ILLINOIS POLLUTION CONTROL BOARD
    August 23,
    1979
    ENVIRONMENTAL PROTECTION AGENCY,
    )
    Complainant,
    v.
    )
    PCB 76—190
    ILLINOIS CENTRAL GULF RAILROAD CO.,
    Respondent.
    MR. REED NEUMAN, ASSISTANT ATTORNEY GENERAL, APPEARED ON BEHALF
    OF COMPLAINANT;
    MR. TERRY N. BROWN,
    GUNDLOCK, LEE, EGGMAN, BOYLE AND ROESSLER,
    APPEARED ON BEHALI? OF RESPONDENT.
    OPINION
    ANI) ORDER OF THE BOARD
    (by Mr. Goodman):
    This enforcement action was filed before the Board on
    August
    9,
    1976 by the Illinois Environmental Protection Agency
    (Agency) alleging violation of Section
    9(a) of the Illinois
    Environmental Protection Act
    (Act) by Illinois Central Gulf
    Railroad
    (ICG), Monsanto Corporation
    (Monsanto), Amax Zinc
    Company,
    Inc.
    (Amax),
    and General
    American Transportation
    Company
    (GATX).
    Monsanto,
    Amax and GATX were later dismissed
    from the action on the Agency’s motion.
    At the May 14, 1979
    hearing,
    the Agency and ICG submitted a Proposed Stipulation
    and Settlement Agreement
    (Stipulation).
    No testimony was
    offered, nor were any witnesses called.
    No members of the
    public were present.
    The Pro7osed Stipulation asserts that at approximately
    2:15 p.m.
    on May 29,
    1976,
    a train owned and operated by ICG
    derailed
    for undetermined causes approximately 200 feet west
    of Illinois Highway 157 and 200 feet north of
    Illinois High-
    way 163
    in St. Clair County, near Centerville,
    Illinois.
    Two
    of the fourteen derailed cars contained chemical materials.
    A car consigned by Monsanto contained approximately 140,000
    pounds of chiorosulfonic acid.
    A car consigned by
    Ainax con-
    tained approximately 100,000 pounds of sulfuric acid in 93
    concentration.
    Surfuric acid leaked from the car after damage to its
    safety vent assembly,
    caused when the car rolled on its side.
    When the acid flowed into
    a ditch between the main rail line
    and a parallel
    track,
    a sulfuric acid mist developed.
    A fire—
    35—183

    —2—
    man treating the spill received minor burns.
    By 4:00 p.m.
    on
    May 29,
    1976, after approximately 15 tons of
    acid
    had been
    released,
    Amax personnel had stopped the leak.
    Standing acid
    was drained into a pit and neutralized with limestone
    dust.
    The derailed car containing chlorosulfonic acid stood
    upright, but acid leaked from its east end and formed a pool
    underneath the car.
    The acid decomposed as
    it reacted with
    moisture
    in the ambient air and it formed a dense cloud of
    hydrochloric acid and sulfur dioxide approximately 200 feet
    high and 100 feet
    in diameter.
    By 6:45 p.m.,
    ICG workmen
    had set the car on its side to locate the rupture, but were
    prevented
    from doing
    so by dense
    fumes.
    Crewmen drained the
    chlorosulfonic acid into a trench and pit they had dug and
    appreciably reduced the fumes by applying earth as
    a cover.
    Approximately 20 tons of
    chlorosulfonic acid had spilled from
    the
    car.
    Hulcher Emergency Service,
    Inc.
    (Hulcher), upon ICG’s
    request,
    sent
    a
    chemical team to the scene by 5:00 p.m. on
    May
    29,
    1976.
    At
    6:00
    p.m.,
    Hulcher’s
    re—railing
    team
    was
    contacted when the ICG crews and Huicher’s chemical team
    could not stop the leak.
    At 10:00 p.m.,
    the re—railing crew
    arrived, cleared the area,
    located the rupture and sealed the
    leak.
    J3y 10:00 a.m. on May 30,
    1976,
    the chiorosulfonic acid
    had been transferred to empty cars.
    The damaged car which had
    prevented access
    to the acid spill was removed.
    The spilled
    acid was then covered with
    lime and earth.
    The fumes were
    brought under control by 1:30 p.m. on May 30,
    1976,
    at which
    time nearly 500 evacuees were allowed
    to return.
    Approximately
    28 citizens were treated or examined at Centerville Hospital
    for fume—related injuries and were released; one was admitted.
    For purposes of the Proposed Settlement,
    the parties
    stipulate that ICG caused or allowed the discharge of contam-
    inants into the atmosphere
    so as to cause or tend to cause
    air pollution
    in Illinois
    in violation of Section
    9(a) of the
    Act.
    The parties, however,
    further stipulate that the viola-
    tions by ICG were unintentional.
    Although ICC submits that
    it acted promptly and diligently to correct the problems and
    dangers,
    the Agency maintains that ICG did not swiftly enough
    recognize
    its inability to solve the acid problem and the need
    for re—railing
    crews
    to he called to the scene.
    In any event,
    the parties are aware
    that
    the
    Board
    in
    EPA v.
    Chicago
    & North
    Western Transjportation
    Co.,etal.,
    30 PCB
    365,
    PCB 76—155
    (June
    8,
    1978)
    held
    that
    operators
    of
    a
    potential
    source
    of
    pollution
    have
    a
    duty
    to
    anticipate
    and
    make
    preparations
    to
    abate
    possible
    pollution
    before
    it
    occurs
    see
    Phil
    l~sPetro—
    ~c..
    EPA and Chicago
    &
    Northwestern
    Transportation
    Co.,
    Ill.
    App.
    3rd
    (2nd
    District,
    1979)1.
    The parties sub-
    mit
    that
    their controversy,
    if fully litigated, would conclude
    in a similar
    result.
    35—184

    —3—
    The Board
    finds that ICG violated Section
    9(a)
    of the
    Act.
    In the lack of evidence to the contrary,
    the Board pre-
    sumes
    that ICG followed a prepared emergency plan and respon-
    ded promptly in abating the pollution problem caused by the
    accident.
    Considering the significant economic
    loss exper-
    ienced by ICG in this matter,
    and ICG’s recognition of and
    attempts to resolve the problem, the Board holds that impos-
    ing a fine would not further the enforcement of the Act in
    this case.
    The Board hereby accepts the Proposed Stipulation and
    Settlement Agreement as presented at the hearing of May 14,
    1979,
    and incorporates the document by reference as
    if fully
    set forth herein.
    This Opinion constitutes
    the findings
    of fact and conclu-
    sions of
    law of the Board in this matter.
    ORDER
    It is the Order of the Pollution Control Board that:
    1)
    the Illinois Central Gulf Railroad Company violated
    Section 9(a)
    of the Environmental Protection Act.
    2)
    the
    Proposed Stipulation and Settlement Agreement as
    presented during the hearing of May 14, 1979 is incor-
    porated by reference as
    if fully set forth herein and
    is
    to be given full
    effect.
    I, Christan L. Moffett, Clerk of the Illinois Pollution
    Control Board,
    Opinion and Order were
    on the
    1979 by
    a vote of
    Christan L. Moffe~
    Illinois Pollution~~trolBoard
    day of
    35—185

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