
    A. We actually have a camera set up and
    4 we see pictures of it, we have an hourly snapshot of
    5 it that we retrieve over the internet.
    6
    Q. So you're looking at the actual box
    7 on-site at IKO?
    8
    A. Uh-huh.
    9
    Q. Correct?
    10
    A. Uh-huh.
    11
    Q. So when it gets close to full, is that
    12 when you --
    13
    A. Yeah, I know about when. It's on a
    14 little conveyor, so you can kind of predict.
    15 Sometimes we get there a little bit too early and
    16 sometimes we've gotten there just a little bit too
    17 late. We just have to wait a little bit longer and
    18 reorganize, but yes.
    19
    Q. Okay. So you send a driver to -- from
    20 the Jo'Lyn facility to IKO. Where is IKO's facility
    21 located?
    22
    A. Bedford Park, it's down by Midway.
    23
    Q. Okay. And is IKO the only
    24 manufacturer that you currently purchase GBSM from?
    L.A. REPORTING (312) 419-9292

    32
    1
    A. Yes.
    2
    Q. Are you interested, if approved, to be
    3 able to run your operation -- do you anticipate
    4 perhaps seeking additional manufacturers of GBSM?
    5
    A. Yes, I really do because we've had
    6 just great feedback from this, so to have enough
    7 supply for the demand, it would be --
    8
    Q. Are there asphalt shingle
    9 manufacturers in Illinois?
    10
    A. Yes.
    11
    Q. Who are in the Chicago -- located in
    12 the Chicago metropolitan area?
    13
    A. Yes.
    14
    Q. So you have other sources of the GBSM
    15 potentially?
    16
    A. Yes.
    17
    Q. When your truck gets to IKO, I'm sure
    18 it goes in, it's weighed, then what happens?
    19
    A. We switch out the boxes and they get
    20 re-weighed. We do examine the boxes. Some of this
    21 stuff is just to normal for us I forget to go over
    22 it.
    23
    Q. Let me stop you there. When you say
    24 the boxes, it's my understanding -- and please
    L.A. REPORTING (312) 419-9292

    33
    1 correct me if I'm wrong -- that there are two
    2 different types of boxes at the IKO facility, one
    3 has the GBSM tabs in it; is that correct?
    4
    A. Yes.
    5
    Q. What is a GBSM tab?
    6
    A. It's the little piece -- if you look
    7 at your shingle, it's a little tab, you usually have
    8 three tabs on your shingles, and it's that little
    9 slot that makes it look like there's three pieces.
    10
    Q. So its the cutout?
    11
    A. Yes.
    12
    Q. Okay. And I believe that you've also
    13 referred previously to GBSM sheets?
    14
    A. Uh-huh.
    15
    Q. Where are GBSM sheets?
    16
    A. They're the full shingle that has not
    17 passed quality control for whatever reason, could be
    18 wrong colors. Additionally, it could be a line
    19 break in the back feed of material, when they're
    20 creating it, so they don't want that piece out on
    21 the market, however it does have to go through the
    22 whole process, things like that.
    23
    Q. Okay. And those -- the GBSM sheets
    24 are stored separately from the GBSM tabs?
    L.A. REPORTING (312) 419-9292

    34
    1
    A. Yes, they are.
    2
    Q. So when you pick up, do you pick up
    3 both boxes?
    4
    A. Yes.
    5
    Q. Then they're hauled back into the
    6 Jo'Lyn facility?
    7
    A. Correct.
    8
    Q. When your driver picks up the GBSM at
    9 the facility, you mentioned that you do examine the
    10 GBSM. What's the purpose of that? What are you
    11 looking for?
    12
    A. Well, just to make sure that
    13 everything is safely packed in there and just to
    14 kind of glance to make sure it's a clean, consistent
    15 load, which we have never had anything in there, but
    16 you always want to check your load no matter what
    17 you're hauling, and then to tarp the box to make
    18 sure that it hauls safely.
    19
    Q. Does your contract give you the right
    20 to refuse or to reject GBSM if it's not consistent
    21 with the consistent material?
    22
    A. Yes. However, that has never
    23 occurred.
    24
    Q. Okay.
    L.A. REPORTING (312) 419-9292

    35
    1
    A. It's never occurred.
    2
    Q. But you have the right to do it if it
    3 were to occur?
    4
    A. Yes.
    5
    Q. And I think -- I'm sorry, I think I
    6 might have talked over you. I understand that you
    7 tarp this material -- or you tarp the boxes before
    8 it's transported back to Woodstock; is that correct?
    9
    A. Correct.
    10
    Q. Okay. When you get it back to your
    11 facility in Woodstock, what happens?
    12
    A. We put it in a -- I don't know if --
    13 I'm going to say the staging area.
    14
    Q. That's okay.
    15
    A. I'm not sure if that's correct. And
    16 it's in the center of the picture right around where
    17 the grinder actually sits. We use that and the
    18 grinder isn't sitting there right now, but we use
    19 that as a temporary storage just to kind of conserve
    20 on when we hire the excavator to come in and all
    21 that type of stuff, and it gets placed there, when
    22 that area gets full we stockpile it onto the
    23 piles --
    24
    Q. Do you rotate that?
    L.A. REPORTING (312) 419-9292

    36
    1
    A. -- in chronological order so freshest
    2 is here and it goes around in a circle and it comes
    3 back on the side. So we would always use the oldest
    4 product first and --
    5
    Q. Why do you use the oldest product
    6 first?
    7
    A. Because I think it makes good sense.
    8 I think that's the best way to do business.
    9
    Q. Does it cut down on your storage time
    10 in that particular load of GBSM?
    11
    A. Yes.
    12
    Q. Do you mix the GBSM tabs and the GBSM
    13 sheets when you store them at your facility?
    14
    A. Kind of, but not. I mean, they can be
    15 combined in rolls, but they're not really, they are
    16 done separately. I don't know that we've --
    17 purposely have done that.
    18
    Q. Okay. Do you have a standard on how
    19 high the piles of GBSM can be?
    20
    A. Yes.
    21
    Q. How high is that?
    22
    A. Twenty-five feet.
    23
    Q. What happens if you were to have more
    24 than that, would you just create a new pile?
    L.A. REPORTING (312) 419-9292

    37
    1
    A. No. We're kind of at a standstill
    2 right now, so...
    3
    Q. Yes.
    4
    A. We would just move it over a little
    5 bit more. No, we are limited to that area.
    6
    Q. Oh, yeah, I'm sorry, I wasn't clear.
    7 I didn't mean that you'd create a new area, I meant
    8 that instead of going up you'd go over, correct?
    9
    A. Correct.
    10
    Q. Now, when you get an order for Eclipse
    11 Dust Control and it's time to go out and pave --
    12 install the product at the site, what procedures
    13 happen then? Is that when you do the grinding?
    14
    A. Yes.
    15
    Q. How does the grinding work?
    16
    A. Well, the excavator puts it into the
    17 grinder, it has an in-feed and a little drum roller
    18 and it pushes it through grates which actually make
    19 it smaller, it comes out about -- feeds directly
    20 into the receptacle, it is carried to the customer.
    21 And there's two different ways to install it, so he
    22 would either put it right into the asphalt spreader,
    23 or kind of spread/dump it like you see gravel doing,
    24 to spread it with the bobcat.
    L.A. REPORTING (312) 419-9292

    38
    1
    Q. Okay. When you truck it to the --
    2 when you truck the shredded GBSM to the location, is
    3 that container tarped, is it covered?
    4
    A. Yes.
    5
    Q. Let's talk a little bit about the
    6 installation of the actual -- you mentioned that you
    7 would spread it out, depending upon whether you use
    8 an asphalt spreader or the bobcat. Then what
    9 happens after you've deposited the GBSM at the
    10 customer's location?
    11
    A. I'm going to step back just a minute.
    12 Before we even do that, the area needs to be graded,
    13 just like you would a regular driveway. If you're
    14 getting -- whatever product you're using, you have
    15 to properly grade the material so it has a little
    16 arc in the driveway. All that kind of stuff,
    17 otherwise the product really won't last. So that is
    18 done first. We fill it with gravel, smooth out the
    19 actual gravel and base, we make a good solid base,
    20 the material is brought in and it's spread either
    21 way, there's two different ways it's spread, and
    22 then it is compacted with a roller.
    23
    Q. How thick is the GBSM after spreading
    24 but before it's compacted? How much do you put on
    L.A. REPORTING (312) 419-9292

    39
    1 there?
    2
    A. After it is spread, before it's
    3 compacted?
    4
    Q. Right.
    5
    A. It's between six to four inches. It
    6 varies between six to four inches. And when it's
    7 compacted, it really just smooshes down quite a bit
    8 and it goes to about a two-inch material, some areas
    9 it's three and it's --
    10
    Q. After it's compacted with the
    11 vibratory roller, does the sun continue that process
    12 of the sealing, if you will?
    13
    A. Yes. And you do need the full sun.
    14
    Q. So you only currently apply this
    15 product in full-sun areas?
    16
    A. Yes.
    17
    Q. I have another sample. This is -- Ms.
    18 Powles, can you identify for us what this is?
    19
    A. That is actually the material that we
    20 submitted in Exhibit 1, and we actually just made a
    21 little sample of it, so it's very heavy, sorry, and
    22 it's made of steel and we put it in here and
    23 actually drove over it with the truck. We did have
    24 one of those little halogen lights on it for a
    L.A. REPORTING (312) 419-9292

    40
    1 minute which softened it up just a little bit.
    2 Yeah. And I think that has been there for, I'm
    3 going to say three, four years that has been in
    4 this.
    5
    Q. Okay. So is this representative of
    6 the finished product that the GBSM would be?
    7
    A. Yes, it is.
    8
    Q. Okay. So that's called Eclipse Dust
    9 Control, right?
    10
    A. Yes. Uh-huh.
    11
    Q. Okay.
    12
    MS. HARVEY: So I would like to place
    13
    this into evidence as Exhibit 3. I'll show
    14
    to Mr. Kim so that you can actually see what
    15
    the product looks like. You can see that it
    16
    looks quite a bit like asphalt.
    17
    (Document marked as Exhibit No. 3
    18
    for identification, 12/22/04.)
    19
    MR. KIM: Can I see the back?
    20
    MS. HARVEY: Sure. It's just a frame
    21
    essentially. Obviously, think of this
    22
    without the metal.
    23
    MS. HARVEY: It's heavy, sorry.
    24
    HEARING OFFICER ANTONIOLLI: Now that
    L.A. REPORTING (312) 419-9292

    41
    1
    everyone has had a chance to see this, does
    2
    anyone have any objection to me entering this
    3
    into the record as Hearing Exhibit 3? And
    4
    seeing none, I will enter this sample of
    5
    Eclipse Dust Control into the record as
    6
    Exhibit 3.
    7
    (Whereupon, Exhibit No. 3 was
    8
    received in evidence by the
    9
    Hearing Officer.)
    10
    MS. HARVEY: Thank you, Madam Hearing
    11
    Officer.
    12 BY MS. HARVEY:
    13
    Q. Miss Powles, have Jo'Lyn and Falcon
    14 created test sections of the Eclipse Dust Control?
    15
    A. Yes.
    16
    Q. How many?
    17
    A. Two.
    18
    Q. Okay. When was the first one
    19 installed?
    20
    A. Well --
    21
    Q. Approximately?
    22
    A. It was over four years ago.
    23
    Q. Okay. In 2000?
    24
    A. Uh-huh. Sounds good.
    L.A. REPORTING (312) 419-9292

    42
    1
    Q. And where was that installed?
    2
    A. In Harvard at Two Kennedy Drive.
    3
    Q. Is it a driveway installation?
    4
    A. Yes.
    5
    Q. And how has that test section held up?
    6
    A. It's really held up the best out of
    7 all the test sections. We're very happy with it.
    8 There's -- there is no cracking there. It's a
    9 beautiful product, it really is. It's held up
    10 great.
    11
    Q. And your second test section, when was
    12 that installed?
    13
    A. That is two solid years. I want --
    14
    Q. Yeah.
    15
    MS. HARVEY: For the record --
    16 BY THE WITNESS:
    17
    A. It's a little over two years.
    18
    MS. HARVEY: -- most of this
    19
    information is contained in the amended
    20
    petition that was filed by the petitioners
    21
    in, I believe, July, and also, there are
    22
    pictures attached to that exhibit of the GBSM
    23
    test sections as well.
    24
    HEARING OFFICER ANTONIOLLI: Ms.
    L.A. REPORTING (312) 419-9292

    43
    1
    Powles, can I ask real quick, is this
    2
    Exhibit 3 now the sample of Eclipse Dust
    3
    Control, what you would take to visit a
    4
    client when you show them what the final
    5
    product would be like?
    6
    THE WITNESS: Yes.
    7
    HEARING OFFICER ANTONIOLLI: Okay.
    8 BY MS. HARVEY:
    9
    Q. I'm sorry, forgive me if I've asked
    10 you this. How has the second test section held up?
    11
    A. It's held up very good, also, in the
    12 full sun area. Part of that was installed in the
    13 shade and when we did do that, we were aware that it
    14 needed full sun, but we still wanted to test the
    15 area -- test -- you know. So it has held up very
    16 well. We plow at both locations.
    17
    Q. Let me ask you this. What's the
    18 location of your second test section? Where is that
    19 installed?
    20
    A. That is in McHenry County in the
    21 Heartland Township.
    22
    Q. Okay. Have you installed any other
    23 test sections or just those two?
    24
    A. No, just those two.
    L.A. REPORTING (312) 419-9292

    44
    1
    Q. Am I correct that you have orders from
    2 customers -- when you have the environmental okay to
    3 go ahead, that you have orders for installation?
    4
    A. Yes.
    5
    Q. Okay.
    6
    A. In fact, we've had several calls for a
    7 more -- more material -- more customers, however,
    8 we're not able to service them. And, you know,
    9 luckily they're waiting for us so far, but, yeah, we
    10 did lose one customer.
    11
    MS. HARVEY: And, again, for the
    12
    record, the information relating to those
    13
    contracts is attached to the -- I believe the
    14
    first petition for adjusted standard and
    15
    copies of those contracts are also included
    16
    as exhibits to that petition.
    17 BY MS. HARVEY:
    18
    Q. Miss Powles, I want to turn to -- the
    19 Pollution Control Board asked some fairly specific
    20 questions in the order directing us to come to
    21 hearing, and we have prepared a written document
    22 that I think you have that addresses some of those.
    23 It looks like this (indicating). I think everybody
    24 has it.
    L.A. REPORTING (312) 419-9292

    45
    1
    MS. HARVEY: I just want to -- first
    2
    of all, I guess I'd like to mark this as
    3
    Exhibit 4, I believe it would be, although I
    4
    do intend to have Ms. Powles read the answers
    5
    for the benefit of the public and because
    6
    Mr. Kim had not had a chance to see this
    7
    prior to this morning. But I'd like to mark
    8
    it as an exhibit because I am going to ask
    9
    her to read directly off of it.
    10
    (Document marked as Exhibit No. 4
    11
    for identification, 12/22/04.)
    12
    HEARING OFFICER ANTONIOLLI: Okay.
    13
    And I know you've had a short time to look at
    14
    this, Mr. Kim, but do you or anyone else have
    15
    any objection to me entering this testimony
    16
    of Kathy Powles on behalf of petitioners into
    17
    the record as Exhibit 4?
    18
    MR. KIM: No.
    19
    HEARING OFFICER ANTONIOLLI: Okay.
    20
    And seeing none, I will enter that as
    21
    Exhibit 4.
    22
    (Whereupon, Exhibit No. 4 was
    23
    received in evidence by the
    24
    Hearing Officer.)
    L.A. REPORTING (312) 419-9292

    46
    1
    HEARING OFFICER ANTONIOLLI: And you
    2
    can go ahead.
    3
    MS. HARVEY: Thank you.
    4 BY MS. HARVEY:
    5
    Q. Ms. Powles, "How does the GBSM form a
    6 cohesive surface through compaction and sun
    7 exposure?"
    8
    A. "GBSM is predominantly crushed
    9 limestone, trap rock and asphalt; it comes to us in
    10 various sized strips. These strips bend easily.
    11 Once they have been exposes to the sun for one to
    12 two hours, the material becomes more pliable and
    13 bends easier. The trap rock is the outer coating on
    14 one side of the GBSM; this rock is a small cubical
    15 rock. A cubical rock has a larger surface area than
    16 a smooth rounded rock, and has pointed edges. This
    17 rock and the asphalt/limestone mixture is the major
    18 factor in the binding capabilities. Please note
    19 that, when GBSM is used as a roofing shingle, it
    20 will bond together on the roof. The roofers do use
    21 nails, but you can clearly see in a windstorm that
    22 shingles do not start to flop in the wind because
    23 there is a bond with each shingle not only at the
    24 nailed area." And that occurs simply from the sun.
    L.A. REPORTING (312) 419-9292

    47
    1
    "For pavement application the
    2 material is ground, installed, and compacted. Under
    3 the pressure of compaction, the small trap rock will
    4 puncture the crushed limestone/asphalt mixture,
    5 creating a secure adhesion to the material above and
    6 below. Plus, the fresh ground edges will bond
    7 together, by their composition alone."
    8
    Q. Thank you. Are fine or loose GBSM
    9 present in newer applications after you completely
    10 compact the material and it's been exposed to the
    11 sun?
    12
    A. "As in any pavement application, there
    13 are small amounts of material that do not bond.
    14 (This is true with concrete and blacktop pavements.)
    15 The same is true with GBSM. Our test sections show
    16 that the trap rock is the material that typically
    17 falls to the edge of the pavement. We are convinced
    18 that this happens because the material has gotten
    19 dusty. Picture if you will two balls of dough. If
    20 you try to stick them together they will stick with
    21 ease. However if you roll those same balls of dough
    22 in flour and press them together they do not stick."
    23
    Q. I think that's a good analogy. Could
    24 you please describe the expected EDC (Eclipse Dust
    L.A. REPORTING (312) 419-9292

    48
    1 Control) surface as it wears and continues to
    2 weather beyond its useful life, and whether or not
    3 it yields fines or loose material?
    4
    A. "We expect the surface of EDC to
    5 continue to have a strong bond for several years.
    6 Our four-year-old test section shows only a small
    7 amount of wear. When closely examined, the minimal
    8 breakdown comes from some of the trap rock that is
    9 on the top of the surface, which breaks away. We
    10 believe this breakaway to occur when plowing the
    11 snow off the surface in the winter months. It has
    12 been a very small amount.
    13
    In a regular blacktop or concrete
    14 roadway, during the winter months contraction and
    15 expansion occur. During this time, you can notice
    16 cracking and upheaval of the blacktop or concrete
    17 material in large sections, where large pieces will
    18 break away. This will occur within its first year
    19 of life of the blacktop or concrete surface.
    20 Conversely, EDC has not cracked in four-year-old
    21 test section; there have not been any large or small
    22 chunks that have broken away during the seasonal
    23 weather changes.
    24
    We expect the surface to continue
    L.A. REPORTING (312) 419-9292

    49
    1 its secure bond, with small amounts of loose
    2 material, the trap rock, to flow to the edge of the
    3 pavement. The shingles are more resilient to the
    4 weather than other current pavement methods. We
    5 believe this to be from the larger pieces that make
    6 up the material, because of the overlapping of that
    7 material that bonds together makes it more difficult
    8 to crack during expansion and contraction."
    9
    Q. What is the range of the expected
    10 useful life of the EDC surface?
    11
    A. "We foresee the expected life of EDC
    12 as a solid pavement base to range from six to
    13 eight years, if not longer. We currently have two
    14 test sections of EDC. The first test section was
    15 made of 1/4" by 6" pieces of GBSM. The first test
    16 section was installed in August 2000. The second
    17 test section was created with 1/2" minus pieces of
    18 GBSM, installed in August of 2001. In the full-sun
    19 areas, both are holding a strong bond, with a smooth
    20 surface. We anticipate the material to last as long
    21 as blacktop paving, if not longer."
    22
    Q. Please discuss the fate of the EDC
    23 applied product after its useful life: Whether it
    24 becomes a new waste to be removed, whether it can be
    L.A. REPORTING (312) 419-9292

