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

COMMISSIONER OF THE DEPARTMENT    )
OF ENVIRONMENTAL MANAGEMENT,    )
                            )
                Complainant,        )            
                            )CAUSE NO. H-13524 or 1997-8236-H
            v.                )
                            )
CITIZENS GAS & COKE UTILITY,        )
                            )
                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. Pursuant to IC 13-30-3-3, entry into this agreement does not constitute an admission of any violation contained herein.

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 Citizens Gas & Coke Utility (hereinafter referred to as "Respondent"), which is a company doing business at 2950 Prospect Street, located in Indianapolis, Indiana. The U.S. EPA I.D. number of the facility is IND 006421549.

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

    

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

        Mr. Martin C. Dusel            Mr. John E. Havard
        Executive Vice President        Superintendent of Env. Services
        Citizens Gas & Coke Utility        Citizens Gas & Coke Utility
        2020 North Meridian Street        2950 Prospect Street
        Indianapolis, IN 46202        Indianapolis, IN 46203

    5.    Respondent manufactures metallurgical-grade coke for use at foundries and steel mills. In addition, Respondent mixes filtered coke oven gas with natural gas for sale to the general public. Hazardous wastes generated from these activities include hazardous waste codes D002, D003, D018, D026, D038, K141 and K142.

          6.    The IDEM contends that the following violations were in existence or observed by staff of the Office of Land Quality (OLQ) of IDEM during inspections of the facility conducted on March 21, 25, 26 and 31, 1997. In addition to these contentions of IDEM, the Findings of Fact contained herein include information submitted to IDEM by Respondent subsequent to the inspections.

              Pursuant to IC 13-30-2-1, no person may discharge, emit, cause, allow, or threaten to discharge, emit, cause, or allow any contaminant or waste, including any noxious odor, either alone or in combination with contaminants from other sources into the environment in any form that causes or would cause pollution in violation of 40 CFR 265.31. Based on information gathered by the IDEM, Respondent allowed the release of contaminants into the environment. These releases include, but are not limited to, the following:

                 1.     Release of soil around the bermed concrete pad that contains the fuel oil unloading station and the soil on the pad itself appeared to be contaminated with fuel oil;

            2.     Soil in front of the concrete containment for the E&H decanters was contaminated with coal tar sludge (hazardous waste code K087); and

                 3.     The wastes stored on the recycling center oxide pad were not being managed to prevent a release to the environment.

              Pursuant to IC 13-30-2-1(10) and 40 CFR 270.1(c), a person may not commence or engage in the operation of a hazardous waste facility without having first obtained a permit from the IDEM. Based on information

            gathered by the IDEM, Respondent operated as a storage facility by storing hazardous waste in the following locations:

            1.    Several unpermitted waste piles were being managed on-site on a large bermed concrete pad known as the recycling center oxide pad and;
            
                 2.    Two (2) twenty cubic yard roll-offs of debris (hazardous waste codes K141, K142, D018 and D026) were stored (also on the oxide pad) for greater than ninety (90) days. On September 15, 1995, a roll-off of debris was returned to Respondent's facility after it had been rejected from Chemical Waste Management of Indiana (CWM) on hazardous waste manifest number INA 1045976. This roll-off was shipped to Michigan Disposal, Inc. (MDI), utilizing hazardous waste manifest number MI 4676155, on May 1, 1996. On November 14, 1995, a second roll-off of debris was returned to the facility after it had been rejected from CWM on hazardous waste manifest number INA 077627. This roll-off was shipped to MDI, utilizing hazardous waste manifest number MI 3638808, on May 1, 1996.

              Pursuant to 329 IAC 3.1-1-10 and 40 CFR 264.11, every hazardous waste owner or operator of a hazardous waste storage facility shall notify the Commissioner of such activities on forms provided by the Commissioner.
            Based on information gathered by the IDEM, Respondent had not notified the Commissioner as a hazardous waste storage facility.
        
