STATE OF ILLINOIS

COUNTY OF COO K

SS.

IN THE

~L~Ak'Sk"kvE:O (}f:f:/Ct:

JUN 10 ' 8,,'008

POllu1i~~gr: 1LINOI

Ontr( V8 S CIRCUIT COURT OF COOK COUNTY, ILLINOIS 0ard

COUNTY DEPARTMENT, LAW DIVISION

I

IN THE MATTER OF:

PROPOSED NEW 35 ILL, ADM. CODE

PART 223 STANDARDS AND

LIMITATIONS FOR ORGANIC MATERIAL

EMISSIONS FOR AREA SOURCES

R08-17

(Rulemaking -

Air)

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TRANSCRIPT OF PROCEEDINGS held in the

above-entitled cause before Hearing Officer Timothy

Fox, called by 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 4th Day of

June, A.D., 2008, commencing at 9:00 a.m.
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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 PROTECTION AGENCY

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. David Darling

HODGE, DWYER, ZEMAN,

3150 Roland Avenue

Post Office Box 5776

Springfield, IL 62705

(217) 523-4900

BY: MS. KATHERINE HODGE

MS. LAUREN LURKINS

Appeared on behalf of the Illinois Environmental

Regulatory Group.

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of the Board's technical staff.

and not repetitious or privileged will be admitted

Administrative Code 223, Standards and Limitations

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Also present from

Page 3

MR. FOX: The time of 9:00 o'clock having

Today we are holding the second

Fox, and I am the hearing officer for this

come and just passed, I want to call this hearing to

Pollution Control Board hearing. My name is Tim

order. Good morning, and welcome to the Illinois

Environmental Protection Agency on January 2nd of

for Organic Material Emissions for Area Sources.

proceeding entitled Proposed New 35 Illinois

the board today are, at my far left, board member

Andrea S. Moore, who is the lead board member for s

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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 governed by the Board's

order dated January 24th of 2008.

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into the record. Please note that any questions

that are posed today either by the Board members or

the Board staff are intended solely to help develop

a clear and complete record for the Board's decision

and do not reflect any judgment or prejudgement or

conclusion regarding the proposal.

The Board did not receive

pre-filed testimony for this second hearing. If any

participant wishes to testify today, there is a

signup sheet and pens sitting directing in front of

our court reporter. If you do wish to testifYt you

certainly would be sworn in and may be asked

questions about your testimony as any other witness

would be.

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

person who wishes to testify may do so. And as a

housekeeping matter 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 other person so that we can have a

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aerosol 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 Board may not have

gotten it yet. 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, if you would like to begin.

I

I'm not -- I hope

MR. MATOESIAN: Okay. Thank you, sir.

Good morning. My name is Charles Matoesian. I'm

appearing for the Illinois Environmental Protection

Agency. With me 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 Board and 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

permission we will be filing an errata sheet to

withdraw our portion of the rule dealing with

errata sheet on Monday.

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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, did mention the

6 Agency's errata sheet NO.2 to one another. To the

7 best of my knowledge, that mail service has not been

8 completed on the Board. What we discussed was if

9 there is interest in seeing it in the course of this

10 hearing today, we could adjourn for a brief break,

11 make copies, and have 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 of your

18 record here this morning, Mr. Matoesian. Thank you.

19

20 it.

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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 may very ;

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( 1 MR. MATOESIAN: Okay.

Page 7 Ie

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2 MR. FOX: And I believe the Board and

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3 its staff would be 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. Did you have

11 anything further you wished to add?

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MR. MATOESIAN: No. That's okay.

MR. FOX: We certainly can field --

14 Mr. Matoesian, on behalf of the Agency, can field

15 any questions. If anyone does have a question, if

16 would they please raise their hand so that I may

17 recognize them. And please, if they would, for your

18 first question, indicate who you may represent and

19 in what capacity you may do so in addition to your

20 name. Miss Hodge, I believe you have a question.

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MS. HODGE: My name is Katherine

Hodge, H-o-d-g-e, and I'm with the law firm Hodge,

Dwyer, Zeman, here today representing the Illinois

24 Environmental Regulatory Group.
(Witness sworn.)

Page 8

MR. FOX: And Ms. Hodge! I should have

done this first of all. Before the Agency does

accept questions! it would be best! I think! for the

court reporter to swear them both in.

that such emission reductions will amount to

14.2 percent for the consumer and commercial

products rule that's proposed here beyond those

achieved by 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 moved up 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

Swear him in.

The TSD further states

I have a few questions for

MR. FOX: Swear him in.

MR. MATOESIAN:

MS. HODGE:

quality standard by 2010.

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that in writing. I'm not -- I wasn't involved with I)

attainment demonstration.

believe that there is sufficient time for effective

we leave today.

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We can answer that in

I believe that was the

Yeah.

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MR. DAVIS: I would have to respond to I

MR. MATOESIAN:

MR. DAVIS: I wasn't involved with the

MR. DAVIS:

MR. FOX: And we can deal with the

MS. HODGE: Okay. That's fine.

