ILLINOIS POLLUTION CONTROL BOARD

December

5,

1974

OLIN CORPORATION,

Petitioner,

)

vs.

)

PCB 74-335

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

)

OPINION AND ORDER OF THE BOARD (by

Mr.

Dumelle):

On

September 10,

1974, Olin Corporation filed

its Petition For Variance

seeking therein relief for

a period of one year from the provisions

of Air

Pollution

Control

Rules 203(e)

(Particulate Emission Standards and Limitations

for Incinerators)

and 206(b)

(Carbon Monoxide Emission Standards and Limitations,

Incinerators)

in order to allow continued operation of its experimental

combustion

device.

In the alternative, Petitioner requests

a variance from the provisions

of Rule 502(Open Burning Prohibition)

and Section 9(c)

of the Environmental

Protection Act, relating to open burning.

Petitioner further seeks clarification

as

to whether

a permit will

be required under Rule 103 to continue the operation

of this

device,

and,

if so,

Petitioner seeks relief from Rule 104, requiring

a compliance program.

Petitioner manufactures various propellant and pyrotechnic products at its

facility located within Williamson County, near Marion,

Illinois.

The subject

of the Petition

is the disposal

of explosive and pyrotechnic wastes generated

during the manufacturing process.

The products manufactured by Petitioner vary from year to year.

However,

all

of its products are related to

a propellant or pyrotechnic technology.

The

United States through

its

Department of Defense is the major customer for such

products.

The quantity and type of raw materials processed by Petitioner may

vary widely depending upon Petitioner’s success

in bidding for Government contracts.

Actual amounts of explosive wastes generated are directly related

to production

volume.

While Petitioner cannot state with certainty what its product line or

volume will

be in

1975,

it is estimated that the maximum amount of explosive

waste generated weekly will

not exceed the following amounts:

Ammonium Nitrate Propellant

500 lbs.

Double Base Propellant

300 lbs.

RDX Type Explosive

200 lbs.

Single Base Propellant

20

lbs.

Ammonium Perchlorate Propellant

20 lbs.

Boron-Potassium Nitrate Propellant

200 lbs.

Black Powder

10 lbs.

Nitroglycerine

in Sawdust

25 lbs.

Potassium Perchiorate Propellant

20 lbs.

Firecracker Mix

50

lbs.

Colored Smoke Mix

100 lbs.

Contaminated Packaging

200 lbs.

Pyrotechnic

Flare Scrap

50

lbs.

14

—629

---

-2-

This waste

Is generated by activities

such

as machine clearing,

floor sweepings and rejected product.

Petitioner proposes to dispose

of the scrap

in

its experimental

combustion device which

is operated

two days

a week.

This device will handle

a maximum scrap rate of 400 lbs.

per hour.

Normally the scrap

is

fed

in

2

to

3

lb.

increments

and each

increment

is fully consumed before another is

added.

The quantity and type of contaminants discharged

by Petitioner’s

experimental

combustion chamber are estimated to be less than 24 grains

of particulate matter and less than 0.001

cubic feet of carbon monoxide

per pound of scrap burned.

The device here involved is designed to

operate with approximately 3000

excess air to insure that the rapidly

expanding gases from the combustion of explosive wastes are pulled

through the scrubbing devices rather than puffed out the various openings

of the combustion chamber.

Further,

the explosive scrap burned

has

a

low carboncontent.

Thus,

when the particulate emission calculations

of rule 203(e) are applied to this device with the required adjustments

eliminating excess air and correcting to 12

C02, it does not meet the

applicable regulations.

It does, however,

remove 99.74

by weight

of

the particulate emissions generated.

The carbon monoxide emissions

limit of rule 206(f)

is also exceeded

by this device when the required correction to 50

excess air is made.

Charcoal at the base of the combustion chamber

is utilized as an ignition

source for the explosive scrap and as

a refractory material

for the

extremely high flame temperature resulting from the burning of this scrap.

While the flame temperature

is high,

the heat value of this material

is

low, and it is rapidly cooled

by the excess air required.

Petitioner

believes that this sequence

of

events generates the unacceptably high

amounts of carbon monoxide.

Petitioner notes,

however,

that the

maximum carbon monoxide produced is 1.6 lb. per hour of operation.

Petitioner has no program to bring this device into compliance with

existing regulations.

It is Petitioner’s contention that this device

represents

an advance

in the state of the art which

is not recognized

by present regulations.

Petitioner has been before this Board several

times due to

explosive waste disposal problems.

(See PCB 71—60,

PCB 71-231,

PCB 72—357, 72—517, and PCB 73—395.)

Initially, Petitioner obtained

a variance from the Board

in order to allow open burning of

pyrotechnic and explosive wastes while controlled methods

of

thermal

destruction were investigated.

Eventually, Petitioner

developed the combustion device described above.

On September 13, 1974 an Agency representative visited Petitioner’s

plant

to observe the operation of the device.

During that visit,

emissions were 5-10

opaque and all

operations were found

to be

in

order.

The Agency

is aware of only one malfunction that has occurred

during

the operation of the device and has no information to indicate

that Petitioner has failed to abide fully with prior orders of the

Board.

14

—

630

---

-3—

The Agency calculates that the actual

carbon monoxide emissions from

the combustion device approach

.05 cubic feet per pound of scrap burned,

and that the particulate emissions are approximately 24 grains per pound

of scrap burned.

An important aspect of Petitioner’s operation is

that

99.7

by weight of the particulate emissions

is removed.

The Agency agrees that the existing emission standards are not well

suited to apply to Petitioner’s device and that regulatory changes are in

order to correct that problem.

The parties are currently seeking

a mutu-

ally acceptable proposed amendment to existing regulations which will cover

the device and bring Petitioner into compliance.

The proposed date for the variance extends beyond May 30,

1975.

We

are aware that action by this Board may not stay the impact of a federally-

approved implementation plan.

However, at the least,

a variance does grant

protection from the state regulation.

We are disposed to grant relief.

Petitioner’s combustion device rep-

resents

an advance in

the state of the art which greatly reduces the part-

iculate emissions from the disposal

process and is vastly preferable to

open burning.

The device

is operated

in an

isolated strip mine area, there-

by minimizing possible injury to the public and to the environment.

Variance

will be granted from the provisions of Rule 203 (e)

and 206

(b)

in order

to allow continued operation of the combustion device.

Variance from

Rules

103

is not necessary since the Agency can grant

a permit based upon

the variance contained herein.

Mr.

Henss dissents.

This Opinion constitutes

the findings of fact and conclusions

of law

of the Board.

IT

IS

THE ORDER of the Pollution Control Board that Olin Corporation

be granted

a variance for

a period

of one year from the date of this Order

from the provisions of Rules

104, 203

(e) and 206

(b) of Chapter 2 of the

Pollution Control Board Rules and Regulations

in order to permit continued

operation of its combustion device, subject to the following conditions:

1.

Olin Corporation shall

apply for an operating permit for its com-

bustion device from the Agency; and

2.

Olin Corporation shall

not operate

its combustion device

to exceed

a maximum scrap incinerating rate of 400 pounds per hour.

3.

Olin Corporation shall file a compliance plan with the Agency incorp-

orating its research and development program into the plan and report quarterly

to the Agency on progress.

14—631

---

-4-

I,

Christan

L.

Moffett, Clerk of

the Illinois Pollution Control

Board,

do hereby certify t~tthe ~boveOpinion and Order was adopted

on this

5Ø~

day of

(J,flhJ)-?/?,

,

1974 by

a vote of

i/__

1

~

Christan

L.

Moffett, Cler

Illinois Pollution Control

Board