ILLINOIS POLLUTION CONTROL BOARD
December
3,
1967
IN
THE
MATTER OF:
)
VOLATILE ORGANIC MATERIAL
)
R82-l4
EMISSIONS FROM STATIONARY
SOURCES: RACT III
OPINION
AND
ORDER OF THE BOARD
(by
B.
Forcade):
This matter
comes before the Board as part of
a series of
proposed amendments
to
35
Ill. Adm.
Code Part
215, Organic
Material Emission Standards and Limitations,
for the mitigation
of ozone pollution.
All
of the proposed
amendments address some
aspect of
the existing regulations controlling Volatile Organic
Material
(“VOM”) emissions
from coating operations.
The
particular proposal
triat
is the subject
of
today’s Opinion and
Order
is an amendment to Section 215.204
by the Minnesota Mining
and Manufacturing Company
(“3M”) which specifies Reasonably
Available Control Technology
(“RACT”)
for its Bedford Park
Facility (“BPF”).
3M provided
testimony at
the merit hearings on
the Illinois Environmental Protection Agency
(“Agency”) proposed
amendments
to
35
Ill. Adm.
Code 215.204
and 215.207,
as well as
on its own site—specific proposal.
The merit hearings relating
to the
3M proposal were held on March
21, 1986;
August 4, 1986
and September
3,
1986.
Hearings were held
on May
8 and 21,
1987,
to address the Economic Impact Study
(EcIS)
of amendments
to
Sections 215.204 and 215.207 and
to accept final merit
evidence.
3M cross—examined the EcIS contractor
at the May 21,
1987,
hearing regarding
the emission assumptions.
3M has also
provided additional documents
(Exs.
98,
121,
122,
123,
124 and
153)
in support of
its proposal.
On ~iuly 16, 1987,
the Board proposed
regulatory amendments
to Sections 211.122, 215.204, 215.205 and 215.207 for first
notice comment which were published
at
11
Ill.
Req.
12811 and
12835 dated August
7,
1987.
Public comments and responses
to
additional questions
in the August
27,
1987, hearing officer
order were received from the Agency
(P.C.
114 and 119)
and from
3M
(P.C.
118).
On October
1,
1987,
the Board proposed regulatory
language for second notice and review by the Joint Committee on
Administrative Rules
(JCAR).
The Board’s second notice also
denied
3M’s September
22, 1987 request
for extension of the 45—
day first notice comment period.
The Board’s decision was based
on
the Agency’s September 29, 1987 motion
to deny 3M’s request.
The Board decided
that 3M’s request was untimely and its approval
would be unfair since
it would allow 3M an additional opportunity
to comment
on both the proposed amendments
and the Agency’s
timely filed comments.
The Board’s second notice opinion did not
address
3M’s site—specific proposed amendment. The merits
of 3M’s
proposed amendment limiting VOMs
at its BPF will
be addressed
in
tne
instant Opinion
and Order.
84~75
—2—
On November
23,
1987, 3M filed
a letter
requesting
the Board
defer
ruling on this matter
(P.C.
121).
On December
3,
1987,
3M
filed
a Motion to Redocket Site—Specific proposal,
requesting
“the Board
to redocket the
3M site—specific proposal and
incorporate the existing testimony and comments on the 3M cap
into the new docket and defer consideration
of the proposal until
the Board completes
its current RACT
rulemaking agenda.”
That
motion
is denied.
The decision on the regulatory language which
3M
is proposing
is
in fact
a RACT decision.
Section 172 of the
Clean Air Act compels that those decisions be made prior
to
December 31,
1987.
If, after
reviewing this decision,
3M chooses
to file future
requests for site—specific relief,
it
is free to do
so.
3M’s BPF primarily manufactures pressure sensitive
tapes for
industrial
use.
In addition,
a number
of other individual
types
of tape are also manufactured.
In testimony,
it was stated
that
the BPF manufactures 77 individual
types of
tape incorporating
the use of over 100 different types of coatings
(R.
3608).
3M
has been using Section 215.207, which allows volume—based
calculations and averaging across coating lines
(crossline avera-
ging)
to comply with the Board’s existing coating rules.
The
Board’s October
1,
1987, second notice opinion and order
incorporates
the Agency’s proposed amendments to Sections 215.204
and 215.207, which require solids—based calculations and are
in
accordance with USEPA policy.
