ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
2009 MALL STREET, COLLINSVILLE, ILLINOIS 62234
THOMAS V. SKINNER, DIRECTOR
618/346-5120
FAX: 618/346-5155
October 18, 2001
Prior Oil Company
Attn: John Prior
140 Gompers Street
Wamac, Illinois 62801
Re:
1894925001
—
Washington County
Wamac/Prior Oil Company
Compliance File
Dear Mr. Prior:
On August 30, 2001, your facility was inspected by Chris Cahnovsky and Connie Letsky ofthe
Illinois Environmental Protection Agency. The purpose ofthis inspection was to determine your
facility’s compliance with the Illinois Environmental Protection Act and
35
Illinois
Administrative Code. At the time ofthe inspection, apparent violations found in previous
inspections conducted on August 22, 2000, November 3, 2000 and December
5,
2000 were again
observed.
For your information, a copy ofthis inspection report is enclosed. Please contact Chris
Cahnovsky at 618/346-5120 if you have any questions regarding this inspection.
Sincerely,
Chris N. Cahnovsky, Regional Manager
Field Operations Section
Bureau ofLand
CNC:jlb/priorcontvioltrl01801 cnc
Enclosure
be:
BOL
-
Division File
BOL
-
Collinsville
Todd Rettig
-
DLC
PEOPLE’S
EXHIBIT
8
PRINTED ON RECYCLED PAPER
LPC#: 1894925001 --WASHINGTON COUNTY
Inspection
Date: 08/30/2001
9.
55(a)
NO PERSON SHALL:
(1)
Cause or Allow Open Dumping of Any Used or Waste Tire
(2)
Cause or Allow Open Burning of Any Used or Waste Tire
35 ILUNOIS.ADMJNISTRATIVE CODE REQUIREMENTS
SUBTJTLE G
10.
81 2.101(a)
.
FAILURE TO SUBMIT AN APPLICATION FOR A PERMIT TO DEVELOP AND
OPERATE A LANDFILL
11.
722.111
HAZARDOUS WASTE DETERMINATION
12.
808.121
SPECIAL WASTE DETERMINATION
13.
809.302(a)
ACCEPTANCE OF SPECIAL WASTE FROM A WASTE TRANSPORTER
WITHOUT A WASTE HAULING PERMIT, UNIFORM WASTE PROGRAM
REGISTRATION AND PERMIT AND/OR MANIFEST
OTHER. REQUIREMENTS
14.
.
APPARENT VIOLATION OF: ( ) PCB; ( ) CIRCUIT COURT
CASE NUMBER:
ORDER ENTERED ON:
15.
Informational Notes
1.
Illinois Environmental Protection Act: 415 ILCS 5/4.
2.
Illinois Pollution Control Board: 35 III. Adm. Code, Subtitle G.
3. Statutory and regulatory references herein are provided for convenience only and should not be construed as legal
conclusions of the Agency or as limiting the Agency’s statutory or regulatory powers. Requirements of some statutes
and regulations cited are in summary format. Full text of requirements can be found in references listed in 1. and 2.
above.
4. The provisions of subsection (p) of Section 21 of the Illinois Environmental Protection Act shall be enforceable either
by administrative citation under Section 31.1 of the Act or by complaint under Section 31 of the Act.
5. This inspection was conducted in accordance with Sections 4(c) and 4(d) of the Illinois Environmental Protection Act:
415 ILCS 5/4(c) and (d).
6.
Items marked with an “NE” were not evaluated at the time of this inspection.
7. Statutory effective date: through 7/9/99.
8. Regulatory effective date: through 5/20/99.
(Open Dump - 2)
Signature of Inspector(s)
8/O&~9
1894925001
--
Washington County
Prior Oil Company
Date of Inspection: August 30, 2001
Prepared by: Chris Cahnovsky
NARRATIVE
On August 30, 2001, Connie Letsky and I conducted a follow-up inspection at Prior Oil
Company in Wamac, illinois. No one was present during this inspection. The weather
was hot, the temperature was about 85 degrees and soil conditions were dry. We arrived
at the site about 11:00 a.m.
A fence has been put up limiting access to the site from Mitchell Lane. We entered the
site from the adjacent property. I observed that the pile of crude oil contaminated soil
removed from a dump pit was still on-site. This soil is from the remediation of a pit that
contained crude oil behind Prior Oil Company’s shed. This soil was removed and placed
in a roll-off box. The soil was then again dumped on the ground. A Violation Notice
was sent to Mr. John Prior for the dumping of crude oil in the pit. Prior Oil Company
submitted a Compliance Commitment Agreement on December 12, 2000. The CCA
stated that the soil would be disposed of at a landfill. To date the soil has not been
disposed of at a permitted landfill. The Illinois EPA rejected the CCA on December 26,
2000 because the violations remain the subject ofdisagreement between the illinois EPA
and Prior Oil Company. The Illinois EPA sent a Notice ofIntent to Pursue Legal Action
letter to Mr. Prior on May 22, 2001. Mr. Prior did not respond to this letter.
The illinois EPA responded to a citizen complaint at Prior Oil Company on December
5,
2000. The complainant alleged that oil field waste was being dumped in a hole behind
the old incinerator behind Prior’s shop. The illinois EPA discovered that about three
barrels, 126 gallons, of crude oil had been dumped in the vegetation behind the old
incinerator. An Administrative Citation was issued for this dump on December 29, 2000.
Mr. Prior has not responded to the Administrative Citation.
I reinspected this area during the August 20, 2001 inspection. The area appeared
undisturbed. It did not appear that any soil excavation had taken place. I did not observe
any black oil staining. It is possible that over time the crude oil had washed offthe
vegetation and into the soil.
I observed that a new pit had been dug behind the shop. No waste was observed in this
pit. Access to the pit was blocked by a rack of steel pipes. It appears that this site has
remained unchanged since the December 5, 2000.
STATE OF ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
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LPC
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LPC # 1894925001
—
Washington County
Prior Oil Company
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
August 30, 2001
TIME:
11:00—11:20
DIRECTION:
North
PHOTO by:
Chris Cahnovsky
PHOTO FILE
NAME:
1894925001-08082001-001
DATE: August 30, 2001
TIME: 11:00—11:20
DIRECTION:
West
PHOTO by:
Chris Cahnovsky
PHOTO FILE
NAME:
1894925001-08082001-002
LPC # 1894925001
—
Washington County
Prior Oil Company
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
August 30, 2001
TIME:
11:00— 11:20
DIRECTION:
North
PHOTO by:
Chris Cahnovsky
PHOTO FILE
NAME:
1894925001-08082001-003
DATE:
August 30, 2001
TIME:
11:00—11:20
DIRECTION:
Northeast
PHOTO by:
Chris Cahnovsky
PHOTO FILE NAME:
1894925001-08082001-004
LPC # 1894925001
—
Washington County
Prior Oil Company
FOS File
DIGITAL PHOTOGRAPH PHOTOCOPIES
DATE:
August 30, 2001
TIME:
11:00— 11:20
DIRECTION:
East
PHOTO by:
Chris Cahnovsky
PHOTO FILE NAME:
1894925001-08082001-005