ILLINOIS POLLUTION CONTROL

BOARD

NORTHERN PETROCHEMICAL COMPANY

V.

ENVIRONMENTAL PROTECTION AGENCY

June

9, 1971

#71—47

OPINION OF THE BOARD (BY MR. LAWTON):

NORTHERN PE:~C:~CHEM:CALCOMPANY filed a Petition for

Variance

under Section ~

~c

of ohe Environmental Protection Act and Rule

2-1.3 of the to

Regulations Governing the Control of Air

Pollution,

orroposes to conduct a fire-fighting training

course for

I on its property located approximately

eight miles

City of Morris in Crundy County. As proposed,

the course

;

I.e June ai~dbe conducted twice a week, continuing

through th

HT~tober, 1971. Various solvents and materials

generated

.

~octuring process of Petitioner would be burned

in the oto~

:temonstration of various types of equipment

employed

.::

of fires. Approximately 50 gallons of

gasoline,

~ quified propane would be burned during

each

trot;

which would last no more than 30 minutes per

session.

we: ~I

take place on the property of Petitioner.

NiI.

Enviroo:~e

—

consider~.

200 feet

anproxtow

of the I

-

of the

fire.

11

notes

of Sloe

althcu

plant

area.

fightir.::

that oh;

proposed,

than 4 ~e:o.

June 1, 1

in the Petition, investigation by the

..;:;on Agency discloses that three sites are under

0, or the north edge of Petitioner’s property

P.oute 6, Site B in the center of the property

‘~e~north of scattered homes on the south bank

owen Canal and Site C on

the southeast corner

w:r:rheast of the

last residences.

Adequate

~ould

be on hand to preclude the

spread of

:.o ~Jf the

Environmental Protection Agency

.S~O,Lth residents in the area, particularly

eubstantial obiection to the proposed burning

ewe expressed to the

odors from Petitioner’s

s located in

an industrially-developed

.1. E300lovees

would he

involved in the f ire—

~ccnmental Protection Agency recommends

wood, cut rather than the 44 demonstrations

~eI.to 10 demonstrations, with no more

calendar month for the pericd between

---

The Environmental Protection Agency notes that in the case

of Deere & Co. v. Environmental Protection Agency, #70-20, 2

sessions were requested for a total of 60 employees, indicating

that 30 pupils could receive the necessary instruction during a single

session. On the basis of the number of employees involved in the

present case, and the period of time available, the Environmental

Protection Agency’s proposal appears reasonable. Also of the three

sites proposed, it suggests that Site C is clearly preferable.

It is the most distant from residential development and in the

vicinity of industrial activities and not likely to create safety

hazards for traffic and burdens on nearby residents.

In Deere, we noted:

“The importance of instructing employees in firefighting

techniques is clear. Indeed, such instruction not only may

reduce injuries and property losses due to fire; it may in

the long run result in less air pollution, since the destruction

of a plant by fire would emit far more pollution than a few

small and controlled instruction sessions. Moreover, we agree

with Deere that there is no ~ubstitute, in learning how to

fight fires, for actually fighting fires. Further, Deere

tells us its insurability may depend upon adequate fire-

fighting knowledge among its employees.”

The same considerations maintain in the present case and we

grant the variation -subject to the terms and conditions hereinafter

set forth. As in Deere, we waive the requirement for the filing of

any bond.

This Opinion constitutes the finding of fact and conclusions

of law of the Board.

IT IS ORDERED by the Pollution Control Board that Northern

Petrochemical Company be authorized to burn solvents in the open

for purposes of conducting a training course in fire-fighting, sub-

ject to the following terms and conditions:

1. Demonstrations shall be limited to 10 sessions, taking

place between June 1, 1971 and October 31, 1971, with no

more than 4 demonstrations in ai~iy calendar month,

2. Burning shall be conducted on Site C described in the

recommendation of the Environmental Protection Agency,

and only when the prevailing wind is not from the south-

east.

1 *

682

---

3. Burning shall be conducted only when wind speed is no

less than 5 nor more than 20 miles per hour and only

at such times when weather conditions are such to assure

suitable dispersal of air contaminants.

4. Burning shall be conducted only between the hours of

10:00 A,M. and 4:00 P.M.

5. On or before November 30, 1971, Petitioner shall file

with the Board and with the Agency a report on each

training session as conducted, describing the number of

trainees attending,the character and amount of combustibles

burned, stating the date and type of burning, the total

duration of such burning, a description of weather conditions

and a description of emissions generated by such burning.

6. Suitable fire-fighting equipment shall be on hand to

prevent the spread of the fires.

7. Petitioner shall make every effort to avoid the use of

combustibles that generate extreme smoke and the burning

as conducted shaiLnot cause air pollution as defined

in Section 3(b) of the Environmental Protection Act.

7. The Environmental Protection Agency shall be notified in

advance of the day in which the burning is to take place,

and shall be permitted to observe the training session.

I, Regina E. Ryan, Clerk of the Board, certify t at the Board adopted

the above Opinion and Order this

9’~

day of

~

,

1971.

I

*