STATE

OF

ILLINOIS

COUNTY

OF

MADISON

BEFCRI~

THE

POLLUTION

CONTROL

BOARD

OF

THE

STATE

OF

ILLINOIS

IN

THE

MATTER

~

App:LIcation

for

extension

of

lrarjance

of

OLIN

CORPORATI0N~

East

Alton,

X11ir~ois

OPINION

OF

THE

BOARD

(BY

MR~ LAWTCN)

On

June

~

197O~ OLIN

CORPORATION

of

East

Iliton,

2I1ino~s

fiIe~

~L~fl

tIe

kit

.~uti~m Conc~o1

s3c~ra

a

7~~1~i

~n

rPquestLng

an

e~ten~ot

(~t Its

xi~rirg

‘~ariat~n

ori~oaiJv

ora~tee

or

May

1E3,

1967,

to

continue

dispcsai

of

its

extic,sive

trade

waste

by

open

burnanq

The

present.

variation

expires

Oc

echer

22

1970

The

maxioum

~eri

od

of

tires

for

which

a

variation

eon

be

9rantcct,

both

under

the

I: root

lliir~cis

Air

Pol1ut~ox;

2Dflt~Ci Act

anu

the

present

E~nvirc

flCfl~5:L

prctectior~

Act,

is

one

year

The

2ivion

subject

to

the

:mr!aoce

is

.reforied

cc

ac

toe

Ni~’teter

-Western.

01 cas ion

Pursue.nt

to

the

~roc2sions

c:

the

Nov

:cnmenta.

1

Orotection

c ~v

L

~ro~

-~t~

earL

~

c

~

~a

a

investictatiort

aci

ccc:

ir:endaticn

to

ehe

Nc £iu’:ion

hontrol

Board

i5:Lative

•tc

a:LL

OOt:ICOCe

app~~cati.

ocis

A

rocc:o.ce

bat.

on

ty

the

Agency

to

allow

toc

varrance

extensi.on

was

recoivoc

by

the

Board

on

September

18

970

Because

of

the

snort

tcxemaon.~ng

until

the

vasiatico

“e:ui 0

become

a

:zoia2~cnOiy

crented

ic~

cpera~-

\

~ 01

1sW

an

re

aa~iir

r

e~

e

r

~o,-u a

tc ~o cci

y

~er

~.

r ~1 Ice

eyo.. ~

a

a

t

ai-msri

wruec

to

N

h.

hsxsort

Oirector

reLotierino

fervices

Olin

Brass

•

cuogesoonc

that

a

ncw

Pet~tior:

cc

liJ,ad

in

comoliance

with

the

present

scatotorV

srcvisions

relative

to

variances

and

further

indicased

that

a

Eear~ect thereon

wou~b

be

;pedited.

A

new

petition

for

earienc:e

extension

was

received

by

the

Pollution

Control

Board

on

Se’::tercber

23~1t7O.

Pursuant.

to

notice

•

a

Hearinq

was

held

on

t:ne-~new Petition

for

variance

extension

at

the

City

Hall

Aiton

L21i~Oi~

on

October

13

,

~‘.

Si;ewert

testified

that

ha

was

to

cnarcre

of

ammunition

procescirLg

encrineering

at

the

Ec~SL

hi con

works

He

testified

to

the

charnctcr

of

the

armenitioc

croducod

at

che

---

plant and the resulting scrap for which disposal was required.

Loaded ammunition consists of a priming compound, propellant

powder and a bullet or lead

shot, classified into center fire and

rim fire cartridges and shot gun shells.

Scrap generated in the manufacture of ammunition

is contam-

inated with explosives requiring disposal beyond ordinary means.

Up to 400 pounds per week of priming compound is scrapped.

The material used in the manufacture of primers constitutes

the most shock-sensitive explosives available, stable enough

for safe handling, and may be burned safely only when wet and

in small quantities.

Propellant powder is reconstructed nitrocellulose containing

up to 40

nitroglycerine, extremely flammable and subject to ex-

plosion under conditions of confinement.

It may be burned in

the open in small quantities.

Approximately a ton and a half

per week of explosive contaminated material must be burned.

