ILLINOIS POLLUTION CONTROL BOARD
August
5,
1993
IN THE MATTER OF:
)
)
PETITION OF DART CONTAINER
)
AS 91-6
CORPORATION OF ILLINOIS
)
(Adjusted Standard)
FOR ADJUSTED STANDARD FROM
)
35
ILL. ADM.
CODE 218.986(a)
)
JOSEPH V.
KARAGANIS AND JANES
D. BRUSSLAR, KARAGANIS AND WHITE
LTD. APPEARED ON BEHALF OF DART CONTAINER CORPORATION;
JULIE K.
ARNITAGE AND JULIA N. GENTILE APPEARED ON BEHALF OF THE
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY.
OPINION AND ORDER OF THE BOARD
(by C. A. Manning):
This matter is before the Board on
a July 19,
1991,
filing
of a petition for adjusted standard by Dart Container Corporation
of Illinois
(Dart or Petitioner)
pursuant to Section 28.1 of the
Environmental Protection Act
(Act).
(415 ILCS 5/28.1
(1992).)
On October
11,
1991,
Dart filed an amended petition for an
adjusted standard
from
35
111. Adm.
Code, Subpart TT,
§218.986(a).
218.986(a)~would require Dart to achieve an
overall reduction
in non-fugitive volatile organic material
(VOM)
emissions of at least 81 percent.
Dart proposes an adjusted
standard from 218.986(a), which
if granted, may result in a
revision to the State Implementation Plan
(SIP).
1The Board notes that
in both the petition and amended
petition, Dart asks for an adjusted standard from Section
218.980.
However,
in the reply brief,
Dart asks for relief from
Section 218.986(a).
At hearing, Ms.
Arinitage,
an assistant
attorney on behalf
of the Illinois Environmental Protection
Agency,
stated she had no objection to the technical merits of
Dart’s proposal for an adjusted standard from Section 218.986(a).
(Tr.
at 5.)
Additionally, the Hearing Officer noted the caption
on the stipulation submitted by the Agency and Dart stated Dart
was seeking an adjusted standard from 35
Ill.
Adin.
Code
218.986(a).
(Tr.
at
7 and Stip.
at
1.)
Section 218.980 is the
applicability section for the Subpart while Section 218.986
contains the control requirements.
Thus,
Section 218.986
is the
correct section.
2
BACKGROUND
Dart operates a polystyrene foam packaging facility adjacent
to the Illinois East—West Toliway in North Aurora,
in Kane
County,
Illinois.
Dart manufactures drinking cups and other food
containers from expandable polystyrene
(EPS) beads.
Dart’s
production process involves volatile organic materials
(VON)
emissions of the EPS blowing agent, pentane,
in excess of 100
tons per year.
The facility is a non-Control Technique Guideline
emissions source that
is addressed by the June 29,
1990,
Chicago
area Federal Implementation Plan
(FIP)
promulgated by the United
States Environmental Protection Agency
(USEPA)
(40 CFR 52.741)
and the related Illinois Reasonably Available Control Technology
(RACT)
Rules found at 35
Ill. Adm. Code Part 218.
PROCEDURAL HISTORY
On August
7,
1991,
the Illinois Environmental Protection
Agency
(Agency)
filed a motion to dismiss Dart’s petition seeking
an adjusted standard.
Dart responded to the Agency motion to
dismiss on August
19,
1991.
On November
13,
1991, the Agency
filed
a response to Dart’s petition recommending that the Board
deny Dart’s petition.
On February 14,
1992, Dart and the Agency filed a joint
status report stating they were in the process of negotiating and
that Dart required additional time to file a reply to the
Agency’s response.
A second status report was filed by the
Agency on May 4,
1992 indicating negotiations were on-going
between the Agency and Dart.
On Nay 29,
1992, Dart filed
a reply
in further support of the petition for an adjusted standard.
The
Board notes the reply is significantly larger and provides more
technical
information than the original petition.
On July 24,
1992,
the Agency filed
a response to Dart’s May
29th reply
(Resp.).
The response withdrew the Agency’s earlier
recommendation
of denial of Dart’s petition and stated the Agency
had no objections to the technical merits of Dart’s petition.
However, the recommendation was contingent upon Dart providing
further information to the Agency.
On August
10,
1992,
the
Agency filed an amendment to its July 24,
1992, response removing
the contingencies of the July 24,
1992, response
(Am. Resp.).
