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,

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Complainant,

 

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v.

 

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Case No. 2005-14849-A

 

 

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BRC RUBBER GROUP, 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.

 

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 BRC Rubber Group, Inc. (Respondent), which owns and operates a stationary miscellaneous automotive rubber parts manufacturing and coating facility (with ID number 009-00002) located at 623 West Monroe St., in Montpelier, Blackford County, Indiana (the “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 May 24, 2006, IDEM issued a Notice of Violation via Certified Mail to:

 

Charles V. Chaffee, President

Clifford W. Chaffee, Registered Agent

BRC Rubber Group, Inc.

BRC Rubber Group, Inc.

Highway 33 PO Box 227

589 South Main Street

Churubusco, IN  46723

Churubusco, IN  46723

 

5.                  A records review, on or around December 1, 2004, was conducted at the Site by a representative of IDEM’s Office of Air Quality (OAQ).  The following violations were in existence or observed at the time of this records review:

 

a.                  Pursuant to 326 IAC 2-7-10.5 and 326 IAC 2-7-12, an owner or operator of a Part 70 source proposing to construct new emission units, modify existing emission units, or otherwise modify the source shall submit a request for a modification approval.

 

The respondent constructed a phosphate line, in January of 2003, a large turntable blaster, small Vac-U Blast and a Goff turntable, all in January of 2004, without first submitting a request for a source modification, the permit modification application was received by IDEM on August 30, 2004, a violation of 326 IAC 2-7-10.5 and 326 IAC 2-7-12.

 

6.                  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 shall comply with 326 IAC 2-7-10.5 and 326 IAC 2-7-12.

 

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

 

Janusz Johnson, Enforcement Case Manager

Office of Enforcement – Mail Code 60-02

Indiana Department of Environmental Management

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

4.                  Respondent is assessed a civil penalty of Twenty Three Thousand Eight Hundred Dollars ($23,800).  Within thirty (30) days of the Effective Date of the Agreed Order, Respondent shall pay a portion of this penalty in the amount of Nineteen Thousand Eight Hundred Sixty Dollars and Fifty Cents ($19,860.50).  Said penalty amount shall be due and payable to the Environmental Management Special Fund. In lieu of payment of the remaining civil penalty, Respondent shall perform and complete a Supplemental Environmental Project (“SEP”).  Respondent estimates that this SEP will cost Seven Thousand Eight Hundred Seventy Nine Dollars ($7,879).  Within thirty (30) days of completing this SEP, Respondent shall submit written notice and documentation to IDEM which substantiates all actions taken and costs incurred with respect to the SEP.  In the event that the cost of the SEP is less than Seven Thousand Eight Hundred Seventy Nine Dollars ($7,879), Respondent shall pay Fifty Percent (50%) of the difference between the proposed cost of the SEP ($7,879) and the actual cost of the SEP.

 

5.                  As a Supplemental Environmental Project, Respondent shall reduce the amount of spent solvents disposed of as hazardous waste by installing and operating a Model Digit22N Resolv-r® solvent recycling machine at the Site.  Respondent shall purchase and install the solvent recycling machine by no later than December 31, 2006.  Respondent shall fully implement these solvent recycling operations no later than February 3, 2007.  Implementation of this SEP will reclaim sixty percent (60%) or more of the spent solvents from the painting and adhesive operations, an estimated hazardous waste reduction of 9,600 pounds per year.

 

6.                  In the event that the Respondent does not complete the SEP by February 3, 2007, the full amount of the civil penalty as stated in paragraph 4 above, plus interest established by IC 24-4.6-1-101 on the remaining amount, less the portion of the civil penalty Respondent has already paid, will be due within fifteen (15) days from Respondent's receipt of IDEM’s notice to pay.  Interest, at the rate established by IC 24-4.6-1-101, shall be calculated on the amount due from the date which is thirty (30) days after the Effective Date of this Agreed Order until the full civil penalty is paid.

 

7.                  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:

 

Cashier

Indiana Department of Environmental Management

100 N. Senate Avenue

P. O. Box 7060

Indianapolis, IN 46204-2251

 

8.                  In the event that the civil penalty required by Order paragraph No. 4 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.

 

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

 

 

Remainder of page left blank intentionally

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

BRC Rubber Group, Inc.

 

By:

 

 

By:

 

 

David P. McIver

 

Printed:

 

 

Chief, Air 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 December 18, 2006

 

Thomas W. Easterly

 

Commissioner