              Pursuant to 40 CFR Part 264, owners or operators of hazardous waste storage facilities must comply with all applicable requirements of the Part. Based on information gathered by the IDEM, Respondent operated a hazardous waste storage facility without complying with any of the requirements contained in 40 CFR Part 264.    
        
             e.     Pursuant to 40 CFR Part 264, owners and operators of facilities that store hazardous waste in piles (as defined in 40 CFR 260.10) must comply with the requirements of Subpart L. Based on information gathered by the IDEM, Respondent stored hazardous waste in piles on the oxide pad without complying with the requirements of Subpart L of 40 CFR Part 264. Specifically, hazardous wastes were stored in piles on the oxide pad without complying with the following requirements of Subpart L:

            1. Several piles of hazardous waste were piled higher than the berm that surrounds the oxide pad allowing for possible wind dispersion;


            2. The oxide pad did not have an impermeable coating; and

            3. The run-off management system for the oxide pad was not able to collect and control at least the water volume resulting from a 24-hour, 25-year storm.

        f.    Pursuant to 40 CFR 262.11 and 40 CFR 268.7, a person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste. If a generator's waste is determined to be hazardous, the generator must determine if the waste is restricted from land disposal under 40 CFR Part 268. Based on information gathered by the IDEM, Respondent failed to perform a hazardous waste and land disposal determination for a pile of excavated soil located east of the power house.
            Based upon sampling conducted by Respondent on April 1, 1997, the pile of soil was determined to be nonhazardous.

        g.    Pursuant to 329 IAC 3.1-7-8 and 329 IAC 3.1-7-11, generators of hazardous waste must utilize and properly complete the Uniform Hazardous Waste Manifest. Based on information gathered by the IDEM, Respondent failed to properly complete hazardous waste manifest number MI4676384. Specifically, box 11a. was marked incorrectly on all three copies of the manifest that were available for review. Box I. was marked "K141" on all three copies except for the copy signed by the TSD facility which corrected the box to reflect a hazardous waste code of "D018."
            Box 11a. was not changed to reflect the correct hazardous waste code. Information submitted by Respondent subsequent to the inspections indicates that this violation has now been corrected.

             h.    Pursuant to 40 CFR 262.34(a)(2&3) a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit provided that the date upon which each period of accumulation begins is clearly marked and visible for inspection on each container and that each container, while being accumulated on-site, is labeled or marked clearly with the words "Hazardous Waste." Based on information gathered by the IDEM, Respondent failed to label/mark and date a one cubic yard container (K141 and K142) located on the oxide pad with the start date of accumulation or with the words "hazardous waste."

             Pursuant to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.173(a), a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit provided that the containers holding hazardous waste are kept closed during storage, except when it is necessary to add or remove waste. Based on information gathered by the IDEM, Respondent

failed to store closed a one cubic yard container of debris (K141/K142)
            located on the oxide pad.

        j.    Pursuant to 40 CFR 262.43(a)(4) referencing 40 CFR 265.35, a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit provided that adequate aisle space is maintained between containers to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment. Based on information gathered by the IDEM, Respondent
            failed to provide adequate aisle space between roll-offs of hazardous waste located on the oxide pad. In most instances, small piles of hazardous waste surrounded the roll-offs or occupied the space between roll-offs, making the roll-offs inaccessible in case of emergency.

        k.     Pursuant to 329 IAC 3.1-7-14, a generator who ships his hazardous waste off-site to a treatment, storage, or disposal facility within the United States must prepare and submit biennial reports to the IDEM. Based on information gathered by the IDEM, Respondent has operated as a large quantity generator but has failed to prepare and submit biennial reports to the IDEM since 1987.
            Since the time if the of the inspection, Respondent has submitted the required biennial reports and they have been deemed adequate.
    
        l.    Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.16, a generator must provide facility personnel involved in hazardous waste management a program of classroom instruction or on-the-job training that teaches them to perform their hazardous waste duties in a way that ensures the facility's compliance with all requirements of 40 CFR 265.16, and must provide an annual review of that training. Based on information gathered by the IDEM, Respondent failed to provide several employees with hazardous waste training within one year of their previous training date. In addition, Mr. Tracy Frye of Kipin Industries, Inc., Respondent's subcontractor, had also not received his annual training review.

     7.    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 his delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the effective date.


    2.    Within thirty (30) days of the Effective Date of the Order, Respondent shall submit to the IDEM for approval, a closure plan for the oxide pad where the waste piles and the two (2) twenty cubic yard roll-offs of debris were stored. This plan shall be written in accordance with the provisions of 40 CFR Part 264, Subpart G.

    3.    Upon notice of approval by IDEM of the closure plan, Respondent shall implement the approved plan in accordance with the time frames contained therein.

