ILLINOIS POLLUTION CONTROL BOARD
September 8, 1988
SONOCO PRODUCTS COMPANY,
Petitioner,
v.
)
PCB 88—60
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by J.D. Dumelle):
This matter comes before the Board upon an April 4, 1988
petition for variance filed by Sonoco Products Company
(Sonoco). Sonoco requests variance from the effluent standards
for five—day biochemical oxygen demand (BOD5) and total suspended
solids (TSS) set forth at 35 Ill. Adm. Code 304.120. On April
25, 1988 a written objection to the variance was filed with the
Board, thereby necessitating a public hearing. On May 23, 1988
Sonoco filed an amended petition responding to the Board’s
request for additional information. The Illinois Environmental
Protection Agency (Agency) filed its recommendation on July 18,
1988, recommending denial of the variance. On July 28, 1988,
hearing was held in Rockton, Illinois. Members of the public
were present and testified. For the reasons set forth below, the
Board today grants Sonoco a variance from 35 Ill. Adm. Code
304.120 subject to certain conditions.
BACKGROUND
The Sonoco Products Company Rockton Paper Mill (the Mill)
was acquired by Sonoco in 1963. The Mill is approximately 120
years old and is located on the Rock River in Rockton,
Illinois. The Mill produces paperboard from wastepaper and waste
corrugated boxes. In 1987, the Mill recycled approximately
27,000 tons of wastepaper to produce 24,362 tons of specialty
paperboard. The primary raw materials for the papermaking
process are wastepaper, water and steam.
Sonoco’s wastewater treatment system was designed in 1966
and construction was completed in 1967. The system utilizes the
extended aeration variation of the activated sludge process. The
system consists of 23 feet diameter primary clarifiers, followed
by a 430 foot long oxidation ditch (loop design), and then a 28
feet diameter final clarifier. The system was designed for 0.345
million gallons per day (MCD) average flow with a 90 to 95
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treatment efficiency for BOD5 and TSS. However, water u~age and
effluent flow have been reduced to the current 0.081 MCD average
as a result of in—plant process modifications and water/sludge
recycling, i.e., “closing up.” Nutrient addition of anhydrous
ammonia and phosphorus pellets is used as necessary to enhance
the activated sludge process. Treatment sufficiency is
summarized below from the Discharge Monitoring Reports (DMR5)
submitted to the Agency during the most recent twelve month
period.
Average
Loadings
Concentrations
Month
Flow (MCD)
lbs/day
(mg/l)
BDD
‘I~S
(Mo. Avg.)
BOD
¶ISS
(Mo. Avg.)
5/88
0.085
16.0 21.1
22.5
29.4
4/88
0.087
16.9 24.24
23.2
33.3
3/88
0.086
18
23.6
25.2
33.1
2/88
0.085
20
16.7
27.25
22.9
1/88
0.087
21
18.3
29
25.4
12/87
0.084
20
20.5
29
29
11/87
0.087
16.25 17.5
22.5
24.1
10/87
0.085
19.6 20.9
28.4
29.7
9/87
0.086
13
17.4
19
23.8
8/87
0.090
13
19.4
17.5
25.8
7/87
0.077
7.6
15.6
13.8
22
6/87
0.082
9.5 15.3
13.5
23.3
Average
0.085
15.9 19.2
22.6
26.7
(Illinois standard)
30
30
Sonoco states that its operations are in full compliance
with United Stated Environmental Protection Agency (USEPA)
guidelines that require use of the best control technology for
Conventional pollutants in the “Paper from Wastepaper”
subcategory of the pulp, paper and paperboard industry. However,
Sonoco argues that the Illinois effluent standards for BOD5 and
TSS set forth at 35 Ill. Adm. Code 304.120 are “at best
difficult, and often impossible, for the treatment system at the
Rockton Mill to achieve,” and that periodic excursions from the
limits occur. Moreover, Sonoco argues that planned future
production increases will almost certainly result in larger
excursions from the effluent standards.
Timely notice of the variance petition was effectuated by
the Agency. The Agency states that two written objections were
received, one from Ms. Ora Larson, who identified herself as a
trustee of the Village of Rocktorj and a member of the Winnebago
County Groundwater Advisory Committee, and the other from Mr.
Richard Steward on behalf of the Rockton Boat Club. The Board
*
The Agency states that the 1987 average flow was 0.085 MGD.
