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. 2020-27349-H

 

 

)

 

FARNSWORTH METAL RECYCLING, LLC

 

)

 

AND RAY’S TRASH SERVICE INC.,

 

)

 

 

 

)

 

Respondents.

 

)

 

 

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 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. 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 IC 13-13-1-1.

 

2.            Respondent is Farnsworth Metal Recycling, LLC., which owns/operates a recycling facility and owns the property, parcel # 49-11-20-102-009.000-970, located at 3602 Farnsworth Street, in Indianapolis, Marion County, Indiana (“Site”).

 

3.            Respondent is Ray’s Trash Services Inc, which owns/operates a recycling and waste disposal operation with the main office located at 3859 East US Highway 40, in Clayton, Hendricks County, Indiana.

 

4.            Respondent, Ray’s Trash Services Inc., received a “Use of Tear-off Asphalt Roofing Shingles” Legitimate Use Approval (“Approval”) on June 1, 2017.  This Approval allowed non-asbestos containing shingles to be sent to Respondent, Farnsworth Metal Recycling, LLC, to be ground and marketed for Hot Mixed Asphalt (“HMA”).  The Approval expired on June 1, 2020.

 

5.            The amount of non-asbestos shingles noted at the Site during the September 8, 2020 inspection are as follows:

Pile 1.       Ground shingles measured approximately 44 ft x 21 ft x 5 ft (volume = 4,620 ft3) stored in a bunker and covered with a tarp.

Pile 2.       Whole shingles measured approximately 120 ft x 84 ft x 12.5 ft (volume = 21,000 ft3) stored outside, partially covered and contained.

Pile 3.       Ground shingles measured approximately 60 ft x 53 ft x 10 ft (volume = 31,800 ft3) stored inside a barn.

 

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 regular mail to:

 

Donald Matthews, President

Donald B Matthews, President

Ray’s Trash Service Inc.

Farnsworth Metal Recycling, LLC

3859 East US HWY 40, Drawer 1

1223 South CR 525 East

Clayton, Indiana 46118

Avon, Indiana 46123

 

 

Donald Matthews

 

Registered Agent for

 

Farnsworth Metal Recycling, LLC and

 

Ray’s Trash Service Inc.

 

3859 East US Highway 40

 

Belleville, Indiana 46118

 

 

8.         During an investigation, including inspections on October 17, 2019, February 3, 2020, and September 8, 2020, conducted by a representative of IDEM, the following violations were found:

 

a.         Pursuant to Approval Condition 2, the use as described and managed below is limited to HMA.  If it is determined that the use is no longer suitable or a market does not exist, the use must cease.

 

As noted during the October 17, 2019, February 3, 2020, and September 8, 2020 inspections, Respondents failed to find and/or utilize a market for HMA and failed to stop collecting/storing non-asbestos shingles at the Site. Respondent, Farnsworth Metal Recycling, LLC, stated, during the October 17, 2019 inspection, that non-asbestos shingles had not been received at the Site or ground non-asbestos shingles sent for re-use since 2017.

 

b.         Pursuant to Approval Condition 3a and 4a, shingles have tested negative for asbestos. Every layer of every roof must be tested. Testing results must be made available to IDEM upon request.

 

As noted during the February 3, 2020 and September 8, 2020 inspections, Respondents failed to submit asbestos testing results for the time of May to Oct 2017.

 

c.         Pursuant to Approval Condition 7, ground shingle material will be stored in a building. Piles are not to exceed [the volume and height requirements in accordance with] condition 10.

 

As noted during the October 17, 2019 inspection, Respondents had one (1) ground shingle pile stored outside and uncovered.

 

Respondents relocated the ground shingle pile to an inside location prior to the February 3, 2020 inspection.

 

d.         Pursuant to Approval Condition 8, whole singles will be stored in piles. The piles must be completely covered with a tarp and located on the interior of the property on an impervious surface (e.g., asphalt pad, concrete pad, etc.) In the event the shingles are found to be migrating to the property lines, the facility must comply with condition 9. Piles are not to exceed [the volume and height requirements in accordance with] condition 10.

