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### CHICAGO 8-HOUR OZONE ATTAINMENT DEMONSTRATION AND REDESIGNATION REQUEST ILLINOIS ENVIRONMENTAL PROTECTION AGENCY PUBLIC HEARING FOR STATE IMPLEMENTATION PLAN SUBMITTALS FOR CHICAGO OZONE NONATTAINMENT AREA

December 16, 2008 9:05 a.m. 100 West Randolph Room 9-031 Chicago, Illinois

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McCorkle Court Reporters,•• In.c•................................. Chicago, Illinois (312). • ATTACHMENT 4

### 1 ATTENDEES:

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### 11 12 13 14 15 16 17 18 19 20 21 22 23 24 

### MS. DANA VETTERHOFFER Hearing Officer



### MR. JEFFREY SPRAGUE MR. ROBERT J. KALEEL

MS. RACHEL DOCTORS MS. PAMELA BROOKS

MR. MIKE ROGERS MR. SCOTT LEOPOLD MR. DAVID ASSELMEIR MR. BRIAN URBASZEWSKI MR. ERIC MELVIN MR. CHRIS DEMEDOURAS MR. ALEC DAVIS MR. BOB ELVERT MR. BILL CONSTAUTELOS MR. SCOTT MILLER MR. ROSS PATRONSKY

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 2 "

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### 1 HEARING OFFICER VETTERHOFFER: It's about 9:05, 2 so if everybody is ready, we will get started and 3 we can go on the record. I

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### Good morning. My name is Dana 5 Vetterhoffer and I work for the Illinois 6 

### Environmental Protection Agency. I want to thank I 

### 7 everyone for coming today. I've been designated to 8 

### serve as the Hearing Officer in this matter. As 9 the Hearing Officer, my sole responsibility is to 10 make sure this proceeding runs properly and in 11 accordance with the rules. 12 This is a public hearing before the 13 Illinois EPA for the purpose of gathering public 14 comments related to the 1997 8-hour National 15 Ambient Air Quality Standards, or NAAQS. 16 First, the Illinois EPA is seeking 1 Ii 

### 17 comments on the draft attainment demonstration 18 which contains the state's plan for attaining the 19 state's planned 8-hour ozone maximum. IIIinois EPA I, I' I 

### 20 intends to request that the United States EPA 21 redesignate 1997**bas~d** 

### on ambient monitoring data 22 from 2006 through 2008. 23 Second, the Illinois EPA is seeking 24 comments on the draft maintenance plan, which 3

. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052Copies of these procedures can be obtained from me •• 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 b, 22 23 24 contains the state's plan for maintaining the 8-hour ozone maximum for at least ten years after the US EPA redesignates the area to attainment. Both documents contain the new motor vehicle emission budget. The Illinois EPA proposes to submit these to meet the requirements of the federal Clean Air Act. This hearing will satisfy the requirements of Section 1-10-L of the Clean Air Act, codified at 42 United**State~Code** 74-10-L. Finally, at the conclusion of the discussion regarding the two sets of material, we will conclude the hearing and then the Illinois EPA will then take comments off the record regarding establishing boundary for the nonattainment areas to be established pursuant to the 2008 ozone maximum protection. It's now approximately 9:07 on December 16, 2008. This public hearing is being held under the Illinois Supreme Court procedure for hearing for informational and quasi-public legislative hearings, which can be found at Illinois 3635.

upon request, or they can be accessed on the website of the Illinois Pollution Control Board. I

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McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 That website is www.ipcb.state.il.us. Public 2 hearing means this is strictly an informative 3 hearing and an opportunity for Illinois EPA to 4 provide information. And it's also an opportunity 5 for you to provide information to the Illinois 6 EPA. This is not a contested hearing. 7 

### I would like to explain briefly how 8 today's hearing is going to proceed. First, we**~9** 

### will hear from the Illinois EPA staff members 10 present today to present themselves, and each is 11 going to give a brief slide show presentation. 12 Following the presentation I will ask the public 13 for comments. You are not required to comment at 14 this hearing. Written comments maybe submitted to 15 the agency at any time within the public comment 16 period, which ends at midnight on January 15, 2009. 17 Any person who wants to make oral 18 comments may do so as long as the issues are 19 relevant. If you have lengthy comments or 20 questions it may be helpful to submit them to me in 21 writing before the close of the comment period. 22 All speakers will have the opportunity to direct 23-- questions to the Illinois EPA panel, or they can 24 just make general comments, or they can do both.

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 5 I1 Our panel members will make an effort to address 2 your comments, but I will not permit or allow 3 anyone to engage in long dialog with our panel. 4 Also, there is a sign-in sheet at the 5 entrance to the room. If you haven't signed in 6 already, if you can do so, that would be great. 7 The Illinois EPA following this hearing 8 will prepare a response of this summary, which will -9 be available on its website. In the response 10 summary the agency will attempt to answer all the 11 relevant and significant questions raised at that 12 hearing or submitted to me prior to the close of 13 the comment period. 14 Again, the written record of this matter 15 will close on January 15, 2009. Therefore, I will 16 accept all written comments as long as they're I

17 18 19 20 21 postmarked by midnight on that date. Please send all written documents or data to my attention at the following address. Dana Vetterhoffer, Hearing Officer, at the Illinois Environmental Protection Agency, 1021 North Grand I Ie

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22 Avenue East, P.O. Box 19276, Springfield, Illinois. 23 For anyone wishing**t~make** comments or 24 request questions, I want to remind you that we 6

. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 I

### 1 have a court reporter here to take a verbatim 2 record of these proceedings for the purpose of 3 4 

### making our administrative record. For her benefit please keep the general background noise to a I I' I I' 

### 5 minimum, which I don't think will be a problem 6 7 8 

### today. Also, please remember that the court reporter can only record one person speaking at a I,



### -- " 9 time, so please try not to speak over-one another. 10 When it's your turn to speak, please state your 11 name, spell your last name, and if applicable, 12 state any governmental body, organization, or 13 14 

### society that you represent. Please speak clearly and slowly so that the court reporter can I' 1\ I 

### 15 understand what you are saying. 16 Before we start the Illinois EPA's 17, 

### presentation, I would like to record a number of 18 preliminary documents into the record as Exhibits. 19 I would like to record as Exhibit No.1 a copy of 20 the notice of public hearing. Exhibit No.2 is a 21 copy of the Illinois EPA's attainment 22 demonstration, including two appendices. And 23

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### Exhibit 3 

### is a copy of the maintenance plan. , I

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### The agency's slide presentation will be 1% 7 I:

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052I MR. ASSELMEIR: My name is David Asselmeir, I I' the Illinois EPA, air quality planning section. I

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I· My name is Mike Rogers, I'm in the MR. ROGERS:

MR. LEOPOLD: My name is Scott Leopold, with MS. BROOKS: My name is Pamela Brooks, I'm in MS. DOCTOR: My name is Rachel Doctors, I'm an cMRc,KAI:EEL: My name is Robert Kaleel, I'm a

MR. SPRAGUE: My name is Jeffrey Sprague, I'm a Now I will ask that the Illinois EPA

MR. KALEEL: Shall we start? manager of the air quality planning section.

unit manager for the IIIinois EPA>-,· make their presentations. Exhibit 4. Although we don't have a copy of the

inventory and data support unit. go by "Buzz," and I am the unit manager for the division of mobile source programs. attorney within the division of legal counsel. actual slides today, they will be posted on the

the Bureau of Air, air quality planning section. also request that as well. wishes to get a copy of the Exhibits from me can agency's website probably by weekend. Anyone who

staff present today to introduce themselves and 1 2 3 4 5 6 7 8

.- .- 9 10 11 12 13 14 15 16 17 18 19 20 21 f!, 22 23 24

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-- . McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 HEARING OFFICER VETTERHOFFER: Yes. 2 MR. KALEEL: We'll go ahead and start our Power 3 Point show. We will make these Power Point slides 4 available on our website as soon as we get back to 5 Springfield. And maybe we ought to dim the lights 6 a little bit. 7 It's going to be one of these rare 8 meetings where I don't talk much. You can hold me

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### to that.

- 10 Dana covered this already in her 11 introductory remarks, but what we are presenting 12 today is the attainment demonstration for 8-hour 13 ozone. I just wanted to make a few remarks about 14 what that includes. It includes a model attainment 15 16 17 18 19 ,- 

### demonstration, a photo chemical modeling exercise, including a listing of the control measures that we

are relying upon in our attainment demonstration to attain the standard. I; 

### There is a section on transportation 20 conformity as required by the Clean Air Act. There I 

### 21 is a discussion of the base year 2002 emissions 22

_inventory, another Clean Air Act requirement. That '·23 

### inventory document, by the way,was submitted I

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### 24 believe in 2004 to US EPA. So it's long been part I 9 Ii

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052I area qualifies for redesignation to attainment of t the 8-hour ozone standard. This is the 1997 ozone

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, .' When we got nonattainment areas So with that, I will turn it over to

MR. LEOPOLD: Good morning. My name is Scott maintenance plan. We will be discussing that also.

photochemical modeler on staff. There is a reasonable further progress,

Leopold. I'm with the Illinois Environmental And a discussion of reasonably available control

And finally, as Dana had mentioned, the Chicago

designated in Illinois for the 1997 8-hour ozone redesignation request is a submittal of a

Protection Agency and I am now the only or RFP, demonstration that we'll discuss today.

technology as it is required by the Clean Air Act.

area, as well as nonattainment counties in nearby attainment demonstration. And indeed, we have a of US EPA's record of our attainment demonstration.

