ILLINOIS POLLUTION

CONTROL

BOARD

August

2,

1984

DEPARJ.L~1ENTOF THE

ARMY

)

JOLIET ARMY AMMUNITION PLANT,

)

)

Petitioner,

v~.

)

PCB

83—174

ENVIRONMENTAL PROTECTION AGENCY,

)

)

Respondents

ML.

JOHN A0 ROCK, ATTORNEY~AT~’LAW,APPEARED

FOR PETITIONER;

ML

PETER

E0 ORLINSKI, ATTORNEY~AT-LAW,

APPEARED FOR

RESPONDENTO

OPINION

AND ORDER OF THE BOARD

(by B~Forcade):

This matter comes to the Board upon

a November 21,

1983

Petition for Variance, and a January 12, 1984 Amended Petition,

filed by Department of the Army, Joliet Army Ammunition Plant

(~‘Army”)0 On January

9,

1984,

the Board

received

a

letter from

Ms0

Gisela Topolski, which it construed as

an objection0

On

February

24,

1984, the Illinois Environmental

Protection Agency

(“Agency~)

filed a recommendation that variance

be granted

with

conditions0

Hearing was held June

28, l984~

Army has petitioned for a one~yearvariance

from old

Rule

505 of Chapter 2:

Air Pollution, presently

codified at 35

Ill,

Mm0

Code 237~lO3~That regulation prohibits

the open

burning

of

explosive wastes0

Army seeks the variance to

allow

burning of

25

buildings contaminated with an explosive called

~tetry10~

The

variance would apply to Army~sfacility which

is approximately 18

miles south of Joliet,

5 miles north of Wilmington and

2 miles

south of Elwood,

in a rural area of Will

County0

The Army facility is owned by the United

States

Government

and is operated by the contractor, Uniroyal0

The facility,

when

operating, manufactures explosives and loads and

assembles

munitions0

The facility is presently on standby

status

(R0

1-10)~

During World War II, and the conflicts in

Korea and

Viet

Nam, the Army facility manufactured tetryl0

Twelve

production

lines were used to manufacture the explosive;

now, Army

has been

instructed to decommission six of those production

lines,

approximately 25 buildings, by the Rock

Island Headquarters

(R0

l0~12)~

These 25 wood and steel buildings were

built around 1940 and

have

become contaminated with from a few

ounces to a pound of

59~249

---

2

tetryl per

building

(R0

12,

l6)~

Any

effort

at

conventional

demolition would risk the possibility of a

worker hammering on a

pocket of explosives,

causing

an

explosion

that

may result in

serious bodily harm or death

(R. l5-l6)~ Standard destruction

protocols call

for the buildings to

be burned~

If the variance

is not

granted the buildings will remain

as a safety hazard and

the

land

upon

which

they

sit

could

not

be

used

for

future

production

needs

CR..

20-21).

The 25 buildings propose~ifor

demolition

are

all

in

one

area0

The

area

is

about

one

and one-quarter miles from the

nearest

installation

property

line,

one

and

one—half

miles

from

the

nearest

off-post

residence

or business, and two and one-half

miles

from

Elwood,

the

nearest

community

CR.

14).

The

area

surrounding the facility

is

rural

(Rec.

¶13).

Army proposes to first remove

all

asbestos (siding,

shingles, insulation) and lead (flooring,

pipes) from the

buildings0

Then one or two buildings will be burned at one time.

Wood

will be added to the buildings to ensure a temperature high

enough for complete destruction of the

tetry.

(R. l6)~ Each burn

of one or two buildings would be conducted in daylight, when

atmospheric conditions

are

conducive to smoke dissipation, and

with numerous safety and notification procedures.

Army and the

Agency have agreed on these conditions

(R.

25).

By using calculations from United States Environmental

Protection Agency manual

AP-42,

Table 2.4.2,

the parties found

the following estimated emissions under the agreed conditions

(Pet.

¶4; Rec, ¶~8—9;

R.

19):

Total

Maximum

Annual

Hourly

Emissions

Emissions

Particulates

5,358 pounds

39.3 pounds/hour

Carbon Monoxide

44,128 pounds

323.8 pounds/hour

Organics

7,565 pounds

57.1

pounds/hour

The three

nearest air monitoring

stations are 10 to 18 miles

away and showed

no violations in 1982 for

particulates, carbon

monoxide or ozone.

