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.

CHUCK FORNEY,
D.B.A.
BLOOMINGTON AUTO PARTS,

Respondent.

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Case No. 2005-14409-H




 

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. 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 Chuck Forney, d.b.a. Bloomington Auto Parts, ("Respondent"), who owns and operates a facility located at 7650 North SR 37 in Bloomington, Monroe 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, IDEM issued a Notice of Violation via Certified Mail to:

Chuck Forney, d.b.a. Bloomington Auto Parts
7650 North SR 37
Bloomington, IN  47404

 

5. Respondent owns and operates an auto salvage yard and processes scrap metal.  Respondent processes about one hundred (100) vehicles each month.  At the time of the inspection, Respondent was storing over 1,000 waste tires on-site.

 

6. An inspection on May 3, 2004, was 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 this inspection:

 

a. Pursuant to 329 IAC 10-4-2, no person shall cause or allow the storage, containment, processing, or disposal of solid waste in a manner which creates a threat to human health or the environment, including the creating of a fire hazard, vector attraction, air or water pollution, or other contamination.   Respondent caused and/or allowed over 1,000 waste tires, a solid waste, to be stored at the Site on the northeast part of the Site.  Respondent also caused and/or allowed dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, fuel, and waste tires, to be disposed at various locations of the Site in a manner which creates a threat to human health or the environment.

 

b. Pursuant to 329 IAC 10-4-3, open dumping and open dumps, as those terms are defined in IC 13-11-2-146 and IC 13-11-2-147, are prohibited.  Respondent caused and/or allowed dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, fuel, and wastes tires, solid wastes, to be open dumped at the Site.  Over 1,000 waste tires were stored at the northeast portion of the Site.  Dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, and fuel, were open dumped in the following areas:

 

1) At the northern portion of the Site; and

 

2) At the garage and outside parts areas on the western side of the Site.

 

c. Pursuant to 329 IAC 15-3-2, the owner of a waste tire storage site shall possess a valid certificate of registration issued under 329 IAC 15-3; comply with all applicable requirements of 329 IAC 15-3; and maintain financial assurance as required by 329 IAC 15-5.  Respondent stored at least 1,000 waste tires outside at the Site without a valid certificate of registration under 329 IAC 15-3; did not comply with all applicable requirements of 329 IAC 15-3; and did not maintain financial assurance as required by 329 IAC 15-5.

 

d. Pursuant to IC 13-30-2-1(3), no person shall deposit any contaminant upon the land in a place or manner that creates or would create a pollution hazard that violates or would violate 329 IAC 10-4-2 and 329 IAC 10-4-3.   Respondent deposited waste tires on the northeast portion of the Site and deposited dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, and fuel in the following areas:

 

1) At the northern portion of the Site; and

 

2) At the garage and outside parts areas on the western side of the Site.

 

e. Pursuant to IC 13-30-2-1(4), no person shall deposit or cause or allow the deposit of contaminants or solid waste upon the land, except through the use of sanitary landfills, incineration, composting, garbage grinding, or another method acceptable to the solid waste management board.   Respondent caused and/or allowed dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, fuel, and waste tires, contaminants or solid wastes, to be deposited at the Site in a manner unacceptable to the solid waste management board.

 

f. Pursuant to IC 13-30-2-1(5), no person shall dump or cause or allow the open dumping of garbage or any other solid waste in violation of 329 IAC 10-4-2 and 329 IAC 10-4-3.  Respondent caused and/or allowed dissembled vehicle parts (including batteries), household wastes, construction debris,  automotive fluids, oil, and fuel, and waste tires, solid wastes, to be open dumped at the Site.

 

g. Pursuant to IC 13-30-2-1(1), no person shall 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 in violation of 329 IAC 10-4-2 and 329 IAC 10-4-3.  Respondent allowed dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, fuel, and waste tires to be released into the environment in the following areas:

 

1) The northeast portion of the Site;

 

2) The northern portion of the Site; and

           

3) At the garage and outside parts areas on the western side of the Site.

 

h. Pursuant to 327 IAC 15, a person who has a point source discharge of storm water associated with industrial activity and meets the general and applicability requirements of 327 IAC 15-2-2(a)(1), 15-2-3, and 15-6-2, must comply with, among other things, the requirements of 327 IAC 15-2-5, 15-6-5, 15-6-7, 15-6-7.3, and 15-6-7.5.  Point source discharges of storm water associated with industrial activity have occurred at the Site, and Respondent’s industrial activity meets the general and applicability requirements of 327 IAC 15-2-2(a)(1), 15-2-3, and 15-6-2, but Respondent had not complied with the requirements of 327 IAC 15-2-5, 15-6-5, 15-6-7, 15-6-7.3, and 15-6-7.5.

 

i. Pursuant to 327 IAC 15-2-5, any person responsible for the operation of a facility from which a point source discharge of pollutants and/or storm water occurs must submit a Notice of Intent (NOI) letter to the commissioner that complies with this section, 327 IAC 15-3, and the additional requirements in any applicable general permit rule.  Respondent failed to submit an NOI letter to the commissioner.

 

j. Pursuant to 327 IAC 15-6-2(a)(5)(E), the requirements of this rule apply to all facilities involved in the recycling of materials, including metal scrap yards, battery reclaimers, salvage yards, and automobile junkyards, including those classified under the following SIC codes:

 

(i) 5015 (motor vehicle parts, used) and

 

(ii) 5093 (scrap and waste materials).

