ILLINOIS POLLUTION CONTROL BOARD
August
6,
1987
IN THE MATTER OF:
PROPOSED AMENDMENTS
TO 35
ILL. ADM. CODE
)
R 86—17(A)
304.120, DEOXYGENATING
WASTES STANDARDS
ADOPTED RULE.
FINAL ORDER.
FINAL OPINION AND
ORDER
OF THE BOARD
(by 3. Marlin):
This matter
comes before the Board upon
a proposal
by the
Illinois Environmental Protection Agency
(Agency)
to amend
35
Ill. Adm. Code
304.120, Deoxygenating Wastes,
filed with the
Board on April
23,
1986.
Hearings on
this proposal were held by
the Board on June
24,
1986 at Peoria
(generating
a transcript
hereinafter referred
to as
RI)
and June 27,
1986 at Effingham
(generating
a transcript hereinafter referred to
as Ru).
On
January
5,
1987, the Department of Energy and Natural Resources
(DENR)
filed with
the
Board
its negative declaration.
The DENR
stated that “tihe
net economic
impact of the regulation is
favorable and the costs of compliance are small
or are borne
entirely
by the
proponent of
the regulation.”
The Economic and
Technical Advisory Committee concurred with DENR’s finding that
economic impact studies were not necessary in this matter.
By
a
letter dated December
15,
1986,
DENR requested that
the
record
in
this matter
remain open until
January
23,
1987 so that
DENR
could
submit two exhibits which would
“aid
the Board in its
deliberations.”
By
a Hearing Officer Order dated December
19,
1986,
the
record was held open until February
25,
1987 to allow
interested persons
to comment upon
the two DENR exhibits which
were filed with
the Board on January 23,
1987.
By its Order of March
5,
1987,
the Board sent part of
the
Agency’s proposal to First Notice and opened Docket
B
to consider
the remaining aspects of
the
Agency’s proposal.
The Board’s
proposed rule appeared
in the Illinois Register on March
27,
1988.
11
Ill. Reg.
5011.
During the First Notice period, the Board received one
public comment concerning the proposed rule.
Citizens Utilities
Company of
Illinois
(Citizens)
filed
a comment on April
24, 1987,
which requested that the Board’s proposed rule include wastewater
treatment works
of investor—owned utilities.
That is, Citizens
would
like privately owned treatment facilities
to qualify for
a
lagoon exemption if
it has
an untreated waste load between 2500
and 5000 population equivalents.
The rule applies only
to
a
publicly owned treatment works
(POTW).
The Board notes
that
Citizen’s comment merits consideration, and the Board
will
explore this issue
further under Docket B.
80—237
2
On May
28, 1987,
the Board adopted
the proposed rule for
Second Notice.
The Second Notice period began on June 10.
On
July
22,
the Joint Committee on Administrative Rules voted an
objection to the proposed rule because of
the Board’s failure to
provide “adequate standards used
to determine when a publicly
owned treatment works has reached the end
of its
‘useful
life’.”
In response to that objection, the Board has modified
the previous version of the rule so as
to include an additional
subsection further defining the
term useful life.
The Board will
adopt,
as final,
this modified version
of the rule.
The Agency proposal essentially requests that the Board
expand
the lagoon exemption
of Section 304.120 to include
publicly owned treatment works
(POTW) whose untreated waste load
is
less than or
equal
to 5000 population equivalents
(p.e.).
The
current regulation allows an exemption for any waste treatment
facility whose untreated waste load
is less than 2,500
p.e.
provided other exemption requirements are satisfied.
The current
and proposed
lagoon exemption applies only to effluents whose
dilution ratio
is less than five
to one.
If
a facility qualifies
for
an exemption,
it is exempt from the requirements that the
effluent not exceed
10 milligrams per liter
(mg/l) biochemical
oxygen demand
(BOD5)
as well as
12 nig/l
suspended solids.
Instead, the exempted facility would be subject to limits
of
30
mg/l BOD5 and
37 mg/i suspended solids.
The Agency proposal changes the requirements for
a source to
qualify
for such
an exemption.
Under the proposal, several
of
the current exemption requirements are unaltered.
First,
a
source must employ third—stage treatment lagoons.
Secondly,
the
lagoons must be properly constructed, maintained and operated.
