ILLINOIS POLLUTION CONTROL BOARD
    September 1,
    1994
    IN THE MATTER OF:
    )
    )
    PETITION OF ALUMAX INC.
    )
    AS 92-13
    FOR AN ADJUSTED STANDARD
    )
    (Adjusted Standard)
    FROM 35 ILL: ADM. CODE
    )
    PART 218
    )
    KATHERINE D. HODGE OF HODGE
    AND
    DWYER APPEARED ON BEHALF OF
    PETITIONER, ALUNAX INC.;
    SHEILA G. KOLBE APPEARED ON BEHALF OF PETITIONER,
    ILLINOIS
    ENVIRONMENTAL PROTECTION AGENCY.
    OPINION
    AND
    ORDER OF THE BOARD
    (by M. McFawn):
    This matter is before the Board on a joint petition for
    adjusted standard filed by Aluniax Inc.
    (Alumax) and the Illinois
    Environmental Protection Agency
    (Agency) on December 20,
    1993.
    The petitioners request that Alumax be given an adjusted standard
    from the air emission control requirements of 35 Iii.
    Adni.
    Code
    Part 218 Subpart TT for its aluminum sheet manufacturing facility
    located in Morris,
    Illinois.
    The Board’s responsibility in this matter arises from the
    Environmental Protection Act
    (Act)
    (415 ILCS 5/1 et seq.).
    The
    Board is charged therein to “determine,
    define and implement the
    environmental control standards applicable in the State of
    Illinois”
    (Section 5(b)
    of the Act)
    and to “grant
    .
    .
    .
    an
    adjusted standard for persons who can justify such an adjustment”
    (Section 28.1(a)
    of the Act).
    Thus,
    the Board is charged with
    the rulemaking functions under the Act, including the authority
    to grant individual adjusted standards which are different from
    the Board’s generally applicable regulations.
    Although usually
    granted as permanent relief, the adjusted standard is not adopted
    as
    a rule.
    Rather,
    the opinion and order granting, and
    oftentimes conditioning, the relief requested serves as the
    regulatory and enforcement vehicle.
    Based upon the record before it and upon review of the
    factors involved in the consideration of adjusted standards, the
    Board finds that petitioners have demonstrated that grant of the
    adjusted standard sought
    is warranted.
    The adjusted standard
    accordingly is granted.
    ADJUSTED STANDARD PROCEDURE
    Section 28.1 of the Act provides that a petitioner may
    request, and the Board may adopt,
    an environmental standard that
    is:
    (a) applicable solely to the petitioner,
    and
    (b) different

    2
    from the standard that would otherwise apply to petitioner
    pursuant to a rule of general applicability.
    Such a standard
    is
    called an adjusted standard.
    The general procedures that govern
    an adjusted standard proceeding are found at Section 28.1 of the
    Act and within the Board’s procedural rules at 35
    Ill. Adm. Code
    Part 106.
    Where, as here, the regulation of general applicability does
    not specify a level of justification required for a petitioner to
    qualify for an adjusted standard, the Act at Section 28.1(c)
    specifies four demonstrations that must be made by a successful
    petitioner:
    1)
    Factors relating to that petitioner are substantially
    and significantly different from the factors relied
    upon by the Board in adopting the general regulation
    applicable to that petitioner;
    2)
    The existence of those factors justifies an adjusted
    standard;
    3)
    The requested standard will not result in environmental
    or health effects substantially and significantly more
    adverse than the effects considered by the Board
    in
    adopting the rule of general applicability; and
    4)
    The adjusted standard
    is consistent with any applicable
    federal law.
    (415 ILCS 5/28.1(c).)
    PROCEDURAL HISTORY
    Alumax originally filed a petition for adjusted standard on
    November
    25,
    1992.
    On January 7,
    1993,
    the Board issued an order
    finding this petition deficient, and directing Alumax to submit
    an amended petition by March
    8,
    1993.
    On March
    6,
    1993, Alumax
    submitted an amended petition.
    By order dated March 25,
    1993,
    the Board found the amended petition to be deficient as well, and
    ordered Alumax to submit an additional amended petition by
    April
    16,
    1993.
    On April
    5,
    1993, Alumax filed a motion
    requesting an extension of time to file
    a second amended
    petition, and the Board granted a 30-day extension until May 16,
    1993.
    Subsequently, Alumax requested
    3 additional extensions
    while engaged in negotiations with the Agency, which the Board
    granted.
    During that time, Alumax requested the Agency to join as co-
    petitioner in this adjusted standard proceeding,
    and the Agency
    agreed.
    On December 13,
    1993, Alumax and the Agency jointly
    requested a 21-day extension until January
    3,
    1994 to file a
    joint petition, which the Board granted by order dated December