    50
    1 incorporated into a fresh application of EDC,
    2 whether it can serve as a subbase for another paving
    3 material, whether it can be removed and used as a
    4 component of recycled asphalt pavement or if there
    5 are other possible applications?
    6
    A. "Good question, because I think all
    7 products should be asked this question before they
    8 come on the market. As everything, it could become
    9 a waste; it's basically up to the owner. However,
    10 EDC can be broken up and graded, used by itself or
    11 mixed with either gravel, recycled asphalt pavement
    12 (RAP) or recycled concrete and used as a subbase
    13 material for roadways. There are other potential
    14 uses. Other uses and markets for removed EDC are:
    15 1) Subbase material for roadways; 2) Subbase
    16 material for around piping (i.e., water and sewer
    17 lines); 3) Mixed with an emulsion and used as
    18 pothole patch; 4) Mixed with gravel, for dust
    19 suppression; 5) Compressed and formed into paving
    20 blocks; 6) Gravel/EDC mixture for the edge of
    21 roadways."
    22
    Q. Would you incorporate an old EDC
    23 application into a new EDC application?
    24
    A. Currently, not at this time, no.
    L.A. REPORTING (312) 419-9292

    51
    1
    Q. Do you plan to promote EDC for use --
    2 installation on feed lots?
    3
    A. "No. We will remove --" even though
    4 it is on our flyer. "We will remove feedlots from
    5 the list of uses of the material. We have not
    6 actively gone after this market even though it is on
    7 our flier, which we will remove. I stress that our
    8 removal of this use is not because we believe there
    9 is any harmful exposure to livestock to fines or
    10 particles of EDC. However, in order to allay any
    11 concerns about potential health effects, we will not
    12 include feedlots as a potential market for EDC. I
    13 would like to add, though, they do use this method
    14 to keep down mud in Canadian feedlots."
    15
    Q. And finally in this particular
    16 section, do you intend to use GBSM in hot mix
    17 asphalt?
    18
    A. "During research and development we
    19 did look at GBSM being used in the hot mix asphalt.
    20 GBSM is often used in hot mix asphalt in other areas
    21 of the country. However, we have found the 'Eclipse
    22 Dust Control' method to be a far superior
    23 application. It uses less energy to create, both in
    24 trucking and processing. So the answer to the
    L.A. REPORTING (312) 419-9292

    52
    1 question is: No, we do not intend to use GBSM in
    2 hot mix asphalt."
    3
    Q. Thank you, Ms. Powles. During the
    4 course of this proceeding, and I believe in some of
    5 your conversations with IEPA even prior to the
    6 beginning of this process, there have been some
    7 environmental concerns that have been raised about
    8 the GBSM and its applications.
    9
    First of all, let me back up. Did
    10 you meet with IEPA prior to -- or during the time
    11 when your were starting this business?
    12
    A. Yes.
    13
    Q. And what was the purpose of those
    14 meetings?
    15
    A. Well, to get our water -- water runoff
    16 or our storm water permit, which we have, and to get
    17 an air permit.
    18
    Q. And did you receive an air permit?
    19
    A. No.
    20
    Q. Why was the air permit denied?
    21
    A. They said I needed a land permit.
    22
    Q. And did you file an application for a
    23 land permit?
    24
    A. Yes.
    L.A. REPORTING (312) 419-9292

    53
    1
    Q. And what was the outcome of that?
    2
    A. It was denied.
    3
    Q. Okay. And why was it denied?
    4
    Let me put it another way. Was it
    5 denied for reasons that you hadn't complied with
    6 some of the content requirements that are applicable
    7 to waste facilities? You didn't provide some of the
    8 information that they needed?
    9
    A. Yes.
    10
    Q. Okay. In your conversations with
    11 IEPA, did they consistently take the position that
    12 GBSM is a waste?
    13
    A. No.
    14
    Q. Okay. Were you ever told that it was
    15 not a waste and you didn't need a permit?
    16
    A. Yes.
    17
    Q. But then the eventual outcome was the
    18 Agency's position was that it is a waste, correct?
    19
    A. Yes, currently.
    20
    Q. Okay. There have been some
    21 environmental questions raised about the GBSM. Do
    22 you know if there has been testing of the GBSM
    23 itself performed, not by Jo'Lyn, but by IKO?
    24
    A. Yes.
    L.A. REPORTING (312) 419-9292

    54
    1
    Q. And do you know what the results of
    2 those tests were in general?
    3
    A. They were all good. They all passed.
    4 So much so that the IEPA gave them a letter of its
    5 approval of GBSM to use -- to be used for pavement
    6 purpose and in hot-mix applications.
    7
    Q. Do you know what the date of that
    8 letter was?
    9
    A. 1993.
    10
    Q. Okay.
    11
    MS. HARVEY: And for the record, we've
    12
    submitted that letter into the record, it's
    13
    attached as an exhibit to the petition -- the
    14
    original petition, and actually it would also
    15
    be included in a group exhibit we'll be
    16
    entering later.
    17
    HEARING OFFICER ANTONIOLLI: Okay.
    18 BY MS. HARVEY:
    19
    Q. Did you rely upon that letter when you
    20 started your business -- or when you moved into the
    21 Eclipse Dust Control, excuse me?
    22
    A. Yes.
    23
    Q. And are you aware of any reason -- any
    24 change in the IKO -- the IKO GBSM since that 1993
    L.A. REPORTING (312) 419-9292

    55
    1 date that would change any of the environmental
    2 concerns?
    3
    A. No. There have been no changes and we
    4 have requested information on that, and there have
    5 been no changes in the composition of the material
    6 since they got their determination, as is stated in
    7 that letter.
    8
    Q. Now, we touched a little bit upon the
    9 quality control that Jo'Lyn uses, but let's go back
    10 to that for a second.
    11
    How do you ensure that nothing
    12 gets into the GBSM that you shred except GBSM? Do
    13 you do a visual inspection at the facility?
    14
    A. It's visual, yes. We do a visual at
    15 both locations when we unload it, when we stockpile
    16 it and, you know, if I might add, we are putting
    17 this through a very expensive piece of machinery and
    18 if there are any contaminants in it, we are risking
    19 a $225,000 piece of machinery to be damaged and, you
    20 know, that just won't happen.
    21
    Q. And I believe you said that in your
    22 business relationship with IKO you've never had a
    23 need too reject any GBSM?
    24
    A. Correct.
    L.A. REPORTING (312) 419-9292

    56
    1
    Q. But I'm correct that your contract
    2 allows you to do so if you were to find that there
    3 was a problem with the load?
    4
    A. Yes.
    5
    Q. Okay. Do you do, at your site, any
    6 physical or chemical testing of the -- I'm talking
    7 about at the Jo'Lyn facility now -- of the GBSM?
    8
    A. No, we do not.
    9
    Q. Okay. Do you think that there's a
    10 need to test?
    11
    A. No, because it is a consistent
    12 material that comes from the manufacturer. We are
    13 purchasing that specific material and that is what
    14 we are getting.
    15
    Q. Okay.
    16
    A. We have no reason to doubt that, you
    17 can visually see.
    18
    Q. So you could tell by looking at it,
    19 with your level of experience, that this is the
    20 material that you need for your business?
    21
    A. Yes.
    22
    MS. HARVEY: I do want to go back a
    23
    minute to the 1993 waste determination, which
    24
    I think I will, with the hearing officer's
    L.A. REPORTING (312) 419-9292

    57
    1
    permission, pull out of it. There's a large
    2
    rubber banded exhibit that has IKO letterhead
    3
    on the top. The third document in that
    4
    exhibit is the May 1993 solid waste
    5
    determination from IEPA. It is already in
    6
    the record, but so that I can show this to
    7
    the witness, I would like to mark this
    8
    separately as -- I think that's Exhibit 5?
    9
    (Document marked as Exhibit No. 5
    10
    for identification, 12/22/04.)
    11
    HEARING OFFICER ANTONIOLLI: This
    12
    letter separate from the documents in the
    13
    packet?
    14
    MS. HARVEY: Yes, please.
    15
    HEARING OFFICER ANTONIOLLI: Okay.
    16
    What I have before me is a letter from IKO
    17
    Chicago to the -- no, from the Environmental
    18
    Protection Agency to IKO Chicago, dated May
    19
    20th, 1993.
    20
    Are there any objections to me
    21
    entering this into the record as Hearing
    22
    Exhibit 5? And seeing none, and I'll note as
    23
    Ms. Harvey's already noted, that it's
    24
    attached to the petitioner's original
    L.A. REPORTING (312) 419-9292

    58
    1
    petition, dated April 1st, 2004.
    2
    And I will enter that into the
    3
    record as Exhibit 5, if you give me a minute
    4
    so I can give this to the court reporter.
    5
    (Whereupon, Exhibit No. 5 was
    6
    received in evidence by the
    7
    Hearing Officer.)
    8
    MS. HARVEY: Thank you, Madam Hearing
    9
    Officer.
    10 BY MS. HARVEY:
    11
    Q. Ms. Powles, you have before you the
    12 May 1993 waste determination letter that we've
    13 marked as Exhibit 5. Is this the letter you talked
    14 about earlier that you relied upon?
    15
    A. Yes.
    16
    Q. This letter talks about -- please just
    17 read me the first sentence of the letter.
    18
    A. The Agency's?
    19
    Q. Yes.
    20
    A. "The Agency has evaluated your request
    21 for a solid waste determination for granulated
    22 bituminous shingle material(GBSM) generated by the
    23 Bedford Park facility and has determined that it is
    24 not a solid waste when utilized for the following
    L.A. REPORTING (312) 419-9292

    59
    1 applications."
    2
    Q. Thank you. Now, the rest of the
    3 letter talks about -- or the next two numbered
    4 paragraphs talk about these enumerated applications
    5 that are approved. Can you summarize for me the
    6 first one? What does that say? What is the
    7 approved application there?
    8
    A. Well, it's exactly what we're doing at
    9 Jo'Lyn Corporation, Eclipse Dust Control, which is,
    10 "GBSM Shingle Chips may be used to form a pavement
    11 surface for unpaved, muddy, soft or dusty roadways.
    12 The Shingle chips shall be applied at a sufficient
    13 thickness to ensure a cohesive, durable roadbed."
    14
    Q. Okay. Is that consistent with what
    15 Jo'Lyn and Falcon do with their Eclipse Dust
    16 Control?
    17
    A. Yes.
    18
    Q. The second numbered paragraph there,
    19 can you summarize for us what process that
    20 describes?
    21
    A. The second paragraph?
    22
    Q. Yeah, the numbered Paragraph 2.
    23
    A. Okay. "GBSM Ground Chips are divided
    24 into the following categories: Coarse ground chips
    L.A. REPORTING (312) 419-9292

    60
    1 may be used to form a pavement surface for unpaved
    2 roadways. Also, these chips may be used to form a
    3 pavement subbase material for road construction
    4 projects. Once again, the chips should be applied
    5 at a sufficient thickness to provide a stable base
    6 structure."
    7
    Q. Okay.
    8
    A. And they may be -- and fine ground
    9 chips (-1/2") may be added as an ingredient to hot
    10 mix asphalt paving components.
    11
    Q. Okay. And you testified earlier that
    12 Jo'Lyn does not -- Jo'Lyn and Falcon do not use the
    13 GBSM in the hot mix asphalt, correct?
    14
    A. Correct.
    15
    Q. But that is an approved use of GBSM
    16 under this letter?
    17
    A. Yes, it is.
    18
    Q. Okay. So is it your position that
    19 GBSM -- that Jo'Lyn's and Falcon's use of GBSM in
    20 paving products is consistent with the approval
    21 obtained from the Agency in 1993?
    22
    A. Yes.
    23
    Q. Thank you.
    24
    MS. HARVEY: Madam Hearing Officer, if
    L.A. REPORTING (312) 419-9292

    61
    1
    I can have just a couple minutes, I think I
    2
    may be done with my direct examination.
    3
    HEARING OFFICER ANTONIOLLI: Sure.
    4
    MS. HARVEY: I don't know if you want
    5
    to take five minutes now?
    6
    HEARING OFFICER ANTONIOLLI: Yes.
    7
    We'll take a break now then before we
    8
    continue on to cross-questioning by Mr. Kim,
    9
    if he chooses to do so. So we'll go off the
    10
    record now.
    11
    (Whereupon, after a short
    12
    break was had, the following
    13
    proceedings were held
    14
    accordingly.)
    15
    HEARING OFFICER ANTONIOLLI: We're
    16
    back on the record. It's about 10:15 and we
    17
    just took a short break. At this point, Ms.
    18
    Harvey, do you have any further questions for
    19
    your witness?
    20
    MS. HARVEY: I do not.
    21
    HEARING OFFICER ANTONIOLLI: Okay.
    22
    Let me explain a little bit how we'll proceed
    23
    then from this point forward. Of course, as
    24
    I mentioned before, anyone here has the
    L.A. REPORTING (312) 419-9292

    62
    1
    opportunity to testify. And, again, if you
    2
    choose to testify, you will subject -- you'll
    3
    be sworn in and subject to cross-questioning.
    4
    We'll hold people who wish to testify until
    5
    after the petitioner's witnesses have
    6
    finished and we've asked questions of the
    7
    witnesses.
    8
    But at this point, I'd like to
    9
    open the floor to public comments. So anyone
    10
    here who wishes to make a statement on the
    11
    record can do so. Please just raise your
    12
    hand, I'll recognize you and then I'll ask
    13
    you to state your name and who you represent
    14
    for the record.
    15
    And is there anyone here that
    16
    would like to do that now? Yes, can you
    17
    introduce yourself and tell us who you
    18
    represent?
    19
    MS. MEUCH I'm Beverly Meuch and I'm
    20
    representing the Lou Marchi Total Recycling
    21
    Institute, and I am going to read a statement
    22
    from the waste reduction assistant of that
    23
    institute.
    24
    It says to the Illinois Pollution
    L.A. REPORTING (312) 419-9292

    63
    1
    Control Board, in the past, the Lou Marchi
    2
    Total Recycling Institute at McHenry County
    3
    College has supported the production and
    4
    application of Jo'Lyn Corporation's Eclipse
    5
    Dust Control to save natural resources and to
    6
    save our limited landfill space.
    7
    Recently, I flew to their
    8
    operations and observed driveways which had
    9
    been applied with recycled roofing shingles
    10
    that are from the manufacturer. The
    11
    driveways had been applied two to four years
    12
    ago and still had a good surface for vehicles
    13
    to use.
    14
    These materials definitely need to
    15
    be classified as a recycled commodity and not
    16
    a waste material, Pat Dieckhoff.
    17
    And I would like to present this
    18
    letter for -- in a hard-copy form, to whom, I
    19
    don't know.
    20
    MS. HARVEY: The Hearing Officer.
    21
    MS. MEUCH: Okay.
    22
    HEARING OFFICER ANTONIOLLI: Thank
    23
    you.
    24
    MS. MEUCH: You're welcome.
    L.A. REPORTING (312) 419-9292

    64
    1
    HEARING OFFICER ANTONIOLLI: Now, I
    2
    don't have a list of the public comments
    3
    here, and what we need to do is -- I may have
    4
    to ask you to file this with the Clerk of the
    5
    Board as a public comment.
    6
    MS. MEUCH: That's fine.
    7
    HEARING OFFICER ANTONIOLLI: So I can
    8
    talk to you on our next break about that.
    9
    Okay. Is there anyone else here
    10
    who would like to make a public comment?
    11
    Please remember that this isn't the only
    12
    opportunity you'll have, you can also do so
    13
    after the witnesses have finished testifying
    14
    and we've also completed questions. So if I
    15
    see no further public requests for public
    16
    comment --
    17
    MR. LOWE: I'd like to make a comment.
    18
    HEARING OFFICER ANTONIOLLI: Go ahead
    19
    and introduce yourself and can you spell your
    20
    name for the court reporter?
    21
    MR. LOWE: L-O-W-E.
    22
    HEARING OFFICER ANTONIOLLI: Okay.
    23
    And state who you represent.
    24
    MR. LOWE: Myself.
    L.A. REPORTING (312) 419-9292

    65
    1
    HEARING OFFICER ANTONIOLLI: Would you
    2
    like to make a statement?
    3
    MR. LOWE: Yes, I would now.
    4
    HEARING OFFICER ANTONIOLLI: Please do
    5
    so, yes.
    6
    MR. LOWE: I think what they're doing
    7
    is admirable. I think it doesn't affect the
    8
    environmental situation of this world at all.
    9
    There are a lot of shingles that are going to
    10
    landfills that I think they ought to take out
    11
    of the other construction and demolition
    12
    debris. They're taking a pure shingle from a
    13
    manufacturer with absolutely no contaminants
    14
    in it whosoever and trying to turn it into a
    15
    useful product.
    16
    They -- I think I'm missing the
    17
    boat. You have to get the Illinois
    18
    Department of Transportation to agree to
    19
    this, but I think those shingles should be
    20
    used in asphalt, not surface, but binders and
    21
    lower levels of asphalt. The reason being is
    22
    that recycled -- I recycle asphalt and
    23
    concrete. The recycled asphalt that we put
    24
    back into a product that is used on the state
    L.A. REPORTING (312) 419-9292

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    1
    highways contains very little amount of
    2
    asphalt material. Probably about -- I don't
    3
    know -- 3 to 5 percent, 6 percent.
    4
    On the other hand, shingles, have
    5
    almost a 35 percent less asphalt content.
    6
    So, therefore, when they -- you know, they're
    7
    talking about not putting it into the
    8
    asphalt, I think they should put it in the
    9
    asphalt, but I don't know if IDOT would agree
    10
    with that. But it's a very useful product.
    11
    I think the benefit of that is, you know,
    12
    you're using less asphalt material in making
    13
    the recycled asphalt because of the content
    14
    of the asphalt in the shingles. So it's --
    15
    to me, it's a very economical thing and end
    16
    of my theory.
    17
    HEARING OFFICER ANTONIOLLI: Thank
    18
    you. And anyone else? The gentleman in the
    19
    second row.
    20
    MR. MURRAY: My name is Michael
    21
    Murray, I'm a commissioner at the Heartland
    22
    Township, and I've known Don and Kathy for
    23
    the last -- quite a few years, since they
    24
    moved into our area. I think the product
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    1
    that they are proposing looks good and that,
    2
    like, in our township, we still have quite a
    3
    few miles of gravel road and that it could be
    4
    incorporated and to keep the dust down. And
    5
    I've seen the applications that they have
    6
    done in their driveways and what have you,
    7
    and it looks like it has held up real well.
    8
    And I have not seen where I think that it
    9
    would be any endangerment to the environment.
    10
    Thank you.
    11
    HEARING OFFICER ANTONIOLLI: Thanks,
    12
    Mr. Murray. And is there anyone else? Okay.
    13
    Please go ahead.
    14
    MS. NEIMANN: Yes, I'm Jean Niemann,
    15
    that's N-I-E-M-A-N-N, and I'd like to give a
    16
    comment as a citizen of McHenry County, as
    17
    well as the planner -- the solid waste
    18
    coordinator for McHenry County.
    19
    And McHenry County currently has a
    20
    solid waste management plan and the plan
    21
    supports recycling. And the reason that it
    22
    supports recycling largely is because they
    23
    want to keep as much waste
    24
    products/commodities out of the landfill as
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    68
    1
    possible, so they support recycling.
    2
    And I guess I have a question for
    3
    Mr. Kim, which would be what could the EPA do
    4
    to facilitate all aspects of recycling in
    5
    Illinois?
    6
    HEARING OFFICER ANTONIOLLI: That's a
    7
    question that we may choose to ask Mr. Kim.
    8
    He can answer it now if he feels like it or
    9
    later when we will take questions. Would you
    10
    like to respond to her right now?
    11
    MR. KIM: Well, it's a good question
    12
    and I guess the best answer I can give you --
    13
    it's also a broad question. And the best
    14
    answer I can give you is that I know that our
    15
    Agency has a policy and the State has a
    16
    policy and you're a solid waste planner and
    17
    coordinator, so you know this, there's a
    18
    hierarchy of the solid waste management of
    19
    the state, and recycling is certainly at or
    20
    near the top of that hierarchy. And so our
    21
    Agency and the State does everything it can
    22
    to promote and to encourage recycling. At
    23
    the same time, we have to be mindful of
    24
    regulations and statutes that are still going
    L.A. REPORTING (312) 419-9292

