ILLINOIS POLLUTION CONTROL BOARD
January 5, 2006
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
) R05-20
EXEMPTIONS FROM STATE
) (Rulemaking - Air)
PERMITTING REQUIREMENTS
)
FOR PLASTIC INJECTION MOLDING )
OPERATIONS )
(35 ILL. ADM. CODE 201.146)
)
Proposed Rule. Second Notice.
OPINION AND ORDER OF THE BOARD (by N.J. Melas):
Today the Board adopts the proposed rule for second notice pursuant to the Illinois
Administrative Procedure Act (5 ILCS 100/1-1
et seq
.). This rulemaking, proposed by the
Chemical Industry Council of Illinois (CICI), proposes revisions to the Board’s regulations
regarding exemptions from air construction and operating permit requirements. The proposal
seeks to add one category to the existing list of permit exemptions in Section 201.146. 35 Ill.
Adm. Code 201.146. According to CICI, the purpose of the proposal is to eliminate the burden
of state construction and operating permitting of low emitting emission units and activities for
both the Environmental Protection Agency (Agency) and owners and operators of plastic
injection molding (PIM) operations.
The Board received no public comments during the 45-day first-notice public comment
period, which ended November 28, 2005, and the proposal adopted here is substantively
unchanged from that adopted in the Board’s September 15, 2005 first-notice opinion and order.
In this opinion, the Board provides the procedural history of this rulemaking, an overview of the
proposed exemption, and a discussion of the second-notice proposal.
Today the Board adopts this proposal for second-notice review by the Joint Committee
on Administrative Rules (JCAR).
PROCEDURAL HISTORY
CICI states that because of the low level of emissions they generate, PIM operations
would qualify for the exemption from permitting for Federally Enforceable State Operating
Permit (FESOP) sources with a low potential to emit proposed by the proponents in the pending
rulemaking docket Proposed Amendments to Exemptions from State Permitting Requirements
(35 Ill. Adm. Code 201.146), R05-19. Statement at 3. CICI states, however, that proposed
FESOP sources exemption would apply only to permitted facilities, so PIM facilities that do not
require an Agency-issued air pollution control permit would not be eligible for that proposed
exemption.
2
Today the Board adopts CICI’s proposal for first-notice. First notice publication in the
Illinois Register
will begin a 45-day period for interested persons to file public comments with
the Board. The Board describes the proposed exemption and the various issues raised at hearing
in more detail below.
PROCEDURAL BACKGROUND
On April 19, 2005, CICI filed this proposal for rulemaking pursuant to Sections 27 and
28 of the Environmental Protection Act (Act) and 35 Ill. Adm. Code 102.202(b).
1
The Board
accepted this matter for hearing on May 5, 2005. Section 201.146 contains a list of 59
exemptions based on categories of emission units and activities that CICI refers to as
“categorical exemptions.” Statement at 1-2.
2
The proposed amendment would include PIM
operations in the categories of emissions units exempt from state air permitting requirements.
The Board notes that it is simultaneously adopting for first notice another proposal that amends
Section 201.146, entitled Proposed Amendments to Exemptions from State Permitting
Requirements (35 Ill. Adm. Code 201.146), R05-19 (Sept. 15, 2005).
The Board granted CICI’s motion to expedite this rulemaking on May 19, 2005. The
Board has held two public hearings in this rulemaking. The first hearing was held on July 1,
2005, in Chicago before Hearing Officer Amy Antoniolli and the second hearing was held on
July 15, 2005, in Springfield before Hearing Officer John Knittle.
3
Mr. Lynne Harris, Vice-President for Science and Technology of the Society of the
Plastics Industry, Incorporated (SPI, Inc.) testified on behalf of CICI. Ms. Lisa Frede, Director
of Regulatory Affairs for CICI, testified on CICI’s behalf and stated that CICI has 198 member
companies with over 54,000 employees. Tr.1 at 15. Ms. Pat Sharkey also testified on CICI’s
behalf.
Mr. Don Sutton testified on behalf of the Agency. Mr. Sutton is the manager of the
permit section, Division of Air Pollution Control, Bureau of Air, since 1991. Mr. Sutton is
responsible for issuing construction and operating permits for the Bureau of Air.
