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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,            )
                            )    CASE NO. 1999-8682-S
            v.                )
    )
CROWE WRECKING COMPANY, INC.,    )
                            )
            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 Crowe Wrecking Company, Inc. (hereinafter referred to as "Respondent"), who is a company doing business at 2400 North Grove Street, Evansville, Vanderburgh County, Indiana (hereinafter referred to as the "Site").

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 on February 21, 2000, to:
        Karl Crowe, President
        Crowe Wrecking Co., Inc.
        2400 North Grove Street
        Evansville, IN 47710

5.     Designated representatives of IDEM conducted inspections at the facility on July 19, 1999, August 31, 1999, October 18, 1999, November 8, 1999, December 20, 1999, and January 4, 2000. During these inspections the following violations were observed:
         A.    Pursuant to 329 IAC 10-37-3, owners and operators of a construction/demolition site shall apply no less than two (2) feet of final cover over any area in the fill within one hundred eighty (180) days when solid waste has not been disposed of for one (1) year, or any area of the construction/demolition site that has been filled to its approved elevation. The construction/demolition site must have a maximum projected erosion rate of five (5) tons per acre per year, and the final cover must have a slope of not less than two percent (2%) and not greater than thirty-three percent (33%). This violation is based on the fact that during the above noted inspections, final cover has not been adequately applied at the Site within one hundred eighty (180) days of no additional disposal for one (1) year.

    B.    Pursuant to 329 IAC 10-36-14(a) and (b) and (c), cover material must be continuously maintained, including the application and compaction of additional cover as needed to maintain required depth. A grass or ground cover crop must be established and maintained continuously as soon as weather permits and seasonal conditions are suitable. The site must be graded to promote surface water drainage and to prevent the ponding of water on previously filled areas. This violation is based on the fact that during the above noted inspections the cover material has not been adequately maintained as to required depth, vegetation cover and proper grading.

    C.    Pursuant to 329 IAC 10-37-1, owners or operators of a construction/demolition site shall close the facilities in a manner that minimizes the need for further maintenance, controls post-closure escape of waste, waste constituents, leachate, contaminated precipitation, or waste decomposition products to the ground or surface waters or atmosphere and is in compliance with applicable closure provisions and conditions imposed in the facility permit. This violation is based on the fact that during the above noted inspections, the closure standards have not been met for the closure requirements listed above.

    D.    Pursuant to 329 IAC 10-36-15(a) and (b), any leachate on the surface of a construction/demolition site must be immediately managed or controlled to

prevent off-site migration. Any surface movement of leachate past a point of fifty (50) feet outside of the solid waste boundary is prohibited except as specified in the facility permit. This violation is based on the fact that during the above noted inspections, leachate migrated off-site, past a point of fifty (50) feet outside the solid waste boundary.
6.    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.    Respondent shall follow final closure activities per the approved submitted plan prepared by American Enviro-Services and have final cover and vegetation placed over the entire landfill by June 20, 2000.

3.    Respondent shall properly collect and manage leachate generated at the Site as needed.

4.    All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:
    Jennifer Fajt, Enforcement Case Manager
    Office of Enforcement
    Indiana Department of Environmental Management
    100 North Senate Avenue
    P.O. Box 6015
    Indianapolis, Indiana 46206-6015

5.    Respondent is assessed a civil penalty of $11,718.75, to be paid in six (6) quarterly payments. The first payment of $1,953.13 shall be due on or before June 30, 2000. The second payment of $1,953.12 shall be due on or before September 29, 2000. The third payment of $1,953.13 shall be due on or before December 29, 2000. The fourth payment of $1,953.12 shall be due on or before March 30, 2001. The fifth payment of $1,953.13 shall be due on or before June 29, 2001. The sixth and final payment of $1,953.12 shall be due on or before September 28, 2001. Said penalty amounts shall be payable to the Environmental Management Special Fund.

6.    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 Condition #2        $1,000 per week
        Order Condition #3        $500 per event

7.    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 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.

8.    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 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46207-7060

9.    In the event that the civil penalty required by paragraph 5 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.

10.    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.

11.    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.

12.    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.

13.    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:____________________________
Paul Higginbotham, Chief
Solid Waste Section                Printed:________________________
Office of Enforcement
                            Title:__________________________

Date:_________________________            Date:__________________________

COUNSEL FOR COMPLAINANT:            
Department of Environmental Management

By:___________________________        
Office of Legal Counsel
Department of Environmental Management

Date:__________________________        

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

                            For the Commissioner:

                            Signed on 5/18/00
                            _________________________
                            Felicia A. Robinson
                            Assistant Commissioner
                            Office of Enforcement

Converted by Andrew Scriven