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. 2025-30702-U

 

 

)

 

SB BROWNSBURG HOLDINGS INC. AND

 

)

 

BROWNSBURG OPERATIONS

 

)

 

CORPORATION,

 

)

 

 

 

)

 

Respondents.

 

)

 

 

AGREED ORDER

 

Complainant and Respondents 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. Respondents’ entry into this Agreed Order shall not constitute a waiver of any defense, legal or equitable, which Respondents 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 Indiana Code (“IC”) 13-13-1-1.

 

2.            Respondent SB Brownsburg Holdings Inc. which owns the Underground Storage Tank (“UST”) systems, with UST Facility ID 40070, located at 7963 Paul Avenue, parcel number 32-07-26-200-022.000-016, in Brownsburg, Hendricks County, Indiana (the “Site”).

 

3.            Respondent Brownsburg Operations Corporation operates the UST systems located at the Site.

4.            Respondents own and operate one (1) 12,000-gallon regular unleaded (“RUL”) gasoline and one (1) 8,000-gallon compartmented UST. C1 is 4,000-gallon premium unleaded (“PUL”) and C2 is 4,000-gallon diesel. All USTs are steel CLAD and double-walled. The piping is OPW flexwork, double-walled, and pressurized.

 

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”) on July 16, 2025 via certified mail to:

 

Surinder Singh, President and Registered

Amarjit Kaur, President for

Agent for,

Brownsburg Operations Corporation,

SB Brownsburg Holdings Inc., UST and

UST Operator

Property Owner

7963 Paul Avenue

6755 Robin Hood Court

Brownsburg, Indiana 46112

Indianapolis, Indiana 46227

Kamlakaur2018@yahoo.com

Singh_paul21@yahoo.com

 

Singh_paul21@icloud.com

Amarjit Kaur, Registered Agent for

 

Brownsburg Operations Corporation

 

2701 Lafayette Road

 

Indianapolis, Indiana 46222

 

6.            Indiana has incorporated the majority of the federal UST regulations pursuant to 329 Indiana Administrative Code (“IAC”) 1-1-1.

 

7.            During an investigation including an inspection on January 17, 2025 conducted by a representative of IDEM, the following violations were found:

 

a.            Pursuant to IC 13-23-12-1, each year if an underground storage tank has not been closed before January 1 of the year under rules adopted under IC 13-23-1-2; or a requirement imposed by the commissioner before the adoption of rules under IC 13-23-1-2; the owner shall pay to the department an annual registration fee. The annual registration fee required by this section is ninety dollars ($90) for each underground petroleum storage tank; or two hundred forty-five dollars ($245) for each underground storage tank containing regulated substances other than petroleum. If an underground storage tank consists of a single tank in which there are separate compartments, a separate fee shall be paid for each compartment within the single tank. If an underground storage tank consists of a combination of tanks, a separate fee shall be paid for each compartment within each tank in the combination of tanks.

 

As noted during the inspection, Respondents failed to pay the annual registration fee for 2023 and 2024.

 

UST fees for 2023 and 2024 paid in May 2024.

 

b.         Pursuant to 329 Indiana Administrative Code (“IAC”) 9-2-2(c), an owner and operator required to submit a form under subsection (a)(2) shall provide all the information required in subsection (b) on a form approved by the Indiana archives and records administration for use by the department and shall indicate the type of notification on the form.

 

As noted during the inspection, Respondents failed to submit a complete notification form with all required information and/or failed to indicate the type of notification on the form.

 

A notification form was received November 5, 2024 and an Administrative denial was issued on December 12, 2024. A corrected form has not been submitted.

 

On August 2, 2024 an updated notification for was resubmitted.  On August 4, 2025, an approval notice was issued.

 

c.         Pursuant to 40 Code of Federal Regulations (“CFR”) 280.40(a)(2), owners and operators of UST systems must provide a method, or combination of methods, of release detection that is installed and calibrated in accordance with the manufacturer’s instructions.