Scott Leopold who will talk about the model attainment demonstration.

standard, we suddenly needed to produce an standard, One of the requirementsfor'a

··number of nonattainment counties,jn theGhicago 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 fI, 22 23 24

" McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052meteorology through the summer. We have used

-- we I,

talk about here shortly, we developed both a base I'; 11 Ii; 1 2 3 4 5 6 7 8 -,,,-,,', 9 10 11 12 13 14 15 16 17 18 19 20 21 22**'~23** 24 states. Part of my duties as a photochemical modeler with the Illinois EPA is to participate and contribute also in the LADCO, the Lake Michigan Air Directors Consortium. And the other states participating in that group also have photochemical modelers, and we pool our resources to produce more data and more analyses. In the process of modeling we use -- the US EPA requires that we use a couple-of-different models. They are very complex models for emissions, for meteorology, and for the actual photochemistry. Ozone is not actually emitted, it is produced by photochemical reactions. So we have to have a model that is complex enough to understand how to do that. And I'm not familiar with this slide quite yet, so -- there are steps that we use to do this. We go through development of a meteorological data set which reflects actual

produced both 2002 meteorology and 2005 meteorology.And inventory-wise, which Jeff will I

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McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052, the Atlantic Ocean to the east. We focus in with a

the Rockies all the way to the east coast, and then

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,- 12 MR. SPRAGUE: As I introduced myself I think that's you. midwestern area, up into even the southern region modeling most of the eastern half of the country, The photochemical modeling grid nests Michigan basin. 0 As an example, the MM5, which is the

have used a 4 kilometer grid, the finest grid in

of Canada. inside the meteorological modeling grid, but it'smeteorological model we use, the modeling goes all

still very substantial. At 36 kilometers we are

and at 12 kilometers we are monitoring all of the most of the eastern half of the United States.

the areas of prime interest, which are in the Lake ; locally and transported. So our data sets cover recognized decades ago that ozone is both formed

smaller grid, a 12 kilometer grid spacing east of these inventories and meteorological data sets

cover a very wide spatial area, because we year inventory and a future year inventory. And

-th-e 'way"Out'in the Pacific Ocean to the west and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 ( 22 23- 24

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8

";' 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 previously, my name is Jeff Sprague and I'm the modeling unit manager in the air quality planning section. Fundamentally, with respect to ozone SIP modeling, we need to develop a base year inventory. And this is for two purposes: for model validation; and secondly, for having a foundation from which to project future year emissions. Now, US EPA in their mod-el:inggui'da-nce recommends a 2002 inventory, but they also provide for alternate base years. In the case of the Chicago SIP demonstration, what we have done, of

course, is we've gone and actually produced base years, two base year inventories; one for 2002 and

one for 2005. The reason being that coordinating the two, we felt that it just enhanced the overall assessment we were undertaking. Now, there is a great many people and a great many entities that have contributed to developing the base year inventory, as well as the future year inventories of course. The states, as f!, indicated under the second bullet point there, have provided the various data elements to the base year inventory. And under the third bullet point there,13

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 I

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,1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 the Lake Michigan Air Directors Consortium, the various contractors that they have hired, have contributed emission estimates for the various

source sectors that are identified there. One element that is missing is the nonroad component, other than airports, rail and commercial, which was largely provided by the State of Wisconsin.

_'.0 :;:,Lastly, there are variaus tools which we

use to implement this processing. The primary ones being EMS and CONCEPT, which are the acronyms for two emission models. And then there are various software tools that we used to generate sub-portions of the inventory prior to processing the whole inventory through those two emission models. When we look at the base year inventory, keep in mind again we said we generated one for 2002, we also generated one for 2005. The bar histogram you see here were extracted from the TSD document, which supports our scenario. And the topmost portion of this diagram breaks out the I:

-2'3 "'average emiss·tons for the five stateLADCO region 24 for each of the individual states. So you have a 14

. '.' McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052I

breaks it out on a source sector basis. So we are likewise, for the bottom one, vae on the left and

The bottom portion of t-hat diagram portion is for NOx emissions.

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### Ii If you look on the vae side, you can

What is not easily extractable from this

So again, basecase 2002 and 2005 for

marine, airports and rail, and lastly for area Nax on the right.

EGUs, which is an acronym for electrical generating units, for non-EGUs, which are point sources other

are. And if you look at what I've included in the 0 15 And in the case of NOx, we have the on-road sector

as predominating. emissions, non-road emissions, plus commercial, than electrical generating units. On-road

see that area source emissions dominate for voe. I see. This portion is for vae emissions, and this

vae on the left and for NOx on the right. And

seeing here, well, how much is being contributed by general feel there for what each state was contributing. And this got chopped off at the top

diagram is, is what the Illinois'contributions--c'" -emissions. 1 2 3 4 5 6 7 8

--7.' 9 10 11 12 13 14 15 16 17 18 19 20 21 22 c-",2<l

.:' .,.,' '-'-"- 24

. .. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 parentheses here, for VOC for the 2002 base year we 2 are looking at 1681 tons per summer weekday for 3 2002. And then for 2005 we are looking at 1576. 4 And as you read down a little bit further, for NOx 5 we are looking at 2621 tons per summer weekday for 6 2002, and 2010 for 2005. 7 The subheads under there provide 8 breakouts which are not discernible from the bar -9 ---hislogr-ams, but give you a feel forjust what the 10 tonnages are when we looked at individual sectors 11 for Illinois alone. 12 The emission modeling, the emission I 13 process, is just a way of taking an inventory and 14 essentially ratcheting it down, resolving it to the 15 level needed by the air quality simulation model. 16 And there is a slight distinction. True emissions 17 modeling will generate emission estimates from what I

I 18 are called first principles. These are the 19 fundamental calculations that you would undertake, 20 but the model actually does it, to produce emission 21 estimates. For emissions processing what we are 22 doing is we are really taking the estimates and

--- ·'-23**-~** then, as I ;ndicated, resolving:::them down to the 24 level that is needed for the air quality model. 16

'" , " McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8

;" '"9 10 11 12 13 14 15 16 17 18 19 20 21 22 '·'·,:...2-3c··' 24

........ But perhaps of greatest importance is what our emissions modeling, emissions processing software is doing. And again, those are the two tools referred to as EMS and CONCEPT. And what they're doing is they are going through and spatially allocating emissions. So we have point sources and we have coordinates, we place them in the grid cells we need. If we have area source emiss;ons., wS"';:have to rely on something called spatial surrogates to allocate county level emissions to the individual grid cells. The same applies for non-road. So it's just a way of putting emissions where they need to go. Temporal allocation allows us to account for the variability on a day-of-the-week basis or an hour-of-the-day basis. And then lastly, speciation takes these, a complex grouping, in the case of VOCs organic compounds, to a much

more simplified group of species that the air quality model can in turn-handle. it, Throughout the process of doing em'i;ssions processing, there isquaTity**assurance~'** checks that are intrinsic to the model so that 17

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 I

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I1 warning and air messages may be generated 2 indicating where there is data missing, where data 3 may be out of bounds, any of a host of potential 4- 5 6 problems that may generate these messages. But the inventory as it's being processed undergoes truly a thorough quality F

1 7 assurance to demonstrate indeed that any potential 8 errors are being removed. And with the 9 - ""tdent4-:ftcation of corrections,

-of-c·course, you make 10 adjustments to the inventory and it truly becomes 11 an iterative process where you make the corrections 12 or you make improvements to the inventory, you I 13 reprocess and provide new data sets for the air 14 quality model. 15 The map graphic that you see in the I

16 lower right there is just kind of a means of 17 visuallyassessing whether the emissions have been 18 placed where they should be placed. And in this 19 case, for vehicle NOx emissions for 2005 on a July 20 weekday. Just for kind of a crude assessment as to 21 22 whether we've done everything properly. What we have done, we have talked about -23 ,- bur base yecrr estimates, and thatts important as I

24 mentioned for model validation, and as a foundation 18 I,

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" McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 for developing our future year estimates. 2 The future year estimates then make use 3 of growth factors. And in this case a specific

I on-the-book controls, which are the federal and I wayside with the vacatur of the CAIR rule. And in 'i I" its place what has been implemented in the model is· H used, along with activity data to project the base 

