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. 2020-27103-S

 

 

)

 

garrett 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 Indiana Code (“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 IC 13-13-1-1.

 

2.            Respondent is Garrett LLC (“Respondent”), the owns/operates the former Dalton Foundry, parcel number 57-09-04-400-482.000-004 (“Foundry”) located at 200 West Ohio Street, in Kendallville, Noble 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”) to:

 

Michael E. Heitz, Member

Cory Heitz, Member

Garrett LLC

Garrett LLC

588 Central Avenue

coryheitz@gmail.com

Lexington, KY 40502

 

mh@meheitz.com

 

 

 

Rosie Miller, Registered Agent

 

Garrett LLC

 

1600 Kammerer Rd.

 

Kendallville, IN 46755

 

 

5.            The February 12, 2020, inspection resulted in the issuance of a Violation Letter dated February 19, 2020.

 

6.            During an investigation including a record review and inspection on February 12, 2020 conducted by a representative of IDEM, the following violations were found:

 

a.         Pursuant to 329 IAC 10-4-4, the owner of real estate upon which an open dump is located is responsible for the following:

(1)          Correcting and controlling any nuisance conditions that occur as a result of the open dump.  Correction and control of nuisance conditions must include:

A.           Removal of all waste from the area of the open dump and disposal of such wastes in a solid waste land disposal facility permitted to accept the waste; or

B.           Other methods as approved by the commissioner.

(2)          Eliminating any threat to human health or the environment.

 

As noted during the record review, Respondent purchased the property in July 2014 and has not yet complied with the requirements of 329 IAC 10-4-4.

 

b.         Pursuant to 329 IAC 10-4-3, open dumping and open dumps, as those terms are defined in IC 13-11-2-146 and IC 13-11-2-147, are prohibited.

 

As noted during the inspection, foundry waste was disposed at the Site so as to constitute an open dump. Additionally, foundry waste appeared to be leaving the property via drainage ditches on-site and leachate also appears to be entering the ditches.

 

c.          Pursuant to IC 13-30-2-1(4), no person shall deposit or cause or allow the deposit of contaminants or solid waste upon the land, except through the use of sanitary landfills, incineration, composting, garbage grinding, or another method acceptable to the board.

 

As noted during the inspections, Respondent caused and/or allowed contaminants and/or solid waste to be deposited at the Site in a method unacceptable to the board. Specifically, exposed foundry sand waste was present throughout the property. Additionally, foundry waste appeared to be leaving the property via drainage ditches on-site and leachate also appears to be entering the ditches.

 

d.          Pursuant to 329 IAC 10-4-2, no person shall cause or allow the storage, containment, processing, or disposal of solid waste in a manner which creates a threat to human health or the environment, including the creating of a fire hazard, vector attraction, air or water pollution, or other contamination.

 

As noted during the inspection, exposed foundry sand waste was present throughout the property. Additionally, foundry waste appeared to be leaving the property via drainage ditches on-site and leachate also appears to be entering the ditches.

 

e.          Pursuant to IC 13-30-2-1(5), no person shall dump or cause or allow the open dumping of garbage or any other solid waste in violation of rules adopted by the board.

 

As noted during the inspection, foundry waste was disposed at the Site to constitute an open dump. Additionally, foundry waste appeared to be leaving the property via drainage ditches on-site and leachate also appears to be entering the ditches.

 

7.            On January 18, 2022, IWM Consulting Group submitted a Closure Plan on behalf of Respondent.

 

8.            Orders of the Commissioner are subject to administrative review by the Office of Environmental Adjudication under IC 4-21.5; however, in recognition of the settlement reached, Respondent acknowledges notice of this right and 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 and rules listed in the findings of fact above.

 

3.            Within one (1) year of the Effective Date, Respondent shall implement closure requirements to address the waste deposited on the Site. Specifically, Respondent shall:

 

a.         Clear trees and large vegetation and grade the surface to create a minimum of 2% slope and a maximum of 33% slope. Other slopes may be acceptable if use of the property and alternative cover is proposed and approved by IDEM. If other alternatives are proposed and approved by IDEM, the proposal shall demonstrate that erosion can be controlled on the steeper slopes, or no ponding of water will occur on the flatter slopes. This may include working around the easement for the existing power lines.

 

b.         Establish soil cover over exposed waste unless an alternative cover is proposed and approved by IDEM.  IDEM will accept, at a minimum, eighteen inches of clay-type soil, although two feet of clay-type soil is recommended.  Respondent may place the eighteen inches in stages as the soil becomes available, provided erosion control methods are implemented, and the soil is placed within one year.

 

c.         The final cover shall have a maximum soil loss is of 5 tons per acre per year based on the Universal Soil Loss Equation, as required by 329 IAC 10-30-3.

 

d.         Establish vegetation over the covered waste area.

 

e.            Once at least eighteen inches of clay-type soil has been placed, graded, and seeded, Respondent shall submit to IDEM within thirty (30) days of completing Orders 3.b., 3.c., and 3.d. the required closure documentation. The documentation shall include: as-built grading plan depicting waste boundaries; verification of the soil cover thickness by probes, hand auger, or test pits; and minimum number of borings or holes should be two per acre.

 

f.          Any post-closure use of the property requires IDEM approval.

 

g.         Prepare an operational and maintenance (“O&M”) plan.  The O&M plan, at a minimum, shall include:

·                     Mowing as needed, typically twice per year.

·                     Maintain the silt fence around the soil covered area until vegetation is established.

·                     Maintain the vegetative cover.

·                     Inspect at least 2 times per year for erosion; any erosion rills and gullies deeper than nine (9) inches that have formed must be filled, graded, reseeded, and mulched, or otherwise stabilized.

