ILLINOIS POLLUTION CONTROL BOARD
    January
    6,
    1972
    ENVIRONMENTAL
    PROTECTION AGENCY
    v,
    )
    PCB 71—259
    CITY OF MONMOTJTH
    Mr. Prescott E. Bloom,
    Special Assistant Attorney General for
    the Environmental Protection Agency
    Mr. Bufford W.
    Bottle, Jr., City Attorney,
    for the City of Monmouth
    OPINION OF
    THE
    BOARD
    (by Mr. Dumelle)
    This enforcement action was filed on September
    3,
    1971.
    In
    its complaint the Environmental Protection Agency
    (EPA) alleged that
    the City of Monmouth (Monmouth)
    owned and operated a sewage lagoon
    which accepted wastes discharged by Wilson Packing Company
    (Wilson)
    and that the sewage treatment facilities were operated in such a
    manner so
    as to create obnoxious odors causing air pollution in
    violation of Section 9(a)
    of the Environmental Protection Act.
    Further
    the complaint alleged a continuous violation.
    Although no commence-
    ment of the duration was averred it can be fairly said that the
    allegation relates from the first alleged date through the date of
    the hearing.
    By order of the Hearing Officer on November
    2, 1971 the complainant
    was granted leave to amend its complaint as to the particular days
    on which it was averred that the respondent caused or allowed the
    emission of
    odors so as
    to cause air pollution.
    The 2~gencyenumerated
    May 11, 1967,
    September 15, September 17, September
    23, September 29,
    1970, and June
    17,
    1971 as specific dates of violation.
    The City of Monmouth filed an answer to the complaint on
    November
    2,
    1971 in which it denied the substantive allegations of
    violations of the Environmental Protection Act.
    At the same time
    Monmouth filed a motion to dismiss alleging
    (1) that the Environmental
    Protection Act was unconstitutional because it was violative of
    the due process sections of the Illinois and U.S. Constitutions,
    (2)
    that the Act was unconstitutional because it provided for the
    imposition of fines and other punishments without allowing for
    3
    345

    a trial by
    jury,
    (3)
    that the amended complaint specified
    a
    violation of
    the Act on
    a date before the Act was effective,
    (4)
    that the complaint was defective because the facts were predicated
    on “information and belief” without such
    a premise for an action
    being provided for by the Environmental Protection Act,
    and
    (5)
    that the complaint and Environmental Protection Act purported to
    subject
    a local public entity to
    a fine or loss of property in
    violation of
    the Local Governmental and Gov~rnmentalEmployees
    Tort Immunity Act
    (Ill.
    Rev.
    Stat.
    ch,
    85, ~ 1-101 to 10—101).
    Nonmouth’s contention of invalidity as to the allegation of
    violation for May
    11,
    1967 is well
    taken.
    There can be
    no violation
    of the Environmental Protection Act before July
    1,
    1970, the allega-
    tion pertaining
    to May
    11, 1967 is therefore stricken.
    Of course,
    there
    could
    be
    a
    violation
    of
    pre—existing
    regulations
    or
    the
    former
    Air
    Pollution
    Control
    Act
    but
    that
    is
    not
    what
    was
    alleged
    in this
    case.
    Except
    for
    allowing
    that
    portion
    of
    Monmouth~s
    motion
    as
    a
    motion
    to
    strike,
    our
    ruling
    on
    the
    Cityrs
    move
    to
    dismiss
    is
    to
    deny
    the
    motion.
    The
    first
    two
    contentions
    in
    the
    Motion
    to
    dismiss
    are
    untenable
    and
    must
    fail
    on
    the
    basis
    discussed
    at
    length
    in
    the
    Board’s
    Opinion
    in
    EPA
    v.
    Granite
    City
    Steel,
    PCB
    70-34,
    (March
    17,
    1971).
    Nothing
    in
    the
    Environmental
    Protection
    Act
    precludes considera-
    tion of
    a
    complaint
    averred
    on
    “information
    and
    belief”.
    No
    valid
    objection under the environmental statute can be made to allegations
    of fact on information and belief.
    The Illinois Local Governmental
    and Governmental Employees
    Tort Immunity Act has
    no application to the instant facts.
    The opera-
    tive section of that act states that
    “Nothing in this Act affects
    the right to obtain relief other than damages against a
    local public
    entity...”