MR. DAVIS:

MS. HODGE: The proposed rule has a

MR. FOX: Mr. Davis, I'm sorry. If

commercial products rule in the attainment

demonstration modeling as conducted and recently

completed?

writing.

timing deadlines for filing of post hearing before

attainment demonstration. I believe we probably

compliance date of January 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.

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MS. HODGE: Okay. Thank you. If

2 compliance with the ozone standard is to be

3 demonstrated by June 15th, 2010, as required by

4 federal rule, is it correct that only the 2009 ozone 11

5 season could potentially be influenced by the

6 provisions of this rule?

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8 question?

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MR. DAVIS: Could you 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 demonstrated by

15 June 15th, 2010 -- which is my understanding as the

16 requirement of the federal rule, and I think you

17 offered testimony in that regard to the first

18 hearing -- is it correct, then, that only the 2009

19 ozone season could potentially be influenced by the

20 provisions of this rule? Meaning, is it true that

21 we would only get the benefit from the 2009 season?

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MR. DAVIS: Yes.

MS. HODGE: Okay. Thank you. Why has

24 the Agency waited until this point in time to
Page 11

MS. HODGE: Okay. Thank you.,

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MR. FOX: Mr. Davis, if I may, when)

j

,

j

MS. HODGE: That's fine. When does

really know.

July. It keeps getting pushed back. So I don't

I.

MR. FOX: Fair enough.

I think I testified to that at the first

MS. HODGE: That's fine. Thank you.

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 policy making decision, so we

rule and tried to get it filed as soon as -- as soon

Mr. Rory isn't involved in the policy making -- or

propose the rule?

we heard that it would be in May of last year. More

could answer that after discussing with the

management.

the Agency expect the USEPA to propose and

promulgate its federal consumer products rule?

hearing. Now I've been told it will be somewhere in

recently, we heard that it would be in May of this

year.

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you referred to July/ is that July of this year/

2008?

MR. DAVIS: Yes.

MR. FOX: Thank you.

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

consumer products rule will be beyond January 1/

2009/ or do you -- or do you know?

MR. DAVIS: I couldn't speculate on

that based on what they'll find in the ruling.

MS. HODGE: Okay. The Agency has

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 OTC model rule. Could you

clarify whether the Agency's proposed rule in this

proceeding and the supporting documentation that's

been permitted as based upon the 2001 version of the

OTC model rule/ or is it based upon the 2006 version

of the OTC model rule?

MR. DAVIS: I believe that when we

started it was more based on 2001. As we went

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each document. A

consistent with the -- with the current OTC model

MR. DAVIS: I would have to check on

rule most consistent with the current OTC rules. We

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Why is the 2001

it is probably

here's the Agency

We tried to make the

MS. HODGE: Okay. Thank you. So that

MS. HODGE: Okay. Let's do that.

industry on what changes could be 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 if you'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 OTC model rule.

rule not included as a reference?

updating to that technical support for the 2006

ruling.

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1 Page 63 and then over to Page 64, Item No. 16, we

2 have the model rule for consumer products, ozone

3 transfer commission of November 29th, 2001.

4 MR. DAVIS: Like I said, I believe

5 that we started before 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 in our 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 our OTC -- or our

11 rules, you know, in our own format, and we relied a ,

-,

13 rule to be consistent with the OTC.

14 MS. HODGE: Okay. I would just like

15 to clarify on one of your statements. So is it your

16 position that the Agency relied primarily upon the

17 2001 version of the rule?

records to get to where many of our limits were.

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MR. DAVIS: No, I wouldn't say that.

I -- we probably should have included that in the

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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 would be helpful if it's part of a
Page 15

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MS. HODGE: And that's part of what

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MR. DAVIS: Sure.

I

I'm not certain not having

Those white papers are

I could probably come up with I'Ii

the Mack Tech white paper side is the basis for the

this would be on Page 63 of the TSD. In particular,

post-hearing comment that was asked

paper, and that's reference number three, and again,

commercial products called the Mack Tech white

white paper for the course category of consumer

MR. FOX: And am I correct, Mr. Davis,

Agency states that it relied upon Mack Tech interim

I'll be addressing in a few minutes too. Thank you.

Okay. Again, in the TSD, in Attachment A, 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 reduction VOM emissions that will

that and submit that also if it would be helpful. :

recent we have today.

know if the information in the Mack Tech white paper

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updated from time to time, and we get new copies and "

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we certainly try to keep up with the latest copy. I;

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My guess would be that's probably not the most

a copy in front of me.

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reference number three refers to an interim white

this would indicate that the 2001 OTe model rule was

MR. DAVIS: Yeah. I would say that

MR. FOX: Very good. Thank you.

I

MR. DAVIS: It could, but that's not

MS. HODGE: That was my next 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 dated December 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 Tech white paper?

said is dated January 1, 2005, don't you think that

So would you agree that perhaps that this reference

from the interim white paper that, again, as Mr. Fox

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always the case. Many times they -- Mack Tech works I{

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for Labco (phonetic), who does a lot of our research I;

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for us. Many times they anticipate what kind of

would have to check with them to see if they were

basing that on 2001 or 2006.

reductions would be achieved by different rules.

