STATE OF INDIANA

)

SS:

BEFORE THE INDIANA DEPARTMENT OF

 

)

 

 

COUNTY OF MARION

)

 

ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

)

 

OF ENVIRONMENTAL MANAGEMENT,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case No. 2013-21399-H &

 

 

)

2013-21526-H

 

 

)

 

Heritage Environmental Services, LLC.,

 

)

 

 

 

)

 

Respondent.

 

)

 

 

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 Heritage Environmental Services, LLC (“Respondent”), which owns/operates Heritage Treatment Center with United States Environmental Protection Agency (EPA) ID No. IND 093 219 012, located at 7901 West Morris Street, in Indianapolis, Marion County, Indiana (“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.

 

Mr. Kenneth Price

Mr. Thomas L. Matrix, Registered Agent for

Heritage Environmental Services, LLC

Heritage Environmental Services, LLC

P.O. Box 68123

5400 W 86th Street

Indianapolis, IN 46268

Indianapolis, IN 46268

 

5.            Respondent notified the U.S. EPA of hazardous waste activities on July 25, 1980.  Respondent is an industrial waste treatment and recycling facility.  Respondent is also a large quantity hazardous waste generator, large quantity handler of universal waste, used oil transfer facility and used oil transporter.

 

6.            Respondent was first issued a RCRA Part B permit (hereinafter referred to as “Permit”) for treatment and storage of hazardous waste on December 28, 1990.  Respondent was issued a Final Permit Renewal on December 31, 2007 which expired January 18, 2013.  Respondent’s Permit was renewed effective May 4, 2013.

 

7.            Respondent was issued a Violation Letter dated April 23, 2012 addressing the December 16, 2011, January 25 and 27, 2012 inspections.   IDEM staff received a response dated May 23, 2012 to the Violation Letter.

 

8.         329 IAC 3.1 incorporates certain federal hazardous waste management requirements found in 40 CFR Parts 260 through 270, and Part 273 including these identified below.

 

9.         During an investigation including inspections on December 16, 2011, January 25, 27, February 28, August 27, November 2, 2012 and December 10, 11, and  12, 2012 conducted by a representatives of IDEM, the following violations were found:

 

a.         Pursuant to 40 CFR 262.34(c)(1), a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste in containers at or near any point of generation (in a satellite container), and under the control of the operator of the process generating the waste.

 

As noted during the December 2012 inspections, Respondent accumulated hazardous waste in a satellite accumulation container that was not under the control of the operator of the process generating the waste.  Specifically, Respondent had one (1) 1/2 gallon satellite accumulation poly container labeled Hazardous Waste Cyanide and NASH stored on a shelf with other sample retains.  The full container was not near the point of generation or under the control of an operator.  The Cyanide Destruction Units have not been operating since September 2012.

 

Respondent contends this finding was corrected during the December 10-12, 2012 inspections.

 

b.         Pursuant to 40 CFR 262.34(a)(3), a generator may accumulate hazardous waste on-site for 90 days or less without a permit, provided that, while being accumulated on-site, each container and tank is labeled or marked clearly with the words "Hazardous Waste."

 

As noted during the December 2012 inspections, Respondent accumulated hazardous waste on-site, without a permit, and did not label or clearly mark hazardous waste containers with the words "Hazardous Waste."  Specifically, the following hazardous waste containers:

 

a)            A vacuum truck with a hose used during maintenance activities to clean out a grated floor pit/sump of hazardous waste solids located on the east side of the building nearby Tanks E-1, E-2, and E-3 and

b)            one sixteen gallon partially full container located on the west side of the drum warehouse building near Container Storage Area (CSA) 5.

 

According to facility personnel the sixteen gallon container was being reprocessed but the employee who was working in that area went on break and left the unlabeled container unattended.

 

Respondent contends these findings were corrected during the December 10-12, 2012 inspections.

 

c.            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 December 2012 inspections, Respondent accumulated hazardous waste on-site, without a permit, and did not mark hazardous waste containers with accumulation start dates.  Specifically, one five-thousand gallon tanker located north of the Plant 1 offices outside in the parking lot was labeled hazardous waste but was incorrectly marked with a designated start of accumulation date of 11/01/2012.  The tanker should have been marked with the date 12/03/2012 according to the facility representative.

 

Respondent contends these findings were corrected during the December 10-12, 2012 inspections.