Because 3M’s BPF would
be affected
by these Agency proposed rules when finally adopted by the Board,
3M proposes
a site—specific alternative
to compliance with
the
Agency’s proposed amendments
using
a solids—based calculation.
3M claims that its proposed rule would ease scheduling
difficulties at the BPF and would result
in less emissions than
would be allowed under
the Agency’s proposed rules
(P.C.
114).
3M claims
it
is complying with Section 215.207
(using cross—
line averaging and volume—based calculations)
on
a daily basis by
prop’er scheduling of
its coating lines.
Some of
3M’s lines are
controlled while others
are not.
The BPF is located
in Cook
County,
a non—attainment area for ozone, and is the largest
single stationary source of VOM in the entire state with
calculated 1985 VOM emissions of over 9,000 tons
(P.C.
113,
Attachment
5,
p.
5).
This represents more emissions than several
major automobile plants
(P.C.
113, Attachment
5,
p.
1).
Implementation of RACT in ozone non—attainment areas
is required
as
a part of
a federally approvable
state implementation plan
(“SIP”)
under the federal Clean Air Act
(“CAA”)
(42 U.S.C.
7401
et seq.).
Section 172 of the
CAA
requires that RACT be
implemented at existing stationary sources
in the non—attainment
areas of those states needing
an extension from the 1982 deadline
until
1987 to achieve the air quality standard for ozone.
Illinois is such
a state, having requested the extension
in its
1979 and 1982 SIPs.
The definition of RACT
is contained
in 40 CFR 51, along with
the requirements for
a federally approvable
SIP.
However,
the
84—76
—3—
specific parameters
of what constitutes
reasonably available
controls,
and,
therefore,
the levels of control which
the states
must adopt
to insure that RACT
is implemented,
are not contained
in federal regulations.
Instead,
the United States Environmental
Protection Agency (“USEPA”) publishes
a series
of documents
entitled “Control Technology Guidelines”
(“CTGs”).
Each CTG
deals with a specific industry category and specifies
the means
and degree of control
applicable
to that
industry category,
vihich
the (JSEPA requires the state
to adopt categorically
as part of
its SIP.
Failure
to adopt rules
identical to
those prescribed
in
the CTG’s,
or other ones demonstrated
by the individual
state
as
comparable,
can mean that the state will have
an inadequate SIP,
which
in turn,
can trigger the sanction provisions
of
the CAA
found
at Sections 110,
113 and 176
(42 U.S.C.A. 7410,
7413,
7506).
Although there
is
no mandate
in the CAA for requiring
the
adoption
of CTGs by
a state,
federal policy as articulated
in the
“General Preamble
for Proposed Rulemaking and Approval
of State
Implementation Plan Revisions for Non—attainment Areas”
(44 FR
20372)
requires it.
In addition,
USEPA allows tne states until
the January after
one year from the finalization of a CTG
to
adopt either
the “rules”
contained therein,
or comparable
rules,
if sources covered by that particular CTG are within a state’s
non—attainment areas
(44 FR 53761;
Ex.
16
& Ex.
132).
The CTG,
which covers 3M’s BPF,
for the paper coating industry was
published
in May 1977 and specifies
a limitation
of 2.9 pounds of
VOM/gallon
of coating
(lb/gal).
This
is RACT for 3M’s BPF.
At the March
21,
1986 hearing
in Bolingbrook,
Illinois,
Mr.
Tom Zosel,
3M, testified
and presented for the first
time,
an
alternative proposed rule
(hereinafter, the initial
3M
proposal)
that would be applicable
to the 3M BPF
(Ex.
98).
The initial 3M
proposal sought
to replace
the rate based RACT limit
of 2.9 lb/—
a1 with
a VOM emissions cap,
at
its BPF,
of 9,000
tons per year
(T/yr) and 75,000 pounds per day (lb/d) from all coating
operations subject
to existing rule 215.207
and all new or
modified paper
coating lines
to be added
in the future.
3M
claims that their proposal
represents
RACT for the BPF.
This
proposal was submitted
by
the Agency to the United States
Environmental Protection Agency
(“USEPA”)
for review.
USEPA did
not view the initial
3M proposal favorably and stated that the
emission limitations proposed by 3M would be
a relaxation
of RACT
level control requirements
(P.C.
113, Attachment
5).
