ILLINOIS POLLUTION CONTROL BOARD
December
29, 1983
G.
D. SEARLE
& CO.
AND
SEARLE
FOOD RESOURCES,
INC.
AND PARK
FOREST SOUTH UTILITIES COMPANY,
Petitioners,
v.
)
PCB 83—73
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY,
Respondent.
MR. JEFFREY C.
FORT AND MS.
M,
THERESE YASDICK, MARTIN,
CRAIG, CHESTER AND
SONNENSCHE1N, APPEARED FOR PETITIONERS;
MR. DAVID RIESER,
ATTORNEY
AT LAW, APPEARED FOR
RESPONDENT.
OPINION
AND ORDER OF THE BOARD
~by D.
Anderson):
This
matter
comes
before the Board upon
a
petition
and
amended
petition
for variance filed June
3
and
August
10,
1983
by
G.
D.
Searle
&
Co., Searle Food Resources Inc.
(Searle)
and
Park
Forest South Utilities Company
(PFSU).
The
amended
petition
requests
a variance from
35
Iii,
Adm.
Code
307.102(a)
as
it relates to discharges
to a public sewer
system
which
may
cause
the treatment
works
effluent
to
cause
violations
of
water
quality standards for
total
dissolved
solids
(TDS),
chloride
and sulfate
(35 111. Adm, Code
302.208).
On June
17,
1983
the Board received
a timely written
objection from Ms. Gisela
Topoiski,
and directed that hearings
be scheduled.
The Board
also received
written objections
from:
Ms. Helen
Nystrum,
Mr. Lawrence
Lawless, Mr. Richard
Blievernicht, Mr. Liese
Ricketts, Supervisor
of Crete Town-
ship, and Mr.
Robert
Gaines.
On August
26,
1983 Ms. Topoiski
withdrew her objection.
On July
5,
1983 the Illinois Environmental
Protection
Agency
(Agency)
recommended
that the
variance be denied for
lack of information.
On September
16,
1983 the Agency filed
a first amended recommendation
which
indicated that some of
the needed information
had been supplied;
however,
the
Agency could not
determine whether arbitrary
or unreasonable
hardship existed and
declined to make
a recommendation as to
whether to grant or deny
the variance.
The Agency did,
however, recommend conditions
should
the Board determine to
grant a variance,
On December
8,
1983 the Agency filed a
brief which recommended a
grant of the
variance with condi-
tions.
On September
27,
1983 Searle filed a
response
to
55~441
the
recommendation,
A public hearing was held on
Novem-
ber 2,
1983
in Park Forest South.
Members of the
public
attended
and commented,
On
November
30,
1983 the Board received
a
letter from
the
Agency
requesting incorporation into the record
of
a
letter
to the Agency from Mr.
E,
E.
(Bud)
Sweet dated
Novem-
ber
14,
1983.
On December 23,
1983 the Board
received a
letter
from the petitioners opposing the incorporation,
The
Board
hereby incorporates both Mr.
Sweet~s
and the
Petitionèrs
letters into the record as public comments.
On
December 19,
1983 Petitioners filed a motion
to
correct
line 16 on page 30 of the transcript to
read $8,400,000
instead
of $8,400 per year.
The motion
is granted.
On December 28,
1983 petitioners filed a niotion for
leave
to
file
their
reply
brief,
which
had
been
filed
on
December
27.
The
motion is granted.
This variance concerns a plant owned by Searle in
Park
Forest
South,
Will
County.
The
plant
manufactures
aspartame,
a low
calorie
sweetener
recently
approved
by
the
Food and
Drug
Administration
(R,
23).
The operation is referred
to
as
a pilot plant.
It will eventually produce 130
metric
tons
per month.
It will have over 200 full time
employees
and
an
annual payroll in excess of $6 million dollars
per
year
(R.
22)
Searle purchased the plant, which included
some equipment which could be adapted to aspartame produc-
tion
(R,
24)
Development of the plant is proceeding in four
phases
or
“trains”
(Amended Pet.,
p.
3,
R.
24).
Train IV
will be
complete
“by the end of the year”,
apparently meaning
1984
(R.
34)
Aspartame production involves bonding two amino
acids
together and purifying the adduct,
This involves the use
of
sulfuric acid,
hydrochloric acid and acetic anhydrlde,
with
neutralization by caustic soda,
This produces
a high
TDS
process
wastestrearn,
in addition, solvent and methanol
recovery operations produce a high TDS bottom wastestream
(R,
54),
Other sources include boiler blowdown and the
regeneration backwash from xeolite water softening
(R,
38,
42,
54,
62,
112),
The primary constituents of the TDS are chloride
and
sulfate
(R.
