ILLINOIS POLLUTION CONTROL BOARD
November
8,
1973
)
IN THE MATTER OF WATER QUALITY
)
R72-4
STANDARDS REVISIONS
)
)
OPINION OF THE BOARD
(by Mr. Dumelie):
This Opinion of the Board
is
in support of amendments
to Chapter
3 of the Pollution Control Board’s Water Pollution Regulations
adopted on June 28,
1973.
These
amendments were consolidated from
revisions proposed by the Board,
the Environmental Protection
Agency (Agency),Granite City Steel, The Metropolitan Sanitary
District of Greater Chicago
(MSDGC), and Commonwealth Edison Company.
After reviewing
the record produced in ten hearings,
the Board adopted
the amendments
as published in the Newsletter
#65, May 17,
1973,
with two revisions
that were published in Newsletter #69, July
16,
1973.
The Amendments were first published in Newsletter #50, July 14,
1972.
Hearings were held in six cities throughout
Illinois.
1.
The first group
of amendments were proposed by the Board.
An amendment to Sec.
406 Nitrogen was proposed and adopted to
control industrial
dischargers of more than 100 lbs.
of ammonia
as N, whose wasteload cannot be computed on
a population equivalent
(PE) basis.
Such industrial
dischargers who discharge into the
Illinois River,
Chicago River System or Calumet River System will be
subject
to an ammonia effluent standard of 3.0 mg/l
as N after
December
31,
1974.
The Board found that present technology
is
capable of meeting
this limit
and should result in the removal
of
much ammonia nitrification oxygen demand
(NOD)
from these stressed
waterways.
Ammonia removal from
such industrial wastes, when com-
pared with removal from domestic wastes
is rather easily applied
(R.
25, September
13,
1972).
The definition of “water” in Section
104 Definitions
was
amended by the Board to add a clause that
allows
the use
of in-stream
aeration under Agency permit.
Another Board proposal would have allowed the Agency to require
bonds
as
a condition to obtain an Agency permit.
After
considering
their revision,
the Board declined to adopt the proposed new Section
926.
10—69
-2-
2.
Another group of amendments which were proposed
by
the Agency,
were received on April
7,
1972.
The first
of the Agency proposals
was
to amend Section 103 Repeals to repeal SWB-2
and SWB-l7,
and
to replace SWB-2 with
a new Part XII:
Treatment Plant Operation
Certification.
SWB-2 and SWB-l7 were adopted by the Illinois Sanitary
Water Board and continued in effect by Section 49(c)
of the
Environmental Protection Act “until repealed,
amended,
or superseded
by regulations under this Act.”
SWB-2
set rigid regulations that governed
the certification of treatment plant operators by
the Agency.
The
Agency desired this
amendment to permit them
a greater flexibility
to change certification requirements with technological developments.
As
a result of discussion concerning this amendment the Agency proposed
an addition to Part XII
to insure
that an applicant could appeal
his certification denial
to the Board.
The Board adopted the repeal
of SWB-2
and the addition of Part XII
in order to allow the Agency
to
cope with various problems such
as how to certify the 400 MSDGC
plant operators.
The Agency sought the repeal of SWB-l7 because
of language that might be construed to conflict with the act which
gives
the Agency exclusive control of
the administration
of Federal
grant
monies.
The Board agreed and amended Section
103 to repeal
SWB-17 which had set out rules
for establishing priorities for
awarding Federal monies
in order
to
avoid any conflict with the Act.
The next portion of the Agency proposal dealt with
a relatively
minor
group of amendments to correct
or supply missing STORET NUMBERS
in the following Sections:
203(f),
204(b),
206(c),
and 408(a).
The Agency proposed a correction of
a typographical error
in the
placement
of the phrase “for excess energy” within Section 104
Definitions “Industrial Wastes”.
A correction
of misspelled words
in Section 501,
502 and 912 was also proposed.
The
Board adopted
these changes
as published in Newsletter #65, May
17,
1973.
The Agency proposed to amend Section
302 Restricted Use Waters
by adding
a clause
to
require that the Board hold hearings
in 1973
and every
5 years thereafter to determine whether any Restricted
Use Water
should be reclassified
as
a General Use Water.
This
amendment
is in response to
the Federal Environmental Protection
Agency
(U.S.
EPA)
policy not to approve restricted use
status
as
a permanent status for any water
(R.
11,
September 13,
1972
and Ex.
#4).
