STATE OF
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BEFORE THE
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COUNTY OF
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ENVIRONMENTAL
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COMMISSIONER
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OF
ENVIRONMENTAL MANAGEMENT, |
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Complainant, |
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Case No. 2020-27180-H |
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TRADEBE TREATMENT AND RECYCLING, 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 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 Tradebe Treatment and Recycling,
LLC (“Respondent”), which owns and operates the facility with U.S. EPA ID No. IND000646943,
located at 4343 Kennedy Avenue, in East Chicago, Lake County, Indiana (“Site”).
3.
Respondent has a RCRA permit (“Permit”), which
authorizes Respondent, as the permittee, to conduct storage and treatment
activities at this Site. Respondent operates as a large quantity generator of
hazardous waste pursuant to a Permit dated April 28, 2017 (modified December
17, 2018).
4.
IDEM has jurisdiction over the parties and the
subject matter of this action.
5. Pursuant to IC 13-30-3-3, on November
13, 2020, IDEM issued a Notice of Violation (“NOV”) to:
Tradebe Treatment and Recycling, LLC |
Corporation Service Co., Registered Agent |
Attn: Victor
Creixell De Villalonga,
Mgr. |
Tradebe Treatment and Recycling, LLC |
234
Hobart Street |
135 N. Pennsylvania Street, Suite 1610 |
Meriden, CT 06450 |
Indianapolis, IN 46204 |
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Tradebe Treatment and Recycling, LLC |
Tradebe Treatment and Recycling, LLC |
Attn: Timothy Denhof, EHS Manager |
Attn: Tita LaGrimas, VP Regulatory Affairs |
4343 Kennedy Avenue |
1433 East 83rd Avenue, Suite 200 |
East Chicago, IN 46312 |
Merrillville, IN 46410 |
6.
329 Indiana
Administrative Code (“IAC”) 3.1 incorporates certain federal hazardous waste
management requirements found in 40 Code of Federal Regulations (“CFR”) Parts
260 through 270 and Part 273, including those identified below.
7.
During an investigation, including an inspection
on June 22, 2020 conducted by a representative of
IDEM, the following violations were found:
a. Pursuant to Permit
Condition I.D.8.b, the Permittee shall allow the Commissioner or an authorized
representative to have access to and copy, at reasonable times, any records
that must be kept under the conditions of the Permit.
As noted
during the inspection and subsequent August 21, 2020
submittal, Respondent failed to produce the requested manifests, waste
profiles, waste analysis, and reason for quarantine for the quarantined containers
located in Area 7-A4 and listed in Attachment C of the June 22, 2020 Inspection
Report (VFC# 83003998). To include, but not limited to, the following:
1. Information on Drums: D005424653,
D005391250, D005395538, D005406520, D005406521, D005422094, D004958251,
D004958252, D005382060, D004948609, D005384185, and D005389527.
2. Drum D005389483 on Manifest
014839390FLE (received on 05/19/2020) was shipped as Waste Solids Containing
Flammable Liquids (D001, D018, D035, D039, D040, U002); however, the approved
Profile states “drained retain sample jars.” The requested Waste Analysis was
not submitted.
3. Drum D005419778 on Manifest
021094600JJK (received on 06/01/2020) was shipped under Profile # FC-004 as
Waste Methyl Methacrylate Monomer, Stabilized. The Manifest was amended on
06/12/20 to add D001 as per the Profile. The requested lab analysis and waste
analysis were not submitted.
4. Drum D005435636 and D005435637 on
Manifest 020945607JJK (received 06/05/2020) were shipped as Waste
Environmentally Hazardous Substance, Liquid (D011) under Profile # ZIH-19-LP04C6
(2 x CF @1035P). The profile is for lab pack quantities of low BTU materials;
however, the containers were cubic yard boxes. The containers were marked Profile
DS022-19-TX06C6 and had the correct shipping description. The August 21, 2020 submittal corrected this error but failed to include the
waste analysis as requested.
5. Drum D006435668 on Manifest
020945607JJK (received 06/05/2020) was shipped as Hazardous Waste Solid (D009,
D006, D008, D011) under Profile # DS001-19-TX97C6. The profile DS001-19-TX97C6
included in the August 21, 2020 submittal was for a
different generator. The requested waste analysis was
not submitted.
