ILLINOIS POLLUTION CONTROL BOARD

July 20,

1995

IN THE MATTER OF:

)

JOINT PETITION OF SOLAR

)

 AS 94-2

CORPORATION AND THE ILLINOIS

)

 (Adjusted Standard

 Air)

ENVIRONMENTAL PROTECTION

)

AGENCY FOR ADJUSTED

)

STANDARDS FROM 35 ILL. ADM.

 CODE.

)

218,

 SUBPART PP.

)

MARK

LATHAN

OF GARDNER, CARTON & DOUGLAS APPEARED ON BEHALF OF

PETITIONER, SOLAR CORPORATION;

SHEILA G. KOLBE APPEARED ON BEHALF OF PETITIONER, ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY.

OPINION

AND

ORDER OF THE BOARD

 (by N. McFawn):

This matter is before the Board on a petition for adjusted

standard filed by Solar Corporation

 (Solar)

 on February 14,

 1994,

as amended on January

3,

 1995,

 and joined by the Illinois

Environmental Protection Agency (Agency)

 on February 28,

 1995.

The petitioners request that Solar be given an adjusted standard

front the air emission control requirements of

 35 Ill. Adm. Code

Part 218 Subpart PP for its manufacturing facility located in

Libertyville, Lake County,

 Illinois.

The Board’s responsibility in this matter arises from the

 Environmental Protection Act

 (Act)

 (415 ILCS 5/1 et seq.).

The

Board

 is charged therein to “determine, define and implement the

environmental control standards applicable in the State of

Illinois”

 (Section 5(b)

 of the Act) and to “grant.. .an adjusted

standard for persons who can justify such an adjustment”

 (Section

28.1(a) of the Act).

 Thus, the Board is charged with the

authority to grant individual adjusted standards which are

different from the Board’s generally applicable regulations.

Although usually granted as permanent relief, the adjusted

standard is not adopted as

 a rule under the Administrative Code.

Rather, the opinion and order granting, and oftentimes

conditioning, the relief requested serves both a regulatory and

an enforcement function.

Based upon the recorC before us

 and upon review of the

factors involved in the consideration of adjusted standards, the

Board finds that petitioners, most particularly Solar, have

demonstrated that the adjusted standard sought is warranted.

The

adjusted standard accordingly is granted, subject to the

conditions outlined in the order.

ADJUSTED

STANDARD

PROCEDURE

Section 28.1 of the Act provides that a petitioner may

request, and the Board may adopt,

 an environmental standard that

is:

 (a) applicable solely to the petitioner, and

 (b) different

from the standard that would otherwise apply to petitioner

pursuant to a rule of general applicability.

 Such a standard is

called an adjusted standard.

 The general procedures that govern

an adjusted standard proceeding are found at Section 28.1 of the

Act and within the Board’s procedural rules at 35 Ill. Adm.

 Code

Part 106.

Where, as here,

 the regulation of general applicability does

not specify a level of justification required from a petitioner

to qualify for an adjusted standard, the Act at Section 28.1

(C)

specifies four demonstrations that must be made by a successful

petitioner.

 They are:

(1)

Faetors

 relating to that petitioner are substantially

and significantly different from the factors relied

upon by the Board in adopting the general regulations

applicable to that petitioner;

(2)

 The existence of those factors justifies an adjusted

standard;

(3)

 The requested standard will not result in environmental

or health effects substantially and significantly more

adverse than the effects considered by the Board in

adopting the rule of general applicability; and

(4)

 The adjusted standard is consistent with any applicable

federal law.

(415 ILCS 5/28.1(c))

PROCEDURAL HISTORY

Solar originally filed a petition for adjusted standard on

February 14,

 1994.

 On March

3,

 1994,

 the Board issued an order

finding this petition deficient,

 and directing Solar to submit an

amended petition by April 15,

 1994.

 On April

1,

 1994,

 Solar and

the Agency moved for an extension of time to file an amended

petition,

 i.e.,

until May 27,

 1994.

 That motion was granted by

Board order

or

Apr11 24,

 1994.

 Arter several more joint motions

requesting additional time to file, all of which were granted,

Solar filed its amended petition on January

3,

 1995, which was

accepted by the Board on January 11,

 1995.

During the time intervening the initial filing and the

amended petition, Solar and the Agency negotiated regarding the

3

relief requested by Solar.

