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STATE
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BEFORE THE INDIANA DEPARTMENT |
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COMMISSIONER OF THE DEPARTMENT Complainant, v. EXIDE TECHNOLOGIES, INC., Respondent. |
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AGREED ORDER
The Complainant and
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 (“IDEM”), a department of the State of
2. Respondent
is Exide Technologies, Inc. ("Respondent"), which owns and operates
the company with U.S. EPA ID No.
3. 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 on June 23rd,
2006 via Certified Mail to:
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Craig H. Mulhauser |
CT Corporation System |
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President |
Registered Agent for: |
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Exide Technologies, Inc. |
Exide Technologies, Inc. |
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210 Carnegie Center, |
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5. Pursuant
to IC 13-30-3-3, IDEM issued a second Notice of Violation on December 11, 2006
via Certified Mail to:
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Mr. Gordon Ulsh |
CT Corporation System |
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President |
Registered Agent for: |
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Exide Technologies, Inc. |
Exide Technologies, Inc. |
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210 Carnegie Center, |
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6. Respondent
most recently notified the U.S. EPA of Large Quantity Generator and Treatment,
Storage, and Disposal activities on February 24, 2006. Respondent was issued a hazardous waste
permit renewal for storage on November 16, 2004.
7. Respondent
is a secondary lead smelter. Lead is
reclaimed from lead-acid batteries and other lead bearing material.
8. 329
IAC 3.1 incorporates certain federal hazardous waste management requirements
found in 40 CFR Parts 260 through 273, including those identified below.
9. During
an investigation, including inspections on January 24, 2006, June 23 and 28,
2006, and September 21, 2006, conducted by representatives of IDEM, the
following violations were found:
a. Pursuant
to 262.34(a)(2), a generator may accumulate hazardous waste on-site for 90 days
or less without a permit, provided that the date when the accumulation begins
is clearly marked and visible for inspection on each container. The following containers were not labeled
with accumulation start dates:
1. One
container of K069 baghouse dust located underneath the scrubbers. This
violation was observed during the January 24, 2006 inspection.
2. Two
trailers (No. 370322 and CT4) of D008 waste located in the trailer storage
lot. This violation was observed during
the June 2006 inspections.
3. Three
roll-offs of D008 waste located in the trailer storage lot. This violation was observed during the June
2006 inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has implemented a
new labeling procedure whereby all trailers and roll offs are labeled as
“Hazardous Waste” with accumulation start dates as soon as waste is placed in
them. Once lab results are obtained
indicating the regulatory status of the waste, the labels are either updated
with the manifest document number when shipped, or, if non-hazardous, removed.
b. Pursuant
to 40 CFR 262.34(a)(3), a generator may accumulate hazardous waste on-site for
90 days or less without a permit, provided that containers are labeled or marked clearly with the words
“Hazardous Waste.” The following
containers were not marked with the words “Hazardous Waste.”
1. One
container of K069 baghouse dust located underneath the scrubbers. This
violation was observed during the January 24, 2006 inspection.
2. Two
trailers (No. 370322 and CT4) of D008 waste located in the trailer storage
lot. This violation was observed during
the June 2006 inspections.
3. Three
roll-offs of D008 waste located in the trailer storage lot. This violation was observed during the June
2006 inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has implemented a
new labeling procedure whereby all trailers and roll offs are labeled as
“Hazardous Waste” with accumulation start dates as soon as waste is placed in
them. Once lab results are obtained
indicating the regulatory status of the waste, the labels are either updated
with the manifest document number when shipped, or, if non-hazardous, removed.
c. Pursuant
to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.173(a), a container holding
hazardous waste must always be closed during storage, unless necessary to add
or remove waste. Respondent did not
store closed a container of K069 baghouse located underneath a scrubber. This violation was observed during the
January 24, 2006 inspection.
d. Pursuant
to 262.34(a)(1)(i) referencing 40 CFR 265.174, a generator must conduct weekly
inspections of container storage areas.
Respondent did not conduct the required weekly inspections of the
following containers:
1) Trailer 3703223, which is located in
the trailer storage lot.
2) Trailer CT4, which is located in the
trailer storage lot.
3) Three roll-offs located in the trailer
storage lot.
This
violation was observed during the June 2006 inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that all container storage
areas are now inspected weekly.
e. Pursuant
to Permit Conditions IV.E.1 and Attachment D-10a(1), owners and operators of
all containment buildings must use controls and practices to ensure containment
of the hazardous waste within the unit.
