ILLINOIS POLLUTICN CONTROL BOARD

December 18, 1986

EMERGENCY TECHNICAL SERVICES, CORP.,

Complainant,

v.

)

PCB 86—217

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY,

Respondent.

OPINION AND ORDER OF THE BOARD (by J.D. Dunielle):

This matter comes before the Board upon a December 17, 1986

recommendation by the Illinois Environmental Protection Agency

(Agency) that Emergency Technical Services Corporation (ETSC) be

granted a 45—day provisional variance from 35 Ill. Adni. Code

237.102, subject to conditions, to allow ETSC to detonate small

quantities of explosive or shock sensitive chemicals found in

Illinois schools, hospitals and small businesses. ETSC plans to

detonate these materials at a 2,500 acre Illinois National

General site near Marseilles, LaSalle County, Illinois.

The Agency has investigated the request by ETSC and has

determined that there is no viable alternative to detonation

disposal of these materials, that safety considerations demand

that the materials be removed from storage near people and that

there is no presently available disposal site to receive the

materials. Therefore, the Agency has found that with the dangers

and lack of alternatives present in ETSC’s case, it would impose

an arbitrary or unreasonable hardship on ETEC to wait for the

usual variance process. The Agency has also found that the

environmental impact in granting this variance is minimal in that

conditions placed on the grant of provisional variance should

insure that operations are optimal for destruction and disposal.

For the above reasons, the Agency recommends that ETSC be

granted provisional variance, subject to conditions. The Board

agrees and hereby grants ETSC provisional variance from 35 Ill.

Adm. Code 237.102, subject to conditions, to allow the detonation

of small quantities of explosive or shock sensitive chemicals

found in Illinois schools, hospitals and small businesses at a

2,500 acre Illinois National General site near Marseilles,

LaSalle County, Illinois.

This Opinion constitutes the Board’s findings of fact and

conclusion of law in this matter.

74-312

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ORDER

The Board hereby grants the Emergency Technical Services

Corporation provisional variance from 35 Ill. Adm. Code 237.102,

subject to the following conditions:

1. Variance shall run from December 18, 1986 to February 1,

1987.

2. The open burning shall only be conducted between the

hours of 9:00 a.ni. and 4:00 p.m.

3. The open burning shall only commence when the cloud

cover over the burn site is no more than 50 percent.

4. Any visually contaminated soils and vegitation shall be

excavated after each operational day and be

containerized for disposal as a special waste.

5. Because completeness of reaction and explosive reaction

products are so unpredictable, monitoring to verify the

efficiency of the technique is warranted:

A. A visual record of each detonation by still camera

or videotape is recommended to include:

1. “waste” container alone

2. material as prepared with initiator, co—

explosive (if used) and blasting cap

3. actual detonation or shortly after showing

fire and smoke evolved

4. close up of detonation site documenting

residue or lack thereof

B. A soil sample of the detonation site where blasts

disturbed soil. One composite sample per day of

operation is acceptable. Analysis to be for parent

materials detonated with at least 0.1 ppm detection

limit unless evidence can be provided documenting a

higher detection limit is the best commonly

achievable.

C. A record of air temperature, wind speed, wind

direction, cloud cover, humidity, precipitation for

each day of operation and any significant changes

that occurred during operations.

6. Materials to be detonated shall be limited to:

A. “common ethers”

74-313

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1. diethyl ether (ethyl ether)

2. isobutyl ether

3. isopropyl ether

4. tetrahydrofuran

B. “aromatic trinitro compounds”

1. picric acid (trinitrophenol)

2. trinitrotoleune (TNT)

3. trinitrobenzene

4. trinitroaniline

5. trinitrosalicylic acid

6. picran’ic acid

7. picryl chloride

C. “organic peroxides”

1. benzoyl peroxide

2. acetyl peroxide

3. tert—butly hydroperoxide

4. cuniene hydroperoxide

D. “miscellaneous explosives”

1. dinitrophenyl hydrazine

2. vinylidene chloride (l,l—dichloroethylene)

3. pentaerythritoltetranitrate (PETN)

4. cyclo—1,3,5—trimethylene—2,4,6 trinitramine

(RDX)

5. nitroguanidine

7. Materials containing the following toxic metals are not

acceptable: Antimony, Arsenic, Barium, Beryliuni,

Cadiruiurn, Chromium, Cobalt, Gallium, Gernianiuin, Hafnium,

Indium, Iridium, Lead, Maganese, Mercury, Nickel,

Osmium, Platinim, Rhenium, Rhodium, Rutheniuir, Selenium,

Silver, Tellurium, Thallium, Tungsten, and Vanadium.

74-314

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8. Within 7 days of the Board’s Order, Peitioner shall

execute a Certificate of Acceptance and Agreement which

shall execute a Certificate of Acceptance and Agreement

which shall be sent to:

Mr. William D. Ingersol

Illinois Environmental Protection Agency

Enforcement Services

2200 Churchill Road

P.O. Box 19276

Springfield, IL 62794

This certification shall have the following form:

I, (We) ______________________________, having read the

Order of the Illinois Pollution Control Board in PCB 86—217 dated

December 18, 1986, understand and accept said Order, realizing

that such acceptance renders all terms and conditions thereto

binding and enforceable.

EMERGENCY TECHNICAL SERVICES

BY:_______

(NAME)

(TITLE)

(DATE)

IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify ~that the above Opi~pionand Order was

adopted on the

-

~

day of /i-~i~-t,, 1986 by a vote

of

____________

Dorothy N. /Gunn, Clerk

Illinois Pollution Control Board