IL EPA-Violation Notice-Vienna Correctional Center
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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 • (217) 782-3397 JB PRlnKER, GOVERNOR JOHN J. KIM, DIRECTOR 21 7/785-0561 December 13, 2022 CERTIFIED MAIL# 7011 1150 000108571873 RETURN RECEIPT REQUESTED Vienna Correctional Center c/o Chalen Tatum 6695 State Hwy 146e Vienna, IL 62995 Re: Violation Notice: VIENNA CORRECTIONAL CENTER Facility No.: IL0875510 Violation Notice No.: W-2022-00070 Dear Mr. Tatum: This constitutes a Violation Notice pursuant to Section 31 ( a)(l) of the Illinois Environmental Protection Act ("Act"), 415 ILCS 5/31 (a)( 1), and is based upon a review of available information and an investigation by representatives of the Illinois Environmental Protection Agency (" Illinois EPA"). The Illinois EPA hereby provides notice of alleged violations of environmental laws, regulations, or permits as set forth in Attachment A to this notice. Attachment A includes an explanation of the activities that the Illinois EPA believes may resolve the specified alleged violations, including an estimate of a reasonable time period to complete the necessary activities. Due to the nature and seriousness of the alleged violations, please be advised that resolution of the violations may also require the involvement of a prosecutorial authority for purposes that may include, among others, the imposition of statutory penalties. A written response, which may include a request for a meeting with representatives of the Illinois EPA, must be submitted yia certified mail to the Illinois EPA within 45 days of receipt of this letter. If a meeting is requested, it shall be held within 60 days of receipt of this notice. The response must include information in rebuttal, explanation, or justification of each alleged violation and a statement indicating whether or not the facility wishes to enter into a Compliance Commitment Agreement ("CCA") pursuant to Section 31 (a) of the Act. If the facility wishes to enter into a CCA, the written response must also include proposed terms for the CCA that includes dates for achieving each commitment and may include a statement that compliance has been achieved for some or all of the alleged violations. The proposed terms of the CCA should contain sufficient detail and must include steps to be taken to achieve compliance and the necessary dates by which compliance will be achieved. 2125 S First Street, Champaign, IL 61820 (217) 278-5800 1101 Eastport Plaza Or., Suite 100, Colhnsv1lle, ll 62234 (618) 346-5120 9511 Harrison Street, Des Plaines, ll 60016 (8471294-4000 595 S. State Street, Elgin, IL 60123 (847) 608-3131 2309 W. Main Street, Suite 116, Marion, IL 62959 (618) 993-7200 412 SW Washington Street, Suite 0, Peoria, ll 61602 {309) 671-3022 4302 N Main Street, Rockford, IL 61103 (815) 987-7760 PLEASE PRINT ON RECYCLED PAPER Page 2 of2 IL08755 l O VIENNA CORRECTIONAL CENTER VN W-2022The Illinois EPA wilt review the proposed terms for a CCA provided by the facility and, within 30 days of receipt, will respond with either a proposed CCA or a notice that no CCA will be issued by the Illinois EPA. If the Illinois EPA sends a proposed CCA, the facility must respond in writing by either agreeing to and signing the proposed CCA or by notifying the Illinois EPA that the facility rejects the terms of the proposed CCA. If a timely written response to this Violation Notice is not provided, it shall be considered a waiver of the opportunity to respond and meet, and the Illinois EPA may proceed with referral to a prosecutorial authority. Written communications should be directed to: Illinois EPA - Division of Public Water Supplies Attn: Adam Nutt, CAS #19 P.O. BOX 19276 Springfield, IL 62794-9276 All communications must include reference to this Violation Notice number, W-2022-00070. Questions regarding this Violation Notice should be directed to Adam Nutt at 217/785-056 l. Sincerely, ~~ Joey Logan-Pugh Manager, Compliance Assurance Section Division of Public Water Supplies Bureau of Water Attachments cc: CHALEN TATUM DALLAS MAZE BOW ID: W0878510001 PAGE NO. 1 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Questions regarding the violations identified in this attachment should be referred to Adam Nutt at (217) 785-0561. A review of information available to the Illinois EPA indicates the following violations of statutes, regulations, or permits. Included with each type of violation is an explanation of the activities that the Illinois EPA believes may resolve the violation including an estimated time period for resolution. Water Treatment Plant/Distribution Sy stem Maintenance There are structure/maintenance problems, which threaten the quality of the drinking water provided to customers. Violation Date 06/16/2022 Violation Description Delayed and deferred maintenance on critical components of the treatment plant has resulted in the need of treatment unit repair. Existing units have deteriorated beyond a maintenance level and now require immediate repair. The deteriorated state of the circular