ILLINOIS POLLUTION CONTROL BOARD

September 20, 1985

oi~pARTMEr4T OF THE ARMY

)

(Savanna Army

Depot Activity), )

)

Petitioner,

)

)

V.

)

PCB 85—1.43

TLLINOS

ENVIRONMENTAL

)

~ROTECTION AGENCY,

)

Respondent.

)

OPINION AND ORDER OF THE BOARD (by W.J. Nega):

This provisional variance request comes before the Board

upon a September 19, 1985 Recommendation of the

Illinois

Environmental

Protection Agency (Agency). The Agency recommends

that the Board grant the Department of the Army, Savanna Army

Depot Activity (SVADA), a

45-day provisional variance from the

open burning prohibitions of 35 Ill. Adm. Code 237.102 to allow

the destruction by burning of specified unstable explosive

propeilants. (Rec, 1).

The Board previosly granted the Petitioner a 45-day

provisional variance on August 7, 1985, retroactive to August 3,

1985 and lasting to September 16, 1985, in PCB 85-113 to allow

the emergency destruction by open burning of

209,463

pounds of M6

propellant and 97,773 pounds of MIS propellant. (See~ Opinion

and Order of August 7, 1985 in Department of the Army, Savanna

Army Depot Activity v. Illinois EPA, PCB 85-113). Section 36(c)

bE the Illinois Environmental Protection Act (Act) limits the

duration of provisional variances granted to any one person to a

total maximum of 90 days during any calendar year.

The Petitioner, which has been directed by U.S. Army

headquarters to demilitarize approximately 10,367 rounds of

ammunition immediately to avoid a possible explosion hazard or

potentially tragic accident, has requested a provisional variance

to 8110w

the emergency destruction of the following propellants

by open burning:

Ii,

75 MM HE

9,477

rounds

unknown

stabilizer

:~,

75 MM

FE—WP

740 rounds

0.25 percent stabilizer

3. 105 MM HE

150 rounds

0.01 percent stabilizer

Oue to its low stabilizer content, this ammunition has been

suspended from issue and use by the Army because of the inherent

danger

that the propellant couLd ignite at any time. (See:

Department

of Army teletype messages which are attached to the

provisional

variance request:. which “recommend destruction

of the

65~559

---

propellanc~ in the lots indicated, immediately or as

expeditiously as possible”; Rec, 1).

SVA~DA

intends to burn these propeilants on its inactive

burn pads which are located in remote part of the army depot 3

l,’2 miles away

from the nearest city. The closest city Is

Bellevue,

Iowa which has a population of 1182, Blanding,

Illinois,

which

has a population of 150 individuals, is located

about 3.8 miles from the burn area. The nearest homes are also

about 3.8 miles from the Petitioner’s burn area. (Rec 2).

Moreover, in the vicinity of these burn pads, the population

density is very sparse. Carbon monoxide, oxides of nitrogen,

carbon dioxide and particulates are the pollutants which are

expected to be emitted during the Petitioner’s open burning

activities. The Petitioner estimat:es

that.

four to five burns

will be required to completely destroy the propellant.

The Petitioner has noted that its explosives are inherently

unstable and have been known to deteriorate in storage when there

is a low stabilizer content or hazardous stabilizer loss.

The

Petitioners

propellant stability tests on some of the lots of

unstable explosive propeilants in question have indicated that an

extremely dangerous situation

now exists and the stabilizer

content of the propellant has fallen below the safe level for

continued storage.

The Agency’s investigation of this situation has revealed

that safety procedures are excellent and that the Petitioner has

an adequate firefighting detail at the facility as well as mutual

aid agreements with nearby fire departments to assure adequate

fire

protection. (Rec, 2). The Petitioner has agreed to conduct

its open burning ~ctivitie~ only during periods when there is

less than 50 cloud cover and

only between the hours of 9:00 A.M.

and 4:00 P.M. (Rec. 5. Mr.

