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,

 

)

 

 

 

)

 

 

v.

 

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Case No. 2024-30456-H

 

 

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belden 2010 inc. D/b/a Belden wire and cable company,

 

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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 Belden 2010 Inc. d/b/a Belden Wire and Cable Company (“Respondent”), which owns/operates the facility with United States Environmental Protection Agency (“EPA”) ID No. IND006421374, located at 350 Northwest North Street, in Richmond, Wayne 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:

 

Ashish Chand, President                                       Corporation Service Company, Registered

Belden 2010 Inc. d/b/a Belden Wire                      Agent for Belden 2010 Inc. d/b/a Belden

and Cable Company                                               Wire and Cable Company

1 North Brentwood Boulevard, 15th Floor           135 North Pennsylvania Street, Suite 1610

St. Louis, MO 63105                                               Indianapolis, IN 46204

 

5.            Respondent notified EPA of Large Quantity Generator activities.

 

6.            Respondent manufactures singular and stranded wire for communications and data transmission.

 

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.            A Referral to Land Enforcement Section Letter which required a response to violation within 30 days was issued to the Respondent on May 31, 2024 (VFC# 83646147). Respondent submitted a response on June 21, 2024, and July 15, 2024 (VFC# 83707343). Based upon the responses received from Respondent and subsequent conversations, a Hazardous Waste Inspection Continuation/Description of Additional Violations was issued to Respondent on October 4, 2024 (VFC# 83707343).

 

9.            During an investigation including an inspection on April 25, 2024, conducted by a representative of IDEM, the following violations were found:

 

a.         Pursuant to 40 CFR 262.11(a), the hazardous waste determination for each solid waste must be made at the point of waste generation.

 

As noted during the inspection, Respondent did not make hazardous waste determinations on the following:

·            Two (2) 55-gallon drums located in the northeast corner of the plating         area.

·            Seven (7) 55-gallon drums located in the basement along the west wall of Building 19 in the empty drum staging area. Three (3) of the drums contained an unknown white sludge and one (1) was labeled unregulated sludge the source of which was unknown. Three of the drums could not be accessed and the contents were unknown.

·            Five (5) 5-gallon pails located in the basement along the south wall of Building 19 basement.

·            Two (2) 55-gallon drums located in the basement in the east storage area.

·            Contaminated wipes and sponges generated from cleaning printing equipment and oily wipes.

·            Numerous small containers stored in multiple storage cabinets located in the Facility Maintenance Area of the basement (south side of basement) containing unusable products.

·            A mixture of used oil and plating waste from overflow from WWT Tank 1 and its containment (north containment pit).

·            Wastewater, after WWT Tank 2, and prior to being added to the 20,000-gallon tank. Evaluate for characteristics.

·            Spent filters generated from the plating line and F006 applicability.

·          Used oil/F006 sludge mixture. Evaluate for characteristics.

 

Additionally, an improper waste determination was made for used oil commingled with a listed hazardous waste (F006). The waste was improperly determined to be used oil and handled as such. An improper waste determination was made on the solvent wipes containing chloroform (D022). Wipes contaminated with D022 cannot be managed under the solvent contaminated wipes exclusion and must be managed as hazardous waste (F003/D001/D022/D035).

 

On June 21, 2024, Respondent submitted documentation deemed adequate for the following:

·            Five (5) 5-gallon pails located in the basement along the south wall of Building 19 basement.

·            Two (2) 55-gallon drums located in the basement in the east storage area.

·            Used oil/F006 sludge mixture improperly determined to be used oil, was determined not to exhibit additional hazardous characteristics.

 

On April 23, 2025, Respondent submitted documentation deemed adequate for the

following:

·            Two (2) 55-gallon drums located in the northeast corner of the plating         area.

·            Seven (7) 55-gallon drums located in the basement along the west wall of Building 19 in the empty drum staging area.

 

 

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.

 

As noted during the inspection, Respondent did not identify all applicable EPA hazardous waste numbers for used oil commingled with F006 hazardous waste. Respondent shipped the waste as oily wastewater and/or used oil through Superior Environmental Solutions on March 21, 2024, and Valicor Environmental Services, LLC on April 17, 2024. The waste was shipped as used oil to Safety Kleen prior to the March and April 2024 shipments.

 

c.            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 generated used oil commingled with F006 hazardous waste and shipped as oily wastewater and/or used oil through Superior Environmental Solutions on March 21, 2024, and Valicor Environmental Services, LLC on April 17, 2024. The receiving facilities are not permitted to accept hazardous waste. The waste was shipped as used oil to Safety Kleen prior to the March and April 2024 shipments.

