|
STATE OF |
) |
|
BEFORE
THE INDIANA DEPARTMENT |
||
|
|
|||||
|
COMMISSIONER
OF THE DEPARTMENT Complainant, v. MILLWOOD
ACRES LLC, Respondent. |
) |
2010-19509-D |
|||
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
3.
Complainant is
the Commissioner (Complainant) of the Indiana Department of Environmental
Management (IDEM), a department of the State of
4.
Respondent is Millwood Acres LLC, which owns/operates the
Millwood Acres Wastewater Treatment Plant with National Pollutant Discharge
Elimination System (NPDES) Permit No. IN0036412, located at
5.
Respondent also owns/operates a community public water
supply (PWS) system with PWSID No. IN5243016, serving 113 persons located at
9452 N SR 19, Lot 3 in Etna Green,
6.
IDEM has jurisdiction over the parties and the subject
matter of this action.
7.
Pursuant to IC 13-30-3-3, IDEM issued Notices of Violation
(NOVs) for Site A (Case No. 2010-19419-W), via Certified Mail, on September 13,
2010, and for Site B (Case No. 2010-19509-D), via Certified Mail, on October
12, 2010, to:
|
Joel Comino,
Registered Agent |
|
Millwood
Acres, LLC |
|
12781 CR 44 |
|
|
8.
Respondent is the
business of operating a mobile home park and providing water and wastewater
treatment services for residents of the park.
9.
During an investigation conducted by a representative of
IDEM, the following violations were found at Site A:
A.
Pursuant to 327 IAC 5-2-8(1), Respondent is required to
comply with all terms and conditions of the Permit. Pursuant to Part I.A.1 of
the Permit, Respondent is required to meet flow monitoring requirements and
effluent limitations for pH, carbonaceous biochemical oxygen demand, five day
(cBOD5), total suspended solids (TSS), ammonia nitrogen (NH3-N), E. coli,
total residual chlorine (TRC), and dissolved oxygen (DO) for the Site.
IDEM records review showed that
effluent violations occurred at Respondent’s wastewater treatment plant for:
NH3-N during the months of January, March, and April 2010; E. coli
during the month of April 2010; TRC during the month of April 2010; DO during
the month of April 2010; cBOD5 during the month of April 2010; and TSS during the month of April
2010, in violation of 327 IAC 5-2-8(1) and Part I.A.1 of the Permit.
B.
Pursuant to 327 IAC 5-22-10, and Part II.A.14. of the
Permit, the owner or governing body of a wastewater treatment plant shall be
responsible for accomplishing the following:
1) Provide adequate funding and oversight to ensure the proper:
a) operation;
b) maintenance;
c) management; and
d) supervision;
of the designated facilities.
2) Place each wastewater treatment plant under the direct
supervision of one certified operator to be in responsible charge who:
a) holds a current certification of a classification eligible
for operation at the classification of the wastewater treatment plant;
b) makes process control or system integrity decisions about
the overall daily operation, maintenance, management, and supervision of each
wastewater treatment plant necessary to meet the performance requirements and
limits of:
i) the assigned permit;
ii) local ordinances; and
iii) other applicable regulatory
requirements; and
c) is responsible that written and electronic monitoring
reports are prepared under his or her direction or supervision in accordance
with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. The
responsible charge operator certifies that based on his or her inquiry of the
persons who manage the system, or those persons directly responsible for
gathering the information, that the information submitted is, to the best of
his or her knowledge and belief, true, accurate, and complete.
3) Notify the commissioner of the name of the person designated
according to subdivision b. to be the certified operator in responsible charge.
4)
Submit written notification to the commissioner not later
than 30 days after the occurrence of a change in one of the following:
a)
The person serving as the certified operator in responsible
charge of the wastewater treatment plant.
b)
Conditions or circumstances that were used as the basis for
the original classification of the wastewater treatment plant.
5) The responsibilities of the owner or governing body
described in this section may not be delegated.
IDEM’s investigation discovered that
Respondent has not provided funding and oversight to ensure the proper
operation and maintenance of the wastewater treatment plant by failing to place
it under the direct supervision of one certified operator to be in responsible
charge since May 2, 2010, in violation of 327 IAC 5-22-10 and Part II.A.14. of
the Permit. No discharge monitoring reports (DMRs) or monthly reports of
operation (MROs) have been submitted for Respondent’s wastewater treatment
plant for the months of May through July 2010, in violation of 327 IAC 5-22-10
and Part I.B.3. of the Permit.
10.
During an investigation conducted by a representative of
IDEM, the following violations were found at Site B:
A.