On August
6,
1992,
a hearing was conducted
in Geneva,
Illinois.
At hearing,
the Agency and Dart filed
a stipulated
agreement.
The agreement set forth the Agency’s recommendation
for granting the adjusted standard as an alternative control plan
subject to several conditions.
PROPOSED ADJUSTED STM~DARD
In its amended petition,
Petitioner proposed the following
3
adjusted standard and rationale:
Dart Container of Illinois shall comply with Subpart TT
of Section 218.986(c)
by reducing plant emissions by
45
from the baseline value of 207 tons per year.
(Am.
Pet.
at 31.)
In summary, Dart requests that an adjusted standard of
45
reduction
in VOC emissions be approved by the Board
as an adjusted standard and by the Agency as an
alternative control plan and SIP revision.
Dart hopes
that these levels will allow it to meet the regulations
of 218.980 by limiting emissions to 55
of the baseline
emissions or 114 tons of emissions per year in the
processing of 7810 tons of EPS into containers.
(Am.
Pet.
at 31.)
However, the agreement between Dart and the Agency contains
standards more stringent than those originally proposed in the
amended petition.
It establishes testing and reporting
requirements for the Dart facility
(Stip.
at 3—6.)
and requires
Dart’s emissions capture and control systems to achieve an
overall reduction in uncontrolled VOM emissions from the pre-
expanders,
blenders,
and holding tanks of at least 81 percent.
(Stip.
at 3.)
Additionally, the agreement requires each capture
system to achieve at least 85 percent capture of all the VOM
emissions from the pre-expanders,
blenders,
and holding tanks.
(Stip.
at 3.)
The agreement also asks that the boilers be
operated and maintained
so as to achieve at least
95 percent
destruction of VOM from the pre-expanders,
blenders,
and holding
tanks.
(Stip.
at 3.)
ADJUSTED STANDARD JUSTIFICATION
Section
28.1
of the Act allows the Board to grant an
“adjusted standard” modifying the effect of general rules
in
specific cases.
35
Ill.
Adm. Code 106 Subpart G contains
procedures to be followed in adjusted standard matters.
Where
the Board specifies
a
“level of justification”
at the time it
adopts the rule of general applicability, then that level
of
justification controls any adjusted standards filed pursuant to
the rule.
Absent
a specified
level of justification,
the level
of justification
is found
in Section 28.1(c)
of the Act.
Dart seeks an adjusted standard from the following
regulation:
Subpart TT of SubTitle B Air Pollution
35 Ill.
Adn.
Code 218.986
Every
owner
or operator of
an emissions
4
source subject to this Subpart shall comply
with the requirements of subsection
(a),
(b),
or
(c)
below.
a)
Emission capture and control equipment
which achieve an overall reduction in
uncontrolled VON emissions of at
least
81 percent,
or
c)
An alternative control plan which has
been approved by the Agency and approved
by the USEPA as a SIP revision.
Dart
is governed by 35 Ill.
Adrn.
Code Part 218 instead of
35
Ill.
Adrn.
Code Part 215 because it is within the Chicago area
FIP.2
However,
Dart notes
in its reply that although the
facility
is governed by Part 218,
only Part 215 contains a
procedure for issuance of adjusted
RACT
emission-limitation
standards by the Board.
Dart argues the Board should utilize the
adjusted standard justification in Part 215 since none exists in
Part 218 and grant its adjusted standard since the technology
Dart proposes constitutes RACT.
However,
since
35 Ill.
Adm.
Code 218.986(a)
does not list a
specific level of justification for an adjusted standard, an
adjusted standard from this part must meet the criteria found in
Section 28.1 of the Act rather than Part 215.
Section 28.1(c)
states:
C)
If
a
regulation of general applicability does not
specify a level of justification required of a
petitioner to qualify for an adjusted standard,
the Board may grant individual adjusted standards
whenever the Board determines, upon adequate proof
by petitioner,
that:
1.
factors relating to that petitioner
are substantially and significantly
different from the factors relied
upon by the
Board in adopting the
general regulation applicable to
235
Ill.Adm.Code Part 215 contains the standards and
limitations
for emissions of organic material from stationary
sources other than the Chicago area counties
of Cook,
DuPage,
Kane, Lake, McHenry and Will,
and the Metro East area counties of
Madison, Monroe and
St.
