ILLINOIS POLLUTION CONTROL BOARD
June
21,
1990
ILLINOIS POWER COMPANY
(Clinton Power Station),
Petitioner,
v.
)
PCB 89—213
(Variance)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
SHELDON
A.
ZABEL,
ESQ.
AND ERIC
L.
LOHRENZ,
SCHIFF
HARDIN
AND
WAITE, ATTORNEYS-AT-LAW, APPEARED ON BEHALF OF PETITIONER; AND
KATHLEEN C.
BASSI, ESQ., ATTORNEY-AT-LAW,
APPEARED ON BEHALF OF
RESPONDENT.
OPINION AND ORDER OF THE BOARD
(by B.
Forcade):
This matter comes before the Board on a petition for
extension of variance,
filed on December
21,
1989
by Illinois
Power Company
(“IPC”).
IPC seeks
a
three—year extension
of the
variance granted
in PCB 88—97,
100 PCB 177
(June
22,
1989), which
granted relief
from the thermal effluent limitations
imposed upon
the discharge
from IPC’s Clinton Power Station
(“Stationt’)
in
Clinton,
Illinois.
That variance will expire
on
October
1,
1990.
IPC seeks an extension of
the variance until October
1,
1993.
IPC requests
the additional time
to compile information
and
to file a petition
for permanent relief from thermal effluent
limitations applicable
to its Clinton fa.~ility.
The applicable
regulation governing the :em~erature
of
IPC’s discharges
is
current Section 302.211, Temperature,
35
Iii. Adm.
Code
302.211.
Procedural History
This variance extension
is based on
the request
for variance
in
PCB 88—97
filed by IPC on June
3,
1988.
The variance was
granted
on June
22,
1989 and provided
relief from the thermal
standards set forth
in PCB 81—82,
~hich
relief would expire on
October
1,
1990.
The Board’s Opinion and Order
of June
22,
1989
is incorporated
by
reference pursuant
to the Board’s Order
off
January
11,
1990
in this proceeding,
PCB 89—213.
The petition for extension of variance was filed December
21,
1989.
The Illinois Environmental Protection Agency
(“Agency”)
filed
its
recommendation onJanuary
22,
1990,
in favor
112—373
—2—
of
the requested
relief,
but with a shorter
time—frame
for
gathering data and filing
for site—specific relief.
IPC filed
its First Amendment
to the Petition for Extension of Variance on
February
22, 1990,
along with
a waiver
of hearing and supporting
affidavits, as required by
35 Ill. Adm.
Code 104.124.
The Agency
filed
its Response to First Amendment
to Petition for Extension
of Variance and a Motion for Decision without Hearing on March
2,
1990.
The Agency reaffirmed
its earlier
recommendation and did
not object
to the waiver
of hearing.
The Facility
IPC
is
a public utility based in Decatur,
:llinois.
Its
service
territory includes approximately 15,000 square miles.
IPC employs approximately 4,600 people,
and provides electrical
service
to an estimated 543,000 customers.
IPC owns and operates
a nuclear—fueled electrical generating station located
in
Clinton,
Illinois.
The Station
is designed to produce 933 net
megawatts of
electricity.
In conjunction ‘~~ithconstruction
of
the Clinton Power Station,
IPC constructed Clinton Lake, which
has a total surface area
of 5,000 acres.
This artificial cooling
lake was formed by damming two streams,
Salt Creek and its north
fork,
downstream
of their confluence.
Water
is withdrawn from
one arm of the lake
to cool the condensers and discharged into
the other
arm.
The previously granted variance concerned the
thermal effluent limitations imposed upon this discharge.
Background
In the Board’s Opinion and Order
of August
14,
1975,
In the
Matter
of Water Quality and Effluent Standard Amendments,
Cooling
Lake,
18 PCB
381,
R75—2,
the Board established
a thermal effluent
limit
for the Clinton Power Station of 96°F, subject
to the
variance conditions specified
in IPC
v.
IEPA,
18 PCB
241,
PCB 75—
31 (July
31,
1975).
The effluent standard was modified by the
Board under
the combined dockets R80—17 and PCB 81—82
on May
28,
1981
in IPC v.
IEPA,
41 PCB 501,
PCB 81—82.
