BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

AMEREN ASH POND CLOSURE RULES

(HUTSONVILLE

POWER STATION) :

PROPOSED 35 TIL ADM. CODE 840.101

THROUGH 840.144

)

)

)

)

)

)

R09-21

(Rulemaking - Land)

NOTICE

John T. Therriault, Clerk

Illinois

Pollution Control Board

James R. Thompson Center

Suite

11-500

100

W. Randolph

Chicago, Illinois

60601

Matthew J. Duun, Chief

Office of the Attorney General

Environmental Bureau, North

69 West Washington St., Suite 1800

Chicago, illinois 60602

Attached Service List

Virginia

Yang

General Counsel

Illinois Dept. of Natural Resources

One Natural Resources Way

Springfield, Illinois 62702-1271

Tim Fox, Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

Suite

11-500

100

W. Randolph

Chicago, Illinois 60601

PLEASE TAKE NOTICE

that

I have today filed with the Office of the Clerk of the

Illinois Pollution Control Board the Illinois Environmental Protection Agency's Pre-Filed

Answers to Pre-Filed Questions of Prairie Rivers Network, copies of which

are

herewith served

upon you.

TAL

PROTECTION AGENCY

By;

-{~~~~~U4~~~

M kWight

Assistant Counsel

Division

of Legal Counsel

DATE: September

22, 2009

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

Electronic Filing - Received, Clerk's Office, September 22, 2009

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

AMEREN ASH POND CLOSURE RULES

(HUTSONVILLE POWER STATION) :

PROPOSED

3S ILL. ADM. CODE 840.101

THROUGH 840.144

)

)

)

)

)

)

R09-21

(Rulemaking - Land)

ILLINQJSENVIRONMENTAL PROTECTION AGENCY'S llR8-FILED ANSWERS TO

PRE-FILED OUESTIONSQF PRAIRIE RIVERS NETWORK.

Pursuant to the Hearing Officer Order entered June 30, 2009, the Illinois Environmental

Protection Agency

("Illinois EPA" or "Agency") submits the following answers to the pre-filed

questions submitted on behalf of Prairie Rivers Network ("PRN") by Traci L. Barkley, Water

Resources

Scientist. PRN's questions II through IS are directed to the Agency. The questions

and the Agency's answers are

as follows:

11.

Section 840.114 Groundwater Monitoring Program. (a) "The owner and

operator

of Ash Pond D must monitor .... : 35 III. Adm. Code 620.410(a) and

(d) except radium-226 and

radium-228." Why are these two constituents

excluded?

Based on research conducted by the United States Geological Survey ("USGS"), radium

and other radioactive elements in coal

ash are not significantly elevated above concentrations

that occur in materials found naturally in the environment. The

USGS also found that dissolved

concentrations

of these radioactive elements are below levels of health concern. Therefore, the

inclusion

of Radium 226 and Radium 228 is not warranted. This information can be found in

USGS Fact Sheet FS-163-97, October 1997, provided as Attachment I to this document.

12.

Per Section 3.135 (a)(9)(B), "CCB shall not exceed Class I Groundwater

Standards for metals when tested utilizing test method ASTM D3987-85. The

sample or samples tested shall be representative of the CCB being considered

for use." Why isn't this requirement referenced under Section 840.124?

Section 3. 13S(b) of the Act (41S ILCS S/3.13S(b» allows coal combustion waste

I

---

("CCW") to be used beneficially without meeting the metals standards established in Section

3.

I

35(a-5)(B), if the applicant demonstrates to the Agency that three criteria will be met:

I)

The use

of the CCW will not cause, threaten or allow the discharge of any contaminant into the

environment; 2) the use will otherwise protect human health and safety and the environment; and 3)

the use constitutes a legitimate use

of the CCW as a raw material that is an effective substitute for an

analogous raw material. Ameren originally proposed, in effect, that the CCB detenmnation may be

made

in this site-specific context, and the Agency has concurred with this approach. Ameren' s

Original Proposal at §

840.

I

24(c); Agency's Proposed Amendments at § 840.

I

24(d)(4).

The Agency believes the use

of CCW to create the slope for the final cover system

constitutes a legitimate use

as an effective substitnte for other fill material. The slope itself is

subject to the stability criteria

of35

TIl.