There have been two public comments filed in this rulemaking. The first was a
correction to the July 1, 2005 hearing transcript filed by the Environmental Protection Agency
(Agency) (PC 1), and the second was a post-hearing comment filed by CICI (PC 2). CICI has
filed three errata sheets suggesting changes to the proposed rule language.
SUMMARY OF PROPOSAL FOR SECOND-NOTICE
1
The proponents’ statement of reasons will be cited to as “Statement at _.”
2
The Board will cite to the Statement of Reasons as “Statement at _.”
3
The transcripts from the April 12, 2005 hearing will be cited to as “Tr.1 at _,” and the transcript
from the June 14, 2005 hearing will be cited to as “Tr.2 at _.”
3
The proposed exemption adds a new exemption for owners and operators of PIM
operations to the existing list of permit exemptions in Section 201.146. 35 Ill. Adm. Code
201.146. The rule language limits the exemption to facilities that use 5,000 tons or less of resin
annually in the PIM process. The 5,000 ton limit applies facility-wide rather than to each piece
of PIM equipment. Tr.2 at 10.
DISCUSSION OF SECOND-NOTICE PROPOSAL
The Board has received no public comments during the first-notice public comment
period. At second notice, the Board only makes changes received from JCAR all of which are
grammatical and non-substantive and, therefore, require no discussion.
The Board found at first notice that the proposal did not raise concerns regarding
technical feasibility. Nobody testified or commented about DCEO’s decision not to perform an
economic impact study on this rulemaking. As found at first notice, the Board finds here that the
proposal is both technically feasible and economically reasonable.
CONCLUSION
The Board adopts the proposed exemption from state air permitting proposal for second-
notice review by JCAR. The 45-day second-notice public comment period will begin on the date
written notice is received by JCAR and the Board will accept comments only from JCAR during
the second-notice period.
See
35 Ill. Adm. Code 102.606.
ORDER
The Board directs the Clerk to cause the filing of the following rule with the Joint
Committee on Administrative Rules for its second-notice review. Proposed deletions to the
current rules are stricken and proposed additions are underlined.
TITLE 35: ENVIRONMENTAL PROTECTION
SUBTITLE B: AIR POLLUTION
CHAPTER I: POLLUTION CONTROL BOARD
SUBCHAPTER a: PERMITS AND GENERAL PROVISIONS
PART 201
PERMITS AND GENERAL PROVISIONS
SUBPART A: DEFINITIONS
Section
201.101 Other Definitions
201.102 Definitions
201.103 Abbreviations and Units
201.104 Incorporations by Reference
4
SUBPART B: GENERAL PROVISIONS
Section
201.121 Existence of Permit No Defense
201.122 Proof of Emissions
201.123 Burden of Persuasion Regarding Exceptions
201.124 Annual Report
201.125 Severability
201.126 Repealer
SUBPART C: PROHIBITIONS
Section
201.141 Prohibition of Air Pollution
201.142 Construction Permit Required
201.143 Operating Permits for New Sources
201.144 Operating Permits for Existing Sources
201.146 Exemptions from State Permit Requirements
201.147 Former Permits
201.148 Operation Without Compliance Program and Project Completion Schedule
201.149 Operation During Malfunction, Breakdown or Startups
201.150 Circumvention
201.151 Design of Effluent Exhaust Systems
SUBPART D: PERMIT APPLICATIONS AND REVIEW PROCESS
Section
201.152 Contents of Application for Construction Permit
201.153 Incomplete Applications (Repealed)
201.154 Signatures (Repealed)
201.155 Standards for Issuance (Repealed)
201.156 Conditions
201.157 Contents of Application for Operating Permit