Clair.
35 Ill.Adm.Code Part 218 governs
the standards and limitations for the Chicago area.
35
Ill.Adm.Code Part 219 applies to the Metro East area.
5
the 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.
The Board notes that compliance with
35 Ill.Adm.Code
218.986(c)
requires the petitioner to submit any alternative
control plan approved by the Board in granting an adjusted
standard, to the USEPA for approval as a SIP revision.
Subsection 218.986(c)
further requires the Agency to approve an
alternative control plan as
a SIP revision.
However,
such
approval has already been rendered as part of the stipulated
agreement between the parties
(Stip.
at
1)
Section 28(c) (1)
and
(2)
Existence of Substantially
and Significantly Different Factors
Under Section 28.1(c) (1)
of the Act, the petitioner must
show that factors relating to
it are substantially and
significantly different from the factors relied upon by the Board
in adopting the rule
of general applicability at
35 Ill. Adm.
218.986.
Under Section 28.1(c) (2),
the petitioner must show that
the existence of the Section 28.1(c) (1)
factors justifies an
adjusted standard.
In order to address these factors,
Dart relies upon the
argument that
in formulating Subpart TT of Section 218, the Board
and USEPA realized
a “high probable cost” existed for controlling
VOM from the main process and storage areas of polystyrene
facilities.
(Reply at 13.)
Dart argues that
in creating the
Chicago-area FIP,
the USEPA reviewed the Board’s opinion and
order
in
In re Organic Material Emission Standard and
Limitations:
Organic Emission Generic Rule, R86-18,
____PCB
(April
7,
1988),
in which the Board adopted Part 215 Subpar~E~p,
Miscellaneous Fabricated Product Manufacturing Processes.
(Reply
at
12
&
13.)
In R86-l8,
the Board adopted the Agency’s recommendation to
exclude Mobil Chemical Company,
a polystyrene foam packaging
plant,
from Part
215,
Subpart PP.
(Reply at 12.)
Dart’s view
is
the exclusion was granted because the cost effectiveness of
6
compliance did not constitute RACT.
Dart cites the Agency’s
Final Comments on R86-l8 at page 32 as support
for this
proposition.
(Reply at 12.)
Additionally, Dart states that
based
on the Board’s opinion and order in R86-l8,
USEPA realized
the costs of compliance for polystyrene foam-packaging plants
probably would be high.
(Reply at 13.)
Dart suggests
it sits in
a position similar to that of Mobil
and this Board has already recognized that a polystyrene facility
such as Mobil
is entitled to an exclusion from Part 215.
Dart
argues,
it
is equally unable to comply with the onerous
requirements of Part 218,
and should be entitled to an adjusted
standard.
As evidence of the compliance problems Dart faces,
Dart states
in its reply that
it has implemented process
modifications which have eliminated 44 tons of emissions per
year.
(Reply at
5.)
However, to reduce non-fugitive VOM
emissions by 81 percent as required by Section 218.986(a), Dart
would have to eliminate an additional
123 tons of pentane from
its manufacturing process.
(Reply at
6.)
To achieve an 81
percent reduction,
Dart would have to enclose the molding area
and implement the pre-expander system with existing
modifications.
Dart estimates this cost at approximately
$3,450,000.
(Reply at 7.)
Dart believes the pre-expander system
is the only cost-effective way to destroy an acceptable volume of
VON emissions.
It
is Dart’s position that
a pre-expander system
plus the process modifications
it now has in place constitute
RACT.
(Reply at
8 and
9.)
Dart’s claim that
it is justified
in seeking an adjusted
standard since it
is differently situated than those facilities
the Board envisioned in devising the rule of general
applicability is supported by the Agency’s July 24,
1992,
response.
In the response, the Agency states that compliance
with 218.896(a) has not been shown to be technically feasible for
Dart’s plant and compliance may cause the plant to shut down.
(Resp.
at 3.)
Additionally, the Agency states
it
is satisfied
Dart’s proposed method of control
is the only system which
appears to be utilized by plants of Dart’s type.
(Resp.
at 3.)
The Board
finds,
based upon the record,
the factors relating
to Dart are substantially and significantly different from the
factors relied upon by the Board when adopting the rule of
general applicability.
Therefore,
Dart is justified
in seeking
an adjusted standard.