clarifier (Accelator) has resulted in an attempt to temporarily reconstruct it. The temporary reconstruction of the Accelator is not ptructurally approvable and its treatment capabilities are hindered in its current state of repair. Rule/Reg. Section 18 of the Act 415 601.101 and 604.105. Violation Date 06/16/2022 Violation Description The failure to maintain paint or other protective coatings on all water plant and distribution system water storage tanks has made the facilities vulnerable to potential system contamination via microbial growth, loss of disinfectant residual, taste and odor problems 1 and other water quality issues. Rule/Reg . Section 18 of the Act 415 ILCS 5/18, 601.101 and 604.1330(a). ILCS 5/18, and 35 Ill. and 35 I ll . Adm. Adm. Code Code PAGE NO. 2 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Description There are numerous leaks in the AquaStore reaction tank at the Water Treatment Plant that have been improperly repaired. This tank must have all leaks properly repaired or the tank must be replaced. The sidewalls of all water storage structures must be watertight with no openings except properly constructed vents, manholes, overflow, risers, drains, pump mountings, control ports, or piping for inflow and outflow. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 601.101 and 604.1325(a). Violation Date 06/16/2022 Violation Description Modify all water storage facilities with separate inlet and outlet pipes, mixers, or other acceptable means to avoid stagnation. Note that poor water circulation and long detention times can lead to loss of disinfectant residual, microbial growth, formation of disinfection byproducts, taste and odor problems, and other water quality problems. Complete water turnover in all storage tanks should occur at a minimum of every five days. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 601.101 and 604.1300(f). Violation Date 06/16/2022 Violation Description The air scour for Filter #2 did not appear to be providing proper air scouring for the entire filter area. Repairs should be made to ensure that the entire area of the filter is receiving proper air scouring. Rule/Reg. Section 18 of the Act, 601.101 and 604.605(1). 41 5 ILCS 5/18, and 35 Ill. Adm. and 35 Ill. Adm. and 35 Ill. Adm. Code Code Code PAGE NO. 3 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Description The indicating loss of head gauges and indicating rate of flow meters for each filter were not operational. Indicating loss of head gauges and an operational meter indicating the instantaneous rate of flow must be provided on each filter. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 601.101 and 604.605(i) (2). Violation Date 06/16/2022 Violation Description There are no compound pressure gauges on the suction lines and no standard pressure gauges on the discharge lines of the pumps at the water treatment plant. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 604 .1225 (c) (1) (A) and (C). Violation Date 06/16/2022 Violation Description There is no means to measure the amount of water used for backwashing the filters. An operational rate of flow indicator on the main wash water line or backwash waste line must be provided. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 601.101 and 604.605(j) (5). Violation Date 06/16/2022 Violation Description A piece of rigid foam had been added to the splitter box for Clarifier #1 and #2 to regulate the flow between the units. A means of measuring and modifying the flow to each clarifier must be provided. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 601. 101 and 604. 500 (d) ( 4) . and 35 Ill. Adm. Code and 35 Ill. Adm. Code and 35 Ill. Adm. and 35 Ill. Adm. Code Code PAGE NO. 4 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Descrip tion There is a single chemical feed pump for the alum , potassium permanganate , lime , caustic , ammonium sulfate , and h ydrofluosilicic acid feed systems . When chemical feed is nece ssary for the protection of the supply, such as c hlorination , coagulation or other essential processes , a minimum of two feeders must be provided with each having a dequ ate capacity to provide the maximum dosage necessary . Rule/Reg. Sect ion 18 of the Act , 415 ILCS 5/18 , 35 Ill . Adm . Code 601 . 101 and 604 . 1105 (b) . Inadequate Materials/Desi gns for Finished Water Storage The materials and designs used for finished water storage shall provide stability and durability as well as protect the quality of stored water. Violation Date 06/16/2022 Violation Description There is ponding of water in the low service pump room , which 'is a lso the roof of the 0 . 067 million gallon (MG} clearwell . The roof of all storage structures must be well drained. Rule/Reg. Section 18 of the Act , 415 ILCS 5/18, 601.101 and 604.1325(e). and 35 Ill. Adm. Code Violation Date 06/16/2022 Violation Description There is ponding of water on the floor of the pump station , which is also the roof of the 0.013 million gallon (MG) clearwell. The roof of all storage structures must be well drained. