STATE OF ILLINOIS COUNTY OF COO K SS.
IN THE

# ~L 

# k"k**~Ak'S** 

### vE:O (}f:f:/Ct: 

### JUN10' 

## 8,,'008

# POllu1i~~

# gr:1LINOI Ontr(

### V8 S CIRCUIT COURT OF COOK COUNTY, ILLINOIS 0ard COUNTY DEPARTMENT, LAWDIVISION
I INTHE MATTER OF: PROPOSED NEW 35 ILL, ADM. CODE PART 223 STANDARDS AND LIMITATIONS FOR ORGANIC MATERIAL EMISSIONS FORAREA SOURCES R08-17 (Rulemaking

- Air)



# (

( \, TRANSCRIPT OF PROCEEDINGS held in the above-entitled cause before Hearing OfficerTimothy Fox, calledby the Illinois Pollution Control Board, pursuant to notice, taken before Rebecca Graziano, CSR, within and for the County of Cook and State of 

### I; Illinois, at the Thompson Center, 100 West Randolph,

## I! Room 2-025, Chicago, Illinois, on the 4thDay of June, A.D., 2008, commencing at 9:00 a.m.1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 2 A P PEA RAN C E S ILLINOIS POLLUTION CONTROL BOARD Mr. Timothy J. Fox Ms. Andrea Moore Mr. Nicholas Melas Mr. Anad Rao THE ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY Mr. Rory Davis Mr. Charles Matoesian THE CHEMICAL INDUSTRY COUNCIL OF ILLINOIS Ms. Lisa Frede W.R. MEADOWS, INC. Mr. Dave Carey THE NATIONAL PAINT AND COATINGS ASSOCIATION Mr. DavidDarling HODGE, DWYER, ZEMAN, 3150 RolandAvenue Post Office Box 5776 Springfield, IL 62705 (217) 523-4900 BY: MS. KATHERINE HODGE MS. LAUREN LURKINS Appeared onbehalf of the Illinois Environmental Regulatory Group. ..

; )I' of the Board's technical staff.

and not repetitious orprivilegedwill be admitted Administrative Code 223, Standards andLimitations

I; Also present from Page 3 MR. FOX: The time of 9:00 o'clockhaving

Today we are holding the second Fox, and I am the hearing officer for this come andjustpassed, I want to call this hearing to
Pollution Control Board hearing. My name is Tim order. Goodmorning, andwelcome to the Illinois

Environmental ProtectionAgency on January 2nd of for Organic Material Emissions for Area Sources. proceeding entitled ProposedNew 35 Illinois

the board today are, at my far left, boardmember Andrea S. Moore, who is the leadboardmember for s**I~** this rulemaking, and to my immediate left is Board 

## I; member, Nicholas J. Melas, to my right is Anand Rao R-0817. The proposal was filed by the Illinois The board docket number for this rulemaking is

hearing in this rulemaking. The first hearing took place Wednesday, April 30th, 2008, in Springfield. procedural rules. All information that is relevant 2008, and the Board accepted it for hearing in an

This proceeding is governedby the Board's order dated January 24th of 2008. 1 2 3 4 5 6 7 8 9 10 11 12 

### ( <- 13 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 4 into the record. Please note that any questions that are posed today eitherby the Boardmembers or the Board staff are intended solely to help develop a clear and complete record for the Board's decision and do not reflect anyjudgment orprejudgement or conclusion regarding the proposal. The Board did not receive pre-filed testimony for this secondhearing. If any participant wishes to testify today, there is a signup sheet andpens sitting directing in front of our court reporter. Ifyou do wish to testifYt you certainly would be sworn in andmay be asked questions about your testimony as any otherwitness wouldbe. We will begin this hearing with the Agency. There are questions, clearly, that the participants have for them on the basis of their proposal, and after that, as time permits, any personwho wishes to testify may do so. And as a housekeepingmatter for the benefit of our court reporter, please speak clearly. I don't think amplification will be an issue in this room with this many people, and avoid speaking at the same time as any otherperson so that we canhave a I

I

Iaerosol codings, which is subpart D, starting at 223.400 and going on. So that's


### - - just that for the record.

I And I would note we filed a second

housekeeping issues that came up with the first everyone's gotten it, but the Boardmay not have gotten ityet. This concerns a lot of the, sort of, Page 5 transcript that is clear
-- that is as clear as possible. Do we have any questions before we proceed to the Agency for questions at all? Very well. Mr. Matoesian, ifyou would like to begin.

I I'm not -- I hope MR. MATOESIAN: Okay. Thankyou, sir. Goodmorning. Myname is Charles Matoesian. I'm appearing for the Illinois Environmental Protection Agency. Withme today is Mr. Rory Davis, an engineer with the Agency. Having providing testimony at the first hearing, we are here mainly to answer questions from the Boardand the public. I would state for the record, however, having spoken to the USEPA, the federal aerosol rule is beyond legal challenge at this point. So with the Board's permissionwe will be filing an errata sheet to withdraw our portion of the rule dealing with

errata sheet onMonday. 1 2 3 4 5 6 7 8 9 10 11 12 

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

## ( 1 Page 6 draft of the rule. And with that I will send it

-- I 2 some things back over to the Board. 3 MR. FOX: Very well. For the record, j 4 Mr. Matoesian and I, in discussing procedural 5 matters before hearing began, didmention the 6 Agency's errata sheet NO.2 to one another. To the 7 best ofmy knowledge, that mail service has not been 8 completed on the Board. What we discussedwas if 9 there is interest in seeing it in the course of this 10 hearing today, we could adjourn for a briefbreak, 11 make copies, andhave it admitted in the record so 12 that it was in front of us at the matter of the 

# ( 13 discussion. I plainly see some indication that we 14 would like that to happen, and that participants 15 would like to have the errata sheet in front of them 16 today for the purpose'of the hearing. So we can 17 break at an appropriate time so that is part ofyour 18 record here this morning, Mr. Matoesian. Thankyou. 19 20 it. 21 22 it. MS. HODGE: Oh, we do have a copy of
MR. MATOESIAN: They have a copy of

24 well be arriving in our Chicago office as we speak. 23 MR. FOX: I apologize. It mayvery ; ;

### ( 1 MR. MATOESIAN: Okay. Page 7 Ie 

## I, 2 MR. FOX: And I believe the Boardand I; 3 its staffwouldbe content to await that

-- 4 MR. MATOESIAN: Okay. 5 MR. FOX: based on the technical 6 and housekeeping nature of the errata sheet. But it

## I' 7 appears that I was mistaken that there is not at 8 this point specific interest in having it admitted 9 this morning as a hearing exhibit. Mr. Matoesian, 10 thanks for letting me interrupt. Didyou have 11 anything further you wished to add? 12 13 MR. MATOESIAN: No. That's okay. MR. FOX: We certainly can field

-- 14 Mr. Matoesian, onbehalfof the Agency, can field 15 any questions. If anyone does have a question, if 16 would they please raise theirhand so that I may 17 recognize them. Andplease, if theywould, for your 18 first question, indicate who youmay represent and 19 inwhat capacityyoumay do so in addition to your 20 name. Miss Hodge, I believe you have a question. 21 22 23 MS. HODGE: Myname is Katherine Hodge, H-o-d-g-e, and I'mwith the law firm Hodge, Dwyer, Zeman, here today representing the Illinois 24 Environmental Regulatory Group.(Witness sworn.) Page 8 MR. FOX: AndMs. Hodge! I should have done this first of all. Before the Agency does accept questions! it wouldbe best! I think! for the court reporter to swear themboth in.

that such emission reductions will amount to 14.2 percent for the consumer and commercial products rule that's proposed here beyond those achievedby the federal rule. Has the Agency used the 14.2 percent reduction from the consumer and Mr. Davis! and the first question goes to the statement in the Agency's technical support document

-- and would it be better if I movedup for this? Okay. And as I said! this goes to the Agency's technical support document! and in particular! Mr. Davis! in the Section 2.7! reduction of the Illinois emissions in Illinois! it's on Page 29 of the TSD. The Agency says that the emission reduction from this proposed rule will help Illinois attain the eight hour national ambient air Swearhim in.

The TSD further states I have a few questions for Swearhim in. MR. FOX: MR. MATOESIAN:

MS. HODGE:

quality standardby 2010. 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24Page 9

that inwriting. I'mnot -- I wasn't involvedwith I) attainment demonstration.

believe that there is sufficient time for effective we leave today. I:

I I I I:

We can answer that in

I believe that was the Yeah. I' 

## I;

I I wouldhave to respond to I MR. DAVIS:

MR. MATOESIAN: MR. DAVIS: I wasn't involvedwith the

MR. DAVIS: MR. FOX: Andwe can deal with the MS. HODGE: Okay. That's fine. MR. DAVIS:

MS. HODGE: The proposedrule has a MR. FOX: Mr. Davis, I'm sorry. If commercial products rule in the attainment demonstrationmodeling as conducted and recently completed?

writing.

timing deadlines for filing ofpost hearing before attainment demonstration. I believe we probably

compliance date ofJanuary 1, 2009. Does the Agency did, but I couldn't say for certain, and I can --

parties to implement the provisions of this rule? assumption, yes. you could give us a little more volume. 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 241 Page 10 ' MS. HODGE: Okay. Thankyou. If 2 compliance with the ozone standard is to be 3 demonstratedby June 15th, 2010, as requiredby 4 federal rule, is it correct that only the 2009 ozone 11 5 season couldpotentiallybe influencedby the 6 provisions of this rule? 7 8 question? 9 MR. DAVIS: Couldyou repeat the
MR. FOX: And, Mr. Davis, I'm sorry to 10 interrupt again. We really need to have you speak a 11 little more clearly, please. 12 MR. DAVIS: She's sitting right here. 13 MS. HODGE: Yeah. If compliance with 14 the ozone standard is to be demonstratedby 15 June 15th, 2010
-- which is myunderstanding as the 16 requirement of the federal rule, and I thinkyou 17 offered testimony in that regard to the first 18 hearing

-- is it correct, then, that only the 2009 19 ozone season couldpotentiallybe influencedby the 20 provisions of this rule? Meaning, is it true that 21 we would only get the benefit from the 2009 season? 22 23 MR. DAVIS: Yes. MS. HODGE: Okay. Thankyou. Why has 24 the Agency waiteduntil this point in time toPage 11

MS. HODGE: Okay. Thankyou.,) MR. FOX: Mr. Davis, if I may, when) j

### , j MS. HODGE: That's fine. Whendoes

really know. July. It keeps getting pushedback. So I don't I. Fair enough. MR. FOX:

I think I testified to that at the first MS. HODGE: That's fine. Thankyou. MR. MATOESIAN: And if I could, MR. DAVIS: I think we proposed the

A. That we are not sure about. Last year industry and tried to get everything consistent as was possible with all the input we took from

Mr. Davis

-- in the policymaking decision, so we rule and tried to get it filed as soon as -- as soon

Mr. Rory isn't involved in the policymaking

-- or propose the rule?

we heard that it wouldbe inMay of last year. More could answer that after discussing with the management.

the Agency expect the USEPA to propose and promulgate its federal consumerproducts rule?

hearing. Now I've been told it will be somewhere in recently, we heard that it wouldbe inMay of this year. 1 2 3 4 5 6 7 8 9 10 11 12

" 13 

## ( 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 12 you referred to July/ is that July of this year/ 2008? MR. DAVIS: Yes. MR. FOX: Thankyou. MR. DAVIS: But again/ we aren't really counting on seeing it in July. MS. HODGE: Does the Agency have an expectation that the compliance date for the federal consumerproducts rule will be beyondJanuary 1/ 2009/ or do you -- ordo you know? MR. DAVIS: I couldn't speculate on that based onwhat they'll find in the ruling. MS. HODGE: Okay. The Agencyhas stated in its statement of reasons/ and also I think at the first hearing/ that it's basing its proposed rule in this proceeding on the ozone transport commission/ or the OTCmodel rule. Couldyou clarify whether the Agency's proposed rule in this proceeding and the supporting documentation that's beenpermitted as basedupon the 2001 version of the OTCmodel rule/ or is it basedupon the 2006 version of the OTCmodel rule? MR. DAVIS: I believe that whenwe started it was more based on 2001. As we went :

,
,.eachdocument. A consistent with the

-- with the current OTCmodel

MR. DAVIS: I wouldhave to check on rule most consistent with the current OTC rules. We

I

I

Why is the 2001 it is probably

here's the Agency We tried to make the

MS. HODGE: Okay. Thankyou. So that

MS. HODGE: Okay. Let's do that. industry onwhat changes couldbe made to make our Page 13 through the process, we took lot of input from

-- you went into my next question.

the Illinois EPA's TSD, and ifyou'll look at limits and the technical aspects of the rule very

earlier, and I believe that there wasn't much rules. So I would say that the closer to the 2006 and its limits, but I think a lot

Let's take a look at the do write our rules in our own format, so it's not

of the technical support might have come from precisely the OTCmodel rule.

rule not included as a reference? updating to that technical support for the 2006 ruling. 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24Page 14 1 Page 63 and then over to Page 64, ItemNo. 16, we 2 have the model rule for consumerproducts, ozone 3 transfer commission ofNovember 29th, 2001. 4 MR. DAVIS: Like I said, I believe 5 that we startedbefore we had a 2006 final model 6 rule from the OTC, and I believe that most of our 7 technical support was for

-- was from that time 8 period, the

-- we certainly could include 2006 rule 9 inour references. But like I said, neither rule 10 was the sole basis for our rule. We write our

12 lot on the industry input to get ourOTC
-- or our 11 rules, you know, in our own format, andwe relied a ,
-, 13 rule to be consistent with the OTC. 14 MS. HODGE: Okay. I wouldjust like 15 to clarify on one ofyour statements. So is ityour 16 position that the Agency reliedprimarilyupon the 17 2001 version of the rule?

records to get to where many of our limits were. 18 19 20 21 22 MR. DAVIS: No, I wouldn't say that. I
-- we probably shouldhave included that in the 

### : g And like I said, we can include that now if it would; be helpful for comparison. 23 MR. FOX: Mr. Davis, from the Board's 24 perspective, that wouldbe helpful if it's part ofaPage 15

I MS. HODGE: And that's part ofwhat I MR. DAVIS: Sure.

I

I'mnot certainnot having Those white papers are



# I' I couldprobably come up with

### Ii the Mack Tech white paper side is the basis for the this wouldbe on Page 63 of the TSD. Inparticular, post-hearing comment that was asked

paper, and that's reference number three, and again, commercial products called the Mack Techwhite white paper for the course category of consumer

MR. FOX: And am I correct, Mr. Davis, Agency states that it relieduponMack Tech interim I'll be addressing in a few minutes too. Thankyou. Okay. Again, in the TSD, inAttachmentA, the

MR. DAVIS: result from implementing the OTC model rule. Do you

model rule? was based on the 2001 or the 2006 version of the OTC 14.2 percent reductionVOM emissions that will

that and submit that also if it wouldbe helpful. : recent we have today. know if the information in the Mack Techwhite paper**.~** updated from time to time, andwe get new copies and" I' we certainly try to keep up with the latest copy. I;**I~** My guess wouldbe that's probably not the most a copy in front ofme. 1 2 3 4 5 6 7 8 9 10 11 12 13 \ 14 15 16 17 18 19 20 21 22 23 24reference number three refers to an interimwhite

this would indicate that the 2001 OTemodel rule was MR. DAVIS: Yeah. I would say that
MR. FOX: Very good. Thankyou.

I MR. DAVIS: It could, but that's not MS. HODGE: That was mynext question. Page 16 if I may interrupt a moment Ms. Hodge, that the

MR. FOX: Please go ahead.

MR. DAVIS: But being December 2005, I MS. HODGE: Oh, that's all right. paper datedDecember 1st, 2005. Is that correct?