Also,
in order
to qualify for an exemption,
an effluent’s
deoxygenating constituents must not, alone or
in combination with
other sources,
cause
a violation of the applicable dissolved
oxygen standard.
The Agency’s proposal
seeks
to change the
requisite factors dealing with population equivalents.
The
language of the proposal requires that the source qualify under
one of the following three categories.
1)
Any wastewater
treatment works whose untreated waste
load is less than 2500 p.e.
and
is sufficiently isolated
that combining with other sources to aggregate 2500 p.e.
or more
is not practicable.
2)
Any publicly owned treatment works
in existence on
January
1,
1986 whose untreated waste load is 5000 p.e.
or
less and sufficiently isolated that combining
to
aggregate 5000 p.e.
or more
is not practicable.
3)
Any publicly owned treatment works whose untreated waste
load
is 5000 p.e.
or less which has reached the end
of
its useful life and
is sufficiently isolated that
combining
to aggregate 5000 p.e.
or more
is not
80—238
3
practicable.
The current regulation contains only the first category.
It
is the Agency’s position that
a p.e. maximum of
5000
equates with the concept of
a small
town lagoon exemption better
than the current maximum of
a 2500 p.e..
According to the
Agency,
POTW’s serving communities with
a population greater
than
5000 generally do not utilize lagoons.
(R
II.
5,
48).
The Agency asserts that the alternative
to lagoon use
is
the
employment of mechanical treatment systems, such
as an activated
sludge filter system.
Mechanical treatment systems have
the
ability
to produce an effluent that
is within 10 mg/i DOD5 and
12
mg/I suspended solids.
However,
the Agency states that small
towns often do not operate these systems properly and that as
a
result performance levels decline.
(R
II.
13).
On the other
hand,
the Agency asserts
that
lagoon systems,
although often not
capable of maintaining 10/12 standard, are more forgiving when
subject
to less than adequate operational attention.
That is,
the lagoon system provides
a more consistent and stable
performance with
a less than sophisticated operator.
(R II.
24—
5).
The mechanical
treatment systems are generally more
expensive to build and operate than lagoon systems.
The Agency
claims that the current exemption limitation of 2500 p.e. does
not take into account the economic hardship of small communities
which are faced with utilizing the more costly mechanical
treatment systems
in order
to achieve the 10/12 standard.
According to
the Agency,
the communities between
a 2500 and 5000
p.e.
level were once able
to take advantage
of federal and state
grants.
However,
the Agency states
that such grants have dried
up and that only low interest loans
are available for
these
communities.
As
a consequence, communities within
the 2500
to
5000 p.c.
level must now bear the full capital and operational
costs
of
their wastewater treatment systems.
(R
I.
6).
It
is the
Agency’s position that the economic burden of requiring
communities of 5000 p.c. and under
to utilize mechanical
treatment facilities
is unjustified.
The Agency believes
that
5000 p.c.
is
a logical upper limit for the lagoon exemption since
almost all POTW’s treating more waste have chosen mechanical
systems, probably due
to economies
of scale.
(R II.
48).
The Board notes that the Agency’s proposal would not exempt
private wastewater
treatment works which operate at levels
between 2500 and 5000 p.c.
The current regulation allows an
exemption for private facilities that operate below 2500 p.c.
It
is the Agency’s position that an exansion of
the exemption for
private facilities
is unnecessary.
According to the Agency,
the
private facilities have had
a better compliance record when
compared with POTW’s of
similar size.
The Agency also states
that the technical ability
of the private operators as well as
the private facilities’
ability
to pass cost on to the customer
80—239
4
are important factors which distinguish private wastewater
treatment works from POTW’s.
Therefore,
private facilities are
not
included in the Agency’s proposed expansion of
the lagoon
exemption.
(R I.
21—2).
The Board will further address this
issue
in
Docket
13.
The Agency filed with the Board a United States
Environmental Protection Agency (U.S.EPA)
response to the
Agency’s proposal.
In
a letter
to the Agency dated August
12,
1986,
the U.S.EPA states,
“Our review of the prepared amendments
indicated
that overall,
the changes should not result
in any
conflicts with applicable Federal regulations.”
(P.C.
#9).
Economic Impact
At hearing,
the Agency stated that there were 15 communities
presently utilizing lagoon systems which would
immediately
benefit from the proposed rule change.
