R E
c,
~
CLERK’S OFF~CE
BEFORE THE
ILLINOIS POLLUTION
CONTROL BOARD
APR
1~~ 2005
STATE OF
~LUNO~S
Pollut~Ofl
Contro’ Board
IN THE MATTER OF:
)
)
PLASTIC INJECTION MOLDING
)
R 05-
OPERATIONS
)
NOTICE
OF FILING
TO:
Ms. Dorothy M. Gunn
Division of Legal Counsel
Clerk ofthe Board
Illinois Environmental Protection
Agency
Illinois Pollution
Control Board
1021 North Grand Avenue East
100 West Randolph Street
Post Office Box
19276
Suite 11-500
Springfield, Illinois 62794-9276
Chicago, Illinois 60601
(VIA
FIRST CLASS MAIL)
(VIA FIRST CLASS MAIL)
(PERSONS ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that on April
19, 2005, I filed with the Office of the Clerk of
the Illinois
Pollution Control Board an original and nine copies each of ENTRY OF
APPEARANCE OF PATRICIA F. SHARKEY, PROPOSAL OF AMENDMENT and
STATEMENT OF REASONS, copies of which are hereby served upon you.
Dated:
April
19, 2005
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
By:
____________________
\
One
fits Attorneys
Patricia F. Sharkey
Mayer, Brown, Rowe &
Maw LLP
190 South
LaSalle Street
Chicago, Illinois
60603-344 1
(312) 782-0600
THis
DOCUMENT HAS
BEEN PRINTED ON RECYCLED PAPER
CERTIFICATE OF SERVICE
I, Patricia F. Sharkey, an attorney, hereby certify that I have served the attached ENTRY
OF APPEARANCE OF PATRICIA F. SHARKEY, PROPOSAL OF AMENDMENT and
STATEMENT OF REASONS
upon:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(Hand Delivery)
Matthew Dunn, Chief
Division of Environmental Enforcement
Office of the Attorney General
188 West Randolph Street, 20t~~
Floor
Chicago, Illinois 60601
(U.S. Mail)
Donald Sutton
Manager, Permit Section
Division of Air Pollution
Bureau ofAir
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box
19276
Springfield, Illinois 62794-9276
(U.S.
Mail)
Charles E. Matoesian
Division ofLegal
Counsel
Illinois Environmental Protection
Agency
1021
North Grand Avenue East
Post Office Box
19276
Springfield, Illinois 62794-9276
(U.S. Mail)
Office ofLegal Services
Illinois Department ofNatural Resources
One Natural Resources Way
Springfield, Illinois
62702-1271
(U.S. Mail)
as indicated above, by delivery or by depositing said documents in the United States Mail,
postage prepaid, in Chicago, Illinois on April
19, 2005.
Patricia F. Sharkey
Mayer,
Brown, Rowe & Maw LLP
190 South LaSalle Street
Chicago, Illinois
60603-3441
(312) 782-0600
~atricia1F.’~1carkey
I
THIS DOCUMENT HAS BEEN PRINTED ON RECYCLED PAPER
REcE~vr~!D
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR
192005
)
)
)
R05-____
)
STATE OF ILUNOIS
Pollution Control Board
ENTRY
OF APPEARANCE OF PATRICIA F. SHARKEY
NOW COMES PATRICIA F. SHARKEY,
and hereby enters her appearance in this
matter on behalfof the Chemical Industry Council of Illinois.
Dated:
April
J~,
2005
Patricia F. Sharkey
Mayer,
Brown, Rowe & Maw LLP
190 South LaSalle Street
Chicago, nlinois 60603-344 1
(312) 782-0600
Respectfully submitted,
By
IN THE MATTER OF:
PLASTIC
INJECTION MOLDING
OPERATIONS
THIS DOCUMENT HAS BEEN PRINTED ON
RECYCLED PAPER
RE C E ~iV E
D
CLERK’S
OFFICE
APR
1
92005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE
OF
ILLINOIS
Pollution Control Board
IN THE MATTER OF:
)
)
PLASTIC INJECTION MOLDING
)
R 05-
OPERATIONS
)
PROPOSAL OF
AMENDMENT
The CHEMICAL NDUSTRY
COUNCIL OF ILLINOIS (“CICI”), pursuant to 35111. Admin.
Code 102.202,
moves the Board to accept forhearing CICI’s proposal for amendment of 35
Ill.
Admin. Code Part 201.146 attached hereto.