 Prior to the amended petition being

filed, the Agency reviewed the draft of the same and asked that

Solar prepare a Technical Support Document

 (TSD) which would

provide additional support for the adjusted standard sought by

Solar.

 The fifth joint extension of time filed October 26,

1994

and

granted by the Board on November 3,

 1994 was to afford Solar

time to prepare such TSD.

 The TSD was filed along with the

January

3,

 1995 amended petition.

 Solar requested trade secret

protection for two exhibits attached to the TSD, pursuant to 35

Ill. Adm. Code 120.201, which has been afforded by the Board

since that time.

At the time the amended petition was filed, Solar and the

Agency still had some unresolved underlying issues.

 They

successfully resolved those issues, and on February 28,

 1995,

they filed a joint motion for co-petitioner status, attached to

which was proposed language for the adjusted standard amending

the language proposed in the January

 3 amended petition.

The

Board granted that motion and accepted the amended proposed

language by order dated March

9,

 1995.

 On April

7,

 1995 a

hearing was held in this matter in Libertyville, Illinois before

hearing officer June Edvenson.

 Kenneth Formanski and Greg Miller

testified on behalf of Solar, and

 John Blazis testified on

behalf of the Agency.

 Board Member McFawri, her assistant,

 Kevin

Desharnais and technical assistant Anand Rao were present.

No

members of the public were present.

 On May 3,

 1095,

 Solar filed

a motion to correct the transcripts, which is hereby granted.

On

May 5,

 1995,

 Solar and the Agency filed a joint motion to modify

the proposed adjusted standard language adding, in pertinent

part,

 a specific commitment by Solar to continue its research and

 development efforts to find alternatives to solvent—based

adhesives.

 That motion is also hereby granted.

RULE OF GENERAL APPLICABILITY

Solar seeks

an adjusted standard from the air emission

control requirements of 35 Iii. Adm. Code Part 218 Subpart PP,

which is entitled Miscellaneous Fabricated Product Manufacturing

Processes.

 The Board notes that Solar filed the initial adjusted

standard petition on February 14,

 1994,

 i.e.,

 within 20 days of

the effective date of those RACT requirements.

 Therefore,

 Solar

is exempt from these requirements until the Board’s final

decision on this petition.

 Absent a grant of the requested

adjusted standard, the following requirements would become

applicable to Solar:

1.

 Emissions capture and control techniques which achieve

an overall reduction in uncontrolled VOM emissions of

at least 21 percent;

or

2.

 Use of adhesives that do not exceed 3.5 pounds of VON

per gallon; or

3.

 An equivalent alternative control plan which has been

approved by the Agency and the U.S. EPA in a federally

enforceable permit or as

 a State Implementation Plan

(SIP)

 revision.

(35 Ill.

 Adm. Code 218.926.)

Of most concern to Solar is the daily weighted average

content of coating limitation of 3.5 pounds

of

volatile organic

materials

 (VON) per gallon when miscellaneous fabricated products

are manufactured.

 This limitation was originally adopted as RACT

in R91-7, PACT Deficiencies in the Chicago Area:

 Amendments to

35 Ill. Adm. Code Part 215 and the Addition of Part 218 (July 25,

1991), and was initially applicable only to major sources with

actual VOM emissions in excess of 100 tons per year

 (tpy).

In

response to the Federal Implementation Plan adopted by the U.S.

EPA, the Board later amended the applicability threshold to a

maximum theoretical emissions

 (MTE)

 of VON of 100 tpy or more for

Chicago-area sources in R93-9,

 Omnibus Cleanup of the VON PACT

Rules Applicable to Ozone Nonattainment Areas

 (September 9,1993).

In R93-14, PACT for Major Sources Emitting VON in Chicago

Nonattainment Area:

 25 Tons

 (January 6,

 1994), the applicability

threshold for Chicago area sources was again amended to include

miscellaneous fabricated product manufacturing processes with

potential to emit

 (PTE) of 25 tpy or more of VON, but which have

NTE of VOM

 less

 than 100 tpy.

 These

 25 tpy sources, which

include the Solar facility located in Libertyville, are now

regulated as major sources, and the date of compliance with

Subpart PP is March 15,

 1995.

 Prior to the adoption of the rules

 R93-14, Solar had not been regulated by the 100 tpy rules at

Subpart PP.

