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,

Complainant,

v.

LAKE LASALLE PROPERTY
OWNERS ASSOCIATION, INC.,

Respondent.

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Case No. 2009-18336-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 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 owns and/or operates a construction project at Lake LaSalle located at the intersection of Lake LaSalle Road and Three Story Hill Road, Morgantown, Brown County, Indiana (the “Site”).  The construction project at the Site consists of land disturbance of approximately 2.28 acres within Lake LaSalle, and the installation of two (2) weir structures within the Big Thunder Creek and Lawrence Creek branches of Lake LaSalle.  In addition, more than one (1) acre of dredged material was placed in an upland ravine, in tributaries of Big Thunder Creek, and adjacent to Big Thunder Creek.

 

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

 

4.                  Pursuant to IC 13-30-3-3, May 22, 2009, IDEM issued a Notice of Violation via Certified Mail to:

 

Charles Backofen, President

Linda Schwaner, Registered Agent

Lake LaSalle Property Owners Association, Inc.

Lake LaSalle Property Owners Association, Inc.

8465 N. LaSalle Road

970 Keyhole Cove

Morgantown, IN 46160

Greenwood, IN 46142

 

5.                  During an investigation on October 28, 2008, conducted by representatives of IDEM, the following violations were found:

 

6.                  Pursuant to 327 Indiana Administrative Code (“IAC”) 2-1.5-2 and Indiana Code (“IC”) 13-11-2-265(a), “Waters”, for purposes of water pollution control laws and environmental management, means:

 

(1)               the accumulation of water, surface and underground, natural and artificial, public and private; or

(2)               a part of the accumulations of waters of the State, that are wholly or partially within, flow through, or border upon Indiana.  The term “waters” does not include:

a.                   an exempt isolated wetland;

b.                  private pond; or

c.                   an off-stream pond, reservoir, wetland, or other facility built for reduction or control of pollution or cooling of water before discharge.

(3)               The term includes all waters of the United States, as defined in Section 502(7) of the federal Clean Water Act [33 United States Code (“USC”) 1362(7)], that are located in Indiana.

 

7.                  During the construction project, Respondent conducted regulated activities at the Site.  Specifically, Respondent discharged dredged or fill material into unnamed tributaries of Big Thunder Creek and Lawrence Creek branches of Lake LaSalle.  The Site is classified by the United States Army Corps of Engineers (“USACE”), as jurisdictional streams, and is considered waters of the State, as defined by IC 13-11-2-265(a).

 

8.                  Pursuant to Section 404 of the Clean Water Act (33 USC 1341),  which provides for IDEM to administer its own 401 Water Quality Certification Program for construction projects that impact a wetland, the 401 Water Quality Certification outlines compensation requirements for the loss of wetland use including the restoration success criteria, deed restriction, and a Monitoring Plan.  Filling of waters of the United States (and waters of the State of Indiana) is prohibited unless the responsible party has applied for and obtained the appropriate permit and water quality certification in advance.

 

9.                  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 National Pollutant Discharge Elimination System (“NPDES”) permit obtained prior to discharge.  327 IAC 5-2-4(2) excludes from regulation a site for which a permit has been issued under Section 404 of the Clean Water Act (33 USC 1341).

 

10.             On or about October 28, 2008, IDEM’s representatives discovered that Respondent caused and/or contributed to cause earthen fill material to enter waters of the State by filling streams and dredging areas at the Site.  Respondent discharged earthen fill material into waters of the State without first obtaining a valid 404 Permit and Section 401 Water Quality Certification, in violation of 404 Permit and Section 401 Water Quality Certification requirements and 327 IAC 5-2-2.

 

11.             On January 15, 2009, IDEM issued a denial of Section 401 Water Quality Certification, which referenced IDEM’s December 16, 2008 violation letter that outlined Respondent’s deficient Section 401 Water Quality Certification application dated September 30, 2008.

 

12.             On July 24, 2009, Respondent submitted its complete application for Section 401 Water Quality Certification requesting after-the-fact authorization for the dredging of accumulated sediment, installation of two concrete weir structures in the upper reaches of Lake LaSalle, and installation of a drainage pipe in a tributary of Lawrence Creek, as required by Section 401 of the Water Quality Certification.

 

13.             On October 9, 2009, IDEM issued the Section 401 Water Quality Certification after-the-fact authorization to mitigate the impact that was caused by the dredging project at the Site, IDEM No. 2009-391-07-DDC-V, and USACE No. LRL-2008-971-lcl, in accordance with the 404 Permit and Section 401 Water Quality Certification requirements and 327 IAC 5-2-2.

