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0
AS 07 - 45-*
(Adjusted Standard)
FEB 0 4 2008
STATE
OF
ILLINOIS
"ollutli JP
Control Board
One of Its Attorneys
RECEIVED
CLERKS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PETITION OF CABOT CORPORATION
FOR AN ADJUSTED STANDARD FROM
35 III. Adm. Code Part 738, Subpart B
NOTICE OF FILING
TO: SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution Control Board Cabot Corporation's
Motion to Extend Stay of Proceedings on Cabot
Corporation's Petition for Reissuance of Adjusted Standard.
DATED:
February 4, 2008
CABOT CORPORATION
By:
Eric E. Boyd (6194309)
SEYFARTH SHAW
LLP
131 South Dearborn Street
Chicago, Illinois 60603
Tel. (312) 460-5000
Fax: (312) 460-7000
Printed on Recycled Paper
C111 11407504 I
 
SERVICE LIST
Illinois Pollution Control Board
Attention: Clerk
100 W. Randolph Street
James R. Thompson Center, Suite 11-500
Chicago, Illinois 60601-3218
Illinois Environmental Protection Agency
Division of Legal Counsel
Attention: Kyle Nash Davis, Esq.
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, IL 62794-9274
Printed on Recycled Paper
2
CM 11407504.1
 
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
FEB
0 4 2008
STATE OF ILLINOIS
Pollution Control Board
IN THE MATTER OF:
PETITION OF CABOT CORPORATION
FOR AN ADJUSTED STANDARD FROM
35 111. Adm. Code Part 738, Subpart B
AS 07-06
(Adjusted Standard)
MOTION TO EXTEND STAY OF PROCEEDINGS ON CABOT CORPORATION'S
PETITION FOR REISSUANCE OF ADJUSTED STANDARD
Cabot Corporation ("Cabot"), through its attorneys, Seyfarth Shaw LLP, and pursuant to
35 III. Admin. Code ยงยง 101.500 and 100.514, moves to stay proceedings on its May 29, 2007
Petition for Reissuance of Adjusted Standard ("May 29, 2007 Petition"). In support of this
motion, Cabot states:
1.
Cabot filed the May 29, 2007 Petition seeking reissuance of its adjusted standard from
the Illinois state underground injection control ("UIC") regulations for Wells Nos. 2 and 3 at its
Tuscola, Illinois facility ("Facility").
2.
Also on May 29, 2007, Cabot filed a Motion to Stay Proceedings. The Motion to Stay
requested that the Board stay further action on the Petition until the U.S. EPA takes final action
on a similar petition Cabot filed with the U.S. EPA. The motion explained that staying the
proceeding until the U.S. EPA takes action, "will assist the Board in making the appropriate
determination and ensure that the Board does not apply more stringent law to Cabot than is
warranted under the circumstances." May 29, 2007 Motion to Stay, at Par. 9.
Printed on Recycled Paper
(111 11405854.]
 
3.
On August 9, 2007, the Board entered an order staying this proceeding until February 9,
2008. The August 9, 2007 Order explained that the parties may request an extension of the
initial stay and the time for the Agency to file its recommendation by asking the Hearing Officer.
4.
To date, the U.S. EPA has taken no action on Cabot's no migration demonstration or
petition. In addition, the U.S. EPA has provided no indication as to when it will be taking action.
5.
As a result, Cabot requests that the stay be extended for an additional six months, or until
August 9, 2008. The time by which the Respondent's recommendation needs to be submitted
should also be extended until 45 days after the expiration of the stay, or until September 23,
2008.
6.
On January 31, 2008, the attorney for Cabot, Eric E. Boyd, spoke with the attorney for
the IEPA, Kyle Nash Davis. Mr. Davis indicated that the IEPA has no objection to this motion.
WHEREFORE, Cabot Corporation respectfully requests that the Board stay all
proceedings on the May 29, 2007 Petition until August 9, 2008 and extend the time by which the
Agency must file its recommendation until September 23, 2008.
DATED:
February 4, 2008
Respectfully submitted,
CABOT CORPORATION
One of Its Attorneys
Eric E. Boyd (6194309)
SEYFARTH SHAW LLP
131 South Dearborn Street
Chicago, Illinois 60603
Tel. (312) 460-5000
Fax: (312) 460-7000
Printed on Recycled Paper
2
By:
CHI I I 405854 A
 
CERTIFICATE OF SERVICE
I, Eric E. Boyd, hereby certify that on February 4, 2008, I caused a copy of Cabot
Corporation's Motion to Extend Stay
of Proceedings on
Cabot Corporation's
Petition for
Reissuance of Adjusted Standard
to be served upon the parties listed below via First Class
U.S. Mail:
Illinois Pollution Control Board
Attention: Clerk
100 W. Randolph Street
James R. Thompson Center, Suite 11-500
Chicago, Illinois 60601-3218
Illinois Environmental Protection Agency
Division of Legal Counsel
Attention: Kyle Nash Davis, Esq.
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, IL 62794-9274I
ri3c
Printed on Recycled Paper
3
C111
114075041

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