STATE OF INDIANA

COUNTY OF MARION

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SS:

BEFORE THE INDIANA DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT,

Complainant,

v.

Clay township regional
waste district
,

Respondent.

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Case No. 2004-13861-W




 

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.

 

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 IC 13-13-1-1.

 

2.                  The Respondent is Clay Township Regional Waste District (“Respondent”), which owns and operates the sanitary sewer construction extension project having its main office located at 10701 North College Avenue, Indianapolis, Indiana.  The Respondent was constructing a sanitary sewer extension construction project (Permit Approval No. 16490) for Austin Oaks off-site force main, located adjacent to US Highway 421, from 106th Street and Willow Drive, Zionsville, traversing through Boone and Hamilton Counties, Indiana (the “Site”) at the time the violations were discovered.

 

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, on July 18, 2006, IDEM issued a Notice of Violation via Certified Mail to the Respondent at the address below:

 

Andrew Williams, Utility Director

Clay Township Regional Waste District

10701 North College Avenue

Indianapolis, Indiana 46280-1098

 

5.                  Pursuant to 327 IAC 3-2-1, no person shall cause or allow the construction, installation, or modification of any water pollution treatment/control facility or sanitary sewer, without a valid construction permit issued by the commissioner.

 

6.                  Pursuant to 327 IAC 3-2-2(d), construction shall not commence until all necessary state approvals and permits are obtained.

 

7.                  On or about November 11, 2004, the Respondent submitted a construction permit application for the construction of a sanitary sewer extension project at the Site.  As stated in the Respondent’s construction permit application and in the permit issued by IDEM, “The scope of the project included the installation of approximately 1,955 feet of 16-inch diameter and 144 linear feet of 12-inch diameter PVC (SDR 21 ASTM D 2241) force main.  The 12-inch force main was to be installed by bore and jack method across US Highway 421, and capped upstream for future connection to lift station No.16 (or Presbyterian Church lift station) and will be connected to the existing 16-inch force main at the US Highway 421 right of way.  The force main’s ultimate peak future flow for the project will be 3,774,500 gallons per day… through the Austin Oaks lift station (No. 14) and the sanitary sewer system to the Clay Township Regional Waste District’s wastewater treatment plant (“WWTP”).”

 

8.                  During the construction permit application review, IDEM received a letter from the Respondent’s representative at Consoer Townsend Envirodyne Engineers, Inc., which stated the following:

 

“The new force main will extend and connect to portions of the existing 16” force main installed under IDEM permit approval No. 8367.  (The permitted 14” diameter force main was upsized to a 16” diameter by addendum).”

 

The Respondent informed IDEM that the “addendum” was between Brenwick Development Company, Inc. and its contractor.  IDEM did not issue any addendum for the construction project at the Site.  IDEM was not informed of and did not approve the pipe size adjustment from 14-inches to 16-inches, prior to construction at the Site.

 

9.                  On January 26, and January 30, and March 29, 2004, IDEM received additional information required to process the Respondent’s construction permit application.  The Respondent submitted plans and specifications that referenced constructing the new force main to an existing 16-inch diameter force main.  The 1995 construction permit, Approval No. 8367, was issued for a 14-inch diameter force main.  The Respondent failed to submit a request to IDEM for a revision to the 1995 construction permit, Approval No. 8367, prior to the installation of the 16-inch diameter force main, in violation of 327 IAC 3-2-1 and 327 IAC 3-2-2(d).

 

10.             On February 24, 2004, a representative of IDEM notified Ron Lauritsen, the Respondent’s representative from Consoer Townsend Envirodyne Engineers, Inc. that the Respondent was in violation of the 1995 construction permit, Approval No. 8367 and that the Respondent was required to submit “as-built” plans and specifications, including verification of completion of the pressure/leakage testing, for IDEM’s approval.  IDEM also notified Consoer Townsend Envirodyne Engineers, Inc, the Respondent’s representative, that a formal enforcement action was pending.

 

11.             Although on April 15, 2004, IDEM issued a construction permit for the sanitary sewers under the permit, Approval No. 16490, at the Site, the Respondent did not submit “as-built” plans and specifications, including verification of completion of the pressure/leakage testing requirement for the force main that was installed under the 1995 permit, Approval No. 8367, in accordance with the permit and 327 IAC 3-6-19, in violation of 327 IAC 3-2-1 and 327 IAC 3-2-2(d).

 

12.             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 maintain compliance with all requirements of 327 IAC 3 and all other applicable rules and statutes.

