ILLINOIS POLLUTION CONTROL BOARD
November 7, 1996
WHITE CAP, INC.,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
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PCB 96-191
(Variance - Air)
TRACEY L. MIHELIC, GARDNER, CARTON & DOUGLAS, APPEARED ON BEHALF
OF PETITIONER;
CHRISTINA L. ARCHER APPEARED ON BEHALF OF RESPONDENT.
OPINION AND ORDER OF THE BOARD (by J. Theodore Meyer):
This matter comes before the Board on a petition for extension of variance filed March
6, 1996 by White Cap, Inc. (White Cap). The petition requests an extension of variance from
certain testing requirements of the Board’s air emissions regulations. (35 Ill.Adm.Code
218.105(b), 218.205(c)(2), 218.207, 218.211 (1994).) The Board previously granted White
Cap a variance from the capture efficiency test methods in Continental White Cap, Inc. v.
IEPA (April 22, 1993), PCB 92-155, and granted a variance extension in White Cap, Inc. v.
IEPA (August 11, 1994), PCB 94-93, that expired April 22, 1996. On April 4, 1996 the
Board granted White Cap’s motion to incorporate the record from White Cap, Inc. v. IEPA
(August 11, 1994), PCB 94-93. White Cap now seeks an extension of the variance until
November 10, 1998 to allow time for Illinois to revise its State Implementation Plan (SIP),
thereby allowing White Cap to conduct alternative capture efficiency testing on its coating
lines. White Cap also requests the Board to retroactively apply any grant of variance to April
22, 1996.
The Illinois Environmental Protection Agency (Agency) filed its recommendation on
June 3, 1996. The Agency asserts that an arbitrary or unreasonable hardship would continue
to result if the requested relief is denied and therefore recommends grant of variance. (Rec. at
1.)
1
However, the Agency recommends that the variance expire on August 15, 1997 or until
White Cap receives a federally enforceable permit, whichever occurs first. (Id.)
In its petition White Cap requested a hearing in this matter. Hearing was held July 17,
1996 in Chicago, Illinois before Chief Hearing Officer Michael L. Wallace. No members of
1
The petition for variance will be cited as (Pet. at __.); the Agency Recommendation will be
cited as (Rec. at __.) and the hearing transcript will be cited as (Tr. at __.).
2
the public attended. The Agency entered an oral motion to amend its recommendation to
reflect that White Cap had 127 tons per year of volatile organic material (VOM) emissions in
1995, not the reported 236 VOM per year. Hearing Officer Wallace granted the motion. (Tr.
at 5.) As stated at hearing, the only remaining issue between the parties is the term of the
variance extension. (Tr. at 6.) White Cap filed its post hearing brief on September 4, 1996;
the Agency filed its post-hearing response on September 23, 1996; and White Cap filed its
post-hearing reply on September 27, 1996.
2
For the reasons set forth below, the Board finds that to require immediate compliance
with capture efficiency test method regulations would continue to impose an arbitrary or
unreasonable hardship on White Cap. The Board further finds that White Cap has
demonstrated satisfactory progress toward achieving compliance during the term of its prior
variance. The Board finds that unusual circumstances in this matter justify a retroactive
application of the variance. The Board therefore grants White Cap an extension of its prior
variance, subject to certain conditions set forth in the attached order.
The Board’s responsibility in this matter arises from the Illinois Environmental
Protection Act (Act). (415 ILCS 5/1
et seq.
(1994).) The Board is charged therein with the
responsibility of granting variance from Board regulations whenever it is found that immediate
compliance with the regulations would impose an arbitrary or unreasonable hardship upon the
petitioner. (415 ILCS 5/35(a).) A request for extension of variance may be extended from
year to year upon a showing of satisfactory progress during the prior variance. (415 ILCS
5/36(b).) The Agency is required to appear at hearings on variance petitions (415 ILCS
5/4(f)), and is charged, among other things, with the responsibility of investigating each
variance petition and making a recommendation to the Board as to the disposition of the
petition. (415 ILCS 5/37(a).)