 

As noted during the October 17, 2019 and February 3, 2020 inspections, Respondents had one (1) whole shingle pile stored uncovered.

 

e.         Pursuant to Approval Condition 10, no shingle pile may exceed 50,000 cubic feet in volume. No shingle pile may exceed a height of 10 feet.

 

As noted during the October 17, 2019 and February 3, 2020 inspections, Respondents had one (1) shingle pile at a height of 12.5 feet.

 

f.          Pursuant to 329 Indiana Administrative Code (“IAC”) 13-4-3(e), upon detection of a release of used oil to the environment not subject to the requirements of 40 CFR 280 Subpart F, which has occurred after the effective date of this rule, a generator must perform the following clean-up steps:

(1)       Stop the release.

(2)       Contain the released used oil.

(3)       Clean up and manage properly the released used oil and other materials.

 

As noted during the October 17, 2019 and February 3, 2020 inspections, Respondents had several small sized fluid releases and heavy staining near Building 3, near the whole shingle pile, and near the machine turnings stored at the receiving area.

 

As noted in the September 8, 2020 inspection, Respondents had addressed the oil releases, retrained facility personnel, and notified the machine turnings company to reduce the amount or residual lubricant on the turnings received.

 

g.         Pursuant to IC 13-30-2-1(4), a person may not deposit or cause or allow the deposit of any 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.

 

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.

 

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.

 

Respondents stored three (3) shingle piles onsite with the intent to market for HMA per the Approval. Respondent, Farnsworth Metal Recycling, LLC, stated, during the October 17, 2019 inspection, that non-asbestos shingles had not been received at the Site or ground non-asbestos shingles sent for re-use since 2017. The Approval expired on June 1, 2020 and the three (3) non-asbestos shingle piles, noted at the September 10, 2020 inspection, are considered a solid waste.

 

h.         Pursuant to 329 IAC 10-4-4(a), 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 solid 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.

 

Respondent, Farnsworth Metal Recycling, LLC, as property owner, failed to remove and properly disposal of non-asbestos shingles, a solid waste.

 

9.         On March 17, 2021, Respondent, Farnsworth Metal Recycling, LLC, was issued an interim Legitimate Use Approval (“2021 Approval”), which will remain in effect until December 31, 2021.

 

10.       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, Respondents acknowledge notice of this right and 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.            Respondents shall comply with the statute and rules listed in the findings of fact above.

 

3.         Upon the Effective Date, Respondent, Farnsworth Metal Recycling, LLC, shall comply with the 2021 Approval issued on March 12, 2021.

4.         Upon the Effective Date and while operating under the 2021 Approval, Respondent, Farnsworth Metal Recycling, LLC, shall not accept new shingles (ground or whole) at the Site.

 

5.         Respondents shall have all shingles (ground and whole) removed from the Site by December 31, 2021.  A stipulated penalty, see Order Paragraph 10, has been established for failure to have all shingles removed by this deadline.

 

Respondents shall ensure by August 31, 2021 that 50% or greater of the shingles have been sent for reuse and/or transportation to a State approved solid waste management facility.

 

Respondents shall ensure by November 30, 2021 that 75% or greater of the shingles have been sent for reuse and/or transportation to a State approved solid waste management facility.

 

6.            Within thirty (30) days of the Effective Date and monthly thereafter, until December 31, 2021, Respondents shall submit documentation of the quantity of shingles sent for reuse and/or transportation to a State approved solid waste management facility.

 

7.            Respondent is required to submit a new Legitimate Use Approval Application before acceptance of new shingles. A Legitimate Use Approval will be contingent upon removal of all existing shingles (ground and whole) by December 31, 2021, completion of an Enforcement Follow-up inspection, and the issuance of a Resolution of Case letter.