### Ii year emissions to the future year just based upon

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That has subsequently gone by the When we then overlay controls, we end up

mentioned. other source categories**th~t** have already been And the future year controls that were used included the integrated planning model which takes piece of software called EGAS, and the version 5 is

into consideration electric power generation and

simply applicable on-the-book controls. And the

state rules that on the books, also apply to the to produce emission estimates. growth.

distribution with full consideration of least cost ":;'**-.~** ,--

- -.._-'._.. with our final future years' emissions' inventory

. 4 5 6 7 8

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';,.;"-..;-<.**~";-:-_2-a-c** And 1astly, any court orders applicable 24 to whatever facilities to which they relate are 19

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 also included with the EMV emission adjustments for 2 the future year. 3 The second bullet point here, biogenic I. 4 emissions and Canadian emissions were assumed 5 constant, so no changes between the base year and I I 6 future year. And then for non-LADCD states we used 7 whatever the other regional planning organizations 8 would provide to us. A-closer look at**the~future** year 10 emissions again. VDC on the left, NDx on the 11 right. The first two bars more or less reproduce 12 what we saw on the previous slides for the 2002 13 base year and the 2005 base year. But we have also 14 included some selective out years for 2009, 2012 15 and 2018. 16 These are aggregate totals for the whole 17 five state LADCD region, so they.have some value. 18 They don't tell the complete story, of course, but 1

I:' 19 on an emission sector basis you can pretty much see r

1 20 the breakout there as well. And we see some we 21 see reductions, of course, in on-road mobile for I I 22 VOCs. For non-road we see some reductions. We 23 see significant reductions in,EGYs from the base 24 year to the future year. And what you're seeing in 20

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 part there is just regulatory programs phasing in 2 that are translating into reduced emissions. So 3 this is true not only for the base years in part 4 between 2002 and 2005, but more markedly between 5 the base years and the outlying future years. 6 And again for your benefit, some 7 specific numbers for Illinois, both in totals and 8 for individual emission sectors. 9c What aretheseon-the-book controls? 10 First of all, we have these utility boiler NOx 11 emission controls as a result of the Title IV under 12 the Clean Air Act Amendment. And these are due to 13 translate into approximately 2 million tons NOx 14 lower from 1980 levels. 15 Secondly, our NOx SIP CO, which is a 16 trading program based on electrical generating

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_ units not emitting more than 1.5 pounds per million 18 BTU. In addition to that, boiler and turbine 19 limits, these are the non-EGU limits that are 20 referred to there, of 60 percent, and then some 21 additional controls. So 30;production from NOx

1 22 from cement kilns, and then 82 percent control '«2'3

.. efficiency on NOx for stationary engi'nes. 24 This program was implemented on May 31,21 Ii

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8 9-

- 10 11 12 13 14 15 16 17 18 19 20 21 22 "23-

24 2004, and again we are seeing the benefits in reduced emissions from the base year as a result of this federal rule making. Then a host of smaller ones, but all contributing in their own way. We have the national emission standards for hazardous air pollutants in NAAQS, and the new source performance standards. We have aerosol coatings and**"-~archi** tectural and industrial maintenance coatings,

as well as consumer solvent re-makings, as indicated there. These VOM reductions are approximately .114 pounds of UM per capita for aerosol coatings, 1.1 pounds per capita for AIM coatings, and .9 pounds per capita for consumer solvents coatings. There is also a portable fuel container rule making, in which the limit to evaporation and permeation emissions in portable fuel containers is .3 grams of hydrocarbons per gallon per day. The vehicle inspection and maintenance program provides reductions from mobile emissions, reformulated gasoline and like matter. Then we have a seRias: of-federal rule makings that relate to tail pipe emissions for 22

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 ,1 passenger vehicles, light duty trucks, and medium 2 duty vehicles. And these are at least for the tier 3 two motor vehicle standards and low sulfur gas rule 4 making. There is an 80 PPM**s~lfur** cap that's fully 5 effective in 2006, and tail pipe standards which 6 become fully effective or fully phased in in 2007 7 and 2009 time frames. 8 For the on-road heavy duty diesel 9 engines and the sulfur diesel fue-l requirement 10 phased in by 2007, so obviously that's already 11 taken place. And the ultra low sulfur diesel 12 requirement was required by June of 2006. 13 The last bullet point on this slide, 14 non-road diesel engines and diesel sulfur 15 requirements. So we've addressed some on-road rule 16 makings, and now lastly, there is a non-road rule 17 making. And as indicated here, year 2007,phased in 18 new emission standards and introduced standards of , 19 a 500 PPM cap by June of 2007 and reduced to a 15 20 PPM standard by June of 2010. 21 And lastly, for \he on-the-books 22 controls, there are several other motor vehicle

24 ignition, recreational vehicle standards, and ""'-?23-" federal programs. Evaporative large spark "

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McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 

### marine compression ignition standards and 2 locomotive engine standards. 3 There have been a series of consent 4 decrees entered into between various companies and 5 the courts. These have a direct impact on the 6 allowable NOx and YOM emissions. And for DYNEGY 7 Midwest Corporation, requires the installation of 8 certain NOx controls. Some of the equipment they -9:"':'-81**re:~n:t~-:'currentl**y'

### have;. it'sJust placing it into I

10 11 12 13 14 15 16 17 18 19 20

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### operation and in another instance at least acquiring those controls. Refinery consent decrees, you can see a listing of some of the affected sources there translating into, of course, NOx control. There

are other pollutants as well that are captured by these consent decrees, including silver oxide emisstons1particulate emissions, carbon-monoxide emissions. But for our purposes, the NOx control is the most important here for the ozone set. And lastly, the ethanol plant consent decree affecting sources as you see them listed there, and primarily affecting YOM emissions. Many of you are aw.8r-Ef·of the current pending Illinois NOx RACT rule making. This 24 I, I: I McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 

### addresses a host of sources that are within the 2 nonattainment areas for sources that are major 3 sources emitting greater than a hundred tons per 4 year. Includedamongst these are electrical 5 generating unit boilers, process heaters, cement 6 kilns, lime kilns, furnaces at iron and steel 7 manufacturing facilities. 8 And the particular emission limits are 9

-a 

### function of different-things.-**Ins-:i'P~1@-:.,:terms"** 10 

### it either reflects a pounds per million BTU heat 11 

### input limit, or in the case of cement kilns and 12 

### lime kilns and glass manufacturing, that it's eight 13 

### pounds per essentially product produced, be it 14 

### clinker, glass, things of that nature. 15 

### So that's the form of the emission 16 

### limitations. It's somewhat different depending on 17 

### whether you're talking a combustion**source~or** 18 

### whether you're talking about

- - well, _I should say 19 

### a boiler or process heater versus a process unit 20 

### like a glass manufacturing furnace. 21 

### And I believe that's my last slide, so 22 I'll turn it over to the next presenter. MR. LEOPOLD: Well, whenwe·'use the 24 t, 

### photochemical model we use it in a relative sense. I: 25 I, F

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, McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8 -9 10 11 12 13 14 15 16 17 18 19 20

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### That is, we don't necessarily look at the actual values coming out of the model and use them explicitly, but we look at the percent change and apply that to the actual monitored design value. So the design value that we get for a forecast is the design value in the base year, which is the monitored design value times this thing called an RRF, which is a relative reduction '·factor-;,-·And that is the amount.,percentage change

that we see in the modeling between the future year and the base year. In the process of combining the emissions and the meteorology all together in the photochemical model, we finally get the actual

ozone parts per billion prediction. We do a base year model in order to validate that the model is behaving corr.ectly . We can do .thjs, .of course, because 2005 

### has already occurred. We can compare that against the monitored values to insure that indeed our model is predicting reasonably well and

can be used then to project into a future year. The final results with and without the controls

-- well, go back tothe·base year. There

are a number of sites that are not in attainment in 26 I,**~.**

.... .. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 ....

### 1 the base year. We initially went ahead and modeled 2 with CAIR when CAIR was still with us, and then 3 came back and did the same modeling for future 4 years, 2009, 

### the attainment year, and 2012,

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### Jmd 5 found that at least for ozone there was not that 6 much difference between including the CAIR controls 7 and not including the CAIR controls. In 2009 

### we 8 are basically clean except for this stubborn Holland monitor where we are-j**ustbarely_~er·the** 10 

### standard, both considering CAIR controls and 11 

### considering life without CAIR. And by 2012, 

### then, 12 

### we have attainment throughout the Lake Michigan 13 area. 14 Note that there are no actual Illinois 15 sites listed here. That's because the Illinois 16 monitors are already in attainment. 17 

### Next, please. Well, when weare 18 modeling a result that is that close to the 19 

### standard, whether we are just under the standard or 20 

### just above the standard, US EPA requires that be 21 

### put together in what's called·a weight of evidence 22 demonstration. Which is just additional analysis

-i-.:;,:**:;.$=~23 ,--~that**  

### contributes to the conclusion that we have 24 come to. 27

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. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 "1 What this weight of evidence analysis 2 can comprise could be additional modeling, and this 3 could be, for example, US EPA's CAIR modeling. Air 4 quality trends, which is pretty**self-explanator~.** 5 And what US EPA calls other diagnostics often 6 comprising statistical analyses, source of portion I 7 method and such.

