ILLINOIS POLLUTION CONTROL BOARD
August 9,
1973
)
CITY OF MOUNT OLIVE
)
v.
PCB 73-124
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF WAVERLY
)
PCB 73-127
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
ANNA STATE HOSPITAL
)
)
v.
)
PCB 73-129
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF CARRIER MILLS
)
PCB 73-131
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
VILLAGE OF NORRIS CITY
)
v.
PCB 73-132
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF HARRISBURG
)
V.
PCB 73-133
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF WHITE HALL
)
)
v.
PCB 73-153
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
9—9
-2—
)
ILLINOIS STATE FARM (Vandalia)
)
)
v.
)
PCB 73-154
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF ASHLEY
)
)
v.
)
PCB 73-162
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
VILLAGE OF SORENTO
)
)
V.
)
PCB
73-170
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
TRIPLE OAKS WATER COMPANY
)
)
PCB 73-177
v.
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF
ST. ELMO
)
)
PCB 73-186
V.
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF SPARTA
)
)
PCB 73-196
v.
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF EUREKA
)
PCB 73-206
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
9—10
-3-
)
ELDORADO WATER COMPANY
)
)
PCB 73-207
v.
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
VIENNA CORRECTIONAL CENTER
)
)
v.
)
PCB 73-232
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
CITY OF NASHVILLE
)
)
V.
)
PCB 73-227
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
VILLAGE OF SHIPMAN
)
)
V.
)
PCB 73-259
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
VILLAGE OF AVON
)
)
V.
)
PCB 73-256
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
SUMMERFIELD, LEBANON, MASCOUTAH
)
WATER COMMISSION
)
)
v.
)
PCB 73-276
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
)
OPINION OF THE BOARD
(by Mr. Dumelle)
This opinion covers the grant of Variances
in the
20 cases
listed
for which orders were issued between May 31, 1973 and this
date
permitting copper sulfate dosing to control algae.
9—11
-4-
A year ago, on August
8,
1972 we granted three variances
to
cities
to use copper sulfate
in order to control algae
in water
supply reservoirs
(City of LaHarpe,
et al, PCB
72-168,
203,
225).
We said then
We concur in
the grant but do
so reluctantly because
of what appears
to be an incomplete
discussion by the
Agency or by the various cities of alternative methods
of treatment
or of possible harm.
However, the algae
bloom “season” is now almost over and no discernible
harm from using copper sulfate
appears
in these records.
Ample
time remains before next summer for both
the
Agency and all Illinois water
supply users
to prepare
fuller discussions on both alternative methods and
possible harm from the present practice.(SPCB
117)
Unfortunately the Agency and the Institute did not act promptly
in authorizing
a research study and only on May 30, 1973 did the
Board receive an interim report on “Algae Control
in Water Supply
Reservoirs” by
Dr. Charles
B.
Muchmore of Southern Illinois University.
At
this date the final report has not yet been received and the Board
has had to
act without full information available
to it.
Dr. Muchmore’s report involved a literature search; questionnaires
to the
50 states
(37 replies received);
and contact with individuals
knowledgeable
in algal growth control.
Ot the
37 states which replied,
only three reported fish kills
because
of excessive copper sulfate usage and attributed this
to
the
lowering
of dissolved oxygen levels due to overkill of algae and rooted
aquatic plants.
The possibility of fish kills
is
a reason then to
keep copper sulfate dosage as low as possible.
We point out that the Agency recommendations show copper levels
resulting from CuSO4 use varying from
as
low as
0.03 mg/l for the
Vienna Correctional Center
(PCB 73-232)
to
as high
as
0.70 mg/l for
the Summerfield, Lebanon, Mascoutah Water Commission
(PCB
73-276)
which was granted today.
If 0.03 mg/l of copper will kill algae
then why should
23
times
as much be necessary
(0.70 mg/l)
in another
case?
It may be that
the traditional amounts of copper sulfate
always used in the past are being recommended by
the Agency with
no
attempt to prescribe
the least possible amount.
Dr.