In addition to the Federal objection,
the
revision would give notice
to those who are currently discharging
into Restricted Use Waters
that they are not permanently guaranteed
such use
(R.
12, September 14, 1972).
The Board agreed with the
Agency’s reasoning and adopted
Its amendment to reflect
a limitation
on the Restricted Use designation.
The Agency proposed a change in Section 404(f)(ii)B to substitute
“the levels
set by the applicable water quality standard” for the
previously specified numerical DO
level.
The Board approved this
clarification and adopted the amendment.
10—70
-3-
The Agency proposed amending Section 405 Bacteria by addition
of “governed by this part”
to clarify the.wording which requires
disinfection of combined overflows by July 31,
1972.
The deletion
of
the language referring to SWB-7 through SWB-lS was also proposed.
The Agency also proposed establishing
a later deadline of December 31,
1973 for discharges into the Ohio
and Mississippi Rivers
Regulations
passed by
the Board in 1971
(R.
70-3
and 71-3) required disinfection
of combined overflows discharging into the Ohio and Mississippi
Rivers by December 31,
1973.
When
the Board amended this regulation
in R70-7,
71-14 and 71-20
it unintentionally accelerated the deadline for
Ohio and Mississippi River discharges.
The Board adopted this
amendment to correct a previous error.
The Agency proposed that Section 406 Nitrogen be amended to
include the Des Plaines downstream
of its confluence with the
Chicago River System in those waters which have an effluent limita-
tion on ammonia.
The Board approved this amendment because
it
conforms
to the Boa:d’s original intent when
it placed ammonia
effluents on the other waterways listed in this Section.
The Agency proposed a specific standard of 0.025 mg/i as
a
limit for discharges of cyanideinto
a public sewer system.
5ection 702(a) Cyanide previously had read “detectable
levels of
cyanide”.
The Board adopted this
as
a parallel to the Water Quality
Standard of 0.025 mg/I found in Section
203.
The Agency proposed the deletion of “by the Agency”
in Section
942 Permit Revocation to conform to the Board’s desire that all
permit revocations
take place only
as
a result of
a complaint and
action brought before the Board.
The Board amended Section 942
to
conform with this policy.
3.
Granite City Steel
Company proposed an amendment to reclassify
Horseshoe Lake
from Public and Food Processing Water Supply to
General Use
(Section 303).
The Board received the proposal on
July
6,
1972.
The basis for their request was that Horseshoe Lake
had never and would never be used for a public or food processing
water supply and thus should not be classified as
such.
Various
company officials so testified in support of their proposal
(R.
32,
84, and 111, September
22,
1972).
Granite City Steel’s Engineering
Consultant, Mr. John Huston,
testified that the Lake did not meet
the drinking water standards required as
a source of public waters.
The Agency testified that
in their view an amendment of the rules
regarding Horseshoe Lake
is not needed at the present
time
(R.
10,
September
22,
1972).
The Board finds
that there
is
no need
to
reclassify Horseshoe Lake
as
a general use water
(Section 301) and to
take
it out of Section 303 Public and Food Processing Water Supply
10—71
-4-
because
of the extreme
unlikelihood that the Lake will ever be
used
as
a public water supply and thus such standards may never
become operative.
4.
The MSDGC proposed an amendment
to Section 404(e) Deoxygenatirtg
Wastes
to change the effluent limits
to
10 mg/l BOD5
and 12 mg/l
suspended solids
(SS) from
4 rng/l BODç and
5 mg/l SS.
The Board
received the proposal
on April
25,
1972.
At the hearing, the
Agency stated that they did not oppose the amendment
(R.
17, 9/13/72).
The original purpose
of requiring
the MSDGC
to meet
a
4 mg/l
BOD
and
5 mg/i
SS was to remove deoxygenating wastes from their effl~ent
and thus allow the DO in the ~downstreamwaterways
to reach the
level
prescribed by the existing standard.
During periods of low flow up
to 99
of the flow in the sanitary district’s
controlled waterways
is made of MSDGC effluent.
Evidence presented by Mr. Ralph Evans, Illinois Water Quality
Survey,
tends
to show that,
even with the MSDGC meeting the 4-5
effluent standard,
the Illinois River at Marseilles
and Starved
Rock will not meet
the DO standard of
6 and will be in fact
less
than
4 mg/l DO
(R.
114,
10/19/72).
