ILLINOIS

POLLUTION CONTROL BOARD

January 6

1977

IMC CHEMICAL GROUP, INC.,

)

Petitioner,

v.

)

 PCB 76—259

ENVIRONMENTAL PROTECTION AGENCY,

)

Respondent,

OPINION

AND

 ORDER OF THE BOARD

 (by Dr. Satchell):

On October 19, 1976 IMC Chemical Group,

 Inc.

 filed with

the Pollution Control Board

 (Board)

 a petition for variance

from Rule 505 of the Chapter

 2: Air Pollution Control Regu-

lations

 to burn twenty-four buildings and four powder ponds

located at Petitioner’s facilities which have been storage

facilities for explosive products.

 The Environmental Pro-

tection Agency’s

 (Agency)

 Recommendation in this matter was

filed December

2,

 1976.

Petitioner has had a previous variance at this site in

PCB 71-57.

 Petitioner operates a plant in an area of approx-

imately

 608 acres

 in Marion, Williamson County,

 Illinois where

explosive products are stored for distribution by its Trojan

Division.

 There are twenty-four buildings located at the site

that have been used for the storage and/or manufacture of ex-

plosives.

 Eight powder ponds on the premise have also been

utilized by Petitioner.

 For a period of

 sixteen years these

buildings were used for the handling and processing of ex-

plosives including the following: nitroglycerin dynamite

 (DYN),

nitroglycerin

 (NG), nitrocellulose

 (NC), pentaerythritol tetra-

nitrate

(PETN)

 cyclonite

 (RDX)

 trinitrotoluene

 (TNT)

 lead

azide,

lead

sLyphnaLe

 and mixLurc~oF

 LEic aforemenLioned

such

Torpex,

HBX

and

FNH.

Over the years the buildings and powder ponds have become

contaminated with explosives.

 Respondent’s facility is located

within Crab Orchard Wildlife Refuge and is leased from the

United States Department of Interior, Bureau of Sport Fisheries

and Wildlife,

 Petitioner’s lease expires December 30, 1980.

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547

—2—

The leasee does have the option of terminating the lease upon

giving a year’s written notice.

 A condition for terminating

the lease requires the leasee or assigns

 to neutralize all

contaminated

 sites.

 The buildings at the site have not been

used since

 1971.

 These buildings and four powder ponds are

dangerously contaminated despite decontamination procedures

 attempted by Petitioner.

 Petitioner states

 it is necessary

to decontaminate the buildings and ponds as they constitute

a definite fire and explosion hazard.

 Petitioner states

that

the

only safe way to decontaminate these facilities

is

through open burning or flashing.

 Without burning Petitioner

contends that it is impossible to remove or desensitize all

explosives from cracks

 in the concrete or from absorption into

the wood or to complete any and all requirements

 to decontami-

nate facilities.

 Any other means of decontamination would

create

an extreme danger for the workmen involved in the

operation.

An Agency representative visited the site on November

1,

1976 to investigate the site concerned in the variance petition.

The Agency representative inspected the three types of buildings

(designated

A,

 B, and

C)

 expected to be burned.

 Buildings of

Type A contain the more dangerous explosive wastes.

 The type A

buildings

are

underground igloos constructed of eight inch thick

reinforced concrete walls.

 One—quarter inch thick plywood

covers the major portion of the walls, while wood framework

and wooden storage cabinets are scattered throughout.

 Boards

separate the upper and lower levels, while the floors are com-

prised of three—quarter inch plywood covered by three—quarter

 inch maple

 flooring.

 All exposed wood has been painted a

number of times.

 Due to dangerous transfer lines still

in

place, these buildings are to be burned in place.

 The con-

taminated wood will be sprayed with a reducing agent.

The

floor will be covered with straw and the wood and straw will

be soaked with number two fuel oil.

The

 type B buildings are metal quonset huL sLructures

with internal wooden structure similar to type

A.

 In this

case once the reducing agent is applied, all the wooden mate-

rial is

 to be removed to the open burning site where

 it will

be burned.

 The remaining concrete floor will then be covered

with straw and soaked with number two fuel oil.

 This will be

flash burned to insure decontamination of the cracks and

pockets where explosive material build—up might have occurred.

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548

—3—

Buildings of type C have

 a wood and metal frame with tin

roofing.

 Flash burning alone will be conducted in these build-

ings

 to ignite any accumulation of explosives

 on the floor area.

The ponds are to be drained and allowed to dry.

 Then the

ponds will be

 :Lined with six inches of straw and sprayed with

number two fuel oil and burned.

Petitioner will have

 four trained men on the site who will

be equipped with adequate fire hydrants and hoses to provide

fire protect~ion,and the neighboring fire department will be

placed on

 a standby basis to prevent the spread of

 fire.

The

open burning will be conducted under the direction of personnel

trained in decontamination procedures and will be conducted

between the hours of 8:00 A.M.

 and 3:00 P.M.

 The burning and

flashing would occur at a maximum of three times per week and

amount of material burned would vary from a minimum of three

tons

to

 a maximum of

 fifteen tons.

 Following this burning

schedule and allowing for bad weather conditions Petitioner

states the decontamination procedure could be completed in

six months.