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notes that only Ms. Larson’s objection was filed with the
Board. The Agency states that both letters expressed concern
about dioxin from paper pulp industries in general and about
maintaining the dissolved oxygen levels in the Rock River. As
Sonoco waived its right to a hearing, Ms. Larson’s timely filed
objection served to trigger the hearing held on July 28, 1988.
The Agency states that Sonoco has neither previously
requested variance relief nor been the subject of any enforcement
action. However, Sonoco has filed a permit appeal (PCB 88—59)
which is presently pending.
HARD S HI P
Sonoco believes that compliance with the effluent standards
for BOD5 and TSS would impose an arbitrary and unreasonable
hardship on the Rockton Mill.
First, Sonoco argues that “it is economically unreasonable
to require more stringent effluent standards beyond the Federal
BCT limitations.” (Amended Petition at 8.) Sonoco states that
the Mill is classified by the USEPA as an existing point source
within the “Paperboard from Wastepaper” subcategory of the pulp,
paper, and paperboard industrial classification, thereby
subjecting the Mill, pursuant to Section 301(b) of the Clean
Water Act to the “best practicable control technology currently
available” (BPT) as defined by USEPA pursuant to Section 304(b)
of the Clean Water Act. Sonoco notes that in 1982, USEPA
received information that mills processing corrugated material
experience higher HOD5 raw waste loads than other types of
wastepaper mills. Thereafter, USEPA divided the paperboard from
wastepaper subcategory into “noncorrugating” and “corrugating”
medium subdivisions. USEPA then promulgated the present BPT
mass—based BOD5 and TSS effluent limitations for the corrugating
medium subcategory, of which the Rockton Mill is one. That
standard for BOD5 is a maximum of 5.7 pounds per 1000 pounds
production (lbs/1000 lbs production) for any one day and a 2.8
lbs/l000 lbs production average daily value for 30 consecutive
days. For TSS, the standard is a maximum of 9.2 lbs/l000 lbs
production for any one day and a 4.6 lbs/l000 lbs. production
average daily value for 30 consecutive days. Sonoco states that
in a attempt to comply with the Clean Water Act’s requirement
that all existing point source dischargers of conventional
pollutants achieve effluent limitations equivalent to those
achieved by dischargers employing best pollutant control
technology (BCT), USEPA conducted a review of the control and
treatment technologies available and applied the “two—part cost—
reasonableness test” pursuant to Section 304(b)(4)(B) of the
Clean Water Act. Sonoco’s amended petition includes USEPA’s
findings with respect to the cost reasonableness of imposing BCT
on this industry: none of the subcategories in the pulp, paper,
and paperboard industry passed both parts of the cost—
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reasonableness test with respect to any of the options
analyzed. As a result, Sonoco states that USEPA has determined
that for all subcategories within the industry the best pollution
control technology available for conventional pollutants that is
reasonable in cost and effluent reduction benefit is that
provided by BPT.
Apparently, Sonoco’s argument is as follows: (1) there
exist three levels of control technology
—
BPT, BCT, and the
Illinois limits, (2) BCT is more stringent that BPT, and the
Illinois limits are more stringent than BCT, (3) USEPA has
determined that the cost of imposing BCT on this industry is
unreasonable, (resulting in the application of BPT on this
industry), (4) the Illinois limits, being more stringent, are
more costly than BCT, (5) therefore, the Illinois limits are also
economically unreasonable. Unfortunately the Agency
recommendation is not enlightening on this issue. Nor was this
issue discussed at hearing. Thus the only source of information
on the issue is the amended petition.
The Board is unable to make a finding of arbitrary or
unreasonable hardship on this basis. First, there is no
information to indicate what the expected cost of compliance is
with the Illinois effluent limitations, i.e., the limitations in
issue. Thus, the Board cannot conclude that compliance with 35
Ill. Adm. Code 304.120 would impose a hardship on this basis
alone. Moreover, the Board notes that Tables 1 and 3 of the
amended petition set forth effluent limitations imposed by BPT
and BCT. These effluent limitations are alleged to be exactly
the same. The Board questions whether this is correct. Finally,
although Table 4 presents BCT limitations invalidated by the
Court in American Paper Institute v. EPA, 660 F 2d 954 (4th Cir.
