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.

 

)

Case No. 2005-14474-H

 

 

)

 

JACK GULLEY d/b/a

 

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GULLEY’S AUTO SALVAGE,

 

)

 

 

 

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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.

 

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 Jack Gulley d/b/a Gulley’s Auto Salvage ("Respondent"), which owns and/or operates the company located at RR #1, Box 226, in Francisco, Gibson 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:

 

Jack Gulley d/b/a

Gulley’s Auto Salvage

RR #1, Box 226

Francisco, IN 47649

 

5.                  Respondent owns and/or operates an auto salvage yard and had about 300 vehicles on site at the time of the inspection and was storing over 1,000 waste tires on-site. 

 

6.                  An inspection on April 29, 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 allowed waste tires, a solid waste, to be stored, and allowed automotive fluids, oil, fuel and waste tires, to be disposed at the Site in a manner which creates a threat to human health or the environment.  Contamination and open dumping was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.

 

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 allowed waste tires, automotive fluids, oil, fuel, and non-ferrous automotive scrap, solid wastes, to be open dumped at the Site.  Open dumping was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.

 

c.                  Pursuant to IC 13-30-2-1(3), no person shall deposit any contaminants 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, automotive fluids, oil, and fuel, contaminants, at the Site in violation of 329 IAC 10-4-2 and 329 IAC 10-4-3.  Contamination and open dumping was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.

 

d.                  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 waste tires, automotive fluids, oil, and fuel, contaminants or solid waste, to be deposited at the Site in a method unacceptable to the solid waste management board.  Contamination and open dumping was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.

 

e.                  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 waste tires, automotive fluid, oil, fuel, and non-ferrous automotive scrap, solid wastes, to be open dumped at the Site.  Open dumping was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.  

 

f.                    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 waste tires and waste automotive fluid, oil, and fuel, to be released into the environment.  Contamination was observed throughout the site, but the heaviest of the soil staining was observed toward the center of the property near the crusher.

 

g.                  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 15-6-7, 15-6-7.3, and 15-6-7.5

 

h.                  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:

 

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

 

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

 

(c)               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 thirty (30) 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.

 

3.                  Within forty-five (45) 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.                  Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(5).  Specifically, Respondent shall remove all automotive scrap and garbage from the site and dispose of it properly.

 

5.                  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 crushing activities and immediately cease allowing the release of contaminants into the environment.

 

6.                  Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall submit to IDEM a site assessment plan.  The purpose of the site assessment plan shall be to conduct sampling and analysis in order to assess potential soil and ground water contamination described in Findings of Fact Nos. 6a, 6b, 6c, 6d, 6e, and 6f (the center of the property, near the crusher) and, if necessary, the nature and extent of contamination.  The site assessment plan shall be based upon the principles outlined within IDEM’s Risk Integrated System of Closure (RISC) Technical Resource Guidance Document (“TRGD”), dated February 15, 2001, which can be accessed at http://www/IN/gov/idem/land/risc.  In addition, the site assessment plan shall:

 

a.                  Describe and evaluate all areas of potential contamination in and around the  area of concern.

 

b.                  Specify the method of determining the number and location of samples to be taken to yield a representative assessment of the area of concern.  This method shall be:

 

1.                  random sampling, pursuant to Section 3.4 of Chapter 3 of the TRGD; or

 

2.                  directed sampling, pursuant to Section 3.4 of Chapter 3 of the TRGD; and

 

3.                  developed to provide locations and methods of any ground water samples pursuant to Section 3.4 of Chapter 3 of the TRGD.

 

c.                  Specify how the soil samples will be obtained and handled in order to minimize loss of volatile constituents.  Respondent may composite samples of non-volatiles (i.e., metals and semi-volatiles), but shall not composite samples of volatiles, pursuant to Section 3.4 of Chapter 3 of the TRGD.

 

d.                  Specify how the ground water samples will be obtained and describe the sampling procedures.

 

e.                  Clearly define all sampling and analytical protocols designed to identify hazardous waste or its constituents, pursuant to 40 CFR Part 261, including 40 CFR Part 261 Appendices I, II, III, and VIII.  The site assessment plan shall include the method of sample collection, pursuant to “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846.  This includes, but is not limited to, sample collection containers, preservatives, and holding times.  Specify the analytical methods to be used and the method’s Estimated Quantitation Limits (EQLs).

 

f.                    Specify that chain-of-custody of the samples shall be maintained and Quality Assurance and Quality Control (“QA/QC”) procedures shall be followed, pursuant to Appendix 2 of the TRGD.

 

g.                  Include within the site assessment plan a supplemental contingent plan for determining the nature and extent of:

 

1.                  soil contamination, as specified in Chapter 4 of the TRGD, in the event that sampling and analysis indicates soil contamination to exist above default residential levels as specified in Table A, Appendix I, of the TRGD; and

 

2.                  ground water contamination in the event that sampling and analysis indicates hazardous waste or its constituents are detected in the ground water as specified in Chapter 4 of the TRGD.

