ILLINOIS POLLUTION CONTROL BOARD

THE OLIN CORPORATION

)

/-~(i~3No. 70—25

v

ENVIRONMENTAL PROTECTION AGENCY

)

OPINION OF THE BOARD

 (BY MR.

LAWTON):

 December 22, 1970

The Energy Systems Division of Olin Corporation, East Alton,

Illinois, filed a Petition for Extension of Variance previously

granted by the Air Pollution Control Board on March 25, 1970 in

No. VR 70—4, which variance expired October

1,

 1970.

 The present

petition was received by the Pollution Control Board on Septem-

ber 30, 1970 and seeks a one-year extension of the previous variance

to dispose by open burning of six powder contaminated buildings

remaining on the site,

 approximately 7,000,000 pounds of waste

ball powder

 (“fines”) stored under water at various locations

of

the former Ball Powder plant site, approximately 1.8 million pounds

of rocket ammunition

 (“grains”)

 stored under water in concrete

pools and to burn over approximately sixty-six acres of land where

loose powder has accumulated,

 The original variance permitted the

open burning of

 240 powder-contaminated buildings located on the

Ball Powder plant site and the open burning of an undetermined

amount of waste Located in sioughs on the premises.

The one-year extension is needed primarily

 to dispose of the

fines and grains above-described,

The

burning

of the

buildings and

the decontamination of the ground can

be

achieved in a relatively

short period of time.

 Written complaints against the petition were

received by the Environmental Protection Agency from four persons

and several verbal complaints were made to Agency personnel directed

primarily to the burning of the

buildings

and not to

the

disposal of

the powder.

 The Environmental Protection Agency recommended that

the Petition be granted allowing the contaminated buildings to be

disposed of over a one—month period, and that a one-year variation

be granted for disposal of the powder and decontamination of the

ground,

 The Environmental Protection Agency’s recommendation sug-

gested that the grant of variance he conditional on

 the posting

of

 a bond “in sufficient amount to insure that the Petitioner de-

voted maximum efforts of developing an alternative method of

disposal of explosive waste”.

 The Sanitation and Pollution Com-

mittee of the Madison County Sanitation and Pollution Department

filed a memorandum with the Board stating that while it was opposed

to open burning, it does not oppose the present variance request provi-

ding certain conditions were made relative to the time and manner

in which the buildings were burned.

Hearing was conducted in Alton on the foregoing Petition on

December 1,

 1970.

 The fQllowing witnesses testified on behalf of

Petitioner:

 Edwin McWhorter, Technical Director of the Energy

Systems Division of the Olin Corporation; Dr. Robert B. McComb,

Senior Staff Engineering Assistant, Energy Systems Division;

Lawrence M. Garvin, Smokeless Powder Operations;

 and Richard

B.

Clark, Manager of the Weather Systems Group.

 These witnesses

testified to the character and, extent of the buildings and ex-

plosives to be burned, the absence of suitable alternative means

of disposal, the manner of the proposed burning, the correlation

of the proposed burning to weather conditions, the anticipated

emissions,and the dangers inherent in allowing the present condi-

tions

 to continue.

 No one appeared in opposition to the petition.

The Sanitation and Pollution Committee of the Madison County Sani-

tation and Pollution Department stated that it is not opposed to

the petition, providing certain conditions as to the burning of the

buildings were met.

Olin Corporation has manufactured explosives

 at its present

site at East Alton for approximately eighty years.

 In 1936 a new

process of ball powder manufacture was employed by which powder

was manufactured under water, thereby reducing the need for handling

of dry powder and the dangers attendant thereto.

 The process resulted

in certain waste powder slurries being pumped into sloughs where

 they presently remain under water.

 In recent years, the Ball Powder

operation was moved to Florida and the Ball Powder plant site has

been abandoned.

 For Olin to utilize this property, it became neces-

sary to remove 240 structures and dispose of the powder located in

the area, both under water and on the ground.