MS. HODGE: Is that -- Ms. Hodge, I'm sorry for interrupting. probably

-- well, I can't speculate on it.

the basis for the Mack Techwhite paper? said is datedJanuary 1, 2005, don't you think that So wouldyou agree that perhaps that this reference from the interimwhite paper that, again, as Mr. Fox

I: 

### I: always the case. Many times they

-- Mack Techworks I{ I; for Labco (phonetic), who does a lot ofour research I; I'· for us. Many times they anticipate what kind of
wouldhave to check with them to see if they were basing that on 2001 or 2006. reductions wouldbe achievedby different rules. 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24 I 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 Page 17 really couldn't say. MS. HODGE: Thankyou. Is that something that the Agency could also address in writing

-- MR. DAVIS: Yeah. MS. HODGE:
-- as well as if there have been any updates provided that are in the record? MR. FOX: And in this case, you anticipatedmy question, Ms. Hodge, so I thankyou for doing so. MS. HODGE: Okay. Andwe're going to go back and look at this list ofreferences one more time, and reference number 18, which is a report preparedby EH Pechan andAssociates Inc., entitled Control Measure Development Support Analysis of Ozone Transport CommissionModel Rule, and I'm going to call this the Pechan document, and it's dated March 31st, 2001. Because of its date, wouldn't it make sense to assume that this document was also prepared in reference to the 2001 OTC model rule and not to the 2006 OTCmodel rule? MR. DAVIS: Yes. MS. HODGE: Okay. And

-- Pechan?

### Page 18 MR. DAVIS: Yes.

MR. DAVIS: Yes. MR. DAVIS: Yes.

model rule?

I

## I'

Couldyou, just for the

I know that a few categories MR. RAO:

I believe we added those categories.

MR. DAVIS: I don't know what you MR. RAO: May I ask, Mr. Davis, are

MR. RAO: And some ofthese changes MS. HODGE: Thankyou. Andwouldyou

MS. HODGE: Okay. Thankyou. the EH Pechanreport, inparticular in support of the 14.2 percent emission reduction? also agree that the MackTechwhite paper sites to

it's essentially the same. limits were changed. from the 2001 rule to the 2006 rules?
would call significant. I know that some of the

different categories. There were significant were added. record, comment onhow significant the changes are

certainproducts and to put certainproducts in changes, I guess, but not -- structurally I think Some of the definitions were changed to include you familiar with this inyourversion of the OTC 1 2 3 4 5 6 7 8 9 10 11 12 

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

### ( 1 2 Page 19 are reflected inyourproposal? MR. DAVIS: Yes, yes. But as I said, 3 4 those changes the 2006 rule and I apologize for not including most of those changes were made 5 upon commentby an industry when they submit 6 comments to us saying "You should really change this 7 part to reflect the new OTC rule," and ourgoal 8 certainlywas to stay consistent with the most 9 current OTC model rules and California rules, and I 10 believe Mr. Biel complimentedus for taking their

14 would it be possible for you to highlight some of 

# ( 11 12 13 comments seriously and implementing those changes. MR. RAO: Okay. Since you will be submitting that document later inyour comment, :

15 these significant changes andhow they're reflected 16 17 18 inyour rules?MR. DAVIS: Sure. MR. RAO: Since it will be : 

### ;

19 post-hearing, it wouldbe helpful to see where those 20 things are. 21 22 MR. DAVIS: Sure. MR. RAO: Thankyou. 23 MR. DAVIS: I believe there's a red 24 line version from 2006 to 2001. I don't know that

I;Page 20 1 that wouldbe an official document that OTe 2 released, but it maybe helpful. I might be able to 3 corne up with that. I know that I had itpersonally. 4 That couldbe helpful 5 MR. RAO: Yeah. 6 MR. DAVIS:

-- just to see they're 7 highlighted inyellow andblue. So that's

-- it was 8 helpful to me certainly. I' I 9 MR. RAO: Ifyou could get the release

14 apologize it's in black andwhite. So ifyou go to 

## ( 10 11 12 13 for the document or something like that, that would be helpful for us. Thankyou. MS. HODGE: Thankyou. And I do have a copy of that document that we're discussing, and I
15 the webpage, you can actually see, you know, the 16 highlighted colors. I've given a copy to counsel 17 for the Agency, and thenhere's a copy for the Board 18 that I'd like to move have this admitted as an 19 Exhibit for today. Do you wantme to describe it? 20 MR. FOX: Actually I think we've had 21 probably a sufficient description ofwhat it is and 22 we can certainly rely on that, Ms. Hodge. 23 24 MS. HODGE: Thankyou. MR. FOX: Thanks for your willingness.

### I; [: 

### I; Davis, are

### I'

I would sayyes, and I MS. HODGE: Thankyou. Mr.
MR. DAVIS: Yes.

MR. DAVIS: MS. HODGE: Did the Agency rely on

MS. HODGE: Okay. Thankyou. I would Page 21 We do have a motion fromMs. Hodge onbehalf of IERG to admit as what wouldbe Exhibit No.3, as she

into the record of this hearing as Exhibit NO.3? Ie described the 2006 version of the OTe draft ormodel

I

I

Ms. Hodge, for the copy of that document. rule. Is there any objection to admission of that

to 2006, but yes. this document in developing the regulatoryproposal

thinkwe relied on it solely for changes from 2001 wouldhave to apologize for not including that in the reference the documents relied on. I don't Neither seeing nor hearing any, it will be so marked and admitted as hearing Exhibit NO.3. Thankyou,

notes, and I think I'm going to read this statement about mid-way down the page there's some notes, five
from this coverpage, cover Page 1 of the document, askyou to turn to Page 1 of this document, and for this proceeding? you familiar with this document? 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24j us?

hazardous nature are included in this model for

each state to decide whether it wishes to include Such This Page 22 I "This model rule was developedby

OTC takes no position onwhether to
States opting to promulgate rules MR. DAVIS: Notes one, two, and three?
MR. DAVIS: "Certain compounds into the record.

MS. HODGE: Mm-hmm, yes. the Ozone Transport Commission as part of a regional
standard and reduce eight hour ozone levels. effort to attain andmaintain the eight hour ozone

hour standard in areas." And then I would ask you to look at notes, inparticular one, two, and three, is an amendment to the November 29th, 2001, model rule, developedby the OTC states to address the one

include these pounds in such a way. and wouldyoumind reading those into the record for

rulemaking. affectedby this model rule may not cause or

regulation of said compound and its state-specific I; compounds are under other state authorities. convenience of the state, whichmay regulate such compounds are noted with an asterisk, and is up to contribute to formation of ozone, but due to their 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24 (1 2 3 4 5 6 7 8 9 10 11 12 

### (-- 13 14 15 16 17 18 19 20 21 22 23 24 Page 23 based on this model rule must comply with state-specific administrative requirements and procedures, underline text, and are changes made to the original OTC model rule datedNovember 2nd, 2001, inbold text, our references to agencies outside the OTC. OTC states, sections, titles, and for special points of interest. The term OTC state or an OTC state agency are placeholders for individual statement names. MS. HODGE: Thankyouverymuch. Couldyou go to Page 20 of this document now, please? And down at the bottomof the page, number three standards, and then it starts with a table of standards. And then if we go over to the next page, Page 21, is it -- is it yourunderstanding, then, that the items that are underlined that these are the new categories that were added in the 2006 version of the rule? MR. DAVIS: Yes. MS. HODGE: Okay. And are these

-- these underlined items, are they included in the Agency's proposal in this proceeding? MR. DAVIS: I believe they are. MS. HODGE: Okay. So we have

-- onPage 24 1 Page 21, is it correct that we have newproduct 2 category for adhesive removers? 3 4 MR. DAVIS: Yes. MS. HODGE: Okay. Andwe have some 5 subcategories under adhesives for contact general 6 7 8 purpose and contact special purpose? MR. DAVIS: Yes. MS. HODGE: Okay. Under air : ; 9 fresheners, we have a new subcategory for 10 semisolids? 

# ( 11 12 13 14 MR. DAVIS: Right. MS. HODGE: We have a brandnew category for anti-static products, non-aerosol. And; ifyou go over to Page 22, we have several

-- 15 several more new categories that are in the 2006 16 rule, but not in the 2001? 17 18 19 20 21 MR. DAVIS: Right. MS. HODGE: We have electrical cleaner and electronic cleaner. Is that correct? MR. DAVIS: YUp. MS. HODGE: Okay. We also have

-- the 22 fabric refreshener category is new, footwear leather 23 care products is new. Is that correct? 24 MR. DAVIS: Yes.1 Page 25 MS. HODGE: Anothernew category here, 2 graffiti remover. On Page 23, similarly, we have a 3
-- is it correct that we have a new category for 4 hairstyling products? 5 6 7 8 9 MR. DAVIS: MS. HODGE: for shaving gel? MR. DAVIS: MS. HODGE: Yes. Do we have a new category
Yes. Do we have a new category 10 for toilet/urinal care?


# ( 11 12 13 14 15 16 17 MR. DAVIS: Yes. MS. HODGE: And then finally on this page, do we have a new category for wood cleaner? MR. DAVIS: Yes. MS. HODGE: On Page 24 -- MR. DAVIS: I believe that's MS. HODGE: 1 1msorry. Those are 18 subcategories ofwood cleaner, I believe. So all of 19 these categories that we've just identified, these 20 are all

-- these are some of the significant changes 21 in the '06 rule versus the '01 rule. Is that 22 correct? 23 MR. DAVIS: Yes. And I should 24 clarify, some of these were included in the previousPage 26

I 1 rule, and they're more specific categories than were 2 in the previous rule. Forinstance, the hairstyling

### I} 3 products might have beenunderhairstyling gels 4 before, or shaving gels might have beenunder 5 shaving creams. They've got a sevenpercent max. I 6 believe that was addedbecause shaving creams hada 7 five percentmaximumpercentage and shaving gels got 8 sevenpercent. So some of those are -- were 9 included in the the products themselves were 10 included in the original rule, but then were given a

## I'

I 11 more specific category. 12 MS. HODGE: Okay. Thankyou. Could I 13 we turn to Page 29 of this document now, please? I 14 15 And in sectionNo.4 on Page 29, we have a list of exemptions, and I would turnyour attention down to

# I ~ 16 itemNo. I, andwouldyou agree that the 17 strikethrough in this provision changes an exception 18 from the '01 rule to the '06 rule? 19 20 MR. DAVIS: Yes. MS. HODGE: So is it accurate that 21 under the 2001 rule the exemptionwould apply to air 22 fresheners and insecticides containing at least 23 98 percent paradichlorobenzene? 24 MR. DAVIS: Yes.Page 27

we have products that are being sold in Illinois now I' MS. HODGE: Okay. Thankyou. Since 17

rule, and that rule did not include these new MR. DAVIS: That's correct.

### I ~

II' But for the 2006 rule, the Yes.

I' I would say it's possible, Is that true? MS. HODGE: MR. DAVIS: MS. HODGE:

MR. DAVIS: it appears, at least to me here today, that the exemption only applies to insecticides containing

the original. I believe inmy testimony and in the technical support document, we said that the rulemaking on the 2001 OTC model rule, including the Agency based the technical support for its
emission reductions achievedby the 2001 OTC model 98 percent paradichlorobenzene. Is that correct?

but the categories that are added, like I said, some of them are more specific categories than were in

that are compliant because of the California and OTC significantlymodified, is it true that the Agency's goal of the Illinois emission reductions couldbe achieved without these categories?

reductions couldbe less than 14.2 percent because categories, and in at least one exemptionwas 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 13 \ 14 15 16 17 18 19 20 21 22 23 24 

## ( Page 28 model rules. So 14.2 percent wouldn't be an exact figure. I believe that's in the TSD and in the

-- my testimony. And also to include themwhile

-- if 

## I; you wanted to take that 14.2 percent to be an exact number, then the additional categories wouldbe additional reductions, whichwould also be helpful with the attainment demonstration. MR. MATOESIAN: And I thinkbeyond that, we'll get more fully into this inwriting. MS. HODGE: That's fine. Thankyou. I'd like to turnbacknow to the Agency's technical support document, and couldwe go to Page 30 of that, document, please? I'm sorry. Let's go back to Page 29 to start with. Section 2.7 here is reduction of the Illinois emissions in Illinois. There's a narrative, and then there's a table over on Page 30, table 2.7.1. estimating the Illinois emission reductions for consumerproducts. Is that correct? MR. DAVIS: Yes. MS. HODGE: Couldyou tell me what the**I~** number ten footnote means? Is that a reference to your reference document number ten? MR. DAVIS: It couldbe, yes.

## ( 1 Page 29 MS. HODGE: And couldyou tell me what 2 that document is, please? 3 MR. DAVIS: That is a technical 4 support document from the state ofNewJersey that 5 listed all of the categories that were in the rule 6 at that time, and the reason that I used the 7 document from New Jersey was it was the most concise 8 table. It's actually taken from Californiadata, 9 but it was nicely put together, and that's why I 10 used those. 11 MS. HODGE: So the Agency didn't do 12 its own independent analysis of emission reductions 

# ( 13 14 15 16 17 18 for its consumerproducts rule? MR. DAVIS: No. MS. HODGE: Andwhat's the date of this New Jersey document? MR. DAVIS: 2003. MS. HODGE: Do you think it's likely I

19 that this 2003 NewJersey report covered only the 20 categories in the 2001 OTC rule? 21 22 yes. 23 MR. DAVIS: I think that's likely,
MS. HODGE: So if I go back and look 24 at this table, 2.7.1, does this table include these

I I'Page 30 1 new categories that we identifiedjust a few minutes 2 ago from the OTC 2006 rule? Does this table include 3 those new categories? 4 5 others. 6 MR. DAVIS: I would say some andnot
MS. HODGE: Okay. Couldyou go 7 through and showus, please, where it doesn't show
9 that wouldbe easier to address inwriting

-- 8 the new categories? And if that wouldbe something ·



# ·

· 10 MR. MATOESIAN: That wouldprobablybe

, 11 much easier.' 

# ( 12 13 14 15 MS. HODGE: All right. I would ask that we do that. MR. DAVIS: Sure. MS. HODGE: So ifa category is not 16 listed in this table, is it correct to state that 17 the Agency really didnot consider emission 18 reductions associatedwith that category? 19 20 21 22 23 MR. DAVIS: As I said, some of the

-- some of the categories are more specific categories.


## , So I would sayperhaps andperhaps not, because some of the new categories wouldbe included inhere. MS. HODGE: All right. Thankyou. So 24 is it accurate to say that the Agency didnotPage 31 . 1 include the ozone reducing impact ofreduction

-- of 2 emission reductions from at least some of these 3 4 5 categories? MR. DAVIS: MS. HODGE: Yes. Does the Agency know the I'

6 emission reductions to be achieved from adding these 7 additional categories? 8 MR. DAVIS: I would say no. The 9 Agency doesn't really have the resources to do it 10 case by case. As a determination, we did rely on 11 New Jersey andMack Tech, Labco, and California.

14 additional categories for its '06 rule? 

# ( 12 13

15 16 17 MS. HODGE: Do you know whether the OTC estimatedemission reductions for these
MR. DAVIS: That I wouldhave to check on. MS. HODGE: Okay. And that's 18 something to be submitted, right? 19 20 MR. MATOESIAN: Okay. MS. HODGE: We wouldneed that too. 21 Since it appears that the Agency, at least to me 22 here today, based its rulemaking on the 2001 OTC 23 model rule, and the 2001 OTCmodel rule does not 24 include these additional categories, is it true thatI

Did the Agency consider the cost associatedwith ;

Agency wouldnot have considered the cost. Is that correct? j

, MR. DAVIS: Yes. 