    69
    1
    to be there and still need to be addressed.
    2
    So we can't completely turn a
    3
    blind eye to one aspect of the law while
    4
    trying to promote another. We have to try
    5
    and keep things in balance and that's what
    6
    we're trying to do here. But to say -- I
    7
    wish I could be more specific to answer that,
    8
    but it's a good question, that's just the
    9
    best answer I can give you.
    10
    HEARING OFFICER ANTONIOLLI: Okay.
    11
    Thanks for your comment. And Ms. Niemann,
    12
    thank you for your statement.
    13
    Yes, in the back?
    14
    MS. STEVENS: Laura Stevens, and I'm
    15
    just a citizen. I've known Cathy and Donny
    16
    for over 25 years and I see this as a win-win
    17
    situation. You're taking a material that
    18
    otherwise I see is being landfilled and
    19
    turning it into a useful product. I have
    20
    also seen the application itself and it has
    21
    held up as they say.
    22
    HEARING OFFICER ANTONIOLLI: Thank
    23
    you. Is there anyone else now? Okay. I see
    24
    a hand over here.
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    1
    MS. MARSH: Pamela Marsh, M-A-R-S-H,
    2
    and I too am a citizen and I would like to
    3
    support them. As a healthcare professional
    4
    as well, I see that there are uses for this
    5
    that -- to keep out of the landfills to keep
    6
    our environment healthier. And I have seen
    7
    it applied, I like it too. It's not
    8
    offensive, the odor is not offensive and, to
    9
    me, I think that's important. I just support
    10
    the whole thing.
    11
    HEARING OFFICER ANTONIOLLI: Okay.
    12
    Thanks for your comment, Ms. Marsh.
    13
    MR. LOWE: Yes, I'd like to make
    14
    another statement saying that, you know, I
    15
    have no idea who these people are, I just
    16
    think that their idea is a great idea.
    17
    HEARING OFFICER ANTONIOLLI: Okay.
    18
    We're happy you can be here to make your
    19
    comment.
    20
    Is there anyone else now? Okay.
    21
    Seeing no hands, at this point I will turn it
    22
    over to Mr. Kim and he can begin his
    23
    questioning of Ms. Powles.
    24
    MR. KIM: Thank you.
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    1
    CROSS EXAMINATION
    2 BY MR. KIM:
    3
    Q. And Ms. Powles, I'll -- I'm going to
    4 ask questions sort of in the order that you
    5 presented your testimony. So if I ask a question
    6 and you don't understand it, or you need a little
    7 context or what have you, just let me know.
    8
    A. Okay.
    9
    Q. When you were speaking about the
    10 Eclipse Dust Control, or EDC, you said that can be
    11 used in addition to asphalt or pavement or in
    12 substitution of asphalt and pavement; is that right?
    13 You said the EDC could be applied to driveways,
    14 parking lots and pathways?
    15
    A. Correct.
    16
    Q. And would that be -- and I think you
    17 kind of touched on this in some other answers, but
    18 if you could just sort of clarify, that would be
    19 used either in conjunction with traditional pavement
    20 materials or would that be used in substitution of
    21 that or either one?
    22
    A. In substitution currently. It's just
    23 in substitution.
    24
    Q. Okay. And when I said driveways,
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    1 parking lots and pathways, would that also include
    2 roadways?
    3
    A. Yes.
    4
    Q. Okay. As far as you know, or in your
    5 marketing to potential customers, do you have any
    6 limits as to what types of roadways EDC could be
    7 used upon?
    8
    In other words, have there been
    9 any types of roads where you said, we don't think
    10 this would be a good application, for whatever
    11 reason, or you don't see any limits at this point in
    12 time?
    13
    A. We have not.
    14
    Q. You have not?
    15
    A. Denied anybody.
    16
    Q. Okay.
    17
    A. However, we are not going to sell a
    18 product that isn't going to fit their application.
    19 I don't see where it wouldn't fit, but if there is a
    20 possibility -- but, you know, we would just use our
    21 judgment.
    22
    Q. Can you think of any example where it
    23 might not be appropriate?
    24
    A. Well, on top of 90, you know,
    L.A. REPORTING (312) 419-9292

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    1 something like that, I know that's a little extreme.
    2 But something like that, no.
    3
    Q. So that would be, for example, you
    4 know, a high volume roadway? Is that the kind of
    5 thing you're saying maybe would not be appropriate?
    6
    A. At this time, that is correct.
    7
    Q. Okay.
    8
    MR. RAO: May I ask a follow-up to
    9
    your question?
    10
    MR. KIM: Sure.
    11
    MR. RAO: Are there any regulatory
    12
    restrictions in terms of using EDC on
    13
    roadways, like, you know, some department of
    14
    transportation limitation or such?
    15
    THE WITNESS: No.
    16 BY MR. KIM:
    17
    Q. You said that the -- and correct me if
    18 I'm wrong when I go through the process -- you said
    19 the GBSM is basically ground up and then after it's
    20 ground up, I guess then it becomes EDC; is that
    21 right?
    22
    A. GBSM becomes EDC, correct.
    23
    Q. After the grinding process?
    24
    A. Correct.
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    1
    Q. Okay. And then you said it's spread
    2 in two different fashions and then it's rolled, and
    3 I think later on you -- were there two different
    4 fashions? Either -- well, what are the two
    5 different fashions?
    6
    A. That it's applied -- it's either
    7 applied through an asphalt spreader.
    8
    Q. Okay.
    9
    A. Or it is spread out through the back
    10 of the truck and then leveled with a bobcat blade,
    11 and then they both are compacted.
    12
    Q. Okay. When would you use one, you
    13 know, means as opposed to the other, or does it
    14 matter?
    15
    A. I don't think it really matters. It
    16 depends on the equipment that is available. We
    17 would like to use the asphalt spreader, however, we
    18 have to rent that equipment or subcontract. So it
    19 would just --
    20
    Q. Would using an asphalt spreader allow
    21 for a more uniformed distribution as opposed to, you
    22 know, prior to rolling?
    23
    A. Not necessarily.
    24
    Q. Okay. I don't even know, so I'm just
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    1 asking.
    2
    A. Okay.
    3
    Q. You were making reference to the
    4 piles, and why don't you -- if you've got Exhibit
    5 Number 2, figure one, your site map.
    6
    A. Uh-huh.
    7
    Q. In this map I see two dark piles that
    8 are identified GBSM?
    9
    A. Correct.
    10
    Q. Was one of these piles what you said
    11 was sort of the interim pile that's then moved to
    12 the more --
    13
    A. No.
    14
    Q. Okay. Could you explain what the two
    15 different piles are?
    16
    A. Well, we started on the back as the
    17 original stockpile of material and then we moved to
    18 the front here.
    19
    Q. So when you say the back, is that the
    20 larger pile?
    21
    A. Correct.
    22
    Q. And then the smaller pile?
    23
    A. Correct.
    24
    Q. So is this reflective of what you
    L.A. REPORTING (312) 419-9292

    76
    1 actually have on-site right now?
    2
    A. Yes, it is.
    3
    Q. Do you know roughly what volume or how
    4 much GBSM you have on-site right now?
    5
    A. I believe its 5000 tons. I haven't
    6 really looked at that number, so I really have to
    7 confirm that. We can put that in the
    8 after-paperwork.
    9
    Q. Okay. And these piles are separated
    10 -- well, let me clarify that -- or let me rephrase
    11 that.
    12
    You said that you would try and
    13 keep the tabs and the shingles or the sheets from
    14 being commingled?
    15
    A. No. I said that they have been, not
    16 that we've done that purposely. They can be
    17 mingled.
    18
    Q. Okay.
    19
    A. But no, they are not purposely
    20 separated.
    21
    Q. Okay. So when your trucks go to IKO,
    22 there's -- you said there was a separate box for
    23 tabs and a separate box for -- is it --
    24
    A. Sheet material.
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    1
    Q. Sheets. Okay. So then you would --
    2 so at IKO those two different sizes are segregated,
    3 correct?
    4
    A. Uh-huh.
    5
    Q. When you bring them to your facility,
    6 do you maintain that segregation or do you put them
    7 in one pile?
    8
    A. We don't purposely maintain it.
    9
    Q. Okay.
    10
    A. But it has been done that way.
    11
    Q. Okay.
    12
    A. You know, there is some consistency
    13 with that.
    14
    Q. Okay. So -- okay. The piles that you
    15 have on your site right now, do you have any tarps
    16 or any covers over those piles?
    17
    A. No, we do not.
    18
    Q. Okay. And you said you only will
    19 grind on an as-needed basis; is that right?
    20
    A. Yes.
    21
    Q. Roughly, how much GBSM basically does
    22 it take to grind down to make, you know -- I guess
    23 what I'm thinking of is if I've got a driveway
    24 that's, say, 15 feet by 30 feet, do you have some
    L.A. REPORTING (312) 419-9292

    78
    1 idea of how much GBSM you need to grind so that you
    2 can get enough EDC? So in other words, does one
    3 cubic foot come down to, you know, half a cubic foot
    4 of EDC, that kind of thing?
    5
    A. We actually have a -- we made a
    6 program for it.
    7
    Q. Okay.
    8
    A. I'd have to refer to that program.
    9
    Q. Okay. But there is -- and I guess I
    10 think the --
    11
    A. There is an equation, yes.
    12
    Q. Yes. Some kind of conversion factor?
    13
    A. Yes.
    14
    Q. Okay. If it's possible, do you think
    15 you could provide that in your post-hearing
    16 information?
    17
    A. Yes.
    18
    Q. Okay. And the material that you've
    19 got on your site, is it sitting on any kind of
    20 concrete pad or is it just sitting on dirt or
    21 asphalt?
    22
    A. We formed a gravel base, so it's
    23 sitting on a gravel base.
    24
    Q. Okay. It would have been great if you
    L.A. REPORTING (312) 419-9292

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    1 said you put it on top of the EDC.
    2
    A. Right. Well, we're hoping.
    3
    Q. You said that you've got a camera --
    4 and this is also in your operating manual on Page 4.
    5 You've got a live camera feed from IKO that you can
    6 maintain over the internet so that you can see when
    7 the boxes are full?
    8
    A. Uh-huh.
    9
    Q. And that's pretty much when you go out
    10 to retrieve the boxes?
    11
    A. Correct.
    12
    Q. Is it a -- do those boxes fill on a
    13 regular basis or is it sort of uneven? Does it
    14 depend upon -- and some of these questions may be
    15 better for IKO's witness, but...
    16
    A. They'd probably be better from Dave,
    17 but, yes, from our stand, you know, if something
    18 happens on the line and they have to take a pause,
    19 so they do vary.
    20
    Q. Okay. Do you know, roughly speaking,
    21 what your intervals have been as far as sending your
    22 trucks out to go bring the boxes back? Are we
    23 talking weekly or monthly?
    24
    A. They go daily.
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    1
    Q. Daily? Okay.
    2
    A. Yes.
    3
    Q. How big are the boxes that we're
    4 talking about?
    5
    A. Eight-foot across, 18 feet long and
    6 about six-foot tall.
    7
    Q. So 8-by-18-by-6?
    8
    A. Uh-huh.
    9
    Q. And you may not know this and I can
    10 ask the other witness, but if for some reason you
    11 notice that the box is full but you -- for
    12 mechanical problems or weather problems, what have
    13 you, if you can't go out and retrieve the box, do
    14 you know what they do with the material that won't
    15 go in the box?
    16
    A. We'll make sure we get it.
    17
    Q. Okay.
    18
    A. You know, we're a service company and
    19 we will service them.
    20
    Q. Okay.
    21
    A. I can't imagine -- you know, if
    22 there's a tornado, I'm not sure. That's a question
    23 for David too, but we will service them.
    24
    Q. Okay. But in terms of what they would
    L.A. REPORTING (312) 419-9292

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    1 do if for some reason you can't -- and I understand
    2 what you're saying -- but if for some reason you
    3 couldn't make it out there, do you know what they
    4 would do with the material?
    5
    A. No, I don't. I do not.
    6
    Q. Okay.
    7
    MR. RAO: May I ask a follow-up?
    8
    MR. KIM: Sure.
    9
    MR. RAO: Are you hauling GBSM
    10
    material from IKO right now --
    11
    THE WITNESS: No.
    12
    MR. RAO: -- on an ongoing basis?
    13
    THE WITNESS: No.
    14
    MR. RAO: So your responses to
    15
    Mr. Kim's questions were what? If you go
    16
    into your full-time operations, that's when
    17
    you do this on a daily basis?
    18
    THE WITNESS: Correct.
    19
    MR. RAO: Thanks.
    20 BY MR. KIM:
    21
    Q. I was mistaken. I thought you were
    22 doing that on a daily basis right now. You don't
    23 actively do that right now?
    24
    A. No, we've actually been told to halt
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    1 by the IEPA.
    2
    Q. Okay. So how did you get the -- where
    3 did the GBSM on your site right now come from?
    4
    A. When we started the research and
    5 development, we had formed a contract with them. We
    6 didn't go for the air permit immediately -- well, we
    7 went for it twice. You know, it's best that -- I'm
    8 not really sure on this and I'd really like to be
    9 sure.
    10
    Q. Sure.
    11
    A. And I do have it documented at the
    12 office, so I'd like to follow-up with this in the --
    13
    Q. Okay. Well, would it be safe to say
    14 that this material was received from IKO before you
    15 ran into what, you know, any kind of problems with
    16 the EPA?
    17
    A. Correct.
    18
    Q. Okay.
    19
    A. That's right.
    20
    Q. But there are these actual boxes that
    21 are in place right now at IKO that you can see on
    22 camera?
    23
    A. Well, I'm sure there are, however, we
    24 have not been looking because we are not hauling.
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    1
    Q. So do you actually have this internet
    2 camera feed right now?
    3
    A. No.
    4
    Q. Okay. So right now you don't know
    5 what IKO does with these tabs and the sheets right
    6 now?
    7
    A. I'm not getting them.
    8
    Q. Okay.
    9
    A. That's all I know.
    10
    Q. That's fine. And, again, looking at
    11 your operating manual, the operating procedures, it
    12 seems to be clear, for example, in item number one,
    13 this live camera feed, and number two, arriving at
    14 IKO, this is intended to address specifically the
    15 receipt of material from IKO Chicago; is that right?
    16
    A. Correct.
    17
    Q. And this would need to be revised if
    18 you received GBSM from other suppliers; is that
    19 right?
    20
    A. This wouldn't -- what do you mean this
    21 would need to be revised?
    22
    Q. Well, do you anticipate having a
    23 camera feed at every supplier, the same as you would
    24 have at IKO?
    L.A. REPORTING (312) 419-9292

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    1
    A. You know, we'd have to look at the
    2 facility.
    3
    Q. Okay.
    4
    A. That's not anything I could determine
    5 right now.
    6
    Q. Okay. But you did say that you would
    7 anticipate IKO not being your sole provider of
    8 material because of your expected demand; is that
    9 right?
    10
    A. That is correct.
    11
    Q. Okay. You said that it's in your
    12 contractor agreement with IKO that you could, based
    13 on your visual inspection -- and I guess this
    14 would -- well, let me ask a different question.
    15
    Is it right that there are two
    16 chances for you to do a visual inspection? Once,
    17 when you actually go to IKO to look at the boxes
    18 before you basically put them on your truck, and
    19 then the second time, at your site when you're
    20 actually -- before you put them into the grinder; is
    21 that a fair statement? And if not, explain what
    22 that is?
    23
    A. Well, we look at it at the facility
    24 and then when we unload it. However, like I said,
    L.A. REPORTING (312) 419-9292

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    1 we have never had anything besides the material in
    2 the load. It is a material we are purchasing. We
    3 do inspect it and it's a very easy visual
    4 inspection, you can just see.
    5
    Q. Okay. So there are at least then two
    6 opportunities, once at IKO's facility and then once
    7 at your facility before you actually put it into
    8 your grinder; is that right? At least those two
    9 chances?
    10
    A. When we stockpile would be the second
    11 time.
    12
    Q. I'm sorry. When you stockpile it.
    13 I'm sorry. Okay. And you said that your contract
    14 does allow you to reject a load or a box that you
    15 don't find to be meeting your criteria; is that
    16 right?
    17
    A. Correct.
    18
    Q. If that happens at your site, let's
    19 say the visual inspection at IKO doesn't prove to be
    20 a problem, but you do have a problem when you do the
    21 visual inspection at your site before you stockpile
    22 it?
    23
    A. Uh-huh.
    24
    Q. What would you do with the material
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    1 then?
    2
    A. I would actually have to speak with
    3 the head man who oversees that --
    4
    Q. Okay.
    5
    A. -- operation. I'd have to answer that
    6 in rebuttal. We've never had that problem. I do
    7 not anticipate ever having that problem. We would
    8 handle it, you know, depending on what it was or --
    9 it's just --
    10
    Q. Okay. When you said the head man, you
    11 mean?
    12
    A. The head man, I didn't know what else
    13 to say.
    14
    Q. No, I understand. Do you mean the
    15 head man at Falcon/Jo'Lyn or the head man at IKO
    16 Chicago?
    17
    A. The supervisor -- I would say both,
    18 but I was speaking of Don.
    19
    Q. Okay. Do you know if the contract --
    20 the agreement that you have with IKO, does that lay
    21 out what contingent would be if the visual
    22 inspection fails?
    23
    A. Yes, it does.
    24
    Q. Okay. And I'm assuming Ms. Harvey
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    1 might have a copy of that contract.
    2
    MS. HARVEY: I can either show it to
    3
    her now or I can ask her on redirect.
    4
    MR. KIM: You can show it to her now.
    5
    Can you tell me where you're looking?
    6
    MS. HARVEY: Yes. I'm sorry. This is
    7
    actually Exhibit A to the initial petition
    8
    dated April 21st, it's the very first exhibit
    9
    and, Kathy, you will see here it talks about
    10
    what happens if it's rejected.
    11
    THE WITNESS: "In the event that any
    12
    BSM furnished to Jo'Lyn by IKO as BSM is
    13
    hereafter, due to the presence of
    14
    contaminants therein, rejected by potential
    15
    purchaser or otherwise determined by Jo'Lyn
    16
    not to be resaleable, IKO shall pay Jo'Lyn
    17
    the charges incurred by Jo'Lyn for hauling
    18
    and disposal of such material."
    19 BY MR. KIM:
    20
    Q. Okay. So by your contract, if your
    21 visual inspection turns up some abnormalities or
    22 some material that you couldn't use for your
    23 operation, IKO would pay you the costs for your
    24 taking that and having it disposed of; is that
    L.A. REPORTING (312) 419-9292

    88
    1 right?
    2
    A. Correct. That's what that reads.
    3
    Q. Okay. And that contract is the one
    4 that's still -- that's the most recent and that's
    5 the most up-to-date contract that you have between
    6 your companies and IKO; is that correct?
    7
    A. That is the most recent.
    8
    Q. Okay. You said as far as the
    9 stockpiles at your facility, you maintain no more
    10 than 25 feet in height?
    11
    A. Uh-huh.
    12
    Q. And if it gets higher than that, you
    13 would just basically spread it out a little more; is
    14 that right?
    15
    A. Uh-huh.
    16
    Q. How did you happen to arrive at the
    17 25 feet?
    18
    A. That's about where it's at. And I'd
    19 have to answer that in the post-hearing. You know,
    20 I don't want to answer it incorrectly.
    21
    Q. Okay. But it's not pursuant to some
    22 specific zoning requirement or anything like that,
    23 it's just more of a site-specific type thing you
    24 guys have come up with on your own?
    L.A. REPORTING (312) 419-9292