    4.    Within thirty (30) days of the Effective Date of the Order, Respondent shall provide financial assurance for closure, pursuant to 329 IAC 3.1-15-4.

    5.    Within thirty (30) days of the Effective Date of the Order, Respondent shall excavate all oil contaminated soils near the fuel oil loading station to a depth six (6) inches below visible signs of contamination. Submit documentation of proper disposal to IDEM for review.

    6.    Within thirty (30) days of the Effective Date of the Order, Respondent shall submit for IDEM review the verification sampling which was taken following excavation and disposal of soils contaminated with coal tar sludge by the E&H decanters. Also, Respondent shall submit documentation of proper disposal.

    7.    In the future, Respondent shall ensure that all hazardous waste manifests are properly completed.

    8.    In the future, Respondent shall ensure that all containers holding hazardous waste in the less than 90-day accumulations area are clearly marked with the date upon which each period of accumulation begins and are marked with the words "Hazardous Waste."

    9.    In the future, Respondent shall ensure that containers holding hazardous waste are kept closed during storage, except when it is necessary to add or remove waste.

    10.    In the future, Respondent shall provide adequate aisle space to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation in the event of an emergency, unless aisle space is not needed for any of these purposes.

    11.    In the future, Respondent shall ensure that all facility personnel involved in hazardous waste management receive an annual review of the initial hazardous waste training. Submit to this office documentation which indicates that this training has been provided to applicable personnel.

    12.    All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:

        Richard R. Milton
        Office of Enforcement
        Hazardous Waste Section
        Indiana Department of
        Environmental Management
        P.O. Box 6015
        Indianapolis, Indiana 46206-6015

    13.    Respondent is assessed a civil penalty of $71,250. Of this amount, $14,250 shall be due and payable to the Environmental Management Special Fund within thirty (30) days of the Effective Date of this Agreed Order. In lieu of payment of the remaining Civil Penalty ($57,000), the Respondent shall perform and complete the Supplemental Environmental Project (SEP), as described in Exhibit A. The exhibit is hereby incorporated by reference and made part of this Agreed Order. Respondent shall also be required to obtain all necessary permits prior to implementation. The total funds expended on the SEP shall be a minimum of $114,000. Documentation of the final costs shall be submitted upon completion. If the SEP is not completed in accordance with this agreement and within the specified time period, the Respondent agrees to pay the remaining Civil Penalty, plus interest established by IC 24-4.6-1-101, to the Environmental Management Special Fund. Payment of the remaining amount of the Civil Penalty shall be submitted within fifteen (15) days from receipt of a notice to pay from IDEM. Interest on the remaining Civil Penalty shall be paid from the Effective Date of this Agreed Order.

    14.    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
            Order Conditions            
            #2 through #6                $1,000 per day

    15.    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 assessment of the
        stipulated penalty 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.


     16.    Civil and stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the cause number of this action (H-13524) and shall be mailed to:

        Cashier
        IDEM
        100 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46206-7060

    17.    In the event that the civil penalty required by paragraph 13 is not paid within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall pay interest on the unpaid balance at the rate established by IC 24-4.6-1-101. The interest shall continue to accrue until the civil penalty is paid in full.

    18.    This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, and assigns. The 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.

    19.    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 the Agreed Order did not contain the invalid terms.
    
    20.    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 by contract require that all contractors, firms, and other persons acting for it comply with the terms of this Agreed Order.

    21.    This Agreed Order shall remain in effect until IDEM issues a Resolution of Cause letter to Respondent.


TECHNICAL RECOMMENDATIONS:            RESPONDENT:
Department of Environmental Management            

By:    ________________________            By:    ________________________
    Nancy L. Johnston, Chief
    Hazardous Waste Section                Title:    ________________________
    Office of Enforcement

Date:    ________________________            Date:    ________________________

LEGAL RECOMMENDATION:                COUNSEL FOR RESPONDENT:
Department of Environmental Management

By:    ________________________            By:    ________________________
    Scott R. Storms    
    Office of Legal Counsel

Date:    ________________________            Date:    ________________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

THIS _14______ DAY OF __APRIL__________ 2000.

                                For the Commissioner:

                                 signed 4/14/00
                                Felicia A. Robinson
                                Assistant Commissioner
                                Office of Enforcement

Converted by Andrew Scriven