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really couldn't say.

MS. HODGE: Thank you. 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

anticipated my question, Ms. Hodge, so I thank you

for doing so.

MS. HODGE: Okay. And we're going to

go back and look at this list of references one more

time, and reference number 18, which is a report

prepared by EH Pechan and Associates Inc., entitled

Control Measure Development Support Analysis of

Ozone Transport Commission Model 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 OTC model rule?

MR. DAVIS: Yes.

MS. HODGE: Okay. And -- Pechan?
Page 18

MR. DAVIS: Yes.

MR. DAVIS: Yes.

MR. DAVIS: Yes.

model rule?

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Could you, 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 of these changes

MS. HODGE: Thank you. And would you

MS. HODGE: Okay. Thank you.

the EH Pechan report, in particular in support of

the 14.2 percent emission reduction?

also agree that the Mack Tech white 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 on how significant the changes are

certain products and to put certain products in

changes, I guess, but not -- structurally I think

Some of the definitions were changed to include

you familiar with this in your version of the OTC

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are reflected in your proposal?

MR. DAVIS: Yes, yes. But as I said,

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those changes

the 2006 rule

and I apologize for not including

most of those changes were made

5 upon comment by an industry when they submit

6 comments to us saying "You should really change this

7 part to reflect the new OTC rule," and our goal

8 certainly was to stay consistent with the most

9 current OTC model rules and California rules, and I

10 believe Mr. Biel complimented us for taking their

14 would it be possible for you to highlight some of

(

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comments seriously and implementing those changes.

MR. RAO: Okay. Since you will be

submitting that document later in your comment,

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15 these significant changes and how they're reflected

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in your rules?

MR. DAVIS: Sure.

MR. RAO: Since it will be

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19 post-hearing, it would be helpful to see where those

20 things are.

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MR. DAVIS: Sure.

MR. RAO: Thank you.

23 MR. DAVIS: I believe there's a red

24 line version from 2006 to 2001. I don't know that

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1 that would be an official document that OTe

2 released, but it may be helpful. I might be able to

3 corne up with that. I know that I had it personally.

4 That could be helpful

5 MR. RAO: Yeah.

6 MR. DAVIS: -- just to see they're

7 highlighted in yellow and blue. So that's -- it was

8 helpful to me certainly. I'

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9 MR. RAO: If you could get the release

14 apologize it's in black and white. So if you go to

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for the document or something like that, that would

be helpful for us. Thank you.

MS. HODGE: Thank you. And I do have

a copy of that document that we're discussing, and I

15 the web page, you can actually see, you know, the

16 highlighted colors. I've given a copy to counsel

17 for the Agency, and then here's a copy for the Board

18 that I'd like to move have this admitted as an

19 Exhibit for today. Do you want me to describe it?

20 MR. FOX: Actually I think we've had

21 probably a sufficient description of what it is and

22 we can certainly rely on that, Ms. Hodge.

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MS. HODGE: Thank you.

MR. FOX: Thanks for your willingness.
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Davis, are I'

I would say yes, and I

MS. HODGE: Thank you. Mr.

MR. DAVIS: Yes.

MR. DAVIS:

MS. HODGE: Did the Agency rely on

MS. HODGE: Okay. Thank you. I would

Page 21

We do have a motion from Ms. Hodge on behalf of IERG

to admit as what would be Exhibit No.3, as she

into the record of this hearing as Exhibit NO.3?

Ie

described the 2006 version of the OTe draft or model I

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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 regulatory proposal

think we relied on it solely for changes from 2001

would have 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. Thank you,

notes, and I think I'm going to read this statement

about mid-way down the page there's some notes, five

from this cover page, cover Page 1 of the document,

ask you to turn to Page 1 of this document, and

for this proceeding?

you familiar with this document?

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us?

hazardous nature are included in this model for

each state to decide whether it wishes to include

Such

This

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"This model rule was developed by

OTC takes no position on whether 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 and maintain the eight hour ozone

hour standard in areas." And then I would ask you

to look at notes, in particular one, two, and three,

is an amendment to the November 29th, 2001, model

rule, developed by the OTC states to address the one

include these pounds in such a way.

and would you mind reading those into the record for

rulemaking.

affected by 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, which may regulate such

compounds are noted with an asterisk, and is up to

contribute to formation of ozone, but due to their

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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 dated November 2nd,

2001, in bold 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: Thank you very much.

Could you go to Page 20 of this document now,

please? And down at the bottom of 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 your understanding, 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 -- on
Page 24

1 Page 21, is it correct that we have new product

2 category for adhesive removers?

3

4

MR. DAVIS: Yes.

MS. HODGE: Okay. And we 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 brand new

category for anti-static products, non-aerosol. And;

if you 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: Another new 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?

