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. 2023-29164-H

 

 

)

 

TRADEBE TREATMENT AND

RECYCLING, LLC,

 

)

)

 

 

 

)

 

Respondent.

 

)

 

 

AGREED ORDER

 

Complainant and Respondent desire to settle and compromise this action without hearing or adjudication of any issue of fact or law, and consent to the entry of the following Findings of Fact and Order. Pursuant to Indiana Code (“IC”) 13-30-3-3, entry into the terms of this Agreed Order does not constitute an admission of any violation contained herein. Respondent’s entry into this Agreed Order shall not constitute a waiver of any defense, legal or equitable, which Respondent may have in any future administrative or judicial proceeding, except a proceeding to enforce this order.

 

I. FINDINGS OF FACT

 

1.                  Complainant is the Commissioner (“Complainant”) of the Indiana Department of Environmental Management (“IDEM”), a department of the State of Indiana created by IC 13-13-1-1.

 

2.                  Respondent is Tradebe Treatment and Recycling, LLC (“Respondent”), which owns and operates the facility with U.S. EPA ID No. IND000646943, located at 4343 Kennedy Avenue, in East Chicago, Lake County, Indiana (“Site”).

 

3.                  Respondent has a RCRA permit (“Permit”), which authorizes Respondent, as the permittee, to conduct storage and treatment activities at this Site. Respondent operates as a large quantity generator of hazardous waste pursuant to a Permit dated April 28, 2017 (modified December 17, 2018). A RCRA Permit renewal application was submitted on October 28, 2021 [VFC# 83236773] and remains under review.

 

4.                  IDEM has jurisdiction over the parties and the subject matter of this action.

 

5.                  Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation (“NOV”) via Certified Mail to:

 

Robert O’Brien, Manager

Corporation Service Company, Registered Agent

Tradebe Treatment and Recycling, LLC

Tradebe Treatment and Recycling, LLC

1433 E. 83rd Ave., Suite 200

135 North Pennsylvania Street, Suite 1610

Merrillville, IN 46410

Indianapolis, IN 46204

 

 

Tita LaGrimas

 

VP Regulatory Affairs and Sustainability

 

Tradebe Treatment and Recycling, LLC

 

1433 East 83rd Avenue, Suite 200

 

Merrillville, IN 46410

 

Tita.LaGrimas@tradebe.com

 

 

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 December 5, 2022 [VFC# 83421274], conducted by a representative of IDEM, the following violations were found:

 

a.         Pursuant to 40 CFR 264.171 and Permit Condition III.C., if a container holding hazardous waste is not in good condition (e.g., appreciable rusting, apparent structural defects) or if it begins to leak, the Permittee must transfer the hazardous waste from such container to a container that is in good condition or otherwise manage the waste in compliance with the conditions of the permit.

 

As noted during the inspection, Respondent had eighteen (18) containers of hazardous waste that were not stored in good condition.

 

b.         Pursuant to Permit Condition III. E. c., containers of 30 gallons or more must be stored so that they can be inspected for leaks and for deterioration caused by corrosion or other factors, without having to move the containers during the inspection and must have adequate aisle space between rows (approximately 2 ½ feet) to facilitate inspection.

 

As noted during the inspection, there was inadequate aisle space between container rows in Area 7 North Apron and Area 3.

 

c.         Pursuant to Permit Condition III.E.2.a. and Attachment D, Table D-1, containerized hazardous waste or hazardous secondary materials either being transferred from one permitted unit to another (such as from container storage to tank storage) or being removed from one permitted unit followed by replacement back into that same unit shall remain outside of permitted units only for the minimum time necessary to either transfer the containers to a different storage unit or to remove the containers, perform the activities that required the staging to occur, and return the containers to a permitted storage unit. In no instance shall this time period exceed 12 hours. The containers will be managed in accordance with applicable conditions in Attachment D of the permit. Documentation of container movement from a permitted storage area to a staging area followed by placement into a permitted storage area will include: the identification of the container, the date of movement, the time the first container was removed from permitted storage, the location of the staging area, and the time the first container was removed from the staging area and placed into permitted storage. This documentation shall be maintained for 30 days.

