STATE OF INDIANA

 

COUNTY OF MARION

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BEFORE THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT,

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Complainant,

 

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v.

 

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Case Nos. 2004-14398-A and 2005-14923-A

 

 

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PHELPS DODGE INDUSTRIES, INC. dba PHELPS DODGE MAGNET WIRE COMPANY,

 

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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 Phelps Dodge Industries, Inc. d/b/a Phelps Dodge Magnet Wire Company ("Respondent"), which owned and operated the magnet wire coating operation with Plant ID No. 003-00013, located at 4300 New Haven Ave. in Ft. Wayne, Allen Co., Indiana (“Site”).

 

3.                  Respondent contends that on February 10, 2006, Rea Magnet Wire, Inc. acquired the assets of and assumed all liabilities, obligations, and commitments, unless expressly excluded, arising out of or relating to the magnet wire coating operation at the Site.

 

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

 

5.                  Pursuant to IC 13-30-3-3, on March 1, 2006 and April 11, 2006 IDEM issued a Notice of Violation via Certified Mail to:

 

Larry Bagwell, President

CT Corporation System, Registered Agent

Rea Magnet Wire Company, Inc.

3600 E. Pontiac St.

Ft. Wayne, IN  46803

 

J. Steven Whisler, President

Phelps Dodge Industries, Inc.

One North Central Ave.

Phoenix, AZ  85004

251 E. Ohio St., Suite 1100

Indianapolis, IN  46204

 

 

CT Corporation System, Registered Agent

251 E. Ohio St., Suite 1100

Indianapolis, IN  46204

 

6.                  A records review was conducted of the Site by a representative of IDEM’s Office Air Quality (OAQ).  The following violations were in existence or observed at the time of this review:

 

a.                  Pursuant to Part 70 Permit T003-6925-00013, Sections D.1, D.2, D.3, D.4, D.5 and D.6, the Respondents must operate and maintain the thermal oxidizers serving the wire enameling ovens at a minimum operating temperature.

The Respondents failed to meet the minimum temperature of the thermal oxidizers serving the wire enameling ovens in Sections D.1, D.2, D.3, D.4, D.5 and D.6 of permit T003-6925-00013 on several dates in 1st, 2nd, 3rd and 4th Quarters 2003; 1st, 2nd, 3rd and 4th Quarters 2004; and on several dates in 1st and 2nd Quarters 2005.

 

b.                  Pursuant to Part 70 Permit T003-6925-00013, conditions D.1.7(a), D.2.7(a), D.3.8(a), D.4.6(a), D.5.7(a) and D.6.7(a) the Respondents must operate a continuous monitoring system and record the thermal oxidizer temperature.  If the continuous monitoring system is not in operation, the temperature shall be recorded manually once ever 15-minute period.

The Respondents failed to record the thermal oxidizer temperatures from the wire enameling ovens in Sections D.1, D.2, D.3, D.4, D.5 and D.6 from December 13 – 20, 2002, a violation of permit T003-6925-00013 conditions D.1.7(a), D.2.7(a), D.3.8(a), D.4.6(a), D.5.7(a) and D.6.7(a).

 

c.                  Pursuant to Part 70 Permit T003-6925-00013, conditions D.1.8(a)(2), D.2.8(a)(2), D.3.9(b)(1), D.4.7(b)(1), D.5.8(a)(2) and D.6.8(a)(2), the Respondents shall maintain continuous temperature records (on an hourly average basis) for the thermal oxidizers.

The Respondents failed to maintain continuous temperature records (on an hourly average basis) for the thermal oxidizers from the wire enameling ovens in Sections D.1, D.2, D.3, D.4, D.5 and D.6 from December 13 – 20, 2002, a violation of permit T003-6925-00013 conditions D.1.8(a)(2), D.2.8(a)(2), D.3.9(b)(1), D.4.7(b)(1), D.5.8(a)(2) and D.6.8(a)(2).

 

d.                  Pursuant to Part 70 Permit T003-6925-00013, condition D.10.2(e), the Respondents shall provide a permanent, conspicuous label summarizing the operation requirements for the cold cleaner operations.

The Respondents failed to post permanent conspicuous labels on each of the cold cleaners, noted during an inspection on June 10, 2004, a violation of permit T003-6925-00013, condition D.10.2(e).

 

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.                  Respondent is assessed a civil penalty of Two Hundred and Sixteen Thousand Dollars ($216,000).  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.

 

3.                  Civil 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’s Office - Mail Code 50-10C

100 North Senate Avenue

Indianapolis, Indiana  46204-2251

 

4.                  In the event that the civil penalty required by Order paragraph 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.

 

5.                  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.

 

6.                  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.

 

7.                  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.

 

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

 

9.                  This Agreed Order resolves all violations set out in this Agreed Order and in the March 1, 2006 and April 11, 2006 Notices of Violation described in Findings of Fact paragraph 5.

 

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TECHNICAL RECOMMENDATION:

RESPONDENT:

Department of Environmental Management

Phelps Dodge Industries, Inc. d/b/a

Phelps Dodge Magnet Wire Company

 

 

By:__________________________

By:________________________

David P. McIver

Chief, Air Section

 

Office of Enforcement

Printed:__________________

 

 

 

Title:________________________

 

 

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 _______________, 20__.

 

 

For the Commissioner:

 

 

Signed November 30, 2006

Matthew T. Klein

Assistant Commissioner for

Compliance & Enforcement