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STATE OF
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BEFORE THE
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COMMISSIONER
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Complainant, |
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Case No. 2021-27902-H |
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Federal-mogul powertrain 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 Federal-Mogul Powertrain LLC (“Respondent”),
which owns/operates the facility with United States Environmental Protection
Agency (“EPA”) ID No. IND984868422, located at 3605 West Cleveland Road, in South
Bend, St. Joseph 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”) via Certified Mail
to:
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Federal-Mogul Powertrain LLC |
Corporate Creations Network, Inc., |
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Attn: David Jachcik,
Member |
Registered Agent for Federal Mogul |
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27300 West Eleven Mile Road |
Powertrain LLC |
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Southfield, MI 48034 |
8520 Allison Pointe Boulevard, #220 |
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Indianapolis, IN 46250 |
5.
Respondent notified EPA of Large Quantity Generator activities.
6. 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.
7.
During
an investigation including an
inspection on May 14, 2021 conducted by a
representative of IDEM, the following violations were found:
a. Pursuant to 40 CFR 262.11(a): A person who generates a solid waste must
determine if that waste is a hazardous waste at the point of waste generation,
before any dilution, mixing, or other alteration of the waste occurs, and at
any time in the course of its management that it has, or may have, changed its
properties as a result of exposure to the environment or other factors that may
change the properties of the waste such that the RCRA classification of the
waste may change.
As noted during the inspection,
Respondent did not make a proper hazardous waste determination on F019 wastes.
Approximately 12,200 gallons of F019 waste was shipped offsite as
“non-regulated, oily water and solids”.
b. Pursuant to 40 CFR 262.11(g), small
quantity generators and large quantity generators must identify all applicable
EPA hazardous waste numbers (EPA hazardous waste codes) in subparts C and D of
part 261.
c. Pursuant
to 329 IAC 3.1-1-10, every hazardous waste generator, transporter, or owner or
operator of a hazardous waste facility shall notify the commissioner of its
hazardous waste activity on the approved forms.
As noted
during the inspection, Respondent failed to notify the Commissioner of
hazardous waste storage and treatment activities for F019 wastes.
d. Pursuant
to 40 CFR 262.18(c), a generator must not offer its hazardous waste to transporters
or to treatment, storage, or disposal facilities that have not received an EPA
identification number.
As
noted during the inspection, Respondent offered F019 hazardous waste shipped as
non-hazardous oily water and solids to a facility not permitted to accept
hazardous waste. Specifically, Respondent shipped F019 hazardous waste from the
Sludge Thickener tank and tanks N1, N2, and N3 on January 21, 2021 and April 13, 3021 to Inserv
and subsequently transferred to Liquid Industrial Waste. Neither facility is permitted to accept
hazardous waste.
e. Pursuant
to 40 CFR 262.20, a generator who transports, or offers for transportation,
hazardous waste for offsite treatment, storage, or disposal, must prepare a
manifest. A generator must designate on the manifest one facility which is
permitted to handle the waste described on the manifest. A generator may designate
an alternate facility to handle his waste in the event that
an emergency prevents delivery of the waste to the primary designated facility.
As noted
during the inspection, Respondent offered hazardous waste for transportation
for offsite treatment, storage, or disposal without preparing a manifest.
Specifically, hazardous waste liquid and sludge (F019) was shipped as
non-regulated oily water and solids without utilizing a hazardous waste
manifest.
f. Pursuant
to IC 13-30-2-1(12), a person may not cause or allow the transportation of a
hazardous waste without a manifest if a manifest is required by law.
As noted
during the inspection, Respondent offered hazardous waste for transportation
for offsite treatment, storage, or disposal without preparing a manifest.
Specifically, hazardous waste liquid and sludge (F019) was shipped as
non-regulated oily water and solids without utilizing a hazardous waste
manifest.
g. Pursuant
to 40 CFR 262.17(a), a large quantity generator accumulates hazardous waste on
site for no more than 90 days is an operator of a storage facility and is
subject to the requirements of 40 CFR Part 264 and the permit requirements of
40 CFR Part 270 unless he has been granted an extension to the 90 day period.
As
noted during the inspection, Respondent stored hazardous waste on-site for
greater than 90 days without complying with 40 CFR Part 264 and 40 CFR Part
270. Specifically, Respondent stored one 20-cubic yard roll-off since November
20, 2020 and
approximately 3,000 gallons in the Sludge Thickener Tank since January 28, 2021
of F019 hazardous waste for greater than 90 days.
h. Pursuant
to IC 13-30-2-1(10), a person may not commence or engage in the operation of a
hazardous waste facility without having first obtained a permit from the
department.