Rim fire ammunition and wet priming compound are burned in a

vertical destruction chamber or open-type incinerator eight

feet high and five feet in diameter.

Some gray smoke

is gener-

ated from this operation.

Center fire ammunition is burned in a

destruction chamber or, alternatively, the bullets may be

extracted and the powder burned.

Plastic shot shells and

components are burned in the open, ignited with small quantities

of fuel oil.

Propellant powder which cannot be burned in a

chamber is burned on the ground.

Although dry propellant burns

with a light gray smoke, the powder is normally mixed with oil

in order to minimize the danger of explosion from spills and

in movement from the point of manufacture to the point of

disposal.

Burning operations are confined to the Olin property.

Smoke

generated normally does not extend beyond its boundaries.

Photo-

graphic exhibits were introduced illustrating all of the fore-

going methods of disposal.

A water-glycol wetting agent is

being utilized on an experimental basis in lieu of oil for the

soaking of the propellant powder prior to burning, which would

eliminate the dense smoke now being generated by the oil, but

is subject to further experimentation.

Testimony indicated that the closest house was 900 feet south

of the burning area and that the prevailing winds blow from the

south and southwest.

The north property line of Petitioner’s

property is 1,700

feet

from the burning area and the area to

the north thereof is uninhabited.

---

Various munition manufacturing plants throughout the

country have been contacted,

as well as the United States Govern-

ment, and that in

no case were the methods of disposal more

advanced than those being utilized at the Olin plant.

While there were some variations in the method of disposal

throughout the country at different ammunition manufacturing

plants,

the method was generally that of open burning.

The

reason ascribed in each case was the danger inherent in any type

of closed burning of explosives or material contaminated with

explosives.

Illinois Institute of Technology Research Institute is in

the process of making a proposal to Olin to sample and determine

what emissions are coming from the burning of explosive wastes.

Alternative provisions set forth in the Department of Defense Safety

Manual relating to disposal of solid wastes were not feasible to

the Olin operation.

Specifically, biodegradation was not feasible

because organic binders and oil in which scrap explosive is immersed

is not.biodegradable.

Chemical degradation was unsuitable because

of the formation of sludge and by-products.

Burial would create

the likelihood of explosion in the process or possible fires

from decomposition.

Burial at sea was deemed impracticable be-

cause of distance involved.

Dr. T.

F. McDonnell testified that he was Manager of Chemical

Engineering in the Engineering and Development Group of Olin.

Inability to find an existing closed type waste destructor for

explosive wastes lead to Olin’s Energy Systems Division, establishing

a program to develop a continuous feed incinerator which could

safely process the explosive materials generated at Olin’s Marion,

Illinois plant.

The development of the prototype destructor is in

the preliminary experimental testing stage.

Development of an

explosive waste destructor

is being undertaken at Radford

Army

Ammunition Plant, Radford, Virginia.

In the destruction chamber operation, potential contaminants

are nitrogen oxide and heavy metal oxide from the primer mix and

ammunition cases.

Nitrogen dioxide analysis is indicated at

less than one ppm.

Undiluted flue gas of 200 to 300 ppm of

carbon dioxide

is estimated.

Fallout of particulates

is indicated

to be small although some heavy metals including lead may be

emitted.

It is estimated that five pounds of lead per week are

emitted from the chamber.

No mercury emission is indicated.

Sulphur emissions are deemed to be at a minimum because of the

absence of sulphur compound in the scrap.

Open burning of propellant scrap and contaminated waste amount

to approximately 400 pounds a day or 2,000 pounds per week.

Oil

is added to wet down the propellant accounting for sooty smoke.

1

—

59

---

The operation is essentially

free of particulate emission except

for the soot from

the

oil~ Tests are underway

on

storage

of

scrap

propellant

under

water glycol sollution

to determine

whether smoke can be eliminated.

Nitrocelloluse propellant

emits some nitrogen oxides,

but well below the hazard level

before reaching any employees or inhabited areas adjacent to

the Olin property.

Scrap shotgun

shells

are

burned

in

the

open

in

a

barricaded

area.