This regulatory proposal includes:
1) the proposed
amendatory language; 2) a Statement of Reasons; and 3) an
Appearance for the attorney
representing CICI.
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL
OF ILLINOIS
By:
~e~~Attomes
Dated:
April
19, 2005
Patricia F. Sharkey
Mayer,
Brown, Rowe & Maw LLP
190 South
LaSalle Street
Chicago, Illinois
60603-3441
(312) 782-0600
THIS DOCUMENT HAS BEEN PRINTED ON RECYCLED PAPER
P E C E ~V E D
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR
192005
IN THE MATTER OF:
)
STATE OF
ILUNOIS
Pollution Control Board
PLASTIC INJECTION MOLDING
)
R 05
-?
OPERATIONS
)
)
STATEMENT OF REASONS
The Chemical Industry Council of Illinois (“CICI”) hereby submits this Statement of
Reasons to the Illinois Pollution Control Board (“Board”) pursuant to Sections 27 and 28 of the
Environmental Protection Act (“Act”) (415 ILCS 5/27 and 28) and 35 Ill. Admin.
Code
§
102.202(b), in support ofthe proposed revision to 35 Ill. Admin.
Code
§
201.146 which
is
attached hereto in Exhibit A.
I.
STATEMENT OF FACTS
AND
PURPOSE AND EFFECT OF PROPOSAL
Subpart C of Part 201
ofthe Board’s Air Pollution Control Regulations
(35
Iii. Admin.
Code Part 201, Subpart C) contains the requirements for air construction and operatingpermits.
Pursuant to
Section 201.142 (35 Ill. Admin.
Code
201.142), a construction permit is required
when constructing or modifying an emission source. Pursuant to Section 201.
143
(35
Ill. Admin.
Code 201.143), an operating permit is required for the operation of any emission source for
which
a construction permit is required under Section 201.142.
Under these rules,
construction
and operating permits are required for any new emission units,
physical changes and changes in
the method of operations which increase emissions unless such new emission units or changes
are covered by a permit exemption
listed in
35 Ill. Admin. Code 201.146.
Section 201.146 contains a list of permit exemptions based on categories of emission
units and
activities.
These exemptions
are referred to herein as “categorical exemptions.”
This
THIS DOCUMENT
IS SUBMITFED ON RECYCLED PAPER
rulemaking proposal would amend the current list of 59 categorical exemptions in Section
201.146 by adding the following additional category:
“hhh)
Plastic
injection, compression, and transfer molding
equipment,
and associated plastic resin handling, storage,
granulating, and drying equipment.”
This proposed categorical exemption will be referred to herein as the “plastic injection
molding” exemption.
The contaminant of concern generated by “plastic injection molding”
operations is volatile organic material (“VOM”).
While large plastic injection molding machines
may have the potential to emit as much
as 0.1
tons per year, a typical plastic injection molding
machine has potential emissions on the order of0.02 tons
per year under worst case assumptions.
These emissions
are of a level that
is the same or lower than the emissions generated by other
categories of emission units that are currently exempt from state permitting under
Section 201.146.
Emissions
from the associated activities covered under this proposed
exemption are negligible.
The sole purpose of this amendment is to relieve the Illinois EPA and owners and
operators from the burden of state construction and operation permitting for these very low
emitting emission units and activities.
The existing language of Section 201.146, which will be
applicable to this exemption, provides:
.The permitting exemptions in this Section
do not relieve the
owner or operator of any source form the obligation to comply
with any
other applicable requirements, including the obligation to
obtain a permit pursuant to Sections 9.1(d) and
39.5 of the Act,
Sections
165,
173 and 502 ofthe Clean Air Act or any other
applicable permit or registration requirements.”
This proposed amendment will not result in an increase in any emissions because
Section 201.146 does not relieve owners
and operators from the duty to
comply with
all
-2-
THIS DOUJMENT
is SUBMrITED ON RECYCLED PAPER
otherwise applicable
requirements.
Although there are no specific emission limitations or
emission controls prescribed by regulation for plastic injection molding operations that require
specification in
a permit, plastic injection
molding operations, like
the other categories of
emission units
and activities that are exempt under Section
201.146, will remain
subject to
all
regulations of general applicability, such as the regulatory prohibition on the emission of more
than 8 lb./hour ofVOM to the environment which is contained in
35 Ill. Admin. Code 218.301.
Finally, to the extent that these emission units and activities are located at facilities that have
total emissions in excess of major source thresholds, the existing language in Section 201.146
makes it clear that the permitting requirements of Section
165,
173 and
502 ofthe Clean Air Act
will apply to these emission units and activities.
