ILLINOIS POLLUTION CONTROL BOARD
    May 3, 1973
    OLIN CORPORATION,
    )
    Petitioner,
    v.
    )
    PCB 73-87
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD (by Mr. Seaman):
    Petitioner operates a facility in Marion, Williamson
    County, for the manufacture of various propellant and
    pyrotechnic devices sold mainly to the U. S. Department of
    Defense. The subject of this petition for variance is the
    open burning of explosive waste of a new product Petitioner
    plans to introduce to its Williamson County facility. This
    product will be the assembly or “load and pack’s of inter-
    mediate caliber ammunition, including high explosive
    incendiary ammunition for military use. Petitioner plans to
    install the capacity to assemble 11,000 rounds of ammunition
    per eight-hour work shift. Petitioner indicates that it will
    generate 15.7 pounds of high explosive RDX slurry type scrap
    per shift.
    Petitioner alleges that there is no known method of
    safe disposal of this waste except by open burning. RDX
    possesses such a high energy of detonation as to make burning
    it in a closed vessel extremely hazardous. However, Peti-
    tioner does state that it will investigate other feasible
    alternatives to open burning during the period of the variance.
    No data is available to Petitioner concerning the actual
    products of combustion of RDX. However, if sufficient oxygen
    were present to allow complete combustion, the theoretical
    products of combustion of 15.7 pounds of this scrap are
    alleged to be:
    Carbon dioxide 6.8 lbs.
    Water
    2.5 lbs.
    NOx (as NO2)
    12.4 lbs.
    Aluminum oxide 9.8 lbs.
    The Agency agrees with Petitioner’s estimates.
    7
    — 699
    —2—
    In its Recommendation, the Agency states that the
    explosive RDX waste is at all times kept completely sub-
    merged in water to prevent explosion; that the material
    cannot be transported over great distances because of its
    explosive nature; and that the open burning site is in a
    remote abandoned strip mine. This is the same site where
    Petitioner open burns pyrotechnic waste under a variance
    granted by the Pollution Control Board. The Agency has re-
    ceived no complaints from the public as a result of Peti-
    tioner’s past open burning practices.
    Petitioner is unable to estimate the cost of compliance
    since no method of compliance is presently known. Petitioner
    is further unable to state what injury, if any, would be
    caused by open burning of the scrap here involved. However,
    Petitioner alleges that open burning of sm~allquantities of
    RDX scrap in other states has not caused any noticeable
    damage or caused any complaints to Petitioner.
    Olin Corporation believes that the denial of a variance
    under this petition would impose an arbitrary and unreason-
    able hardship. Petitioner knows of no safe means other than
    open burning to dispose of the explosive scrap here involved.
    This material becomes less stable with age, and storage
    would merely increase a fire and explosive hazard. The
    inability to dispose of this scrap would require Petitioner,
    for safety reasons, to stop production of the item generating
    the scrap.
    In view of the relatively small amount of waste under
    consideration, the current lack of technically feasible
    alternatives to open burning and Petitioner’s pledge to pursue
    and implement methods to achieve compliance, this Board is
    di.-sposed to allow the variance requested, subject to certain
    conditions.
    This opinion constitutes the findings of fact and conclu-
    sions of law of the Board.
    IT IS THE ORDER of the Pollution Control Board that a
    variance be granted to Olin Corporation as requested for a
    period of one year from the date of this opinion subject to
    the following conditions:
    (a) Petitioner shall limit the amount of material to
    be open burned to that amount stated by Petitioner
    in its variance request.
    (b) Whenever possible, Petitioner shall limit its
    open burning to such times when atmospheric
    conditions will readily dissipate any contaminants.
    7
    — 700
    —3—
    (c) Within 30 days of the date of this Order, Peti-
    tioner shall submit in writing a progress report
    to the Agency. Said report shall contain:
    1) Any complaints received by Olin concerning
    the open burning of the RDX;
    2) Progress made toward implementing a program
    of eliminating the open burning of the RDX;
    said reports shall continue monthly during the term of this
    variance.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, certify tha~the above Opinion and Order
    was
    adopted by
    the
    Board onthe~
    day of
    ____ ___________,
    1973, by a vote
    7
    —
    701

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