Electronic
Filing
- Received,
Clerk’s
Office, February
18, 2009
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
DYNEGY
MIDWEST
GENERATION,
INC.,
Petitioner,
ILLINOIS
ENVIRONMENTAL
PROTECTION
Agency,
To:
NOTICE
OF FILING
John
Therriault,
Assistant
Clerk
Illinois Pollution
Control Board
James
R.
Thompson
Center
Suite 11-500
100
West Randolph
Chicago, Illinois
60601
Illinois
Environmental
Protection
Agency
Division
of
Legal
Counsel
1021 North
Grand
Avenue, East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
PLEASE
TAKE
NOTICE
that we
have today
electronically
filed
with the
Office of the
Clerk of the
Pollution
Control
Board MOTION
FOR
RECONSIDERATION,
copies of which
are
herewith
served upon
y
Dated:
February
18, 2009
Kathleen C.
Bassi
Stephen J.
Bonebrake
SCHIFF HARDIN,
LLP
6600
Sears
Tower
233
South
Wacker
Drive
Chicago,
Illinois
60606
312-258-5500
V.
)
)
)
)
)
PCB 09-48
)
Variance
Air
)
)
)
Electronic
Filing
- Received,
Clerk’s
Office,
February
18,
2009
BEFORE
THE
ILLINOIS
POLLUTION CONTROL
BOARD
DYNEGY
MIDWEST
GENERATION,
INC.,
)
)
Petitioner,
)
)
v.
)
PCB
09-048
)
Variance
— Air
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
Agency,
)
)
Respondent.
)
MOTION
FOR
RECONSIDERATION
OF
RECOMMENCING
THE
120-DAY
PERIOD
FOR
THE
BOARD’S
DECISION
NOW
COMES
Petitioner,
DYNEGY
MIDWEST
GENERATION. [NC.
(“DMG”).
by
and
through
its
attorneys,
SCHIFF
HARD1N,
LLP,
pursuant
to
35
Il1.Adm.Code
§
101.520,’
and
moves
the Board
to
reconsider
its
Order
entered
February
5,
2009,
in this
matter
(“Order”),
finding
that
the
“informational
deficiencies”
cited
by
the Board
are
so
egregious
as to require
DMG
to
submit
an
amended
petition,
2
thereby
recommencing the 1 20-day
statutory
period
for
the
Board to
issue
its decision
on the
merits
of
DMG’s
Petition
for Variance
(“Petition”).
More
specifically,
DMG
respectfully
requests
that the
Board
reconsider
its
determination
that the
120-
Hereinafter,
references
to the Board’s
rules
codified
at
35
Ill.Adm.Code
are
referred
to
merely
by section
number.
2
DMG
is,
indeed,
providing
the
four
additional
items
of
information
requested
by
the
Board
by filing
a
document
stylized
as an
Amended
Petition
for
Variance
simultaneously
with
this
Motion
for
Reconsideration.
However,
as stated
in
the
Amended
Petition,
the document
would
be more
correctly
stylized
as a Supplement
to DMG’s
Petition
for
Variance.
Also
as
stated
in the
Amended
Petition,
DMG
does
not waive
any
rights
of
appeal
of the
Board’s
Order
by
complying with its
terms
and submitting
document
stylized
as
an Amended
Petition
for
Variance.
Electronic
Filing
- Received,
Clerk’s
Office, February
18, 2009
day
statutory
period for decision
must
recommence.
In
support of
its
Motion for
Reconsideration,
DM0 states
as
follows:
I.
BACKGROUND
1.
On January 9,
2009, DM0
petitioned the Board to
grant it
relief
from the
requirements
of Sections
225.233(c)(1)(A)
and 3
225.233(c)(2) that
it
inject
halogenated
activated
carbon
4
at a rate
of
5.0
pounds per
million actual cubic
feet
(“lb/macf”)
exhaust gas flow
beginning July
1, 2009, at Unit 3 at its
Baldwin
Energy
Complex (“Baldwin
Unit 3”).
Pet.,
p.
1.
The
relief sought in
the Petition for Variance
is
time-sensitive
in light of
the July 1,
2009,
compliance
date
applicable
to
Baldwin
Unit 3 and
the lead time
needed,
to
prepare
Baldwin
Unit
3 to
meet the
requirements
of
Section
225.233. The term
of the variance
would end March 31,
2010, by
which time Baldwin
Unit 3
will be temporarily shut
down as
part
of the outage
necessary
for DM0
to install
various
pollution control equipment
on that unit. Pet.,
p.