    (Ill.
    Rev.
    Stat.
    ch.
    85,
    ~ 2—101, emphasis added).
    A hearing was held in Monmouth on November
    22 ar~d23,
    1971.
    At that time counsel for the EPA and Monmouth entered into
    a five
    page stipulation which provided a comprehensive background
    to. the
    situation.
    In substance
    the stipulation related that the City of
    Monmouth,
    the County
    seat of Warren County,
    has
    a population of
    11,500.
    It is surrounded by farming areas, where
    cattle, hogs and
    corn are raised in large quantities.
    In 1966 Agar Packing Company
    built a slaughter house and
    a
    large packing plant within the city
    limits
    of
    Monmouth,
    toward the north end of
    the city,
    and developed
    a successful business employing some 300 people.
    Agar was
    succeeded by Wilson—Sinclair, who bought the business
    in 1968.
    Wilson
    is presently the largest employer in Monmouth with approximately
    370 employees.
    About 1965,
    the packing company
    (Agar and later Wilson)
    entered into
    a written contract with Monmouth to have its sewage
    34~

    disposed of by the city in a sewage treatment plant constructed and
    maintained by
    the city.
    Starting in 1967 odors developed,
    and
    complaints began to be received by
    the City and
    the State Sanitary
    Water Board.
    At
    the hearing Mr. Kenneth Merideth, an Environmental Control
    Engineer
    for the EPA testified that he inspected the lagoon area on
    September
    23,
    1971 and detected the odor typical of hydrogen sulfide
    in the area
    (R.24,
    Comp.
    Ex.
    1).
    Miss Gail Pepper,
    a sanitarian for the EPA testified
    to visiting
    the lagoon area on September
    16,
    1970 and observing paint discolora-
    tion apparently caused by hydrogen sulfide fumigation
    (R,39-44).
    She noted that what had been applied
    as white paint had turned in
    part to yellow—brown
    (R.44).
    She stated further, however,
    that she
    did not sense any hydrogen sulfide odor while speaking to several
    persons at their residences, who had complained to the EPA
    (R.4l-42).
    Mr. Dwight Brass, another engineer
    for the EPA, visited the
    Monmouth lagoon site on June
    17,
    1971 and detected a very strong
    odor characteristic of hydrogen sulfide (R.5l-59).
    The odor was
    also detected by Mr. Brass at the Dorman residence about
    a half
    mile north of
    the lagoon
    (R.59).
    At another residence at which
    Mr. Brass interviewed a complaining party, the odor was
    not detected
    on that same
    day.
    The latter house was approximately an eighth of
    a mile from the lagoon
    (R,60).
    Mr. Willard Sloss,
    a building contractor who
    lives within
    a
    quarter of
    a mile of the lagoon, stated that the presence of odor
    was
    a fairly constant, continuing presence,
    “most any day or night
    or month or week”
    (R.66).
    Mr.
    Sloss could not pin the specific pre-
    sence of odor to any of
    the particular dates stated in the complaint
    (R.69-70).
    He did state that the odor at his residence on November
    11,
    1971 was an obnoxious one which awakened him
    (R.70).
    Mr. Gerald Fischer,
    a farmer who
    is also
    in the livestock
    commission buisness and maintains a place of business about 960
    feet from
    the lagoon site
    (R.75-76), testified as to the lagoons
    emissions’
    discoloring effect on white paint
    (R.79—82).
    He stated
    that he painted
    a portion of a building
    two years ago with
    a
    sulfide resistant formulation and that the paint discolored
    to
    a
    bluish-purple
    (R.79—Bl).
    He also testified to the general presence
    of the odor of rotten eggs
    (R.8l-82).
    He stated further that he
    felt that the odor adversely affected his asthmatic condition
    (R.82—
    83)
    .
    When the odor comes
    he has
    to leave the area
    (R.83)
    .
    Mr.
    Fischer stated that the odor was present at his place of business
    on the morning of the first day of the hearing
    (R.85).
    3
    347

    Mr. William Kinkaid,
    a
    former employee of Mr. Fischer who
    lived
    on
    the
    Fischer premises for more
    than 15 years, about 1000
    feet
    from
    the
    lagoon,
    described
    the
    odor
    as
    worse
    than
    rotten
    eggs
    (R.87).
