STATE OF INDIANA

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BEFORE THE INDIANA DEPARTMENT

 

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SS:

OF ENVIRONMENTAL MANAGEMENT

COUNTY OF MARION

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COMMISSIONER OF THE DEPARTMENT

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OF ENVIRONMENTAL MANAGEMENT,

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Complainant,

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v.

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CASE NO. 2003-12643-W

 

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TOWN OF KIRKLIN,

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Respondent.

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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 the Respondent may have in any future administrative or judicial proceeding, except a proceeding to enforce this order.

 

 

I.  FINDINGS OF FACT

 

1.                  The Complainant is the Commissioner (Complainant) of the Indiana Department of Environmental Management, a department of the State of Indiana created by Indiana Code (IC) 13-13-1-1.

 

2.                  The Respondent is the Town of Kirklin (Respondent), which owns and operates a publicly owned treatment works (POTW) comprised of a 100% separate sanitary sewer collection system and a municipal wastewater treatment plant (WWTP), located at 800 North Main Street, on U.S. Highway 421, in Kirklin, Clinton County, Indiana (Site).

The Respondent is authorized by National Pollutant Discharge Elimination System (NPDES) Permit No. IN0020630 (the Permit) to discharge treated municipal and/or domestic wastewater from its municipal WWTP via Outfall 001 into waters of the State consisting of an unnamed tributary of McClamrock Ditch, thence to McClamrock Ditch, and thence to Sugar Creek, within the Wabash River watershed (the Receiving Waters), in accordance with effluent limitations, monitoring requirements, and other conditions set forth therein.

 

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 (NOV) on December 29, 2004, via Certified Mail to Walter Minnick, President, Kirklin Town Council.

 

5.                  Inspections and record reviews were conducted at the site on the dates specified below by a representative of IDEM’s Office of Water Quality (OWQ).  The violations described in the following paragraphs were in existence or observed at the time of these inspections and record reviews, and were cited in the NOV.

 

6.                  Pursuant to 327 Indiana Administrative Code (IAC) 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Part I.A.1 of the Permit contains numeric effluent limitations and monitoring requirements applicable to the discharge from the WWTP via Outfall 001.

The Respondent failed to meet the numeric effluent limitations contained in the Permit, as reported by the Respondent on Discharge Monitoring Reports (DMRs) submitted from November 2001 through May 2004 and specified below, in violation of 327 IAC 5-2-8(1) and Parts I.A.1 and II.A.1 of the Permit:

i.                    The maximum monthly and weekly average loading limitations for ammonia-nitrogen (NH3-N) for the months of October 2002 and April 2004.

ii.                  The maximum monthly and weekly average concentration limitations for NH3-N for the month of October 2002.

iii.                The daily maximum concentration limitation for E. Coli for the month of August 2002.

 

7.                  Pursuant to 327 IAC 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Pursuant to 327 IAC
5-2-8(9), the permittee is required to comply with the monitoring, recording, and reporting requirements established in accordance with sections 13 through 15 of 327 IAC 5-2.

Pursuant to 327 IAC
5-2-13(a), all permittees shall monitor parameters and conditions specified by the permit, including but not limited to, the following:

i.                    The mass, concentration, or other measurement specified in section 11, 11.1, and 11.6 of 327 IAC 5-2 for each pollutant specified in the permit.

ii.                  The volume of wastewater flow at monitoring points specified in the permit, including the final effluent flow from each point source.

iii.                Other parameters as specifically required in the permit.

 

Pursuant to 327 IAC 5-2-13(b), a POTW shall monitor the mass concentration, or other units of specified pollutants in the raw influent, in the discharge from intermediate unit treatment processes as specified in the permit or the applicable report of operation (also referred to as the monthly report of operation or MRO) form, and in the final effluent, as well as the volume of effluent flow.

Part I.A.1 of the Permit contains numeric effluent limitations and monitoring requirements applicable to the discharge from the WWTP via Outfall 001.

Pursuant to Part I.B.2 of the Permit, the raw influent and the wastewater from intermediate unit treatment processes, as well as the final effluent, shall be sampled and analyzed for the pollutants and operational parameters specified by the applicable
MRO form.

