ILLINOIS POLLUTION

CONTROL BOARD

April 25, 1972

ENVIRONMENTAL

PROTECTION

AGENCY

)

)

)

v.

)

171—323

)

AYRSHIRE COAL COMPANY, a Division )

of AMERICAN

METAL CLIMAX, INC.,

)

and AMERICAN METAL CLIMAX,

INC., a)

Corporation

)

OPINION OF ThE BOARD

(BY

MR. LAWTON):

Respondent

(Ayrshire) controls a strip coal mine (Delta Mine)

east

of Marion, Illinois in Williamson

County, the

natural drainage

from part of which flows into the South

Fork of the Saline

River.

On October 13, 1971, the Illinois Environmental Protection Agency

(Agency) filed a complaint alleging that Ayrshire caused or allowed

the discharge of contaminants from this mine so as

to cause or threatc n

pollution of the waters of Illinois, in violation of section 12(a)

of the Environmental Protection Act (Act); deposited contaminants

upon the land so as to create a water pollution hazard, in violation c f

section 12(d) of the Act; and violated Rule SWB-l4 of the Rules and

Regulations of the Sanitary Water Board (continued in effect by

section 49(c) of the Act) pertaining to the minimum quality conditionE

acceptable for all waters subject to the regulation and to quality

conditions applicable to aquatic life and agriculture and stock

watering sectors of the waters of Illinois.

On the date of the scheduled hearing, the Parties proposed to

stipulate to certain facts in order to avoid litigation.

The proposec

stipulation pertained to Ayrshire’s ownership and control of the

sources of mine drainage and the accuracy of the Agency’ s effluent

measurements and water quality data. The Hearing Officer ordered thai

the parties, pursuant to PCB Procedural Rule 333, submit a Stipulatioz

of Facts Material to Controversy; that each party submit written

arquinent on the issue of an appropriate ranedy; and

that the Parties

aabmit to the Board a plan for abating the contaminated mine drainage,

tncl.uding time schedules and costs.

In the event the Parties failed

to reach an agreement on a proposed control plan, an additional hearit

wa to be held solely on the issue of abatement

•

The terms of the

proposed stipulation and the Hearing Officer’s order were

announced

at

the public hearing in Marion, Illinois on November 22, 1971.

Members of the public were afforded an opportunity to comment on the

allegations of the Agency’s complaint and the proposed settlement.

4—415

---

The Parties have submitted the Stipulation of Pacts; have

requested that no cease and desist order be entered and have filed

written arguments on the issue of appropriate penalty. After meetings

between the parties, Ayrshire submitted to the Board on March 23,

1972, its proposed abatement plan. On April

11, 1972, the Agency

stated its agreement with the proposed control strategy.

We find that Ayrshire, by carelessly maintaining and improperly

controlling these sources of contaminated mine drainage has caused,

threatened and allowed the discharge ~f contaminants so as to tend

to cause water pollution of the South Fork of the Saline River. Flow-

ever, in view of the proposed abatement program discussed below,

we decline to enter a cease and desist order at this time. We

impose a $1,000.00 penalty for violation of Section 12(a) of the

Act as aforesaid. We approve the Plan of Abatement of this contaminated

mine drainage. Our action is based on the following considerations:

In 1946, Ayrshire purchased the Delta Mine from its original

operators. When Ayrshire assumed control of the mine, it also assumed

control of a coal mine preparation plant used for sizing and washing

extracted minerals. This preparation plant generated a waste product

known as “gob”, consisting of shales, clays, coal fines and other

refuse materials produced by the cleaning of mined coal. Gob contains

iron sulphide, also known as “pyrites”, capable upon exposure to air of

oxidizing to form sulphuric acid which is then transported by water

moving over and through the refuse area. This acid drainage can

also pick up other mineral contaminants as

it

flows and, upon reaching

streams in sufficient quantity and concentration,

can

be toxic to

aquatic life, produce discoloration

and render water unsuitable

for

public use.

Prior to and after Ayrshire’s assumption of control of this

mined area, gob was piLed in large heaps around the preparation plant.

Likewise, overturned earth, “overburden”, from the strip mining opera--

tion was cast in this area to form “spoil banks”.