6. Drum D005439729, D005439730,
D005439731, D005439732 on manifest 013753091FLE (received 06/08/2020) were
shipped under Profile # WOM-475 as Waste Paint Related Materials (D001, U031,
U197). The approved Profile lists waste codes D001, D002, U031, and U197. D002
was not listed on the Manifest. The requested waste analysis was not submitted
nor was the reason the containers were in Area 7-A4.
7. Drum D005429949 and D005429950 on Manifest
020920936JJK (received 3/23/2020) were shipped as Waste PCBs with waste codes
D005, D006, D007, D008 (2DF at 7Kg) under Profile # PCB12-15-PC09C7. A
description of what the container contained was not provided.
8. Drum D005429894 on Manifest
020945561JJK (received 06/01/2020) was shipped under Profile # ZP2-19-LP08C1 as
Waste 1,1,1 Trichloroethane (U226). Profile ZP2-19-LP08C1 is for reactive lab
pack material with multiple D, F, K, P, and U codes and a shipping description
of Waste Self Heating Solid, Toxic, Inorganic 4.2 (6.1). Information requested
as to why the container was in Area 7-A4 was not received.
b. Pursuant to 40 CFR
264.72(e)(4),
for full or partial load rejections and residues that are to be sent off-site
to an alternate facility, the facility is required to prepare a new manifest in
accordance with §262.20(a) of this chapter and copy the manifest tracking
number found in Item 4 of the new manifest to the manifest reference number
line in the Discrepancy Block of the old manifest (Item 18a).
Pursuant
to Permit Condition II.J, the permittee must comply with the manifest
requirements.
As noted during the inspection,
manifest 016085748JJK was created and completed by Respondent to reject waste
to an alternate facility. The original manifest 017204209JJK and the
information in the e-manifest were not updated or corrected to show the
rejection; Item 18a in the original manifest was blank.
c. Pursuant to 40 CFR 264.72(f)(1),
(4) and (5), for rejected wastes and residues that must be sent back to the
generator, the facility is required to prepare a new manifest in accordance
with §262.20(a) of this chapter and write the facility's U.S. EPA ID number in
Item 1 of the new manifest. Write the facility's name and mailing address in
Item 5 of the new manifest; If the mailing address is different from the
facility's site address, then write the facility's site address in the
designated space for Item 5 of the new manifest; copy the manifest tracking
number found in Item 4 of the new manifest to the manifest reference number
line in the Discrepancy Block of the old manifest (Item 18a); and write the DOT
description for the rejected load or the residue in Item 9 (U.S. DOT
Description) of the new manifest and write the container types, quantity, and
volume(s) of waste.
Pursuant
to Permit Condition II.J, the permittee must comply with the manifest
requirements.
As noted
during the inspection, manifest 16085732JJK and 016085734JJK were created and
completed by Respondent to reject waste back to the generator. The manifests
listed the original generator’s name, address, and EPA identification number in
items 1 and 5 and the original manifests, 021068933 JJK and 013758524FLE, and
the information in the e-manifest were not updated or corrected to show the
rejection; Item 18a in the original manifests were blank.
d. Pursuant to 40 CFR 264.72(c), upon
discovering a significant difference in quantity or type, the owner or operator
must attempt to reconcile the discrepancy with the waste generator or
transporter (e.g., with telephone conversations). If the
discrepancy is not resolved within 15 days after receiving the waste, the owner
or operator must immediately submit to the Regional Administrator a letter
describing the discrepancy and attempts to reconcile it, and a copy of the
manifest or shipping paper at issue.
Pursuant
to Permit Condition II.J, the permittee must comply with the manifest
requirements.
As noted
during the inspection and review of the August 21, 2020
submittal, container discrepancies were noted in Area 7-A4, as indicated
below:
1. Waste stream profiles
and waste analysis for Manifest shipments 014538380JJK, 017573140JJK,
017573248JJK, and 017573027JJK were reviewed and significant discrepancies were
found in waste type (flash point and physical state) for several containers. Respondent failed to resolve and/or report discrepancies within 15 days after
receiving the waste.
2. Drums D005394833,
D005394834, D005394836, and D005394837 on Manifest 021109941JJK (received May
21, 2020) were profiled as >10,000 BTU, no water, however, upon receipt, the
waste analysis suggested 100 BTU, 96% water. A new profile for an aqueous waste
stream was received on June 11, 2020. Respondent failed to resolve and/or report
discrepancies within 15 days after receiving the waste.
