STATE OF INDIANA

)

SS:

BEFORE THE INDIANA DEPARTMENT OF

 

)

 

 

COUNTY OF MARION

)

 

ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

)

 

OF ENVIRONMENTAL MANAGEMENT,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case No. 2005-15299-S

 

 

)

 

JACKSON DAIRY FARM, INC.,

 

)

 

 

 

)

 

Respondent.

 

)

 

 

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 Jackson Dairy Farm, Inc. (“Respondent”), which owns and operates the confined feeding operation (“CFO”), CFO Approval No. AW-4775, located at 789 East Old Kokomo Road, in Marion, Grant 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 March 17, 2006, IDEM issued a Notice of Violation via Certified Mail to:

 

Robert Jackson, President and

Registered Agent

Jackson Dairy Farm, Inc.

789 East Old Kokomo Road

Marion, Indiana 46953

 

5.                  Inspections, on August 10 and 19, 2005, were conducted at the Site by representatives of IDEM’s Office of Land Quality (OLQ).  The following violations were in existence or observed at the time of these inspections:

 

6.         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.

 

Respondent caused and/or allowed the discharge of animal manure, an organic matter, from the Site on or about August 10, 2005, into waters of the state, in violation of 327 IAC 2-1-6, 327 IAC 2-6.1-7 and/or 327 IAC 5-2-2, and thus violated IC 13-18-4-5.

 

7.         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.

 

Respondent caused and/or allowed the discharge of animal manure, a contaminant or waste, into the environment from the Site on or about August 10, 2005, in violation of 327 IAC 2-1-6, 327 IAC 2-6.1-7 and/or 327 IAC 5-2-2, and thus violated IC 13-30-2-1(1).

 

8.         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.

 

Respondent operated and controlled a facility from which reportable spills of animal manure, an objectionable substance, occurred on or about August 10, 2005.  The Respondent failed to contain the spill and failed to undertake or cause others to undertake activities needed to accomplish a spill response until instructed to do so by IDEM personnel, in violation of 327 IAC 2-6.1-7.

 

9.         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 putrescent or otherwise 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.

 

Respondent caused and/or allowed the discharge of animal manure, a substance or material, from the Site on or about August 10, 2005, into waters of the state that settled to form putrescent or otherwise objectionable deposits and/or that was in an amount sufficient to be unsightly or deleterious and/or that produced color, visible oil sheen, odor, or other conditions in such degree to create a nuisance and/or was in amounts sufficient to be acutely toxic to, or otherwise severely injure or kill aquatic life, other animals, plants or humans and/or 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, in violation of 327 IAC 2-1-6(a)(1).

 

10.       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.

 

Respondent caused and/or allowed the discharge of animal manure, a pollutant, from the Site on or about August 10, 2005, into 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.

 

11.       Pursuant to 327 IAC 15-15-10(c), manure, litter, and process wastewater must be in an approved storage structure until removed for land application.

 

On or about August 19, 2005, the Respondent stored animal manure in an unapproved storage structure prior to land application, in violation of 327 IAC 15-15-10(c).

 

12.       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 327 IAC 2-6.1-7, 327 IAC 2-1-6, 327 IAC 5-2-2, IC 13-30-2-1, IC 13-18-4-5 and 327 IAC 15-15-10(c).

 

3.                  Within one (1) year of approval by IDEM and the Grant County Area Plan Commission, Respondent shall construct the modified manure management system and the process wastewater collection system described in the Confined Feeding Approval Application attached hereto and incorporated by reference at “Appendix A”.

 

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

 

Craig Henry, Enforcement Case Manager

Indiana Department of Environmental Management

Office of Enforcement – Mail Code 60-02

100 North Senate Avenue, Room 1315

Indianapolis, Indiana 46204-2251

 

5.         Respondent is assessed a civil penalty of Seven Thousand Eight Hundred ($7,800.00) Dollars.  Said penalty amount shall be due and payable to the Environmental Management Special Fund per the following:  Respondent shall make four (4) equal quarterly payments of One Thousand Nine Hundred Fifty Dollars ($1,950.00) each. The first installment of the civil penalty shall be due and payable to the Environmental Management Special Fund within thirty (30) days of the Effective Date of this Agreed Order.  Each subsequent installment shall be due in ninety (90) day intervals.

 

6.         In the event the terms and conditions of the following paragraph is 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

 

7.         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.

 

8.         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’s Office – Mail Code:  50-10C

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

9.         In the event that each installment payment of the civil penalty required by Order paragraph No. 5 is not paid on or before the due date, 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 payment is paid in full.

 

10.       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.

 

11.       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.

 

12.       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.

 

13.       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

 

Jackson Dairy Farm, Inc.

 

 

 

 

 

 

By:

______________________

 

By:

___________________

 

Janet Arnold, Section Chief

 

 

 

 

Solid Waste/UST Section

 

Printed:

___________________

 

Office of Enforcement

 

 

 

 

 

 

Title:

___________________

 

 

 

 

 

Date:

___________________

 

Date:

___________________

 

 

 

COUNSEL FOR COMPLAINANT:

 

COUNSEL FOR RESPONDENT:

Department of Environmental Management

 

 

 

 

 

By:

______________________

 

By:

____________________

 

Deputy Attorney General

 

 

 

 

 

 

 

 

 

 

 

 

 

Date:

______________________

 

Date:

____________________

 

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_________

DAY OF

__________________

, 2006

.

 

 

 

For the Commissioner:

 

 

 

Signed on January 22, 2007

 

Robert B. Keene

 

Assistant Commissioner

 

Office of Legal Counsel and Enforcement