20,
¶
34.
If DMG
is
not
timely granted
the relief sought,
then DM0
must
take a two-day outage
in spring
2009 to install
the
sorbent
injection lances
for Baldwin
Unit 3 and
have sorbent on-site
before
July 1,
2009,
in order to
comply
with
Section
225.233(c).
5
DM0
also
sought
relief from the related
monitoring,
recordkeeping, and
reporting
provisions at
Sections 225.210(b)
and (d) and
225.233(c)(5).
“The
terms
“halogenated
activated carbon”
and “sorbent”
were
used
interchangeably
in
the
Petition for
Variance and
are, likewise, used interchangeably
here.
As discussed
in the Amended
Petition, DM0
must
comply with Section
225.23 3(c)
and,
therefore,
must proceed
with
plans for
installing the sorbent
injection system
at
Baldwin
Unit 3 if
it does
not
have
a
decision
from the
Board
at
its May 7,
2009, meeting, barring
any
other relief
that
might
be
available.
Moreover,
DM0 will not inject
sorbent
at
Havana Unit
6 or
Hennepin
Unit
2 beginning
July
1, 2009,
unless
the relief requested
in the Petition
for Variance
is
granted,
as
the
compliance
date
for these
units is not until December
31, 2009.
-2-
Electronic
Filing - Received,
Clerk’s
Office, February
18, 2009
2.
To ensure there would be no
environmental
harm resulting from the
granting of
this variance, DM0 proposed to inject
sorbent at Unit
6 at
its Havana Power Station
(“Havana
Unit 6”) and at Unit
2 of
its Hennepin
Power Station
(“Hennepin
Unit 2”) approximately
six
months before required, see Section
225.23
3(c)(1)(A), at a rate of 5
lbs/macfor at the rate
necessary for these two
units
to achieve,
either individually
or averaged
together, mercury
reductions of
90%
or a mercury
emission rate
of 0.0080 lb/GWhr
6based
upon a single stack test
on
the applicable unit or units in accordance with
proposed
Sections
225.239(d)(4) and (5), (e),
and
(f)(1), assuming that those
sections are adopted
under
the Board’s Docket R09-10
substantively the same as on the date
of the filing of the Petition. Pet.
p.
20,
¶
36(A).
3.
On February
5,
2009, the Board issued an Order in this matter
identifying four
“informational
deficiencies.”
Order,
p.
1.
The Order further stated that
[b]efore this proceeding can
continue,
petitioners must
remedy these
informational deficiencies by filing an amended petition. . .
. Failure to timely
file
the
amended petition will
subject
this matter to dismissal.
See 35
Ill. Adm.
Code
104.230. The 120-day
statutory
period for the Board
to decide
this case will
recommence upon
filing of the amended petition. See 35 111. Adm.Code
1
04.232(a)(2).
Order,
p.
2. For each of
the “informational deficiencies” identified in
the Order, the Board cited
a
subsection of Section
104.204.
6
The
proposed compliance plan providing for DMG’s compliance
with
the 90%
removal
rate
or the mercury
emission rate was for purposes
of the
variance only and
was not intended
to
be
an opt-in to
the mercury emission standards of Section 225.233(d). See Pet.,
p.
21,
¶
39.
Note
that the Board’s Order contains a typographical
error and dates the Order as
February 5,
2008.
-3-
Electronic
Filing
- Received,
Clerk’s
Office, February
18, 2009
II.
THE
BOARD’S
INFORMATION
REQUESTS
DO
NOT
ESTABLISH
AN
INADEQUATE
PETITION
FOR
VARIANCE.
4.
Pursuant
to Section
104.230,
the
provisions
of Section
104.204
are essentially
jurisdictional
in nature.
That is, if
the
information
required
by
one
or more of
the subsections
of
Section
104.204
is not
included
in
the petition,
the
Board may
dismiss the
petition
for
variance
pursuant
to Section
104.230(b).
However,
the
“informational
deficiencies”
identified
by the
Board
in this matter
do not
support dismissal
and
do not
rise to the
level
ofjurisdictional
deficiencies.
