STATE OF INDIANA

COUNTY OF MARION

)
)
)


SS:

BEFORE THE INDIANA DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT,

Complainant,

v.

DAVE O’MARA CONTRACTOR, INC.,

Respondent.

)
)
)
)
)
)
)
)
)
)






Case No. 2008-17961-W




 

AGREED ORDER

 

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 Indiana Code (“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 Indiana created by Indiana Code (“IC”) 13-13-1-1.

 

2.                  Respondent is Dave O’Mara Contractor, Inc. (“Respondent”).  Respondent conducted business with the Town of Carthage (“Town”) as its contractor, to perform services to replace/repair drinking water lines in the Town on or about July 16, 2008.

 

3.                  Respondent was contracted by the Town to repair and/or replace drinking water lines near the drinking water plant, located on Main Street, Carthage, Rush County, Indiana, (the “Site”).  Respondent’s main office is located at 1100 O & M Avenue, North Vernon, Indiana.

 

4.                  IDEM has jurisdiction over the parties and subject matter of this action.

 

5.                  Pursuant to IC 13-30-3-3, on December 12, 2008, IDEM issued a Notice of Violation to the Town, Case No. 2008-17957-W and Respondent, Case No. 2008-17961-W, via Certified Mail to:

 

Rick Bush, Town Board President

Dave O’Mara, President

David J. O’Mara, Registered Agent

Town of Carthage

Dave O’Mara Contractor, Inc.

Dave O’Mara Contractor, Inc.

P. O. Box 26

P. O. Box 1139

1100 O & M Avenue

Carthage, IN 46115

North Vernon, IN 47265

North Vernon, IN 47265

 

6.                  The Town and Respondent have agreed that Respondent will resolve the issues identified herein by entry into this Agreed Order.  Therefore, the Notice of Violation previously issued to the Town, Case No. 2008-17957-W, will be dismissed.

 

7.                  During an investigation on July 16, 2008, conducted by representatives of IDEM and the Indiana Department of Natural Resources (“IDNR”), the following violations were found:

 

8.                  Pursuant to 327 Indiana Administrative Code (“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 National Pollutant Discharge Elimination System (“NPDES”) permit obtained prior to discharge.

 

9.                  Representatives of IDEM’s Office of Environmental Response and IDNR conducted an investigation of a release of an unknown amount of drinking water containing chlorine, which, at the time of the investigation, was being purged from the water lines by Respondent at the Site.  The chlorine contaminated water was discharged from the Site, flowed into the storm drain, into Carthage Creek, and then flowed to the Big Blue River.  Respondent failed to obtain a valid NPDES permit prior to discharging the chlorinated water into the waters of the State, in violation of 327 IAC 5-2-2.

 

10.             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 (2) hours of discovery, communicate a spill report to the Department of Environmental Management, Office of Environmental Response.

 

11.             A reportable spill of an unknown amount of the water containing pollutants discharged from the Site for an undetermined period of time; and was not properly contained; and/or responded to; and/or reported by Respondent; in violation of 327 IAC 2-6.1-7.

 

12.             On May 29, 2009, Respondent developed and submitted a Spill Response Plan (“SRP”) to IDEM for review in the event of future unpermitted discharges of chlorinated water related to purging of drinking water system lines, subject to a contract between Respondent and the Town for repair/replacement of the Town’s drinking water system lines.

 

13.             On June 10, 2009, IDEM approved the SRP, which is outlined in Attachment “A” of this Agreed Order.

 

14.             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.

 

15.             Respondent caused and/or allowed the discharge of the water containing pollutants in amounts sufficient to be classified as contaminants or waste from the Site into the environment, in violation of 327 IAC 2-6.1-7, and thus violating IC 13-30-2-1(1).

 

16.             Pursuant to 327 IAC 2-1-6(a)(1), the following are minimum water quality conditions, 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 to otherwise severely injure or kill aquatic life, other animals, plants or human.

(E)       which are in concentrations or combinations that will cause or contribute to the growth of aquatic plants or algae to such a degree as to create a nuisance, be unsightly, or otherwise impair the designated uses.

