NOTICE OF VIOLATION

 

Via Certified Mail#                                  Via Certified Mail#

 

To:

Wal-Mart Stores Inc.

Wal-Mart Stores Inc.

 

H. Lee Scott, Jr., President

CT Corporation System

 

702 S. W. 8th St.

251 E. Ohio Street, Suite 1100

 

Bentonville, AR  72716

Indianapolis, IN  46204

 

 

Cause No. 2006-16296-W

 

Based on an investigation, the Indiana Department of Environmental Management ("IDEM") has reason to believe that Wal-Mart Stores Inc. ("Respondent") has violated environmental rules and statutes.  The violations are based on the following:

 

1.                  The Respondent owns and operates a sanitary wastewater sewer and lift station located in the City of Madison, Jefferson County, Indiana.  The Respondent's sanitary wastewater sewer and lift station system serves the Wal-Mart Store No. 1327, and transports wastewater to the City of Madison publicly owned treatment works ("POTW").

 

2.                  Pursuant to IC 13-30-2-1, no person may discharge, emit, cause, allow, or threaten to discharge, emit, cause, or allow any contaminant or waste including any noxious odor, either alone or in combination with contaminants from other sources, into the environment or into any publicly owned treatment works in any form which causes or would cause pollution that violates or would violate rules, standards, or discharge or emission requirements adopted by the appropriate board under the environmental management laws.

 

3.                  Pursuant to IC 13-18-4-5, it is unlawful for any person to throw, run, drain, or otherwise dispose into any of the streams or waters of Indiana; or cause, permit, or suffer to be thrown, run, drained, allowed to seep, or otherwise disposed into any waters; any organic or inorganic matter that causes or contributes to a polluted condition of any waters, as determined by a rule of the board adopted under IC 13-18-4-1 and IC 13-18-4-3.

 

4.                  Pursuant to 327 IAC 5-2-2, any discharge of pollutants into the waters of the state as a point source discharge, except for exclusions made in 327 IAC 5-2-4, is prohibited unless in conformity with a valid NPDES permit obtained prior to the discharge.

 

5.                  Pursuant to 327 IAC 2-1-6(a)(1), all waters at all times and at all places, including the mixing zone, shall meet the minimum conditions of being free from substances, materials, floating debris, oil, or scum attributable to municipal, industrial, agricultural, and other land use practices, or other discharges:

 

 

A.        that will settle to form putrescent or otherwise objectionable deposits;

B.        that are in amounts sufficient to be unsightly or deleterious;

C.        that produce color, visible oil sheen, odor, or other conditions in such degree as to create a nuisance;

D.        which are in amounts sufficient to be acutely toxic to, or to otherwise severely injure or kill aquatic life, other animals, plants, or humans; and

E.        which are in concentrations or combinations that will cause or contribute to the growth of aquatic plants or algae to such degree as to create a nuisance, be unsightly, or otherwise impair the designated uses.

 

6.                  Pursuant to 327 IAC 2-6.1-7, any person who operates, controls, or maintains any mode of transportation or facility from which a spill occurs shall, upon discovery of a reportable spill to the soil or surface waters of the state, do the following:

 

A.        contain the spill, if possible, to prevent additional spilled material from entering the waters of the state.

B.        undertake or cause others to undertake activities needed to accomplish a spill response.

C.        as soon as possible, but within two hours of discovery, communicate a spill report to the Department of Environmental Management, Office of Environmental Response at 1-888-233-7745.

D.        submit to the Department of Environmental Management a written copy of the spill report, if requested in writing by the department.

E.        except from modes of transportation other than pipelines, exercise due diligence and document attempts to notify the following:

i.          for spills to surface water that cause damage, the nearest affected downstream water user located within ten miles of the spill and in the state of Indiana; and

ii.         for spills to soil outside the facility boundary, the affected property owner or owners, operator or operators, or occupant or occupants.

 

7.                  An investigation conducted by IDEM indicates that discharges of untreated sewage occurred from Respondent's sanitary wastewater sewer and lift station as follows:

 

A.        On July 28, 2003, IDEM received a compliant that a lift station located on the south side of the Wal-Mart store at State Road 62 and Ivy Tech Drive was overflowing.  On July 29, 2003, IDEM staff conducted an inspection at the lift station and observed that a spill of sewage from the manhole next to the lift station had occurred and had flowed several hundred feet to the south.  The spill did not enter waters of the state, however the discharge of contaminant into the environment, and the Respondent's failure to report the spill to IDEM, were in violation of IC 13-30-2-1 and 327 IAC 2-6.1-7.

