ORIGINAL
IN THE MATTER OF :
ILLINOIS POLLUTION CONTROL BOARD
June 19, 2007
STATIONARY RECRIPROCATING
)
INTERNAL COMBUSTION ENGINES AND )
TURBINES : AMENDMENTS TO 35 ILL
. )
ADM . CODE SECTION 201 .146 AND )
PARTS 211 and 217
)
Page 1
JUN9;, 1
R07-18
STATE OF
(Rulemak!RV~inrr"j°
REPORT OF PROCEEDINGS held in the
above-entitled cause before Hearing Officer Timothy
Fox, called by the Illinois Pollution Control Board,
taken before Laura Bernar, CSR, a notary public
within and for the County of Cook and state of
Illinois, at the James R
. Thompson Center, 160 North
LaSalle Street, Chicago, Illinois, on the 19th day
of June, 2007, commencing at the hour of 10 :00 a .m .
Vac)
PFICE
2Cf?
ntrol
ILLINOISBoard
1
2
3
MS . RACHEL DOCTORS
Assistant Counsel
4
Division of Legal Counsel
Illinois Environmental Protection Agency
5
1021 North Grand Avenue East
P .O . Box 19276
6
Springfield, Illinois 62794-9276
7
MR . JOSHUA R . MORE
-AND-
8
MS . KATHLEEN C . BASSI
Schiff Hardin
9
6600 Sears Tower
Chicago, Illinois 60606
10
(312) 258-5567
On behalf of the Pipeline Consortium
11
12
13
14
15
16
17
18
19
20
21
22
23
24
A P P E A R A N C E S
:
Page 2
Page 3
1
HEARING OFFICER FOX : Good morning and
2
welcome to this Illinois Pollution Control
3
Board hearing . My name is Tim Fox, and I am
4
the hearing officer for this rulemaking
5
proceeding which is entitled Fast Track Rules
6
Under Nitrogen Oxide Or NOx SIP Call Phase II
7
Amendments to 35 Illinois Administrative Code
8
201
.146 and parts 211 and 217 . The Board
9
Docket Number for this rulemaking is RO 7-18 .
10
The Board received this proposal on April 6
11
of 2007 from the Illinois Environmental
12
Protection Agency and accepted this proposal
13
for hearing on April 19, 2007 .
14
Let me make some quick
15
introductions of the persons who are present
16
here from the board . To my left is board
17
member Thomas E . Johnson and to his left at
18
the end of the table is Anand Rao of the
19
board's technical staff . To my far right is
20
board member Nicholas Melas, and at my
21
immediate right is Marie Tipsord who is
22
assistant ttorney to the board's acting
23
chairman, Dr
. G . Tanner Girard .
24
Member Johnson, did you have
Page 4
1
any introductory remarks you wish to make?
2
MR
. JOHNSON : Briefly I was going to
3
welcome participants and the general public,
4
but it appears I only need to welcome
5
participants . I'm filling in for Andrea
6
today . If, indeed there is a third hearing,
7
I suspect she'll be back . So thank you for
8
your participation, and I look forward to
9
today's hearing .
10
HEARING OFFICER FOX
: As member
11
Johnson indicated, we are holding the second
12
hearing in this rulemaking . The third
13
hearing is now scheduled to take place on
14
Monday, July 2, 2007 at 1 :00 p .m . in
15
Springfield . This proceeding is governed by
16
the Board's procedural rules . All
17
information that is relevant and that is not
18
repetitious or privileged will be admitted
19
into the record . Please note that any
20
questions posed today by the Board or by its
21
staff are intended solely to assist in
22
developing a clear and complete record for
23
the Board's decision and do not reflect any
24
prejudgment of the proposal . Under Section
Page 5
1
28 .5G2 of the Environmental Protection Act,
2
this hearing, quote, shall be devoted to
3
presentation of testimony, documents, and
4
comments by affected entities and all other
5
interested parties, unquote . The Board
6
received prefiled testimony on June 8 from a
7
single participant in this proceeding, a
8
Mr . James McCarthy on behalf of the group of
9
natural gas transmission companies . Under
10
Section 28 .5G, that prefiled testimony is
11
admitted into the record without reading . So
12
we will begin this hearing with his prefiled
13
testimony and the questions that other
14
participants may have on the basis of that
15
prefiled testimony .
16
As a last note for the court
17
reporter who's, of course, transcribing our
18
proceeding, I would ask that you speak as
19
clearly as possible and avoid speaking at the
20
same time as another participant so that she
21
has as easy a task as possible in producing a
22
transcript of this hearing .
23
Are there questions at all
24
about the procedures before we begin? Very
Page 6
1
well . If we can begin, Mr . More, if you're
2
prepared, we can have the corporate reporter
swear in Mr . McCarthy . And if he wishes to
4
make a brief statement, he certainly would be
5
welcome do that, and we can proceed then with
6
any questions that other participants may
7
have .
8
MR . MORE : Josh More and Kathleen
9
Bassi from Schiff Hardin on behalf of ANR
10
Pipeline, Kinder Morgan, Incorporated,
11
Trunkline Gas Company, Panhandle Eastern
12
Company, Pipeline Consortium . We're here to
13
present testimony from Jim McCarthy .
14
(Witness sworn .)
15
HEARING OFFICER FOX : Mr . More, if I
16
may interrupt, I'm taking things out of
17
order
. Miss Bassi has handed me a copy of
18
the prefiled testimony of Mr
. McCarthy .
19
Should I construe that as a motion to admit
20
that into the record as Hearing Exhibit
21
No . 3?
22
MR . MORE : Please .
23
HEARING OFFICER FOX : Is there any
24
objection on anyone's part to the admission
Page 7
1
of that prefiled testimony as
Exhibit
No .
3?
2
Neither seeing nor hearing none, it will be
3
so admitted and marked as Exhibit No . 3 .
4
And, Mr . More, thank you for
5
letting me interrupt you .
6
MR . MORE : We are not going to offer
7
a summary of the testimony, so if you like,
8
we can proceed with the questions .