Pursuant to 327 IAC
5-2-14(a) and Part I.B.6 of the Permit, any permittee required to monitor under 327 IAC 5-2-13 shall maintain records of all monitoring information and monitoring activities, including:

i.                    The date, exact place, and time of sampling or measurements;

ii.                  The person(s) who performed the sampling or measurements;

iii.                The date(s) analyses were performed;

iv.                 The person(s) who performed the analyses;

v.                   The analytical techniques or methods used; and

vi.                 The results of such measurements and analyses.

 

Pursuant to 327 IAC 5-2-14(b), all records of monitoring activities and results (including all original strip chart recordings for continuous monitoring instrumentation and calibration and maintenance records) shall be retained by the permittee for at least three years.

Pursuant to Part I.B.8 of the Permit, all records and information resulting from the monitoring activities required by the Permit, including all records of analyses performed and calibration and maintenance of instrumentation and recording from continuous monitoring instrumentation, shall be retained for a minimum of three years.  In cases where the original records are kept at another location, a copy of all such records shall be kept at the permitted facility.

The Respondent failed to monitor the pollutants and operational parameters required by the Permit and/or record and maintain on site the required data pertaining to that monitoring, as documented on IDEM inspection reports and specified below, in violation of one or more of 327 IAC 5-2-8(1), 327 IAC 5-2-8(9), 327 IAC 5-2-13(a), 327 IAC 5-2-13(b), 327 IAC 5-2-14(a), 327 IAC 5-2-14(b), and Parts I.B.2., I.B.6, I.B.8, and II.A.1 of the Permit:

i.                    No data was available for the percent of settling or dissolved oxygen (DO) levels, as documented on the October 10, 2002, inspection report.

ii.                  Data for the mixed liquor DO in the aeration tank and 30-minute settleability tests were not being properly recorded, as documented on the December 12, 2002, inspection report.

 

8.                  Pursuant 327 IAC 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Pursuant to 327 IAC
5-2-8(9), the permittee is required to comply with the monitoring, recording, and reporting requirements established in accordance with sections 13 through 15 of 327 IAC 5-2.

Part I.A.1 of the Permit contains numeric effluent limitations and monitoring requirements applicable to the discharge from the WWTP via Outfall 001.

Pursuant to Part I.B.2 of the Permit, the raw influent and the wastewater from intermediate unit treatment processes, as well as the final effluent, shall be sampled and analyzed fro the pollutants and operational parameters specified by the applicable
MRO form.

Pursuant to 327 IAC
5-2-14(a) and Part I.B.6 of the Permit, any permittee required to monitor under 327 IAC 5-2-13 shall maintain records of all monitoring information and monitoring activities, including:

i.                    The date, exact place, and time of sampling or measurements;

ii.                  The person(s) who performed the sampling or measurements;

iii.                The date(s) analyses were performed;

iv.                 The person(s) who performed the analyses;

v.                   The analytical techniques or methods used; and

vi.                 The results of such measurements and analyses.

 

Pursuant to 327 IAC 5-2-14(b), all records of monitoring activities and results (including all original strip chart recordings for continuous monitoring instrumentation and calibration and maintenance records) shall be retained by the permittee for at least three years.

Pursuant to Part I.B.8 of the Permit, all records and information resulting from the monitoring activities required by the Permit, including all records of analyses performed and calibration and maintenance of instrumentation and recording from continuous monitoring instrumentation, shall be retained for a minimum of three years.  In cases where the original records are kept at another location, a copy of all such records shall be kept at the permitted facility.

The Respondent failed to record and/or maintain on site all records and information resulting from the monitoring activities pertaining to required monitoring, as documented on IDEM inspection reports, in violation of one or more of 327 IAC 5-2-8(1), 327 IAC 5-2-8(9), 327 IAC 5-2-14(a), 327 IAC 5-2-14(b), and Parts I.B.2., I.B.6, I.B.8, and II.A.1 of the Permit.  Specifically, no lab data sheets were available to verify the source of the NH3-N data reported to the state on DMRs and MROs, as documented on the
December 12, 2002, inspection report.

 

9.                  Pursuant to 327 IAC 5-2-8(1) and Part II.A. 1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Pursuant to 327 IAC
5-2-8(9), the permittee is required to comply with the monitoring, recording, and reporting requirements established in accordance with sections 13 through 15 of 327 IAC 5-2.