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm , Code 601.101 and 604.1325(e). PAGE NO. 5 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Description There is a leak observed in the sidewall of the 0.700 MG ground storage tank. This tank has been leaking for several years. The roof and sidewalls of all water storage structures must be watertight with no openings except properly constructed vents, manholes, overflow, risers, drains, pump mountings, control ports, or piping for inflow and outflow. Rule/Reg. Section 18 of the Act, 601.101 and 604.1325(a) 415 ILCS 5/18, and 35 Ill. Adm. Code Nitrification Action Plan Any community water supply distributing water without a free chlorine residual must create a Nitrification Action Plan (NAP). The NAP must: a. Contain a plan for monitoring total ammonia as nitrogen (N) , free ammonia as N, nitrite as N, nitrate as N, monochloramine residual, dichloramine residual, and total chlorine residual. b. Contain system specific levels of the chemicals in listed in A when action must be taken. c. Contain specific correction actions to be taken if the levels listed in Bare exceeded. d. Be maintained on site and made available to the Agency upon request. Violation Date 06/16/2022 Violation Description No Nitrification Action Plan has been created for the distribution system. A NAP for the distribution system must be created. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18 , 35 Ill. Adm. Code 601. 1 0 1 and 604.140. Violation Date 06/16/2022 Violation Description Raw and finished water meters are no longer operational. Water production is being estimated due to the failure of these meters. All pump stations (raw, finished, etc . ) must have flow rate indicators and totalizer meters. Rule/Reg. Section 18 of the Act , 604.1215(h). 415 ILCS 5/18 , and 35 Ill . Adm. Code PAGE NO. 6 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Description The potassium permanganate feed tank, sodium chlorite feed tank, sodium chlorite storage area, alum feed tank, caustic feed tank, ammonium sulfate feed tank, hydrofluosilicic acid storage area, and lime feed tank do not have secondary containment. Separate containment vessels or protective curbing under or around all chemical feed and storage tanks, sized to hold the volume of the largest tank, must be provided. Rule/Reg. Section 18 of the Act, 604.1105(j) (7). Violation Date 06/16/2022 Violation Description Chlorine gas cylinders are stored at the facilty. There are no provisions to chemically neutralize chlorine gas in the event of any measured release. Provisions must be made to chemically neutralize chlorine gas where feed and/or storage are located near residential or developed areas in the event of any measured chlorine release. The equipment must be sized to treat the entire contents of the largest storage container on site. Rule/Reg. Section 18 of the Act 415 604.lllS(c) (11). Violation Date 06/16/2022 Violation Description There is a single switch for the lights and ventilating fan outside the chlorine room. Separate switches for the ventilating fan and lights outside the chlorine room must be provided. Rule/Reg. Section 18 of the Act, 604 .1115 (c) (8). Violation Date 06/16/2022 Violation Description At the time of inspection, · it was noted that the chemical safety equipment provided for operational staff appeared to have deteriorated. All community water supplies whose treatment involves chemical application must have and maintain a chemical safety plan. Personal protective equipment consistent with that plan must be provided. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 604.160(a) and 604.lll0(a). 415 ILCS 5/18, 415 ILCS 5/18, ILCS 5/18, and 35 Ill. Adm. and 35 Ill. Adm. and 35 Ill. Adm. and 35 Ill. Adm. Code Code Code Code PAGE NO. 7 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Violation Date 06/16/2022 Violation Description Failure to provide level controls for water storage structure. Water system operation, monitoring, and recording require the basic tools of telephones, computers, and internet access. In order for your operator to monitor the regulatory information required of your system, these basic operational items at this time are either nonexistent or operationally inferior. These tools should be provided and updated. In addition, basic system monitoring is enhanced if electronic monitoring and controls (such as a SCADA system) are provided for your operators which enables on site monitoring of operations and distribution from one location. Through computers and smart phones, SCADA systems can notify multiple personnel of system issues before emergencies develop. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, Section 604.125(a) and 604.1320(a) and 35 Ill. Adm. Code · Fluoridation Requirement All Community Water Supplies that are required to add fluoride to the water must maintain a fluoride ion concentration, reported as F, of O. 7 mg/ f in the distribution system. Violation Date 06/16/2022 Violation Description Fluoride results submitted for analysis between April 1, 2021 and March 31, 2022 ranged from 0.308 rng/L to 0.474 mg/L. The fluoride content in the finished water must be maintained at 0.7 mg/L. Rule/Reg. Section 18 of the Act, 415 ILCS 5/18, 611.125 and 604.1150(a). and 35 Ill . Adm. Code PAGE NO . 