    He
    stated
    that
    the
    odor
    would
    make
    you
    sick
    to
    your
    stomach
    and
    caused
    a
    headache
    (R.87-90).
    He
    also
    testified
    that
    the
    odor
    made
    him
    retch
    (R.91),
    Mr.
    Kincaid
    further
    told
    of
    white
    paint
    turning
    to
    a
    yellowish-brown color
    (R.88).
    He
    stated
    that
    he
    left
    his
    enployment at the Fischer place because of the odor
    (R89—90).
    Mr. Fred
    King,
    a part time employee of the Fischer sale barn,
    lives about
    250 feet away from the lagoon
    (R.95),
    He testified of
    experiencing
    a suffocating odor which
    he found to be obnoxious
    (R.
    96).
    He also testified as
    to observing the discoloration of white
    paint since
    the lagoon has been operating
    (R.97).
    He noticed that
    the woodwork inside his house around the windows was stained as well
    as the exterior painted surfaces.
    He said the odor was worst when
    there was no wind at all
    (R.99)
    Mr. Merle Day
    lives about 250—300
    feet from
    the northwest
    corner of
    the lagoon
    (R.lOl).
    He described the odor as “rotten
    eggs that have probably been rotten
    a couple of
    times over”
    (R.l02).
    His wife and children have gotten sick
    to their stomachs from the
    odor
    (R.l03-l04).
    He described the odor
    as
    a pervasive, generally
    present odor
    (R.104)
    .
    Through Mr. King several photographs
    of
    his house taken on August
    19,
    1971 were introduced.
    They showed
    severe discoloring of exterior white paint of the type expected
    from hydrogen sulfide fumigation
    (R.l09—lll,
    Comp.
    Ex.
    3—9).
    Mrs. Helen McMahon lives one-half mile north of the lagoon
    (R.
    113).
    She described the odor
    as generally present and obnoxious.
    She told of seeing her white-painted house turn brownish-black
    overnight in August, 1971
    (R.
    118,122—124).
    She also stated that
    wallpaper
    and books inside
    the house turned
    a brownish color
    (R.120),
    Mr. Harold Dorman lives approximately
    a half—mile north of
    the lagoon
    (R.l25).
    He stated that he has kept
    some record of the
    incidence of odor at his residence since October of 1970
    (R.l26).
    Between October
    30
    and November
    28, 1970 he detected odor
    19 of
    30
    days.
    Between December
    22,
    1970 and January
    24,
    1971 he smelled
    the characteristic odor on 27 of 34 days.
    Between June
    30 and
    August 1,
    1971 he noted the odor on 25 of 32 days.
    Between August 29
    and November
    17,
    1971 he recorded the incidence of odor on 53 of
    81 days
    (R.l26-l28).
    He described the odor by saying it stinks and
    is
    “as rotten a smell as
    I have ever smelled”
    (R.l28).
    Other witnesses,
    including some called by the City, testified
    to detecting the rotten egg odor up to a mile from the lagoon
    site
    (R.231,
    236,
    247,
    252).
    3
    348

    At the end of the complainant~scase counsel
    for Monmouth made
    a
    motion
    to
    dismiss
    for
    failure
    to
    prove
    their
    case
    (R.l40).
    We
    deny
    the motion.
    Mr. John McLaughlin,
    a Consulting Civil Engineer, who
    is
    Monmouth’s present consultant
    as well as the engineer who designed
    the lagoon treatment system
    (R.l4l-l43)
    outlined the history
    of the facility.
    The lagoon system was designed
    to treat the wastes
    from a hog kill and packing plant operation of
    3,000 hogs per day
    with
    a HOD load of 8100 pounds per day
    (R.l44).
    The treatment facility consists of
    a
    three
    cell waste stabili-
    zation system.
    The first cell
    is an anaerobic digestion pond
    while
    the second and third cells
    are aerobic
    (R.l44).
    The system is
    a
    common
    and
    economical
    one
    in
    the
    meat
    packing
    industry
    (R.l45).
    The
    cost
    of
    the
    original
    construction of the lagoons was $105,000
    (R.l45).
    The
    first
    cell
    is
    275
    feet
    square
    and
    15
    feet
    deep.
    The
    second
    and
    third
    cells
    are
    about
    48
    acres
    each
    and
    5
    feet
    deep.
    The
    total
    volume
    of
    water
    in
    the
    three
    cells
    is
    117
    million
    gallons
    (R.l46).