 

Respondent failed to comply with the requirements of 327 IAC 15-6, including, but not limited to, the following:

 

(1) Failure to submit additional information with the NOI letter as required by 327 IAC 15-6-5.

 

(2) Failure to develop, implement, update, and maintain a Storm Water Pollution Prevention Plan as required by 327 IAC 15-6-7.

 

(3) Failure to monitor as required by 327 IAC 15-6-7.3.

 

(4) Failure to submit an annual report to the commissioner as required by 327 IAC 15-6-7.5.

 

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. Within one hundred and eighty (180) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(3).  Specifically, Respondent shall remove all tires from the Site and dispose of them at a permitted solid waste management facility.  Respondent shall submit progress reports, including manifests, to IDEM at sixty (60) days and one hundred and twenty (120) days of the Effective Date of this Agreed Order.

 

3. Within two hundred and ten (210) days of the Effective Date of this Agreed Order, Respondent shall submit written documentation that the tires removed from the Site have been taken to a permitted solid waste management facility.

 

4. Respondent shall ensure that all work conducted to satisfy the requirements of Order paragraph 2 above is done in compliance with all applicable federal, state, and local laws and regulations.

 

5. Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(3), (4) and (5) according to the following timeframes.  Specifically, Respondent shall clean up the open dumping and/or releases in the following areas by removing all dissembled vehicle parts (including batteries), household wastes, construction debris, automotive fluids, oil, and fuel, and by excavating the soil six inches beyond visible contamination:

 

a.) At the garage and outside parts areas on the western side of the Site where petroleum stained soils were observed within two hundred and ten (210) days of the Effective Date of this Agreed Order; and

 

b.) At the area on the northern side of the Site where open dumping was observed within one hundred and eighty (180) days of the Effective Date of this Agreed Order.

 

6. Within forty-five (45) days of completion of the cleanup required by Orders 5a. & b. above, Effective Date of this Agreed Order, Respondent shall submit to IDEM documentation that the releases and/or open dumping in the above areas have been cleaned up.

 

7. Upon the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(1).  Specifically, Respondent shall take immediate steps to capture any potential release of fluids during auto salvage activities and immediately cease allowing the release of contaminants into the environment.

 

8. Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with 327 IAC 15-2-5(a) and submit an NOI letter, which complies with all of the requirements of 327 IAC 15-3 and 327 IAC 15-6-5, to IDEM.

 

9. In the event IDEM determines that the NOI letter submitted by Respondent is deficient or otherwise unacceptable, Respondent shall revise and resubmit the NOI to IDEM in accordance with IDEM’s notice.

 

10. Within ninety (90) days of the Effective Date of this Agreed Order, Respondent shall conduct monitoring as required by 327 IAC 15-6-7.3.

 

11. Within thirty (30) days after laboratory analyses conducted pursuant to Order paragraph 10 have been completed, Respondent shall submit sampling data results to IDEM for review.  Respondent shall also, in accordance with 327 IAC 15-6-7(b)(9), include the sampling data results in the Storm Water Pollution Prevention Plan required by Order paragraph 12.

 

12. Within one hundred and eighty (180) days of the Effective Date of this Agreed Order, Respondent shall comply with 327 IAC 15-6-7.  Specifically, Respondent shall develop and submit to IDEM for approval a Storm Water Pollution Prevention Plan.

 

13. Within ten (10) days of notice of IDEM’s approval of the Storm Water Pollution Prevention Plan, Respondent shall implement the plan as approved.

 

14. Within three hundred and ninety-five (395) days of the Effective Date of this Agreed Order, Respondent shall submit an Annual Report in accordance with 327 IAC 15-6-7.5.

 

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

Brenda Lepter, Enforcement Case Manager
Office of Enforcement
Indiana Department of Environmental Management
100 N. Senate Avenue
P. O. Box 6015

Indianapolis, IN 46206-6015

 

16. 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

Failure to comply with Order paragraph 2
Failure to comply with Order paragraph 3
Failure to comply with Order paragraph 5a.
Failure to comply with Order paragraph 5b.
Failure to comply with Order paragraph 6
Failure to comply with Order paragraph 8
Failure to comply with Order paragraph 9
Failure to comply with Order paragraph 10
Failure to comply with Order paragraph 11
Failure to comply with Order paragraph 12
Failure to comply with Order paragraph 13
Failure to comply with Order paragraph 14

Penalty

$1000 per week
$500 per week
$1000 per week
$1000 per week
$500 per week
$1000 per week
$1000 per week
$1000 per week
$500 per week
$1000 per week
$1000 per week
$500 per week

 

 

17. 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.

 

18. 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:

Cashier
IDEM
100 N. Senate Avenue
P. O. Box 7060

Indianapolis, IN 46207-7060

 

19. 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.

 

20. 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.

 

21. Notwithstanding any other provision of this Agreed Order, the Complainant reserves, and this Agreed Order is without prejudice to, the right to institute proceedings in this action or in a new action for injunctive relief, costs, civil penalty and/or remediation of environmental contamination that is either discovered after the entry into the Agreed Order or that has not been adequately remedied despite compliance by Respondent with the terms of this Agreed Order.

 

22. 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.

 

23. This Agreed Order shall remain in effect until IDEM issues a Resolution of Case letter to Respondent.

 

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

 

 

By:

 

 

By:

 

 

Nancy L. Johnston, Chief

 

Printed:

 

 

Office of Enforcement

 

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

 

, 200

 

.

 

 

For The Commissioner:

 

 

Signed on June 2, 2005

 

Matthew T. Klein

 

Assistant Commissioner

 

for Compliance and Enforcement