Rather,
each
one
is
in the
nature of
a request
for
additional
information,
such
as
information
that
would
or could
be obtained
through
direct
or cross
examination
at
a
hearing
or
through interrogatories
or other
fact-gathering
procedures.
Certainly
any number
of questions
might
be raised
about
any
variance
petition, but
that does not
mean that
the
Petition
filed is
deficient.
None
of
the
information
requested by
the
Board
is essential
for the Board
to fairly
and
comprehensively
determine
whether
DMG’s
Petition
should
be
granted.
None
of
the
particular
information
requested
by
the Board
in
the
Order is specifically,
or in
some cases,
even
indirectly,
referenced
under
Section
104.204.
Therefore,
it is improper
for the Board
to treat
DMG’s
submittal
of this information
as an
amended
petition
(regardless
of
the
phrasing
of the
document),
thus
recommencing
the
120-day statutory
period
for
the Board
to issue its
decision in
this
matter.
A
Item 1:
Location
of
Air Quality
Monitors
Relative
to DMG’s
Power
Plants
5.
Item
1
requires
DMG to
“indicate
the nearest
monitoring
station
as well as
the
nearest
downwind
monitoring
station
maintained
by
the Agency
that
are used
for
monitoring
mercury
emissions
for
each
of
Dynegy’s
power
stations
and identify
the specific
stations by
name
and
location.”
Order,
p.
1.
DMG provided
a
map
taken from
page
34
of
the Illinois
Environmental
Protection
Agency’s
(“Agency”)
Illinois
AnnualAir
Quality Report
2006.
Pet.
-4-
Electronic
Filing
- Received,
Clerk’s
Office,
February
18,
2009
Ex. I (cited
at
Pet.
p.
2,
¶
2, footnote
2).
DMG’s
power stations
were
superimposed
upon this
map. DM0
contends
that this
map alone
is
sufficient
to satisf’
the requirements
of
Section
1
04.204(b)(2).
6.
Section
1 04.204(b)(2)
requires
identification
of
the nearest
air
monitoring
stations
“if known.”
35
Ill.Adm.Code
§
l04.204(b)(2).
Section
104.204(b)(2)
does
not require
the
identity
of
specific stations
by
name
and the
exact street
address. The
map taken
from the
2006
air quality
report
shows
the
locations
of the
Agency’s
air monitoring
stations,
which
is all that
Section
104.204(b)(2)
requires.
There
is nothing
in Section
104.204(b)(2)
to suggest
that
anything
more than
a copy
of the
Agency’s
map from
the Agency’s
annual
air quality
report is
required
if the petitioner’s
source is
identified
on that
map or
otherwise
in relation
to
that map.
7.
Moreover,
the
Agency’s
annual
air
quality reports
are
readily
available
online,
and
the map
was
properly cited.
The information
the Board
requests in
Item
1 is readily
obtainable
by the
Board
and would
not have
caused it
to expend undue
time
and effort
to
obtain
it.
8.
DM0
is, indeed,
providing
the information
requested
by
the Board
in
the
Amended
Petition filed
simultaneously
with
this
Motion
for
Reconsideration.
However,
the
information
is
taken
from
the Agency’s
2007
air
quality
report,
not available
at the
time that
the
Petition
for
Variance
was initially
filed.
Had the
Board’s
rules
been
more
specific
regarding
the
level of
detail the
Board
prefers,
DMG would
have
provided it
at the
time
that it
initially
filed
its
Petition
for Variance.
9.
For
the reasons
set forth
above,
the additional
information
requested
by
the Board
in its
Order
at
Item
I does not
rise
to the
level of
a
jurisdictional
deficiency
and is
not
a
ground
for the Board
to
dismiss
DMG’s
Petition
for Variance
or recommence
the 120-day
statutory
-5-
Electronic
Filing
- Received,
Clerk’s
Office,
February
18,
2009
period for decision.
The
map at Exhibit
1
of
DMG’s Petition
for
Variance
showed the
locations
of all
of the
Agency’s
air
monitoring
stations
and the locations
of DMG’s
power
plants,
thereby
satisfying
the
requirements
of
Section
104.204(b)(2).
B.
Item 2: Quantification
of the Amount
and
Type of
Coal Burned
at
Baldwin
Unit 3, Havana
Unit 6,
and
Hennepin
Unit
2
10.