(

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12

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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 1 m sorry. Those are

18 subcategories of wood 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 previous
Page 26 I

1 rule, and they're more specific categories than were

2 in the previous rule. For instance, the hairstyling I}

3 products might have been under hairstyling gels

4 before, or shaving gels might have been under

5 shaving creams. They've got a seven percent max. I

6 believe that was added because shaving creams had a

7 five percent maximum percentage and shaving gels got

8 seven percent. 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. Thank you. Could I

13 we turn to Page 29 of this document now, please? I

14

15

And in section No.4 on Page 29, we have a list of

exemptions, and I would turn your attention down to I ~

16 item No. I, and would you 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 exemption would 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. Thank you. Since 17

rule, and that rule did not include these new

MR. DAVIS: That's correct.

I ~

I

I' But for the 2006 rule, the

Yes.

I' I would say it's possible,

MS. HODGE: Is that true?

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 in my 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 achieved by 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

significantly modified, is it true that the Agency's

goal of the Illinois emission reductions could be

achieved without these categories?

reductions could be less than 14.2 percent because

categories, and in at least one exemption was

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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 them while -- if I;

you wanted to take that 14.2 percent to be an exact

number, then the additional categories would be

additional reductions, which would also be helpful

with the attainment demonstration.

MR. MATOESIAN: And I think beyond

that, we'll get more fully into this in writing.

MS. HODGE: That's fine. Thank you.

I'd like to turn back now to the Agency's technical

support document, and could we 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 consumer products. Is that

correct?

MR. DAVIS: Yes.

MS. HODGE: Could you tell me what the I~

number ten footnote means? Is that a reference to

your reference document number ten?

MR. DAVIS: It could be, yes.
( 1

Page 29

MS. HODGE: And could you tell me what

2 that document is, please?

3 MR. DAVIS: That is a technical

4 support document from the state of New Jersey 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 California data,

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

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15

16

17

18

for its consumer products rule?

MR. DAVIS: No.

MS. HODGE: And what's the date of

this New Jersey document?

MR. DAVIS: 2003.

MS. HODGE: Do you think it's likely

I

19 that this 2003 New Jersey 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 identified just 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 and not

MS. HODGE: Okay. Could you go

7 through and show us, please, where it doesn't show

9 that would be easier to address in writing --

8 the new categories? And if that would be something ·

·

·

10 MR. MATOESIAN: That would probably be ,

11 much easier.'

(

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13

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15

MS. HODGE: All right. I would ask

that we do that.

MR. DAVIS: Sure.

MS. HODGE: So if a category is not

16 listed in this table, is it correct to state that

17 the Agency really did not consider emission

18 reductions associated with 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 say perhaps and perhaps not, because some

of the new categories would be included in here.

MS. HODGE: All right. Thank you. So

24 is it accurate to say that the Agency did not
Page 31 .

1 include the ozone reducing impact of reduction -- 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 and Mack Tech, Labco, and California.

14 additional categories for its '06 rule?

(

12

13

15

16

17

MS. HODGE: Do you know whether the

OTC estimated emission reductions for these

MR. DAVIS: That I would have to check

on.

MS. HODGE: Okay. And that's

18 something to be submitted, right?

19

20

MR. MATOESIAN: Okay.

MS. HODGE: We would need 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 OTC model rule does not

24 include these additional categories, is it true that
I

Did the Agency consider the cost associated with ;

Agency would not have considered the cost. Is that

correct? j

,

MR. DAVIS: Yes.

;

'.

Could you repeat that?

MS. HODGE: Certainly. We've been

MR. DAVIS:

MS. HODGE: And so the question is:

MR. DAVIS: Sure.

Page 32

the Agency did not consider the cost for compliance

MR. DAVIS: I would say as far as they

talking about whether or not the Agency considered

the emission reductions associated with the

associated with regulating these additional

categories?

whether the Agency analyzed the cost -- the

MS. HODGE: Thank you. So if the

additional categories, and this question goes to

were considered by the other resources that I have

additional categories.

compliance cost associated with adding these

compliance for the cost of these additional

categories?

mentioned previously.

other resources did not consider the costs, then the

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that Exhibit NO.3?

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Page 33

MS. HODGE: Okay. Thank you. Also,

we had mentioned early on in this OTe document -- is .

..

;

MR. FOX: Number three, yes. ;

MS. HODGE: Thank you, Mr. Fox. We

6 had mentioned the change to the exemption for

8 Agency did not consider the cost of compliance as

7

9

10

paradichlorobenzene. So is it also true that the

associated with this modified exemption?

MR. DAVIS: That's possible. I would

·

·

·

11 have to -- I would have 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 they were from a document •

,

15

16

17

18

included. If they were not, then I would say they

were not.

MS. HODGE: Okay. Thank you.

MR. DAVIS: And as I stated, neither

19 one nor the other was the sole basis. I think a few

20 questions ago, that's why I was asking you to repeat

21 it. I think you'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. Thank you. Thanks
Page 34

1 for that clarification. Do you know whether the OTC

2 estimated the cost for compliance for adding these

3 additional categories? I

4 MR. DAVIS: I would have to check on I

I

5 that.