201.158 Incomplete Applications
201.159 Signatures
201.160 Standards for Issuance
201.161 Conditions
201.162 Duration
201.163 Joint Construction and Operating Permits
201.164 Design Criteria
201.165 Hearings
201.166 Revocation
201.167 Revisions to Permits
201.168 Appeals from Conditions
201.169 Special Provisions for Certain Operating Permits
201.170 Portable Emission Units
5
SUBPART E: SPECIAL PROVISIONS FOR OPERATING PERMITS FOR CERTAIN
SMALLER SOURCES
Section
201.180 Applicability (Repealed)
201.181 Expiration and Renewal (Repealed)
201.187 Requirement for a Revised Permit (Repealed)
SUBPART F: CAAPP PERMITS
Section
201.207 Applicability
201.208 Supplemental Information
201.209 Emissions of Hazardous Air Pollutants
201.210 Categories of Insignificant Activities or Emission Levels
201.211 Application for Classification
as an Insignificant Activity
201.212 Revisions to Lists of Insignificant Activities or Emission Levels
SUBPART G: EXPERIMENTAL PERMITS
(Reserved)
SUBPART H: COMPLIANCE PROGRAMS AND PROJECT COMPLETION SCHEDULES
Section
201.241 Contents of Compliance Program
201.242 Contents of Project Completion Schedule
201.243 Standards for Approval
201.244 Revisions
201.245 Effects of Approval
201.246 Records and Reports
201.247 Submission and Approval Dates
SUBPART I: MALFUNCTIONS, BREAKDOWNS OR STARTUPS
Section
201.261 Contents of Request for Permission to Operate During a Malfunction, Breakdown
or Startup
201.262 Standards for Granting Permission to Operate During a Malfunction, Breakdown
or Startup
201.263 Records and Reports
201.264 Continued Operation or Startup Prior to Granting of Operating Permit
201.265 Effect of Granting of Permission to Operate During a Malfunction, Breakdown or
Startup
SUBPART
J:
MONITORING AND TESTING
6
Section
201.281 Permit Monitoring Equipment Requirements
201.282 Testing
201.283 Records and Reports
SUBPART K: RECORDS AND REPORTS
Section
201.301 Records
201.302 Reports
SUBPART
L:
CONTINUOUS MONITORING
Section
201.401 Continuous Monitoring Requirements
201.402 Alternative Monitoring
201.403 Exempt Sources
201.404 Monitoring System Malfunction
201.405 Excess Emission Reporting
201.406 Data Reduction
201.407 Retention of Information
201.408 Compliance Schedules
201.APPENDIX A Rule into Section Table
201.APPENDIX B Section into Rule Table
201.APPENDIX C Past Compliance Dates
AUTHORITY: Implementing Sections 10, 39, and 39.5 and authorized by Section 27 of the
Environmental Protection Act [415 ILCS 5/10, 27, 39, and 39.5].
SOURCE: Adopted as Chapter 2: Air Pollution, Part I: General Provisions, in R71-23, 4 PCB
191, filed and effective April 14, 1972; amended in R78-3 and 4, 35 PCB 75 and 243, at 3 Ill.
Reg.30, p. 124, effective July 28, 1979; amended in R80-5, at 7 Ill. Reg. 1244, effective January
21, 1983; codified at 7 Ill. Reg. 13579; amended in R82-1 (Docket A) at 10 Ill. Reg. 12628,
effective July 7, 1986; amended in R87-38 at 13 Ill. Reg. 2066, effective February 3, 1989;
amended in R89-7(A) at 13 Ill. Reg. 19444, effective December 5, 1989; amended in R89-7(B)
at 15 Ill. Reg. 17710, effective November 26, 1991; amended in R93-11 at 17 Ill. Reg. 21483,
effective December 7, 1993; amended in R94-12 at 18 Ill. Reg. 15002, effective September 21,
1994; amended in R94-14 at 18 Ill. Reg. 15760, effective October 17, 1994; amended in R96-17
at 21 Ill. Reg. 7878, effective June 17, 1997; amended in R98-13 at 22 Ill. Reg. 11451, effective
June 23, 1998; amended in R98-28 at 22 Ill. Reg. 11823, effective July 31, 1998; amended in
R02 -10, at 27 Ill. Reg. 5820, effective March 21, 2003; amended in R05-20 at 30 Ill. Reg.