Pursuant 327 IAC
5-2-13(a), all permittees shall monitor parameters and conditions specified by the permit, including but not limited to, the following:

i.                    The mass, concentration, or other measurement specified in section 11, 11.1, and 11.6 of 327 IAC 5-2 for each pollutant specified in the permit.

ii.                  The volume of wastewater flow at monitoring points specified in the permit, including the final effluent flow from each point source.

iii.                Other parameters as specifically required in the permit.

 

Pursuant to 327 IAC 5-2-13(b), a POTW shall monitor the mass concentration, or other units of specified pollutants in the raw influent, in the discharge from intermediate unit treatment processes as specified in the permit or the applicable report of operation (also referred to as the monthly report of operation or MRO) form, and in the final effluent, as well as the volume of effluent flow.

Part I.A.1 of the Permit contains numeric effluent limitations and monitoring requirements applicable to the discharge from the WWTP via Outfall 001.

Pursuant to Part I.B.2 of the Permit, the raw influent and the wastewater from intermediate unit treatment processes, as well as the final effluent, shall be sampled and analyzed for the pollutants and operational parameters specified by the applicable
MRO form.

Pursuant to 327 IAC
5-2-15(a), permittees shall report to the commissioner, using DMRs (EPA Form 3320-1), and also, in the case of POTWs and other specifically identified types of facilities, MROs.  These reports shall be submitted as often as required by the permit and shall include the results of any monitoring specified by the permit pursuant to 327 IAC 5-2-13.

Pursuant to Part I.B.3 of the Permit, the permittee shall submit to IDEM monitoring reports, including but not limited to DMRs and MROs, containing the results obtained during the previous month.

The Respondent failed to monitor the pollutants and operational parameters required by the Permit and/or to properly report the required data pertaining to that monitoring, as determined by a review of the DMRs and MROs submitted by the Respondent from November 2001 through May 2004 and specified below, in violation  of one or more of 327 IAC 5-2-8(1), 327 IAC 5-2-8(9), 327 IAC 5-2-13(a), 327 IAC 5-2-13(b), 327 IAC 5-2-158(a), and Parts I.A.1, I.B.2, I.B.3, and II.A.1 of the Permit:

i.                    The Respondent failed to monitor the following pollutants and operational parameters and/or report on both the DMR and the appropriate MRO the required data pertaining to that monitoring for November 2002:

a.                  Flow, in conduit or through the WWTP;

b.                  Total flow;

c.                  5-day carbonaceous biological oxygen demand (CBOD5);

d.                  NH3-N;

e.                  pH; and

f.                    Dissolved Oxygen

ii.                  The Respondent failed to report on the appropriate MRO the required monitoring data for January, February, March, April, May, June, July, August, September, and November 2002.

 

10.             Pursuant to 327 IAC 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Pursuant to 327 IAC
5-2-8(14), applications, reports or other information submitted to the commissioner shall be signed and certified as defined under 327 IAC 5-2-22.

Pursuant to 327 IAC
5-2-22(b) and Part II.C.6 of the Permit, all reports required by permits and other information requested by the commissioner shall be signed by a person described in 327 IAC 5-2-22(a), or by a duly authorized representative of that person.  A person is a duly recognized representative only if the authorization is made in writing to the commissioner by a person described in 327 IAC 5-2-22(a) and the authorization includes the name of the specific individual or specific position having responsibility for the overall operation of the regulated facility or activity.

Pursuant to 327 IAC 5-2-22(a) and Part II.C.6 of the Permit, all permit applications for municipalities, state agencies, federal agencies, or other public agencies or political subdivisions thereof shall be signed by either a principal executive officer or ranking elected official.

The Respondent failed to have either a principal executive officer or a ranking elected official, or a duly authorized representative of that person, sign the DMRs and MROs submitted for January, February, March, April, May, June, July, August, and September 2002, and May 2004, in violation of 327 IAC 5-2-8(1), 327 IAC 5-2-8(14), 327 IAC 5-2-22(b), and Parts II.A.1 and II.C.6 of the Permit.