### ; '. Couldyou repeat that? MS. HODGE: Certainly. We've been MR. DAVIS:

MS. HODGE: And so the question is: MR. DAVIS: Sure. Page 32 the Agency didnot consider the cost for compliance

MR. DAVIS: I would say as far as they talking about whether ornot the Agency considered the emission reductions associatedwith the associatedwith regulating these additional categories?

whether the Agency analyzed the cost -- the

MS. HODGE: Thankyou. So if the additional categories, and this question goes to

were consideredby the otherresources that I have additional categories. compliance cost associatedwith adding these

compliance for the cost of these additional categories?

mentionedpreviously.
otherresources didnot consider the costs, then the 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24that Exhibit NO.3? 1 2 3 4 5 Page 33 MS. HODGE: Okay. Thankyou. Also, we hadmentioned early on in this OTe document

-- is
.

.. ; MR. FOX: Number three, yes. ; MS. HODGE: Thankyou, Mr. Fox. We 6 hadmentioned the change to the exemption for
8 Agency didnot consider the cost of compliance as 7

9 10 paradichlorobenzene. So is it also true that the
associatedwith this modified exemption? MR. DAVIS: That's possible. I would 

### ·

·



### ·
11 have to -- I wouldhave to retrace where we were 12 getting our cost effective numbers

-- where our cost
that that did include that, then I would say it was 

# ( 13 14 impact numbers from. If theywere from a document

• , 15 16 17 18 included. If theywere not, then I would say they were not. MS. HODGE: Okay. Thankyou. MR. DAVIS: And as I stated, neither 19 one nor the otherwas the sole basis. I think a few 20 questions ago, that's why I was asking you to repeat 21 it. I thinkyou've said a number of times that we 22 are basing it on 2001. But I don't think that's 23 wholly accurate. 24 MS. HODGE: Okay. Thankyou. ThanksPage 34 1 for that clarification. Do you knowwhether the OTC 2 estimated the cost for compliance for adding these 3 additional categories?

I 4 MR. DAVIS: I wouldhave to check on I

I 5 that. 6 MS. HODGE: Ifyou could, please. 7 Okay. I would

-- and I'm sorry for this jumping 8 around, but I just I want to keep the subject 9 category together. Couldwe turnback to the 10 Exhibit 3, and inparticular the note number one, 11 andjust to go back and revisit it. So is it your 12 understanding that the newly listed categories that 

# ( 13 14 include an asteriskbeside it in this document, that OTC is saying it's up to the state to decide whether ., That is myunderstanding, MR. DAVIS: it wishes to include regulation of those categories? , ;; 

# , 

# ; yes. 17 15 16

18 MS. HODGE: And isn't it true that the 19 OTC also concluded that certainof these compounds 20 may not cause or contribute to formation of ozone 21 

### I: but are listedhere only for theirhazardous nature? 22 MR. DAVIS: Yes. 23 MS. HODGE: Okay. Did the Agency do 24 any independent analysis of these compounds with the1 2 Page 35 asterisks beside to determine whether there was really any airquality impact from

-- on ozone I'

### I~ 3 formation? 4 5 MR. DAVIS: I don't believe so. MS. HODGE: Okay. And couldwejust I

6 take a look, for the record, and identify some of 7 these that have the asterisks beside them, please? 8 I would askyou to go to page I
9 10 MR. DAVIS: 24? MS. HODGE: Thankyou. I think that's I 11 where I'mgoing. I thought I had all ofmy tabs 12 here. Please let's start on Page 24. Ifyou could 

# ( 13 14 15 just describe some of these that are optional. MR. DAVIS: If I could describe them? MS. HODGE: Mm-hmm. Just identify 16 them

-- just identify them, please, for the record.l 17 MR. DAVIS: Well, there's 18 antiperspirants and deodorants that contain any 19 compound identified in Title 17, 3 chapter I, 20 subchapter 7, Section 93000 as a topic air 21 contaminant. There's also solid air fresheners and 22 toilet/urinal products that contain 23 paradichlorobenzene? 24 MS. HODGE: So excuse me, Mr. Davis.

### ( 1 Page 36 Wouldyou agree that those things were probably 2 listed onlybecause of theirhazardous nature as 3 determinedby California, the state of California? 4 5 MR. DAVIS: Yes. MS. HODGE: Couldwe go over to 6 Page 27, and I would direct your attention to the 7 subcategory I
-- the age is stricken through 8 products containing ozone didhe completing 9 compound. So is it yourunderstanding that these, 10 too, would've been something that would've been 11 optional? 

# ( 12 13 14 MR. DAVIS: I don't know that that wouldbe optional, or -- yes, I guess it wouldbe. MS. HODGE: Okay. And did Illinois 

# .

• 15 EPAmake any kind of independent analysis on that? 16 17 18 MR. DAVIS: I don't believe we included the table, and yes, there was some -- there

### I! was some analysis ofwhetherwe should include it or 19 not. I wouldhave to check and see if I had any 20 notes on that. I believe that I thought that these
but I wouldhave to checkback and see -- andwe 21 22 [ compounds were already coveredunder something else,

## I; I' 

## I; I; 23 just thought it was extraneous to include it again. 24 MR. MATOESIAN: We can do that in

### ( 1 2 3 Page 37 writing, perform that inwriting. MR. FOX: Thankyou. MS. HODGE: That's fine. Thankyou so 4 much. On to Page 28, this subcategoryL, 5 requirements for contact adhesives, electronic 6 cleaners, footwear, leather care products, and 7 all-purpose degreasers. So you're understanding 8 that the OTC, too, is indicating that this is 9 optional for the sates, these categories? 10 11 MR. DAVIS: Yes. MS. HODGE: And down onM, middle of 12 page on two, requirements for adhesive removers, 

# ( 13 cleaners, and graffiti removers, is it your 14 understanding, too, that those wouldbe optional for 15 regulation? 16 17 MR. DAVIS: That's right. MS. HODGE: Okay. Page 29, at the top 18 of the page, N, subsectionN, requirements for solid 19 air fresheners and toilet/urinal care products. Is , 20 it yourunderstanding that this category that

-- I'm

## , 21 22 23 24 sorry -- the OTC had determined that this category was optional by the states as well? MR. DAVIS: Yes. MS. HODGE: Are you aware that the



### , ;I MR. DAVIS: Yes. inadvertent admission. omission?

I

I

I



### I: I' II, 

### I:

I MS. HODGE: Well, I did, I did. MR. DAVIS: I thought you said 2001. MR. DAVIS: I don't believe I

MR. DAVIS: All right. MS. HODGE: Is it the Agency's intent MS. HODGE: Okay. Has the Agency MR. DAVIS: Sure, yes.

MS. HODGE: So it's the Agency's MR. DAVIS: That mayhave been an MS. HODGE: However, it's not in the Page 38 Agency's proposal includes the category ofnail polishremovers at proposed Section 223.205?

intent to regulate nail polish removers? product category and limits. Was thatjust an TSD at table 2.2.1, which is proposed regulated

with the technical and economic informationprovided

to maintain its proposal to adopt a state version of Ie**I~** in this record to support the 2001 OTCmodel rule? considered amending its proposal to be consistent

the 2006 OTC rule? understand what you're askingme. As far as 1 2 3 4 5 6 7 8 9 10 11 12 

### ( 13

" 14 15 16 17 18 19 20 21 22 23 241

MR. DAVIS: I believe that we've I I', stated that we would be willing to provide any of

for Illinois. II, Page 39 MS. HODGE: And it's my understanding and I know that you don't necessarily agree

MS. HODGE: Thankyou. And where

-- MR. MATOESIAN: We can get that back withme about this today

-- but again, it appears to that

me that a lot of the support here that's in this

OTC model rule. So my question is really two parts. One, does the Agency
-- has the Agency considered actual regulatoryproposal is modeled after the 2006

to you. record is in support of the 2001 OTC model rule, and

amending its proposal so that it wouldbe consistent with the support, or in the alternative has it
2006 version?

industrymainly to try to get a very consistent rule the additional support we can find for the 2006 considered offering the additional support for the yet it's also my understanding that the Agency's

rule. And as I've statedbefore, obviouslyboth rules were considered, and we worked with the

where the resource material

-- you've stated that 1 2 3 4 5 6 7 8 9 10 11 12 ( 13 14 15 16 17 18 19 20 21 22 23 24categories, will the Agency go forth and do it's own I·

MR. MATOESIAN: We'll respond to that. Page 40 I you relied upon other entities and other states in

that the Agency doesn't have the resources to go

I In the event

Thankyou. That's all I I
-- I couldn'tpromise

MR. FOX: Very well. Thankyou, MR. MATOESIAN: We can answer that one

MS. HODGE: MR. DAVIS:

MS. HODGE: Okay. And this is a the impact either, youknow, the technical support

that today. of those entities and states perhaps didnot address conducting some of the analysis here, andwhere some

in writing too.

were interested in asking questions, and if I may this rule without that kind of analysis?

Ms. Hodge. There were otherpersons, I know, who that the Board shouldmove forward with adoption of analysis to support those additional categories? or the economic information for these newly added

forth and do that, would it be the Agency1s position

have today.

make one quickhousekeeping announcement first of policy question, too, Mr. Matoesian. 1 2 3 4 5 6 7 8 9 10 11 12 13 \ 14 15 16 17 18 19 20 21 22 23 24director of environmental affairs for the National the court reportermay know who you are. ifthey don't wish to do so. But I believe someone persons who wish to testify will be sworn in andmay

fromI; 

### I) Ii If I couldjust ask I'mDavidDarling,

Wouldyou like to do so I wanted to make sure that anyone who

MR. DARLING:

MR. FOX: hearingbegan. Posted directly in front of the

MR. FOX: Very good. Thankyou for Page 41 all, we didhave some folks who arrived after the

MR. DARLING: Actually, I gave her a be asked questions on the part of other court reporter is a form onwhichyou can signup if

possibility, althoughno one is required to testify

identifying yourselfby name and association so that participants. did arrive afterwe beganknew that that was a

indicated that they wanted to ask a question, and, you wish to testify. And like otherwitnesses,

there, or come up to the chair? Paint and Coatings Association. sir, ifyou wouldn't mindbefore beginning, just

; business card. '

a couple questions. doing that. 1 2 3 4 5 6 7 8 9 10 11 12 

### / 13 

### \ 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 42 ; MR. DARLING: Okay. I'll come up. MR. FOX: Whicheverworks for you. MR. DARLING: Hopefully I'll be a little bit shorter. We appreciate all the changes that Illinois EPAhas made with regards to the EOC rule. I justhave a couple clarifying questions. Well, as far as appreciation, you clarifiedVOM and VOC that they are identical, which is a good step forward. You also clarified that instead of allowing orrequiring industry to respond with a 30 days of a writtennotice, you've now gone to 90 days. Again, we appreciate

-- that's consistent with our comments. I do have two other comments for your consideration. We sent in a letter onMay

. 19th. To be consistent with OTC, there is one category that we missed with all the back and forth.

## i; MR. FOX: Mr. Darling, if I could interrupt you for one second, that is marked in the Board's record as public comment, or PC number two. But I apologize for interrupting. Please go on. MR. DARLING: No problem. Thankyou verymuch for the clarification. And

-- yes. And so -- just that I understand the intent is to try to be like the OTC states, so we request -- we would

# I ~Page 43 1 appreciate if Illinois EPA can include the category 2 concrete surface retarder as a definition, a limit 3 of 780 grams per liter, and include concrete surface

## i; 4 retarder in the most restrictive limit as identified 5 in the letter. Again, this is to be consistent with 6 the OTC states ormodel rule. 7 I did have one other comment. I 8 Like the aerosol rule you spoke about earlier, will 9 Illinois EPA
-- it was ourunderstanding that I 10 Illinois EPA, when the national aim rule is revised 11 hopefully in a year or so, that Illinois would also 12 rescind their rule and adopt the national rule. 

# ( 13 14 That was ourunderstanding in the past. clarify? Couldyou

15 MR. DAVIS: That

-- 16 MR. MATOESIAN: We'dhave to make a 17 decision once we see the federal rule. 18 MR. DARLING: Ourunderstanding is 19 hopefully it's going to be verymuch like the OTC 20 model rule. 21 22 also. MR. DAVIS: That's ourunderstanding

23 24 MR. DARLING: Okay. MR. MATOESIAN: We couldn't speculate j

.

,Page 44 1 until we see it in writing. 2 MR. DARLING: Is it yourunderstanding I 3 that hopefully if it**~s** consistent with the OTC, 4 would that be a better or easier decision onyour 5 part, or it's hard to say? 6 7 point. 8 9 MR. MATOESIAN: Hard to say at this
MR. DARLING: That's it for me. MR. FOX: Mr. Darling, if I may 10 interruptjust for a moment. Yourpublic comment 

## ( 11 12 13 14 15 16 had included a definition of concrete surface retarder and in the company limit. Do youknow whether the agency agrees with the inclusion of the language you hadproposed in that rule, orperhaps Mr. Davis could answer that question? MR. DARLING: I do not know. We I I

17 submitted the comment. We would certainlyhope that 18 to be consistent with the OTC rule. 19 MR. DAVIS: Sure. We'll have to check 20 on that andmake sure that's something that wouldbe 21 22 consistent with the OTC model rule. MR. FOX: And if that could also be 23 addressed in a post-hearing comment, that wouldbe 24 certainlyhelpful to the Board.1 2 3 4 5 Page 45 MR. DAVIS: Sure. MR. DARLING: Just to clarify, this came out of directly, I believe, NewYork and Pennsylvania. MR. FOX: And specifically, the 

## I'

I 6 definition is consistent with those two states. 7 MR. DARLING: Right, correct. 8 Actually, all three, the definition, the limit, and 9 10 -- there's three parts. MR. FOX: And that last categorization 

# ( 11 12 13 14 15 16 17 is under the most restrictive limit as well. Very well. Thankyou, Mr. Darling. Didyouhave more questions for the Agency at this time? MR. DARLING: No. MR. FOX: Very well. MR. DARLING: Thankyou. MR. FOX: Thankyouverymuch. I see 18 one more indicating that they'd like to make a 19 question, and also ifyou'd like to ask for

-- 20 21 MS. FREDE: I justhave one quick question. My name is Lisa Frede. I'mwith the 22 Chemical Industry Council of Illinois. In the 23 Illinois EPA second errata sheet to its proposal for 24 the addition of 35 Illinois Administrative Code 223

### MR. DAVIS: And that was 14?

that. which document?

MR. RAO: We don't have the errata If I may interrupt, Ms. MR. FOX: Is this something that the Agency can

MS. HODGE: Wouldyou like a copy of MS. FREDE: Yes, sir. MS. FREDE: Of the errata sheet that
MR. FOX: Thankyou, verymuch.

MS. HODGE: We have an extra copy. I 

### Page 46 

### containedan inadvertent erroronnumber 14 on Page 7. Specifically the explanation states that the

architectural and industrial maintenance code and requirement of Section 223.320, i.e., the proposedamendment is intended to clarify the

sheet here. Couldyou please

-- was just

-- have lapsedjust for a second. That's Page 7 of Frede, you referred to Page 7, andmy attentionmay correct for us? of Section 223.255, i.e., the consumerproducts proposedamendment actuallypertains to provisions regulation. regulation. This reference is not correct. The 1 2 3 4 5 6 7 8 9 10 11 12 

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

## ( 1 Page 47 MR. DAVIS: I think that's a typo in 2 the errata. So that wouldbe an error in the 3 4 5 errata, and I thinkwe can correct that easily. MS. FREDE: Thankyou. MR. FOX: Mr. Matoesian, Ms. Hodge has' 6 kindly made available a duplicate copy of the errata 7 sheet, of course not yet received throughmail 8 service. Wouldyou be willing to offera motion to , 9 10 11 12 admit that as Exhibit No. 4 so that was part of our hearing today?MR. MATOESIAN: Sure. That's fine. MR. FOX: HearingMr. Matoesian's motion to admit errata SheetNumber 2 dated
is there any objection to its admission as that 

# ( 13 14 15 June 2nd, 2008, as Exhibit No. 4 in this proceeding, 1 

### Ij
16 exhibit number? Neither seeing nor hearing any, it 17 will be admitted andmarked as Exhibit NO.4. And 18 Ms. Hodge, thankyou again for making a copy 19 available. Ms. Frede, did that wrap up your 20 questioning? 21 22 verymuch. 23 MS. FREDE: That was all. Thankyou
MR. FOX: Absolutely. Sir, ifyou 24 would also please identifyyourself andpose any

## ( 1 2 Page 48\ question for the Agency that youmay have. MR. CAREY: Myname is Dave Carey. I 3 work for W.R. Meadows. We're a family manufacturing 4 companyhere in Illinois. We've actuallybeen in 5 6 7 8 business since 1926 in the State of Illinois. have manufacturing facilities, kind of, scatted throughout the U.S. We're, kind of, regionally based, andwe make products used in commercial We

...

