ILLINOIS POLLUTION CONTROL BOARD
January 3,1974
OLIN CORPORATION,
Petitioner,
vs.
PCB 73—427
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
Mr. Thomas Martin, attorney, on behalf of Petitioner.
Mr. Dale Turner, Assistant Attorney General on behalf of
Respondent.
OPINION AND ORDER OF
THE BOARD (by Mr. Seaman)
On October 9, 1973, Petitioner, Olin Corporation,
filed its Petition for Variance seeking variance from the
provisions of Section 9(c) of the Illinois Environmental
Protection Act and Section 502(a)
,
Part V, Chapter 2 of
the Illinois Pollution Control Board Rules and Regulations
prohibiting open burning. A public hearing was held in
this matter on November 15, 1973.
Petitioner requests that a variance be granted to
permit the open burning of the quantity of scrap primers
which Petitioner has on hand on the date of this Board’s
Order in excess of 3,150 pounds; but that Petitioner be
limited to open burning of such material in maximum quantities
of 1,400 pounds per day.
Petitioner operates a plant, consisting of an area of
approximately 1,732 acres at East Alton, County of Madison,
Illinois, where it manufactures, inter alia, shot shell
ammunition and primer explosives. Approximately 5,700
employees are currently employed at Petitioner’s East Alton
location.
Reference is made to PCB case Numbers 70-11 and 71-7
which were Orders granting to Petitioner extensions of its
existing variance, originally granted on May 18, 19G7,by
the Air Pollution Control Board, to continue disposal of
Petitioner’s explosive trade wastes by open burning. In
December, 1971, Petitioner commenced operation of a new
incinerator, rotary popper incinerator and air pollution
control equipment designed to permit the burning of its
explosive wastes in compliance with the air pollution
regulations
for incinerators.
The Illinois Environmental Protection
Agency (Agency) on March 12, 1973,
issued
to Petitioner an
operating permit for the aforementioned equipment.
10
—
537
—2—
Petitioner alleges that because of higher than
anticipated quantities of explosive trade wastes
during 1973, and particularly because of maintenance
problems with respect to the aEorementioned equipment
resulting in approximately 52 working days of down time
from January through September, 1973, the following
approximate quantities of explosive trade waste have
accumulated as of October 5, 1973:
(a) 7,000 pounds of scrap primers. (12,600 pounds
as of November 15, 1973. R,5)
(b) 500,000 pounds of scrap shot shells (both
empty and loaded).
(c) 250,000 pounds of scrap loaded metallic
ammunition (rifle and pistol cartridges).
The foregoing accumulation al1eg~dlyhas occurred
in spite of the fact that the present incinerator equipment
is being operated five days a week on a three shift basis
and one shift on Saturday. For safety reasons, the scrap
primers are presently burned in small quantities together
with scrap shot shells in the incinerator. The scrap primers
are not burned in the rotary popper. It is conceivable
that in the next few months it might be possible for Petitioner
to dispose of its accumulation of scrap primers in the
incinerator without the necessity for open burning, but
Petitioner considers this to be unlikely in view of its
experience with maintenance problems and shut downs during
the preceding months of 1973. Based on this experience,
Petitioner forecasts a continuation of some maintenance
problems and down time with respect to the incinerator, with
the result being an inability to reduce the accumulated
quantity of scrap primers and, very possibly, an actual
increase in such accumulation.
The average generation rate of scrap primers from
Petitioner’s manufacturing operations is 1,050 pounds per
day. Petitioner’s Loss Prevention Department has determined
that it is unsafe to store quantities of scrap primers in
excess of a normal three day accumulation (3,150 pounds).
The scrap primers must be kept wet, under water, and not
be allowed to freeze. They are currently stored in ten
quart buckets and require daily inspection to insure that
the water cover has not leaked out or evaporated. If these
scrap primers were allowed to dry, due to a leaking bucket
or for some other cause, they could easily be set off by
impact or spark with a resultant high order detonation.
This excess accumulation represents a severe hazard to the
employees and to the property of Petitioner.
10—538
—3—
As
noteci a~c~c, there are large backlogs of scrap
shot shells and metallic ammunition which represent
something of a fire and security hazard, but Petitioner
believes that these accumulations can be held in storage
pending Petitioner’s ability to dispose of same in the
present incinerator and rotary popper. For this reason,
Petitioner does not seek a variance to open burn the scrap
shot shells and metallic ammunition.
In order to solve the safety and backlog problems,
Petitioner has developed plans for additional facilities,
as follows:
(a) Additional vertical incinerator for rapid, safe
disposal of scrap primers. This will eliminate
the present system of destroying them in small
quantities along with scrap shot shells in the
existing incinerator. This unit will also
be used for the disposal of loaded metallic
ammunition. The rotary popper has proven to
be unsatisfactory for loaded rounds because of
necessity for frequent removal of lead.
(b) Additional pollution control equipment to remove
particulates from the effluent from the vertical
incinerator. In view of the short life expectancy
of the scrubber now in use on the scrap ammunition
incinerator, it is considered advisable to install
one new scrubber with capacity to handle the
effluent from the new vertical incinerator, the
present rotary popper incinerator, and the present
scrap ammunition incinerator. This would probably
be a high energy Venturi scrubber, replacing the
medium energy Tailor CVX scrubber now in use.
Such a scrubber would represent the best currently
available technology for removing particulates
from burning scrap explosives and ammunition.
