ILLINOIS POLLUTION CONTROL BOARD
    January 3,1974
    OLIN CORPORATION,
    Petitioner,
    vs.
    PCB 73—427
    ILLINOIS ENVIRONMENTAL PROTECTION
    AGENCY,
    Respondent.
    Mr. Thomas Martin, attorney, on behalf of Petitioner.
    Mr. Dale Turner, Assistant Attorney General on behalf of
    Respondent.
    OPINION AND ORDER OF
    THE BOARD (by Mr. Seaman)
    On October 9, 1973, Petitioner, Olin Corporation,
    filed its Petition for Variance seeking variance from the
    provisions of Section 9(c) of the Illinois Environmental
    Protection Act and Section 502(a)
    ,
    Part V, Chapter 2 of
    the Illinois Pollution Control Board Rules and Regulations
    prohibiting open burning. A public hearing was held in
    this matter on November 15, 1973.
    Petitioner requests that a variance be granted to
    permit the open burning of the quantity of scrap primers
    which Petitioner has on hand on the date of this Board’s
    Order in excess of 3,150 pounds; but that Petitioner be
    limited to open burning of such material in maximum quantities
    of 1,400 pounds per day.
    Petitioner operates a plant, consisting of an area of
    approximately 1,732 acres at East Alton, County of Madison,
    Illinois, where it manufactures, inter alia, shot shell
    ammunition and primer explosives. Approximately 5,700
    employees are currently employed at Petitioner’s East Alton
    location.
    Reference is made to PCB case Numbers 70-11 and 71-7
    which were Orders granting to Petitioner extensions of its
    existing variance, originally granted on May 18, 19G7,by
    the Air Pollution Control Board, to continue disposal of
    Petitioner’s explosive trade wastes by open burning. In
    December, 1971, Petitioner commenced operation of a new
    incinerator, rotary popper incinerator and air pollution
    control equipment designed to permit the burning of its
    explosive wastes in compliance with the air pollution
    regulations
    for incinerators.
    The Illinois Environmental Protection
    Agency (Agency) on March 12, 1973,
    issued
    to Petitioner an
    operating permit for the aforementioned equipment.
    10
    537

    —2—
    Petitioner alleges that because of higher than
    anticipated quantities of explosive trade wastes
    during 1973, and particularly because of maintenance
    problems with respect to the aEorementioned equipment
    resulting in approximately 52 working days of down time
    from January through September, 1973, the following
    approximate quantities of explosive trade waste have
    accumulated as of October 5, 1973:
    (a) 7,000 pounds of scrap primers. (12,600 pounds
    as of November 15, 1973. R,5)
    (b) 500,000 pounds of scrap shot shells (both
    empty and loaded).
    (c) 250,000 pounds of scrap loaded metallic
    ammunition (rifle and pistol cartridges).
    The foregoing accumulation al1eg~dlyhas occurred
    in spite of the fact that the present incinerator equipment
    is being operated five days a week on a three shift basis
    and one shift on Saturday. For safety reasons, the scrap
    primers are presently burned in small quantities together
    with scrap shot shells in the incinerator. The scrap primers
    are not burned in the rotary popper. It is conceivable
    that in the next few months it might be possible for Petitioner
    to dispose of its accumulation of scrap primers in the
    incinerator without the necessity for open burning, but
    Petitioner considers this to be unlikely in view of its
    experience with maintenance problems and shut downs during
    the preceding months of 1973. Based on this experience,
    Petitioner forecasts a continuation of some maintenance
    problems and down time with respect to the incinerator, with
    the result being an inability to reduce the accumulated
    quantity of scrap primers and, very possibly, an actual
    increase in such accumulation.
    The average generation rate of scrap primers from
    Petitioner’s manufacturing operations is 1,050 pounds per
    day. Petitioner’s Loss Prevention Department has determined
    that it is unsafe to store quantities of scrap primers in
    excess of a normal three day accumulation (3,150 pounds).
    The scrap primers must be kept wet, under water, and not
    be allowed to freeze. They are currently stored in ten
    quart buckets and require daily inspection to insure that
    the water cover has not leaked out or evaporated. If these
    scrap primers were allowed to dry, due to a leaking bucket
    or for some other cause, they could easily be set off by
    impact or spark with a resultant high order detonation.
    This excess accumulation represents a severe hazard to the
    employees and to the property of Petitioner.
    10—538