The Board
notes that although Dart has provided evidence
adequate to justify seeking an adjusted standard, not all
polystyrene plants
in the Chicago area FIP are substantially and
significantly different from the factors relied upon by the Board
when adopting Section 218.986.
In the future,
a petitioner
seeking
an adjusted standard from Section 218.986 will be
required to introduce evidence sufficient to justify an adjusted
7
standard for the individual facility.
Section 28.1(c) (3)
Environmental and Health Effects
Under 28.1(c) (3), petitioner must show that
if granted,
the
adjusted standard will not result
in significantly and
substantially more adverse health or environmental effects than
those considered by the Board in adopting the rule of general
applicability.
The Environmental Impact
Affidavit
(EIA)
submitted by Dart
at the request of the Agency explores the possible effects which
could occur in the event the adjusted standard is granted.
The
EIA focuses mainly on the effect on air quality of the pentane
blowing agent used for manufacturing cups.
The study used for the EIA was based upon a model which
approximated the dispersion, exposure,
and effects of pentane
emitted from Dart.
(EIA at 2.)
The EIA states the study was
designed to examine the impact of pentane on the most exposed
local individual
in the urban areas of Chicago where the highest
ozone readings are found.
(EIA at 4.)
The EIA also states that
the ozone analysis
is
“extremely conservative”
in that it assumes
that all pentane avoids depletion, deposition,
or removal on its
way to the lakefront.
The study also makes the assumption all
pentane immediately reacts to contribute to ozone formation upon
arriving at the lakefront.
(EIA at 4.)
The EIA concludes the additional
amount of pentane which
would be emitted by Dart
if the adjusted standard were granted
would not significantly contribute to ozone formation
in the
Chicago Metropolitan Area.
(EIA at 6.)
The EIA also concludes
the additional pentane release should not present
a hazard to
residents living near the Dart facility.
(EIA at 4.)
The Agency’s amended response states the Agency reviewed the
information provided by Dart pertaining to the impact of pentane
on the environment
in light of an adjusted standard.
The Agency
concluded the small amount of pentane which would be released
pursuant to the adjusted standard should not result
in an adverse
effect on human health.
(Am. Resp.
at 2.)
The Agency also
determined that
if the Board grants the adjusted standard, the
standard will neither result in a decrease or significant
increase in VOM emissions.
(Am. Resp.
at
2.)
Based upon the EIA and the Agency’s amended response, the
Board finds that
if granted,
the adjusted standard will not
result
in significantly and substantially more adverse health or
environmental effects then those considered by the Board
in
adopting Section 218.986.
Section 28(c) (1) (4) Consistency with Federal Law
8
Finally, under Section 28.1(c) (4) the petitioner must show
the proposed adjusted standard
is consistent with any applicable
federal law.
In order to fulfill state law requirements, Dart
must obtain an adjusted standard from the state rules.
An
adjusted standard from Section 218.986(a)
is consistent with
Federal
law if the proposed alternative control plan is approved
by both the Agency and the USEPA.
The Agency,
in its amended
response, states that it accepts Darts proposal for an adjusted
standard as an alternative control plan.
(Resp.
at 3.)
The Board finds that Dart’s petition for an adjusted
standard is consistent with state law, and so grants the adjusted
standard.
However,
the Board notes that in order to fully comply
with 40 CFR 52.741(x) (v) (3) (iii)
and 35
Ill.
Adin. Code
218.986(c),
Dart must seek approval from USEPA for a SIP
revision.
COMPLIANCE WITH 35 ILL.ADN.CODE
106
•
705 REQUIREMENTS
The adjusted standard procedures found at
35
Ill. Adm. Code
106 Subtitle G were adopted by this Board on July 10,
1989.
The
Board has reviewed the Dart amended petition for adherence to the
petition content requirements of 35
Ill. Adm.
Code
106.705.
Although the amended petition does not
in the strictest sense,
comport with 106.705,
this Board concludes that Dart has
provided sufficient information to substantially satisfy 35
Ill.
Adm. Code 106.705.
CONCLUSION
Section
28.1 of the Act allows for an adjusted standard from
a rule when certain conditions have been met upon adequate proof
by the petitioner.
Following a careful review of the record, the
Board hereby grants Dart’s request for an adjusted standard from
35 Ill.
Adm. Code 218.986(a).
