ILLINOIS POLLUTION CONTROL BOARD
June
23,
1971
Spartan Printing
Company
Division
)
World Color Press, Inc.
)
)
vs.
)
.PCB 71—19
+
Environmental Protection Agency
)
Harold
S.
Goodman
and
David
N.
Conn,
Attorneys
for
the
Petitioner
John
Stanley
McCreery,
Attorney
for
the
Agency.
Opinion
of
the
Board
(by
Mr.
Kisseli!
On
February
12,
1971,
Spartan
Printing
Company,
World
Color
Press, Inc.
(Spartan) filed
a. petition for variance with the Board
asking for additional tine
within
which
to
construct
certain
waste
treatment facilities at its plant in Sparta, Illinois.
The petition
alleges that Spartan generates liquid wastes from its printing
operation;
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the discharge to levels satisfactory with current stream standards
dfficult;”
that Spartan has ~eveloped,after a long period of study,
a
two
phase
treatment
system
which,
when
installed,
would
substafltially
reduce
the
contaminants
discharged
by
Spartan;
that,
based
on
current
commitments,
phase
1
of
the
project
can
be
completed
by
June
30,
1971,
and,
phase
2
can
be
completed
by
March
30,.
1972..
The
Environmental
Protection
Agency
filed
a
recommendation
with
the
Board
recommending
that
the
variance
be
granted,
but
under
the
foflowing
conditions:
1)
That
phase
1
and
2
of
the
project
be
completed
within
6
months
of
the
entry
of
the
Board’s
decision;
2)
That Spartan pay a $50,000 oenalty;
3)
That Spartan file a performance bond of $300,000;
4)
Th&t during the installation of phase 1 and 2
Spartan
not
launder
wipecloths
on
the
premises;
and
5)
That
during
the
instaslation
of
phase
1
and
2
Spartan
not
produce offset plates on the premises.
A hearing was held on the petition on
May
13 and 14, 1971, in
Sparta, Illinois, before Timothy Harker, the designated hearing
officer.
2—fl
Spartan operates an offset printing facility in Sparta,
Illinois.
It employs
1486 people
(40
of whom
come from the City
of Sparta and
the remainder from an area 15 to
20 miles
from the
plant) and has
an annual payroll
of $11.6 million.
Spartan~s
business consists of
the printing, by use
of the web
offset press,
monthly magazines,
covering such subjects
as photography, the outdoors,
confession magazines and men~smagazines.
These magazines
are
printed for persons who
then distribute
them
nationally.
The
printing operation consists
of
three phases:
1)
the preparatory opera-
tion which includes making plates;
2)
the printing operation, which
involves
the use of presses,
ink and paper; and
3)
the binding,
stitchi
assembly, wrapping and shipoing of the magazines to the distributor.
The plates
(called “deep etch aluminum”
plates)
presently used
by Spartan are merely
a sheet of aluminum which has been coated with
a light—sensitive material.
The surface of the elate
is etched with
the
aid of
a copperized solution,
to
produce
a
rough
surface
which
is
the
design
of
the
material
to
be printed,
The
“non-orinting”
area
of
the
plates
are
treated so that they attract
water,
and
the
“printing”
area
of
the
plate
attracts
the
oily
ink
which
is
imeressed
onto
the
paper
in
the
offset
press.
Another
tvoe
of
elate
can
be
used
in
the
process,
but
is
not
presently
used
by
Soartan,
These
are
called
“ore-sensitized”
elates
and
do
not
need
the
chemical
treatment
re~uired
fm~thc
“deep
etch
aluminum”
elates.
While
the
“ore-
SCIISI
~
pi~L~
a~e
~sa a~~~’c ~
they
don
t
last
very
1ong--on~y
an
average
of
1000
iaoressions
can
b~
obtained
from
these
elates,
while
the
“deco
etch”
elates
can
produce up to 275,000
imoressions.
The
offset
process
used
by
Spartan
is
a
web
t~oe,
which
means
that the paper on which
the printing
is done
is
fed
into the offset
press
on
a continuous
roll,
and after printing the oroner sections
are cut.
This orocess was
first installed at the Soartan plant
in
1956.
Spartan has
21 presses at the Sparta
facility.
Besides the chemical solutions discharged in the elate operation,
there
is
another major area of chemical discharge.