3. Drum D005358972 on Manifest
020945593JJK (received 05/06/2020) was shipped as Environmentally Hazardous
Substances Liquid, N.O.S (Chromium) D007 and profiled as Hazardous Waste
Liquids with multiple waste codes (D002, D004, D005, D006, D007, D008, D009, D010,
D011 and pH of 4.1-10 (Profile # DL015-19-TX12C1). Upon receipt, waste analysis
suggested a pH of 1 and was positive for an oxidizer. Respondent submitted Profile
# OL003-19-FL13C1 on 08/21/2020 for this drum, which was for an alkaline
permanganate liquid and does not match the waste analysis. Respondent failed to resolve and/or report discrepancies within 15 days
after receiving the waste.
4. Drum D005417162
on Manifest 020945604JJK (received on 05/29/2020) was shipped as Hazardous
Waste Solid and profiled as Inorganic Debris. Upon receipt, waste analysis did
not suggest a variation from the approved profile. E-Manifest was last updated on August 3, 2020
and is now amended with waste codes D007 and D035. Respondent failed to resolve
and/or report
discrepancies within 15 days after receiving the waste.
5. Drums D005417173 and D005417174 on
Manifest 020945604JJK (received 05/29/2020) were shipped as Hazardous Waste
Liquid, D006, D007, D035 under Profile # DL015-19-TX12C4. Upon receipt, waste
analysis suggests that this is a solid material. Respondent
failed to resolve and/or report discrepancies within 15 days after
receiving the waste.
6. Drum D005440021 on Manifest
013547315FLE (received 06/08/2020) was shipped under profile 03134740 as Waste
Corrosive Liquid Acidic Inorganic (D002) and profiled with a pH <2. Upon
receipt, waste analysis submitted suggests the waste has a pH of 12 and was
positive for being an oxidizer. A new profile
for Sodium
Hydroxide/Sodium Nitrate with D001/D002 waste codes was received on June 30, 2020. Respondent failed to resolve and/or report
discrepancies within 15 days after receiving the waste.
7. Manifest 020920936JJK (received 03/23/20) for Waste PCBs with
waste codes D005, D006, D007, D008 (2DF at 7Kg) under profile PCB12-15-PC09C7
was not signed by the designated facility. In addition, the Profile was marked
as “Not a RCRA waste” and did not list waste codes. An updated Profile # RL003-15-RX97C1
(with “provided new” handwritten on it) was submitted on 08/21/2020 but does not
appear to have anything to do with these containers, including the generator
site. Respondent failed to resolve and/or report
discrepancies within 15 days after receiving the waste.
8. Drum D005440026 on Manifest
013547315FLE (received 06/08/2020) was shipped under Profile # 3134700 as Waste
Sodium Hydroxide (D002). Upon receipt, the waste analysis submitted tested
positive for oxidizer. The August 21, 2020 submittal
included a new Profile # 3134757 for Sodium Hydroxide/Sodium Nitrate with
D001/D002 waste codes. The profile was signed on 06/30/2020. Respondent
resolved the discrepancy but failed to submit a discrepancy report with 15 days
after receiving the waste.
9. Drum D005334947 on manifest
019358499JJK (received 04/23/2020) indicates the waste was shipped on non-hazardous
waste Manifest NHWM23189880. The waste was shipped under Profile # 1000226685
as surfactant and water. Upon receipt, waste analysis suggests the waste had a
flash point of < 140 and was positive for being an oxidizer. The August 21, 2020 submittal included a hazardous waste Manifest
016085761JJK, which referenced the non-hazardous waste manifest NHWM23189880
and a Profile # 1000264216 for an ignitable oxidizing soap solution. The
profile was signed on 06/18/2020. Respondent resolved the discrepancy but
failed to submit a discrepancy report with 15 days after receiving the waste.
Pursuant to Attachment C, Permit Condition C-2d, the number of samples collected to
satisfactorily characterize an incoming shipment will vary from generator to generator
and from waste stream to waste stream. A minimum of 10% of each shipment of
drums is sampled. The trained sampling technician takes a
"representative" sample based on visual changes in the material
composition. Qualified personnel evaluate the waste streams to determine the
proper number of samples needed to define a shipment within an established
confidence limit. Factors such as process information, material storage
information, packaging procedures, material matrix, shipment size, number of
containers shipped, and sampling methods are evaluated in determining the
appropriate number of samples needed to establish confidence in the
characterization type of the waste shipment.
