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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,            )
                            )    CAUSE NO. UST-22
            v.                )
    )
JAGPAL SINGH OTAL d/b/a

    )
31 CAR AND TRUCK PLAZA f/k/a    )
JOHNSON'S GARAGE     )
AND    )
MG PETROLEUM SERVICES, LLC    )
                            )
            Respondents.            )

AGREED ORDER

    The Complainant and the 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 IC 13-30-3-3, entry into this Agreed Order does not constitute an admission of any violation contained herein. This Agreed Order is entered into solely for the purpose of resolving this disputed matter.

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.    Respondents are Jagpal Singh Otal d/b/a 31 Car and Truck Plaza f/k/a Johnson's Garage who owned underground storage tanks (USTs) located at 31 Car and Truck Plaza f/k/a Johnson's Garage, IDEM Facility ID #4729, 21575 US 31 North, Cicero, Hamilton County, Indiana (Site), and MG Petroleum Services, LLC the primary contractor for UST work performed at the Site and per the Indiana Department of Environmental Management's determination an operator of USTs at the Site (Respondents).

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

4.    A petroleum release at the Site was reported by American Environmental Abatement Company, Inc. on March 18, 1998, and IDEM Incident Number 9803540 was issued on March 24, 1998.

5.    Based on an investigation of the Site by designated representatives of IDEM between May 7, 1999, and June 17, 1999, IDEM found non-compliance with the following environmental rules and statutes :

    A.    Pursuant to 329 IAC 9-4-3(2), the owner and operator shall measure for the presence of a release where contamination is most likely to be present at the underground storage tank site.

    B.     Pursuant to 329 IAC 9-5-2(2), the owner and operator shall take immediate action to prevent further release of regulated substance into the environment.

    C.    Pursuant to 329 IAC 9-5-3.1, the owner and operator is required to remove free product to the maximum extent practicable when it is encountered, and they are required to submit a free product removal report within forty-five (45) days after confirming the release.

    D.    Pursuant to 329 IAC 9-5-4.1(a)(4), the owner and operator shall remedy hazards posed by contaminated soils that are excavated or exposed and shall do so in compliance with applicable state and local requirements.

    E.    Pursuant to 329 IAC 9-5-4.1(a)(5), the owner and operator shall measure for the presence of a release where contamination is most likely to be present.
                            
    F.    Pursuant to 329 IAC 9-5-4.1(a)(6), the owner and operator shall investigate to determine the presence of free product, and begin free product removal as soon as practicable.
                        


    G.    Pursuant to 329 IAC 9-5-5.1(a) and (b), the owner and operator shall assemble information (Initial Site Characterization/ISC) about the site and the nature of the release, and submit the ISC to IDEM within forty-five (45) days of release confirmation.

    H.    Pursuant to 329 IAC 9-6-2(a)(3), if any water is encountered in the UST excavation during closure one water sample must be taken and analyzed.

    I.    Pursuant to 329 IAC 10-4-2, no person shall cause or allow solid waste to be disposed of in a manner which creates a threat to human health and the environment, including the creating of a fire hazard, vector attractant, air or water pollution, or other contamination.                 
                        
    J.    Pursuant to 329 IAC 10-4-3, prohibits open dumping and open dumps.

    K.    Pursuant to 329 IAC 10-8.1-5(a), special waste may only be disposed of in a solid waste land disposal facility that is approved to accept the special waste.

    L.    Pursuant to IC 13-30-2-1(1), no person may discharge, or threaten to discharge any contaminant or waste into the environment in a form that causes pollution that violates a rule adopted by one (1) of the boards.

    M.    Pursuant to IC 13-30-2-1(3), no person may deposit any contaminants upon the land in violation of a rule adopted by one (1) of the boards.

    N.    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 unless done in manner acceptable to the solid waste management board.

    O.    Pursuant to IC 13-30-2-1(5), no person may cause or allow the open dumping of solid waste in violation of rules adopted by the solid waste management board.

6.    On or about June 25, 1999, the Respondents submitted an initial site characterization (ISC) to IDEM.

7.    On or about July 14, 1999, the Respondents submitted a further site investigation (FSI) and corrective action plan (CAP) to IDEM.                


8.    On or about August 10, 1999, IDEM issued a response to the Respondents' ISC, FSI and CAP mentioned above. IDEM requested additional information to be submitted.

9.    On or about August 25, 1999, the Respondents submitted a Summary Report and Additional Site Activities Report to IDEM.

10.    On or about September 29, 1999, IDEM issued a response to the Respondents' Additional Site Activities Report, ISC and FSI. IDEM requested additional information to be submitted.

11.    On or about January 11, 2000, the Respondents submitted a Summary Report and Proposed Corrective Action Plan in response to IDEM's request pursuant to Finding of Facts paragraph 10 above. The supplemental response includes information regarding petroleum contaminated soils located at: (1) Beaver Materials, 16101 River Avenue, Noblesville, Hamilton County, Indiana ; and (2) Warren Auto, 17625 River Avenue, Noblesville, Hamilton County, Indiana.

12.    The Respondents waive their right to the issuance of a Notice Of Violation and to the settlement period of sixty (60) days as provided for by IC 13-30-3-3.

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

2.    Respondents shall maintain compliance with all applicable laws and rules from the date of issuance of this Agreed Order by the Complainant.

3.    If IDEM determines from the information that the Respondents submitted per Finding of Fact paragraph 11 above, that the extent of contamination has not been adequately defined, then the Respondents shall submit a Further Site Investigation Plan (FSIP) within thirty (30) days of receiving written notice from IDEM. The FSIP must be approved by IDEM prior to the implementation of the FSIP. The Respondents shall implement the FSIP within ten (10) days of IDEM approval of the FSIP. The approved FSIP shall become an enforceable part of this Agreed Order. If necessary, this condition shall be repeated until the extent of contamination is adequately defined.