Some

smoke

is

generated

from

the

combustion

ci

plastic

cases.

A

small

amount

of

nitrogen

oxide

~ss

generated

from

the

nitrocelloluse

nil:roglycerin

propellant.

Emission

of

heavy

metals

is

insignificant.

Any

accumulation

of

expiosiVC

waste

is

extremcly

unsafe.

It

is

necessary

in

the

onerating

areas

of

plants

using

explosives

to

keen

all

scrap

exitlosives

in

oil

or

some

other

desensitizing

agents

to

protect.

the

safety

of

•the

employees

and

the

plant.

This

witness

likewise

testified

that

in

reviewing

orocesses

authorized

by

private

comnanies

and

the

Federal

government,

no

other

methods

are

being

used

in

the

dispos.ai

•of

explosive

waste

that

were

sub~-

stantially

dii

f~erent

if torn

t:hose

being

•enigag.ed

in

inc

Olin.

C.

B.

flexor:

Director

of

Engineering

Servtces

testified

•that

suostant.ia~LIy

stT~.al.!er quantot.r:.es

of

explosives

were

being

burned

than

iLo

for:cer’

veers

as

indicated

in

his

Affidavit.

C

A.

Ri:qrt

,

Controller

•

hrcnrur:ition

Operations

hinchester-~

Western

D’it:Lt.ion

ci

Olin

Co.rporation.~

Easthlton,

testi.fted

.t’hat

to

~

r

to

I.~ cc

a

tot

~l

~.

I

e~p~o~ci

at

the

A1tc~ri .site

,.anrd

that:.

•the

annual

cayroll

at

the

2

,700

em~

o .loyee s

of

t:hrc

~‘~L’inahe

ste r~Western

.0lois

i.on

was

an :oroximate

ly

$20

0°f

~3fo

If

‘sl•~

o~ ah0iti~o1

$5

000

000.

00

f.’rinqe

bone fits.

I

‘Ic

at

r

~nrr

at

a n~

It

tor

of

ce

County

$70

0

,

U 00

.

o

.~

tch

‘year

1

ft 70

C.

N,.

Backer:

hanucre::

of

Contract

Administration

,

Winchester~

ties

tern

Division

•

forts aif.:ffnO.

to

tIre

number

of

contract Is

xi,

t.h

the

Federal

Government

ma

t.he

sunol:’

of

oiL tita~~yaremun.i.tictn

arid

I

~ eUc~

a

St

~u

r

1

y

r~ne~~

r

C

cornr.ilffance

with

safet

Ti

regui.ations

set

iort.h

sri

various

government

Based

anon

the

:IH:::o’egolnq

evidence

adduced

at

the

Hearing

and

the

matters

set

forth

if::

tIre

Petition

and

Affidavit~~ Petitioner

h.as

satisfied

atte

sta.

atory

requisites

for

‘the

granting

of

a

J3~trtfl”C

~.i.

t

w

ice

L

irt

ati

it

Lxoloc

gene.rate~d

Olin

s

as.

rnuior:

wh.i.ch

c artnot

be

storco.i.

witho.ut

suh-~

staritial

ha:

tea

Ii

tf

~i..’.

OS.’si’iflJ.’toi,

arid

property

o.i

Not:

I t.±i.rner.

---

At

the

present

time,

no suitable incineration

methods

or

other

means

of

disposal

are

available.

Ta~aediate

prohibition

of

Olin’s

open

burning

of

explosive

waste

would

constitute

an arbitrary

or

unreasonable

hardship.

Insistence

on

closed

burning

of

explosive

waste

would

confront

the

Petitioner

with

the

un-

realistic

alternatives

of

blowing

up

its

plant

or

closing

down

its

entire

operation.

Neither

appear

to

be

a

satisfac-

tory

solution.

It

is

also

evident

that

the

operation,

as

conducted

by

Olin,

has

not

produced

any

discernible

impact

on

the

adjacent

properties

or

its

residents

•

The

is

one

calling

for

the

unusual

remedy

of

a

variance.