I· Next, please. This is an example of k

out of the attainment, and very clearly throughout 1

Michigan basin is in attainment for 8-hour ozone. > • monitor we have is the Holland monitor here on the east side of Lake Michigan. Otherwise, the Lake Next, please. By the time we get to

validated. But having said that, the only stubborn again because the 2008 ozone data has not yet been looktng at-the air qualtty trends.. Again, pretty

deep red colors there are those monitored that are

2006 to 2008, and these are preliminary values a number of locations out of attainment. the Lake Michigan basin and throughout the Midwest, straightforward. 2000 to 2002 design values. The 8

----_

....:.._.", - -9' 10 11 12 13 14 15 16 17 18 19 20 21

, 22 And certainly the Chicago area is included.

,-. '23 Next, please. An example- of the other 24 kind of analyses we can do, and again, in the 28

. . " ' , McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8 .-' ···-9

.. 10 11 12 13 14 15 16 17 18 19 20 21 22

:> ·23 24 attainment document we have provided is also the technical support document that LADCD has put together, and these analyses are included in there along with a lot of other information. So if you're interested in the different kind of analyses that were done, you can certainly refer to that. This is just one excerpt from that document. Aprocess that two people from US EPA named Cox; C-o-x,- and Chu,**C-h-u,came·l.lp~with·a** number of years ago with a statistical technique to try to minimize the effects of meteorology on ozone trends such that a trend that is left reflects emission reductions. And this is done for the Chiwaukee monitor. This is in Wisconsin, but it's just over the border and has been historically what

we call a control monitor for the Chicago area. A monitor that is affected by the Chicago plume_, And since 1997, we have seen a downward trend in ozone design values. The upward parts of the trend there in 2001, 2005, are likely due still

to meteorology. Again, this tfchnique minimizes the effect of meteorology, but does not completely eliminate it. But overall**from~1997** to 2007, "we have a very good downward trend in ozone design 29

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 ,

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I I I.

I I

I

'1I: I' I

I" ,', , 

### 1 values in that critical Chiwaukee monitor.

2 

### Next, please. The fundamental 3 

### question. That's a great slide. Do the analyses

, 

### 4 show that we can demonstrate attainment with the 58-hour ozone standard by the 2010 deadline? And we 6 say yes. 7 MR. SPRAGUE: We have already addressed all 8 

### those control programs, so this is an additional

-**9",qn~~~\Ale.don't** 

### need.

Chicago. Respiratory Health Association for Metropolitan F



### In the slide that Jeff haq up above the MR. URBASZEWSKI: Brian Urbaszewski,

I.: I Ie t I

I. 

## k r k



### Not that 30 MR. URBASZEWSKI: Why? MR. SPRAGUE: There was"_a,","J

### ot,oJ difficulty MR. SPRAGUE: Yes. MR. KALEEL: Should we pause for a little bit

model attainment demonstration before we move on to

emissions, you indicated Canadian emissions were

with working with the Canadian inventory. what emissions were assumed in the gross factoring and see if there are any questions just on the

the RFP analysis?

constant going forward. 10 11 12 13 14 15 16 17 18 19 20 21 fI. 

### 22

" 23- 24

" ,,' "

, "'" ',

.. , .. '"

, .. ,'" " ' McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 considerable effort wasn't expended to do so, 2 through. There was a lot of proprietary concerns 3 regarding the Canadian database. And in the 4 absence of feeling really comfortable that we could 5 produce a future year inventory that could really ! 6 past the test, the option was just to essentially

7 eliminate that potential source of what would be f 8 added error, just to keep it constant from the base 9 10 year. MR. URBASZEWSKI: Okay. '. 

### I' 11 MR. SPRAGUE: I fully appreciate that it kind 12 of defies rational thinking, but in the absence of 13 actually being able to produce a future year 14 inventory, you can be comfortable that a lot of 15 quality assurance that's gone into it would be 16 acceptable to the Canadians that you would be 17 -better off just eliminating that potential source 18 of error. 19 MR. KALEEL: If I can add to that, there is a ,

20 21 22 lot of effort between the US government and the Canadian government to work on'emission inventories and to coordinate quality issues, and we are kind --23" of tracking that. That is not anything, being Fed, 24 or that LADCD could fully be involved in. It's 31

.. , McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 really government to government. It's just been 2 very difficult to get accurate emissions data from 3 Canada. 4 MR. URBASZEWSKI: Okay. In terms of the 5 modeling that is used, I'm not that familiar with 6 the guts of the modeling, so whoever wants to 7 answer this, feel free. 8 But looking at between 2009 and prior

! 9 to 2009 and going out 

### to 2012 there are going to be 10 11 12 13 14 certain reductions from 502 from closed power plant units. I'm trying figure out if you get a !' reduction in S02, my understanding is sulfate formation is opaque, it helps reflect sunlight back in space, contributes to global cooling. That 15 would also mean that less

-- sulfur would block 16 sunlight from reaching the ground and forming 17 ground level ozone. But if you remove S02, then 18 you're actually increasing the amount of solar 19 radiation that is reaching the ground. 20 Is that going to.be driving more ozone '21 formation, and is that accounted for in the model?

22 MR. SPRAGUE: That is a great question. 23 Scott, you understand 24 MR. LEOPOLD: I understand the question. No, 32

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052We project future year emissions of course, but not II,

33 demonstration here. [,

I

I I

The sulphate issue is' one of the things MR. KALEEL: I think that is out of the realm MR. URBASZEWSKI: But this would

-- okay. Just

modeling. meteorology that is used is simply a replica of

meteorology.

it's really outside of the realm of our incorporated into the model going forward?

that is being looked at by our researchers, but implications for ozone formation, no? Is somebody going forward, I'm thinking, I'm making some that is not accounted for in the model. The

We don't actually project future year meteorology.

report on here. There is a lot of research on way, shape, or form, if there are SOx regs going

as well as upstate, which could have significant assumptions here. If CAIR goes into effect in some

climate change and a lot of efforts in the looking into that or making sure that is 2005 basecase. So we are using 2005 meteorology.

of the state planning process that we are trying to see significant reduction in S02 emissions in state forward in the state, which there may be, you could 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

.-".-:..

- -23 24

-,' '"' McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 MR. URBASZEWSKI: All right. Just from the . 2 document itself, I was looking at and I was 3 confused by a couple of things. 4 For the internal combustion engines, 5 the NOx rules that were implemented took effect in 6 2008, it said that the original attempt would be 7 covering turbines and internal combustion engines, 8 and from what I read it said that the 2008 -,:9**,,-r,egu~lati'ons'only** affected internal combustion 10 engines. 11 Are those turbines mentioned EGUs, or 12 was there something separated that was excluded? 13 MR. KALEEL: They are non-EGUs. It's for the 14 turbines that are involved in the current rule 15 making. 16 MR. URBASZEWSKI: So this is something that 17 would be bumped into the RACT rules? 18 MR. KALEEL: There are a couple of different 19 rule makings going on in regards to the engine 20 rules. There are certain large engines that were i21 identified in the NOx SIP CO rule making. These

22 are sources located statewide, I think there is a 23 total of 278 engines. Thatrule'making is 24 complete. I am forgetting the exact compliance 34 I

" " '- McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 3 4 5 6 7 8**--'-'-~.-** 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 deadline, but that is now passed. There is a separate rule making that IEPA has submitted to the Pollution Control Board dealing with other engines and turbines located in nonattainment areas. That is part of our NOx RACTS. That rule is still pending before the Pollution Control Board. MR. URBASZEWSKI: Looking on in the actual document and 1isting out all.the consent,decr:.ee_s that are occurring with the DYNEGY and the refineries and such, there is some of them list dates by when things are going to go on and there ARE some that don't. The DYNEGY settlement in the actual document says that some NOx controls are going to go on, but it doesn't say when. Whereas in the other descriptions in the other consent decrees it does list out certain dates what is going to happen. MR. SPRAGUE: Yes. There are variable compliance dates for ADM, and I don't want to say it was an oversight, but kind of. gets pretty ft; lengthy if you begin to list all the compliance dates for particular emissions sources at each of the ADM facilities for YOM controls versus NOx

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 35 I

I

I I1 controls versus whatever. 2 So it was a conscious decision to not 3 go to the lengthy listing of all those, thinking 4 that just referring you to, just citing the**consen~** 5 decree order itself would probably be sufficient to 6 direct you to the specific information if you were 7 truly interested in getting into it. 8 MR. KALEEL: We will try to do a better job or