    89
    1
    A. Pretty much, but I believe I'd have to
    2 get back on that.
    3
    Q. Sure.
    4
    A. Because I'd like to follow-up on that
    5 properly.
    6
    Q. That's fine. As far as the
    7 application of the EDC is concerned, who actually
    8 does the application? Would it be your company or
    9 would it be the buyer of the product? For example,
    10 if I'm a township and I see I've got a section of
    11 road that I'd like to have EDC applied on and I make
    12 an agreement with you, I sign a contract, would your
    13 people come out and spread the EDC and roll it and
    14 compact it or would my people do that or how would
    15 that work?
    16
    A. It just depends on their -- what they
    17 desire. Typically, we always do the installation
    18 for driveways, and roadways for the townships, I did
    19 not negotiate those contracts, so I truly cannot
    20 answer the question.
    21
    Q. Okay. Are there contracts right now
    22 with some townships?
    23
    A. Yes.
    24
    Q. Do you know -- well, to the best of
    L.A. REPORTING (312) 419-9292

    90
    1 your recollection, do you think those contracts
    2 might specify who does the application?
    3
    A. I'm not clear. It's been quite a
    4 while since I have seen those.
    5
    Q. That's fine. Do you know -- and Ms.
    6 Harvey may know this -- but are any of those
    7 contracts included as exhibits? I think that's what
    8 she's checking.
    9
    MS. HARVEY: There are some contracts
    10
    that are included as exhibits if you --
    11
    MR. KIM: Okay.
    12
    MS. HARVEY: In the original petition,
    13
    I believe the contracts for purchase begin --
    14
    it's Group Exhibit E.
    15
    MR. KIM: Okay. We'll just take a
    16
    look at that then.
    17 BY MR. KIM:
    18
    Q. And you said that the sun plays an
    19 active role in the sealing process of the EDC; is
    20 that correct?
    21
    A. Yes.
    22
    Q. Does it depend on -- so aside from you
    23 needing full sun, do you need -- are there any
    24 ranges as far as temperature that come into play?
    L.A. REPORTING (312) 419-9292

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    1
    A. At this time, I really can't answer
    2 that. I would have to say yes. However, on the
    3 other hand, I would tend to say yes to the other.
    4 We would not install it in cold weather, however, I
    5 can testing that theory, but I believe that it would
    6 work in cold weather.
    7
    Q. Okay. Does your
    8 operating --
    9
    MR. POWLES: Excuse me, Madam Hearing
    10
    Officer?
    11
    HEARING OFFICER ANTONIOLLI: Yes?
    12
    MR. POWLES: May I speak, please?
    13
    HEARING OFFICER ANTONIOLLI: Yes.
    14
    Ms. Powles, your husband may have an answer
    15
    to John's question, if no one objects, we
    16
    could have him sworn in and he can answer
    17
    that question.
    18
    MR. KIM: That's fine.
    19
    MR. POWLES: Before I swear in and
    20
    everything, I just want to say the reason
    21
    they don't have me up there is because I'm
    22
    really frustrated with this whole thing, but
    23
    I'd like to -- because some of the
    24
    frustration in the length of what's happening
    L.A. REPORTING (312) 419-9292

    92
    1
    is because --
    2
    MR. KIM: Well, before --
    3
    MR. POWLES: -- the questions asked
    4
    and there's no answers, by golly, if I'm
    5
    sitting here, I'd like to give an answer. I
    6
    don't want to give testimony, but I'd like to
    7
    give an answer.
    8
    HEARING OFFICER ANTONIOLLI: Sir, why
    9
    don't we have you sworn in. If you do have a
    10
    specific answer to Mr. Kim's question, you
    11
    can go ahead and provide that now and then
    12
    you can follow-up with comments or testimony
    13
    at a later time.
    14
    MS. HARVEY: Don, can you specifically
    15
    answer John's question.
    16
    MR. POWLES: Well, about five or six
    17
    of them.
    18
    THE WITNESS: Well, we can answer it
    19
    in the post-brief thing.
    20
    MR. POWLES: I was just wondering -- I
    21
    didn't want to be sworn in, but I was
    22
    wondering if it would be possible for me to
    23
    sit next to my wife and give her a technical
    24
    answer that he asks of her.
    L.A. REPORTING (312) 419-9292

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    1
    HEARING OFFICER ANTONIOLLI: Well,
    2
    since you would be the one providing the
    3
    information, we would like to have you sworn
    4
    in. And you can do that if you can answer
    5
    those questions.
    6
    MS. HARVEY: Can I make a suggestion?
    7
    After Mr. Kim --
    8
    THE WITNESS: I better not.
    9
    MS. HARVEY: -- has finished his
    10
    questions, maybe you would give us an
    11
    opportunity to consult with Mr. Powles and
    12
    see if there are questions that he can answer
    13
    at that time. That way, we'll know all of it
    14
    at once that --
    15
    HEARING OFFICER ANTONIOLLI: Sure. In
    16
    fact, we'll probably take a break in another
    17
    15, 20 minutes.
    18
    MR. POWLES: Sorry to interrupt.
    19
    HEARING OFFICER ANTONIOLLI: That's
    20
    okay.
    21 BY MR. KIM:
    22
    Q. Well, I was looking at the operating
    23 manual and it does say on the last page, on Page 7,
    24 that it sort of says -- there's a sentence on Page 7
    L.A. REPORTING (312) 419-9292

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    1 -- this is again in Exhibit 2 in the last paragraph,
    2 "During the working season (approximately April
    3 through September, depending upon the weather),
    4 storage times will be quite short. During the "off
    5 season," storage time could be as long as
    6 eight months, if the GBSM is received late in the
    7 working season and the beginning of the next season
    8 is delayed due to weather."
    9
    So -- and if you don't want to
    10 answer this, if you'd rather wait, that's fine --
    11 but is it safe to say that you generally anticipate
    12 only doing application during the working season,
    13 which would be from April to September?
    14
    A. Yes. Relatively the same working
    15 season as the hot mix plants.
    16
    Q. Okay. That's fine.
    17
    A. It's pretty identical.
    18
    Q. Okay. And you were talking about two
    19 test sections that have been applied of EDC. One
    20 installed in 2000, and one installed roughly in
    21 2002. I know you said the first installation was on
    22 a driveway. Do you know what was the second
    23 installation? Was it another driveway?
    24
    A. It was a driveway.
    L.A. REPORTING (312) 419-9292

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    1
    Q. Driveway, okay. And you said that --
    2 you testified that it held up very good in the sunny
    3 areas and not so good in the shaded areas.
    4
    What was the condition of the EDC
    5 in the shaded areas?
    6
    A. It slightly broke up. The bond wasn't
    7 there 100 percent, so there was wear.
    8
    Q. Okay.
    9
    MR. RAO: May I ask a follow-up
    10
    regarding the test section?
    11
    MR. KIM: Sure.
    12
    MR. RAO: Ms. Powles, what was the
    13
    length of these driveways that you used for
    14
    the test section?
    15
    THE WITNESS: The one was roughly --
    16
    I'm going to say between 50 -- I'd say 50 to
    17
    100 feet. I'm trying to think of a football
    18
    field.
    19
    MR. RAO: Approximately. Just give us
    20
    an idea.
    21
    THE WITNESS: Yeah. And about
    22
    ten feet from side to side. And then the
    23
    other driveway was eight feet from side to
    24
    side and I'd say about 200 feet.
    L.A. REPORTING (312) 419-9292

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    1
    MR. RAO: And what type of vehicle
    2
    traffic are these sections subjected to?
    3
    THE WITNESS: The first one, it's
    4
    fairly heavy traffic. It's in a parking lot.
    5
    It used to be our old facility. We have
    6
    several of our trucks go in and out of there,
    7
    it's a storage facility for small storage.
    8
    So there's cars going in and out on a daily
    9
    basis, both heavy and light. And then the
    10
    other one is a basic driveway for our home.
    11
    MR. RAO: Thank you.
    12 BY MR. KIM:
    13
    Q. And when you said the other one, the
    14 driveway for the home, was that the more recent
    15 application or was that the older application?
    16
    A. It was the more recent.
    17
    Q. Okay. And if EDC is applied to
    18 roadways, do you have any information as to what the
    19 impact application of road salt might have to the
    20 material?
    21
    A. No.
    22
    Q. Okay. Do you know --
    23
    A. I might be able to follow-up on that
    24 for you though.
    L.A. REPORTING (312) 419-9292

    97
    1
    Q. Okay. Do you know -- I ask this
    2 because my father has an asphalt driveway and he
    3 does not put salt down, he says it makes a stain and
    4 makes a mess and I don't know -- do you know if the
    5 people that have the test sections, do they apply
    6 any kind of salt to those surfaces to the best of
    7 your knowledge?
    8
    A. Yeah. To the best of my knowledge, I
    9 don't know, but I can follow-up on that also.
    10
    Q. Okay. You were talking about in I
    11 think your written testimony, potential results of
    12 old EDC -- it's on -- this would be Exhibit 4 on the
    13 last page -- I thought you testified -- and correct
    14 me if I'm wrong -- I thought you testified that you
    15 had not incorporated old EDC into new EDC; is that
    16 right?
    17
    A. That's correct.
    18
    Q. Okay. Now, what did you -- when you
    19 say incorporate, do you mean you wouldn't put a new
    20 application of EDC over an existing application of
    21 EDC?
    22
    A. Mix it -- I would not mix it together.
    23 I would not mix the two materials together --
    24
    Q. Okay.
    L.A. REPORTING (312) 419-9292

    98
    1
    A. -- because we are selling, currently,
    2 EDC fresh and clean.
    3
    Q. Uh-huh.
    4
    A. At this point, I really don't have
    5 that much. I really don't have any used EDC to use
    6 at this time, but I would not sell it mixed.
    7
    Q. Okay.
    8
    MS. LIU: As a follow-up, could you
    9
    apply new EDC over an old application?
    10
    THE WITNESS: Yes.
    11
    MS. LIU: Would you need to do any
    12
    modification to create a subbase?
    13
    THE WITNESS: I guess I answer your
    14
    question a little bit unknowingly. However,
    15
    we have put EDC directly on top of blacktop
    16
    and it has gone on top of concrete a little
    17
    bit and it has formed against it. We have
    18
    not done any test sections to where we've put
    19
    EDC on top of EDC. However, I believe it
    20
    would bond.
    21
    MS. LIU: Okay. Thank you.
    22 BY MR. KIM:
    23
    Q. I think I just have two questions
    24 remaining for you. One is, when you were speaking
    L.A. REPORTING (312) 419-9292

    99
    1 about the visual inspections, regardless of where
    2 that takes place, what kind of thing would lead to
    3 your visual inspection being -- to something failing
    4 the visual inspection? In other words, what do you
    5 look for and what would you see that would say,
    6 well, we can't accept that?
    7
    A. On the load?
    8
    Q. Yes.
    9
    A. What would make us not accept it? You
    10 know, when a little piece of paper that flew in
    11 there, we would pick it out. If there were several
    12 things, that would be up to the supervisor and that
    13 would be determined right there.
    14
    Q. Okay.
    15
    A. There's definite rules and guidelines
    16 to that, but if we can handle the situation
    17 ourselves right there, we will. We don't want to
    18 waste time or money, so we try and we would take
    19 care of it the best way we can.
    20
    Q. When you say there are definite rules
    21 and guidelines, what are you referring to?
    22
    A. Well, what we would accept and what we
    23 wouldn't.
    24
    Q. Okay. Are those spelled out
    L.A. REPORTING (312) 419-9292

    100
    1 somewhere? Do you know?
    2
    A. Not on the rejected loads, we've never
    3 had any. We don't anticipate having any. If -- I
    4 would be more than willing to write it up for you if
    5 you'd like.
    6
    Q. Okay. So there is nothing right now
    7 that you have that sets out what you would -- would
    8 constitute a failed visual inspection; is that
    9 right? Like for example --
    10
    A. I'd have to go check. I have lots of
    11 documents to show. I cannot answer that.
    12
    Q. Okay.
    13
    MS. HARVEY: Can I just clarify?
    14
    MR. KIM: Sure.
    15
    MS. HARVEY: Are you asking if there's
    16
    anything in writing now that spells out when
    17
    a load is rejected; is that your question?
    18
    MR. KIM: Yes. I guess I'm wondering
    19
    either if there's something in writing unique
    20
    to Jo'Lyn and Falcon or you made reference to
    21
    some rules and guidelines that there's
    22
    something else that you're specifically
    23
    referring to, you know, is some independent
    24
    body that has a list of guidelines or
    L.A. REPORTING (312) 419-9292

    101
    1
    something like that.
    2
    THE WITNESS: I'd have to get back to
    3
    you on that.
    4
    MR. KIM: Okay. That's fine.
    5 BY MR. KIM:
    6
    Q. And then the last question I have is
    7 you made reference to Exhibit No. 5, which is the
    8 May 1993 letter that Illinois EPA sent to IKO
    9 Chicago?
    10
    A. Uh-huh.
    11
    Q. And in that letter, Paragraph 2 has
    12 two categories, A and B?
    13
    A. Correct.
    14
    Q. And you said that you're not going to
    15 be using -- you're not going to be getting into
    16 what's in category B, which is the hot mix asphalt;
    17 is that right?
    18
    A. That's correct.
    19
    Q. Okay. So you would be limiting your
    20 use of the GBSM so that it would be consistent with
    21 what is defined in Section 2A; is that right?
    22
    A. That's correct.
    23
    Q. Okay.
    24
    MR. KIM: That's all I have.
    L.A. REPORTING (312) 419-9292

    102
    1
    HEARING OFFICER ANTONIOLLI: Okay.
    2
    Thank you, Mr. Kim. We are going to break
    3
    now, it's 10:55. Let's take a ten-minute
    4
    break and come back at 11:05 and then we can
    5
    continue with questions at that point.
    6
    (Whereupon, after a short
    7
    break was had, the following
    8
    proceedings were held
    9
    accordingly.)
    10
    HEARING OFFICER ANTONIOLLI: Okay. We
    11
    are back on the record now. It is ten after
    12
    11:00 and I'd like to note just two things
    13
    before we get back to questions. First,
    14
    Senator Althoff was here with us for a short
    15
    while this morning and she just left.
    16
    And second of all, we also heard
    17
    after the first break this morning a public
    18
    comment from Beverly Meuch and at that point
    19
    she read into the record a letter from Pat
    20
    Dieckhoff and Lou Marchi of Total Recycling
    21
    Institute at McHenry County College, and at
    22
    this time, if there are no objections, I'm
    23
    going to enter that into the exhibits as
    24
    Hearing Officer Exhibit 1 because it's not
    L.A. REPORTING (312) 419-9292

    103
    1
    been presented by either of the parties.
    2
    I'll just go ahead and make that a part of
    3
    the record now.
    4
    (Document marked as Hearing
    5
    Officer Exhibit No. 1 for
    6
    identification, 12/22/04.)
    7
    HEARING OFFICER ANTONIOLLI: Thank
    8
    you. And Mr. Kim, you finished your
    9
    questions at this point?
    10
    MR. KIM: Yes.
    11
    HEARING OFFICER ANTONIOLLI: And,
    12
    Ms. Harvey, would you like to continue with
    13
    any follow-up questions?
    14
    MS. HARVEY: I would defer until after
    15
    the Board staff has questions that they
    16
    wanted to ask and I would wait until after
    17
    that.
    18
    MR. RAO: We have a few clarifying
    19
    questions. My first few questions relate to
    20
    your GBSM quality control, and on Page 2 of
    21
    your petition, it cites that Jo'Lyn has a
    22
    contract for purchase of GBSM from IKO
    23
    Chicago. There were no cost figures
    24
    presented in that copy of the contract.
    L.A. REPORTING (312) 419-9292

    104
    1
    Could you please comment on what's the cost
    2
    of GBSM raw material on a first-time basis?
    3
    THE WITNESS: Per ton, it's $5 a ton.
    4
    MR. RAO: Also, in the IEPA's
    5
    recommendation, one of the concerns they had
    6
    raised was about quality control requirements
    7
    and you did testify today about what kind of
    8
    quality control that you will implement as
    9
    part of your operating procedures.
    10
    My question is in terms of
    11
    purchasing GBSM material from other
    12
    manufacturers, would you follow the same
    13
    procedures that you plan to follow with IKO?
    14
    THE WITNESS: Essentially, yes, but
    15
    some things might be changed a little bit
    16
    because of their locations and the way that
    17
    their plant is set up. But basically it
    18
    would be the same process. Just, you know,
    19
    on the pick up and the contracts.
    20
    MR. RAO: Also, regarding the chemical
    21
    composition testing, you have presented some
    22
    information which is still not marked as an
    23
    exhibit, which I am sure supports your
    24
    contention that it's a material that meets
    L.A. REPORTING (312) 419-9292

    105
    1
    all the regulatory requirements. That was
    2
    part of the Board's question in the court
    3
    order. Would you require the same kind of
    4
    testing from other manufacturers before you
    5
    enter into a contract with the manufacturers
    6
    to purchase GBSM material?
    7
    THE WITNESS: I would require their
    8
    MSDS reports to see the compositions and that
    9
    it's already deemed safe for the environment
    10
    because it is on the roof of every home, so
    11
    they all should be -- I would require that.
    12
    HEARING OFFICER ANTONIOLLI: Can you
    13
    explain for the record what MSDS stands for?
    14
    THE WITNESS: Material Safety Data
    15
    Sheets.
    16
    HEARING OFFICER ANTONIOLLI: Thank
    17
    you.
    18
    MR. RAO: Also in response to
    19
    Mr. Kim's question regarding the procedures
    20
    that you follow for inspecting the material
    21
    when you pick it up at the manufacturer's
    22
    facility to make sure that you are receiving
    23
    the consistent material that, you know, meets
    24
    your specifications, you mentioned that there
    L.A. REPORTING (312) 419-9292

    106
    1
    were some guidelines that you follow and that
    2
    you're going to provide us the information.
    3
    THE WITNESS: Uh-huh.
    4
    MR. RAO: Are you aware of any
    5
    load-checking requirements in the Board's
    6
    landfill regulations for solid waste? And if
    7
    you're not, however, that's fine. It's
    8
    something that the Board has where it spells
    9
    out the kinds of visual inspections that's
    10
    done when most solid waste is picked up and I
    11
    was just wondering if you could follow some
    12
    of those procedures as to how you eliminate
    13
    different types of material getting into your
    14
    wastestream?
    15
    THE WITNESS: Right, you know, we
    16
    don't have a way -- I mean, to me this is --
    17
    we're purchasing a product, so it would be
    18
    like a regular business purchasing a product
    19
    to make whatever they make.
    20
    I have not analyzed those.
    21
    However, they do not pertain to this case
    22
    here because it is not a waste.
    23
    MR. RAO: Okay.
    24
    THE WITNESS: And we are purchasing a
    L.A. REPORTING (312) 419-9292

    107
    1
    product and it's from a reputable company.
    2
    MR. RAO: Okay. And also part of your
    3
    petition in response to some questions about
    4
    whether this waste is -- I mean, this
    5
    material is classified as a special waste, I
    6
    think in one of your responses you said that
    7
    the facility selling you this material will
    8
    provide you with a certification that it's
    9
    not a special waste; is that correct?
    10
    MS. HARVEY: Maybe I can just direct
    11
    you to the appropriate part of that. It's in
    12
    the amended petition that was filed in July.
    13
    I believe in there it discusses the fact that
    14
    this waste -- this material was previously
    15
    declassified by IEPA as not a special waste.
    16
    I'll be discussing that with Mr. Foulkes
    17
    briefly in his testimony.
    18
    Since the special waste rules have
    19
    changed since that declassification was done
    20
    and now it can basically be
    21
    self-despecialized, for lack of a better
    22
    word, you can self-certify that it falls in
    23
    the exemptions. It is our belief that IKO
    24
    can self-certify that, if the Board takes the
    L.A. REPORTING (312) 419-9292