 

d.            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 in the basement near the wastewater treatment area where two (2) 55-gallon containers of F006 dated February 1, 2024, were stored.

 

On July 15, 2024, Respondent submitted documentation confirming weekly inspections for this area were implemented.

 

e.            Pursuant to 40 CFR 262.17(a)(1)(vi)(B), the large quantity generator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction while ignitable or reactive waste is being handled. The large quantity generator must confine smoking and open flame to specially designated locations. “No Smoking” signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.

 

As noted during the inspection, Respondent failed to post a “No Smoking” sign in the less than 90-day area where ignitable hazardous waste is stored.

 

On July 15, 2024, Respondent submitted photographic documentation of the posted signage.

 

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, one (1) 55-gallon container of wipes with solvents and inks in the less than 90-day storage shed and three (3) 1-gallon containers of unusable HCL (D002) stored in the laboratory were not marked or labeled with the words “Hazardous Waste.”

 

On July 15, 2024, Respondent submitted documentation that the HCL containers are still in process and not yet 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, one (1) 55-gallon container of wipes with solvents and inks in the less than 90-day storage shed was not marked 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, one (1) 55-gallon container of wipes with solvents and inks and one (1) 55-gallon drum of D001/F003 hazardous waste in the less than 90-day storage shed, and three (3) 1-gallon containers of D002 stored in the laboratory were not marked with an accumulation start date.

 

On July 15, 2024, Respondent submitted documentation that the HCL containers are still in process and not yet waste.

 

i.              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.

 

As noted during the inspection, hazardous waste was stored in the following tanks which did not meet the requirements of Subpart J:

·         One (1) 1,500-gallon poly tank located in the basement.

·         One (1) 2,800-gallon poly tank located in the basement.

 

On April 24, 2025, Respondent submitted a flow diagram for system changes made to the process.

 

j.              Pursuant to 40 CFR 262.17(a)(6) referencing 40 CFR 262.251, a large quantity generator must maintain and operate the facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.

 

As noted during the inspection, Respondent failed to properly manage the following areas to minimize a release to the environment:

·         Spent solvent used at the ink jet and ring band stations. Solvent and inks used in the processes that are not captured in small containers at the stations are allowed to flow directly to the floor or onto various absorbents (rags, sponges, absorbent pads, and socks) either on the printing units or on the floor under the units. Staining was significant in several of the areas.

·         Quench and dip oils leaked to areas of the first floor and/or to the containment areas of the filtering units in the north and south areas of the basement. The north side containment pit also houses the wastewater treatment system for plating waste, generating F006 waste. Tank 1 of the WWT system overflows into the north containment pit and is pumped to the 20,000-gallon tank along with the quench and dip oils. Additionally, F006 liquid is also pumped from the centrifuge and/or Tank 2 to the 20,000-gallon tank, and then to the evaporator and then to two poly tanks. The two poly tanks are not managed as Subpart J tanks.

·         Liquids and debris were observed on the floor of the tin plating area and under the plating lines. The liquid was within a bermed area of the plating department.

 

On February 28, 2025, Respondent submitted photographic documentation of the cleanup of these areas.

 

k.            Pursuant to 40 CFR 262.17(a)(6) referencing 40 CFR 262.261, the content of the contingency plan must include the following: a description of appropriate actions, arrangements with local emergency response teams, contact information for the emergency coordinators, emergency equipment, and an evacuation plan.

 

As noted during the inspection, Respondent's contingency plan did not include all of the required information. Specifically, the emergency coordinators list was outdated.

 

On July 15, 2024, Respondent submitted a revised contingency plan.

 

l.              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 develop a quick reference guide to the contingency plan.

 

On July 15, 2024, Respondent developed and submitted a quick reference guide.

 

m.          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 did not have the required land disposal restriction documentation for used oil commingled with a listed hazardous waste (F006).

 

On February 28, 2025, Respondent provided a copy of the LDR for F006 disposal.

 

n.            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, Respondent generated used oil commingled with a F006 hazardous waste. The waste was improperly determined to be used oil and shipped as oily wastewater and/or used oil through Superior Environmental Solutions on March 21, 2024, and Valicor Environmental Services, LLC on April 17, 2024, without preparing a hazardous waste manifest. The waste was shipped as used oil to Safety Kleen prior to the March and April 2024 shipments.