The Board also
granted
IPC a provisional variance from the limits set
in PCB 81—
82, since
IPC was unable
to meet the limit
of 99°Ffor
a maximum
of
44 days within
a
twelve—month period because of
a pump
failure.
IPC v.
IEPA,
91 PCB 169,
PCB 88—118
(Aug.
4,
1988).
The Board’s June
22,
1989 Opinion and Order
in PCB 88—97,
describes much of
IPC’s history before the Board,
dating
back
to
1980 for this facility.
In response
to
a
980 petition from IPC,
pursuant
to
35
Ill. Adm.
Code
302.211, the Board issued its Order
dated May 28,
1981, providing
that
the daily average temperature
of discharges should
riot exceed 99°Fduring more than 12 percent
of
the hours
in a twelve—month period
(i.e.,
44 days)
and at
no
time should temperatures exceed 108.3°F.
IPC
v.
IE~A, PCB 88-~7,
100 PCB 177,
178
(June
22, 1989),
citing IPC v.
IEPA,
PCB 81—82,
42 PCB 145
(June
25,
1981);
IPC
v.
IEPA, PCB 81—82,
41
PCB 501
112—374
—3—
(May
28,
1981).
Finding
in
1987
that discharge temperatures were
higher
than anticipated
~or the power levels being experienced,
IPC concluded
that thermal limits would preclude full power
operation of the Stat~onas may be required during dry and hot
summer conditions.
Consequently,
IPC sought
a variance in PCB
88—97, which would increase
the number of days
to 90 days
in a
calendar year where the daily average temperature could exceed
99°F.
Further, assuming the same monitoring point,
IPC sought
to
increase the maximum allowable temperature
level to 110.7°F.
In
that proceeding,
the Agency recommended the grant of variance,
but disagreed with IPC as
to
the extent
of
relief and as
to the
possible environmental impact.
The Agency also requested that
the Board condition
the variance on IPC’s filing
a site—specific
petition by April
1,
1991.
Section
104.121(f)
of
the Board’s regulations,
35
Ill.
Adm.
Code 104.121(f),
requires that an applicant
for
a variance submit
a compliance plan since
the contemplated
relief
is only
temporary.
IPC’s plan
to achieve compliance
in PCB 88—97 was
to
gather data and submit a request for permanent site—specific
relief.
IPC had expected to submit its site—specific petition by
March of
1990.
Other compliance alternatives were considered,
but rejected by IPC as too costly.
One plan involved $13.5
million to Sl6.3 million in capital expenditures and another plan
to derate
(operate below capacity) would have involved
a revenue
loss of
$76.6 million.
IPC v.
IEPA,
100 PCB 177,
180,
181.
Although atypical as
a compliance
plan,
the Board found that
seeking site-specific relies
would be acceptable and explained
its rationale as
follows:
The
prospect
of
filing
for
site-specific
regulatory
relief
does
not
obviate
the
need
for
a
compliance
plan
in
a
variance
proceeding,
however,
the
Board
has
recognized
that
some
factual
circumstances
prompt
scme
flexibility
regarding
this
requirement.
(Anderson
Clayton
Foods
v.
LEPA,
PCB
84—147
(January
24,
1985).)
The Board
has granted a
variance
in
the
absence
of
a
concrete com-
pliance plan
where more
information
regarding
new technology needed
to
be
gathered
in order
to recommend methods
off
compliance or, alter-
natively,
regulatory
changes.
(IL)
Similarly,
the
Board
granted
a
variance
e. en
though
a
petitioner
did
riot
present
a
compliance
plan
where
the
technology
did
not
exist
for
petitioner
to
reasonably
reach
compliance.
(Mobil
Oil Company
v.
IEPA,
PCB
84—37
(September
20,
1984).)
The
Board
concluded
that
the
conducting
of
research
aimed
at
finding
a means
of
coming
into com-
pliance
could
be
accepted
as
a
compliance
I 12—375
—4—
plan.
(Id.)
Lastly,
the Board has recognized
a
rare
exception
to
the
compliance
plan
requirement where
the variance requested
is of
a
limited
duration,
the
environmental
impact
is minimal and petitioner has made good-faith
efforts
to
remain
in
compliance.
(General
Motors Corp.
v.
IEPA,
PCB 86-195
(February
19,
1987).
The
Board
concludes
that,
under
the
instant
ciroumstances,
the
lack
of
a concrete
compliance
plan does
not bar the granting
off
a
variance.