 

11.             Pursuant to 327 IAC 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of the permit.

Pursuant to 327 IAC
5-2-8(8), the permittee shall at all times maintain in good working order and efficiently operate all facilities and systems (and related appurtenances) for collection and treatment that are:

i.                    Installed or used by the permittee; and

ii.                  Necessary for achieving compliance with the terms and conditions of the permit.

 

Pursuant to Part II.B.1 of the Permit, all waste collection, control, treatment, and disposal facilities shall be operated in a manner such that, among other requirements, at all times, all facilities are operated as efficiently as possible and in a manner which will minimize upsets and discharges of excessive pollutants.

The Respondent failed to maintain its WWTP in good working order and/or to operate its WWTP as efficiently as possible, evidenced as specified below, in violation of 327 IAC
5-2-8(1), 327 IAC 5-2-8(8), and Parts II.A.1 and II.B.1 of the Permit:

i.                    The NH3-N and E. coli effluent limitation violations specified in Item 3 above;

ii.                  IDEM’s documentation on its inspection report of sludge in the Receiving Waters on October 22, 2002; and

iii.                IDEM’s documentation on its inspection report of sludge in the Receiving Waters on December 12, 2002.

 

12.             Pursuant to 327 IAC 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

Pursuant to 327 IAC 2-1-6(a)(1) and Part I.A.2 of the Permit, all waters at all times and at all places, including the mixing zone, shall meet certain minimum conditions, including but not limited to , being free from substances, materials, floating debris, oil, or scum attributable to municipal, industrial, agricultural, and other land use practices, or other discharges:

i.                    That will settle to form putrescent or otherwise objectionable deposits;

ii.                  That are in amounts sufficient to be unsightly or deleterious; or

iii.                That produce color, visible oil sheen, odor, or other conditions in such degree as to create a nuisance.

 

The Respondent allowed sludge to enter the Receiving Waters that settled to form putrescent or otherwise objectionable deposits, that was in an amount sufficient to be unsightly or deleterious, and/or that produce color, visible oil sheen, odor, or other conditions in such degree as to create a nuisance,

i.                    IDEM’s documentation on its inspection report of sludge in the Receiving Waters on October 22, 2002; and

ii.                  IDEM’s documentation on its inspection report of sludge in the Receiving Waters on December 12, 2002.

 

13.             Pursuant to IC 13-18-4-5, it is unlawful for any person to throw, run, drain, or otherwise dispose into any of the streams or waters of Indiana; or cause, permit, or suffer to be thrown, run, drained, allowed to seep, or otherwise disposed into any waters; any organic or inorganic matter that causes or contributes to a polluted condition of any waters, as determined by a rule of the Water Pollution Control Board adopted under sections 1 and 3 of IC 13-18-4.

The Respondent’s violation of 327 IAC 2-1-6(a)(1) by allowing sludge to enter the Receiving Waters, as referenced in Item 12 above, caused or contributed to a polluted condition of the waters of Indiana.  Because the Respondent violated 327 IAC 2-1-6(a)(1), which is a rule adopted by the Water Pollution Control Board under IC 13-18-4-1 and/or IC 13-18-4-3, in a manner that caused or contributed to a polluted condition of the waters of Indiana, the Respondent also violated IC 13-18-4-5.

 

14.             Pursuant to IC 13-30-2-1(1), no person may discharge, emit, cause, allow, or threaten to discharge, emit, cause, or allow any contaminant or waste, including any noxious odor, either alone or in combination with contaminants from other sources, into the environment or into any publicly owned treatment works (POTW) in any form which causes or would cause pollution which violates rules, standards, or discharge or emission requirements adopted by the appropriate board under the environmental management laws.

The Respondent’s violations of 327 IAC 5-2-8(1) by failing to meet the numeric effluent limitations contained in the Permit, as referenced in Item 3 above, and of 327 IAC 5-2-8(1) and 327 IAC 2-1-6(a)(1) by allowing sludge to enter the Receiving Waters, as referenced in Item 12 above, caused or would have caused pollution.  Because the Respondent violated 327 IAC 5-2-8(1) and 327 IAC 2-1-6(a)(1), both rules adopted by the Water Pollution Control Board under the environmental management laws, in a manner that caused or would have caused pollution, the Respondent also violated IC 13-30-2-1.