 

o.            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 inspection, Respondent failed to utilize the assigned U.S. EPA identification number when it generated used oil commingled with a F006 hazardous waste and shipped as oily wastewater and/or used oil through Superior Environmental Solutions on March 21, 2024, and Valicor Environmental Services, LLC on April 17, 2024. The waste was shipped as used oil to Safety Kleen prior to the March and April 2024 shipments.

 

p.            Pursuant to 40 CFR 262.15(a)(4), a satellite accumulation container holding hazardous waste must be closed at all times during accumulation, except when adding, removing or consolidating waste.

 

As noted during the inspection, Respondent accumulated one (1) 55-gallon container fitted with an aerosol can puncturing device, one (1) 55-gallon container of D002/F006 waste, and two (2) containers of used wipes with F003/D001/D022/D035 solvents and inks in satellite accumulation containers that were not closed.

 

On July 15, 2024, Respondent submitted photographic documentation of the container fitted with an aerosol can puncturing device closed.

 

q.            Pursuant to 40 CFR 262.15(a)(5)(i), a generator must mark or label its satellite hazardous waste containers with the words “Hazardous Waste.”

 

As noted during the inspection, Respondent accumulated one (1) 55-gallon container of D002/F006 waste and containers of wipes with F003/D001/D022/D035 solvents and inks in the extruder, vulcanization, and lacquer areas and did not properly mark the satellite accumulation containers with the words “Hazardous Waste.”

 

On July 15, 2024, Respondent submitted photographic documentation of the D002/F006 container labeled with the words “Hazardous Waste.”

 

r.             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 containers of wipes with F003/D001/D022/D035 solvents and inks in the extruder, vulcanization, and lacquer areas and did not properly mark the satellite accumulation containers with an indication of the hazards of the contents.

 

s.            Pursuant to 40 CFR 273.13(d), a small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of universal waste to the environment in containers that must remain closed.

 

As noted during the inspection, Respondent did not store one (1) 4-foot box of universal waste lamps in the wire drawing maintenance area and two (2) 4-foot boxes of universal waste lamps in the universal waste storage area in the southeast portion of the basement closed.

 

On July 15, 2024, Respondent submitted photographic documentation of the containers closed.

 

t.             Pursuant to 329 IAC 13-4-2(a), mixtures of used oil and hazardous waste must be managed in accordance with 329 IAC 13-3-1(b). Pursuant to 329 IAC 13-3-1(b)(2), used oil mixed with characteristic hazardous waste identified in 40 CFR 261, Subpart C, revised as of July 1, 2005, is subject to 329 IAC 3.1, Hazardous Waste Management Permit Program and Related Hazardous Waste Management and 329 IAC 3.1-7-1, Adoption of federal standards applicable to generators of hazardous waste.

 

As noted during the inspection, Respondent failed to manage used oil mixed with listed waste (D002/F006) as hazardous waste. Specifically, the mixture of waste is generated from dip and quench oils, filtered in the basement, processed and/or leaking from filtration equipment and plating treatment waste, a D002/F006 waste.

 

u.            Pursuant to 329 IAC 13-4-3(d), generators must label all used oil containers and aboveground tanks with the words “Used Oil.”

 

As noted during the inspection, Respondent did not label used oil containers with the words “Used Oil.” Specifically, Respondent failed to label the following containers of used oil with the words “Used Oil”:

·         Eight (8) 55-gallon drums in east side storage shed.

·         One (1) 5-gallon pail at a wire drawing machine.

·         One (1) 275-gallon tote in the basement on the west side of Building 19.

·         The containment pits.

 

On July 15, 2024, Respondent submitted photographic documentation of used oil containers labeled as such.

 

v.            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.

 

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.

 

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 (1) 55-gallon container of used wipes (F003/D001/D022/D035) in the less than 90-day storage shed since October/November 2023.

 

10.         Orders of the Commissioner are subject to administrative review by the Office of Administrative 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 statutes and rules listed in the findings of fact above.

 

3.            Within thirty (30) days of the Effective Date, Respondent shall comply with 40 CFR 262.11. Specifically, Respondent shall complete a waste determination on the following:

·         Numerous small containers stored in multiple storage cabinets located in the Facility Maintenance Area of the basement (south side of basement) containing unusable products.

·         A mixture of used oil and plating waste from the overflow from WWT Tank 1 and its containment (north containment pit). Submit sampling results.

·         Wastewater, after WWT Tank 2, and prior to being added to the 20,000-gallon tank. Evaluate for characteristics and submit sampling results.

