STATE OF INDIANA

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SS:

BEFORE THE INDIANA DEPARTMENT OF

 

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COUNTY OF MARION

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ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

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OF ENVIRONMENTAL MANAGEMENT,

 

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Complainant,

 

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v.

 

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Case No. 2010-19034-H

 

 

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MID-STATE CHEMICAL & SUPPLY CORP.,

 

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Respondent.

 

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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 is Mid-State Chemical & Supply Corp. (“Respondent”), which owned and/or operated the facility with United States Environmental Protection Agency ("EPA") ID No. IND 039995121, located at 2100 Greenbriar Lane in Indianapolis, Marion County, Indiana (the “Site”).

 

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 ("NOV") via Certified Mail to:

 

Paul J. Bosler, Jr., President

Paul J. Bosler, Jr., Registered Agent for

Mid-State Chemical & Supply Corp.

Mid-State Chemical & Supply Corp.

2100 Greenbrier Lane

1072 3rd Avenue, NW

Indianapolis, IN  46218

Carmel, IN  46032

 

5.          Respondent closed the facility in October 2008, leaving behind solid and hazardous wastes in containers and bags.  Prior to closing, Respondent had operated as a chemical compound formulator at this Site and had supplied industrial cleaning compounds.

 

6.          Respondent last notified the U.S. EPA of conditionally exempt small quantity generator activities on August 23, 2005.  At the time of the facility's closing, Respondent had accumulated enough hazardous waste on-site to be subject to the large quantity generator requirements of 40 CFR 262.

 

7.          329 Indiana Administrative Code (“IAC”) 3.1 incorporates certain federal hazardous waste management requirements found in 40 Code of Federal Regulations (“CFR”) Parts 260 through 270 and Part 273, including those identified below.

 

a.         Pursuant to 40 CFR 262.11, a person who generates a solid waste must determine if that waste is hazardous.

 

As noted during the inspections, Respondent did not make hazardous waste determinations on the wastes left behind on-site.  Multiple containers on the north and east sides of the property, as well as within the shipping and receiving warehouse, had not had hazardous waste determinations made on their contents.

 

Respondent presented information at a settlement conference between the two parties on July 1, 2010 indicating that, even though many of the containers were eventually shipped off as containing hazardous wastes, company representatives had believed that their contents could be used by a new owner once the Site was purchased.

 

b.        Pursuant to 40 CFR 270.1(c), a permit is required for the treatment, storage and disposal of any hazardous waste as identified or listed in 40 CFR Part 261.

As noted during the inspections, Respondent stored hazardous waste identified or listed in 40 CFR Part 261 without a permit.  Numerous containers holding hazardous wastes, located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property, were stored on-site for greater than 90 days without a permit.

 

Respondent provided IDEM with documentation on November 1, 2010, demonstrating that the wastes on the north side of the property were non-hazardous.

c.                  Pursuant to IC 13-30-2-1(10), a person may not commence or engage in the operation of a hazardous waste facility without having first obtained a permit from the department.

 

As noted during the inspections, Respondent operated a hazardous waste facility without having first obtained a permit from the department.

 

d.                  Pursuant to 329 IAC 3.1-1-10, every hazardous waste generator, transporter, or owner or operator of a hazardous waste facility shall notify the commissioner of its hazardous waste activity on the approved forms.

 

As noted during the inspections, Respondent failed to notify the Commissioner of hazardous waste storage activities.

 

e.        Pursuant to 40 CFR 262.34(b), a generator who accumulates hazardous waste for more than 90 days is an operator of a storage facility and is subject to the requirements of 40 CFR Part 264 and the permit requirements of 40 CFR Part 270 unless he has been granted an extension to the 90 day period.

As noted during the inspections, Respondent stored hazardous waste on-site for greater than 90 days without complying with 40 CFR Part 264 and 40 CFR Part 270.  Numerous containers holding hazardous wastes, located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property, were stored on-site for greater than 90 days without a permit.

 

Respondent provided IDEM with documentation on November 1, 2010, demonstrating that the wastes on the north side of the property were non-hazardous.