Adm. Code 811.304. The use will not result in discharge of

contaminants to the environment and will otherwise protect human health and safety because the

material will be used

in an engineered application in which it will be placed above the water table

and beneath the final cover system consisting

of a geosynthetic membrane and at least three feet of

soil material. This exceeds the standard for CCB used as structnral fill set forth in Section

3.135(a)(8)

of the Act. Once construction is complete, vegetation must be established to stabilize

the soil layer. The final cover system is subject

to the inspection and maintenance requirements set

forth in Section 840.136. Therefore, the three statutory criteria will be satisfied. The Agency

believes this approach is in substantial compliance with the requirements

of the Act.

13.

Why doesn't the additional use of coal combustion byproduct require an

independent approval pursuant to Section 3.135 of the Act, according to

IEPA's suggested edits to Section 840.124?

Please

see the response to Question 12.

14.

We appreciate [Mr. Nightingale's] request on behalf of the Agency for a

moratorium on additional site-specific rules for closure of coal combustion

2

---

waste surface impoundments. Can you tell us why, given the fact that new

federal rules regarding the management

of coal combustion wastes are likely

forthcoming, the Agency

is not requesting that Ameren's Hutsonville Pond D

activities also be placed on hold?

As stated in Mr. Nightingale's testimony, the Agency has requested that the Pollution

Control Board

("Board") consider a moratorium on proceeding with additional proposals for site-

specific closures

of CCW surface impoundments pending clarification of widely anticipated

federal rules for the management

of CCW and their effect, if any, on the closure of existing

CCW impoundments. If federal rules do not address the closure of existing ash ponds, it may be

appropriate to proceed with a generally applicable rule for ash ponds

in Illinois. The reason the

Agency

has not requested that Ameren's proposal be included within a moratorium is that

Ameren filed its proposal with the Board and

it

was accepted for hearing before the Agency

clarified its

0\\'Il

position on the matter. The Agency's position initially arose out of its

difficulties in finding the resources to assemble a workgroup to respond to Ameren's proposal.

Ameren took Ash Pond D out

of service in 2000 and has pursued closure intermittently

since that time. The absence

of clearly applicable closure requirements along with

disagreements between Ameren and the Agency conceruing the proper approach have been the

causes

of significant delays. The interaction between Ameren and the Agency ultimately

resulted

in the adjusted standard proceeding filed by Ameren in August 2008.

In the Maller of:

Petition

of Ameren Energy Generating Company for Adjusted Standards from

35

Ill. Adm. Code

Parts

811,814,815, PCB AS 09-1 (March 5, 2009). The Board found the landfill rules

inapplicable to surface impoundments and dismissed the adjusted standard proceeding.

It

directed Arneren to file a site-specific rule if

it

wished to pursue the matter.

After the dismissal

of its proposed adjusted standard, 'Ameren moved very quickly to

prepare and file its proposal in this proceeding because

of its stated desire to sell the facility.

3

---

During this short interval, the Agency did not fully consider the implications of the site-specific

approach

as complicated by the number of similar sites needing closure, the uncertain impacts of

state budget/resource issues, and the additional uncertainty of the outcome of the federal review

ofCCW management. The Agency's decision

to request the moratorium did not come until well

after the proposal had been filed with the Board and accepted. While the policy reasons for the

moratorium are compelling, the

legal gmunds for taking such action with regard to future filings

are uncertain. Requesting that a moratorium apply

so that a previously docketed proceeding

would

be delayed indefinitely or dismissed would raise additional legal issues of retroactivity

and

was never seriously considered by the Agency.

To be clear, the Agency does not object to the site-specific approach itself as a

mechanism

for developing acceptable closure requirements for individual ash ponds. The

Agency believes that will

be accomplished in this proceeding with appropriate amendments to

Ameren's original proposal. Rather, the request for a moratorium is driven by the prospect of70

or more of these proceedings, especially in light of the resource issues and the potential for

conflicts with decisions

to be made at the federal level. Moreover, devoting scarce resources to

the

task of developing and promulgating a statewide rule would be wasteful if the proposal

expected later this

fall makes clear the U.S. EPA intends to regulate this activity pursuant to

federal law.

15.