 

15.             On October 22, 2002, IDEM’s inspector performed a routine inspection that included observations of effluent sampling and operating and maintenance (O&M) violations.

 

16.             On December 12, 2002, IDEM’s inspector performed an inspection following a WWTP upset.  The inspection included the IDEM inspector’s observations of site maintenance, effluent sampling, record reporting, and receiving water violations.

The inspector noted that sludge was observed within the receiving stream at the Respondent’s Site.

 

17.             On November 23, 2004, IDEM’s inspector and a representative of the Office of Enforcement performed an inspection and/or site evaluation of the Respondent’s POTW.  Observations include but are not limited to effluent sampling, operations and maintenance (O&M), records review, review of the certified operator in responsible charge, and renewal of the Respondent’s permit.

 

18.             On January 31, 2005, Respondent met with IDEM and presented a summary of compliance actions taken since the incidents referenced in the above Findings.

 

19.             In recognition of the settlement reached, the 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 his delegate, and has been received by the Respondent.  This Agreed Order shall have no force or effect until the Effective Date.

2.                  The Respondent shall comply with IC 13-30-2-1, IC 13-18-4-5, 327 IAC 2-1-6(a), 327 IAC 5-2-8(1), 327 IAC 5-2-8(8), 327 IAC 5-2-8(9), 327 IAC 5-2-8(14), 327 IAC 5-2-13, 327 IAC 5-2-14, 327 IAC 5-2-15, 327 IAC 5-2-22, and Parts I.A.1, I.A.2, I.B.2, I.B.3, I.B.6, I.B.8, II.A.1, II.B.1, II.C.6 of the Permit.

3.                  Beginning on the Effective Date of this Agreed Order, and continuing until implementation of the Compliance Plan required pursuant to Order Paragraph 4 is complete, the Respondent shall, at all times, operate its existing sanitary collection system and WWTP as efficiently and effectively as possible.

4.                  Within 60 days of the Effective Date of this Agreed Order, the Respondent shall develop and submit to IDEM for its approval a compliance plan (CP) that includes, but is not limited to, the following:

 

A.                 A description of the actions that the Respondent will take and management systems that the Respondent will develop and implement to achieve and maintain continuous compliance with the effluent limitations contained in the Permit.  Such actions shall include, but not be limited to routine operation and maintenance of all treatment facilities and proper management, removal, storage, and disposal of sludge;

B.                 A description of the actions that the Respondent will take to identify potential discharge points located within the sanitary collection system, and in the event that such points exist, to prevent discharges from such points;

C.                A description of the actions that the Respondent will take to ensure that the sanitary collection system is at all times efficiently operated and maintained in good working order.  Such actions shall include, but not be limited to, identification and reduction of inflow and infiltration sources, including stormwater connections to the sanitary collection system, to maintain compliance with the NPDES Permit.

D.                A description of the actions that the Respondent will take to comply with the monitoring and reporting requirements of the Permit, including maintenance and utilization of a final effluent flow meter and continuous chart recorder(s), systems for proper sampling and laboratory analysis, timely submittal of complete and accurate monthly reports, and proper signature of monthly reports;  and

E.                 A schedule for initiation and completion of all actions described in the CP, including specific milestone dates.

 

Additional requirements that need to be included in the CP are included in Attachment A, which is hereby incorporated into this Agreed Order and deemed an enforceable part thereof.

 

5.                  The Respondent shall, upon completion of implementation of the portion of the CP required by Order Paragraph 4.A, be subject to the stipulated penalties specified in Order Paragraph 17 below for violation of the ammonia nitrogen monthly average concentration effluent limitation contained in the Permit.

6.                  The Respondent shall, within 12 months of the completion of the portion of the CP required by Order Paragraph 4.A (Performance Period), demonstrate for a period of 10 consecutive months, compliance with the effluent limitations contained in the Permit.  In the event that an effluent limitation violation occurs during the Performance Period, the Respondent shall, within 60 days of becoming aware of the effluent limitation violation, submit to IDEM for its approval, an Effluent Limitation Compliance Plan, that includes a description of the additional actions that the Respondent will take to achieve and maintain continuous compliance with the effluent limitations contained in the Permit and a schedule, including specific milestone dates for initiating and completing such actions.