    3
    16,
    1993.
    Alumax and the Agency submitted
    a joint petition for
    adjusted standard on December 20,
    1993.
    Petitioners included
    proposed language for the adjusted standard as Exhibit
    8.
    Hearing was held in this matter on March
    1,
    1994 in Morris,
    Illinois, before hearing officer Deborah Frank.
    At hearing,
    Mr.
    Walter
    3.
    Hawkins and Mr. Michael P. MacDonald testified on
    behalf of Aluinax, and Mr. Chris Romaine testified on behalf of
    the Agency.
    No members of the public attended.
    On May
    31,
    1994,
    the parties jointly filed a motion to correct the transcript,
    which is hereby granted.
    Simultaneously,
    the parties filed
    amended proposed language for a Board order granting the adjusted
    standard, which replaced the language previously submitted as
    Exhibit
    8.
    RULE OF GENERAL APPLICABILITY
    Petitioners seek an adjusted standard from the air emission
    control requirements of
    35 Ill. Adm. Code Part 218.
    These
    regulations became applicable to the Alumax facility as a result
    of the Board’s adoption of amendments to the reasonably available
    control technology
    (RACT)
    rules in R9l-28.
    These amendments
    expanded the Chicago ozone non—attainment area to include Goose
    Lake and Aux Sable Townships in Grundy County and Oswego Township
    in Kendall County.
    These regulations became effective November
    15,
    1992,
    and affected stationary sources of VON emissions in
    these townships, including the Aluinax facility, were required to
    demonstrate compliance by November 15,
    1993.
    RACT is defined as
    “the lowest emission limitation that an emission unit is capable
    of meeting by the application of control technology that is
    reasonably available considering technological and economic
    feasibility.”
    (35 Ill. Adm. Code 211.5370.)
    Alumax is subject to the requirements in Subpart TT of the
    RACT rules,
    entitled “Other Emission Units.”
    Pursuant to Section
    218.980(b) (1), the applicability threshold for Subpart TT is
    potential to emit 25 tons per year.
    The applicable emission
    control requirements are set forth in Section 218.986, which
    states in pertinent part:
    Every owner or operator of an emission unit subject to this
    Subpart shall comply with the requirements of subsection
    (a),
    (b),
    (C),
    (d),
    or
    (e)
    below.
    (a)
    Emission capture and control equipment which achieve an
    overall reduction in uncontrolled VON emissions of at
    least 81 percent from each emission unit,
    or
    (C)
    An alternative control plan which has been approved by
    the Agency and the USEPA in a federally enforceable

