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. 2006-15396-A

 

 

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CREATIVE FOAM CORPORATION,

 

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d/b/a BREMEN CORPORATION

 

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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 Creative Foam Corporation d/b/a Bremen Corporation ("Respondent"), which owns and operates the facility with Plant ID No. 099-00033, located at 405 North Industrial Drive, in Bremen, Marshall 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 May 12, 2006, IDEM issued a Notice of Violation via Certified Mail to:

 

Mr. Gerald L. Whitten, President

Mr. James J. Smith, Registered Agent

for Creative Foam Corporation

Creative Foam Corporation

d/b/a Bremen Corporation

300 North Alloy Drive

Fenton, MI 48430

d/b/a Bremen Corporation

405 North Industrial Drive

Bremen, IN 46506

 

5.                  An inspection on December 8, 2006, was conducted at the Site by a representative of IDEM’s Office Air Quality (OAQ).  The following violations were in existence or observed at the time of this inspection:

 

a.                  Pursuant to Paragraph No. D.1.8 of Second SSM No. 099-20282-00033 (“Permit”) issued on November 30, 2005, during the period between 30 and 36 months after September 14, 1999, Respondent shall perform testing on the catalytic oxidizer to determine the overall VOC control efficiency (capture and destruction). Testing of the catalytic oxidizer shall be repeated at least once every two and one half (2.5) years for overall control efficiency using methods approved by the Commissioner.

 

b.                  Respondent failed to conduct the Oxidizer #1 testing within the time required in the Permit, while continuing operating it in violation of Paragraph No. D.1.8 of the Permit.

 

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 permit condition which Respondent was found to be in violation.

 

3.                  Respondent is assessed a civil penalty of Nine Thousand Dollars ($9,000).  Within thirty (30) days of the Effective Date of the Agreed Order, Respondent shall pay a portion of this penalty in the amount of One Thousand Eight Hundred Dollars ($1,800). 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 at least Twenty One Thousand Six Hundred dollars ($21,600).  Within 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 Twenty One Thousand Six Hundred dollars ($21,600), Respondent shall pay thirty three percent (33%) of the difference between the estimated cost of the SEP, Twenty One Thousand Six Hundred dollars ($21,600) and the actual cost of the SEP.

 

As a Supplemental Environmental Project, Respondent shall pave approximately 34,020 square feet of existing crushed stone on the west side of the property.  Respondent shall begin by cleaning the existing asphalt and grading the gravel parking area.  The new parking area will be paved with three and a half inches of base mix and one and a half inches of surface asphalt.  The existing paved parking lot will be covered with one and a half inches of surface asphalt.  Each layer will be thoroughly compacted with a roller.  Implementation of this SEP will control fugitive dust emissions.

 

4.                  In the event that the Respondent does not complete the SEP by August 31, 2007, the full amount of the civil penalty as stated in paragraph three (3) 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.

 

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

Edward Judson, Enforcement Case Manager
Indiana Department of Environmental Management

Office of Enforcement – Mail Code 60-02

100 North Senate Avenue
Indianapolis, IN  46204-2251

 

 

6.                  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

$100 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 the portion of the civil penalty required by Order paragraph 3 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.

 

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 complies with the terms of Order paragraph No. 3 or pays in full any remaining portion of the civil penalty plus interest for which Respondent receives notice to pay pursuant to Order paragraph No. 4.

 

TECHNICAL RECOMMENDATION:

RESPONDENT:

Department of Environmental Management

 

 

 

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 November 6, 2006

Matthew T. Klein

Assistant Commissioner for

Compliance & Enforcement