In the operation
Spartan employees
are directed to use shop towels
to clean any area
of the plant,
including the plates and the machines,
As
a result
these towels become saturated with
the inks
and
the chemicals
in the
plant.
All in ~allSpartan uses over
7 million towels per year
in
the operation.
These towels are laundered
at the plant
site,
for
a
total annual operating cost of about $56,000.
The discharge from
the laundry operation constitutes
a major portion of
the waste from
the plant.
Presently, Spartan does not treat any of its industrial wastes.
It is estimated that the present flow of industrial waste from the
2
—
20
Spartan plant is 45.4 gallons per minute.
The contaminants contained
in the raw waste
are
somewhat staggering andam listed in the
Spartan
petition
for
variance
as
follows:
Concentration
C.O.D.
3000
—
8000
mg/l
B.O.D.
Q
-
3000
mg/l
Iron
35
*
mg/l
Copper
3
-
28
mg/l
Zinc
42±mg/l•
thromium
26 *
mg/l
Silver
0.05 to
.1 mg/l
Ph.
6.4 to 7.2
Turbidity
50Q to 700
Suspended
Solids
315 ±
mg/l
Spartan
has
known,
and
has
admitted,
that
its
wastes
have
been
for
some
lime
severely affecting the
ditch-
into—which the wastes are
deposited
and
Maxwell Creek, which eventually receives the flow from
the aforementioned ditch.
A -review of the history of Spartan’s
effort,
and
its dealing with the Sanitary Water Board and the Agency
is
necessary
here
for
a
complete
understanding
of
this
case.
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Cl~rc~~°
Klassen,
Technical
Secretary
to
the
Sanitary
Water
Board,
directed
a~letterto
Spartan
(Pet.
Ex.’J-1)
stating
that
a
sample
had
been
taken
of
the
Spartan
waste
and
that
the
sample
was
“black,
of
thick
consis-
tency,
and
apparently
almost
pure
ink
with
some
solvent
mixed
in.”
The
letter
went
on
to say that the “outlet stream downstream from
this discharge indicated that there were obnoxious odors
and
definite signs of pollution.”
Spartan was told to eliminate “immedi-
ately
.
.
.
any pollutional effects” to the stream.. After an
exchange
of
letters
in
which
Spartan
asked
for
a
meeting
with
the
technical
staff
of
the
Sanitary
Water
Board,
a
meeting
was
finally
held
on
December
12,
1966,
at
the
Spartan
plant.
The
record
does
not disclose exactly what was discussed at that December meeting,
but within a month from that date, Spartan hired E.
14.
Webb, a
consulting engineer from Carbondale.
It is apparent that Webb was
told by Spartan to find a solution to its waste problem “without
any strings attached.”
-After an initial examination, Webb advised
Spartan that it had an “extremely complex problem.”
Webb
was still
studying the problem when another letter was received by Spartan
-
from Klassen.
This letter, dated August 10, 1967, acknowledged the
fact
that
Webb
had
been
hired
by
Spartan
to find an answer to the
problem,
but
that
“no
action
had
been
taken
.
.
.
and
the
discharge
is
still
causing
pollution
of
the
receiving stream.”
Spartan was
told
in
that
letter
to
take
“positive
steps”
to
“eliminate
or.
properly treat the discharge.”
Spartan had 30 days within which to
2—21
advise
the Sanitary Water Board of what action
it was going
to take.
Spartan’s first reaction was to attempt to negotiate with the City
of Sparta
to take the wastes into
the municinal waste treatment plant.
This eventually failed after the
City hired engineers to study the
problem
and
concluded
that
it
could
not handle the waste stream for
some undefined reasoii.
In
a letter dated February
1,
1968,
Spartan
advised Klassen of
a specific
time schedule
(for the first time)
for
completion
of
a project which would involve comolete treatment
of the wastes from the Soartan plant.
Spartan admitted in that
letter that “progress has been
a bit slow in connection with
the
pollution problem at our plant”.,
(Pet.
Ex,
J-9)
The date of comple-
tion stated in the letter was August
15,
1968.
Spartan advised Klassen
in a letter dated June
27,
1968,
that Webb had run into
“certain
unique problems” with Spartan’s waste
(Pet.
Ex.
J-11)
and needed
more time.
Speaking on behalf of the Sanitary Water
Board,
on
July
10,
1968,
Klassen approved the new schedule which called for
completion of
the project on January
21,
1969.