7.                  The plans required by Order Paragraphs 4. and 6. are subject to IDEM approval.  In the event that IDEM determines any plan to be deficient or otherwise unapprovable, the Respondent shall, upon written notice by IDEM, revise and resubmit the plan, in accordance with IDEM’s written notice.  If, after three submissions of the plan by the Respondent, IDEM finds the plan to be deficient or otherwise unapprovable, IDEM may require the Respondent to revise and resubmit the plan, or alternatively, may modify and approve the plan, in which case the Respondent shall implement the plan as modified and approved by IDEM.

8.                  Upon approval by IDEM, any plan required pursuant to this Agreed Order shall be incorporated into the Agreed Order and shall be deemed an enforceable part thereof.  The Respondent, upon receipt of written approval from IDEM, shall immediately implement the approved plan and adhere to the schedule contained therein.

9.                  The Respondent shall notify IDEM, in writing, within 10 days of completion of each action or milestone contained in any plan approved by IDEM pursuant to this Agreed Order. The notification shall include a description of the action completed and the date it was completed.

10.             Within 30 days of the Effective Date of this Agreed Order, the Respondent shall determine whether it has sufficient legal authority to:

 

A.                 implement and enforce its sewer use ordinances, service agreements and/or other legally binding documents;

 

B.                 require that all sewers and connections be properly designed and constructed;

 

C.                test and inspect all new and rehabilitated sewers, including both collector sewers and service laterals;

 

D.                regulate flows from satellite collection systems (if any); and

 

E.                 prohibit the connection or introduction of stormwater sources to the sanitary collection system.

 

11.             In the event that the Respondent determines that it does not have the legal authority described in Order Paragraph 10, the Respondent shall take all necessary steps to obtain such legal authority.

 

12.             Within 120 days of the Effective Date of this Agreed Order, the Respondent shall submit to IDEM a statement certifying that it has the legal authority described in Order Paragraph 10.

 

13.             Beginning on the Effective Date, the Respondent shall inspect the sanitary collection system during and/or after precipitation events, in order to determine whether a discharge has occurred. The Respondent shall document its inspections by recording the following:

 

A.                 the date and time of the inspection;

 

B.                 the name of the person(s) conducting the inspection;

 

C.                the date the precipitation event began;

 

D.                the time the precipitation event began (estimated or actual) and, for inspections conducted after the precipitation event, the time the precipitation event ended (estimated or actual), and the volume (estimated or actual) of the precipitation event;

 

E.                 observations as to whether a discharge from the sanitary collection system occurred, is occurring, or is about to occur, and if so the location of the discharge/impending discharge; and

 

F.                 the remedial measures taken in the event that a discharge is found to have occurred, to be occurring, or about to occur.

 

The Respondent shall maintain the required documentation at the WWTP and shall make such documentation available to IDEM representatives for inspection and/or copying upon request.

 

14.             Beginning on the Effective Date, in the event that a discharge from the sanitary collection system occurs the Respondent shall:

A.                 take all reasonable actions to cease the discharge as soon as possible;

 

B.                 properly clean the affected area;

 

C.                remove and properly dispose of sewage and debris from the affected area;

 

D.                report the discharge event as follows:

 

(i)                 Within twenty-four (24) hours of the Respondent’s discovery of the discharge, the Respondent shall provide verbal notification of the event to IDEM, at 317/232-8795 (or 317/232-8694) during regular business hours or 317/233-7745 during non-business hours;

(ii)               Within five (5) days of the Respondent’s discovery of the discharge, the Respondent shall submit written notification of the discharge to IDEM.  The notification shall include the following information: the duration and cause of the discharge and the remedial action taken to eliminate it;

(iii)             The Respondent shall report the duration and estimated volume of the discharge on the Discharge Monitoring Report and the Monthly Report of Operation; and

 

E.                 document all actions taken to cease the discharge and to remediate the affected areas, maintain copies of the documentation at the WWTP, and make such documentation available to IDEM representatives for inspection and/or copying upon request.