Even if the oxygen demand
exerted by nitrofication of ammonia
(NOD)
was
zero,
the model
predicts that
a DO level
of
6
is
not obtainable
(R.
124,
10/19/72).
Modeling conducted by the MSDGC also predicts that both
4 mg/i
BOD
and
5 mg/i
SS
and 10 mg/i BOD~and 12 mg/l
SS will not
achieve
a D~level of
6 mg/l
(R.
283, 10/l~/72).
The MSDGC proposed to amend the standard to require them
to
meet 10-12
instead of
4-5.
They propose to carry out instream-
aeration to raise the DO level
to 6.0 mg/i.
MSDGC presented modeling
evidence that showed an effluent of 4-5 would result in an instream
BODç
level of 2.4 mg/i with
a DO level
of
4.4 mg/I; while
an effluent
of T0-i2 would result in an instream BOD5
level of 2.6 mg/l with
a
DO level
of 4.2 mg/i
(R,
17, 10/20/72).
Evidence shows
the predicted
cost of meeting the 4-5 standards
is
$236.7 million dollars with an
operational
cost of $26 million dollars.
The cost of 10-12 with
instream aeration is $138.8 million dollars with an operating cost
of $16 million dollars per year
(R.
19, 10/20/72).
Two eminent professionals,
Clair Sawyer and General Whipple,
both testified that the most economic way for the MSDGC to meet
the required DO levels
is by 10-12
and instream aeration
(R.
223,
235,
10/20/72).
Dr. Sawyer testified the downstream DO problems
should be eliminated once
the MSDGC begins to remove the NOD by
nitrification
(R.
248,
L0/20/72).
Every pound of NOD
is equal
to 4.57 pounds
of BOD5
(R.
254,
10/20/72).
Dr. Sawyer testified
that the NOD
(ammonia oxygen demand) could be easily reduced
below 2.5 mg/l
(R.
257,
10/20/72).
10—72
-5-
The Board decided
to delete Section 404(b)
instead of
amending
it
as proposed by the MSDGC.
By deleting the requirement,
the intention of the Board
(reading both Section 404(c) and
(f)
together) was
to require the MSDGC
to meet
4 mg/i of BOD5 and
5 mg/i of
SS by December 13,
1977
unless
it can show through
Section 404(f)(ii)
that
such an effluent standard is not required.
In the event
that MSDGC can meet
the burden required in Section 404
(f)(ii)
it
is subject
to an effluent standard of
10 mg/i
of BOD5
and 12 mg/i of
SS.
(See pages 14-16,
of the Board’s Opinion
accompanying R70-8,
71-14 and
71-20, for the reasoning supporting
the creation of
a conditional exemption from the
4 mg/l BOD5
and
5 mg/i SS limit).
The Board. based its decision upon the
modeling evidence presented and by the testimony which showed
that DO standard would be met by
10 mg/l, BOD5
and
12 mg/i of
SS,
in-stream aeration and nitrification.
5.
Commonwealth Edison proposed an amendment
in the alternative
on March
30,
1972,
to loosen the temperature standard on the Des
Plaines River below the
Interstate
55 bridge to its confluence with
the Kankakee River
(hereinafter cited
as
“5 mile stretch”).
The
first alternative would have amended Section
302(1) Restrictive Use
Waters
to
delete
the
phrase
“to
the
Interstate
55 bridge”
and replace
it
with
the
phrase
“to
its
confluence
with
the
Kankakee
River.”
Edison’s second alternative would have amended Section 203(i) (4)
by
adding “Des Piaines River from the Interstate
55 bridge
to its con-
fluence with the Kankakee River.
Temperature in this segment of
the Des Plaines River shall
not exceed 92°Fmore than five percent of
the time,
by more than 5°F.”
In response to
a request from
Hearing Officer Parker
to tighten up its proposal
to reflect the
minimum temperatures possible, Edison withdrew its original amendments
on November 29,
and substituted an amendment to Section 203(i) (4) which
proposed individual monthly temperature limits,
corresponding
to
historical
data,
for the “5 mile stretch”.
This final amendment also
contained a
5
excursion up
to 5°Fmaximum from the monthly limits.
Commonwealth Edison’s Joliet Plant
is
located on the
Des Plaines River 7.3 miles upstream of the
1-55 bridge.
Heated
water from both the old and new portions
of the plant
is discharged
to the river through once-through cooling systems.
After the heated
water
is discharged it mixes with the River water and gradually
cools
as heat dissipates
to the atmosphere.