4.    The Corrective Action Plan (CAP) information submitted by the Respondents as part of the information submitted per Finding of Fact paragraph 11, shall be subject to review, modification, and approval by IDEM. The CAP must address remediation at the Site, Beaver Materials and Warren Auto. Upon notification of deficiencies in the CAP, the Respondents shall have twenty (20) days to revise and resubmit a CAP to IDEM which addresses the deficiencies. Subject to any appeal rights under IC 4-21.5, the Respondents hereby agree to implement the approved CAP within fifteen (15) days of receipt of IDEM's approval of the CAP. The Respondents shall complete all of the requirements in the approved CAP. The approved CAP, including a remediation activity schedule, shall be incorporated into this Agreed Order and shall be deemed an enforceable part thereof.

5.    The Respondents shall apply for and obtain all necessary permits and property access agreements pertaining to investigation and remediation of on-site and/or off-site contamination, if necessary, prior to any investigation or remediation activities being performed.

6.    The Respondents shall permit an agent of IDEM to view and inspect the activities performed pursuant to an FSI or the approved CAP. In order to facilitate such an inspection, the Respondents shall notify IDEM at least twenty-four (24) hours prior to any scheduled activities.    
                    
7.    All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:
                Kris Buckles, LUST Project Manager
                Office of Environmental Response
                Indiana Department of Environmental Management
                100 North Senate Avenue
                P.O. Box 6015
                Indianapolis, Indiana 46206-6015

    All communications regarding this Agreed Order to the Respondents, unless notified otherwise in writing, shall be sent to:

                Mr. Scott Green
                MG Petrolem Services, LLC
                30 West 1st. Street S.W.
                Carmel, Indiana 46032.
                
                Mr. Jagpal Singh Otal
                Johnson's Garage
                21575 US 31 N.
                Cicero, Indiana 46034            


8.    Respondents are assessed a civil penalty of Twenty-Four Thousand Seven Hundred Three Dollars ($24,703). Seven Thousand Nine Hundred Five Dollars ($7,905) shall be due and payable to the Environmental Management Special Fund in four (4) equal quarterly installments of $1,976.25, the first of which will be due on June 30, 2000, and the remainder of which are due on September 30, 2000, December 30, 2000 and March 31, 2001. Sixteen Thousand Seven Hundred Ninety-Eight Dollars ($16, 798) shall be due and payable to the Underground Petroleum Storage Tank Trust Fund in four (4) equal quarterly installments of $4,199.50, the first of which will be due on June 30, 2000, and the remainder of which are due on September 30, 2000, December 30, 2000 and March 31, 2001.

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

        Violation            Penalty
        
Order Condition 3        $500 per day an FSIP is late
        Order Condition 3     $500    per day an approved FSIP is not implemented
        Order Condition 4        $500     per day a revised CAP, if necessary, is late
        Order Condition 4        $1,500 per business day for failure to perform     work pursuant to the schedule in the     approved CAP, unless the reason for non-     compliance with the approved CAP is     beyond the control of the Respondents
                            (i.e. Respondents inability to obtain off-site access despite good faith efforts)              
10.    Stipulated penalties shall be due and payable within thirty (30) days after the Respondents receive 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 Respondents for violation of this Agreed Order. In lieu of assessment of any of the stipulated penalty given above, the Complainant may seek any other remedies or sanctions available by virtue of Respondents' violation of this Agreed Order, or Indiana Law, including but not limited to civil penalties pursuant to IC 13-30-4.



11.    Civil and stipulated penalties are payable by check to the either the Environmental Management Special Fund or the Underground Petroleum Storage Tank Trust Fund, as described in Order Condition Number 9 above. Checks shall include the Cause Number of this action and shall be mailed to:
    
        Cashier
        IDEM
        100 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46207-7060

12.    In the event that the civil penalty is not paid pursuant to Order Condition Number 8 above, the Respondents shall pay interest on the unpaid balance at the rate established by IC 24-4.6-1-101.

13.    This Agreed Order shall apply to and be binding upon the Respondents, their officers, directors, principals, agents, successors, subsidiaries, and assigns. The Respondents' 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 Respondents shall in any way alter its status or responsibilities under this Agreed Order.

14.    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.

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

16.    This Agreed Order shall remain in effect until the Respondents have complied with all terms and conditions of this Agreed Order.


TECHNICAL RECOMMENDATION:        RESPONDENTS:
Department of Environmental Management

By:___________________________        By:____________________________
Paul Higginbotham, Chief             Jagpal Singh Otal
Solid Waste - UST Section             31 Car & Truck Plaza             
Office of Enforcement
                            
Date:_________________________        Date:__________________________

                            By:_____________________________
                             K. Scott Green, Operating Manager
                             MG Petroleum Services, LLC

                            Date:____________________________

COUNSEL FOR COMPLAINANT:        COUNSEL FOR RESPONDENT:
Department of Environmental Management    BOSE McKINNEY & EVANS LLP

By:___________________________        By:____________________________
Office of Legal Counsel                 Kathleen G. Lucas
Department of Environmental Management

Date:__________________________        Date:___________________________

                            By:_____________________________
                             Melinda Shapiro

                            Date:____________________________

                                    

            

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS __________ DAY OF __________________, 2000.

                            For the Commissioner:
                                
                            
                             Signed 2/8/00                                              Felicia A. Robinson
                            Assistant Commissioner
                            Office of Enforcement

                        

Converted by Andrew Scriven