    After
    the
    third
    cell
    the
    effluent
    is
    discharged
    to
    Markham
    Creek
    (R.147),
    Monmouth
    received
    a
    letter
    from
    the
    Sanitary
    Water
    Board
    in
    August,
    1966,
    shortly
    after
    the
    system
    began
    operation,
    in
    which
    the
    City
    was
    advised
    that
    an
    objectionable
    odor
    condition required
    attention
    and
    correction
    (R.l47,
    148,
    Resp.
    Ex.
    1).
    Monmouth
    subse-
    quently
    attempted
    to
    create
    a
    cover
    of
    paunch
    manure
    over
    the
    first
    cell
    (R.l48—l49).
    Mr.
    McLaughlin
    suggested
    that
    the
    hydrogen sulfide generated in
    the anaerobic digestion could be
    rendered
    harmless
    by
    (l)
    containing
    and capturing the gas and burning it or
    (2) oxidizing the H7S by
    exposing it to an aerobic environment
    (R.l50).
    Several met1~odsof
    eliminating the H~Sodor problem have been tried in the past.
    Re-
    circulation from the third to the first cell was tried as
    a way of
    creating
    an
    aerobic
    environment
    at
    the
    top
    of
    the
    first
    cell
    to
    oxidize
    the
    H2S
    (R.l50—15l).
    Next
    aeration
    of
    the
    top
    of
    the
    lagoon was
    tried
    (R.l5l).
    The
    Sanitary
    Water
    Board
    issued
    a
    permit
    for
    each
    of
    Monmouth’s
    attempts
    to
    deal
    with
    the
    odor
    problem
    (R.151).
    The first permission was granted in May,
    1968
    (R.
    152,
    Resp.
    Ex.
    15).
    Early in 1967 it was learned that hog’s blood had been discharged
    to the lagoon system for more than a year.
    It was estimated that
    more
    than 500,000 gallons of blood had been diverted
    to the treatment
    facilities
    (R.
    158—159,
    Resp.
    Ex.
    3)
    .
    The added BOD load, with
    blood having a BOD content in the range of 20,000
    -
    40,000 mg/i
    undoubtedly contributed
    to the poor and inadequate performance of
    the lagoon system
    (R.
    159-161).
    Sometime after discovery, before
    Nay,
    1967,
    the blood discharge was terminated.
    The performance of
    the lagoon improved significantly thereafter
    (R.
    160—163,
    Resp.
    Ex.
    4,
    5,
    6).
    ~3—348

    A further letter from the Sanitary Water Board
    to Monmouth
    in March,
    1968 reiterated
    the existence of the H2S odor in the area
    without recommending any solution to the problem
    (R.
    164—166)
    .
    In
    January,
    1969
    the Sanitary Water Board advised Monmouth of the
    persistence of the odor problem and recommended again
    that
    a cover
    be established on the lagoon
    (H. 166-168).
    Through the years
    the
    City has worked cooperatively with the Sanitary Water Board
    in
    attempting to abate the odor problem
    (R.
    169).
    In the last three or four months Monmouth has
    introduced
    enzymes
    into
    the wastes both at the packing plant
    and in the first
    lagoon cell
    in an added effort to break
    down the biological wastes
    without generating hydrogen sulfide
    CR.
    172,
    249)
    .
    The enzyme treat-
    ment has been recently augmented with the installation
    and opera-
    tion of four aerators
    to create
    a faculative lagoon
    in which the
    bottom would be anaerobic and the upper layer would be aerobic
    (H.
    172—173)
    .
    The enzymes were stopped being put into
    the system
    on the first day of the hearing
    (November
    22,
    1971) when the contract
    with Mapco ran out
    (R,
    251).
    The enzyme addition was only partly
    successful,
    it did not adequately relieve
    the problem
    CR.
    251)
    Odors still persist
    (R.
    252).
    What remains to be tried
    is
    to physically cover the first
    cell
    and incinerate
    the H2S gas collected under the cover
    (H.
    175)
    It
    is estimated that
    a
    cover will cost about $55,000
    CR.
    175—176)
    Agents of Monmouth have recently inspected a cover installation
    in either Greenfield, Michigan or Greenville, Mississippi.
