STATE OF INDIANA

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SS:

BEFORE THE INDIANA DEPARTMENT OF

 

)

 

 

COUNTY OF MARION

)

 

ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

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OF ENVIRONMENTAL MANAGEMENT,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case No. 2020-27180-H

 

 

)

 

TRADEBE TREATMENT AND RECYCLING, 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 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

 

 

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.

 

e.         Pursuant to Attachment C, Permit Condition C, “waste stream” refers to a generator’s process waste shipment.

 

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

 

G.        Respondent shall provide Complainant with: (1) documentation of payment, (2) a copy of the invoice issued by the United States Environmental Protection Agency and (3) a copy of this Agreed Order via Certified Mail within one (1) week of such payment.

 

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:

Department of Environmental Management

 

 

 

By: _________________________

By:  _________________________

 

Jennifer Reno, Section Chief

 

 

Enforcement Section

Printed: ______________________

Office of Land Quality

 

 

Title: ________________________

 

 

Date: __________________

Date: _______________________

 

 

 

 

 

COUNSEL FOR RESPONDENT:

 

 

 

 

 

By: ________________________

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

______

DAY OF

_______________, 20_____.

 

 

For the Commissioner:

 

 

 

Signed 11/4/2021

 

Peggy Dorsey, Assistant Commissioner

 

Office of Land Quality