Pursuant to 327 Indiana Administrative Code (IAC) 8-2-8(c),
a community PWS system using ground water and serving no more than 1,000
persons must collect at least one routine total coliform sample each calendar
month.
IDEM records indicate Respondent failed
to collect at least one routine total coliform sample from its PWS system
during February, April, and May 2010;
each in violation of 327 IAC 8-2-8(c).
B.
Pursuant to 327 IAC 8-2-7, the microbiological maximum
contaminant level (MCL) applies to all PWS facilities and is based on the
presence or absence of total coliforms in a sample, rather than coliform
density. For a system which collects fewer than 40 samples per month, if no
more than one sample collected during the month is total coliform positive, the
system is in compliance with the MCL for total coliforms.
IDEM records indicate that a positive
sample result for total coliforms was obtained in July 2010.
Pursuant to 327 IAC 8-2-8.1, if a
routine sample is total coliform positive, the PWS must collect a set of repeat
samples within 24 hours of being notified by the laboratory or the commissioner
of the positive result.
IDEM records indicate that Respondent
failed to collect the required number of repeat samples in a timely manner in
July 2010, following notification of a positive result, in violation of 327 IAC
8-2-8.1.
C.
Pursuant to 327 IAC 8-2-5.5, a community ground water PWS
shall take a minimum of one sample at every entry point to the distribution
system that is representative of each well after treatment for volatile organic
compound (VOC), testing for four consecutive quarters (base monitoring) during
each compliance period (three years), in order to determine compliance with
section 5.4 of this rule, beginning with the initial compliance period. Each
community ground water system that does not detect a contaminant listed in
section 5.4 is eligible for a waiver from the four consecutive quarters of
monitoring, effective for no more than six years (two compliance periods). As a
condition of the waiver, a ground water system must take one sample at each
sampling point during the time the waiver is effective.
IDEM records indicate that the former
PWS owner completed base monitoring (four
quarters) for VOC testing during the second compliance period and did not have
any detections. In a December 5, 2007 letter, IDEM granted the former PWS owner a
waiver reducing monitoring frequency for VOC
testing to once every three years, with the next monitoring scheduled to occur
during 2009. The former PWS owner
failed to monitor/report
VOC testing for the year 2009. The
Respondent took ownership responsibility in January 2010, and was informed by
IDEM in a January 7, 2010 letter of his current sampling and monitoring
requirements, which included VOC testing in 2010, because the former owner had
failed to monitor VOCs in 2009. Respondent was informed by IDEM, in a February
10, 2010 letter, of corrective action needed for compliance with VOC
monitoring/ reporting, and given until February 28, 2010 to make up the missed
monitoring and was given until March 31, 2010 to submit the results to IDEM.
Respondent has failed to monitor/report VOC testing within the required time
frame in 2010, in violation of 327 IAC 8-2-5.5.
D.
Pursuant to 327 IAC 8-2.1-7, the owner or operator of a PWS
system which fails to perform monitoring required pursuant to 327 IAC 8-2-8(c)
is required to notify persons served by the PWS system, in the manner provided
for in these rules, of such failure.
IDEM records indicate Respondent failed
to notify persons served by its PWS system of the failure to perform the total
coliform monitoring required pursuant to 327 IAC 8-2-8(c) during February,
April, and May 2010, in violation of
327 IAC 8-2.1-7. Respondent also failed
to notify persons served by its PWS system of the failure to perform VOC testing in 2010, as required pursuant
to 327 IAC 8-2-5.5, in violation of 327 IAC 8-2.1-7.
E.
Pursuant to 327 IAC 8-12-1.1, the owner of a water treatment
plant or water distribution system shall be responsible to accomplish the
following:
1)
Place each water treatment facility and water distribution
system under the direct supervision of a certified operator in responsible
charge who:
a)
has a valid certification of a grade eligible for operation
at the classification of water treatment facility or water distribution system
of responsibility; and
b)
is available to make process control or system integrity
decisions about water quality or quantity that affect public health.
2)
Designate a certified operator to have complete
responsibility for the proper operation of the water treatment facility or
water distribution system.
3)
Assure that a minimum of one operator certified according to
this rule must be available.
4)
Notify the commissioner of the name of the person designated
according to this rule to be the certified operator in responsible charge.
5)
Submit written notice to the commissioner no later than 30
days after the occurrence of one of the following:
a)
A change in the person serving as the certified operator in
responsible charge.
b)
A change in conditions or circumstances that were used as
the basis for the original classification of the water treatment plant or water
distribution system.
