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. A-4408
                            )
DEPARTMENT OF CORRECTION        )
PENDLETON CORRECTIONAL FACILITY,    )
                            )
        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 Department of Correction (hereinafter referred to as "Respondent"), a department of the State of Indiana who operates its Pendleton Correctional Facility at 4490 West Reformatory Road, located in Pendleton, 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. Edward L. Cohn, Commissioner            Mr. Jack Duckworth, Superintendent
    Department of Correction                Pendleton Correctional Facility
    402 West Washington Street, Rm. E-334        P. O. Box 28
    Indianapolis, IN 46204                Pendleton, IN 46064


    5.    Rule 326 IAC 2-1-3 requires that no owner or operator shall construct a source or facility without first applying for and obtaining a construction permit from the commissioner for the source or facility. Rule 326 IAC 2-1-4 requires that no owner or operator shall operate a source or facility without first applying for and obtaining an operating permit form the commissioner for the source or facility.

        Respondent constructed a boiler designated as B-5, and converted boilers designated as B-1 through B-3 for coal burning to operate on both natural gas and fuel oil in 1995 without first applying for and obtaining appropriate construction and operating permits, violations of 326 IAC 2-1-3 and 326 IAC 2-1-4.

    6.    Rule 326 IAC 12, which incorporates by reference 40 CFR 60.45c Subpart Dc requires that an operator of any affected facility shall conduct an initial performance test on the facility to determine compliance with the standards.

        Respondent failed to conduct an initial performance stack test on the B-5 boiler as required pursuant to Subpart Dc, a violation of 40 CFR 60.45c Subpart Dc.

    7.    Rule 326 IAC 20-7, which incorporates by reference 40 CFR 63.322(a) requires that a dry cleaning facility operator shall equip the dry cleaning facility with a refrigerated condenser or a carbon adsorber.

        Respondent failed to equip its dry cleaning facility with a refrigerated condenser or a carbon adsorber between October 1996 and July 1997, a violation of 40 CFR 63.322(a).

    8.    40 CFR 63.323(a) requires that a dry cleaning facility operator shall conduct monitoring of a refrigerated condenser or a carbon adsorber.

        Respondent failed to conduct monitoring of a refrigerated condenser or a carbon adsorber between October 1996 and July 1997, a violation of 40 CFR 63.323(a). In July 1997, Respondent replaced its existing dry cleaning facility with the compliant equipment.

    9.    40 CFR 63.324 requires that a dry cleaning facility operator shall keep records and submit reports of the monitoring results to Complainant upon Complainant's request.

        Respondent failed to keep records of the monitoring results between October 1996 and July 1997, a violation of 40 CFR 63.324. Since July 1997, Respondent started required monitoring and record keeping procedures.

    10.    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.    Respondent shall submit an amendment to its Title V permit application to account for the fuel conversion of boilers B-1 through B-3 to the Office of Air Management with a carbon copy to the Office of Enforcement within ninety (90) days from the Effective Date of this Agreed Order.

    3.    Respondent shall submit a particulate matter emissions testing protocol and a proposed test date for boiler B-5 to the Compliance Data Section of the Office of Air Management with a carbon copy to the Office of Enforcement within ninety (90) days from the Effective Date of this Agreed Order and complete the test within one hundred and twenty (120) days from the Effective Date of this Agreed Order. Test shall be conducted pursuant to 326 IAC 3-6.

    4.    Respondent shall develop a standard operating procedure (SOP), post it close to the dry cleaning unit, and train designated personnel to conduct monitoring pursuant to 40 CFR 63.323, and to take records of the results, and submit a copy of the SOP along with the list of trained individuals to the Complainant not later than ninety (90) days from the Effective Date of this Agreed Order.

    5.    Once Respondent has complied with the requirements of Order paragraphs 2, 3, and 4 of this Agreed Order, it shall submit documentation that shows how and when the violations were corrected.

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

        Mr. Michael Stonik, Enforcement Case Manager
        Office of Enforcement
        Indiana Department of Environmental Management
        100 N. Senate Avenue
        P. O. Box 6015
        Indianapolis, IN 46206-6015

    7.    "Force Majeure", for purposes of this Agreed Order, is defined as any event

arising from causes beyond the control of the Respondent that delays or prevents the performance of obligations under Order paragraphs 2 and 3 of this Agreed Order despite Respondent's best efforts to fulfill the obligation. The requirement that the Respondent exercise "best efforts to fulfill the obligation" includes using best efforts to anticipate any potential force majeure event and best efforts to address the effects of any potential force majeure event (1) as it is occurring and (2) following the potential force majeure event, such that the delay is minimized to the greatest extent possible. "Force Majeure" does not include financial inability to complete the work required by this Agreed Order or increases in costs to perform the work.

        The Respondent shall notify Complainant by calling within three (3) calendar days and by writing no later than seven (7) calendar days after any event which the Respondent contends is a force majeure. Such notification shall describe the anticipated length of the delay, the cause or causes of the delay, the measures taken or to be taken by the Respondent to minimize the delay, and the timetable by which these measures will be implemented. The Respondent shall include with any notice all available documentation supporting their claim that the delay was attributable to a force majeure. Failure to comply with the above requirements shall preclude Respondent from asserting any claim of force majeure for that event. The Respondent shall have the burden of demonstrating that the event is a force majeure. The decision of whether an event is a force majeure shall be made by Complainant. Said decision shall be communicated to the Respondent.

        If a delay is attributable to a force majeure, Complainant shall extend, in writing, the time period for performance under this Agreed Order, by the amount of time that is attributable to the event constituting the force majeure.

          This Agreed Order shall apply to and be binding upon the Respondent, its directors and successors. 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:        DEPARTMENT OF CORRECTION:
Department of Environmental Management

By:     _________________________        By: _________________________
    David P. McIver
    Air 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 ____________________, 199___.

                            
                            For the Commissioner:
                            
                            Signed on December 2, 1999
                            ___________________________
                            Felicia A. Robinson
                            Assistant Commissioner
                            of Enforcement

Converted by Andrew Scriven