1981), the record does not indicate what BCT limitations were
achieved in the various options tested for economic
reasonableness. Thus, the Board cannot determine how stringent
the BCT limits were in the alternatives found to be economically
unreasonable as compared to the Illinois limits. In short, the
Board is not persuaded to find arbitrary or unreasonable hardship
based upon this rationale.
Sonoco next argues that the technical feasibility of
attaining the Illinois BODç and TSS effluent standards has not
been demonstrated to be effective for the corrugating subdivision
of the paperboard from wastepaper subcategory. Sonoco states
that substantial evidence demonstrates that biologically treated
recycled board mill effluent cannot consistently meet the
Illinois monthly average effluent limitations. Sonoco points to
a study conducted by the National Council of the Paper Industry
to Air and Stream Improvement (NCASI), which determined that the
long—term average effluent quality must be 18.5 mg BOD5/l to
consistently meet a 30 mg/l monthly average. Further, the NCASI
study demonstrated that only nine of the twenty—nine mills
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affected achieve the 18.5 mg BOD5/l level. A similar analysis of
TSS discharges indicate that three of the other twenty-nine mills
would consistently meet the Illinois TSS limit of 30 mg/i.
On this point, too, the Agency recommendation is not very
enlightening. The Agency states that the unreasonable or
arbitrary hardship imposed by compliance with the load limits
must be viewed in the context of the Rockton Mill. “While the
treatment facilities are able to achieve a BOD removal efficiency
of 99, the Mill itself is old and small with a daily production
of approximately 75 tons of specialty cardboard.” (Agency Rec.
p.6).
The Board is not inclined to find that it is not technically
feasible to comply with the Illinois limits for BOD5 and TSS
where the Rockton Mill has, for the most part, been in
compliance. In fact, at the present level of operation, the
monthly averages (from June 1987 to May 1988) of the BOD and TSS
concentration limits are 22.6 mg/i and 26.7 mg/I respectively,
according to the statistics submitted by the Agency. These
monthly averages demonstrate that it is not technically
infeasible to comply with the requirements of 35 Ill. Adrn. Code
304.120, notwithstanding the fact that the concentration limit
for TSS was violated twice in 1988.
Finally, Sonoco argues that the Rockton facility cannot
comply with the Illinois BOD5 and TSS monthly average
concentration—based effluent standards because the facility
decreased its water consumption pursuant to a water conservation
program. Although the wastewater treatment system was designed
as a 0.345 MGD system, Sonoco notes that effluent flow has been
reduced to an average flow of 0.081 MGD using both in—plant
Process modification and water/sludge recycling from the waste
treatment plant. Sonoco states that this decrease in water
consumption has significant environmental benefits which Sonoco
articulates as follows:
(1) The recycling of in—plant water increases
BOD5 and TSS concentrations in the paper
stock; consequently more of these pollutants
are contained in the manufactured paper and
less are released to the receiving stream, (2)
the reduction of flow increases the retention
time of the wastewater in the treatment
facility, thereby resulting in smaller amounts
of BOD5 and TSS being released to the
receiving stream since the facility has more
time to treat the wastewater, and (3) the
reduction in water usage results in
substantial water conservation, a result
widely recognized as beneficial to the
environment. (Amended Pet. pp. 19—20).
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However, Sonoco states that TSS and BOD5 concentrations are
inversely related to wastewater flow. As wastewater decreases,
the concentration of the pollutants released to the environment
increases. Thus, Sonoco argues that for it to decrease the
concentration of TSS and BOD5 to meet the Illinois requirements,
it would have to increase wastewater flow, thereby losing the
benefits articulated above.
Here, too, the Board is not persuaded to find arbitrary or
unreasonable hardship. The Agency’s recommendation sets forth
the Mill’s discharge statistics as submitted in the Discharge
Monitoring Report (DMRs) during the most recent year, i.e., June
1987 to May 1988. Average flows have ranged from 0.077 MGD in
July of 1987 to 0.090 in August of 1987. All other months had
average flows somewhere in between those amounts. Yet the
standards were violated only twice; which indicates that the
plant can operate in compliance. Although these violations
rendered the plant out of compliance for enforcement purposes,
the Board cannot find arbitrary or unreasonable hardship on this
basis.
