Link to original WordPerfect Document here


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. 1999-8418-H or H-13789
                            )
ROCKWELL AUTOMATION,            )
                            )
        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 terms of this Agreed Order 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 Rockwell Automation (hereinafter referred to as "Respondent"), a company doing business at 500 South Union Street, Mishawaka, Indiana.

    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, IDEM issued a Notice of Violation via Certified Mail to:

            Mr. Eric Swift

            Rockwell Automation
            500 South Union Street
            Mishawaka, IN 46544

    5.    Respondent is a gray iron and ductile iron foundry that produces pulley assemblies, valve bodies, pump housings, and motor housings. Hazardous waste is generated from core and mold making, melting, pouring, shotblasting, grinding, machining, and painting. Respondent notified as a Small Quantity Generator (SQG) and operates with the U.S. EPA identification number IND 042 327 213.

    6.    Based upon an investigation of the facility on June 9, 1999, by the Office of Solid and Hazardous Waste Management (hereinafter referred to as "OSHWM") of IDEM, IDEM contends that the following violations were in existence or observed at the time of the inspection:

        a.    Pursuant to 40 CFR 262.11 and 40 CFR 268.7(a), a generator of a solid waste must determine if that waste is hazardous and if the waste has to be treated before being land disposed. Based upon an investigation by IDEM, Respondent failed to make a proper hazardous waste determination on rags contaminated with paint thinner from cleanup at the Foundry Paint Booth.

        b.    Pursuant to 40 CFR 262.12(c), a generator must not offer hazardous waste to transporters or to treatment, storage, or disposal facilities that have not received an EPA identification number. Based upon an investigation by IDEM, Respondent offered hazardous waste to a transporter who had not received an EPA ID number and to a treatment, storage, and disposal facility (TSD) that is not permitted to receive hazardous waste. Specifically, Respondent offered rags contaminated with paint thinner (F005) to Southeast Berrien County Landfill for transport and disposal. Southeast Berrien County Landfill is not permitted to transport and dispose of hazardous waste.

        c.    Pursuant to 329 IAC 3.1-7-3(a), 329 IAC 3.1-7-4 and IC 13-30-2-1(12), a generator who transports or offers for transportation hazardous waste for off-site treatment, storage, or disposal must prepare a manifest. Based upon an investigation by IDEM, Respondent offered rags contaminated with paint thinner (F005) for off-site transport and disposal to Southeast Berrien County Landfill without using the Indiana hazardous waste manifest form adopted by the board.

        d.    Pursuant to 40 CFR 262.34(d)(4) referencing 40 CFR 262.34(a)(2), a generator may accumulate hazardous waste on-site for 180 days or less without a permit, provided that the date when the accumulation begins is clearly marked and visible for inspection on each container. Based upon an investigation by IDEM, Respondent failed to label the trash hopper which held rags contaminated with thinner (F005) located next to the Foundry Spray Booth with the start of accumulation date.

        e.    Pursuant to 40 CFR 262.34(d)(4) referencing 40 CFR 262.34(a)(3), a generator may accumulate hazardous waste on-site for 180 days or less without a permit, provided that containers are marked with the words "Hazardous Waste." Based upon an investigation by IDEM, Respondent failed to label the trash hopper which held rags contaminated with thinner (F005) located next to the Foundry Spray Booth with the words "Hazardous Waste."

        f.    Pursuant to 40 CFR 262.34(d) referencing 40 CFR 265.173(a), a container holding hazardous waste must always be closed during storage, unless necessary to add or remove waste. Based upon an investigation by IDEM, Respondent failed to store closed the trash hopper which held rags contaminated with paint thinner (F005) located next to the Foundry Spray Booth.

        g.    Pursuant to 40 CFR 268.7(a)(2), if a generator determines that a waste does not meet treatment standards, the generator must submit to the treatment, storage, or disposal facility a one-time notice and certification. Based upon an investigation by IDEM, Respondent offered rags contaminated with paint thinner (F005) to the Southeast Berrien County Landfill for disposal without providing the initial Land Disposal Restriction (LDR) notification.

        h.    Pursuant to 40 CFR 262.34(d)(5)(ii), a generator must implement certain measures to address an emergency situation. Based upon an investigation by IDEM, Respondent failed to implement the following:

            1)    post the required emergency information next to the telephones; and,

            2)    post the location of fire extinguishers and spill control material.

        i.    Pursuant to IC 13-30-2-1(4), no person shall deposit or cause or allow the deposit of any contaminants or solid waste upon the land, except through the use of sanitary landfills, incineration, composting, garbage grinding, or another method acceptable to the solid waste management board. Based upon an investigation by IDEM, Respondent allowed the following releases:

            1)    a deposit of non-hazardous foundry sand south of the concrete pad near the Sand Building which contaminated approximately 3,000 ft2 of soil and extended beyond the pad; and,

            2)    the release of premix (bentonite clay) from the fill pipe located on the east side of the facility.

        j.    Pursuant to 329 IAC 13-4-3(d), generators must label all used oil containers and aboveground tanks with the words "Used Oil." Based upon an investigation by IDEM, Respondent failed to label four (4) 55-gallon and five (5) 5-gallon containers of used oil located in the Hazardous Waste Storage Area with the words "Used Oil."