·         Spent filters generated from the plating line and F006 applicability. Evaluate for characteristics and submit sampling results.

 

 If the waste is hazardous, it shall be managed according to the applicable regulations.

 

4.            Within forty-five (45) days of the Effective Date, Respondent shall submit to IDEM waste determination documentation required in Order paragraph 3.

 

5.            Within thirty (30) days of the Effective Date, Respondent shall submit the disposal documentation for the numerous small containers that were stored in multiple storage cabinets located in the Facility Maintenance Area of the basement.

 

6.            Upon the Effective Date, Respondent shall comply with 40 CFR 262.11 and 329 IAC 13-4-2(a). An improper waste determination was conducted for the used oil mixed with F006 waste and wipes that contain chloroform (D022). Properly manage the mixture of used oil with F006 waste as hazardous waste. Properly manage the chloroform containing wipes as a hazardous waste (D022).

 

7.            Within forty-five (45) days of the Effective Date, Respondent shall comply with 40 CFR 262.11(g). Specifically, Respondent shall submit to IDEM hazardous waste manifests for shipments of the F006 waste stream and D022 wipes listed in Order paragraph 6 with all applicable waste codes identified.

 

8.            Upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(A) and 40 CFR 262.15(a)(5)(i). Specifically, Respondent shall ensure all generator and satellite accumulation containers are labeled or marked clearly with the words “Hazardous Waste.”

 

9.            Upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(B) and 40 CFR 262.15(a)(5)(ii). Specifically, Respondent shall ensure all generator and satellite accumulation containers are labeled or clearly marked with an indication of the hazards of the contents.

 

10.         Upon the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(5)(i)(C). Specifically, Respondent shall ensure all generator accumulation containers are marked with an accumulation start date.

 

11.         Within thirty (30) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(2) referencing 40 CFR 265.190. Specifically, Respondent shall submit a written description of the process changes to IDEM in order to demonstrate the 1,500-gallon and 2,800-gallon poly tanks located in the basement would no longer be subject to Subpart J requirements.  Submit cleanout documentation for these tanks to IDEM.

 

12.         Within thirty (30) days of the Effective Date, Respondent shall comply with 40 CFR 262.17(a)(6) referencing 40 CFR 262.251. Specifically, Respondent shall institute repairs and clean up all released waste in the ink jet and ring band stations, tin plating area and under the plating lines, and to areas of the first floor and/or to the containment areas of the filtering units in the north and south areas of the basement, and submit to IDEM repair documentation and disposal documentation for the cleaned up wastes.

 

13.         Upon the Effective Date, 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.

 

14.         Upon the Effective Date, Respondent shall comply with 329 IAC 3.1-1-13. Specifically, Respondent shall use their assigned EPA Identification Number on manifests.

 

15.         Upon the Effective Date, Respondent shall comply with 40 CFR 262.15(a)(4).  Specifically, Respondent shall ensure that the one (1) 55-gallon container of D002/F006 waste and two (2) containers of used wipes with solvents and inks are stored closed expect to add, remove or consolidate waste.

 

16.         Upon the Effective Date, Respondent shall comply with 40 CFR 262.17, IC 13-30-2-

1(10), and 40 CFR 270.1(c). Specifically, Respondent shall not store hazardous waste onsite for greater than 90 days as a large quantity generator unless an extension is obtained prior to the expiration of the 90-day time period.

 

17.         Within fifteen (15) days of the Effective Date, Respondent shall submit a copy of the hazardous waste manifest documenting the proper disposal of the one (1) 55-gallon container of used wipes (F003/D001/D022/D035) in the less than 90-day storage shed since October/November 2023.

 

18.         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

 

19.         Pursuant to IC 13-30-4-1, Respondent is assessed and agrees to pay a civil penalty of Fifty-Two Thousand Three Hundred Sixty Dollars ($52,360). 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.

 

20.         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 #3

Order paragraph #4

Order paragraph #5

Order paragraph #7

Order paragraph #11

Order paragraph #12

Order paragraph #17

$100 per week

$100 per week

$100 per week

$100 per week

$100 per week

$100 per week

$100 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.

 

21.         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.

 

22.         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 19, above.

 

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

 

24.         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.

 

25.         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.

 

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

 

27.         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.

 

28.         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.

 

29.         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.

 

30.         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.

 

31.         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.

 

32.         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:

 

6/5/2025

 

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 08/08/25

 

 

 

 

 

 

 

Brian Wolff

 

 

Assistant Commissioner

 

 

Office of Land Quality