Pursuant to Attachment C, Permit Condition C.2e, incoming shipments of waste material are
examined upon arrival to ensure consistency by comparison of the materials hazardous
waste manifest information to previous analysis. Following this inspection,
sampling procedures and sample numbers are assigned. The fingerprint analysis
of a given hazardous waste stream will vary depending upon the characteristics
represented by TRADEBE's Analytical Profile or equivalent. Based on the results
of the fingerprint analysis, a load may be re-sampled for analysis and/or be
rejected if it does not meet specification.
As noted during the inspection, Respondent samples 10% of a generator’s
waste stream as required by the Waste Analysis Plan, and then combines samples
of similar waste that will subject to the same processing method (e.g. blending) from multiple generators to determine load
acceptance. Tradebe’s RCRA Permit does not all the
combining of multiple generators to run analytical, such as physical state, pH,
and flash point. Furthermore, based on the
results of the combined fingerprint analysis, Respondent failed to re-sample
the load for analysis and/or rejection for not meeting specification.
f. Pursuant
to 40 CFR 264.71(a)(2)(i), if the facility receives a
hazardous waste shipment accompanied by a manifest, the owner, operator, or his
agent must sign and date each copy of the manifest.
As noted during
the inspection, Respondent failed to obtain a signature for the designated
facility on Manifest 020920936JJK (received 3/23/2020).
g. Pursuant
to 40 CFR 264.76(a) If a facility accepts for treatment, storage, or disposal
any hazardous waste from an off-site source without an accompanying manifest,
or without an accompanying shipping paper as described by §263.20(e) of this
chapter, and if the waste is not excluded from the manifest requirement by this
chapter, then the owner or operator must prepare and submit a letter to the
Regional Administrator within 15 days after receiving the waste. The
unmanifested waste report must contain the following information:
(1) The
EPA identification number, name and address of the facility;
(2) The
date the facility received the waste;
(3) The
EPA identification number, name and address of the generator and the
transporter, if available;
(4) A
description and the quantity of each unmanifested hazardous waste the facility received;
(5) The
method of treatment, storage, or disposal for each hazardous waste;
(6) The
certification signed by the owner or operator of the facility or his authorized
representative; and,
(7) A
brief explanation of why the waste was unmanifested, if known.
As noted
during the inspection, Respondent failed to submit an unmanifested waste report
for the following:
1. Drum
D005334947 on manifest 019358499JJK (received 04/23/2020) indicates the waste
was shipped on non-hazardous waste Manifest NHWM23189880. The waste was shipped
under Profile # 1000226685 as surfactant and water. Upon receipt, waste
analysis suggests the waste had a flash point of < 140 and was positive for
being an oxidizer. The August 21, 2020 submittal
included a hazardous waste Manifest 016085761JJK, which referenced the non-hazardous
waste manifest NHWM23189880 and a Profile # 1000264216 for an ignitable
oxidizing soap solution. The profile was signed on 06/18/2020. Respondent
resolved the discrepancy but failed to submit a discrepancy report with 15 days
after receiving the waste.
8. Respondent
complied with Findings of Fact Paragraph 7 a-d and f-g.
9. 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 rules and Permit
conditions listed in the Findings of Fact above.
3.
Within One Hundred and Twenty (120) days of the
Effective Date, Respondent shall comply with the Waste Analysis Plan regarding
load acceptance by not compositing samples of similar waste, subject to the
same processing method (e.g. blending), from multiple
generators to determine load acceptance.
4.
All submittals required by this Agreed Order,
unless IDEM notifies the Respondent otherwise
in writing, shall be sent to:
Linda
McClure, Enforcement Case Manager |
Office
of Land Quality |
Indiana
Department of Environmental Management |
100
North Senate Avenue |
Indianapolis,
IN 46204-2251 |
5. Respondent
is assessed and agrees to pay a civil penalty of Twelve Thousand Four Hundred
Dollars ($12,400). Within thirty (30) days of the Effective Date of the Agreed
Order, Respondent shall pay a portion of this penalty in the amount of Two Thousand
Four Hundred and Eighty Dollars ($2,480). Said penalty amount shall be due and
payable to the “Environmental Management Special Fund” within thirty (30) days
of the Effective Date; the 30th day being the “Due Date.”
In lieu of payment to IDEM of the
remaining civil penalty, Respondent shall, as a Supplemental Environmental
Project (SEP), make a cash payment of Nine Thousand Nine Hundred and Twenty Dollars
($9,920) to the United States Environmental Protection Agency to partially
support the Great Lakes Legacy Act project described in Subparagraph A. below.