BACKGROUND
White Cap employs approximately 500 people at its manufacturing facility located at
1819 North Major Avenue in Chicago, Cook County, Illinois. (Tr. at 49.) White Cap is the
largest U.S. manufacturer of metal closures or caps for baby food, pickles, preserves, juices
and iced teas. (Tr. at 7, 46.) Multiple layers of coatings are applied to sheet metal that results
in VOM emissions and thereby subjects White Cap to the Board’s VOM emissions regulations
set forth at 35 Ill. Adm. Code Part 218. (Tr. at 47, Rec. at 2.) Strips of sheet metal are then
fed into a dye and shells are punched out, creating the caps. (Tr. at 48-49.)
Originally, White Cap operated 12 process lines that consisted of four printing lines
and eight coating lines. Seven catalytic oxidizers controlled VOM emissions from these lines.
(Tr. at 26.) In November 1995, White Cap began a modernization program on its lithographic
operations at its Chicago facility by which all existing lines will be replaced with permanently
totally enclosed lines. (Tr. at 26-27.) In 1995 and 1996, White Cap removed four coating
lines and one print line from operation and replaced them with one double print line and one
2
These filings shall be cited as (PH Br. at __.); (PH Resp. at __.); and, (PH Reply at __.)
respectively.
3
coating line equipped with permanent total enclosures, each capable of 100% capture
efficiency. (Tr. at 27-28.) White Cap also removed four oxidizers and installed an ABB
regenerative thermal oxidizer that will control emissions from the two new lines as well as two
existing lines. (Pet. at 3-4). White Cap is currently in the process of completing construction
of the two new lines and new thermal oxidizer, and expects to replace the rest of its lines by
mid-1998. (Tr. at 28.)
REGULATORY FRAMEWORK
In determining whether any variance is to be granted, the Act requires the Board to
ascertain whether a petitioner has presented adequate proof that immediate compliance with the
Board regulations at issue would impose an arbitrary or unreasonable hardship. (415 ILCS
5/35(a).) Furthermore, the burden is upon petitioner to show that its claimed hardship
outweighs the public interest in attaining compliance with regulations designed to protect the
public. (Willowbrook Motel v. PCB, 135 Ill. App. 3d 343, 481 N.E.2d 1032 (1st Dist.
1977).) Only upon such showing can the claimed hardship rise to the level of arbitrary or
unreasonable hardship. In addition, the Board may grant a request for extension of variance
on a year to year basis, but only upon a showing of substantial progress toward achieving
compliance. (415 ILCS 36(b).)
A variance, by its very nature, is a temporary reprieve from compliance with the
Board’s regulations, and compliance is to be pursued regardless of the hardship which eventual
compliance presents an individual petitioner. (Monsanto Co. v. PCB, 67 Ill.2d 276, 367
N.E.2d 684 (1977).) Accordingly, as a condition to the granting of variance, a variance
petitioner is required to commit to a plan which is reasonably designed to achieve compliance
within the term of the variance, unless certain special circumstances exist.
The instant variance request concerns VOM emissions test methods set forth in Section
218.105 and as the test methods relate to Section 218.108(b) of the Board’s regulations. These
sections read in pertinent part:
Section 218.105
Test Methods and Procedures
(c)
Capture System Efficiency Test Protocols
(2)
Specific Requirements
The capture efficiency of an emission unit shall be measured using one
of the four protocols given below. Any error margin associated with a
test protocol may not be incorporated into the results of a capture
efficiency test. If these techniques are not suitable for a particular
process, then an alternative capture efficiency protocol may be used,
provided that the alternative protocol is approved by the Agency and
approved by the USEPA [United States Environmental Protection
Agency] as a SIP [State Implementation Plan] revision.
4
Section 218.108
Exemptions, Variations, and Alternative Means of Control or
Compliance Determination
Notwithstanding the provisions of any other Sections of this Part:
(b)
Any equivalent alternative control plans, equivalent device, or other
equivalent alternative practice authorized by the Agency where this Part
provides for such alternative or equivalent practice or equivalent variations or
alterations to test methods approved by the Agency shall be effective only when
included in a federally enforceable permit or approved as a SIP revision.
(35 Ill. Adm. Code 218.105(c)(2), 218.108(b).)
COMPLIANCE PLAN
White Cap states that it complied with all terms of the prior variance order.
Specifically, White Cap submitted data on the VOM contents of its coatings within 180 days of
the order’s date; maintained daily records of the coating amounts, VOM content and VOM
weight per volume of coating used on each line; and prepared monthly reports of these
records, submitting them to the Agency quarterly. (Pet. at 4-5.)