6 MS. HODGE: If you 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. Could we turn back to the

10 Exhibit 3, and in particular the note number one,

11 and just to go back and revisit it. So is it your

12 understanding that the newly listed categories that

( 13

14

include an asterisk beside it in this document, that

OTC is saying it's up to the state to decide whether .,

MR. DAVIS: That is my understanding,

it wishes to include regulation of those categories? ,

;;

,

; 17 yes.

15

16

18 MS. HODGE: And isn't it true that the

19 OTC also concluded that certain of these compounds

20 may not cause or contribute to formation of ozone

21 I: but are listed here only for their hazardous nature?

22 MR. DAVIS: Yes.

23 MS. HODGE: Okay. Did the Agency do

24 any independent analysis of these compounds with the
1

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Page 35

asterisks beside to determine whether there was

really any air quality impact from -- on ozone I'

I~

3 formation?

4

5

MR. DAVIS: I don't believe so.

MS. HODGE: Okay. And could we just

I

6 take a look, for the record, and identify some of

7 these that have the asterisks beside them, please?

8 I would ask you to go to page

I

9

10

MR. DAVIS: 24?

MS. HODGE: Thank you. I think that's I

11 where I'm going. I thought I had all of my tabs

12 here. Please let's start on Page 24. If you 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

Would you agree that those things were probably

2 listed only because of their hazardous nature as

3 determined by California, the state of California?

4

5

MR. DAVIS: Yes.

MS. HODGE: Could we 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 did he completing

9 compound. So is it your understanding 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

would be optional, or -- yes, I guess it would be.

MS. HODGE: Okay. And did Illinois

.

•

15 EPA make 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 of whether we should include it or

19 not. I would have to check and see if I had any

20 notes on that. I believe that I thought that these

but I would have to check back and see -- and we

21

22

[

compounds were already covered under something else, I;

I'

I;

I;

23 just thought it was extraneous to include it again.

24 MR. MATOESIAN: We can do that in
(

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Page 37

writing, perform that in writing.

MR. FOX: Thank you.

MS. HODGE: That's fine. Thank you so

4 much. On to Page 28, this subcategory L,

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 on M, middle of

12 page on two, requirements for adhesive removers,

( 13 cleaners, and graffiti removers, is it your

14 understanding, too, that those would be optional for

15 regulation?

16

17

MR. DAVIS: That's right.

MS. HODGE: Okay. Page 29, at the top

18 of the page, N, subsection N, requirements for solid

19 air fresheners and toilet/urinal care products. Is ,

20 it your understanding 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'

I

I,

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 may have been an

MS. HODGE: However, it's not in the

Page 38

Agency's proposal includes the category of nail

polish removers at proposed Section 223.205?

intent to regulate nail polish removers?

product category and limits. Was that just an

TSD at table 2.2.1, which is proposed regulated

with the technical and economic information provided

to maintain its proposal to adopt a state version of Ie

I~

in this record to support the 2001 OTC model rule?

considered amending its proposal to be consistent

the 2006 OTC rule?

understand what you're asking me. As far as

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stated that we would be willing to provide any of

for Illinois.

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Page 39

MS. HODGE: And it's my understanding

and I know that you don't necessarily agree

MS. HODGE: Thank you. And where --

MR. MATOESIAN: We can get that back

with me 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 regulatory proposal is modeled after the 2006

to you.

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

amending its proposal so that it would be consistent

with the support, or in the alternative has it

2006 version?

industry mainly 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 stated before, obviously both

rules were considered, and we worked with the

where the resource material -- you've stated that

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categories, 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

Thank you. That's all I

I -- I couldn't promise

MR. FOX: Very well. Thank you,

MR. MATOESIAN: We can answer that one

MS. HODGE:

MR. DAVIS:

MS. HODGE: Okay. And this is a

the impact either, you know, the technical support

that today.

of those entities and states perhaps did not address

conducting some of the analysis here, and where some

in writing too.

were interested in asking questions, and if I may

this rule without that kind of analysis?

Ms. Hodge. There were other persons, I know, who

that the Board should move 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 Agency 1 s position

have today.

make one quick housekeeping announcement first of

policy question, too, Mr. Matoesian.

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director of environmental affairs for the National

the court reporter may know who you are.

if they don't wish to do so. But I believe someone

persons who wish to testify will be sworn in and may

from I;

I)

Ii

If I could just ask

I'm David Darling,

Would you like to do so

I wanted to make sure that anyone who

MR. DARLING:

MR. FOX:

hearing began. Posted directly in front of the

MR. FOX: Very good. Thank you for

Page 41

all, we did have 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 on which you can sign up if

possibility, although no one is required to testify

identifying yourself by name and association so that

participants.

did arrive after we began knew that that was a

indicated that they wanted to ask a question, and,

you wish to testify. And like other witnesses,

there, or come up to the chair?