IPC
has
experienced
conditions
at
the Station substantially different
than those
predicted
in
prior
models
and,
as
discussed
below,
has
demonstrated
that
the
expected
adverse
environmental
impact
resulting
from
its
proposed
limitations
is
minima:
and
temporary.
Moreover,
the
parties
agree
and
the
evidence
demor.strates
that
it
is
not
reasonable
to expect IPC to immediately comply
with
the current thermal limits.
IPC v.
IEPA,
PCB 88—97,
100 PCB 177,
181.
The Board
found
that immediate compliance by
IPC would
involve an arbitrary
arid unreasonable hardship since
IPC would
be
required
to “derate” or cut back
its operations
to less than
full
design capacity.
The Board also found
that the higher
thermal
limitation would have minimal
environmental effect for
the short
time periods
involved.
The Board granted
the variance from the
thermal limitations which had been imposed by
the Board Order
of
May
28,
1981
in PCB 81—82,
subject
to the following conditions,
which,
notably,
did not include requiring the filing of a site—
specific petition.
The relevant conditions were:
1.
This
variance
begins
June
22,
1989
and
expires on October
.,
1990;
2.
The
daily
average
temperature
of
dis-
charges
at
the
second
drop
structure
of
the discharge
flume
shall
not
exceed
99
degrees
Fahrenheit
during
more
than
90
days
in
a
twelve—month
period
and
shall
at
no
time
exceed
110.7
degrees
Fahren-
heit during
a fixed calendar
year
running
from January
1
through December
31; and
3.
IPC
shall
monitor
the
temperature
of
water
discharged
from
Clinton
Lake
to
Salt Creek
on
at
least
a daily basis.
112—37E
—5—
IPC v.
IEPA,
PCB 88—97,
100 PCB 177,
187,
188.
Discussion
The variance granted in PCB 88—97 from the thermal standards
established in PCB 81—82 was intended
to give IPC an opportunity
to collect data during the summer of 1989 while operating at full
power and
to prepare statistical thermal data and environmental
information.
This information was
to be submitted as part of
IPC’s petition for site—specific relief.
The filing of the
petition was planned
for March of
1990.
The site—specific relief
was expected
to request the same thermal standards as
the
variance provided.
PC
v.
IEPA,
PCB 88—97,
100 PCB 177,
180.
However,
in
its petition for extension,
IPC asserts that
curtailed operations and unusual weather conditions
in
1989
prevented
the accumulation
off
accurate data
to achieve
this
coal.
The Agency essentially agrees and for this reason both
parties support
an extension of the variance.
LPC would like to have the time to collect data through the
summer
off 1991 and to report its findings to file
its site—
specific petition, and
to make
its
thermal demonstration,
pursuant
to
35
Ill. Adm. Code 302.211(f),
by the fourth quarter
of
1992.
Extending the variance until October of 1993 would be
intended to allow the Board
time
to rule on the site—specific
petition.
The Agency recommends that IPC should be required
to
complete its compilati~noff data and file its site—specific
petition by June of
1992 instead of the fourth quarter
off
1992.
In support of
its position,
IPC’s petition describes
the
unanticipated events of 1989 which prevented the preparation of
meaningful data
for
the site—specific petition.
As one example,
sustained 100
power was not reached until August
8,
1989.
Furthermore, prior
to August
8,. 1989,
the Station was inoperative
for five separate periods.
The time—frames and circumstances
were
as follows:
a)
Jan.
1
—
May
28 first refueling outage;
b)
June
1
—
June
21
failure
off seal on reactor coolant
recirculation pump;
c)
June
28
—
June
30 transformer mechanical problem;
d)
July 14
-
July
26 condenser expansion joint failure; and
e)
July
31
—
Aug.
8 failure
off
relief valve on high
pressure heater.
Outages described above resulted
in much lower monthly average
power
levels
for May through August of
1989 compared with
1988,
1 12—377
—6—
and temperatures were accordingly lower.
Maximum daily average
discharge flume temperatures (flume being
an artificial channel
or
chute
for
a stream of water)
for June,
July, and August
of
1989 were 95°F, 104°Fand 99°Fcompared with the higher
1988
temperatures of 100°F, 106°F, and 108°F, respectively.