59),
After
completion
of
the
expansion,
Searle
would
produce a discharge described in the following
table
55~442
—3—
based on a
flow
of 0.916 million liters
per
day
(0.242
million
gallons per
day
(MGD)) CR.
51, 55):
Average
Maximum (98)
kg/day
kg/day
chloride
1224
1483
Sulfate
785
1084
TDS
7650
11,010
Searle
presently
has some
of
its
high
TDS
waste
hauled
off—site
for disposal.
This
amounts
to over 25,500 gallons
per
day at a cost of nearly $2 million
CR. 29,
39).
Searle pretreats its waste prior to
discharge to
the
Park Forest South
sewer:
a
solvent
recovery
column
can
be
used
to
reduce
the
organic
loading;
and,
a
1.7
million
liter
holding
basin
mixes
and
equalizes
the
discharge
flow
CR.
25,
35,
44).
The
sewage
is
received
at
a
treatment
plant
owned
by
Respondent
PFSU,
a
privately
owned
company
which
provides
water
and
sewer
services
to
the
Village
of
Park
Forest
South
(R.
50).
The
plant
includes
activated
sludge
with
tertiary
treatment
via
granular
media
gravity
filters.
It
discharges
pursuant to NPDES Permit No. IL 0024473 to Deer creek
CR.
51).
The treatment plant has a design capacity of 2.17
MGD
and an average dry weather flow of 0.9
MGD
(3.4 million
liters per day), exclusive of any flow from Searle
CR.
50).
Taking into account the variability of both the Searie and
background
levels, the
following
discharge is
predicted
as a
maximum
concentration
to
be
exceeded
less than 2
of the
time,
and
the
mass
discharge
based
on
a
flow
of
4.32
million
liters
per
day
(1.142
MGD)
CR.
50,
57):
mg/I
kg/day
chloride
492
2130
Sulfate
574
2480
TDS
3140
13,600
TDS may
have
an
adverse
impact
on
activated
sludge
processes at chloride levels of 18,000 to 20,000 mg/i
resulting in an increase in suspended solids and reduction
in organic material removal.
However, no impact is expected
at levels to be produced by the Searle discharge
CR.
59, 63,
Ex.
4).
The effluent discharges to Deer creek
CR. 51).
Above
the plant Deer creek is an intermittent stream; below it is
perennial
CR.
7.).
It meanders east
and
north through
suburban
areas; at the Lincolnshire Golf course it is
daaaed
to forth a shallow, 18-acre lake, called Deer Lake
CR. 71).
55-443
About
14
miles
from
the
discharge
Deer
Creek
joins
Thorn
Creek,
a tributary of the Little Calumet
River
(R.
72).
Deer Creek is a low gradient stream, meaning it drops
only a small distance for each
mile
of
stream
length
(R.
103).
It has been channelized for short distances near East Chicago
Heights
(R.
72).
The
bottom
is
covered
with
a
fine
grain
material
resulting
from
erosion,
This
has
reduced
the
habitat
availability
(R.
107).
The
PFSU
discharge
provides
a
constant
flow
providing relief for aquatic life
from
hot,
dry
conditions
with
low
oxygen
CR.
74,
77).
At
one
time
there
were
several
sewage discharges,
hut
now
PFSU
is
the
only
licensed
discharger
(R,
72,
95).
Above
the
treatment
plant background levels
of
TDS
have
approached
or
exceeded
the 1000 mg/i standard;
indeed,
levels
as
high
as
41,000
mg,/i have been found,
based
on
conductivity
(R,
58,
77,
86).
High TDS levels are
attributed
in
part
to
elevated
TDS levels
in
well
water
used
for
the
public
water
supply
CR.
79),
PFSU supplies water
softened
by
xeolite
to
Park
Forest
South
(R,
112).
Presently mean TDS near the PFSU plant is 3957
mg/l.
The
plant
discharge
is
8() to 90
of the flow at this point.
TDS
falls
to
1200
mg/I
at
the
outfall
of Deer Lake
(R.
77,
86,
Ex.
7).
Deer
Creek
is classified as semi-polluted
to
polluted,
based
on
Agency
criteria
involving counts of benthic
macro-
invertebrates
(R.
93,
Ex.