 

d.            Pursuant to Permit Condition IV.G.1 and 40 CFR 264.193(e)(2)(iv), the secondary containment tank vault system must be provided with an impermeable interior coating or lining that is compatible with the stored waste and that will prevent migration of waste into the concrete.

 

As noted during the December 2012 inspections, Respondent did not properly manage the impermeable coating in the secondary containment system for the permitted wastewater treatment tanks in Containment Area #10 of Plant 1 and the Polishing Building containment area where the permitted hazardous waste Tanks U and W are located.  Specifically, the containment systems in both areas were observed with spalling, cracks, and otherwise deteriorated impermeable coating.

 

Respondent contends these findings were corrected during the December 10-12, 2012 inspections.

 

e.            Pursuant to Permit Condition IV.H.1. & 3., Attachment F., 40 CFR 264.195(b)(3), and 40 CFR 264.15(c)(d), the owner or operator must remedy any deterioration or malfunction of equipment or structures which the inspection reveals on a schedule which ensures that the problem does not lead to an environmental or human hazard.  Where a hazard is imminent or has already occurred, remedial action must be taken immediately.

 

As noted during the December 2012 inspections, Respondent did not properly manage the impermeable coating in the secondary containment system for the permitted wastewater treatment tanks in Containment Area #10 of Plant 1 and the Polishing Building containment area where the permitted hazardous waste Tanks U and W are located.  Specifically, the containment systems in both areas were observed with spalling, cracks, and otherwise deteriorated impermeable coating which was not documented in the tank inspection records.

 

Respondent provided on March 26, 2014 an inspection finding form dated December 27, 2012 which noted deficiencies to the coatings and that they were fixed on January 2, 2013.

 

f.             Pursuant to Permit Condition II.C., and Attachment C. Section 3.6, Heritage will perform dose-response testing to maintain efficient stabilization formulations for wastes shipped off-site and represented as meeting Land Band Restriction (LDR) treatment standards.  The dose/response testing will be performed monthly.

 

As noted during the December 16, 2011 and January 25 & 27, 2012 inspections, monthly dose response records prior to April 17, 2012 for waste stream (WS) 9000-431 (debris) and  prior to March 12, 2012 for WS 9000-236 (filtercake, no debris) were not available for inspection.

 

This finding was corrected by the Respondent based on correspondences dated May 23, 2012, March 26, 2014, and April 21, 2014.

 

g.            Pursuant to Permit Condition I.H.(6) and 40 CFR 264.73, the owner or operator must keep a written operating record to include the method(s) and date(s) of treatment of each hazardous waste received by the facility.

 

As noted during the December 16, 2011 inspection, the operating record did not include records verifying that the method of treatment to meet LDR was being conducted in dump floors in the containment buildings.  Specifically, as an example, on review of treated wastes in DF4, on 12/15/11 and DF1 on 12/15/11, it was not clear that the designated treatment [as required by approved stabilization reagent formulations determined through monthly dose/response tests in the Permit WAP] had been performed.  Records were also not made available for dose/response tests in conjunction with “special formulas” needed on one-time waste stream special soil projects. In addition, some of the records in the Treatment Logs did not identify the units being used [e.g., % or lbs or other applicable units].

 

10.       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 the statutes, rules, and/or permit conditions listed in the findings above.

 

3.            Within thirty (30) days of the Effective Date, Respondent shall submit documentation to IDEM of the repairs and steps that were taken to remedy the deteriorated impermeable coatings for the secondary containment systems for Containment Area 10, around the back side of “B” and “F” Tanks and Tanks U & W located within the Polishing Building.

 

4.            Upon the Effective Date, Respondent shall ensure the inspection logs also include the time of the inspection and the date and nature of any repairs or other remedial actions.

 

5.            Upon the Effective Date, Respondent shall document the dose/response sample ID number representing the selected treatment formulation for each treated batch on the treatment log. Submit within thirty (30) days a copy of the treatment log documenting the dose response sample ID treatment formulation for each treated batch.