Following
USEPA’s review of
the initial 3M proposal,
the Agency
arid
3M
worked together
to develop
a revised proposal but could not come
to an agreement.
On July 30, 1987,
3M proposed an amended site—
specific rule
(P.C.
114)
(hereinafter,
the amended
3M proposal)
for
its BPF which limits emissions
of VOM from all existing and
new paper
coating lines
to
(i)
8,000 T/yr
and 33.33
T/d after
December
31,
1987,
and
to
(ii) 6,000 T/yr
and 25 T/d after
December
31,
1988.
The amended
3M proposal would
also require 3M
to submit actual
and allowable
(under Section 215.207
(a))
annual
emissions data and
to submit
a corrective plan to the Agency
in
84—77
—4—
the event that actual annual emissions exceed
90 percent
of the
allowable annual emissions.
The only
issue involved in considering the merits of the 3M
proposal
is the determination of whether
the amended
3M proposal
is equivalent
to a 2.9 lb/gal RAC2 limitation.
The following
discussion addresses
this issue,
as well
as
the implications
for
the State of Illinois
if the Board should approve
a non—RACT rule
for controlling VON in
a non—attainment area
for
ozone.
Determination of Equivalence
The initial and amended 3M proposals use the concept of caps
on VOM emissions from the BPF.
This
is a unique approach
in that
it sets the maximum amount of VOM emissions completely
independent of
the level
of production.
Emission limits
(“Caps”)
have been proposed for any one day period,
as well
as
a one year
period.
This
is conceptually different from the rate—based
approach
to VOM emissions control, which simply specifies
the
maximum amount
of VOM that is allowed
in the coatings used.
The
specification of RACT for coating operations has generally meant
the use of the rate—based approach, which specifies
the VOM level
which must not be exceeded.
The RACT
level may be met by the use
of either compliant coatings or add—on controls which reduce
emissions
to
a level
at or below the emissions that would result
from the use of compliant coatings.
In the rate—based approach,
the maximum allowable emissions of VOM are
a function of
the
volume or quantity of coatings used,
which
in turn,
is dependent
on types and quantities of each product manufactured.
In order
to determine
if the amended
3M proposal
is
equivalent
to RACT,
as specified by the
2.9 lb/gal rate—based
limitation,
it
is necessary to
be able
to specify
the following:
1.
Annual
and Daily Caps:
The specification
in
tne amended
3M proposal
is 6,000 T/yr
and
25
T/d beginning
December
31,
1988.
Higher
caps
of
8000
T/yr
and
33.33
T/d
would
be
allowed
during
1988
(P.C.
114).
The
initial
3M
proposal
had caps
of 9,000 T/yr and 75,000 lb/d
(Ex.
98).
2.
Production
and
Emission
Control
Data:
This includes the types
and quantities
of
each
coating
used
to
manufacture
all
products and
the VOM capture
and control
efficiencies
of
any
add—on
control
equipment
on
any
coating
line
at
the
affected
facility
during
the
reference
period
used
for
showing
equivalency.
This
type
of
information
is
generally
available
as
historical
data,
but
will
have
to
be
estimated
for
future
years,
since production levels vary from year
to
84—78
—5—
year.
The
data
provided
by
3M
and
the
Agency
contains
some
of
this
information
(Ex.
98; Attachment
5,
P.C.
113)
3.
Application
of
the Rate—Based
Limitation
to Obtain Baseline Emissions for Compari-
son with the Cap:
Differences
of opinion
exist
with
regard
to
the application
of
the
rate—based
limitation
to
3M’s
BPF,.
One
method
of
applying
the
rate—based
limitation
is
to
require
the
use
of
the
Agency
proposed
Section
215.204
and
require
compliance
on
a
line-by—line
basis.
A
second
method
is
to
allow
crossline
averaging
and
require
com-
pliance
in
accordance
with
the
Agency
proposed
Section
215.207.
With
the
second
method,
it
is
also
necessary
to
know which coating
lines,
if
any,
are not
allowed
to
be
included
in
the
crossline
averaging procedure.
If
none
of
the
coating
lines, had
been
equipped
with
controls,
the appli-
cation of these two methods would require
an
equal
amount
of
emissions
reduction.