These gob piles

and spoil banks which Ayrshire inherited and to the growth of which

Ayrshire contributed, constitute a source of contaminated mine drain-

age to the South Fork of the Saline River and led to the prosecution

of this case (Stipulation of Facts, as amended, Page 1)

As Ayrshire states,

the gob piles probably became a source of

contamination almost immediately after their formation in the early

1940’s and continued as such during the 1950’s and 1960’s

(Respondent’s

Argument, pp.

5-6). In 1965, the Company became aware of state

regu-

lations with respect to water pollution, and an effluent abatement

program was initiated.

The abatement efforts begun in July, 1965, consisted of an

attempt to

eliminate acid mine drainage (at-source control rather

than

treatment), by preventing air and water from contacting the gob.

Several laudable steps were taken:

4

—

4W

---

(a) Gob

from the Delta Mine

was no

longer used for

construction of haulage and county roads;

(b) All gob generated from the preparation plant after

the

control plan was initiated was buried.

(c) Existing gob

piles

were covered with two

to four

feet

of earth in an attempt to seal them;

(d) Water was diverted

from gob areas and run-off water

from these areas collected in a ditch (completed

March, 1970)

and

pumped back for use in the

prepara~

tion plant, or impounded and diluted before release

(~CoilectionDitch” plan);

~e) Monthly progress reports were made to

the

Sanitary

Water Board.

These control efforts were successful

in mitigating contaminated

drainage to the Middle Fork of the Saline River, but pollutional

drainage to the South Fork from the gob piles have continued to the

present. The water quality of these discharges

is

not disputed.

(Stip-

ulation of Facts).

As

a standard of comparison, it should be noted that

PCB Regulations, Chap.

ill,

Water Pollution, Part IV, sets an effluent

standard

for manufacturing and processing

sources of 2 mg/i

total iron

and a pH range of 5 to 10. The Board is proposing an effluent standard

applicable to mine drainage of

7

mg/i total iron and a pH

of

5-10

(#R71—25)

The discharge

points on

which the Agency

conducted effluent

san~piing are located primarily below

the county road

which forms the

back

side of

the Collection Ditch and through which most of the con-

taminated drainage occurs. These points

are situated

generally

off

of

the mine property.

An Agency

engineer

on august

59

1971

made the

following

observa-

tions

and collected

the

following water quality saxnples~

(a) At

discharge

point

D-6 (overflow

arid

seepage

from the

collection sump

in the Collection Ditch), the water

was anther in color and the bed was covered with rusty

orange deposits~~ The water had a

pH of 3

and an iron

content of 140

ppm. The pump

designed to drain this

collection sump was not in operation. The discharge

flow rate

was

approximately 250 gallons per minute

(gpm);

(b) Point D-2 had a pH of 2.7

and

an iron

concentration of

102 ppm. The discharge here flowed at approximately

5 gpm

(earlier samples estimate the flow to be up

to

25 gpm);

---

(c) Point D-5 had a pH

of

3,3 and an iron concentration of

18 ppm. The

bed under the flow was a rusty color.

This discharge point is outside the mine property;

(d) This sample was collected where discharge points

D—6 and

0-7

combine outside the mined area. The diuch

here

flows southward to

the River and contained amber

colored water, with rusty orange bottom deposits and

coal fines on the bed. The drainage flowing at 400 gym

ned a pH of 2.9 and an iron level of 65 ppm.

Coal fines

were observed in the field adjaceric, to the drainage ditch;

~)

Point 0—8 heyond the mined area ad a flow of 20 gpu.

pH of 3.4 and an loon level o.f 2.4 ppm,

Samples taken at these discharge points on July 2

.19

7.1 were

amproxemately the same.

On June 18, 1971, this Agency inspector sampled the water quality

t

the uuzh Lor’~ ~ ~ Sal~u. liver upstr~an

to

doc7’u~trEau t~n’ tt~

en rance point of the mi~nedrainage ditches (Pelta Dit.ches)

These

pies showed no appreciable impact from the mine drainage on that

particular date, At this time, effluent

samplhnq

of the discharge

tombs reflected the same poor quality of the previously dis cuSsed

samples.

Mi. Robert Gates of the igency, on April 29, 1971, made observa-

tions and took water quality samples ap~rox:Lmatieg those yreurously

discussed9 except for the flow rate of Point b—6 which was only five

aliens nt~r unu~ Tlo pump qr~~ch

~~.ouiO

r’meuc~ rn.~.

qea~ti~-v of di”—

charge trom tries point was en operateo.n on that Cate.