Specifically, the storage capacity for Bin 5 must not exceed a maximum
capacity of 800 cubic yards. Respondent
accumulated blast slag in Bin 5 beyond its capacity. The Waste Pile Quantity and the Waste Pile
Inspection Logs showed that between 1,270 and 1,315 cubic yards of blast slag
was stored in and outside of Bin 5. This
violation was observed during the June 2006 and September 2006 inspections.
In a March 2, 2007 letter to IDEM, Respondent indicated that on January 2,
2007, the amount of waste stored in Bin 5 was reduced below the capacity limit
of 800 cubic yards.
f. Pursuant
to Permit Condition IV.H and Appendix F-8, upon detection of a condition that
has led to a release of hazardous waste, the owner or operator must enter of
record of discovery in the facility operating record. During the June 2006 inspections, Respondent
stated that repair work being conducted on the crusher caused the excess
accumulation of blast slag in and around Bin 5.
However, this condition was not noted in the facility operating record.
In a March 2, 2007 letter to IDEM, Respondent indicated that personnel responsible
for inspecting the Containment Area have been given additional training to
ensure that malfunctions and deficiencies are noted on inspection logs.
g. Pursuant
to Permit Condition II.E, containment buildings must be inspected weekly using
the Containment Building Inspection Log (Exhibit F-8 of the permit). Respondent has not conducted the inspections
listed in the Containment Building Inspection Log, and four facility personnel
who are responsible for inspections were not familiar with the log. This violation was observed during the June
2006 inspections.
In a March 2, 2007 letter to IDEM, Respondent indicated that the containment
building is now inspected on a weekly basis using the inspection logs found in
Exhibit F-8 of the permit.
h. Pursuant
to Permit Condition II.A., Permit Condition IV.D, and 262.34(a)(4) referencing
40 CFR 265.31, the facility must be maintained and operated to minimize the
possibility of a fire, explosion, or any unplanned sudden or non-sudden release
of hazardous waste or hazardous waste constituents to air, soil, or surface
water, which could threaten human health or the environment. Respondent failed to operate the facility in
a manner that minimizes releases to the environment. The inspector observed the following evidence
of failures to maintain the facility to minimize the possibility of releases:
1. D008
press mud throughout the outdoor areas of the facility including in the slag
and chip trailer storage areas; outside the wastewater treatment area; along
the rail spur; underneath the scrubbers and baghouses; in the entrances into
the maintenance area; and in the chemical storage area on the northeast side of
the property. These violations were
observed during the January 24, 2006 and June 2006 inspections.
2. Heavy
tracking of D008 press mud and dust in Storage Area A. This violation was observed during the
September 21, 2006 inspection.
3. Releases
of Soda Ash at the off-loading area and along the rail spur. This violation was observed during the January
24, 2006 and June 2006 inspections.
4. Releases
of baghouse dust (K069) on the ground under the scrubbers, baghouses, and at
the sump near the tank farm.
5. Sodium
sulfate present on the top of two oxidation tanks, on the exterior of the
tanks, and on the ground. This violation
was observed during the January 24, 2006 inspection.
6. Blast
furnace slag placed outside of the designated bin (Bin 5) caused a major breach
in the integrity of the floor located just south of Bin 5 at the eastern edge
of the Phase II section of the Bin Room Floor.
This violation was observed during the June 2006 and September 21, 2006
inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has cleaned all
exterior concrete surfaces outside the plant of any residual D008 press mud
track-out or spillage.
i. 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 caused or allowed the disposal of
solid waste in a manner which creates a threat to human health or the environment. The inspector observed the following evidence
of the disposal of solid waste in a manner creating a threat to human health or
the environment:
1. D008
press mud throughout the outdoor areas of the facility including in the slag
and chip trailer storage areas; outside the wastewater treatment area; along
the rail spur; underneath the scrubbers and baghouses; in the entrances into
the maintenance area; and in the chemical storage area on the northeast side of
the property. These violations were observed
during the January 24, 2006 and June 2006 inspections.
2. Heavy
tracking of D008 press mud and dust in Storage Area A. This violation was observed during the
September 21, 2006 inspection.
3. Releases
of Soda Ash at the off-loading area and along the rail spur. This violation was observed during the
January 24, 2006 and June 2006 inspections.