    The
    Mayor of Monmouth testified
    to having observed
    a nylon reinforced
    polyurethane material used to cover
    a lagoon
    in Greenville, Missi-
    ssippi
    (R.
    255—258)
    .
    The Mayor stated that the city is committed
    to the use of the covering material
    for the first cell
    CR.
    258)
    Starting
    the day after
    the hearing the Mayor stated that certain
    bacteria would be introduced into
    the lagoon to work on the hydrogen
    sulfide
    CR.
    260)
    .
    This is part of the City’s plan to correct the
    situation.
    The Mayor stated that the engineering for
    the cover and
    incineration equipment is underway
    (R.
    263) but no plans or other
    documents were introduced to delineate the specific plans.
    No
    specific timetable for accomplishment of the incineration was pro-
    posed.
    The Mayor stated he could give no more precise schedule
    beyond saying that
    the planning may take
    60
    to 90 days
    CR.
    263).
    In controlling the H2S odor problem in this case by incineration
    Monmouth must consider
    if they are creating an objectional SO2
    problem.
    From the state of the record we cannot ascertain
    the
    precise volume of H2S generated per day.
    In any event,
    it seems
    safe to assume that tie quantity will not be so large as
    to preclude
    the consideration of incineration
    to control the odor nuisance.
    Beyond that, on
    the instant facts it would appear to be an attractive
    trade-off
    if Monmouth can substitute an SO2 problem for the present
    FI2S problem.
    We should add for the benefit of future parties before
    t~eBoard
    that apart from the testimony of the strength and character
    of the odor as perceived by the senses it would not only be helpful
    but necessary in some cases to have an estimate of
    the quantity of
    the pollbtant which is generated on the record.
    3
    350

    The record contains much evidence of hydrogen sulfide
    fumigation continuing on
    a somewhat regular basis
    in recent years.
    It
    is
    clear
    that
    the
    odors
    from
    the
    treatment
    facilities
    constitutç
    air pollution
    as contemplated by
    the Environmental Protection Act.
    An air pollution nuisance exists in the area around the
    lagoon,
    which
    is of varying intensity and geographical extent,
    due
    to the
    obnoxious odors emanating from the lagoon.
    That the lagoon emissions
    unreasonably interfere with
    the enjoyment of life
    is
    a proposition
    Tell founded
    on this record
    The City of Monmouth has not done everything that it could do
    to improve
    the operation of the facilities and eliminate the
    odor nuisance.
    The history of this problem has not been charac-
    terized by inaction but the City and the packing company have simply
    not done enough.
    The odors have persisted
    through
    the
    years,
    from
    the
    commencement
    of
    the
    lagoon’s
    operation in 1966.
    Five years
    is
    simply too
    long
    a time to not abate the environmental insult of
    prevalent and persistent
    H2S odors.
    Even now, where is
    the City’s
    positive step by step program for abatement?
    The City has said that
    they will install
    a cover and incinerator, but when?
    Important
    aspects of
    the problem’s solution are undeveloped on the record.
    Apart from the instant case we know of another severe H2S problem
    in Illinois which~is well on its way to being
    solved.
    In
    a
    variance
    request
    by
    Texaco,
    Inc.
    in
    Salem,
    Illinois
    we
    considered
    a situation in which 3,000 pounds per day of H2S was
    being emitted
    into the atmosphere.
    Control down to 6.5 pounds per
    day was effected by
    a system which oxidized the H2S
    to elemental
    sulfur by exposure to dissolved air in the presence of
    a nickel
    chloride catalyst
    (I’CB 71—235, October
    14,
    1971;
    See also PCB
    70—29,
    February
    17,
    1971).
    The lagoon treatment facility is for the packing plant’s
    wastes only,
    the city’s residents are served by
    a separate pre-
    existing sewage treatment plant
    in use since
    1932
    (R.267)
    .
    The
    City in this case
    is
    in effect holding the bag for the packing
    industry;
    it
    is
    a surrogate respondent.
    Nonetheless it is the City
    that we must
    focus our attention on in this case.
    They in turn
    will
    have
    to deal with the industry.