Muchinore cites
a 1952 study done in Wisconsin that
shows
that copper concentrations
in bottom muds
of copper sulfate-treated
water reservoirs were considerably
less than the 9000 ppm
(dry basis)
necessary
to affect benthic organisms.
We would point out that
this
study is now 21 years old and it would be well to have more
up-to-date information,
especially from Illinois reservoirs.
The
mention
of copper sulfate usage for 40
years in some water reservoirs
9
—
12
-5-
without harm is not conclusive since
(a) we do not know
if copper
in those bottoms are approaching dangerous levels and
(b) we do
not know if such usage
is warrantedin Illinois waters because of
possibly differing alkalinity
andy hardness characteristics.
Alternative methods of algae
control are dismissed by
Dr. Muchmore
as having more drastic effects upon the environment.
These other methods are; activated carbon,
lime or alum addition
and air injection.
Again, until the premise
is fully proven
(that
copper sulfate causes little harm)
then these
alternatives might
have
to be considered
in the future.
The possibility of using algae-eating fish does
not appear
promising according to a Federal biologist in Arkansas but no
mention is made of two specie~of fish listed in our August
15,
1972 opinion.
Alternative chemicals mentioned by Dr. Muchmore for use
as algicides
are; Hydrothol-47, potassium permanganate
(used in
Arkansas)
and 2-4,1).
(used in Texas).
His final report should
elaborate on the possibilities for their use in Illinois.
We
would also point out that our earlier opinion
(City
of Paris,
City of Oakland,
72-277,
72-289, August 15,
1972
5PCB 171) mentions
2,3-dichloronaphthoquinone and Algimycin-Pll and these
should also
be examined.
In summary, we grant the variances because
the harm to the
environment
seems minimal
and long range in nature.
We point out
that in one case before us, minnows were observed to turn blue
and to remain that color for a day or two (Village of Sorento,
73-170)
but no kills occurred.
In a recent
case,
(Summerfield,
et
al
73-276)
the Agency asks
us to exempt side channel
(not flow through) reservoirs
from the
0.02 mg/l copper water quality standard.
This
is
a good recommendation
and if
the side
channel reservoir were only used for water supply
purposes
(not for fishing)
then we would consider it
as
an appendage
of the water treatment plant
to be dosed with chemicals
at the
operator’s will.
However,
we think
it best
to wait on this matter
of interpretation until
the final report by Dr. Muchmore
is before
us.
Once
the final report
is issued we would expect that the
Agency would propose a change
in
the Water Pollution Regulations to
allow copper sulfate usage if no suitable alternative exists for
algae control.
A year ago we granted similar variances to
five Illinois cities.
None have come back for new variances
indicating that they have
found alternate solutions
to controlling algae or that no algae pro-
blem arose this
year.
The Board would
be
interested
in the Agency
or Dr. Muchinore’s comments on the experience
at these cities.
This opinion constitutes the Board’s findings of
fact and
conclusions of
law.
9
—
13
-6-
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above
Opinion was adopted on the
c1.+.~
day of August,
1973 by a vote
of ___________________________________
Illinois Pollution
1 Board
9—14
ILLINOIS POLLUTION CONTROL BOARD
August 9,
1973
ALTON BOX BOARD COMPANY,
Petitioner,
vs.
)
PCB 73—140
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
Karl Hoagland, Attorney for Alton Box Board Company
Frederick Hopper, Assistant Attorney General for the EPA
OPINION AND ORDER OF THE BOARD
(by Mr. Henss)
Alton Box Board Company requests variance from Sections
402,
403,
404(a) (i)
404(b) (i)
405 and 408(a) (h)
and
(c)
of
Part IV, Chapter
3, Water Pollution Regulations of Illinois
and Section 12(a)
of the Environmental Protection Act.
The
Company states that variance from these water quality and
effluent standards will be needed until construction is completed,
about December 1977, on
a proposed new waste water treatment
facility.
The mill in question is located within the city limits of
Alton in Madison County and borders
the Mississippi River below
Alton Lock and Dam #26.
It is the largest of
4 paperboard mills
owned by the Company.
Approximately 800 tons of paperhoard are
produced daily by the mill’s 720 employees.
