ILLINOIS POLLUTION CONTROL BOARD

March 16,

1978

SAVANNA ARMY DEPOT ACTIVITY,

)

Petitioner,

V.

)

PCB

77—182

ILLINOIS

ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

OPINION AND ORDER OF THE BOARD

(by Dr. Satchel?)

On July

5, 1977 the Savanna Army Depot

Activity

filed a

petition for variance from the Rules 202 (b)?

502 (a)

and 505

of the Boärd~sChapter

2:

Air Pollution Control Regulations.

After several subsequent pleadings the

Environmental

Protection

Agency

(Agency)

filed its amended recommendation

on February

8,

1978.

Petitioner is a U.S. Army

installation and is primarily

engaged

in

storing useable munitions

and

in the

demilitarization

of unserviceable munitions for the

U.S.

Department of

Defense,

Part of the demilitarization process

involves

the open burning

of explosive waste,

It is estimated

by

Petitioner

that

96 tons

of material will be burned in fiscal

years

1978 and 1979.

The

Agency estimates that the combined

amount of all

specified

contaminants

to

be

emitted

from

open

burning

of

96

tons

of

material

will total less than one ton.

In 1975 Petitioner burned

an

average

amount

of

material

on

approximately 100

days per

year consisting of:

800 artillery projectiles

at 25

lbs. TNT each

400 wooden containers at

20 lbs.

each

2 rockets at 50

lbs. each

10

lbs. of hand grenades

10 cannister mines at

33

lbs.

each

1,757 lbs. of No.

2 fuel oil,

The wooden containers are contaminated

and must be

destroyed

so that it is not possible to sell,

stockpile, or give

them

away.

These wooden containers are

consequently used

to ignite

the other explosive material,

The

fuel oil

is poured over

the wooden containers to serve as

part of the

igniting process.

However, now Petitioner requests permission to burn only that

material which constitutes a safety

hazard, material that requires

immediate destruction to protect personnel and property.

Some

material decomposes over time becoming a safety hazard.

Peti-

tioner has established a policy of

refusing to

accept material

for storage in the future which may

become a safety

hazard,

This should help minimize the open burning that will occur.

29

—

359

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—2—

At the present time there is no incinerator system available

to

control

the

discharge

of

contaminates.

Petitioner

intends

to

install

an

environmentally

approved

incinerator

designed

to

control

emissions

from

the

ammunition

demolition

ground

facil-

ities.

The construction of Petitioner’s incinerator has been

deferred pending the evaluation of test results from a proto-

type incinerator.

The control equipment Petitioner intends

to

install,

should the prototype prove successful,

consists of

a

fluidized bed reactor,

a decontamination oven,

a cyclone sep-

arator, a venturi scrubber and a column scrubber.

Petitioner’s

construction is to be completed by July 1984.

The only other

immediate alternative to the continuation of open burning

is the

shipment of the explosive material to another Army installation

in the United States at an estimated cost of $50,000 per year.

The nearest residences to the open burning location are

approximately

3 1/2 miles to the northwest in Bellevue, Iowa,

population 1,182.

Blanding, Illinois, population 150,

is

approximately 3.8 miles to the northeast.

The nearest ambient

air monitoring station is 9.0 miles

to the northwest in

Galena, Illinois.

The Agency regards this as being too distant

to provide relevant data.

The Agency states in

its reconrnendation that the methodology

of controlling emissions from the open burning of this material

is still an uncertain one.

The purpose of developing and operating

the prototype is to augment the knowledge concerning the methods

of control.

The Agency agrees with Petitioner that there is no

reasonable and prudent alternative but to open burn certain

amounts of material.

Transportation to other sites

for disposal

is unreasonable because of the possibilities of explosion during

the handling and transportation process.

The Agency states that

in consideration of the small amount of contaminants to be pro-

duced, the very small segment of the population which may be

affected by the contaminants and the uncertainties regarding air

pollution control methodology as well as the safety hazard

posed by disallowing open burning the Agency recommends the grant

of the variance with certain conditions.

The Board finds that the Petitioner has shown sufficient

hardship to warrant the grant of a variance subject to the Agency’s

conditions.

Th~danger of storing or moving the explosives and

the uncertainty of control methods balanced against the small

amount of contaminants to be released in a sparsely populated area

indicate that Petitioner would suffer an arbitrary and un-

reasonable hardship if denied a variance.

The Board does agree

with the Agency that a variance from Rule 505 of Chapter

2

is

unnecessary.

This Opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

29

—

360

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—3—

ORDER

is the order of the Pollution Control Board that the

~avanna Army Depot Activity is granted a variance from

~Rules202(b)

and 502(a)

of Chapter

2:

Air Pollution Control

Regulations in order to open burn explosive waste until

July 1,

1979 subject to the following conditions:

I.

The only

material which can be open burned

is

that which requires immediate destruction

to

protect personnel and property.

2.

Petitioner shall report to the Agency any changes

in location of the open burning or any increase

in quantities of material to be open burned within

30

days

of Petitioner’s discovery of same.

Any

such

reports shall be sent to DAPC

-

Field Operations

Sections, 4302 North Main Street, Rockford, Illinois

611 C)3.

~3. No Later

than March

1,

1979, Petitioner

shall

submit

to the Agency a status report which includes

information regarding any new alternatives to open

burning,

any new air pollution control techniques

for open burning and the progress of the proto-

type

incinerator.

The status

report ~ha11

be

sent to

the address specified in Condition Number

2.

4.

Within 45 days after the date of

this

Board Order

herein Petitioner shall execute and forward to

the DAPC

-

Field Operations Sections,

4302 North

Main Street, Rockford, Illinois

61103

a

Certifi-

cation of Acceptance and Agreement

to he

bound to

all terms and conditions of the var~an.ce.

This

45 day period shall be held in

abeyance

for any

period during which this matter is appealed.

The

form of said Certification shall be

as

follows:

CERTIFICATION

I

(We)

____________________________________

~ni

read and

fully

understanding the

Order of

the Illinoir lollution

Control

Board in PCB 77-182 hereby accepts

said Order and agree

to be

bound by all terms and conditions thereof.

Title

Date

29

—

361

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—4—

I, Christan

L. Moffett, Clerk of the

Illinois Pollution

Control Board, hereby certify the above Opinion and Order were

adoptçd on the

je,’~

day of

~

,

1978 by a vote

of

~

Christan

L, MofM~1, Clerk

Illinois Pollution Control Board

29

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