During the period of installation of the new scrubber,
it will be necessary to shut down the incinerator which is
presently being used for the disposal of the scrap primers
arid
scrap shot shells. During this shut down period, there
will be no other way to legally dispose of scrap primers
unless the variance for open burning herein requested is
granted (the scrap shot shells and metallic ammunition will
be allowed to accumulate during this period).
The quantity and type of raw materials which would be
open burned per day, assuming the open burning of a quantity
of 1,400 pounds of scrap primers per day, is as follows:
10—
539
—4—
Steel
726 pounds/day
Brass
596 pounds/day
Explosives (primer mix
78 pounds/day
consisting of normal lead
styphnate, tetracene, pentaerythritol
tetranitrate, barium nitrate, antimony
sulfide, and aluminum).
Petitioner argues thatpending the installation of the
proposed explosive trade waste destruction equipment, the
existence of the large excess quantity of scrap primers
presents an imminent and continuing danger to Petitioner’s
employees and property. Petitioner states that it knows
of no safe method of eliminating this accumulation of
scrap primers other than open burning. The Agency agrees
with this contention. Therefore, Petitioner contends that
compliance with the prohibition against open burning of
this excess accumulation of scrap primers constitutes an
arbitrary and unreasonable hardship. If the requested
variance is not granted, Petitioner is faced with the liklihood
that it will not be able to reduce the large excess accumulation
of scrap primers to the safe level of 3,150 pounds in the
near future, and it is also likely that because of future
probably maintenance problems. with the incinerator, an
increase in this accumulation will occur.
The Agency is of the opinion that prolonged storage
of the subject material could create a fire and safety hazard,
and the material should be disposed of as rapidly as possible.
Petitioner states that this material will be burned in a
vertical incinerator fired by low sulfur oil.
Petitioner, in its proposed timetable for installation
of the new control device, states that construction will
occur between November 15, 1974 and December 31, 1974. It
is assumed that the existing incinerators will be down at
that time, and Petitioner will be required to open burn all
explosive waste generated.
Based on stack tests performed in 1970, the vertical
incinerators Petitioner plans to burn the explosive waste in
will emit 5.68: and 5.51 grains per SCF. c~Thenburning 1,400
pounds of explosive waste, the Agency calculates that the
following emissions can be expected:
10 —540
-5—
Contaminant
Nitrogen oxides
5 ppm
0.15 lbs/day
Sulfur trioxide
122 ppm
3.5 lbs/day
Sulfur dioxide
65 ppm
1.9 lbs/day
Total particulates
167 lbs/day
Lead
28 lbs/day
Barium
7
lbs/day
Zinc
37
lbs/day
Copper
15 lbs/day
Antimony
9
lbs/day
Air quality readings in the East Alton, Alton and Wood
River areas are as follows:
Maximum 24
ug/mhr. 3
Average
Geometricug/m3 Mean
Alton
54
46
Wood River
82
68
The 1975 primary f~deralair quality standard for
particulates is 75 ug/m~. It is the Agency’s opinion that
one year of burning explosive waste will not greatly
deteriorate
the air in the Alton-Wood River area.
The
Agency has received no objections from citizens concerning
the grant of this Variance.
In view of the substantial threat to the safety of
Petitioner’s
employees and those persons in the proximity
of Petitioner’s facility, we are disposed to grant Petitioner
variance to permit open burning of the quantity of accumulated
scrap primers which Petitioner has on hand on the date of
this Order.
However, Petitioner will be limited to open
burning said material to maximum quantities of 1,400 pounds
per day.
Petitioner further requests a variance for a period of
one year or until such time as Petitioner has placed into
operation the above—detailed incinerators
and control equipment
(whichever first occurs) to permit the open burning of quantities
of scrap primers which may accumulate in excess of 3,150
pounds due to maintenance problems with its present incinerator
and during the shutdown necessitated by the installation
of the
new scrubber.
The Agency is of the opinion that Petitioner’s
compliance schedule is reasonable.
Petitioner’s
request will
be granted.
This Opinion constitutes the findings of fact and
conclusions of law of the Board.
10—541
—6—
ORDER
IT IS THE ORDER of the Pollution Control Board
that Petitioner, Olin Corporation, be granted variance
from the provisions of Section 9(c) of the Illinois
Environmental Protection Act and Section 502(a), Part
V, Chapter 2 of the Rules and Regulations until
December 31, 1974 or until its proposed incinerators
are operational (whichever first occurs) subject to
the following conditions:
1. Petitioner shall be allowed to open burn
quantities of scrap primers in excess of 3,150 pounds.
Open burning shall occur in a vertical incinerator fired
by low sulfur oil. Petitioner shall not open burn more
than 1,400 pounds of scrap waste per day;
2. Petitioner
shall incinerate the maximum allowable
amount of scrap primers in the existing incinerators
whenever
it is operational. When operational, the existing
incinerator shall be operated for three shifts a day,
seven days a week, if feasible. When operational, the
existing incinerator must be operated for three shifts
a day, five days a week, with an additional shift on Saturday.
3. Petitioner shall limit open burning to such times
when atmospheric conditions will readily dissipate the
contaminants;
4. Petitioner shall obtain all necessary Construction
and Operating Permits for its proposed new incinerator
and its existing incinerators;
5. By December 31, 1974,or upon completion of the
new incinerator system (whichever first occurs) Petitioner
shall cease open burning of explosive trade waste.
IT IS SO ORDERED.
Mr. Henss was not present.
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, certify that the above Opinion and Order
was adopted on the
.3~
day of
,
1974 by a
voteof
~/
to
~,
~
~4L
10—542