Notwithstanding all of the above discussion, Sonoco’s
request must be viewed in context. Sonoco has attempted to
demonstrate arbitrary or unreasonable hardship based on present
levels of operation, and the Board has declined to find such
hardship on the present levels of operation. In other words, the
Board agrees with the Agency that at the present level of
operations a variance is not necessary. However, Sonoco has
stated its desire to increase operations and wishes to do so in
an environmentally conscientious manner. Sonoco has submitted
evidence which indicates that increased operations would result
in exceedances of the BODç and TSS standards. The Agency admits
that “anticipated noncompliance appears to be likely although
infrequent” and “it is foreseeable that any proposed increase in
production might be hindered by the load limitations.” Thus, it
appears that the Agency recognizes the need for a variance at an
increased level of operation, although it does not specifically
so state. Therefore, the Board believes that the record
establishes that Sonoco would suffer arbitrary and unreasonable
hardship if it were required to comply with 35 Ill. Mm. Code
304.120 at an increased level of operations.
ENVIRONMENTAL IMPACT
Sonoco believes that its current discharge causes no adverse
environmental impact. Sonoco quantified the effect of the
Rockton Mill’s BOD5 discharge on the Rock River by calculating
the oxygen demand placed on the river from the HOD5 discharged
from the Mill. The performance data at the Mill demonstrate that
the average daily quantity of BOD5 discharged for thirty
consecutive days in 6,123.6 grams BOD5 contributed to the River
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is 0.00061 mg. BOD5 per liter of Rock River Water. The maximum
daily BOD5 discharge places “an oxygen demand of 0.00163 mg/l on
the Rock River at average flow and a 0.013 mg/l demand on the
river at its lowest flow in fifty—four years.” (Amended Pet. p.
22.) Sonoco argues that these calculations strongly indicate
that the Rockton Mill’s BOD5 discharge has a “de minimus” effect
On the Rock River. Sonoco also calculated the amount of TSS
contributed by the pull to the Rock River. The average daily
amount of TSS discharged for thirty cons2cutive days is 9,525.6
grams, and the maximum daily amount of TSS discharged i~
133,358.4 grams. Based on an average flow of 4,283 cubic feet
per second and the average daily TSS load, Sonoco determined that
the Mill adds 0.00095 mg. of TSS to a liter of Rock River
water. The maximum daily load of TSS to an average Rock River
flow was calculated to add 0.0133 mg. of TSS to a liter of Rock
River water.
In its recommendation, the Agency states that it has no
information to refute the representations made by Sonoco as to
either the condition of the r2ceiving stream or the impact upon
such stream from Sonoco’s discharge. According to the “IllinOib
Water Quality Report 1986—1987” (IPEA/WPC/88—002), dated April,
1988, the entire length of the Rock River
was classified as having partial aquatic life
use support with minor impairment. Phosphorus
was the major cause of less than full support
due to MWWTP (municipal wastewater treatment
plant) discharges and agricultural runoff
(crop land and pasture land). (Agency Rec.
p.4).
Further, the Agency collected certain data at a site located at
the Route 75 bridge at Rockton in 1986. The numerical value
assigned to the Rock River at this location as to the Water
Quality index (WQI) was 39.7. As the WQI value exceeds 20, the
water quality of the Rock River at this point was considered to
be limited to a certain extent. The Agency determined that the
cause of this limitation in terms of use impairment was excess
nutrients, found to be in municipal discharges, nonirrigated
crops production and pasture land use. The Agency states
therefore that there is no indication that Sonoco’s discharge has
any adverse impact on the Rock River. In fact, the Agency states
that the receiving stream has excellent dissolved oxygen content,
due in large part to the physical conditions of the stream
itself, and can therefore easily assimilate the discharge flows.
The Board is persuaded that curren~ ~
from the Mill
cause no significant adverse environmental impact. However, the
Board is uncertain as to the impact of discharges resulting from
an increased level of operation. The record does not specify
what impact will result. Nonetheless, it appears that, because
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of the excellent dissolved oxygen content in the River and
because of the relatively small amount of discharge per day,
discharges resulting from increased operations will have no
significant adverse impact upon the River during the limited
period of this variance.