9 contact construction, architectural codings that are
I

I 10 used to cure concrete. We also make vaporproofing 11 and waterproofing membranes. 12 13 One of the things that struckme about the proposed rule is that we have this federal I

I

I 14 rule, kind of, on the backburner that's, you know, 15 coming down the pipe. And one of the things I 16 wanted to -- just wantedbring up is as a [

18 17 

### I' manufacturing company, one of the challenges we face

## I; is complying with the different rules we see around 11 19 the country. There are rules in south coasts that 20 we deal with, the OTC rules have alreadybeen 21 mentioned, and for us as a manufacturing company, 22 there are significant costs associatedwith 23 24 reformulating products, retrofitting and changing equipment, and one of the things that hurts us as a j

### ( 1 2 Page 49 company is inconsistency from one region on of the country to the next. 3 MR. FOX: Sirr let me interrupt if I 4 may. Since you're offering testimony about your 5 work andyour companYr may I have the court reporter 6 swearyou in? Certainlywe'll let you continue and
. 7 ask whatever questions the agency would like. 8 9 10 MR. CAREY: Sure. (Witness sworn.) MR. FOX: Sirr thankyou for letting ; 11 me interrupt. Please go ahead. 12 MR. CAREY: So one of the challenges ; 

## ( 13 14 we face is just the costs associatedwithdoing that)

### , and then complying with all these different rules.
. 15 16 I guess the question and the comment I have is why not wait until the federal rule comes outr : .:

.
the Illinois rule and it wouldpreempt the Illinois 17 18 19 especially if it's going to be more restrictive than j 11 ruler as opposed to possibly requiringmanufactures 20 machinesr you knowr formulations andretrofit 21 equipment for a one or 18-monthperiod. 22 Also I'd like tojust say that we 23 have two drivers in the marketplace right now that 24 are actually forcing our industry to voluntarily

### ( 1 reduce

### voc content in ourproducts. One is, Page 50
2 obviously, the solvents. You know, a gallon of gas 3 is $4 a gallon. Whenyoubuy solvents in the 4 marketplace, we've seen some of our costs go up by I, 5 100 percent. So that's one driver, and the other is 6 with the leadprogram and rebuildings. More and 7 more construction activities are looking to use

I 8 products that are more environmentally friendly. So I, 9 that's driving us towards'that end anyway. [\ I: 10 So I guess one of the issues that Ii we'd like the Agency to considerwouldbe just 

## ( 11 12 13 14 

## I: waiting until the federal rule comes out so it makes:: that transition a little bit easier for industry. MR. FOX: Sir, didyou wish to pose a 15 specific question to the Agency? 16 17 MR. CAREY: No. MR. FOX: Okay. Very good. Thankyou 18 for your comments. Was there any otherparticipant 1 19 this morning that wished to pose questions to the 20 Agency while they're available to do so? Very good. 21 The Board itself does have some questions, and in 22 discussing procedural matters brieflybefore the 23 hearing, I did letMr. Matoesianknow that these 24 were in the nature of technical orhousekeepingI apologize in advance if they are I a bit tedious to listen to, andMr. Matoesian, I'm 11 I'

record

-- comments, and that that would certainlybe

going to try to avoid raising anything that was I I

-- what those are. -- but perhaps not MR. FOX:

MR. FOX: MR. MATOESIAN: Okay. Sure. MR. MATOESIAN: Okay. indicated to Mr. Matoesian that these are probably most suitable for responding to post-hearing acceptable to the Board. Page 51 questions about the language of the rule, and I

tell me if I'm asking something that has been
what appears to be addressed in the errata sheet

-- addressed there. Mr. Matoesian, I wanted to raise

intent to have those applied for the purposes of raised in the errata sheet, but certainlyplease

Certainly if they're all addressed in the errata this part," when it appeared to be the Agency's
this subpart. If I may note quickly for the completely. There are in subparts B, C, and D, addressing the three different categories, several definitions that include the phrase "forpurposes of 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24another? MR. MATOESIAN: Oh, okay. I also had a question about a that appear to have the word "part" were adhesive, In

In subsectionA

Particularly with regard to I'dbe delighted. MR. FOX:

MR. FOX: MR. MATOESIAN: We addressed quite a few of those, but ifyou want

in section 223.307, which is part of subpart C, with

through E, which incorporate materials from the code the definitions of coding, concrete curing compound, Page 52 1 sheet, it would not be necessary to address them. I;

definitions of primer and retail outlets.

make those five incorporations consistent with one which is the section addressing incorporations by product, and sanding sealer. The same issue arose architectural coding, hairspray, hairstyling

issue appeared to arise with regard to the Section 223.203, which is subpart B, the definitions I,

number of questions, frankly, about Section 223.120,
reference. Question number one:
of federal regulations, may the Board ask that you Section 223.407, which is part of subpart D, that primer, sanding sealer, and sealer. And in 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. FOX: Number three in subsection 

## Ii later amendments or additions.

QualityManagement District, and the CaliforniaAir

I; -- of the ASTMmaterials, to specifically not including any

MR. FOX: MR. MATOESIAN: Okay. MR. FOX: And secondly, for the MR. MATOESIAN: Okay.

MR. MATOESIAN: Okay. Page 53 the federal

-- specific federal register citations

Resources Board, canyou supply an address for those incorporation of the materials from the South Coast as these are not

entities as you have done with the incorporation

which the public can obtain copies of those Air QualityManagement District, the BayAreaAir

to approval onAugust 10thof 1998, andwe would ask that you clarify whether there is a subsequent version of this method that the Boardwould need to inJuly of 1996, but the proposed subsection refers materials that are incorporatedby reference?

I, which incorporates the South CoastAir Quality Management District method, the document that was filed with the Agency's proposal indicates approval

obtain as part of its record in its proceeding. 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24I,

wouldneed to obtain. of the method that the Boardwouldneed to obtain a

District Rule 1174, the documents filed indicate

In; i MR. FOX: Number five, in subsection Page 54 And number four, similarly in

And finally under this section, MR. MATOESIAN: Okay. May 18th of 2005, and I would ask simply that you subsections J and K, which incorporate the BayArea Air QualityManagement District methods, the

but this proposed subsection refers to amendments of

### Ii I' documents filed with the proposal both indicate that

## I; I, they were amendments proposed on February 4th, 2004,

that it was adopted on October 5th of 1990, but the February 27th of 1991, and again, ifyou could copy of for the record in this proceeding. clarify again whether there is a subsequent version

M, incorporating South Coast Air QualityManagement

the copy filed with the Board, however, there were provision of the CaliforniaAdministrative Code. clarifywhether there is some subsequent version, proposed subsection 120 suggested adoption on

updatedversion, of that document that the Board

question number six, subsectionNincorporates a 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 "<.- 14 15 16 17 18 19 20 21 22 23 24

### ( 1 2 Page 55 five images which appeared to contain the VOC content limits that appear in the document as not 

## Ii I.: 3 available for printing, andwe would ask that in 4 order to complete that document, of course, ifyou 5 6 could supply a copy of the document that does containthose images that appear to be quite 7 relevant, of course. 8 MR. MATOESIAN: Okay. I I 9 MR. FOX: If I maymove on to 10 Section 223.203, which refers to specific 11 definitions for subpart B, the definition of 12 colorant in this section refers to the purposes of 

# ( 13 subpart C, and ifyou wouldbe willing to clarify 14 that reference, indicating whether there is an 15 inadvertent error, orwhether it shouldbe moved to I 16 subpart C, we wouldbe grateful ifyou would clear ' \ 17 that up for us. 18 19 MR. MATOESIAN: Okay. MR. FOX: And similarly, the 20 definition of lacquer in 223.203 refers to the 21 purposes of subpart CandD. So ifyou would i 22 similarly clarify that reference as well, we would 23 appreciate it. And number three, the definition of 24 VOM content also refers here in subpart B to thestandard.

one. subsectionArefers in a list of cross references twice to Section 223.207, and I see that it does so

Inboth Sections 223.250 MR. FOX: Okay. Thankyou for clarify that, we would appreciate that as well. Moving on to Section 223.208,

MR. MATOESIAN: We're looking for that Page 56 I; purposes of subpart B. And ifyou could similarly

MR. MATOESIAN: Okay. that you clarify whether that was anunintended , in the errata sheet as well, andwe would ask simply,

the product dating requirements, specifically that that sheet does not appear to address the issue with Ii they require display of that data no later than 12 waiting, Mr. Matoesian. duplication orwhether there was intent to cross

MR. FOX: And I know I didn't phrase
. i that as clearly as I might have. So I appreciate i that. All right. Andmoving on to Section 223.285, ! j

# , reference another section of the proposedrule.

months prior to the effective date of the applicable additional product dating requirements, the errata regarding product dating and Sections 223.255, 1 2 3 4 5 6 7 8 9 10 11 12 

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

## (1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 57 test methods, subsectionErefers to anASTMmethod incorporatedby reference, although it does not appear to be listed among the ASTMmethods that are incorporatedby reference in Section 223.120. And ifyou would clarify that for us, we would appreciate it. Andmoving on to subpart

## c[ specifically section 223.307, and forgive me if I'm mispronouncing some terms. It's entirelypossible ': that I may do so. The definition is it calcabine recoaters (phonetic) refers to the phrase "flat solvent borns codings," B-o-r-n-s, which is unclear to us. And ifyou could clarify the meaning of that reference, we would appreciate it. Number two, the definition of nuclear coding refers to two ASTMmethods, a different version ofwhich

-- different versions of which appear to be incorporatedby reference in Section 223.120[ and ifyou would clarify, please, whether the Agency intended to incorporate additional methods, we wouldbe grateful for that as well. Number three, the definition of traffic marking coding refers to the termBerets,manufacture conduct a, quote, "Method 24," close refers to the Agency's requirement that a that.

definition of varnish in this section refers to the

I

subsectionB

## I~ I' I, With regard to Section 223.340,

Thenunder Section 223.370, test Number six, the definition ofVOM

And finally, number seven, the Page 58 B-e-r-e-t-s, whichwas unclear to us. Ifyou could clarify the use of that term, we would appreciate

that might have eluded us, that wouldbe great. content refers to, quote, "Procedures specified in

the Agency intended to include language regarding 1 when it would require that analysis, any deadlines purposes sectionunder aerosol codings, and we wouldI' sub Section 223.400A," close quote, which is the appreciate any clarification of that cross

compliance provisions and test methods, referenced, please.

quote, analysis. Couldyou please clarify whether

or requirements relating to it. could offer any clarificationof technical meetings which was not entirely clear to us. And ifyou term fetal sheen, F-e-t-a-l, new word, S-h-e-e-n, 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 241 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 59 methods, subsection E incorporates ASTMmethod D 1613-96, but Section 223.120 incorporates ASTM D 1613-03 under the same title. And ifyou could please clarify those two incorporations, we would appreciate it. Similarly, under subsection F, there's an incorporation ofASTMmethodD 1640-95, but it refers to two specific definitions, first quick dry enamel, and second quick dry primer, sealer, andundercoating, both ofwhich include testing according to a different ASTM standard, 1640-03. And again, if we could ask for a clarification, please. SubsectionHincorporates the Bay AreaAir QualityManagement District method 43, a different version ofwhich is incorporated in Section 223.120. And ifyou wouldplease clarify whether the agency intended to incorporate different versions, and if so, to file bothversions with the Board for its record of this proceeding. SectionHalso refers to a definition ofvolatile organic material in Section 223.307 where it is not defined, and ifyou would also please clarify that reference. .

I;

1



## I:Page 60 I,
with Section 223.400, which is the purposes language;

i Andunder this subsection

-- under Subsection I refers to compliance

been filed with the Board. ;;

:

• : i



# · " ; ; I' ; 

### : • Subsection I

Moving on to Section 223.407, that cross reference as well, please. under aerosol codings. And ifyou would clarify

intended to incorporate different versions, and if also incorporates South CostAir QualityManagement

is incorporatedunder Section 223.120 with another and again, ifyou would clarify whether the Agency

these are definitions for subpart D. The definition this section, finally, subsectionMincorporates an of which is incorporatedby reference in 223.120,

so, whether

-- indicate whetherbothversions have

appendix in the Code of Federal Regulations, which

of aviation ormarine primer refers to federal date in the citation. And ifyou would clarify the

specificationTT-P-1757. And ifyou wouldplease verymuch.

authorities, please. Secondunder that section, the District method number 303-91, a subsequent version

correctversion of that, we would appreciate that

clarify that reference and its source in the federal 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24I

1

MR. MATOESIAN: No. We can do the refer to the federal rule in addressing these

I' Mr. Rao kindly reminds me that you; I:

MR. FOX: Did I raise any questions MR. MATOESIAN: Okay. Thankyou. Mr. Matoesian, I know that was a And nearing the end, product subject to this article. And ifyou could clarifywhether that's meant to refer to a product

intent to withdraw that, which would ineffectively subject to this subpart orpart. Page 61 definition ofproduct weightedMIR refers to a

large number of questions, and appreciate your products as being beyond legal challenge at this point, andunless I misunderstood there was an

those were addressed in a post-hearing comment, I

in, kind of, rushing through those? those are not necessary to clearup. coding products.

proposedrule. So I appreciate the reminder that

as possible as they could for you. moot these questions about the wording of the

hope that the transcript made those about as clear patience. And listening to those, as I said, if section 223.410, limits and requirements for aerosol 1 2 3 4 5 6 7 8 9 10 11 12 

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

## ( 1 Page 62 I ones that weren't corrected already. 2 MR. FOX: Very good. I hope I didn't 3 raise any that were addressed in the errata sheet. 4 We certainly tried to avoid that. If there is**I ~** 5 anyone I have not at this pointput to sleep that 6 had any additional questions for the Agency, I'm 7 sure that Mr. Davis wouldbe happy to answer any of 8 those. I did not want to move ahead while anyone 9 had questions that they wanted to pose. Are there 10 any further questions that anyone had for Mr. Davis 11 for either the Boardmembers, memberMoore, member 12 Melas, or the Board staff, Mr. Rao, were there any

17 today. 13 14 15 16 further questions? I note that the signup sheet for persons who did not pre-file testimonybut who may wish to testify today remains blank, so we do not have any further witnesses to testifyhere I, I I· 18 I canmove on, then, to the issue 19 of the economic impact study. Since 1998, section 20 21 22 23 27B of the Environmental ProtectionAct is required 

