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. 2017-24272-U

 

 

)

 

JIT REAL ESTATE INVESTMENT INC,

 

)

 

JIT INDIANA LLC, &

 

)

 

HERDRICH PETROLEUM CORP.,

 

)

 

 

 

)

 

Respondent,

 

)

 

 

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.               Respondents are JIT Indiana LLC, JIT Real Estate Investment Inc., and Herdrich Petroleum Corp., (“Respondents”), which own/operate the Underground Storage Tank (“UST”) system, with UST Facility ID No. 227, located at 1107 N. Lincoln Street, in Greensburg, Decatur County, Indiana (“Site”).

 

3.       The Site has one (1) 12,000 gallon and two (2) 10,000 gallon steel STiP3 gasoline tanks, and one (1) 6,000 gallon steel STiP3 kerosene tank, all of which were installed November 3, 1995.

 

4.               Respondent Herdrich Petroleum Corp owned the real property that is the UST site at the time the Notice of Violation was issued.  According to Indiana Property Record Card, Parcel Number 16-11-02-110-024.000-016, located at 1107 N. Lincoln Street in Greensburg, Decatur County, belonged to Herdrich Petroleum Corp. The Decatur County Recorder recorded a Memorandum of Land Contract between Herdrich Petroleum Corp and JIT Real Estate Investment Inc.  The Memorandum of Land Contract executed on April 15, 2014 specified the terms and conditions of the Land Contract.  According to a Notification for Underground Storage Tanks form (State Form 45223) received by IDEM on April 16, 2015, Respondent JIT Real Estate Investment Inc. owned the real property that is the UST Site.  On November 16, 2017, Herdrich Petroleum Corp Quitclaim Deeded the property to JIT Real Estate Investment, Inc.

 

5.               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.

 

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

 

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

 

Balwinder Singh, Registered Agent

Balwinder Singh, Registered Agent

JIT Real Estate Investment Inc.

JIT Indiana LLC

2965 Heirloom Lane

2965 Heirloom Lane

Greenwood, IN  46143

Greenwood, IN  46143

 

 

William J. Herdrich, Registered Agent

William J. Herdrich, President

Herdrich Petroleum Corp

Herdrich Petroleum Corp.

296 E. Riverside Dr.

210 East US 52 STE. E.

Rushville, IN  46173

Rushville, IN  46173

 

8.               During an investigation including an inspection on December 6, 2016, conducted by a representative of IDEM, the following violations were found:

 

a.       Pursuant to 329 IAC 9-3.1-2(1), (2), and (3), the owner and operator of a steel UST system with corrosion protection shall comply with the following requirements to ensure that releases due to corrosion are prevented for as long as the UST system is used to store regulated substances:

 

(1)            All corrosion protection systems must be operated and maintained to continuously provide corrosion protection to the metal components of that portion of the tank and piping that routinely contain regulated substances and are in contact with the ground.

 

(2)            All UST systems equipped with galvanic cathodic protection systems must be inspected for proper operation by a qualified cathodic protection tester under the following requirements:  (A) all galvanic cathodic protection systems must be tested within six (6) months of installation and at least every three (3) years thereafter; and (B) Nace International (formerly the National Association of Corrosion Engineers) Standard RP0285-95 “Corrosion Control of Underground Storage Tank Systems by Cathodic Protection”, revised 1995 NACE International, P.O. Box 218340, Houston, Texas 77218-8340.

 

(3)            All UST systems with impressed cathodic protection systems must be: (A) inspected every sixty (60) days to ensure the equipment is running according to manufacturer’s specifications; and (B) tested within six (6) months of installation and at least every three (3) years thereafter.

 

As noted during the inspection, Respondents failed to perform corrosion protection for the steel UST system at the Site to ensure that releases due to corrosion are prevented.  The facility has been out of use for an unknown period of time.  While all USTs contained quantities of regulated product, there is no record of corrosion protection testing for the UST system at the Site.

 

b.       Pursuant to 329 IAC 9-3-1(d), the owner and operator shall maintain the records required at: (1) the underground storage tank site and immediately available for inspection by the agency; or (2) a readily available alternative site and be provided for inspection to the agency upon request.

 

As noted during the inspection, Respondents failed to maintain the records required at the underground storage tank site, or a readily available alternative site.  IDEM requested for inspection, records of corrosion protection testing and release detection testing, which are records required at the site or a readily available alternative site.  Respondents failed to make such records available to IDEM at the time of the inspection and did not respond to the Violation Letter dated December 12, 2016, requesting the records.