COMPLIANCE PLAN
Sonoco has identified several possible methods for achieving
compliance with 35 Ill. Adm. Code 304.120. Specifically,
Sonoco’s compliance alternatives fall within three distinct
groups: (1) additional treatment technologies, (2) further
modifications to recycle more process water and increase
efficiency, and (3) additional compliance options. The group (1)
alternatives include (a) chemically assisted clarification, (b)
filters without chemical addition, and (c) filters with chemical
addition. The group (2) alternatives include (a) partial close-
up, and (b) total close—up. The group (3) alternatives include
(a) discharge to a local publicly owned treatment works, (b) land
application of effluent, and (c) a combination of other
identified alternatives. Sonoco states that all of the above
activities will be conducted as concurrently as possible, and
submits the following schedule for compliance.
ACTIVITY
BEGIN DATE
END DATE
1. Group I
—
Pilot Studies
Phase I (fall/winter)
09/01/88
12/01/88
Phase II (spring/surrmer)
04/01/89
07/01/89
2. Group 2
—
Process
Modifications
06/01/88
05/01/89
3. Group 3
—
Additional
Compliance Options
06/01/88
05/01/89
4. Data Analysis & Selection
of Compliance Alternative 07/01/89
11/01/89
5. Equipment Purchases; Permit
A~lication
and
A~roval 11/01/89
04/01/90
92— 104
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6. Construction
04/01/90
12/01/90
7. Operational Testing,
Training & Modification
12/01/90
09/01/91
8.
Compliance Achieved
No later than
09/01/91
Sonoco states that the study period is based upon the amount
of time that will be required to test the compliance options
during the seasonal periods when TSS and BOD5 levels are most
variable. The highest amount of strain, and apparently the most
valid test of treatment technologies, process modification, and
total waste volume, occurs during the change of seasons. Thus,
Sonoco states that the reliability of its studies depends on its
ability to conduct tests through the fall of 1988 and spring of
1989. Sonoco also notes that after it analyzes its test results,
if it concludes that no compliance alternative is technically
feasible and economically reasonable, it will promptly seek site
specific rulemaking relief. If Sonoco concludes that an
alternative is feasible and reasonable at that time, Sonoco will
implement it according to the schedule above. Finally, Sonoco
states that is it willing to submit progress reports to the Board
and Agency during the variance period.
The Agency states that it believes Sonoco has set forth an
adequate exploration of the compliance options and a sufficiently
detailed plan for investigating and implementing further control
measures. The Agency also believes that the schedule set forth
by Sonoco is acceptable.
The Board, too, believes that Sonoco has set forth adequate
compliance alternatives. However, the Board has a concern with
respect to the schedule proposed. In the event that Sonoco
determines that no compliance alternative is technically feasible
and economically reasonable, Sonoco states that it will seek site
specific relief. This appears to be a conditional compliance
plan. The Board will only grant a variance for a period in which
the facility is actively working toward attaining compliance.
The Board is not persuaded to grant a variance for a period
conditioned upon Sonoco determining that a compliance option is
technically feasible and economically reasonable. That is a
determination that the Board is authorized to make. Thus, the
Board will grant the variance to cover the period of testing and
analysis of results, i.e., through the data analysis and
selection of compliance alternative section ending November 1,
1989. Upon reaching its determination on or before November 1,
1989, Sonoco may petition for a variance extension. At that
time, Sonoco may be in a better position to commit to a definite
compliance plan. Finally, so as not to subject Sonoco to
92— 105
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enforcement during the period it seeks the variance extension
after November 1, 1989, the Board will add 120 days such that the
variance will expire on March 1, 1990.
INTERIM STANDARDS
Although the Agency recommends denial, it acknowledges that
“the Board may well grant variance relief,” and it suggests
interim limits for the discharge of BOD5 and TSS during the
period of the variance. The Agency states that Sonoco could
easily comply with interim limits of 32 mg/l BOD5 and 36 mg/i
TSS. The Agency further states that load limits could be set at
30 lbs/day for both parameters.
Sonoco objects to the Agency’s suggested interim limits.
Sonoco points out that the Agency offers no explanation for its
belief that Sonoco can meet these interim limits. Sonoco
believes that rio interim limits should apply during the period of
the variance because the threat of enforcement will hamper
testing flexibility. Sonoco states that its commitment to
conservation and its compliance record show that it will not
abuse its variance privileges by relaxing its environmental
standards. Sonoco believes that the most practical way to
address the Agency’s concerns is to notify the Agency of its
testing plans and allow Agency representative to be present
during testing.