Item
2 of the
Board’s Order
quotes
DMG’s
statement
in
its Petition
stating
that it
burns
low
sulfur coal
to control
sulfur dioxide
(“SO
2
”)
emissions
and then
requests
quantification
of
“the
amount
and type
of
coal
used
at each
power
station (Baldwin
Unit
3,
Havana
Unit
6, and Hennepin
Unit 2)
and
[whether]
that
amount
and
type
is
expected to
change
during
the
proposed
variance
period,”
citing
Section
1
04.204(b)(6).
Order,
p.
1. Again,
Item 2
asks for
supplemental
information
that
might
be
of
general
interest
to the Board,
but the
lack of
this information
does not
rise
to the
level of a deficiency
that
supports
dismissal
of the
Petition
for
Variance.
Moreover,
DMG’s Petition
for Variance
made
no
claim
of a fuel
switch or
different
coal
usage and
so
had no reason
to
even
consider
providing
such
information
in the
Petition
for Variance.
The
use
of sorbent
for
mercury
control will
not change
the rate of
coal
used
by
these
units.
II.
First,
SO
2
emissions,
to which
the
Board’s
item 2 initially
refers, are
irrelevant
to
the
Petition
for Variance.
The
pollutant
of concern
to the
Petition for
Variance is
mercury.
12.
Second,
the
“materials
used
in the process
or activity
for
which the
variance is
sought,”
35
Ill.Adm.Code
§
104.204(b)(6)
are sorbent,
not coal.
DM0
stated
in its
Petition that
it
estimates
that
it would inject
4 million
pounds
of sorbent
at
Baldwin
Unit
3 during
the
variance
period.
Pet.,
p.
13,
¶
18.
Likewise,
DM0 stated
that it expected
to
inject 2.5
million
fewer
pounds
of sorbent
in
Havana
Unit
6
and Hennepin
Unit
2 during
the variance
period.
Pet.,
p.
15.
In fact,
the
Board referred
to
these
very numbers
in
Item 4 of its
Order.
-6-
Electronic
Filing
- Received,
Clerk’s
Office,
February
18,
2009
13.
Though
the
amount of
coal burned
at these
units during
the variance
period
is
not
necessarily
germane
to the requirements
of Section
104.204(b)(6)
for
DMG’s Petition
for
Variance, the
information
is provided
in
the Petition,
though it
was
not presented
as obviously
as
the
Board apparently
prefers.
See
Pet. Ex.
6,
Table
labeled “Predictions
of
Mercury Emissions
Off-sets
for
Baldwin Unit
3,
70%
Removal”
(“Table”).
The amount
of coal
burned
in each
unit,
which
is a direct
function of
the
capacity
factor,
heat
rate, and
coal heating
value,
is
implicitly
included
in the
Table,
and one can
use
that information
to
determine
the
amounts
of
coal used for
determining
the
mercury reduction
anticipated
during
the variance
period.
Nonetheless,
for
clarity and
convenience
for the
Board,
DMG is specifying
the
amount of
coal
DMG
anticipates
will be burned
during
the variance
period
in the
Amended
Petition
filed
simultaneously
with
this
Motion for
Reconsideration.
14.
For the
reasons set
forth above,
specifically
that coal
is not
the relevant
“material[J
used in the
process
... for which
the variance
is sought,”
35 Ill.Adm.Code
§
1
04.204(b)(6),
and
because
DMG
did provide
the
Board
with both
the amounts
of sorbent
(the
relevant
“material[j
used
in the
process”) that
would
be
injected at
Baldwin Unit
3
if that
unit
were to
comply
with
Section
225.233(c)
and at
Havana Unit
6
and
Hennepin
Unit 2 during
the
variance
period
and information
from
which
the
amount of
coal can be
derived,
Item
2
of
the
Board’s
Order does
not
rise to
the
level
of a jurisdictional
deficiency and
cannot
serve as a
basis
for
dismissal
of the
Petition or
recommence
the
120-day statutory
period
for
decision.
C.
Item 3:
Additional
Mercury
Emissions
at
Baldwin
Unit
3
if the Unit
Operated
Past
March
10,
2010
15.