Additionally,
on only
9 days
in those months
in 1989 did the
average daily discharge
flume temperature exceed 99°F.
In
contrast,
there were
50 such days
in
1988.
IPC summarized
this
information
in its Table
I,
as
follows:
Clinton Power Station
IPC’s Table
I
Comparison
of Selected Station Ooeratina Data
Month
May
June
July
August
Capacity:
Monthly Average
Power Levels (~)
1988
1989
75
3
88
14
88
53
85
67
Maximum Daily
Average Discharge
Flume Temperatures
(°F)
Monthly Averace
Discharge Flume
Temperatures (°F)
1988
1989
81.7
64.1
93.6
78.0
101.2
89.0
103.0
92.6
No.
of Days on Which
Average
Daily Dis-
charge Flume Temper-
atures Exceeded 99°F
Month
May
June
July
August
1988
1989
92
79
100
95
106
104
108
99
1988
1989
0
0
3
0
23
7
24
2
IPC’s Table II, reproduced below, shows
that,
at
four
different
sites on Clinton Lake,
1988 lake temperatures were
consistently higher
than 1989
lake temperatures.
This data
reflects both milder weather and ooera~ingat
lower levels of
output
in 1989 due
to the several outages at
the Station.
The
sites are marked on
a map incltded in
the petition,
and they do
not include
the point
off discharae.
See Pet.,
Fig.
1.
Standard per Variance:
110.7
110.7
90/yr.
90/yr
112—373
—7-.
Clinton Power Station
Table
II
Comparison
of
1988
and
1989 Monthly Avera~
Clinton Lake Temperatures
(°F)
at Selected Sites
Site
4
Site
8
Site
12
Site
16
Month
1968
1989
1988
1989
1988
1989
1988
1989
May
64.8
62.2
—
62.4
69.1
63.0
66.9
June
76.1
74.1
—-
75.4
81.1
76.5
80.2
77.5
July
81.3
79.7
~—
81.3
85.5
82.8
85.6
82.2
August
83.1
79.0
—
79.9
87.4
82.4
85.5
81.5
Site 4:
Near station cooling water intake structure
Site 8:
Near dam
Site 12:
Offshore fran Mascoutin State Park beach
Site 16:
East of the Illincis Route
48 bridge
The next refueling
outage
is planned
for spring
to
September
of
1990.
IPC anticipates operating
at
71
—
92
power during
the
summer of
1990
in connection with, the planned
refueling outage.
Consequently,
IPC asserts
that reduced operations would distort
the data necessary for IPC to evaluate
the effects
of the
discharge
on the aquatic community of sustained high discharge
temperatures
and
to
record short—term
rnaximurr temperatures.
Pet.,
Fig.
2 and Affidavit of
T.L.
Davis,
p.
2 and Revised
Fig.
2.
The
above information and Tables support IPC’s assertion
that:
IPC has already determined,
based
in part
upon
the
data
set
forth
in
‘lables
I
and
II,
that
the
lake
temperature
data
from
the
summer
of
1989
are
unrepresentative
of
those
expected
during normal
operation
in
a warm
suirrrer,
and
do
not
contribute
significantly
to
IPC’s
assessment of the biological effects
of higher
temperatures
at Clinton
Lake.
Further,
based
on
the
expected
operational
constraints
for
the Station
during
the
summer
of
1990
(see
7
above),
IPC
anticipates
that
lake temperature
data
from
the
summer
of
1990
also
will
be
unrepresentative
of design operaticns.
Pet.,
p.
6.
112—379
—8—
Ha rd
S
h i
p
The Agency agrees with
IPC that
to deny the extension of
the
variance granted
in PCB 88—97 would impose an arbitrary and
unreasonable hardship on
IPC.
In the absence of
the requested
relief,
IPC states the hardship as follows:
tPC may be forced
to derate at the Station,
at
significant
cost
to
IPC,
even though
to
do
so
would
result
in
only
a
minimal,
at
best,
environmental
benefit
to
the
aquatic
com-
munity.
In
addition,
IPC
is
constrained
by
the
presently
applicable
thermal
limits
from
obtaining
additional
site—specific
data
to
support
a thermal
standard for Clinton
Lake.
Pet.,
p.
7.
The Agency notes
that the unanticipated reduction
in power
evels
in
1989 frustrated the principal purpose
off
the variance,
i.e.,
to enable
IPC
to gather
representative data.