The Board is persuaded by Sonoco that the Agency’s
suggestions lack justification. Further, the Board believes that
Sonoco’s notification of the Agency of its testing plans along
with an invitation to observe will help alleviate the Agency’s
concerns. Therefore, the Board will require Agency
notification. However, the Board is concerned about what impact
unlimited discharges may have upon the Rock River in light of
this summer’s “drought” conditions. The record does not disclose
what impact the drought has had upon the Rock River, and, as a
result, the Board is hesitant to permit unlimited discharges at
all times. The Board believes that interim concentration limits
of 45 mg/i and load limits of 40 lbs/day for both BOD and TSS
during the periods that testing is not conducted provide Sonoco
the flexibility it requires to test its compliance options while
not adversely impacting the Rock River during the summer’s
drought. However, so as to provide Sonoco the flexibility it
requires to adequately test compliance methods, no interim limits
shall apply during actual testing, provided that the Agency is
notified in advance.
CONCLUS ION
In summary, the Board finds that compliance with the
effluent limits for BOD5 and TSS would impose an arbitrary or
unreasonable hardship upon Sonoco if it were to increase its
92--106
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level of operation. The Board finds that the grant of a variance
would result in no significant adverse impact, if any, on the
environment. The Board accepts the compliance plan and schedule
proposed by Sonoco and will incorporate it into the Board’s Order
below. Finally, the Board finds that interim concentration
limits of 45 mg/i and load limits of 40 lbs/day for both BOD5 and
TSS during non—testing periods and no limits during testing
periods provide Sonoco with reasonable flexibility to conduct its
tests while not adversely impacting the Rock River. Sonoco’s
variance request is therefore granted.
This Opinion constitutes the Board’s findings of facts and
conclusions of law in this matter.
ORDER
Sonoco Products Company (Sonoco) is hereby granted a
variance until March 1, 1990 from 35 Ill. Mm. Code 304.120(a)
and from its NPDES Permit conditions relating to limitations for
five—day Biochemical Oxygen Demand (BOO5) and Total Suspended
Solids (TSS), subject to the following conditions:
1. Sonoco shall commence an investigation and testing
program on September 8, 1988 to explore the technical
feasibility and economic reasonableness of the
compliance alternatives described in Sonoco’s Amended
Petition for Variance, filed with the Board May 23,
1988. Such investigation and testing program shall
extend to and conclude on June 30, 1989.
2. During the course of this investigation and testing
program, Sonoco will notify the Illinois Environmental
Protection Agency (Agency) at the address below no later
than fourteen (14) days in advance of any test to be
conducted with respect to Sonoco’s wastewater discharge.
3. From July 1, 1989, to October 31, 1989, Sonoco shall
review the results of the investigation and testing
program to determine which compliance method it will
implement.
4. This variance shall end on March 1, 1990.
5. During the period of the variance, Sonoco’s effluent
shall not exceed 45 mg/l of five day biological oxygen
demand (BOO5) and 45 xng/l of total suspended solids nor
shall Sonoco’s load limits exceed 40 lbs/day, except
that no limitations shall apply during any test
conducted in accordance with Condition No. 2 above.
6. Sonoco shall submit quarterly progress reports to the
Agency at the following address:
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Illinois Environmental Protection Agency
Division of Water Pollution Control
2200 Churchill Road
Springfield, IL 62708
7. Within 45 days of the date of the Board’s Order,
Petitioner shall execute a Certificate of Acceptance and
Agreement which shall be sent to Mark T. Books at the
address indicated above.
This variance shall be void if Petitioner fails to
execute and forward the certificate within the forty—
five day period. The forty—five day period shall be
held in abeyance during any period that this matter is
being appealed. The form of said Certification shall be
as follows:
CERTIFICATION
I, (We), Sonoco Products Company, having read the Order of
the Illinois Pollution Control Board, in PCB 88—60, dated
September 8, 1988, understand and accept the said Order,
realizing that such acceptance renders all terms and conditions
thereto binding and enforceable.
Petitioner
By: Authorized Agent
Title
Date
Section 41 of the Environmental Protection Act, Ill. Rev.
Stat. 1985 ch. 111 1/2 par. 1041, provides for appeal of final
Orders of the Board within 35 days. The Rules of the Supreme
Court of Illinois establish filing requirements.
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certif t at the above 0 iriion and Order was
adopted on the
_____________
day ~
,
1988 by a vote
Dorothy M,~9Gunn, Clerk
Illinois ~‘ollutionControl Board
92—108
