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. 2014-22627-U

 

 

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KJS properties, llc

 

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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 KJS Properties, LLC (“Respondent”), which owns/operates the Underground Storage Tank (UST) system located at 4899 Georgia Street in Gary, Lake County, Indiana (“Site”).

 

3.         Respondent has (1) 10,000 gallon steel tank and (1) 8,000 gallon steel tank both of which were installed January 1, 1978.

 

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

 

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

 

KJS Properties, LLC, Property Owner

Tracy Kamba, CPA, Registered Agent

1535 W. Grand Avenue

KJS Properties, LLC

Chicago, IL  60642

1901 E. 31st Street, Unit B

 

LaGrange, IL  60526

 

 

Yehya Alqalab, Registered Agent

Yehya Alqalab, Incorporator

A & Y Gas & Mini Mart, Inc.

A & Y Gas & Mini Mart, Inc.

4899 Georgia Street

7106 Broadway

Gary, IN  46409

Merrillville, IN  46410

 

6.         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 Lake County Assessor’s Office, Respondent is the owner of the Site.  In a Special Warranty Deed executed on March 28, 2012, Heartland Bank and Trust Company, an Illinois state bank granted the real property to KJS Properties, LLC, an Illinois limited liability company.

 

7.            A Violation Letter was issued to Respondent KJS Properties, LLC on June 6, 2014, which required Respondent to submit a Notification form within thirty (30) days of receipt of the Violation Letter.  Respondent failed to respond to the Violation Letter.

 

8.            During an investigation including an inspection on January 10, 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 not been closed under 329 IAC 9-6; and (d) an owner required to submit notice under this section shall provide all the information required by the form provided by the agency for each tank for which notice is submitted.

 

As noted during the inspection, Respondent, as owner of the Site, failed to submit notice to IDEM within thirty (30) days of owning the UST system.  No notification signed by Respondent as owner has been submitted to IDEM.

 

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 inspection, Respondent failed to perform monthly release detection on the USTs at the Site.

 

c.            Pursuant to 329 IAC 9-7-4(4)(A)(B), equipment for automatic tank gauging that tests for the loss of product and conducts inventory control must meet the following requirements:

(A)       The automatic product level monitor test can detect a two-tenths (0.2) gallon per hour leak rate from any portion of the tank that routinely contains product.

(B)       Inventory control, or another test of equivalent performance, is conducted under subdivision (1).

 

As noted during the inspection, Respondent failed to perform monthly release detection for the UST system at the Site.

 

d.         Pursuant to 329 IAC 9-9-3(a), 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.

 

As noted during the inspection, Respondent failed to designate a certified Class A, B, and C operator for the UST system at the Site.

 

9.            On May 24, 2016, IDEM received Class A, Class B, and Class C Operator training certificates from Respondent.

 

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 sixty (60) days of the Effective Date, Respondent shall submit notice to IDEM to register tanks using an approved Notification for USTs form.

 

4.            Within sixty (60) days of the Effective Date, Respondent shall perform monthly release detection tests for all USTs at the Site.  Respondent shall submit the passing test results to IDEM for eight (8) months.

 

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

 

Sherri Bass, Enforcement Case Manager

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

6.            Respondent is assessed and agrees to pay a civil penalty of  Eighteen Thousand Eight Hundred and Eighty Dollars ($18,880).  The civil penalty shall be paid in the following manner: Twenty three monthly payments of $786.66 and one monthly payment of $786.82. The First installment of the civil penalty shall be due and payable to the Environmental Management Special Fund within thirty (30) days of the Effective Date of this Agreed Order.  Payments shall be made every month for twenty four (24) months.  Said penalty amount shall be due and payable to the Underground Petroleum Storage Tank Trust Fund.

 

In the event that the civil penalty is not paid when due according to the installment payment schedule, 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.

 

7.         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

Penalty

Order Paragraph 3

$100 per week late

Order Paragraph 4

$100 per week late

 

8.         Stipulated penalties shall be due and payable no later than the 30th day after Respondent receive 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.

 

9.         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

Accounts Receivable

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

10.       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 Underground Petroleum Storage Tank Trust Fund, and shall be payable to IDEM in the manner specified in Paragraph 10, above.

 

11.         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.

 

12.         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.

 

13.         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.

 

14.         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 Respondent of its obligation to comply with the requirements of its applicable permits or any applicable Federal or State law or regulation.

 

15.         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.

 

16.         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.

 

17.         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.

 

18.         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: ________________________

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

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DAY OF

________________________,

 20__.

 

 

For the Commissioner:

 

 

 

Signed June 28, 2016__

 

Bruce H Palin

 

Assistant Commissioner

 

Office of Land Quality