It consumes 735 tons
of coal daily,
93 tons of processed chemicals,
600 tons of re-
claimed wastepaper,
568 tons of wood chips and
8 to 10 million
gallons of water.
Petitioner owns
a total of 43 plants located
in 15 states in its fully integrated production of paperboard
packaging products.
The record indicates that Alton Box has made some progress
over the past 11 years in its attempt to conform to existing
regulations.
A May 18,
1964 letter from the Sanitary Water Board
acknowledges
a
2/3 reduction in fibre content of the Company
effluent.
After failure of an experimental control program
Alton installed an 8.5 MGD wastewater clarifier and sludge
removal system.
In April 1967 the Sanitary Water Board said the
new system could “provide adequate treatment to the tributary
9—
15
—2—
industrial wastes for some years
to come”,
if afforded proper
maintenance and operational control.
Under SWB-l3,
the Alton
mill was required to have secondary treatment by December 1982.
On January 19,
1971 the Environmental Protection Agency
advised Petitioner by letter (Petitioner Exhibit
#23) that newly
adopted regulations now required secondary treatment for the mill
effluent by December 31,
1973.
In April 1971 Petitioner hired Mid—America Engineers Incor-
porated to do
a feasibility study relating to the liquid wastes
(Exhibit 24).
Although the study was to have been completed
within
8 weeks,
it was not received until September 16, 1971.
The recommendations of the study were not followed, allegedly be-
cause Petitioner did not choose to accept undesirable pollutional
trade-offs inherent in the plan.
Evidence also shows that in
April 1971 Alton Box hired
a St. Louis
firm of consulting engineers
to assist in obtaining permits and for consultation on other
phases of their pollution abatement problems
(Petitioner Exhibit
#26).
During May 1971 two Alton Box officials toured six other
mill sites to determine how other paper mills were treating their
liquid effluent before discharge.
Mid-America Engineers was.re-
quested to perform additional studies and subsequently provided
Petitioner with revisions that were found acceptable.
Alton Box adopted a program which called for the complete
elimination of wood chips
from the process in order to abate the
troublesome black liquor effluent.
This would leave reclamation
and recycling of wastepaper
(increased to 950 tons per day)
as the
primary source of raw material.
Under this plan, Alton Box would
be able to reduce its use of land for aeration,
lagoons and ponds.
The time schedule for the 4 stage program
is as follows:
Stage
1:
Install processing equipment for converting the entire
operation to reclamation of wastepaper.
Time required
-
18 months
Estimated completion date
—
September 19, 1974
Effects:
BOD—25 lbs./ton or 20,000 lbs. per day
—
80
reduction
Suspended Solids
-
5 lbs./ton or 2,000
lbs.
per day
-
37.5
reduction
Stage
2:
(simultaneous with Stage
1)
Phase out woodchips and phase in new sources of
reclaimed waste paper
(i.e.,
expansion of the
paper reclamation division).
9—16
—3—
Time required
-
18 months
Estimated completion date
-
September 1974
Effects:
(incorporated in effects shown for Stage
1)
Stage
3:
Close the mill process water system by reducing number
of discharge water points.
Time required
-
24 months
Estimated completion date
—
September
1976
Effects:
BOD-20 lbs./ton or 16,000 lbs. per day
—
85
reduction
Suspended solids
—
0.125 lbs./ton or 100
lbs.
per day
-
98.4
reduction
Stage
4:
Secondary treatment of residual flow
Time required
-
15 months
Estimated completion date
-
December 1977
Effects:
Compliance with Regulations
Under Stage
1, Petitioner plans
to install
2 new hydropulpers,
enlarge and revise the asphalt dispersion system,
and construct
stock tower and conveyor system for feeding the wastepaper to the
hydropulper and cleaners.
Alton Box claims that the 18 month time
frame was supplied by the hydropulper manufacturing firm and in-
cludes time required to design,
fabricate, deliver and install
the equipment
so as to intermesh with the existing reclaimed fibre
system.
As noted above,
Stage
2 would occur simultaneously with
Stage
1.
Petitioner advises that the extremely complex nature of
Stage
3
(eliminating a great number of discharge water points)
delays its commencement until Stage
1 has been completed.
