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,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case No. 2014-22560-U

 

 

)

 

GSD Petroleum, llc,

 

)

 

S & H PETROLEUM, AND

 

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RAGHBIR S PALIA,

 

)

 

 

 

)

 

 

 

)

 

Respondents.

 

)

 

 

AGREED ORDER

 

Complainant and Respondents 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.  Respondents’ entry into this Agreed Order shall not constitute a waiver of any defense, legal or equitable, which Respondents 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 Raghbir S Palia operates an Underground Storage Tank (UST) systems, with UST Facility ID 4860 located at 2650 North State Road 9, parcel # 03-97-17-000-000.901-001 in Columbus, Bartholomew County, Indiana (the “Site”).

 

3.            Respondent S & H Petroleum owns 3 USTs which consist of 1-8,000 gallon gasoline tank, 1-6,000 gallon gasoline tank and 1-2,000 gallon diesel tank which were installed in 1974 and interior lined on November 4, 1992.

 

4.            Owner as defined in IC 13-11-2-150(a)(1)(A) means, for an UST that was in use on November 8, 1984 or brought into use after November 8, 1984 for the storage, use, or dispensing of regulated substances, a person who owns the UST or the real property that is the UST site, or both.  According to the Bartholomew County Assessor’s Office, Respondent GSD Petroleum, LLC is the property owner of the Site.

 

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

 

6.            Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation (NOV) via Certified Mail to:

 

Raghbir S Palia, UST Operator

Jaspal Singh Dhaliwal, Registered Agent

11786 E SR 250

GSD Petroleum, LLC

Crothersville, IN 47229

9653 N. Granville Rd.

 

Mequon, WI 53097

 

 

Raghbir S Palia, Owner & Registered Agent

GSD Petroleum, LLC

S & H Petroleum

2650 N SR 9

7251 E SR 7

Columbus, IN 47203

Columbus, IN 47203

 

 

7.            During an investigation including inspections on January 8, 2014; March 4, 2014 and April 24, 2014, conducted by a representative of IDEM, the following violations were found:

 

a.         Pursuant to 329 IAC 9-2-2(b), any person who owns an UST system or tank shall, within thirty (30) days of owning such an UST system or tank or bringing such tank or UST system into use, submit notice to the agency to register the tank or UST system.  Bringing a tank or UST system “into use” means the tank or UST system contains or has contained a regulated substance and has not been closed under 329 IAC 9-6.

 

As noted during the inspections, Respondents failed to submit notice to IDEM to register the tank or UST system within thirty (30) days of owning such an UST system or tank or bringing such tank or UST system into use.

 

b.         Pursuant to 329 IAC 9-7-2(1), the owner and operator of a petroleum UST system shall provide release detection for tanks and piping as follows: tanks must be monitored at least every thirty (30) days for releases using one (1) of the methods listed in section 4(4) through 4(8) of 329 IAC 9-7.

 

As noted during the inspections, Respondents failed to perform an appropriate method of monthly release detection for the underground storage tank system at the Site.

 

c.         Pursuant to 329 IAC 9-9-3(a)(b), the owner or operator of a UST system must designate a Class A, Class B, and Class C operator for the UST system on or before thirty (30) days after the effective date of this rule, except as provided in subsection (c). The owner and operator of the UST system are responsible for ensuring that the Class A, Class B, and Class C operators fulfill their responsibilities under this rule. Each designated operator must be certified under this rule as follows:

 

(1)       An incoming designated Class A or Class B operator for an existing UST system without compliance deficiencies documented by the department must be certified within thirty (30) days of assuming full operation and maintenance responsibilities at the UST system.

(2)          An incoming designated Class C operator must be certified before assuming responsibilities at a UST system facility.

(3)       An incoming designated Class A or Class B operator at an existing facility that has compliance deficiencies documented by the department must be certified before assuming full operation and maintenance responsibilities at a UST system facility.

(4)       The owner or operator of a UST system that goes into use after the effective date of this rule must designate a certified Class A, Class B, and Class C operator for that system within thirty (30) days of bringing the UST system into use. If the owner and operator of the UST system are separate persons, either the owner or operator may designate the Class A, Class B, and Class C operators for the UST system, but both the owner and the operator have equal responsibility to ensure that Class A, Class B, and Class C operators are designated. An owner or operator may contract with another person to provide Class A or Class B operator services for the owner or operator's UST system.  (b) Either a Class A, Class B, or Class C operator must be present on-site during the operation of a UST system facility, except as provided in subsection (c). At the owner or operator's discretion, one (1) person may be designated as the Class A, Class B, and Class C operator for a facility, provided that person complies with the requirements including the training requirements contained in section 6 of this rule, for each class for which that person is designated.

 

As noted during the inspections, Respondents failed to designate a certified Class A, Class B, and Class C operators for the UST system at the Site.

 

d.         Pursuant to 329 IAC 9-9-7(a)(b) & (c), owners and operators shall maintain records identifying designated and certified Class A, Class B, and Class C operators of each UST system as required in 329 IAC 9-3-1(d).  When requested by the department or at any inspection conducted by the state fire marshal, owners and operators of a facility of facilities containing a UST system shall provide a list of designated certified Class A, Class B, and Class C operators, as applicable for each facility.  All records maintained under this section must include current contact information for each designated operator, including a telephone number and mailing address.