 

14.             Pursuant to 327 IAC 15-5-1, the purpose of this rule is to establish requirements for stormwater discharges from construction activities of one (1) acre or more so that public health, existing water uses, and aquatic biota are protected.

 

15.             Pursuant to 327 IAC 15-3-3, any person proposing a new discharge that will be subject to a general permit rule shall submit a notice of intent (“NOI”) letter and additional information as required by the applicable general permit rule at least one hundred eighty (180) days before the date on which the discharge is to commence unless permission for a later date has been granted by the commissioner or is established in the applicable general permit rule.  A construction activity NOI letter shall be submitted in accordance with

327 IAC 15-5-6.

 

16.             Pursuant to 327 IAC 15-5-2, the requirements of 327 IAC 15-5, apply to all persons who do not obtain an individual NPDES Permit under 327 IAC 15-2-6; meet the general permit rule applicability requirements under 327 IAC 15-2-3; and are involved in construction activity that includes clearing, grading, excavation, and other land disturbing activities, except operations that result in the disturbance of less than one (1) acre of total land area, and that are not, part of a larger common plan of development or sale.

 

17.             Respondent did not submit a NOI letter and was not authorized under the NPDES General Permit Rule, to hold a General Permit, for stormwater discharges associated with construction activity, in violation of 327 IAC 15-3-3 and 327 IAC 15-5-2.

 

18.             On August 11, 2009, Respondent submitted its NOI letter for the required Site stabilization plan, as required by 327 IAC 15-3-3 and 327 IAC 15-5-2.

 

19.             On November 6, 2009, IDEM issued a Notice of Sufficiency letter that authorized Respondent’s construction activity at the Site under general stormwater permit No. INR10B506, which is due to expire on August 11, 2014, as required by 327 IAC 15-3-3 and 327 IAC 15-5-2.

 

20.             Pursuant to 327 IAC 15-5-6(b), for a project site where the proposed land disturbance is one (1) acre or more as determined under section 2 of this rule, the following requirements must be met:

 

(1)               A construction plan must be submitted according to the following:

(A)               Prior to the initiation of any land disturbing activities.

(B)              Sent to the appropriate Soil Water Conservation District (“SWCD”) or other entity designated by the department for:

(i)                 review and verification that the plan meets the requirements of the rule; or

(ii)               a single coordinated review in accordance with subsection (d)(3) if:

(AA)          the construction activity will occur in more than one (1) SWCD; and

(BB)         the project site owner has made a request for a single coordinated review.

(2)               If the construction plan required by subdivision (1) is determined to be deficient, the Brown County SWCD, or other entity designated by the department as the reviewing agency, may require modifications, terms, and conditions as necessary to meet the requirements of the rule. The initiation of construction activity following notification by the reviewing agency that the plan does not meet the requirements of the rule is a violation and subject to enforcement action.

 

21.             Respondent failed to submit a construction plan to SWCD, or other entity designated by the department, prior to commencing land disturbing activities at the Site, in violation of 327 IAC 15-5-6(b).

 

22.             Pursuant to 327 IAC 15-5-4 (32), “sedimentation” means the settling and accumulation of unconsolidated sediment carried by stormwater run-off.

 

23.             Pursuant to 327 IAC 15-5-7(a), all stormwater quality measures and erosion and sediment controls necessary to comply with this rule must be implemented in accordance with the construction plan sufficient to satisfy subsection (b).

 

24.             Pursuant to 327 IAC 15-5-7(b)(1), a project owner shall, at least meet the following requirement: sediment-laden water, which otherwise would flow from the project site, shall be treated by erosion and sediment control measures appropriate to minimize sedimentation.

 

25.             Pursuant to 327 IAC 15-5-7(b)(5), stormwater run-off leaving a project site must be discharged in a manner that is consistent with applicable State or federal law.

 

26.             Pursuant to 327 IAC 15-5-7(b)(8), the stormwater pollution prevention plan (“SWP3”) shall serve as a guideline for stormwater quality, but should not be interpreted to be the only basis for implementation of stormwater quality measures for a project site.  The project site owner is responsible for implementing, in accordance with this rule, all measures necessary to adequately prevent polluted stormwater run-off.

27.             Pursuant to 327 IAC 15-5-7(b)(9), the project site owner shall inform all general contractors, construction management firms, grading or excavating contractors, utility contractors, and the contractors that have primary oversight on individual building lots of the terms and conditions of this rule and the conditions and standards of the SWP3 and the schedule for proposed implementation.