During a January 20, 2010 sanitary
survey, an IDEM representative observed that Respondent had failed to place the
water treatment facility under the direct supervision of a certified operator
in responsible charge who has a valid certification according to the rule. In a January 29, 2010 IDEM letter, Respondent
was informed to retain the services of a certified operator and notify IDEM, in
writing, by February 7, 2010. Respondent
has failed to place the water treatment facility under the direct supervision
of a certified operator in responsible charge who has a valid certification
according to the rule in violation of 327 IAC 8-12-1.1.
F.
Pursuant to 327 IAC 8-2-8.2(e)(2)(c), the commissioner may
review results of a community water system’s sanitary survey to determine
whether significant deficiencies relating to drinking water treatment exist,
including no provisions to warn operators of treatment failures.
IDEM conducted a sanitary survey at
Respondent’s PWS on January 20, 2010 and a follow up inspection on June 12,
2010 which identified a need for Respondent to develop and submit an emergency
plan to identify steps to handle a loss of pressure event of less than twenty
pounds per square inch (20 psi). Respondent failed to provide an adequate
emergency plan that would include identified procedural steps to handle a loss
of water pressure to levels below 20 psi, in violation of 327 IAC
8-2-8.2(e)(2)(c).
G.
Pursuant to 327 IAC 8-4-1, no one shall install or contract
for the construction of any PWS facilities, including water purification or
treatment works, or make any material change in any such existing facilities or
works, until plans and specifications, together with an engineering report
supporting in detail the design set forth in the plans, shall have been
submitted to and approved by the commissioner, so far as relates to their
sanitary features except for at small transient or small nontransient
noncommunity public water systems.
Pursuant to 327 IAC 8-3-2, no person
shall cause or allow the construction, installation, or modification of any
facility, equipment, or device for any PWS without having a valid construction
permit issued by the commissioner, except for replacement of equipment of
similar design and capacity, none of which will change adversely:
1)
the plant operation;
2)
its hydraulic design or waste products; or
3)
the water distribution system design, operation, or
capacity;
without first submitting in writing to
the commissioner a detailed statement of the proposed changes and receiving an
amended construction permit from the commissioner.
IDEM issued an “After The Fact” PWS
construction permit to the previous owner of the PWS for a new well on May 5,
2009 under a condition that all requirements of an October 24, 2008 Well Site
Survey are met. As the new owner of the PWS, Respondent was informed during the
January 20, 2010 sanitary survey, that he was required by the 10/24/08 Well
Site Survey to obtain a construction permit for installation of disinfection
equipment and complete the installation by July 1, 2010. Respondent failed to
meet the disinfection equipment installation requirements of the 10/24/08 Well
Site Survey, thus Respondent is in violation of 327 IAC 8-4-1 and 327 IAC
8-3-2.
11.
A telephonic settlement conference was held on October 26,
2010 during which terms and conditions of the Agreed Order, and compliance
requirements at Sites A and B were discussed.
12.
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.
Upon the Effective Date of this Agreed Order, Respondent
shall comply with 327 IAC 5-22-10, and Part II.A.14. of the Permit. Specifically for Site A, Respondent shall
place the Millwood Acres wastewater treatment plant under the direct
supervision of a certified operator, holding a current, valid Class I Indiana
wastewater treatment plant operator’s certificate, to be in responsible charge
on a continuous basis. Upon the
Effective Date of this Agreed Order, Respondent shall also comply with 327 IAC
8-12-1.1. Specifically for Site B,
Respondent shall place the Millwood Acres PWS under the direct supervision of a
certified operator, holding an appropriate, current, and valid Indiana DSS
distribution system operator’s certificate, to be in responsible charge on a
continuous basis. Upon installation of the required disinfection equipment,
Respondent shall place the Millwood Acres PWS under the direct supervision of a
certified operator, holding an appropriate, current, and valid Indiana WT2
water treatment operator’s certificate, to be in responsible charge on a
continuous basis.
3.
Within 30 days of the Effective Date of this Agreed Order,
Respondent shall develop and submit to IDEM for its approval a compliance plan
(CP) for Site A that includes the following:
a.
actions that Respondent will take to study future needs for
WWTP upgrade and expansion, training, and staffing, in order to comply with all
conditions of the Permit.
b.
actions that Respondent will take to ensure that all WWTP
processes, equipment and infrastructure are at all times efficiently operated
and maintained in good working order, including repairs and preventative
maintenance documentation, and performance of all other monitoring, sampling,
testing, and recordkeeping;
c.
actions that Respondent will take to accurately and
consistently monitor flow volume and mass parameters, and meet all effluent
limits, and to report and correct all treatment process bypasses as required by
the Permit;
d.
an implementation and completion schedule, including
specific milestone dates for developing and implementing the items required by
items a, b, and c above.