9
HEARING OFFICER FOX
: Very well . If
10
there is anyone present who wishes to pose
11
questions to Mr . McCarthy on the basis of his
12
testimony, if they'd simply raise their hand
13
to be recognized, and for the first time
14
please state your name and your affiliation .
15
Ms . Doctors?
16
MS . DOCTORS : Rachel Doctors from the
17
Illinois Environmental Protection Agency . I
18
do have one procedural question . I've got a
19
number of questions of documents that have
20
already been admitted into the record
. Do
21
you want me to --
I also have copies of them .
22
We can readmit them as exhibits, or I can
23
just refer to how they were in the Agency's
24
initial proposal .
Page 8
1
MS . BASSI : Are you planning to ask
2
questions of our witness based on your
3
documents?
4
MS . DOCTORS : It's documents he's
5
referred to in his testimony .
6
MS . BASSI : Okay .
7
MR . MORE : I would ask then, it might
8
expedite the process if you can just avail us
9
with a copy .
10
MS . DOCTORS : Well, I was going to
11
give copies . It's whether we wanted to mark
12
them separately as exhibits or whether we
13
just wanted to refer to them .
14
HEARING OFFICER FOX : For the sake of
15
completeness of the record, if you've got
16
copies, it probably would be best, if perhaps
17
a little redundant, to admit them as hearing
18
exhibits so that we're all precisely on the
19
same page .
20
MS . DOCTORS : Are we ready to begin?
21
HEARING OFFICER FOX : Did you have a
22
substantive question to pose?
23
MS . DOCTORS : Yeah, I've got
24
questions .
Page 9
1
HEARING OFFICER FOX : Please proceed,
2
Ms . Doctors .
3
MS . DOCTORS : Good morning,
4
Mr .
McCarthy .
5
A .
Good morning .
6
Q .
Are you familiar with Attachment 1 to
7 the Board's order of May 24, 2007, and appendix G to
8
the Agency's regulatory proposal?
9
A .
Just for clarification, Attachment 1
10 is the current version of the rule?
11
Q .
Yes, it is . And I have -- That's what
12
I'm saying . I have copies of your board order . I
13 just didn't know if you wanted me to pass them out
.
14
HEARING OFFICER FOX : I think that
15
would be helpful so that we're referring to
16
the same document at the same time .
17
THE WITNESS : Yes . I'm familiar with
18
the document .
19
BY MS . DOCTORS :
20
Q .
I would ask to
-- We also passed out a
21
copy of Appendix G, which I think the Board fully
22
intended to include as part of Attachment 1 but did
23
not . I don't know . But this is the list of
24 affected units under Attachment 1 . So I'd like to
Page 10
1
have these marked as Hearing Exhibit 4 and 5
2
respectively .
3
HEARING OFFICER FOX : Hearing the
4
motion to admit the hearing officer order
5
dated May 24 of 2007 as Exhibit --
Hearing
6
Exhibit No . 4 and to admit the copy of
7
Appendix G as Hearing Exhibit No . 5, is there
8
any objection to the admission of those on
9
the part of any of the participants?
10
Neither seeing nor hearing
11
none, they will be marked and admitted as
12
such, Ms . Doctors .
13
BY MS . DOCTORS :
14
Q .
Can you look at Section 217386 of
15
Attachment A . It's on Page 5 .
16
MS . BASSI : You mean Exhibit 4?
17
MS
. DOCTORS : Yes . It's on Exhibit 4,
18
but it's on Page 5 of Exhibit 4 .
19
BY MS . DOCTORS :
20
Q .
Would you read this section into the
21
record, please?
22
A .
Section 217386 applicability : A
23
stationary reciprocating internal combustion engine
24
listed in Appendix G of this part is subject to the
Page 11
1
requirements of this Subpart Q .
2
Q .
So the proposal before the Board today
3
only applies to the units listed in Appendix G ; is
4 that correct?
5
A .
Those are the applicable units under
6
the rule . And I use that language because of
7
provisions in the rule . It's possible that other
8 equipment would be brought under the rule through
9
emissions average .
10
Q .
Do you know what size engines are
11
included in Appendix G?
12
A .
I am familiar with 25 of the 28
13
engines that I have worked with the natural gas
14
industry on this rule and some of the earlier
15 versions of the rule . And 25 of the 28 engines are
16
operated by companies that I have worked with . So
17
I'm familiar with those 25 engines . They range in
18
size from, I believe the smallest engine is 2400
19 horsepower . The largest engine is --
It's over
20
10,000 horsepower . I think it's either 10 or 12,000
21
horsepower . But most of the engines are around 4 or
22 5,000 horsepower in size
.
23
Q .
Is there anything in Appendix G that
24
listed the threshold for regulatory applicability?
Page 12
1
A .
Not a
threshold, no . It just lists
2
the
affected engines .
4
Q .
So isn't it correct that the proposal
before the Board today in docket R07-18 only impacts
5
engines that emit one ton per day or more as
6
identified in the NOx SIP Call Phase II?
7
A .
Yes . It's one ton per day or more
8
based on the 1995 federal inventory .
9
Q .
I'm going to now ask you some
10 questions about low emission combustion, technology
11 LEC, L-E-C . Explain how LEC technology works .
12
A .
The pollutant we're concerned with is
13
nitrogen oxides, NOx . NOx from natural gas
14 combustion is formed from nitrogen that's in the
15 combustion air, and NOx formation is strongly
16
dependent upon the temperature of the combustion
17
process
. So what LEC does is, in simple terms, it
18 adds additional air to the engine . That additional
19 air lowers the combustion temperatures, and by
20
lowering combustion temperatures it lowers NOx
. So
21 that usually involves turbo charging the engine, or,
22
if the engine already has a turbo charger, it will
23
involve many times enhancing the turbo charger .