 

            As noted during the inspection, Respondents failed to provide a method or combination of methods of release detection that is installed and calibrated in accordance with the manufacturer’s instructions. Specifically, the automatic tank gauge (“ATG”) was nonresponsive and unable to provide release detection records. The screen was frozen showing all sensors (annular and submersible turbine pump (“STP”)) in alarm. Testing documentation from January 9, 2025 showed water present in the interstitial space of the tanks and sensors failing testing.

 

            Documentation of ATG and sensor testing dated April 4, 2025 submitted April 23, 2025; however, the water present in the interstitial space was not addressed.

 

            Documentation submitted April 25, 2025 that water intrusion was repaired with new caps and grommets by contractor.

 

d.         Pursuant to 40 CFR 280.41(a)(2), and previously 329 IAC 9-3-1.3 (repealed 2018), tanks installed after September 2, 2009 must be monitored for releases at least every 30 days using the method listed in § 280.43(g).

 

            As noted during the inspection, Respondents failed to monitor tanks installed after September 2, 2009 utilizing the method listed in § 280.43(g). Specifically, twelve (12) months of interstitial monitoring release detection records for all USTs were not provided.

 

            Documentation of equipment repaired and retested submitted April 23, 2025.

 

e.         Pursuant to 40 CFR 280.41(b)(2), taking into consideration previous Indiana rules 329 IAC 9-2-1(2)(D) and 329 IAC 9-3-1.3 (both repealed 2018), piping installed or replaced after September 2, 2009 must meet one of the following:

(i)        Pressurized piping must be monitored for releases at least every 30 days in accordance with § 280.43(g) and be equipped with an automatic line leak detector in accordance with § 280.44(a)

(ii)        Suction piping must be monitored for releases at least every 30 days in accordance with § 280.43(g).

 

As noted during the inspection, Respondents failed to appropriately monitor piping installed after September 2, 2009 for releases. Specifically, twelve (12) months of interstitial monitoring release detection records for piping were not provided.

 

Documentation of equipment repaired and retested submitted April 23, 2025; however, release detection records were not submitted.

 

f.          Pursuant to 40 CFR 280.43(g), interstitial monitoring between the UST system and a secondary barrier immediately around or beneath it may be used for purposes of release detection, but only if the system is designed, constructed, and installed to detect a leak from any portion of the tank that routinely contains product and also meets one of the following requirements:

(1)       For double walled UST systems, the sampling or testing method can detect a leak through the inner wall in any portion of the tank that routinely contains product;

(2)       For UST systems with a secondary barrier within the excavation zone, the sampling or testing method used can detect a leak between the UST system and the secondary barrier in accordance with this rule; and

(3)       For tanks with an internally fitted liner, an automated device can detect a leak between the inner wall of the tank and the liner, and the liner is compatible with the substance stored.

 

As noted during the inspection, Respondents failed to perform interstitial monitoring in accordance with the rule in that the liquid sensor testing appeared to indicate the compartmented tanks interstitial space contained water. The STP sumps were observed to contain fluid above the liquid sensor which would not allow for proper interstitial monitoring (“IM”) for the piping. The under dispenser containment (“UDC”) also appeared to have fuel lines’ interstitial space open and free to drain; however, there were no sensors in the UDCs.

 

Documentation of equipment repaired and retested submitted April 23, 2025; however, a work order or other documentation showing set up completed and operation has not been submitted.

 

g.         Pursuant to 40 CFR 280.20(c)(1)(ii), to prevent spilling and overfilling associated with product transfer to the UST system, owners and operators must use the following spill and overfill prevention equipment:

(ii)        Overfill prevention equipment that will:

(A)       Automatically shut off flow into the tank when the tank is no more than 95 percent full; or

(B)       Alert the transfer operator when the tank is no more than 90 percent full by restricting the flow into the tank or triggering a high-level alarm; or

(C)      Restrict flow 30 minutes prior to overfilling, alert the transfer operator with a high level alarm one minute before overfilling, or automatically shut off flow into the tank so that none of the fittings located on top of the tank are exposed to product due to overfilling.