    108
    1
    position that it's a waste, that it could be
    2
    self-declassified, if you will, as falling
    3
    under one of the exemptions as not being a
    4
    special waste.
    5
    MR. RAO: Thank you. I have a few
    6
    questions regarding the proposed adjusted
    7
    standard language itself. These are just for
    8
    classification purposes, we know exactly what
    9
    you're proposing here. In -- I'm referring
    10
    to the language proposed in the amended
    11
    subsection on Page 8.
    12
    HEARING OFFICER ANTONIOLLI: On Page
    13
    8.
    14
    MR. RAO: In Subsections 1 and 2, you
    15
    used the word clean as a qualifier to
    16
    describe the GBSM material. Could you please
    17
    explain what clean means in the context of
    18
    describing the GBSM?
    19
    THE WITNESS: Well, it wouldn't have
    20
    dust on it.
    21
    MR. RAO: Okay.
    22
    THE WITNESS: That's a silly
    23
    question -- I mean, a silly answer.
    24
    MR. RAO: You have a definition for
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    1
    GBSM, so if it meets the definition, is that
    2
    considered clean?
    3
    MS. HARVEY: I can tell you what
    4
    the -- I'm a little uncomfortable, I don't
    5
    want to be testifying, but I guess I can shed
    6
    a little light on the discussions that I
    7
    wrote this language based on discussions with
    8
    Ms. Powles. The intent of the word clean is
    9
    that there not be anything other than GBSM,
    10
    not that it -- not that there be a dirt
    11
    factor to it, but that it would be solely
    12
    GBSM and not contaminated with, let's say,
    13
    paper or some other industrial material that
    14
    would be in it. So that's the only intent of
    15
    the word clean based upon our conversations.
    16
    MR. RAO: Okay. And that's fine.
    17
    MS. HARVEY: I suppose actually the
    18
    word clean could just be stricken.
    19
    MR. RAO: Okay. In Subsection 3, the
    20
    current -- you know, when you're referring to
    21
    the grinding of GBSM material, you used the
    22
    term coarse ground or fine ground, and I
    23
    didn't, you know, see those categorizations
    24
    of ground material in your petition or other
    L.A. REPORTING (312) 419-9292

    110
    1
    information that you have provided. Can you
    2
    please explain what fine ground is and what
    3
    coarse ground is?
    4
    THE WITNESS: I believe that we took
    5
    that directly from the 1993 letter, where
    6
    they have put it into two -- GBSM ground
    7
    chips are divided into two of the following
    8
    categories, coarse ground chips and fine
    9
    ground chips.
    10
    MR. RAO: That's not applied to your
    11
    process, the way you grind your material and,
    12
    therefore, apply it?
    13
    THE WITNESS: I'm not sure on that
    14
    question.
    15
    MR. RAO: I know you're referring to
    16
    IEPA's letter that reduces the size of the
    17
    chips to define what's fine ground and what's
    18
    coarse ground, but in your process that you
    19
    have presented to the Board, do you
    20
    differentiate between, you know, fine ground
    21
    and coarse ground or is that just --
    22
    THE WITNESS: No, we do not.
    23
    MR. RAO: So, you know, if we remove
    24
    the terms fine and coarse, it should still be
    L.A. REPORTING (312) 419-9292

    111
    1
    acceptable for your purpose of grinding the
    2
    material and using it?
    3
    MS. HARVEY: Just so I'm clear on the
    4
    question, your question is basically if 3
    5
    said that Jo'Lyn and Falcon continue to grind
    6
    the GBSM into uniform pieces, period, whether
    7
    that would meet their requirements; is that
    8
    what you're asking?
    9
    MR. RAO: Uh-huh.
    10
    MS. HARVEY: Thank you.
    11
    THE WITNESS: Yes.
    12
    HEARING OFFICER ANTONIOLLI: I have a
    13
    question too. I think part of Anand's
    14
    question was that in the IEPA letter, which
    15
    we were just talking about, A) describing
    16
    coarse ground chips, describe the coarse
    17
    ground chips as 1/2" x 1/2" to 5" x 5", and
    18
    the fine ground chips are described as less
    19
    than 1/2" x 1/2", but that they may be used
    20
    as an ingredient in a hot mix paving
    21
    compound, which is a process that you
    22
    mentioned you will not investigate or --
    23
    THE WITNESS: Not --
    24
    HEARING OFFICER ANTONIOLLI: -- will
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    112
    1
    use.
    2
    THE WITNESS: Not with GBSM.
    3
    HEARING OFFICER ANTONIOLLI: Okay.
    4
    MR. KIM: So to clarify then, the
    5
    language means --
    6
    HEARING OFFICER ANTONIOLLI: It's
    7
    getting more confusing.
    8
    MR. KIM: Yeah. Well first of all --
    9
    and I think that the letter that you're
    10
    referring to and language in here, I think
    11
    that the EPA letter uses two different
    12
    spellings of the word coarse. I think
    13
    C-O-A-R-S-E is the correct spelling, and
    14
    certainly I think that --
    15
    MS. HARVEY: I would agree with Mr.
    16
    Kim on that.
    17
    HEARING OFFICER ANTONIOLLI: Yeah.
    18
    MR. KIM: -- under the adjusted
    19
    standard, it should probably read that.
    20
    Second, the adjusted standard
    21
    anticipates use of either coarse ground or
    22
    fine ground chips, but Ms. Powles has, I
    23
    think, testified that even if fine ground
    24
    chips are used, the only reference to that
    L.A. REPORTING (312) 419-9292

    113
    1
    term in this EPA letter is just as to define
    2
    what the size of a fine ground chip is. It's
    3
    not to allow that chip to be used in hot mix
    4
    asphalt.
    5
    HEARING OFFICER ANTONIOLLI: Right.
    6
    It doesn't limit the use of those two
    7
    specific applications.
    8
    MR. KIM: It just defines the size.
    9
    Okay. Yeah, with that clarification.
    10
    HEARING OFFICER ANTONIOLLI: Okay.
    11
    MR. RAO: Could you comment on whether
    12
    you think the installation specifications
    13
    that you testified to, the minimum
    14
    requirements of the thickness and how it
    15
    should be compacted? Should those
    16
    specifications be part of the adjusted
    17
    standard, especially in terms of if you are
    18
    provided with material to some entity who
    19
    wants to purchase this and install it on
    20
    their own? Like, for example, we earlier
    21
    talked about the townships, which you are not
    22
    really sure whether you would be installing
    23
    the product or you'd provide the material and
    24
    they will install the product. So, you know,
    L.A. REPORTING (312) 419-9292

    114
    1
    could you care to comment on this?
    2
    MS. HARVEY: Are you asking if the
    3
    adjusted standard should include installation
    4
    thickness?
    5
    MR. RAO: Should it include it, yeah.
    6
    MS. HARVEY: Can I ask her a question?
    7
    Maybe it might help her answer that.
    8
    Do you anticipate that there might
    9
    be circumstances where you might need to
    10
    somewhat adjust those specifications for some
    11
    reason relating to where you're going to
    12
    apply it, in other words, if there might be
    13
    future developments of your process that
    14
    might lead to some minor adjustments to those
    15
    specifications?
    16
    THE WITNESS: Yes.
    17
    MS. HARVEY: Okay. So, therefore, do
    18
    you believe that -- would limiting the
    19
    adjusted standard language to the -- what's
    20
    currently known as the installation
    21
    specification potentially limit the
    22
    appropriate installation of the EDC in the
    23
    future? That's a bad question, I'm sorry.
    24
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    115
    1
    MR. RAO: Let me put it this way.
    2
    If you provide this material to --
    3
    you know, I want to say a client who wants to
    4
    install it themselves, then will you also
    5
    ensure that part of the contract will say,
    6
    you know, ask the client to install it in --
    7
    according to your specifications?
    8
    THE WITNESS: I think we can.
    9
    MS. HARVEY: Can I just -- I'm a
    10
    little concerned about -- I think we're going
    11
    -- these are all, of course, extremely
    12
    appropriate questions. I don't know that
    13
    there is any indication. We haven't been
    14
    able to look back at all the documents yet to
    15
    determine if there's even been an instance
    16
    where Jo'Lyn and Falcon would sell it for
    17
    installation by somebody else. The contracts
    18
    that I've looked at currently talk about
    19
    installation of -- about selling the
    20
    materials and the labor for installation. I
    21
    would rather have Ms. Powles have an
    22
    opportunity to consider these issues and
    23
    address them in the post-filing comments, if
    24
    that's acceptable, rather than to speculate
    L.A. REPORTING (312) 419-9292

    116
    1
    here as she's sitting here about something
    2
    that, at least to my current knowledge, isn't
    3
    even on the horizon, it hasn't happened yet.
    4
    We are certainly willing to answer the
    5
    question, but I think that she needs an
    6
    opportunity to think about some of those
    7
    issues before she answers those questions.
    8
    MR. RAO: That's perfectly all right,
    9
    yes.
    10
    MS. HARVEY: But it's not something
    11
    that's come up prior to this because, you
    12
    know, all the contracts have been for
    13
    furnishing and installed.
    14
    HEARING OFFICER ANTONIOLLI: Well, at
    15
    this point, let's have Anand ask the
    16
    questions, and Alisa ask questions, at this
    17
    point for the witness and you can answer to
    18
    the best of your ability, and if not, respond
    19
    in written comments after the hearing.
    20
    THE WITNESS: Okay.
    21
    MR. RAO: Yeah. And like the Hearing
    22
    Officer earlier said, these are the questions
    23
    we are asking just so because if it's not in
    24
    the record, if a Board member asks us a
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    117
    1
    question, we can come up with the answers for
    2
    them. So, you know, bear with us and, you
    3
    know, I know it may seem frustrating for you,
    4
    but it helps to have a complete record. So
    5
    you can feel free to answer those questions
    6
    in writing. Okay.
    7
    Also one other issue that was
    8
    not -- the Agency, in the proposal, lists a
    9
    standard with any kind of limitations on
    10
    storage of this material at the site. Please
    11
    comment on whether such limitations are
    12
    appropriate to ensure a quick turnover of the
    13
    accumulated material or if there's a need for
    14
    any sort of limitations.
    15
    MS. HARVEY: Do you mean storage
    16
    limits in terms of time?
    17
    MR. RAO: Accumulated, yeah.
    18
    MS. HARVEY: Time, not amount?
    19
    MR. RAO: Not amount, time, yeah,
    20
    because there are some regulatory
    21
    requirements that would say if it goes over a
    22
    period of a year, it becomes a waste pile.
    23
    MS. HARVEY: Right. If you can answer
    24
    that, you can answer it, otherwise we'll --
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    1
    THE WITNESS: We always want to use
    2
    the material as soon as we possibly can. We
    3
    should be using the material no more than
    4
    eight months, but as soon as two months, even
    5
    a month from when the material comes in.
    6
    Does that answer your question?
    7
    MS. LIU: I have a question. On the
    8
    facility map that you provided us, is there a
    9
    limit to the storage area that you could keep
    10
    the GBSM?
    11
    THE WITNESS: There is for us, not a
    12
    limit, per se, by anybody else, it is a large
    13
    parcel, but we are keeping it within the tree
    14
    line.
    15
    MS. LIU: And that's --
    16
    THE WITNESS: Which you can -- you
    17
    know, I put the little lines in there and
    18
    then coming around this way.
    19
    MS. LIU: That's your own designation?
    20
    THE WITNESS: Correct.
    21
    MS LIU: Okay.
    22
    HEARING OFFICER ANTONIOLLI: And what
    23
    you're referring to, again, is the map on
    24
    Page 3 of the operating manual?
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    119
    1
    THE WITNESS: Uh-huh.
    2
    HEARING OFFICER ANTONIOLLI: Okay.
    3
    MS. LIU: In your petition, you also
    4
    provided a very complete definition of what
    5
    GBSM is, but I notice in the adjusted
    6
    standard wording, there is no definition
    7
    provided. Just so that it can't be ever
    8
    redefined outside the scope of the adjusted
    9
    standard, would it be acceptable to include a
    10
    definition in your adjusted standard wording?
    11
    THE WITNESS: I do believe we can
    12
    write one up.
    13
    MS. HARVEY: I think -- yeah.
    14
    THE WITNESS: I would be more than
    15
    happy to write one up.
    16
    MS. HARVEY: I just want to direct
    17
    your attention to number two in the adjusted
    18
    standard language in the amended petition. I
    19
    think that's the same definition.
    20
    MS. LIU: Okay. Thank you.
    21
    MS. HARVEY: This is Page 8 in the
    22
    amended petition.
    23
    MS. LIU: Would you want to put any
    24
    qualifiers on the word clean?
    L.A. REPORTING (312) 419-9292

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    1
    MS. HARVEY: It seems to me that clean
    2
    is only redundant, if you will, because it
    3
    already requires only GBSM.
    4
    MR. RAO: Okay. Moving on. You
    5
    talked a little bit about the grinder itself.
    6
    Can you describe it a little bit more in
    7
    detail? I know there's an -- I've seen some
    8
    of these grinders which are huge with 500 and
    9
    800 horsepower, with timers and stuff like
    10
    that.
    11
    THE WITNESS: You know, is that it
    12
    right there?
    13
    MR. RAO: Yeah. I want something in
    14
    the record.
    15
    THE WITNESS: Okay.
    16
    MR. RAO: If you can take a look at
    17
    this, you know, that would be fine. The
    18
    thing is, the Board cannot go outside the
    19
    record.
    20
    THE WITNESS: And I can get -- yes.
    21
    MR. RAO: I was just curious about,
    22
    you know, how loud can these grinders get?
    23
    You mentioned a muffler was being used to
    24
    muffle the sounds?
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    121
    1
    THE WITNESS: Yeah. It just has a
    2
    muffler. It does tend to get a little bit
    3
    loud. Not more -- definitely not more than a
    4
    combine outside out in McHenry County. So,
    5
    you know, we have tractors out here that are
    6
    doing things that are much louder than the
    7
    grinder, plus we are in a location that has
    8
    such an excellent buffer. You know, we have
    9
    the big woods around there, plus we're right
    10
    next to the railroad and it's not louder than
    11
    the railroad either. Does that answer your
    12
    question?
    13
    MR. RAO: Yes, it does.
    14
    THE WITNESS: Okay.
    15
    MS. LIU: Just in a follow-up to that
    16
    concerning the grinding in Exhibit 1, the
    17
    shredded GBSM you have provided, is that
    18
    after it's been grinded?
    19
    THE WITNESS: Yeah. And actually that
    20
    is just the tabs that were ground, so that's
    21
    not a mixture with the sheet, but just to
    22
    give you a real accurate --
    23
    MS. LIU: So that is what it actually
    24
    looks like when you apply it?
    L.A. REPORTING (312) 419-9292

    122
    1
    THE WITNESS: Yes.
    2
    MS. LIU: Okay.
    3
    MR. RAO: And the part of your
    4
    testimony you referred to how, initially, you
    5
    applied for an air permit and that's how it
    6
    started --
    7
    THE WITNESS: Uh-huh.
    8
    MR. RAO: -- with the IEPA?
    9
    THE WITNESS: Uh-huh.
    10
    MR. RAO: If Jo'Lyn is granted relief
    11
    in this proceeding, do you still have to get
    12
    an air permit from the IEPA?
    13
    THE WITNESS: From my understanding,
    14
    yes, a machine that big needs one. However,
    15
    I have heard -- the rules could have changed,
    16
    you know, I must say. So I don't know
    17
    because I know there were a couple in that
    18
    were going through. I haven't looked at the
    19
    air permits for a while to be honest with
    20
    you.
    21
    MR. RAO: Okay. Actually, I am done.
    22
    Thank you, very much.
    23
    HEARING OFFICER ANTONIOLLI: Okay.
    24
    MS. LIU: One follow-up question out
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    123
    1
    of curiosity. Do the piles, after they've
    2
    been exposed to the sun for a while,
    3
    eventually just turn into a big solid mass?
    4
    THE WITNESS: No.
    5
    MS. LIU: Okay.
    6
    THE WITNESS: No, but they stick
    7
    together just a little bit, but as soon as we
    8
    hit it with the excavator or whatever, you
    9
    know, it's all -- it all separates very
    10
    easily.
    11
    MS. LIU: Okay. Thank you. Just
    12
    curious.
    13
    MR. RAO: So it is the compaction that
    14
    helps in the bonding?
    15
    THE WITNESS: Yes, the compaction and
    16
    the sun. It's really neat, I bet you guys
    17
    would like it.
    18
    HEARING OFFICER ANTONIOLLI: Okay.
    19
    Thank you, Ms. Liu and Mr. Rao. Ms. Harvey,
    20
    would you like to continue?
    21
    MS. HARVEY: I have just a couple of
    22
    short follow-up questions for Ms. Powles.
    23
    24
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    124
    1
    FURTHER DIRECT EXAMINATION
    2 BY MS. HARVEY:
    3
    Q. Just to clarify some of the testimony
    4 that you gave in response to Mr. Kim's questions.
    5 Ms. Powles, he asked you about basically how you get
    6 these piles of GBSM that's currently on site. When
    7 did you -- did you obtain that GBSM prior to knowing
    8 that you couldn't operate the facility without a
    9 waste permit?
    10
    A. Yes. We thought we would be able to
    11 process the material right away.
    12
    Q. So it wasn't stockpiled speculatively
    13 or thinking that --
    14
    A. No, it never was.
    15
    Q. And am I correct that once you learned
    16 that you couldn't continue to operate, that you
    17 stopped hauling GBSM to the site?
    18
    A. That is correct.
    19
    Q. Okay. Can you give me an idea of how
    20 long it would take to use the current supply of GBSM
    21 that you have on-site? For example, could you use
    22 that whole supply in one working season?
    23
    A. Definitely.
    24
    Q. Could you use it in less than a
    L.A. REPORTING (312) 419-9292

    125
    1 working season?
    2
    A. Yes.
    3
    Q. Okay. Do you believe that you have --
    4 currently have contracts that are sufficient to use
    5 up all the GBSM you currently have on-site?
    6
    A. Contracts plus the contacts that we
    7 haven't contacted because one of our contracts did
    8 back out.
    9
    Q. Why did they back out?
    10
    A. Because they needed to get the dust
    11 down on their driveways so they went to RAP,
    12 actually, Recycled Asphalt Pavement.
    13
    Q. Would it be correct for me to say
    14 that -- would it be correct to say that the contract
    15 backed out because there was a delay in getting
    16 approval for your process?
    17
    A. Exactly.
    18
    Q. Okay. And I think just one other
    19 area. There was also some testimony about your --
    20 the basis for your rejection of GBSM --
    21 theoretically we understand that you haven't had to
    22 reject any GBSM -- but you testified earlier that
    23 it's a visual inspection that you undergo, at least
    24 twice. What are you looking for?
    L.A. REPORTING (312) 419-9292

    126
    1
    A. Anything other than GBSM.
    2
    Q. Okay. And then you would make a
    3 decision whether or not you would remove that from
    4 the GBSM or whether or not you would reject the
    5 load; is that correct?
    6
    A. Correct.
    7
    Q. Okay.
    8
    MS. HARVEY: I don't have anything
    9
    else.
    10
    HEARING OFFICER ANTONIOLLI: Okay.
    11
    Thank you. Does anyone else have questions
    12
    for the witness at this point? Yes, sir.
    13
    Can you introduce yourself?
    14
    MR. TURLEY: I'm William Turley.
    15
    HEARING OFFICER ANTONIOLLI: Thank
    16
    you.
    17
    MR. TURLEY: What is your recycling
    18
    rate, the material you bring in, how much you
    19
    can recycle and how much you can send to the
    20
    landfill after that?
    21
    THE WITNESS: Of the GBSM?
    22
    MR. TURLEY: Yes.
    23
    THE WITNESS: It's 100 percent
    24
    recyclable.
    L.A. REPORTING (312) 419-9292

    127
    1
    MR. TURLEY: Thank you.
    2
    HEARING OFFICER ANTONIOLLI: Okay.
    3
    Thank you and anyone else?
    4
    MS. LIU: I have a follow-up to that
    5
    question. Are there any waste byproducts
    6
    from this process from cleaning the grinder?
    7
    THE WITNESS: No. There is no
    8
    residuals. You just -- as to what we're
    9
    getting in, you can see in that box, yes,
    10
    it's brown, but, you know, that's it.
    11
    MR. LIU: Okay.
    12
    HEARING OFFICER ANTONIOLLI: Okay.
    13
    Thank you. And Ms. Harvey, would you like to
    14
    call your next witness --
    15
    MS. HARVEY: Yes, I would.
    16
    HEARING OFFICER ANTONIOLLI: -- and
    17
    have them sworn in.
    18
    MS. HARVEY: I'd like to call
    19
    Mr. David Foulkes of IKO.
    20
    HEARING OFFICER ANTONIOLLI: Tammi,
    21
    could you swear in the witness?
    22
    (Witness sworn.)
    23
    24
    L.A. REPORTING (312) 419-9292