 

As noted during the inspection, Respondent allowed twenty-three (23) containers of hazardous waste to exceed the 12-hour time period for container transfer/movement between permitted areas and did not manage the twenty-three (23) containers in accordance with Attachment D; Respondent stored liquid containers in solid only permitted units. In addition, Respondent was unable to provide documentation of container movement, to include dates of placement in permitted storage areas [staging log].

 

d.         Pursuant to 40 CFR 264.173(b) and Attachment D, Permit Condition D-1a(2).M.1.c., TRADEBE will manage DOT-approved containers of various sizes, shapes, and capacities. These containers can be arranged in various configurations within the limits of the storage areas. Stored containers may be stacked as specified in this permit, provided the configurations allow for inspection for leaks and provide adequate aisle space between containers/pallets. Containers must be stacked in stable configurations (i.e., container(s) will not readily fall off of the pallet or damage the integrity of the containers or supporting structure).

 

As noted during the inspection, Respondent stored containers in unstable configurations in Area 7 North Apron, Area 6, Area 7 East Apron, and Area 11.

 

e.         Pursuant to 40 CFR 264.177(c), a storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.

 

Pursuant to Permit Condition III.I.3, the Permittee must separate containers of incompatible wastes as indicated in the Process Information, Attachment D.

 

Pursuant to Attachment D, Permit Condition D-la (2).A., TRADEBE will evaluate the chemical and physical analyses of the hazardous waste and hazardous debris to be handled at the facility, pursuant to 40 CFR 270.14(b)(2). The laboratory will evaluate the compatibility characteristics of the waste with the container in accordance with the Waste Analysis Plan (Attachment C). Hazardous waste will be placed into permitted storage areas and chemically incompatible wastes and materials will be segregated to comply with 40 C.F.R. §264.177.

 

Pursuant to Attachment D, Permit Condition D-1a (2).M.1.h., for containers located next to the berms separating areas used to store incompatible wastes in Areas 5 and 6, stacking of individual containers on top of another container is permissible only on the following conditions:

 

i.          the stacked containers are compatible with material in the adjacent sub-area,

ii.         incompatible materials are not store in adjacent sub-area, or

iii.        a barrier has been installed (e.g., netting, fence) that will prevent the upper container from falling into the adjacent sub-area.

 

As noted during the inspection, Respondent stored incompatible hazardous waste together without meeting the separation/barrier requirements; specifically, oxidizer waste was stored with flammable waste in Area 4 South Apron, Area 6, Area 7 North Apron, and Area 7A-2.

 

f.          Pursuant to 40 CFR 264.73(b)(2), the following information must be recorded, as it becomes available, and maintained in the operating record for three years unless noted as follows: the location of each hazardous waste within the facility and the quantity at each location. For disposal facilities, the location and quantity of each hazardous waste must be recorded on a map or diagram that shows each cell or disposal area. For all facilities, this information must include cross-references to manifest document numbers if the waste was accompanied by a manifest. This information must be maintained in the operating record until closure of the facility.

 

Pursuant to Attachment D, Permit Condition D-1a(2).I., containers will be marked, or re-marked, as information becomes available, pursuant to 40 CFR 264.73(b). Containers that are accepted by TRADEBE will be marked with a container specific identification number or symbol. The purpose of the marking is for internal tracking of the container for TRADEBE's operating records.

 

As noted during the inspection, and as required by Respondent’s operating record, Respondent failed to mark five (5) accepted containers with a container specific identification number or symbol (internal Tradebe acceptance or pre-code label).

 

g.         Pursuant to 40 CFR 264.173(a) and Permit Condition III.E.1.a., a container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.

 

As noted during the inspection, Respondent failed to store seven (7) containers of hazardous waste closed.

 

h.         Pursuant to Attachment D, Permit Condition D-1a(2).X., containers containing ignitable or reactive waste, with the exception of rail cars, may not be located within 50 feet of the property line of the facility, refer to Drawing B-397r316J.

 

As noted during the inspection, Respondent stored three (3) containers of ignitable waste in Area 7 East Apron within 50-feet of the property boundary line.

 

i.          Pursuant to Attachment D, Permit Condition D-1a(2).J., containers that require a protection of a dry chemical fire suppression system (based on the waste profile) and will be placed in the northwest sections of Area 6. These areas are equipped with a fire suppression system for water reactive wastes.