(Pet.
Ex.
J-12)
Two
months later, Webb was still trying
to solve
the “complex” problem,
and he hired
Dr.
J.
W. Chen of Southern Illinois University to do
a
“treatability
study” of the Spartan waste.
(Pet.
Ex.
J-l3)
This
study was
to becomple~ed within
6 months.
A new schedule was approved
by
the Sanitary Water Board calling for the completion of the waste
treatment facility by August
29,
1969,
although Kiassen expressed
concern that
a year
would
transpire before
the waste treatment
tac~~~ty
would o~
u~L. .~i
r~un,
(i~e~.
:.~
4
1~c~
say,
the
facility
was
not
complete
on
the
date
promised,
and
orderea,
ai~das
a result,
Klassen directed another
letter to Spartan on December
30,
1969,
indicating that the latest sample taken from the Spartan
plant indicated
a COD of 8340 milligrams per liter,~ A meeting was
requested with Spartan.
(Pet.
Ex.
J-17)
A preliminary engineering
study was
submitted to Klassen by Webb on January
7,
1970.
This
study was,
according to the last schedule ordered by
the Sanitary
Water Board,
to be completed by September
25,
1968.
.
A meeting was
held
at the
Sanitary Water Board offices on January
15,
1970,
to
discuss the proposed plans, and
as
a result of that meeting,
Spartan
committed
to
a completion schedule which would have the treatment
facility
in operation within nine months of that date
(6
for Phase
I
and
3 thereafter
for Phase
II).
(Pet.
Ex.
J-l9)
This schedule was
confirmed by Klassen in
a letter dated February
11,
1970,
(Pet,
Ex.
J-20)
Purchase orders were entered into by Saartan
to begin
installation of the waste treatment facility.
Spartan by the
present variance petition requests additional
time within which
to
complete the waste treatment facilities--phase
1 by June
30,
1971,
and phase
2 by March
30,
1972.
The industrial waste discharged by S~
~tan
has been described
as
complex
by
all of the witnesses
in the case,
Apparently
(although
one witness disagrees)
the treatment process eventually settled upon
was
a unique
one
for the type of waste discharged by Spartan.
It
is
indeed disturbing
to this Board that technology
for
the treatment
2
—
22
of the Spartan type waste
is not readily available,
since there are
obviously many printing plants
(some in Illinois) using
the kind of
process employed by Spartan
at its Sparta plant.
It
is even more
disturbing
to hear that
the reason treatment technology has not
been developed
is because many of the printing facilities
are located
in urban areas
and they merely dump their wastes into the municipal
sewer system without any treatment.
The treatment system eventuall
designed for Spartan may
set an example- for- others
in the
same
business.
It is,
as has been
said,
a two phase process.
Phase
1
employs the use of chemicals
to flocculate
the waste, creating
a
sludge which can be taken out by sedimentation,
Also,
Phase
1 provides
for passing
the de-sludged waste through
a
Zurn micro-strainer.
(The
latter device was suggested
as
a substitute by the Sanitary Water
Board in its January
15,
1970, meeting with Webb
in place of
a sand
filter.
In addition, the
SWB suggested thit
a more complete recycle
system be installed
so that the waste could,
if necessary,
be
recycled through the treatment plant--phase 1--again
to obtain the
best treatment.)
The unique feature of the process to be installed
by
Spartan is phase
2.
This phase -employs
a moving bed carbon
adsorption unit for
the treatment of
a heavy metal waste.
While
moving bed carbon adsorption units have been used to treat organic
waste,
up to this point
(at least the record tells us)
this unit
has
not been used for
the removal or reduction of heavy metals,
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-.
.
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—-————.~.
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rule
on some preliminary matters.
The first
is
a preliminary motion
made by Spartan’s attorney
to‘disallow the Agency recommendation in
this case because it
is so “punitive in nature that they amount
to
punishment for violation of
a law which we never have received proper
notice,
adequate charges”
(R.
16).
We must deny that motion.
The
attorney
for Spartan was apparently upset because the Agency first
advised Spartan
to
f. le for
a variance and Spartan decided to take
that advice.
Snartan assumed that the Agency would
“go along” with
Spartan as the Sanitary Water Board technical
staff had oreviously
done.
Spartan had no right
to assume that that would be
the case.
The Agency is obligated under the Environmental Protection Act to
file recommendations
in all variance cases filed with
the Board.