    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 her 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 this Order, Respondent shall perform a proper hazardous waste determination on rags contaminated with paint thinner (F005) from cleanup at the Foundry Paint Booth pursuant to 40 CFR 262.11 and 40 CFR 268.7(a). Respondent shall submit documentation of compliance to IDEM.

    3.    In the future, Respondent shall not offer its hazardous waste to a transporter and/or a treatment, storage, and disposal facility (TSD) that is not permitted to receive hazardous waste pursuant to 40 CFR 262.12(c).

    4.    In the future, Respondent shall utilize the Indiana hazardous waste manifest form adopted by the board at any time hazardous waste is transported or offered for transportation for off-site treatment, storage or disposal pursuant to 329 IAC 3.1- 7-3(a), 329 IAC 3.1-7-4, and IC 13-30-2-1(12).

    5.    Within thirty (30) days of the effective date of this Order, Respondent shall label the trash hopper holding rags contaminated with paint thinner (F005) located next to the Foundry Spray Booth with the start of accumulation date pursuant to 40 CFR 262.34(d)(4) referencing 40 CFR 262.34(a)(2). Respondent shall submit documentation of compliance to IDEM.

    6.    Within thirty (30) days of the effective date of this Order, Respondent shall label the trash hopper holding rags contaminated with paint thinner (F005) located next to the Foundry Spray Booth with the words "Hazardous Waste" pursuant to 40

CFR 262.34(d)(4) referencing 40 CFR 262.34(a)(3). Respondent shall submit documentation of compliance to IDEM.

    7.    Upon the effective date of this Order, Respondent shall store closed the trash hopper holding rags contaminated with paint thinner (F005) located next to the Foundry Spray Booth, except when it is necessary to add or remove waste pursuant to 40 CFR 262.34(d) referencing 40 CFR 265.173(a).

    8.    In the future, Respondent shall submit to a treatment, storage, or disposal facility the initial Land Disposal Restriction notification where it is determined that a waste does not meet treatment standards pursuant to 40 CFR 268.7(a)(2).

    9.    Within thirty (30) days of the effective date of this Order, Respondent shall post the required emergency information next to the telephones and post the location of fire extinguishers and spill control material pursuant to 40 CFR 262.34(d)(5)(ii). Respondent shall submit documentation of compliance to IDEM.

    10.    Within thirty (30) days of the effective date of this Order, Respondent shall clean up and properly containerize and dispose all visibly impacted soils caused by the release of foundry sand south of the concrete pad near the Sand Building and the release of non-hazardous premix (bentonite clay) from the fill pipe located on the east side of the building. Respondent shall submit documentation of compliance to IDEM.

    11.    Within thirty (30) days of the effective date of this Order, Respondent shall label all used oil containers with the words "Used Oil" pursuant to 329 IAC 13-4-3(d). Respondent shall submit documentation of compliance to IDEM.

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

        Ms. Jennifer Reno
        Office of Enforcement
        Hazardous Waste Section
        Indiana Department of Environmental Management
        100 N. Senate Avenue
        P. O. Box 6015
        Indianapolis, IN 46206-6015

    13.    All submittals required by this Agreed Order shall contain the following certification:

        "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,

or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."

    14.    Respondent is assessed a civil penalty of Twenty-Seven Thousand Eight Hundred Dollars ($27,800). Said penalty amount shall be due and payable to the Environmental Management Special Fund within thirty (30) days of the Effective Date of this Agreed Order.

    15.    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

        Failure to comply with the requirements         $1,000 per day per violation
        of Order Nos. 2, 5, 6, 9, 10, and 11.

    16.    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 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 13-30-4-1.

    17.    Civil and 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
            IDEM
            100 N. Senate Avenue
            P. O. Box 7060
            Indianapolis, IN 46207-7060

    18.    In the event that the civil penalty required by paragraph 14 is not paid within specified time frames 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.

    19.    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.

    20.    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.

    21.    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.

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

TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

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

Date: ________________________            Date: ________________________

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

By: _________________________            By: ________________________
Office of Legal Counsel

Date: _______________________            Date: ______________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS _____ DAY OF ____________________, 2000.

                            For the Commissioner:


                            ___Signed on 3/30/00____
                            Felicia A. Robinson
                            Assistant Commissioner
                            Office of Enforcement

Converted by Andrew Scriven