.-g-nrcrre-complete job and get more information in

10 there. 11 MR. URBASZEWSKI: It was just there was a 12 little less detail was in the DYNEGY settlement 13 than other things that were described. 14 MR. KALEEL: We will try to do better on that. 15 MR. URBASZEWSKI: And in the ADM settlement, 16 too, and this is what kind of confused me about how 17 SOx emissions were worked into the modeling. The 18 ADM description actually talks about SOx 19 reductions, which I didn't understand how all that 20 fit into the ozone emissions. MR. SPRAGUE: It does not. 22 MR. URBASZEWSKI: Just one real quick check on 23 the inventory related to the inspection and 24 maintenance program. 36 I

I

I·

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 .very moist year here. Perhaps we wi11 be record setting by the end of the year. -There was"can unusually low number of 90-plus degree days at 

### I 37 1 2 3 4 5 6 7 8

_

.._- 9 10 11 12 13 14 15 16 17 18 19 20 21 22

-". 2-3 24 Was the inventory corrected for the change of DOC, has that occurred because of a switch from a treadmill test? Because there was a document I had seen in the past that indicated that there was going to be an increase from the past because of the switches to OBD only. MR. KALEEL: The future year inventories do

account for that. The base year inventory, that conversion hadn't happened ye-t tn2002T-nventory. By the time we're projecting to 2009 or 2012, we

are accounting for that. MR. URBASZEWSKI: One final question. Just in terms of meteorology in the 2006 and 2008 years, would you consider that that meteorology was typical in terms of those years, was it close to average in terms of the temperature and rainfall? MR. KALEEL: We are sti11 1ooking at that. I don't know, Scott, if you have some comments on the 2008 meteorology. MR. LEOPOLD: Well, 2008 meteorology in Chicago, certainly it was very moist.**~t's** been a

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 I I

I

I I1 O'Hare Airport. However, for example the month of 2 July was actually above normal for average 3 temperature, which would indicate that there was 4 not much variability in the temperature during the 5 month of July. That is, days were likely I' 6 consistently high in the 80s, lows in the 60s, 7 rather than what happens in some years when we have 8 extremely hot spells followed by cool breaks. - 9 -That kind of scenario could lead to 10 having an above normal July temperature without 11 having above normal number of 90 degree days. 12 MR. URBASZEWSKI: In terms even if the average 13 temperature in July were higher, how would that

-- 14 would that be more critical than the number of 90 15 degree days in determining how many exceedences 16 occurred? 17 MR. LEOPOLD: I'm really not sure of the 18 magnitude of either of those variables as to I I 19 whether one is more important than the other.

21 witho fewer 90 degree days would 1ike1y 1ead to few 22 exceedences. But the scenario that we have this 20 Certainly a below normal temperature year along I

I

23 year 'ITeally can't say at this mO.ment whether one 24 is more important than the other. I

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 established the form of the standard. Which we I) 1 2 3 4 5 6

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22**=--~.:-, 23~**  24 MR. KALEEL: If I may make a comment about the meteorology, US EPA of course recognizes the importance of meteorology in ozone levels in a particular**are~,** and they try to deal with meteorological variability in the way they

look at three years of data, not one year, and you also don't look at just the peak values, but look at the fourth high value. So**the~:idea~is** to try to dampen out as best you can the experience of meteorology and try to assess air quality. So it is a three year standard, based on the fourth high, and what a particular year's ozone produces is really not relevant to determining whether the air is attainment or non- attainment. MR. URBASZEWSKI: Would you say that 2006 was also below a year average or below average in terms of ozone production? MR. KALEEL: Well, I persona11y honestly don't recall. I don't know if Scott has a comment on 2006 meteorology. MR. LEOPOLD: I'm really not up to speed on exactly what happened in 2006 for meteorology. MR. KALEEL: We are really talking more about I

1

I:

1

39 r McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 ....1 the redesignation petition rather than the 2 modeling. Modeling wasn't considered in 2006 3 meteorology or 2008 meteorology. It considered 4 2005 meteorology and just strictly a prediction of 5 air quality to 2009 or to 2012. So that we are 6 really kind of getting ahead of ourselves with this 7 discussion. 8 MR. URBASZEWSKI: Okay. I will leave it there I --9,. --,j:orno,w.

• "'0. 0"._ 10 MR. KALEEL: Okay. Any other questions? 11 MR. ASSELMEIR: I guess I will start here. As 12 I said before, my name is David Asselmeir and my 13 primary responsibility is for compiling the 14 15 16 emissions inventories that are used in these models and by other groups. My primary focus is on what we call Ii I'

I

17 point and area sources. Again,**indu~try** and a 18 bunch of little things that are dry cleaners, all 19 the body shops, consumer solvents, coating, things 20 21 22 23 24 like that. And I also get other data from our mobile source group from the on-road and off-road emissions. But, first slide'cAs:_part of this demonstration, US EPA also requires us to progress40 

### I I: I

. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 towards meeting attainment by what we call a 2 reasonable further progress. And what that is is 3 they required a 15 percent reduction in YOM six 4 years after the base inventory. And again, using 5 the base year, the data I have is 2002. Six years 6 later, of course, is 2008.

7 They give a couple of options on how you 1< 8**~et** your 15 percent reduction. As you've heard 9 before with Jeff,and'Scott, there 'are many' things 10 that go into forming ozone. Many ones are YOM and 11 NOx emissions. The way that US EPA has set that 12 up, you move all YOM, all NOx, or a combination of 13 both of the two. You can do it, certainly you have 14 to work with inside nonattainment area, but since 15 again it is a transport problem also for ozone they 16 do allow you to take into consideration YOM sources 17 within 100 kilometers and NOx sources within 200 , 18 kilometers. And as the documents you have 19 previously been shown show, we are just dealing 20 with YOM reductions in the Chicago area. 21 Next slide. So we have heard about the 22 2002 base year inventory at least based on emission -23 reports or data computer models we have. What we

24 had to do was grow that inventory to 2008 for the 41

. .. .. , McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 point of areas and sources. How we do that is by 2 what we call growth factors. I say growth factors, 3 this doesn't necessarily mean emissions are always 4 going up. They can go down, too, in certain 5 situations. Point of area, more industrial and 6 economic based area type sources are more. Again, 7 employment population type. 8 Usually the growth factors do take into

-**~--** 9**·~:account** some type of industries and new plants 10 being added. Growth factors, we probably did not 11 take into account the growth and the boom, at least 12 the new planned ethanol and biodiesel plants. So 13 we went and made sure we accounted for those in the 14 Chicago area. 15 Certainly those growth factors don't 16 take into account the consent degrees, so we 17 include those in our growth and updates to 2008. 18 And Chicago also has a little bit different one, 19 they have 

### a cap and trade program for YOM. It's 20 our emissions reduction market systems, ERMS. So 21 we have to worry about just allowing companies to 22 grow, whether they bump up against the cap. And 23 when-f checked into that nature,-'if they were or 24 were not going into the cap, they were not anywhere 42

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052these guys have done, the potential possibility has Ii 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

.- ... 23 24 near reaching the cap. So ERMS did not limit the growth in this case for 2008. For our on-road mobile sources, US EPA has a computer model called MOBILE6 for many different types of vehicles, speeds, temperatures, things like that, ran that for 2008. Similarly for off-road, lawn mowers, garden tractors, things like that, the US EPA has what they call the non-road model. That-doesn't include the locomotive, the commercial marine vessels, and the aircraft. We get those different ways. Again, what we had to take into account certainly for the Chicago area is the O'Hare expansion, and we used the documents that they have put together for that and the long-rumored third Chicago airport. So I did a check before you came,

we do not have the third Chicago airport operating in 2008. So for RFP purposes we don't worry about that. But for future projections and modeling

been included in future year inventory. Next slide. In general, there is a little bit more pertaining to a little**bi~** more detail of where the emissions are coming from in 43

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 !

### 1 the Chicago area for VOM emissions in tons per day. 2 Again, RFP only goes to 2008, while you 3 also see 2009, 2010, US EPA, especially Region V 4 here in Chicago, kind·of also want to see us 5 project and go out to the attainment date of 2010. 6 For the most part, as you can see, big 7 reductions of VOM for on-road and off-road vehicles 8 and area source reductions. Where the majority of 9 those reductions come from is from the 10 architectural and maintenance coating rules and the 11 consumer solvent rules. 12 I can't recall if those have been 13 passed yet, but even so, industry and other 14 manufacturers are accounting for that and slowly 15 coming into compliance before the rule is passed. 16 And US EPA issued some guidance on what credits we 17 can take for reductions we can expect to**see~** 

### and 18 those have been included. 19 As I recall, we can take a 75 percent 20 reduction into 2008, and 25 percent to

-- well, not 21 reduction, but 75 

### percent of the total reduction we 22 would expect to see. We went a little bit more 23 conservative and did a 50/50 split. So from that, 24 certainly with mobile sources, we expect to be 44