In lieu of compliance with the 3.5 pound per gallon

limitation, Solar requests an emission limitation of 5.75 pounds

per gallon

 (0.69 kg/i)

 for sources at its Libertyville facility,

subject to certain recordceeping

 restrictions.

BACKGROUND

Solar owns and operates a plant of approximately 250,000

square feet in Libertyville, Lake County,

 Illinois.

 At this

facility, which is approximately

 35 miles north of Chicago, and

within the Chicago area source non-attainment area for ozone,

Solar employees approximately 750 persons.

 There, Solar produces

custom-made,

 fabric-covered plastic decorative components ror

customers manufacturing electronic home and office products, and

a wide variety of fabric—covered interior automotive products for

automotive manufacturers.

 The decorative component3 produced by

Solar include speaker grills for stereos and televisions,

pressure—formed thermoplastic back enclosures for television

sets,

 and other decorative molded parts and fabric wrapped sub-

assemblies.

 The automotive interior products include speaker

grills,

 vinyl and fabric clad door trim components, injection

molded decorative subassemblies,

 seat trim components, and

electric subassemblies.

Production or these products occurs on a three—shift basis,

five days a week.

 Solar is known as a “job shop” because it does

not maintain an inventory of fabric—covered plastic parts readily

available to ship on demand to its customers.

 Instead, Solar

produces particular component parts upon demand.

 When Solar

receives an order from one of its customers,

 Solar quickly re—

tools as necessary to produce the part, produces it,

 and promptly

ships the product out.

 This may require Solar to make as many as

30 to 35 line changes per day.

 (TSD at 4.)

 At hearing, Miller,

a

senior manufacturing engineer at Solar, testified that 40 to 100

line changes can occur, depending on the product load that day.

(Tr.

at

 29.)

 He later explained in a different context that line

changes involve changing the “nests” for each different product

parts, and sometimes also the location of the auto—spray

machines.

 (Tr. at 62.)

The production of fabric-covered plastic parts by Solar

requires the application of adhesives,

 which contain and emit

VOM,

 to the plastic part prior to fabric application.

 Solar’s

customers’ requirements dictate the type of fabric to be applied

to various plastic parts and specifies the adhesion requirements

that must be demonstrated and provided by the adhesives used by

Solar.

 Both the plastic parts and the adhesives must withstand a

 wide range of temperatures and humidities.

 The adhesives must

ensure that the fabric applied will adequately bond and maintain

its adhesion through the life of the plastic part.

ADHESIVES and VON EMISSIONS

Most adhesives used by Solar contain VON in amounts greater

than 3.5 pounds per gallon.

 The annual VON emissions from all

adhesives for the years 1990 through 1994 were 27.35 Tons

 (P),

40.15

T,

 29.14 T,

 44.68 T and 39.80 T per year,

 respectively.

(Ex.3)

 The most used adhesive is Imperial 3317, which contains

5.49 pounds per gallon of VON.

 Miller estimated that Imperial

3317

 is used in approximately 70 to 75 percent of Solar’s

production.

 (Pr.

 at 30.)

 In the years 1990 through 1994,

 its use

accounted for 27.35 T,

 38.22 T,

 29.41

T,

 43.65

 T, and 32.00 T per

year, respectively.

 (Ex.

 2) As discussed in more detail at page

6

of this opinion,

 its VON content has been reduced by

approximately one half to three quarters of a pound of VON per

gallon.

 (Tr. at 31.)

 The total VON emissions from all sources,

including adhesives,

 paints and solvents in the years 1990

through 1994 are 68.24

T,

 88.90 T,

 73.07 T,

 89.90

T,

 and 95.50 T

per year,

 respectively.

 (Ex.1)

6

APPLICATION OF SOLVENT-BASED ADHESIVES

To apply the adhesives to plastic parts, Solar uses either

manual spray guns or “auto—spray” machines.

 The manual

application by spray guns takes place in eleven spray booths

currently permitted by the Agency.

 The auto-spray machines,

of

which there are nine permitted at the time of hearing, and two

others to come on line shortly, are custom-made and deliver a

pre-measured amount or adhesives,

 eliminating the over spray

incurred with manual spray guns.

 However, the auto—spray

machines cannot be used in all applications because, with one

exception, they can only apply adhesives on an X/Y axis.