The river water
temperature, gradually decreases with distance downstream from
the power plant.
Edison presented evidence that
the water does
not cool sufficiently by the time
it reaches the
1-55 bridge to meet
the general use temperature limits during July and August.
The
temperature
at the 1-55 bridge would be
the highest
in the “5 mile
stretch”
(Ex.
#3, Edison Ex.
25, page
5).
10—73
-6-
The final proposed amendment dropped the alternative
to amend
Section 302(i)
and proposed individual monthly temperature limits
for the five mile stretch
from 1-55 bridge to the confluence with
the Kankakee River.
The Board adopted the final Edison amendment
as published with some exceptions.
It set 900F
as
the maximum
temperature standard for the months
of July
and August and reduced
the excursion to four percent
of the previous twelve month period.
The Board also set an automatic termination date
of July
1,
1978
at which
time the general use temperature standard will again apply.
Edison desired
to amend the temperature limit
to avoid the
necessity of providing cooling for its Joiiet Power Plant which
consists of two parts
located on either side of the Des Plaines
River some
7.3 miles upstream from the 1-55 bridge.
(R.
32,
9/8/72)
The Board in a previous decision adopting the revised Water
Quality Standards
(R.
71-14, March
7,
1972) classified the Des
Plaines
River from the confluence with the Canal
at Lockport to
the
1-55 bridge as “restricted” use water
(Section 302(i).
Its
temperature
limits are 93°F (not to be exceeded more than
5
of
the time)
or l00~Fat any time
(Section 205(f).
At
the 1-55
bridge,
a discontinuity in temperature
limit exists
as the river
below the bridge
is classified
as
a “General Use” water with the
more restrictive water temperature
limits contained in Rule
203(i) (4).
The basis for the Board’s decision to use the
1-55 bridge
as
a
boundary for the division of the Des Piaines River into restrictive
and general use
is
that the
location of the bridge corresponds
to
changes in the physical environmental characteristics
of the
area
(R.
71-14
at page
11, March
3,
1972).
Above the bridge,
the
river has been greatly altered by man so that
it
is not
as suited for
recreation,
(Ex.
#3, Edison Ex.
25, page
4)
and water quality
is
such that
at the present time
it
is not capable of supporting
a diverse
aquatic life
(Ex,
#3, Edison Ex,
25, page
4). Edison witnesses expressly
excluded the
S mile stretch below the bridge, from possessing the
characteristic that led the Board to classify the upper river
as
Restrictive Use.
The Board previously decided that
the 1-55 bridge should be
the dividing
line between the upstream Restricted Use designations
and the downstream General Use designation in R71-l4.
The Board
considered over 800 pages
of record and numerous exhibits before
reaching its decision on Edison’s amendment.
Edison’s amendment
is based upon historical water data
it collected during 1966
to
1971
by use of continuous monitors located throughout
the lower Des Plaines
waterway system.
This data was submitted in Edison exhibits 47-62.
However,
no temperature data was recorded at the 1-55 bridge.
Edison
carried out extrapolations using the temperature data
to arrive
at
a probable water temperature at the 1-55 bridge.
The two closest
recorded locations are 3.3 and 4.3 miles from the bridge.
The maximum water temperatures
extrapolated to the 1-55 bridge showed
that
61 occurrences existed above 90°Fduring the moni~o~edI)eriod
(Lx.
#3, Edison Lx.
47, Table
1)
This
data supports the sta~oment
made during the hearings that
the “summer of 1966 shows some of
the warmest water temperature periods recorded in recent decades”
10
—
74
-7-
(Ex.
#3, Edison Ex.
47, page
2).
Thus any standard based upon this
historical data should reflect
a longer period of time than the
five year data period.
Edison’s data clearly demonstrates that the
present Section 203(i)
was violated 19
days during July,
1966.
Edison presented testimony concerning in-plant cooling based
on the maximum reduction in heat discharge required to lower the
observed
water
temperatures
to
that
required
by
Rule
203(i).
Edison
stated
that
operation
at
partial
load
to
achieve
the
required
reduction in thermal discharge
is not possible because
the critical
period of water temperatures coincides with the system wide peaks
that require maximum power production from the Joliet Power Plant.
To meet
the general use standard,
at
the 1-55 bridge, Edison estimated
it would have
to spend
$21.9 million dollars
to construct cooling
towers on the new side
if the critical load
is less
than 75
of
capacity
(Ex.