8 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Special Exception Permit 'No person shall cause or allow the violation of any condition of a Special Ex ception Permit issued by the Illinois EPA . Violation Date 06/16/2022 Violation Description The last known date the turbidimeters were calibrated was unknown . Turbidimeters must be cleaned and calibrated in accordance with the Long Term 1 Interim Enhanced Surface Water Treatment Rule Monitoring Protocol Special Exception Permit (SEP) issued on December 20 , 2004 . Rule/Reg. Section 39(a) of the Act , 415 ILCS 5/39(a) , Section 18 of the Act , 415 ILCS 5/18 , and 35 Ill. Adm. Code 601.101 and 602.600(b). Violation Date 06/16/2022 Violation Description The turbidimeters are different than those that were approved in the most recent Special Exception Permit (SEP), Long Term 1 Interim Enhanced Surface Water Treatment Rule Protocol issued on December 20 , 2004. Obtain an updated Special Exception Permit (SEP) , Long Term 1 Interim Enhanced Surface Water Treatment Rule Protocol. Rule/Reg. Section 39(a) of the Act, 415 ILSC 5/39(a), Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Co de 601.101 and 602.600(b). PAGE NO. 9 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Drinking Water Monthly Opera ting Reports All public wat er supplies are required to submit reports summarizing daily operational a ctivities to the Regional Illinois EPA office each month . Compliance with this is expected within 30 days by submission of the required reports. Violation Date 06/16/2022 Violation Description In reviewing Monthly Operating Reports submitted to this Agency, it was noted that there are no calculated chemical feed dosages for all chemicals that are fed, and the reports are often submitted more than 30 days after the end of the month. These reports must be prepared on an operating report form approved by the Agency, must be signed by the Responsible Operator in Charge, and submitted within 30 days of the end of the month. A copy of the operating report records must be maintained by the official custodian of the public water supply. Rule/Reg. Section 18 of the Act 415 ILCS 5/18, 604.165(a), (c), and (d). and 35 Ill. Adm. Code Drinking Water Construction Permit Public Water Supplies (PWSs) are required to obtain construction permits from Illinois EPA for all construction. Before any deviations from plans and specifications approved by the Agency are made, the public water supply must make a written request for a permit. To meet compliance, the supply is expected to submit as-built plans and specifications pursuant to 35 Ill . Adm. Code 602.116. Violation Date 06/16/2022 Violation Description Failure to obtain a construction permit and failure to use products and materials certified to comply with NSF/ANSI Standard 61. Plastic had been wrapped around the center cone to prevent the short circuiting of Clarifier #3. These modifications had been made without plans and specifications being approved. A construction permit must be obtained prior to making modifications to any treatment equipment, and materials must be certified to comply with NSF/ANSI Standard 61. Rule/Reg. Section 15 of the Act, 415 ILCS 5/15, 602.l0l(a) and (b), 602.200(a) and (b), and 35 Ill. Adm. & 604.l0S(f). Code PAGE NO . 10 OF 10 ATTACHMENT A VIENNA CORRECTIONAL CENTER, IL0875510 VIOLATION NOTICE NO. W-2022-00070: Drinking Water Emergency Permit Public Water Supplies (PWSs) are required to obtain " as-constrticted" approval from Illinois EPA for all changes or additions for wh ich an emergency permit is issued. Violation Date 06/16/2022 Violation Descrip tion Failure t o obtain submit as-built plans and specificatio ns within 60 days of issuance of an emergency permit. Permitting of the installation of the carbon feed system approved under Emergency Construction Permit No. FY2021-0738, issued on March 17 , 2021 , has not been completed. Submit As-Built plans and specifications to complete the permitting process. Rule/Reg. Section 15 of the Act, 602. 104 (d) . 415 ILCS 5/15, and 35 Ill. Adm. Code Emergency Operation Plan Each community water supply must develop an EOP for the provision of water during emergency circumstances including earthquakes, floods, tornados, and other disasters. The EOP must include a review of methods and means by which alternative supplies of drinking water could be provided in the event of destruction, impairment, or contamination of the community water supply. The community water supply must review its emergency operations plan at least every three years and revise the plan as necessary. The plan must be maintained on site and made available to the Agency, upon request. Violation Date 0 6 /1 6/2022 Violation Description At the time of inspection, there was no Emergency Operations Plan (EOP) available for review. Rule/Reg. Section 18 of the Act , 604.135(d) (1) and (2). 415 ILCS 5/18, and 35 Ill. Adm. Code