7),
The bottom deposits
noted
above
would
be sufficient
to result in this classification
(R.
109),
Consultants employed by petitioners
have
conducted
stream
studies
which
confirm this classification
(R.
73,
96).
These
studies are continuing in
preparation
for
a
site—specific
rulemaking
(R.
75)
.
Species identified are
tolerant to high TDS levels
(31.
82,
96).
The
following
regulations are involved in this variance
request:
35
Ill.
Adm. Code
_____
Summary
302,208
General use water quality
standard
of 500 mg/i chloride
302.208
General use water quality
standard
of 500 mg/I
sulfate
302.208
Genera.
use
water
quality standard
of
1000
mg/i
TDS
55-444
35 Iii, Mm.
Code
SummarL~
304,105
Prohibition of effluent discharges
which cause or contribute to
a vio-
lation
of water quality standards
307,102(a)
Prohibition of discharges to
public
sewers which cause the effluent
discharge from the treatment works
to
violate
water
quality
standards.
Total dissolved solids includes everything which is
dissolved,
as opposed to suspended,
in water and which
remains on evaporation,
It is closely related to the salinity
or
hardness of water,
it is an aggregate measure of many
possible contaminants,
including toxic materials,
However,
the TDS standard is set at a level hundreds to millions of
times higher than the standards for individual toxic contami-
nants,
so that it
is extremely unli.kely that the TDS standard
could be violated by a toxic discharge without a violation
of a standard for a toxic contaminant..
In practice, TDS
usually consists mostly of chloride and sulfate, which are
normally ingested in the human diet, but which can cause
problems to aquatic life if present in high concentrations
(R,
79)
The Board had an effluent standard of 3500 mg/I TDS,
This was repealed after the Board recognized that the treat-
ment processes for TDS are very expensive, consume large
amounts of energy and produce concentrated brines which must
still be disposed of
(R76—2l,
43 PCB 367,
398, September 24,
1981),
Regulation of TDS discharges was left to application
of the water quality standards for TDS, chloride and sulfate.
The water quality standards were set in R71-14
(3 PCB
755, March
7,
1972).
They were set in part by reference to
then-current studies on the toxicity of the contaminants to
aquatic life,
More recent studies done in Illinois have
suggested that the chloride standard sh.ould be raised to
around 800 mg/I, the sulfate standard to around 1000 mg/l
and the TDS standard to around 1400 mg/i based on one-tenth
of the 96-hour median tolerance level
(31.
81,
102, Ex,
6),
In
3179-6 the Agency proposed to divide the State into
river basins and propose water quality standards applicable
within each basin,
The Board dismissed 3179—6, but accepted
the
principle of regulation by basins.
The first basin
proposal, concerning the Sangarnon River,
has been proposed
in
R83-20,
Eventually there will be a proposal for the
Lake
Michigan/Des
Plaines basin involved in this variance,
This
could
involve modification of the TDS related water quality
standards
for Deer Creek,
55-445
—6—
The
Searle
discharge will cause the PFSU plant
effluent
to exceed the existing TDS water quality standard,
and
to
come uncomfortably
close to the chloride and sulfate
standards.
Since the PFSU discharge
comprises 80 to 90
of the flow in
the stream,
it will cause violations of water quality
standards.
Searle has
proposed a site-specific modification
of the
regulations
to allow this discharge, which the
Board
has
dismissed
(R83-l4),
Searle has committed itself to
either
pursue
a site
specific rule or to come into
compliance.
In
the interim, Searle
needs a variance to expand
the plant and
discontinue
in
part
the present practice of hauling high
TDS
wastewater
away
from the plant~ Searle has taken
steps
to
reduce
the
TDS
production,
and has
a
program which
may
result
in
further reductions,
Searle
has
completed
the
following
steps
to
reduce
its
TDS
production:
1.
Rinse time of water softeners has been reduced
from four hours to one hour,
2.
Steam condensate return system has been installed
to reduce the use of soft water,
3.
Piping has been installed to utilize soft water
for boiler feed and for cleaning of some equipment.
4,
Superheaters on the methanol and solvent recovery
columns, which used soft water, have been elim-
inated,
5,
Cooled glycol has been substituted for some
once—
through softened cooling water,
6.
Some cooling utilizing soft water has been elim-
inated,
7,
New boiler blowdown control system has been
installed.