 

28.             Pursuant to 327 IAC 15-5-7(b)(10), phasing of construction activities shall be used, where possible, to minimize disturbance of large areas.

 

29.             Pursuant to 327 IAC 15-5-7(b)(11), appropriate measures shall be planned and installed as part of an erosion and sediment control system.

 

30.             Pursuant to 327 IAC 15-5-7(b)(12), all stormwater quality measures must be designed and installed under the guidance of a trained individual.

 

31.             Pursuant to 327 IAC 15-5-7(b)(13), collected run-off leaving a project site must be either discharged directly into a well-defined, stable receiving channel or diffused and released to adjacent property without causing erosion or pollutant problem to the adjacent property owner.

 

32.             Pursuant to 327 IAC 15-5-7(b)(14), drainage channels and swales must be designed and adequately protected so that their final gradients and resultant velocities will not cause erosion in the receiving channel or at the outlet.

 

33.             Pursuant to 327 IAC 15-5-7(b)(15), natural features, including wetlands and sinkholes, shall be protected from pollutants associated with stormwater run-off.

 

34.             Pursuant to 327 IAC 15-5-7(b)(17), during the period of construction activities, all stormwater quality measures necessary to meet the requirements of this rule shall be maintained in working order.

 

35.             Based on the Site inspection conducted by IDEM representatives on October 28, 2008, it was observed that Respondent failed to implement and maintain erosion and sediment control measures at the Site, and/or cause its agent, contractor, and/or subcontractor to implement erosion and sediment control measures necessary to satisfy the requirements of 327 IAC 15-5 during the period of construction activity from on or before August 15, 2008, until the completion of the construction project.  Specifically, erosion and sediment control measures were improperly installed by Respondent and/or its agent, and not maintained causing sediment accumulation; silt fences and other erosion and sediment control measures were not properly installed at the Site, causing dredged and/or fill material to enter unnamed tributaries of Big Thunder Creek and Lawrence Creek branches of Lake LaSalle, which are waters of the State; in violation of 327 IAC 15-5-7(b).

 

36.             Pursuant to 327 IAC 2-1-2(1), for all waters of the state, existing beneficial uses shall be maintained and protected.  No degradation of water quality shall be permitted which would interfere with or become injurious to existing and potential uses.

 

37.             Pursuant to 327 IAC 2-1-6(a)(1), all surface 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 that will settle to form putrescent or otherwise objectionable deposits, that are in amounts sufficient to be unsightly or deleterious, that produce color, odor or other conditions in such degree as to create a nuisance, which are in amounts sufficient to be acutely toxic to, or to otherwise severely injure or kill aquatic life, other animals, plants, or humans.

 

38.             Pursuant to Indiana Code (“IC”) 13-30-2-1(1), a person may not 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.

 

39.             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.

 

40.             The disturbance of the stream bed at the Site, the deposition of sediment and/or soil on the stream bank without a Section 401 Water Quality Certification from IDEM, and the unpermitted discharge to waters of the State, are all in violation of IC 13-30-2-1, IC 13-18-4-5, 327 IAC 5-2-2, 327 IAC 2-1-2(1), and 327 IAC 2-1-6(a)(1).

 

41.             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 all rules and statutes above at issue.

 

3.                  Immediately, upon the of Effective Date, Respondent shall implement the disposal site stabilization plan (“Stabilization Plan”) that meets the intent of 401 Water Quality Certification No. 2009-391-07-DDC-V (See Attachment “A”) and the general stormwater permit No. INR10B506, under 327 IAC 15-5.

 

4.                  Respondent shall timely submit any plan, as required by Attachment “A”.  Upon review, if IDEM deems any plan to be inadequate, a revised plan shall be submitted within fifteen (15) days of receipt of written notice from IDEM of the inadequacies thereof.  If, after submission of the revised plan, IDEM still finds the document to be inadequate, then IDEM will suggest specific modifications to be made to the plan and require re-submittal by a specific date.  Respondent is required to incorporate the IDEM-suggested modifications (or subsequent alternative plan that is acceptable to IDEM) within the prescribed time frames.  Respondent, upon receipt of written notification from IDEM, shall immediately implement the approved plan and adhere to the milestone dates therein.

5.                  Upon receipt of written notice from IDEM’s approval of any plan submitted pursuant to Order Paragraph 3 above, Respondent shall immediately notify IDEM and USACE a minimum of forty-eight (48) hours prior to commencing the Stabilization Plan project at the Site.