 

As noted during the inspections, Respondents failed to provide a list of designated certified Class A, Class B, and Class C operators upon request that included current contact information for each designated operator.

 

8.         On May 19, 2015, Respondents submitted a copy of the Class A, Class B & Class C operator certification for the Site.

 

9.            In recognition of the settlement reached, Respondents waive 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 Respondents.  This Agreed Order shall have no force or effect until the Effective Date.

 

2.            Respondents shall comply with the rule listed in the findings above.

 

3.            Within fifteen (15) days of the Effective Date, Respondents shall submit to IDEM, on the form included as Attachment A, an updated Notification for USTs form.  Respondents may also find the form at http://www.in.gov/idem/5157.htm#olq_ust.

 

4.            Within fifteen (15) days of the Effective Date, Respondents shall begin using an appropriate form of monthly release detection in accordance 329 IAC 9-7-2(1).

 

5.            Within thirty (30) days of the Effective Date, Respondents shall submit documentation of a passing monthly release report, in accordance with 329 IAC 9-7-4(4).

 

6.            Within thirty (30) days of the Effective Date, Respondents shall investigate a suspected release in accordance with 329 IAC 9-4-1.

 

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

 

Janet Arnold, Technical Environmental Specialist

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

8.            Respondents are assessed and agree to pay a civil penalty of Fifteen Thousand Dollars ($15,000).  Respondents are jointly and severally liable for all civil penalty assessments, including stipulated penalties.  Said penalty amount shall be due and payable to the Underground Petroleum Storage Tank Trust Fund in twenty-four (24) monthly installments.  The first installment payment in the amount of Six Hundred and Twenty-Five Dollars ($625) is due within thirty (30) days of the Effective Date; the 30th day being the “Due Date”.  Thereafter, subsequent monthly payments in the amount of Six Hundred and Twenty-Five Dollars ($625) shall be due on the 30th day being the “Due Date”.  Interest shall accrue on unpaid amounts at the rate established by IC 24-4.6-1-101.

 

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

 

Order Paragraph 3

$200 per week or part thereof late

Order Paragraph 4

$500 per week or part thereof late

Order Paragraph 5

$200 per week or part thereof late

Order Paragraph 6

$500 per week or part thereof late

 

10.         Stipulated penalties shall be due and payable no later than the 30th day after Respondents receive written notice that Complainant has determined a stipulated penalty is due; the 30th day being the “Due Date”.  Complainant may notify Respondents at any time that a stipulated penalty is due.  Failure to notify Respondents 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 Respondents for violation of this Agreed Order.  Neither assessment nor payment of stipulated penalties shall preclude Complainant from seeking additional relief against Respondents 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.

 

11.         Civil and stipulated penalties are payable by check to the “Underground Petroleum Storage Tank Trust Fund.”  Checks shall include the Case Number of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Office of Legal Counsel

IGCN, Room N1307

100 North Senate Avenue

Indianapolis, IN 46204

 

12.         In the event that the monies due to IDEM pursuant to this Agreed Order are not paid on or before their Due Date, Respondents 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 Respondents pay any unpaid balance.  Such interest shall be payable to the Underground Petroleum Storage Tank Trust Fund, and shall be payable to IDEM in the manner specified in Paragraph 11 above.

 

13.         This Agreed Order shall jointly and severally apply to and be binding upon Respondents and their successors and assigns.  Respondents’ 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 Respondents shall in any way alter its status or responsibilities under this Agreed Order.

 

14.         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.

 

15.         Respondents shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred.  Respondents shall ensure that all contractors, firms and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

 

16.         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 Respondents pursuant to this Agreed Order, shall not in any way relieve Respondents of their obligation to comply with the requirements of its applicable permits or any applicable Federal or State law or regulation.

 

17.         Complainant does not, by its approval of this Agreed Order, warrant or aver in any manner that Respondents’ 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 Respondents may incur as a result of Respondents’ efforts to comply with this Agreed Order.

 

18.         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.

 

19.         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 Respondents may incur as a result of such communications with the EPA or any other agency or entity.

 

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

 

TECHNICAL RECOMMENDATION:

RESPONDENTS:

Department of Environmental Management

 

 

 

By: _________________________

By:  _________________________

 

Nancy Johnston, Section Chief

GSD Petroleum

 

Enforcement Section

 

Office of Land Quality

Printed: ______________________

 

 

 

Title: ________________________

 

 

Date: __________________

Date: _______________________

 

 

 

 

 

By:  _________________________

 

S & H PETROLEUM,

 

 

 

Printed: ______________________

 

 

 

Title: ________________________

 

 

 

Date: _______________________

 

 

 

 

 

By:  _________________________

 

RAGHBIR S PALIA,

 

 

 

Printed: ______________________

 

 

 

Title: ________________________

 

 

 

 

 

Date: _______________________

 

 

 

 

 

COUNSEL FOR RESPONDENTS:

 

 

 

 

 

By: ________________________

 

 

 

 

 

 

Date: ______________________

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_____

DAY OF

________________________,

 20__.

 

 

For the Commissioner:

 

 

 

Signed November 19, 2015

 

Bruce H Palin

 

Assistant Commissioner

 

Office of Land Quality