 

As noted during the inspection, Respondent stored two (2) containers, requiring dry chemical fire suppression, outside of Area 6.

 

j.          Pursuant to 40 CFR 270.30(i)(2) and Permit Condition I.8.b., the Permittee shall allow the Commissioner, or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit.

 

As requested during the inspection, Respondent failed to provide inbound and outbound truck logs and manifest copies.

 

k.         Pursuant to Permit Condition III.E.2. (b), the Permittee shall ensure that transport vehicles loaded with non-processed hazardous waste for shipment off-site leave the facility (or contiguous property controlled by the Permittee) within 72 hours of the time the hazardous waste is first moved out of permitted storage areas for loading onto the transport vehicle. If the shipment is cancelled, the waste must be placed back into permitted storage within the original 72-hour period.

 

The Permittee will document the time the first container is placed into an outbound trailer. The document identifying the time will be attached to a copy of the outbound manifest and placed inside the loaded trailer.

 

As noted during the inspection, Respondent failed to document the time the first container was placed in outbound Trailer #53R16001.

 

l.          Pursuant to 40 CFR 262.17(a)(1), a large quantity generator may accumulate hazardous waste on site without a permit or interim status, and without complying with the requirements of parts 124, 264 through 267, and 270 of this chapter, or the notification requirements of section 3010 of RCRA, provided that all of the following conditions for exemption are met:

 

(a)        Accumulation. A large quantity generator accumulates hazardous waste on site for no more than 90 days, unless in compliance with the accumulation time limit extension or F006 accumulation conditions for exemption in paragraphs (b) through (e) of this section. The following accumulation conditions also apply:

 

(1)       Accumulation of hazardous waste in containers. If the hazardous waste is placed in containers, the large quantity generator must comply with 40 CFR 262.17(a)(1)(i) through (vii).

 

As noted during the inspection, hazardous waste was identified outside of appropriate containers around SDS1 and SDS2 (char), in Area 3 (unknown waste), in Area 7 East Apron, and near the rail cars.

 

m.        Pursuant to Permit Condition III.F., the Permittee must construct, operate, and maintain the containment system as specified in Process Information, Attachment D, which is incorporated herein by reference.

 

Pursuant to Attachment D, Permit Condition D-1a (3)(e), within 24 hours of detection, TRADEBE shall remove accumulated liquids from the containment areas, or, if it cannot, it shall notify IDEM with an explanation, and remove accumulated liquids within 48 hours of detection and as necessary to prevent overflow of the collection system.

 

Pursuant to Attachment D, Permit Condition D-2d(1)(b) E, surface areas will be maintained free of gaps and cracks.

 

As noted during the inspection, Respondent failed to remove liquids from containment areas (sumps) for over 24 hours in Area 3, Area 6 Rack Room, Area 2 Dock, and Area 11. In addition, the secondary containment in Area 2 had visible cracks in the surface.

 

n.         Pursuant to 40 CFR 262.20(a)(1), a generator that transports, or offers for transport a hazardous waste for offsite treatment, storage, or disposal, or a treatment, storage, or disposal facility that offers for transport a rejected hazardous waste load, must prepare a Manifest (OMB Control number 2050-0039) on EPA Form 8700-22, and, if necessary, EPA Form 8700-22A.

 

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.

 

Pursuant to 329 IAC 3.1-1-13, the commissioner shall require the use of identification numbers issued by the U.S. Environmental Protection Agency.

 

As noted during the December 5, 2022 Site inspection and the December 6, 2022 inspection of the Tradebe Transportation LLC 10-day transfer facility (“Marport”), Respondent, allowed the transportation of six (6) rail cars (with heels, “non-RCRA empty”) offsite to the rail spur at Marport without a manifest. Five (5) of the cars were located on the Marport property and one (1) rail car was located between the two properties on the same rail spur. Respondent utilizes this area as a generator accumulation area, but this is not indicated in Respondent’s RCRA permit nor is the area indicated on Respondent’s facility map.

 

o.         Pursuant to Attachment D, Permit Condition D-1a [Container Receiving], incoming hazardous waste from an off-site generator shall be placed in permitted units within 72 hours, not including non-operating days, upon entering the facility boundary (or contiguous property controlled by the permittee) unless the permittee rejects all or part of an incoming shipment.