    4
    permit or as a SIP revision.
    Alumax thus seeks an exception from the requirement that it
    reduce its VON emissions by 81 percent.
    Additionally, Alumax’s facility is subject to Section
    218.108, which states in relevant part:
    (a)
    Notwithstanding the provisions of any other Sections of
    this Part, any exemptions, variations or alternatives
    to the control requirements, emission limitations, or
    test methods set forth in this Part shall be effective
    only when approved by the Agency and approved by the
    USEPA as a SIP revision.
    Alumax does not believe that it needs to obtain relief from
    Section 218.108.
    Based on language in the Board’s second notice
    opinion in R93-l4, entitled “In the Matter of Reasonably
    Available Control Technology for Major Sources Emitting Volatile
    Organic Materials in the Chicago Ozone Nonattainment Area:
    25
    Tons”
    (November 18,
    1993), Alumax believes that, while it will
    ultimately be necessary to obtain USEPA’s approval of the
    adjusted standard from Section 218.986 as a State Implementation
    Plan
    (SIP)
    revision, the adjusted standard will be effective at
    the state level immediately upon granting by the Board.
    In our second notice opinion in R93-14, the Board affirmed
    the Agency in interpreting Section 218.108 as follows:
    Section 218.108
    is intended to assure the regulated
    community and to inform USEPA and the public that variations
    from adopted rules are available from the
    Board), while
    assuring USEPA that such an action by the state will not
    unilaterally alter the SIP approved by USEPA.
    The Agency
    states that subsection
    (a)
    of Section 218.108 simply
    reiterates the Board’s grant of an adjusted standard, site
    specific rule, or variance does not protect a source from
    federal enforcement until that relief
    .
    .
    .
    is approved by
    the USEPA as a SIP revision
    .
    .
    .
    .
    In sum the Agency
    states that Section 218.108 reiterates relief already
    available to sources and applies generally to the rules, and
    thus has no particular relationship to any particular
    subpart.
    (Id.
    at 5—6.)
    The Board agrees with Alumax that it is not necessary for
    Alumax to receive an adjusted standard from 218.108(a)
    for the
    adjusted standard from Section 218.986 to become effective on the
    state level.
    The adjusted standard from Section 218.986 will be
    effective immediately when granted by the Board.
    Ultimately,
    it
    will have to be approved by the USEPA as a SIP revision.

    5
    BACKGROUND
    Alumax operates an aluminum sheet manufacturing facility in
    Morris, Aux Sable Township, Illinois which produces a wide
    variety of coiled and flat aluminum sheet.
    The facility has been
    in operation since 1968 and employs approximately 350 people.
    (Am. Pet. at 7.)’
    The plant’s manufacturing process includes a hot rolling
    mill and two cold rolling mills.
    The hot rolling mill is used to
    reduce 22—inch thick cast ingots to aluminum sheet between two
    tenths of an inch thick and a quarter inch thick.
    A cold rolling
    mill is then used to further reduce the thickness of the aluminum
    sheet as necessary to meet customer needs and to produce superior
    finished surfaces.
    (Am. Pet. at 7.)
    During both the hot and cold rolling processes, the aluminum
    sheet is sprayed with rolling lubricant, which cools and
    lubricates the metal during the rolling operations.
    In both
    processes, the lubricant is sprayed on in large volumes, and the
    excess is collected in a sump and recirculated.
    (~)
    The
    rolling lubricants are a source of VON emissions for both the hot
    and cold rolling processes.
    (Exh.
    1 at
    8;
    Exh.
    2 at 7.)
    The lubricant used in the hot rolling process consists of an
    oil in water emulsion, typically maintained at
    6 percent oil, but
    no more than 10 percent oil.
    (Exh.
    1 at
    6; Am.
    Pet.
    at 13.)
    This is the minimum practical amount of oil which can be used in
    the rolling mill fluid.
    It is necessary to use an oil in water
    emulsion for the hot rolling process since it is operated at
    approximately 1,000 degrees Fahrenheit,
    and the oil would burn if
    used by itself.
    Some of the water from the emulsion vaporizes
    upon contact with the surface of the aluminum, creating a “steam
    blanket” above it.
    The steam blanket is collected by the hood
    system
    as described below.
    (Exh.
    1 at 6.)
    The hot mill
    lubricant reservoir is maintained at a maximum temperature of 150
    degrees Fahrenheit in order to minimize VON emissions through
    vaporization from the reservoir.
    (Exh.
    1 at
    6,
    12.)
    During the cold rolling process, which is performed at room
    temperature with metal temperatures below 265 degrees Fahrenheit
    (Exh.
    2 at 2), the lubricant used is a highly paraffinic oil with
    additives.
    (Exh.
    2 at
    5; Am.
    Pet. at 8.)
    Additionally, during
    fifteen percent of the passes through the cold rolling mill,
    Stoddard Solvent,
    a highly paraffinic solvent,
    is applied to the
    aluminum to remove excess lubricant,
    in a process called solvent
    1
    The amended petition will be cited as “Am.
    Pet. at
    “,
    exhibits will be cited as “Exh.
    #
    at
    “,
    and the hearing
    transcript will be cited as
    “Tr. at
    “.