24
With the additional air, sometimes the fuel air
21
HEARING OFFICER FOX : For the record,
22
Ms . Doctors has circulated copies of the
23
Federal Register, Volume 69, No . 77 dated
24
Wednesday, April 21 of 2004, which I would
Page 13
1
charge will have difficulty lighting . So often
2
there's a requirement to change the ignition system,
3
so you put more energy into the system to light the
4
charge . And it also sometimes includes changing
5 fuel injectors so that you get better mixing in the
6 engine cylinder prior to lighting the charge . And
7 what those different facets all are intended to do
8 is lower peak combustion temperatures, thus lowering
9
NOx .
10
Q
.
Are you familiar with the phase NOx
11
SIP called Phase II Rule as it appeared in the
12 Federal Register on April 21, 2004?
13
A .
I am .
14
Q .
I would like to offer this as, I guess
15
we're at hearing Exhibit 6?
16
HEARING OFFICER FOX : That's correct .
17
That's the next exhibit number .
18
MS . DOCTORS : It was Attachment A to
19
the Agency's Statement of Reasons
.
I have
20
six copies .
Page 14
1
construe as a motion to admit that as hearing
2
Exhibit No . 6 . Is that correct,
3
Miss Doctors?
4
MS . DOCTORS : Yes .
5
HEARING OFFICER FOX : Is there any
6
objection to the admission of that document
7
as Hearing Exhibit No . 6?
8
Neither seeing nor hearing any
9
objection, it will be marked and admitted as
10
Hearing Exhibit No . 6 in this proceeding .
11
BY MS . DOCTORS :
12
Q .
I'd like to direct your attention to
13 Pages 21619 and 21620?
14
MS . TIPSORD : Nineteen and twenty?
15
MS . DOCTORS : Yes, the last two . I
16
think it's longer . It may repeat somewhere .
17
BY MS . DOCTORS :
18
Q .
Isn't it true that U .S . EPA states
19
that 3 grams per break horsepower, or horsepower
20
hours, how they say it, is achievable for most
21
reciprocating engines with LEC retrofits? It
22
appears in the center column on 619 about midway
23
through that column .
24
A .
I'm just looking for the specific text
Page 15
1 saying most engines . My experience is that many
2 engines can achieve three grams, but not all . So if
3
you want me to read this and find that exact text, I
4 can do that, but .
5
Q .
Yes
. Would you, please .
6
A .
You said it's in the center column on
7
21619?
9
Q .
I'm sorry .
Yes . It's under the heading Response
.
I'm referring you -- I'm sorry . I am
10 mistaken . It's on 620 . I'm being corrected here,
11
and it's in the first column .
12
A .
I see where they say that 60 of the 79
13 tests that they had showed three grams or lower .
14
Q .
Doesn't it also state that emission
15
levels of 2 .2 to 2 .3 grams per break horsepower were
16
found to be achievable?
17
A .
For the specific engines and data that
18
they looked at, they do show that 2 .2 and 2 .3 grams
19
have been achieved .
20
Q .
Then on Page 619, doesn't it state
21 that the Interstate Natural Gas Association of
22
America said that LEC retrofits are consistent with
23
the costs identified by U .S . EPA's NOx SIP Call TSD?
24
MR . MORE : Are you asking him just to
Page
16
1
confirm that
that's what it reads?
2
MS . DOCTORS : Yes .
3
MR . MORE : Are you in the middle
4
paragraph?
5
THE WITNESS : I'm just reading the
6
introductory
text leading to that bullet .
7
Yes . The record does state that INGA
8
indicates that LEC retrofits are consistent
9
with technology and costs in the NOx SIP Call
10
TSD .
11
BY MS . DOCTORS :
12
Q .
Isn't it true that once LEC technology
13
is installed that becomes an integral part of the
14
engine operation?
15
A .
Yes .
16
Q .
So the only time it would be shut off,
17
the LEC technology would be shut off, is when the
18
engine is not running?
19
A .
Correct . The technology can't be
20
turned on and off . It's inherent to the engine once
21
it's installed .
22
Q .
What type of maintenance needs to be
23
done on the LEC equipment?
24
A .
I don't believe there's any specific
Page 17
1
maintenance above and beyond the typical sort of
2
attention that the natural gas companies pay to this
3
equipment .
4
Nothing extra?
5
A .
6
You know, for example, if you install a turbo
7
charger and you didn't have a turbo charger on the
8
engine originally, obviously that's another piece of
9
moving equipment on the engine that you would have
10
to pay attention to . But I don't believe it changes
11
anything in terms of frequency or how attentive they
12
are to the engine .
13
Q .
Are there any additional costs
14
associated of running LEC during the winter months?
15
A .
There would be costs associated with
16
the compliance facet of running the engine, but
17
running the engine in and of itself doesn't
18
introduce additional costs .
19
Q .
Could you explain what you mean by the
20
compliance?
21
MR . MORE : I'm just going to object to
22
this line of questioning . It goes really
23
beyond the testimony that we're offering
24
Mr . McCarthy . It's above and beyond . We
Nothing specific comes to mind, no .
24
Page 18
1
don't get into costs, we're not objecting to
2
the applicability of the rule on an annual
basis .
4
MS . DOCTORS
: Oh, you're not? You're
5
not objecting to the -- is that correct, that
6
you're not --
7
MR . MORE : His testimony makes it
8
pretty clear that we are not --
He says on
9
Page 7, "In regard to the IEPA proposal under
10
consideration at this hearing, the Pipeline
11
Group does not object to the Subpart Q
12
proposal under consideration at today's
13
hearing
."
14
MS . DOCTORS : So there's no objection
15
to the annual applicability of the rule?
16
MR . MORE : That's correct .
17
MS . DOCTORS : Okay . Then we will skip
18
these questions .
19
HEARING OFFICER FOX
: Miss Doctors, if
20
I may interrupt you briefly at this point . I
21
want to note for the record that Exhibit 6,
22
the Federal Register that you've circulated
23
and admitted, does include some underlining,
and at least on the top of Page 21620, a
Page 19
1
handwritten reference, which is fine . I
2
merely need to note for the record that those
were not added by the board and do not
4
constitute any board comments . So having
5
made that statement, please proceed with any
6
further questions that you wanted to raise .