    —3—
    As
    noteci a~c~c, there are large backlogs of scrap
    shot shells and metallic ammunition which represent
    something of a fire and security hazard, but Petitioner
    believes that these accumulations can be held in storage
    pending Petitioner’s ability to dispose of same in the
    present incinerator and rotary popper. For this reason,
    Petitioner does not seek a variance to open burn the scrap
    shot shells and metallic ammunition.
    In order to solve the safety and backlog problems,
    Petitioner has developed plans for additional facilities,
    as follows:
    (a) Additional vertical incinerator for rapid, safe
    disposal of scrap primers. This will eliminate
    the present system of destroying them in small
    quantities along with scrap shot shells in the
    existing incinerator. This unit will also
    be used for the disposal of loaded metallic
    ammunition. The rotary popper has proven to
    be unsatisfactory for loaded rounds because of
    necessity for frequent removal of lead.
    (b) Additional pollution control equipment to remove
    particulates from the effluent from the vertical
    incinerator. In view of the short life expectancy
    of the scrubber now in use on the scrap ammunition
    incinerator, it is considered advisable to install
    one new scrubber with capacity to handle the
    effluent from the new vertical incinerator, the
    present rotary popper incinerator, and the present
    scrap ammunition incinerator. This would probably
    be a high energy Venturi scrubber, replacing the
    medium energy Tailor CVX scrubber now in use.
    Such a scrubber would represent the best currently
    available technology for removing particulates
    from burning scrap explosives and ammunition.
    During the period of installation of the new scrubber,
    it will be necessary to shut down the incinerator which is
    presently being used for the disposal of the scrap primers
    arid
    scrap shot shells. During this shut down period, there
    will be no other way to legally dispose of scrap primers
    unless the variance for open burning herein requested is
    granted (the scrap shot shells and metallic ammunition will
    be allowed to accumulate during this period).
    The quantity and type of raw materials which would be
    open burned per day, assuming the open burning of a quantity
    of 1,400 pounds of scrap primers per day, is as follows:
    10—
    539

    —4—
    Steel
    726 pounds/day
    Brass
    596 pounds/day
    Explosives (primer mix
    78 pounds/day
    consisting of normal lead
    styphnate, tetracene, pentaerythritol
    tetranitrate, barium nitrate, antimony
    sulfide, and aluminum).
    Petitioner argues thatpending the installation of the
    proposed explosive trade waste destruction equipment, the
    existence of the large excess quantity of scrap primers
    presents an imminent and continuing danger to Petitioner’s
    employees and property. Petitioner states that it knows
    of no safe method of eliminating this accumulation of
    scrap primers other than open burning. The Agency agrees
    with this contention. Therefore, Petitioner contends that
    compliance with the prohibition against open burning of
    this excess accumulation of scrap primers constitutes an
    arbitrary and unreasonable hardship. If the requested
    variance is not granted, Petitioner is faced with the liklihood
    that it will not be able to reduce the large excess accumulation
    of scrap primers to the safe level of 3,150 pounds in the
    near future, and it is also likely that because of future
    probably maintenance problems. with the incinerator, an
    increase in this accumulation will occur.
    The Agency is of the opinion that prolonged storage
    of the subject material could create a fire and safety hazard,
    and the material should be disposed of as rapidly as possible.
    Petitioner states that this material will be burned in a
    vertical incinerator fired by low sulfur oil.
    Petitioner, in its proposed timetable for installation
    of the new control device, states that construction will
    occur between November 15, 1974 and December 31, 1974. It
    is assumed that the existing incinerators will be down at
    that time, and Petitioner will be required to open burn all
    explosive waste generated.
    Based on stack tests performed in 1970, the vertical
    incinerators Petitioner plans to burn the explosive waste in
    will emit 5.68: and 5.51 grains per SCF. c~Thenburning 1,400
    pounds of explosive waste, the Agency calculates that the
    following emissions can be expected:
    10 —540