White Cap has taken other steps in addition to complying with the Board’s previous
order. White Cap is in the process of replacing its 12 coating lines with new lines which will
be permanently closed and will achieve 100% capture efficiency. White Cap has replaced four
lines in the last year, as well as installed an ABB Preheater Regenerative Thermal Oxidizer,
which controls emissions from two new lines, as well as two existing lines. (Pet. at 3-4, Rec.
at 6-7.) White Cap expects to complete its modernization program by mid-1998. (Tr. at 28.)
White Cap asserts that the requested variance is needed to allow the Agency sufficient
time to submit a SIP revision to the USEPA. White Cap states that the SIP revision is
necessary before it can use alternative test methods to achieve compliance with Board
regulations. White Cap states it is requesting the variance to terminate on November 10, 1998
so that White Cap will not be required to spend money to test coating lines it intends to replace
with lines expected to emit significantly less emissions. (PH Reply at 5.)
ARBITRARY AND UNREASONABLE HARDSHIP
White Cap states that the situation in which the Board previously found an arbitrary or
unreasonable hardship to exist, thereby granting White Cap the prior variance, continues to
exist. White Cap states that, during its prior variance, it was awaiting USEPA approval of its
Federal Implementation Plan (FIP) revision petition before conducting the required tests.
USEPA addressed the dilemma caused by the capture efficiency testing requirements of the
FIP by entering into a consent agreement with White Cap. The consent agreement allows
White Cap to conduct capture efficiency testing on existing lines not permanently enclosed
using alternative test methods, including Data Quality Objective (DQO) and Lower
Competency Level (LCL) methods, as set forth in its guidance memorandum. (PH Brief at 3-
4, Pet. at Exhibit 2.) The consent agreement also provides Illinois time to modify its SIP to
5
incorporate these alternative capture efficiency test methods by requiring White Cap to achieve
compliance by November 10, 1998. White Cap states that to require it to conduct testing
before this date would require White Cap to test lines which will ultimately be replaced. (Tr.
at 131.)
The Agency agrees that the Board previously found an arbitrary or unreasonable
hardship existed in its grant of the original variance in PCB 92-155 and the extension in PCB
94-93. The Agency acknowledged that USEPA has extended the time for White Cap to
conduct capture efficiency testing until November 10, 1998. Since White Cap does not have a
federally enforceable permit allowing the use of alternative CE test methods, the Agency
agrees that requiring immediate compliance with the CE testing requirements of the Board’s
regulations would continue to impose an arbitrary or unreasonable hardship. However, the
Agency states that White Cap may use alternative test methods once it receives a federally
enforceable state operating permit pursuant to the Clean Air Act Permit Program (CAAPP),
and that revision of the Board’s regulations is not required. Therefore, the Agency concludes,
White Cap’s belief that the regulations must be revised in a SIP revision before it can use
alternative test methods is unfounded, and any hardship resulting from that mistaken belief is
self-imposed. (Rec. at 8-9). The Agency recommends that the Board grant White Cap an
extension of its prior variance until August 15, 1997, or until the Agency issues White Cap a
CAAPP permit, whichever is earlier. (Tr. at 133-35.)
ENVIRONMENTAL IMPACT
White Cap states that it is in compliance with the emission standards set forth in the
Board’s regulations and therefore a grant of variance extension regarding the date by which
emissions testing must be completed would not pose an environmental or human health threat.
(Pet. at 4.)
The Agency maintains that the issuance of the requested variance may result in an
environmental impact. The Agency states that White Cap has the potential to emit 1,308 tons
per year (TPY) of VOM and averages 736 TPY before control measures are employed. (Rec.
at 6.) The Agency estimates White Cap’s current average controlled VOM emissions to be
140 TPY. (Tr. at 7.) Based on Section 302 of the Clean Air Act and Section 39.5 of the Act,
the Agency asserts that White Cap is a major source of air pollution. Since VOM contributes
to the formation of ozone, the Agency concludes that a grant of the requested extension of
variance may have an adverse impact on the ozone air quality in the Chicago nonattainment
area.
CONSISTENCY WITH FEDERAL LAW
Pursuant to Section 35 of the Act, the Board may grant variances only if they are
consistent with the provisions of the Clean Air Act. (42 U.S.C. 7401
et seq.