    128
    1 WHEREUPON:
    2
    DAVID FOULKES
    3 called as a witness herein, having been first duly
    4 sworn, deposeth and saith as follows:
    5
    DIRECT EXAMINATION
    6 BY MS. HARVEY:
    7
    Q. Can you state your name for the
    8 record, please?
    9
    A. My name is David Foulkes, F, as in
    10 Frank, O-U-L-K-E-S, as in Sam.
    11
    Q. Who is your employer, Mr. Foulkes?
    12
    A. I work for IKO.
    13
    Q. And what are your job responsibilities
    14 at IKO?
    15
    A. I'm on the corporate staff of the
    16 parent company and I have responsibilities for
    17 environmental issues, for transportation,
    18 responsibility for a railcar fleet of about 150
    19 railcars, I'm involved in raw material purchasing,
    20 labor relations and new site selection.
    21
    Q. Quite a bit, I'd say, apparently.
    22
    A. It makes the job interesting.
    23
    Q. What is your educational background?
    24 Do you have an undergraduate degree?
    L.A. REPORTING (312) 419-9292

    129
    1
    A. I have an undergraduate degree in
    2 economics and a graduate degree, master's with
    3 emphasis in labor relations.
    4
    Q. Where did you obtain those degrees?
    5
    A. University of Cincinnati.
    6
    Q. Okay. How long have you worked for
    7 IKO?
    8
    A. It will be 18 years in March.
    9
    Q. Prior to your employment at IKO, who
    10 did you work for immediately before your employment
    11 at IKO?
    12
    A. I worked for a company called Fuji
    13 Tech, which was a Japanese elevator company.
    14
    Q. What did you do there?
    15
    A. Basically production control,
    16 warehousing, shipping and receiving
    17 responsibilities.
    18
    Q. And did you have employment prior to
    19 your employment at Fuji Tech?
    20
    A. I worked for a company by the name of
    21 Sun Chemical, which was involved in the manufacture
    22 of organic pigments.
    23
    Q. Okay. And as you said, you started
    24 your employment at IKO roughly 18 years ago; is that
    L.A. REPORTING (312) 419-9292

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    1 correct?
    2
    A. Correct.
    3
    Q. Have you held any position other than
    4 the position you currently hold?
    5
    A. Well, I started in operations
    6 management. I was plant manager in the Franklin,
    7 Ohio facility for a number years before I moved into
    8 my current position.
    9
    So rather than being quite as
    10 focused, it just then blossomed into a number of
    11 different responsibilities.
    12
    Q. What year did you move into your
    13 current position at IKO?
    14
    A. January 1996.
    15
    Q. Thank you. I want to talk a little
    16 bit about the background of IKO as an entity. Can
    17 you tell me a little bit about the corporate
    18 history? What does IKO do?
    19
    A. IKO is a family-owned corporation.
    20 The family -- the owners are in Canada. We started
    21 in Canada in 1948 as a roofing manufacturer and
    22 since, then have grown to become the largest
    23 manufacturer of asphalt roofing products in Canada.
    24 We started a presence in the United States in the
    L.A. REPORTING (312) 419-9292

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    1 late 1970s. We are still relatively small-fish in
    2 the United States, but are working to increase our
    3 market penetration. We also have a number of plants
    4 in Europe.
    5
    Q. Okay. And the types of products that
    6 you manufacture, are they all roofing products?
    7
    A. Well, they're all roofing-related
    8 products.
    9
    Q. Okay.
    10
    A. The plant that we're talking about
    11 here in Bedford Park is strictly an asphalt roofing
    12 manufacturing facility. However, as a corporation,
    13 we have become almost totally vertically integrated,
    14 so that we have our own quarries where we crush our
    15 own rock, we color our own rock, we have our own oil
    16 and gas wells where we can produce our own
    17 petroleum, we have our own fleet of trucks. I
    18 mentioned we have our own fleet of railcars, we even
    19 have our own distribution line where we sell the
    20 finished product.
    21
    Q. How many plants do you have in the
    22 United States that make asphalt roofing products?
    23
    A. We have four plants in the United
    24 States that are roofing manufacturers.
    L.A. REPORTING (312) 419-9292

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    1
    Q. And where are they located?
    2
    A. We have the one in Bedford Park, we
    3 have one in Franklin, Ohio, southwest Ohio near
    4 Cincinnati, we have one in Wilmington, Delaware and
    5 we have one in Sumas, Washington, which is northeast
    6 of Seattle.
    7
    Q. Are you building a new plant in
    8 Illinois?
    9
    A. We are building a new facility in
    10 Kankakee, just south of Chicago, which will be
    11 supplementary to the Bedford Park facility making a
    12 slightly different product, still asphalt roofing,
    13 but a different product than the Bedford Park
    14 facility, so that would be operating together.
    15
    Q. Okay. When do you anticipate that --
    16 hopefully that plant going online?
    17
    A. Well, a lot of it's going to depend on
    18 weather, but if everything works out, we hope to be
    19 producing shingles by this summer -- this coming
    20 summer.
    21
    Q. I want to go back for a second to your
    22 discussion of the vertical integration concept.
    23 Would it be correct for me to say that IKO or an IKO
    24 company is able to provide all of the ingredients of
    L.A. REPORTING (312) 419-9292

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    1 the asphalt shingles that IKO manufactures?
    2
    A. Not completely.
    3
    Q. Okay.
    4
    A. We do not have our own refineries.
    5
    Q. Okay.
    6
    A. We do have our own oil and gas wells
    7 and we use those as a hedge against the volatility
    8 of the petroleum market these days. But we will
    9 sell that, for instance, out in western Canada, and
    10 yet, we will buy our asphalt, say, from Whiting,
    11 Indiana. Not the same raw material that went into
    12 it, but we are hedged there on the pricing.
    13
    Q. The other ingredients of your roofing
    14 shingles, the trap rock, the limestone, et cetera --
    15 there's information in the record that we will mark
    16 soon -- are those all provided by IKO companies?
    17
    A. The carrier sheets, which can be
    18 either paper, organic in base or fiberglass, we do
    19 produce. We have our own paper mills for the
    20 organic sheet and we have a joint venture in
    21 Danville, Illinois where we produce our own
    22 fiberglass matters. The granules -- we produce 100
    23 percent of our own face granules. There are some
    24 granules that are called head-lap granules that are
    L.A. REPORTING (312) 419-9292

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    1 hidden underneath the shingle above, where we buy
    2 boiler slag and other waste products to try and
    3 recycle those. We don't have to use the expensive
    4 face granules.
    5
    The limestone that we use in the
    6 products, we do buy that on the market. That is
    7 just a very inexpensive commodity-type item.
    8
    Q. Okay. Let's focus on the GBSM that
    9 we've heard so much about today.
    10
    From IKO's perspective, what is
    11 GBSM? Why do you end up with it?
    12
    A. We are, as a company, very sensitive
    13 to quality, and so when we put out a product that
    14 has an IKO label on it, that has the owning family's
    15 name on it. They will not allow us to put out a
    16 product that isn't of very high quality. If it
    17 doesn't meet those specifications, then it is
    18 surplused. We will not put it out, we will not sell
    19 it on the market and we will recycle it. We do have
    20 recycling operations associated with all of our
    21 North American plants right now, except for the
    22 Bedford Park plant, which is where we've had the
    23 issues.
    24
    Q. And we'll come back to that in a
    L.A. REPORTING (312) 419-9292

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    1 little bit. But do you know what the other plants
    2 use the GBSM for?
    3
    A. The majority of the GBSM in the other
    4 plants is used as an ingredient in hot mix paving.
    5 Most of the other plants are urban applications and
    6 there's not the demand for an alternative to gravel
    7 driveways in the urban environment, people are
    8 looking at asphalt pavement for driveways and
    9 parking lots and that's why the majority of it --
    10
    Q. So that GBSM is used for a paving
    11 application?
    12
    A. Correct.
    13
    Q. Okay.
    14
    MS. HARVEY: I want to show you what
    15
    I'd like to mark as, I think, Exhibit 6 -- it
    16
    would actually be Group Exhibit 6. This is
    17
    the large rubber band-bound packet that has
    18
    on its top a February 22nd, 1993 letter from
    19
    IKO Chicago to Larry Easterp at IEPA. So I
    20
    guess I just ask that we mark this as Group
    21
    Exhibit 6.
    22
    (Document marked as Exhibit No. 6
    23
    for identification, 12/22/04.)
    24
    HEARING OFFICER ANTONIOLLI: Okay.
    L.A. REPORTING (312) 419-9292

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    1
    And what I have in my hand is exactly as
    2
    Ms. Harvey described, a letter from IKO
    3
    Chicago to Mr. Easterp, and it is a
    4
    collection of six documents.
    5
    Does anyone have an objection to
    6
    me entering that as Exhibit 6 at this time?
    7
    Seeing none, I will go ahead and
    8
    enter that as Exhibit 6.
    9
    (Whereupon, Exhibit No. 6 was
    10
    received in evidence by the
    11
    Hearing Officer.)
    12
    MS. HARVEY: Thank you, Madam Hearing
    13
    Officer.
    14 BY MS. HARVEY:
    15
    Q. Mr. Foulkes, can you tell me what this
    16 letter is related to? Did there come a time when
    17 IKO needed to submit materials to IEPA regarding the
    18 GBSM?
    19
    A. In the early '90s there was a question
    20 raised by the IEPA about our wastestream and whether
    21 our wastestream should be classified as a special
    22 waste or not.
    23
    Q. When you say your wastestream, are you
    24 referring specifically to GBSM?
    L.A. REPORTING (312) 419-9292

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    1
    A. Actually, I'm talk about everything --
    2
    Q. Okay.
    3
    A. -- that comes out of the plant.
    4
    Q. Okay.
    5
    A. And what we did is we made a number of
    6 trips to Springfield, we sat down with the EPA
    7 officials, and at that point it was suggested we
    8 submit an application for decertification -- or I
    9 don't know if decertification is the correct word --
    10 but reclassification of your wastestream, number
    11 one, and number two, if you're going to try to sell
    12 the GBSM, then you want to ask for some type of
    13 determination as to whether GBSM can be used -- can
    14 be sold and can be used as a road application, a
    15 road filler.
    16
    So we submitted it early in 1993,
    17 a packet, and I believe that that is the second one
    18 in here, it's called Solid Waste Determination
    19 Request dated January 29, 1993.
    20
    Q. And what was the outcome of that --
    21 well, let me back up a second.
    22
    Mr. Foulkes, were you personally
    23 involved with the negotiations or the submittal of
    24 this material to the Illinois Environmental
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    1 Protection Agency?
    2
    A. No. At the time, I was plant manager
    3 in the plant -- in the Ohio plant, but there was a
    4 great deal of interaction between the plants and so
    5 with my environmental background, I did stay in
    6 touch with this.
    7
    Q. Have you subsequently in the course of
    8 your current duties at IKO had reason to become
    9 involved actually -- or obviously here with Falcon
    10 and Jo'Lyn, with the issue of how to classify the
    11 GBSM?
    12
    A. Yes, very much so, having made a
    13 number of trips to Springfield to talk with the EPA
    14 officials in Springfield in reference to this and
    15 actually also our new plant in Kankakee and the
    16 issues surrounding that.
    17
    Q. Okay.
    18
    MS. HARVEY: Madam Hearing Officer,
    19
    I'm not going to ask Mr. Foulkes to go
    20
    through all the contents of these documents
    21
    because he didn't create them. However, they
    22
    are created in the course of business of
    23
    Mr. Foulkes' business, so I want to submit
    24
    them into the record and just indicate to --
    L.A. REPORTING (312) 419-9292

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    1
    have Mr. Foulkes indicate to some degree what
    2
    the contents of these documents are so that
    3
    the Board will have the information in front
    4
    of it.
    5
    More specifically, I want to point
    6
    you to the second document which Mr. Foulkes
    7
    just stated is dated January 29, 1993. This,
    8
    I believe, was the original submittal in
    9
    support of both the request that you referred
    10
    to in the rebuttal in the special waste
    11
    declassification, as well as the
    12
    determination that you could sell the GBSM;
    13
    is that correct?
    14
    THE WITNESS: That's my understanding,
    15
    yes.
    16 BY MS. HARVEY:
    17
    Q. And the table of contents lists the
    18 complete contents of the application, including
    19 information such as the GBSM composition, some
    20 testing results on the GBSM and a number of
    21 appendixes that support those; is that correct?
    22
    A. That is correct.
    23
    Q. Okay. Do you know, in general,
    24 laypeople's terms, the results of toxicity testing
    L.A. REPORTING (312) 419-9292

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    1 on GBSM?
    2
    A. The TCLP tests showed no issues or any
    3 reasons why there should be any concern from a toxic
    4 standpoint on the GBSM material.
    5
    Q. Okay. And after this material was
    6 submitted to IEPA, I believe the next step was IKO
    7 received from IEPA the waste determination that the
    8 GBSM was not a waste when used for a paving product.
    9 I'm referring to, I believe, it's Exhibit 5, the May
    10 1993 waste determination.
    11
    A. That is correct.
    12
    Q. So to your knowledge, that waste
    13 determination was based upon the information in this
    14 January 29th submittal, correct?
    15
    A. That is correct, yes.
    16
    Q. Okay. Did IKO subsequently receive
    17 additional correspondence from IEPA in relation to
    18 this solid waste declassification? I believe that
    19 might be the next item in your exhibit.
    20
    A. Yes. In June of 1993, we received a
    21 letter from the IEPA saying that our request for
    22 declassification was incomplete and they
    23 specifically noted a number of items in here that we
    24 needed to address in our submittal to the IEPA.
    L.A. REPORTING (312) 419-9292

    141
    1
    Q. Okay. And then am I correct that the
    2 next two documents in your packet, which are a cover
    3 letter dated November 5th, 1993 from IKO and an
    4 application for waste classification dated April --
    5 excuse me, October 29th, 1993 -- was that IKO's
    6 response to that June letter from the IEPA?
    7
    A. That is correct.
    8
    Q. Okay. And am I correct that the
    9 application for waste classification, this October
    10 document, provides yet additional information in
    11 response to IEPA's content requests, if you will?
    12
    A. That is correct, yes.
    13
    Q. Then what happened?
    14
    A. Then I believe it was in January of
    15 '94 we received a letter from the IEPA agreeing with
    16 our request for declassification of our general
    17 wastestream as a special waste and --
    18
    Q. I'm sorry, go ahead.
    19
    A. -- and so that we could take any
    20 material that we needed to dispose of to the
    21 sanitary island fill.
    22
    Q. Is that the last letter, the last
    23 document in that packet? Does that look to be --
    24
    A. Yes. January 14th, '94.
    L.A. REPORTING (312) 419-9292

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    1
    Q. May I ask you, before this issue arose
    2 in the early '90s of whether or not your wastestream
    3 was special waste, how did IKO dispose of its waste?
    4
    A. We have owned this plant since 1981,
    5 and since we owned the plant, we had been taking the
    6 material to the sanitary landfill. And our
    7 predecessors had been taking it to the landfill and
    8 our competitors had been taking it to the landfill.
    9
    Q. Did there come a time when you were
    10 notified by the IEPA that you had to stop taking it
    11 to the landfill?
    12
    A. I think it was in 1992 that we were
    13 notified by the IEPA that we could no longer take it
    14 to the sanitary landfill and we had to consider all
    15 of our waste as a special waste.
    16
    Q. Do you know if your competitors in
    17 Illinois were also informed that they needed to
    18 dispose of their waste as special waste?
    19
    A. To our understanding, we were the only
    20 manufacturer in the state of Illinois that was so
    21 picked on.
    22
    Q. Do you know how many asphalt shingle
    23 manufacturers there are in the state of Illinois,
    24 roughly?
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    1
    A. Well, right now, there are only two
    2 plants left in the state of Illinois, ours in
    3 Bedford Park and Owens Corning in Summit here.
    4
    Q. You say right now, were there more?
    5
    A. There were a number of additional
    6 plants. They have closed up and moved their
    7 applications out of the state.
    8
    Q. Okay.
    9
    HEARING OFFICER ANTONIOLLI: As long
    10
    as we have a pause now, I am going to
    11
    recommend that we take a break and let's go
    12
    off the record.
    13
    (Whereupon, after a short
    14
    break was had, the following
    15
    proceedings were held
    16
    accordingly.)
    17
    HEARING OFFICER ANTONIOLLI: We are
    18
    now back on the record. We are now prepared
    19
    to go back on the record and it is about
    20
    12:00 o'clock and we're continuing with
    21
    questions of the second witness.
    22 BY MS. HARVEY:
    23
    Q. Mr. Foulkes, the information that was
    24 submitted to IEPA in support of the solid waste
    L.A. REPORTING (312) 419-9292

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    1 determination and the declassification of special
    2 waste is all dated 1992 and 1993. Have the
    3 ingredients that IKO uses in its process changed
    4 appreciably since that time?
    5
    A. No.
    6
    Q. Okay.
    7
    MS. HARVEY: I'm going to show you
    8
    what I would like to mark as Exhibit 7, which
    9
    is a one-page letter from Mr. Foulkes to
    10
    Ms. Powles on IKO's letterhead that
    11
    confirms -- well, I'll let Mr. Foulkes
    12
    testify to the content of the letter. In
    13
    fact, I'd like to mark it as Exhibit 7.
    14
    (Document marked as Exhibit
    15
    No. 7 for identification,
    16
    12/22/04.)
    17
    HEARING OFFICER ANTONIOLLI: Okay.
    18
    And Mr. Kim, you had an opportunity to take a
    19
    look at this?
    20
    MR. KIM: Yes.
    21
    HEARING OFFICER ANTONIOLLI: If there
    22
    are no objections, I'll enter this letter
    23
    from IKO to Ms. Powles as Exhibit No. 7.
    24
    And seeing none, I will enter that
    L.A. REPORTING (312) 419-9292

    145
    1
    as Exhibit 7.
    2
    (Whereupon, Exhibit No. 7 was
    3
    received in evidence by the
    4
    Hearing Officer.)
    5
    MS. HARVEY: Thank you, Madam Hearing
    6
    Officer.
    7 BY MS. HARVEY:
    8
    Q. Mr. Foulkes, did you author this
    9 letter?
    10
    A. That is correct.
    11
    Q. And what's the gist of the letter, if
    12 you will?
    13
    A. Basically, the ingredients that go
    14 into asphalt shingles today are the same ingredients
    15 that went into asphalt shingles in the early '90s.
    16 The only real difference today is the shape of the
    17 finished products. The raw material ingredients
    18 basically are the same.
    19
    Q. Okay. I think you testified a little
    20 earlier too that you supplied to the market -- you
    21 supplied most of the ingredients for those at IKO?
    22
    A. That's probably the biggest change is
    23 that in the early '90s, we were buying the majority
    24 of our raw materials and today we are producing the
    L.A. REPORTING (312) 419-9292