While
understanding
the
Board’s
confusion
that gave rise
to the question
posed
at
Item 3 in the
Order,
the additional
information
requested
does
not rise
to the
level
of a
jurisdictional
deficiency
in the
Petition
creating
a ground
for
dismissal
of the Petition.
-7-
Electronic
Filing - Received,
Clerk’s
Office, February 18, 2009
Moreover, Section
104.204(c), the section cited as
support
for the Board’s request for
information, does not require
the type of information
that
the Board requested in Item 3,
despite
the
Board’s reference to the end date on the
Table in
Exhibit 6 to the
Petition.
16.
Section
104.204(c) requires that the Petitioner provide “[djata describing
the
nature and
extent of the present or anticipated
failure
to meet the regulation. .
. from which
variance is sought and facts that support petitioner’s argument that compliance with the
regulation. .
. was not
or
cannot be achieved
by
any required compliance date.” The
Board’s
information request asks for
any
amount of mercury to be emitted in excess of
126.83 pounds
at
Baldwin Unit 3
if the unit is operated
past
March
6,
2010. The information on the Table
was
provided to demonstrate that
there would be no environmental
harm
resulting
from the
variance
and that,
in fact, DMG
estimated
there could be a net environmental benefit
resulting from its
proposed compliance plan
relative
to its operation
of Havana Unit
6
and Hennepin Unit
2.8
17.
The amount of mercury
that
could
be emitted during the term of the variance is
not part of the “extent
of the. . . anticipated failure” to
comply
because there is no
requirement
that DMG emit
only
a
certain
amount of
mercury or at a prescribed rate. The only requirement
applicable to Baldwin Unit 3
during the variance
period is
that it inject one of the named
brands
of sorbent at a
rate of
5
lb/macf through an
injection system designed
for
effective absorption of
mercury. 35
Ill.Adm.Code
§
225.233(c)(2);
see also Testimony of Jim Ross, R09-10 Tr.,
pp.
(Feb.
10, 2009). That
system was described in the Petition. See
Pet.,
p.
13,
¶
19;
see also Pet.
Ex. 5
(discussion of the
inhibitive effect
of
injection of sulfur trioxide on mercury
removal,
a
8
The
Board could view subparagraph
A
of
the compliance
plan at
¶
36
of the Petition
as
more
appropriately characterized as a
condition
of granting the variance.
However, the Board
determines the
conditions of a variance, and
DMG’s characterizing
its pfoposed
operation of
Havana Unit 6 and Hennepin Unit 2 as part of the compliance plan rather than as a
condition
to
the granting of
the variance
is also
not a ground for
dismissal of the Petition.
-8-
Electronic
Filing - Received,
Clerk’s
Office,
February 18,
2009
limitation
on the ability of Baldwin
Unit 3
to more effectively remove
mercury). The
extent of
the “anticipated
failure” is that
DMG would inject
no sorbent at
Baldwin Unit
3.
That
is
implicit
in
DMG’s
request
for the variance and
was
stated
numerous
times in the
Petition. See, e.g., Pet.
p.
20,
¶
35(A).
18.
For the reasons
set forth above,
the
Board’s
request for
additional
information
regarding
the amount of
mercury that
DMG estimates would
be emitted if
the spring 2010 outage
begins
after March
6,
2010,
does not
rise
to
the level
of a
jurisdictional
deficiency
and cannot
serve as
a
basis
for
dismissal
of the Petition or
recommence the 120-day
statutory
period
for
decision.
Because
there
is
no
requiremefit for
reduction of a
specific amount
of
mercury
and
no
mercury emission
limitation that
applies to Baldwin
Unit
3,
the amount
of mercury that would
be
emitted during
the 15 days identified
in Item
3
of the Order is irrelevant.
D.
Item
4: Amount
of
Money Saved by
Not Losing Revenue
Through an
Outage to
Install Lances
at
Baldwin Unit
3
19.
The
Board cites
DMG’s
decision
to
not
include the cost of
lost revenue (a
commercially
sensitive
issue in light of market
competition)
due
to the
outage
that would be
necessary
to install
lances for injecting sorbent
at Baldwin
Unit
3
as
a
piece of
information rising
to the
level of
ajurisdictional
deficiency
pursuant to Section
104.204(d).
However, Section
104.204(d)
does not require
a
petitioner
to
provide
explicitly
each cost of
immediate compliance.