The low level of emissions generated by plastic injection molding operations would
qualify for the
de minimis emissions
exemption proposed by the Illinois Environmental
Regulatory Group and the Illinois EPA in the pending rulemaking docket R05-19.
However, that
exemption, as proposed, only applies to
permittedfacilities.
Thus, plastic injection molding
facilities that
do not otherwise require an Illinois EPA air pollution control permit would not be
eligible for that
de
minimis emissions
exemption.
A categorical exemption is also more appropriate for plastic injection molding operations
because this category covers operations which are acknowledged to have very low emissions.
The proposed categorical exemption will
allow owners and operators and Illinois EPA inspectors
to readily determine that plastic injection molding operations do not require permits without
having to perform
emission tests or calculations.
Because this proposed amendment is different
in
nature from the proposal in R05-19,
CICI requests that this docket not be combined with that
rulemaking docket.
-3-
THIS DOCUMENT
IS
SUBMITI’ED ON RECYCLED PAPER
II.
AFFECTED SOURCES AND GEOGRAPHIC REGIONS
CICI
is a statewide trade association representing the chemical
industry in Illinois.
CICI
represents
198 member companies with
over 54,000 employees employed in
745 manufacturing
facilities and 975 wholesale and distribution facilities throughout Illinois.
See Affidavit ofMark
Biel, Exhibit B hereto.
Chemical manufacturers
in Illinois produce a wide array of products,
including plastics, plastic resins and plastic products.
There are approximately 500 facilities
in Illinois that perform plastic injection molding.
Many of these are
small facilities with as few as 20 employees and less than $5 million in
annual
sales.
Although
plastic
injection
molding machines
may
be
used at larger facilities
that
also have
coating or other operations,
many
plastic injection
molding plants,
as a
whole, qualify as “true
minor”
emission sources
with
total
actual emissions
well below major source thresholds.
Many
plastic
injection
molding
facilities
do
not operate any other emission
units
which are subject to
Illinois
permit requirements,
and thus
are
not
otherwise required to obtain
air pollution
control
permits from
the Illinois EPA.
Facilities
operating
plastic injection molding equipment
are believed to be located
throughout
the
State of
illinois.
III.
TECHNICAL FEASIBILITY AND
ECONOMIC REASONABLENESS/IMPACT
The proposed revision to 35
III. Admin. Code
§
201.146 does not impose any new
requirements
and will not affect emissions to the environment.
In fact, many owners
and
operators believe
that
“plastic injection
molding” is covered under other existing categorical
exemptions.
Nonetheless
the
adoption
of
this
specific
language
will
resolve
any ambiguity.
By
clearly exempting
this
category
of very minor emission
sources, this proposed
revision
will
reduce unwarranted
permitting
costs to business and
the
State.
By
eliminating
-4-
THIS DOCUMENT IS SUBMrTTED ON RECYCLED PAPER
ambiguity regarding permitting requirements, this proposal will relieve owners and operators of
plastic injection molding processes from the risk ofenforcement actions based upon differences
in interpretation of existing categorical exemptions.
Finally, this exemption will allow
Illinois
EPA to
save its permitting and enforcement resources for more significant emission sources.
Because this exemption will not relieve affected
emission units from any applicable requirement
other than state construction and operating permitting, this rulemaking will not impact air quality
in Illinois.
Therefore, an
analysis of technical feasibility
and economic reasonableness is not
appropriate or required.
IV.
COMMUNICATION WITH INTERESTED PARTIES
CICI and its
member companies
have had several discussions
with Illinois EPA as to the
appropriateness of adding this categorical exemption to the list of existing categorical
exemptions in
35 Ill. Admin.
Code
§
201.146.
illinois EPA has agreed that this is a category of
emission sources for which a categorical exemption is appropriate and beneficial to the State.
CICI has discussed this proposal with
its
membership and has also discussed it with
representatives of the Society
ofthe Plastics Industry, Inc., all of whom support this exemption.
V.
SYNOPSIS
OF
TESTIMONY
CICI will present testimony in
support of this proposal, as may representatives of one or
more representatives of its member companies.
This testimony will focus on the plastic injection
molding business,
a description of plastic injection molding equipment and
operations, the nature
and volume of emissions associated
with these operations and the general air pollution
regulations which are applicable to these operations.
