EPA v. Wildlife Mobile Home Park, IL0995425, Ra MCL

Case summary

The December 22, 2012 2011 second Amended AO requires system to comply with the Combined Radium MCL of 5 pCi/L as soon as possible and no later than July 31, 2012; submit to U.S. EPA and Illinois EPA a letter stating Respondent’s intention to comply within 10 days from receipt of this Order; submit to U.S. EPA and Illinois EPA a detailed plan (Plan) for bringing the System into compliance with the Combined Radium MCL, including milestones with dates for planning engineering/design, obtaining funding, Illinois EPA construction permit, commence construction/equipment installation, complete construction/equipment installation, and Illinois EPA operating permit. The AO also requires system to submit to U.S. EPA and Illinois EPA in writing, a progress report on the status of achieving each identified milestone by January, 31, 2012, March 31, 2012 and by the end of each subsequent calendar quarter, and to continue to sample quarterly for combined radium and provide public notice each quarter as long as the violations persists. Wildlife met the requirements of the December 2011 Order by notifying U.S. EPA and Illinois EPA of its intention to comply with the terms of the December 2011 Order by submitting a construction permit application to Illinois EPA on December 30, 2011, and sending U.S. EPA a copy with specifications, construction drawings, and engineer's design summary on the same day. The permit application contained a detailed plan for bringing Wildlife into compliance with the Combined Radium MCL, but it did not include milestones with dates for implementing the plan. Wildlife’s engineering firm’s letter to U.S. EPA and Illinois EPA, dated January 27, 2012, provided milestones and dates for implementing the plan. Wildlife also provided the following addition information and clarification requested by U.S. EPA prior to commencing construction/equipment installation: (1) a modified lease agreement with each homeowner to allow access for installation, servicing, salt delivery and sampling; (2) a letter from the Wildlife’s owner indicating he will perform any work not performed by the water softener installation and servicing company; and (3) a modification to the water softener installation and servicing company contracts to clarify sample collection for homeowners with un-softened outside hose bibs, establish firm installation costs based on the home inspections already performed, and set a fixed lease period. Wildlife completed installation of all nine softener units by July 31, 2012, and applied for and obtained an Illinois EPA operating permit for ion exchange point of entry radium remediation at residences on August 10, 2012. Illinois EPA also issued the owner a supplemental construction permit on July 7, 2012, allowing the installation of POE softeners at currently unoccupied lots. Illinois EPA returned Wildlife to compliance with the Combined Radium MCL on August 15, 2012. Our records show that Wildlife submitted a quarterly written progress report on the status of achieving each identified milestone as required in the December 2011 Order. Our records also show that Wildlife continued to monitor quarterly for Combined Radium, provided quarterly public notice as long as the violation persisted, and submitted all monitoring results and copies of public notices and public notice certification statements to U.S. EPA and Illinois EPA. Finally, our records show that Wildlife has not exceeded the Combined Radium MCL since the third calendar quarter of 2012.

Defendants (1)

• Earl E. CazelNamed in settlement

Facilities (1)

• WILDLIFE MOBILE HOME PARK

  EAST SOUTH STREET, SENECA, IL, 61360

  Registry ID: 110028135630

Statutes cited

• SDWA 1414C — PWS - Notice to Persons Served
• SDWA 1412/1414 — National Drinking Water Regulations

Enforcement conclusions (1)

• Wildlife Mobile Home Park, IL0995425, Ra MCLentered 2011-12-22

  Primary law: SDWA

Timeline (3 milestones)

• 2011-12-22Final Order Issued
• 2012-01-17Enforcement Action Data Entered
• 2013-07-30Enforcement Action Closed