STATE OF INDIANA

)

SS:

BEFORE THE INDIANA DEPARTMENT OF

 

)

 

 

COUNTY OF MARION

)

 

ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

)

 

OF ENVIRONMENTAL MANAGEMENT,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case No. 2021-27651-H

 

 

)

 

E & H TUBING, INC.,

 

)

 

 

 

)

 

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 E & H Tubing, Inc. (“Respondent”), which owns/operates the facility with United States Environmental Protection Agency (“EPA”) ID No. INR000128280, located at 848 West Sweet Street, in Brownstown, Jackson 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:

 

E & H Tubing, Inc.

E & H Tubing, Inc., Registered Agent

Attn: Gary Birnbaum, Chairman

848 West Sweet Street

4401 West Roosevelt Road

Brownstown, IN 47220

Chicago, IL 60624

 

 

5.            Respondent notified EPA of Large Quantity Generator activities.

 

6.            Respondent manufactures steel tubing primarily for the agricultural industry.

 

7.         329 Indiana Administrative Code (“IAC”) 3.1 incorporates federal hazardous waste management requirements found in 40 Code of Federal Regulations (“CFR”) Parts 260 through 270 and Part 273, including those identified below.

 

8.            During an investigation including an inspection on January 21, 2021 conducted by a representative of IDEM, the following violations were found:

 

a.         During the inspection, IDEM noted that an Alternate Emergency Coordinator was handling the inspection and could not locate all of the required paperwork because the Primary Emergency Coordinator was not available due to COVID-19. E&H Tubing later provided records to IDEM as noted further below. E&H Tubing asserts that it has remedied training of any non-primary personnel.

 

b.         Pursuant to 40 CFR 262.17(a)(1)(v), at least weekly, the large quantity generator must inspect central accumulation areas. The large quantity generator must look for leaking containers and for deterioration of containers caused by corrosion or other factors.

 

As noted during the inspection, Respondent failed to conduct weekly inspections of the 90-day accumulation area in the Coolant Room.

 

On May 14, 2021, Respondent provided weekly inspection logs for the month of April 2021.

 

c.        Pursuant to 40 CFR 262.17(a)(5)(i)(B), a large quantity generator may accumulate hazardous waste on-site for 90 days or less without a permit, provided that, while being accumulated on-site, each container is labeled or marked with an indication of the hazards of the contents.

 

As noted during the inspection, Respondent accumulated hazardous waste on-site, without a permit, and did not label or clearly mark one (1) 55-gallon container located in the Coolant Room with an indication of the hazards of the contents.

 

d.         Pursuant to 40 CFR 262.17(a)(5)(i)(C), a large quantity generator may accumulate hazardous waste on-site for 90 days or less without a permit, provided that the date when the accumulation begins is clearly marked and visible for inspection on each container.

 

As noted during the inspection, Respondent accumulated hazardous waste on-site, without a permit, and did not mark one (1) hazardous waste container located in the Coolant Room with accumulation start date.

 

e.         Pursuant to 40 CFR 262.17(a)(7)(i),(ii), and (iii), facility personnel must complete a program of classroom instruction, online training, or on-the-job training that teaches them to perform their duties in compliance with the hazardous waste management rules. Employees must be trained within six months after their date of hire and must take part in an annual review of the initial training.

 

As noted during the inspection, Respondent did not provide hazardous waste training to employees.

 

On April 30, 2021, Respondent provided documentation of the 2018, 2019, and 2020 personnel training logs.

 

f.          Pursuant to 40 CFR 262.17(a)(7)(iv), certain hazardous waste training related documents and records including job title, job descriptions, a description of the type and amount of required training, and completion documents with respect to the hazardous waste management training must be maintained on-site.

 

As noted during the inspection, Respondent did not maintain the required hazardous waste training related documents and records on-site.

 

On April 30, 2021, Respondent provided a job description and training logs for 2018, 2019, and 2020.