But,
in
practice
the
application
of
215.204
on
a
line—by—line
basis
will
result
in
greater
emissions
reductions
than
the application
of
215.207. Section
215.204
would
impose
controls
on
all
of
the uncontrolled lines but will not allow
the
level
of
control
on
overcontrolled
lines
to
be
reduced.
This
represents
(JSEPA’s
view
with
regard
to
application
of
Section
215.204
in
non—attainment
areas
lacking
a
SIP demonstration
(NALD)
(P.C.
113).
In
addition,
the degree
of
control
imposed
on the uncontrolled lines
can also affect
the emissions reductions.
In order
to better understand how differences
in
the method
of application
affects the emissions
at 3M’s BPF and the
difficulties
of
comparing them with the emissions cap proposed by
3M, Table
1
is presented below.
This table
is based
on the table
prepared by USEPA during their
review of the
initial 3M proposal
(P.C.
113, Attachment
5, page
10).
The data used
to develop
the
table comes from 3M and the Agency.
3M estimated
their
1985
emissions at 9,081
T/y.
Because a carbon adsorber was put into
place
in 1986 on one of
the lines, the Agency’s adjusted estimate
for actual emissions
of 7,405 T/y for the period May 1985
to
April
1986
is used
in the
table.
A total
of
11 coating lines
were considered.
Three
of these lines do not have any add—on
controls.
84—79
—6—
Table
1
Conditions
Emissions
(T/y)
Estimated
Reductions*
1. Actual
for period 5/85—4/86
7,405
2.
If
3 uncontrolled lines minimally
complied with 215.204,
controls on
remaining lines were not relaxed,
and
level of production is the same as
for period from 5/65 to 4/86
4,112
3,293
3.
If
3 uncontrolled lines receive 90
control, controls on remaining line
are not relaxed, and level
of produc-
tion is
the same as
for period from
5/85
to 4/86
3,222
4,183
4.
If minimally complying with 215.207
using crossline averaging and
a mass
rate of 2.9 lb/gal,
and level
of pro-
duction is the same as for period
from 5/85 to 4/86
8,329
—
924
5.
Initial 3M proposal with
no
specification on level
of
production
9,000
—
1,595
6.
Amended
3M proposal
for 1988
with no
specification on level
of
production
8,000
—
595
7. Amended
3M proposal after
1988 with
no specification on level of
production
6,000
1,405
*Reductjons are the amounts below the actual of 7,405 T/yr.
Negative reductions are the amounts above
the actual.
Conditions
1,
2,
3 and
4
are the possible emissions
baselines against which
the 3M proposals might
be compared.
However,
these conditions
are directly linked with the level of
production.
Any increase or decrease
in production would
increase or decrease, respectively,
the amounts
of coatings
used.
This
in turn, would increase or decrease, respectively,
the estimated emissions listed
in the table.
Thus, depending on
the cnoice of baseline condition and a specified level
of
production,
the 3M caps
(conditions
6
and
7) may or may not be
equivalent
to RACT.
For the reference period
(5/85
to 4/86)
considered
in the
84—80
above
table,
the emissions allowed under
the Agency’s proposed
215.207
(with crossline averaging)
of 8,323 T/y
(i.e.
Condition
4
in Table
1)
is higher
than the
3M proposed caps of 8,000 T/y
in
1988 and 6,000 T/y after
1988.
However,
decreases
in production
or cnanges
in coating
lines subject
to crossline averaging could
result
in baseline emissions under proposed Section 215.207 that
are below the level
of the 3M proposed
annual caps.
The application of
Section 215.207
to 3M’s BPF requires that
compliance
be shown based
on
a daily average
(R.
5343).
Section
172 of the CAA requires
that RACT be
implemented
in non—
attainment areas by December
31,
1987.
USEPA’s interpretation of
this requirement is reflected
in
its policy that also requires
compliance with
RACT
on the basis of
a 24—hour averaging period
(Ex.
99).
3M’s amended
proposal provides
a daily cap of 33.33
T/d
in 1988 and
25 T/d after
1988.
In order
to calculate
baseline emissions for comparison with these proposed daily
caps,
the
level
of production and determination
of the coating lines
subject to crossline averaging
is required.
Since
3M has not
provided sufficient
information
to calculate baseline emissions
on a daily basis,
the Board cannot determine
if the daily caps
are better than RACT.
Thus
it becomes clear
that the
concept of an emissions cap,
without being
linked with
a specific production level,
as
presented by 3M, cannot
be evaluated
on a comparative basis with
a RACT level
which
is based
on the rate based concept.