7
MS . DOCTORS : I'm sorry .
8
MEMBER RAO : May I ask a follow-up
9
question to your prior question?
10
Mr . McCarthy, on Page 6 of
11
your prefiled testimony, the second paragraph
12
you state that, "Despite the lack of an IEPA
13
rule, the affected natural gas companies have
14
proactively initiated reduction programs and
15
compliance plans for units in Appendix G of
16
the proposal ." Does that mean that all the
17
25 units that you're familiar with already
18
have this LEC technology implemented on those
19
units?
20
THE WITNESS : What it means is that
21
for those 25 engines, LEC has either been
22
installed or the companies have developed an
23
averaging strategy where they're introducing
24
either controls on those units or other units
Page 20
to achieve reductions .
MEMBER RAO : And that could involve
some costs to the affected companies?
4
THE WITNESS : Yes .
5
MEMBER RAO : And are those costs
6
consistent with what the estimates have been
7
shown in TSD?
8
THE WITNESS : We've not looked at that
9
level of cost detail
.
10
MEMBER RAO : Okay .
11
MS . DOCTORS : I'm sorry . Just --
12
HEARING OFFICER FOX : Mr . McCarthy, if
13
you could repeat your last answer
. I believe
14
Ms . Doctors had trouble hearing you .
15
THE WITNESS : The question was
16
regarding the costs . And my answer was we
17
have not looked at, specifically, at the
18
costs for activities underway with those 25
19
engines relative to the information that's -
20
We didn't specifically say which information,
21
but relative to cost information in the
22
record .
23
BY MS . DOCTORS :
24
Q .
I'm just going to ask one follow-up
Page 21
1 question . The reason -- I'll point out where the
3
Agency's concern came from . It came from Page 7 of
the testimony, the last sentence in the fourth
5
paragraph that begins "second ." Mr . McCarthy
indicated that there was an additional burden
6 because of the annual compliance requirement
. So it
7 is our understanding that you will not be filing an
8
objection to the annual component of Attachment 1?
9
MR . MORE : That's correct .
10
MS . DOCTORS : Let me just look through
11
what I have . All right .
12
HEARING OFFICER FOX : Ms . Doctors, do
13
you or the Agency have any further questions
14
for Mr . McCarthy?
15
MS . DOCTORS : Yes, we do . We just are
16
trying to short-cut . Thank you .
17
HEARING OFFICER FOX : No worries
.
18
Please go ahead when you're ready .
19
BY MS . DOCTORS :
20
Q .
We have some questions concerning SCR
21 technology that was referenced in your testimony .
22
On Page 7 of your testimony . At the bottom of
23
Page 7, can you read the last sentence that begins
24
"however," and then continues on to Page 8 .
Page 22
1
A .
"However, to date, SCR has not been
2
successfully applied to gas transmission units, and
3
U .S . EPA has acknowledged this limitation ."
4
Q
.
That's what my questions pertain to .
5
Are you familiar with U .S . EPA's Alternate Control
6
Techniques, ACT document, that was originally
7
Attachment 11C to the Agency's proposal?
8
A .
Yes .
9
Q .
And what I'm handing out is just the
10
portion that deals with control technologies, or
11
Chapter 5 . And this would be marked as hearing, I
12
think we're at 6 .
13
HEARING OFFICER FOX : We are at 7 .
14
MS . DOCTORS
: We are at 7 .
15
BY MS . DOCTORS :
16
Q .
Okay . Can you please turn to Page 55 .
17
HEARING OFFICER FOX : Ms . Doctors, if
18
you don't mind, let's formally admit that .
19
I'll construe your distribution again as a
20
motion to admit the U .S . EPA Alternative
21
Control Technique's document NOx Emissions
22
From Stationary Reciprocating Internal
23
Combustion Engines as a motion to admit that
24
document as hearing Exhibit No . 7 ; is that
Page 23
1
correct?
2
MS . DOCTORS : Correct .
3
HEARING OFFICER FOX : Is there any
4
objection on the part of any of the
5
participants?
6
MR . MORE : I would have just one
7
clarifying objection . It's just a portion of
8
that document . I'd ask that the record
9
reflect that .
10
MS . DOCTORS : Right . Let's clarify .
11
It's just Chapter -- It's all of Chapter 5
12
entitled NOx Control Techniques .
13
HEARING OFFICER FOX : I appreciate the
14
clarification . And that is, in fact, what's
15
beyond the face sheet of what you've
16
distributed, Ms . Doctors . Beyond that
17
clarification, Mr . More, was there any
18
objection on the part of the Pipeline to
19
admission?
20
MR . MORE : No objection .
21
HEARING OFFICER FOX
: Very well, it
22
will be admitted as described as Hearing
23
Exhibit No . 7 and so marked, Ms . Doctors .
24
Thank you for letting me interrupt you .
1
BY MS . DOCTORS :
2
Are you familiar with this document?
3
A
.
I am familiar with it .
4
Q .
Can you turn to Page 55 .
5
A .
Okay .
6
Q .
Isn't it true that the ACT lists SCR
7
as a feasible technology?
8
A .
It lists SCR as a technology . I'm not
9
sure if it
how or if it passes judgment on
10
feasibility .
11
Q .
Isn't it true that Chapter 5 of this
12
NOx technique lists a variety of control technology
13
in addition to SCR?
14
MR . MORE : I'm going to just object
.
15
Are you asking him to tell you what the
16
document says? The document speaks for
17
itself . And I'm not sure that he's qualified
18
to testify as to what it intends to say or
19
what it infers or implies .
20
MS . BASSI : May I add to that
21
objection? Moreover, he's testified that LEC
22
has been
-- is, has been, or is being applied
23
to all of the engines that we're here
24
speaking for or they're involved in an
Page
24
24
Page 25
averaging plan . We don't understand the
2
whole line of this questioning .
3
MS . DOCTORS : It goes to the statement
4
in his testimony where he said SCR couldn't
5
be used at the bottom of Page 7 .