__________, effective ________.
7
SUBPART C: PROHIBITIONS
Section 201.146 Exemptions from State Permit Requirements
Construction or operating permits, pursuant to Sections 201.142, 201.143 and 201.144 of this
Part, are not required for the classes of equipment and activities listed below in this Section. The
permitting exemptions in this Section do not relieve the owner or operator of any source from
any obligation to comply with any other applicable requirements, including the obligation to
obtain a permit pursuant to Sections 9.1(d) and 39.5 of the Act, Sections 165, 173 and 502 of the
Clean Air Act or any other applicable permit or registration requirements.
a) Air contaminant detectors or recorders, combustion controllers or combustion
shutoffs;
b) Air conditioning or ventilating equipment not designed to remove air
contaminants generated by or released from associated equipment;
c) Each fuel burning emission unit for indirect systems and for heating and reheating
furnace systems used exclusively for residential, or commercial establishments
using gas and/or fuel oil exclusively with a design heat input capacity of less than
14.6 MW (50 mmbtu/hr) , except that a permit shall be required for any such
emission unit with a design heat input capacity of at least 10 mmbtu/hr that was
constructed, reconstructed or modified after June 9, 1989 and that is subject to 40
CFR 60, Subpart D;
d) Each fuel burning emission unit other than those listed in subsection (c) of this
Section for direct systems used for comfort heating purposes and indirect heating
systems with a design heat input capacity of less than 2930 kW (10 mmbtu/hr);
e) Internal combustion engines or boilers (including the fuel system) of motor
vehicles, locomotives, air craft, watercraft, lifttrucks and other vehicles powered
by nonroad engines;
f) Bench scale laboratory equipment and laboratory equipment used exclusively for
chemical and physical analysis, including associated laboratory fume hoods,
vacuum producing devices and control devices installed primarily to address
potential accidental releases;
g) Coating operations located at a source using not in excess of 18,925 l (5,000 gal)
of coating (including thinner) per year;
h) Any emission unit acquired exclusively for domestic use, except that a permit
shall be required for any incinerator and for any fuel combustion emission unit
using solid fuel with a design heat input capacity of 14.6 MW (50 mmbtu/hr) or
more;
8
i) Any stationary internal combustion engine with a rated power output of less than
1118 kW (1500 horsepower), except that a permit shall be required for any
stationary gas turbine engine with a rated heat input at peak load of 10.7
gigajoules/hr (10 mmbtu/hr) or more that is constructed, reconstructed or
modified after October 3, 1977 and that is subject to requirements of 40 CFR 60,
Subpart GG;
j) Rest room facilities and associated cleanup operations, and stacks or vents used to
prevent the escape of sewer gases through plumbing traps;
k) Safety devices designed to protect life and limb, provided that a permit is not
otherwise required for the emission unit with which the safety device is
associated;
l) Storage tanks for liquids for retail dispensing except for storage tanks that are
subject to the requirements of 35 Ill. Adm. Code 215.583(a)(2), 218.583(a)(2) or
219.583(a)(2);
m) Printing operations with aggregate organic solvent usage that never exceeds 2,839
l (750 gal) per year from all printing lines at the source, including organic solvent
from inks, dilutents, fountain solutions and cleaning materials;
n) Storage tanks of:
1) Organic liquids with a capacity of less than 37,850 l (10,000 gal),
provided the storage tank is not used to store any material listed as a
hazardous air pollutant pursuant to Section 112(b) of the Clean Air Act,
and provided the storage tank is not subject to the requirements of 35 Ill.
Adm. Code 215.583(a)(2), 218.583(a)(2) or 219.583(a)(2);
2) Any size containing exclusively soaps, detergents, surfactants, waxes,
glycerin, vegetable oils, greases, animal fats, sweetener, corn syrup,
aqueous salt solutions or aqueous caustic solutions, provided an organic
solvent has not been mixed with such materials; or
3) Any size containing virgin or re-refined distillate oil, hydrocarbon
condensate from natural gas pipeline or storage systems, lubricating oil or
residual fuel oils.
