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Case Nos. 2022-28788-H
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2022-28789-H |
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Logansport Utilities, |
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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 Logansport Utilities
(“Respondent”), which owns/operates the facility with United States
Environmental Protection Agency (“EPA”) ID No. IND981952518, located at 800
Race Street, in Logansport, Cass County, Indiana (“Logansport Generating Plant”)
and the facility located at 824 Michigan Avenue, in Logansport, Cass County,
Indiana (“Logansport Utilities”).
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:
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Logansport Utilities |
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Attn: Greg Toth |
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601 East Broadway |
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Logansport, IN 46947 |
5.
Respondent notified EPA as a Non-Handler of
hazardous waste for the Logansport Generating Plant. Logansport Utilities has
not submitted a notification for hazardous waste activities.
6.
Respondent is a utility company.
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.
Count I
(2022-28788-H)
Logansport
Generating Plant
a.
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 large
quantity generator activities.
b.
Pursuant
to 40 CFR 262.13, a generator must determine its
generator category. A generator’s
category is based on the amount of hazardous waste generated each month and may
change from month to month.
c.
Pursuant
to 40 CFR 262.17(a), a large quantity generator
that accumulates hazardous waste on site for 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 400 gallons of D002/D004/D007/D010 identified as hazardous waste in lab
analytical provided to the Respondent in July 2021.
d.
Pursuant to 40 CFR 262.17(a)(1)(iii), the large
quantity generator must use container made of or lined with materials that will
not react with, and are otherwise compatible with, the hazardous waste to be
accumulated, so that the ability of the container to contain the waste is not
impaired.
As noted
during the inspection, Respondent allowed 400 gallons of D002/D004/D007/D010 hazardous waste to be pumped into incompatible, unlined 55-gallon steel
containers. Ultimately, the containers failed resulting in a release to the
environment.
e.
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
concrete pad where the sixteen (16) 55-gallon containers of D002 waste were
stored between April 11, 2022 thru May 31, 2022.
f.
Pursuant to 40 CFR 262.17(a)(5)(i)(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
container 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 containers with the
words "Hazardous Waste." Specifically, sixteen (16) 55-gallon
containers of D002/D004/D007/D010 and one (1) 30-yard cubic roll-off of
D002/D004/D007/D010 were not marked or labeled as “Hazardous Waste”.
g.
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, sixteen (16) 55-gallon containers of
D002/D004/D007/D010 and one (1) 30-yard cubic roll-off of D002/D004/D007/D010
were not marked or labeled with an indication of the hazards of the contents.
h.
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 hazardous waste containers with accumulation start
dates. Specifically, sixteen (16) 55-gallon containers of D002/D004/D007/D010
and one (1) 30-yard cubic roll-off of D002/D004/D007/D010 were not marked with
an accumulation start date.
i.
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, Logansport Utilities transported one (1) 30-yard cubic roll-off
of D002/D004/D007/D010 from the Generating Plant to the coal storage facility
located at 824 Michigan Avenue, Logansport, Indiana.
j.
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 caused or allowed the transportation of a
hazardous waste without a manifest as required by law. Specifically, Logansport
Utilities transported one (1) 30-yard cubic roll-off of D002/D004/D007/D010 from
the Generating Plant to the coal storage facility located at 824 Michigan
Avenue, Logansport, Indiana.
k.
Pursuant
to 40 CFR 262.10(a)(3), a generator shall not transport, offer its hazardous
waste for transport, or otherwise cause its hazardous waste to be sent to a
facility that is not a designated facility, as defined in 40 CFR 262.10, or not
otherwise authorized to receive the generator’s hazardous waste.
As noted
during the inspection, Respondent offered hazardous waste for transport to a
non-designated facility. Specifically, Respondent allowed the transportation of
one (1) 30-yard cubic roll-off of
D002/D004/D007/D010 hazardous waste from Logansport Generating Plant to
Logansport Utilities coal storage facility.
Count II
2022-28789-H
Logansport
Utilities
1. During an investigation including an inspection on June 20, 2022,
conducted by a representative of IDEM, the following violations were found:
a. 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 transporter and treatment,
storage, and disposal activities.
b.
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 caused or allowed the transportation of a
hazardous waste without a manifest as required by law. Specifically, Logansport
Utilities transported one (1) 30-yard cubic roll-off of D002/D004/D007/D010
from the Generating Plant to the coal storage facility located at 824 Michigan
Avenue, Logansport, Indiana without a manifest.
c.
Pursuant
to 329 IAC 3.1-1-13, the commissioner shall require the use of identification
numbers issued by the United States Environmental Protection Agency.
As noted
during the inspection, Respondent failed to obtain an EPA ID number.
d.
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 transported and
stored one (1)
30-yard cubic roll-off of D002/D004/D007/D010 hazardous waste from
Logansport Generating Plant to Logansport Utilities coal storage facility.
e.
