The Springdale Questions and Answers page

Why is the Springdale Pit project being done?

The project is being done to supplement the filling of the pit with on-site "spoil" material originally removed from the pit during mining. LC&N is only required to fill the pit to a certain elevation, which they are doing with on-site material. This would ensure that rain water runs off the site rather than collects there. However, that would still leave an area that resembles a pit. By using coal ash at the site, LC&N can enhance and improve the reclamation of the Springdale Pit in order to ensure the site is filled as closely to the original contour of the land as possible.

Where is the project located?

It is just off Route 209 about a half-mile east of the center of the Borough of Tamaqua near Mt. Pisgah.

What is the history of the site?

The site was originally the location of an underground mine in the late 1880's, and then worked as a surface mine operation by several different companies from World War II to the early 1990's, including Greenwood Stripping and Bethlehem Mines. LC&N then took over operations at the site and mined there for about ten years.
The surface mine pit is currently about 300-400 feet deep and approximately 2,500 feet long and 1,200 feet wide. The coal ash being used on the site originates from coal-fueled power generating stations in Pennsylvania, New Jersey and New York.

Who is responsible for reclaiming the site?

LC&N is responsible for reclaiming the site because they took it over from Bethlehem Mines in the early 1990's and continued to mine the site.

Is LC&N using the material that was originally removed from the site during mining operations to reclaim it?

LC&N is using on-site spoil material to reclaim the site in addition to coal ash. In fact, the majority of the material being used to reclaim the pit is on-site spoil material. Unfortunately, there is simply not enough spoil material left at the site to restore it back to its original contour.

What about the coal refuse piles?

There are abandoned coal refuse piles and spoil piles on the site as well. However, LC&N is not required to use those piles in reclamation because they were produced by a different mine operator before the state and federal mining reclamation laws were passed in the 1960's and 70's (including the 1977 U.S. Surface Mining Control and Reclamation Act, which requires mine operators to reclaim their sites; mining done before this law was enacted are commonly referred to as 'pre-Act'). Because of this, LC&N is not legally required to use those culm piles to reclaim the site.

Is coal ash safe?

Yes, the use of coal ash for mine reclamation is safe and has been demonstrated as such over the course of many years, both in Pennsylvania and elsewhere. The U.S. Environmental Protection Agency (EPA), for instance, has determined that coal ash is not considered a hazardous waste and will not be regulated as one.
DEP has analyzed coal ash and coal ash leachate (water passed through the ash) for over 20 years from many different sources of ash. LC&N has used the coal ash material at the Little Italy site for over 10 years with close monitoring and supervision by DEP. The Department has observed no groundwater contamination from the site.
Additionally, a citizen's group called the Lake Hauto Association has also been testing water samples for 10 years from Lake Hauto adjacent to Panther Creek Partners in Nesquehoning, Carbon County, a power generating station that produces coal ash. They have found no adverse effects on the lake from the ash.
The department also issued a one-of-a-kind demonstration permit for placing coal ash in direct contact with a mine pool at the NEPCO cogeneration plant in McAdoo, Schuylkill County. The results were positive and significant: the coal ash increased the pH in the mine pool from distinctly acidic to distinctly alkaline and improved the water in other ways as well. The ash also solidified in contact with the mine pool water, allowing heavy equipment to be operated on top of the ash at the water's edge. This project has been significantly studied by Pennsylvania State University and DEP.
While a study by a faculty member of the Virginia Polytechnic Institute and State University (Va. Tech) raised concerns about disposing of coal ash, another study by a different Va. Tech faculty member supported the use of coal ash in mine reclamation projects.
In a 1999 letter written by Professor W. Lee Daniels of Va. Tech to the EPA, Prof. Daniels described his 9 years of research into the use of coal ash and other coal combustion products in the reclamation of mine lands, and stated his support for the practice. In his research, Daniels found that coal ash significantly reduced the threat of acid mine drainage by both reducing the level of metals found in water run-off from mine sites and restricting water's movement through coal waste material.
He also stated that he felt that existing federal and state regulations do require "sufficient testing and appropriate management practices of coal fly ash and related CCPs (coal combustion products) when utilized in both mined land and agricultural environments."
Recent allegations that some mining sites reclaimed with coal ash in western Pennsylvania have demonstrated contamination to groundwater due to the ash placement are misleading. These sites were former mining sites from years ago that were remined. An investigation of these cases revealed that the water contamination is actually a result of acid mine drainage that existed prior to the remining and reclamation of the sites, and that this degraded water has not been made worse by the use of coal ash.