    6
    washing.
    (Tr. at
    16; Am. Pet. at 8.)
    This
    is necessary to
    prevent staining during the annealing process, which follows the
    rolling process.
    The Stoddard Solvent is also a source of VOM
    emissions for the cold rolling process.
    The excess solvent is
    captured in the coolant sump and becomes an additive to the
    rolling lubricant.
    (Exh.
    2 at
    4; Tr. at 17.)
    A hood system is employed at both the hot mill and cold
    mills, which collects the fumes generated.
    The collected fumes
    are treated with a Busch cyclonic unit that separates out and
    collects particulates and droplets of oil for reuse.
    (Exh.
    1 at
    8 and 13;
    Exh.
    2 at
    2 and 16.)
    The remainder, which has been
    vaporized,
    is vented to the atmosphere.
    The rolling operations
    thus result in emissions of volatile organic materials in vapor
    and aerosol forms.
    Alumax performed emission testing at its facility from
    August 31 through September
    2,
    1993, the results of which were
    attached to the amended petition as Exhibit
    3.
    Based on this
    testing, Alumax estimates that its actual VON emissions are as
    follows:
    1)
    for the hot rolling mill,
    the estimated emissions are
    approximately
    6 tons per year (0.02 tons per day);
    and
    2)
    for the cold rolling mills, the estimated emissions total
    approximately 88 tons per year (0.24 tons per day).
    (Exh.
    4; see calculations in Exh. 5.)
    The facility’s emissions,
    actual and potential,
    thus exceed 25
    tons per year, the threshold for applicability of control
    requirements.
    COMPLIANCE EFFORTS
    In November 1992,
    Alumax conducted studies of potential VON
    control technologies for its hot rolling
    (Exh.
    1)
    and cold
    rolling
    (Exh.
    2) processes.
    No add—on control technologies were
    found at any facility.
    Alumax investigated control technologies
    used at sources with similar emissions.
    The technologies
    investigated for both the hot rolling process and the cold
    rolling process included incineration, oil absorption,
    and carbon
    adsorption.
    For the cold rolling process only, Alumax also
    investigated the use of stream concentration with additional
    controls.
    Subsequently, after Alumax performed its emissions
    tests in August
    -
    September 1993, Alumax recalculated the costs
    of various control methods using the updated data.
    The results
    of these investigations are discussed below.
    Incineration.
    Alumax investigated the installation and
    operation of an incinerator for both its hot and cold rolling

    7
    mill emissions.
    The estimated annual cost of installing and
    operating an incinerator for the hot rolling process is $174,500
    per ton, assuming a capture and control efficiency of 81 percent,
    although such efficiency is not guaranteed by the equipment
    vendor.
    (Exh.
    6.)
    The estimated annual cost of installing and
    operating an incinerator for the for the cold rolling process is
    estimated to be $25,811 per ton.
    (Exh.
    7.)
    Alumax asserts that
    these costs render the technology economically unreasonable.
    Alumax also asserts that incineration is technologically
    infeasible for the hot rolling process, due to low-level,
    variable VON concentrations and high water concentration in the
    hot rolling mill emissions.
    (Exh.
    1 at 13
    -
    15.)
    These
    conditions would require the use of supplemental fuel, which
    would increase operating costs, and could result in incomplete
    combustion, which would generate additional VON emissions and
    nitrogen oxides emissions.
    (~~)
    Alumax also asserts that incineration is an unsafe
    technology for use on either the hot or cold rolling mills.
    The
    variable nature of the emissions from the rolling processes can
    lead to a buildup of an explosive level of fumes in the exhaust
    system.
    An incinerator would introduce a flame source into this
    environment, creating an unwarranted risk of mill fires.
    Alumax
    points out that incineration is not used as an emission control
    technology on rolling mills anywhere in the world.
    (
    Exh.
    2 at
    16.)
    Oil Absorption.
    Alumax also investigated the use of oil
    absorption for both its hot and cold rolling processes.
    (Exh.
    1
    at 15; Exh.
    2 at 18.)
    This technology uses a scrubber system
    wherein the mill exhaust gas stream is exposed to a wash oil that
    absorbs the VON.
    The VON is then separated from the wash oil by
    use of a continuous vacuum distillation system, and the wash oil
    is recirculated for reuse.
    For the hot rolling process, Alumax asserts that the varying
    vapor pressures that result from the use of the oil in water
    emulsion as a rolling lubricant render this technology
    ineffective.
    (Exh.
    1 at 16-17.)
    There are no vendors which have
    such a treatment system available for a hot rolling process or
    any oil and water emulsion.
    Alumax therefore has found this
    process to be technologically infeasible for the hot rolling
    process.
    While oil absorption has been used as a treatment technology
    for new cold rolling mill installations,
    it has not been used as
    a retrofit technology.
    (Exh.
    2 at 18
    -
    20.)
    Retrofitting an
    existing plant for application of this technology would be
    constrained by many site specific factors, due to the size of the
    control units and the complex ductwork required.
    The structures
    necessary to treat one large rolling mill would occupy an area of