(RI.16; RII.ll;
Ag.
Exh.
#8).
After
the hearing,
the Agency submitted data to the Board
which indicates that
21 communities would be
“eligible
to apply
to
a lagoon exemption immediately upon the adoption
of the
proposal.”
The Agency indicated that two of
these communities
are currently using mechanical treatment systems.
(P.C.
#2,
Attachment
1).
By including these two communities
on such
a
list,
the Agency implies that the mechanical treatment systems
of
these two communities are currently at the end of their useful
lives.
Other data presented by the Agency indicates that
approximately 144 other communities, currently using mechanical
treatment systems, would qualify for an exemption under the
Agency proposal once the systems
reach the end of
their useful
life.
The Agency notes that some
of these facilities may be
consolidated with other plants
or expanded
so as
to remove them
from exemption eligibility.
(P.C.
#2, Attachment 2).
The
following economic data comparing the cost of compliance with and
without the proposal were also supplied by the Agency as well as
by testimony at the hearing.
80—240
5
Compliance Cost
Compliance Cost
Without
the
Proposed Exemption
With the Proposed Exemption
POTW
Monthly House
Monthly House
Discharger
Capital
OM&R
Hold Cost
Capital
OM&R
Hold Cost
Aledo
$2,509,000
108,000
1,910,000
50,000
Christopher
2,800,000
————
16.78
800,000
9.55
(Would receive $1.4 million
grant from EPA)
Coal City
3,206,000
166,700
68.95*
757,000
62,400
31.23*
Gillespie
2,991,000
826,000
110,000
Johnston
City
2,500,000
800,000
Kincaid
3,000,000
703,000
45,000
McLeans—
boro
**
1,500,000
41,500
16.50
1,000,000
25,800
11.00
New Baden
1,500,000
141,000
260,000
71,000
Staunton
3,800,000
192,000
2,000,000
79,000
Virden
**
5,012,000
2,840,000
*
:
(for
20 years)
**
:
Denotes current mechanical plant.
Denotes Data Not Presented.
(P.C.
#2 Attachment
1;
RI.
29;
RIl.
31
RII.
38; RII.
43)
It
is clear that the communities listed above would save
a
considerable amount of money
if the Agency’s proposal
is
adopted.
If such costs are representative,
the proposal,
if
adopted, would eventually result
in a savings to over one hundred
communities.
As previously stated, DENR has concluded that the
net economic impact
of the proposed amendement would
be
favorable.
Environmental Impact
It
is the Agency’s position that mechanical systems,
such
as
activated sludge systems and trickling filters,
generally show
“more identifiable
impact and detriment than properly designed
and operated lagoon systems.”
According to the Agency, this poor
performance level
of mechanical
systems
is primarily due
to plant
80—241
6
upsets,
solids washout,
and difficulties
in achieving stable and
consistent ammonia
reduction.
(Rh.
10).
Consequently,
the
Agency concludes that “lagoons may
be more protective
of
receiving stream water quality than mechanical facilities.”
In
support of this conclusion, the Agency refers the Board
to Stream
Surveys
it has provided.
(P.C.
#4).
Attached
to the stream surveys are NPDES monitoring data
reports
for the years
1983 through
1985.
These
reports present
data on the quality of the POT~effluents over
three years.
On
the other hand,
the stream surveys of the same POTW’s did not
always sample
the effluent for BODç and suspended solids.
Even
when the effluents were sampled,
tFie results merely represent the
quality of the effluent at one point
in time.
Consequently,
the
data shown below is taken from the NPDES monitoring reports.
The
figures presented
are averages of the yearly average for the
years
1983,
1984 and 1985.
Flow
BOD5
Suspended Solids
Discharger
(MGD)
(rng/l)
(mg/l)
Mechanical Systems
Walnut
0.20
15.0
18.0
Lake County,
Sylvan—Diamond Lake
0.26
18.7
14.3
Red Bud
0.51
5.7
9.0
Bushnell
0.57
11.3
7.0
Lagoon Systems
Greenfield
0.21
8.7
13.0
Mount Sterling
0.47
11.3
21.7
Breese
0.53
2.3
9.7
(P.C.
#2)
A flow rate range from
.25 to
.50 million gallons per day
(MGD)
roughly represents
a population equivalents
range of
2500
to 5000.