The Board accepts the adjusted
standard as set out
in the stipulated agreement between Dart and
the Agency as an Agency-approved alternative control plan
required by
35
Ill. Adm. Code 218.986(c).
(Stip.
at
1.)
The
final order accompanying this opinion includes several compliance
deadlines which have passed; the Board will retain these dates as
they appear
in the stipulated agreement between the parties.
335 Ill. Adm.
Code 106.705(g)
requires quantitative and
qualitative impact analysis of
a variety of factors.
While this
information was not originally
a part of the amended petition,
Dart provided an Environmental Impact Affidavit
(EIA)
in a
subsequent
filing.
The
EIA
considered together with the amended
petition satisfies the information requirements
of
106.705(g).
9
This opinion constitutes the Board’s findings of fact and
conclusions
of law
in this matter.
ORDER
The Board grants Dart an adjusted standard from 35
Ill. Adm.
Code 218.986 for its expandable polystyrene product plant located
at 310 South Evergreen Drive,
North Aurora, Kane County,
Illinois
(Plant),
subject to the following conditions:
1.
The current permitted production capacity of
the Plant
is 7,810 tons of expanded
polystyrene
(EPS)
beads per year.
Increases
in production beyond 7,810 tons per year
would require
a modified operating permit
pursuant to 35 Ill. Adm. Code Part 201.
Modifications to the Plant would require a
construction permit pursuant to 35
Ill. Adm.
Code Part 201.
2.
The pentane
(or any other volatile organic
material
(VOM)
expansion agent)
content of
the expandable polystyrene beads shall not
exceed 6.0
by weight as received by the
plant.
3.
The Plant shall
capture VON emissions from
the pre-expanders, blenders and holding tanks
and control these emissions by ducting them
to the boiler at all times except when the
following maintenance activities are being
performed:
a)
flame arrestor
maintenance
b)
VON
(pentane) sensor
calibration
c)
filter maintenance
d)
VON (pentane) sensor replacement
4.
The specified maintenance activities shall be
performed so as to minimize to the extent
reasonably possible the period of time during
which VON emissions are uncontrolled.
5.
In no event shall the duration of the
specified maintenance activities exceed the
following:
10
a)
Six
(6)
hours per month
for flame arrestor
maintenance
b)
Eighteen
(18) hours per
month for pentane sensor
calibration and filter
maintenance
c)
One
(1)
hour per month
for pentane sensor
replacement
6.
Maintenance of the flame arrestors shall be
performed on Saturdays, Sundays or holidays
except during emergency.
7.
Maintenance activities
(other than of the
flame arrestors)
shall be performed so that
the maximum period of time during which VON
emissions are uncontrolled on a particular
day shall not exceed two
(2)
hours.
8.
The capture system including hooding and
exhaust fans on individual emissions units
shall be designed and operated so that
essentially all loss of VOM occurs through
forced draft openings.
All natural draft
openings in emission units shall be designed
to preclude the loss of VON by minimizing the
size and number of openings to the amount
necessary for safe and proper equipment
operation and by maintaining at least an
average face velocity of one hundred
(100)
feet per minute across each opening,
except
for the pentane dilution air vent and the
bead transfer air inlet on the pre-
expanders/hoppers, each of which shall have
an average face velocity of at least fifty
(50)
feet per minute.
9.
During operation of an emission unit, any
access port and hatches
in the capture systeni
shall be tightly closed except as production,
inspection,
sampling,
and maintenance
procedures require access.
10.
The Plant’s emissions capture and control
systems shall achieve an overall reduction in
uncontrolled VON emissions from the pre-
expanders,
blenders,
and holding tanks of at
least eighty-one
(81)
percent.
Each capture
11
system shall achieve eighty—five
(85) percent
capture of the VON emissions from the pre-
expanders,
blenders, and holding tanks.
Boilers shall be operated and maintained to
achieve at least ninety—five
(95) percent
destruction of VON from the pre-expanders,
blenders, and holding tanks.
11.
The Plant shall
implement good management and
housekeeping practices to minimize fugitive
VON emissions from any operation prior to
introduction of EPS beads to the molding
process.
12.
The Plant shall not cause or allow visible
emissions from its processes except water
vapor.
13.
The Plant shall perform testing to establish
the capture efficiency of the hoods which
collect the VON from pre-expanders, blenders,
and holding tanks, and the destruction
efficiency of the boilers.
14.