Joseph Mall, the Agency’s District

Engineer, visited the Petitioner’s site on

August 3, 1985 “to

review

the proposed conditions with SVADA staff and observe the

procedures

taken

with the first burn” under the earlier

provisional variance,

(Rec.. 2). According to Mr. Mall, each

Durn (which takes place on a “burn pad”) is propellant which is

“lit with a

fuse of sawdust soaked in diesel fuel allowing

PersonneL to retreat

to safe

areas~. (Rec. 2),

The most visible

emissions

come

from

the fuse. Each burn lasts less than one

minute and produces an orange flash of approximately 100 feet in

diameter.

(Rec~ 2).

~t

the present time, the Petitioner has no other means

availahl~

to destroy and dispose of the dangerous, unstable

propellant.. Although a new explosive waste incinerator is

currently under construction at the

site,

the completion of

construction has been delayed because of equipment availability

problems and the necessity for technical review of the trial test

burn plan.~ Therefore, the new expThsive waste incinerator is not

expected to be operational

until

sometime in the spring of

1986. (Rec.

3.)~

85-~56O

---

—3—

The Petitioner emphasizes

that

“because of the low

stabilizer content, there is an inherent danger that the

propellant could ignite at any

time. SYADA

personnel are trained

in handling explosives and every safety precaution will be taken

to ensure the safety of

the

personnel during the removal of the

propellant and during burning operations’. (See: letter dated

September 13. 1985 to

the

Agency). Transportation of the

propellant to another military installation also is not feasible,

since the risk in shipping the unstable propellant would be even

gre.~cter than continued storage. (Rec. 3).

t ne retitionci.

nas

previously s.atud in PCB 85—113

that

deterioration which resulted in an explosion of propellant in a

storage location occurred on June 6, 1985 at the Lexington-Blue

Grass Army Depot due to “auto ignition of propellant with low

stabilizer content’. On July 31, 1985, there was a similar

explosion at a military facility in Dugway, Utah. On August 2,

1985, Mr. James Ryan of SVADA reported

that

“Army personnel

from

New Jersey investigated the problem at Savanna and determined

that the danger of explosion was imminent’.

The Petitioner has asserted that, at the time the Board

granted SVADA a provisional variance in PCB 85-113 to open burn

balk propellant, ‘it was not known that fixed (assembled) rounds

of ammunition had the same problem with low stabilizer content in

the propellant”. However, subsequent investigation of the

July 31, 1985 explosion at the Army’s Dugway, Utah proving

grounds facility disclosed

that

the explosion also involved fixed

rounds of ammunition. Accordingly, in light of the experience

gained during the intensive Utah investigation, the Department of

Army

has ordered the Petitioner to remove the propellant from its

fixed rounds aad t.u immediately destroy the propellant to avoid a

potei:

tally hazardous situation

•

The propellant to be destroyed

Nitrocellulose

potassium sulfate

12

diphenylamine

12

‘The Agency believes that, with the danger of ezptosion

apparent”, it would cbvLously be an arbitrary and unreasonable

hardship for

SVADA

to wait for the normal period of time to

pr’~ce~san ordinary

variance petition.

(Rec. 3).

Transport of

the prnpelLants to another faciLity is not a practical

‘~.

t:arua’.

~.

ye

because cf the inherent instability of the

~

tnnts and the risks involved3 and the Petitioner’ s new

a

waste ~csc~neratorwill

no:

become

available until next

year- aecause of the serious threat of explosion, the Agency has

inc ~ “~at“then-, is ~ ssriou~&vger to Illinois cItizens

(ern~:i

ce:.’I:~e

of

SVAD/~

here

bec&

use

avert’ though the odds are

probably against an explosion taing p.ace,

that

is a

risk

we

shoa2.

t’:C t_.

tLflf.:’

“

to

ncc~t;.:

~flt of possibly fatal

*15.581

---

-4-

In ref erencz~ to the Petic~oner’s handling of this situation,

the Agency states that:

“If the Department of

the

Army has not made a complete

inventory of

its

propellant, the Agency advises here that

this inventory be

taken promptly. If any more low-stabilizer

propellant is found, this variance must be amended with

burning to be conpleted by November

4, 1985

...

the Agency,

and presumably the Board, do not here look kindly on this

variance req.~nst~Provisional variances are an extraordinary

recedy and ~

Dt

to be treated so lightly. When the

btahrt.jzer

ttm

vas

first

discu.