 

c.               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, Respondents failed to perform an appropriate method of monthly release detection for the underground storage tank system at the Site.  There were dispensers located at the facility, but they were all Red Tagged by the Department of Weights and Measures.  The store building is vacant and the electric meter does not appear to be on.  Electric power is generally required for proper operation of Automatic Tank Guage.

 

9.               Respondents submitted passing tank tightness test for the three (3) 10,000 gallon gasoline tanks, but the one (1) 6,000 gallon kerosene tank failed.

 

10.           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.               Within thirty (30) days of the Effective Date, Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall conduct line tightness testing for the kerosene tank and submit the results to IDEM.

 

3.               Within thirty (30) days of the Effective Date, if not already submitted to IDEM then Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall submit the last twelve (12) months of the UST system release detection test results to IDEM.

 

4.               Within thirty (30) days of the Effective Date, if not already submitted to IDEM then Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall submit the last two (2) cathodic protection test results for the UST system to IDEM.

 

5.               Within thirty (30) days of the Effective Date, if the test results for the past year have not already been submitted to IDEM then Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall have the corrosion protection system on its UST system fully inspected by a qualified cathodic protection tester and submit the results to IDEM.

 

6.               If Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. cannot comply with the requirements of Order paragraphs two (2) through five (5), then Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall comply with the requirements of Order paragraphs seven (7) through ten (10).

 

7.               Within sixty (60) days of the Effective Date, Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall permanently close the underground storage tanks in accordance with the requirements of 329 IAC 9-6-1 through 329 IAC 9-6-4, including the applicable requirement for corrective action under 329 IAC 9-5-1 through 329 IAC 9-5-8.

 

8.               At least thirty (30) days before beginning closure, Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall notify IDEM using the notification form required by 329 IAC 9-2-2(a), and the office of the state fire marshal of intent to close the underground storage tanks.

 

9.               At least seven (7) days prior to scheduled closure activities, Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall notify IDEM’s Underground Storage Tank Section to permit an agent of IDEM to view and inspect the activities performed pursuant to closure of the UST system.

 

10.           Within thirty (30) days of closing the UST system, Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall submit a closure report to IDEM which shall include the notification form required by 329 IAC 9-2-2(a).

 

11.     All submittals required by this Agreed Order, unless Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. 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

 

12.     Respondents are assessed and agree to pay a civil penalty of Twenty-Five Thousand Dollars ($25,000.00).  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 four (4) installments.  The first installment of Six Thousand Two Hundred and Fifty Dollars ($6,250.00) shall be paid within ninety (90) days of the Effective Date; the 90th day being the “Due Date”.  Subsequent installments of Six Thousand Two Hundred and Fifty Dollars ($6,250.00) shall be paid one hundred and eighty (180) days of the Effective Date, two hundred and seventy (270) days of the Effective Date, and three hundred and sixty (360) days of the Effective Date.

 

13.     In the event the terms and conditions of the following paragraphs are violated, Complainant may assess and Respondents JIT Indiana LLC and JIT Real Estate Investment Inc. shall pay a stipulated penalty in the following amount:

 

Order Paragraph 2

$250 per week late

Order Paragraph 3

$250 per week late

Order Paragraph 4

$250 per week late

Order Paragraph 5

$250 per week late

Order Paragraph 7

$500 per week late

Order Paragraph 8

$100 per week late

Order Paragraph 9

$100 per week late

Order Paragraph 10

$250 per week late

 

 

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

 

15.     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

 

16.     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 15, above.

 

17.     This Agreed Order shall jointly and severally apply to and be binding upon Respondents 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 their status or responsibilities under this Agreed Order.

 

18.     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.

 

19.     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.

 

20.     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 their applicable permits or any applicable Federal or State law or regulation.

 

21.     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.

 

22.     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.

 

23.     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.

 

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

 

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 RESPONDENT:

 

 

 

By: _________________________

 

 

 

 

Date: ________________________

 

 

RESPONDENT:

 

 

 

 

 

By:  _________________________

 

 

 

 

 

Printed: ______________________

 

 

 

Title: ________________________

 

 

 

Date: ________________________

 

 

 

 

 

COUNSEL FOR RESPONDENT:

 

 

 

By: _________________________

 

 

 

 

Date: ________________________

 

 

RESPONDENT:

 

 

 

 

 

By:  _________________________

 

 

 

 

 

Printed: ______________________

 

 

 

Title: ________________________

 

 

 

Date: ________________________

 

 

 

 

 

COUNSEL FOR RESPONDENT:

 

 

 

By: _________________________

 

 

 

 

Date: ________________________

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_________

DAY OF

________________________,

20__.

 

 

For the Commissioner:

 

 

 

Signed August 7, 2018

 

Peggy Dorsey, Assistant Commissioner

 

Office of Land Quality