) The parties
state that USEPA has approved the coating rules set forth in Subpart F of Part 218, and a
proposed final rule is expected, which must then go through the SIP process. (Pet. at 6, Rec.
at 7-8.) The Agency notes that the consent agreement into which White Cap and USEPA
entered does not affect White Cap’s responsibility to comply with other local, state or federal
6
laws, but states that the requested variance can be issued consistent with federal law. (Rec. at
8.)
TERM OF VARIANCE
Termination Date
Both parties generally agree that an extension of variance is appropriate in this matter.
The only area of disagreement is the term of variance. White Cap requests that the variance
expire on November 10, 1998, the date given in the USEPA consent agreement. White Cap
states that this time frame would allow it to complete its modernization program before testing
its coating lines, as well as allow Illinois to include the DQO and LCL alternative capture
efficiency test methods into its SIP. White Cap asserts that Section 218.105 requires the
submission of a SIP revision before White Cap can use the alternative test methods in
question. (PH Br. at 8.) White Cap argues that in the USEPA consent agreement, the
USEPA did not include the option of using alternative test methods under a federally
enforceable state operating permit (FESOP) as set forth in Section 218.108, therefore, it is not
a viable compliance option. White Cap also contends that tying its variance term to the
USEPA consent agreement would foster the Board’s prior concern that only one body of law
cover these matters. (PH Brief at 4, PCB 94-93 at 4.)
The Agency counters that compliance with testing requirements can be achieved much
sooner than November 10, 1998, and that a SIP revision is not necessary before White Cap
can utilize either the DQO or LCL alternative test methods. At hearing, Gary Beckstead, an
environmental protection engineer for the Agency, explained that the DQO and LCL
alternative test methods are not specifically found in Illinois regulations, but that Section
218.108(b) allows sources the flexibility to use these alternative methods, provided that the
alternative test methods are part of either a SIP revision or a FESOP. (Tr. at 52-57.) The
Agency contends that White Cap could obtain a FESOP much sooner than Illinois could obtain
a SIP revision and therefore recommends that the variance terminate when the FESOP is
obtained. (Tr. at 134.) Specifically, the Agency testified that White Cap applied for a
CAAPP permit (which is a FESOP permit) on December 7, 1995. The Agency is required to
issue or deny a permit within two years of the application, but the Agency stated that it expects
to issue White Cap’s CAAPP permit sooner than two years, and probably by August 15, 1997.
(Tr. at 59.) Therefore the Agency recommends that the variance terminate on August 15,
1997 or when White Cap receives its CAAPP permit, whichever is earlier. The Agency
asserts that this time frame would permit testing by late 1997 or early 1998, which is more
desirable than waiting until November 1998 (Tr. at 134.)
Inception Date
White Cap also requested that this variance be applied retroactively to April 22, 1996,
the date by which its last variance terminated. (Pet. at 6.) The Agency stated that it has no
objection to a retroactive date for this variance request. (Rec. at 10.)
DISCUSSION
7
The Board finds the hardship that existed during the prior variance continues to exist
for White Cap. Specifically, the Board finds that an arbitrary or unreasonable hardship would
result if White Cap were required to conduct coating line testing pursuant to Section 218.105
before alternative test methods are available, either through a SIP revision or through a
FESOP.
The Board further finds that White Cap has made substantial progress towards
achieving compliance during the term of its prior variance. Namely, White Cap has applied
for a CAAPP permit, receipt of which will allow it to conduct either the DQO or LCL
alternative test method. In addition, White Cap is committed to reducing its total VOM
emissions. It has implemented a modernization program to replace all of its coating lines with
five permanently totally enclosed lines. (Tr. at 26-28.) In 1995, White Cap replaced four
lines and four oxidizers with two permanently totally enclosed lines and an ABB preheater
regenerative thermal oxidizer which controls emissions from the two new lines and two
existing lines. (PH Br. at 9.) White Cap expects to replace four more lines with one
permanently totally enclosed line in winter 1996 and complete its modernization program by
mid-1998. (Tr. at 27-28.) White Cap’s modernization efforts have resulted in 80% reduction
in emissions since 1994. (Tr. at 29.) The Board therefore grants White Cap an extension of
its prior variance.