 

6.                  Upon completion of the approved Site Stabilization Plan and compensatory mitigation project, Respondent is required to monitor the Site and timely submit annual reports to IDEM and USACE, as required by 401 Water Quality Certification No. 2009-391-07-DDC-V (See Attachment “A”).

 

7.                  For the purposes of this Agreed Order, a Construction Plan (“CP”) is defined as a representation of a project site and all activities associated with the project.  The CP includes the location of the project site, buildings and other infrastructure, grading activities, schedules for implementation, and other pertinent information related to the project site.  A stormwater pollution prevention plan (“SWP3”) is a part of the CP, pursuant to 327 IAC 15-5-4(5) and 327 IAC 15-5-4 (35).

 

8.                  Respondent shall, immediately upon the Effective Date, implement the erosion and sediment control measures contained in the approved CP for the Site and any other erosion and sediment control measures necessary to:

 

a.      ensure compliance with the requirements of 327 IAC 15-5-7 and 327 IAC 2-1-6(a)(1); and

b.      prevent sediment from leaving the site and entering or threatening to enter waters of the State.

 

9.                  Respondent shall, upon the Effective Date, and continuing until the construction at the site has been completed, implement a self-monitoring program as required by 327 IAC 15-5-7(18), including assuring that a trained individual performs a written evaluation of the project site by the end of the next business day following each measurable storm event; and at a minimum of one (1) time per week, in order to determine whether the erosion and sediment controls are:

 

a.      properly installed and maintained; and

b.      adequate to ensure compliance with the requirements of 327 IAC 15-5-7, and to prevent sediment from leaving the site and entering or threatening to enter waters of the State.

 

For the purposes of this Agreed Order, a “measurable storm event” is defined as a precipitation event that results in a total measured precipitation accumulation equal to or greater than 0.5 inches of rainfall.

 

10.             In the event that deficiencies are found during the inspections of the Site conducted pursuant to Order Paragraph 9 above, Respondent shall immediately take all actions necessary to correct the deficiencies.  Such actions may include, but are not necessarily limited to, removal of accumulated sediment from behind silt fences and storm inlets, assurance that conveyance channels and swales are stabilized, and installation of additional erosion and sediment control measures, if determined necessary.

 

11.             Respondent shall maintain records of the inspections conducted pursuant to Order Paragraph 9 above and corrective actions taken pursuant to Order Paragraph 10 above.  The records shall include, but not necessarily be limited to:

 

a.            the date and time of inspection;

b.            the weather conditions at the time of the inspection;

c.             the name of the individual conducting the inspection;

d.            a description of observations made during the inspection, specifically including a description of any deficiencies that were found; and

e.            a description of the corrective actions taken as a result of deficiencies found during the inspection.

 

12.             Respondent shall make the records required pursuant to Order Paragraph 11 above available for inspection and copying by representatives of IDEM and its representatives.

 

13.             Respondent shall, within fifteen (15) days of the Effective Date, provide written notification to all parties with access to the Site, including contractors and subcontractors, of the requirements contained in the approved CP.

 

14.             Respondent shall, within thirty (30) days of the Effective Date, submit to IDEM a copy of the notification required pursuant to Order Paragraph 13 above and a statement certifying that the notification was provided to all parties with access to the Site.

 

15.             Upon completion of all general stormwater permit No. INR10B506 requirements for termination at the Site, Respondent shall first receive verification from IDEM that the project is complete and ready to be terminated.  Once verification has been received from IDEM, Respondent shall submit the notice of termination (“NOT”), as outlined in 327 IAC 15-5-8.

 

16.             Respondent shall, within ten (10) days of the completion of the milestone dates for any plan required above, Respondent shall submit written documentation of completion of each milestone to IDEM’s Office of Water Quality Water Enforcement Section, Section 401 Water Quality Certification Program, and USACE at the addresses in Order Paragraph 17 below.

 

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

 

Aletha Lenahan, Enforcement Case Manager

Indiana Department of Environmental Management

Water Enforcement Section

Office of Water Quality – Mail Code 60-02W

100 North Senate Avenue, Room N1255

Indianapolis, IN 46204-2251

 

And

 

David Carr, Wetlands Project Manager

Indiana Department of Environmental Management

Section 401 Water Quality Certification Program

Office of Water Quality - Mail Code 65-42 WQS

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

And

 

Laban Lindley, Wetlands Project Manager

U.S. Army Corps of Engineers

Indianapolis Regulatory Office

9799 Billings Road

Indianapolis, IN 46216-1055

 

18.             Respondent is assessed a civil penalty of Five Thousand Dollars ($5,000).  Said penalty amount shall be due and payable to the “Environmental Management Special Fund” thirty (30) days of the Effective Date.  In the event that the civil penalty is not paid within thirty (30) days of the Effective Date, Respondents 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.