4.
The Respondent shall, within nine months of the completion
of the portion of the CP required by Paragraphs 2 and 3 (Performance Period),
demonstrate a period of six consecutive months that it consistently meets all
Permit conditions and requirements for Site A.
During the Performance Period, the Respondent shall be subject to
stipulated penalties, as specified below.
Within sixty days of the date that Respondent fails to achieve the
Compliance Demonstration at Site A, or it becomes aware that it will not be
able to achieve the Compliance Demonstration within the Performance Period, it
shall develop and submit to IDEM, for approval, a plan which identifies the
additional actions that Respondent will take to consistently meet all Permit
conditions and spill response requirements.
This “Additional Action Plan”, if required, shall include a new
implementation and completion schedule, including specific milestone dates.
5.
The plans required by Paragraphs 3 and 4 above are subject
to IDEM approval. 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
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 Respondent, upon receipt of written
notification from IDEM, shall immediately implement the approved plan and
adhere to the milestone dates therein.
The approved Compliance Plan and Additional Action Plan shall be
incorporated into the Agreed Order and shall be deemed an enforceable part
thereof. Failure by the Respondent to
submit any plan by the specified date, or to meet any of the milestones in the
approved plan will subject the Respondent to stipulated penalties as described
below. Failure to achieve compliance at
the conclusion of work under an Additional Action Plan will subject Respondent
to additional enforcement action.
6.
Beginning on the Effective Date of this Agreed Order and
continuing until the completion of the Plans required by Paragraphs 3, 4, and
5, the Respondent shall, at all times, operate its existing wastewater
treatment system as efficiently and effectively as possible.
7.
For Site B, beginning within 30 days of the Effective Date,
Respondent shall, for the purposes of this Order collect at
least one routine total coliform sample in its PWS system, and report the
results to IDEM, for 12 consecutive months.
It is the responsibility of the Respondent to continue sampling monthly,
pursuant to 327 IAC 8-2-8 (c), after completion of the 12 consecutive months of
sampling required by this paragraph.
8.
Within the shorter of either 10 days after Respondent
receives any total coliform monitoring results or 10 days after the end of the
applicable total coliform monitoring period, Respondent shall submit said
monitoring results for its PWS system to IDEM.
9.
If the results of any routine monthly sample for total
coliform required by paragraph 7 indicate a “positive” result, the following
actions shall be taken:
a.
Further analyze the positive sample for E. coli;
b.
Contact the Drinking Water Branch immediately at
317-234-7445 for further instructions;
c.
Collect four repeat samples and one ground water source
sample for total coliform bacteria within 24 hours; and
d.
In the following month, collect five routine samples rather
than the usual one.
10.
Beginning upon the Effective Date, Respondent shall
demonstrate one full year of operation in compliance with the total coliform
rule and ground water rule (including the MCL, monitoring, reporting and public
notification requirements). This will be
referred to as the Compliance Demonstration for Site B.
In the event the Respondent fails to
achieve the requirements of the Compliance Demonstration for Site B, Respondent
shall within 60 days of becoming aware of such failure, develop and submit to
IDEM a Compliance Plan (CP) which identifies actions to be taken in order to
achieve compliance. The CP shall include
an implementation and completion schedule, including specific milestone
dates. The CP shall be subject to the
approval of IDEM. The approved CP shall
be incorporated into this Agreed Order and shall be deemed an enforceable part
hereof.
11.
Within 30 days of the Effective Date, Respondent shall
provide public notice for the past total coliform and VOC monitoring violations
listed in Paragraph 8 of the Findings of Facts above, by following these steps:
a. Complete
attached public notice and certification form for public notice.
b. Post public notice where the public has
ready access for viewing, and for as long as the violation persists, but in no
case less than seven days, even if the violation is resolved.
12.
Within 10 days of issuing the public notice in Paragraph 11
of this Order, Respondent shall send to IDEM a signed certification form for
public notice and representative copy of the public notice issued.
13.
Within 30 days of Effective Date, Respondent shall submit to
IDEM a construction permit application including plans and specifications for
the installation of appropriate disinfection equipment for the PWS, as required
by the May 5, 2009 an “After The Fact” PWS construction permit and requirements
of the October 24, 2008 Well Site Survey, and shall install the disinfection
equipment within 30 days of construction permit approval by IDEM.
14.