Does coal ash contain dangerous levels of dioxin or other contaminants?

No, the type of coal ash approved for placement at the Springdale Pit does not contain dangerous levels of dioxin or other contaminants. According to the EPA, dioxin is not typically found in significant levels in ash from the type of coal-fired power plants that are supplying the ash to the Springdale Pit.
Scientific studies have shown that dioxin concentrations in coal ash are typically 10 parts per trillion or less, and that background concentrations of dioxin found in typical soil are often several times higher than the levels found in coal ash. The reason for that is dioxin is a compound produced by natural processes.
In comparison, the proposed regulatory limit for dioxin in material considered "safe fill/clean fill" - inert fill material that is allowed to be used anywhere without a permit - is 120 parts per trillion. That's higher than the levels found in the coal ash being used at this site.
These scientific studies have found that the dioxin concentrations in the coal ash are relatively low, because the coal combustion process does not have two factors that promote the production of dioxin. These are:
· chlorinated organic compounds,
· temperatures below 750 degrees Celsius. Dioxin is produced in combustion activities at temperatures below 750 degrees Celsius and destroyed at temperatures above 750 degrees Celsius. Since the combustion temperatures in the coal-fired power plants are greater than 800 degrees Celsius, and the large pulverized coal burners typically burn at 1,450 to 1,600 degrees Celsius, dioxin compounds are destroyed in these processes.
In summary, because of these characteristics of coal-fired power plants - the lack of chlorinated organic compounds and the temperatures of greater than 750 degrees Celsius - the ash being used at the Springdale Pit does not contain dangerous levels of dioxin. In addition to this, the Borough of Tamaqua is also testing the material, and to date that testing confirms that there are no dangerous levels of dioxins, PCB's or metals associated with the coal ash being used in the Springdale Pit.

What standards does coal ash have to meet?

The standards for coal ash and coal ash leachate are included in Chapter 287 of DEP's Residual Waste Regulations (and, specifically, in Module 25 of the Department's application package). The material does not have to meet clean fill/safe fill standards because those standards are used for material that is intended to be placed at any location at any time without a permit, including locations that may mean close human contact. The Springdale Pit reclamation, however, is part of an active mining permit and requires extensive monitoring and testing, and it is designed to prevent close human contact.
The analysis required for the material includes an analysis of the total solids (meaning from the material itself) and an analysis of the leachate, or the amount of material that may leach into the water that contacts the coal ash and then intermingles with the ground water. The acceptable standards, however, are based upon the leachate results, not the total solids results. The leachate values are used because these results give an indication of how much of the solid ash components will be released into the groundwater.
The leachate results are typically far lower than results for the total solids. For example, the results for aluminum in coal ash are sometimes reported as 20,000 milligrams per kilogram (mg/kg) in the total solids results, because aluminum is a major component of many rocks. However, the analysis of the leachate of aluminum, or how much aluminum may leach off the coal ash in to water, typically comes back as 1 mg/liter, meaning it does not tend to leach into the water that contacts the coal ash. (1 mg/liter or 1 mg/kg equals one part per million.) The leachate maximum standard for aluminum is 5 mg/liter, so if a leachate result was found of 1 mg/liter for aluminum, that would be considered acceptable.
Adding more material to a site also does not necessarily increase the risk. The threshold limits that are set by the state and federal environmental agencies are based on scientific studies that determine levels of exposure that will or will not be harmful to human health. These "risk" levels are based on concentrations of the substance, such as parts per million. Adding more material in which a substance might be present doesn't increase the risk because the substance is still only present at the same level. In other words, if the level of a certain compound is deemed to be 20 parts per million, it will still only exist at a level of 20 parts per million when new material is added. The level will remain the same.
Additionally, because these 20 parts per million are generally not concentrated together but rather spread throughout the entire amount of ash, they do not pose a threat. For example, picture a stadium with one million people, and 20 of them are wearing red hats. If someone were standing far enough away to see all one million people, the only way they would notice those 20 people wearing red hats is if they come together in a concentrated group.
The same is true of components such as arsenic. The only way those components could pose a threat is if they became concentrated, such as in a water discharge from the site. The process of material leaching off into water could form that concentration, but extensive leachate monitoring data reviewed by DEP shows that the coal ash leachate and groundwater monitoring results at this site and others in Pennsylvania are well within acceptable limits. Additional safeguards to discourage this type of concentration have also been included in the Springdale Pit project design.