Termination Date
As stated by both parties at hearing, the only unresolved issue here is the term of the
requested variance. Section 218.108 of the Board’s regulations states that “[n]otwithstanding
the provisions of any other Sections of this Part” any alternative test methods approved by the
Agency “shall be effective only when included in a federally enforceable permit or approved
as a SIP revision.” (35 Ill. Adm. Code 218.108(b).) The Board construes this section to
mean that, regardless of other language found in Part 218, alternative test methods are
acceptable provided they are included in either a FESOP or approved as a SIP revision. By its
terms, Section 218.108 supersedes Section 218.105 regarding alternative test methods. As
such the logical termination date for the requested variance would be the earlier occurrence of
the two options provided in Section 218.108(b). The Board’s order must provide a date
certain by which the variance will terminate and the Board believes this date should be tied to
the option that will further the Act’s underlying policy of achieving compliance as soon as
possible.
White Cap applied for a CAAPP permit, which is a federally enforceable permit, on
December 7, 1995. The Agency found the application complete on January 12, 1996. (Tr. at
21.) The Agency is required to issue the CAAPP permit within two years of application;
therefore, the permit will issue on January 12, 1998 at the latest.
3
In contrast, the SIP revision
process is not driven by a deadline, and in this case the process is likely to take longer than
January 1998 to complete. Specifically, USEPA has published its proposal of rulemaking for
3
The Agency indicated at hearing that it expects to issue a CAAPP permit to White Cap prior
to January 12, 1998, and that it is committed to issuing the permit by August 15, 1997. (Tr.
at 59, PH Reply at 9-10.)
8
the alternative test methods but has not published a final rulemaking. Illinois cannot revise its
SIP until the USEPA finalizes its rulemaking. Although the Agency anticipates a final
rulemaking in December 1996, both parties agree that there is considerable uncertainty as to
when the USEPA will publish a final rulemaking.
The Board finds it more likely that White Cap can achieve compliance under a CAAPP
permit sooner than under a SIP revision. Accordingly, the date certain by which this variance
extension shall expire will be the last day the Agency can issue White Cap its CAAPP permit.
In summary, this variance extension shall terminate when White Cap obtains its CAAPP
permit or 90 days after Illinois revises its SIP to include alternative test methods pursuant to
Section 218.105, whichever is sooner, but no later than January 12, 1998. This termination
date allows White Cap to determine compliance with the Act before the 1998 ozone season as
well as provide White Cap time to continue its modernization program of replacing its coating
lines.
Inception Date
Regarding the inception date for the requested variance, the Board notes its well-
established rule of beginning the term of a variance on the date the Board renders its decision,
absent unusual or extraordinary circumstances. (DMI, Inc. v. IEPA (December 19, 1991),
PCB 90-227, 128 PCB 245-249.) The reasoning behind this general rule is to discourage
untimely filed petitions for variance. (Fedders-USA v. EPA, (April 6, 1989), PCB 86-47, 98
PCB 15, DMI, Inc. v. EPA, (February 23, 1987), PCB 88-1332, 96 PCB 185.) As stated in
DMI, Inc., if a petitioner wishes a variance to commence on a certain date, its petition must be
filed at least 120 days prior to the desired inception date. (Id.) However, where the petition
was otherwise timely filed before the prior variance expired, the Board has moved the starting
date to the latest date by which the Act would have required a Board decision, i.e., the 120-
day decision deadline. (Monsanto Co. v. EPA, (April 27, 1989), PCB 88-206(B), 98 PCB
267.) This type of partially retroactive variance is entirely consistent with the Board’s
underlying principle of rarely granting retroactive variances.
Here, White Cap requests that the term of its variance commence retroactively on April
22, 1996, the date its prior variance expired. (Pet. at 6.) In reading the record, the Board
finds that unusual circumstances warrant a retroactive application of this variance request. To
expect White Cap to have filed its petition for variance extension on or about December 22,
1995, 120 days before April 22, 1996, would have required White Cap to prepare its petition
before knowing whether or not the Agency approved its CAAPP application. In addition, the
Board acknowledges the uncertainty White Cap faced when two agencies issued two different
interpretations of alternative test method requirements. Therefore, the Board will grant a
retroactive inception date of April 22, 1996 in this matter.