Paint and Coatings Association.

sir, if you wouldn't mind before beginning, just

;

business card. '

a couple questions.

doing that.

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Page 42 ;

MR. DARLING: Okay. I'll come up.

MR. FOX: Whichever works for you.

MR. DARLING: Hopefully I'll be a

little bit shorter. We appreciate all the changes

that Illinois EPA has made with regards to the EOC

rule. I just have a couple clarifying questions.

Well, as far as appreciation, you clarified VOM and

VOC that they are identical, which is a good step

forward. You also clarified that instead of

allowing or requiring industry to respond with a

30 days of a written notice, 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 on May .

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. Thank you

very much 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 or model rule.

7 I did have one other comment. I

8 Like the aerosol rule you spoke about earlier, will

9 Illinois EPA -- it was our understanding 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 our understanding in the past.

clarify?

Could you

15 MR. DAVIS: That --

16 MR. MATOESIAN: We'd have to make a

17 decision once we see the federal rule.

18 MR. DARLING: Our understanding is

19 hopefully it's going to be very much like the OTC

20 model rule.

21

22 also.

MR. DAVIS: That's our understanding

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 your understanding

I

3 that hopefully if it ~s consistent with the OTC,

4 would that be a better or easier decision on your

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 interrupt just for a moment. Your public comment

(

11

12

13

14

15

16

had included a definition of concrete surface

retarder and in the company limit. Do you know

whether the agency agrees with the inclusion of the

language you had proposed in that rule, or perhaps

Mr. Davis could answer that question?

MR. DARLING: I do not know. We

I

I

17 submitted the comment. We would certainly hope that

18 to be consistent with the OTC rule.

19 MR. DAVIS: Sure. We'll have to check

20 on that and make sure that's something that would be

21

22

consistent with the OTC model rule.

MR. FOX: And if that could also be

23 addressed in a post-hearing comment, that would be

24 certainly helpful to the Board.
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Page 45

MR. DAVIS: Sure.

MR. DARLING: Just to clarify, this

came out of directly, I believe, New York 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

(

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is under the most restrictive limit as well. Very

well. Thank you, Mr. Darling. Did you have more

questions for the Agency at this time?

MR. DARLING: No.

MR. FOX: Very well.

MR. DARLING: Thank you.

MR. FOX: Thank you very much. I see

18 one more indicating that they'd like to make a

19 question, and also if you'd like to ask for --

20

21

MS. FREDE: I just have one quick

question. My name is Lisa Frede. I'm with 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

MR. FOX: If I may interrupt, Ms.

Is this something that the Agency can

MS. HODGE: Would you like a copy of

MS. FREDE: Yes, sir.

MS. FREDE: Of the errata sheet that

MR. FOX: Thank you, very much.

MS. HODGE: We have an extra copy.

I

Page 46

contained an inadvertent error on number 14 on Page

7. Specifically the explanation states that the

architectural and industrial maintenance code and

requirement of Section 223.320, i.e., the

proposed amendment is intended to clarify the

sheet here. Could you please --

was just --

have lapsed just for a second. That's Page 7 of

Frede, you referred to Page 7, and my attention may

correct for us?

of Section 223.255, i.e., the consumer products

proposed amendment actually pertains to provisions

regulation.

regulation. This reference is not correct. The

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MR. DAVIS: I think that's a typo in

2 the errata. So that would be an error in the

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errata, and I think we can correct that easily.

MS. FREDE: Thank you.

MR. FOX: Mr. Matoesian, Ms. Hodge has'

6 kindly made available a duplicate copy of the errata

7 sheet, of course not yet received through mail

8 service. Would you be willing to offer a motion to ,

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admit that as Exhibit No. 4 so that was part of our

hearing today?

MR. MATOESIAN: Sure. That's fine.

MR. FOX: Hearing Mr. Matoesian's

motion to admit errata Sheet Number 2 dated

is there any objection to its admission as that

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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 and marked as Exhibit NO.4. And

18 Ms. Hodge, thank you again for making a copy

19 available. Ms. Frede, did that wrap up your

20 questioning?

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22 very much.

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MS. FREDE: That was all. Thank you

MR. FOX: Absolutely. Sir, if you

24 would also please identify yourself and pose any
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Page 48\

question for the Agency that you may have.

MR. CAREY: My name is Dave Carey. I

3 work for W.R. Meadows. We're a family manufacturing

4 company here in Illinois. We've actually been in

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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, and we make products used in commercial

We

...

9 contact construction, architectural codings that are I

I

10 used to cure concrete. We also make vapor proofing

11 and water proofing membranes.

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One of the things that struck me

about the proposed rule is that we have this federal

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14 rule, kind of, on the back burner that's, you know,

15 coming down the pipe. And one of the things I

16 wanted to -- just wanted bring 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 already been

21 mentioned, and for us as a manufacturing company,

22 there are significant costs associated with

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reformulating products, retrofitting and changing

equipment, and one of the things that hurts us as a

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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 and your companYr may I have the court reporter

6 swear you in? Certainly we'll let you continue and .