 

As noted during the inspection, Respondents failed to properly maintain appropriate overfill prevention equipment. Specifically, automatic shutoff devices (“ASD”) were listed on previous notification forms; however, they were not observed at the time of the inspection and the presence ball float valves (“BFV”) could not be verified.

 

Documentation submitted showing ASD installed.

 

h.         Pursuant to 40 CFR 280.35(a)(1), spill prevention equipment (such as a catchment basin, spill bucket, or other spill containment device) and containment sumps used for interstitial monitoring of piping must prevent releases to the environment by meeting one of the following:

(i)         The equipment is double walled and the integrity of both walls is periodically monitored at a frequency not less than the frequency of the walkthrough inspections described in §280.36. Owners and operators must begin meeting paragraph (a)(1)(ii) of this section and conduct a test within 30 days of discontinuing periodic monitoring of this equipment; or

(ii)        The spill prevention equipment and containment sumps used for interstitial monitoring of piping are tested at least once every three years to ensure the equipment is liquid tight by using vacuum, pressure, or liquid testing in accordance with one of the following criteria:

(A)       Requirements developed by the manufacturer (Note: Owners and operators may use this option only if the manufacturer has developed requirements);

(B)       Code of practice developed by a nationally recognized association or independent testing laboratory; or

(C)       Requirements determined by the implementing agency to be no less protective of human health and the environment than the requirements listed in paragraphs (1)(1)(ii)(A) and (B) of this section.

 

As noted during the inspection, Respondents failed to ensure spill prevention equipment and/or containment sumps used for interstitial monitoring of piping were operating properly to prevent releases to the environment. Specifically, spill bucket, STP and UDC testing documentation were not provided.

 

Documentation of spill bucket, UDC, and STP testing dated April 3, 2025-April 4, 2025 received on April 23, 2025.

 

i.          Pursuant to 40 CFR 280.35(a)(2), overfill prevention equipment must be inspected at least once every three years. At a minimum, the inspection must ensure that overfill prevention equipment is set to activate at the correct level specified in § 280.20(c) and will activate when regulated substance reaches that level. Inspections must be conducted in accordance with one of the criteria in paragraph (a)(1)(ii)(A) through (C) of this section.

 

            As noted during the inspection, Respondents failed to inspect overfill prevention equipment at least once every three years.

 

j.          Pursuant to 40 CFR 280.36(a)(1)(i), as incorporated, to properly operate and maintain UST systems, not later than June 28, 2021, owners and operators must meet one of the following:

(1) Conduct a walkthrough inspection that, at a minimum, checks the following equipment as specified below:

(i)        Every 30 days (Exception: spill prevention equipment at UST systems receiving deliveries at intervals greater than every 30 days may be checked prior to each delivery):

(A)       Spill prevention equipment—visually check for damage; remove liquid or debris; check for and remove obstructions in the fill pipe; check the fill cap to make sure it is securely on the fill pipe; and, for double walled spill prevention equipment with interstitial monitoring, check for a leak in the interstitial area; and

(B)       Release detection equipment— check to make sure the release detection equipment is operating with no alarms or other unusual operating conditions present; and ensure records of release detection testing are reviewed and current.

 

As noted during the inspection, Respondents failed to properly conduct 30-day walkthrough inspections to check equipment as specified.

 

k.         Pursuant to 40 CFR 280.245, owners and operators of underground storage tank systems must maintain a list of designated Class A, Class B, and Class C operators with specified information and maintain appropriate records including specified information verifying that training and retraining, as applicable, have been completed, in accordance with § 280.34.

 

            As noted during the inspection, Respondents failed to maintain a list of designated Class A, Class B, and Class C operators with complete information and to maintain appropriate records verifying that training and retraining has been completed.

 

8.         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, Respondents acknowledge notice of this right and waive 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 Respondents. This Agreed Order shall have no force or effect until the Effective Date.