·                     Submit biannual inspection reports to IDEM within 60 days of the date of inspection.

·                     No trees, woody shrubs, or deep-rooted plants may be grown on the vegetated cover unless it is approved by the commissioner based on a demonstration that the roots will not penetrate into the waste layer.

·                     No foundry waste may be exposed (visible) at any time.

·                     A description of the storm water quality measures to be implemented to control or minimize pollutants associated with storm water run-off.

 

4.            Within thirty (30) days of the Effective Date, Respondent shall submit to IDEM for review prior to recording a draft environmental restrictive covenant (“ERC”) for the area where waste was deposited.  Determining the area where waste was deposited may require delineation of the solid waste boundaries, which may require test pits. After the ERC is approved by IDEM, Respondent shall record and send proof of recording within thirty (30) days. The ERC shall include the following terms:

 

a.         The ERC must identify appropriate restrictions to ensure the soil cap and vegetated cover is not damaged, which shall include ongoing compliance by any future owners with the approved operational and maintenance plan.

b.            The ERC shall also state that groundwater may not be withdrawn from the Site for drinking water purposes.

c.            The existing wells on Respondent’s property must not be altered or destroyed until approved by IDEM.  Once approved by IDEM, the groundwater monitoring wells shall be closed in accordance with IDNR 312 13-10-2.

 

5.            Within thirty (30) days of the Effective Date, Respondent shall submit to IDEM a legal description of the Site, which shall include a correct description of the southwest boundary.

 

6.            Within sixty days (60) of the Effective Date, Respondent shall provide closure and post-closure cost estimate, and an original copy of financial assurance established for the amount established by the cost estimate.

 

7.            Upon the Effective Date, Respondent shall cease releases of foundry waste and leachate into the on-site drainage ditches.

 

8.            All submittals required by this Agreed Order, unless IDEM notifies the Respondent otherwise in writing, shall be sent to:

 

Christina Halloran, Enforcement Case Manager

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

9.            Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Twenty-Two Thousand Five Hundred Dollars ($22,500). Within thirty (30) days of the Effective Date, Respondent shall pay a portion of this penalty in the amount of Four Thousand Five Hundred Dollars ($4,500) 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 Noble County, Indiana. Respondent will make a payment in the amount of Eighteen Thousand Dollars $18,000 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 Noble County, 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 Noble County 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

 

Civil and stipulated penalties are payable to the “Environmental Management Special Fund” by:

 

Mail:

Civil 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

Accounts Receivable

IGCN, Room 1340

100 North Senate Avenue

Indianapolis, IN 46204

 

Online:

Accounts Receivable is accepting payments online by e-Check, Master Card, Visa or Discover. Please visit www.IN.gov/IDEM. Under Online Services, click Online Payment options and follow the prompts. A processing fee of $1 plus 1.99% will be charged for credit card payments.  A processing fee of $1.00 will be charged for eCheck payments.

 

The Case Number is required to complete the process.

 

Phone:

You may also call us at 317-234-3099 and follow the instructions for Master Card, Visa or Discover payments. A processing fee of $1 plus 1.99% will be charged for credit card payments. A processing fee of $1.00 will be charged for eCheck payments.

 

The Case Number is required to complete the process.

 

10.         In the event the terms and conditions of the following paragraphs are violated, Complainant may assess and Respondent shall pay stipulated penalties in the following amounts:

 

Paragraph

Stipulated Penalty

Order paragraph #3

$100 per week late

Order paragraph #4

$100 per week late

Order paragraph #5

$100 per week late

Order paragraph #6

$100 per week late

 

11.         Stipulated penalties shall be due and payable no later than the thirtieth day after Respondent receives written notice that Complainant has determined a stipulated penalty is due; the thirtieth 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 a 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.

 

12.         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 9, above.

 

13.         Signatories to this Agreed Order certify that they are fully authorized to execute this Agreed Order and legally bind the party they represent.

 

14.         This Agreed Order shall apply to and be binding upon Respondent and all successors and assigns. Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners, successors, or assigns before ownership rights are transferred.

 

15.         No change in ownership, corporate, or partnership status of Respondent shall in any way alter the Respondent’s status or responsibilities under this Agreed Order.

 

16.         Respondent shall ensure that all contractors, firms, and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

 

17.         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.

 

18.         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 the obligation to comply with the requirements of any applicable permits or any applicable Federal or State laws or regulations.

 

19.         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.

 

20.         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 violations specified in the NOV.

 

21.         Nothing in this Agreed Order shall prevent IDEM or anyone acting on its behalf from communicating with the U.S. Environmental Protection Agency (U.S. 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 U.S. EPA or any other agency or entity.

 

22.         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:  _________________________

 

Jennifer Reno, Section Chief

 

 

Land Enforcement Section

Printed: ______________________

Office of Land Quality

 

 

Title: ________________________

 

 

Date: _____________

Date: _______________________

 

 

 

 

COUNSEL FOR THE INDIANA FINANCE

COUNSEL FOR RESPONDENT:

AUTHORITY:

 

For the Indiana Brownfields Program

 

By:  _________________________

By:  _________________________

 

 

Printed: ______________________

Printed: ______________________

 

 

Title: ________________________

Title: ________________________

 

 

Date: _______________________

Date: _______________________

 

 

 

 

COUNSEL &/OR AUTHORIZED

 

REPRESENTATIVE:

 

For the City of Kendallville:

 

 

 

By:  _________________________

 

 

 

Printed: ______________________

 

 

 

Title: ________________________

 

 

 

Date: _______________________

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_________

DAY OF

________________________,

20__.

 

 

For the Commissioner:

 

 

 

Signed 10/11/2022_____________

 

Peggy Dorsey, Assistant Commissioner

 

Office of Land Quality