4’eu, prudence would have

Endicated a

Lete survey of the inventory at Petitioner’s

Eaci2.ity.

.oner apparentty did not pursue this form of

action.. Pc

.

:ter should ba on notice that the Agency only

recommends

.

rant of this variance to protect the safety

of the citi

of LJ.linois. It is

most.

assuredly not for

the conven±~.. of tne Department of the Army.” (Rec. 4-5).

The

agency ;eves that the actual environmental impact of

the

burn.;

ng wil

ninimal because

the

burn

site is near the

middle of a larg .:litary facility and the area outside the

SVADA facility i’ •ary sparsely populated. (Rec. 3). The Agency

has

calculated ti

there will be about 287 pounds of

particulates emit.

:.

~ durtng each burn and that “even a much

larger amount of ~rticulateswould be insignificant in such a

sparsely populated area”, thee. 3Y. The amount of CO and NOx

released is “unquantifiable with available

information” but is

thought to be relatively minor. (Rec. 3).

Accordingly

•

the Agency has concluded

that compliance on a

short-term

basis

with

tne

open burning provisions of 35 Ill. Adm.

Code 237.102 would mpc.se an arbitrary or unreasonable hardship

upon the Pet..Lioner

tii

light

of the serious safety problem in the

instant casc the minimal environnental impact; the lack of

feasLble alternatives; the actual explosions under comparable

conds.ions at s~rnilarfacilities; and the fact that time is of

the esence.

Theretore)

the Agency recommends that

the Board

grant ~e provisional variance until November 4, 1985. (Rec. 5).

PL:suant to section 3Eb) of the Illinois Environmental

!~:ota:t.onAct, the Board hereby grants the provisional variance

as reconmended.

This Opinion consUtutes the Board’s findings of fact and

3RDEa

The Petitioner, the

Department

of the Army (Savanna Any

Depot. hctivity~

hereby ;rant.:d a pro’riaional variance until

November 4 192~

..~t

65-582

---

destruction

by

burning of the propellants identified in the

~)rovisional variance request, subject to the following

conditions:

1. The open burning shall only be conducted between the

hours of 9:00 A.M. and 4:00 P.M.

2. The open burning shall only commence when the cloud

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

3.

The Petitioner shall notify officials of municipalities

within a

5 mile radius of the burn site of the open

burning.

4.

The Petitioner shaLl

cease the

open burning if citizen

complaints are received

and only continue

when weather

conditions have changed sufficiently to avoid the causes

of those complaints.

This condition is to apply only to

the extent possible while completing the destruction of

the propellant by November 4~1985,

.5. The Petitioner shall conduct the open burning in full

compliance with Section 725.482 of the Board’s RCRA

Rules. (35

Ill. Adm, Code 725.482)

6.

The Petitioner shall notify the Agency when the burning

is completed.

Notice shall be made to:

Illinois Environmental Protection

Agency

Division of Air Pollution Control

Field Operations Section

5415 N. University

Peoria, Illinois

61614

Telephone:

(309)691-2200

7~ Within 7 days of t.he date of the Board’s Order, the

Petitioner shall execute a Certificate of Acceptance and

Agreement which shall be sent to Mr. William D.

Ingersoll at the following address:

Mr. William D. Ingersoll

Illinois Environmental Protection Agency

Enforcement Services

2200 Churchill Road

Springfield, Illinois 62706

This certification

shall have the following form:

I, (We)______________

_____________________, having

read the Or

iinos~liut±on

Control Board in

PCB 85-143 dated September

20,

l985~, understand and accept said

---

—6-

Order, realizing that such acceptance renders all terms and

conditions thereto binding and enforceable.

~iento.teArm~~

Savanna Army

Depot Activity

By: Authorized

Agent

Ti

L

I.e

T)

ate

IT S SO ORDERED.

I, Dorothy N, Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the above Opinion and Order was

adopted on the

~O1~

day of

~

,

1985 by a vote

of_

•-/-~

-

~

~

/•••~ ~.

Dorothy H.

G~i~n,

Clerk

Illinois

Pollution Control Board

65-ä64