It
is
analogous
to comparing apples with oranges.
Thus,
the
3M
proposed caps would have to be viewed as having been made
arbitrarily just to provide them witn
the flexibility needed
to
accommodate
the scheduling difficulties that they face.
The
Board must conclude that the amended 3M proposal
is not RACT.
The Board’s conclusion
is
supported
in the record by the
following statements made by USEPA regarding
the 3M proposal:
1.
“If
production
will
in
fact
rise
at
the
plant,
Illinois
could
place
a
cap on
the
company
in addition
to
retaining
the
2.9
lbs/gal
rate
limit.
There
are no assur-
ances
there
will
be
such growth
and
any
company chould
(sic)
use
this
same logic
when
requesting
a
bubble
or
SIP relaxa-
tion.
If
approved,
EPA
would
be per-
ceived
as
granting
‘emission
rights.’”
(P.C.
113, Att.
5,
p.
2)
2.
“All
of
EPA’s
past
SIP
policy
has
been
that emission
limits should
be on
a rate
basis.
SIP’s
do
not
normally
regulate
production.
If
production
goes
up,
sources
are
allowed
to
emit
more.
If
production
goes
down,
the
source
must
emit
less.
This
eliminates
any
credit
84—81
—8—
for
downtime
or
reduced
capacity.
The
EPA’s
control
technique
guidelines
gen-
erally specify
limits
in
terms
of
a rate
or percent reduction.
If production does
(sic)
down,
a source cannot turn off con-
trol
equipment
such
as
an
afterburner
or
carbon
adsorber
nor
can
the
source
in-
crease
its
pounds
of
VOC
in
each
gallon
of
paint
coating,
or
ink
if
it
paints
less.
3M’s proposal
is
not RACT because
three
lines
are
not
controlled.”
(P.C.
113, Att.
5,
p.
9)
An additional concern with 3M’s amended proposal with regard
to the annual caps is that USEPA’s policy prohibits averaging
periods longer than
30 days
(Ex.
99(b)).
“Extended
averaging”
is
defined
by USEPA as greater
than 24—hour averaging
(Ex. 99(b)).
Extended averaging
is prohibited
by USEPA policy “unless
it can
be shown
that compliance
on
a daily basis
is not technically or
economically feasible”
(Ex.
99(a)).
No such showing has been
made
in this case
(P.C.
113,
Att.
5,
p.
9).
In addition, USEPA’s
policy “prohibits extended averaging
in areas lacking approved
SIP’s until
the SIP has been revised demonstrating ambient
standards attainment and maintenance
of reasonable
further
progress (reflecting the maximum daily emissions
from the
source)”
(Ex.
99(a)).
As already noted,
the
3M plant
is located
in an area which
lacks
an approved 1982 ozone SIP.
Although 3M’s amended proposal contains caps on
a daily
basis,
the Board has several
additional concerns with the
proposed daily caps.
One concern
is that
the daily caps are not
equivalent to the respective annual caps.
The daily cap
in the
amended
3M proposal
is 33.33 T/d for 1988.
The annual cap for
1988
is 8,000 T/yr.
The plant
is
in operation
a minimum
of 360
days per year
(Tr.
5311).
Therefore,
based
art
the annual cap,
which
is considered
to be RACT by
3M, and 360 days
of operation,
the “daily cap equivalent
of RACT”
is 22.22
T/d.
It appears that
the proposed daily cap of
33.33 T/d exceeds
the “daily cap
equivalent of RACT” by
50.
Another concern regarding the proposed
daily caps
is that 3M
has never focused on whether these caps would be RACT.
In fact,
it appears
that
the intent
of 3M’s proposal
is for the yearly,
and not the daily,
caps to
be consistent with RACT
(Ex.
99(a)).
3M has never argued that use
of the daily caps would
improve
the
environment.
Since Section
172 of
the CAA requires implementation
of RACT
by December
31, 1987,
the Board would have to conclude
that RACT
for the 3M BPF
is 33.33 tons per day under
all operational levels
in order
to approve
the site—specific rule.
There is no evidence
in the record
to support
a 33.33 ton per day limit as constitut-
ing RACT for 3M at all operational levels.