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 meeting our reasonable further progress. 2 Next slide. I'll go through this. 3 Calculating 15 percent of a number sounds fairly 4 easy. One thing you_have to take into account is 5 there are certain things we are not allowed to take 6 credit for in the reductions. And the example is 7 the lone case I have here is the Federal Motor 8 Vehicle Control Program. So we have to subtract 9 that, so we don't get that credit. Then we do our 10 15 percent. 11 This little step in the calculation is 12 gone through but in more detail in the document, 13 just going through here. But our a target is 628 14 tons per day of VOM. That is what reasonable 15 further progress gets us. Based upon our projected 16 inventories, the new sources, different control 17 strategles, we're projecting 591 tons per day, 18 which is close to a 20 percent reduction. 19 So again, we are believing we will 20 easily get the 15 percent reduction for VOCs. That 21 is all we are taking into consideration in the 22 Chicago area. 23 And I believe that is the last one 24 there. 45

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 MR. KALEEL: Any questions on the RFP 2 demonstration? Again, this is a required element 3 of our attainment demonstration. 4 Brian. 5 MR. URBASZEWSKI: Just out of curiosity, the 6 ethanol plants being incorporated into the 7 inventory, there were quite a number of ethanol 8 plant proposals which even with the economic 9 changes going forward there is still a federal 10 mandate for an increase in the federal mandate for 11 ethanol. So I assume a lot of these are still 12 going to be built because this is where the corner 13 is, in Illinois, but perhaps just outside the 14 Chicago nonattainment area. 15 And I'm trying to figure out in terms 16 of effect on ozone formation, how the emissions 17 from the plant that you would expect to be bUllt 18 just outside the nonattainment area are going to 19 affect attainment? 20 MR. KALEEL: Jeff, do you want it? 21 MR.. SPRAGUE: My understanding from our 22 permitting section is really we have no ethanol 23 plants to be built just outside the Chicago non24 attainment area. We have two down in the Metro 46

.".'.' McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 .......

### 1 east area, one in Alton, and I think the other ones 2 are more or less clustered in the west around the 3 northwestern part of the state, with one 4 exception. There is one other one down in the far 5 southeastern part of the state. Is it Palatine? 6 No, that's not right. It escapes me right now. 7 MR. KALEEL: Have we included the ones we know 8 of in the modeling exercise? 9 MR. SPRAGUE: Yes. 10 MR. KALEEL: So I think we have made a fair 11 estimate of at least what we know is in the 12 pipeline, so to speak. And in terms of future 13 analyses or maintaining the standard after that 14 present date, I will talk about our maintenance 15 plan in a little while. But one of the elements in 16 our maintenance plan is to review the emissions 17 inventory on a regular basis. So we will be happy 18 to take your comments on that element or best ways 19 to do that. We are trying to do that. 20 MR. URBASZEWSKI: Okay. 21 MR. KALEEL: Why don't you go ahead and**~lick** < 

### 22 ahead on the next slide here, Jeff. Reasonably 23 available control technology. I will make a few 24 remarks about where we are with that with this 47

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263·0052

### 1 particular requirement. 2 The Clean Air Act RACT requirements for 3 both VOM, volatile organic materials, or sometimes 4 VOCs, we use those terms kind of interchangeably, 5 and also for nitrogen oxides. We have a long 6 history of VOM RACT rules in Illinois in the 7 Chicago nonattainment area. These were promulgated 8 in the 1990 Clean Air Act and adopted for the 9**purp~se** 

### of obtaining the one-hour ozone standard. 10 Obviously that standard has since been released for 11 8-hour ozone, but these earlier RACT rules still 12 provide predictions that help us for the 8-hour 13 standard. 14 In 2006 and 2007, US EPA issued new 15 control technology guidance documents, or CTGs. We 16 are still working on regulatory proposals to

- 

### 17 promulgate the requirements of those CTGs. We need 18 to complete thoee rule makings and submit those to 19 the US EPA before the attainment demonstration is 20 considered complete. So we don't expect that US 21 EPA will be able to take final action on this 22 submittal until those rules are completed and 23 submitted to the US EPA. 24 Similarly, NOx RACT requirements are 48

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 contained in the Clean Air Act. We should have 2 submitted NOx RACT rules a couple years ago. We 3 have not yet done that. The RACT requirements for 4 NOx are before the Illinois Pollution Control Board 5 right now, and what we intend to do in this 6 submittal to US EPA is to provide a commitment to 7 US EPA to adopt the NOx RACT rule and submit that 8 as soon as the Board has finished with the rule 9 making. And a similar commitment for the VOM RACT 10 requirements. 11 So this is not an area that Illinois is 12 complete. And again, US EPA won't be able to take 13 final action until these requirements are completed 14 and submitted. 15 In terms of contingency measures, this 16 is another area of the Clean Air Act. We need to 17 make a demonstration or include measures that are 18 to be implemented if we fail to achieve reasonable 19 further progress. If we fail to achieve the 20 attainment by the attainment date, these 21 contingency measures are supposed to be in effect. 22 We are required to or supposed to take further 23 action, state action, to get these reductions. To 24 meet this requirement we are relying on both state49 % :; McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052I" 

### 1 and federal measures that have already been adopted [0 Ii 

### 2 that will provide emission reductions beyond 2010. 3 

### Next slide. There is a list of these 4 measures. Many of these measures you have already 5 seen in our attainment demonstration. In other 6 words, these are measures that we are relying on to 7 demonstrate attainment. But many of these measures 8 will provide continuing emission reductions, 9 greater reductions in the future year than they 10 have by the attainment year. So those additional 11 reductions beyond 2010 are being relied upon to 12

- meet this requirement. I won't read this 1ist, but 13 these are the measures. 14 Unless there are questions on RAeT or on 15 contingency measures, I will pause for a second. 16 Mike Rogers is going to talk about the 17 transportation conformity requirements. 18 MR. ROGERS: Good morning. My name is Mike 19 Rogers, I'm with the Illinois Environmental 20 Protection Agency's Bureau of Air, and I am 21 responsible for dealing with issues related to 

### e 22 transportation conformity and the development of 23 State Implementation Plan, "SIP" motor vehicle 24 emissions budgets. 50

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 Section 176(c)(4) of the Clean Air Act 2 Amendments of 1990 requires that transportation 3 plans funded or approved under Title 23 USC must be 4 determined to conform with state or federal air 5 implementation plans. In order to demonstrate 6 conformity, motor vehicle emissions resulting from 7 the implementation of transportation plans and 8 transportation improvement programs must be equal 9 to or less than the motor vehicle emissions budget 10 established in the SIP. 11 The Chicago 8-hour ozone attainment 12 demonstration and maintenance plans being discussed 13 today·contain estimates of year 2009 and 2020 14 Chicago area volatile organic compound, "VOC," and 15 oxides of nitrogen, "NOx," on-road motor vehicle 16 emissions. These levels of motor vehicle emissions 17 establish a cap or "budget" for the purpose of 18 determining conformity between transportation 19 planning activities and air quality plans. 20 The motor vehicle .emissions budgets 21 proposed in the 8-hour ozone attainment 22 demonstration were developed consistent with the 23 methodology and control strategy assumptions used 24 in the air quality modeling. They are based on the 51

.,. McCorkle Court Reporters. Inc. Chicago. Illinois (312) 263-00521 compared to baseline 1990 fuel. 2 The 11M program, in effect since 2007, 3 requires biennial on-board diagnostics, "OBD," 4 testing on all model year 1996 and newer light duty 5 gasoline vehicles, and exhaust idle and gas cap 6 testing on model year 1996 and newer heavy duty 7 gasoline vehicles registered in the testable area. 8 The Chicago testable ara is based on 9 urbanized areas and includes all of Cook, DuPage, 10 and Lake Counties, and parts of Kane, Kendall, 11 McHenry, and Will Counties. The program includes a 12 four-year grace period for new vehicles. The 13 benefits of national motor vehicle emissions 14 control programs such as the Tier 2 emissions 15 standards and fuel sulfur controls are accounted 16 for within the emissions factors generated by the 17 US EPA MOBLIE6 model. 18 Combining these VMT assumptions with the 19 year-specific

## voe and NOx gram per mile emission 20 rates from the MOBILE6 model, the proposed Chicago 21 attainment demonstration year 2009 motor vehicle 14 22 emissions budgets are 106.92 tons per summer day of 23 VOC, and 261.02 tons per day of NOx. The 24 maintenance plan year 2020 motor vehicle emissions53

.... ... McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 budgets are 56.07 tons per summer day of VOC, and I 

### I, 2 79.09 tons of NOx. 3 This concludes my testimony. 4 HEARING OFFICER VETTERHOFFER:Doesanybody 5 have any questions? 6 MR. KALEEL: Okay. As we mentioned in our 7 introductory remarks, the agency is going to be 8 submitting the attainment demonstration document, 9 which is what we have described up until now in 10 this hearing. The other SIPS submittal, the 11 implementation plan submittal that we will be 12 making is a maintenance plan for the Chicago non13**attai~ment** 

### area. And the maintenance plan is a 14 required element of a request by the state to US 15 EPA to redesignate the Chicago area to attainment 16 status for the 1997 standard. 17 At the same time that we are making a 18 request to redesignate the area to attainment for 19 the 1997 standard, we will be working on a 20 recommendation to US EPA. This recommendation is 21 due next March, which is to establish**boundarie~** 