 

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

Mr. Paul Cluxton, Environmental Manager
Office of Enforcement
Indiana Department of Environmental Management
100 North Senate Avenue
Indianapolis, IN  46204

 

16.             The Respondent is assessed a civil penalty of One Thousand Five Hundred and Fifteen Dollars ($1,515).  Said penalty amount shall be due and payable to the Environmental Management Special Fund within 30 days of the Effective Date.

17.             In the event the terms and conditions of the following Order paragraphs are violated, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amount:

 

Order Paragraph Number

Violation

Penalty Amount

4

Failure to submit the CP, as required.

$250 per each week or part thereof late

5

Violation of ammonia nitrogen monthly average effluent limitation contained in the Permit, subsequent to completion of implementation of the portion of the CP required pursuant to Order Paragraph 4.A.

$1000 per violation

6

Failure to submit Effluent Limitation Compliance Plan, if required.

$250 per each week or part thereof late

7

Failure to revise and resubmit any plan required pursuant to this Agreed Order, as required.

$250 per each week or part thereof late

8

Failure to implement an approved plan, or to meet any milestone date set forth in any approved plan.

$500 per each week or part thereof late

9

Failure to notify IDEM, in writing, within 10 days of completion of each action contained in the approved action plan.

$250 per each week or part thereof late

12

Failure to timely submit certification statement

$250 per each week or part thereof late

13

Failure to inspect sanitary collection system, as required

$500 per violation

13

Failure to document inspections of sanitary collection system or make documentation available to IDEM, as required

$500 per violation

14

Failure to take all reasonable actions to cease the discharge as soon as possible; properly clean the affected area; remove and properly dispose of sewage and debris from the affected area; or report the discharge event, as required

$500 per violation

14

Failure to document action taken to cease the discharge and to remediate the affected areas, or make documentation available to IDEM, as required.

$500 per violation

 

18.             Stipulated penalties shall be due and payable within 30 days after the Respondent receives written notice that the Complainant has determined a stipulated penalty is due.  Assessment and payment of stipulated penalties shall not preclude the Complainant from seeking any additional relief against the Respondent for violation of the Agreed Order.  In lieu of any of the stipulated penalties given above, the Complainant may seek any other remedies or sanctions available by virtue of the Respondent's violation of this Agreed Order, or Indiana law, including but not limited to civil penalties pursuant to IC 13-30-4.

 

19.             Civil and stipulated penalties are payable by check to the Environmental Management Special Fund.  Checks shall include the Case Number (2003-12643-W) 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

 

20.             In the event that the civil penalty required by Order Paragraph 16, is not paid within 30 days of the Effective Date of this Agreed Order, the 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.

 

21.             This Agreed Order shall apply to and be binding upon the Respondent, its successors, 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.

 

22.             In the event that any terms of the 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.

 

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

24.             “Force Majeure”, for purposes of this Agreed Order, is defined as any event arising from causes totally beyond the control and without fault of the Respondent that delays or prevents the performance of any obligation under this Agreed Order despite Respondent’s best efforts to fulfill the obligation.  The requirement that the Respondent exercise “best efforts to fulfill the obligation” includes using best efforts to anticipate any potential force majeure event and best efforts to address the effects of any potential force majeure event (1) as it is occurring and (2) following the potential force majeure event, such that the delay is minimized to the greatest extent possible.  “Force Majeure” does not include changed business or economic conditions, financial inability to complete the work required by this Agreed Order, or increases in costs to perform the work.

The Respondent shall notify IDEM by calling the case manager within three (3) calendar days and by writing no later than seven (7) calendar days after it has knowledge of any event which the Respondent contends is a force majeure.  Such notification shall describe the anticipated length of the delay, the cause or causes of the delay, the measures taken or to be taken by the Respondent to minimize the delay, and the timetable by which these measures will be implemented.  The Respondent shall include with any notice all available documentation supporting its claim that the delay was attributable to a force majeure.  Failure to comply with the above requirements shall preclude Respondent from asserting any claim of force majeure for that event.  The Respondent shall have the burden of demonstrating that the event is a force majeure.  The decision of whether an event is a force majeure shall be made by IDEM.

If a delay is attributable to a force majeure, IDEM shall extend, in writing, the time period for performance under this Agreed Order, by the amount of time that is directly attributable to the event constituting the force majeure.