4. Releases
of baghouse dust (K069) on the ground under the scrubbers, baghouses, and at
the sump near the tank farm.
5. Sodium
sulfate present on the top of two oxidation tanks, on the exterior of the
tanks, and on the ground. This violation
was observed during the January 24, 2006 inspection.
6. Blast
furnace slag placed outside of the designated bin (Bin 5) caused a major breach
in the integrity of the floor located just south of Bin 5 at the eastern edge
of the Phase II section of the Bin Room Floor.
This violation was observed during the June 2006 and September 21, 2006
inspections.
In
a February 28, 2007 letter to IDEM, Respondent indicated that it has cleaned
all exterior concrete surfaces outside the plant of any residual D008 press mud
track-out or spillage.
j. Pursuant
to IC 13-30-2-1(1), no person shall 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.
Respondent caused and allowed the discharge of contaminants and waste
into environment. The inspector observed
the following evidence of discharges to the environment:
1. D008
press mud throughout the outdoor areas of the facility including in the slag
and chip trailer storage areas; outside the wastewater treatment area; along
the rail spur; underneath the scrubbers and baghouses; in the entrances into
the maintenance area; and in the chemical storage area on the northeast side of
the property. These violations were
observed during the January 24, 2006 and June 2006 inspections.
2. Heavy
tracking of D008 press mud and dust in Storage Area A. This violation was observed during the
September 21, 2006 inspection.
3. Releases
of Soda Ash at the off-loading area and along the rail spur. This violation was observed during the January
24, 2006 and June 2006 inspections.
4. Releases
of baghouse dust (K069) on the ground under the scrubbers, baghouses, and at
the sump near the tank farm.
5. Sodium
sulfate present on the top of two oxidation tanks, on the exterior of the
tanks, and on the ground. This violation
was observed during the January 24, 2006 inspection.
6. Blast
furnace slag placed outside of the designated bin (Bin 5) caused a major breach
in the integrity of the floor located just south of Bin 5 at the eastern edge
of the Phase II section of the Bin Room Floor.
This violation was observed during the June 2006 and September 21, 2006
inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has cleaned all
exterior concrete surfaces outside the plant of any residual D008 press mud
track-out or spillage.
k. 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.
Respondent deposited contaminants upon the land in a place or manner
that creates a pollution hazard. The
inspector observed the following evidence of the deposit of contaminants upon
the land:
1. D008
press mud throughout the outdoor areas of the facility including in the slag
and chip trailer storage areas; outside the wastewater treatment area; along
the rail spur; underneath the scrubbers and baghouses; in the entrances into
the maintenance area; and in the chemical storage area on the northeast side of
the property. These violations were
observed during the January 24, 2006 and June 2006 inspections.
2. Heavy
tracking of D008 press mud and dust in Storage Area A. This violation was observed during the
September 21, 2006 inspection.
3. Releases
of Soda Ash at the off-loading area and along the rail spur. This violation was
observed during the January 24, 2006 and June 2006 inspections.
4. Releases
of baghouse dust (K069) on the ground under the scrubbers, baghouses, and at
the sump near the tank farm.
5. Sodium
sulfate present on the top of two oxidation tanks, on the exterior of the
tanks, and on the ground. This violation
was observed during the January 24, 2006 inspection.
6. Blast
furnace slag placed outside of the designated bin (Bin 5) caused a major breach
in the integrity of the floor located just south of Bin 5 at the eastern edge
of the Phase II section of the Bin Room Floor.
This violation was observed during the June 2006 and September 21, 2006
inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has cleaned all
exterior concrete surfaces outside the plant of any residual D008 press mud
track-out or spillage.
l. Pursuant
to IC 13-30-2-1(4), no person shall deposit or cause or allow the deposit of
any 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 allowed the deposit of
contaminants and solid waste upon the land.
The inspector observed the following evidence of the deposit of
contaminants and solid waste upon the land:
1. D008
press mud throughout the outdoor areas of the facility including in the slag
and chip trailer storage areas; outside the wastewater treatment area; along
the rail spur; underneath the scrubbers and baghouses; in the entrances into
the maintenance area; and in the chemical storage area on the northeast side of
the property. These violations were
observed during the January 24, 2006 and June 2006 inspections.
2. Heavy
tracking of D008 press mud and dust in Storage Area A. This violation was observed during the
September 21, 2006 inspection.
3. Releases
of Soda Ash at the off-loading area and along the rail spur. This violation was
observed during the January 24, 2006 and June 2006 inspections.