This
seems reasonable
to us.
Installation of
a new clarifier originally called for in
Stage
4 has now been programmed for installation during Stage
1.
Alton Box claims that as much of Stage
4 as possible has been
accelerated and advanced into the earlier stages.
Alton Box submitted this program to the Agency along with a
Project Completion Schedule on August 25,
1972,
and followed with
permit application on September 29,
1972.
On December 18,
1972,
the Environmental Protection Agency rejected the Project Completion
Schedule because of the obvious failure of the proposed system to
be in full operation by December 31,
1973
as required by Regulation,
and several administrative inadequacies.
The permit was then
denied because there was no approved Project Completion Schedule
9
—
17
—4—
and because of failure to provide
a complete list of contaminants
discharged and their concentrations.
After
a series of meetings with the Agency and their consulting
engineers, Alton Box submitted a revised Project Completion
Schedule and permit application giving the following information:
Current average daily flow
-—
9,600,000 GPD
Designed average daily flow
——
14,400,000 GPD
Current influent BOD
--
1,500 mg/i
Current influent suspended solids
--
1,800 mg/i
On page
5 of the Mid—America Engineer’s Report
(Exhibit #31) we
note
a column titled
“Mill Effluent” under which BOD and suspended
solids were shown to be
1450 mg/i and 300 mg/i respectively.
It
could not be determined whether the ~‘Mil1Effluent” was the influent
to the waste treatment works or the effluent to the Mississippi
River.
Page 10 of this same report contained the following table:
Present
Future
Reduction
Total Process effluent
10,600 gal/ton
1,250 gal/ton
88
Total BOD5 Discharge
133 lb/ton
4 lb/ton
97
Total Suspended Solid
discharge
7.45 lb/ton
1/8 lb/ton
98.3
Calculations from this Table reveal that the present discharges
for
BOD and suspended solids are about 1,500 mg/i and 90 mg/i respectively.
The BOD figure obtained by this calculation for Processed Discharge
is exactly the same figure given for “Current Influent BOD”.
Com-
pounding the confusion,
as the Agency points out,
a discharge of
4 lbs. BOD per ton of production in an effluent of
1,250 gallon per
ton yields about 384 mg/i,
far in excess of the 20 mg/i which
Petitioner claims will be the BOD concentration upon completion of
all stages of
the proposed abatement program.
Also at issue in this proceeding was the question whether the
receiving stream was the Mississippi River or
a tributary to
t.~:e
Mississippi River known as Shields Branch.
In granting the 1965
permit, the SWB classified Petitioner’s discharge as being directly
to the Mississippi River.
However, the Agency contends that the
discharge actually entered Shields Branch about 1/4 mile before
reaching the Mississippi River.
If we upheld the Agency’s position,
the effluent criteria imposed on Alton Box would not be
20 mg/i BOD
and 25 mg/i suspended solids as Petitioner thought but a more
stringent
4 mg/i BOD and 5 mg/i suspended solids.
9
—
18
—5—
We hold that the higher standard for emissions
to the
Mississippi River
is applicable here.
Evidence indicated that
Shields Branch as it was once known, no longer exists.
A former
Alton Box Board employee and long—time resident of the area
testified that the spring feeding the Branch had been capped or
plugged sometime in the past causing the Branch to become
essentially a stagnant no-flow ditch.
The Agency offered no
evidence on this point.
Except for periods of wet weather,
all
flow upstream of Petitioner’s outfall
is the result of indus~al
wastewater discharges from other industry in the area.
The
original Shields Branch discharged to the Mississippi at a point
above the Alton Box property.
However, the erection of
a levee
diverted whatever flow the Branch may have carried onto Alton
Box lands.
An aerial photograph
(Exhibit #9), marked to delineate
the original course of Shields Branch before diversion,
appears
to
show that the industrial drainage ditch and Shields Branch are two
different courses below
a point near the LaClede Steel plant.
Petitioner’s effluent is not at any point in the original course
of
Shields Creek.
The photograph vividly displays Petitioner’s
discharge point to the industrial drainage ditch in that the
ditch becomes very dark.