Samples ta~.en by a third agency enspector on September 11, 19 19

September 21., 1970 and November 16, 1970 reflect the flow rate of 019

to vary from .50 to 200 gallons per minute.

The water quality on these

dates approximates that of previously discussed. sampling periods.

Similarly, photographs taken

by

the Agency, (Exhioit .5) reflect dis-

coloration and bottom deposits in the drainage ditches.

The control pi:ogram, begun

iii

1965, failed in part: largely be~

cause of the unworkability of the ‘~Col1ection Ditch~ plan .5 or pre-

venting run—off water from the mine site, although an additional

discharge source, Poent 0—7, originated in :~97l, This Is seepage

from a strip pit north of the county road which became contaminated

with acid water. The Collection Ditch, from the beginning, did not

function properly for several reasons:

(a) The collection sump in the Ditch was located next to a

railroad bed; if the strip wee lowered to a depth adequate

to collect the volume of rue—off water, the fill material

supporting the railroad track would slide. To prevent this,

the collection strap was maintained at a high level,. depr:! ving

---

it of surge capacity and allowing overflow during a

heath’ rainfall (Point 0—6) 9 or when the pump was shut

down for repairs~

(Is)

The water which the sump could contain exerted hydraulth:

press nrc 3r~ the cc:uni:.v ;:oad ~whichi~formed. ttie sout.h

.~

ide of

the sumne., causing conti .r.~uous seepage through the m.cad

hen

C

t:he source u~

.~

.s evera

.

dimmch,arqe tOiTlt:S ~:

~:

~

.i SOt) foot layer: nit

t,~e.rt

rook ~‘;th,ch “m.robably should

,

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to eack

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In

19 70

.,

appears tu bate been poorly des tpn.ed and 1: ad,iyrrnc:Ln.tained.

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---

Saline River. Additional contingencies are whether the pump in the

Collection Ditch is working and

whether

the sump is overflowing.

The fluctuations of weather and the vagaries of mechanical failure cannot

control

protection of

the

waters of Illinois.

By this opinion, we do not hold that the mere presence of a poten-

tial source of water pollutants on the land

necessarily constitutes a

“threat” of water

pollution in violation of

Section 12(a) of the Act,

Nor does the threatened discharae of any kind of contaminants into

the

waters

of

Illinois

necessarily “tend to cause water

pollution”.

Rather, where ss here, a large source of toxic contaminants is deposited

or is maintained on the land in close proximity to the waters ci lil:..~

no.ls. which contaminants can readily reach the waters of the state

in such quanta ties and ooncentrr’cteons or under such conditions as to

cause po.LJ..ute~:m of those waters , the. risk c:t poilution becomes unrea-

sonable and constltutes an unlawful threat within the raeanl ncr of the

Environmental Protection Ant.

(See Environmental Protection, Agency v~

Soil Enrichment Materials

n, PC3 ~719272)

Pa find no evidence that. Ay:cshire nas caused a. vsolatIon of

SWB—l4 or has “caused” Water po:Liution in violation of Section 12(a)

of the Act. While the Delta drainage unquestionably produces seaimen~’

tat~o arc toicora depoarts to Ian Piccesi-a

L.7 Ccentiorea ~n5 na: a

very low pH, there are no facts before us which would indicate tiler:

the Delta litches are “eatar~ o~ :l~iais’

anna7

toe mearlig 05

and the Environmental Protection Act. Whale discharning pollutants

into a

stream

that

is an

“open

sewer”

may

be wcj.swfu1L (Environmental

Protection Agency

v,

City of Ithampaign, ECE 171--IS) , contaminatinci

‘the waters of an open sewer that is a sewer is generally permissible

(Sc Lnv~ronraentel Prote~tion ,-qerc~

~on pars anmpan~, to’- , Pcn3

r~70-49). The

Agency proceeded

as if an

total

ignorance of th~ ~ppe~

case arid, a few cursory conclusions aside, made

no

reference to whather

c:r not any or all of the Delta Ditches constitutes a

stream. Under~

standably, Respondent remaired selent on this point.

Also, Ayrshire

has not, on the evidence before us, caused water pollution of the South

Fork

of

the Saline River.

The water quality data (one measurement)

shows the Delta Ditch

drainage to

exert

no demonstrable impact

on

tne South Fork on the date of that sample.

Nor has Respondent “deposited contaminants on the land so as tee

-.oreate a water pollution hazard” in violation of SectIon 12

(d)

of

the

Act.