### 22 for the nonattainment area for the 2008 ozone 23 standard. We will talk about this at the 24 conclusion of the hearing. We will be seeking

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 541 comments from the public on what those boundaries 2 should be for the new standard. 3 I guess the policy statement that we are 4 making today is that we want to move ahead to 5 planning for attainment of the new, more stringent 6 standard. The 1997 standard has been superceded at 7 the federal level, and by moving ahead with our 8 planning we would be able to address the more 9 stringent standard. 10 The 1997 8-hour ozone standard, there 11 are others requirement in terms of new source 12 review and permitting that we would like to just 13 get behind us. One of those is actually a legacy 14 of the previous one our standard. So that we are 15 basically making the statement that the Chicago 16 area is not attaining the current ozone standard, 17 but we are moving beyond the 1997 to look at the18 2008 standard. So that is I guess the reason why 19 we are doing that, and we are trying to do it 20 simultaneously. 21 We don't want to send a signal that 22 Chicago is attaining the ozone standard, because 23 clearly we have not. But we have attained the 1997 24 standard that has being replaced by US EPA. 55 :,

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 j'i So I will discuss the requirements of a**I~** 2 maintenance plan, the idea of a maintenance plan as 3 it provides for continued attainment of the air 4 quality standard for a period of at least ten years 5 after the area has been designated to attainment. 6 The idea is to prevent future violations through 7 the implementation of contingency meters that would 8 have an automatic trigger or virtually automatic 9 trigger, not requiring years of additional rule 10 making. We are required, since this is a SIP 11 submittal, to have a public hearing and that is the 12 reason for bringing it up today. 13 Let's walk through some of the elements 14 of the maintenance plan. The actual document is 15 available on our website, so this is just going to 16 discuss or this Power Point is just discussing the 17 highlights-of that plan. We need to identify what 18 is the, quote, attainment year. What is the year 19 that we actually are attaining the ozone standard. 20 The ozone standard is not really 21 attained, and the way the standard is written, it's 22 really not attained in any given year. It really 23 takes a three year period of record. And what 24 we're I guess**identifyi~g** 2006 as our attainment 56

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 year, it's really the first of a three year period 2 of monitored attainment; 2006, 7 and 8. So for the 3 purposes of this demonstration, we are calling 2006 4 the attainment year. 5 In terms of projecting our inventory, as 6 I mentioned before we need to show maintenance for 7 a period of at least ten years following

0. 8 redesignation. We don't really know when US EPA is 9 going to act on this submittal. So to cover our 10 bases we were really projecting out 14 years from 11 the attainment year; or in other words, out to the 12 year 2020. We will do a demonstration and 13 inventory to show that the attainment level of 14 emissions will not be exceeded in the future 15 years. At least within this period of record. 16 Then a final comment here is that we 17 will continue to operate an appropriate monitoring 18 network. 19 Some more requirements. We need to 20 maintain within the State of Illinois the legal 21 authority to implement and enforce control 22 measures. We have to provide provisions for future 23 updates of the emissions inventory to track 24 emission levels. We need to make a commitment to 57

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 2 adopt a requirement for transportation plans that conform. And these are all comments that we are I I: Ii I

I 3 making with this. 4 Continuing, we need to commit to submit 5 a revised plan eight years after the 6 redesignation. The idea to this is in eight years 7 we revise the plan so that we can continue to

.. 8 maintain for a period of ten years following the 9 exploration of this maintenance plan. So in other 10 words, from 2020 to 2030. So that commitment is 11 contained in the plan. 12 We have to commit to enact and implement 13 contingency measures in the event that the air

.. 14 quality standard is exceeded after the area has 15 been redesignated to attainment. In other words, 16 what happens if ozone levels get worse unexpectedly 17 or what is our response to that. That is to be 18 addressed by the contingency measures, and we are 19 providing and I will go through a list of measures 20 that we are relying upon in this plan. Ii I

21 22 Now, first off, I think this is a similar slide to what Scott showed earlier. To 23 qualify for redesignation obviously we need to be 24 attaining the standard. The panel on the left 58

.,<...•..,: McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 shows monitored design values for the period of 2 2001 through 2003. This is the data that US EPA 3 looked at in establishing the nonattainment area 4 boundaries. It's a little hard to read the values 5 there on the slide, but at least looking at the 6 color code, the red dots represent monitor 7 locations where monitored design values for that 8 period of time were above the level of the 1997 9 standard. In other words, 85 parts per billion or 10 greater. 11 The panel on the right reflects the same 12 information for the most recent three year period 13 of record, 2006 through 2008. Just comparing' 14 visually the slide on the left versus the one on 15 the right, clearly much improvement is evidenced by 16 the number of green circles that you see there. 17 These are the monitors that are below the level of 18 the design value. All the monitors in the 19 Chicagoland region and in eastern Wisconsin, 20 northern Indiana are showing attainment with the 21 air quality-standard. 22 One monitor in the Lake Michigan region 23 that is not yet showing attainment based on the 24 most recent three-year period of record is the one59

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 located in Holland, Michigan. And as Scott Leopold 2 had testified earlier, our attainment plan does 3 address Holland, Michigan in terms of its ability 4 to attain the air quality standard. I think the 5 modeling is showing that that monitor will attain 6 no later than 2012 with measures that are contained 7 in our attainment plan. So based on this 8 monitoring data, the Chicago nonattainment area 9 qualifies for redesignation to attainment. 10 This slide is showing the changes in 11 emission levels from 2002 through 2006. What we 12 are trying to demonstrate here is we did achieve 13 attainment through the implementation of control 14 measures and not just to the vagaries of the 15 meteorology. I think in both columns for VOC and 16 NOx you can see significant emission reductions 17 within the Chicago nonattainment area from 2002 18 through 2006. 19 The control measures that provided those 20 reductions are listed here. These are the same 21 measures that we have of course relied upon in our 22 attainment demonstration. I won't repeat them all 23 here. But again, they are enforceable measures 24 that are in place that cause these emission 60

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 reductions to happen. 2 Now, in terms of demonstrating 3 maintenance after the area has been redesignated to 4 attainment, we need to project our inventory out to 5 the year 2020. And in projecting those emissions 6 we need to account for growth of various emission 7 sectors as well as the effects of control measures 8 that have been or will be**impl~mented** between the 9**attainme~t** year and that future year projecting out 10 at least ten years or out to year 2020. 11 And these are some control measures that 12 we believe will continue to provide ECO and NOx 13 emissions out to the year 2020. The Illinois' 14 pollution standard and combined commuter 15 maintenance and the Illinois mercury control will 16 provide significant reductions in the future years, 17 not just in the nonattainment area but statewide. 18 These requirements affect the electric generating 19 units in the state. Coal-fired power plants. Our 20 NOx RACT requirements discussed earlier that has 21 not yet been-adopted by the Pollution Control 22 Board, but will provide NOx reduction in the 23 nonattainment areas after

-- well, obviously after 24 the year 2006, but well before the year 2020. So 61

., '. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 within that time period. I**I~** 

### 2 Buzz had previously talked about the 3 aerosol coats, the architectural industrial 4 maintenance coats rule, portable fuel containers, 5 aerosol coats. Most of these are still pending 6 before the Illinois Pollution Control Board, but we 7 will provide significant DOC reductions in future 8 years. 9 The vehicle inspection and maintenance 10 program will be continued. The motor vehicle 11 control programs, the tier two, the heavy duty 12 vehicle standards, the off-road engine standards. 13 These are"all programs that will provide reduction, 14 continuing reductions in future years. 15 And then the consent decrees, I think 16 Jeff had listed those previously. Those reductions 17 are not yet ail in place, and we commented to Brian 18 that we would try to provide a better listing of 19 what the dates are of when those reductions are 20 expected. But again, all of these measures will be 21 providing emission reductions up through the year 22 2020. 23 This slide I guess depicts 24 quantitatively what we have been discussing. The 62

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052 I**I~**

### 1 chart on the top shows the emission reductions for 2 

### the year 2006. 

### The chart on the bottom shows 3 emission levels for 2020. 

### And comparing VOC and 4 NOx numbers between 2006 

### and 2020, 

### you see 5 substantial reductions from the attainment year to 6 the projection year. 7 And another program that will provide 8 continued maintenance or attainment of the qual,ty 9 standard of course is the multiple pollutant 10 standards from the utility boilers. And that's 11 kind of a tabulation of what the area on that slide 12 that shows 2007

-- 

### it should be 2020 

### and 13 basically the level of NOx emissions in future 14 years will be cut in half from the electric utility 15 sectors. Or at least-the coal boilers. 16 Now, in terms of the contingency measure 17 portion of the maintenance plan, what we are 18 proposing is a commitment to enact and implement 19 additional measures in the event future violation 20 

### of the air quality standards occurs. We have done 21 this similar to this in years past. I think what 22 has been fairly successful in the past, we have 23 