 The original variation

permitted the burning of 240 powder-contaminated buildings and

authorized the burning of

 “nitrocellulose located in sloughs” but

was vague

 as to the extent, nature and degree of the powder, located

on the premises.

 Under the prior variation, virtually all of the

structures have been removed.

 While the present variation petition

—

136

seeks allowance for burning of the remaining six powder contaminated

structures,

 the principal thrust of the petition is

 to permit dis-

posal of the remaining explosive powder on the site, estimated

to

be 7,000,000 pounds of ball powder and 1.8 million pounds of rocket

propellant and to

be permitted to decontaminate approximately

66

acres of powder—contaminated ground.

The six buildings remaining on

the site have all been used in

the manufacture and storing

 of explosive powder.

 They will be

manually dismantled and removed.

 However,

 in order to protect the

 workmen involved in the dismantling operation,

 it is necessary

that all powder-contaminated portions be. burned to avoid flash fires

and possible explosion.

 The objective

 is not to cause demolition

of the buildings by burning, but rather to eliminate the powder-

contaminated portions

 to enable safe removal.

 This process has al-

ready been accomplished

 in over two hundred structures and only

six

remain for removal.

In the process of manufacture of ball Dowder,

 a small percentage

is too

 fine for use.

 This becomes explosive waste and is referred

to as

 ‘fines’.

 During the past thirty years,

 these fines, produced

as part of the basic under water ammunition manufacturing process

have drained into sloughs

 in the area and remain under water at the

present time.

 In other areas, powder has been manually dumped into

low spots,

 some of which is under water and some exposed to

the

air.

Petitioner estimates

 that there are approximately 7,000,000 pounds

of accumulated ball powder or

 “fines”

 located on the premises, most

of which is under water.

 In addition, approximately

 1.8 million

pounds of rocket

ammunition

has been stored in concrete—lined pools

on

 the premises.

 This ammunition, referred to as

 “grains’,

is

 approximately 40

 nitroglycerin and highly susceptible to detonation.

Each grain weighs approximately thirty pounds.

 In addition to the

foregoing, approximately

66

 acres

 of the 200—acre

 site

 are contami-

nated with

 loose powder resulting from spillage, overflows and

handling errors.

Olin proposes to re-claim the area involved

 for its expanded

activities which use is precluded by the presence of the explosives

and the

powder—contaminated structures on the premises,,

 Some effort

has been made to sell

 the powder but has not been successful.

Maps introduced as Exhibits

 1 and

 2 show the locations of the

proposed burning areas and the structures

 to be burned.

 Residential

areas surrounding the Olin complex are likewise indicated.

—

137

The proposed methods for disposing by burning of the varioua

elements involved were described by the witnesses.

 The buildings

would be burned out before being made available to a contractor for

dismantling.

 In order for a fire to be of sufficient heat to ignite

the contaminating powder, approximately one hundred pounds of dry

powder would be spread throughout the building.

 A fine spray of

fuel oil would be sprayed on the wooden members where needed to

aid in the igniting.

 Less than five gallons of fuel oil would

be required for each building,

 Precautions would be taken to pre-

vent spreading of the fire and the creation of smoke nuisance.

Consideration would be given to wind speed, wind direction and

atmosphereic characteristics,

 A burning index developed by the Olin

Weather Systems Group would be used as

 a guide for predicting favor-

able burning days and buildings would be burned only on days when

atmosphereic and dispersion conditions were suitable to prevent such

spread and nuisance.

 (See testimony of Richard B, Clark.)

 Some

smoke would be generated by the burning of the buildings, resulting from

the oil and the combustion of the wooden structural members and the

roofing material. Bach building would burn for approximately three or

four hours.

 Petitioner seeks a two-month period during which to dis-

pose of the six buildings.

The “fines” or waste ball powder would be pumped in a slurry

onto the concrete pads of the buildings previously demolished.

The

powder would take three or four days to dry and would then be

spread to a depth of approximately two inches and burned.