As noted
during the inspection, Respondent operated a hazardous waste facility without
having first obtained a permit from the department. Specifically, Respondent
stored one 20-cubic yard roll-off since November 20, 2020
and approximately 3,000 gallons in the Sludge Thickener Tank since January 28,
2021 of F019 hazardous waste.
Additionally,
Respondent treated F019 waste to render it less hazardous or to make it safe or
acceptable for transport. On April 7,
2021, Respondent requested the transporter pick-up F019 roll-off. On April 22,
2021, the transporter arrived but would not accept the waste for transportation
as it was too wet and liquid
was leaking from the roll-off. Respondent drained liquid from the roll-off into
Tank T1 and subsequently pumped to Tanks N1 and N2 for neutralization to make
the roll-off safe and acceptable to transport. Liquids were also pumped from
the F019 roll-off into the Sludge Thickener Tank.
i. Pursuant
to 40 CFR 270.1(c), a permit is required for the treatment, storage
and disposal of any hazardous waste as identified or listed in 40 CFR Part 261.
As
noted during the inspection, Respondent stored hazardous waste identified or
listed in 40 CFR Part 261 without a permit. Specifically, Respondent stored one 20-cubic
yard roll-off since November 20, 2020 and
approximately 3,000 gallons in the Sludge Thickener Tank since January 28, 2021
of F019 hazardous waste.
Additionally,
Respondent treated F019 waste to render it less hazardous or to make it safe or
acceptable for transport. On April 7,
2021, Respondent requested the transporter pick-up F019 roll-off. On April 22,
2021, the transporter arrived but would not accept the waste for transportation
as it was too wet and liquid was leaking from the
roll-off. Respondent drained liquid from the roll-off into Tank T1 and
subsequently pumped to Tanks N1 and N2 for neutralization to make the roll-off
safe and acceptable to transport. Liquids were also pumped from the F019
roll-off into the Sludge Thickener Tank.
j. 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 containers with an indication of the
hazards of the contents. Specifically, Respondent failed to label or mark one
20-cubic yard roll-off of F019 and one 55-gallon container of D009 crushed
mercury-containing bulbs.
k. Pursuant
to 40 CFR 262.17(a)(5)(ii)(A), 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 tank is labeled or marked clearly with
the words "Hazardous Waste."
As noted
during the inspection, Respondent accumulated hazardous waste on-site, without
a permit, and did not label or clearly mark hazardous waste tanks with the
words "Hazardous Waste." Specifically,
Respondent failed to label or mark the following tanks as hazardous waste:
Sludge Thickener, T1, N1, N2, and N3.
l. Pursuant
to 40 CFR 262.17(a)(5)(ii)(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 tank 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 tanks with an indication of the
hazards of the contents. Specifically, Respondent failed
to label or mark the following tanks with an indication of the hazards: Sludge
Thickener, T1, N1, N2, and N3.
m. Pursuant
to 40 CFR 262.17(a)(5)(ii)(C) and (D), 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, inventory
logs, monitoring equipment, or other records are used to demonstrate that
hazardous waste has been emptied within 90 days of first entering the tank if
using a batch process, or in the case of a tank with a continuous flow process,
demonstrates that the estimated volumes of hazardous waste entering the tank
daily exit the tank within 90 days of first entering. Inventory logs or records must be maintained
on site and readily available for inspection.
As noted
during the inspection, Respondent accumulated hazardous waste on-site, without
a permit, and failed to demonstrate through inventory logs, monitoring
equipment or other records tank contents were emptied within 90 days and failed
to maintain these records on site and readily available for inspection. Specifically,
Respondent failed to demonstrate tank contents were emptied every 90 days and
failed to maintain records for the following tanks: Sludge Thickener, T1, N1,
N2, and N3.
n. Pursuant
to 40 CFR 262.17(a)(6) referencing 40 CFR 262.262(b), a large quantity
generator that first becomes subject to these provisions after May 30, 2017 or
a large quantity generator that is otherwise amending its contingency plan must at that time
submit a quick reference guide of the contingency plan to the local emergency
responders identified at paragraph (a) of this section or, as appropriate, the
Local Emergency Planning Committee. The quick reference guide must include:
(1)
The
types/names of hazardous wastes in layman’s terms and the associated hazard
associated with each hazardous waste present at any one time.
(2)
The
estimated maximum amount of each hazardous waste that may be present at any one
time.
(3)
The
identification of any hazardous wastes where exposure would require unique or
special treatment by medical or hospital staff.
(4)
A
map of the facility showing where hazardous wastes are generated, accumulated and treated and routes for accessing these
wastes.