 

h.                  Include within the site assessment plan time frames for its implementation.

 

i.                    Be approved by IDEM prior to its implementation.

 

7.                  Within fifteen (15) days of receiving notice from IDEM of approval of the site assessment plan, Respondent shall implement it as approved and in accordance with the time frames contained therein.

 

8.                  Within fifteen (15) days of obtaining the analytical results, Respondent shall submit said results, including chain-of-custody information, and QA/QC records, pursuant to Appendix 2 of the TRGD, to IDEM.

 

9.                  If soil or ground water contamination is identified, Respondent shall submit within sixty (60) days subsequent to the completion of the analyses, a remediation workplan to IDEM for the purpose of remediating all soil and /or ground water contamination.  The remediation workplan shall:

 

a.                  In accordance with Chapter 6 of the TRGD, remediate each contaminated area to closure.  Closure levels shall be one of the following:

 

1.                  default residential levels, pursuant to Table A, Appendix I, in the TRGD; or

 

2.                  commercial/industrial default values (if appropriate to the facility), pursuant to Table A, Appendix I, in the TRGD.  Ground water shall meet residential default values at the property boundary or control;  or

 

3.                  closure levels for soil can also be established using the non-default procedures presented in Chapter 7 of the RISC Technical Guide.  The alternate cleanup level proposal must document that the constituents left in soil will not adversely impact any other environmental medium (ground water, surface water, or atmosphere) and that direct contact through dermal exposure, inhalation, or ingestion will not result in threats to human health or the environment; or

 

4.                  background levels for metals, pursuant to Section 1.6 of Chapter 1 of the TRGD, and/or the analytical method’s estimated quantitation limits (“EQLs”) for organics.

 

b.                  Include a soil and/or a ground water sampling and analysis plan to be performed after the cleanup has been performed which verifies that all contamination has been removed.

 

c.                  Include within the remediation workplan time frames for its implementation.

 

10.             Within fifteen (15) days of approval by IDEM of the remediation workplan, Respondent shall implement the plan as approved and in accordance with the time frames contained therein. 

 

11.             Within thirty (30) days of completion of the remedial action conducted pursuant to the remediation workplan, Respondent shall submit to IDEM certification by an independent registered professional engineer that the remedial action has been completed as outlined in the approved remediation workplan.

 

12.             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).   Specifically, Respondent shall clean up all releases throughout the facility evident by soil staining with the exception of the area near the crusher being addressed by order paragraphs 6 thru 11, by excavating the soil six inches beyond visible contamination.

 

13.             Within forty-five (45) days of the Effective Date of this Agreed Order, Respondent shall submit to IDEM documentation that releases in the above areas have been cleaned up.

 

14.             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.

 

15.             In the event that 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. 

 

16.             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.

 

17.             Within thirty (30) days after laboratory analyses conducted pursuant to Order paragraph 16 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 18.

 

18.             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.

 

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

 

20.             In the event IDEM determines that any plan submitted by Respondent is deficient or otherwise unacceptable, Respondent shall revise and resubmit the plan to IDEM in accordance with IDEM's notice.  After three (3) submissions of such plan by Respondent, IDEM may modify and approve any such plan and Respondent must implement the plan as modified by IDEM.  The approved plan shall be incorporated into this Agreed Order and shall be deemed an enforceable part thereof.

 

21.             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

 

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

 

Deirdre Wyatt, Enforcement Case Manager

Indiana Department of Environmental Management

Office of Enforcement Mail Code 60-02

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

23.             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 2

$250 per week

Failure to comply with Order paragraph 3

$250 per week

Failure to comply with Order paragraph 4

$250 per week

Failure to comply with Order paragraph 6

$250 per week

Failure to comply with Order paragraph 7

$250 per week

Failure to comply with Order paragraph 8

$250 per week

Failure to comply with Order paragraph 9

$250 per week

Failure to comply with Order paragraph 10

$250 per week

Failure to comply with Order paragraph 11

$250 per week

Failure to comply with Order paragraph 12

$250 per week

Failure to comply with Order paragraph 13

$250 per week

Failure to comply with Order paragraph 14

$250 per week

Failure to comply with Order paragraph 15

$250 per week

Failure to comply with Order paragraph 16

$250 per week

Failure to comply with Order paragraph 17

$250 per week

Failure to comply with Order paragraph 18

$250 per week

Failure to comply with Order paragraph 19

$250 per week

Failure to comply with Order paragraph 20

$250 per week

Failure to comply with Order paragraph 21

$250 per week

 

24.             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.

 

25.             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’s Office Mail Code 50-10C

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

26.             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.

 

27.             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.

 

28.             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.

 

29.             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.

 

30.             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

 

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

________________

, 200

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For The Commissioner:

 

 

 

 

 

 

 

Adopted 4/12/06

 

 

 

Matthew T. Klein

 

 

 

Assistant Commissioner

 

 

 

of Compliance and Enforcement