All submittals required by this Agreed Order, unless
Respondent is notified otherwise in writing by IDEM, shall be sent to:
|
Dave Knox, Enforcement Case Manager |
|
Indiana Department of Environmental
Management |
|
Office of Water Quality – Mail Code
60-02W |
|
|
|
|
15.
Respondent is assessed a civil penalty of Eight Thousand
Nine Hundred Fifty Five Dollars ($8,955).
Said penalty amount shall be due and payable to the Environmental
Management Special Fund in eighteen (18) monthly installment payments. The
first monthly installment payment for Four Hundred Fifty Five Dollars ($455) is
due within thirty (30) days of the Effective Date. Each of the remaining seventeen (17) monthly
installment payments for Five Hundred ($500) shall be due within 30 days of the
preceding month’s due date. In the
event that any civil penalty installment is not paid within thirty (30) days of
its due 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.
16.
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 |
Stipulated
Penalty |
|
2 |
Failure to place wastewater plant or
PWS under the direct supervision of a certified operator to be in responsible
charge on a continuous basis. |
$500 per week without appropriately certified
operator at each Site. |
|
3 |
Failure to submit compliance plan
within the required time period. |
$500 per week late, or part thereof. |
|
4 |
Failure to
submit the Additional Action Plan, if required, within the given time period. |
$250 per each week or part thereof
late |
|
4 |
Failure to
comply with permit terms and conditions during the Performance Period. |
$150 per event |
|
5,
10 |
Failure to submit or resubmit any
revised CP or Additional Action Plan, if required, or to respond to IDEM
requests within the required timeframe. |
$250 per
each week or part thereof late |
|
5,
10, 11 |
Failure to
implement, or meet any condition or milestone date set forth in any approved
CP or Additional Action Plan |
$500 per
week late, or part thereof. |
|
7 |
Failure to
monitor total coliform for 12 consecutive months beginning within 30 days of
the Effective Date. |
$500 per
sample missed. |
|
8 |
Failure to
submit total coliform sample results to IDEM within the shorter of 10 days
after receiving the total coliform monitoring results, or 10 days after the end
of the applicable total coliform monitoring period. |
$100 per
week, or part thereof, past the 10-day deadline. |
|
9 |
Failure to
comply with any or all of the requirements of this paragraph, once a total
coliform positive sample result is obtained. |
$250 per
week for violation of any part of this requirement. |
|
12 |
Failure to
provide public notice for the monitoring violations listed in Paragraph 11 of
the Findings of Fact within 30 days of the Effective Date. |
$250 per
week, or part thereof, past the 30-day deadline. |
|
12 |
Failure to
send to IDEM within 10 days a representative copy of each public notice and
its signed accompanying Certification form for public notice. |
$100 per
week, or part thereof, past the 10-day deadline. |
|
13 |
Failure to
timely submit appropriate construction permit application for disinfection
equipment and/or failure to timely install equipment after approval by IDEM. |
$500 per
week late, or part thereof. |
17.
Stipulated penalties shall be due and payable within 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.
18.
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 |
|
|
|
|
19.
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.
20.
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.
21.
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.
22.
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.
23.
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.
24.
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.
25.
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.
26.
This Agreed Order shall remain in effect until Respondent
has complied with all terms and conditions of Order Paragraph Nos. 2 through 18
and IDEM issues a Resolution of Case letter.
REMAINDER OF PAGE INTENTIONALLY LEFT
BLANK
|
TECHNICAL
RECOMMENDATION: |
RESPONDENT: |
|
|
Department
of Environmental Management |
Millwood
Acres, LLC |
|
|
|
|
|
|
By:
________________________ |
By: ________________________ |
|
|
|
Mark
W. Stanifer, Chief |
|
|
|
Water Enforcement Section |
|
|
Office
of Water Quality |
|
|
|
|
|
|
|
|
|
|
|
Date:
______________________ |
Date:
_______________________ |
|
|
|
|
|
|
|
|
|
|
COUNSEL
FOR COMPLAINANT: |
COUNSEL
FOR RESPONDENT: |
|
|
For
the Department of Environmental Management |
|
|
|
|
|
|
|
By: ________________________ |
By: _________________________ |
|
|
|
|
|
|
|
|
|
|
Date:
_______________________ |
Date:
_______________________ |
|
|
|
||
|
APPROVED
AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL |
||
|
MANAGEMENT
THIS ______ DAY OF _________________, 20___. |
||
|
|
||
|
|
For
the Commissioner: |
|
|
|
|
|
|
|
Signed
on January 4, 2011 |
|
|
|
Bruno Pigott |
|
|
|
Assistant
Commissioner |
|
|
|
Office
of Water Quality |
|