The Agency, notwithstanding
previous dealings with
the person who
files
for
a variance,
must,
if this system is
to work,
be
free
to
make that kind of recommendation which it thinks in good conscience
is required
in any
case.
To dismiss the recommendation
for the reasons
stated,
or implied,
by Spartan would severely limit the independence
of the Agency in making recommendations.
This we cannot
do.
We
feel further that the Agency’s recommendations do not violate any
constitutional right due Spartan.
This
is not
an enforcement case
brought by the Agency,
rather
it
is
a variance
case which the Board
must decide on the evidence presented
in the record.
This is what
the Board intends
to do in all cases,
and it will be done
in this
one.
2
—
23
Spartan made another
motion
which
does
have
some
merit.
When
the Agency began to
call
witnesses in this case, Spartan
made a
motion that those witnesses should not be allowed
to
testify,
or
that the matter be
continued
until
Spartan
had
had
a
chance
to
examine the witnesses.
Spartan had, in the pre-hearing stages of this
case, requested that the
hearing
officer
order
the
Agency
to
supply
to Spartan a list of witnesses, as called for by Rule 313(b) of the
Procedural Rules of the Board.
That Rule provides as follows:
“(b)
The Hearing Officer shall order the following discovery
upon written request of any party:
Ci)
list of witnesses who
may
be called at the hearing”
On
March
25, 1971, the Hearing Officer in this case did in fact
require the Agency to
make
such a list avtilable to Spartan.
Pursuant
to this order a representative of the Agency telephoned the
attorney
for Spartan and advised him
that
two
witnesses (McSwiggin and Teske)
would be called by the Agency.
In fact, the Agency. put on additional
witnesses-at the
hearing.
We
cannot
allow
this-practice.
The
Agency
must follow the
Procedural
Rules
of
the
Board,
just
as
all
other
parties before the
Board
must
follow
àur
rules.
The
purpose
of
Rule
313 is to allow parties
to
find
out
in
advance
what
witnesses
for
the
other side are going to say.
-
This knowledge not only reduces the
surprise at the
time
of the hearing, and therefore results in a
ata
.aJIiOrsaCtlvC anJ
rea~ual
heachrj,
~
~y
4t
e.ar4.04n
naasa
to
disposition
of
matters
by
agreement
of
the
parties
and
appsc.vai
of~
the
Board.
We
therefore
hbld
that
in
this
case
the
testimony
of
the witnesses of the Agency, except for the testimony of Teske and
McSwiggin, shall not be considered by this Board aspart of the
record in this case.
We are not unmindful of the fact that in this
case the hearing officer held that the witnesses offered no surprise
to Spartan in
that
the
witnesses’
testimony
was
very
much similar
to that given by other witnesses.-
But- Rule 313(b)
Ci)
does exist
and if it is to have any meaning, it must be enforced, particularly
in a case where the Agency gave Spartan the names of two witnesses,
and no others, and particularly in a case when the Agency did not
argue, or show, that these “new” witnesses were being put on in
rebuttal to evidence introduced by Spartan and not contemplated by
the Agency.
Even without the testimony of the Agency witnesses, however, this
case can be decided by the Board.
The first major issue, of course,
is whether the variance should be granted.
The Environmental
Protection
Act
states
that
a
variance
shall
be
granted
to
a
petitioner
if he proves that compliance with the
Act,
the rules and regulations
promulgated thereunder, or an order of
the
Board creates an “arbitrary
and-unreasonable hardship”.
Section 35,
~vironmental Protection
Act.
We have held on numerous occasions that in determining whether
such a hardship exists we will balance the benefits and detriments
to the public against the benefits and detriments to the petitioner,
and
further
we
have
said
that
this
is
not
an
equal
balance.
We
will
2—24
look to the benefits
to be afforded to the public
as being the
strongest of the factors,
After
a review of theevidence presented,
we
feel that the variance should be granted in this
case upon
certain conditions, which will be dealt with separately.
Spartan
presently has
a program which will substantially reduce
its discharge
of contaminants into
the waterways of the StatC of Illinois.
The pro-
gram will be partially accomplished by June
30,
1971, when Phase
1
will be comoleted.
This will remove between
70 and
75
of
the
contaminants
generated by Spartan,
Phase
2 will be completed by
March
30,
1972,
and bring
the plant
into compliance with
the present
orders under which
it is operating.