Most of the above existing steps involve reducing the
consumption of softened water, since the backflushing with
sodium
chloride appears to be an important contributor to
the
TDS
load
(31,
27,
42),
Searle has proposed
a
continuing program to reduce
the
TDS
production further,
One possibility is to utilize
the
well
water directly for aspartame production, without
soften-
ing.
Another is replacement of the xeolite softening
with
reverse
osmosis
to eliminate the addition of TDS
during
the
regeneration
backflushing
(31.
28,
32),
Searle has
committed
itself to
completion of these studies by July,
1985
(31.
28,
Reply Brief).
—7--
Searle
is currently avoiding water quality violations
by hauling some of its high TDS wastewater for off-site
disposal.
Disposal of 25,500 gallons per day at $0.l15 per
gallon costs
about $1,960,000 per year,
Costs are expected
to rise to
$0.13 per gallon in 1984.
With completion
of
the
plant,
about
178,000 gallons per day would require disposal
off-site without the variance,
costing about $8,400,000.
With the variance requested, only 18,000 gallons per day
would
require off—site disposal, costing only about
$850,000
per
year
(31,
30),
This difference of $7,650,000 per year
is
the hardship complained of.
The stream studies conducted by Dames and Moore for the
petitioners indicate that the combined concentration of
chloride and sulfate could exceed 1800 mg/i,
and TDS levels
5130
mg/i, without causing undue stress to aquatic commu-
nities
(31,
82,
Ex,
7).
The levels of TDS proposed would not
limit improvement in stream conditions should certain other
limiting factors be removed
(R,
96).
During a hot, dry summer Deer Lake could act as an
evaporating basin resulting in elevated TDS levels.
Dames
and Moore predict a maximum TDS concentration of 3800 mg/i
during a 30-day period without rain in July
(R.
83, Ex.
8).
Considering that the lake habitat is severely stressed due
to the practice of draining
it several times per year by the
golf
course,
these TDS levels should have no impact
(31.
84).
Another concern is the use of water from Deer Creek for
irrigation.
Dames and Moore walked the stream and saw no
indications of permanent irrigation systems
(31,
72,
87,
89).
However, Mr.
Simon DeBoer and Mr. Fred Schubert testified
that they used the creek water for irrigation
(31.
143, 155,
160).
One problem with irrigation with high TDS water
is that
it can cause a decrease in permeability of clays,
The
tendency of high TDS water to do this depends on the sodium
adsorption rate
(SAR)
and the type of clay.
According to
Dames and Moore,
the SAR for the wastewater
is 12,7, which
is below the critical value of 20 for nonexpanding clayey
soils, such as the illites which border the stream,
The
sodium content of the wastewater
is therefore not expected
to
have any deleterious effect
(R,
85,
98,
102),
Another problem concerns contamination of shallow wells
near Deer Creek with high TDS water, and the possibility
that Deer Creek serves as a recharge source for local aquifers.
Dames and Moore did not identify any shallow wells adjacent
to the creek during their stream walk
(R,
72,
87,
89,
91,
96, 109).
They defined “shallow wells”
as wells less than
20
feet deep, probably hand—dug wells at older residences
(31.
96, 160,
170),
There are
a number of wells up to
and over
55-447
100
feet deep
(R.
97
110,
l6J
.
tt~
area
contains
sand
formations which may conduct water to ahe deeper limestone
aquifer.
On the other hand
i’
is po~siblethat
impermeable
layers
between the surface and this depth preclude the
possibility
that the
stream
is
recharging
the
deeper
aquifer
(31,
172),
The Agency has recommended that the variance
be
conditioned
on studies to be performed by Searle on whether
the discharge will impact TDS levels
~n water used for
drink-
ing and irrigationS
The Board finds that ~t wo~ldimpose arbitrary or
unreasonable hardsh~pto rcqu
3-
~ to cortinue hauling
its
waste off-site for
djc’~
mm
g
mpletion of
studies
which
will be made conditio~
f
1.
varianre
The Board
also
notes Searl&s stated ~
eat tc timely pursue a
site—
specific
rule change
or
alteirat~v~Il,to comply
(31.
33).
The
Board will ther~for~
q ~n
vir
-~
with conditions.