IfUSEPA redetermines coal combustion waste to be "hazardous" in nature

per

ReRA,

would Subchapter c, Part 724 regulations governing standards

for hazardous waste treatment, storage and disposal facilities

be sufficient to

govern the closure of Ameren's Hutsonville Pond D?

With all due respect, the federal approach suggested by the question is beyond the

scope

of this proceeding, and the Agency workgroup has not evaluated its sufficiency.

Further, the Agency has

no knowledge of the U.S. EPA's intentions beyond published

4

Electronic Filing - Received, Clerk's Office, September 22, 2009

---

speculation and has made no formal

~valuation

of such an approach. The Agency

expects that any federal proposal will be published for comment in the

Federal Register.

If

so, the Agency will very likely perform an evaluation of the proposal at that time and

submit comments in that forum.

5

---

ATTACHMENT 1

October, 1997

Radioactive Elements in Coal and Fly Ash:

Abundance, Forms, and Environmental

Significance

The entire Fact Sheet

FS-163-9Z

can be downloaded and viewed with Adobe Acrobat

Reader.

If you do not already have Acrobat Reader, you may download Adobe Acrobat

Reader from this site.

Introduction

Coal Is largely composed of organic matter, but It is the inorganic matter in coal-

minerals and trace elements- that have been cited as possible causes of health,

enVironmental,

and technological problems associated with the use of coal. Some trace

elements in coal are

naturally radioactive. These radioactive elements include uranium (U),

thorium (Th), and their numerous decay products, including radium (Ra) and radon (Rn).

Although these elements are

less chemically toxic than other coal constituents such as

arsenic, selenium, or mercury, questions have been raised concerning possible risk from

radiation.

In order to accurately address these questions and to predict the mobility of

radioactive elements during the coal fuel-cycle, it is important to determine the

concentration, distribution, and form

of radioactive elements in coal and fly ash.

Abundance of Radioactive Elements in Coal and Fly Ash

Assessment of the radiation exposure from coal burning is critically dependent on the

concentration

of radioactive elements in coal and in the fly ash that remains after

combustion. Data

for uranium and thorium content in coal is available from the u.s.

Geological Survey (USGS), which maintains the largest database of infor-mation on the

chemical composition

of U.S. coal. This database is searchable on the World Wide Web at:

http://energy.er.usgs.gov/Droducts/databases/ CoaIOuaJ/intro.htm. Figure 1

displays the frequency distribution

of uranium concentration for approximately 2,000 coal

samples from the Western United States and approximately

300 coals from the Illinois

Basin. In the majority

of samples, concentrations of uranium fall in the range from slightly

below 1 to 4 parts per million (ppm). Similar uranium concentrations are found

in a variety

of common rocks and soils, as indicated in figure 2. Coals with more than 20 ppm uranium

are rare in the United States. Thorium concentrations in coal

fall within a similar

1-4

ppm

range, compared to an average crustal abundance of approximately 10 ppm. Coals with

more than

20 ppm thorium are extremely rare.

During coal combustion most

of the uranium, thorium, and their decay products are

released from the original coal

matrix and are distributed between the gas phase and solid

combustion products.

7

Electronic Filing - Received, Clerk's Office, September 22, 2009

---

10.

IIUnols Basin

nllnnnnn

n

...

I:

~

54C

0 ...

Il

"300

I

.,

100

Westem Untted States

-

r-

.,

,':1J

lr

IU) Po')

foI,Gt

~

(J5..'l (J',q [t.1lJ(Q.J;'l.'(I1,

4f(l,

~J,

1(1")(.111."

~'!

URANUAtCOllfCl!NT'RA

~

rrt

~

c;cw.. <PPfA.l

Figure 1. Distribution of uranium concentration in coal from two areas of the

United States.

.... _ ... - U.S. 0001.

__ - -OrJmltlcfOd<

___ - Aya;h= 10. t.ts."",I,

__ - -

- Blo::k .h,l""

___ - ., Phcspha'E rod

!

"!

',,!I'

!!! "lIl'

. 0,,,.1 '!

II" {

0.1

1D

10

10J

1000

URANIUM CONCENTRATION (ppm)

The partitioning between gas and solid is

controlled by the

volatility and chemistry of

the individual elements. Virtually 100

percent of the radon gas present in feed

coal is transferred

to the gas phase and is

lost in stack emissions.