### identified conceptually two levels of contingency 24 levels, we call them level I and level II, and each 63

McCorkle Court Reporters, Inc. Chicago, Ill;no;s (312) 263-00521 of these have different triggers, if you will, in 2 terms of when these measures would be implemented. 3 It will help us determine what is the 4 appropriate response. The id.ea to the Jevel I are 5 measures the state would take before we actually 6 violate the air quality standard and perhaps end up 7 back in a nonattainment status. The idea is to try 8 to track emission levels and air quality levels, 9 and if we think we are getting close, try to 10 implement measures to prevent the actual violation 11 happening. I will try to talk about that in the 12 next slide here. 13

.The two triggers, the level I trigger 14 would be tracking air quality on a year-to-year 15 basis. As we have discussed, attainment or 16 nonattainment is based on three years of monitoring 17 data, but what-the IEPA asked us to do is look at 18 monitored values on a year-to-year basis, and when 19 we see a fourth high ozone concentration on any 20

.monitor in the nonattainment area exceeding 84

., 21 22 23 24 parts per billion, which is the level of 1997 standard, that we would implement level I measures. Also, as a trigger under level I to review the emissions inventory on a regular basis, 64**~j** ']

. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 on an every-three-year basis and evaluate emission 2 trend. If again we see emissions trending above 3 what we have projected, what we are expecting to be 4 the level of emissions to maintain the standards, 5 then we would implement level I contingency 6 measures. 7 The level II, this is really the part 8 that is required by US EPA. This would be 9**conting~ncy** measures that are implemented if the 10 air quality standard is in fact violated. 11 Now, in both level I and level II 12 contingency measures the agency will conduct an 13 analysis. We try to figure out as best we can what 14 is causing exceedences of the standard or causing 15 violation of the standard. And this lists the type 16 of things we will look at, the weather patterns, 17 the conclusiveness of the meteorology, what is the 18 emission source that we think are contributing to 19 the exceedences or the violations. Emission 20 trends, what kind of control measures can be 21 implemented, and when we think we could reasonably 22 get emission reduction from those measures. What 23 new technologies are available and what the 24 geographic applicability should be of those 65

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 measures. Should it be just within the non2 attainment area or should we consider upwind 3 control measures. So this is one of the analyses 4 that we will conduct regardless of whether it's a 5 level I or level II trigger. 6 We have I think a more complete list in 7 the document of potential contingency measures. 8 But again, these are measures that we expect will 9 provide continued emission reductions beyond the 10 attainment year. All of these programs either have 11 been or will soon be implemented or promulgate by 12 the Pollution Control Board and/or US EPA. 13 And I mentioned the various commitments 14 that are part of a maintenance plan. We are 15 committing to redo the maintenance plan eight years 16 after US EPA redesignates the area to attainment. 17 We will continue to perform emission inventory 18 updates every three years. We will continue to 19 monitor ozone levels in Illinois and we will we 20 have the authority to enforce all the same 21 requirements that are contained in our state 22 implementation plan. And again, we are committing 23 to implement contingency measures based on the 24 level I and level II triggers that I've discussed. 66

_. McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-0052

### 1 Any questions on the maintenance plan? 2 MR. URBASZEWSKI: My memory is a little foggy 3 on the status of the one-hour ozone standard. But 4 it's correct that US EPA revoked the one-hour 5 standard? 6 MR. KALEEL: Yes. ·7 MR. URBASZEWSKI: So ifwe get into a similar

8 situation where the new ozone standard promulgated 9 this year goes into effect, there is potential for 10 US EPA to revoke the old 1997 ozone standard as 11 well? 12 MR. KALEEL: I think that potential exists. I 13 don't think the US EPA has issued any guidance yet 14 on how they will implement the new standard. The 15 complications that arose from the revocation of the 16 one standard, as I mentioned, is one of the reasons 17 why we're pursuing redesignation now. The 18 implementation rule that.US EPA issued subsequent 19 to the 1997 standards had been subject to legal 20 challenge. There were a number of things that the 21 US EPA told us we could do in our program that in 22 fact were taken away by the courts years later and 23 very much complicated our program. 24 So we think the best way to make a 67

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 clean break from the 1997 standards is to go ahead 2 with the redesignation at this time. And again, we 3 really don't expect the area to be attainment for 4 ozone, at least not for any great length of**~ime,** 5 because of the 2008 air quality standards. 6 MR. URBASZEWSKI: Can you briefly explain in 7 the current absence of CAIR how the state is 8 dealing with" the NOx SIP CO rules to insure the 9 existing NOx reduction standpoint. 10 MR. KALEEL: The state's NOx SIP CO rules are 11 still in effect. We did not include a sunset 12 provision in Illinois's CAIR rule, so there is 13 nothing we need to do to insure the NOx SIP CO 14 stays in place. US EPA has not yet allocated 15 allowances under theNOx SIP CO, which they have to 16 do before the 2009 summer season. I think they are 17 going to wait until the last possible minute to 18 make those allocations, waiting to see what the 19 court does with the CAIR rule. There is nothing we 20 need to do to continue to implement the NOx SIP CO. 21 MR. URBASZEWSKI: That's it. 22 MR. KALEEL: Any other questions? 23 HEARING OFFICER VETTERHOFFER: Does anyone have 24 any comments they would like to make for the 68

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 record? I am not seeing anyone indicating that

-- 2 oh. 3 MR. URBASZEWSKI: One other real quick 4 question. We are bouncing around 

### a lot of 5 different subjects today. But on the maintenance 6 plan there was a tape or there was a table C2 which 7 looked at 2005 Chicago nonattainment area emissions 8 that I had trouble understanding the difference 9 between tons per day and tons per year. There were 10 some situations where it was a tons per year, but 11 it was broken out by tons per day. And in others· 12 it was broken out by tons per day and tons per 13 year, but I couldn't figure out how it added up. 14 It didn't seem to make sense. 15 MS. DOCTORS: Was this in the document? 16 MR. URBASZEWSKI: It was in the

-- 17 MS. DOCTORS: Do you have a page number? 18 MR. URBASZEWSKI: Table C2. 19 MR. KALEEL: I'm having trouble finding it. So 20 the comment is just clarifying the tons per day and 21 tons per year? 22 MR. URBASZEWSKI: And how tons per year, what 23 developed from tons per day or vice versa. It just 24 wasn't clear how the numbers matched up. There is69

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 no explanation for the table really. 2 MR. KALEEL: I think what we will do is take a 3 look at that table and see if we can clarify how 4 it's presented and what we are trying to say or how 5 we relied upon that information. 6 MR. URBASZEWSKI: Okay. 7 MR. KALEEL: Thank you. 8 MR. URBASZEWSKI: That's it. 9 HEARING OFFICER VETTERHOFFER: Does anyone have 10 any other questions or comments? I don't see 11 anybody indicating that they wish to make any 12 comment or ask additional questions. 13 I would like to remind everyone that if 14 you decide after this hearing that you have some 15 comment you would like to make that you didn't 16 think of today, you can send that in as a written 17 comment. Again, -the comment periad, for the 18 record, in this matter closes on January 15, 2009. 19 Any written comments must be postmarked before 20 midnight on that day and sent to me to be accepted 21 as part of the record. 22 Copies of the transcripts of this 23 hearing will be made available on the Illinois 24 EPA's website as soon as we obtain a copy from the70

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 court reporter and have it posted on the Illinois 2 EPA website. The website address is 3 www.epa.state.il.us. 4 Any of the copies of the drafts 5 identified today are available on request. All of 6 the Exhibits that we have used are also available 7 off of the Illinois EPA website. 8 The time is now approximately 10:45 a.m. 9 Seeing that there are no other members of the 10 public with questions or comments,we will now 11 adjourn this hearing. I would like to thank 12 everyone for their participation. 13 (Which were all the proceedings 14 heard or offered at the hearing 15 of said cause.) 16 17 18 19 20 21 22 23 24 71

McCorkle Court Reporters, Inc. Chicago, Illinois (312) 263-00521 

### STATE OF ILLINOIS 2 

### 3 COUNTY OF COO K 4 ) 

### ) SS: )

5 

### April T. Hansen, being first duly sworn 6 

### on oath, says that she is a court reporter doing 7 

### business in the City of Chicago, and that she 8 

### reported in shorthand the proceedings of said 9 

### hearing, and that the foregoing is a true and 10 

### correct transcript of her shorthand notes so taken 11 

### as aforesaid, and contains the excerpts of 12 

### proceedings given at said hearing. 13 14 15 16

# +L/cd~ Certified Shorthand Reporter

20 19**of~** \ 17 18 

### SUBSCRIBED AND SWORN TO Before me this day 2009. "OFFICIALSEAL" MELISSAALLEGRETTI NutaryPublic.SI,lIcuflIIinuis My**l'ull\lllis.~iun** Exp,()312.UI2012 21 22

### ~"~'~9te**~.** 23 Notary Public 24

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