 Manual

spray guns must be used to apply adhesives to irregularly shaped

or curved plastic parts.

 (Ain.Pet. at

 8; TSD at 10; Tr.

 at 34-

36.)

Solar has calculated that each auto—spray machine emits

only 2.45 pounds of VON per eight hour shift,

 in comparison to a

manual spray gun which emits an estimated 14.03 pounds of VON per

eight hour shift.

 (Am.Pet.

at

 7; TSD at 8-9;

Tr.

 at 34-35.)

These calculations for VON emissions were based on material usage

observations comparing adhesive usage by auto—spray machines and

manual spray guns over a one week period.

COMPLIANCE ALTERNATIVES

To achieve compliance with the 25 ton RACT rules, Solar

 investigated:

 (1) reformulation of adhesives;

 (2) water—based

adhesives;

 (3) alternatives to adhesives; and

(4)

 catalytic

oxidation.

 Each alternative compliance method is discussed

below.

Reformulation of Adhesives.

 Early on,

 Solar began

investigating reformulating the adhesives.

 Initially,

reformulation allowed Solar to reduce the VON content in the

adhesive most widely used from 6.02 to 5.49 pounds per gallon,

raising the percent of solids from 20 percent to 30 percent.

Further reduction could not be achieved without increasing the

solids content to 50 per cent, which would result in an adhesive

so viscous that it could not be applied with either the manual

gun or auto—spray.

 Solar also investigated substituting acetone

for either toluene or methylene ketone; neither was technically

feasible because satisfactory bonding of the fabric to the

plastic substrate could

not

occur

 without either volatile

component.

 (TSD at 1-11;

Tr.

 30-32; Am.Pet. at 9.)

Water-Based Adhesives.

 Solar currently uses two water-

based adhesives.

 Investigations began in 1987 into water-based

adhesives, resulted in Solar being able to replace

 a two-

component solvent—based adhesive with a water-based adhesive,

thereby reducing emissions associated with adhesives by at least

10 percent.

 This water-based adhesive is applied using a

laminating process, which only works well with flat, two

dimensional surfaces.

 (Tr.

 at 50—15.)

The second type of water-based adhesive is used to apply

vinyl to a plastic substrate in Solar’s vacuum—forming process.

Solar anticipates that two to three percent of its production

in

1996 will involve this process.

 (Tr.

 49.)

 This glue has a

reportable VON content of 1.88 pounds per gallon,

 compared to the

glue formerly used which had approximately 84 percent methylene

ketone, which represents approximately six pounds per gallon of

VON.

Adhesiveless Processes.

 Solar also investigated

alternatives to adhesives,

 conducting test trials with sonic

welding and a heat plate.

 Sonic welding proved unsatisfactory

for technical and economic reasons.

 Technically,

 sonic welding

only works

 if the plastic edges are joined at

 90 degree angles.

Many of the plastic parts are not flat,

 and therefore cannot be

welded in that manner.

 (Tr. at 58-61.)

 The capital cost for 10

sonic welding machines was estimated at $750,000, with operating

(retooling) costs of $500,000 for a total of $1,250,000.

Retooling would have to occur on an annual basis since the

products produced by Solar’s customers change year to year.

 (TSD

p.13,

 Am.Pet.

 p.11.)

 At hearing, Miller lowered that estimate to

$1 Million based upon an estimate of $3,600 per new nest,

 i.e.,

retooling,

for

 a total of $360,000

 in annual retooling costs plus

the $750,000

 in capital costs.

 (Tr.

 at 63.)

Solar also investigated and now uses

 a heat plate to bond

cloth to plastic, which

 is an adhesiveless process.

 For this

process to be feasible, the plastic part must have sufficient

cross section to withstand the heat generated in bonding.

Currently,

 Solar uses this process for approximately 20 per cent

of the fabric covered plastic parts.

 since this process uses no

adhesives, the VOM formerly emitted in applying the fabric to

these plastic parts

 is reduced to zero.

 (Tr.

 at 52-54.)

Catalytic Oxidation.

 Solar also investigated catalytic

oxidation as add—on controls as a means of achieving 81 per cent

capture and control of VON emissions from the manual spray booths

and auto-spray machines.

 The estimated costs were $25,000 and

$10,000 per ton for the manual spray guns and auto-spray

machines, respectively.

