ILLINOIS POLLUTION CONTROL BOARD

August 12

,

1976

OLIN CORPORATION,

)

Petitioner,

v.

)

PCB 76—165

)

ENVIRONMENTAL PROTECTION AGENCY,

)

)

Respondent.

OPINION

AND

ORDER OF THE BOARD

(by Dr. Satchell):

This matter comes before the Board on a petition filed

by Olin Corporation

(Olin)

on May 27, 1976 seeking relief

from Rule 505, Chapter 2, Air Pollution Control Regulations

(Regulations) to permit the destruction by burning of four.

small buildings of frame construction covered with construc-

tion paper siding and roofing material which for about thirty

years had been used for handling and processing various dry

explosives and pyrotechnic mixes at Olin’s East Alton, Illinois

facility.

The facility is part of Olin’s Winchester—Western

Division and consists of an area of about 1,732 acres; and at

which about 6,000 employees currently produce, among other

things, ammunition and explosive products.

The aforementioned

buildings have accumulated by dusting, spillage,

etc. dangerous

amounts of explosive contaminants which,

in spite of extensive

cleaning and decontamination procedures, remain a definite fire

and explosion hazard

(Pet.

2,3), and, since Olin abandoned

the use of the buildings in 1972 in favor of a chemical method

to destroy

scrap explosives,

they no longer serve a useful

purpose.

Previous attempts to dismantle similar buildings

even with known precautionary measures resulted in serious

injury to two workmen

(Pet.

3).

In the Agency Recommendation filed on July 20,

1976

it is pointed out that Olin has previously sought several

variances pertaining to explosive wastes at this facility.

In cases PCB 70—4,

70—11,

70—25,

71—7,

71—371, and 73—427

variances were sought for the burning of wastes;

also, in

PCB 74-28 Olin obtained a variance from Rule 203(e)

to

operate an incinerator until May 29, 1975; more importantly,

in PCB 72-281 Olin was granted a variance to burn 31 buildings

contaminated by explosive wastes according to well—defined

23—331

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conditions specified by the Board.

Olin has received all

necessary permits concerning air pollution emission sources

and control equipment at the East Alton facility.

Mr. Mike Elbl, Agency Field Operations Engineer for

Region IV, conducted an investigation on site on June

7, 1976

finding that the buildings contained no materials comprised

of asbestos fibers; the aggregate of all explosive wastes

was no greater than 25 pounds; and the nearest residence is

about 1,000 feet south of the buildings.

While no reliable emission factors are available for

the open burning of the materials of issue, the Agency, based

on Table 2.4-1 of AP-42, A Comtilation of Air Pollution Emission

Factors, USEPA, offers a rough estimate of 1,000 pounds or less

particulate emissions from the proposed burning.

Also, the

Agency estimates the emission of the following gases: equal to

or less than 1,250 pounds carbon monoxide;

300 pounds organic

material;

60 pounds nitrogen oxides and 10 pounds of sulfur

oxides.

These emissions are equated by the Agency as being

the amount a single Wood River refinery would emit in about

one-half hour of operation.

The nearest Agency ambient air quality station

(Wood River

Station located at 54 Wolcott)

is about two and one half miles

southwest.

At this station, in 1975, annual geometric mean

for particulates was

78 ug/m3

sulfur dioxide readings gave

an arithmetic mean of

0.032 ppm;

and also the 24-hour maximum

sulfur dioxide primary standard was violated on several

occasions.

No other violations were recorded.

On June

8,

9,

10 and 11 of 1976 an ozone yellow alert was called for the

Wood River/Alton area and it is expected that additional ozone

violations will occur at this station during the summer months.

The Agency states that it is doubtful that the burning

of Olin’s four buildings will have a measurable impact on the

air quality in the Alton/Wood River area because of the minor

amount of emissions and the few hours of burn.

The small

amount of explosive emissions would pose no health threat

to area residents

(Rec.

3).

The Agency agrees with Olin that open burning is the

safest method of disposing of the contaminated buildings and,

if performed under the special conditions given, the Agency

is amenable to waiving the posting of a performance bond.

The Agency agrees that the failure to grant Olin a vari-

ance would present a danger to the employees and the East

Alton facility that would be an arbitrary and unreasonable

hardship.

While

two citizen requests to not grant the variance

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332

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have been received,

the Board is convinced that disposing

of the buildings under selected and favorable conditions

will be less likely to cause annoyance or hazard than by

chance burning and/or explosion.

Under the conditions set forth in the Order, the Agency

recommends that the variance be granted.

The Board finds

no

viable alternative method of disposing of the contaminated

buildings and is convinced that the buildings pose a threat

not only to Olin’s facility and employees but possibly also

to the area.

While realizing that the emissions from such

open burning will contribute to the already polluted area,

the environmental damage appears minimal when compared to

the possible hazard of allowing the buildings to remain.

Therefore,

the Board shall grant Olin a variance from Rule

505 of the Regulations, subject to strict adherence to the

conditions enumerated in the Order.

This Opinion constitutes the Board’s findings of fact

and conclusions of law.

ORDER

The Pollution Control Board hereby grants the Olin

Corporation a variance from Rule 505, Chapter

2: Air Regu-

lations to permit the disposal by burning of buildings

designated

as. T-313, T-306, T-300 and T-307

at Olin’s

facility’in East Alton, Illinois subject to the following

conditions:

1.

At least one week prior to the date burning

is scheduled to take place, Petitioner shall

notify the Agency’s Region IV Office at the

following address:

Illinois Environmental Protection Agency

ll5A West Main Street

Collinsville, Illinois

2.

The Petitioner shall notify the Agency’s

Region IV Office via telephone on the day of

the scheduled burning, but before such

burning shall take place.

If ambient air

quality and/or weather conditions are not

favorable to burning, the Agency shall have

the right to instruct Petitioner to postpone

the burning until improved conditions warrant

the scheduling of the burning period.

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333

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3.

Petitioner shall file a written report with

the Agency within thirty

(30) days after the

destruction of the buildings, giving details

of said destruction.

4.

Within fourteen

(14) days after the date of

this Order, the Petitioner shall execute and

forward to the Control Program Coordinator at

Illinois Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Springfield, Illinois 62706

the Certification of Acceptance and agreement

to be bound by all terms and conditions of

the variance.

The form of said Certification

shall be as follows:

CERTIFICATION

I

(We), ___________________________, having read

and fully understanding the Order of the Illinois

Pollution Control Board in PCB 76—165, hereby accept

said Order and agree to be bound by all the terms

and conditions thereof.

Signed by

_____________________

Title ___________________________

Date ____________________________

IT IS SO ORDERED.

Mr. Dumelle dissented.

I, Christan L.

Moffett, Clerk of the Illinois Pollution

Control Board, hereby certify the abov~Opinion and Order were

adopt~71onthe

/~+~

day of\/J~~L~4*..

,

1976 by a vote

Christan L. Moffe~

,

~lerk

Illinois Pollutio

ntrol Board

23—