    8
    approximately 40 by 55 feet,
    and would weigh at least 50 tons.
    (Exh.
    2 at 20.)
    This would need to be constructed adjacent to
    each of the existing mills, and would require establishment of a
    suitable foundation for each unit.
    Alumax determined that the
    annual cost of retrofitting its cold rolling mills with oil
    absorption technology would be $40,200 per ton.
    (Exh.
    7.)
    Therefore, Alumax asserts that this technology is economically
    unreasonable.
    Carbon adsorption.
    Carbon adsorption is a two—phase process
    wherein hydrocarbons and other compounds are selectively
    attracted to the surface of an adsorbent material, generally
    activated carbon.
    The adsorbent material is then subject to
    regeneration, usually through steam or a vacuum.
    (Exh.
    1 at
    17;
    Exh.
    2 at 20.)
    Alumax investigated the use of both fixed-bed
    carbon adsorption and fluidized—bed carbon adsorption systems.
    Alumax found that the high vapor content of emissions from
    the hot rolling mill makes this technology infeasible for its hot
    rolling process.
    The water would be preferentially adsorbed by
    the adsorption bed, which would prevent the carbon from removing
    a substantial amount of VON.
    (Exh.
    1 at 19.)
    This technology
    therefore has never been installed on hot rolling mills.
    (~~)
    For the cold rolling process, Alumax found that this
    technology has been installed on only a single new rolling mill
    in the United States, and that it has never been used as a
    retrofit technology.
    (Exh.
    2 at 22.)
    Alumax asserts that this
    technology is not appropriate for its facility due to the high
    potential for rapid fouling of the carbon beds by the heavy
    lubricant compounds.
    Additionally, due to this heavy lubricant
    fouling, Alumax would be unable to regenerate the carbon on—site,
    and would have to frequently change the carbon.
    (Exh.
    2 at 22
    -
    23.)
    Stream concentration.
    Stream concentration with additional
    controls was also investigated as a potential emission control
    only for the cold rolling process.
    This technique uses activated
    carbon to concentrate a dilute waste stream prior to ultimate
    disposal through incineration.
    (Exh.
    2 at 23
    -
    24.)
    Alumax asserts that,
    similar to carbon adsorption,
    application of this technique would be technologically infeasible
    due to heavy fouling of the carbon.
    (Exh.
    2 at 24.)
    The expense
    and downtime caused by frequent fouling make this process
    infeasible for the Alumax facility.
    Additionally, even if the
    waste stream was concentrated 10—fold, the inlet concentration
    would be low, requiring the use of supplemental fuel.
    (~)
    The
    risks associated with operation of a flame source are also
    present.
    (~~)
    Alumax thus asserts that this technology is
    infeasible for its facility.