4. Releases
of baghouse dust (K069) on the ground under the scrubbers, baghouses, and at
the sump near the tank farm.
5. Sodium
sulfate present on the top of two oxidation tanks, on the exterior of the
tanks, and on the ground. This violation
was observed during the January 24, 2006 inspection.
6. Blast
furnace slag placed outside of the designated bin (Bin 5) caused a major breach
in the integrity of the floor located just south of Bin 5 at the eastern edge
of the Phase II section of the Bin Room Floor.
This violation was observed during the June 2006 and September 21, 2006
inspections.
In
a March 2, 2007 letter to IDEM, Respondent indicated that it has cleaned all
exterior concrete surfaces outside the plant of any residual D008 press mud
track-out or spillage.
m. Pursuant
to Permit Condition II.I.3 and Attachment G, the Permittee shall review and
immediately amend, if necessary, the Contingency Plan. The two latest revisions to Respondent’s
Contingency Plan did not accurately reflect facility conditions. Specifically, the December 2, 2005 Contingency
Plan did not contain current information regarding the crusher/stabilization
unit and reverberatory furnace slag. The
Contingency Plan reviewed by the inspector during the June 2006 inspection also
contained inaccurate information on the crusher/stabilization unit, and did not
refer to reverberatory furnace slag at all.
This violation was noted during the June 2006 inspections.
In a March 2, 2007 letter to IDEM, Respondent indicated that it revised the
Contingency Plan. On January 9, 2007,
Exide submitted a permit modification to reflect current facility conditions in
the Contingency Plan.
9. 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. Upon
the Effective Date of this Agreed Order, Respondent shall comply with 40 CFR
262.34(a)(2). Specifically, Respondent
shall ensure that all containers of hazardous waste are marked with
accumulation start dates.
3. Upon
the Effective Date of this Agreed Order, Respondent shall comply with 40 CFR
262.34(a)(3). Specifically, Respondent
shall ensure that all containers of D008 waste are marked with the words
“Hazardous Waste.”
4. Upon
the Effective Date of this Agreed Order, Respondent shall comply with 40 CFR
265.173(a). Specifically, Respondent
shall ensure that all containers of hazardous waste are stored closed.
5. Upon
the Effective Date of this Agreed Order, Respondent shall comply with 40 CFR
265.174. Specifically, Respondent shall
ensure that it conducts weekly inspections of the all hazardous waste container
storage areas.
6. Upon
the Effective Date of this Agreed Order, Respondent shall comply with Permit
Condition II.E and Permit Condition IV.H.
Specifically, Respondent shall ensure that containment buildings are
inspected on a weekly basis and that the facility inspection logs (Exhibit F-8
of the permit) are used during the inspections.
7. Upon
the Effective Date of this Agreed Order, Respondent shall ensure that all
malfunctions and deficiencies are noted on inspection logs.
8. Upon
the Effective Date of this Agreed Order, Respondent shall comply with Permit
Condition IV.E.1 and Attachment D-10a(1).
Specifically, Respondent shall not store wastes in Bin 5 in excess of
the permitted capacity of 800 cubic yards.
9. Upon
the Effective Date of this Agreed Order, Respondent shall not store blast
furnace slag outside the containment walls of Bin 5.
10. Within
ninety (90) days of the Effective Date of this Agreed Order, Respondent shall
comply with Permit Condition II.A; IV.D; 40 CFR 265.31; 329 IAC 10-4-2; and IC 13-30-2-1(1), (3), and (4). Specifically, Respondent shall clean up the
following:
a. All
releases of the D008 press mud throughout the indoor areas of the facility,
including in Storage Area A.
b. All releases of Baghouse Dust.
c. All
releases of Soda Ash, including in the off-loading area and along the rail
spur.
d. All
releases of Sodium Sulfate in the area of the oxidation tanks and on the
ground.
For areas where releases and track-out are present on soil, Respondent shall
excavate soil to six inches beyond visible contamination.
11. Within
one hundred twenty (120) days of the Effective Date of this Agreed Order,
Respondent shall submit to IDEM documentation that releases and track-out of
the D008 press mud, Baghouse Dust, Soda Ash, and Sodium Sulfate have been
cleaned up.
12. Upon
the Effective Date of this Agreed Order, Respondent shall comply with Permit
Conditions II.A and IV.D. Specifically,
Respondent shall implement procedures to ensure that releases and track-out of
D008 press mud do not occur.