MR . MORE : I think he stands by that
7
statement .
8
THE WITNESS : "Has not been
9
successfully applied to gas transmission
10
units ." I stand firmly by that statement .
11
MS . BASSI : It doesn't say all
12
engines . It says gas transmission units .
13
BY MS . DOCTORS :
14
Q
.
Why? Why do you feel that it hasn't
15
been --
16
A .
To my knowledge, there is only one
17
installation in the U .S . that has occurred, and that
18
installation was taken out of service after a couple
19
of years because it wasn't functioning properly .
20
Q .
Which installation was that?
21
A .
It's in the south coast jurisdiction
22
in California .
23
Q .
What's the difficulty with SCR?
A .
The problems -- SCR is the technology
Page 26
1
that was
originally developed for very large utility
2
scale applications like coall fired utility boilers,
for example . And there's certain characteristics of
4
those facilities that aren't necessarily the same
5
sort of characteristics for a reciprocating internal
6
combustion engine . One of the - key technical
7
requirements of SCR is that you finely control the
8
amount of ammonia that you inject into the exhaust
.
9
You add ammonia into the exhaust to make reactions
10
occur across the catalyst to reduce the NOx . So one
11
of the difficulties that has been seen and that is
12
forecast if additional installation should occur is
13
that the control for ammonia feed is not -- has not
14
been developed sophisticated enough for application
15
to the way an engine NOx emissions vary in the
16
exhaust
. You need to match ammonia to NOx and the
17
NOx
variability can introduce difficulties with
18
controlling the ammonia feed rate properly . That's
19
one issue .
20
Q .
So basically you're saying it's
21
because of the variable load nature of the --
22
A .
It ties to load variability
. Because
23
as the load changes or the operating conditions of
24
the engine change, the
NOx changes on an IC engine .
Page 27
1
An IC engine is internal
combustion engine .
2
Besides the one place in California,
3
are you aware of whether SCR has been employed on
4
any other gas engines?
5
A .
I believe there's a -- I'm not sure
6
which state, but I believe there are one or two
7
engines in the Eastern U .S . that have had SCR
8
installed . I think one is in New Jersey .
9
MS . BASSI : Are those gas transmission
10
engines?
11
THE WITNESS : They are not gas
12
transmission engines . They're in different
13
applications
. And, anecdotally, I've talked
14
to folks affiliated with those engines, and
15
they found many difficulties in getting the
16
SCR to work properly on those engines and
17
questioned whether it will continue to work
18
over time .
19
BY MS . DOCTORS :
20
Q .
Now, is this also true for diesel
21
engines?
22
A .
I can't really speak to diesel and SCR
23
because I've not worked closely with that
24
application .
Page 28
1
Q
Are you aware that HUGG has used this
2
type of system at MIRATECH for gas pipeline?
3
MS . BASSI : Who?
4
MS . DOCTORS : HUGG, H-U-G-G?
5
THE WITNESS : I'm not, no . I have
6
heard of HUGG and MIRATECH, but I'm not
7
familiar with that application .
8
BY MS . DOCTORS :
9
Q .
Isn't it true that the provisions of
10
Attachment 1 do not require the installation of any
11
particular type of control technology?
12
MS . BASSI : What is Attachment 1?
13
Exhibit what?
14
MR . MORE : Exhibit 4 .
15
MS . DOCTORS : That's Exhibit 4?
16
THE WITNESS : That's correct .
17
BY MS . DOCTORS :
18
Q .
Isn't it true that provisions of the
19
proposal before the board today allow for the owner
20
or operator to have discretion on the type of
21
control equipment to install so long as the
22
requirements of the rule are met?
23
A .
That's true .
24
Q .
So there's no requirement that anybody
1
install SCR?
2
A .
Correct . But it is identified in the
3
TSD for the rulemaking as a viable technology which
4
is why it was mentioned in my testimony .
5
Q .
Okay . Isn't it true, though, that
6
when the TSD was written, it covered a broad range
7
of engines besides gas transmission engines,
8
pipeline engines?
9
A .
Yes .
10
MS . BASSI
: Can I ask a follow-up to
11
that line, please?
12
MS . DOCTORS : You don't have to ask
13
me .
14
HEARING OFFICER FOX : Miss Bassi .
15
MS . BASSI : Mr . McCarthy, are you
16
familiar with types of engines that are at
17
the Phoenix Chemical Company which is also
18
part of Appendix G, Exhibit 5?
19
THE WITNESS : I'm not familiar with
20
that company's engines .
21
MS . BASSI : Is it possible at all that
22
they might require SCR or some other type of
23
control technology than is being applied to
24
the gas transmission engines?
Page 29
1
THE WITNESS :
Page 30
Not knowing the engines,
2
it's possible .
3
MS .
BASSI : Thank you .
4 BY MS . DOCTORS :
5
Q .
On Page 8 of your testimony, didn't
6
you
on Page 8, the last paragraph, you make the
7 statement that this TSD indicates that 5,000 per ton
8 is the basis used for IS engines under the NOx SIP
9
Call ; is that correct?
10
A .
Yes .
11
Q .
I'd like to refer you to Page -- This
12 would be Hearing Exhibit 8 . What I'm handing out is
13
just a cover sheet from the Illinois EPA's Technical
14
Support Document and a copy of Chapter 5 which dealt
15 with cost effectiveness, and I'm marking it as
16 Exhibit 8 and asking that it be entered, if there's
17
no objection .
18
MR . MORE : No objection .
19
HEARING OFFICER FOX : We can certainly
20
wait until it's circulated to assure,
21
Mr . More, that you don't have any objection
.
22
And Ms . Doctors has moved to admit
23
as Hearing Exhibit No . 8, Chapter 5 regarding
24
cost effectiveness of controls from the
Page 31
1
technical support document that was initially
2
submitted with the rulemaking proposal in
3
this case on April 6 . Is there any objection
4
to the admission of that as Exhibit No . 8?
5
MR . MORE : No objection .