7 ask whatever questions the agency would like.

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MR. CAREY: Sure.

(Wi tness sworn.)

MR. FOX: Sirr thank you for letting ;

11 me interrupt. Please go ahead.

12 MR. CAREY: So one of the challenges ;

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we face is just the costs associated with doing that),

and then complying with all these different rules. .

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I guess the question and the comment I have is why

not wait until the federal rule comes out r

:

.:

.

the Illinois rule and it would preempt the Illinois

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especially if it's going to be more restrictive than j

11

ruler as opposed to possibly requiring manufactures

20 machines r you know r formulations and retrofit

21 equipment for a one or 18-month period.

22 Also I'd like to just 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 our products. One is,

Page 50

2 obviously, the solvents. You know, a gallon of gas

3 is $4 a gallon. When you buy 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 lead program 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 consider would be just

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waiting until the federal rule comes out so it makes ::

that transition a little bit easier for industry.

MR. FOX: Sir, did you wish to pose a

15 specific question to the Agency?

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MR. CAREY: No.

MR. FOX: Okay. Very good. Thank you

18 for your comments. Was there any other participant 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 briefly before the

23 hearing, I did let Mr. Matoesian know that these

24 were in the nature of technical or housekeeping
I apologize in advance if they are I

a bit tedious to listen to, and Mr. Matoesian, I'm 11

I'

record --

comments, and that that would certainly be

going to try to avoid raising anything that was

I

I

-- what those are.

MR. FOX: -- but perhaps not

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 certainly please

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 "for purposes of

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another?

MR. MATOESIAN: Oh, okay.

I also had a question about a

that appear to have the word "part" were adhesive,

In

In subsection A

Particularly with regard to

MR. FOX: I'd be delighted.

MR. FOX:

MR. MATOESIAN: We addressed quite a

few of those, but if you 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

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MR. FOX: Number three in subsection Ii

later amendments or additions.

Quality Management District, and the California Air

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-- of the ASTM materials, 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, can you 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 Quality Management District, the Bay Area Air

to approval on August 10th of 1998, and we would ask

that you clarify whether there is a subsequent

version of this method that the Board would need to

in July of 1996, but the proposed subsection refers

materials that are incorporated by reference?

I, which incorporates the South Coast Air 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.

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would need to obtain.

of the method that the Board would need to obtain a

District Rule 1174, the documents filed indicate

In ;

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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 Bay Area

Air Quality Management 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, if you could

copy of for the record in this proceeding.

clarify again whether there is a subsequent version

M, incorporating South Coast Air Quality Management

the copy filed with the Board, however, there were

provision of the California Administrative Code.

clarify whether there is some subsequent version,

proposed subsection 120 suggested adoption on

updated version, of that document that the Board

question number six, subsection N incorporates a

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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, and we would ask that in

4 order to complete that document, of course, if you

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6

could supply a copy of the document that does

contain those images that appear to be quite

7 relevant, of course.

8 MR. MATOESIAN: Okay. I

I

9 MR. FOX: If I may move 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 if you would be willing to clarify

14 that reference, indicating whether there is an

15 inadvertent error, or whether it should be moved to I

16 subpart C, we would be grateful if you would clear '

\

17 that up for us.

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MR. MATOESIAN: Okay.

MR. FOX: And similarly, the

20 definition of lacquer in 223.203 refers to the

21 purposes of subpart C and D. So if you 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 the
standard.

one.

subsection A refers in a list of cross references

twice to Section 223.207, and I see that it does so

In both Sections 223.250

MR. FOX: Okay. Thank you 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 if you could similarly

MR. MATOESIAN: Okay.

that you clarify whether that was an unintended ,

in the errata sheet as well, and we 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 or whether 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. And moving on to Section 223.285, !

j

,

reference another section of the proposed rule.

months prior to the effective date of the applicable

additional product dating requirements, the errata

regarding product dating and Sections 223.255,

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Page 57

test methods, subsection E refers to an ASTM method

incorporated by reference, although it does not

appear to be listed among the ASTM methods that are

incorporated by reference in Section 223.120. And

if you would clarify that for us, we would

appreciate it.

And moving on to subpart c[

specifically section 223.307, and forgive me if I'm

mispronouncing some terms. It's entirely possible

':

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 if you could clarify the meaning of that

reference, we would appreciate it.

Number two, the definition of

nuclear coding refers to two ASTM methods, a

different version of which -- different versions of

which appear to be incorporated by reference in

Section 223.120[ and if you would clarify, please,

whether the Agency intended to incorporate

additional methods, we would be grateful for that as

well.