The dark liquid is also very evident
at the ditch outfall to the Mississippi River and for some
distance downstream.
We find that Petitioner’s effluent reaches
the Mississippi
in an industrial ditch.
While we are convinced that Aiton Box has made a good be-
ginning, we do not believe there is sufficient information for
immediate acceptance of its entire abatement program.
Petitioner’s
conversion to 100
reclaimed paper for feedstock will reduce some
pollution problems.
By removing the wood chips, the black liquor
portion of the present influent to the treatment plant will be
eliminated.
Upon completion of the entire project, Petitioner
states that an estimated $4.7 million from the corporate’s $23
million pollution control budget will have been spent.
This must
be viewed as
a significant outlay for a plant as old as
the Alton
mill.
An air poliution control program for the Alton miii has
already been completed.
However, Petitioner leaves us up in the air by failing to
reveal methods to be used in Stage
4
to achieve compliance; and
computations of anticipated BOD levels in the influent
(or
effluent)
leave something to be desired.
Aiton Box Board Company stated that a variance denial would
cause the termination of operations
or subject the Company
to
possible fines
for continued operations beyond December 31, 1973.
If forced to close, Alton Box claims that an immediate economic
loss of over $12,500,000 would occur which would place the Company
9—19
—6—
in default under its long—term loan agreements.
Other adverse
effects would be
the possible loss of employment of 721 persons,
loss of payroll, loss of State and Federal tax payments and the
loss of production capabilities during
a period of severe
shortage of paperboard for paperboard packaging.
Aiton Box
claims that the resulting paperboard shortage could have
a direct and
serious effect on customer plants employing
more
than
30,000
persons in Illinois alone.
The Environmental Proteciton Agency recommends that we grant
Petitioner a variance from Rule 921(a)
and
(d)
of Chapter
3 and
deny all other variances.
Although Alton Box did not specifically
ask for exemption from those Rules, the Agency expressed in their
Recommendation a belief that Alton’s Petition should be so construed.
On June 28, 1973 we deleted Rule 921(d)
from Chapter
3 therefore
that portion of the Agency’s Recommendation is now moot.
The
Agency also expressed
a belief that Petitioner should have requested
relief from Rule
1002(a)
of Chapter
3.
The Agency recommends denial on the ground that the hardships
alleged above are self-imposed and not sufficient
to justify the
grant of
a variance.
The Agency has an enforcement case pending
and may fear the effect of a variance on that prosecution case.
however, the variance is not a shield against prosecution of
violations which occurred before or after the term of the variance.
Using Petitioner’s estimate of BOD discharge of 106,000 lbs.
per day, the Agency calculated that Alton Box was dumping the
equivalent of the untreated sewage of some 623,529 persons into
Illinois waters.
Petitioner calls
this
a factually incorrect
statement representing
a blatant and total falsehood,
the sole
purpose of which was to mislead and prejudice the Board against
Petitioner.
Dr.
James W.
Irvin,
appearing on behalf of Petitioner,
testified
that he “would not expect the BOD,
as anticipated to be discharged
from the Aiton Box Board during this intervening period, from
present until their facilities are complete,
to have a significant
effect on the oxygen resource of the Mississippi River”.
When.
asked to describe his statement in language other than
~significant”
Dr. Irvin replied:
“It would have
to be an opinion but I would not
expect that the present discharge would cause
a depression
in the
dissolved oxygen of anything more than half
a milligram
a liter”.
(R.
273)
Dr.
Irvin iater testified pertaining to the suspended
solids and Petitioner’s effluent that “...my opinion is
that the
suspended solids discharge is rather insignificant”.
(R.
276)
9
—20
—7--
We do not agree with Dr.
Irvin that an estimated depression
of up to 1/2 milligram per liter dissolved oxygen caused by
the
effluent from a single source is insignificant.
USGS figures
for the twelve month period,
October 1970 to September 1971,
show
that the Mississippi
River at Chouteau Island had an average
dissolved oxygen concentration of about 7.3 mg/i
(Exhibit #56).