6
HEARING OFFICER FOX : Neither seeing
7
nor hearing an objection, it will be marked
8
and admitted as Exhibit No
. 8, Ms
. Doctors .
9
BY MS . DOCTORS :
10
Q .
I'd like to refer you to -- at the
11
bottom of the page it says 40, it's probably about
12
the third page in, to Table 5-2 . And there's also
13
Table 5-3 . Are these the tables you looked at when
14
you were writing your testimony ; is that correct?
15
A .
My testimony is in reference to the
16
paragraph on that page where it states U .S . EPA
17
selected the $5,000 per ton regulatory alternative
18
as the basis for controlling rights .
19
Q .
Isn't it true that the $5,000 relates
20
to U .S . EPA's evaluation of one of several
21
regulatory alternatives under the first NOx SIP Call
22
not under Phase II?
23
A .
I wasn't familiar with that $5,000 per
24
ton cost threshold which was the basis for my
Page 32
comment .
2
Q .
Okay . Can I direct you to look
at
3
Table 5-2, the
first
column
. What it is entitled --
4
A .
Regulatory alternative .
5
Q .
So in that column, doesn't it list a
6
number of alternatives and costs associated with
7
them?
8
A .
Yes, it does .
9
Q .
And isn't $5,000 a ton the maximum?
10
A .
It is the maximum in Table 5-2 .
11
Q .
And I'd like to refer you to Table 5-3
12
and the last number -- Oh, looking at the last
13
column, what is the last column, the title of the
14
last column?
15
A .
Ozone Season Cost Effectiveness,
16
Dollars Per Ozone Season Ton .
17
Q .
And what is the cost effectiveness of
18
the $5,000 a ton alternative?
19
A .
In Table 5-3 it's 1,215 .
20
Q .
And what level of control is that --
21
does that correspond to? What level of reduction of
22
NOx?
23
A .
I don't know the answer to that
24
question . This is the Agency's table .
Page 33
1
Q .
Okay .
Well, I'd like to just refer
2
you to the last sentence
in the paragraph that you
quoted .
4
A .
Okay . The last sentence in that
5
paragraph says that that refers to an average
6
reduction of 90 percent from an uncontrolled 2007
7
baseline .
8
Q .
And isn't it true that the proposal
9
before the Board today relates to an 82 percent
10
reduction of NOx?
11
A .
That's true .
12
HEARING OFFICER FOX : Ms . Doctors, I
13
believe Miss Bassi has a question, if we may .
14
MS . BASSI : Ms . Doctors, on these
15
tables that you're referring so, there's a
16
footnote -- or a reference to a Footnote 11 .
17
Is that included in the exhibit?
18
MS . DOCTORS : I do not believe so .
19
I'll have to --
20
MS . BASSI : Well,
seems to me that
21
what you're doing here is -- We don't know
22
where these tables came from on the basis of
23
your exhibit . And the statement that
24
Mr . McCarthy is referring to in his testimony
Page 34
1
says U.S . EPA selected the $5,000 per ton
2
regulatory alternative, and it appears that
3
what you're doing is pointing to these tables
4
to make some point about the $5,000 per ton,
5
but we don't know if these are U .S . EPA
6
numbers, we don't know if they're your
7
numbers, we don't know where they came from .
8
MS . DOCTORS : I direct the Board -- I
9
don't have an extra copy of the TSD, but --
10
actually I'm being directed by -- Was that in
11
Chapter 5? I can direct you to
-- I mean he
12
quoted it . Your witness quoted the table .
13
So, therefore --
14
MS . BASSI : My witness quoted a
15
sentence .
16
MS . DOCTORS : Right . Out of something
17
that had a footnote, so you'd assume that he
18
would --
19
MS . BASSI : No . The sentence is not a
20
footnote .
21
MS . DOCTORS
: Okay . In any case, the
22
reference to where the numbers come from,
23
Mr . McCarthy, I'd like to direct you to Page
24
37 of Chapter --
Page 35
1
MR . MORE : I'm
going to object on the
2
grounds that you're --
It sounds like you're
attempting to have Mr . McCarthy authenticate
your document and lay a foundation for the
5
accuracy of the information in here
. Your
6
witnesses could have very well done that
.
7
He's just regurgitating what the document
8
says .
9
MS . DOCTORS : But he's taking issue
10
with it, so .
11
THE WITNESS : I took issue with the
12
quote of $5,000 per ton as the U .S . EPA
13
preferred alternative .
14
MS . DOCTORS
: Okay . Just for the
15
Board's reference, from the TSD it was
16
Reference 11 in the Agency's TSD which comes
17
from regulatory impact analysis for the NOx
18
SIP Call and Section 26 Petition Volume 1
19
Costs and Economic Impact . It's Reference
20
11 in the TSD itself . So it's part of the
21
Board's record already, in any case .
22
We're ready to move on to some new
23
questions .
24
HEARING OFFICER FOX
: When you're
1
ready, Ms . Doctors, please do .
2
BY MS . DOCTORS :
3
Q .
Are you familiar with the TSD that was
4
prepared for the NOx SIP Call dated October 3rd and
5
originally part of the Agency's submittal, TSD
6
Reference 12, and I have copies . This would be -
7
Are we at 9?
8
HEARING OFFICER FOX : That would be
9
the next exhibit number, yes .
10
MS
. DOCTORS
: It's the whole document,
11
I believe .
12
HEARING OFFICER FOX : Ms . Doctors,
13
before addressing the admissibility, would
14
you please clarify more specifically what
15
this document is and which rulemaking docket
16
it originated with?
17
MS . DOCTORS : It originated in RO7-18,
18
and it was reference 12 in the technical
19
support document .
20
HEARING OFFICER FOX : You made a
21
reference to CAIR .
22
MS . DOCTORS : I'm sorry . I misspoke .
23
Excuse me . I'm getting -- the rules are
24
merging .
Page 36
Page 37
1
HEARING OFFICER FOX : Thank you .
2
THE WITNESS
: I am familiar with this
3
document .