 

B.        On July 25, 2005, IDEM received a complaint that a lift station at the Wal-Mart at 567 Ivy Tech Drive in the City of Madison had overflowed and sewage had flowed onto the ground and to a pond.  On July 26, 2005, IDEM staff conducted an inspection at that site and observed that the lift station had recently overflowed to the ground around the lift station.  The sewage did not appear to have left the property and the area was treated with lime, however the discharge of contaminant into the environment, the violation of minimum water quality conditions, and the Respondent's failure to contain and report the spill to IDEM, were in violation of  IC 13-30-2-1 and 327 IAC 2-6.1-7.

 

C.        On September 27, 2005, IDEM received a complaint that water samples taken down stream of the Wal-Mart store at 567 Ivy Tech Drive in the City of Madison indicated high levels of fecal coliform downstream of Wal-Mart's storm sewer.  On September 29, 2005, IDEM staff conducted an inspection at the Wal-Mart store and observed that the trash compactor on the east side of the building was discharging wastewater to the truck well which flows to the storm sewer.  Dog food and other waste were observed on the pavement around the compactor and any runoff would go to the storm sewer.  The discharge of contaminant to the environment and to waters of the state without a permit, the violation of minimum water quality conditions, and the Respondent's failure to contain and report the spill to IDEM, were in violation of IC 13-30-2-1, IC 13-18-4-5, 327 IAC 5-2-2, 327 IAC 2-1-6(a)(1), and 327 IAC 2-6.1-7.

 

D.        On September 18, 2006, IDEM received a complaint that the lift station at the Wal-Mart store at 567 Ivy Tech Drive in the City of Madison was overflowing and discharging raw sewage.  On September 19, 2006, IDEM staff conducted an inspection at the Wal-Mart store and observed that the lift station at the site was discharging raw sewage to the ground.  Raw sewage was flowing and seeping to a ditch which flows to Crooked Creek.  Sludge was deposited on the ground and some sludge was present in the ditch from the seepage.  The overflow had not been reported to IDEM. The discharge of contaminant to the environment and to waters of the state without a permit, the violation of minimum water quality conditions, and the Respondent's failure to contain and report the spill to IDEM, were in violation of IC 13-30-2-1, IC 13-18-4-5, 327 IAC 5-2-2, 327 IAC 2-1-6(a)(1), and 327 IAC 2-6.1-7.

 

In accordance with IC 13-30-3-3, the Commissioner is required to notify an alleged violator in writing that a violation may exist and offer an opportunity to enter into an Agreed Order providing for the actions required to correct the violations and for the payment of a civil penalty.  The Commissioner is not required to extend this offer for more than 60 days.

 

Entering into an Agreed Order will prevent the issuance of a Notice and Order of the Commissioner under IC 13-30-3-4, or the filing of a civil court action under IC 13-14-2-6.  IDEM encourages settlement by Agreed Order, thereby saving time and resources.  Timely settlement by Agreed Order may result in a reduced civil penalty.  Settlement discussions will also allow the opportunity to present any mitigating factors that may be relevant to the violations.  In addition, as provided in IC 13-30-3-3, an alleged violator may enter into an Agreed Order without admitting that the violation occurred.

 

If settlement is not reached within 60 days of receipt of this Notice of Violation, the Commissioner may issue a Notice and Order containing the actions that must be taken to achieve compliance, the required time frames, and an appropriate civil penalty.  Pursuant to IC 13-30-4-1, the Commissioner may assess penalties of up to $25,000 per day for each violation.

 

Please contact Terry Ressler, case manager, at 317/232-8433 within fifteen (15) days after receipt of this Notice to discuss resolution of this matter.

 

 

For the Commissioner:

 

Signed on December 12, 2006

Date:   _______________

Lori Kyle Endris

Acting Branch Chief

Office of Enforcement

 

cc:       Jefferson County Health Department

City of Madison, Water and Sewage Department

B.J. Hicks, Environmental Compliance Manger, Wal-Mart Stores, Inc.