It
does state
that a petition
ai
provide the
overall capital costs
and
annualized
capital and
operating
costs
of
immediate
compliance. Therefore,
the
additional
information that the
Board
requests
does not
rise the
level
of
a
jurisdictional deficiency,
serving as a
basis for dismissal
of
the
Petition or
recommencement of
the 120-day statutory
period
for
decision.
20.
Section
104.204(d)
requires the corresponding
costs of
compliance alternatives.
DM0
provided
those
costs,
though again apparently
not as obviously as
the Board prefers.
-9-
Electronic
Filing
- Received,
Clerk’s
Office,
February
18, 2009
There is no
compliance
alternative,
DM0
must inject
sorbent
at
a
rate of 5
lb/macf
at
Baldwin
Unit 3. There
is no other
way for
Baldwin
Unit
3 to comply
with
Section
225.233(c)(2).
Therefore,
there is no
cost associated
with
a
compliance
alternative.
21.
DM0 did
propose
to inject
sorbent
at
Havana
Unit 6
and
Hennepin
Unit
2 to
ensure
there
,ras
no environmental
harm resulting
from
the granting
of the
variance.
Item
4 of
the Board’s
Order
refers
to this
proposal
and confuses
the cost
of this
action,
not required
by
any
rule
but
offered
as an
offset
to
avoid
environmental
harm,
with the
cost
of an alternative
compliance
approach.
Injecting
sorbent at
Havana
Unit 6
and Hennepin
Unit
2 is not an
alternative
compliance
approach.
It is merely
an activity
that DM0
is
willing
to undertake
to
offset
the
mercury emissions
that
would occur
from operating
Baldwin
Unit
3
without
sorbent
injection
during
the
variance period.
22.
For the
reasons
set forth
above,
Item 4
of
the Board’s
Order
does
not request
information
that
is
required
by
Section
104.204(d).
The
information
required
by
Section
104.204(d)
was included
in the
Petition for
Variance.
Item 4 cannot
serve as
a basis
for
the
Board
to dismiss
DMG’s
Petition
or
recommence
the 120-day
statutory
period
for
decision.
III.
CONCLUSION
WHEREFORE,
for the
reasons set
forth above,
DMG asserts
that there
were no
“informational
deficiencies”
in its
Petition
for Variance
and that
the Board’s
Order
was
improper.
Therefore,
the Board’s
determination
that
the
I
20-day
statutory
period
for
it
to
issue
its
decision
regarding
DMG’s Petition
for Variance
must
recommence
was improper
as
well.
For
these
reasons,
DMG
respectfully
requests
that the Board
reconsider
its determination
that
the
-10-
Electronic Filing
- Received, Clerk’s
Office,
February
18,
2009
120-day
statutory
period
for decision
must
recommence
upon the
filing
of DMG’s
responses
to
the
Board’s
requests
for
additional
information.
Respectfully
submitted,
DYNEGY
MIDWEST
GENERATION, INC.,
by:
One
of ts
Attorneys
Dated:
February
18,
2009
Kathleen
C.
Bassi
Stephen
J. Bonebrake
SCHIFF
HARDIN,
LLP
6600 Sears
Tower
233 South
Wacker
Drive
Chicago,
Illinois
60606
312-258-5500
Fax:
312-258-2600
kbassi@schifthardin.com
—11—
Electronic
Filing - Received,
Clerk’s
Office, February
18,
2009
CERTIFICATE
OF SERVICE
I, the
undersigned, certify
that on
this
18
th
day of
February,
2009, I have served
electronically
the attached
MOTION
FOR
RECONSIDERATION
upon
the following
persons:
John
Therriault, Assistant
Clerk
Illinois
Pollution Control
Board
James
R. Thompson
Center
Suite
11-500
100 West
Randolph
Chicago,
Illinois 60601
and
by
first class mail,
postage affixed, upon:
John J.
Kim, Managing Attorney
Illinois
Environmental Protection
Agency
Division of Legal
Counsel
1021
North
Grand
Avenue,
East
P.O.
Box 19276
Springfield, Illinois
62794-9276
Kathleen C. Bassi
Stephen
J.
Bonebrake
SCHIFF
HARD1N,
LLP
6600 Sears Tower
233 South
Wacker
Drive
Chicago,
Illinois 60606
312-258-5500