 

3.                  Upon commencing future construction of any sanitary sewers that tie into the 16-inch force main, the Respondent shall complete the pressure/leakage testing requirements for the force main that was installed under the 1995 permit, Approval No. 8367, which demonstrates the pressure/leakage testing requirement for the force main was completed in accordance with 327 IAC 3-6-19 and the pipe manufacturer.

4.                  If, in the future the Respondent wishes to use the existing 16-inch force main and if the sewer does not meet the pressure/leakage testing requirements, any further modification to the existing pipe will require the Respondent to submit a construction permit application to IDEM prior to repair or replacement of the existing force main.  All future sanitary sewer construction must be done in accordance with 327 IAC 3.

 

5.                  Within 10 days of completion of the test, the Respondent shall submit verification to IDEM at the addresses below, which demonstrates the pressure/leakage testing requirement for the force main was completed in accordance with 327 IAC 3-6-19 and the pipe manufacturer.  If the Respondent is required to submit a new construction permit application, it may also submit the application to the address below:

 

Sholeh Hourmozdi, Engineer

Indiana Department of Environmental Management

Office of Water Quality – Mail Code 65 – 40

Facility Construction Section

100 N. Senate Avenue

Indianapolis, Indiana 46204-2251

 

6.                  The Respondent is assessed a civil penalty of Three Thousand, Four Hundred Fifty Dollars ($3,400).  Said penalty amount shall be due and payable to the Environmental Management Special Fund within 30 days of the Effective Date of this Agreed Order.

 

7.                  In the event that the civil penalty required by Order Paragraph 6, 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.

 

8.                  The Civil penalty is payable by check to the Environmental Management Special Fund.  Payments shall include the Case Number 2004-13681-W, of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Cashiers Office-Mail Code 50 - 10C

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

9.                  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.

 

10.             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.

 

11.             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.

 

12.             This Agreed Order is not and shall not be interpreted to be a permit or a modification of an existing permit.  This Agreed Order, and IDEM’s review or approval of any submittal made by the Respondent pursuant to this Agreed Order, shall not in any way relieve the Respondent of its obligation to comply with the requirements of any applicable permit or order or with any other applicable federal or state law or regulation.

 

13.             The Complainant does not, by its approval of this Agreed Order, warrant or aver in any manner that the Respondent’s compliance with any aspect of this Agreed Order will result in compliance with the provisions of any permit or order or any applicable federal or state law or regulation.  Additionally, IDEM or anyone acting on its behalf shall not be held liable for any costs or penalties the Respondent may incur as a result of Respondent’s efforts to comply with this Agreed Order.

 

14.             Nothing in this Agreed Order shall prevent or limit IDEM’s rights to obtain penalties or injunctive relief under any applicable federal or state law or regulation, except that IDEM may not seek additional civil penalties for the violations specified in the Notice of Violation.

 

15.             Nothing in this Agreed Order shall prevent IDEM or anyone acting on its behalf from communicating with the United States Environmental Protection Agency (“EPA”) or any other agency or entity about any matters relating to this enforcement action.  IDEM or anyone acting on its behalf shall not be held liable for any costs or penalties the Respondent may incur as a result of such communications with the EPA or any other agency or entity.

 

16.             This Agreed Order shall remain in effect until the Respondent has complied with Paragraphs 6 through 9 of this Agreed Order and IDEM has issued a close-out letter to the Respondent.

 

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

 

 

Department of Environmental Management

 

Clay Township Regional

Waste District

 

 

 

 

 

By:

 

 

By:

 

 

 

 

Mark W. Stanifer, Chief

 

Printed:

 

 

 

 

Water Enforcement Section

 

Title:

 

 

 

 

Office of Enforcement

 

 

 

 

 

Date:

 

 

Date:

 

 

 

 

 

 

COUNSEL FOR COMPLAINANT:

 

COUNSEL FOR RESPONDENT:

 

 

Department of Environmental Management

 

 

 

 

 

 

 

By:

 

 

By:

 

 

 

 

 

 

 

 

 

 

 

Office of Legal Counsel

 

 

 

 

Date:

 

 

Date:

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

 

MANAGEMENT THIS

 

 DAY OF

 

, 200

 

.

 

 

 

 

For The Commissioner:

 

 

 

 

 

Signed on November 17, 2006

 

 

Matthew T. Klein

 

 

Assistant Commissioner for

 

 

Compliance and Enforcement