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,

 

)

 

 

 

)

 

v.

 

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Case No. 2004-13974-S

 

 

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TRANSFARM, INC.,

 

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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 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 ("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 Transfarm, Inc. ("Respondent"), which owns and operates the confined feeding operation ("CFO"), CFO Approval No. AW-5010, located at 332 West 100 North, in Reynolds, White County, Indiana ("Site").

 

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

 

4.                  Pursuant to IC 13-30-3-3, on August 30, 2004, IDEM issued a Notice of Violation via Certified Mail to:

 

Brian Furrer

President and Registered Agent

Transfarm, Inc.

332 West 100 North

Reynolds, IN 47980

 

5.                  Inspections, on November 18, 19 & 20, 2003, were conducted at the Site by a representative of IDEM's Office of Land Quality (OLQ).  The following violations were in existence or observed at the time of these inspections.

 

A.                 Pursuant to 327 IAC 2-6.1-7, any person who operates, controls or maintains any mode of transportation or facility from which a spill occurs shall, upon discovery of a reportable spill to the soil or surface waters of the state, contain the spill, if possible, to prevent additional spilled material from entering the waters of the state; undertake or cause others to undertake activities needed to accomplish a spill response; and as soon as possible, but within two hours of discovery, communicate a spill report to the Department of Environmental Management, Office of Environmental Response.

A reportable spill of waste liquid from the Site into an unnamed ditch (waters of the state) occurred on or about November 18-20, 2003 and was not properly contained and/or responded to and/or reported by the Respondent, in violation of 327 IAC 2-6.1-7.

 

B.                 Pursuant to 327 IAC 2-1-6(a)(1), all waters at all times and at all places, including the mixing zone, shall meet the minimum conditions of being free from substances, materials, floating debris, oil, or scum attributable to municipal, industrial, agricultural, and other land use practices, or other discharges:

 

(A)              that will settle to form objectionable deposits;

(B)              that are in amounts sufficient to be unsightly or deleterious;

(C)             that produce color, visible oil sheen, odor, or other conditions in such degree as to create a nuisance;

(D)             which are in amounts sufficient to be acutely toxic to, or otherwise severely injure or kill aquatic life, other animals, plants, or humans; and

(E)              which are in concentrations or combinations that will cause or contribute to the growth of aquatic plants or algae to such degree as to create a nuisance, be unsightly, or otherwise impair the designated uses.

 

(F)              The Respondent caused and/or allowed the discharge of waste liquid from the Site on or about November 18-20, 2003, into an unnamed ditch (waters of the state) that was in an amount sufficient to be unsightly or deleterious, that produced color, visible oil sheen, odor, or other conditions in such degree to create a nuisance, which was in amounts sufficient to be acutely toxic to, or otherwise severely injure or kill aquatic life, other animals, plants or humans, in violation of 327 IAC 2-1-6(a)(1).

 

C.                Pursuant to 327 IAC 5-2-2, any discharge of pollutants into waters of the         state as a point source discharge, except for exclusions made in 327 IAC 5-2-4, is prohibited unless in conformity with a valid NPDES Permit obtained prior to the discharge.

The Respondent caused and/or allowed the discharge of waste liquid, a pollutant, from the Site on or about November 18-20, 2003, into an unnamed ditch (waters of the state) without a valid NPDES permit and without meeting any of the exclusions in 327 IAC 5-2-4, in violation of 327 IAC 5-2-2.

 

D.                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 this state, or to 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 board adopted under IC 13-18-4-1 and IC 13-18-4-3.

The Respondent caused and/or allowed the discharge of waste liquid, an organic matter, from the Site on or about November 18-20, 2003 into an unnamed ditch (waters of the state) in violation of 327 IAC 2-6.1-7, 327 IAC 2-1-6(a)(1) and/or 327 IAC 5-2-2, and thus violated IC 13-18-4-5.

 

E.                 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 in any form which causes or would cause pollution which violates or which would violate rules, standards, or discharge or emission requirements adopted by the appropriate board under the environmental management laws.

The Respondent caused and/or allowed the discharge of waste liquid, a contaminant or waste, into the environment from the Site on or about November 18-20, 2003, in violation of 327 IAC 2-6.1-7, 327 IAC 2-1-6(a)(1) and 327 IAC 5-2-2, and thus violated IC 13-30-2-1(1).

