ILLINOIS POLLUTION CONTROL BOARD
March 20, 1980
SAVANNA ARMY DEPOT,
Petìtìoner,
V.
)
PCB 79—109
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD
(by Dr. Satchel?):
This matter comes before the Board upon a variance petition
filed May 18, 1980 by the Department of the Army,
Savanna Army
Depot Activity.
An amended petition was filed on September 14,
1979.
Petitioner requests, pursuant to Rule
505,
a variance
from Rules
202(b)
and 502(a)
of Chapter
2:
Air Pollution Control
Regulations.
The variance would authorize open burning of ex-
plosive material at the Savanna Depot.
On July 18,
1979 the
Environmental Protection Agency
(Agency)
recommended denial, but
on November
5,
1979 recommended that the variance be granted with
conditions.
Hearing was waived and no public comment has been
received.
The Savanna Army Depot is situated on the Mississippi River,
north of Savanna.
The Depot is situated in Jo Daviess and Carroll
Counties.
The facility is used for storage of useable munitions
and demilitarization of unserviceable munitions for the
tJ.
S.
Department of Defense.
The facility previously obtained a vari-
ance for open burning of explosive waste which expired July
1,
1979
(PCB 77—182,
29 PCB 359, March
16,
1978),
On October
4,
1979 the Board granted Petitioner an emergency variance to burn
1800 pounds of M2 propellant
(PCB 79-183,
35 PCB 497, 537).
Petitioner estimates that about seventy tons per year will
require open burning in fiscal years 1979 through 1984.
Forty-
five tons were actually burned during 1978.
Petitioner has re-
duced the amount burned from 1611 tons in 1975 and has installed
a bag house costing $100,000 to reduce emissions from its small
arms deactivation furnace
(Amended Pet.
3).
The Agency believes the proposed burning will result in
emission of 0.0469 tons of particulates per year
(Amended Rec,
3).
Most of this results
from contaminated wooden packing crates and
not the explosives.
The Agency also expects emissions
of sulfur
dioxide, nitrogen oxides, carbon monoxide and hydrocarbons but is
—2—
unable
to
estimate
the
amounts,
Petitioner
has
recently
installed
two
air
quality
monitoring
stations
at
the
Savanna
Depot.
These
generally
show
compliance
with
National
Ambient
Air
Quality
Stan-
dards
(NAAQS)
during
May
and
June
of
1979
(Amended
Pet.).
The
DeDot
is
situated
in
an
attainment
area
for
primary
stan-
dards
for
total
suspended
particulates
(TSP)
and
sulfur
dioxide
(Amended
Rec.
6)
It
is
not
classified
for
nitrogen
oxides,
carbon
monoxide and hydrocarbons.
The nearest Agency reporting station
is Galena,
9.0 miles north of the Depot.
During 1978 it showed
compliance
with
the primary NAAQS,
The nearest residence is 3.5
miles from the burning grounds.
There have been no complaints
about
the cast burning
Amended Rec.
7).
The Agency believes grant of the variance will cause no
violation of NAAQS,
The Board finds that requiring immediate
cessation of open burning woul~impose an arbitrary and unrea-
sonable hardship on Petitioner.
The variance will be submitted
to the United States Environmental Protection Agency as a revision
of the State Implementation Plan.
On March
30,
1979 the Department of the Army entered into a
Federal Facility Compliance Agreement with the United States
Environmental Protection A~ency (USEPA)
(Petition).
This agree-
ment provides for construction of an ammunition demilitarization
facility with air quality control devices
at the Savanna Depot.
Petitioner estimates that the cost will be about $26,000,000.
Final design
is to start in September,
1980 and be completed by
July
1981,
The construction
award
will be
in September 1981 with
construction completed by May 1984.
Compliance
is to be achieved
by September 1984.
The
Army
must submit
a progress report to
t:oe
Agency
and
USEPA
within
ten
days
of
the
date
for
achievement
of
each
incremental
step
in the
compliance
schedule.
The
schedule
is
fixed
and
definite
except
to
the
extent
the
United
States
Con-
gress
may fail to approve budget and/or authorization requests.
The Agency is satisfied that with the proposed system the
Depot will achieve compliance
(Amended Rec.
6).
However, the
Agency believes Petitioner’s proposed compliance schedule needs to
be reevaluated to achieve compliance in
a more expeditious manner
and should not be dependent on Congressional approval.
The Agency
recommends that the variance expire on April
1,
1980 with periodic
variances during the term of the construction.
—3—
The Board has reviewed Petitoner’s compliance schedule and
finds
it satisfactory.
The variance
will expire on September 30,
1984.
Petitioner will submit the progress reports required by
the
Federal Facility Compliance Agreement.
Since there is
a gap
in
the schedule of nearly three years during which no reports are
due,
the Board will also order quarterly progress reports
detailing
progress made on the compliance program and identifying the types
and amounts of waste burned each day under this variance during the
previous quarter.
The parties are in agreement concerning the
remaining conditions
(Petitioner’s Corrected Brief,
8; Amended
Rec.
8).
This Opinion constitutes the Board’s findings
of fact and
conclusions of law in this matter,
ORDER
Petitioner,
Department of the Army, Savanna Army Depot
Activity,
is granted
a variance
from Rules
202(b)
and 502(a)
of Chapter
2:
Air Pollution Control Regulations, subject to
the
following conditions:
1,
This variance will expire on September 30,
1984.
2.
Petitioner shall burn explosives and explosive con-
taminated waste only.
Petitioner shall take all
reason~blesteps
to separate uncontaminated waste from
explosive waste and avoid commingling of uncontaminated
waste with explosive waste.
3.
At all times during which ooen burning
is being con-
ducted, Petitioner shall have at least two trained
persons on
the site with adequate
fire fighting capa-
bility to prevent the spread of the fire,
4.
Local fire fighting authorities shall be notified prior
to th~ecommencement of open burning activities.
5,
All open burning activities shall be conducted under the
direction of personnel trained in explosive burning pro-
cedures.
6.
Petitioner shall notify the Agency’s Reqion
I office in
Maywood by telephone
(312/345—9780)
at least twenty-
four hours
in advance of any open burning.
8.
Petitioner shall submit
the
reports
required
by
the
Federal Facilities Compliance Agreement and,
in
addition, on or before April 10,
1980
and
every
three
months thereafter, Petitioner shall submit written
reports to the Agency at:
Enviionmental Protection Agency
Division of Air Pollution Control
1701 South First Avenue,
Suite
1205
Maywood, Illinois 60153
The reports shall detail all progress made in pursuing
Petitioner’s compliance program and shall quantify the
amounts and types of all materials burned on each
specific day that open burning occurred during the
reporting period.
9.
Within forty—five days of the date of
this
Order,
Petitioner shall execute and forward to the Illinois
Environmental Protection Agency, Variance Section,
2200 Churchill Road,
Springfield, Illinois 62706,
a
Certificate
of Acceptance and Agreement to be bound
to all terms and conditions of this variance.
This
forty—five day period shall be held in
abeyance for
any period this matter is being appealed.
The form
of the Certificate shall be
as follows:
CERTIFICATION
1,
(We)
_______________________________,
having
read and fully understandina the Order
in PCB 79-109,
hereby accept that Order and agree
to be bound by all
of its terms and conditions,
SIGNED
____________________________
TITLE
____________________________
DATE
____________________________
I, Christan
L.
Moffett, Clerk of the Illinois Pollution
Control
Board,
hereby
certify
the
above
Opinion
and
Order
were
adopted on the ~
day of ~
—
,
1980 by a vote of
~
Illinois
Pollution