(5)
A
street map of the facility in relation to surrounding businesses, schools,
residential areas to understand how best to get to the facility and also evacuate citizens and workers.
(6)
The
locations of water supply.
(7)
The
identification of on-site notification systems; and
(8)
The
name of the emergency coordinator(s) and 7/24-hour emergency telephone number(s)
or, in the case of a facility where an emergency coordinator is continuously on
duty, the emergency telephone number for the emergency coordinator.
As noted
during the inspection, Respondent failed to include a quick reference guide of
the contingency plan.
o. Pursuant
to 40 CFR 262.17(a)(7)(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 annual hazardous waste training.
p. 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 all the required hazardous waste
training related documents and records on-site.
q. 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.
r. 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 a land disposal
notification form when disposing of F019 hazardous waste as non-regulated oily
water and solids.
s. Pursuant
to 40 CFR 262.17(a)(2) referencing 40 CFR 265.190, tank systems for storing or
treating hazardous waste must meet the requirements of Subpart J.
As noted
during the inspection, the wastewater treatment system was shut down on January
29, 2021. The following tanks were used
to store and/or treat hazardous waste without meeting the requirements of
Subpart J: Sludge Thickener, T1, N1, N2, and N3.
t. Pursuant to 40 CFR 262.15(a)(5)(ii), a generator must mark or label its satellite
hazardous waste containers with an indication of the hazards of the contents.
As noted during the inspection,
Respondent accumulated hazardous waste in containers at or near the point of
generation without a permit and did not properly mark satellite accumulation
containers with an indication of the hazards of the contents. Specifically,
Respondent failed to mark the following satellite accumulation containers with
the indication of the hazards of the contents: skirt coating liquid;
phosphating line, filters and rags; and aerosol paint waste.
8.
Orders
of the Commissioner are subject to administrative review by the Office of
Environmental Adjudication under IC 4-21.5; however, in recognition of the
settlement reached, Respondent acknowledges notice of this right and waives any
right to administrative and judicial review of this Agreed Order.
II. ORDER
1.
This Agreed Order shall be effective
(“Effective Date”) when it is approved by Complainant or Complainant’s delegate, and has been received by Respondent. This Agreed
Order shall have no force or effect until the Effective Date.
2.
Respondent shall comply with the statutes and rules listed in the
findings of fact above.
3.
Upon the Effective Date of the Agreed Order,
Respondent shall comply with 40 CFR 262.11. Specifically, Respondent shall
cease the disposal of F019 waste as a non-hazardous waste. Respondent shall use the F019 waste code on
all hazardous waste manifests.
4.
Within fifteen (15) days of the Effective Date,
Respondent shall submit to IDEM documentation verifying a proper waste
determination and disposal records for F019 hazardous waste.
5. Upon the Effective Date of the Agreed
Order,
Respondent shall comply with 329 IAC 3.1-1-10. Specifically, Respondent shall
notify the Commissioner of storage and treatment activity
or cease said activities.
6. Within fifteen (15) days of the
Effective Date, Respondent shall submit to IDEM notification documentation or
documentation that storage and treatment activities have ceased.
7. Upon the Effective Date of the Agreed
Order, Respondent shall comply with 40 CFR 262.18(c). Specifically, Respondent
shall offer F019 hazardous waste for transport or to a treatment, storage or
disposal facility that has received an EPA identification number.
8. Upon the Effective Date of the Agreed
Order, Respondent shall comply with 40 CFR 262.20 and IC 13-30-2-1(12).
Specifically, Respondent shall properly manifest F019 hazardous waste for
shipment.
9. Within thirty
(30) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a),
IC 13-30-2-1(10), and 40 CFR 270.1(c). Specifically, Respondent shall not
accumulate hazardous waste for more than 90 days unless an extension has been
granted to the timeframe for as long as it remains a large quantity generator
of hazardous waste.
10. Within forty-five (45) days of the Effective
Date, Respondent shall empty and properly manage and dispose of F019 hazardous
waste from the following tanks: Sludge Thickener, T1, N1, N2, and N3.
11. Within sixty (60) days of the Effective
Date, Respondent shall properly close the following tanks according to the tank
closure performance standards requirements at 40 CFR 262.17(a)(8)(iii): Sludge Thickener, T1, N1, N2, and N3.
12. Within thirty (30) days of the Effective
Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(B),
40 CFR 262.17(a)(5)(ii)(B), and 40 CFR 262.15(a)(5)(ii). Specifically,
Respondent shall mark or label all hazardous waste containers and tanks with an
indication of the hazards of the contents.
13. Within thirty (30)
days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(ii)(A).