Number three, the definition of

traffic marking coding refers to the term Berets,
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

subsection B

I~

I'

I,

With regard to Section 223.340,

Then under Section 223.370, test

Number six, the definition of VOM

And finally, number seven, the

Page 58

B-e-r-e-t-s, which was unclear to us. If you could

clarify the use of that term, we would appreciate

that might have eluded us, that would be 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 section under aerosol codings, and we would I'

sub Section 223.400A," close quote, which is the

appreciate any clarification of that cross

compliance provisions and test methods,

referenced, please.

quote, analysis. Could you please clarify whether

or requirements relating to it.

could offer any clarification of technical meetings

which was not entirely clear to us. And if you

term fetal sheen, F-e-t-a-l, new word, S-h-e-e-n,

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Page 59

methods, subsection E incorporates ASTM method

D 1613-96, but Section 223.120 incorporates ASTM

D 1613-03 under the same title. And if you could

please clarify those two incorporations, we would

appreciate it.

Similarly, under subsection F,

there's an incorporation of ASTM method D 1640-95,

but it refers to two specific definitions, first

quick dry enamel, and second quick dry primer,

sealer, and undercoating, both of which include

testing according to a different ASTM standard,

1640-03. And again, if we could ask for a

clarification, please.

Subsection H incorporates the Bay

Area Air Quality Management District method 43, a

different version of which is incorporated in

Section 223.120. And if you would please clarify

whether the agency intended to incorporate different

versions, and if so, to file both versions with the

Board for its record of this proceeding.

Section H also refers to a

definition of volatile organic material in

Section 223.307 where it is not defined, and if you

would also please clarify that reference.

.

I;

1

I:
Page 60 I,

with Section 223.400, which is the purposes language;

i

And under this subsection -- under

Subsection I refers to compliance

been filed with the Board.

;

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•

:

i

·

";

;

I'

;

:

•

Subsection I

Moving on to Section 223.407,

that cross reference as well, please.

under aerosol codings. And if you would clarify

intended to incorporate different versions, and if

also incorporates South Cost Air Quality Management

is incorporated under Section 223.120 with another

and again, if you would clarify whether the Agency

these are definitions for subpart D. The definition

this section, finally, subsection M incorporates an

of which is incorporated by reference in 223.120,

so, whether -- indicate whether both versions have

appendix in the Code of Federal Regulations, which

of aviation or marine primer refers to federal

date in the citation. And if you would clarify the

specification TT-P-1757. And if you would please

very much.

authorities, please. Second under that section, the

District method number 303-91, a subsequent version

correct version of that, we would appreciate that

clarify that reference and its source in the federal

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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. Thank you.

Mr. Matoesian, I know that was a

And nearing the end,

product subject to this article. And if you could

clarify whether that's meant to refer to a product

intent to withdraw that, which would ineffectively

subject to this subpart or part.

Page 61

definition of product weighted MIR refers to a

large number of questions, and appreciate your

products as being beyond legal challenge at this

point, and unless 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 clear up.

coding products.

proposed rule. 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

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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 point put to sleep that

6 had any additional questions for the Agency, I'm

7 sure that Mr. Davis would be 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 Board members, member Moore, member

12 Melas, or the Board staff, Mr. Rao, were there any

17 today.

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further questions? I note that the sign up sheet

for persons who did not pre-file testimony but who

may wish to testify today remains blank, so we do

not have any further witnesses to testify here I,

I

I·

18 I can move on, then, to the issue

19 of the economic impact study. Since 1998, section

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27B of the Environmental Protection Act 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 Board adopts them. The
anyone who would like to testify or offer comment 1\

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Page 63

Board must 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 Board has received no response from the

testimony with regard to that request. Is there

regarding that request filed by the Board with the

department of commerce and economic opportunity?

Seeing or hearing 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 Board receives 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 can view it, download it, and copy it

free of charge 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 or holidays, I will issue a hearing officer

order very 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

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Page 65

I

electronically through the Board's clerk's office

and any questions about the use of the COOL system

should be directed to the check's office. Filings

}

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While no other hearings are not

online, the COOL system that you heard reference to,

with the Board, whether paper 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 officer order.

arrived with Marie 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

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Page 66 I

appreciates your time, your effort, and your input,

and we can adjourn. Thank you.

participants who are here today. I know the Board I,

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matters that need to be addressed at this time?

Seeing none, thank you certainly to Mr. Davis,

Mr. Matoesian, Ms. Hodge, and all of the other

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Page 67 Ie

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STATE OF ILLINOIS

SS

COUNTY OF COOK

REBECCA A. 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 said hearing and that the foregoing is a

true and correct transcript of her shorthand notes

so taken as aforesaid and contains all the

proceedings given at said hearing.

REBECCA

~.1J~ A. GRAZIANO, CSR

29 South LaSalle Street, Suite 850

Chicago, Illinois 60603

License No.: 084-004659

SUBSCRIBED AND SWORN TO

before me this 4th day

of June, A.D., 2008.

r,//~/ ,---';>L._~ ~~/;. I e~-u

Notary Public

C\Iofi 1/ 'tkl

DIANA ll"'\ v,n

Notory Puul,...· . ~I' ,',. .! ,,"~ ,<;

_ CommissIon t >f.II E;<, "","

1\

•

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Page 68

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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 ADM 1:6 47:18 28:11 38:14 7:1541:7

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52:15,16 34:2 54:23 64:16 40:15 46:7 65:10

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