Petitlo e
or
a
~L
ly
r
nce from
Section
307
a
I
tr
5~
riance from
the water q’sl
y at
~
t
r~agreed
to
this,
Howev~r ~i
-
-
a
a vari-
ance from cac
C
ark lorest
South a vari-uace iron
‘~
3
Phese Sections
prohibit disc1~zrgesto the sewu~~r,i.
f
art
the sewage treat-
ment
plant, respoctivell
~h at
mm vi~zltonsof water
quality standards in the r~cev:.
a
Cart
The Board will
set
water quality—lased
ci
liar
~-e~d
d~
mm
canditions
of
the variances,
The cond
+
ons
f
r
-
a
-~
~ilarto
conditions re omr ‘~nde
~‘ e
rt~brief
with
certain
exceptions.
The Boar3 ha
pii.~the Order to
provide
separate
variances
and condit~ons
-
~earle and PFSU,
The
discharge and ~‘ff1uer~ hr
g
d
r
taic been made
immediately app1~immb1
t~a at
variance without
limitations through
xrpleLto~ r~
The studies
on
the impact
on
grourdwaler
ad
~
amma
will be
required
by the
end
of
1985
~r
o~
~t
~is
nformation
is available in time for a
3
1 we
~tipu1ated
f
~
ing
Lor
the Park
lie
ci ~ciarge from
recharg—
S.
~he Board notes
e
ac
rigr
sodium
The Board roles ~-h
~ or
that PFSU provides xeol, t
a
a
Forest South public water
rp~Jj
ing
of
this
is
prcbabll ye y
~i
also that xelite s~i1terirj
-r
levels
in
drirking waex
pj
F
have
been
linked to a nuttb~
1
~
h pi blems,
There are
processes
such
as
lime sot a
-
~i
b
o”Oid
high
sodium
levels,
and
may
result
in
tower
‘IDS
discharges,
The
Board
therefore
will
require
PFSL
to
raport
to
the
Agency
as to
where
its
softener
regeneraLi
~
wa~~
i~
discharged.
In
the
ad
a
dium
levels
—9-
event
it
is
being
discharged.
tqDeer
Creek, PFSU will be
required
to
undertake
studies
as
to
hbti
tO’eednce
o
•lla(natt
any
TDS
discharges
from
water
softening.
This
Opinion constitutes the
Board’
s findings of fact
and
conclusions of law in this matter.
ORDER
1)
Petitioners G.
D. Searle & Co. and Searle Food
Resources, Inc
•
are
granted
a variance from 35
Ill. Mm. Code 307.102(a) as it applies to the
water quality standards for total dissolved solids,
chloride and sulfate of 35 Ill. Adm. Code 302.208,
subject to the following conditions:
a)
This variance applies only to discharges to
publicly regulated
sewers
from Petitioners’
aspartame
production facility in Park Forest
South.
b)
This
variance
will
expire
on
December
29,
1988, or
35
days
after
a
site
specific
rule
applicable to the subject discharges is filed
with the Secretary of State, whichever
occurs
first.
c)
The
discharge
shall
be subject to the following
interim
discharge
limitations,
where
the
terms
“monthly
average”
and
“daily
composite”
shall
be as defined in 35 Ill. Adm. Code
304.104:
Daily
Monthly
Ccmposite
Average
(kg/day)
(kg/day)
Chloride
1500
Sulfate
1100
Total dissolved
solids
11,100
7700
d)
Petitioners shall monitor their discharge and
the stream for the following:
total dissolved
solids, sulfate, chloride,
sodium
and flow.
The monitoring
frequency
shall be weekly at
locations
downstream
of Park Forest South
Utility Company’s outfall and daily at
Searle’s discharge to the sewer.
55.449
—10--
e)
On or before July
31,
1985 Petitioners shall
complete a study of
the
following alternatives:
i)
the utilization of the plant~sraw water
supply in lieu of deionized water for
various process water usages and the
installation of a reverse osmosis unit
to reduce or eliminate the deionization
and water softening operations;
ii)
physical-chemical desalination processes,
such as
reverse
osmosis,
electrodialysis,
freeze crystallization, multistage flash
distillation, multiple effect or vertical
tube
evaporation,
:Lnciuding
associated
pretreatment facilities;
iii)
utilization
of
lime
or
ammonia
instead
of caustic for neutralization
of
acids
and the use of the resulting solutions
as
soil
conditioners
in
landfill opera-
tions;
or
iv)
some
combination
of
the
above
processes
or
alternatives.