HEARING OFFICER FOX : Before we
5
proceed with any questions, Ms . Doctors, I
6
assume that your circulation of this document
7
entitled Stationary Reciprocating Internal
8
Combustion Engines Technical Support Document
9
for NOx Sip Call dated October 2003 is a
10
motion to admit that as Hearing Exhibit
11
No . 9 ; is that correct?
12
MS . DOCTORS : Yes .
13
HEARING OFFICER FOX : Is there any
14
objection to admitting that?
15
MR . MORE : Yes . The document appears
16
to be incomplete . It is only even pages .
17
MS . DOCTORS : You're kidding .
18
MR . MORE
: I suspect that's a function
19
of double-sided --
20
MS . DOCTORS : Oh, no . Well, it is
21
already part of the record . I do have a
22
complete copy that I'm willing to share with
23
the witness for the purpose of testimony .
24
And I bet I even have an additional one . Do
24
Page 38
you have one? I think we can come up with
some more copies . I don't know that I have
3
six, though .
4
HEARING OFFICER FOX : What I would
5
suggest is that since this was originally
6
submitted and remains part of the Board's
7
record in this docket, that if it's
8
acceptable, Mr . McCarthy, to use the copy
9
that Ms . Doctors has provided to you we can
10
proceed to --
11
MS . DOCTORS : We'll give you one, too .
12
I can get more copies . So there is at least
13
three .
14
MR . MORE : I have no objection to this
15
version being submitted .
16
BY MS . DOCTORS :
17
Q .
I just have one question . Please look
18
at Page 34 .
19
HEARING OFFICER FOX : May I interrupt
20
you, Ms . Doctors . Mr . More has indicated
21
that there is no objection to admitting this
22
as Exhibit 9 . If I keep this as the Board's
23
exhibit number, will I deprive you of a copy
you need?
Page 39
1
MS . DOCTORS : No . I have one .
2
HEARING OFFICER FOX
: Hearing no
3
objection and seeing no objection, it will be
4
marked and admitted as Hearing Exhibit No . 9
5
in this proceeding . And thank you for
6
letting me interrupt you, Ms . Doctors .
7 BY MS . DOCTORS :
8
Q .
Please look at Page 34 . Isn't it true
9
that the average cost for reducing NOx using LEC is
10
approximately $500 per ton, according to U .S . EPA's
11 analysis?
12
A .
Yes . This particular U .S . EPA
13
analysis indicates the average cost of $532 per ton .
14
Q .
I have no further questions .
15
MS . BASSI : May we have a moment,
16
please .
17
HEARING OFFICER FOX : Ms . Doctors, did
18
you mean no further questions with regard to
19
this -
20
MS . DOCTORS : No . I meant no further
21
questions .
22
HEARING OFFICER FOX : Miss Bassi, in
23
response to your question in speaking briefly
24
with Miss Doctors before hearing, she wished
Page 40
1
to go off the
record to
have
a brief
2
conversation with her personnel before we
proceeded any further . So if we may go off
the record for a moment and allow the
5
participants a chance to speak with one
6
another, that would be great . Thank you .
7
(Off the record .)
8
HEARING OFFICER FOX : If we may go
9
back on the record, please . If the Agency
10
has still completed its questions and there
11
are no further questions it wanted to pose to
12
Mr . McCarthy?
13
MS . DOCTORS : Not at this time .
14
HEARING OFFICER FOX
: Very good . I
15
know there are two representatives of the
16
board who had a question that they wish to
17
pose . The first of them, Board Member
18
Johnson had a question, I believe, for
19
Mr . McCarthy .
20
MR . JOHNSON : Mine will be brief . And
21
I
just want to sum up what I consider to be
22
the most relevant statement in your testimony
23
today and ask you if it's still the case . At
24
the top of Page 7 you testified that, "In
regard to the IEPA proposal under
2
consideration of this hearing, The Pipeline
3
Group does not object to Subpart Q proposal
4
under consideration at today's hearing ." Is
5
that still the case?
6
THE WITNESS : That is still the case .
7
MR . JOHNSON : Thank you .
8
HEARING OFFICER FOX : Mr . Melas, Board
9
Member Melas had indicated as well that he
10
had a question . Mr . Melas?
11
MEMBER MELAS : This is just primarily
12
curiosity question of mine . When you started
13
describing the LEC process, you mentioned
14
that the purpose is to lower the combustion
15
temperature . Now, is it not true that the IC
16
engines that are utilized by the gas pipeline
17
companies do their heavy work in the
18
wintertime when there's a great demand for
19
the gas as opposed to the summertime?
20
THE WITNESS : That's true . Typically
21
there's heavier load during the winter
22
heating season than during warmer months .
23
MEMBER MELAS : And when you're trying
24
to utilize LEC because of -- particularly in
Page 41
Page
42
1
the dead of winter when you're bringing in
2
air temperature at a much lower temperature,
it would make the process a lot more
4
efficient and further reduce NOx than if you
5
were dealing with temperature -- air
6
temperatures of 85 or 90 .
7
THE WITNESS : That's true .
8
Environmental affects -- temperature and
9
humidity impact the emissions performance .
10
MEMBER MELAS : And that's the time
11
when you're more concerned about reducing
12
excessive amount of NOx in the -- when the
13
engine is working harder .
14
THE WITNESS : The engines typically
15
run more during the winter season .
16
MEMBER MELAS : So if global warming
17
doesn't catch up to us, you would be more
18
able to meet the NOx requirements during that
19
period of heavy production or heavy usage?
20
THE WITNESS : Yeah . I just want to be
21
careful of how I'm saying this, because some
22
engines
often what happens is you have
23
multiple engines at a facility . So even when
24
your load gas demand is lower, you still
Page 43
1
might be running a single engine at a high
2
load . In the winter, you might be running
3
three engines or five engines at a high load .
4
So there's that sort of balancing that goes
5
on as well . But the ambient temperature
6
point you made is still valid . Cooler
7
temperatures help lower the peak temperatures
8
which help lower the NOx .
9
MEMBER MELAS : Thank you .