Specifically, Respondent shall mark or label all hazardous waste tanks with
the words “Hazardous Waste”.
14. Within thirty (30) days of the Effective
Date, Respondent shall comply with 40 CFR 262.17(a)(5)(ii)(C) and (D).
Specifically, Respondent shall document and maintain records that demonstrate hazardous
waste tanks are emptied of their contents every 90 days and submit said documentation
to IDEM.
15. Within thirty (30) days of the Effective
Date, Respondent shall comply with 40 CFR 262.17(a)(6) referencing 40 CFR
262.262(b). Specifically, Respondent
shall develop a quick reference guide and submit it to the local emergency
responders and IDEM.
16. 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.
17. Within forty-five (45) days of the
Effective Date, Respondent shall submit to IDEM documentation of hazardous
waste management training to all individuals involved with hazardous waste
management.
18. Within forty-five (45) days of the
Effective Date, Respondent shall comply with 40 CFR 262.17(a)(7)(iv). Specifically,
Respondent shall develop and submit to IDEM 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.
19. 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.
20. Upon the Effective Date of the Agreed
Order, Respondent shall comply with 40 CFR 268.7(a). Specifically, Respondent
shall not allow transportation of hazardous waste for off-site treatment,
storage, disposal without preparing a one-time Land Disposal Notification Form
and identifying the hazardous waste constituents associated with the waste.
21.
All submittals required by this Agreed Order,
unless IDEM notifies the Respondent otherwise
in writing, shall be sent to:
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Debbie
Chesterson, Enforcement Case Manager |
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Office
of Land Quality |
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Indiana
Department of Environmental Management |
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100
North Senate Avenue |
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Indianapolis,
IN 46204-2251 |
22. Pursuant to IC 13-30-4-1, Respondent is
assessed and agrees to pay a civil penalty of Fifty-Eight Thousand Two Hundred Ten
Dollars ($58,210). Respondent shall pay by the due date printed on the Invoice,
as attached.
Civil and stipulated penalties are
payable to the “Environmental Management Special Fund” by:
Mail:
Civil penalties are payable by check to
the “Environmental Management Special Fund”. Checks shall include the Case
Number of this action and shall be mailed to:
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Indiana
Department of Environmental Management |
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Accounts
Receivable |
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IGCN,
Room 1340 |
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100
North Senate Avenue Indianapolis,
IN 46204 |
Online:
Accounts Receivable is accepting
payments online by e-Check, Master Card, Visa or Discover. Please visit www.IN.gov/IDEM.
Under Online Services, click Online Payment options and follow the prompts. A
processing fee of $1 plus 1.99% will be charged for credit card payments.
A processing fee of $1.00 will be charged for eCheck
payments.
The Case Number is required to complete
the process.
Phone:
You may also call us at 317-234-3099 and
follow the instructions for Master Card, Visa or Discover payments. A
processing fee of $1 plus 1.99% will be charged for credit card payments.
A processing fee of $1.00 will be charged for eCheck
payments.
The Case Number is required to complete
the process.
23.
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:
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Paragraph |
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Penalty |
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Order paragraph 4 |
$100 per week |
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Order paragraph 6 |
$100 per week |
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Order paragraph 14 |
$100 per week |
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Order paragraph 15 |
$100 per week |
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Order paragraph 17 |
$100 per week |
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Order paragraph 18 |
$100 per week |
24.
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.
25.
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 an additional penalty of 10 percent, payable to the “Environmental
Management Special Fund”, and shall be payable to IDEM in the manner specified
in Paragraph 22 above.
26.
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 25, above.
27.
Signatories to this Agreed Order certify that
they are fully authorized to execute this Agreed Order and legally bind the
party they represent.
28.
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.
29.
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.
30.
Respondent shall ensure that all contractors,
firms, and other persons performing work under this Agreed Order comply with
the terms of this Agreed Order.
31.
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.
32.
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.
33.
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.
34.
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.
35.
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.
36. This Agreed Order shall remain in effect until
IDEM issues a Resolution of Case letter to Respondent.
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TECHNICAL RECOMMENDATION: |
RESPONDENT: |
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Department of Environmental Management |
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By: _________ |
By:
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Jennifer
Reno, Section Chief |
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Land Enforcement
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Printed: ______________________ |
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Office of
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Title: ________________________ |
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Date: _____________ |
Date: _______________________ |
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COUNSEL FOR RESPONDENT: |
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By: ________________________ |
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Date: ______________________ |
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APPROVED AND
ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL |
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MANAGEMENT
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DAY
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20__. |
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For the
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_Signed on
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Peggy Dorsey, Assistant Commissioner |
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Office of
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