The Board finds
that
the hardship established by the record in PCB 88—97
is
ongoing.
The significant costs
of immediate compliance
noted
in
the earlier proceeding would also apply to the present
circumstances.
The Board
finds
that
the delays
in gathering data
are not self—imposed, and immediate compliance would
result
in
arbitrary and unreasonable hardship.
Environmental Impact
In
its petition,
IPC asserts
that the thermal effluent
discharge produces minimal environmental effects.
Pet.,
p.
8.
The Agency responded that
it has
no contrary information, but
that:
the Agency reserves
the
riaht
to revisit
this
variance extension and the underlying variance
should
it
become
apparent
that
an
increased
number
of days
at 99°F is having
an
impact
on
the
lake
which
is
not
at
this
time
anticipated.
Agency Recom.,
p.
4.
The Agency expressed concern that
since
there are only
92
days between June
1 and August
31,
this
“means, effectively,
that
IPC’s thermal
limit
at Clinton
Lake
is 110.7°F.”
Agency Recom.,
p.
4.
This assertion may somewhat overstate
~he problem since
September might
also involve days
off
1-ugh
temperatures.
However,
the Board agrees that some negative environmental impact
could
result.
For
this
reason,
the Agency’s
request
at page
5 of
its
Recommendation warrants special attention:
112—38~)
—9—
(Tihe
Agency
does
not
understand
why
IPC
requires
over
a
year
to
compile
and evaluate
the biological
data
it
anticipates
gathering
in
the
summer
of
1991.
It
would
seem more
reasonable
to
require
IPC
to
have
gathered,
compiled and evaluated
its data by June,
1992,
and
to
file
its
petition
for
site—specific
rule at
that
time.
Agency Recom.,
p.
5.
The Board notes
that
in
PCB 88—97,
the record supported
a
finding
of minimal environmental impact.
The variety and
quantity of fish was acceptable, and sport fishing conditions
were favorable.
However,
the record was somewhat deficient
in
exploring the impact
on the broad spectrum of aquatic
life.
Relying on that record,
which
is uncontroverted here,
the Board
finds
that the risk
of adverse
environmental impact appears
modest and extending the variance would
not pose significant
environmental
risk.
However, more detailed biological data
should be developed as quickly as possible.
Timing of Relief Requested
The requested variance
is intended to supply the above data
for the summers of 1990 and 1991.
How quickly
that data should
be made available
is disputed by the parties.
The Board
is persuaded that the affidavit of James
A.
Smithson, Supervisor—Biological Program of
IPC,
supports
a
finding
that the necessary biological and thermal data could not
reasonably be submitted by
the Agency’s suggested date
in June of
1992.
The Board construes
the Agency’s use of the phrase
“by
June,
1992”
to mean that IPC should gather data and file its
site—specific petition by June
1,
1992.
IPC asserts
that
to do
so would require “sacrificing accuracy and quality”
in the report
of biological data.
See Affidavit,
J.
Smithson,
p.
2.
IPC
asserted through the aforementioned affidavit
that sampling would
still be taken in December
of 1991 and that the biological
evaluation
to be performed would be similar
to a report, which
required approximately 20
overtime per week
for about
six months
by
its biological
staff.
Supra,
p.
2.
To shorten
this time—
frame would
recuire hiring more staff or
excessive overtime.
Supra,
p.
3.
IPC,
therefore,
maintains
that the appropriate
deadline would be
in the fourth quarter of
1992.
The Board construes IPC’s references
to completing
its
reports and
filing for permanent relief
as well
as making
its
thermal demonstration “unti”
or
“by the fourth quarter of 1992”
as meaning
that,
sometime between October
1 and December
31,
1992,
IPC will submit all thermal and biological data along with
112—381
—10—
its petition for permanent
relief and its thermal demonstration
pursuant
to
35
Ill.
Adrn.
Code 302.211(f).
The Board
finds
that October
1,
1992
is an appropriate date
by which
IPC must compile and submit the report covering all
months through December,
1991.
This allows
9 months
in 1992
to
prepare
the report,
which, even with some overtime or
hiring of
additional personnel,
appears reasonable.
The Board will not
impose the June,
1992 deadline based on the affidavits presented
by
IPC,
even though
it acknowledges
the general dissatisfaction
expressed by the Agency.