Respondent shall make such payment in accordance with Subparagraph F through G below.
Timely, full payment to the United States Environmental Protection Agency
satisfies Respondent’s obligation to undertake a SEP to offset a portion of the
civil penalty assessed in this matter.
A. The project to be partially supported by
the SEP lies within the Grand Calumet River / Indiana Harbor Ship Canal Great
Lakes Area of Concern (AOC) designated by the International Joint Commission.
Specifically, the project consists of sediment remediation and habitat
restoration in and adjacent to a 3.1-mile reach of the East Branch Grand
Calumet River (EBGCR) that extends from the most upstream boundary of either
the: (1) ConRail Bridge; or (2) the downstream
terminus of the US Steel sediment project (near the Gary Sanitary District National
Pollutant Discharge Elimination System permitted outfall) to Cline Road.
B. If, following deposit of the funds
pursuant to Subparagraphs F through G of this Agreed Order, IDEM determines
that the aforementioned Great Lakes Legacy Act project
is no longer viable, the agency reserves the right to apply the cash payment
described in Subparagraph A to another, similar Great Lakes Legacy Act project
within the Grand Calumet River / Indiana Harbor Ship Canal AOC.
C. The implementation of this SEP will benefit
human health and the environment within the AOC by reducing exposure to
sediment contaminants, including PCBs, oil and grease, and heavy metals, via
direct contact and through the food chain. Remediation of contaminated
sediments is the key action that has been identified as needed to remove six of
the 12 remaining Beneficial Use Impairments (“BUIs”) negatively impacting the
AOC. These BUIs are:
·
Restrictions on
fish and wildlife consumption
·
Tainting of fish
and wildlife flavor
·
Fish tumors or
other deformities
·
Bird or animal
deformities or reproduction problems
·
Degradation of
benthos (aquatic organisms that live on, in, or near the bottom of waterways)
·
Restriction on
dredging activities.
D. In addition to the direct impacts on
human health and the environment, remediation of contaminated sediment at Great
Lakes AOCs has been linked to economic growth and revitalization at affected
communities.
E. Respondent agrees to invoicing by the
United States Environmental Protection Agency, for the full amount of the SEP,
via electronic mail sent to the following address for Tita LaGrimas, VP
Regulatory Affairs and Sustainability, Tradebe Environmental Services, LLC: Tita.LaGrimas@tradebe.com.
F. The Respondent shall render payment via
check to the United States Environmental Protection Agency by the due date
printed on the Invoice, which shall be no sooner than 30 days following the
issuance of the Invoice. The Respondent shall include the account number listed
on the invoice in the memo line of the check. The check shall be sent via
Certified Mail or an equivalent shipping method utilizing signed receipt confirmation,
along with a printed copy of the invoice received from the United States
Environmental Protection Agency, to:
U.S.
Environmental Protection Agency |
FOIA
& Miscellaneous Payments |
Government
Lockbox 979078 |
1005
Convention Plaza |
SL-MO-C2-GL |
St.
Louis, MO 63101 |
H. In the event that Respondent does not make its SEP payment
to the United States Environmental Protection Agency by the due date printed on
the invoice, 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 to IDEM
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 due date printed on the invoice received from the
United States Environmental Protection Agency until the full civil penalty is
paid.
6.
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 |
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 6, above.
7.
Signatories to this Agreed Order certify that
they are fully authorized to execute this Agreed Order and legally bind the
party they represent.
8.
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.
9.
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.
10.
Respondent shall ensure that all contractors,
firms, and other persons performing work under this Agreed Order comply with
the terms of this Agreed Order.
11.
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.
12.
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.
13.
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.
14.
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.
15.
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.
16.
This Agreed Order shall remain in effect until
IDEM issues a Resolution of Case letter to Respondent.
TECHNICAL
RECOMMENDATION: |
RESPONDENT: |
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Department
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By:
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By: _________________________ |
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Jennifer Reno, Section Chief |
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Enforcement Section |
Printed:
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Office of Land Quality |
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Title:
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Date:
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Date:
_______________________ |
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COUNSEL
FOR RESPONDENT: |
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By:
________________________ |
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APPROVED
AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL |
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MANAGEMENT THIS |
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DAY OF |
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For
the Commissioner: |
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Signed 11/4/2021 |
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Peggy
Dorsey, Assistant Commissioner |
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Office
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