~3, Edison Ex.
66, page
2).
Dr.
Lauer,
an Edison witness,
testified that Edison’s
discharge of hot
water would have
a limited effect on the
aquatic
life use of the Lower Des Plaines River
(Ex.
#3, Edison
Exs.
17,
37,
and 38).
He stated in his
opinion, the maximum effect
of the temperatures allowed by Edison’s proposed amendment would be
that 785 pounds of
•fish would move out of the
“5 mile stretch” and
into cooler water
for up
to two weeks
of
the year (Edison Lx.
17 and
38,
10).
Edison presented
a cost-benefit analyses which concluded,
based upon
a fish harvest of
100 pounds per acre per year,
that
the fish would have
to be worth $27.91 per pound to warrant
cooling towers
(Ex.
#3,
Edison Lx.
26, Page
4).
Dr. Upton
further testified that based upon
a more conservative fish harvest,
the fish would “in reality” have to be worth $1,395 per pound
(Ex.
#3,
Edison Ex.
26, Page
6).
Substantial opposition
to Edison’s proposal was voiced by the
Agency,
U.S. EPA and by several citizen witnesses.
The U.S. EPA
objected
to any reclassification of
a water
into the Restricted Use
category because of its policy to opposal
to such
a classification.
The U.S.
EPA,
in conjunction with the Illinois Conservation Department
collected fish on May 16,
1972 from five locations within the “five
mile stretch”
(Lx.
#2, Milburn).
The total
catch consisted of 156 fish;
including goldfish, emerald shiners, northern redhorse, white
crapp:ie,
white suckers, gizzard shad,
channel catfish
and rock bass.
Edison’s
consultant also conducted
a fish survey,
Lx.
#3,
Edison Lx.
44,
at one
location in
the
“5 mile stretch” and collected 19
fish;
including
goldfish,
carp and quiliback.
Although these surveys disclosed that
fish species were more diversified in either the Kankakee
or Illinois
Rivers than in the Lower Des Plaines,
the Lower Des Plaines
is
capable of supporting
a desirable aquatic hiota
(R.
109,
9/14/72).
The
presence
of
benthic
organisms
supports
the
conclusion
that
the
fish
are
not
just
passing
through
because
bottom
feeding
fish
have
a
source
of
food
(R.
109,
9/14/72).
10
—
75
-8-
Evidence
of
the
effects
of
temperature
on
various
fish
species
is
documented
in Exhibit
31, and Ex.
#3, Edison Exhibits
38,
41 and
76.
In Exhibit
31 the Duluth National Water Quality Laboratory recommends
maximum weekly average temperatures for the Illinois Rivers.
These
values
are derived from data of lethal temperatures, maximum tempera-
tures, reproduction and growth and should result in “maintenance
of reasonably good populations of most species
to be protected”.
When compared to proposed temperature limits
for the “five mile
stretch”,
the recommendations of the Water Quality Laboratory are
considerably lower,
Edison has presented evidence that diversified
fish, populations exist
in Dresden Lake poo1s which have water
temperatures ranging from 96.8°Fto 86°F.
This presents evidence
that some fish can acclimate to high water temperatures when
confined in an elevated temperature body
of water
(Lx.
#3, Edison
Ex.
41).
But fish
in the Des Plaines River are not confined.
The Board finds
that the
lower “five mile stretch”
is capable
of providing
a source of recreation badly needed in the area
(R.
107, 9/14/72),
and is supporting
a limited desirable aquatic
biota.
The Board reduced Edison’s proposed 92°Ftemperature
limit
during July and August
to 90°Fin order to give protection to this
aquatic
life.
Dr.
Lauer testified that 90°Fis recognized as
a
temperature which will begin to affect
some individual
species
(R.
277,
11/29/72).
A maximum temperature limit of 90°Fis
recognized
as necessary to protect fish
(R.
219,
11/29/72,
Ex.
#3,
Edison Lx.
39, reference
5, page 57).
The Board reduced the allowable excursion to
4
of the previous
year not to exceed SOP after reviewing Lx.
#3, Edison Ex.
47, Table
I,
Support Table
B.
An excursion of
4
would
allow up
to 14.6 days
per year.
The Board finds that this excursion more closely reflects
the historical data.
It should be noted that projected excursion
temperatures
are
in fact “projected” values not measured values.