 

e.                  Pursuant to 40 CFR 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.

 

As noted during the inspections, Respondent accumulated hazardous waste on-site, without a permit, and did not mark any hazardous waste containers stored for greater than 90 days and located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property with accumulation start dates.

 

Respondent provided IDEM with documentation on November 1, 2010, demonstrating that the wastes on the north side of the property were non-hazardous.

 

f.                    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, while being accumulated on-site, each container and tank is labeled or marked clearly with the words "Hazardous Waste."

 

As noted during the inspections, Respondent accumulated hazardous waste on-site, without a permit, and did not label or clearly mark any hazardous waste containers stored for greater than 90 days and located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property with the words "Hazardous Waste."

 

Respondent provided IDEM with documentation on November 1, 2010, demonstrating that the wastes on the north side of the property were non-hazardous.

 

g.                  Pursuant to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.174, a generator must  inspect areas where containers are stored, at least weekly, looking for leaks and deterioration caused by corrosion or other factors.

 

As noted during the inspections, Respondent failed to conduct weekly inspections at the container/storage areas.

 

i.          Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.31, facilities 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.

 

As noted during the inspections, Respondent failed to properly manage the facility to minimize a release to the environment.  Numerous containers and bags of abandoned chemical wastes stored in lieu of disposal and located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property were not managed in a manner 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 provided IDEM with documentation on November 1, 2010, demonstrating that the wastes on the north side of the property were non-hazardous.

 

j.         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.

 

As noted during the inspections, Respondent caused and/or allowed solid waste, including, but not limited to numerous containers and bags of abandoned chemical wastes located in the main shipping and receiving warehouse, outside on the east side of the main building, and on the north side of the property, to be stored and disposed at the Site in a manner which creates a threat to human health or the environment.

 

k.                  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 in any form that causes or would cause pollution that violates or would violate 40 CFR 265.31 and/or 329 IAC 10-4-2, rules adopted by the board under the environmental management laws.

 

As noted during the inspections, Respondent, by abandoning wastes at the site, threatened to discharge, emit, cause, or allow contaminants and wastes into the environment in a form that causes or would cause pollution in violation of 40 CFR 265.31 and/or 329 IAC  10-4-2.

 

l.         Pursuant to 40 CFR 268.50, the storage of hazardous wastes restricted from land disposal is prohibited unless each container is clearly marked to identify its contents and the date each period of accumulation begins and each tank is marked with the same, unless the information for each tank is recorded and maintained in the operating record at the facility.

 

As noted during the inspections, Respondent stored hazardous wastes restricted from land disposal and had not clearly marked the containers to identify their contents and had not marked the date each period of accumulation began.

 

8.          On February 9, 2010, Respondent submitted shipping documents including manifests and bills of lading to IDEM via E-mail.  The documents indicated that the abandoned wastes included, but were not limited to, the following:  two hundred and fifteen (215) gallons of hazardous waste designated as D002; one thousand two hundred (1200) pounds of hazardous waste designated as D001; sixty five (65) gallons of hazardous waste designated as D001/F003; ten (10) pounds of hazardous waste designated as U219: and five hundred (500) gallons of non-hazardous waste regulated liquids.  The February 12, 2010 IDEM inspection verified that all wastes at the Site have been transported off-site.

 

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 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, and/or permit conditions or listed in the findings here and/or above at issue.

 

3.         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall submit three (3) hard copies and one complete copy of the entire document on CD, in PDF format no greater than 100 megabytes per file, of a hazardous waste closure plan for all areas at the Site where hazardous wastes were stored for greater than 90 days including, but not limited to, the main shipping and receiving warehouse and outside on the east side of the main building, to IDEM for approval.  This closure plan shall be completed in accordance with the provisions of 40 CFR 264 Subpart G, as incorporated by 329 IAC 3.1-9-1.

 

4.         Within ten (10) days of notice of IDEM’s approval of the closure plan, Respondent shall implement the plan as approved and in accordance with the time frames contained therein.