In con-trast, less

volatile elements such as

thorium, uranium,

and the majority of their decay products are

almost

entirely retained in the solid

combustion wastes. Modern

power plants

can recover greater than 99.5 percent of the

solid combustion wastes. The average ash

yield

of coal burned in the United States is

approximately 10 weight percent. Therefore,

the concentration

of most radioactive

'--__________________ elements in solid combustion wastes will be

Figur<

2.

T,.lIir.1

ran~.

ofuFlmitlDl

com:mlmtion

in ooal.

fly

approximately 10 times the concentration in

ash,a.da,..ril'tyorcommonroclis.

the original coal. Figure 2 illustrates that the

uranium concentration of most fly ash (10 to 30 ppm) is still in the range found in some

granitic rocks, phosphate rocks, and shales. For example, the Chattanooga Shale that

occurs in a large portion of the Southeastern United States contains between 10 and 85

ppm U.

Forms of Occurrence of Radioactive Elements in Coal and Fly Ash

The USGS has a current research project to investigate the distribution and modes of

occurrence (chemical form) of trace elements in coal and coal combustion products. The

approach typically involves

(1) ultra sensitive chemical or radiometric analyses of particles

separated on the basis of size, density, mineral

or magnetic properties, (2) analysis of

chemical extracts that selectively attack certain components of coal or fly ash, (3) direct

observation and microbeam analysis

of very small areas or grains, and (4) radiographic

techniques

that identify the location and abundance of radioactive elements.

Most

thorium in coal is contained in common phosphate minerals such as monazite or

apatite. In contrast, uranium is found in both the mineral and organic fractions of coal.

Some uranium

may be added slowly over geologic time because organic matter can extract

dissolved uranium from ground water. In fly ash, the uranium is more concentrated in the

finer sized particles. If during coal combustion some uranium is concentrated on ash

surfaces as a condensate,

then this surface-bound uranium is potentially more susceptible

8

---

to leaching. However, no obvious evidence of surface enrichment of uranium has been

found

in the hundreds of fly ash particles

r-________________

--,examined

by USGS researchers.

he above observation is based on the use

of fission-track radiography, a

sophisticated technique for observing the

distribution

of uranium in particles as small

as

0.001

centimeter in diameter. Figure 3

includes a photograph

of a hollow glassy

phere of fly ash

and Its corresponding

Ission track image. The diameter of this

relatively large glassy sphere

is

approximately

0.01

em. The distribution

and concentration of uranium are indicated

by fission tracks, which appear

as dark

linear features in the radiograph. Additional

images produced by

USGS researchers

!:Fi;-gl1-"'~J.-:P=b-.I:-.-gra-.,Jll;-,

(1~e~fl~);-.f:-.-:h~."!:I1;-""-·

-:gW"'-')-~'

"ny-a-•

.,.h-Jl-al~1i:-:tI~e......lfrom

a variety of fly ash particles confirm

(0.01 .. "

Ilia .... , ... )

lIu4

ils IiL.I ...

h .. fkradlograph (right).

the preferential location of uranium within

VrAlllum dislriburi .... a"d Conttllll'lliiolt are Inlliealtd

by

the glassy component of fly ash particles.

Ihel •• ali"" ... ,,1 ""'"ily or dorllllnelll' n"i.n Ira<"" in lilt

rodiog ... ph.

Impact of Radioactive Elements Associated With Coal Utilization

Radioactive elements from coal and fly ash may come in contact with the general public

when they

are dispersed in air and water or are included in commercial products that

contain fly ash.

.

The radiation hazard from airborne emissions

of coal-fired power plants was evaluated in

a series of studies conducted from

1975-1985.

These studies concluded that the maximum

radiation dose to an individual living within

1 km of a modern power plant Is equivalent to a

minor, perhaps

1

to

5

percent, increase above the radiation from the natural environment.

For the average citizen, the radiation dose

from coal burning is considerably less.

Components of the radiation environment

that impact the U.S. population are illustrated in

figure 4. Natural sources account

for the majority (82 percent) of radiation. Man-made

sources of radiation are dominated by medical

X-rays (11 percent). On this plot, the

average population dose attributed to coal burning is included under the consumer products

category and

is much less than 1 percent of the total dose.