 

19.             In the event the terms and conditions of the following paragraphs are violated, Complainant may assess, and Respondent shall pay, a stipulated penalty in the following amount:

 

PARAGRAPH

VIOLATION

PENALTY DUE

3

Failure to timely implement Stabilization Plan, as required.

$500 per day for each day past the deadline.

4

Failure to timely submit any plan or revision required by the Stabilization Plan (see Attachment “A”).

$500 per day for each day past the deadline.

5

Failure to notify IDEM and USACE at a minimum of forty-eight (48) hours prior to commencing any stabilization, mitigation or restoration project at the Site.

$500 per day for each day past the deadline.

6

Failure to monitor the Site, as required by Respondent’s 401 Water Quality Certification.

$500 per day for each day past the deadline.

6

Failure to timely submit the annual monitoring reports to IDEM and USACE, as described in the 401 Water Quality Certification.

$500 per day for each day past the deadline.

8

Failure to implement erosion and sediment control measures contained in the approved CP, as necessary to comply with 327 IAC 15-5 requirements.

$500 per violation/per day.

9

Failure to timely implement a self-monitoring program to inspect the Site, as required.

$500 per violation/per day.

10

Failure to immediately take all actions necessary to correct deficiencies found during Site inspections.

$500 per violation/per day.

11

Failure to maintain inspection records, as required.

$500 per day for each day past the deadline.

12

Failure to maintain required records at the Site, or failure to make required records available to IDEM and SWCD.

$500 per violation/per day.

13

Failure to timely provide written notification to all parties with access to the Site, as required.

$500 per week/per event late.

14

Failure to timely submit certification statement and copy of notice provided pursuant to Order Paragraph 13.

$500 per violation/per day.

15

Failure to receive Site completion verification from IDEM prior to submission of NOT.

$500 per day for each day past the deadline.

15

Failure to submit the NOT to IDEM upon termination of construction activities at the site.

$500 per day for each day past the deadline.

16

Failure to timely submit documentation of completion of each milestone, as required for the Stabilization Plan and compensatory mitigation project.

$500 per week/per event late.

 

20.             Stipulated penalties shall be due and payable within thirty (30) days after Respondent receives written notice that 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 set out 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: 2009-18336-W, of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Cashier – Mail Code 50-10C

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

22.             This Agreed Order shall apply to and be binding upon Respondent and his successors and assigns.  Respondent’s signatories to this Agreed Order certify that he is fully authorized to execute this Agreed Order and legally bind the party he represents.  No change in ownership, corporate, or partnership status of Respondent shall in any way alter his status or responsibilities under this Agreed Order.

 

23.             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.

 

24.             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.

 

25.             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 his obligation to comply with the requirements of his applicable permits or any applicable Federal or State law or regulation.

 

26.             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.

 

27.             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.

 

28.             Nothing in this Agreed Order shall prevent IDEM or anyone acting on its behalf from communicating with the United States 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 the EPA or any other agency or entity.

 

29.             This Agreed Order shall remain in effect until Respondent has complied with Order Paragraphs 3 through 21 and IDEM issues a Resolution of Case letter to Respondent.

 

Remainder of this page intentionally left blank.

 

TECHNICAL RECOMMENDATION:

RESPONDENT:

 

Department of Environmental Management

Lake LaSalle Owners Association, Inc.

 

 

 

 

By: ________________________

By:

 

 

 

Mark W. Stanifer, Chief

Water Enforcement Section

 

 

Printed:

 

 

 

Office of Water Quality

 

 

 

Title:

 

 

 

 

 

Date: __________________

Date:

 

 

 

 

 

 

 

 

 

COUNSEL FOR COMPLAINANT:

COUNSEL FOR RESPONDENT:

 

For Department of Environmental Management

 

 

 

 

 

By: ____________________

By: ______________________

 

 

 

 

 

 

 

Date: _______________________

Date: _______________________

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

 

MANAGEMENT THIS

______

DAY OF

_______________________,

2010.

 

 

 

 

 

Signed on March 15, 2010

 

 

Bruno Pigott

 

 

Assistant Commissioner

 

 

Office of Water Quality