 

F.                 Pursuant to 327 IAC 16-3-1(a), a confined feeding operation shall be managed to avoid an unpermitted discharge into waters of the state.

The Respondent did not manage the confined feeding operation to avoid an unpermitted discharge into waters of the state, resulting in discharges of waste liquid from the Site on or about November 18-20, 2003, into an unnamed ditch, waters of the state, without a valid permit, in violation of 327 IAC 16-3-1(a).

 

6.                  On March 9, 2006, IDEM issued Respondent a General National Pollutant Discharge Elimination System ("NPDES") permit, No. ING805560, for the Site.  The permit includes plans for:

 

A.                 Converting the run-off collection lagoon at the composting pad into a manure storage structure that complies with the requirements found at 327 IAC 16.

 

B.                 Building cattle barns to replace some of the open feed lots; and

 

C.                Construction of a waste management system for the collection and storage of process wastewater (as defined at 327 IAC 5-4-3(b)(12)) from the production area at the Site.

 

7.                  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 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 complete sufficient cattle barns to house the number of cattle currently on Lot Nos. 1, 2, 3, 4, 5, 10, 11 & 12 and the associated manure management system within one (1) year of the Effective Date of the General NPDES permit, No. ING805560, for the Site.  These lots are noted on Respondent's Farmstead Plan, attached hereto and incorporated by reference as "Attachment A."

 

3.                  The Respondent shall remove the cattle from Lot Nos. 1, 2, 3, 4, 5 and 12 and permanently seed all of these lots on or before March 9, 2006.

 

4.                  Following the seeding and establishment of vegetation on Lot Nos. 1, 2, 3, 4, 5 and 12 as referenced above, the Respondent shall maintain no less than 50% vegetation on these lots.

 

5.                  Should circumstances prevent completion of the projects described in Order Conditions 2, 3, and 4 above and Respondent has made a good faith effort to comply, the Respondent may request and the complainant may grant a one hundred and eighty (180) day extension to complete the projects.

 

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

 

Indiana Department of Environmental Management

Craig Henry, Enforcement Case Manager

Office of Enforcement Mail Code 60-02

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

7.                  Respondent is assessed a civil penalty of Three Thousand Seven Hundred Twenty Five ($3,725.00) Dollars.  Said penalty amount shall be due and payable to the Environmental Management Special Fund within thirty (30) days of the Effective Date of this Agreed Order.

 

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

 

Violation

Penalty

Failure to comply with Order paragraph No.3

$1,000.00 per week

Failure to comply with Order paragraph No. 4

$1,000.00 per week

 

9.                  Stipulated penalties shall be due and payable within thirty (30) days after 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 Respondent's violation of this Agreed Order or Indiana law, including, but not limited to, civil penalties pursuant to IC 13-30-4.

 

10.             Civil and stipulated penalties are payable by check to the Environmental Management Special Fund.  Checks shall include the Case Number of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Cashier Mail Code 50-10C

100 N. Senate Avenue

Indianapolis, IN 46204-7060

 

11.             In the event that the civil penalty required by Order paragraph No. 6 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.

 

12.             "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.

 

13.             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.

 

14.             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.

 

15.             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.

 

16.             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

Transfarm, Inc.

 

 

By:

____________________

By:

______________ ______

 

Paul Higginbotham, Chief

 

 

 

Solid Waste/UST Section

Printed:

_____________________

 

Office of Enforcement

 

 

 

 

 

 

Date:

__________________

Date:

____________________

 

 

 

 

COUNSEL FOR COMPLAINANT:

COUNSEL FOR RESPONDENT:

Department of Environmental Management

Bose McKinney & Evans, LLP

 

 

 

 

By:

________ __________

By:

____________________

 

Office of Legal Counsel

 

 

 

 

 

 

Date:

__________________

Date:

______________________

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_______

DAY OF

________________

, 20__.

 

 

 

For the Commissioner:

 

 

 

 

 

Signed April 12, 2006

 

Matthew T. Klein

 

Assistant Commissioner for

 

Compliance & Enforcement