Determinations of capture efficiency shall be
made by measurement of the VON in each forced
draft opening using the appropriate gas phase
test methods and procedures specified
in
35
Ill. Adm. Code 218.105.
Determination of
destruction efficiency shall be made by
measurement of the VON using the appropriate
methods and procedures specified
in 35
Ill.
Adm.
Code 218.105.
Representative equipment
shall be tested.
15.
The Plant shall
install,
operate,
and
maintain in good working order
a continuous
monitoring and recording system for direct—
to—the—atmosphere bypass vents.
16.
The Plant shall
install, operate,
and
maintain
in good working order
a continuous
monitoring and recording system for air flow
of the capture systems.
17.
The Plant
shall install, operate,
and
maintain in good working order
a continuous
monitoring and recording system for the VOM
content of the gas stream in the capture
system relative to the Lower Explosive Limit.
18.
All continuous monitoring and recording
12
instruments shall be properly installed,
calibrated,
and operated.
19.
Not later than April
1,
1993,
the following
must occur:
Installation and operation of
the capture and control systems;
installation and operation of monitoring and
recording devices; demonstration of capture
and destruction efficiencies as specified
herein; and implementation of all record
keeping.
20.
Prior to testing, a test protocol shall be
submitted to the Agency for approval.
21.
The Agency shall be notified in writing not
less than thirty
(30) days prior to testing.
22.
Copies of the final test report(s)
shall be
submitted to the Agency within fourteen
(14)
days after the test results are completed and
finalized.
The final test report(s)
shall
include at
a minimum:.
a)
a summary of results
b)
general
information
c)
description
of test method(s)
d)
description of test conditions
23.
The Plant shall maintain monthly usage
records of all materials containing VON.
These records shall include the name and
identification number of each material, the
total weight of each material, and the VON
content of each material.
24.
The Plant shall maintain records
of each
occurrence when access ports and hatches in
the capture system are opened for production,
inspection,
sampling,
and maintenance
procedures,
including the date,
time,
duration, and a detailed explanation for
opening.
25.
The Plant shall maintain records of the
operating status for the capture system,
control system, monitoring and recording
devices,
and the pre-expanders, blenders, and
holding tanks.
26.
The Plant shall maintain records of each
13
occurrence when one of the conditions of this
Stipulation was not met,
including,
the date,
time,
duration, and
a detailed explanation
for each occurrence.
27.
The Plant shall maintain records of the VOM
content
of each shipment of EPS beads as
received at the Plant,
as determined by
representative sampling and laboratory
analysis.
This requirement may be satisfied
by records of analysis performed by the
manufacturer for each batch of EPS beads
prior
to shipment, provided that VON losses
prior to receipt of the beads by the Plant
can be adequately accounted for.
No changes
in the adjustment factor used to account for
such losses shall be made without the prior
approval
of the Agency.
In the event of an
inconsistency between the manufacturer’s data
and the Plant’s data for shipment,
the
Plant’s data shall govern.
28.
The Plant shall maintain records for all
monitoring systems.
29.
The Plant shall maintain records for the
capture system,
control systems, and
monitoring equipment detailing all
maintenance performed including the date,
time,
duration,
and a detailed explanation of
each outage.
The Plant may use its chart
recorder(s) to satisfy this record keeping
requirement to the extent applicable.
30.
The Plant
shall submit to the Agency an
annual report of VON emissions with
supporting calculations and a summary of
maintenance activities for the capture and
control systems.
31.
The Plant will continue to investigate
methods to reduce VON emissions.
Annual
progress reports detailing such efforts shall
be submitted to the Agency beginning April
1,
1993.
32.
Submittal of information including but not
limited
to
the test protocol,
notice of
testing,
final testing report and annual
report shall be sent to:
14
Illinois Environmental Protection Agency
Permit Section
P.O.
Box 19276
Springfield,
IL 62794—9276
and
Illinois Environmental Protection Agency
Field Operations Service
1701 First Avenue
Maywood,
IL 60153
IT IS SO ORDERED.
Section 41 of the Environmental Protection Act (415 ILCS
5/4.
(1992)) provides for appeal of final orders of the Board
within 35 days.
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 ~ove
opinion and order was
adopted on the 5~
day of
__________________,
1993, by
a
vote of
~
.
~
~
~
Dorothy M. ~nn,
Clerk
Illinois Po’llution Control Board