CICI will
also provide testimony on the
appropriateness and benefit
of adding this categorical exemption to Section
201.146.
Finally,
-5-
THIS DOCUMENT IS SUBMITFED ON RECYCLED PAPER
CICI will also provide information on similar exemptions which have been adopted by the Board
and by other states with approved State Implementation Plans.
VI.
MATERIALS INCORPORATED
No material is to be incorporated by reference within the subsections proposed for
addition to Section 201.146.
VII.
REQUEST
FOR WAIVER OF PETITION REQUIREMENT
CICI
is an Illinois “not-for-profit” organization with 198 member companies all of which
operate businesses in
Illinois.
A list of CICI’s member companies is attached hereto as
Exhibit C.
As stated
in the attached Affidavit of
Mark Biel, Executive Director, CICI’s member
companies
employ over
54,000
employees who work in
745
manufacturing facilities and
975
wholesale and distribution facilities in Illinois.
See
Exhibit B.
CICI’s
members
and their
employees are “persons” within the meaning of
35
Ill.
Admin. Code
101.202
and
102.202(t).
As further stated in the attached Affidavit of Mark
Biel,
CICI’s
member companies
support the attached proposal to amend the Board’s regulations and have requested that
CICI
submit this proposal on their
behalf.
See
Exhibit B.
Based on all of the above, CICI requests
that the Board waive the requirement that a petition containing the signatures of two hundred
persons accompany this proposal.
VIII.
CERTIFICATION
OF MOST RECENT REGULATION
The proposed categorical exemption would be a new subsection under 35 III. Admin.
Code
§
201.146.
CICI certifies, by its attorney’s signature below, that the portion of 35 III.
Admin. Code
§
201.146 cited in this proposal
is the most recent version of 35 Ill. Admin. Code
§
201.146,
as published on the
Illinois Pollution Control Board’s
Web
site.
-6-
THIS
DOCUMENT IS
SI
IBM 111’ED ON
RECYCLED PAPER
IX.
CONSISTENCY WITH FEDERAL LAW
The
proposed regulatory revision will
affect Illinois’ State Implementation Program
(“SIP”).
Therefore, if
the proposed regulatory amendment is approved, Illinois
EPA will
be
required to submit a
SIP
revision to
USEPA.
To meet the hearing requirements for SIP
revisions, a public hearing must be
held
in this rulemaking procedure.
See
40 C.F.R.
§~
5 1.102
and
51.104.
X.
CONCLUSION
CICI
is proposing this categorical exemption to reduce the permitting burden
on certain
very minor emission sources in the plastics industry, and relieve Illinois
EPA
of the burden of
permitting these very minor emission sources.
FOR THE
REASONS STATED ABOVE, CICI
hereby submits this regulatory
proposal and requests that the Board adopt this proposed addition to 35 Ill. Admin.
Code
§
201.146.
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL
OF ILLINOIS
By:______________
—
\
One~
of Its Attome~
Dated:
~h
V
/
Patricia F. Sharkey
Mayer, Brown, Rowe &
Maw LLP
190
South LaSalle Street
Chicago, Illinois
60603-3441
(312) 782-0600
-7-
THIS DOCUMENT IS SUBMI’ITED ON RECYCLED PAPER
Exhibit A
TITLE 35:
ENVIRONMENTAL PROTECTION
SUBTITLE
B:
AIR POLLUTION
CHAPTER I:
POLLUTION CONTROL BOARD
PART 201
PERMITS AND GENERAL PROVISIONS
Section
201.146
Exemptions from State Permit Requirements
Construction oroperating permits, pursuant to Sections 201.142, 201.143, and 201.144 of this
Part, are not required for the classes of equipment and activities listed below in this Section.
The
permitting exemptions in this Section do not relieve the owner or operator of any source from
any obligation
to comply with
any other applicable requirements, including the obligation to
obtain a permit pursuant to Sections
9.1(d)
and
39.5
of the
Act, Sections
165,
173,
and
502
of the
Clean AirAct or any other applicable permit or registration requirements.
hhh)
Plastic injection, compression, and
transfermolding equipment, and associated plastic
resin
handling, storage,
granulating, and drying equipment.
THIS
DOCUMENT IS SUBMI1TED ON RECYCLED PAPER
Exhibit
B
STATE OF ILLINOIS
)
)
SS
COUNTY OF COOK
)
AFFIDAVIT OF MARK BIEL
EXECUTIVE DIRECTOR
CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
I, Mark Bid, being first duly sworn, state as follows:
1.