o) Threaded pipe connections, vessel manways, flanges, valves, pump seals, pressure
relief valves, pressure relief devices and pumps;
p) Sampling connections used exclusively to withdraw materials for testing and
analyses;
9
q) All storage tanks of Illinois crude oil with capacity of less than 151,400 l (40,000
gal) located on oil field sites;
r) All organic material-water single or multiple compartment effluent water
separator facilities for Illinois crude oil of vapor pressure of less than 34.5 kPa
absolute (5 psia);
s) Grain-handling operations, exclusive of grain-drying operations, with an annual
grain through-put not exceeding 300,000 bushels;
t) Grain-drying operations with a total grain-drying capacity not exceeding 750
bushels per hour for 5% moisture extraction at manufacturer's rated capacity,
using the American Society of Agricultural Engineers Standard 248.2, Section 9,
Basis for Stating Drying Capacity of Batch and Continuous-Flow Grain Dryers;
u) Portable grain-handling equipment and one-turn storage space;
v) Cold cleaning degreasers that are not in-line cleaning machines, where the vapor
pressure of the solvents used never exceeds 2 kPa (15 mmHg or 0.3 psi) measured
at 38
°
C (100
°
F) or 0.7 kPa (5 mmHg or 0.1 psi) at 20
°
C (68
°
F);
w) Coin-operated dry
cleaning operations;
x) Dry cleaning operations at a source that consume less than 30 gallons per month
of perchloroethylene;
y) Brazing, soldering, wave soldering or welding equipment, including associated
ventilation hoods;
z) Cafeterias, kitchens, and other similar facilities, including smokehouses, used for
preparing food or beverages, but not including facilities used in the manufacturing
and wholesale distribution of food, beverages, food or beverage products, or food
or beverage components;
aa) Equipment for carving, cutting, routing, turning, drilling, machining, sawing,
surface grinding, sanding, planing, buffing, sand blast cleaning, shot blasting, shot
peening, or polishing ceramic artwork, leather, metals (other than beryllium),
plastics, concrete, rubber, paper stock, wood or wood products, where such
equipment is either:
1) Used for maintenance activity;
2) Manually operated;
3) Exhausted inside a building; or
10
4) Vented externally with emissions controlled by an appropriately operated
cyclonic inertial separator (cyclone), filter, electro-static precipitor or a
scrubber.
bb) Feed mills that produce no more than 10,000 tons of feed per calendar year,
provided that a permit is not otherwise required for the source pursuant to Section
201.142, 201.143 or 201.144;
cc) Extruders used for the extrusion of metals, minerals, plastics, rubber or wood,
excluding:
1) Extruders used in the manufacture of polymers;
2) Extruders using foaming agents or release agents that contain volatile
organic materials or Class I or II substances subject to the requirements of
Title VI of the Clean Air Act; and
3) Extruders processing scrap material that was produced using foaming
agents containing volatile organic materials or Class I or II substances
subject to the requirements of Title VI of the Clean Air Act.
dd) Furnaces used for melting metals, other than beryllium, with a brim full capacity
of less than 450 cubic inches by volume;
ee) Equipment used for the melting or application of less than 22,767 kg/yr (50,000
lbs/yr) of wax to which no organic solvent has been added;
ff) Equipment used for filling drums, pails or other packaging containers, excluding
aerosol cans, with soaps, detergents, surfactants, lubricating oils, waxes, vegetable
oils, greases, animal fats, glycerin, sweeteners, corn syrup, aqueous salt solutions
or aqueous caustic solutions, provided an organic solvent has not been mixed with
such materials;
gg) Loading and unloading systems for railcars, tank trucks, or watercraft that handle
only the following liquid materials: soaps, detergents, surfactants, lubricating oils,
waxes, glycerin, vegetable oils, greases, animal fats, sweetener, corn syrup,
aqueous salt solutions or aqueous caustic solutions, provided an organic solvent
has not been mixed with such materials;
hh) Equipment used for the mixing and blending of materials at ambient temperatures
to make water based adhesives, provided each material mixed or blended contains
less than 5% organic solvent by weight;
ii) Die casting machines where a metal or plastic is formed under pressure in a die
located at a source with a throughput of less than 2,000,000 lbs of metal or plastic
per year, in the aggregate, from all die casting machines;
11
jj) Air pollution control devices used exclusively with other equipment that is
exempt from permitting, as provided in this Section;
kk) An emission unit for which a registration system designed to identify sources and
emission units subject to emission control requirements is in place, such as the
registration system found at 35 Ill. Adm. Code 218.586 (Gasoline Dispensing
Operations - Motor Vehicle Fueling Operations) and 35 Ill. Adm. Code 218,
Subpart HH (Motor Vehicle Refinishing);
ll) Photographic process equipment by which an image is reproduced upon material
sensitized to radiant energy;
mm) Equipment used for hydraulic or hydrostatic testing;
nn) General vehicle maintenance and servicing activities conducted at a source, motor
vehicle repair shops, and motor vehicle body shops, but not including:
1) Gasoline fuel handling; and
2) Motor vehicle refinishing.