 

2.            Respondents shall comply with the statute and rules listed in the findings of fact above.

 

3.            Within thirty (30) days of the Effective Date, Respondents shall comply with 40 CFR 280.35(a)(2). Specifically, Respondents shall contract with an appropriately certified contractor to inspect, repair and test all overfill prevention equipment in accordance with a standard of practice referenced in the rule and submit documentation to the IDEM case manager at the address specified below.

 

4.            Within thirty (30) days of the Effective Date, Respondents shall comply with 40 CFR 280.36(a)(1)(i). Specifically, Respondents shall conduct a 30-day walkthrough inspection for all UST systems at the Site in accordance with 40 CFR 280.36(a)(1)(i) and submit documentation to the IDEM case manager at the address specified below.

 

5.            Within thirty (30) days of the Effective Date, Respondents shall comply with 40 CFR 280.245. Specifically, Respondents shall submit to the IDEM case manager at the address specified below a list of those employees designated to be Class A, Class B and Class C operators and training/retraining records with all necessary information included.

 

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

 

Jodi Pisula, 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, Respondents are assessed and agree to pay a civil penalty of Thirteen Thousand Two Hundred Dollars ($13,200.00), for which are jointly and severally liable. Said penalty amount shall be due and payable in twelve (12) monthly installments of One Thousand One Hundred Dollars ($1,100.00). Respondents shall pay the first installment by the due date printed on the Invoice, as attached. Respondents shall pay by the due date printed on subsequent invoices in accordance with the agreed upon payment plan.

 

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, American Express, or Discover. Please visit https://www.in.gov/idem/resources/e-services/online-payment-options/.  Under Transaction Item, choose Invoice 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 e-Check payments. The Case Number is required to complete the process.

 

For any questions or assistance regarding payments, please contact IDEM’s Accounts Receivable Team at (317) 233-2394.

 

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 #3

$100.00 per week

Order paragraph #4

$100.00 per week

Order paragraph #5

$100.00 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.

 

9.            Stipulated penalties shall be due and payable no later than the thirtieth day after Respondents receive written notice that Complainant has determined a stipulated penalty is due; at which time, a separate invoice will be issued. Complainant may notify Respondents at any time that a stipulated penalty is due. Failure to notify Respondents 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 Respondents for violation of this Agreed Order. Neither assessment nor payment of stipulated penalties shall preclude Complainant from seeking additional relief against Respondents 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. Respondents are jointly and severally liable for all stipulated penalty assessments.

 

10.         In the event that the monies due to IDEM pursuant to this Agreed Order are not paid on or before their Due Date, Respondents 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 10, 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 jointly and severally apply to and be binding upon Respondents and all successors and assigns. Respondents 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 Respondents shall in any way alter the Respondents’ status or responsibilities under this Agreed Order.

 

14.         Respondents 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 Respondents pursuant to this Agreed Order, shall not in any way relieve Respondents 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 Respondents’ 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 Respondents may incur as a result of Respondents’ 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 Respondents 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 Respondents.

 

REMAINDER OF PAGE LEFT BLANK INTENTIONALLY

 


 

TECHNICAL RECOMMENDATION:

 

Department of Environmental Management

 

 

 

 

By:

 

 

 

 

 

Jennifer Reno, Chief

 

 

 

Land Enforcement Section

 

 

 

Compliance Branch

 

 

 

Office of Land Quality

 

 

Date:

 

 

 

 

 

 

 

 

 

RESPONDENT:

SB Brownsburg Holdings Inc.

COUNSEL FOR RESPONDENT:

 

By:

 

 

By:

 

Printed:

 

 

Printed:

 

Date:

 

 

Date:

 

 

 

 

 

 

 

 

RESPONDENT:

Brownsburg Operations Corporation

COUNSEL FOR RESPONDENT:

 

By:

 

 

By:

 

Printed:

 

 

Printed:

 

Date:

 

 

Date:

 

 

 

 

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

 

DAY OF

 

, 20_____

 

 

 

 

 

 

For the Commissioner:

 

 

 

 

Signed 10/2/25

 

 

 

 

 

 

 

 

Brian Wolff

 

 

Assistant Commissioner

 

 

Office of Land Quality