(P.C.
#2).
The Board notes that at hearing the Breese
facility’s near—compliance performance level was classified
as an
exceptional case among lagoon systems. (Rh.
45).
The record does not indicate how or why the seven plants and
the associated stream surveys were selected from the universe of
available facilities.
The Board does not know
if these are
representative of the facilities and streams that may fall under
the proposed rule.
The record would also have benefited
from a
more complete discussion of
the various design configurations
80—242
7
that lagoon and mechanical plants may use and the capabilities
and costs
of each.
The information provided does not
conclusively support the Agency’s contention that lagoons
generally have less adverse impact on receiving streams or
that
lagoons cannot produce effluent of
a better quality than 30/37 on
a consistent basis.
Agency data show that the performance levels vary
considerably between POTW’s of the same system type and size,
as
well
as across system types.
It
is also apparent that with
regard
to these facilities neither
system type consistently out
performs the other.
The proposed
rule,
as well as
the current
regulation,
provides that no exemption may be granted
to
a facility
if the
discharge
from that facility,
alone
or
in combination with other
discharges will cause
a violation of the applicable dissolved
oxygen water quality standard.
DENR points out that the
environmental impact
of
a lagoon exemption will vary from site
to
site.
(DENR Exh.
#1, p.3).
DENR asserts that the Agency’s
modeling techniques
do not adequately take into account such
factors
as sediment oxygen demand and algal respiration.
Consequently, DENR concludes that the Agency will always
overestimate the existing dissolved oxygen content of
a stream.
Such
a situation would lead
to an inaccurate evaluation of
whether water quality standards will
be violated by
a POT~1
exemption,
according to DENR.
DENR requests that the regulation
include methods of calculation
to ensure that dissolved oxygen
standards are not violated by POTW exemptions.
(DENR Exh.
#1,
p.
11).
The foundation
for the proposal
is the Agency’s view that
POTW’s treating
a load less than 5000 p.c.
can neither
afford
to
utilize nor properly operate mechanical systems to meet the 10/12
standard.
Therefore,
the Agency concludes that these POTW’s
should be allowed
to utilize lagoon exemptions.
The Agency
presumes that the only viable option for these POTW’s
is
a lagoon
system and less stringent effluent limitations.
DENR submitted
a
report which concluded that land treatment systems could provide
an alternative for wastewater treatment.
The report states that
any point discharge from
a land treatment system would be well
within the 10/12 standard.
In many instances,
a land treatment
system would have no point discharge.
(DENR Exh.
#2,
p.
1—2,
3—
2,
3—20).
The report makes
a strong case for land treatment
systems.
Such systems would store effluent in lagoons
for later
application to land.
It
is also possible
to develop
a hybrid
system which would discharge to streams during high flow and
irrigate land during the growing
season. The effluent can be
spread
by
a number
of methods including standard agricultural
irrigation systems.
The table below given approximate lagoon
size and the land required for
slow rate application.
The
information
is derived from DENR Exh.
#2,
pp.
3—27 and 4—6.
80—243
8
Wastewater Flow Rate
(MGD)
Storage Lagoon
Land for Application
0.1
2.18 acres
38.4 acres
0
2
4
36
“
76
8
0
3
6.54
“
115
0.4
8.70
“
154
0.5
10.9
“
192
The Agency responded
to this report in
a cursory fashion,
characterizing land treatment
as
a technology that has
consistently failed
to be adopted by consulting engineers and
their clients.
The DENR report raises issues which the Board
would like see expanded upon.
Specifically, what economically
reasonable alternatives are available
for POTW’s
to treat
wastewater
and what standard could
they meet.
This topic will
be
discussed further under Docket
13.
S
U
mrnary
It
is clear that the net economic effect of expanding the
lagoon exemption would
be positive.
Many communities would save
considerable amounts of money
by being allowed
to utilize lagoons
to meet
a 30/37
rather than
a 10/12
standard.
However,
the Board
is disappointed by
the
quantity and quality of data presented by
the Agency concerning
the costs and capabilities
of various
treatment alternatives and the environmental impact
of the
proposal.
According to the Agency’s own figures, over 150
communities could eventually take advantage of
this proposed
expansion of
the lagoon exemption.
The Agency has given
the
Board effluent information on only seven POTW’s.