## Ii that the Board request that the department now known as the Department of Commerce and Economic Opportunity conduct an economic impact study of 24 proposed rules before the Boardadopts them. Theanyone who would like to testify or offer comment 1\ 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24 Page 63 Boardmust make either of the economic impact study performed, or the department's explanation for not conducting one, available for the public at least 20 days before a pUblic hearing. In this rulemaking proceeding, the Board, in a letter dated January 24th of 2008, requested that the department conduct an economic impact study on this rulemaking proposal. To date the Boardhas receivedno response from the testimony with regard to that request. Is there regarding that request filed by the Boardwith the department of commerce and economic opportunity? Seeing orhearing no indication that anyone would like to do so, what I would like to do at this point is to go off the record just for a moment or two to address some procedural issues. (Whereupon, a discussion was had

off the record.) MR. FOX: The participants in this hearing went off the record specifically to discuss procedural issues related to the filing of post-hearing comments. Before it takes action on the Agency's proposal, the Board will hold open a I

I
j ,: Tuesday, June 10th. And as soon as it is filed with the Board, it will be placed electronically on the me -- we will also hold open a period for responses to the Agency's post-hearing comment in a period for those ending 14 days after the Boardreceives the In order to -- in addition, forgive Page 64 period specifically for post-hearing comments ending 30 days after the Board receives the transcript of this hearing, which is expected on or about Tuesday, June 10th.

clerk's office online as soon. As it is posted I' there, you canview it, download it, and copy it free ofcharge at any time. In addition, anyone may file more general public comments on this proposal that has been filed by the Agency. Those may be filed post hearing comment from the Agency approximately July 24th, I believe we determined. In order to set those deadlines more clearly and to avoid setting deadlines on weekends orholidays, I will issue a hearing officer ordervery quickly after we receive the hearing transcript so that those dates are as clear as possible to all of the participants. The copies, again, are expected in approximately six days on 1 2 3 4 5 6 7 8 9 10 11 12 

## ( 13 14 15 16 17 18 19 20 21 22 23 24Page 65

I electronically through the Board's clerk's office
and any questions about the use of the COOL system shouldbe directed to the check's office. Filings

} I I

I**I~** While no otherhearings are not online, the COOL system that you heard reference to,

with the Board, whetherpaper or electronic, must
I also be served on the hearing officer and on those I' persons on the service list. For filing with the

With that, are there any other that you have the most recent version of the service I' list, and if anyone has questions about procedural
information contained on the web, and certainly on

was remise in not recognizing them earlier, and I'm clerk, please contact the clerk's office to ensure

virtually everyone in the room. aspects, they may certainly contact with the contact 19 IE

The Board is fortunate to have working with it this

sure Marie's face, that is entirely familiar to I I; very, very, quickly one other non-substantive issue. any hearing officerorder.

arrived withMarie Tipsord, who is the attorney assistant for acting chairman, Tanner Gerard, and I scheduling in this rulemaking, I did want to address

summer an intern, Katie Kindel (phonetic). She 1 2 3 4 5 6 7 8 9 10 11 12 

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

### Page 66 I



### appreciates your time, your effort, andyour input, andwe can adjourn. Thankyou. participants who are here today. I know the Board 

### 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 i \ 

### matters that need to be addressed at this time? Seeingnone, thankyou certainly to Mr. Davis, Mr. Matoesian, Ms. Hodge, and all of the other I**I~** I I'Page 67 Ie 1 2 3 4 5 6 7 8 9 10 11 12 

# ( 13 14 15 16 17 18 19 20 21 22 23 24 STATE OF ILLINOIS SS COUNTY OF COOK

REBECCAA. GRAZIANO, being first duly sworn on oath says that she is a court reporter doing business in the City of Chicagoj that she reported in shorthand the proceedings given at the taking of saidhearing and that the foregoing is a true and correct transcript ofher shorthandnotes so taken as aforesaid and contains all the proceedings given at saidhearing.

# ~.1J~ REBECCAA. GRAZIANO, CSR 29 SouthLaSalle Street, Suite 850 Chicago, Illinois 60603 License No.: 084-004659
SUBSCRIBED AND SWORN TO before me this 4thday of June, A.D., 2008.

### r,//~/ /;. I

### e~-u**,---';>L._~ ~~**  Notary Public

C\Iofi 1/ 'tkl DIANAll"'\v,n NotoryPuul,...· .**~I'** ,',. .!**,,"~** ,<;

_ CommissIont>f.IIE;<, ""," 1\

•**I~**



## IiPage68 A added 52:6 16:12 6:68:10 always antipers
... 

### ( able20:2 18:18,18 adhesives 36:23 8:13 16:17 35:18 about4:13 23:17 24:537:5 39:3 12:18 ambient anti-static 11:16 26:6 adjourn 42:12 23:22 8:18 24:13 21:22 27:18 6:1066:6 43:5 27:14 amending anyone 32:639:3 40:5 ADM1:6 47:18 28:11 38:14 7:1541:7 43:8 adding administ
... 54:8,17 38:1,10 39:10 62:5,8,10 48:13 31:6 3:723:2 59:12 38:19 amendm
... 63:11,14 49:451:1 32:10 45:24 60:8 39:6 22:546:3 64:22 52:15,16 34:2 54:23 64:16 40:15 46:7 65:10 61:12,19 addition admission age36:7 51:18 amendm
... anything 64:365:3 7:19 21:438:9 agencies 53:19 53:354:5 7:1151:8 65:10 45:24 47:15 23:5 58:18 54:6 anyway above-en
... 64:4,22 admit21:2 agency2:6 63:24 among 50:9 1:10 additional 47:9,13 3:114:16 64:6 57:3 apologize Absolutely 28:5,6 admitted 5:3,8,9 ago30:2 amount 6:2319:3

47:23 31:7,14 3:246:11 7:148:2 33:20 8:20 20:14 accept8:3 31:24 7:820:18 8:16,23 agree16:11 amplifica
... 21:16 acceptable 32:2,8,11 21:7 9:20 18:3 4:22 42:20

51:5 32:15 47:17 10:24 26:16 Anad2:5 51:6 accepted 34:3 adopt 11:14 36:139:2 analysis appear

3:12 39:12,16 38:20 12:7,13 agrees 17:16 52:655:2 according 40:7 43:12 13:16,23 44:13 29:12 55:6 

# ( 59:11 56:14 adopted 14:16 ahead16:9 34:24 56:15 accurate 57:21 54:15 15:617:3 49:11 36:15,18 57:3,18

.. 26:20 62:6 adoption 20:17 62:8 40:2,7,17 appeared 30:24 additions 40:16 21:12 aim43:10 58:20,22 2:21 33:23 53:3 54:16 23:827:9 air1:78:18 analyzed 51:18 achieved address adopts 29:11 24:8 32:9 52:13

8:23 17:322:6 62:24 30:17,24 26:21 Anand 55:1 16:20 30:940:3 advance 31:5,9,21 35:2,20 3:17 appearing 27:11,16 52:153:9 51:6 32:1,6,9 35:21 Andrea2:4 5:7 31:6 56:15 aerosol 32:14,22 37:19 3:15 appears Act62:20 63:17 5:13,17 33:8 53:7,7,8 announc... 7:727:8 acting 65:15 43:858:7 34:23 53:17 40:24 31:21

65:20 addressed 60:361:6 38:13 54:3,13 another 39:3 action 44:23 affairs 39:9,9 59:15 6:625:1 51:12

63:23 51:11,12 41:20 40:6,14 60:5 52:22 appendix activities 51:24 affected 44:13 allowing 56:9 60:14

50:7 52:2 22:14 45:13 42:10 60:15 applicable actual39:7 61:18 aforesaid 46:948:1 all-purpo
... answer 56:18 actually 62:366:1 67:11 49:7 37:7 5:119:12 applied

20:15,20 addressing after4:18 50:11,15 already 11:9 51:19 29:8 15:4 11:939:7 50:20 36:21 40:10 applies 41:15 51:16 41:1,8 57:20 48:20 44:15 27:4 45:846:7 52:17 64:2,7,13 58:21 62:1 62:7 apply 48:4 61:8 again 59:18 alternative anticipate 26:21 49:24 adhesive 10:10 60:862:6 39:11 16:19 appreciate add7:11 24:2 12:5 15:5 64:8,24 although anticipated 42:4,12 37:12 15:9 Agency's 41:957:2 17:10 43:1Page69 55:23 associated 2:17 6:58:2 beyond 54:4 45:3 56:2,23 30:18 aviation 9:1714:5 5:138:22 56:12 capacity 57:6,14 32:2,7,10 60:21 26:4 12:928:8 59:10,19 7:19 58:2,8 32:14 avoid4:23 39:17 61:9 60:10 card41:16 59:5 33:9 51:862:4 41:12 Bie119:10 bottom care24:23 60:17 48:22 64:11 50:22 bit42:4 23:12 25:10 61:13,16 49:13 await7:3 62:24 50:13 Box2:18 37:6,19 apprecia
... Associates aware 63:4,23 51:7 brand Carey2:13

66:5 17:15 37:24 67:19 black 24:12 48:2,2 apprecia
... association A.D1:16 began6:5 20:14 break6:10 49:8,12

42:7 2:14 67:20 41:2,8 blank 6:17 50:16 appropri... 41:13,21 a.m1:16 begin4:15 62:15 brief6:10 case16:17

6:17 assume 5:4 blue20:7 briefly 17:9 approval 17:20 B beginning board1:11 50:22 31:10,10

53:19,21 assumpti
... B51:15 41:12 2:23:4,9 bring categories approxi
... 9:24 52:5 behalf2:21 3:12,14 48:16 18:17,18

64:8,16 asterisk 55:11,24 7:1421:1 3:14,15 burner 18:21 April3:21 22:19 56:1 being 3:164:2 48:14 23:17 architect
... 34:13 58:17 16:24 4:3,7 business 24:15

46:548:9 asterisks back6:2 27:23 5:11,22 41:16 25:19 52:7 35:1,7 11:21 61:967:5 6:2,87:2 48:567:7 26:1 Area1:7 ASTM 17:13 believe7:2 20:17 buy50:3 27:13,16

3:853:7 53:12 28:11,13 7:209:10 40:16 B-e-r-e-t-s 27:18,19 54:2 57:1,3,16 29:23 9:21,23 44:24 58:1 28:529:5 

# ( 59:15 59:1,2,7 34:9,11 12:23 50:21 B-o-r-n-s 29:20 areas22:7 59:11 36:22 13:11 51:5 57:12 30:1,3,8 arise52:13 Attachm
... 39:21 14:4,6 52:20 30:20,20 arose52:8 13:17 42:16 18:18 53:9,23 C 30:22 around 15:5 48:14 19:10,23 54:9,19 C1:22:1 31:3,7,14

34:8 attain8:18 based7:5 23:23 54:24 51:15 31:24 48:18 22:3 12:12,20 25:16,18 59:20 52:9 32:3,8,11 arrive41:8 attainment 12:21,24 26:6 60:11 55:13,16 32:16 arrived 9:1,6,10 15:15 27:20 62:11,12 55:21 34:3,12

41:1 28:7 23:127:9 28:235:4 62:21,24 57:7 34:15 65:19 attention 31:22 36:16,20 63:1,6,9 calcabine 37:940:6 arriving 26:15 48:8 38:17 63:12,24 57:10 40:7

6:24 36:6 basing 39:14 64:2,7,18 California 51:16 article61:2 46:12 12:15 41:10 65:5,17 19:9 categoriz
... asked4:12 attorney 16:22 45:364:9 66:4 27:24 45:10 15:141:6 65:19 33:22 benefit Board's 29:8 category asking August basis4:17 4:20 3:18,22 31:11 15:724:2

33:20 53:21 14:10 10:21 4:45:14 36:3,3 24:13,22 38:18 authorities 15:11 Berets 14:23 53:8 25:1,3,6,9 40:23 22:18 16:15 57:24 42:19 54:23 25:13 51:10 60:24 33:19 beside 65:1 call3:2 26:11 aspects available Bay53:7 34:13 bold23:5 17:18 30:15,18 13:6 47:6,19 54:2 35:1,7 borns 18:16 34:9 65:11 50:20 59:14 best6:78:3 57:12 called1:11 37:20,21 assistant 55:363:3 before1:10 better8:11 both8:4 15:8 38:1,6

65:20 Avenue 1:125:2 44:4 39:17 came5:24 42:16Page70 43:1 chapter 60:3,8,16 colorant 48:21 48:10 65:11 

### ( cause1:10 35:19 60:23 55:12 49:1,5 52:10 contain 22:14 charge 61:3 colors comparis... conduct 35:18,22 34:20 64:21 clarifying 20:16 14:22 58:19 55:1,6 Center Charles 42:6 come3:2 complete 62:23 contained 1:14 2:85:6 cleaner 13:10 4:455:4 63:7 46:1 certain check 24:18,19 15:22 completed conducted 65:12

9:11 13:20 25:13,18 20:3 6:89:3 9:2 containing 15:17 16:21 cleaners 41:24 completely conducting 26:22 18:20,20 31:15 37:6,13 42:1 51:15 40:263:3 27:436:8 22:13 34:4 clear4:4 comes completing consider contains 34:19 36:19,22 5:1,1 49:16 36:8 30:17 67:11 certainly 44:19 55:16 50:12 complian... 32:1,14 contamin...

4:127:13 check's 58:13 coming 9:2010:2 32:21 35:21 14:8 65:4 61:14,19 48:15 10:13 33:8 content7:3 15:20 Chemical 64:14 commenc... 12:832:1 50:11 50:155:2 19:820:8 2:945:22 clearly 1:16 32:10,15 consider... 55:24 20:22 Chicago 4:16,21 comment 33:834:2 42:14 58:5 32:5 1:156:24 10:11 15:1 58:17 considered continue 44:17,24 67:7,16 56:23 18:13 60:1 32:6,18 49:6 49:651:4 CIRCUIT 64:11 19:5,13 compliant 32:22 contribute 51:9,24 1:3 clerk65:8 42:19 27:24 38:14 22:15 62:4 citation clerk's 43:7 complim... 39:9,12 34:20 

# ( 65:11,12 60:16 64:19 44:10,17 19:10 39:18 Control 66:2 citations 65:1,8 44:23 comply consistent 1:112:2 chair41:24 53:1 close58:6 49:15 23:1 11:513:3 3:417:16 chairman cited13:16 58:19 61:18 complying 13:7 convenie...