    -5—
    Contaminant
    Nitrogen oxides
    5 ppm
    0.15 lbs/day
    Sulfur trioxide
    122 ppm
    3.5 lbs/day
    Sulfur dioxide
    65 ppm
    1.9 lbs/day
    Total particulates
    167 lbs/day
    Lead
    28 lbs/day
    Barium
    7
    lbs/day
    Zinc
    37
    lbs/day
    Copper
    15 lbs/day
    Antimony
    9
    lbs/day
    Air quality readings in the East Alton, Alton and Wood
    River areas are as follows:
    Maximum 24
    ug/mhr. 3
    Average
    Geometricug/m3 Mean
    Alton
    54
    46
    Wood River
    82
    68
    The 1975 primary f~deralair quality standard for
    particulates is 75 ug/m~. It is the Agency’s opinion that
    one year of burning explosive waste will not greatly
    deteriorate
    the air in the Alton-Wood River area.
    The
    Agency has received no objections from citizens concerning
    the grant of this Variance.
    In view of the substantial threat to the safety of
    Petitioner’s
    employees and those persons in the proximity
    of Petitioner’s facility, we are disposed to grant Petitioner
    variance to permit open burning of the quantity of accumulated
    scrap primers which Petitioner has on hand on the date of
    this Order.
    However, Petitioner will be limited to open
    burning said material to maximum quantities of 1,400 pounds
    per day.
    Petitioner further requests a variance for a period of
    one year or until such time as Petitioner has placed into
    operation the above—detailed incinerators
    and control equipment
    (whichever first occurs) to permit the open burning of quantities
    of scrap primers which may accumulate in excess of 3,150
    pounds due to maintenance problems with its present incinerator
    and during the shutdown necessitated by the installation
    of the
    new scrubber.
    The Agency is of the opinion that Petitioner’s
    compliance schedule is reasonable.
    Petitioner’s
    request will
    be granted.
    This Opinion constitutes the findings of fact and
    conclusions of law of the Board.
    10—541

    —6—
    ORDER
    IT IS THE ORDER of the Pollution Control Board
    that Petitioner, Olin Corporation, be granted variance
    from the provisions of Section 9(c) of the Illinois
    Environmental Protection Act and Section 502(a), Part
    V, Chapter 2 of the Rules and Regulations until
    December 31, 1974 or until its proposed incinerators
    are operational (whichever first occurs) subject to
    the following conditions:
    1. Petitioner shall be allowed to open burn
    quantities of scrap primers in excess of 3,150 pounds.
    Open burning shall occur in a vertical incinerator fired
    by low sulfur oil. Petitioner shall not open burn more
    than 1,400 pounds of scrap waste per day;
    2. Petitioner
    shall incinerate the maximum allowable
    amount of scrap primers in the existing incinerators
    whenever
    it is operational. When operational, the existing
    incinerator shall be operated for three shifts a day,
    seven days a week, if feasible. When operational, the
    existing incinerator must be operated for three shifts
    a day, five days a week, with an additional shift on Saturday.
    3. Petitioner shall limit open burning to such times
    when atmospheric conditions will readily dissipate the
    contaminants;
    4. Petitioner shall obtain all necessary Construction
    and Operating Permits for its proposed new incinerator
    and its existing incinerators;
    5. By December 31, 1974,or upon completion of the
    new incinerator system (whichever first occurs) Petitioner
    shall cease open burning of explosive trade waste.
    IT IS SO ORDERED.
    Mr. Henss was not present.
    I, Christan L. Moffett, Clerk of the Illinois Pollution
    Control Board, certify that the above Opinion and Order
    was adopted on the
    .3~
    day of
    ,
    1974 by a
    voteof
    ~/
    to
    ~,
    ~
    ~4L
    10—542

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