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STATE OF INDIANA    )        BEFORE THE INDIANA DEPARTMENT
                )    SS:    OF ENVIRONMENTAL MANAGEMENT
COUNTY OF MARION    )

COMMISSIONER OF THE DEPARTMENT    )
OF ENVIRONMENTAL MANAGEMENT,    )
                            )
        Complainant,            )
                            )
            v.                )CAUSE NO. B-2489 or 1999-4783-W
                            )
                            )
TOWN OF WHITESTOWN,            )
RESPONDENT.                    )
                            )

AGREED ORDER


    The Complainant and the 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.

I. FINDINGS OF FACT

1.    Complainant is the Commissioner (hereinafter referred to as "Complainant") of the Indiana Department of Environmental Management, a department of the State of Indiana created by IC 13-13-1-1.

2.     Respondent is the Town of Whitestown (hereinafter referred to as "Respondent"), which owns and operates the publically owned treatment works (POTW) operated under National Pollutant Discharge Elimination System (NPDES) permit IN 0020796 and located at 75 Main Street, Whitestown, Indiana 46075.

3.     The Indiana Department of Environmental Management ("IDEM") has jurisdiction over the parties and subject matter of this action.

4.     Pursuant to IC 13-30-3-3, on October 14, 1999, IDEM issued a Notice of Violation via Certified Mail to:

        Marta Haza
        Town Board President            
        P.O. Box 325
        Whitestown, Indiana 46075    

5.     Pursuant to 327 IAC 2-4-1, a person, firm or corporation that operates a municipal, industrial, commercial or agricultural waste treatment plant control facility or discharges wastewaters to the waters of the state of Indiana shall submit to the Commissioner monthly reports of operation (MRO), which shall include flow measurements and wastewater characteristics.

6.    Pursuant to 327 IAC 5-2-15(a), a permittee must submit Discharge Monitoring Reports (DMRs) and Monthly Reports of Operation (MROs) to the commissioner. Such reports shall include flow measurements and waste characteristics.

7.    Pursuant to 327 IAC 5-2-8(1), the conditions apply to all NPDES permits and shall be incorporated into the permits either expressly or by reference. The permittee shall comply with all terms and conditions of its NPDES permit; any permit non-compliance constitutes a violation of the Clean Water Act (CWA) and the Environmental Management Act (EMA) and is grounds for enforcement action.

7.    Part I.B.3. of Permit IN 0020796 states, in part, the permittee shall submit monitoring reports to the Indiana Department of Environmental Management containing results obtained during the previous month and shall be postmarked no later than the 28th day of the month following each completed monitoring period. These reports shall include, but not be limited to, the Discharge Monitoring Report and the Monthly Report of Operation.
                                    
8.    Pursuant to 327 IAC 5-2-14, any permittee required to monitor under 327 IAC 5-2-13 shall maintain records of all monitoring information and monitoring activities as set forth in this rule.
                                            
9.    Part I.A.1. of Permit IN 0020796 states, in part, the permittee shall take samples and measurements to meet the effluent limitations and monitoring requirements at a location representative of the discharge.

10.    Part I.B.6. of Permit IN 0020796 states, in part, for each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: a.) the exact place, date, and time of sampling; b.) the person(s) who performed the sampling or measurements; c.) the dates the analyses were performed; d.)

the person(s) who performed the analyses; e.) the analytical techniques or methods used; and f.) the results of all required analyses and measurements.

11.    Part I.B.4.(b)(4) of Permit IN 0020796 states, in part, the 24-hour Composite Sample consists of two (2) grab samples, one collected at a time representing the daily peak flow, and the other sample collected at a time representing the average daily flow. The grab samples for the composites shall be proportioned to flow.

12.     A review of records and inspection reports dated March 17, 1998, March 19, 1998, March 20, 1998, March 23, 1998, and January 27, 1999 documents that the Town of Whitestown failed to submit the required monthly reports and failed to monitor as required for December 1997 and February through June 1998. This is in violation of 327 IAC 5-2- 15(a), 327 IAC 2-4-1, 327 IAC 5-2-8(1) and of Permit IN 0020796.

13.    A January 27, 1999 inspection report documents failure to maintain a sampling log in violation of 217 IAC 5-2-14(a), 327 IAC 5-2-8(1) and Part I.B.6. of Permit IN 0020796.
        