The Board
finds
that the possibility of
any risk of environmental harm should be assessed as early as
possible and,
therefore,
chooses
the beginning rather
than
the
end of
the fourth quarter.
If IPC~spetition for permanent
relief
is filed by October
1,
1992,
the extension of variance
will continue automatically until October
1,
1993,
which date was
suggested by both IPC and the Agency.
Consistency with Federal Law
Both IPC and the Agency maintain that the Board may grant
the relief requested by IPC or
recommended by the Agency
consistent with the Clean Water Act.
(33 USC sec.
1251 et
Conclusion
The hardship demonstrated
in the variance proceeding,
the
minimal environmental effects, and the unique circumstances of
the 1989 and 1990 operating conditions
support
the requested
extension of variance.
The Board finds
that adequate proof has
been presented that immediate compliance with the thermal limits
entered
in PCB 81-82 would continue
to impose an arbitrary or
unreasonable hardship upon IPC.
Accordingly, the variance will
be extended subject
to
the conditions outlined
in the Order
below.
The Board notes
that its findings in this proceeding for
extension of variance are not binding on any future proceeding
for site—specific relief.
The Board also notes
that IPC may wish
to consider the alternative of
an adjusted standard.
The
permanent relief contemplated
in paragraph
two of
today’s Order
could
take the form of either
a site—specific rulemaking or
an
adjusted standard.
The Board, again, directs
that
in future
proceedings,
IPC address the environmental impact of the thermal
discharges on invertebrates and other vertebrates as well as
sport
fish.
See IPC v.
LEPA,
PCB 87—17,
100 PCB 177,
184.
This Opinion constitutes
the Board’s findings of
fact and
conclusions of law in
this matter.
112—1S2
—11—
ORDER
Illinois Power Company is hereby granted an extension of the
variance granted
in PCB 88—97, Board Opinion and Order of June
22, 1989 from the thermal limitations
imposed
in the Board’s
Order of May
28,
1981
(PCB 81—82) for
its Clinton Power Station
subject
to the following conditions:
1.
This extension
off variance begins October
1,
1990 and
expires
on October
1,
1992;
2.
If IPC submits
a petition
for permanent
relief not later
than October
1,
1992,
this extension of
variance shall
expire on October
1,
1993;
3.
The daily average temperature
of discharges
at
the
second drop structure
off the discharge flume
shall not
exceed
99 degrees Fahrenheit during more than
90 days
in
a twelve—month period and shall
at no time exceed 110.7
degrees Fahrenheit during a fixed calendar year running
from January
1 through December
31;
4.
IPC shall monitor the temperature of water discharged
from Clinton Lake
to Salt Creek on
at least
a daily
basis; and
5.
Within forty—five
(45) days of today’s Order,
Petitioner
shall execute and forward
to:
Illinois Environmental Protection Agency
Enforcement Programs
2200 Churchill Road
Springfield,
IL 62794—9276
a Certificate of Acceptance and Agreement
to be bound to all
terms and conditions of
the granted variance.
This
forty—
five
(45) day period shall
be held
in abeyance
for any period
during which this matter is being appealed.
If
the
Petitioner
fails to execute and forward the agreement
within
a forty—five
(45) day period,
the variance shall
be null and
void.
The form of Certification shall be as
follows:
I12—3~3
—12—
CERTIFICATION
I
(We), __________________________
,
hereby accept and
agree
to be bound by all terms and conditions of
the Order of
the Pollution Control Board
in PCB 89—213, dated June
21,
1990.
Peti tioner
Authorized Agency
Title
Date
Section
41
of the Environmental Protection Act,
Ill. Rev.
Stat.
1987,
ch. lll~, par.
1041, provides for appeal of final
Orders of the Board within
35 days.
The Rules of the Supreme
Court
of Illinois establish filing requirements.
IT
IS SO ORDERED.
I,
Dorothy
M. Gum,
Clerk of the Illinois Pollution Control
Board,
hereby certify that the above-ppinion and Order was
adopted on the
~
.2~I—
day of
__________________
,
1990,
by a
vote of
7--c)
.
.
/1~
/
2~’
~
7).
~
~
Dorothy M./~unn, Clerk
Illinois ~O11ution
Control Board
112—384