Fly ash is commonly used as an additive to concrete building products, but the

radioactivity

of typical fly ash is not significantly different from that of more conventional

concrete additives

or other build-Ing materials such as granite or red brick. One extreme

calculation

that assumed high proportions of fly-ash-rich concrete in a residence suggested

a dose enhancement, compared to normal concrete,

of 3 percent of the natural

environmental radiation.

Another consideration

is that low-density, f1y-ash-rich concrete products may be a

source

of radon gas. Direct measurement of this contribution to Indoor radon is complicated

by the much larger contribution from underlying soil and

rock (see fig. 4). The emanation of

radon gas from fly ash is less than from natural soil of similar uranium content. Present

calculations indicate

that concrete building products of all types contribute less than

10

. percent of the total indoor radon.

9

---

Approximately three-fourths of the annual

production of fly ash is destined for disposal in

engineered surface impoundments and landfills, or in

abandoned mines and quarries. The primary

environmental concern associated

with these disposal

=:c..=r0n.Ee.",sites is the potential for groundwater contamination.

Fi~ur'C

4. Pt:rtent.;J5!C (:ontrihution

{If

ynrlou" rndilltion

!I;.llJ't\.";'oi

to the- tot;LI

,lu"t'rft2C r:ulhltioD

dO!ii~

In lhc U.S. J'tOpulatioo ..

Standardized tests of the leachability of toxic trace

elements such as arsenic, selenium, lead, and mercury

from fly ash show that the amounts dissolved are

sufficiently low to justify regulatory classification of fly

ash as nonhazardous solid waste. Maximum allowable

concentrations under these standardized tests are

100

times drinking water standards, but these concentration

limits are rarely approached in leachates

of fly ash.

The leachability of radioactive elements from fly ash

has relevance in view of the U.S. Environmental

Protection Agency (USEPA) drinking

water standard for dissolved radium (5 picocuries per

liter) and the proposed addition of drinking water standards for uranium and radon by the

year

2000.

Previous studies of radioelement mobility in the enviroment, and in particular, in

the vicinity of uranium mines and mills, provide a basis for predicting which chemical

conditions are likely

to influence leachability of uranium, barium (a chemical analog for

radium), and thorium from fly ash. For example, leachability of radioactive elements is

critically influenced by

the pH that results from reaction of water with fly ash. Extremes of

either acidity (pH<4) or alkalinity (pH>8) can enhance solubility of radioactive elements.

Acidic solutions attack a

variety of mineral phases that are found in fly ash. However,

neutralization of acid solutions by subsequent reaction with natural rock or soil promotes

precipitation or sorption of many dissolved elements including uranium, thorium, and many

of their decay products. Highly alkaline solutions promote dissolution of the glassy

components of fly ash that are an identified host of uranium; this can, in particular, increase

uranium solubility

as uranium-carbonate species. Fortunately, most leachates of fly ash are

rich in dissolved sulfate, and

this minimizes the solubility of barium (and radium), which

form highly insoluble sulfates.

Direct measurements

of dissolved uranium and radium in water that has contacted fly

ash are limited to a small number of laboratory leaching studies, including some by'USGS

researchers, and sparse data for natural water near some ash disposal sites. These

preliminary results indicate

that concentrations are typically below the current drinking

water standard for radium (5 picocuries per liter) or the initially proposed drinking water

standard for uranium of

20

parts per billion (ppb).

Summary

Radioactive elements in coal and fly ash should not be sources of alarm. The vast

majority of coal and the majority of fly ash are not significantly enriched in radioactive

elements,

or in associated radioactivity, compa red to common soils or rocks. This

observation provides a useful geologic perspective for addressing societal concerns

regarding possible radiation and radon hazard.

The location and

form of radioactive elements in fly ash determine the availability of

elements for leaching during ash utilization or disposal. Existing measurements of uranium

distribution in fly ash particles indicate a uniform distribution of uranium throughout the

glassy particles. The apparent absence of abundant, surface-bound, relatively available

uranium suggests that the rate of release of uranium is dominantly controlled by the

relatively slow dissolution of host ash particles.

