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. 2024-29946-H

 

 

)

 

brenntag great lakes, 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 Brenntag Great Lakes, LLC, which owns/operates the facility, with United States Environmental Protection Agency (“EPA”) ID No. IND984891556, located at 1615 Estella Avenue, in Fort Wayne, Allen County, Indiana (“Site”).

 

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

 

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

 

Kaoni Rhodes, Manager

Brenntag Great Lakes, LLC

Corporation Service Company, Registered Agent

for Brenntag Great Lakes, LLC

4420 North Harley Davidson Avenue

Wauwatosa, WI 53225

135 North Pennsylvania Street, Suite 1610

Indianapolis, IN 46204

 

5.            Respondent notified EPA of Large Quantity Generator activities on February 16, 2023 and subsequentially updated to Non-Handler activities on September 20, 2023.

 

6.            Respondent was formerly a wholesale distributor of chemicals at this Site.

 

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

 

8.            During an investigation including an inspection on June 20, 2023, conducted by a representative of IDEM, the following violations were found:

 

a.        Pursuant to 40 CFR 262.11(a), a person who generates solid waste must determine if that waste is a hazardous waste at the point of generation.

 

As noted during the inspection, Respondent failed to make hazardous waste determinations on wastes generated during the clean-up of containment areas, tanks, and process equipment as part of the facility closure in November 2022. Waste from the clean-up activities, waste residuals left in process equipment and many small containers storing various chemicals collected throughout the building, including the laboratory, were stored onsite.

 

On October 9, 2023, Respondent submitted manifests documenting disposal.

 

b.        Pursuant to 40 CFR 262.17(a)(8), a large quantity generator accumulating hazardous wastes in containers, tanks, drip pads, and containment buildings prior to closing a unit at the facility, or prior to closing the facility, must meet the following conditions:

(i)     Must place a notice in the operating record within 30 days after closure or meet the closure performance standards of 262.17(a)(8)(iii).

(ii)  Notify EPA using form 8700-12 no later than 30 days prior to closing the facility or notify EPA using form 8700-12 within 90 days after closing the facility that it has complied with the closure performance standards of 40 CFR 262.17(a)(8)(iii) or (iv).

 

As noted during the inspection, Respondent failed to submit notification of closure using form 8700-12.

 

On March 4, 2024, Respondent submitted a closure notification for the September 20, 2023 closure.

 

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 numerous containers of D and U listed hazardous waste beyond the 90-day period. Respondent ceased operations in November 2022 and shipped the waste off-site in August 2023.

 

On October 9, 2023, Respondent submitted manifests documenting disposal.

 

d.      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 numerous containers of D and U listed hazardous waste without obtaining a permit. Respondent ceased operations in November 2022 and shipped the waste off-site in August 2023.

 

On October 9, 2023, Respondent submitted manifests documenting disposal.

 

e.        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 numerous containers of D and U listed hazardous waste without obtaining a permit. Respondent ceased operations in November 2022 and shipped the waste off-site in August 2023.

 

On October 9, 2023, Respondent submitted manifests documenting disposal.

 

f.         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 central accumulation areas.

 

g.            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."

 

h.        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.

 

i.          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.

 

j.          Pursuant to 40 CFR 262.17(a)(6) referencing 40 CFR 262.260, a generator must have a contingency plan for the facility.

 

As noted during the inspection, Respondent failed to maintain an onsite contingency plan.

 

k.        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 maintain an onsite quick reference guide.

 

l.              Pursuant to 40 CFR 262.42(a)(2) and 329 IAC 3.1-7-2, a large quantity generator must submit an Exception Report to the EPA Regional Administrator if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter.

 

As noted during the inspection, Respondent failed to submit an Exception Report for manifest 023993443 JJK received by the initial transporter on August 2, 2023, and signed by the destination facility on October 5, 2023. Respondent did not receive a copy of the manifest with the handwritten signature from the designated facility within 45 days of the date the waste was accepted by the initial transporter.