    They may want to consider an
    1
    Air
    po1lution~J~
    defined
    in
    Section
    3(b)
    of the Act:
    (b)
    “Air Pollution”
    is the presence
    in the atmosphere of one or
    more contaminants
    in sufficient quantities and of such
    characteristics and duration as
    to be injurious to human,
    plant or animal life,
    to health,
    or to property or to
    unreasonably interfere with the enjoyment of
    life or property;
    A contaminant
    is defined
    in Section 3(d);
    (d)
    “Contaminant”
    is any solid,
    liquid,
    or gaseous matter, any
    odor,
    or any form of energy, from whatever source.
    3S~

    industrial waste ordinance
    as
    a method of generating the funds re-
    quired to deal with
    the problem.
    We will order Monmouth to act within six months
    to abate
    the
    odor nuisance which has been continuing for five years.
    Neither
    the presence of the odor nor the means of controlling it are new
    things.
    We
    are not unmindful of the state of this record which
    is
    deficient on
    the questions of construction schedule and cost of con-
    trol facilities.
    We are therefore requiring Monmouth to submit
    detail affidavits by February 15,
    1971 estimating
    the cost of
    the
    needed correctives and delineating a firm schedule for their installa-
    tion.
    Further we will enter
    a cease and desist order relating to
    the detectable emissions of hydrogen sulfide which shall take effect
    six months from date.
    That is to say,
    if the city has not solved
    the problem six months from date
    (and have not applied for and
    received relief from such order from this Board)
    they will have
    to shut down the hydrogen sulfide generating operation i.e.
    the
    treatment lagoon.
    We will not allow
    the further operation of
    a
    treatment facility which is
    so demonstrably
    inadequate
    as
    to
    regularly and seriously affect the daily
    lives of the close—in
    residents.
    The remaining issue
    is the question of
    a money penalty.
    (See
    EPA v
    City of Marion,
    PCB 71-25, October
    28,
    1971;
    EPA
    v. City of
    East St.
    Louis,
    PCB
    71—26, July
    8,
    1971).
    The Agency has asked
    for the maximum penalty of $10,000 plus $1,000 per day
    for
    a
    continuing violation.
    We are not prepared to go
    so far at this
    time.
    We will impose
    a penalty in the total amount of
    $2,000
    and trust that
    this sanction together with
    the prospective cease
    and desist order and other parts of this order will serve
    to com-
    pletely abate
    the existing nuisance.
    This Opinion constitutes the Board’s findings of
    fact and
    conclusions of law.
    3—352

    ORDER
    The
    Board
    having
    considered
    the complaint,
    answer,
    transcript
    and
    exhibits
    in
    this
    proceeding hereby enters the fo1lowinc~order:
    1.
    The
    City
    of
    Moninouth
    shall
    cease
    and
    desist
    from
    causino
    air
    pollution
    due
    to
    the
    uncontrolled
    emission of hydrogen
    sulfide odors within six months from date.
    2.
    The City of Monmouth shall by February
    15,
    1972 submit to
    the EPA complete plans,
    specifications
    and schedule detailing
    the
    program
    of
    covering
    the
    lagoon
    and
    incinerating
    the
    hydro-
    gen
    sulfide.
    With
    the
    exception
    of
    the
    specifications
    and
    any
    engineering
    blueprints,
    the
    Board
    shall
    receive
    6
    copies
    of
    all
    of
    the
    foregoing materials
    by
    February
    15.
    3.
    The
    City
    of
    Monmouth
    shall
    submit monthly reports, commencing
    on
    March
    15
    and
    continuing
    for
    3
    months
    thereafter,
    to
    the
    Board
    and
    the
    EPA
    detailing progress
    to date on their program
    to
    abate
    the
    odor
    nuisance.
    4.
    The
    City
    of
    Monmouth
    shall
    pay
    to
    the
    State
    of
    Illinois,
    on
    or
    before
    February
    15,
    1972,
    the
    sum
    of
    Two
    Thousand
    Dollars
    ($2,000.00)
    as
    a
    penalty
    for
    violations
    of
    the Environmental
    Protection
    Act
    found
    herein.
    I,
    Christan
    L.
    Moffett,
    Clerk
    of
    the
    Illinois
    Pollution
    Control
    Board,
    hereby
    certify
    that
    the
    Board
    adopted
    the
    above
    Opinion
    and
    Order
    thas
    ~
    day
    of
    January,
    1972
    by
    a
    vote
    of
    ~y—
    C
    C
    ~77
    ~
    Christan
    L.
    Moffet~~lerk
    Illinois Pollution Control Board
    3
    353

    .
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