 Solar believes these costs to be

economically unreasonable.

In sum,

 Solar has designed and purchased new processes,

products

and

 equipment to

reduce

its VON emissions,

 even before

Subpart PP became applicable to the Libertyville facility.

 Solar

has investigated reformulated adhesives.

 In 1989,

 Solar replaced

one of the adhesives frequently used,

 that had a VON content of

a

6.02 pounds per gallon, with

 a higher solids adhesive that has

only 5.49 pounds per gallon of VON.

 (TSD

p.

at

 11; Am.Pet. at

p.12.) Also,

 where feasible,

 Solar has replaced high VON content

adhesives with water—based adhesives, which contain virtually no

VOM.

 It has automated its spraying operations to the maximum

extent possible to date,

 and switched to a heat plate process for

bonding fabric to 20 percent of the fabric covered plastic parts

it produces,

 eliminating VON emissions entirely from that portion

of its production.

In

 a comparison of adhesive used in 1993 and 1994, two years

in which the amount of Solar’s business was relatively the same,

Solar used approximately 2,000 gallons less of adhesives in the

latter year.

 Solar attributes that reduction for the most part

to the heat plate process and,

 in lesser part,

 to an increased

use in the auto—spray machines over the manual spray guns.

 (Tr.

at 74—89.)

 Solar believes that the measures taken by it over the

years to research, develop and implement alternative technologies

 and adhesives represent all that is technically feasible and

economically reasonable at this time.

 They also represent a

commitment by Solar to aggressively investigate and implement

processes which reduce the amount of VON emitted by their

operations.

HEALTH AND ENVIRONMENTAL EFFECTS

The petitioners assert that the impact to general air

quality will be insignificant based upon the emission data of VON

from the adhesives used by Solar and that the requested adjusted

standard

will

 have no adverse impact on

health

the

environment.

With respect to air quality, Solar estimates the maximum VON

emissions per day will be significantly less than one ton per day

should it receive the requested adjusted standard’.

 Based upon

the Agency’s total daily emission

von

from

all sources in Lake

County at 113.62 tons,

 Solar’s contribution given the requested

relief

will

significantly

 less than one percent of the total

daily VON emissions in Lake County.

 (TSD at 14.)

 Based upon its

‘Solar

made this representation

at a time that it was requesting an adjusted standard

which

would have allowed it to

use a

“specialty adhesive”

with

emission

limit of 8.2

pounds per

gallon.

That request

was

subsequently withdrawn

because Solar learned that the

solvent in this

adhesive,

methylene chloride

was

not defined as a VOM.

Solar never

quantified how

much of its daily

VOM emissions were attributable

this specialty

adhesive,

but

attributed .84 tpy

to the

specialty

adhesive.

Since the

daily effect is

something less than

that represented

in the Amended

Petition, the

Board

will rely

upon Solar’s annual

representations primarily

when assessing the environmental impact of the requested adjusted

standard.

9

1993

adhesive

usage,

Solar

estimates

that

the

total

 VON emissions

will

45.72

tpy.

Solar

were

 to comply with Subpart PP using

adhesives

with

 maximum VON content of

3.5

pounds

per

gallon,

the

result

would

VON emissions of

 28 tpy,

 as compared to the

1993

47.5

tpy.

The

difference

approximately

tpy

 0.054

tons

per

day,

which

Solar

contends

 would have no quantifiable

effect on ambient ozone levels in the Chicago area ozone non—

attainment area.

 (Am.Pet. at

 16.)

With respect to other impacts on the environment,

 Solar

explained

that

its

solid

 waste generation will remain the same

whether

complies

with

Subpart

the

proposed

adjusted

standard.

However,

 Solar explained that the proposed adjusted

standard

will

result

lower

energy

usage

and

 costs.

 Since no

compliant

adhesives

are

 available,

 Solar would have to attempt

compliance

using

the

percent

capture

and

control

compliance

alternative.

While

the

result

would

very

 dilute VON

concentration in the exhaust stream,

 this compliance alternative

would require using large amounts of natural gas to provide

sufficient heat for adequate VON destruction, assuming that this

 air stream could in fact becaptured.

 (TSD at

 13; Am.Pet.

at

16.)

At hearing, the Agency stated its conclusion that the

hardship resulting from the denial of the adjusted standard would

outweigh any environmental impact from the grant of the relief

requested.