14.    On April 24, 1997, IDEM issued Agreed Order, Cause No. B-1787 to the Town of Whitestown for violations which included: failure to submit monthly reports; failure to meet NPDES permit effluent limitations; failure to properly operate and maintain its facility; and denial of access to authorized IDEM representatives. The Agreed Order included a requirement for the Town of Whitestown to submit and implement a Compliance Plan to address and correct the identified areas of noncompliance. On February 11, 1999, IDEM issued a Close Out Notification for Cause No. B-1787, as it had been determined that the Town of Whitestown had complied with the terms of the Agreed Order. However, a letter also dated February 11, 1999 advised the Town of Whitestown that the non-existence of Discharge Monitoring Reports (DMRs) for the months of December 1997 and February through June 1998 was still at issue as a basis for a separate enforcement action.

15.     On November 8, 1999, a Settlement Conference was held during which designated representatives of the Town of Whitestown and designated representatives of IDEM discussed the issues and problems at the Whitestown POTW, as identified in the Notice of Violation issued on October 14, 1999 and in an inspection conducted on September 30, 1999 (Attachment A). Whitestown informed IDEM that it had installed a flow meter and is also implementing procedures to address and resolve operations and maintenance and records/reports problems.

16.    In recognition of the settlement reached, Respondent 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 the Complainant or her delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the Effective Date.

2.     Within sixty (60) days of the Effective Date, the Respondent shall submit to IDEM a plan for evaluation of the POTW's current I/I status, utilizing data provided by the effluent flow meter and including a designated number of rain events that meet          specific parameters, such as amount and duration of rain. The plan shall also include a schedule, including dates, for addressing and resolving any identified I/I problems. Respondent shall submit written verification of completion of identified steps within fifteen (15) days of completion.

3.     Within thirty days (30) days of the Effective Date the Respondent shall correct all areas identified as "unsatisfactory " on the September 30, 1999 inspection report. Respondent shall follow the procedures as specified in the Compliance Plan submitted and approved for resolution of Cause B-1787 to maintain the POTW in such a manner that future inspections will not identify areas as "unsatisfactory." Respondent shall also review the O & M Manual to assure that it has a procedure in place to assure that all sampling and testing as required by the NPDES permit will be done, particularly in times when the certified operator may be unable to do so.

4.     In consideration of the fact that a number of the violations cited in the Notice of Violation resulted from the work of an operator no longer employed by the Town of Whitestown and also that the Town is taking considerable steps to address the problems, no civil penalty is being assessed at this time.

5.     In the event the following terms and conditions are violated, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amounts:

         Violation                        Penalty

    Paragraph 2     Failure to submit plan            $500 per week late

    Paragraph 2    Failure to implement identified
             corrective actions                $1,000 per week late
    
    Paragraph 2    Failure to provide written notification    $500 per week late

    Paragraph 3    "Unsatisfactory" evaluation of Operation &
            Maintenance, Laboratory, Self-Monitoring        $1,000 per


            Program, or Records/Reports on inspection report     documented area
                        
6.     Stipulated penalties shall be due and payable within thirty (30) days after Respondent receives written notice that the Complainant has determined a stipulated penalty is due. Assessment and payment of stipulated penalties shall not preclude the Complainant from seeking any additional relief against the Respondent for violation of the Agreed Order. In lieu of any of the stipulated penalties given above, the Complainant may seek any other remedies or sanctions available by virtue of Respondent's violation of this Agreed Order, or Indiana law, including but not limited to civil penalties pursuant to IC 13-30-4.

7.     Stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the Cause Number of this action and shall be mailed to:

                Cashier
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 7060
                Indianapolis, IN 46207-7060

8.     This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, and assigns. The Respondent's signatories to this Agreed Order certify that they are fully authorized to execute this document and legally bind the parties they represent. No change in ownership, corporate, or partnership status of the Respondent shall in any way alter its status or responsibilities under this Agreed Order.

9.     In the event that any terms of the 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 the Agreed Order did not contain the invalid terms.

10.     The Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred. Respondent shall ensure that all contractors, firms and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

11.     This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order.


TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By:     _________________________        By:     _________________________
    Mark Stanifer, Section Chief
    Office of Enforcement            Printed: ________________________

                            Title:     ________________________

Date: _______________                Date:     _______________

COUNSEL FOR COMPLAINANT:        COUNSEL FOR RESPONDENT:
Department of Environmental Management

By: _________________________            By: ________________________
Office of Legal Counsel                
Department of Environmental Management

Date: _______________                Date: _______________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS ___________ DAY OF ______________________, 1999.

                            FOR THE COMMISSIONER:

                            Signed May 1, 2000
                            Felicia A. Robinson
                            Assistant Commissioner of Enforcement

Converted by Andrew Scriven