ILLINOIS POLLUTION CONTROL BOARD

December 18 

1975

OLIN CORPORATION, a          

)

Virginia Corporation,        

)

Petitioner,

v.

)    PCB 75—333

THE STATE OF ILLINOIS,        

)

ENVIRONMENTAL PROTECTION AGENCY,  

)

Respondent.

OPINION 

AND

ORDER OF THE BOARD (by Mr. Young):

On August 22, 1975, Olin Corporation filed a petition for

variance seeking therein relief from the Air Pollution Control

Regulations dealing with compliance programs and project com-

pletion schedules (Rule 104), the particulate emission standards

for incinerators (Rule 203(e)) and the carbon monoxide emission

standards for incinerators (Rule 206(b)). On August 28, 1975,

the Board found the petition to be inadequate in that it failed

to include information pertaining to the criteria required by

Train v. NRDC, Inc., 43 USLW 4467 (Supreme Court No. 73-1742,

April 16, 1975). An amended petition for variance was subse-

quently filed on October 14, 1975, containing supplemental in-

formation.

Petitioner manufactures various propellant and pyrotechnic

products at its facility located within Williamson County, near

Marion, Illinois. The subject of the peti.tion is the disposal

of explosive and pyrotechnic wastes generated during the manu-

facturing process. The U. S. Department of Defense is normally

the major customer for such products, and the actual items pro-

duced vary in accordance with Government contracts issued on an

annual basis. While Petitioner cannot state with certainty what

its product line or volume will be in 1976, it estimates that

the maximum amount and type of hazardous explosive waste generated

weekly will be:

Axnmonium Nitrate Propellant        

500 lbs.

Double Base Propellant           

300 lbs.

RDX Type Explosive             

200 lbs.

Single Base Propellant           

20 lbs.

Ammonium Perchlorate Propellant       

20 lbs.

Boron—Potassium Nitrate Propellant     

200 lbs.

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Black Powder                

10 lbs.

Nitroglycerine in Sawdust          

25 lbs.

Potassium Perchiorate Propellant      

20 lbs.

Firecracker Mix               

50 lbs.

Colored Smoke Mix             

100 lbs.

Contaminated Packaging           

200 lbs.

Pyrotechnic Flare Scrap           

50 lbs.

Olin has been before the Board several times since 1971

as a result of problems concerning disposal of these explosive

wastes (see PCB 71—60, 6/28/71; PCB 71—231, 2/18/72; PCB 72—357,

10/31/72; PCB 72—517, 3/22/73; PCB 73—395, 12/13/73; and PCB

74—335, 1/2/75).

Olin has filed a petition for a rule change with the Board

regarding pyrotechnic incinerators (PCB R75-13). While the

Agency has not yet fully evaluated Olin’s proposal, after pre-

liminary analysis the Agency feels a rule change may be in order.

Olin presently operates a pyrotechnic incinerator under a variance

granted by the Board which will expire December 5, 1975. This

incinerator was constructed in accordance with the terms of its

prior variances, and represents an advance in the state of the

art of explosive waste disposal.

Petitioner alleges that incinerators designed to handle

explosive wastes differ widely from those designed to burn rnuni—

cipal wastes. Explosive materials generate large volumes of

highly heated and rapidly expanding gases which must be safely

contained. To accomplish this, explosive materials must be

burned in small increments and in a partial vacuum to avoid over—

pressurization. The partial vacuum is created by constantly drawing

air through the burning chamber and out the exhaust port. The

excess air thus introduced into the burning chamber also quenches

the heat of combustion and in so doing increases the generation

of carbon monoxide as opposed to carbon dioxide. Explosive wastes

have a low carbon content when compared to municipal wastes; thus,

less material is present to create carbon oxides initially. Peti-

tioner alleges all of these factors combine to make the present

measuring technique for emissions inequitable when applied to

pyrotechnic incinerators.

Rule 206(b) prohibits the emission of carbon monoxide (CD)

over 500 ppm when corrected to 50 excess air. Petitioner sub-

mits that the required correction to 50 excess air may accurately

measure operating efficiency for incinerators burning municipal

type solid wastes, but the correction to 50 excess air imposes

a severe penalty on incinerators burning explosive wastes. Be-

cause the thermal destruction process employed utilizes large

volumes of air to quench the heat of combustion generated by

these explosive wastes, the required correction to 50 excess air

penalizes explosive burning incinerators. In addition, the

quenching effect results in the production of large amount of (CO)

489

—3—

because the carbon is less readily oxidized to carbon dioxide

(CO2) at the lower temperature. Petitioner alleges that both

of these effects combine to make the present measuring technique

for emissions inequitable when applied to explosive burning

incinerators. Although the Aqency calculates the carbon monoxide

(CD) emissions only approach .05 cubic feet/lb. of scrap burned,

this emission exceeds the limit of 206(b) when required correction

to 50 excess air is made.

