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. 2006-15340-A, 2006-15341-A, 2006-15342-A, 2006-15343-A and

2006-15344-A

 

 

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BRUCE CARTER ASSOCIATES, LLC,

 

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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 Bruce Carter Associates, LLC ("Respondent"), which owns and operates an environmental consulting company, located at 6330 E. 75th Street, Suite 150, in Indianapolis, Marion County, Indiana and 733 Princeton Street in Elkhart, Elkhart County, Indiana.

 

3.                  Respondent provided consulting services including Phase I and/or Phase II Site Investigations at the Indiana Copper Corporation located at 666 Lincoln Blvd. in Marion, Grant County, Indiana (“Site 1”); the William H. Pfarrer Plating Company located at US Highway 35 South in Walton, Cass County, Indiana (“Site 2”); 66, 68, 70, 72-74 S. Broadway in Peru, Miami County, Indiana (“Site 3”); the Bront and Mafcote buildings located at 401 and 410 S. Carroll Street in Wabash, Wabash County, Indiana (“Site 4”); and Richardson’s Dry Cleaners located at 608 E. Broadway Street in Logansport, Cass County, Indiana (“Site 5”).  The services included inspection of the buildings for the presence, quantity and condition of asbestos containing materials.

 

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

 

5.                  The Respondent waives issuance of a Notice of Violation and to the settlement period of sixty (60) days as provided for by IC 13-30-3-3.

 

6.                  A records review was conducted of the Sites 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 326 IAC 18-1-3(a)(1), no person shall inspect for asbestos containing materials at a facility without current licensing by IDEM.

The Respondent used an inspector not currently licensed to perform asbestos inspections to inspect the facilities for asbestos on June 3, 2004 at Site 1, on January 26, 2005 at Site 2, on March 25, 2005, April 11, 2005 and May 25, 2005 at Site 3, on March 3, 2005 at Site 4 and on May 19, 2005 at Site 5, violations of 326 IAC 18-1-3(a)(1).

 

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 shall comply with 326 IAC 18-1.

 

3.                  Respondent shall send David King to a licensed training course provider to re-take the asbestos inspector course within sixty (60) days of the Effective Date of this Order.

 

4.                  Respondent shall re-apply to IDEM’s Asbestos Section for an asbestos inspector license for David King within fourteen (14) days after successful completion of the training course.

 

5.                  Respondent shall provide documentation of completion of paragraphs 3 and 4 within seventy-five (75) days of the Effective Date of this Order.

 

6.                  Respondent shall hire an independent licensed asbestos inspector or perform a thorough asbestos inspection pursuant to 326 IAC 14-10-1 of Site 1, Site 2 and Site 5 using a licensed asbestos inspector at Respondent’s expense within one-hundred and eighty (180) days of the Effective Date of this Order.

 

7.                  Respondent shall provide asbestos awareness training subject to IDEM approval and ensure all Respondent’s employees attend within one-hundred and eighty (180) days of the Effective Date of this Order.

 

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

Lynne Sullivan, Enforcement Case Manager
Indiana Department of Environmental Management

Office of Enforcement – Mail Code 60-02

100 North Senate Avenue
Indianapolis, IN  46204-2251

 

9.                  Respondent is assessed a civil penalty of Twelve Thousand Four Hundred Dollars ($12,400).  Said penalty amount shall be due and payable to the Asbestos Trust Fund within thirty (30) days of the Effective Date of this Agreed Order.

 

Violation                                                                      Penalty

Failure to comply with Order paragraph 3              $100 per week

Failure to comply with Order paragraph 4              $100 per week

Failure to comply with Order paragraph 5              $100 per week

Failure to comply with Order paragraph 6              $300 per week

Failure to comply with Order paragraph 7              $100 per week

 

10.             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:

 

11.             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.

 

12.             Civil and stipulated penalties are payable by check to the Asbestos Trust 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

 

1.                  In the event that the civil penalty required by Order paragraph 9 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.

 

2.                  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.

 

3.                  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.

 

4.                  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.

 

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

 

 

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TECHNICAL RECOMMENDATION:

RESPONDENT:

Department of Environmental Management

Bruce Carter Associates, LLC

 

 

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 on June 11, 2006

Matthew T. Klein

Assistant Commissioner for

Compliance & Enforcement