The Agency contacted the manager

 of Crab Orchard Wildlife

Refuge within which the open burning site

 is located.

 He was

in complete agreement with the proposal.

 The Agency has re-

ceived no citizen complaints

 in regard to the burning.

The Agency estimates that the aggregate of all explosives

in the twenty-four buildings will total no more than 240 pounds.

The Agency states that this along with the 77,670 barrels of

pond residue shown on Petitioner’s Exhibit

 #3 would total no

more than 80,000 pounds of explosive wastes.

The Agency states no reliable emission factors are avail-

able for the open burning of the materials contemplated by this

Petition for Variance:

 lumber, straw, explosive wastes and fuel

oil along wiLh miscellaneous rubber and plastics.

 However,

based on emission factors presented in Table 2.4-1 of AP-42, ~k

Compilation of Air Pollution Emission Factors, published by the

UKited States Environmental Protection Agency and based on

Exhibit

 #3 of Petition, the Agency offers a rough estimate

that based on a worse case situation~9.4 tons of particulates

would be generated from the open burning of the twenty-four

buildings and four ponds.

 In addition,

 the Agency estimates

that burning the buildings would release 18.3 tons or less of

carbon monoxide,

 2.8 tons or less of organic material,

 .56 tons

or

 less of nitrogen oxides and 187 pdunds or less of sulfur oxides.

—

549

—4—

The

 nearest residence to Petitioner’s facility is

approximately

 .48 miles south of the open burning site.

Marion,

 Illinois, population 12,900 is located approxi—

IrLately

 5~~5

miles northeast of the facility.

 There are

no other similar emission sources

 in the area.

 The major

portion of the surrounding area

 is Crab Orchard Wildlife

Refuge.

In the 1975 Illinois Air Quality Report, Marion,

Illinois

 is listed as having 46 micrograms/cubic meter

(annual geometric mean)

 with the three highest twenty-

four hour samples being 131,

 123,

 and 118 micrograms per

cubic meter.

 This results

 in no violations of the State

and Federal primary particulate emission standard of 75

micrograms/cubic meter

 (annual geometric mean) with

 a maxi-

mum

 twenty—four hour concentration of 260 micrograms per

cubic meter.

 There was also no violation of the State and

Federal secondary standards, Chapter

 2: Air Pollution Control

Regulations, Rule 307(a).

 Other 1975 readings taken at the

Marion station include:

Allowable State and

Reading

 Federal Standard

Nitrogen dioxide

 .011 ppm

 .05 ppm

Sulfur dioxide

 .006 ppm

 .03 ppm

The Agency does not rely on the above information as

conclusive that Petitioner’s operation will not violate the

air quality standards; however, the Agency believes that

given the relatively small amount of pollutants and the time

period over which they will be released that the possibility

of violations of the ambient air quality in the area are

minimal.

 The Aqency recommends

 Lhat the Board qrant the

variance subject to certain conditions.

The

 Board finds the IMC Chemical has shown sufficient

hardship to warrant the grant of this variance.

 Other methods

available to Petitioner place Petitioner’s employees

 in danger

of possible explosions or leave questions

 of whether all the

explosives have been neutralized.

 The 1975 air quality data

indicates that it is not probable that this variance will cause

24

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550

5—

violations of the ambient air quality.

 The Board grants

Petitioner

 a variance from Rule 505 of the Chapter

 2: Air

Pollution Regulations subject to the conditions set out in

the order.

This Opinion constitutes the Board’s findings of fact

and conclusions

 of law in this matter.

ORDER

It

 is the order of the Pollution Control Board that

IMC Chemical Group, Inc.

 is granted a variance from Rule

505 of the Chapter

 2: Air Pollution Control Regulations in

order

 to burn twenty~fourbuildings and four powder ponds

in a period of six months subject to the following conditions:

(a) That no more than one specific site be burned per

day.

(b) That no more than three specific sites be burned

per seven

 (7) day period, and no burning shall

occur on a day subsequent to a burning.

(c) At least three

(3)

 days prior to each scheduled

burning,

 the Petitioner shall notify the Regional

Office of the site to be burned and the estimated

material involved.

Region IV~soffice address

is:

Illinois Environmental Protection Agency

liSA West Main Street

Collinsville, Illinois

(d) The Petitioner shall notify the Agency’s Region IV

office via telephone

 (618

 345—0700)

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 post-

pone the burning until improved conditions warrant

the scheduling of the burning period.

(a) Petitioner shall file a written report with the Agency

within thirty

 (30)

 days after the destruction of each

site, giving details of said destruction.

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551

—6—

(f) 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

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

having read

I

 (We)

and fully understanding the Order of the Illinois

Pollution Control Board in PCB 76-259,

 hereby accept

said Order and agree to be bound by all the terms and

conditions thereof

Signed

Title

Date

I, Christan

 L. Moffett, Clerk

 of the Tilinois Pollution

ConLroi Board,

 hereby certify

 the above Opinion and Order were

ado~onth~

~

 day ~

 1977 by a vote

istan L. Moffe~t,4,~1erk

Illinois Pollution(~9htrolBoard

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552