Data prepared by the Illinois Environmental Protection Agency for
the year 1971 reveals
that the Mississippi River at the Illinois
Terminal Road Bridge at East Alton had an average dissolved
oxygen concentration of 8.5 mg/i
(Water Quality Network, 1971
Summary of Data, Volume
1, page 1-229).
If we adopt
Dr.
Irvin’s
reasoning,
we should view
as insignificant the fact that similar
discharges from an additional
5 industrial sites in the same area
could reduce the oxygen content of the Mississippi River below
standards.
We believe the Illinois General Assembly expressed
a
different viewpoint in Section 11 of the Environmental Protection
Act:
“It is the purpose of this Title to restore,
maintain and enhance the purity of the waters
of this State..
The Mississippi is not a pure stream and it has a large
capacity but this fact is not an excuse for the dumping of large
amounts of waste.
The record in this proceeding demonstrates the need for
an
early start on construction of the waste treatment facilities at
Alton Box Board Company.
Alton Box has expressed a belief that
construction of the proposed system could begin within two or
three weeks of our decision.
Delaying a decision until the
conclusion of the enforcement action would not speed the proposed
system along.
We do not believe our decision today places the
Agency’s enforcement case in jeopardy since the dates involved
preceed the dates for which we intend to grant the variance.
The Agency warns that we “are being given the opportunity to
buy a pig in
a poke’.
If so, we do not accept the offer.
The
first three stages of the construction program should reduce BOD
by 85
and suspended solids by 98.4.
These reductions will not
be sufficient for compliance with our regulations, but they are
none the less significant reductions.
We have been left in the
dark
as to the proposed fourth stage system.
Obviously we can
not approve
a proposed system that has not been fully explained to
us.
We can, however,
start the first three stages on their way by
granting a variance with certain conditions.
Petitioner must be
fully aware that the granting of future variances will depend upon
adherence to the conditions and that such future variances should
not he considered assured.
We will expect a discussion
of possible
9—21
—8—
alternatives for Stage
4 upon the first request for variance
extension.
ORDER
It is the Order of the Board that:
1.
Aiton Box Board Company is granted a variance
from Rules
402,
403,
404(a)(i) and
(b)(i),
405
408(a),
(b), and
(c), and 921(a)
of the Water
Pollution Regulations of Illinois and a limited
variance from Section 12(a)
of the Environmental
Protection Act from April
6,
1973 until April
6,
1974
for the purpose of constructing the proposed
new process and waste water treatment facilities
as described by documents submitted during this
proceeding.
The variance from Section 12(a)
EPA
shall be applicable only as to BOD and suspended
solids levels.
We are not at this time granting
a variance for the discharge of any contaminants
which were not considered in this Opinion.
2.
Petitioner shall by September 13,
1973 post
a
bond in the amount of $500,000
in
a form acceptable
to the Environmental Protection Agency, such bond
to be forfeited in the event Petitioner fails
to
install and operate the abatement equipment described
in this proceeding and equipment to be described at
a later date.
The bond shall be mailed to Fiscal
Services Division, Illinois EPA,
2200 Churchill
Road,
Springfield,
Illinois 62706.
3.
This variance is conditioned upon the submission of
monthly progress reports commencing September 15,
1973 to the Agency describing the status of con-
struction and installation of the proposed new
process and waste treatment plant and upon a
showing of satisfactory progress in the installation.
4.
As further condition,
Petitioner shall by September 30,
1973 submit to the Board and the Agency data that
precisely and clearly shows current and anticipated
concentrations of all contaminants
cited in Part
4
of the Water Pollution Regulations of Illinois for
the mill influent liauid to and effluent liquid from
the waste water treatment works.
9
—
22
—9—
5.
Petitioner shall diligently attempt to expedite
the construction of the new waste treatment plant
at all stages.
Quarterly reports commencing
December
1,
1973 shall be submitted to the Agency
showing progress or lack of progress being made
toward the selection of methods
to be installed
during Stage
4.
I, Christan L.
Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order was adopted
this
‘j’~
day of August,
1973 by
a vote of
~
to
C’
f
—
1
•~~i
‘
~
--~
~
~
9
—
23
