ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRANO AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 · (217) 782·3397
JB PRITZKER, GOVERNOR
JOHN J. KIM, DIRECTOR

21 7/785-0561
January 9, 2023
CERTIFIED MAIL #7021 2720 0000 2345 0304
RETURN RECEIPT REQUESTED
Stateville Correctional Center
c/o Randy Pfister
16300 Route 53
Crest Hill, IL 60403

Re:

Violation Notice: ST ATEVILLE CORRECTIONAL CENTER
Facility No.: IL1977910
Violation Notice No.: W-2022-00073

Dear Mr. Pfister:
This constitutes a Violation Notice pursuant to Section 3 I(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 lllinois
EPA, must be submitted via 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 3 l(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, ll61820 (217) 278-5800
1101 Eastport Plaza Or., Suite 100, Collinsville, IL 62234 (618) 346-5120
9Sl 1 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 D, Peoria, ll 61602 (309) 671-3022
4302 N. Main Street, Rockford, ll 61103 (815) 987-7760

PLEASE PRINT ON RECYCLED PAPER

Page 2 of 2
IL1977910 STATEVILLE CORRECTIONAL CENTER
YN W-2022-00073
The Illinois EPA will review the proposed tenns 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 J. Nutt, CAS #19
P.O. BOX 19276
Springfield, IL 62794-9276

All communications must include reference to this Violation Notice number, W-2022-00073.
Questions regarding this Violation Notice should be directed to Adam J. Nutt at 217/785-0561.
Sincerely,

?~

2:lZ

Manager, Compliance Assurance Section
Division of Public Water Supplies
Bureau of Water
Attachments

cc: Jenniagh Daly
Frank Dunmire
BOW ID: Wl978!00003

PAGE NO. l OF 5

ATTACHMENT A
STATEVILLE CORRECTIONAL CENTER, IL1977910 VIOLATION NOTICE NO. W-202200073:
Questions regarding the violations identified in this attachment sho uld be
referred to Adam J. 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.

Drinking Water Cross-Connection .Control Program
Al 1 public water supplies must have an active cross-connection control
program. It is not possible for the Agency to evaluate whether a water
system's cross-connection control program is comprehensive without the
ability to evaluate an ordinance or service agreement. Compliance is expected
to be achieved by submitting your water supply's cross-connection control
ordinance or water use agreement within 90 days to the Illinois EPA.
Additionally, provide an implementation schedule including when your water
system will conduct its cross-connection survey of the distribution system;
how your water system will evaluate high risk service connections; and how
your water system will track cross connection control devices and their
annual inspection.
Violation
Date
11/28/2022

Rule/Reg.

Violation
Description
Failure to have a comprehensive cross-connection control
program. (on-going violation)
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101 and 604.1505.

Drinking Water Cross-Connection Program Device Inventory
A community water supply must maintain records of all backflow preventers
that require annual testing.
To achieve compliance, an inventory of all
backflow prevention devices in the system must be created, and documentation
submitted to the Illinois EPA within 90 days.
Violation
Date
11/28/2022

Rule/Reg.

Violation
Description
Failure to maintain records of all backflow preventers that
require annual testing.
Section 18 of the Act 415 ILCS 5/18, 35 Ill. Adm. Code 601.101
and 604 . 1505 (b) (5).

PAGE NO. 2 OF 5
ATTACHMENT A
STATEVILLE CORRECTIONAL CENTER, IL1977910 VIOLATION NOTICE NO . W-202200073:
Drinking Water Cross-Connection Device Testing
A community water supply must assure all backflow preventers are tested at
least annually. To achieve compliance, each backflow prevention dev i ce must
be tested, and documentation submitted to the Illinois EPA within 90 days.
Violation
Date
11/28/2022

Rule/Reg.

Violation
Description
Failure to perform annual testing of all backflow prevention
devices in the system.
(on-going violation)
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101 and 604.1510(a).

Emergency Operation Plan
Each community water supply must develop an Emergency Operations Plan for
the provision of water under emergency circumstances, including earthquakes,
floods, tornados, and other disasters.
The Emergency Operations Plan must
include a review of the methods and means by which alternative supplies of
drinking water could be provided in the event of destruction, impairment, or
contamination of a community water supply. Compliance with this is expected
to be achieved within 90 days by developing and maintaining an Emergency
Operations Plan for the public water supply. This Emergency Operations Plan
must be maintained on-site and available to the Agency, upon request, and
must be reviewed every three years.
Violation
Date
11/28/2022

Rule/Reg.

Violation
Description
Failure to have an emergency operations plan.
violation)
Section 18 of the Act 415 ILCS 5/18, and 35 Ill.
601.101 and 604.135.

(on-going
Adm.