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 transported and stored one (1) 30-yard cubic roll-off of D002/D004/D007/D010
hazardous waste from
Logansport Generating Plant to Logansport Utilities coal storage facility.
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 statute and rules listed in the
findings of fact above.
3.
Upon the Effective Date of the Agreed Order,
Respondent shall comply with 329 IAC 3.1-1-10 and 329 IAC 3.1-1-13.
Specifically, Respondent shall submit an electronic notification of generator activities
in the myRCRAid module of RCRAInfo.
Instructions can be found here: https://www.in.gov/idem/waste/waste-industries/waste-transportation/how-to-obtain-a-new-rcra-id-number/.
Respondent shall utilize the EPA ID Number assigned to them for all hazardous
waste shipments.
4.
Upon
the Effective Date of the Agreed Order, 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.
5.
Upon
the Effective Date of the Agreed Order,
Respondent shall comply with 40 CFR 262.13. Specifically, Respondent shall
determine their generator category on a monthly basis.
6.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR
262.17(a)(1)(iii). Specifically, Respondent shall utilize containers that are lined
with materials that will not react with and are compatible with the hazardous
waste being accumulated.
7.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR
262.17(a)(1)(v). Specifically, Respondent shall conduct weekly inspections of
central accumulation areas for as long as it remains a large quantity generator
of hazardous waste.
8.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR
262.17(a)(5)(i)(A). Specifically, Respondent shall mark
hazardous waste containers with the words “Hazardous Waste.”
9.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR
262.17(a)(5)(i)(B). Specifically, Respondent shall
mark hazardous waste containers with an indication of the hazards of the
contents.
10.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR
262.17(a)(5)(i)(C). Specifically, Respondent shall mark hazardous waste containers with an
accumulation start date.
11.
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 hazardous waste prior
to shipment utilizing
hazardous waste transporters and treatment, storage, and disposal facilities with
an EPA identification number.
12.
Upon
the Effective Date of the Agreed Order, Respondent shall comply with IC 13-30-2-1(10) and 40 CFR 270.1(c). Specifically,
Respondent shall cease the acceptance and storage of hazardous waste or apply
for a permit for the treatment, storage, and disposal of hazardous waste.
13.
Upon
the Effective Date of the Agreed Order, Respondent shall cease hazardous waste
transporter activities.
14.
Within
fifteen (15) days of the Effective Date of the Agreed Order, Respondent shall
properly dispose of the 30-yard cubic
roll-off of D002/D004/D007/D010 hazardous waste to a permitted
treatment, storage, and disposal facility.
15.
Within thirty (30) days of the Effective Date
of the Agreed Order, Respondent shall submit disposal documentation from
Paragraph 14, including hazardous waste manifest and land disposal restriction
form, to IDEM.
16.
Within
thirty (30) days of the Effective Date of this Agreed Order, Respondent shall
submit a site assessment for approval. Contact the case manager for how to
submit the site assessment. The purpose of the site assessment plan shall be to
conduct sampling and analysis in order to assess potential contamination of
different media (soil, ground water, and vapor) from the area of concern which
includes the spill location of the D002/D004/D007/D010 hazardous waste at the cement
slab in the east southeast corner of the Generating Plant where 9th
Street ends and curves into an alley
and, if necessary, the nature and extent of contamination. The site assessment plan shall be based upon
the principles outlined in IDEM’s Remediation Closure Guide (RCG), dated March
22, 2012, which can be accessed at: http://www.IN.gov/idem/cleanups/2329.htm. In addition, the site assessment plan shall:
a.
Describe
and evaluate all areas of potential contamination in and around each area of
concern.
b.
Specify
the method of determining the number and location of samples to be taken to
yield a representative assessment of each media of concern. This method shall be in accordance with
Section 3, Conceptual Site Model of the RCG, to address each media:
1. Soil sampling, pursuant to Sections 3
and 8 of the RCG; and
2. Ground water sampling, pursuant to
Sections 3, 4, and 9 of the RCG.
c.
Specify
how the soil samples will be obtained and handled in order to
minimize loss of volatile constituents. Respondent
may composite samples of non-volatiles (i.e., metals and semi-volatiles), but
shall not composite samples of volatiles, pursuant to Section 3.2.4 of the RCG.
d.
Specify
how the ground water samples, pursuant to Section 3.3 of the RCG, will be obtained
and describe the sampling procedures.
e.
Clearly
define all sampling and analytical protocols designed to identify hazardous
waste or its constituents, pursuant to 40 CFR 261, including Appendices I, II,
III, and VIII. The site assessment plan
shall include the method of sample collection, pursuant to “Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication
SW-846. This includes, but is not
limited to, sample collection containers, preservatives, and holding
times. Specify the analytical methods to
be used and the method’s reporting and detection limits.
f.