 

8.         All submittals required by this Agreed Order, unless IDEM notifies the Respondents 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

 

9.         Pursuant to IC 13-30-4-1, Respondents are assessed and agree to pay a civil penalty of Eight Thousand Two Hundred Dollars ($8,200). Within thirty (30) days of the Effective Date of the Agreed Order, Respondents shall pay a portion of this penalty in the amount of One Thousand Six Hundred Forty Dollars ($1,640). 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, Respondents shall make a cash payment of Six Thousand Five Hundred Sixty Dollars ($6,560) to IDEM’s “Waste Tire Fund.” Respondents shall make such payment within thirty (30) days of the Effective Date of this Agreed Order. Payment to the “Waste Tire Fund” satisfies Respondent’s obligation to undertake a SEP to offset a portion of the civil penalty assessed in this matter.

 

The SEP proceeds will be spent on solid waste sites in the State of Indiana with waste tires. These sites are often abandoned or the landowner demonstrates an inability to pay for the proper removal and disposal of the waste tires.

 

In the event that Respondents do not make its SEP payment within thirty (30) days of the Effective Date of this Agreed Order, 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 Respondents have already paid, will be due to IDEM within fifteen (15) days from Respondents’ 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 for the SEP is payable by check to the “Waste Tire Fund.”  The Case Number of this action shall be included in the memo line of the check.  The check shall be mailed to:

 

Indiana Department of Environmental Management

Accounts Receivable

IGCN, Room 1340

100 North Senate Avenue

Indianapolis, IN 46204

 

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

 

Paragraph

Action

Stipulated Penalty

3

Failure to comply with the 2021 Approval.

$300 per week

4

Failure to refrain from accepting shingles at the Site.

$300 per week

5

Failure to remove all shingles at the Site by December 31, 2021.

$1,000 per month or part there of

6

Failure to submit monthly quantity reuse/disposal documentation

$150 per week

 

11.         Stipulated penalties shall be due and payable no later than the thirtieth day after Respondents receive written notice that Complainant has determined a stipulated penalty is due; the thirtieth day being the “Due Date.” Complainant may notify Respondents at any time that a stipulated penalty is due. Failure to notify Respondents 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 Respondents for violation of this Agreed Order. Neither assessment nor payment of stipulated penalties shall preclude Complainant from seeking additional relief against Respondents 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. Respondents are jointly and severally liable for all stipulated penalty assessments.

 

12.         Civil and stipulated 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

 

13.         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 “Environmental Management Special Fund” and shall be payable to IDEM in the manner specified in Paragraph 13, above.

 

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

 

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

 

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

 

17.         Respondents shall ensure that all contractors, firms, and other persons performing work under this Agreed Order comply with the terms of 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.         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 the obligation to comply with the requirements of any applicable permits or any applicable Federal or State laws or regulations.

 

20.         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.

 

21.         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.

 

22.         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 Respondents may incur as a result of such communications with the U.S. EPA or any other agency or entity.

 

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

 

TECHNICAL RECOMMENDATION:

 

Department of Environmental Management

 

 

 

By: _______

 

Jennifer Reno, Chief

 

 

Land Enforcement Section

 

 

Office of Land Quality

 

 

 

 

 

Date: ___________

 

 

 

 

 

COUNSEL FOR RESPONDENT:

RESPONDENT:

 

 

 

 

By:  _________________________

By:  _________________________

 

 

 

Printed: ______________________

Printed: ______________________

 

 

Title: ________________________

Title: ________________________

 

 

Date: _______________________

Date: _______________________

 

 

 

 

COUNSEL FOR RESPONDENT:

RESPONDENT:

 

 

 

 

By:  _________________________

By:  _________________________

 

 

 

Printed: ______________________

Printed: ______________________

 

 

Title: ________________________

Title: ________________________

 

 

Date: _______________________

Date: _______________________

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

______

DAY OF

________________________,

20__.

 

 

For the Commissioner:

 

 

 

Signed 4/7/2021

 

Peggy Dorsey

 

Assistant Commissioner

 

Office of Land Quality