65:20 City67:7 closer13:9 63:11 48:18 14:13 22:17 challenge clarificat... Coast53:6 64:6,8 49:14 19:8 Cook1:3

5:1461:9 34:1 53:17 comments compound 38:14 1:1367:2 challenges 42:22 54:13 19:6,11 22:21 39:10,19 COOL

48:17 58:8,14 coasts 42:13,13 35:19 42:12,15 65:2,3 49:12 59:13 48:19 50:18 36:9 43:544:3 copies6:11 change clarified Coatings 51:4 52:10 44:18,21 15:19 19:633:6 42:7,9 2:14 63:23 compoun... 45:6 53:13 changed clarify 41:21 64:1,23 22:13,18 52:21 64:15 18:17,19 12:18 code1:6 commerce 22:19 construct... copy6:19 changes· 14:15 3:745:24 62:22 34:19,24 48:950:7 6:21 13:2 25:24 46:5 63:13 36:21 consumer 15:18,20 18:13,22 43:14 52:19 commerc... concerns 8:21,24 20:13,16 18:24 45:246:3 54:23 8:219:1 5:23 11:15 20:17 19:3,4,11 53:22 60:14 15:848:8 concise 12:914:2 21:8 19:15 54:8,18 coding commissi... 29:7 15:7 46:20,24 21:18 55:13,22 52:7,10 12:17 concluded 28:18 47:6,18 23:3 56:2,7 57:16,24 14:3 34:19 29:13 54:10,24 25:20 57:5,13 61:7 17:17 conclusion 46:8 55:5 26:17 57:19 codings 22:2 4:6 contact 64:20 42:4 58:2,20 5:1748:9 company concrete 24:5,6 correct changing 59:4,17 57:12 44:12 43:2,3 37:548:9 10:4,18

48:23 59:24 58:760:3 48:4,17 44:11 65:8,11 15:24Page71 16:324:1 29:19 dating 34:4,16 55:23 developing 20:13 24:19,23 36:21 56:13,14 34:22 57:10,15 21:13 21:8,10 25:3,22 creams 56:16 35:4,9,14 57:23 Develop
... 21:13,21 27:5,6 26:5,6 Dave2:13 35:17,24 58:4,11 17:16 21:24 28:19 cross56:4 48:2 36:4,12 59:22 different 23:11 30:16 56:858:8 David2:15 36:16 60:20 16:20 26:13 32:23 60:4 41:19 37:10,16 61:1 18:21 27:21 45:746:6 CSR1:13 Davis2:7 37:23 defmitions 48:18 28:12,13 46:10 67:15 5:88:9 38:3,8,12 18:19 49:14 28:23 47:3 cure48:10 8:149:4 38:17,22 51:17 51:16 29:2,4,7 60:17 curing 9:7,9,14 38:24 52:5,10 57:17,17 29:16 67:10 52:10 9:2310:7 39:14 52:14 59:11,16 33:2,13 corrected current 10:9,12 40:8 55:11 59:18 34:13

62:1 13:3,7 10:22 43:15,21 59:8 60:9 46:14 cost32:1,9 19:9 11:2,8,24 44:15,19 60:20 direct36:6 53:18

32:10,14 12:3,5,11 45:1 degreasers directed 54:19 32:15,22 D 12:23 46:18 37:7 65:4 55:2,4,5 33:8,12 D5:17 13:20 47:162:7 delighted directing documen
... 33:12 51:15 14:4,18 62:10 52:4 4:10 12:19 34:260:5 52:12 14:23 66:2 demonst
... directly documents costs32:21 55:21 15:2,17 day1:15 10:3,14 41:245:3 13:17

48:22 59:2,3,7 15:24 67:19 demonst
... director 21:17 49:13 60:20 16:4,16 days42:11 9:2,6,10 41:20 54:4,14

, 50:4 Darling 16:24 42:12 28:7 discuss doing 

## ( Council 2:15 17:5,23 63:464:2 deodorants 63:21 17:11 2:945:22 41:15,19 18:1,6,8 64:7,16 35:18 discussed 41:18 counsel 41:19 18:11,15 deadlines departm
... 6:8 49:13

20:16 42:1,3,17 19:2,17 9:17 1:462:21 discussing 67:7 counting 42:21 19:21,23 58:22 62:22 6:411:9 done8:2 12:6 43:18,23 20:621:9 64:10,11 63:7,13 20:13 53:10 country 44:2,8,9 21:11,15 dea19:16 departm
... 50:22 down

48:19 44:16 22:11,13 48:20 63:2 discussion 21:22 49:2 45:2,7,12 23:19,23 dealing describe 6:13 23:12 County1:2 45:14,16 24:3,7,11 5:16 20:19 63:18 26:15 1:3,4,13 data29:8 24:17,20 December 35:13,14 display 37:11 67:2 56:17 24:24 16:3,24 described 56:17 48:15 couple date9:20 25:5,8,11 decide 21:3 District download

41:22 12:8 25:14,16 22:20 description 53:7,8,18 64:20 42:6 17:19 25:23 34:14 20:21 54:3,14 draft6:1 course6:9 29:15 26:19,24 decision determin
... 59:15 21:3 15:747:7 56:18 27:2,6,17 4:411:8 31:10 60:6 driver50:5 55:4,7 60:16 28:20,24 43:17 determine DIVISION drivers court1:3 63:8 29:3,14 44:4 35:1 1:4 49:23

4:11,20 dated3:13 29:17,21 defined determin
... docket3:9 driving 8:441:3 16:3,13 30:4,14 59:23 36:3 document 50:9 41:14 17:18 30:19 definition 37:21 8:11,13 dry59:9,9 49:567:6 23:4 31:4,8,15 43:2 64:9 13:21 due22:15 cover21:24 47:13 32:4,12 44:11 develop4:3 17:18,20 duly67:6

21:24 63:6 32:17,24 45:6,8 developed 19:13 duplicate covered dates64:14 33:10,18 55:11,20 22:1,6 20:1,10 47:6Page72 duplicati
... 58:15 13:24 34:10 fetal58:12 26:7 37:2

56:8 emission equipment 47:9,14 few8:8 52:21 40:21 Dwyer 8:17,20 48:24 47:16,17 15:4 54:12 41:17,23

2:177:23 18:5 49:21 expect 18:17 55:1 42:2,17 27:11,15 errata5:15 11:14 30:1 flat57:11 44:9,22 E 28:18 5:216:6 expectati
... 33:19 folks41:1 45:5,10 E2:1,1 29:12 6:157:6 12:8 52:3 footnote 45:15,17

52:19 30:17 45:23 expected field7:13 28:22 46:11,17 57:159:1 31:2,6,13 46:15,22 64:3,16 7:14 footwear 47:5,12 each13:21 32:7 47:2,3,6 explanati
... figure28:2 24:22 47:23

22:20 emissions 47:13 46:263:2 fIle59:19 37:6 49:3,10 earlier 1:73:8 51:9,12 extra46:24 64:22 forcing 50:14,17 13:11 8:15 51:24 extraneous fIled3:10 49:24 51:14,23 43:8 15:12 56:6,14 36:23 5:2011:3 foregoing 52:4,24 65:21 28:15 62:3 53:19 67:9 53:5,12 early33:2 enamel error46:1 F 54:4,14 forgive 53:16 easier30:9 59:9 47:2 F59:6 54:24 57:864:4 54:12

30:11 end50:9 55:15 fabric 60:11 form41:3 55:9,19 44:4 61:5 especially 24:22 63:12 format 56:11,22 50:13 ending 49:17 face48:17 64:17,24 13:4 61:22 easily47:3 64:1,7 essentially 49:13 64:24 14:11 62:2 economic engineer 18:23 65:22 filing5:15 formation 63:20

38:15 5:9 estimated facilities 9:17 22:15 frankly 40:5 enough 31:13 48:6 63:22 34:20 52:16 

## ( 62:19,22 11:12 34:2 Fair11:12 65:7 35:3 Frede2:10 62:23 ensure estimating familiar Filings formulat
... 45:20,21 63:1,7,13 65:8 28:17 18:9 65:4 49:20 46:12,15 effective entirely event40:13 21:10 final14:5 forth40:6 46:19

9:21 57:9 everyone 65:22 fmally 40:15 47:4,19 33:12 58:13 65:23 family48:3 25:12 42:16 47:21 56:18 65:22 everyone's far3:14 54:21 fortunate free64:21 effort22:3 entities 5:22 32:17 58:10 65:17 fresheners

66:5 40:1,3 everything 38:18 60:13 forward 24:9 EH17:15 53:10 11:5 42:7 find12:12 40:16 26:22 18:4 entitled3:6 exact28:1 February 39:16 42:9 35:21 eight8:18 17:15 28:4 54:5,17 fine9:15 four54:1 37:19

22:3,4 environ
... exception federal 11:11,13 Fox1:11 friendly either4:2 2:6,21 26:17 5:138:23 28:10 2:33:1,5 50:8

40:4 3:115:7 excuse 10:4,16 37:3 6:3,23 from3:13 62:11 7:24 35:24 11:15 47:11 7:2,5,13 5:118:17 63:1 41:20 exemption 12:8 firm7:22 8:1,69:7 8:24 electrical 62:20 26:21 43:17 first3:20 9:1610:9 10:21

24:18 environ
... 27:4,13 48:13 5:10,24 11:12,24 11:413:1 electronic 50:8 33:6,9 49:16 7:188:2 12:4 13:10

24:19 EOC42:5 exemptio
... 50:12 8:910:17 14:23 14:6,7,23 37:565:5 EPA36:15 26:15 52:20 11:19 15:24 15:13,19 ( electroni.
.. 42:543:1 exhibit7:9 53:1,1 12:15 16:6,9,12 16:12 ., 64:18 43:9,10 20:19 60:14,21 40:24 17:9 18:14 65:1 45:23 21:2,5,7 60:23 59:867:5 20:20,24 19:24 eluded EPA's 33:3 61:8 five21:22 33:4,5 21:1,18Page73 21:24 29:23 H helpful 29:15,18 I implement 

### ( 26:18 30:6 H59:14,21 14:22,24 29:23 identical 9:22 29:4,7,8 34:11 hairspray 15:23 30:6,12 42:8 impleme
... 30:231:2 35:836:5 52:7 19:19 30:15,23 identified 15:13 31:6 40:6,14 hairstyling 20:2,4,8 31:5,12 25:19 19:11 33:13,13 42:20 25:426:2 20:11 31:17,20 30:1 inadvert
... 35:2 49:11 26:352:7 28:6 32:5,13 35:19 38:946:1 41:23 50:4 hand7:16 44:24 32:20 43:4 55:15 49:1 63:16 happen her41:15 33:1,5,17 identify Inc2:12 52:19 goal19:7 6:14 67:10 33:24 35:6,15 17:15 53:663:9 27:15 happy62:7 highlight 34:6,18 35:16 include 64:8 goes8:9,12 hard44:5,6 19:14 34:23 47:24 14:8,21 front4:10 32:8 having3:1 highlight
... 35:5,10 identifying 18:19

6:12,15 going5:18 5:9,12 20:7,16 35:15,24 41:13 22:20,23 15:18 17:12,17 7:815:17 him8:5,6 36:5,14 IERG21:1 27:12 41:2 21:23 hazardous Hodge2:17 37:3,11 IL2:18 28:3 fully28:9 35:11 22:16 2:196:19 37:17,24 ILL1:6 29:24 further 43:19 34:21 7:20,21 38:4,10 Illinois1:1 30:231:1

7:118:19 49:17 36:2 7:22,22 38:13,19 1:3,11,14 31:24 62:10,13 51:8 heard 8:1,8 38:23 1:152:2 33:14 62:16 gone42:11 11:17,18 9:15,19 39:1,23 2:6,9,21 34:13,15 F-e-t-a-l good3:3 65:2 10:1,13 40:12,19 3:3,6,10 36:18,23

58:12 5:616:6 hearing 10:23 40:22 5:77:23 43:1,3. 41:17 1:103:2 11:11,13 46:20,24 8:15,15 51:17 

## ( G 42:8 3:4,5,12 11:23 47:5,18 8:18 58:21 gallon50:2 50:17,20 3:20,20 12:7,13 66:3 13:24 59:10

50:3 62:2 4:8,15 13:14,22 hold63:24 27:15,23 included gas50:2 gotten5:22 5:106:5 14:14 64:5 28:15,15 13:19 gave41:15 5:23 6:10,16 15:316:1 holding 28:17 14:19 ge125:7 governed 7:99:17 16:7,8,10 3:19 36:14 22:16 gels26:3,4 3:22 10:18 16:23 holidays 39:20 23:21

26:7 graffiti 11:20 17:2,6,10 64:12 42:543:1 25:24 general 25:2 12:15 17:12,24 hope5:21 43:9,10 26:9,10

24:5 37:13 21:5,6,7 18:2,7 44:17 43:11 30:22 64:23 grams43:3 41:2 20:12,22 61:19 45:22,23 33:15 Gerard grateful 47:10,12 20:23 62:2 45:24 36:17

65:20 55:16 47:16 21:1,8,9 hopefully 48:4,5 44:11 getting 57:21 50:23 21:12,20 42:3 49:18,18 includes 11:21 Graziano 63:4,14 22:12 43:11,19 67:1,16 38:1 33:12 1:1267:5 63:21 23:10,20 44:3 images including give9:8 67:15 64:3,8,12 23:24 hour8:18 55:1,6 19:3 given20:16 great58:15 64:13 24:4,8,12 22:3,4,7 immediate 21:16

26:10 Group 65:6,13 24:18,21 housekee
... 3:16 27:10 67:8,12 2:217:24 67:9,12 25:1,6,9 4:205:24 impact 53:2 go16:9 guess15:21 hearings 25:12,15 7:640:24 31:1 inclusion 17:13 18:22 65:14 25:17 50:24 33:13 44:13
, 20:14 36:13 26:12,20 hurts48:24 inconsist
... 

### \ held1:9 35:240:4 23:11,14 49:15 help4:3 27:1,3,7 H-o-d-g-e 62:19,23 49:1 24:14 50:10 8:17 28:10,21 7:22 63:1,8 incorpor
... 28:12,13 29:1,11 52:19Page74 54:2 14:12 65:18 June1:16 15:14 7:22 1:73:7 57:20 19:5 interrupt 10:3,15 18:15,16 lead3:15 limits13:6 59:18 39:19 7:10 47:14 18:17 50:6 13:9 60:9 42:10 10:10 64:4,17 19:24 least26:22 14:20 incorpor
... 45:22 16:1 67:20 20:3,15 27:8,13 18:17

53:14 49:24 42:18 just3:2 31:5,12 31:2,21 38:655:2 57:2,4,18 50:13 44:10 5:18 34:1 63:3 61:6 59:16 ineffectiv
... 46:11 14:14 36:12 leather line19:24 60:7,15 61:11 49:3,11 18:12 39:240:4 24:22 Lisa2:10 incorpor
... influenced interrupt
... 20:6 40:22 37:6 45:21

53:17 10:5,19 16:7 25:19 41:14 leave9:18 list17:13 54:22 informat
... 42:20 30:134:8 44:12,16 left3:14,16 26:14 59:1,2,14 3:23 involved 34:11 48:14 legal5:14 56:465:7 60:5,13 15:14 9:5,9 35:5,13 49:20 61:9 65:10 incorpor
... 38:15 11:7 35:15,16 50:2,23 less27:22 listed29:5

54:13 40:5 issue4:22 36:23 56:22 let49:3,6 30:16 incorpor
... 65:12 52:8,13 38:6 61:15 50:23 34:12,21

53:6,10 initial 56:15 41:12,21 66:4 letter42:14 36:257:3 59:7 13:18 62:18 42:6,23 knowledge 43:563:6 listen51:7 incorpor
... input11:4 64:12 44:10 6:7 letting7:10 listening

52:17,21 13:1 65:16 45:2,20 known 49:10 61:17 59:4 14:12 issues5:24 46:13,16 62:21 let's13:22 liter43:3 independ
... 66:5 50:10 48:16 13:23 little9:8

29:12 insecticid
... 63:17,22 49:13,22 L 28:13 10:11 

## ( 34:24 26:22 item14:1 50:11 L37:4 35:12 42:4 36:15 27:4 26:16 63:16 Labco levels22:4 50:13 indicate instance items23:16 16:18 License look13:23

7:18 26:2 23:21 K 31:11 67:17 13:24 16:14 instead i.e46:4,8 K1:254:2 lacquer like5:4 17:13 54:4,14 42:9 Katherine 55:20 6:14,15 22:8 60:10 intended J 2:197:21 language 14:4,9,14 29:23 indicated 4:346:3 J2:33:17 Katie65:18 44:14 14:21 35:6

41:11 57:20 54:2 keep15:20 51:1 20:10,18 looking 51:2 58:21 January 34:8 58:21 27:18 50:7 indicates 59:18 3:11,13 keeps 60:2 28:11 56:20

53:19 60:9 9:2012:9 11:21 lapsed 41:4,23 lot5:23 indicating intent 16:13 kind16:19 46:13 42:24 13:1,9

37:8 38:11,19 63:6 36:15 large61:16 43:8,19 14:12 45:18 42:23 Jersey29:4 40:17 LaSalle 45:18,19 16:18 55:14 51:19 29:7,16 48:6,7,14 67:16 46:20 39:4 indication 56:8 29:19 61:23 last11:16 49:7,22 