 (Tr.

 at 101.)

CONSISTENCY WITH FEDERAL LAW

The petitioners assert that the proposed adjusted standard

would be consistent with

federal

law.

They

assert

that

the

proposed

alternative

standard

constitutes

PACT

 for the

Libertyville

facility,

and

therefore

consistent

with

the

federal

Clean

Air

Act.

(Am.

 Pet. at 17.)

 solar notes that

should the adjusted standard be granted by the Board,

 it will be

submitted as

 a SIP revision as the RACT rule specific to Solar,

thus comporting with federal procedural requirements.

CONCLUSION

The Board finds that the joint petitioners have demonstrated

that an adjusted standard is appropriate for the Solar facility

in Libertyville, Illinois.

 They have demonstrated that no other

technologies or alternative adhesives,

 other than those currently

in use,

 are available at this time which are technologically

feasible and economically reasonable for Solar’s manufacturing

 process.

 Furthermore, they have presented proof adequate to

support the following findings by the Board on the criteria set

out Section 28.1(c)

 of the Act.

10

Solar did not participate in the R93-14 rulemaking which

contains the technical support justifying

RACT

 for adhesives.

However,

 as Solar pointed out, that record did not contain

specific technical support about the application of fabric to

plastic parts.

 Solar explained that it did not participate in

that rulemaking because it believed that Its research and

development efforts would allow it to achieve compliance with

Subpart PP.

 Instead, through diligent research and development

efforts Solar has achieved reductions in its

VOM

smissions

and

is

using technology and adhesives which represent RACT for its

manufacturing operation.

 We find that this evidence demonstrates

that factors relating to Solar’s operations are substantially and

significantly different from those relied upon by the Board in

adopting the rule of general applicability, and that these

factors warrant the granting of an adjusted standard.

We further find that the evidence presented by Solar

concerning its VOM emissions and the impact on air quality and

other aspects

of

the

environment

demonotrates that the proposed

alternative standard will not impact human health or the

environment

substantially

significantly

adversely

than

the

effects

considered

the

Board

adopting

Subpart

the

R93—l4

rulemaking.

Finally,

petitioners

have

demonstrated

that

the

proposed

alternative

standard

will

consistent

with

federal

law.

 Accordingly,

the

proposed

adjusted

standard

 is granted,

subject to conditions suggested by the joint petitioners.

This opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

ORDER

Solar is hereby granted an adjusted standard from the

control requirements found at 35 Ill. Adm. Code 218.Subpart PP

for its facility located at 100 Solar Drive in Libertyville

Township, Lake County,

 Illinois,

 subject to the following

provisions and conditions:

1)

 The emission limitation of VOM for the adhesive applied

for

joining

fabric

plastic

parts

 at sources subject

to this adjusted standard is:

kg/l

lb/gal

Adhesive

0.69

(5.75)

2)

 The above emission limitation is expressed in units of

VON per volume of ud1ie~ive

(minus

 water and any

compounds which are specifically exempted from the

definition of VOM)

 as applied by each adhesive

applicator.

 Compounds which are specifically exempted

11

from

the

definition

VON

shall

treated

water

for

the

purpose

calculating

the

“less

water”

part

the

coating

composition.

3)

 Compliance with this adjusted standard must be

demonstrated through the applicable coating analysis

test

methods

and

procedures

specified

Ill.

Adm.

Code 218.105(a) and the recordkeeping and reporting

requirements specified at 35 Ill. Adm.

 Code

218.211(c).

Solar

shall

continue

its

research

and

development

efforts regarding alternatives to solvents-based

adhesives and will utilize such alternatives as they

 become available,

 if and when they are technically

feasible and economically reasonable.

ORDERED.

Section

the

Environmental

Protection

Act

(415

ILCS

5/41

(1994)

provides

for

the

appeal

final

Board

orders

within

days

the

date

service

this

order.

The

Rules

the

Supreme

Court

Illinois

establish

filing

requirements.

(See

also

Ill.

Adm.

Code

101.246

“Notions

for

Reconsideration”.)

Dorothy

Gunn,

Clerk

the

Illinois

Pollution

Control

Board,

hereby

certify

that

opinion

and

order

was

adopted

the2öZZL~day

1995,

vote

ion

Control

Board