The particulate emission standards and limitations for

incinerators under Rule 203(e) are based upon a measuring tech-

nique which corrects particulate concentrations in effluent gases

to 12 (C02) and excludes any carbon dioxide attributable to the

auxiliary fuel source. Petitioner likewise submits that the

required correction to 12 (C02) may accurately measure operating

efficiency for incinerators burning municipal type solid wastes,

but the correction to 12 (C02) imposes a severe penalty on

incinerators burning explosive wastes. Municipal wastes contain

significant amounts of carbon containing material from which

(C02) is produced. In contrast, explosive wastes are generally

low carbon wastes from which little (C02) is produced. In addi-

tion, any carbon dioxide which is generated becomes greatly diluted

by the excess air used to quench the heat of combustion. Petitioner

alleges that these effects combine to make the present measuring

technique of Rule 203(e) for emissions inequitable when applied

to explosive burning incinerators.

The Agency calculates particulate emissions from this in-

cinerator at .0404 grains/standard cubic foot (SCF) with .04

(C02). The required correction to 12 (C02) gives rise to

emissions of 1.21 grains/SCF. This exceeds the limit of Rule

203(e) (4) of 0.1 grains/SCF of effluent gas when corrected to

12 (C02). The Agency notes that 99.4 of these particulate

emissions are removed, however.

Petitioner believes that compliance with existing emission

standards for incinerators would impose an arbitrary and un-

reasonable hardship. Petitioner does not believe the grant of

the variance would prevent compliance with national air quality

standards. Particulate concentrations in the area of the in-

cinerator were found to be 32 micrograms per cubic meter (annual

geometric mean) and 64 micrograms per cubic meter (maximum 24

hour average). This is well below the primary standard for

particulate matter of 75 micrograms per cubic meter (AGM) and

260 micrograms per cubic meter (maximum 24 hour concentration).

Carbon monoxide emissions from burning certain wastes can reach

a maximum level of 19.1 lbs. per hour. Dispersion estimates have

been made by Petitioner in accordance with Public Health Service

Publication No. 999-AP--26. The maximum carbon monoxide concentra-

tion resulting from the operation of the incinerator under the

worst climatic conditions with a 5 m.p.h. wind will occur approxi-

mately 0.3 miles from the incinerator. The (CO) concentration

- 490

—4—

at this distance would be 0.57 ppm. The maximum one hour con-

centration of (CD) permitted is 35 ppm. The Board finds back-

ground carbon monoxide to be slight in Williamson County and

that operation of the incinerator should not prevent the attain-

ment or maintenance of the national ambient air quality standards

for (CO).

We are disposed to grant relief. Petitioner’s incinerator

represents an advance in the state of the art which greatly re-

duces the particulate emissions from the disposal process and

is mostly preferable to open burning. The incinerator is operated

in an isolated strip mine area minimizing possible injury to

public and the environment. Variance will be granted from the

provisions of Rule 203(e) and 206(b) in order to allow continued

operation of the incinerator. Variance will be granted from

Rule 203 because Petitioner’s incinerator represents the state

of the art and to deny a variance at this time when there is a

lack of technical feasibility for a better control scheme would

place an unreasonable hardship on Petitioner. The grant of this

variance is conditional upon the requirement that Petitioner

continues to emit particulates and (CO) at or below current levels,

and a standard certificate of acceptance is included. In addition,

in the event a rule change is adopted by the Board pursuant to

PCB R75-l3, the variance shall terminate thirty days after that

adoption date.

This Opinion constitutes the findings of fact and conclusions

of law of the Board in this matter.

ORDER

IT IS THE ORDER OF THE POLLUTION CONTROL BOARD that Peti-

tioner, Olin Corporation, be granted for its Williamson County

explosive waste incinerator a variance from Rule 203(e), 206(b)

and 104 of the Pollution Control Board Rules and Regulations for

the period from December 6, 1975 to December 5, 1976, subject

to the following conditions:

1. Olin Corporation shall make application for an operating

permit from the Agency for its pyrotechnic incinerator within

30 days of the Board Order, and secure said operating permit

within 120 days of Board Order;

2. Olin Corporation shall not operate its pyrotechnic

incinerator at a rate exceeding 400 pounds of scrap per hour in

any one hour;

3.

Olin 

Corporation shall 

continue 

to operate the pyro-

technic incinerator so that particulate and carbon monoxide

emissions do not exceed levels currently produced;

491

—5—

4. Olin Corporation shall continue its present program

of pyrotechnic incinerator development;

5. In the event a rule change is adopted by the Board

pursuant to PCB R75-l3, the variance shall terminate thirty

days after that adoption date;

6. Within 30 days of the date of the adoption of this

Order Petitioner, Olin Corporation, shall complete and submit

to the Environmental Protection Agency, at the following address,

the following certification:

Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Springfield, Illinois 62706

I, (We), ___________________________ having read

the Order of the Illinois Pollution Control Board in

PCB 75-333, understand and accept said Order, realizing

that such acceptance renders all terms and conditions

thereto binding and enforceable.

SIGNED

TITLE

DATE

IT IS SO ORDERED.

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby cc tify the above Opinion and Order

were adopted on the 

__________

day of 

___________________,

1975

by a vote of 

4_~

Christan L. Moff~Jk, C

Illinois Pollution Control Board

492