If data
presented at hearing
by Coal City
is counted,
the Board has
before it effluent information from eight POTW’s.
Although the Agency proposal
is written
so that no exemption
will be granted which would result
in
a violation of dissolved
oxygen standard,
the Agency proposal could
still result
in
a
decline
in
the quality of
the receiving streams.
Given the
record,
it
is impossible
for the Board
to assess the
environmental
impact that will
result
if up to 150 communities
switch
to lagoon systems.
The Clean Water Act requires all POTW’s
to be
in compliance
with effluent limitations by July 1,
1988.
The Board recognizes
the urgent need for
a number of POTW’s
to ascertain whether or
not they will qualify for an exemption so that they may alter
their operations accordingly
in order to achieve compliance by
the deadline.
It
is apparent that many communities presently
need relief
so that their compliance will
be assured by July 1,
1988.
However,
the record
is insufficient to support the full
extent of
the exemption proposal requested by the Agency.
As
a
result, the Board will allow lagoon exemptions
for those POTW’s
treating
a load of less than 5000 p.c.,
which are presently
utilizing lagoon systems
or which have
a system that has reached
the end of its useful life by January
1,
1987.
Such action will
80—244
9
essentially preserve
the
status quo regarding impact on streams
while allowing communities to take advantage of the coming
construction season.
Due
to the unresolved questions in this record,
it
is
necessary for the Board to consider under
a separate docket the
proposal for expanding the lagoon exemption to
those non—lagoon
facilities which have not reached the end of their useful lives
by January
1,
1987.
This docket allows the Agency and the
public,
including DENR,
to provide information
on
a number
of
topics including whether well designed and run lagoon systems can
produce an effluent
of better than 30/37 quality;
the costs of
various
treatment alternatives;
the practical feasibility of
using land treatment
in Illinois alone or
in combination with
other methods;
and the impact
of various systems on streams.
In P.C.
#6,
the Agency questioned the propriety of DENR
filing
its exhibits
#1 and
#2 after
issuing
a negative
declaration.
The concern would appear
to be that the exhibits
could
lead
to
a modified proposal with altered
economic
impact.
In
this matter,
the Board
has already opened Docket
B based on
a
desire for an expanded record.
The stated concern will,
therefore, not impact Docket A.
The type of information
contained
in the two exhibits
is most helpful
to the Board
in
reaching informal decisions on complex rules.
The Board
encourages DENR and other
knowledgeable persons
or entities
to
participate
in the regulatory process.
The Board specifically
notes that DENR’s ability
to participate
is by no means limited
to its EcIS function.
That function
is separate from its
right
to provide such technical
input to the process as it deems
appropriate.
DENR
is diverse and includes the Scientific Surveys
as well
as the remnants
of the Institute for Environmental
Quality which was originally mandated
to among other things “give
expert guidance
to
the
Agency
and
to
the Board
in the formulation
of
regulations”.
Ill Rev. Stat.
1975,
ch.
1111/2,
par.
1006.
Technical input
to
a proceeding,
such
as that contained
in the
two exhibits,
is appropriately introduced at hearing and may be
considered
in the EcIS process.
Such information
is generally
presented by DENR personnel while
the EchS
is often prepared by
outside consultants under contract.
The Board recognizes the
potential problems associated with the timing
of the filing
in
question and the fact that the exhibits were not discussed at
hearing.
However,
the Agency and other participants did have 30
days to comment on the two exhibits.
The coming hearings
in
Docket B will provide the opportunity
to correct any problems
that would otherwise exist because of the lateness of the
filings.
As stated earlier, DENR requests that the Board include
in
the regulation modeling methods to ensure that dissolved oxygen
water quality standards
are not violated by the lagoon
exemptions.
DENR claims that
the modeling methods used by the
Agency overestimate the dissolved oxygen content of the
streams.
Such modeling techniques are certainly within the field
80—245
10
of the Agency’s expertise.
The Board will defer
to the Agency’s
technical expertise
in choosing the proper
modeling method
in
Docket
A.
The issue
can be explored on the record by all
participants
in Docket
B.
ORDER
In response to the objection of the Joint Committee on
Administrative Rules,
the Board hereby modifies its rule to add
subsection
(f)
and directs the Clerk
to cause the publication of
a notice
of this response in the Illinois Register.
