STATE OF INDIANA

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SS:

BEFORE THE INDIANA DEPARTMENT OF

 

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COUNTY OF MARION

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ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

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OF ENVIRONMENTAL MANAGEMENT,

 

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Complainant,

 

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v.

 

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Case No. 2023-29875-H

 

 

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crown cork & Seal usa, inc.,

 

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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 Crown Cork & Seal USA, Inc. (“Respondent”), which owns/operates the facility with United States Environmental Protection Agency (“EPA”) ID No. IND006037857, located at 400 North Walnut Street, in Crawfordsville, Montgomery 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, on February 20, 2024, IDEM issued a Notice of Violation (“NOV”) via certified mail to:

 

Alfred J. Dermody

C T Corporation System, Registered Agent

Crown Cork & Seal USA, Inc.

Crown Cork & Seal USA, Inc.

770 Township Line Road

334 North Senate Avenue

Yardley, PA 19067

Indianapolis, IN 46204

 

5.                  Respondent notified EPA of Large Quantity Generator activities on January 9, 2024.

 

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 11, 2023, 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 hazardous waste determination on two (2) totes of elementary neutralization unit wicket wash (“wicket wash”), a solid waste, generated by Respondent. Specifically, Respondent determined that one (1) tote of wicket wash (shipped February 15, 2022, 2,320 pounds, non-hazardous manifest # 233965) and one (1) tote of wicket wash (shipped September 12, 2023, 2,384 pounds, bill of lading #329407) were a non-hazardous waste when in fact the two (2) totes had a pH of 12.5 (D002).

 

Both totes were disposed of properly as follows:

February 25, 2022. The designated facility returned the rejected tote (2,320 lbs.) from non-hazardous manifest #233965 to Respondent on Manifest #012526931 FLE. Respondent adjusted the pH and returned the neutralized tote to the designated facility for disposal as a non-hazardous waste.

 

September 20, 2023. At the request of Respondent, the designated facility shipped the rejected tote (2,384 lbs.) from bill of lading #329407 to a designated facility on Manifest #018196148 FLE for proper disposition.

 

b.         Pursuant to 40 CFRF 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 § 260.10 of this chapter, or not otherwise authorized to receive the generator's hazardous waste.

 

As noted during the inspection, Respondent offered two (2) totes of wicket wash, a D002 hazardous waste, to a designated facility not authorized to receive the hazardous waste.

 

c.         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.

 

As noted during the inspection, Respondent failed to determine if two (2) totes of wicket wash (D002) were restricted from land disposal and if the waste had to be treated before being land disposed.

 

d.         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.

 

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, on February 15, 2022 and September 12, 2023, Respondent offered hazardous waste, wicket wash (D002), for transportation for offsite disposal without preparing a manifest.

 

e.         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 (U.S. EPA).

 

As noted during the inspection, Respondent failed to use its assigned U.S. EPA ID number on Manifest # 018196148 FLE, dated September 30, 2023.

 

f.          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 training records of hazardous waste training for the outside contractor whose employees provide the cleaning service for the curing oven at the Site.

 

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.                  Immediately upon the Effective Date, Respondent shall comply with 40 CFR 262.11(a), 40 CFR 262.10(a)(3), 40 CFR 262.17(a)(9) referencing 40 CFR 268.7(a), 40 CFR 262.20, and IC 13-30-2-1(12). Specifically, Respondent shall ensure:

a.         A hazardous waste determination in completed as required prior to shipment.

b.         A manifest is used for shipment of hazardous waste.

c.         A LDR is generated as required.

 

4.                  Within thirty (30) days of the Effective Date, Respondent shall comply with 329 IAC 3.1-1-13. Specifically, Respondent shall correct the EPA ID Number on Manifest 018196148FLE to reflect Respondent’s EPA ID Number. Documentation of correction shall be submitted to IDEM.

 

5.                  Within thirty (30) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(7)(v). Specifically, Respondent shall develop and/or maintain personnel training records on-site for the required time. These records shall include contractor personnel training records which are applicable to their duties at the Site.

 

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

 

Linda McClure, Enforcement Case Manager

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

7.                  Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Twelve Thousand Eight Hundred Dollars ($12,800). 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 “Indiana Department of Environmental Management” by:

 

            Mail:

Civil penalties are payable by check to the “Indiana Department of Environmental Management.” Checks shall include the Case Number of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Accounts Receivable

P.O. Box 3295

Indianapolis, IN 46206

 

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 $0.40 plus 2.06% will be charged for credit card payments.  A processing fee of $0.15 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 $0.40 plus 2.06% will be charged for credit card payments.  A processing fee of $0.15 will be charged for eCheck payments.

The Case Number is required to complete the process.

 

8.                  In the event the terms and conditions of the following paragraphs are violated, Complainant may assess, and Respondent shall pay a stipulated penalty in the following amount:

 

Paragraph

Stipulated Penalty

Order paragraph #4

$100 per week

Order paragraph #5

$100 per week

 

9.                  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; 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.

 

10.              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 “Indiana Department of Environmental Management,” and shall be payable to IDEM in the manner specified in Paragraph 7, above.

 

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

 

12.              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.

 

13.              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.

 

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

 

15.              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.

 

16.              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.

 

17.              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.

 

18.              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.

 

19.              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.

 

20.              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:

RESPONDENT:

Department of Environmental Management

 

 

 

 

By:

 

 

By:

 

 

Jennifer Reno, Chief

Printed:

 

 

Land Enforcement Section

Title:

 

 

Compliance Branch

 

 

 

Office of Land Quality

 

 

Date:

 

3/19/2024

 

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 3/27/2024

 

 

 

 

 

 

 

 

Peggy Dorsey

 

 

Assistant Commissioner

 

 

Office of Land Quality