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NOTICE OF VIOLATION


VIA CERTIFIED MAIL #____________________        VIA CERTIFIED MAIL #___________________

The Honorable Robert J. Bercick            Walter Ruzich, Street Commissioner
Mayor of Whiting                    Whiting Sanitary District
1443 119th Street                    1915 Front Street
Whiting, Indiana 46394                Whiting, Indiana 46394

Cause No. UST-18

    Designated representatives of the Indiana Department of Environmental Management (hereinafter referred to as "IDEM") conducted an inspection on March 23, 1999, at Whiting Sanitary District, Facility ID #12819, located at 1915 Front Street, Whiting, Lake County, Indiana (hereinafter referred to as "the Site"). The registered owner and operator of the regulated underground storage tanks at the Site are the City of Whiting and the Whiting Sanitary District, respectively (hereinafter referred to as "the Respondents").

    During the above noted inspection, the Respondents were found in violation of :

        Emergency Rules Concerning Underground Storage Tanks (ERUST), LSA #99- 61(E), 22 IR 2536 at 2545, Section 64(a) (329 IAC 9-2.1-1(a)), (1999) which states:
            All existing UST systems shall comply with one (1) of the following requirements on or before December 22, 1998:
                (1) New UST system performance standards under Section 62 (329 IAC 9-2-1).
                (2) The upgrading requirements under subsections (b) through (d).
                (3) Closure requirements under Section 82 through Section 86 (329 IAC 9-6-1 through 329 IAC 9-6-5), including applicable requirements for corrective action under Section 74 through Section 81 (329 IAC 9-5-1 through 329 IAC 9-5-8).
        This violation is based on the fact that the Respondents' UST systems at the Site do not meet the new UST system performance standards, have not been upgraded and have not been properly closed.


        ERUST, LSA #99-61(E), 22 IR 2536 at 2561, Section 88 (329 IAC 9-7-2- (1)(B)), (1999) which states:
            The owner and operator of a petroleum UST system shall provide release detection for tanks and piping as follows:
                (1) Tanks must be monitored at least every thirty (30) days for releases using one (1) of the following methods listed in SECTION 90(4) (329 IAC 9-7-4(4)) through SECTION 90(8) (329 IAC 9-7-4(8)), except for the following:
                    (B) A UST system that does not meet the performance standards in SECTION 62 (329 IAC 9-2-1) or SECTION 64 (329 IAC 9-2.1-1) may use:
                        (i) monthly inventory controls conducted under SECTION 90(1) (329 IAC 9-7-4(1)) or SECTION 90(2) (329 IAC 9-7-4(2)); and
                        (ii) annual tank tightness testing conducted under SECTION 90(3) (329 IAC 9-7-4(3));
                    until December 22, 1998, when the tank must be upgraded under SECTION 64 (329 IAC 9-2.1-1) or permanently closed under SECTION 82 (329 IAC 9-6-1).
        This violation is based on the fact that the Respondents' UST systems at the site do not have leak detection.

    In accordance with IC 13-30-3-3, the Commissioner is required to notify you in writing that the Commissioner believes a violation exists and offer you 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 sixty (60) days.

    If settlement is not reached within sixty (60) days of your receipt of this Notice, the Commissioner may issue an Order pursuant to IC 13-30-3-4 containing the actions you must take to achieve compliance, the required time frames, and an appropriate civil penalty. Pursuant to IC 13-23-14-3, the Commissioner may assess penalties of up to $10,000 per underground storage tank for each day of violation.

    Entering into an Agreed Order will prevent the issuance of an 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 timely 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 give you the opportunity to present any mitigating factors that may be relevant to the violations. In addition, as provided in IC 13-30-3-3, you may enter into an Agreed Order without admitting that the violation occurred.

    To discuss this matter further, please contact Lori Colpaert at 317/232-7202 within

fifteen (15) days after receipt of this Notice to request a conference. If settlement is reached, an Agreed Order will be prepared and sent to you for review and signature.

                            FOR THE COMMISSIONER:

                            Signed 5/7/99

Date:_______________                _________________________
                            Felicia Robinson George
                            Assistant Commissioner
                            Office of Enforcement

cc:    Lake County Health Department
    IDEM Facility File, ID# 12819
    http://www.ai.org/idem/

Converted by Andrew Scriven