    146
    1 majority of our raw materials.
    2
    There are two reasons for that
    3 really. One is -- three reasons. One is cost.
    4 Obviously, we can control the cost factors a little
    5 bit better. Two is a continuous supply, we can
    6 control the supply of the materials. But number
    7 three, and probably the most important reason for
    8 doing this, is quality.
    9
    Again, the K of IKO is the initial
    10 for the owning family of the company, so they
    11 literally are putting their name in every bundle of
    12 shingles that goes out, and they want to make sure
    13 that we are the best shingle on the market today.
    14 So that's really the reason we have gone in this
    15 direction.
    16
    Q. Okay. You testified a little earlier
    17 in your explanation that the wastes -- the GBSM from
    18 your -- the paving plants in the United States,
    19 other than Bedford Park, are all used for paving
    20 applications -- or approved for use of paving
    21 applications?
    22
    A. Yes.
    23
    Q. I just want to direct your attention
    24 to -- this is, again, I'm referring to the
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    1 January 29th, 1993 submittal -- does this include --
    2 I believe, I'll direct your attention to starting
    3 with Appendix E, it's found on Pages 79 and 80. Do
    4 these -- and then going on through, I believe, Page
    5 97. Do these documents discuss the regulatory
    6 approval in other states for this paving use?
    7
    A. That is correct, yes.
    8
    Q. Okay. And to your understanding,
    9 these approvals are still in effect, there's been no
    10 changes? Nobody has revoked their approval, so to
    11 speak?
    12
    A. That is correct. We are recycling all
    13 of the products out of our Wilmington and Franklin,
    14 Ohio facilities.
    15
    Q. Do you have occasions to talk to other
    16 people in your field, other manufacturers, about
    17 what they do with their GBSM?
    18
    A. Yes. I, personally, and we, as a
    19 company, are very active in the industry trade
    20 association, ARMA, the Asphalt Roofing Manufacturers
    21 Association -- and ARMA has tried to focus on the
    22 issue of recycling as one of their main thrusts.
    23 And, in fact, I believe that it was a program -- a
    24 seminar that was put on by ARMA and then several
    L.A. REPORTING (312) 419-9292

    148
    1 other organizations, recycling operations, that
    2 started Falcon Waste down the road of looking at the
    3 concept of using GBSM.
    4
    Q. To your knowledge, do some of your
    5 competitors also have their GBSM used as paving?
    6
    A. A large number. In fact, wherever
    7 possible, the industry in general recycles, yes.
    8
    Q. Okay. There were some questions a
    9 little earlier from Mr. Kim about what are you doing
    10 with your GBSM since -- currently since Falcon and
    11 Jo'Lyn are not able to pick it up and haul it. What
    12 is happening to the GBSM from Bedford Park?
    13
    A. Well, unfortunately, the majority of
    14 it is going into the landfill at the moment. We are
    15 able to recycle or sell a very small amount of it to
    16 a small recycling operation in Chicago.
    17
    Q. What do they do with it?
    18
    A. They make what's called Protective
    19 Board, which is where they grind up the material and
    20 then put it between two sheets of fiberglass and it
    21 becomes a very hard walking surface that is then
    22 used on flat built-up roofs as a surface for
    23 maintenance people, et cetera, so they won't destroy
    24 the basic membrane of the roof.
    L.A. REPORTING (312) 419-9292

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    1
    MS. LIU: Can you say what that was
    2
    called again? Protective --
    3
    THE WITNESS: Protective Board.
    4
    MS. LIU: Board?
    5
    THE WITNESS: Board.
    6
    MS. LIU: Is that the name of the
    7
    product?
    8
    THE WITNESS: That's a brand name. I
    9
    think there are a number of different names.
    10
    It's a walking surface for built-up roofs.
    11 BY MS. HARVEY:
    12
    Q. Is there any reason other than the
    13 fact that operations in Illinois can't currently
    14 pick up and use your GBSM -- is there any other
    15 reason that your GBSM is being landfilled?
    16
    A. No. We cannot find anybody else in
    17 Illinois that can do it. There are people out of
    18 state that will take it, the problem is the
    19 economics, the freight costs, to send it out of
    20 state are just too high.
    21
    Q. Okay.
    22
    MS. HARVEY: I want to show you what
    23
    I'm going to ask to be marked as Exhibit 8,
    24
    which is an ASTM standard for -- it's
    L.A. REPORTING (312) 419-9292

    150
    1
    D 3462-00, and I'm going to ask this to be
    2
    marked as Exhibit 8. Is that right?
    3
    (Document marked as Exhibit No. 8
    4
    for identification, 12/22/04.)
    5
    HEARING OFFICER ANTONIOLLI: Yes. We
    6
    are at Exhibit 8 at this point. And if there
    7
    are no objections, I'll enter this, what I
    8
    have in front of me, entitled Standard
    9
    Specification For Asphalt Shingles Made From
    10
    Glass Felt and Surfaced With Mineral Granules
    11
    as Exhibit 8.
    12
    And seeing no objections, this is
    13
    Exhibit 8.
    14
    (Whereupon, Exhibit No. 8 was
    15
    received in evidence by the
    16
    Hearing Officer.)
    17
    MS. HARVEY: Thank you, Madam Hearing
    18
    Officer.
    19 BY MS. HARVEY:
    20
    Q. Mr. Foulkes, are you familiar with
    21 this standard?
    22
    A. I am familiar with this standard.
    23
    Q. What is this standard for?
    24
    A. This is a standard put out by the
    L.A. REPORTING (312) 419-9292

    151
    1 National Standards Institute for minimum quality
    2 standards for asphalt shingles so that the
    3 architects or the users can specify minimum quality
    4 standards for the shingles that they specify on
    5 their jobs.
    6
    Q. Does IKO manufacture their shingles to
    7 be consistent with these standards?
    8
    A. One hundred percent of our shingles
    9 are included in this standard.
    10
    Q. And just so I'm clear, this
    11 specification talks about design and strength of
    12 your shingles, not about the use of GBSM?
    13
    A. That is correct. This is for finished
    14 shingles.
    15
    MS. HARVEY: Madam Hearing Officer,
    16
    just to make it clear, I think there have
    17
    been some concerns both by the Agency and by
    18
    the Board about what specifications are in
    19
    place. This is for -- it's submitting that
    20
    basically there are no standards for how you
    21
    put down Eclipse Dust Control, Falcon and
    22
    Jo'Lyn are leaders in the area, but this does
    23
    demonstrate that there are standards to which
    24
    the shingles and, therefore, the GBSM is
    L.A. REPORTING (312) 419-9292

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    1
    manufactured, that it's not a willy-nilly, if
    2
    you will, process.
    3
    HEARING OFFICER ANTONIOLLI: Thank
    4
    you.
    5 BY MS. HARVEY:
    6
    Q. Do you have other standards that you
    7 have to -- that IKO chooses to comply with? Are
    8 there state standards in other places about the
    9 durability, if you will, of asphalt shingles?
    10
    A. Well, one that comes to mind right now
    11 is the state of Florida has been hit very hard by
    12 weather-related incidents, and so over the last
    13 couple of years they have developed standards that
    14 you have to meet in order to sell shingles into the
    15 state of Florida. And even though Florida is not a
    16 typical market for us, we have met those standards
    17 and have received state certification to sell in the
    18 state of Florida if we so desire.
    19
    We use that as a marketing tool
    20 that when we go out, even if we're not selling in
    21 Florida, we meet state of Florida requirements and
    22 it's just another way of differentiating our product
    23 from our competitor's when we try to sell the
    24 concept of quality.
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    1
    Q. Thank you.
    2
    MS. HARVEY: I don't have anything
    3
    else on direct examination.
    4
    HEARING OFFICER ANTONIOLLI: Okay.
    5
    Mr. Kim, would you like to ask questions?
    6
    MR. KIM: Yes. I will speak as
    7
    quickly as I can without being unintelligible
    8
    to just try and move things along.
    9
    HEARING OFFICER ANTONIOLLI: But slow
    10
    enough so the court reporter can get it down.
    11
    MR. KIM: Yes, certainly.
    12
    CROSS EXAMINATION
    13 BY MR. KIM:
    14
    Q. Mr. Foulkes, as I told Ms. Powles, I'm
    15 going to sort of ask you questions in the order that
    16 you testified. So if anything seems -- if you need
    17 some background, just let me know.
    18
    You spoke about one of the
    19 emphases -- major emphasis for your company being on
    20 quality control?
    21
    A. Correct.
    22
    Q. And to try and achieve that, your
    23 company employs the concept of vertical integration
    24 to ensure you have as much control over what you're
    L.A. REPORTING (312) 419-9292

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    1 using and so forth; is that right?
    2
    A. That is correct.
    3
    Q. Do you know if that's a standard
    4 practice or a standard business model for other
    5 shingle manufacturers in your business?
    6
    A. No. In fact, we're bucking the trend
    7 from most of the industry.
    8
    Q. Okay.
    9
    A. But I do personally believe that
    10 that's why we, as a company, have been so successful
    11 where an awful lot of our competitors are no longer
    12 in business today.
    13
    Q. Okay. And along those lines, you said
    14 that, right now, aside from your company and your
    15 soon-to-be-up plant in Kankakee, Owens Corning is
    16 the only other manufacturer in Illinois that's
    17 making asphalt shingles; is that correct?
    18
    A. That's my understanding.
    19
    Q. In terms of output, do you know how
    20 your Bedford plant compares with the volume that
    21 Owens puts out?
    22
    A. I'm not sure.
    23
    Q. Okay. Do you know, to the best of
    24 your knowledge, if Owens employs a vertical
    L.A. REPORTING (312) 419-9292

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    1 integration concept in terms of their manufacturing
    2 process?
    3
    A. To a certain extent, but not to the
    4 same degree that we do.
    5
    Q. Sure. In terms of your process, are
    6 there certain aspects of IKO's manufacturing and so
    7 forth that are -- that you would consider to be
    8 trade secret and confidential in terms of, you know,
    9 processes or what have you that are unique to your
    10 company? And I'm specifically talking about the
    11 Bedford Park facility.
    12
    A. I'm just trying to think. Sure. I
    13 don't think that there is anything that we do in
    14 Bedford Park that is not standard in the industry.
    15
    Q. Okay. So it would be safe to say then
    16 that nothing happens at Bedford Park that wouldn't
    17 happen at, say, Owens Corning in terms of
    18 manufacturing?
    19
    A. As far as the manufacturing of the
    20 base sheet, now, the cutting and the forming of the
    21 individual shingles is unique to each manufacturer.
    22
    Q. And I'm not asking you to say exactly
    23 what Owens does, I'm just saying to the best of your
    24 knowledge -- and I guess that's kind of my point --
    L.A. REPORTING (312) 419-9292

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    1 there may be some differences in manufacturing from
    2 one company to the other; is that safe to say?
    3
    A. No.
    4
    Q. Okay.
    5
    A. As far as a manufacturer, the
    6 application of raw materials, I think, would be
    7 very, very similar.
    8
    Q. Okay.
    9
    A. The actual cutting and forming of the
    10 finished product would be different.
    11
    Q. Okay.
    12
    A. But that has no impact on GBSM.
    13
    Q. Right. Okay. That helps. And I
    14 think you answered this question, but just so I'm
    15 clear. From the time that you received the -- that
    16 your company received the letters from the Illinois
    17 EPA in 1993, up until the period of time that Falcon
    18 and Jo'Lyn were accepting the GBSM, was it your
    19 testimony that most of that GBSM didn't have a
    20 market, so aside from the small manufacturer, you
    21 were primarily landfilling that?
    22
    A. During the whole period?
    23
    Q. No. I'm just specifically looking
    24 from say -- and I don't know exactly when it was
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    1 that Falcon began accepting it, but let's just --
    2 I'm going to say 2002, okay?
    3
    MS. HARVEY: The first test
    4
    application, just for the record, was 2000.
    5 BY MR. KIM:
    6
    Q. Okay. Say from roughly 1993 to
    7 roughly 2000, do you know -- after EPA sent the
    8 letters and before Falcon started accepting your
    9 GBSM, do you know what your Bedford Park facility
    10 was doing with the GBSM?
    11
    A. The majority of it went to the
    12 landfill.
    13
    Q. Okay.
    14
    A. We did try to start recycling
    15 operations with several other people in the Chicago
    16 area --
    17
    Q. Okay.
    18
    A. -- but they did not pan out.
    19
    Q. Sure. And since the period of time
    20 that Falcon has not been able to accept that
    21 material to the present, is the GBSM still being
    22 taken except for the company that's making the
    23 Protective Board? Is that GBSM still being taken to
    24 a landfill?
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    1
    A. After we stopped using Falcon, we
    2 started using a company in Indiana.
    3
    Q. Okay.
    4
    A. And we worked with them for quite a
    5 while until freight just got too expensive. One of
    6 the problems -- I'm not from Chicago -- but traffic
    7 in Chicago is terrible and it means that the trucks
    8 spend and extremely large amount of time just
    9 sitting in traffic.
    10
    Q. Sure.
    11
    A. You're paying for the use of that
    12 truck, you're paying for the driver, so from a
    13 financial standpoint, it did not make sense to truck
    14 it out of state.
    15
    Q. Okay. So once that business decision
    16 was made, did you then revert back to landfill?
    17
    A. To the landfill, yes.
    18
    Q. Okay.
    19
    A. We have a contract with our current
    20 waste disposal firm that they handle anything that
    21 goes to the landfill. We, however -- anything we
    22 wish to recycle, we can immediately pull it out of
    23 that stream.
    24
    Q. Okay. Do you know roughly right now
    L.A. REPORTING (312) 419-9292

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    1 how much GBSM your Bedford Park facility is
    2 producing?
    3
    A. Including the material that's going to
    4 the landfill?
    5
    Q. Yeah.
    6
    A. Probably 10,000 to 12,000 tons this
    7 year.
    8
    Q. Okay. Is it a consistent production
    9 or is it -- because, again, I would imagine from
    10 an application standpoint, summer months are going
    11 to use more shingles than winter months -- is it a
    12 consistent production line or does it vary from the
    13 time of the year?
    14
    A. It is somewhat seasonal in nature, but
    15 we try very hard to keep our employees gainfully
    16 employed twelve months a year. So during the slower
    17 application periods, the wintertime, we build stock.
    18
    Q. Okay.
    19
    A. And keep the plant going, so we do
    20 continue to generate GBSM during that time frame.
    21
    Q. Okay. And you may or may not know
    22 this, but just for clarification. The information
    23 that was in Exhibit No. 6 -- and specifically I'm
    24 looking at -- there was a February 22, 1993 cover
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    1 letter, and that, I think, referenced the attachment
    2 which was dated January 29th, 1993?
    3
    A. Correct.
    4
    Q. Did that packet of information lead to
    5 both the June 22nd, 1993 letter that's in that
    6 exhibit, as well as the May 1993 letter that was
    7 pulled out and is a separate exhibit now?
    8
    A. That is my recollection, yes.
    9
    Q. Okay. So I just want to make clear,
    10 there's not a separate set of documents that led to
    11 the use of the --
    12
    A. No. We made one submittal for both.
    13
    Q. Okay. Then the last question that I
    14 have for you -- the second to the last question that
    15 I have for you is in terms of plant locations. Do
    16 you know off the top of your head if there are other
    17 asphalt shingle manufacturers located in Wisconsin
    18 near the Illinois border and Indiana near the metro
    19 Chicago area, in those locations?
    20
    A. Well, there's one just across the
    21 Indiana border which sells a lot of material, a big
    22 competitor of ours. There's also one on the
    23 southern Illinois/Indiana border. I'm not aware of
    24 any on the Wisconsin border.
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    1
    Q. Do you know what the company in
    2 Indiana -- not in southern, but near Chicago -- do
    3 you know what they do with their GBSM?
    4
    A. They send it to the same Indiana
    5 recycler that we were trying to use.
    6
    Q. Okay. The last question that I have
    7 for you was as far as the ASTM standard, your
    8 shingles all meet or exceed the ASTM standard that's
    9 in Exhibit A; is that right?
    10
    A. That's correct.
    11
    Q. Okay. And I don't even know how to
    12 phrase this question, but would it be -- I
    13 understand that what's going to be considered the
    14 GBSM, which would be the tabs and the sheets, that
    15 those aren't really shingles, those are the -- those
    16 are what used to be part of what's the finished
    17 product of the shingle. But I guess what I'm asking
    18 is, can you tie any correlation between this ASTM
    19 standard and the tabs and the sheets? I mean, would
    20 those meet that ASTM standard if that's -- I mean,
    21 can you say that or -- I understand the shingles do,
    22 but I guess what I'm wondering is what's the
    23 relationship to this ASTM standard and the GBSM?
    24
    A. The products that make up GBSM in most
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    1 cases are -- well, let me go back and give you the
    2 sources. When we make three-tab shingles, these are
    3 the shingles that have three equal sized tabs with
    4 little notches cut out in between.
    5
    Q. Okay.
    6
    A. The notches are the tabs that we
    7 talked about earlier that are part of the
    8 wastestream or the byproducts, whatever you -- GBSM
    9 stream.
    10
    Q. I understand, yes.
    11
    A. There are actual shingles that go into
    12 this stream also, because when you have -- when you
    13 are making slices on the fiberglass or the paper
    14 carrier, the medium that carries the asphalt, we do
    15 not sell the splices. Some of our competitors do,
    16 don't.
    17
    Q. Okay.
    18
    A. So that if a shingle includes a
    19 splice, then that goes into the GBSM stream.
    20
    Q. Okay.
    21
    A. Would that meet ASTM standards?
    22 Probably not, because part of that standard includes
    23 what's called tear resistance, it's an actual
    24 strength factor for the shingle.
    L.A. REPORTING (312) 419-9292

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    1
    Q. Okay.
    2
    A. We don't believe that splices will,
    3 long term, provide that tear strength.
    4
    Q. Okay.
    5
    A. So from that standpoint, no. There
    6 are times when there might not be enough granules on
    7 the sheet. Now, you can't sell that sheet because
    8 it's just going to look like a big, black mess up on
    9 the roof. Will that meet the strength standards?
    10 Probably not, because the granules do provide some
    11 strength to the sheet. But is it consistent as far
    12 as the raw materials are concerned? Yes. It's the
    13 same asphalt, it's the same granule source, might
    14 just be in a slightly different ratio.
    15
    Q. And using that as an example, that
    16 would be the type of thing that typically -- or that
    17 not typically -- but potentially could end up as
    18 part of the GBSM stream; is that correct?
    19
    A. Yes.
    20
    MR. KIM: I have no further questions.
    21
    HEARING OFFICER ANTONIOLLI: Okay.
    22
    Thank you. Does anyone else have questions
    23
    for this witness?
    24
    MS. MARSH: I do. I guess maybe I'm a
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    1
    little confused because I'm thinking that the
    2
    product -- we're talking about the tabs as
    3
    well as the surplus of the shingles or
    4
    whatever. Is that safe to use on our roofs
    5
    and our buildings? This is what are
    6
    considered as being -- it's certified, we can
    7
    use this, correct? But this is just surplus
    8
    and we just have nothing do with it? I mean,
    9
    it doesn't change molecularly, correct?
    10
    THE WITNESS: GBSM is molecularly
    11
    exactly the same as the roofs that you have
    12
    on your home.
    13
    MS. MARSH: So that's exposed to
    14
    elements and it doesn't harm our environment
    15
    according to the Illinois Protection Agency;
    16
    correct?
    17
    THE WITNESS: That's correct. In
    18
    fact, my understanding is that the EPA has
    19
    given approval to groups to use as a
    20
    collection system for assistance. Many of us
    21
    who grew up in rural areas drank water that
    22
    came off that roof that was made of an
    23
    asphalt shingle. So...
    24
    MS. MARSH: So why is this so much
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    1
    different then? Why is there a conflict with
    2
    this being used? If it's safe to use in
    3
    whole pieces, why is it not safe to use
    4
    ground?
    5
    THE WITNESS: You'll have to address
    6
    that question to somebody else.
    7
    MS. MARSH: I'm just confused.
    8
    HEARING OFFICER ANTONIOLLI: Thank
    9
    you.
    10
    MR. RAO: I have a little
    11
    clarification question.
    12
    In the amended petition on Page
    13
    10, it was stated that IKO Chicago generates
    14
    approximately 8300 tons of GBSM per year. So
    15
    was that figure based on some earlier data or
    16
    you mentioned you --
    17
    MS. HARVEY: I don't think Mr. Foulkes
    18
    has had the benefit of reviewing the amended
    19
    petition, so let me find that for him.
    20
    MR. RAO: Okay.
    21
    MR. KIM: What page, I'm sorry, were
    22
    you referring to?
    23
    MR. RAO: Page 10 of his answer.
    24
    MR. KIM: Thank you.
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    166
    1
    THE WITNESS: When was this
    2
    application put into place?
    3
    MS. HARVEY: I filed it -- this is in
    4
    2000 -- or I'm sorry, 2004.
    5
    THE WITNESS: Okay. It was based on
    6
    2003 data.
    7
    MS. HARVEY: It would have been based
    8
    upon data from 2003. Okay.
    9
    THE WITNESS: That probably was a good
    10
    number from 2003. What has happened is
    11
    though at the end of 2003, we installed
    12
    what's called a laminator, and I talked about
    13
    the different sizes of shingles. What we do
    14
    with the laminator is we laminate two pieces
    15
    of the sheet together to make a solid
    16
    shingle. You've probably seen them on
    17
    upscale homes. It duplicates the appearance
    18
    of a wood shake, but has all the advantages
    19
    of an asphalt shingle.
    20
    Manufacturing that changes your
    21
    byproduct volume significantly. It reduces
    22
    it on the one hand because you have no little
    23
    notches that you cut out. But because you're
    24
    taking two pieces and putting them together,
    L.A. REPORTING (312) 419-9292