I
am the
Executive Director of the Chemical
Industry Council of Illinois,
a not-
for-profit Illinois corporation.
2.
The Chemical Industry Council ofIllinois (“CICI”) is a statewide trade
association representing
the chemical industry in Illinois.
CICI has offices in Des Plaines and
Springfield,
Illinois.
CICI represents
198 member companies with over
54,
000 employees
employed in
745
manufacturing facilities and
975 wholesale and distribution facilities in Illinois.
Chemical manufacturers in Illinois produce a wide array of products from plastics, pesticides and
industrial chemicals to lifesaving medicines and household products.
Workers directly employed
in the
chemical industry represent
7.3
ofthe
state’s manufacturing work force and have an
average wage over $60,000 per year.
The chemical industry generates an additional 296,000
jobs in Illinois at industry suppliers, manufacturers, transporters, trade and business
services
companies, and construction companies.
2.
One of
CICI’s functions
is to represent its member companies in the formation of
public policies and programs which are mutually beneficial to the
citizens of Illinois
and
the
chemical industry.
In this capacity,
CICI
monitors statewide legislation and regulations in
Illinois, including environmental permitting programs, and provides information and makes
CHDBO1
1271599.1
18-Apr-05
14:58
Exhibit
B
recommendations to its membership.
CICI also
often advocates on behalfofits membership for
more cost effective and
efficient regulatory requirements.
3.
The attached proposed amendment to the Illinois Pollution Control Board’s
regulations governing state air pollution control permits for plastic injection molding operations,
R05-_,is
supported by CICI members and is proposed by dcl
on theirbehaif.
FURTHER AFFIANT SAYETH NOT.
L~______
ark Biel
Executive Director
Chemical Industry Council of Illinois
2250 East Devon, Suite 239
Des Plaines, IL
60018
(847) 544-5999
STATE OF ILLINOIS
)
)
SS.
COUNTY OF
COOK
)
Signed
and
sworn
to
by
‘l~otAK
T~
I
who appeared
before me andlor affirmed
his
signature to
me,
a Notary
Public,
in
and
for
the
County of Cook, State ofIllinois,
on this
/,~‘~—day
of April,
2005, in order to affix his
signature
as his free and voluntary act.
~
Notary Public
r~CI~r’~EAL’~1
~
Donna M. Draper
~
Notary
Public, 5tateof Illinois
My
Commission Exp.
03/25/2006
CHDBOI
1271599.1
18-Apr-05
14:58
MEMBERSHIP
EXHIBIT
C
CICI
REGULAR MEMBERS
3M Company
Abbott Laboratories
Afton Chemical
Air Liquide
Air Products & Chemicals
Inc.
Akzo Nobel Surface
Chemistry LLC
American Chemistry Council
Ashland Inc.
Aux Sable
L.P.
Inc.
BASF
Basic
Chemical
Solutions
BOC
Gases
BP
Brenntag Great Lakes, LLC
Cabot Corporation
Calgon
Carbon
Corporation
Carus
Chemical Company
The Cary Company
Caterpillar
CCL Custom
Manufacturing
Inc.
Celanese
CF Industries
Chemblend of America,
LLC
CHEMCENTRAL Corporation
Chem Trade Logistics
CITGO
Petroleum Corporation
Clorox
Cognis Corporation
Consumer Specialty Products
The Dow Chemical Company
Dow Agro Sciences
El. DuPont & Co. Inc.
Eastman Chemical Company
Ecolab
EMCO Chemical Distributors Inc.
Enthone-OMI
Inc.
Enviro Tech International
ExxonMobil Chemical Company
FBC
Industries Inc.
FMC Corporation
Flint Hills Resources
Forbo Adhesives,
LLC
Formosa Plastics Illinois
Fuji-Hunt
Photographic Chemicals
GE Betz
GE Plastics
The Gillette Company
Grace Davison
W.R. Grace Company
GROWMARK,
Inc.
C.P.
Hall Company
Hentzen Coatings,
Inc.
Honeywell
International,
Inc.
Huntsman Chemical Corp.
Hydrite Chemical
Company
Illinois Tool Works
Inc.
INEOS Silicas
Americas,
LLC.
Innophos,
Inc.
JLM Chemicals
Inc.
K.A.
Steel Chemicals,
Inc.
Koppers
Industries
Inc.
Lambent Technologies
LaRoche
Industries Inc.