### LVRKINS

6:13 61:11 31:11 Kindel 11:17 50:11 2:20 63:14 interest6:9 judgment 65:18 45:10 63:11,15 individual 7:823:7 4:5 kindly47:6 later19:13 63:15 M

23:9 interested July11:21 61:7 53:3 likely M37:11 industrial 40:23 12:1,1,6 knew41:8 56:17 29:18,21 54:13

46:5 interim 53:20 know latest15:20 limit43:2,4 60:13 industry 15:616:2 64:9 11:22 LAUREN 44:12 machines

2:911:5 16:12 jumping 12:10 2:20 45:8,11 49:20 13:2 intern 34:7 14:11 law1:4 Limitatio
... Mack15:6Page75 15:8,11 14:20 54:11 Measure Miss7:20 more9:8 63:165:5 

### ( 15:14 16:17,19 55:8,18 17:16 missed 10:11 16:15,17 March 56:10,12 meetings 42:16 11:17 N 18:3 17:19 56:20 58:14 mistaken 12:24 N2:137:18 31:11 Marie 61:15,21 Melas2:4 7:7 17:13 37:18 made13:2 65:19 61:24 3:17 misunde
... 24:15 54:22 19:423:3 Marie's 66:3 62:12 61:10 26:1,11 nail38:1 42:547:6 65:22 Matoesia
... member Mm-hmm 27:19 38:11 61:19 marine 47:12 3:14,15 22:12 28:9 name3:4 mail6:7 60:21 matter1:5 3:17 35:15 30:20 5:67:20

47:7 marked 4:206:12 62:11,11 model 45:12,18 7:21 mainly 21:6 matters6:5 members 12:17,21 49:17 41:13

5:10 42:18 50:22 4:262:11 12:22 50:6,7,8 45:21 39:19 47:17 66:1 membra
... 13:5,7,16 64:11,22 48:2 maintain marketpl... max26:5 48:11 14:2,5 morning names23:9

22:3 49:23 maximum mention 15:13,16 3:35:6 narrative 38:20 50:4 26:7 6:5 16:14 6:187:9 28:16 maintena
... marking may4:12 mentioned 17:17,21 50:19 national

46:5 57:24 4:195:22 32:19 17:22 most13:3 2:148:18 make6:11 material 6:237:16 33:2,6 18:10 14:6 41:20 13:2,5 1:73:8 7:18,19 48:21 19:921:3 15:21 43:10,12 17:20 39:24 11:17,18 method 22:1,5,14 19:4,8 nature7:6 36:15 59:22 11:24 53:18,23 22:16 29:743:4 22:16 40:24 materials 16:118:8 54:957:1 23:1,4 45:11 34:21 

# ( 41:7 52:19 20:2 58:19 27:10,11 51:365:9 36:2 43:16 53:6,12 22:14,17 59:1,7,15 28:1 motion 50:24 44:20 53:14 34:20 60:6 31:23,23 21:147:8 nearing 45:18 Matoesian 38:8 methods 38:16 47:13 61:5 48:8,10 2:85:4,5 40:23 54:357:1 39:5,8 move20:18 necessarily 52:21 5:66:4 41:5,14 57:3,16 43:6,20 40:16 39:2 63:1 6:18,21 42:14 57:21 44:21 55:962:8 necessary makes 7:1,4,9,12 44:9 58:17 modeled 62:18 52:1

50:12 7:148:5 46:11,12 59:1 39:7 moved8:11 61:14 making 9:1211:6 48:149:4 middle modeling 55:15 need10:10 11:7,8 28:8 49:5 37:11 9:2 moving 31:20 47:18 30:10 51:20 mid-way modified 56:3,24 53:23 manage... 31:19 52:20 21:22 27:14 57:7 54:9,20 11:10 36:24 54:755:9 might 33:9 60:19 66:1 53:7,8,18 39:21 57:10 13:10 moment much neither 54:3,13 40:10,13 62:15 20:226:3 16:1 13:11 14:921:6 59:15 40:18 64:22,24 26:4 44:10 23:10 33:18 60:5 43:16,24 65:11 56:23 63:16 30:11 47:16 manufac
... 44:647:5 Meadows 58:15 Monday 37:4 new1:63:6

58:19 47:11 2:1248:3 mind22:9 5:21 42:22 15:19 manufac
... 50:23 meaning 41:12 months 43:19 19:7

49:19 51:2,7,11 10:20 minutes 56:18 45:17 23:17 

### ( manufac
... 51:13,22 57:13 15:430:1 Moore2:4 46:17 24:1,9,12 48:3,6,17 52:2,23 means MIR61:1 3:15 47:22 24:15,22 48:21 53:4,11 28:22 mispron
... 62:11 60:18 24:23 many4:23 53:15 meant61:3 57:9 moot61:12 must23:1 25:1,3,6,9Page76 25:13 28:5,22 official 33:19 26:10 outlets 41:21 27:12 28:23 20:1 34:10 27:20 52:14 paper15:7 29:4,7,16 33:4,21 Oh6:19 39:9 OTC12:17 outside 15:9,11 29:19 34:10 16:8 40:10,24 12:21,22 23:6 15:14 30:1,3,8 42:19 52:23 41:9 13:3,5,7 over6:2 16:3,12 30:22 46:1 okay5:5 42:15,18 13:16,18 14:1 16:15 31:11 47:13,16 7:1,4,12 43:7 14:6,12 23:14 18:365:5 45:3 52:16,18 8:129:15 45:18,20 14:13 24:14 papers 58:12 53:16 10:1,23 48:12,15 15:13,15 28:16 15:18 newly 54:1,12 11:23 48:17,24 16:14 36:5 paradich
...

34:12 54:22 12:13 49:1,12 17:21,22 own13:4 26:23 40:5 55:23 13:14,22 49:21 18:9 19:7 14:11 27:533:7 next13:15 57:15,23 14:14 50:1,5,10 19:920:1 29:12 35:23 16:10 58:4,10 15:5 52:18,21 21:322:6 40:6 part1:6 23:14 60:6 17:12,24 56:21 22:22 ozone10:2 6:17 49:2 61:16 18:7 63:3 23:4,6,6,7 10:4,14 14:24 nicely29:9 numbers 19:12 65:16 23:8 10:19 15:319:7 Nicholas 33:12,13 21:20 ones62:1 27:10,11 12:16 22:241:6

2:43:17 23:20,24 online 27:24 14:2 44:547:9 none66:2 0 24:4,8,21 64:19 29:20 17:17 51:18 non-aero... 01:2,2 26:12 65:2 30:2 22:2,3,4 52:6,9,12

24:13 oath67:6 27:730:6 only10:4 31:13,22 22:15 53:24 non-subs
... objection 31:17,19 10:18,21 31:23 31:1 61:4

65:16 21:4 33:1,17 27:4 33:234:1 34:20 participant 

### ( Notary 47:15 33:24 29:19 34:14,19 35:236:8 4:950:18 67:21 obtain 34:7,23 34:21 37:8,21 o'clock3:1 participa
... note4:1 53:13,24 35:5 36:2 38:16,21 4:176:14

5:20 54:9,20 36:14 open63:24 39:5,8 P 41:7 34:10 obviously 37:17 64:5 42:15,24 P2:1,1 63:20 51:20 39:17 38:13 opportun... 43:6,19 page8:16 64:15 62:13 50:2 40:12 62:23 44:3,18 14:1,1 66:4 noted October 42:1 63:13 44:21 15:10 particular

22:19 54:15 43:23 opposed 48:20 20:15 8:14 notes21:22 off63:16 50:17 49:19 other4:13 21:21,22 15:10

21:23 63:19,21 51:13,22 opting 4:24 21:24,24 18:422:8 22:8,11 offer47:8 52:23 22:24 22:18 23:11,12 34:10 36:20 58:14 53:4,11 optional 32:18,21 23:14,15 Particula
... 67:10 63:11 53:15 35:13 33:19 24:1,14 52:24 notice1:12 offered 54:11 36:11,13 40:1,1,22 25:2,13 parties

42:11 10:17 55:8,18 37:9,14 41:4,6 25:15 9:22 November offering 56:10,11 37:22 42:13 26:13,14 parts39:8 14:322:5 39:12 61:21 order3:3 43:750:5 28:12,14 45:9 23:4 49:4 omission 3:1355:4 50:18 28:17 passed3:2 nuclear office2:18 38:7 64:4,10 65:14,16 35:8,12 past43:13

57:16 6:24 once43:17 64:13 65:24 36:637:4 patience number 64:19 one6:6 65:13 66:3 37:12,17 61:17

3:915:9 65:1,4,8 14:15 organic1:7 others30:5 37:18 PC42:19 16:2 officer1:10 17:13 3:859:22 out45:3 46:1,12 Pechan 17:14 3:564:12 22:6,8,11 original 49:16 46:13 17:15,18 23:12 65:6,13 27:13 23:4 50:12 Paint2:14 17:24Page77 18:4 57:11 1:112:2 previous 1:967:8 54:463:8 56:158:7 

### ( Pennsylv
... 65:18 3:4 25:24 67:12 63:24 60:2 45:4 phrase portion 26:2 process 64:23 pursuant pens4:10 51:17 5:16 previously 13:1 propose 1:12 people4:23 56:22 pose47:24 32:19 product 11:1,14 pushed per43:3 57:11 50:14,19 pre-fIle 24:138:6 proposed 11:21 percent pipe48:15 62:9 62:14 52:8 1:63:6 put18:20

8:21,24 place3:21 posed4:2 pre-fIled 56:13,14 8:17,22 29:962:5 15:12 placed position 4:8 56:16 9:1911:2 18:526:5 64:18 14:16 primarily 61:1,2,3 12:15,18 

### 0 26:7,8,23 placehol... 22:22 14:16 products 38:2,5 quality 27:5,22 23:8 40:15 primer 8:229:1 44:14 8:1935:2 28:1,4 plainly possibility 52:11,14 11:15 46:3,7 53:7,8,17 50:5 6:13 41:9 59:9 12:914:2 48:13 54:3,13 percentage please4:1 possible 60:21 15:8 53:20 59:15

26:7 4:217:16 5:211:4 printing 18:20,20 54:5,6,16 60:5 perform 7:17 19:14 55:3 24:13,23 56:9 question

37:1 10:11 27:17 prior56:18 25:426:3 61:13 7:15,18 performed 16:9 33:10 privileged 26:9 62:24 7:208:9

63:2 23:12 57:9 3:24 27:23 Protection 10:8 perhaps 26:13 61:20 probably 28:18 2:63:11 13:15 16:11 28:13 64:15 9:1013:8 29:13 5:762:20 16:10 30:21,21 29:230:7 possibly 14:19 35:22 provide 17:10 

## ( 40:3 34:635:7 49:19 15:21,22 36:837:6 39:15 32:8,13 44:14 35:12,16 post2:18 16:5 37:19 provided 39:8 51:14 42:20 9:1764:8 20:21 46:848:8 17:7 40:13 period14:8 46:23 posted41:2 30:10 48:23 38:15 41:11

49:21 47:24 64:19 36:151:2 50:1,8 providing 44:15 64:1,5,6 49:11 post-hea
... problem 61:7,9 5:9 45:19,21 permission 51:9 15:1 42:21 program provision 48:1

5:15 57:19 19:19 procedural 50:6 26:17 49:15 permits 58:9,20 44:23 3:236:4 promise 54:23 50:15

4:18 59:4,13 51:3 50:22 40:8 provisions 52:15,18 permitted 59:17,24 61:18 63:17,22 promulg
... 9:2210:6 54:22 12:20 60:4,22 63:23 65:10 11:15 10:20 questioni
... person 60:24 64:1,6 procedures 22:24 46:7 47:20

4:19,24 65:8 potentially 23:358:5 proofing 58:17 questions personally point5:14 10:5,19 proceed 48:10,11 public5:11 4:1,13,16

20:3 7:810:24 pounds 5:3 proposal 42:19 5:2,3,11 persons 44:7 22:23 proceeding 3:104:6 44:10 7:158:3

40:22 61:10 precisely 3:6,22 4:18 53:13 8:833:20 41:5 62:5 13:5 12:16,19 13:18 63:3,4 40:23 62:14 63:15 preempt 21:14 19:1 64:23 41:6,22 65:7 points23:7 49:18 23:22 21:13 67:21 42:6 perspecti
... policy11:7 prejudge
... 47:14 23:22 purpose 45:13 14:24 11:8 4:5 53:24 38:1,14 6:1624:6 49:7 pertains 40:13 prepared 54:10 38:20 24:6 50:19,21

46:7 polish38:2 17:15,21 59:20 39:7,10 purposes 51:1 phonetic 38:11 present 63:5 45:23 51:17,19 52:16 16:18 Pollution 3:13 proceedi... 53:19 55:12,21 61:12,16Page78 61:22 29:6 reduction 56:457:1 2:217:24 41:14 64:5 62:6,9,10 reasons 8:14,17 57:11,16 21:13 49:567:6 restrictive 62:13 12:14 8:24 57:24 39:7 represent 43:4 65:3,10 Rebecca 15:12 58:5,11 related 7:18 45:11 quick 1:1267:5 18:5 58:18 63:22 represen... 49:17

40:24 67:15 28:15 59:8,21 relating 7:23 result 45:20 rebuildin
... 31:1 60:1,21 58:23 request 15:13 59:9,9 50:6 reductions 61:1 release 42:24 retail52:14 quickly receive4:7 8:20 reflect4:5 20:9 62:21 retarder

51:20 64:13 16:20 19:7 released 63:10,12 43:2,4 64:13 received 27:11,15 reflected 20:2 requested 44:12 65:16 47:763:9 27:22 19:1,15 relevant 63:7 retrace quite52:2 receives 28:6,18 reformul... 3:2355:7 require 33:11

55:6 64:2,7 29:12 48:23 relied 56:17 retrofit quote58:5 recent 30:18 refreshe
... 13:17 58:22 49:20

58:6,19 15:22 31:2,6,13 24:22 14:11,16 required retrofitting 58:20 65:9 32:7 regard 15:6 10:341:9 48:23 recently refer61:3 10:17 21:17,18 62:20 revised R 9:211:18 61:8 52:13,24 40:1 requirem
... 43:10 R2:1 recoaters reference 58:16 rely20:22 10:16 revisit raise7:16 57:11 13:16,19 63:10 21:12 46:4 34:11

51:11 recognize 15:9 16:2 regarding 31:10 58:18 right3:17 61:22 7:17 16:11 4:656:13 remains requirem
... 10:12 62:3 recognizi
... 17:14,21 58:21 62:15 23:237:5 16:8 

### ( raised51:9 65:21 21:17 63:12 reminder 37:12,18 24:11,17 raising record4:1 28:22,23 regards 61:13 56:14,16 30:12,23

51:8 4:45:12 46:6 42:5 reminds 58:23 31:18 Randolph 5:196:3 52:18 region49:1 61:7 61:6 37:16 1:14 6:11,18 53:14 regional remise requiring 38:24 Rao2:5 17:8 55:14,22 22:2 65:21 42:10 45:7

3:1718:8 18:13 56:957:2 regionally remover 49:19 49:23 18:12,24 21:522:1 57:4,14 48:7 25:2 rescind 56:24 19:12,18 22:935:6 57:18 register removers 43:12 Roland 19:22 35:16 59:24 53:1 24:2 research 2:17 20:5,9 38:16 60:4,7,23 regulate 37:12,13 16:18 room1:15 46:22 39:5 65:2 22:17 38:2,11 resource 4:22 61:7 42:19 referenced 38:11 repeat10:7 39:24 65:23 62:12 51:21 58:9 regulated 32:4 resources Rory2:7 read21:23 53:24 references 38:5 33:20 31:9 5:811:7 reading 54:10 14:9 regulating repetitious 32:18,21 rule5:13