0I
‘•~
o’*. ~u
—9--
In addition,
no showing has been made that the use of
control equipment and/or compliant coatings
is technically
infeasible
or economically unreasonable
(P.C.
113, Att.
5.,
p.
9).
The record
is void
of such arguments.
In fact,
3M has
indicated through its agents that
it would comply with the
Agency’s proposed Section 215.207
(Tr.
5339;
Tr.
5340; P.C. 114;
&
P.c.
118).
Generally,
the Board grants site—specific relief
from the requirements
of general
regulations only upon
a showing
that
it
is not technically feasible or economically reasonable
to
comply with the general regulations.
A recent appellate court
decision has upheld this standard.
In Central Illinois Light Company
v.
Illinois Pollution
Control Board,
No. 3—86—0841
(3d Dist. July 24,
1987),
the Third
District affirmed the Board’s denial
of
a site—specific ru’e—
making proposal of Central Illinois Light Company
(CILCO).
CILCO argued on appeal
that the Board
did not properly apply the
statutory criteria
in its evaluation of the record.
The Third
District rejected this position and stated:
After
a
thorough
review
of
the
evidence
presented
at
the
hearing
in
this
case,
we
conclude
the
Board’s determination
that CILCO
failed
to
demonstrate
compliance
is
tech-
nically
infeasible
and economically unreason-
able
are
amply
supported
by
the
record.
As
the
Board
pointed out
in
denying
a motion by
CILCO
for
a
rehearing,
these
determinations
regarding
technical
feasibility
and
economic
reasonableness alone are sufficient
to support
the decision of the Board.
(Id.
slip op.
at
10).
The Board believes the rationale for the CILCO decision
is
equally applicable here.
Since
3M has not demonstrated that
compliance with the Agency’s proposed amendments
to
35 Ill. Adm.
Code Part 215
is technically infeasible or economically
unreasonable, the request for site—specific standards will be
denied.
The Board also recognizes that the December
31,
1987,
deadline for ozone non—attainment areas
is fast approaching and
failure to meet the Clean Air Act’s requirements for ozone
attainment could have serious consequences for Illinois.
Some of
these potential consequences are as follows:
‘The Board notes that CILCO has filed
a Petition for Leave to
Appeal the Third District’s decision with the Supreme Court of
Illinois.
That petition
is currently pending under Supreme Court
Docket No.
65777.
84—83
—10-
1.
In
accordance
with
Section
110
of
the
CAA,
the USEPA Administrator may prepare
and publish
proposed
regulations
setting
forth
an implementation plan for ozone
in
Illinois’ non—attainment areas;
2.
In
accordance
with
Section
113
of
the
CAA,
the
(JSEPA
may
assume
federal
en-
forcement
of
its
implementation
plan
in
Illinois;
3.
In
accordance
with
Section
176
of
the
CAA,
the administrator may decide not
to
approve
arty projects
or
award
any grants
authorized
by
the
CAA
for
the
state
of
Illinois;
and
4.
In
accordance
with
Section
176
of
the
CAA,
the Secretary of Transportation may
decide
not
to
approve
any
projects
or
award any grants
for Illinois under Title
23
other
than
for
safety,
mass
transit,
or
transportation
improvement
projects
related
to
air
quality
improvement
or
maintenance.
The Board has given serious consideration
to the amended 3M
proposal and acknowledges that the proposal has benefits, but
only under
certain conditions.
Should production increase, a cap
on emissions
is likely
to
increase the benefits to
the
environment.
However, the amended
3M proposal completely
uncouples emissions limitations from production levels in order
to have flexibility
in production scheduling.
Unfortunately,
3M
has not presented sufficient information to convince the Board
(1) that compliance witn
the Agency’s proposal
is technically
infeasible
or economically unreasonable or
(2)
that their
proposed site—specific
rule is equivalent
to or superior
to
RACT.
Therefore,
the Board denies
3tl’s amended site—specific
proposal.
Section 41
of the Environmental Protection Act,
Ill. Rev.
Stat.
1985,
ch.
111—1/2, 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
84—84
—11—
I,
Dorothy
4.
Gunn,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
certif~
that
the
ab~e
Opinion
and
Order
was
adopted
on
the
3A~-~dayof
/J.?.t.~t_~v..S.*~’i.’
,
1987,
by
a
vote
of
7—a
Dorothy
M.
Gunn,
Clerk
Illinois
Pollution
Control
Board
84—85