 

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

 

Christina Halloran, Enforcement Case Manager

Office of Land Quality – Mail Code 60-02L

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

7.            Respondent is assessed and agrees to pay a civil penalty of Twenty Five Thousand Dollars ($25,000).  Within thirty (30) days of the Effective Date, Respondent shall pay a portion of this penalty in the amount of Five Thousand Dollars ($5,000) to the Environmental Management Special Fund.  In lieu of payment of the remaining civil penalty, Respondent shall make a cash payment to the Indiana Finance Authority ("IFA") to fund a Supplemental Environmental Project ("SEP") of activities related to brownfield development at a brownfield site ("Brownfield Site") in Indianapolis, Indiana.  Respondent will make a payment in the amount of Twenty Thousand Dollars ($20,000) to fund SEP activities at the Brownfield Site.  Respondent shall make such payment to the IFA within thirty (30) days of the Effective Date.  Payment to the IFA satisfies Respondent's obligation to undertake a SEP to offset a portion of the civil penalty assessed in this matter. Implementation of this SEP will benefit the community by rejuvenating neighborhoods, increasing the tax base, mitigating threats to human health and the environment, and/or reducing blight.  In the event that the civil penalty is not paid within thirty (30) 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.  The Brownfield Site at which some or all of the SEP proceeds will be spent will be determined by the Brownfields Program for a site located in Indianapolis, Indiana.  The designation of this Brownfield Site to receive the SEP proceeds is agreed upon by the Complainant, Respondent, and the IFA.  The IFA will account for the SEP payment and the Brownfields Program will oversee the work undertaken at the Brownfield Site funded by the SEP proceeds.  If SEP proceeds remain following a determination by the Brownfields Program that no additional SEP proceeds are needed at the Brownfield Site, the Brownfields Program will select another site or sites in Indianapolis at which work will be funded with the balance of the SEP proceeds.  The IFA will notify IDEM's Enforcement Case Manager when SEP-funded activities at the Brownfield Site (and any other site at which activities may be funded with SEP proceeds) are complete.

 

In the event that Respondent does not make its SEP payment within thirty (30) days of the Effective Date, the full amount of the civil penalty as stated in this paragraph, plus interest established by IC 24-4.6-1-101 on the remaining amount, less the portion of the civil penalty Respondent has already paid, will be due within fifteen (15) days from Respondent's receipt of IDEM's notice to pay.  Interest at the rate established by IC 24-4.6-1-101, shall be calculated on the amount due from the date which is thirty (30) days after the Effective Date of this Agreed Order until the full civil penalty is paid.

 

Payment of the SEP is payable by check to the "Indiana Finance Authority."  The text "SEP- Indianapolis" and the Case Numbers of this action shall be included in the memo line of the check.  The check shall be mailed to:

 

Meredith Gramelspacher

Indiana Brownfields Program - SEP

100 N. Senate Avenue

Room 1275

Indianapolis, Indiana  46204

 

8.            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:

 

Penalty

Stipulated Penalty

3

$500 per week

5

$500 per week

 

9.            Stipulated penalties shall be due and payable no later than the 30th day after Respondent receives written notice that Complainant has determined a stipulated penalty is due; the 30th day being the “Due Date”.  Complainant may notify Respondent at any time that a stipulated penalty is due.  Failure to notify Respondent in writing in a timely manner of stipulated penalty assessment shall not waive Complainant’s right to collect such stipulated penalty or preclude Complainant from seeking additional relief against Respondent for violation of this Agreed Order.  Neither assessment nor payment of stipulated penalties shall preclude Complainant from seeking additional relief against Respondent for a violation of this Agreed Order; such additional relief includes any remedies or sanctions available pursuant to Indiana law, including, but not limited to, civil penalties pursuant to IC 13-30-4.

 

10.         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

 

11.         In the event that the monies due to IDEM pursuant to this Agreed Order are not paid on or before their Due Date, Respondent shall pay interest on the unpaid balance at the rate established by IC 24-4.6-1.  The interest shall be computed as having accrued from the Due Date until the date that Respondent pays any unpaid balance.  Such interest shall be payable to the Environmental Management Special Fund, and shall be payable to IDEM in the manner specified in Paragraph 10, above.

 

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 their 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 permits 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: _______________________

 

 

COUSEL FOR INDIANA FINANCE AUTHORITY:

 

For the Indiana Brown fields Program

COUNSEL FOR RESPONDENT:

 

 

By:____________________

 

Director & General Counsel

 

 

By: ________________________

Date:__________________

 

 

 

 

COUNSEL &/OR AUTHORIZED

 

REPRESENTATIVE

Date: ______________________

 

 

By:_____________________

 

 

 

Date:___________________

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_______

DAY OF

________________________,

 20__.

 

 

For the Commissioner:

 

 

 

Signed 06/16/2014 By:_

 

Bruce H Palin

 

Assistant Commissioner

 

Office of Land Quality