VIA CERTIFIED MAIL# ____________________
To: Mr. Herbert Simon, President CT Corporation, Resident Agent
Simon DeBartolo Group Simon DeBartolo Group
PO Box 7033 1 North Capitol Ave.
Indianapolis, Indiana 46207 Indianapolis, Indiana 46204
These violations are based on the fact that during inspection of the Site by IDEM, it was
observed that asbestos containing floor and ceiling tile were not removed prior to renovation
activities which disturbed RACM, a violation of 326 IAC 14-10-4(1). This material was
removed by an unaccredited contractor, a violation of 326 IAC 18-3-3(a)(4).
Rule 329 IAC 10-8-4(b)(1) states that: "The generator or hauler shall provide the facility
with sufficient notice in advance of the disposal such that the facility may prepare to accept the
waste." This violation is based on the fact that the Oak Ridge Landfill was not notified that the
roll off picked up from 305 West Sagamore on October 17, 1998, by Waste Management of
Lafayette and disposed of at the Oak Ridge Landfill contained asbestos-containing material.
Rule 329 IAC 10-8-4(b)(2) states that: "All asbestos-containing waste must be handled in
accordance with the wetting, packaging, and labeling provisions of 40 CFR 61.145(c) and 40
CFR 61.150(a)." This violation is based on the fact that on October 17, 1998, asbestos-
containing material from 305 West Sagamore was stacked in a roll off and not handled in
accordance with the wetting, packaging, and labeling provisions of the rule.
Rule 329 IAC 10-8-4(b)(3) states that: "Each load of asbestos-containing waste must be
accompanied by a waste shipment record in accordance with 40 CFR 61.150(d) that must specify
at least the following information:
(A) Generator's name, complete mailing address, and telephone number.
(B) Removal contractor's name, complete mailing address, and telephone number.
(C) Removal project location.
(D) Source of asbestos.
(E) Volume or weight of waste for disposal.
(F) Original signature of generator or cleanup contractor attesting that the information
required in this subdivision is true and accurate."
This violation is based on the fact that the asbestos-containing roll off that was picked up by
Waste Management of Lafayette on October 17, 1998, from 305 West Sagamore was disposed of
at the Oak Ridge Landfill in Logansport without an asbestos waste shipment record.
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 13-30-4-1, the Commissioner may assess penalties of up to $25,000 per day of any
violation.
The timely entry into an Agreed Order will prevent the necessity of an Order of the
Commissioner being issued under IC 13-30-3-4, or the filing of a civil court action under IC 13-
14-10 or IC 13-14-2-6. Advantages of entering into an Agreed Order are:
1. You may not be required to admit that any violation occurred.
2. The civil penalty may be less than that imposed under an Order of the
Commissioner.
To discuss this matter further, please contact Lynne Donahue at 317/233-5521 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:
Date: Signed 2/23/98 _________________________
David J. Hensel
Director
Office of Enforcement
cc: Janice Loughlin, US EPA Region 5
Art Massing, Simon DeBartolo Group
Jim Smith, Vision Construction Co., Inc.
Tippecanoe County Health Department
OAM Public File
File 2D1
http://www.ai.org/idem/
Converted by Andrew Scriven