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    1
    the actual total byproduct, GBSM, production
    2
    probably increases two- or three-fold. And
    3
    the Bedford Park plant came out producing
    4
    both laminated shingles and three tab
    5
    shingles. Up until the time you cut it,
    6
    there's no difference, it's the same thing,
    7
    it's just how you cut and form that sheet so
    8
    that the -- I think we will see this year in
    9
    2004 somewhere between 10,000 and 12,000, I
    10
    still think that's a good number.
    11
    MR. RAO: So this laminated shingle,
    12
    is that also called architectural?
    13
    THE WITNESS: It's an architectural
    14
    shingle or a dimensional shingle also.
    15
    MR. RAO: All right. As a follow-up,
    16
    you mentioned that your Kankakee plant may go
    17
    online sometime this summer?
    18
    THE WITNESS: Yes.
    19
    MR. RAO: What is the capacity of that
    20
    plant and what kind of tonnage do you think
    21
    that plant will produce of GBSM material?
    22
    THE WITNESS: When that plant is at
    23
    full production, which I don't anticipate for
    24
    over five years or more, they could be
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    1
    producing in the range of 20,000 tons a year
    2
    of GBSM.
    3
    MR. RAO: Okay. Thank you.
    4
    THE WITNESS: That's why, again, we
    5
    hope to be able to do something like this
    6
    because the idea of putting 20,000 tons into
    7
    the landfill just goes against our corporate
    8
    grain.
    9
    MR. RAO: Okay. Thanks.
    10
    MS. LIU: Mr. Foulkes, I have some
    11
    questions regarding the analytical results
    12
    from your testing of the GBSM.
    13
    THE WITNESS: Okay.
    14
    MS. LIU: They appear in Group
    15
    Exhibit 6 under the January 29th, 1993
    16
    portion.
    17
    THE WITNESS: Yes.
    18
    MS. LIU: And they begin on Page 22.
    19
    The analytical results lists the several
    20
    parameters and results as well as the
    21
    regulatory criteria that they're compared to.
    22
    Is that regulatory criteria referring to the
    23
    hazardous waste characteristics?
    24
    THE WITNESS: These -- again, I wasn't
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    1
    directly involved in the discussions with the
    2
    EPA, these were done at the EPA's request.
    3
    I'm assuming that it's -- that's where they
    4
    came from.
    5
    MS. LIU: Okay. Do you know if there
    6
    has been any comparison of these results to
    7
    the Illinois remediation objective under our
    8
    tiered approach to clean up?
    9
    THE WITNESS: I'm not familiar with
    10
    that regulation.
    11
    MS. HARVEY: I can tell you that some
    12
    of that will be addressed in our post-hearing
    13
    brief.
    14
    MS. LIU: I also noticed during the
    15
    public commenting one of the ladies mentioned
    16
    that she doesn't mind the smell at all from
    17
    the Eclipse Dust Control application and I
    18
    was wondering is there a detectable smell?
    19
    Are there detectable volatiles from the
    20
    product?
    21
    THE WITNESS: The only thing that I
    22
    could think that she was referring to was
    23
    actually during the application process when
    24
    this product is first being dumped, it's
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    1
    being aerated and it's going to have a slight
    2
    asphalt odor to it in the same way when you
    3
    would seal your driveway. You're going to
    4
    have some asphalt-type odors that very
    5
    quickly dissipate and then they're gone. So
    6
    I wouldn't anticipate any reason for there
    7
    being odors here, any different than there
    8
    are odors off your roof at home, as an
    9
    example.
    10
    MS. LIU: You don't happen to have any
    11
    analytical results of the volatiles, do you?
    12
    THE WITNESS: No. There's never been
    13
    any reason for that. In fact, during the
    14
    manufacturing of the products, in the plant
    15
    itself, the only thing that the EPA is
    16
    concerned about is particulate matter. They
    17
    are not concerned about VOCs, volatile
    18
    organic compounds.
    19
    MS. LIU: So the odor dissipates
    20
    rather quickly?
    21
    THE WITNESS: If there even is any. I
    22
    mean, when you put down shingles, there might
    23
    be a very slight odor when you first open the
    24
    package. But, I mean, when you drive down
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    1
    your street when you go home tonight, you're
    2
    not going to smell the asphalt shingles. It
    3
    would be the same way here.
    4
    MS. LIU: Okay. Thank you, very much.
    5
    HEARING OFFICER ANTONIOLLI: Okay.
    6
    Are there any further questions or at this
    7
    point would anyone else wish to make a public
    8
    comment or testify if they so choose? Go
    9
    ahead.
    10
    MR. TURLEY: I'm William Turley, I'm
    11
    the executive director of Construction
    12
    Materials Recycling Association. We are a
    13
    national non-profit organization, promotes
    14
    recycling of materials, including concrete,
    15
    asphalt, wood, gypsum and asphalt shingles.
    16
    HEARING OFFICER ANTONIOLLI: Please
    17
    slow down, the court reporter is trying to
    18
    keep up with you.
    19
    MR. TURLEY: We're a national
    20
    non-profit organization. We've been working
    21
    with the U.S. EPA and various state EPAs
    22
    around the country to promote the recycling
    23
    of asphalt shingles and ARMA, and we were one
    24
    of the co-sponsors of that meeting and all
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    1
    that kind of stuff, and held a couple more
    2
    since then.
    3
    Just a few -- and we also put up,
    4
    with a grant from the U.S. EPA, Region 5 --
    5
    www.shinglerecycling.org -- everything and
    6
    anything you ever want to know about shingle
    7
    recycling is on there, okay? So we kind of
    8
    like to think we know a little bit about this
    9
    subject, okay?
    10
    A couple of things that come to
    11
    mind, you mentioned earlier a couple of
    12
    little things. First, that you wanted to
    13
    limit how thick they could put the material
    14
    on to the -- the ground -- on to the
    15
    pavement. Whether it be a limit between four
    16
    and six inches. They've done two test
    17
    pavements. They're not going to know until
    18
    they do a little more testing, do more of
    19
    these, what exactly is the limit that they
    20
    should put this material at.
    21
    HEARING OFFICER ANTONIOLLI: Please
    22
    slow down just a little.
    23
    MR. TURLEY: Okay.
    24
    HEARING OFFICER ANTONIOLLI: Thank
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    you.
    2
    MR. TURLEY: And it would be -- you
    3
    know, we've discovered that we would rather
    4
    not have the states regulate how thick you do
    5
    this stuff, you find out what works best and
    6
    most efficiently, so you use the material in
    7
    the most efficient manner.
    8
    This material, asphalt shingles,
    9
    are currently manufactured -- which there's
    10
    two types that's mentioned, tear-offs and
    11
    manufacturer's waste -- as manufacturer's
    12
    waste. Why are we -- they keep using the
    13
    word clean, it's what we use as an industry
    14
    term. It has no contaminants in it such as
    15
    what post-consumer shingles might have.
    16
    So basically, the materials that
    17
    are in these shingles are the same as asphalt
    18
    pavement. Any regulations along those lines
    19
    should be -- you know, is saying what's used
    20
    in asphalt pavement, especially with the
    21
    application that Falcon wants to do.
    22
    One of the things I asked about
    23
    the recycling rate is, at 100 percent,
    24
    they're matching concrete and asphalt
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    1
    recyclers. Concrete and asphalt recyclers
    2
    don't have to go through a hearing like this.
    3
    It's a the same thing, okay? And they're the
    4
    same materials.
    5
    One of the things with the product
    6
    was rejected loads. Is it a standard
    7
    industry practice what the -- the guy brings
    8
    his roll-off into the yard, dumps it and
    9
    there's a bunch of junk in there. You make
    10
    him -- you scoop it back up, you put it in
    11
    there and you get him to take it to the
    12
    landfill and he learns real quick that's a
    13
    more expensive way to do it and he keeps his
    14
    load clean. And so, you know, as far as, you
    15
    know, this standard of what goes on, they're
    16
    going to be very careful about it -- the
    17
    customer will as far as putting it in there.
    18
    And finally, as the national
    19
    organization who promotes this thing, I get
    20
    to deal with 49 other state EPAs. I have to
    21
    say that I've never seen anything like this
    22
    done in any other state for manufacturers'
    23
    waste. This is the first time and everyone's
    24
    got to run to congratulate the Illinois EPA
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    1
    for being a leader here.
    2
    As far as questioning this
    3
    material, because it is a very -- we just
    4
    heard testimony -- a very safe material that
    5
    is on everyone's house in our neighborhood,
    6
    it is also very economically feasible to
    7
    recycle and it also makes tremendous
    8
    environmental sense I know the Illinois EPA
    9
    agrees with, but continues to throw up
    10
    barriers to these kind of people.
    11
    We suggest that and we hope the
    12
    Pollution Control Board will help the
    13
    Illinois EPA move into the 21st century and
    14
    join the rest of the country, which has a
    15
    tremendous amount of asphalt shingle
    16
    recycling, especially manufacturer's waste
    17
    going on. Thank you, very much.
    18
    HEARING OFFICER ANTONIOLLI: Thank
    19
    you, Mr. Turley. Any other comments? Please
    20
    introduce yourself.
    21
    MR. MITCHELL: Mike Mitchell.
    22
    MS. HARVEY: Yeah. I think that he
    23
    wanted to decide whether he wanted to testify
    24
    or actually do a public comment.
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    1
    HEARING OFFICER ANTONIOLLI: Okay.
    2
    And what do you prefer?
    3
    MS. HARVEY: We talked a little bit
    4
    about the fact that if he testifies, he needs
    5
    to be sworn and subject to cross-examination,
    6
    but that because of that --
    7
    HEARING OFFICER ANTONIOLLI: Your
    8
    testimony would also be given more weight
    9
    than a public comment because you would be
    10
    subject to that cross-questioning on your --
    11
    MR. MITCHELL: Well, yeah, my
    12
    expertise is not as thorough in some ways as
    13
    Bill's, but I have a feel for the recycling
    14
    industry. So I'm willing to testify, sure.
    15
    HEARING OFFICER ANTONIOLLI: Sure.
    16
    Why don't we have you sworn in then?
    17
    (Witness sworn.)
    18
    HEARING OFFICER ANTONIOLLI: And why
    19
    don't you introduce yourself and mention who
    20
    you represent.
    21
    MR. MITCHELL: Sure. My name is Mike
    22
    Mitchell, I'm the executive director of the
    23
    Illinois Recycling Association. And Illinois
    24
    Recycling Association is a non-profit
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    1
    organization. Basically, we were founded in
    2
    1980. In 2005, it will be out 25th
    3
    anniversary, promoting recycling in the state
    4
    of Illinois. And we are a broad-based
    5
    professional association for recyclers. Our
    6
    membership includes some people who deal in
    7
    construction material recycling. The
    8
    majority of our members are involved in
    9
    curbside programs, you know, both the
    10
    processors on the curb-end, as well as the
    11
    county officials, municipal officials who,
    12
    you know, provide the service and get those
    13
    green bins to your curb, and then also
    14
    coordinate with the operator of the material
    15
    recovery facilities that -- so we are a very
    16
    broad-based promotion of recycling.
    17
    And we submitted back in -- I
    18
    submitted and half of the Illinois Recycling
    19
    Association back on July 26th -- it's
    20
    actually a matter of your public record as PC
    21
    Document Number 1, a letter of support for
    22
    Falcon Waste and Recycling in terms of their
    23
    petition for an adjusted standard. I just
    24
    want to underscore that and to say that our
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    1
    support is -- our support of that process is
    2
    very strong and we believe this is, indeed,
    3
    recycling, not waste handling. And that, in
    4
    fact, I know that in the statement of the
    5
    case, it mentions that they're applying for
    6
    an adjusted standard or as an alternative,
    7
    finding inapplicability. I think,
    8
    technically, a finding of inapplicability is
    9
    more proper just in the sense that this is,
    10
    with all due respect, more obviously a
    11
    recycling operation as Bill mentioned. And
    12
    Mr. Kim mentioned that, you know, with EPA
    13
    standards, recycling is very high in the
    14
    waste-handling hierarchy. And in terms of
    15
    recycler's terminology, we always say we have
    16
    our own hierarchy, we speak -- very
    17
    similarly, we speak of reduce, re-use,
    18
    recycle. And I see this -- Kathy's --
    19
    Falcon's proposal or process, you know, as
    20
    exactly that, you're reducing IKO's
    21
    wastestream, and it's being re-used by Falcon
    22
    or Jo'Lyn Corporation and is being marketed
    23
    as a commodity. So it's not waste, it is, in
    24
    fact, very clearly a commodity.
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    1
    And in the letter that we wrote in
    2
    July cited the statutory -- the Illinois
    3
    statutory definition of recycling. This new
    4
    product made from recycled material is a
    5
    perfect example of the statutory definition
    6
    of recycling. Quote, any of -- any process
    7
    by which materials that would otherwise be
    8
    disposed of or discarded are collected,
    9
    separated or processed and returned to the
    10
    economic mainstream in the form of raw
    11
    materials or products.
    12
    So the questions that were going
    13
    on, what happens to the load if it is not
    14
    received -- if Falcon doesn't take it, it is
    15
    disposed of and landfilled. And you said,
    16
    unfortunately, that can be true of anything.
    17
    Being if an office building in the Loop
    18
    doesn't recycle, that paper is disposed of.
    19
    You know, if a resident in McHenry County
    20
    doesn't recycle, those cans and newspapers
    21
    are disposed of, yet the office paper,
    22
    newspaper and cans are unquestionably
    23
    recyclable commodities, but the absence of a
    24
    service provider and an end-market,
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    1
    everything is waste.
    2
    You know, which we think is
    3
    really, you know, the genius of Falcon's
    4
    proposal here, and we think it's very
    5
    important for the IEPA and the Illinois
    6
    Pollution Control Board to approve the
    7
    development of this type of creative and
    8
    innovative market development that increases
    9
    the recycling industry's ability to serve as
    10
    a significant economic driver in Illinois.
    11
    Innovative processes such as
    12
    Falcon's should be embraced and applauded for
    13
    finding ways to keep otherwise hard to
    14
    recycle material out of landfills and into
    15
    the productive economy in an environmentally
    16
    friendly way.
    17
    So we are very much in favor of
    18
    these processes being encouraged in Illinois.
    19
    We think it's very important that a case like
    20
    this be determined in their favor to just
    21
    reduce the obstacles and promote creative
    22
    recycling in construction materials. And
    23
    nothing was mentioned about the fact that the
    24
    market itself has a major role to play. In
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    1
    other words, AKO (sic) is facing -- either
    2
    Falcon Waste and Recycling will pay them $5 a
    3
    ton for the commodity, or in absence of a
    4
    service provider, in an absence of a market,
    5
    they get stuck paying perhas up to $40 a ton
    6
    at the landfill. So from the business'
    7
    interest, what would you rather do? Would
    8
    you rather get $5 for a commodity or be put
    9
    in the unfortunate situation of throwing
    10
    something, otherwise that could be useful,
    11
    away in absence of a service provider and in
    12
    absence of a market, paying up to $40 a ton
    13
    to dispose of it.
    14
    So that's where we feel very
    15
    strongly that this is a recycling process
    16
    because there is a clearly defined market for
    17
    the material. And I mentioned the example of
    18
    bottles, cans and papers that become waste,
    19
    if they are not recycled, but they're clearly
    20
    recognized as recyclable materials. Also
    21
    there's a -- for example, we have a lot of
    22
    members in the plastic lumber industry,
    23
    people that make decking and fencing and
    24
    stuff like that, and patio furniture out of
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    1
    post-manufacturer pre-consumer scrap plastic.
    2
    None of our members -- I checked with a
    3
    couple of our members even today -- none of
    4
    our members in those industries are required
    5
    to have waste handling permits, even though
    6
    they handle pre-consumer post-manufacturer's
    7
    scrap from an industrial facility. That
    8
    industrial facility would otherwise dispose
    9
    or discard of the material, but fortunately
    10
    there is, you know, a service provider and an
    11
    end-market for the material, so it is not
    12
    waste, it is a recyclable commodity, and
    13
    those industries are not -- none of those
    14
    businesses have a waste-siting permits or
    15
    anything like that, it's clearly understood
    16
    that's a recycled commodity and that's --
    17
    outside of reading the chicken scratch that
    18
    passes for my notes, that might be it.
    19
    HEARING OFFICER ANTONIOLLI: Okay.
    20
    Well, thank you. Let's take a break right
    21
    now and you can go ahead and change your
    22
    paper. We're off the record.
    23
    24
    L.A. REPORTING (312) 419-9292

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    1
    (Whereupon, after a short
    2
    break was had, the following
    3
    proceedings were held
    4
    accordingly.)
    5
    HEARING OFFICER ANTONIOLLI: We're
    6
    back on the record and it's about 1:00
    7
    o'clock in the afternoon. We last ended
    8
    before the break with Mr. Mitchell providing
    9
    some testimony and at this point, does anyone
    10
    have questions for Mr. Mitchell or would
    11
    anyone else like to make a comment?
    12
    And seeing no hands, then I will
    13
    thank you all for your attendance here today
    14
    and your interests in this petition.
    15
    The Board will try to address all
    16
    of your questions, especially, for example,
    17
    the question Ms. Marsh had, in its final
    18
    opinion and order when it makes a
    19
    determination.
    20
    And we also discussed some dates
    21
    for post-hearing briefs off the record. So
    22
    on the record, I'd like to say that the
    23
    petitioners have until January 14th to file a
    24
    post-hearing brief and then the Agency has
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    1
    until January 28th to file a response and
    2
    then any reply will be due by February 7th.
    3
    And, again, thank you all for
    4
    attending. I'd like to note also that based
    5
    on my legal experience and judgment and
    6
    observation, I find there are no credibility
    7
    issues with the witnesses that testified here
    8
    today and thank you both for your testimony.
    9
    And would the technical unit like
    10
    to add anything before we conclude?
    11
    MR. RAO: Yes, to thank all the
    12
    participants for being patient with us on
    13
    this proceeding.
    14
    HEARING OFFICER ANTONIOLLI: And we
    15
    thank McHenry College for their hospitality
    16
    and if there's nothing else, thank you, very
    17
    much, everyone, and have a safe trip home.
    18
    Happy holidays.
    19
    (Which were all the proceedings
    20
    had in the above-entitled cause
    21
    on this date.)
    22
    23
    24
    L.A. REPORTING (312) 419-9292

    185
    1 STATE OF ILLINOIS )
    2
    ) SS.
    3 COUNTY OF WILL )
    4
    5
    6
    I, Tamara Manganiello, RPR, do hereby state
    7 that I am a court reporter doing business in the
    8 city of Chicago, County of Cook, and state of
    9 Illinois; that I reported by means of machine
    10 shorthand the proceedings held in the foregoing
    11 cause, and that the foregoing is a true and correct
    12 transcript of my shorthand notes so taken as
    13 aforesaid.
    14
    15
    ______________________________
    TAMARA MANGANIELLO, RPR
    16
    License No. 084-004560
    17
    18
    19
    20
    SUBSCRIBED AND SWORN TO
    21 before me this ____ day
    of _______, A.D., 2005.
    22
    23
    _______________________
    24 Notary Public
    L.A. REPORTING (312) 419-9292

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