Previous studies of dissolved radioelements in the environment, and existing knowledge

of the chemical properties of uranium and radium' can be used to predict the most important

10

---

chemical controls, such 'as pH, on solubility of uranium and radium when fly ash interacts

with water. Limited measurements

of dissolved uranium and radium in water leachates of

fly ash and in natural water from some ash disposal sites indicate that dissolved

concentrations

of these radioactive elements are below levels of human health concern.

Suggested Reading:

Tadmore, J.,

1986,

Radioactivity from coal-fired power plants: A review: Journal of

Environmental Radioactivity, v.

4,

p.

177-204.

Cothern, C.R., and Smith, J.E., Jr.,

1987,

Environmental Radon: New York, Plenum Press,

363 p.

Ionizing radiation exposure of the population of the United States,

1987:

Bethesda, Md.,

National

CounCil on Radiation Protection and Measurements, Report

93, 87

p.

Swaine, D.l.,

1990,

Trace Elements in Coal: London, Butterworths,

278

p.

Swaine, D.l., and Goodarzi, F.,

1997,

Environmental Aspects of Trace Elements in Coal:

Dordrecht, Kluwer Academic

Publishers,

312

p.

For more information please contact:

Dr. Robert A. Zielinski, U.S.

Geological Survey

Denver Federal Center, Mail Stop

973

Denver, Colorado

80225

(303) 236-4719;

e-mail:

rzlelinski@usgs.gov

Dr. Robert

B. Finkelman, U.S.

Geological Survey

National Center, Mail Stop

956

12201

Sunrise Valley Drive,

Reston,

VA

20192

703-648-6412;

e-mail:

rbf@usgs.gov

Accessibilit FOIA Privac Policies and Notices

r:~m~[!J~~·92lf,,"1u.s.

Department of the Interior I U.S. Geological Survey

URL:

http://pubs.usgs.gov/fs/1997/fs163-97/FS-163-97.html

Page Contact: Energy Program Inquiries

Website Assistance:

USGS Publications Team

Last modified: Monday, 31-Dec-2007

14:20;29

EST

11

Electronic Filing - Received, Clerk's Office, September 22, 2009

---

STATE OF ILLINOIS

)

)

COUNTY OF SANGAMON

)

PROOF OF SERVICE

I, the undersigned, on oath state that I have served the attached Illinois

Environmental Protection Agency's Pre-Filed Answers to Pre-Filed Ouestions of Prairie

Rivers Network, upon the persons to whom they are directed,

by procedures specified by

the Illinois Pollution Control Board or by placing a copy of each in an envelope

addressed to:

John

T. Therriault, Clerk

IlIinois Pollution Control Board

James R. Thompson Center

Suite

11-500

100

W. Randolph

Chicago, Dlinois

6060

I

(Electronic Filing)

Matthew J. Dunn, Chief

Office of the Attorney General

Environmental Bureau, North

69 West Washington St., Suite

1800

Chicago, Illinois 60602

(First Class Mail)

(Attached Service List - First Class Mail)

Virginia

Yang

General Counsel

Illinois Dept.

of Natural Resources

One Natural Resources

Way

Springfield, Illinois 62702-1271

(First Class Mail)

Tim Fox, Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

Suite

11-500

100

W. Randolph

Chicago, lllinois

60601

(Electronic ming)

and sending or mailing them, as applicable, from Springfield, Illinois on September 22,

2009, and with sufficient postage affixed as indicate above.

SUBSCRffiED AND SWORN TO BEFORE ME

---

Joshua R. More

Schiff Hardin,

LLP

6600 Sears Tower

233 South Wacker Drive

Chicago,

IL 60606-6473

Kathleen C. Bassi

Schiff Hardin,

LLP

6600 Sears Tower

233 South Wacker Drive

Chicago,

IL 60606-6473

Amy Antoniolli

Schiff Hardin,

LLP

6600 Sears Tower

233 South Wacker Drive

Chicago,

IL 60606-6473

Tracy Barkley

Prairie

Rivers Network

1902 Fox Drive, Suite G

Champaign,

IL 61820

Kyle Nash Davis

!EPA

SERVICE LIST FOR PCB R2009-21

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

John Kim

!EPA

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Electronic Filing - Received, Clerk's Office, September 22, 2009