 

17.             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 Indiana; or 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 sections 1 and 3 of this chapter.

 

18.             An investigation by IDEM and IDNR revealed that the water containing pollutants, which was discharged from the Site, caused, or contributed to, the contamination of the waters of the State.  Specifically, approximately one hundred fifty (150) dead fish were observed downstream from the discharge point where the chlorinated water entered Carthage Creek, to where Carthage Creek flows to the Big Blue River, in violation of 327 IAC 2-1-6(a)(1), and thus violating IC 13-30-2-1(1) and IC 13-18-4-5.

 

19.             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 Complainant or Complainant’s delegate, and has been received by Respondent.  This Agreed Order shall have no force or effect until the Effective Date.

 

2.                  Respondent shall comply with statutes, rules, its SRP, and/or permit condition listed in the findings above at issue.

 

3.                  During activities where Respondent is contracted to perform services to repair/replace drinking water lines for the Town, Respondent shall take all necessary steps to prevent unpermitted discharges of chlorinated water into the environment, including waters of the State, from the portion of the public water supply distribution system that it has been designated to repair/replace.

 

4.                  The approved SRP, as noted in Findings of Fact Paragraphs 12 and 13 above and outlined in Attachment “A”, was submitted by Respondent, shall be incorporated into this Agreed Order and shall be deemed an enforceable part thereof.  Respondent shall immediately implement the approved SRP and adhere to the requirements contained therein.

 

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

 

Aletha Lenahan, Case Manager, Water Enforcement Section

Indiana Department of Environmental Management

Office of Water Quality – Mail Code 65-40

Room N1255, 100 North Senate Avenue

Indianapolis, IN 46204-2251

 

6.                  Respondent is assessed a civil penalty of Nine Thousand Dollars ($9,000).  Said penalty amount shall be due and payable to the Environmental Management Special Fund within forty-five (45) days of the Effective Date.  In the event that the civil penalty is not paid within forty-five (45) days of the Effective 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 civil penalty is paid in full.

 

7.                  Respondent shall make a separate payment of One Hundred Thirteen Dollars and Twenty-Four Cents ($113.24), in satisfaction of any liability for damage to Indiana’s natural resources.  Payment shall be made to the Indiana Department of Natural Resources (“IDNR”), under authority of IC 14-22-10-6, to the “Contaminants Account” within thirty (30) days of the Effective Date of this Agreed Order.  Respondent shall provide Complainant, at the address in Order Paragraph 5 above, with documentation of reimbursement, promptly upon payment to IDNR at the address below:

 

Attention to: Restoration Biologist

IDNR Division of Fish and Wildlife

Room W-273, IGCS

402 West Washington Street

Indianapolis, Indiana 46204

8.                  Civil penalties, as required by Order Paragraph 6 above, are payable by check to the Environmental Management Special Fund.  Payment shall include the Case Number “2008-17961-W”, of this action and shall be mailed to:

 

Cashiers Office – Mail Code 50-10C

Indiana Department of Environmental Management

100 N. Senate Avenue

Indianapolis, Indiana 46204-2251

 

9.                  This Agreed Order shall apply to and be binding upon Respondent and its successors and assigns.  Respondent’s signatories to this Agreed Order certify that they are fully authorized to execute this Agreed Order and legally bind the parties they represent.  No change in ownership, corporate, or partnership status of Respondent shall in any way alter it status or responsibilities under this Agreed Order.

 

10.             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.

 

11.             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 is not and shall not be interpreted to be a permit or a modification of an existing permit.  This Agreed Order, and IDEM’s review or approval of any submittal made by Respondent pursuant to this Agreed Order, shall not in any way relieve Respondent of their obligation to comply with the requirements of their applicable permit or any applicable Federal or State law or regulation.

 

13.             Complainant does not, by its approval of this Agreed Order, warrant or aver in any manner that Respondent’s compliance with any aspect of this Agreed Order will result in compliance with the provisions of any permit, order, or any applicable Federal or State law or regulation.  Additionally, IDEM or anyone acting on its behalf shall not be held liable for any costs or penalties Respondent may incur as a result of Respondent’s efforts to comply with this Agreed Order.