Specify
that chain-of-custody of the samples shall be maintained
and Quality Assurance and Quality Control (“QA/QC”) procedures shall be
followed, pursuant to Section 3.8 through 3.10 of the RCG for all media.
g.
Include
within the site assessment plan a supplemental contingent plan for determining
the horizontal and vertical nature and extent of:
1. Soil contamination, as specified
Sections 3 and 8 of the RCG, in the event that
sampling, and analysis indicates soil contamination to exist above screening
levels as specified in Table A-6 of Appendix A of the RCG; and
2. Ground water contamination in the event
that sampling and analysis indicates hazardous waste
or its constituents are detected in the ground water as specified in Sections
3, 4, and 9 of the RCG.
h.
If
soil or ground water contamination is above screening levels and there is an
enclosed structure where indoor air may be impacted, it may be necessary to
conduct a vapor intrusion investigation.
In regard to soil contamination, professional
judgment will dictate the necessity of a vapor intrusion investigation.
i.
Include
within the site assessment plan time frames for its implementation.
j.
Be
approved by IDEM prior to its implementation.
17.
Within
fifteen (15) days of receiving notice from IDEM of approval of the site
assessment plan, Respondent shall implement it as approved and in accordance
with the time frames contained therein.
18.
Within
fifteen (15) days of obtaining the analytical results, Respondent shall submit
said results, including chain-of-custody information, and QA/QC records,
pursuant to Section 3.8 through 3.10 of the RCG to IDEM.
19. Respondent shall submit within forty-five
(45) days subsequent to the submittal of the
analytical results, a remediation workplan which identifies potential contaminants,
potential receptors, and exposure pathways to IDEM for the purpose of
identifying all media contamination. The
remediation workplan shall:
a. In accordance with Section 7, Risk
Evaluation of the RCG, remediate each contaminated area to meet the remediation
objective(s). Remediation objectives
shall be one of the following:
1. screening levels, pursuant to Table A-6
of Appendix A in the RCG; or
2. levels based upon site specific risk
assessment; or
3. levels based on site specific risk
assessment taking into account remedial measures that
manage the risk and controls completed and potential pathways; or
4. background levels for inorganics,
pursuant to the RCG, and/or the analytical method’s estimated quantitation
limits (“EQLs”) for organics.
b. Include a sampling and analysis plan to
be performed after the remedial activities have been performed which verifies
that all contamination meets the remediation objective(s).
c.
Include
within the remediation workplan time frames of its implementation.
20.
Within
fifteen (15) days of approval by IDEM of the remediation workplan, Respondent
shall implement the remedial action(s) within the plan as approved and in accordance
with the time frames contained therein.
21.
Within
thirty (30) days of completion of the remedial action(s) conducted pursuant to
the remediation workplan, Respondent shall submit to IDEM certification by an
independent registered professional engineer that the remedial action(s)
has/have been completed as outlined in the approved remediation workplan.
22. In the event IDEM determines that any
plan submitted by Respondent is deficient or otherwise unacceptable, Respondent
shall revise and resubmit the plan to IDEM in accordance with IDEM’s
notice. After three (3) submissions of
such plan by Respondent, IDEM may modify and approve any such plan and
Respondent must implement the plan as modified by IDEM. The approved plan shall be incorporated into
this Agreed Order and shall be deemed an enforceable part thereof.
23.
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 |
24.
Pursuant
to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Thirty-Two
Thousand Dollars ($32,000). After this Agreed Order is adopted (signed by the
Assistant Commissioner of the Office of Land Quality), Respondent shall pay by
the due date printed on the Invoice that will be attached to the adopted Agreed
Order.
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 |
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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.
25.
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 |
Stipulated Penalty |
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Order paragraph
3 |
$100
per week |
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Order paragraph
14 |
$100
per week |
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Order paragraph
16 |
$500
per week |
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Order paragraph
18 |
$500
per week |
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Order paragraph
19 |
$500
per week |
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Order paragraph
21 |
$500
per week |
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Order paragraph
22 |
$500
per week |
26.
Stipulated penalties shall be due and payable after
Respondent receives written notice that Complainant has determined a stipulated
penalty is due; at which time, a separate invoice will be issued. 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.
27.
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 24, above.
28.
Signatories to this Agreed Order certify that
they are fully authorized to execute this Agreed Order and legally bind the
party they represent.
29.
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.
30.
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.
31.
Respondent shall ensure that all contractors,
firms, and other persons performing work under this Agreed Order comply with
the terms of this Agreed Order.
32.
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.
33.
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.
34.
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.
35.
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.
36.
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.
37.
This
Agreed Order shall remain in effect until IDEM issues a Resolution of Case
letter to Respondent.
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APPROVED
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MANAGEMENT
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Peggy
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