While ther~will be some
discharge of contaminants
into the stream during the time when the
project
is being completed,
we
feel that
this is permissible
since
the alternative
to not grinting the variance would be
a shut
down of the plant.
The economic impact in~thiscommunity would be
too great
to allow
for the little benefit to be gained
in the stream
if the discharges wgre continued for just
a short time——one week
for
phase
1.
Spartan employs almost 1500 people with
an annual payroll
of
$11.6 million.
Shutting down
the plant would surelyput
all of
these people out of work,
thereby severely affecting
the community.
Perhaps,
this would be
&
viable alterAative
if the pollution caused
by the industry were
so great
and the prospect was that it would
continue, unabated,
for some
time.
But this
is not the
case here,
~
ie~l,Li~atbha..~ ,~bu,:ld
~
:T~c1iticesi~pe~ed~
The first
is
a money penalty.
The record adequately demonstrates
that
Spartan has taken
too much tim~in figuring out what
it should do about
the problem with
its wastes.
Spartan recognized back in
1966 that
it had
a pollution problem, when it responded to the.letters
of the
Sanitary Water Board.
It will take
this industry almost six years
to solve
its problem,
and while we could agree that the last phase
of this treatment process
is indeed
a unique one,
certainly that part
of the project which comprises phase
1 could have been designed and
completed
a
long
time ago.
Since
this part of the process would
remove between
70
and
75
of the waste from the waste stream, the
construction of this phase of
the project would have alleviated
the pollution problem in the ditch which Spartan admits exists and
has existed for some time.
One witness stated that the treatability
study could have been done
in
a year,
rather than 18 months
(R.352-3).
We agree with that witness
and we
feel that it was incumbent upon
Spartan
to push
its consultant as hard as it could to get th~job
done,
It would be no excuse
to this Boird
for Spartan to merely
point to
its consultant and say that he failed to do
the job
in time.
Spartan,
as is true with other persons who hire outsiders
to do the
work, cannot hide behind another~s failure to get
the
job done in time.
(Marblehead Lime Co.
v.
EPA, PCB 70-52 and City of Mattoon
v.
EPA,
PCB 71-8)
We
feel that
a penalty
can be imposed here as
a condition to the
grant of
a variance,
and we have
so held
in
a number of other cases.
(Marquette Cement Co. ~v. EPA, PCB 70-23 and GAF Corporation
v.
EPA,
PCB 71-il)
We do
feel that such penalties must be geared in amount to
2
—
25
the degree of laxity shown by the industry, municipality or sas4tary
distridt.
While we do feelap~ialtyiscalled for in this case, we
do not agree with the aunt suggested by the Agency.
We feel
that
many of the delays occasioned by Sparta were in fact excused by the
Sanitary Water Board, and it is only the most recent delay which is
not.
It is the performance in 1970 on which the oenaltv should be
based, that is the
.z.nabi lity to .complete the
project
within
the
time
last
granted
by
the
Sanitary
Water
Board-—the
completion
date
was
to
be
nine
months
after
PeI~ruary11,
1970,
which
would
have
been
November
11, 1970.
The few design suggestions
made
by
the
Sanitary
Water
Board are no excuse for not completing
the
project on time.
This
failure to complete the project on time is the basis for imposing a
condition on the grant of this variance that Spartan pay a penalty of
$10,000.
The secozid condition whiâh we would impose upon Spartan is the
posting of a performance bond with the Agency in the amount of
$200,000, which is the approximata cost of construction of phase 2
of.the•project.
TheAct requires that in any case where additional
time is allowed for the completion of a project the
Board
must require
the posting of a performance bond or other security.
Section 36A,
Environmental Protection Act.
The
bond should be based
upon
the
total cost of phase 2 of the project because phase
1 will be
u4rI-iislly
rnmnlnfeci
what,
thftc
r~pjn3ny~
.qn~t
nrci.r
are
tqsuinl.
The Agedcy has made additional recommendations on which we should
c6ndition the granting of this variance.
We disagree with all those
additional recommendations for the following reasons:
1)
The first recommendation of the Agency *as that the complete
installation of phase
1
and
2 be finished within
six
months from the
date of entry of the decision by the Board.
The Agency did not
support this rather severe time schedule with
any
witnesses who could
actually say that this operation could be completed within that time.