 

m.        Pursuant to 40 CFR 262.17(a)(2) referencing 40 CFR 265.190, if waste is placed in tanks, the large quantity generator must comply with the applicable requirements of Subpart J. The requirements of Subpart J apply to owners and operators of facilities that use tank systems for storing or treating hazardous waste except as otherwise provided in paragraphs (a), (b), and (c) of this section or in § 265.1 of this part.

 

As noted during the inspection, Respondent left residual waste in tanks from which usable products were removed between August and November 2022. The business operations at the site ceased in November 2022. Respondent did not finish removing residual wastes in tanks until August 2, 2023. The tanks were left with residual product for greater than 90-days making the tanks subject to Subpart J requirements. The tanks did not comply with all Subpart J requirements and previously stored ferric chloride, sodium hypochlorite, hydrogen peroxide, sulfuric acid, and DEF.

 

9.            Orders of the Commissioner are subject to administrative review by the Office of Adinistriative Law Proceedings under IC 4-21.5; however, in recognition of the settlement reached, Respondent acknowledges notice of this right and waives any right to administrative and judicial review of this Agreed Order.

 

II. ORDER

 

1.            This Agreed Order shall be effective (“Effective Date”) when it is approved by Complainant or Complainant’s delegate and has been received by Respondent. This Agreed Order shall have no force or effect until the Effective Date.

 

2.            Respondent shall comply with the rules listed in the findings of fact above.

 

3.            Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.11. Specifically, Respondent shall complete waste determinations at the point of generation.

 

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 262.17(a)(1)(v). Specifically, Respondent shall inspect central accumulation areas as long as Respondent remains a large quantity generator of hazardous waste.

 

6.            Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(A). Specifically, Respondent shall label or clearly mark hazardous waste containers with the words "Hazardous Waste."

 

7.            Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(B). Specifically, Respondent shall label or clearly mark containers with an indication of the hazards of the contents.

 

8.            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 accumulation start dates.

 

9.            Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.260.  Specifically, Respondent shall develop and maintain a contingency plan for as long as Respondent remains a large quantity generator of hazardous waste.

 

10.         Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.17(a)(6) referencing 40 CFR 262.262(b). Specifically, Respondent shall maintain an onsite quick reference guide for as long as Respondent remains a large quantity generator of hazardous waste.

 

11.         Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.42(a)(2) and 329 IAC 3.1-7-2. Specifically, Respondent shall submit exception reports when required.

 

12.         Upon the Effective Date of the Agreed Order, Respondent shall comply with 40 CFR 262.17(a)(2) referencing 40 CFR 265.190. Specifically, Respondent shall comply with Subpart J requirements.

 

14.         Within sixty (60) days of the Effective Date of this Agreed Order, Respondent shall submit to IDEM a hazardous waste closure plan for the rack storage area in the warehouse, blending and acid rinse tanks inside the building’s southeast corner, the room located between the storage racks in the warehouse and the southwest dock, and the outdoor tank farm area for approval. Contact the case manager for how to submit the closure plan. The closure plan shall be completed in accordance with the provisions of 40 CFR 264 Subpart G, as incorporated by 329 IAC 3.1-9-1.

 

15.         Within thirty (30) days of notice of IDEM’s approval of the closure plan, Respondent shall implement the plan as approved and in accordance with the time frames contained therein.

 

16.         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.

 

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

 

Debbie Chesterson, Enforcement Case Manager

Office of Land Quality

Indiana Department of Environmental Management

100 North Senate Avenue

Indianapolis, IN 46204-2251

 

18.         Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Fifty-Eight Thousand Four Hundred Thirty-Eight Dollars ($58,438). 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.

 

19.         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 14

$500 per week

Order paragraph 15

$500 per week

 

 

Stipulated penalties shall begin to be assessed on the date after the Effective Date and shall continue until the documentation is submitted as required by the associated paragraph.

 

20.         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.

 

21.         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 18, above.

 

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

 

23.         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.

 

24.         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.

 

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

 

26.         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.

 

27.         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.

 

28.         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.

 

29.         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.

 

30.         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.

 

31.         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:

 

4/25/2025

 

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 on 06/20/25

 

 

 

 

 

 

 

 

Brian Wolff

 

 

Assistant Commissioner

 

 

Office of Land Quality