 

g.         Pursuant to 40 CFR 262.17(a)(7)(v), hazardous waste training records on current personnel must be kept until closure of the facility. Records on former employees must be kept for at least three years from the date the employee last worked at the facility.

 

As noted during the inspection, Respondent did not maintain copies of hazardous waste training records for current and past employees.

 

On April 30, 2021, Respondent provided training records for 2018, 2019, and 2020.

 

h.         Pursuant to 40 CFR 262.17(a)(9) referencing 40 CFR 268.7(a), a generator must determine if a hazardous waste is restricted from land disposal and if the waste has to be treated before being land disposed. With the initial shipment of waste to each treatment, storage, or disposal facility, a generator must send a one-time written notice to each facility receiving the waste and place a copy in the file.

 

As noted during the inspection, Respondent failed to provide the one-time written notice and place a copy in the file for hazardous waste streams generated. Specifically, land ban notification forms were not provided for hazardous waste streams.

 

On May 14, 2021, Respondent provided land ban notification forms along with hazardous waste manifests for 2019, 2020, and 2021.

 

i.          Pursuant to 40 CFR 262.23(a)(3) and 40 CFR 262.40(a), the generator must retain copies of hazardous waste manifests for a period of three (3) years from the date of receipt of the hazardous waste by the designated facility.

 

As noted during the inspection, Respondent failed to retain copies of hazardous waste manifests as required.

 

On May 14, 2021, Respondent provided manifest copies of all 2019, 2020, and 2021 hazardous waste manifests to IDEM.

 

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 listed in the findings of fact above.

 

3.         Immediately upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(B). Specifically, Respondent shall ensure all less than ninety (90) day hazardous waste containers are clearly labeled or marked with an indication of the hazards of the contents.

 

4.            Immediately upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(C). Specifically, Respondent shall ensure all less than ninety (90) day hazardous waste containers are clearly marked with the start of accumulation date.

 

5.         Within thirty (30) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(7). Specifically, Respondent shall provide personnel training to all individuals involved with hazardous waste management that teaches them to perform their duties in compliance with the hazardous waste management rules.

 

6.         Within forty-five (45) days of the Effective Date, Respondent shall submit to IDEM documentation of hazardous waste management training completed in 2021 to all individuals involved with hazardous waste management.

 

7.         Within forty-five (45) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(7)(iv). Specifically, Respondent shall submit to IDEM 2021 hazardous waste training related documents including a description of the type and amount of required training.

 

8.         Immediately upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(7)(v). Specifically, Respondent shall maintain hazardous waste training records on current personnel until closure of the facility. Records on former employees must be maintained for at least three years from the date the employee last worked at the facility.

 

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

 

Debbie Chesterson, Enforcement Case Manager

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

10.       Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Five Thousand Four Hundred Dollars ($5,400). Said penalty amount shall be due and payable to the “Environmental Management Special Fund” within thirty (30) days of the Effective Date; the thirtieth day being the “Due Date.”

 

11.       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 #6

$100 per week

Order paragraph #7

$100 per week

 

12.         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.

 

13.         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

 

14.         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 13, above.

 

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

 

16.         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.

 

17.         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.

 

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

 

19.         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.

 

20.         This Agreed Order is not and shall not be interpreted to be a permit or a modification of an existing permit. This Agreed Order, and IDEM’s review or approval of any submittal made by 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.

 

21.         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.

 

22.         Nothing in this Agreed Order shall prevent or limit IDEM’s rights to obtain penalties or injunctive relief under any applicable Federal or State law or regulation, except that IDEM may not, and hereby waives its right to, seek additional civil penalties for the violations specified in the NOV.

 

23.         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.

 

24.       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 RESPONDENT:

 

 

 

 

 

By: ________________________

 

 

 

 

 

 

Date: ______________________

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_________

DAY OF

________________________,

20__.

 

 

For the Commissioner:

 

 

 

Signed on 11/16/21_________________

 

Peggy Dorsey, Assistant Commissioner

 

Office of Land Quality