13. Within
ninety (90) days of the Effective Date of this Agreed Order, Respondent shall
submit to IDEM a detailed written description of procedures that have been implemented
to eliminate releases and track-out of D008 press mud inside and outside of the
facility.
14. Upon
the Effective Date of this Agreed Order, Respondent shall comply with IC
13-30-2-1(4). Specifically, Respondent
shall implement procedures to prevent the release of Soda Ash at the
off-loading area and along the rail spur.
15. Within
ninety (90) days of the Effective Date of this Agreed Order, Respondent shall
submit to IDEM a detailed written description of procedures that have been
implemented to eliminate the release of Soda Ash at the off-loading area and
along the rail spur.
16. All
submittals required by this Agreed Order, unless notified otherwise in writing,
shall be sent to:
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Aubrey N. Sherif |
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Senior Environmental
Manager |
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Indiana Department of
Environmental Management |
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Office of Enforcement Mail Code 60-02 |
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17. Respondent
is assessed a civil penalty of Sixty Two Thousand Two Hundred Fifty Dollars
($62,250). Within thirty (30) days of
the Effective Date of the Agreed Order, Respondent shall pay a portion of this
penalty in the amount of Twelve Thousand Four Hundred Fifty Dollars
($12,450). 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 One Hundred Sixty Thousand Dollars ($160,000). 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 Ninety-Nine Thousand Six Hundred Dollars
($99,600), Respondent shall pay fifty
percent (50%) of the difference between the proposed cost of the SEP and the
actual cost of the SEP.
18. As a
Supplemental Environmental Project, Respondent shall construct a dedicated
Clarifier and Scrubber Sludge Recapturing System. The SEP will involve the conversion of a
current water treatment tank into a sludge thickening tank, which requires a
modification creating a still well and discharge weir within the tank. Respondent will also purchase and install a
dedicated press filter to recover the sludge; piping and pumps to create an
adjunct to the current closed system and route the sludge to the converted tank
and new filter press; and control circuits to activate the system
automatically. Respondent shall have the
SEP constructed and operational by no later than December 30, 2007. Implementation of this SEP will reduce the
loading on the Waste Water Treatment (WWT) system’s sand filters and the
potential for filter media breakthrough.
This reduction will increase the efficiency of the sand filters and
extend the effective life of the filter media within them. A secondary reduction of waste will also be
realized by the less frequent need to dispose of the used filter media and
repack the filters with fresh sand. The tertiary benefit of this aspect of the
project is a reduction in the trace lead and antimony currently discharged into
Respondent’s waste stream. The SEP will
also increase the WWT system’s chemical precipitation efficiency while reducing
the total amount of pre-treatment chemicals used, which will also result in a
net decrease of those treatment chemicals in the waste stream.
In the event that the Respondent does not complete the SEP by December 30,
2007, the full amount of the civil penalty as stated in paragraph 17 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.
19. In the
event the terms and conditions of the following paragraphs are violated, the
Complainant may assess and Respondent shall pay a stipulated penalty in the
following amount:
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Violation |
Penalty |
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Failure to comply with
Order paragraph 11 |
$500 per week |
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Failure to comply with
Order paragraph 13 |
$500 per week |
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Failure to comply with
Order paragraph 15 |
$500 per week |
20. 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 Complainant from seeking any additional
relief against Respondent for violation of this Agreed Order. In lieu of any of the stipulated penalties
given above, 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.
21. 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:
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Indiana Department of
Environmental Management |
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Cashier’s Office Mail Code 50-10C |
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22. In the
event that the civil penalty required by Order paragraph 17 is not paid within
thirty (30) days of the Effective Date of this Agreed Order, Respondent shall
pay interest shall continue to accrue until the civil penalty is paid in full.
23. This
Agreed Order shall apply to and be binding upon Respondent, its successors and
assigns. 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 Respondent shall in any way alter its
status or responsibilities under this Agreed Order.
24. In the
event that any terms of this 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 this Agreed Order did not contain the invalid terms.
25. 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.
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Nancy L. Johnston |
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Section Chief |
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Title: |
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Office
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COUNSEL
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COUNSEL
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For
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By: |
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By: |
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Deputy
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Date: |
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APPROVED
AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL |
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MANAGEMENT THIS |
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For
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Signed
on June 5, 2007 |
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Robert
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Assistant
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Office
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