CONCLUSION
The Board finds that an arbitrary or unreasonable hardship continues to exist for White
Cap if White Cap were required to achieve immediate compliance with the Board’s VOM
emissions testing requirements. The Board further finds that White Cap has demonstrated
9
substantial progress towards achieving compliance during its prior variance. Therefore, the
Board grants White Cap an extension of its prior variance. The effective inception date of this
variance is April 22, 1996. The variance shall continue until White Cap obtains a federally
enforceable state operating permit pursuant to the Clean Air Act Permit Program, or 90 days
after Illinois revises its State Implementation Plan to include alternative test methods,
whichever is sooner, but in any case, no later than January 12, 1998.
This finding constitutes the Board’s findings of fact and conclusions of law in this
matter.
ORDER
Petitioner, White Cap, Inc. (White Cap), is hereby granted variance from the testing
requirements found in 35 Ill. Adm. Code 218.105(b), 218.205(c), 218.207 and 218.211 for its
facility located at 1819 North Major Avenue in Chicago, Illinois. This grant of variance shall
begin on April 22, 1996, and is subject to the following conditions:
1.
Variance shall terminate on the date upon which the Illinois Environmental
Protection Agency (Agency) issues White Cap a federally enforceable state operating
permit pursuant to the Clean Air Act Permit Program, or 90 days following the date
Illinois revises its State Implementation Plan to include alternative test methods
pursuant to Section 218.105, whichever is sooner, but no later than January 12, 1998.
2.
White Cap shall test its applicable lines for Capture Efficiency (CE) pursuant to
either the seven proposed test methods (Methods 204A through G) or the alternative CE
test methods (Data Quality Objective or Lower Competency Level), as specified in the
United States Environmental Protection Agency CE Guidance Memorandum dated
February 7, 1995.
3.
White Cap shall keep daily records of the following items starting on the date of
this order, including:
(a)
the amount of each coating used in each coating line;
(b)
the VOM content of each coating applied (lb VOM/gal of solids);
(c)
the weight of VOM per volume of coating solids applied daily on each
coating line (VOMs, pursuant to 35 Ill.Adm.Code 218.104(e)(2)).
3.
White Cap shall prepare a monthly report for Agency inspection on the daily
records required above. The report must also demonstrate White Cap’s compliance
with 35 Ill.Adm.Code 218.207(b)(2). White Cap shall submit one copy of the monthly
compliance demonstrations on a quarterly basis to each of the following Agency
officers:
Illinois Environmental Protection Agency
Bureau of Air
2200 Churchill Road, P.O. Box 19276
Springfield, Illinois 62794-9276
10
Attn: Compliance Section Manager
Illinois Environmental Protection Agency
Division of Air Pollution Control
Intercontinental Center
1701 First Avenue
Maywood, Illinois 60153
Attn: Mel Villalobos
IT IS SO ORDERED.
Board Member M. McFawn concurred.
If White Cap chooses to accept this variance subject to the above order, within forty-
five days of the grant of the variance, White Cap must execute and forward the attached
certificate of acceptance and agreement to:
Stephen C. Ewart
Division of Legal Counsel
Illinois Environmental Protection Agency
P.O. Box 19276
2200 Churchill Road
Springfield, Illinois 62794-9276
Once executed and received, that certificate of acceptance and agreement shall bind
White Cap to all terms and conditions of the granted variance. The 45-day period shall be
held in abeyance during any period that this matter is appealed. Failure to execute and
forward the certificate within 45 days renders this variance void. The form of the certificate is
as follows:
11
CERTIFICATION
I (We), ______________________________________________, hereby accept and
agree to be bound by all the terms of the Order of the Pollution Control Board in PCB
96-191, November 7, 1996.
_________________________________
Petitioner
_________________________________
Authorized Agent
_________________________________
Title
_________________________________
Date
Section 41 of the Environmental Protection Act (415 ILCS 5/41 (1994)) provides for
the appeal of final Board orders within 35 days of the date of service of this order. The Rules
of the Supreme Court of Illinois establish filing requirements. (See also 35 Ill.Adm.Code
101.246 "Motions for Reconsideration.")
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control Board, hereby certify that
the above opinion and order was adopted on the _____ day of ___________, 1996, by a vote
of ______________.
___________________________________
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board