BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE
MATTER OF:
CITGO PETROLEUM CORPORATION and
PDV MIDWEST REFINING, L.L.C.,
Petitioners,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
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PCB 08-33
(Variance - Water)
NOTICE OF FILING
To:
Dorothy M. Gunn, Clerk
Douglas Scott, Director
Illinois Pollution Control Board
Illinois Environmental Protection Agency
100 West Randolph, Suite 11-500
1021 N. Grand Avenue East, P.O. Box 19274
Chicago, IL 60601
Springfield, IL 62794-9274
Sanjay Sofat, Office
of General Counsel
Illinois Environmental Protection Agency
1021 N. Grand Avenue East P.O. Box 19274
Springfield, IL 62794-9274
Please take notice that on January 22, 2008, we filed electronically with the Office
of the
Clerk
of the Illinois Pollution Control Board the attached
Motion to Incorporate,
a copy of
which is served upon you.
CITGO PETROLEUM CORPORATION and
PDV MIDWEST REFINING, L.L.C.
il.-~~~-
.
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By: ...:..%'1
'0_.
_
One of Its Attorneys
Jeffrey
C. Fort
Ariel J. Tesher
Sonnenschein Nath
&
Rosenthal LLP
7800 Sears Tower
233
S. Wacker Drive
Chicago, IL 60606-6404
Electronic Filing - Received, Clerk's Office, January 22, 2008
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
CITGO PETROLEUM CORPORATION and
PDV MIDWEST REFINING, L.L.C.,
Petitioners,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
)
)
)
)
)
)
)
)
)
)
PCB 08-33
(Variance - Water)
Motion to Incorporate
On November 14,2007, CITGO Petroleum Corporation ("CITGO") and PDV Midwest
Refining, L.L.C. ("PDVMR") (collectively, "Petitioners") filed a Petition for Extension of
Variance ("Petition") with the Illinois Pollution Control Board ("Board"). On December 20,
2007, the Board issued an order ("Order") directing Petitioners to file an amended petition
providing additional information. In support of Petitioners' filed response, and in accordance
with 35 Ill. Adm. Code 104.210(d)(3), Petitioners file this Motion to Incorporate. Petitioners
respectfully request that the Board incorporate into the record in this proceeding any material
from the record of the prior variance proceeding,
Citgo Petroleum Corporation and PDV
Midwest Refining,
L.L.
c.,
v. Illinois Environmental Protection Agency,
PCB 05-85, (Variance --
Water). Petitioners request that the entire record, including the initial petition, all orders, agency
recommendations, pre-filed testimony, hearing transcripts, exhibits, and briefs contained in PCB
05-85 be incorporated into this variance proceeding, PCB 08-33.
1
Electronic Filing - Received, Clerk's Office, January 22, 2008
WHEREFORE, CITGO requests that this Motion to Incorporate be granted.
CITGO
PETROLEUM CORPORATION and
PDV MIDWEST REFINING, L.L.C.
IrL.
C
By:
JV
5:
j
~rJ'
_
One of Its Attorneys
Dated: January 22, 2008
Jeffrey
C.
Fort
Ariel J. Tesher
Sonnenschein
Nath
&
Rosenthal LLP
7800 Sears Tower
233 South Wacker Drive
Chicago, IL 60606-6404
2
Electronic Filing - Received, Clerk's Office, January 22, 2008
CERTIFICATE OF SERVICE
The undersigned, an attorney, certifies that I have served upon the individuals named on
the attached Notice of Filing true and correct copies of this
Motion to Incorporate
by First
Class Mail, postage prepaid, on January 22,2008.
12361589
3
Electronic Filing - Received, Clerk's Office, January 22, 2008