oo) Equipment using water, water and soap or detergent, or a suspension of abrasives
in water for purposes of cleaning or finishing, provided no organic solvent has
been added to the water;
pp) Administrative activities including, but not limited to, paper shredding, copying,
photographic activities and blueprinting machines. This does not include
incinerators;
qq) Laundry dryers, extractors, and tumblers processing that have been cleaned with
water solutions of bleach or detergents that are:
1) Located at a source and process clothing, bedding and other fabric items
used at the source, provided that any organic solvent present in such items
before processing that is retained from cleanup operations shall be
addressed as part of the VOM emissions from use of cleaning materials;
2) Located at a commercial laundry; or
3) Coin operated.
rr) Housekeeping activities for cleaning purposes, including collecting spilled and
accumulated materials, including operation of fixed vacuum cleaning systems
specifically for such purposes, but not including use of cleaning materials that
contain organic solvent;
12
ss) Refrigeration systems, including storage tanks used in refrigeration systems, but
excluding any combustion equipment associated with such systems;
tt) Activities associated with the construction, on-site repair, maintenance or
dismantlement of buildings, utility lines, pipelines, wells, excavations, earthworks
and other structures that do not constitute emission units;
uu) Piping and storage systems for natural gas, propane and liquefied petroleum gas;
vv) Water treatment or storage systems, as follows:
1) Systems for potable water or boiler feedwater;
2) Systems, including cooling towers, for process water, provided that such
water has not been in direct or indirect contact with process streams that
contain volatile organic material or materials listed as hazardous air
pollutants pursuant to Section 112(b) of the Clean Air Act.
ww) Lawn care, landscape maintenance and grounds keeping activities;
xx) Containers, reservoirs or tanks used exclusively in dipping operations to coat
objects with oils, waxes or greases, provided no organic solvent has been mixed
with such materials;
yy) Use of consumer products, including hazardous substances as that term is defined
in the Federal Hazardous Substances Act (15 USC U.S.C. 1261 et seq.), where the
product is used at a source in the same manner as normal consumer use;
zz) Activities directly used in the diagnosis and treatment of disease, injury or other
medical condition;
aaa) Activities associated with the construction, repair or maintenance of roads or
other paved or open areas, including operation of street sweepers, vacuum trucks,
spray trucks and other vehicles related to the control of fugitive emissions of such
roads or other areas;
bbb) Storage and handling of drums or other transportable containers, where the
containers are sealed during storage and handling;
ccc) Activities at a source associated with the maintenance, repair or dismantlement of
an emission unit or other equipment installed at the source, not including the
shutdown of the unit or equipment, including preparation for maintenance, repair
or dismantlement, and preparation for subsequent startup, including preparation of
a shutdown vessel for entry, replacement of insulation, welding and cutting, and
steam purging of a vessel prior to startup;
13
ddd)
Equipment used for corona arc discharge surface treatment of plastic with a power
rating of 5 kW or less or equipped with an ozone destruction device;
eee)
Equipment used to seal or cut plastic bags for commercial, industrial or
domestic use;
fff)
Each direct-fired gas dryer used for a washing, cleaning, coating or printing line,
excluding:
1)
Dryers with a rated heat input capacity of 2930 kW (10 mmbtu/hr) or
more; and
2)
Dryers for which emissions other than those attributable to combustion of
fuel in the dryer, including emissions attributable to use or application of
cleaning agents, washing materials, coatings or inks or other process
materials that contain volatile organic material are not addressed as part of
the permitting of such line, if a permit is otherwise required for the line;
and
ggg)
Municipal solid waste landfills with a maximum total design capacity of less than
2.5 million Mg or 2.5 million m
3
that are not required to install a gas collection
and control system pursuant to 35 Ill. Adm. Code 220 or 800 through 849 or
Section 9.1 of the Act; and .
hhh)
Plastic injection molding equipment with an annual through-put not exceeding
5,000 tons of plastic resin in the aggregate from all plastic injection molding
equipment at the source, and all associated plastic resin loading, unloading,
conveying, mixing, storage, grinding, and drying equipment and associated mold
release and mold cleaning agents.
(Source: Amended at 30 Ill. Reg. __________, effective ____________)
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control Board, certify that the Board
adopted the above opinion and order on January 5, 2006, by a vote of 4-0.
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