The

Stipulation of Facts states that toe ‘discharges arise

from

gob piles and cast material deposited prior

to July 1? 1970, the dIes-

tive

date of the Act. Had these contaminatang gob piles and spoil banks

been deposited or enlarged subsequent

to

that date, Respondent might be

in

violation

of Section

12(d),

Ayrshire ‘ s proposed abatement program appears to

be an

effective

strategy to eliminate the “threat” of water pollution.

It encompasses

the grading of refuse piles to prevent water from ponding on them;

4 —

420

---

covering refuse areas with

earth

to seal them;

lowering

the Collec-

tion

Ditch to ease ti-ic hydraulic pressure on the

county

road

through

woich

seepage escapes to the South Fork; constructing an interception

ditch to reduce

the flow into the

Collection Ditch; and improving the

sump and pump system in

the

Collection Ditch,

thus more

effectively

directing run—off water back to

the

preparation olant.

The system,

if

successful, should prevent

ccntaminated

drainage :Erom leaving the

mine site. To prevent erosion,

revegetation

of the covered

refuse

area is planned, This

should

stabilize the cover and help maintain

the control system.

Finally, It should. he noted that. the Sa.i±OC River Basin has faced

this hazard of toxic Delta Mine drainage for years despite prolonged,

costly (approximately $300,000.00 by .19 72) but only sartially successful

control efforts,

This is dramatic evidence .of the need for environmen—

tat, planning t.o prevent the creation of mine--related water pollution

sources.

(See IF? 1-25, Hine-related Polluticn, Proposed Regulations)

This opinion constctutes the findings of fact and conclusions

of law c~fthe Board.

ORDER

I. All provisions of the stipulated Plan of Abatement for

delta Mine Drainage dated March 21,. 1972 are hereby

adopted. and made a nart of this Order.

Respondent

Avrshire shall comply with all terms of said Plan of

Abatement. respecting but not limited to the followinq

abatement procedures:

(a) Ayrshire shall construct a Contour Collecting

Ditch to direct runoff into the present Collecting

Ditch so that only runoff from undisturbed land will

be permitted to drain into the

0-2

water sampling

station.

This shall be completed by hay 1, 1972,

(b) Ayrshire shall lower the water level in the Present

Collecting :Ditch by deepening said Ditch five feet

or more and maintaining a minlmum bottom width of

ten feet: so as to prevent seepage through the county

road into drainage areas 0-2, 0—S. D-4 and 0-5,

This shall .oe completed by August 1, 1972,

(c) Ayrshire shall construct a 500,000 gallon surnp at the

end of the Present Collecting Ditch and shall maintain

said. sump at a sufficiently

low elevation to eliminate

seepage through the county road

from

the swap. Said

suxap shall be drained by mear~sof an electric pump

with a

capacity of 1,000 gpm which shall

he supported by

duplicate spare pump. This shall he completed by August

1972,

4 — 421

---

(:3,)

The Present lump shall be. backlilled,

‘graded and.

covered with four feet of dirt

upon completion

of

the sung required

by

par.,l(dbf the Order, so as to

eliminate mine drainage from

seeping through the

±‘Ill material into the 0—9 sampling station.

This shall be ~~‘.n’cr1rric’t7’cby August. 1, 1972

(a)

Ayr.snire shall construct a 30 , 000 gallon Collect-ins’

Sump,~dra.ined. by an eiectr’erc p’ueng of 500 gprn capa’—

city

with

a. cop .r...ic a to .0 ac.s‘--up’ pump so as

. e.Lama an be

mine d.ra:.L:nacre from a arspi icc; eta thor 0—-? .

Tb is she.

ne completed to Se terirlber 1, 1 ?‘72,,

f

AynsL: inc. s’hal 1. constr ‘aol: a’:: tuner Contour Ccii: cinc~

‘Di ‘t:c’:Li “aral IL alto

the. Collloctlnc: Di t.~ch so .r~snn

~o J er

~n I “ C

iC L.LI~’’~”

ove’rburcl.er: near: t.hc: Co:Lcot..i g DItch ,- reducreth a

1. lilt.

,,

i

it-c

~iJ

-

p

I a

ci

d a’:: :1 na pa

I

roe: :; err. ~n1.1 an’ .s ‘hat I cusP—I,;

p.~..4

.9

.

Th.:s a hal I be complete:. Ian L1ove~nberr .1.