Significant problems are present when actually measuring temperatures
due
to differing temperatures which exist across the width and depth
of
a body of water.
A projection based upon temperature necessarily
reflects
such
problems.
The
Board
decided
to
add
Section
203(i)
(9),
which
cancels
the
special
temperature
limits
on
July
1,
1978,
as
middle
ground
between
Edison’s
proposal
and
the
need
to
protect
aquatic
life.
Evidence
was
presented
that
temperature
is
not
presently
the
limiting
factor
which
restricts
aquatic
life
in
the
“S
mile
stretch”.
(Lx.
#3, Edison Ex.
7, pages
3-4)
However,
additional evidence was
presented during the hearing that water quality in the Des Plaines
will be improved as
the MSDGC, which
is the major pollution source,
further reduced the pollutants contained in its effluent.
10
—
76
-9-
The MSIJGC is
required by Section 404(f)
to produce an effluent
which shall not exceed 4 mg/i BODE or
5 mg/i SS on or before D~c’E~n1h~-
31,
1977.
They are required by S~cti’ôn406 to limit their ammonia
discharges
to
2.5 mg/l during April
through October,
or
4 mg/l
other times,
after December 31,
1977.
Dr.
Sawyer testified that
DO problems below Lockport will be resolved by ammonia removal
(R.
248,
10/19/72).
The MSDGC has stated that
they are going
to conduct instream-aeration to raise the
1)0 level
to 6.0 mg/l
(See pages
4 and
5
of this Opinion for discussion of instream
aeration plans
of MSDGC).
They are required to treat or remove
combined sewer overflows by December
31, 1977
(Section 602(d)),
and work on the proposed “deep
tunnel”
is underway.
All of
these projects are designated or required to be completed before
July
1978 with the resulting reduction of the pollution load to
the Des Plaines River.
The Board finds that by July 1978, temperature
will be
the limiting factor to the attainment of
a desirable
aquatic biota in the Des Plaines River below the
1-55 bridge.
The July
1,
1978,
termination date for the specific temperature
standard is reasonable in light of the special circumstances pre-
sented in this fact
situation.
It
is
a Board policy to protect and
enhance the quality of the aquatic environment whenever possible.
Large discharges of heated water disturb
the aquatic environment.
The water quality in the Lower Des Plaines River
is presently
depressed by discharges from upstream
sources
such
as
the MSDGC.
Such dischargers are currently under orders,
or required by Board
regulations,
to reduce their discharges by 1977 and are planning
to implement remedial programs to further enhance water quality.
Water quality in the “five-mile stretch”,
should be the
limiting
factor to obtain or support
a desirable aquatic life by 1978.
The
termination of thermal standards,
which allowed discharges that
limit the aquatic biota,
is therefore necessary to protect aquatic
life in the lower “five-mile stretch”.
Edison
is required by
Sec.
203(i)(5)
to conduct
a program to
monitor the affects
of their discharges
of heated water from the
Joliet Plant and present
the results of that program to the Board
at
a hearing to be held between March, 1977 and March 1978.
If,
at that time,
the Board is convinced that Edison’s discharge has
not caused,
or
is not reasonably expected to cause significant
ecological damage to the Des Plaines River;
the Board would not require
Edison to construct cooling facilities.
Edison could then either
ask the Board to amend its regulation to extend to the termination
date
to reflect water quality as would then be present
in the “five-
mile stretch”,
or seek
a variance from the standard.
But
if the Board
is convinced that Edison has caused or
is reasonably expected to
cause
significant ecological damage in the future,
then
the Board
is required
by Section
203(i) (5)
to order
Edison to carry out appropriate
10—77
—10-
measures to correct ecological damage.
Edison, because
it had
relied upon existing Board regulations, would have the variance
procedure available to seek time
to correct
the problem.
The
Board
notes
that
cost
benefit
analyses,
as
used
by
Edison,
would
result
in
the
allowance
of
large
thermal
discharges
on
even
small
trout
streams
since
it
is
likely
that
a
lake
or
artificial
stream
for
Fishing
purposes
could
be
built
for
less
money
than
cooling
facilities.
I,
Christan
L.
Moffett,
Clerk
of
the
filinois
Pollution
Co~trol
Board,
hereby
certify
the
above
0p
nion
was
adopted
on
the
8
~
day
of
November,
1973
by
a
vote
of
—.3
Christan
L.Moflet
~~TIerk
Illinois Pollution ~~tro1
Board
10
—
78