 

5.         In the event IDEM determines that any plan submitted by Respondent is deficient or otherwise unacceptable, Respondent shall revise and resubmit the plan to IDEM in accordance with IDEM's notice.  After three (3) submissions of such plan by Respondent, IDEM may modify and approve any such plan and Respondent must implement the plan as modified by IDEM.  The approved plan shall be incorporated into this Agreed Order and shall be deemed an enforceable part thereof.

 

6.         Within thirty (30) days of the Effective Date, Respondent shall submit documentation to IDEM demonstrating that all wastes, both solid and hazardous, at the Site have been properly transported off-site and disposed of at permitted facilities.

 

7.          All submittals required by this Agreed Order, unless Respondent is notified otherwise in writing by IDEM, shall be sent to:

 

Brenda Lepter, Enforcement Case Manager

Office of Land Quality – Mail Code 60-02L

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

8.          Respondent is assessed a civil penalty of Thirty Thousand Four Hundred Dollars ($30,400).  Within thirty (30) days of the Effective Date of the Agreed Order, Respondent shall pay a portion of this penalty in the amount of Eight Thousand Four Hundred Dollars ($8,400).  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 Twenty Two Thousand Dollars ($22,000).  Within thirty 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 $22,000, Respondent shall pay one hundred percent of the difference between the proposed cost of the SEP ($22,000) and the actual cost of the SEP.

 

As a Supplemental Environmental Project, Respondent shall perform a pollution prevention project which results in conservation of energy.  Specifically, Respondent shall make a one-time payment to Bosler Energy Technologies, LLC for the design, purchase, and installation of an Energy Automation Systems, Inc. system for the Clay Township Regional Waste Treatment Plant in Hamilton County, Indiana.  Installation of this system shall result in the conservation of energy, specifically estimated to be $7,750 per year, 126,816 kWh per year, and 55.8 ton of coal not burned per year.  Respondent's agreement with Bosler Energy Technologies, Inc. and/or the Clay Township Regional Waste Treatment Plant shall include a provision that any removed fixtures and equipment from the old system are recycled whenever possible and properly disposed when unable to be recycled.  Respondent shall ensure that Bosler Energy Technologies, LLC receives the payment by December 10, 2010 in order for the project to be completed by December 31, 2010.  Implementation of this SEP will result in actual energy conservation.

 

In the event that Respondent does not complete the SEP according to the timeframes set forth above, the full amount of the civil penalty as stated above, plus interest established by IC 24-4.6-1-101, 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.

 

9.          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:

 

Failure to comply with Order No. 3

$500 per week

 

 

Failure to comply with Order No. 4

$500 per week

 

 

Failure to comply with Order No. 5

$500 per week

 

 

Failure to comply with Order No. 6

$250 per week

 

10.       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.

 

11.       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 – Mail Code 50-10C

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

12.       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 party 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.

 

13.       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.

 

14.       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.

 

15.       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 its obligation to comply with the requirements of its applicable permit or any applicable Federal or State law or regulation.

 

16.       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.

 

17.       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 NOV.

 

18.       Nothing in this Agreed Order shall prevent IDEM or anyone acting on its behalf from communicating with the 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.

 

19.       This Agreed Order shall remain in effect until IDEM issues a Resolution of Case letter to Respondent.

 

TECHNICAL RECOMMENDATION:

RESPONDENT:

Department of Environmental Management

 

 

 

By: _________________________

By:  _________________________

 

Nancy Johnston, Section Chief

 

 

Enforcement Section

Printed: ______________________

Office of Land Quality

 

 

Title: ________________________

 

 

Date: __________________

Date: _______________________

 

 

 

 

COUNSEL FOR COMPLAINANT:

COUNSEL FOR RESPONDENT:

For the Department of Environmental Management

 

 

 

By: ________________________

By: ________________________

 

Deputy Attorney General

 

 

 

Date: _______________________

Date: ______________________

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

______

DAY OF

_______________,

 2010.

 

 

 

 

For the Commissioner:

 

 

 

Signed on 1/5/2011

 

Bruce H Palin

 

Assistant Commissioner

 

Office of Land Quality