Lonza Inc.
Lyondell Chemical Company
Matheson Tn-Gas
The Mcintyre Group, LTD
Assoc.
Corn
Products
International
Crompton
DSM Desotech
Daubert Industries, Inc.
Degussa Goldschmidt Chemicals
DIAL Corporation
Diversified CPC
International
CICI AFFILIATE MEMBERS
A & R
Distribution, Inc.
Advanced Waste Services,
Inc.
A.F.
Crissie Co.,
LTD.
Alliance 3PL Corp.
Arthur J. Gallagher Risk
Management Services,
Inc.
Bork Transport of Illinois
Carbis, Inc.
CBSL Transportation Services,
Inc.
Coal
City Cob Company,
Inc.
Exelon Generation
Exponent,lnc.
Gateway Warehouse Co.,
Inc.
Great Lakes Terminal Transportation
Heritage
Environmental Services
IMTT/Lemont
International Truck & Engine Corp.
Jevic Transportation
Monsanto Company
Nalco Company
National
Paint & Coatings Assoc.
Noveon,
Inc.
Occidental
Chemical Corp.
Olin Corporation
Orica
Nitrogen
PELRON Corporation
Pierce
Biotechnology
PolyOne Corporation
The P0 Corporation
PRAXAIR Inc.
Producers Chemical Company
PVS
Chemicals, Inc.
Reckitt
Benckiser
Regis Technologies, Inc.
Reichhold Chemicals
Inc.
Resolution
Specialty Materials
LLC
Rhodia Inc.
Rohm
and
Haas Company
Rowell Chemical Corporation
Royster-Clark Nitrogen
Safety-Kleen
Seeler industries
Solutia
Inc.
Solvay Fluoride
Stepan Company
Sun Chemical
Corporation
Syngenta
Crop Protection
Teepak,
LLC.
Unilever HPC USA
Union
Carbide
UCAR
Emulsion
Systems
Univar USA
UOP
VERTEX CHEMICAL CORP.
Vulcan Chemicals
Westfalia-Surge LLC.
Kinder Morgan
Liquid Terminals
Marsh Inc.
Onyx
Environmental
Services,
LLC
Patrick Engineering
Rain For Rent
SET Environmental,
Inc.
T.A.C.,
Inc.
Transport Service
Company
TriIIa Steel
Drum
Waste
Management
CICI
ASSOCIATE MEMBERS
ADEXS, Inc.
Admiral Environmental
Services,
Inc.
Ambitech
Engineering Corporation
AMS Environmental,
Inc.
AQUATERRA
Env. Solutions, Inc.
Arcadis
G & M Inc.
ARI
Environmental
Baker Environmental,
Inc.
Baker & McKenzie
Barnes & Thornburg
Bellande & Sargis
Law Group,LLP
Boelter & Yates,
Inc.
Bradburne, Briller & Johnson,
LLC
CDM
CH2M
Hill
Civil & Environmental
Consultants,
Inc.
Clayton Group Services
Conestoga-Rovers
& Associates
DLA
Piper Rudnick Gray Cary
DOMANI-LLC
Earth Tech
Inc.
Environ
International Corporation
Environmental Monitoring
& Tech.
ENSR Consulting
& Engineering
ERM,
Inc.
Equinox Research Associates,
Inc.
Franzetti Law Firm P.C.
Gardner Carton & Douglas
GEV Corp.
Hinshaw & Culbertson
Hodge
Dwyer
Zeman
Husch & Eppenberger, LLC
Industrial
Facilities Engineering
Jenner & Block
Kestrel Management Services
LLC
MACTEC Engineering
& Consultants,
Inc.
McDermott, Will
& Emery
McGuireWoods LLP
Mayer, Brown, Rowe
& Maw
O’Keefe Lyons & Hynes
R K
& Associates,
Inc.
Roux Associates,
Inc.
Schiff Hardin
LLP
SEECO
Environmental Services
Inc.
Seyfarth Shaw
Shaw E
&
I
Sidley Austin Brown & Wood
Sonnenschein
Nath & Rosenthal Inc.
Terracon
The
RETEC Group,
Inc.
Thompson Coburn
LLP
Total
Environmental
Solutions, P.C.
TRC
Environmental
Corporation
Trinity Consultants Inc.
URS Corporation
Versar,
Inc.
Weaver Boos
Consultants
Wildman,
Harrold, Allen &
Dixon
Winston
& Strawn
