STATE OF INDIANA            )                                   BEFORE THE INDIANA DEPARTMENT

)                       SS:       OF ENVIRONMENTAL MANAGEMENT

COUNTY OF MARION        )

 

 

COMMISSIONER OF THE DEPARTMENT            )

OF ENVIRONMENTAL MANAGEMENT,              )

)

Complainant,                            )

)           CASE NO.2000-10093-S

v.                                             )

)

ST. JOSEPH COUNTY PARKS DEPT.                     )

)

Respondent.                             )

 

 

                                                              AGREED ORDER

 

 

The Complainant and the Respondent desire to settle and compromise this action without hearing or adjudication of any issue of fact or law, and consent to the entry of the following Findings of Fact and Order.  Pursuant to IC 13-30-3-3, entry into the terms of this Agreed Order does not constitute an admission of any violation contained herein.  Respondent's entry into this Agreed Order shall not constitute a waiver of any defense, legal or equitable, which Respondent may have in any future administrative or judicial proceeding, except a proceeding to enforce this order.

 

 

                                                         I.  FINDINGS OF FACT

 

1.         Complainant is the Commissioner (hereinafter referred to as "Complainant") of the Indiana Department of Environmental Management, a department of the State of Indiana created by IC 13-13-1-1.

 

2.         Respondent is St. Joseph County Parks Department (hereinafter referred to as "Respondent"), who owns two (2) UST systems, located at 57057 Laurel Rd., South Bend, St. Joseph County, Indiana (hereinafter referred to as "the Site").

 

3.         The Indiana Department of Environmental Management ("IDEM") has jurisdiction over the parties and subject matter of this action.

 

4.         Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation via Certified Mail to:

 

St. Joseph County Parks Department

Attn: John Berkebile, Director

57057 Laurel Rd.

South Bend, IN 46637

 

5.         Designated representatives of IDEM conducted an inspection at the Site on November 20, 2000.

 

6.         Based on information gathered by IDEM during the above noted inspection, the Respondent has been found in violation of:

 

A.        Pursuant to 329 IAC 9-2.1-1(a)(3), 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 329 IAC 9-2-1.  (2) The upgrading requirements under subsections (b) through (d).  (3) Closure requirements under 329 IAC 9-6-1 through 329 IAC 9-6-5, including applicable requirements for corrective action under 329 IAC 9-5-1 through 329 IAC 9-5-8.  This violation is based on the fact that the UST systems at the Site do not meet the new UST system performance standards, have not been upgraded, and have not been properly closed.           

 

B.         Pursuant to 329 IAC 9-2-2(a), any owner who brings a UST system into use shall, within thirty (30) days of bringing such tank into use, submit notice to the agency to register the tank system using a form provided by the agency for this notification.  This violation is based on the fact that the UST systems at the Site were not registered with IDEM.

 

7.         On October 20, 2000, IDEM received a notice from the Respondent indicating intent to close the UST systems and on November 28, 2000, the UST systems were removed from the ground and permanently closed.  The closure report was received by IDEM on January 11, 2001, and approved on February 1, 2001.

 

8.             In recognition of the settlement reached, Respondent waives any right to administrative and judicial review of this Agreed Order.               

 

II.  ORDER

 

1.         This Agreed Order shall be effective ("Effective Date") when it is approved by the Complainant or her delegate, and has been received by the Respondent.  This Agreed Order shall have no force or effect until the Effective Date.

 

2.         Respondent is assessed a civil penalty of ten thousand dollars ($10,000.00).  Within thirty (30) days of the Effective Date of the Agreed Order, Respondent shall pay a portion of this penalty in the amount of one thousand dollars ($1,000.00).  Said penalty amount shall be due and payable to the Underground Petroleum Storage Tank Trust Fund.  In lieu of payment of the remaining civil penalty, Respondent shall perform and complete a Supplemental Environmental Project (“SEP”).  Respondent estimates that this SEP will cost thirty-seven thousand dollars ($37,000.00).  Within thirty (30) days of completing this SEP, Respondent shall submit written notice and documentation to IDEM which substantiates all actions taken and costs incurred with respect to the SEP.  In the event that the cost of the SEP is less than eighteen thousand dollars ($18,000.00), Respondent shall pay fifty percent (50%) of the difference between the required minimum $18,000.00 cost of the SEP and the actual cost of the SEP.

 

As a SEP, Respondent shall perform a ground water analysis project as described in Attachment A.  Respondent shall complete the SEP and submit a copy of a report detailing the findings of the SEP within one hundred and twenty days (120) of the Effective Date of this Agreed Order.   Implementation of this SEP will assist in determining the cause(s) of potentially impacted ground water and aid in the development of potential corrective action(s) to address the issue(s).

 

In the event that the Respondent does not complete the SEP within 120 days of the Effective Date of this Agreed Order, the full amount of the civil penalty as stated above, plus interest established by IC 24-4.6-1-101 on the remaining amount, less the portion of the civil penalty Respondent has already paid, will be due within fifteen (15) days from Respondent's receipt of IDEM’s notice to pay.  Interest, at the rate established by IC 24-4.6-1-101, shall be calculated on the amount due from the date which is thirty (30) days after the Effective Date of this Agreed Order until the full civil penalty is paid.  

 

3.         All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:

 

                                    Paul Higginbotham,  Section Chief

Office of Enforcement

Indiana Department of Environmental Management

100 N. Senate Avenue

P. O. Box 6015

Indianapolis, IN 46206-6015

 

4.         The civil penalty is payable by check to the Underground Petroleum Storage Tank Trust Fund.  Checks shall include the Case Number of this action and shall be mailed to:

 

Cashier

Indiana Department of Environmental Management

100 N. Senate Avenue

P. O. Box 7060

Indianapolis, IN 46207-7060

 

5.         In the event that the civil penalty required by Order Condition 2 is not paid within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall pay interest on the unpaid balance at the rate established by IC 24-4.6-1-101.  The interest shall continue to accrue until the civil penalty is paid in full.

 

6.         This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, and assigns.  The Respondent's signatories to this Agreed Order certify that they are fully authorized to execute this document and legally bind the parties they represent.  No change in ownership, corporate, or partnership status of the Respondent shall in any way alter its status or responsibilities under this Agreed Order.

 

7.         In the event that any terms of this Agreed Order are found to be invalid, the remaining terms shall remain in full force and effect and shall be construed and enforced as if the Agreed Order did not contain the invalid terms.

 

8.         The Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred.  Respondent shall ensure that all contractors, firms and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

 

9.         This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order.


 

 

TECHNICAL RECOMMENDATION:                       RESPONDENT:

Department of Environmental Management                    St. Joseph County Parks Dept.

 

 

By:___________________________                         By:____________________________

     Paul Higginbotham, Chief

     Solid Waste/UST Section                                        Printed:________________________

     Office of Enforcement

Title:__________________________

 

Date:_________________________                          Date:__________________________

 

 

 

COUNSEL FOR COMPLAINANT:                           COUNSEL FOR RESPONDENT:

Department of Environmental Management

 

 

By:___________________________                         By:____________________________

     Office of Legal Counsel

     Department of Environmental Management

 

Date:__________________________                        Date:___________________________

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS __________ DAY OF __________________, 2004.

 

 

For the Commissioner:

 

 

 

 

signed 8/27/04

Felicia A. Robinson

Deputy Commissioner

Legal Affairs