22:9 59:20 17:13 32:2 3:24 40:14 5:166:1 really 63:16,19 23:556:4 regulation report 53:9 8:17,22 10:10 63:21 referred 22:21 17:14 respond 8:239:1 11:22 records 12:1 34:15 18:4 9:440:18 9:19,22 12:617:1 14:20 46:12 37:15 29:19 42:10 10:4,6,16 19:6 red19:23 refers16:2 46:6,9 reported respondi... 10:20 30:17 reduce 53:20 regulations 67:8 51:3 11:1,3,15 31:935:2 22:450:1 54:6 52:20 reporter response 12:9,16 39:8 reducing 55:10,12 60:14 4:11,21 63:9 12:17,18 reason 31:1 55:20,24 regulatory 8:441:3 responses 12:21,22Page79 13:3,5,6 63:5,8 46:13 sense17:20 4:10 35:13 30:20 13:16,19 65:15 59:9 sent42:14 similarly 36:17,18 50:15 14:2,6,8,9 rules3:23 60:24 seriously 25:254:1 40:2,2 53:1 14:10,13 13:3,4,8 secondly 19:11 55:19,22 41:150:4 55:10 14:17 14:11 53:5 served65:6 56:159:6 50:21 59:8 15:13,16 16:20 section service6:7 simply 54:18 specifically 16:14 18:14 8:14 47:865:7 54:756:6 57:9 45:546:2 17:17,21 19:9,9,16 26:14 65:9 since19:12 63:17 53:2 17:22 22:24 28:14 set64:10 19:18 someone 56:16 18:10,14 28:1 35:20 setting 27:7 41:10 57:8 19:4,7 39:18 38:246:4 64:11 31:21 something 63:21 21:422:1 48:18,19 46:852:5 seven26:5 48:549:4 17:3 64:1 22:6,14 48:20 52:9,12 26:8 62:19 20:10 specificat
... 23:1,4,18 49:14 52:16,17 58:10 sir5:5 30:8 60:22 24:16 62:24 54:21 several 41:12 31:18 specified 25:21,21 ruling 55:10,12 24:14,15 46:19 36:10,21 58:5 26:1,2,10 12:12 56:3,5,9 51:16 47:23 44:20 speculate 26:18,18 13:13 56:24 shaving 49:3,10 46:9 12:11 26:21 rushing 57:4,8,19 25:726:4 50:14 51:10 16:5 27:3,10 61:23 58:6,7,11 26:5,6,7 sites18:3 somewhere 43:24 27:12,12 R-0817 58:16,24 sheen sitting4:10 11:20 spoke43:8 29:5,13 3:10 59:2,17 58:12 10:12 soon11:3,3 spoken 29:20 R08-171:6 59:21,23 sheet4:10 six54:22 64:17,19 5:12 30:2 60:2,13 5:15,21 58:4 sorry9:7 Springfie
... 

## ( 31:14,23 S 60:15,19 6:6,15 64:16 10:916:7 2:183:21 31:23 S2:13:15 60:24 7:645:23 sleep62:5 25:17 SS1:167:1 38:16,21 same4:23 61:6 46:15,23 sold27:23 28:13 staff3:18 39:5,8,17 18:23 62:19 47:7,13 sole14:10 34:7 4:37:3 39:19 52:859:3 sections 51:9,12 33:19 37:21 62:12 40:17 sanding 23:6 52:156:6 solely4:3 sort5:23 standard 42:643:6 52:8,11 56:12,13 56:15 21:18 source 8:1910:2 43:8,10 sates37:9 see6:13 62:3,13 solid35:21 60:23 10:14 43:12,12 saying19:6 16:21 shorter 37:18 Sources 22:4,7 43:17,20 34:14 19:19 42:4 solvent 1:73:8 56:19 44:14,18 says8:16 20:6,15 shorthand 57:12 south 59:11 44:21 67:6 36:19,22 67:8,10 solvents 48:19 standards 48:13,14 scatted 43:17 show30:7 50:2,3 53:6,17 1:63:7 49:16,18 48:6 44:1 30:7 some6:2 54:13 23:13,14 49:19 scheduling 45:17 side15:11 6:13 60:5 start28:14 50:12 65:15 48:18 sign41:3 18:16,19 67:16 35:12 51:1 sealer52:8 56:5 62:13 18:24 speak4:21 started 54:14 52:11,11 seeing6:9 significant 19:14 6:24 12:24 56:961:8 59:10 12:621:6 18:13,16 21:22 10:10 14:5 61:13 season10:5 47:16 18:21 24:4 speaking starting rulemaki
... 10:19,21 63:14 19:15 25:20,24 4:23 5:17 1:63:9 second 66:2 25:20 26:8 special starts 3:16,20 3:194:8 seen50:4 48:22 27:18 23:724:6 23:13 22:22 5:20 semisolids significa
... 30:4,19 specific7:8 state1:1,13 27:10 42:18 24:10 27:14 30:20,21 26:I,ll 5:12 31:22 45:23 send6:1 signup 31:235:6 27:19 22:17,18Page80 22:20 25:18 20:21 58:12 28:23 41:17 35:11 I 23:7,8 subcateg
... suggested term23:7 42:21 36:20,23 \ 29:4 24:936:7 54:16 T 57:24 45:12,16 38:22 30:16 37:4 suitable table23:13 58:2,12 45:17 three15:9 34:14 subchapter 51:3 28:16,17 terms57:9 46:17 16:222:8 36:3 35:20 Suite67:16 29:8,24 test57:1 47:4,18 22:11 38:20 subject summer 29:24 58:17,24 47:21 23:13 48:567:1 34:861:2 65:18 30:2,16 testified 49:10 33:445:8 stated 61:4 supply 36:17 11:19 50:17 45:9 12:14 submit 53:955:5 38:5 testify4:9 56:11 51:16 33:18 15:23 support tabs35:11 4:11,19 61:21 53:16 39:15,17 19:5 8:10,13 take13:23 41:4,5,9 66:2,6 55:23 39:24 submitted 13:10,12 28:435:6 62:15,16 thanks 57:23 statement 31:18 14:7 taken1:12 63:11 7:10 through

8:10 44:17 17:16 29:8 testimony 20:24 13:130:7 12:14 submitting 18:427:9 67:11 4:8,13 33:24 36:747:7 21:23 19:13 27:21 takes22:22 5:10 their4:17 52:19 23:9 subpart 28:12 63:23 10:17 7:16 61:23 statements 5:17 29:4 taking 27:20 19:10 65:1 14:15 51:20 38:16 19:10 28:349:4 22:15 througho
... states8:19 52:5,9,12 39:4,5,11 67:9 62:14 34:21 48:7 15:622:6 55:11,13 39:12,16 talking 63:10 36:2 Tim3:4 22:24 55:16,21 40:4,7 32:6 testing 43:12 time3:1 23:6 55:24 supporting Tanner 59:11 themselves 4:18,24 

## ( 37:22 56:157:7 12:19 65:20 text23:3,5 26:9 6:179:21 40:1,3 60:20 sure11:16 Tech15:6 thank5:5 they'd 10:24 42:24 61:4 15:2 15:8,11 6:1810:1 45:18 14:7 43:645:6 subparts 19:17,21 15:14 10:23 things6:2 15:19,19 46:2 51:15 30:14 16:15,17 11:11,23 19:20 17:14 state-spe... SUBSCR... 32:12 18:3 12:4 36:1 29:6

22:21 67:19 38:341:7 31:11 13:14 48:12,15 45:13 23:2 subsection 44:19,20 technical 15:4 16:6 48:24 64:21 stay19:8 37:18 45:1 3:187:5 17:2,10 think4:21 66:1,5 step42:8 52:18 47:11 8:10,13 18:2,7 8:310:16 times16:17 Street 53:16,20 49:8 13:6,10 19:22 11:2,19 16:19

67:16 54:6,12 51:22 13:12 20:11,12 12:14 33:21 stricken 54:16,22 62:7 14:727:9 20:23 13:9 timing9:17

36:7 56:457:1 65:22 27:21 21:7,9,20 16:13 Timothy strikethr
... 58:17 surface 28:11 23:10 18:22 1:102:3

26:17 59:1,6,14 43:2,3 29:3 26:12 20:20 Tipsord struck 60:1,4,12 44:11 38:15 27:7 21:18,23 65:19

48:12 60:13 swear8:4,5 40:4 28:10 28:8 title35:19 structura... subsectio
... 8:649:6 50:24 30:23 29:18,21 59:3 18:22 54:2 sworn4:12 58:14 32:20 33:19,21 titles23:6 study subseque
... 8:741:5 tedious 33:1,5,17 33:22 today3:14

62:19,23 53:22 49:967:6 51:7 33:24 35:10 3:194:2 ( 63:1,8 54:8,18 67:19 tell28:21 35:10 47:1,3 4:95:8 \ sub58:6 60:6 system 29:1 37:2,3 Thompson 6:10,16 subcateg
... sufficient 65:2,3 51:10 39:23 1:14 7:239:18

24:5 9:21 S-h-e-e-n ten28:22 40:19,21 thought 15:22Page81 20:19 28:238:5 36:937:7 59:16 want3:2 26:1,8,9 47:8 

### ( 27:8 TT-P-1757 37:14,20 60:6,17 20:19 26:10 55:13 31:22 60:22 39:1,6 65:9 34:852:3 27:19 willingness 39:340:9 Tuesday 43:9,13 versions 62:8 29:5 20:24 40:20 64:3,17 43:18,21 57:17 65:15 32:18 wish4:11 47:10 turn21:21 44:2 59:19,19 wanted 33:11,13 41:4,5,10 62:15,17 26:13,15 unintend
... 60:9,10 28:441:7 33:15,16 50:14 66:4 28:11 56:7 versus 41:11 36:1,21 62:15 together 34:9 unless 25:21 48:16,16 39:18 wished

29:934:9 twice56:5 61:10 very5:3 51:11 40:22,23 7:11 toilet/uri... two22:8,11 until10:24 6:3,23 62:9 50:24 50:19

25:10 37:12 44:1 13:616:6 wasn't9:5 52:654:5 wishes4:9 35:22 39:8 49:16 23:10 9:913:11 54:24 4:19 37:19 42:13,19 50:12 39:19 water 61:18 22:20 told11:20 45:6 updated 40:21 48:11 62:3,12 34:15 top37:17 49:23 15:19 41:17 way22:23 weren't withdraw topic35:20 57:15,16 54:19 42:22 web20:15 62:1 5:16 towards 59:4,8 updates 43:19 65:12 West1:14 61:11

50:9 63:16 17:7 45:11,15 Wednesd
... we'll28:9 witness traffic typo47:1 updating 45:17 3:21 40:18 4:138:7

57:24 13:12 46:17 weekends 44:19 49:9 transcript U use50:7 47:22 64:12 49:6 witnesses 1:95:1 unclear 58:265:3 50:17,20 weighted we're 41:4 61:19 57:12 used8:23 60:18 61:1 17:12 62:16 

## ( 64:2,14 58:1 29:6,10 62:2 welcome 20:13 wood25:13 " under 67:10 48:8,10 64:13 3:3 48:3,7 25:18 transfer 22:18 USEPA 65:16,16 well5:46:3 56:20 word52:6 14:3 24:5,8 5:13 view64:20 6:2416:5 we've 58:12 transition 26:3,4,21 11:14 virtually 17:6 20:20 wording

50:13 36:21 U.S48:7 65:23 35:17 25:19 61:12 transport 45:11 VOC42:8 37:22 32:5 work48:3 12:16 54:21 V 50:155:1 38:23 39:14 49:5 17:17 58:7,24 vapor volatile 40:21 48:450:4 worked 22:2 59:3,6 48:10 59:22 42:7 Whichever 39:18 tried11:3,5 60:3,12 varnish volume9:8 45:11,12 42:2 working 13:562:4 60:12,15 58:11 voluntarily 45:15 while28:3 65:17 true10:20 60:24 version 49:24 55:22 50:20 works

27:1,14 undercoa
... 12:20,21 YOM 56:2,6 62:8 16:17 31:24 59:10 14:17 15:12 57:22 65:14 42:2 33:7 underline 15:15 42:7 60:4 white15:7 wouldn't 34:18 23:3 18:9 55:24 went12:24 15:8,11 14:18 67:10 underlined 19:24 58:4 13:15 15:14,18 17:19 try15:20 23:16,21 21:3 63:21 16:2,12 28:1

39:19 understa
... 23:18 W were14:20 16:15 41:12 42:23 38:18 38:20 wait49:16 16:21 18:3 would've 51:8 42:23 39:13 waited 18:17,18 20:14 36:10,10 

### ( TSD8:16 understa
... 53:23 10:24 18:19,21 wholly wrap47:19 8:19 10:15 54:8,18 waiting 19:4 33:23 write13:4 13:17,24 23:15 54:19 50:12 23:17 willing 14:10 15:5,10 34:12,16 57:17 56:12 25:24 39:15 writing9:5Page82 9:1317:4 12054:16 14:3,17 2123:15 63:664:9 6414:1 28:930:9 1446:1,18 15:15 24:1 2736:6 37:1,1 64:7 16:14,22 2172:19 27B62:20 7 40:11 14.28:21 17:19,21 2224:14 27th54:17 735:20 44:1 8:24 18:14 2231:63:7 2837:4 46:2,12 written 15:12 19:24 45:24 298:16 46:13

42:11 18:5 21:18 223.120 26:13,14 78043:3 W.R2:12 27:22 22:523:5 52:16 28:14 8

48:3 28:1,4 24:16 57:4,19 37:17 15th10:3 26:21 59:2,17 67:16 85067:16 Y 10:15 27:10,11 60:7,15 29th14:3 9 Yeah9:14 1613:16 29:20 223.203 22:5 10:13 14:1 31:22,23 52:5 9:001:16 16:417:5 1613-03 33:22 55:10,20 3 3:1 20:5 59:3 38:16,22 223.205 321:2,5,7 9042:12 year11:16 1613-96 39:5 38:2 33:3 93000 11:17,19 59:2 200329:17 223.207 34:10 35:20 12:1 1640-03 29:19 56:5 35:19 9826:23 43:11 59:12 200454:5 223.208 3028:12,17 27:5 yellow20:7 1640-95 200516:3 56:3 42:11 York45:3 59:7 16:13,24 223.250 64:2 Yup24:20 1735:19 54:7 56:12 30th3:21 1817:14 200612:21 223.255 303-91 Z 18th54:7 13:9,12 46:8 60:6 Zeman 18-month 13:18 56:13 31st17:19

2:177:23 49:21 14:5,8 223.285 31502:17 $ 19th42:15 15:15 56:24 351:63:6 192648:5 16:22 223.307 45:24 $450:3 199054:15 17:22 52:957:8 4 199154:17 18:14 59:23 0 199653:20 19:4,24 223.320 426:14 0125:21

26:18 199853:21 21:3,19 46:4 47:9,14 62:19 23:17 223.340 47:17 0625:21 24:15 58:16 4th1:15

26:18 2 27:330:2 223.370 54:5 31:14 26:647:13 38:21 58:24 67:19 084-0046... 2nd3:11 39:7,13 223.400 4359:15

67:17 23:4 39:16 5:1860:2 5 47:14 1 20081:16 223.400A 2-0251:15 3:12,13 58:6 5th54:15 19:2012:9 523-4900

16:13 2.2.138:5 3:21 12:2 223.407 2.78:14 47:14 52:12 2:19 21:21,24 57762:18 35:19 28:14 63:6 60:19 1st16:3 2.7.128:17 67:20 223.410 6 10th53:21 29:24 20099:20 61:6 60603

64:4,17 2023:11 10:4,18 2325:2 67:16 1001:14 63:4 10:21 2425:15 627052:18

50:5 200112:20 12:10 35:9,12 6314:1 117454:14 12:24 20108:19 58:19 15:10 1256:17 13:15 10:3,15 24th3:13