 

25.             This Agreed Order shall remain in effect until the Respondent complies with the terms of Order Paragraphs 3 through 20 and until IDEM issues a Close-Out letter to the Respondent.

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

Town of Kirklin

 

 

 

By:

 

 

By:

 

 

Mark W. Stanifer

 

Printed:

 

 

Section Chief, Water Section

 

Title:

 

 

Office of Enforcement

 

 

 

Date:

 

 

Date:

 

 

 

 

 

 

 

 

 

COUNSEL FOR COMPLAINANT:

 

COUNSEL FOR RESPONDENT:

Department of Environmental Management

 

 

 

 

 

By:

 

 

By:

 

 

Joseph H. Merrick, Attorney

 

 

 

 

Office of Legal Counsel

 

 

 

 

The Department of Environmental Management

 

 

 

Date:

 

 

Date:

 

 

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

 

DAY OF

 

, 200

 

.

 

 

For The Commissioner:

 

 

 

Signed on March18, 2005

 

Matthew T. Klein

 

Assistant Commissioner

 

Attachment A

 

The portion of the Compliance Plan required pursuant to Order Paragraph 4 shall provide for the following:

 

1.                  Development and implementation of a Maintenance Program that includes, but is not necessarily limited to:

 

a.                  routine/ongoing preventive maintenance of facilities and equipment, using a predictive approach to continually review and update maintenance procedures;

 

b.                  identification of critical parts needed for system operation and maintenance;

 

c.                  establishment and maintenance of an adequate inventory of replacement parts; and

 

d.                  routine/ongoing efforts to identify sources of infiltration and inflow and to systematically eliminate those sources.

 

2.                  Development and implementation of an Operations and Capacity Management Program that includes, but is not necessarily limited to:

 

a.                  routine/ongoing assessment of the structural integrity and capacity of the collection system and treatment facilities;

 

b.                  evaluation of the impact of industrial and other non-domestic collection systems tributary to all overflow and/or bypass points, and identification and implementation of actions necessary to address such impacts;

 

c.                  Identification and prioritization of structural and hydraulic deficiencies (particularly those that allow for infiltration and inflow to the collection system and limit the capacity of the sewer lines to transport all collected water to the treatment plant for treatment and/or those that are causing or contributing to collection system discharges) and identification and implementation of rehabilitative actions needed to correct each deficiency,

d.                  monitoring of the collection system, both routinely and during all precipitation events, to identify discharges; and

 

e.                  Procedures for responding to and operating during conditions likely to result in collection system discharges, such as floods, equipment failure, and power failure.

 

3.                  Development and implementation of an Information Management Program that includes, but is not necessarily limited to:

 

a.                  Development and maintenance of an accurate and up-to-date map of the collection system;

 

b.                  Procedures for recording and reporting collection system discharge events, consistent with the requirements of the Permit;

 

c.                  Identification and illustration of trends in overflow occurrences;

 

d.                  Procedures for responding to overflows;

 

e.                  Procedures for tracking collection system problems (including customer complaints);

 

f.                    Maintenance of all records resulting from work performed in the collection system including work orders associated with investigations, inspections, new installations, preventive and routine maintenance, and corrective actions;

 

g.                  Procedures for complying with the records retention requirements of the NPDES permit; and

 

h.                  Documentation of all activities taken in order to implement the portion of the CP required pursuant to Order Paragraph 4.

 

4.                  Development and implementation of a Training and Review Program that includes, but is not necessarily limited to:

 

a.                  Appropriate regular and refresher training on a routine basis for employees and other affected persons, on procedures for implementation of the provisions of the CP required pursuant to Order Paragraph 4.A and D; and

 

b.                  Annual reviews by representatives of all levels of management and staff to assess the overall effectiveness of the CP, and recommend adjustments.

 

5.                  Development and implementation of a Monitoring and Modification Program that includes, but is not necessarily limited to:

 

a.                  Ongoing monitoring of the implementation and effectiveness of the portion of the CP required pursuant to Order Paragraph 4.A, C, and D; and

 

b.                  Modification and update as necessary to ensure that the purpose of the CP required pursuant to Order Paragraph 4.D is achieved.