    9
    As a result of its studies, Alumax determined that there is
    no add-on control technology that is proven to be technologically
    transferable or commercially available for its aluminum hot or
    cold rolling mill operations.
    Therefore, both Alumax and the
    Agency agree that the proposed alternative control requirements
    would result in the highest possible limitations on potential VON
    emissions, and constitute RACT for both the hot and cold rolling
    mills.
    (Am.
    Pet. at 12.)
    PROPOSED ADJUSTED STANDARD
    The co—petitioners have proposed an adjusted standard which
    consists of the control and treatment practices currently
    employed by Alumax.
    The proposed practices include the use of
    low volatility lubricants,
    use of a low volatility solvent, and
    temperature controls to minimize VON emissions.
    These practices
    are combined with the use of a hood system and Busch cyclonic
    unit to collect and treat emissions.
    The proposed adjusted
    standard also includes additional monitoring and record keeping
    requirements.
    HEALTH AND ENVIRONMENTAL EFFECTS
    The co-petitioners assert that there will be no significant
    difference in impact to the environment whether Alumax complies
    with the 81 percent capture and control standard set forth in
    Subpart TT or with the proposed alternative control requirements.
    The total combined difference in emissions will be approximately
    76 tons per year,
    or approximately 0.2 tons per day.
    (Am.
    Pet.
    at 14.)
    The VON emissions from the hot and cold rolling
    operations represent less than one percent of the of the 1990
    point source emissions for the two designated townships in Grundy
    County, and far less than one/half of one percent of the 1990 VON
    point source emissions for the Chicago nonattainment area.
    (Am.
    Pet. at 17.)
    Thus, Alumax and the Agency assert that application
    of the proposed alternative requirements would not have a
    significant adverse impact on the environment.
    CONSISTENCY WITH FEDERAL LAW
    The co-petitioners assert that the proposed adjusted
    standard would be consistent with federal law.
    They assert that
    the proposed alternative standard constitutes RACT for the
    facility, and is therefore consistent with the federal Clean Air
    Act.
    Furthermore,
    the proposed alternative requirements are
    consistent with a site-specific rule recently proposed by the
    United States Environmental Protection Agency
    (USEPA)
    for
    aluminum rolling operations at the Reynolds Metals facility in
    McCook,
    Illinois.
    (Exh.
    12.)

    10
    CONCLUSION
    The Board finds that the joint petitioners have demonstrated
    that an adjusted standard is appropriate for the Alumax facility
    in Norris,
    Illinois.
    The co-petitioners have demonstrated that
    there is no other technologically transferable and economically
    feasible control technology, and have demonstrated that the
    proposed alternative standard will not significantly impact human
    health or the environment.
    Because petitioners have demonstrated
    that there is no add-on technology which can be applied as RACT
    to the Alumax facility which would enable it to meet the 81
    percent VON emissions reduction mandated by Section 218.986, we
    find that petitioners have demonstrated that factors relating to
    Alumax are substantially and significantly different from those
    relied upon by the Board in adopting the rule of general
    applicability, and that these factors warrant the granting of an
    adjusted standard.
    Furthermore, petitioners have demonstrated
    that the proposed alternative standard will be consistent with
    federal law.
    The proposed adjusted standard will accordingly be
    granted, subject to conditions as suggested by the parties.
    This opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    Alumax Inc.
    is hereby granted an adjusted standard from 35
    Ill.
    Adm. Code 218.986, pursuant to 415 ILCS 5/28.1,
    for its
    facility located in Morris, Grundy County,
    Illinois,
    subject to
    the provisions and conditions listed below:
    A)
    The adjusted standard pertains to VOM emissions from
    the operation of Alumax’s aluminum hot rolling mill and
    two aluminum cold rolling mills.
    B)
    The alternative control requirements proposed in the
    December 20,
    1993 petition for adjusted standard, based
    upon current operating procedures of the VON emission
    sources identified in paragraph
    (A)
    above, represent
    Reasonably Available Control Technology
    (RACT)
    and no
    additional controls are required to meet the
    requirements of 35 Ill.
    Adm. Code 218.986
    (a),
    (b),
    (c),
    (d), or
    (e).
    C)
    Alumax shall comply with the following requirements at
    its aluminum hot rolling mill:
    1)
    Rolling lubricants shall consist of oil-in—water
    emulsions, with formulations of no more than 10
    percent, by weight,
    of petroleum-based oils and
    additives.
    Records shall be maintained of such
    emulsion formulations, with identification of all