The strongest case the Agency made was
that
phase
1
and 2 should be
constructed
at
the
same
time, and that
it
was
not
necessary
to
complete
phase
1,
then
do
a
pilot
study
to
determine
how
big the
carbon
columns
of
phase
2
should
be.
But
there
is
sufficient
engin-
eering
testimony
in
the
record- that
the
most
sensible
way
to
construct
this
waste
treatment
facility
is
to
complete
phase
1,
then
do
a
pilot
study
to
determine
what
the
sizing
of
phase
2
should
be,
then
install,
phase
2.
Perhaps,
this
Board
would
make
a
different
decision
if
there
was
an
extended
period
of
time
over
which
phase
2
of
the
project
would
be
completed.
But
phase
1
will
be
completed
within
a
few
days
and
according
to
Spartan’s
witnesses
70
to
75
of.the
contamj.nants
will
be
removed
by
that
part of
the
waste
treatment
system.
The harm to the stream will be greatly minimized after
June
30, 1971, and, therefore, we can allow the additional
time to complete
phase 2.
2—26
2)
The
Agency
recommended
that
during
the
installation
period
Spartan
should
not
he
allowed
to
launder
shop
towels,
or
produce
the
deep etch aluminum plates.
It
is
clear from
the record that alter—
natives
to both of these practices
are
availal.le at
a higher cost,
ard
£th
a
s
r~f~cantlos~ of efthcj~pc
~r
operat1on—~tre to~eIs
could
he
laundered
in
St.
Louis,
and
the
re~sensitized
plates
could
be
used,
Neither
alternative
seems
to
be
a
viable
one,
and
both
would
create
an
arbitrarpi
or
unreasonable
hardship,
as
contemplated
by
the
Act.
Regarding
the
laundeninq
of
towels,
t..he
Agency
did
not
indacate
in
testimony
what
the
cost
would
he
to
launder
the
towels
elsewhere,
It
was
suggested
that
the
towels
he
laundered
in
St.
Louis,
where
the
discharge
would
be
given
little
treatment
in
that
sewer
system.
As
for
the
plates,
we
arc
convinced
that
Spartan
would
like
to
use
the
pre—sensitized
plates
because
they
are
economical
and
easy
to
make,
However,
Spartan
recognizes
that
tddy
are
unreliable
and
not
very durable,
To use those plates
in the Snartan operation would,
according
to the Spartan
testiieony,
severely impair Spartan~sability
to meet the demanding
time schedules
of putting out magazines on
certain days.
This problem would be made much worse by •requiring
shipment of the plates from
St.
Louis.
Furthermore,
as to both
points,
the fact that phase lof
the plant will
be in operation in
a very short
time means
that these wastes will receive some treatment
in the very near
future,
~
~p1n~un
epnsui~utee
h~
s~
~
end
~~nrI’i—
sions of
law,
It
is the order of the Board that the request
of Spartan Printing
for
a variance be granted subject to the following conditions:
I.
Phase
1 of the treatment system shall
be installed
and in
operation by July
1,
1971.
2.
Phase
2 of the treatment system shall
be installed and
in
operation by March
30,
1972,
3.
Spartan shall
pay
to the State of
Illinois,
on o~rbefore
July
28,
1971,
the sum of $10,000
as
a penalty for delay
in completing
the treatment facilities.
4.
Spartan Printing shall post with
the Environmental
Protection Agency on or before July
28,
1971,
in such form as
is satis-
factory to the Agency
a bond or other security
in the amount of
$200,000, which sum shall be forfeited to the State of
Illinois
in
the event that the conditions
of the order are violated or the
printing plant
is operated without
an extension of
the variance and
without Phase
I and
2 in operation on said above-mentioned dites,
2
—
27
5.
During the period this variance
is in effect,
Spartan
Printing shall not increase the pollutional nature of its discharge
either
in
st~ength
or
volume.
6.
Sp~artanshall
file
with the Board and the Agency progress~
reports
on:
September 30,
1971,
December
30,
1971,
and March
30,
1972.
7.
The failure of th~petitioner—to adhere
to any of the
conditions of
this order
shall
be grounds for revocation
of the
variance.
I, Re~ina E.
Ryan, Clerk of the Pollution Control Board,
certify that the~Board adopted the above opinion and order this
~
day of
~
l97l.~—--~
I
/
V
I
~.
~
2
—
213