f)
On
or
before
August
31,
1985
Searle
shall
send to the
Illinois
Environmental Protection
Agency a report summarizing the results of
the investigations of paragraph
(1) (e)
of this
Order,
g)
On or before March
1,
1984 Petitioners shall
submit to the
Illinois
Environmental Protection
Agency for
its
approval a plan of study for
demonstrating
the impacts
of the increased
total dissolved solids levels on
drinking
water
and
irrigation in
the
area
for
Deer
Creek,
Petitioners
shall perform the study
outlined in
the approved
plan and submit the
final
report to
the
Agency
on or before
January
1,
1986,
h)
Petitioners shall
complete
the following
compliance plan even
if no
final
decision
in
the rule change petition has been made:
i)
by January 31,
1985 establish process
design loadings and develop process
waste stream segregation;
55-450
—11—
ii)
by July 30,
1985 complete conceptual
design;
iii) by January 31, 1986 complete installation
of pilot plant;
iv)
by October 31, 1986
complete
detailed
technical and economic evaluation,
establish process design criteria and
select
treatment/control
system.
i)
Within 45 days of the date of this Order,
Petitioners G. D. Searle & Co. and Searle
Food
Resources,
Inc
•
shall execute and forward
to the Illinois Environmental Protection
Agency, Variance Section, 2200 Churchill
Road, Springfield, Illinois 62706, a Certificate
of Acceptance and Agreement to be bound to
all terms and conditions of this variance.
This
45
day
period
shall
be
held
in
abeyance
for
any
period
this
matter
is
being
appealed.
The
form
of
the
Certificate
shall
be
as
follows:
CERTIFICATION
We,
_________________________,
having
read
and fully understanding the Order in
PCB
83-
73
hereby
accept that Order and agree to be
bound
by
all
of
it~
terms and
conditions.
SIGNED
___________________________
TITLE
___________________________
DATE
______________
2)
Petitioner Park Forest South Utilities Company is
granted a variance from 35 Ill. Adm. Code 304.105
as it applies to the water quality standards for
total dissolved solids, chloride and sulfate of 35
Ill. Mm. Code 302.208, subject to the following
conditions:
a)
This variance will apply only to effluent
discharges to Deer Creek from the sewage
treatment
plant receiving the discharges
described
in
paragraph
(1)
(a)
of
this
Order.
55-451
—12—
b)
This
variance shall expire at
the same time
as
in paragraph
(1) (b)
of this Order,
c)
The discharge
shall be
subject to the following
water quality—based
interim effluent standards,
where
the terms
“monthly
average”
and “daily
composite”
shall be as defined
jfl
35
Ill,
Adm, Code 304,104:
Daily Composite
Monthly Average
(mg/l)
(mg/i)
Chloride
500
Sulfate
600
Total dissolved
solids
3150
2500
d)
Petitioner shall monitor its effluent
daily
for the
parameters
in
paragraph
(2)
Cc),
as
required in its NPDES permit~
e)
The Illinois Environmental Protection
Agency shall modify NPDES Permit No,
IL
0024473 consistent with this variance,
f)
On or before June 1,
1984 Park Forest
South
Utilities Company shall report to the Illinois
Environmental Protection Agency as to where
its water softening waste
is discharged,
and
as to the quantities of total dissolved
solids,
chloride and
sulfate discharged~
g)
If Park Forest South Utilities Company
is
discharging total dissolved solids from
water softening
to
Deer
Creek,
on or
before
January
1, 1986
it shall report to the
Illinois Environmental Protection Agency
as to how to reduce or eliminate any TDS
discharges to Deer Creek,
h)
Within 45 days of the date of this Order,
Petitioner Park Forest South Utilities
Company
shall execute and forward to the Illinois
Environmental
Protection
Agency,
Variance
Section,
2200 Churchill Road, Springfield,
Illinois 62706,
a Certificate of Acceptance
and Agreement to be bound to all terms
and
conditions
of this variance.
This 45
day
period shall be
held
in abeyance for any
period
55-452
—13—
this matter
is
being appealed.
The
form of the
Certificate shall be as follows:
CERTIFICATION
I,
(We,)
_____________________,
having read
and fully understanding the Order in PCB
83—73
hereby accept that Order and agree to
be bound
by all of its terms and conditions,
SIGNED
_____________________
TITLE
_______
____________________
DATE
_________
____________________
IT IS SO ORDERED.
Chairman J.
D. Dumelle and Board Member
J,
Anderson
concurred,
Board Member
B.
Forcade
dissented.
I, Christan L,
Moffett, Clerk of the Illinois
Pollution
Control Board, hereby certify
that the above Opinion
and Order
were adopted on
the
~
day of
~
1983 by a
vote of
r~L.f~lerk
Illinois Pollution
Control
Board
55-453