 

As noted during the inspection, Respondent allowed ten (10) incoming hazardous waste containers, with free liquids, from an outside generator to be stored outside of a permitted unit for greater than 72 hours.

 

p.         Pursuant to Permit Condition I.D.10, the Permittee shall give notice to the Commissioner as soon as possible of any planned physical alterations or additions to the permitted facility. 329 IAC 3.1-13; 40 CFR 270.30(1)(1).

 

As detailed during the March 20, 2023 meeting, Respondent improved a section of property contiguous to the Site to utilize a rail spur as a generator accumulation area to store rail cars holding hazardous waste. The rail spur improvements are owned by Respondent; the property on which the rail spur is situated is contiguous with the Site and is leased from a third party that is not affiliated with Respondent and shares no corporate relationship with Respondent. The rail spur exits the facility on the northeast side of the Site onto property leased by Respondent.

 

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, rules and permit conditions listed in the findings of fact above.

 

3.                  Within Thirty (30) days of the Effective Date, Respondent shall submit a draft Class 1 permit modification to IDEM for review. The draft modification must update the facility description and all facility maps to include the rail spur as a generator accumulation area.

 

4.                  Within Thirty (30) days of IDEM approval of the draft Class 1 modification, Respondent shall submit a complete Class 1 Permit Modification consistent with the approved draft. Upon approval of the Class I permit modification required under this paragraph, the requirements outlined in subparagraph n. of this order will not apply to movement of rail cars on the rail spur containing Tradebe generated waste, rejected or off-spec fuel blending loads, or residual heels (non-RCRA empty rail cars).

 

5.                  Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Thirty-Eight Thousand One Hundred Eighty-Eight Dollars ($38,188). 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:

 

Indiana Department of Environmental Management

Accounts Receivable

IGCN, Room 1340

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.

 

6.                  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 3, above.

 

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

 

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

 

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

 

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

 

11.              In the event that any terms of this Agreed Order are found to be invalid, the remaining terms shall remain in full force and effect and shall be construed and enforced as if this Agreed Order did not contain the invalid terms.

 

12.              This Agreed Order is not and shall not be interpreted to be a permit or a modification of an existing permit. This Agreed Order, and IDEM’s review or approval of any submittal made by Respondent pursuant to this Agreed Order, shall not in any way relieve Respondent of the obligation to comply with the requirements of any applicable permits or any applicable Federal or State laws or regulations.

 

13.              Complainant does not, by its approval of this Agreed Order, warrant or aver in any manner that Respondent’s compliance with any aspect of this Agreed Order will result in compliance with the provisions of any permit, order, or any applicable Federal or State law or regulation. Additionally, IDEM or anyone acting on its behalf shall not be held liable for any costs or penalties Respondent may incur as a result of Respondent’s efforts to comply with this Agreed Order.

 

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

 

15.              Nothing in this Agreed Order shall prevent IDEM or anyone acting on its behalf from communicating with the U.S. Environmental Protection Agency (U.S. EPA) or any other agency or entity about any matters relating to this enforcement action. IDEM or anyone acting on its behalf shall not be held liable for any costs or penalties Respondent may incur as a result of such communications with the U.S. EPA or any other agency or entity.

 

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

 

REMAINDER OF PAGE LEFT BLANK INTENTIONALLY

 

TECHNICAL RECOMMENDATION:

Department of Environmental Management

RESPONDENT:

 

 

 

 

By:

 

 

By:

 

 

Jennifer Reno, Chief

Printed:

 

 

Land Enforcement Section

Title:

 

 

Compliance Branch

 

 

 

Office of Land Quality

 

 

Date:

 

3/06/2024

 

Date:

 

 

 

 

 

 

 

 

 

 

COUNSEL FOR RESPONDENT:

 

 

By:

 

 

 

Printed:

 

 

 

Date:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

 

DAY OF

 

, 20_____

 

 

 

 

 

 

For the Commissioner:

 

 

 

Signed March 19, 2024

 

 

 

 

 

 

 

 

Peggy Dorsey

 

 

Assistant Commissioner

 

 

Office of Land Quality