10
MS . DOCTORS : Mr . Fox, I'm going to
11
need one minute to confer with Mr . More and
12
Miss Bassi before we go off the -
13
permanently close the hearing .
14
MR . MORE : We have no questions .
15
HEARING OFFICER FOX : Very good .
16
MS . DOCTORS : But I still need to
17
speak - -
18
HEARING OFFICER FOX : If we may go off
19
the record . And, Ms . Doctors, you've
20
indicated that you wanted to speak with some
21
of the other participants, we will do that
22
once again . Thanks
.
23
24
(Off the record .)
HEARING OFFICER FOX : We may go back
Page 44
1
on the record . What I would like to do first
2
is
verify
that I
believe that all
of
the
3
board members and board staff have posed the
4
questions that they wish to, the Agency has
5
indicated that it has posed questions . Is
6
there anyone else present who does have
7
questions to pose to Mr
. McCarthy on the
8
basis of his testimony?
9
And seeing no indication that
10
anyone does, I'd like to move on to address a
11
few procedural issues before we can move to
12
adjourn this hearing . In this Docket R07-189
13
third hearing is now scheduled to take place
14
on Monday, July 2, at 1 :00 p.m . in
15
Springfield, with a deadline of this Friday,
16
June 22, for prefiling testimony . Under
17
Section 28 .5G3, quote, The third hearing
18
shall be canceled if the Agency indicates to
19
the Board that it does not intend to
20
introduce any material, additional material,
21
forgive me, closed quote . I had, as a
22
procedural matter, spoken with Ms . Doctors
23
about this very issue before hearing .
24
Ms . Doctors, did you have anything
1
to add to that issue at all?
2
MS . DOCTORS : The Agency does not
3
object to canceling the third hearing
.
4
HEARING OFFICER FOX
: Is that a
5
statement -- Is that a statement that you do
6
not intend to introduce any additional
7
material as the statute would allow you to
8
do?
9
MS . DOCTORS : Correct .
10
HEARING OFFICER FOX : You would have
11
no objection if the board, on the record and
12
in a hearing officer order were to cancel the
13
third hearing that's now scheduled to take
14
place on Julie 2?
15
MS . DOCTORS : Correct
.
16
HEARING OFFICER FOX : Very well . That
17
clearly has been the Agency's intentions
18
under 28
.5G3 which have been plainly made
19
clear on the record
. The expedited copies of
20
the transcript of today's hearing should be
21
available to the Board by Thursday, June 21,
22
and very soon after they are available to the
23
Board the transcript will be posted to the
24
Board's Clerk's Office On Line or COOL which
Page 45
Page 46
1
is accessible through the Board's web site at
2
www dot IPCB dot State dot IL dot US .
3
Section 28 .5L of the Act provides that,
4
quote, following the hearings, which conclude
5
with the second hearing today, of course, the
6
Board shall close the record 14 days after
7
the availability of the transcript . Since
8
this proves to be the final hearing in this
9
proceeding, the Board will, of course,
10
consistent with that language, keep the
11
record open for comment for that 14-day
12
period . And in order to make that absolutely
13
as clear as possible for the participants,
14
when that transcript is available and when it
15
is posted to the Board's web site, I will
16
issue a hearing officer order that will let
17
the participants know precisely the date on
18
which that 14-day period begins, and, of
19
course, on which it ends
. Participants may
20
file written public comments in the meantime,
21
of course, in this rulemaking with the clerk
22
of the board and any comments or other
23
filings may be filed electronically through
24
COOL which I believe all of these
Page 47
1
participants are familiar, and any questions
2
about electronic filing should be directed to
3
the Board's assistant clerk, John Therriault,
4
who can be reached at direct number
5
312-814-3629 . Filings with the Board whether
6
paper or electronic, must be served on the
7
hearing officer and on those persons on the
8
serving list . And before filing with the
9
clerk, you may certainly check with me as the
10
hearing officer, to ensure that you have the
11
most recent version of the service list . And
12
if anyone has questions procedurally about
13
other aspects of this rulemaking, they may
14
reach my direct line 312-814-6085 .
15
Are there any other
16
matters that need to be addressed at this
17
time? Ms . Doctors?
18
MS . DOCTORS : The Agency would like to
19
just indicate that they found
--
that we have
20
found and the Pipeline has identified and
21
some other participants, including the
22
Illinois Environmental Regulatory Group, have
23
24
identified some typographical errors in the
rule ; and fairly shortly, maybe next week or
Page 48
1
the week after, probably prior to receipt of
2
the transcript, we'll be filing some kind of
3
joint stipulation or a motion identifying
4
these typos so the Board can work on final
5
regulatory language .
6
HEARING OFFICER FOX : Very good . The
7
14-day comment period, of course, has not yet
8
begun to run since the transcript is not
9
available . So we appreciate the notice that
10
that may be forthcoming and certainly will
11
get to the Board's attention in correcting
12
any of those errors that you may highlight in
13
that filing, Ms . Doctors .
14
Anything further on the part
15
of any of the participants?
16
Before we do formally adjourn, I
17
know I speak for the board members and the
18
rest of the board staff in thanking you for
19
your time, your effort, your appearance here
20
today, your assistance in building a record .
21
And we hope you travel safely, and thank you
22
once again for all of your work and
23
assistance . Thanks
. We are adjourned .
24
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 49
(Which were all the
2
proceedings had .)
3
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1
STATE OF
ILLINOIS )
2
)
SS .
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COUNTY OF COOK
)
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5
I, LAURA BERNAR, being a Certified
6
Shorthand Reporter doing business in the City of
7
Chicago, Illinois, County of Cook, certify that I
8
reported in shorthand the proceedings had at the
9
foregoing hearing of the above-entitled cause . And
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I certify that the foregoing is a true and correct
11
transcript of all my shorthand notes so taken as
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aforesaid and contains all the proceedings had at
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the said meeting of the above-entitled cause .
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LAURA BERNAR, CSR
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Page
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CSR NO . 084-003592
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