What about the sources of the ash?

All the coal-fueled power generating stations that produce the ash used at the Springdale Pit site were required to obtain Beneficial Use Approval from DEP before they could provide coal ash to the site. The coal ash from these power plants is alkaline because the cogeneration plants add limestone during the combustion process for air quality benefits, and the pulverized coal power plants are required to add lime to the ash if the ash is not naturally alkaline.
The permitting process for these sites required the power generating stations to have their ash sampled and analyzed to insure it met the established limits. In addition, each truck that enters the Springdale Pit site has to produce a manifest for a guard at the site to prove they are carrying ash from an approved source.

How often is the site inspected?

DEP conducts inspections at the site every month to make sure the ash is being placed correctly at the site, that the logs being kept for each incoming truck are kept correctly and to make sure there are no excessive dust problems. DEP also conducts water sampling at least quarterly.
LC&N is required to conduct sampling and analysis of the water in the mine pool at certain monitoring points at the site four times a year and more extensive testing once a year. This helps to insure that no contaminants are present in the water. The company also is required to conduct sampling and analysis of each source of coal ash twice a year.

Why is the site not considered a landfill?

The Pennsylvania Beneficial Use Regulations for Coal Ash specifically state that coal ash can be used for mine reclamation projects as long as that project is specifically associated with a site that is part of an active mine permit, which is the case at the Springdale Pit. (The permit is considered active even though actual mining at the site is inactive because the ongoing reclamation work is part of the mine permit.) In addition, under the Solid Waste Management Act, coal ash used to reclaim a mine site, in accordance with the applicable regulations, is not a solid waste.

What about the complaints of local residents of dust from the site and the trucks that pass through town on their way to the site?

DEP's Bureau of Air Quality is conducting "dust patrols" in the Borough of Tamaqua to monitor the situation and to assess whether the dust being seen by residents is indeed from the truck traffic that is carrying the material through town. The dates of the patrols will remain secret so as not to alert potential offenders. If trucks are found to be causing problems, DEP will work with the borough and those trucking companies that have violations to correct the situation.
The trucks themselves are required by the Borough of Tamaqua to be covered by tarps as they haul the coal ash, and those trucking companies that spill material or excessive amounts of dust from their trucks are subject to vehicular citations by the local police departments. DEP's district mining staff has authority over the trucks once they enter the access road to the Springdale Pit site, and that authority allows DEP to issue compliance orders against offenders who create problems on the access roads or the site itself.
In addition to the dust patrols in the borough, DEP will also closely monitor the dust situation at the site and is planning on increasing inspections at the site to monitor for dust and other potential problems. As part of this ongoing effort, DEP's Pottsville District Mining Office and LC&N have incorporated new truck entrance and exit routes with paved and stone surfaces, and LC&N will install truck washes for trucks exiting the site. The first of these efforts appear to have significantly reduced the potential for dust to emanate from the site and for trucks leaving the site to track dust into town.

Is the company going to place river dredge and other materials at the site?

LC&N has applied to DEP's Bureau of Land Recycling and Waste Management for a General Permit that, if approved, would allow them to place a mixture of river dredge material, kiln dust and coal ash at the site. The company originally submitted an application on May 22, 2002 which was deemed administratively complete on September 16, 2002. However, the application was later deemed technically deficient because it didn't provide the necessary technical information about the proposed material, information which is necessary for DEP to make a decision on the application.
Due to the deficiencies, the applicant requested the review be put on hold until they could rework the application and resubmit it. LC&N resubmitted the application in April 2003 after hiring a new consultant. DEP's Bureau of Land Recycling and Waste Management is now reviewing the application and accepting public comment. The public will have the opportunity to request a public meeting or hearing on the application during this 60-day public comment period.
DEP has been reclaiming an abandoned surface mine in Clearfield County at the Bark Camp Mine Reclamation Laboratory using a similar mix of dredged sediment, coal ash and kiln dust over the past four years with very positive results that clearly demonstrate the safety of the material. The Department also recently completed placing dredged sediment in a site near the Springdale Pit called the Tamaqua Dredge Demonstration site and has again been very satisfied with the results.

For more information on this project, contact DEP's Pottsville District Mining Office at (570) 621-3118.