Section 41 of
the Environmental Protection Act,
Ill.
Rev.
Stat.
1985 ch.
11?
½
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.
The Board hereby directs
the Clerk
to cause the filing of
the following final,
adopted rule with the Secretary of State.
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE
C:
WATER POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
PART 304
EFFLUENT STANDARDS
SUBPART
A:
GENERAL EFFLUENT STANDARDS
Section 304.120
Deoxygenating Wastes
Except as provided
in Section 306.103,
all effluents containing
deoxygenating wastes shall meet the following standards:
a)
No effluent shall exceed
30
ing/l
of five day biochemical
oxygen demand
(BODç)
(STORET number 00310)
or 30 mg/l
of
suspended solids (~TORETnumber 00530), except that
treatment works employing three stage lagoon treatment
systems which are properly designed, maintained and
operated, and whose effluent has
a dilution ratio no
less than five
to one or who qualify for exceptions
under paragraph
(c)
shall not exceed
37 mg/i of
suspended solids.
b)
No effluent from any source whose untreated waste load
is 10,000 population equivalents
or more,
or from any
source discharging into the Chicago River System or
into
the Calumet River System,
shall exceed
20 mg/i of BaD5
or
25 mg/l
of suspended solids.
c)
No effluent whose dilution ratio is less than five
to
one shall exceed 10 mg/l
of BOD~or
12 mg/i of suspended
solids, except that sources employing third—stage
treatment lagoons shall
be exempt from this paragraph
(c) provided all
of the following conditions are met:
80—246
11
~
The ~nea~e~
was~e~ea~ ~s ~ess than ~SO9
pep~m~4~ert
e
a~eri~s~nd
1)
The waste source qualifies under one
of the
following categories:
A)
Any wastewater treatment works with an
untreated waste
load less than 2500 population
equivalents, which
is sufficiently isolated
~Ehatcombining with other sources
to aggregate
2500 population equivalents or more is not
practicable.
B)
Any publicly owned
treatment works
in
existence on January
1,
1986 whose untreated
waste
load
is 5000 population equivalents
or
less and sufficiently
isolated that combining
to aggregate
5000 population equivalents or
more is not practicable.
C)
Any publicly owned
treatment works with an
untreated waste
load of 5000 population
equivalents or
less, which has
reached
the end
of
its useful life
by January
1,
1987, and
is
sufficiently isolated that combining
to
aggregate 5000 population equivalents
or more
is not practicable.
~s s
~e4~en~ry ~se~a~ed ~ha~ eemb~n4r~gw±4~h
other
sei~n=ees~e e~g~ega~e
~5OO pepe~a~4orie
a~en~se~
mere 4s ne~p~ae ea~ei-and
32)
The lagoons are properly constructed, maintained
and operated; and
43)
The deoxygenating constituents of
the effluent do
not, alone
or
in combination with other sources,
cause
a violation of
the applicable dissolved
oxygen water quality standard.
d)
No effluent discharged
to the Lake Michigan basin shall
exceed
4 mg/i
of BOD5 or
5 mg/i of suspended solids.
e)
Compliance with the numerical standards
in this Section
shall
be determined on the basis
of the type and
frequency of
sampling prescribed by the NPDES permit for
the discharge
at the time
of monitoring.
f)
For
the purposes of this Section,
useful life
is the
period
of time during which
it
is cost effective
to
operate and maintain
a particular wastewater
treatment
works under consideration.
At
a minimum,
the followin~~
80—247
12
factors re1atir~y to
a wasiewater
treatment works
shall
be
considered
in
a determination of
its useful
life:
1)
Structural and oFerational condition
of components
2)
Past operations
and maintenance
record
3)
Cost for continued
use;
and
4)
Description and costs
for
treatment alternatives.
(Source:
Amended at
11
Ill.
Req. ______________________________
effective ____________________________________
IT
IS SO ORDERED.
3.
Dumelle concurred.~
1,
Dorothy
M.
Gunn,
Clerk of
the
Illinois Pollution Control
Board, h&reby certify
that the above Order was adopted on
tne
~
‘-I
aay of
__________________,
l9b7,
by
a vote
of
C
.
Dorothy
M. Gunn,
Clerk
Illinois Pollution Control Board
80—248