While

the

Petitioner

has

made

a

thorough

and

comprehensive

disclosure

of

its

present

operation

and

indicated

its

efforts

to

find

alternative

methods

of

disposal,

the

evidence

as

to

such

alternative

methods,

both

in

existence

and

in

development,

is

sketchy

and

inadequate.

The

petition

describes

the

Bartlett-Snow

Tumble

Burner

and

the

John

Zink

molten

lead

pot

process,

both

considered by Olin, without detailing

the specifics of the operations or the reasons why the pro—

cones would not be suitable for some or all of Olin’s ex-

plosive waste disposal.

Reference is made to various

conferences with industry and government representatives,

without adequate description as to what was considered and

what the prospects for controlled disposal complying with

ettission standardM would be.

More and greater detailed

information as to all methods in existence

and

in develop-

uent for the disposal oi explosive waste

is necessary before

the Board will grant a further variance beyond the tine

herein provided.

L;

£5

the Order of the Poliution Control

Board

that the existing var:an:e heretofore

qranted

to Olin

corpoxation permitttn; open burning of explosive t:aic

waste

be

extended

to February 22,

1971, subject

to

the

following provisions

a!d

conditions;

---

1.

Olin Corporation shall submit a monthly report, the first

being no later than November 19,

1970,

to the Pollution Control

Board and the Environmental Protection Agency,

specifying the nature,

degree, extent and details of its open burning activities on the

premises subject to the variation.

2.

Olin Corporation shall submit a monthly report to the

Pollution Control Board and the Environmental Protection Agency

indicating what progress has been made relative to improved tech-

nology and new facilities enabling disposal of explosive wastes

in compliance with statutory provisions and the relevant regulations.

Such report shall further indicate what facilities Olin Corporation

is employing or testing as well as all state of the arts advance-

ments in the industry generally and under Federal government direc-

tion.

3.

If the Environmental Protection Agency advises the Board

that the open burning operation of explosive waste by Olin Corpor-

ation is producing an undue burden on adjacent neighboring areas,

the Board shall make a determination as to whether the variance

shall be terminated.

Said determination shall be made only after

a hearing on the matter is scheduled by the Board and held before

a qualified hearing officer.

Olin Corporation will be notified

of the hearing date and shall be allowed

to participate in said

hearing.

As a result of that hearing, the Board may terminate

the variance granted herein before February 22,

1971.

4.

The variation extension hereby granted shall terminate

upon the establishment of alternative means of disposal of explo-

sive waste, relative to all or any part of the Olin Corporation

operation resulting from the availability

of new technology and pro-

cesses which would enable compliance with the relevant statutory

provisions and regulations.

Said determination shall be made

only after a hearing on the matter is scheduled by the Board and

held before a qualified hearing officer.

Olin Corporation will

be notified of the hearing date and shall be allowed to partici-

pate in said hearing.

As a result of that hearing, the Board may

terminate the variance granted herein before February 22, 1971.

5.

A further hearing will be scheduled prior to the termina-

tion of the four—month extension period hereby granted for con-

sideration of any further variance extensions, at which time it

will be incumbent upon Olin Corporation to make a comprehensive

and extensive showing of all methods being presently employed

by Olin Corporation,

by. the explosives industry generally and by

the Federal Government, including those in the experimental stage,

to abate or minimize air pollution as

a consequence of the dis-

posal of explosive trade waste.

1

—•

62

---

The Environmental Protection Agency is requested to report

to the Pollution Control Board at the earliest possible time what

impact the open burning of explosive wastes by Olin Corporation

has upon the surrounding and adjacent areas, with particular regard

to what attitudes have been expressed by reside~tia1occupants

in the immediate vicinity of the Olin Corporation operation.

IT

IS ORDERED THAT:

Variance heretofore granted Olin Corporation,

East Alton,

Illinois

(VR67-9), be extended to February 22, 1971,

subject to

all provisions and conditions above set forth.

I

c5~ncur.

~

/)

I dissent:

.~

(~4

____________________________________

I,

Regina E.

Ryan, certify that the Board has adopted the above

Oninion this

~

day of

,~L&i

,

1970.

)

~

~c~ina

P~.

~

C1~erkof the(~oard

1-63