 Approx~

imately 10,000 to 15,000 pounds of powder would be spread on each

concrete pad.

 Two or three pads of dry powder could be burned in

any one day.

The rocket grains containing nitroglycerin are highly volatile

and subject to detonation~

 It is proposed that six or seven grains

each weighing thirty pounds would be placed side by side and ignited

 through the use of dry powder.

 A string of up to ten 200-pound

increments could be burned in sequence.

 Each 200-pound increment

would burn approximately five minutes.

 Petitioner’s witnesses

testified that the powder burning processes above—described would

not generate any substantial amount of visible smoke.

Three techniques would be used to decontaminate the 66 acres

of ground area where loose powder has been spilled.

 A portable flame

thrower would be used to ignite loose powder.

 Where necessary, small

quantities of dry powder would be added.

 Some fuel oil would be

added to wet powder to aid in ignition.

 It is estimated that ten

acres would be burned with the flame thrower alone, twenty acres

with the use of dry powder and the remaining thirty—six acres will

require the use of’ some fuel oil.

 One acre would be burned at one

time and no more than one acre per day.

 On ground requiring fuel

—

138

oil, approximately 10

 to 20 gallons of oil would be sprayed,over

the acre before burning.

Dr. Robert

 B, McComb testified to the nature of

the emissions

that would result from

 the various types of burnings.

 Scrap powder

would not produce sulphur oxides or noxious particulate emissions.

Nitrogen oxide would be generated in small amounts.

 The rocket pro-

pellant would produce even less particulate and smoke exhaust than

the

 loose powder.

 The burning of the ground would produce some smoke

where fuel oil was utilized but little where

 the explosive wastes

were burned dry.

 Burning of the buildings would cause

 some black

smoke as

 a consequence of tar paper and wood being burned and ig-

nition of

 fuel oil.

 The affidavit of T.

 F. McDonnell indicated

that

 the burning of the propellant wastes would not produce appre-

ciable amounts of carbon monoxide.

The evidence indicates that an extremely dangerous situation

exists at the subject site in its present condition.

 Demolition of

structures without previously igniting

 the powder—contaminated por-

tions would create

 a substantial danger to the workmen engaged in

the dismantling operation, with possible flash fires resulting from

the wrecking process.

 The powder and rocket grains accumulated on

the ground and under water present a hazardous condition which should

not remain.

 This condition was subject to some controls while the

Ball Powder plant was

 in operation, but

the

danger increases with

the abandonment of

 the facility.

 Likewise,

 the potential of serious

water pollution exists from powder remaining

 in sloughs and streams.

Lastly,

 the exposed powder on the ground presents the potential of

 serious danger to personnel

 and property in its present condition.

The alternatives confronting Petition are

to

either allow the

present condition

 to continue with the attributes

 of danger described

above, dispose of its powder in enclosed facilities which will

create explosion and danger of major proportions,

or

 to endeavor

to dispose of the structures and powder under

 a controlled program

ernployin~the maximum degree

 of safety and utilizing meteorological

information

 to minimize

 the danger and burden on the surrounding

area.

 While the impact

of the burning will be primarily on Olin’s

facilities,

there

are residential areas

 that would he affected if

the

burning

not

properly

controlled.

Evidence of witnesses indicates that the state of the arts nas

not reached a point where

 there is any suitable alternative to open

burning of explosive wastes and certainly not in the qualities in-

volved in the present case.

 (See testimony

 of Dr.

 Robert E. McComb,

Affidavit of

T.

F.

McDonnell attached to

the

Petition for Extension

of Variance.)

 The state of the arts relative

 to disposal

 of explosive

wastes

was

considered and discussed

 in substantial detail in Case

No.

PCB-70-ll, Application

 for Extension of Variance of Olin Corpora-

tion,

which

variation

the

Winchester—Weston

Division.’