15 72.

;‘~~c~j~’-’

a:

c’,’9

ate depn.s. I ted. n’riti’;,m:,”,n the ‘IJ’repe,r CIonto’ur

‘a

er.

~‘- “

nc

7

5

‘a,

c:;~arer’e,d ‘:‘~‘:(.‘I:.I:’:

cae~3:~ov’arb’u:~sde:’:, and tha: entire :‘:rn.r~

1

L

I

~7

F

‘to ti’.’te o:: I’Llcrc’t.i.n,r~ :1.a’lchaa,,

This .‘iifla..11 Ire

D”3” Dec’sTme era:

1, .r..n

/ a

(Ira

0:nc

ho In no Dec’entb en .31.. , .119 72 , Ityrs hi no. sInai 1 a ‘abr.:L 1.

,~

F

Iv

“~

—r

C

on

I :rie a 11 :no:cr: :: err’s:: IL Ia:

et ~ct..ioas 0 fan C II)

(:1.)

,3I.,iV.cFL,~1 ir’a she .1, IL dopers it a’ as ho ref use from tine ‘prererarre—’

tenon 3JJ.t.nt of “the Del.. i.e I”IIi.n’:::

n ~

open. ot

pa. I,: a n’7.

on oar said p1. t when. I Ili,’ed. with :‘:on”~eel. C.-- pmo~.::terC:

I

overoerr:de:’:

or In:: tore 1.’c.’rye:r,’b or 1., IL. 9’7 1,1.

try rca In no s’haIL. 1’, a era

a,

LII

a

F

‘a 0’~

“0

er ‘:1 eJ.i..

Order so. as~ to nr’ev.nnt eros ion of thaco:,at nc’I

1)

.Lu~tshl.

ncr aha ILl ::~.1bmit to t.h a Aenucy ~

.re porte’ o 1 a I fern ‘I:a. ‘hoera

:.r3,

etamp LIslenec an.:, or: an

:r.

S Or Cr.

(I)

‘L.Lpo.’r”r the on r.’c::1eta.:::’~.nI each ‘phas. a. o ‘I ‘ice ref ores .n .acr P1

era .OIb’a’hement., hyrshire eha’.l 1 con.duct coat. encrualLl.’tv

S

I

~, ,, —~

“p°

.-

aLL

v.

~,

.~

7 1

2

:‘h.nJ.3..rn’scerr:t t.hs resu. l.a eel’ a race s’a:mr.:i .tng ‘to the .i’Ir.cprnca~

---

2. By

November 1,

1972, Ayrsh~re shall have so

abated and

controlled that drainage from its

Delta Mine which

is the

subject of th±sproceeding that said drainage maintains a

pH range of 5 to 10,

and

a total iron concentration of

7

mg/i

and total

acid does not exceed total alkalinity.

Should said drainage fail to comply with such water quality,

by November 1, 1972, Ayrshire shall

impound and

treat

said drainage so as to

comply

with all applicable effluent

standards,

pending the completion of a permanent abatement

system. This

Par.

2 shall not apply to that drainage

to sampling stations D-B

and D-9.

3. Notwithstanding the above paragraphs of this Order, Ayrshire

shall comply with any Rules and

Regulations for the Control

of Mine Related Pollution adopted pursuant to pending pro-

ceedings in IR7l—25. This par. 3 shall not apply to the

effluent concentrations of discharges to sampling stations

controlled

by par. 2 of this Order until November 1, 1972.

This par. 3 shall not apply to the effluent concentrations

of discharges to sampling stations D-8

and D-9 until

further

Order of this Board

4. Ayrshire shall post with the Agency on or before June 1,

1972 in a form satisfactory to the Agency, abnd in an

amount

equal to the cost of its Plan of

Abatement except

for

points

D-2 and D-9,

which

amount

shall be forfeited

to the State of Illinois in the event the conditions of

this Order are not met. The amount of said bond shall be

substantiated by detailed supporting cost estimates sub-

mitted to the Agency.

5. Ayrshire shall pay

to the State of Illinois, on or before

June 1, 1972, the san of $1,000.00 as a penalty for

violation of Section 12(a) of the Environmental

Protection

Act,

as aforestated.

1, Christan Moffett, Clerk of

the Pollution C8ntrol Board, certify

that the above Opinion was adopted on the

~as

day

of April, 1972,

byavoteof4~,to

o

624a~I~&4t

4—423

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