    11
    oils and additives.
    2)
    A grab sample of the as-applied rolling lubricant
    shall be taken on a monthly basis during any month
    that the mill is in operation and each such sample
    shall be tested,
    using ASTN method D95-83, to
    determine the percent,
    by weight, of petroleum-
    based oils and additives.
    3)
    The inlet sump rolling lubricant temperature shall
    not exceed 200°F and such temperature shall be
    monitored at all times that the mill is in
    operation by the use of thermocouples and measured
    values shall be automatically recorded at least
    every five
    (5)
    minutes by means of a computer data
    system.
    4)
    All records of emulsion formulations, percent oil
    tests,
    and rolling lubricant temperatures shall be
    retained for a period of at least three
    (3) years
    and be available for inspection by the Agency.
    D)
    Alumax shall comply with the following requirements at
    each of its aluminum cold rolling mills:
    1)
    Rolling lubricants shall consist of low vapor
    pressure lubricants composed of highly paraffinic
    oils and additives.
    Records shall be maintained
    of rolling lubricant formulations, with
    identification of all oils and solvent additives.
    2)
    The initial and final boiling points of the as—
    received oils shall be between 440 and 650°F.
    All incoming shipments of oils shall be sampled
    and a distillation range test shall be performed,
    using ASTM method D86-90, on each such sample to
    determine the initial and final boiling points.
    3)
    Stoddard solvent shall be the only solvent
    additive used in rolling lubricants.
    The initial
    and final boiling points of the as-received
    Stoddard solvent used shall be between 310 to 390°
    F.
    All incoming shipments of Stoddard solvent
    shall be sampled and a distillation range test
    shall be performed,
    using ASTN method D86—90, on
    each such sample to determine the initial and
    final boiling points.
    4)
    The initial boiling point of the as—applied
    rolling lubricants shall be greater than 310°F,
    and no more than 10.0 percent of the as-applied

    12
    rolling lubricants shall boil off between the
    initial boiling point and 440°F.
    A grab sample
    of the as-applied rolling lubricants shall be
    taken on a monthly basis from each mill during any
    month that a mill is in operation and a
    distillation range test, using ASTM Method D86—90,
    shall be performed on each such sample to
    determine the initial boiling point and the amount
    boiled off between the initial boiling point and
    440°F.
    5)
    The inlet sump rolling lubricant temperatures at
    each mill shall not exceed 150°F and such
    temperatures shall be monitored at all times that
    a mill is in operation by the use of thermocouples
    and measured values shall be automatically
    recorded at least every five
    (5) minutes by means
    of a computer data system.
    6)
    All records of rolling lubricant formulations,
    distillation tests for oils,
    Stoddard solvent, and
    as-applied rolling lubricants, and rolling
    lubricant temperatures shall be retained for a
    period of at least three
    (3) years and be
    available for inspection by the Agency.
    E)
    A written report shall be submitted to the Agency
    indicating any deviations from the requirements of
    paragraphs
    (C) (1)
    (3)
    and D(l)
    -(5)
    above.
    The
    written report shall provide a description of the
    deviation,
    the date and time of the deviation,the
    measured or monitored data, the cause of the deviation,
    if known, and any corrective action taken.
    Unless more
    frequent or detailed reporting is required under other
    provisions,
    including permit conditions,
    such written
    report shall be submitted,
    for each calendar year, by
    February 15 of the following year.
    (F)
    This Adjusted Standard is effective upon granting by
    the Board.
    Aluinax shall comply with the provisions and
    conditions listed above within 60 days of the Board’s
    Final Order in this matter.
    G)
    In the event that Alumax ceases to own and operate this
    facility, the above requirements shall apply to any
    subsequent owners and operators of the facility.
    IT IS SO ORDERED.

    13
    Section 41 of the Environmental Protection Act
    (415 ILCS
    5/41
    (1992))
    provides for the appeal of final Board orders within
    35 days of the date of service of this order.
    The Rules of the
    Supreme Court of Illinois establish filing requirements.
    (See
    also 35 Ill. Adm. Code 101.246.
    “Motions for Reconsideration.”)
    I, Dorothy N. Gunn,
    Clerk of the Illinois Pollution Control
    Board, hereby certify that the above opinion and order was
    adopted on the
    /~
    day of
    ~
    ,
    1994,
    by a
    vote of
    ~
    .
    Illinois
    Control Board

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