—

139

Based upon the evidence adduced at the Hearing and the

matters set forth in the Petition and Affidavit,

 it is the opinion

of the Board that the Petitioner has satisfied the statutory requisites

for a granting of a variance,

 Explosive waste previously generated by

Olin’s operation and the powder-contaminated structures cannot be

disposed of at the present time other than by open burning.

No

suitable incineration method or other means of disposal appear avail-

able.

 Prohibition of disposal by open burning of the structures and

the explosive wastes would constitute

 an arbitrary and unreasonable

hardship.

 To prevent the disposal would result in a continuing

condition of danger to person and property and to increase the

likelihood of water pollution.

 Insistence on enclosed burning

of explosive waste

 at the present time

 is unrealistic and would

impose

 a hardship on Petitioner disproportionate with any public

benefit achieved.

It is the Order of the Pollution Control Board that the existing

 variance previously granted in No. VR 70-4 be extended to December 1,

1971,

 subject to the following terms and conditions:

I.

 That the six remaining structures be burned by March

1,

1971; that no more than one structure be burned on any

one day; that the Environmental Protection Agency be

advised when such burning is

 to take place and that

such burning take place only when wind direction, wind

speed and meteorological conditions are of a nature to

minimize impact on adjacent and surrounding residential

properties; that such fuel oil as is used shall be of

a

character to minimize smoke emissions;

 and that a full

report be given to the Environmental Protection Agency

when the burning of these structures fs completed.

2.

 All explosive wastes on the premises presently under

water shall be disposed of by December 1,

 1971; ball

powder fines’ shall be disposed of in increments

of

approximately 15,000 pounds and not more than three

such increments shall be disposed of on any one day.

The use of f~~el

 oil shall be minimized to prevent the

emission of smoke.

 Rocket grains shall be disposed

of in increments of approximately two hundred pounds

providing that two strings of ten such increments

may be burned on any one day.

 Where loose powder is

burned on the ground and oil is utilized to ignite the

fire, extreme caution shall be taken to preclude the

escape of smoke beyond the boundaries of the Petitioner’s

 property, and that such fuel oil as

 is used shall be

of a character to minimize smoke emissions.

3.

 Olin Corporation shall submit a monthly report,

the

first being no later than February 1, 1971,

 to the

Pollution Control Board hnd the Environmental Protec-

tion Agency, specifying the nature, degree, extent and

details of its open burning activities on the premises

subject to this variation,

4,

 If the Environmental Protection Agency advis

the

Board that the open burning of explosive waste by Olin

Corporation pursuant to this

 variance

 is producing an un-

due 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 Corpora-

tion will be notiEied at the hearing date and shall be

allowed to

participate

 in said hearing.

As

 a result

of such hearing, the

Board

 may terminate the variance

granted

 herein prior to December

 1, 1971.

5,

The

variation

extension

hereby

granted

shall

terminate

upon

the

establishment

suitable

alternative

means

of

disposal

of

explosive

waste,

relative

all

any

part

the

Olin

Corporation

operation

resulting

 from the

availability

new

technology

and

processes

 which

would

enable

compliance

 with the

relevant

 statutory

provisions

and

regulations.

 Said determination shall

he made

only

after

hearing

scheduled

 by the Board

and

held

before

qualified

hearing

officer.

Olin

Corporation

will

notified

the

 hearing

 dat.e and shall

allowed

part~.cipate

said

hearing.

result.

that

hearing,

the

Board

may

terminate

the

variance

granted

herein

before

December

 1~1971.

Because

the

variance

involved

the

 present

case

princspaiLy

disnosal

of

;reviousiy

acccmulated

explosive

wastes

and

contaminated

structures not

requirina

the

installation

any

new

ec’uipment~

and

is a consequence

the

abandonment

of

an

existing

 facility,

 the Board

does not believe

a

bond

this

 matter

should

‘be

required.

I

dissent

I, Regina

E,

 Ryan, certify that the Board

adoeted

the

ahov6

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