ILLINOIS POLLUTION CONTROL BOARD
    May
    3,
    1973
    )
    REYNOLDS
    METALS
    COMPANY,
    )
    a corporation
    )
    v.
    j
    PCB
    72-518
    ENVIROM4BNTAL
    P~TBcTIONAGENCY
    5
    )
    OPINION OF THE BOARD (by Mr. Dunelle)
    This opinion is in support of the Board order entered herein
    on April
    12, 1973.
    This is a petition requesting a variance from
    Rules 921(d)
    and
    1002 of the
    1~aterRegulations
    until
    June
    1,
    1973
    and also from Rule 903(a) until such time as the Agency shall grant
    petitioner’s resubmitted operating permit application for its out-
    fall.
    Hearing was held on March 2, 1973.
    Reynolds owns
    and operates a large manufacturing facility at
    McCook, Illinois for the making and shaping of aluminum alloys.
    The plant employs 2,500 people.
    They produce annually around
    450,000,000 pounds of aluminum alloy in sheet, plate and other
    forms from aluminum pig, scrap and various alloying metals.
    Waste
    materials from the operation include oils,
    acids, caustics,
    phosphates and various metals and metal oxides, both
    as suspended
    and dissolved solids.
    They operate a wastewater treatment system
    consisting of pH adjustment followed by oil skimming, emulsion
    breaking, dissolved solid precipitation, flocculation and clarifi-
    cation.
    They maintain three outfalls, all of which discharge into the
    Summit-Lyons Ditch.
    The West outfall discharges
    from the industrial
    wastewater treatment plant, the East outfall discharges oil separator
    effluent and the third outfall is for bypassing the industrial waste-
    water treatment effluent during heavy rainfall.
    The bypass is rarely
    used since petitioner maintains three retention ponds to alleviate
    the need for bypassing.
    Petitioner is currently operating its East outfall pursuant
    to an Agency permit.
    Their permit application for the West outfall
    was denied by the Agency on November 21, 1972 because under Rule
    921(d) a permit cannot be issued until a project completion schedule
    is filed and approved pursuant to Rule 1002 and none has been filed.
    7—Il?
    -2-
    Within one week
    after
    receiving the Agency’s letter of denial,
    the petitioner’s plant engineer and members
    of his staff met with
    persons
    from the Agency’s permit section to discuss the denial.
    As
    a
    result of that meeting and of the petitioner’s engineering staff’s
    subsequent investigation of the West outfall treatment plant petitioner
    decided to seek outside expertise to determine and design the modifi-
    cations
    to its entire wastewater treatment system
    as would be necessary
    for timely compliance with both federal and state
    requirements.
    Early in December, 1972
    the petitioner contacted
    a nationally-
    known firm of environmental consulting engineers
    to prepare
    a project
    completion schedule for the Agency.
    After review of the plant
    and
    treatment facilities,
    a joint determination was made in mid-December
    by the consulting engineers and petitioner’s own engineers that
    a
    project completion schedule could be prepared and submitted to the
    Agency by June
    1,
    1973.
    Prior to the adoption of the Board’s
    current Water Pollution
    Regulations,
    the petitioner had undertaken efforts
    to reduce the
    fluoride levels through process modifications.
    Control
    of fluoride
    levels was attempted through reduction of the amount
    of fluoride
    being discharged into the wastewater.
    This method was attempted
    because low level concentrations of fluorides are very difficult
    to treat,
    and also since the petitioner’s existing treatment facilities
    were designed to treat heavy metals,
    oils and suspended solids rather
    than fluorides.
    Input of fluorides
    to
    the wastewater was
    in fact
    reduced by fifty percent by May,
    1972 through work with its conversion
    coatings suppliers on changing the chemical formulation of various
    coatings.
    An even further reduction in fluoride input was
    achieved
    by the same method in September 1972.
    As we have done
    in other cases recently, we will grant the
    variances so that the petitioner may receive its permit for the
    facility.
    We should note, however, that
    this variance in no way
    excuses
    the petitioner from compliance with any substantive provi-
    sions of the Act
    or Regulations.
    The Agency did recommend
    a denial for the reason that
    the hard-
    ship was self imposed.
    We take
    the position that
    a denial would serve
    no useful purpose
    at this point.
    There are only
    a few months involved
    and we would rather see permits issued and the job completed.
    This opinion constitutes
    the Board’s findings
    of fact and
    conclusions of law.
    I,
    Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Opinion
    was
    adopted on the
    ~
    day of May, 1973 by
    a vote of ______________________
    Illinois Po
    rd
    Board
    7
    —
    688

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