Code

Customer Notification and Issuance of Boil Orders
All public water supplies must notify customers and issue boil orde rs when
the sanitary integrity of the water supply has been threatened by low wa t er
pressure, distribution chlorine levels below minimum r equ iremen t s, or
bacterial contamination.
Failing to act aggressively i n this r egard can
pose a health risk to the water supply consumers .
Addi t io n a lly, any
emergency condition, where the safety of the supply is endangered for any
reason, must be reported to the Illinois EPA as soon as possible. Compliance
with this is expected immediately by notification of customers and i ssuanc e
of boil orders when necessary. During the inspection, facil i ty sta f f stated
that boil orders have not been issued during peri?d of low c hlo ri ne r e sidual.

PAGE NO. 3 OF 5
ATTACHMENT A
STATEVILLE CORRECTIONAL CENTER, IL1977910 VIOLATION NOTICE NO. W-202200073:

Violation
Date
11/28/2022
Rule/Reg.

Violation
Descr1.ption
Failure to issue boil orders.
Section 18 of the Act, 415 ILCS 5/18,
601.101 and 604.135(c) (1).

and 35 Ill. Adm. Code

Minimum chlorine levels in the distribution s y stem
Each community water supply must maintain a minimum free chlorine residual
of 0.5 milligrams per Liter (mg/L) or a minimum combined ch~orine residual
of 1. 0 mg/L in all portions of the distribution system.
Compliance with
this is expected to be achieved immediately by verifying minimum chlorine
levels are being achieved.
Violation
Date
11/28/2022

Rule/Reg.

Violation
Description
Failure to maintain a minimum free chlorine residual of O. 5
milligrams per Liter (mg/L) or a minimum combined chlorine
residual of 1.0 mg/Lin all portions of the distribution (ongoing violation)
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101 and 604. 725 (a).

Water Storag e Tank water turnover
Each community water supply must assure water storage tanks are designed to
facilitate turnover of water to avoid stagnation.
Compliance with this is
expected to be achieved within 90 days by verifying a time frame for the
installation of a mixing device i n the elevated storage tank.
Violation
Violation
Date
Description
11/28/2022
Failure to provide a mixing device in the elevated storage tank.
Rule/Reg.
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101 and 604 .1300 (f).

Water Storage Tank Maintenance
There are structure/maintenance problems which threaten the quality of the
drinking water provided. Compliance with this is expected to be achieved
within 90 days .

PAGE NO. 4 OF 5
ATTACHMENT A
STATEVILLE CORRECTIONAL CENTER, IL1977910 VIOLATION NOTICE NO. W-202200073:

Violation
Date
11/28/2022

Violation
Description
Delayed and deferred maintenance on critical components of the
water storage tank interior, piping, check valve, and overflow
have deteriorated beyond maintenance level and now require
immediate repair.
Rule/Reg.
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101, 604.105, and 604.1330(a).

Water Storage Tank Grading and standing water
Inadequate grading has resulted in ponding of surface water standing within
50 feet of the tank, which threatens the quality of the drinking water
provided.
To achieve compliance, the area must be properly graded, and
documentation submitted to the Illinois EPA within 90 days.
Violation
Date
11/28/2022

Violation
Description
Failure to adequately grade the area around the elevated storage
tank resulting in standing surface water within 50 feet of the
tank.
Rule/Reg.
Section 18 of the Act, 415 ILCS 5/18, and 35 Ill. Adm. Code
601.101 and 604 .1300 (i) .

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
11/28/2022

Violation
Description
Failure to obtain a construction permit for the installation of
multiple water softeners used to treat water that may be used
for consumption.
Rule/Reg.
Sections 15 (a) and 18 (a) (3) of the Act, 415 ILCS 5/ 1 5 and 5/18,
and 35 Ill. Adm. Code 602.l0l(a) and (b) and 602.200(a)and (bl.

Drinking Water Operating Permit
Public Water Supplies (PWSs) are required to obtain operating permits f rom
Illinois EPA prior to using or operating any new community water supply o r

PAGE NO. 5 OF 5
ATTACHMENT A
STATEVILLE CORRECTIONAL CENTER, IL1977910 VIOLATION NOTICE NO. W-2O2200073:

new addition to an existing community water supp l y for which a construction
permit is required. Before using a new community water supply or new addition
to an existing community water supply, the public water supply must make a
written request for an operating permit on forms prescribed by the Agency
and must submit any information required by the Agency, including the
submission of water sample results pursuant to 35 Ill. Adm. Code 602.310.
To meet compliance the -s upply is expected to submit as-built plans and
specifications pursuant to 35 Ill. Adm. Code 602.116.
Violation
Date
11/28/2022

Violation
Description
Failure to obtain a construction permit for the installation of
multiple water softeners used to treat water. This water may be
used for consumption.
Rule/Reg.
Sections lS(a) and 18(a) (3) of the Act, 415 ILCS 5/15 and 5/18,
and 35 Ill. Adm. Code 602.l0l(a) and (b) and 602.200(a)and (b).