In 1983 the Braidwood monitoring station

(10

miles south) showed one excursion for ozone

(Rec.

¶14).

The

Agency believes adverse environmental impact from the burning

would be minimal because of

the

isolated area,

a one-year

variance allows emissions to be spread out, and the restrictions

on burning only during favorable atmospheric conditions

(Rec.

¶

15).

One

witness for Army testifed that based on prior

experience burning tetryl contaminated buildings he would not

expect explosions or other problems

CR.

19, 24).

The Board finds

that

denial of variance would constitute an

arbitrary or unreasonable hardship in that continued existence of

the 25 buildings may lead

to

spontaneous explosion (Rec.

¶5), and

59-250

---

3

workers.

This hardship outweighs the minimal

adverse

environmental impact expected from the controlled open burning.

Therefore,

the Board will

grant the requested one—year variance

with the agreed conditions.

This

Opinion constitutes the

Board~sfindings of fact and

conclusions of

law in this matter,

ORDER

The Department

of the Army,

Joliet Army

Ammunition Plant

(“Army~)is hereby

granted a variance

from 35 Ill. Adm, Code

237.103,

subject

to the following

conditions:

1.

This Variance shall

expire

August 2,

1985,

2.

Prior to open burning of

any

building, Army shall:

a)

remove all asbestos siding,

shingles, and pipe

federal and state regulations;

b)

remove and decontaminate all

lead flooring and

pipes;

C)

construct

a

fire

break

around

the

building;

d)

provide

24

hour

advance

notification to the

fire

departments

of Elwood, Manhattan, and

Wilmington and

to the

Agency’s

Maywood

office

at 312/345—9780;

e)

maintain an adequate staff

of

fire fighting

personnel with appropriate

equipment at the

burning site.

3.

Army shall conduct open

burning

operations

only

during

daylight

hours,

4,

Army

shall

conduct

open

burning

operations

only

when

atmospheric conditions are conducive

to good smoke

dissipation.

5.

Army shall not conduct open

burning operations during

episodes declared pursuant to 35

Ill.

Adm. Code Part

244.

6.

Army shall close

all

access

roads

to

the

open burning

site until

all fires have

been completely extinguished.

7,

Army shall provide adequate security personnel to

prevent

unauthorized persons

from entering the open

burning site,

59-251

---

4

8.

Army ~3hallnot burn more than

2 buildings within a

24

hour period,

9.

On or before the 5th day of each

month, Army shall file

written reports with the Agency

detailing:

(a)

date,

time, and location of each

building burned;

(b)

identification of the building

burned;

Cc)

meteorological conditions at

the

time

of the

burning

including wind speed,

wind direction,

temperature, barometric pressure,

relative

humidity,

type of cloud

cover, and visibility.

Said reports

Fthall be sent

to

the Agency at the following

addresses:

Environmental Protection Agency

Division of Air Pollution Control

Control Programs Coordinator

2200 Churchill Road

Springfield,

Illinois 62706

Environmental Protection Agency

Division of Air Pollution

Control

Region

1,

Field Operations Section

1701 South First Avenue

—

Suite

600

Maywood,

Illinois 60153

10.

Within 45 days of the Board~sFinal

Order

herein, Army

shall

execute a Certification

of Acceptance and

Agreement to be bound by all terms and conditions of

the variance,

Said Certification shall be submitted to

the

Agency at the addresses specified in

paragraph 9.

The

45 day period shall be held in

abeyance during any

period that this matter is being

appealed.

The form of

said Certification shall be as follows:

59-252

---

5

CERTIFICATION

Department of the

Army,

Joliet

Army Ammunition Plant, hereby

accepts and agrees to be

bound by all

terms and conditions of the

Order

of

the

Pollution

Control

Board

in

PCB

83—174, dated August

2,

1984.

IT IS SO ORDERED.

(Petitioner)

I,

Dorothy M.

Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the abov~Opinion and Order was

adopted on the

‘~

day of

___________,

1984 by a vote

Illinois Pollution Control Board