 

14.             Nothing in this Agreed Order shall prevent or limit IDEM’s rights to obtain penalties or injunctive relief under any applicable Federal or State law or regulation, except that IDEM may not, and hereby waives its right to, seek additional civil penalties for the same violations specified in the Notice of Violation.

 

15.             Nothing in this Agreed Order shall prevent IDEM, or anyone acting on its behalf, from communicating with the United State Environmental Protection Agency (“EPA”) or any other agency or entity about any matters relating to this enforcement action.  IDEM, or anyone acting on its behalf, shall not be held liable for any costs or penalties Respondent may incur as a result of such communications with EPA or any other agency or entity.

 

16.             This Agreed Order resolves any liability of the Town for any violations specified in the Notice of Violation and this Agreed Order.  Upon Respondent’s payment of the civil penalty, IDEM shall issue a Notice of Dismissal letter to the Town, Case No. 2008-17957-W, indicating that all violations specified in the Notice of Violation issued on December 12, 2008, and this Agreed Order, have been resolved.

 

17.             This Agreed Order shall remain in effect until Respondent has complied with Order Paragraphs 3 through 8, at which time IDEM will issue a Resolution of Case letter to Respondent.

 

Remainder of this page intentionally left blank.

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

Dave O’Mara Contractor, Inc.

 

By:

 

 

By:

 

 

Mark W. Stanifer, Chief

 

Printed:

 

 

Water Enforcement Section

 

Title:

 

 

Office of Water Quality

 

 

 

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

 

, 200

 

.

 

 

For The Commissioner:

 

 

Signed on August 20, 2009

 

Bruno Pigott

 

Assistant Commissioner

 

Office of Water Quality

 

ATTACHMENT A

SPILL RESPONSE PLAN

Water Line Replacement Work at Town of Carthage

 

1.                  The names and telephone numbers of persons who are identified by Respondent as responsible for implementing the Spill Response Plan:

Rob O’Mara

(812) 592-0736

Ted Westerman

(812) 592-1316

Clint Black

(812) 592-0523

 

2.                  Identification of areas where potential spills can occur and their accompanying drainage points:

Work for the Town of Carthage may involve the replacement, repair, or construction of water lines.  After completion of construction, the lines must be disinfected to make them potable.  During the disinfection of water mains, chlorine is used and circulated through the main.  The disinfection water is then typically removed via a hydrant.

Spills could potentially occur at the hydrant(s) and insertion points for chlorine.  Possible drainage points of spills will be storm sewers and sanitary sewer drains, ditches and streams, or other private property.

 

3.                  Procedures to follow in the event of a spill:

Actions to contain or manage any type of spill:

 

Turn off pumps and flow of water.

Create dikes or berms to prevent flow into surface waters.

Employ absorbent material.

Employ dechlorination solution.

Review MSDS of spilled material.

Identify On-Scene Commander.

 

After cleanup, collect spent absorbent material and place it into a leak proof container or bag labeled with the contents and data.  Consult with regular waste handler for specific disposal requirements, which shall include any required waster characterization.

 

Identification of proper authorities to be contacted:

 

IDEM

(888) 233-7745

Rush County Emergency Management Agency

(765) 932-8391

Town of Carthage Fire Department

(765) 565-1234

 

In case of a large spill contact:

 

Midwest Environmental Services, Inc.

(877) 999-7745

 

Mitigation of any adverse affects of the spill:

 

Check for possible health impacts to nearby persons, if any.

Identify impacted ground and surface waters, if any.

Employ dechlorination equipment to treat impacted water.

 

4.                  Identification of equipment and clean up materials to be used in the event of a spill:

Equipment necessary for a particular release will vary, but may include:

Absorbent material.

Dechlorination equipment:  solution and mixing device.

Pipefitting tools.

Shovels.

Excavator.

 

5.                  Procedures for reporting the spill to:

A.                 Any applicable local emergency or health authorities:

 

Contact above local contacts as necessary.

 

B.                 IDEM, in accordance with 327 IAC 2-6.1.

 

Ascertain whether a reportable spill has occurred

If necessary, contact IDEM within two (2) hours