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

COMMISSIONER OF THE DEPARTMENT    )
OF ENVIRONMENTAL MANAGEMENT,    )
                            )
            Complainant,        )
                            )    
                v.            )    CAUSE NO.     B-1887
                            )
                            )
YBMC CORPORATION,                )
                            )
            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 YBMC Corporation, which owns and operates the Yogi Bear Jellystone Park Wastewater Treatment Plant (WWTP), located in Pierceton, Kosciusko County, 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 on November 6, 1996 via Certified Mail to:

    Director of Environmental Affairs            Mr. Larry Ladd, Registered Agent
    YBMC Corporation                    YBMC Corporation
    16152 Prarie Rose Ave.                1916 N. 850 E.
    Goshen, Indiana 46526                Pierceton, Indiana 46562

5.    327 IAC 2-1-6(a)(1) states, in substance, that all waters at all times and at all places, including the mixing zone, shall meet the minimum conditions of being free from substances, materials, floating debris, oil or scum attributable to municipal, industrial, agricultural, and other land use practices or other discharges:

    a.    That will settle to form putrescent or otherwise objectionable deposits;

    b.    That are in amounts sufficient to be unsightly or deleterious;

    c.    That produce color, odor or other conditions in such degree as to create a nuisance;

    d.    Which are in amounts sufficient to be acutely toxic to, or to otherwise severely injure or kill aquatic life, other animals, plants, or humans.

    e.    Which are in concentrations or combinations that will cause or contribute to the growth of aquatic plants or algae to such degree as to create a nuisance, be unsightly, or otherwise impair the designated uses.

6.    327 IAC 5-2-8, states in substance, that the following conditions apply to all NPDES permits and shall be incorporated into the permits either expressly or by reference:

    a.    A permittee shall comply with all terms and conditions of its NPDES permit; any permittee non-compliance constitutes a violation of the Clean Water Act (CWA) and the Environmental Management Act (EMA) and is grounds for enforcement action;

    b.    The permittee shall take all reasonable steps to minimize or correct any adverse impact on the environment resulting from noncompliance with the permit;

    c.    The permittee shall at all times maintain in good working order and efficiently operate all facilities and systems (and related appurtenances) for collection and treatment which are necessary for achieving compliance with the terms and conditions of the permit; and

    d.    The permittee shall comply with monitoring, recording, and reporting requirements established in accordance with 327 IAC 5-2-13, 327 IAC 5-2-14, and 327 IAC 5-2-15.

7.    Part I.B.1. of the Permit states, in part, that the permittee is authorized to discharge from Outfall 001 in accordance with the requirements that BOD5 is limited to 15 mg/l for Weekly Average and 10 mg/l for Monthly Average.

8.    The investigation by the IDEM of the discharge monitoring reports (DMRs) determined that the Respondent has violated Part I.B.1. by exceeding the discharge limits for BOD5 from Outfall 001 for the following months in violation of 327 IAC 2-1-6 and 327 IAC 5- 2-8:

Yogi Bear Jellystone Park BOD5 Violations  
  Monthly Average   Weekly Average  
Permit Requirements   10 mg/l   15 mg/l  
Reported Quantities*      
Month   Year  
July   1993   10.41   33.20  
August   1993   17.65   52.2  
April   1994   15.5   20.07  
May   1994   9.88   15.22  
October   1994   31.6   55.5  
May   1996   7.5   16.1  
June   1996   6.5   17.7  
* Reported Quantities - Actual Violations are highlighted in bold.

9.    Part I.B.1 of the Permit states, in part, that the permittee is authorized to discharge from Outfall 001 in accordance with the requirements that Suspended Solids (TSS) is limited

to 6.3 lbs/day for Monthly Average, 15 mg/l for Weekly Average and 10 mg/l for Monthly Average.

10.    The investigation by the IDEM of the DMRs determined that the Respondent has violated Part I.B.1. by exceeding the discharge limits for TSS from Outfall 001 for the following months in violation of 327 IAC 2-1-6 and 327 IAC 5-2-8:

Yogi Bear's Jellystone Park TSS Violations  
  Quantity Monthly Average   Quality Monthly Average   Quality Weekly Average  
Permit Requirements   6.3 lbs/day   10 mg/l   15 mg/l  
Reported Quantities*       Highest Reported Volume  
Month   Year  
July   1993   52.3   133.5   516.0  
August   1993   27.1   147.7   554.0  
September   1994   0.77   7.13   15.75  
October   1994   0.18   89.4   165.0  
April   1995   1.02   12.3   24.0  
May   1995   6.68   14.7   42.4  
October   1995   0.196   9.4   25.0  
April   1996   1.5   8.2   16.0  
May   1996   11.4   11.8   28.9  
* Reported Quantities - Actual Violations are highlighted in bold.

11.    Part I.B.1 of the Permit requires that a chlorine residual (TRC) shall be maintained at a concentration of at least 0.5 mg/l, but not to exceed 1.0 mg/l as measured at the effluent end of the chlorine contact tank.

12.    The investigation by the IDEM of the DMRs has determined that the Respondent has violated Part I.B.1. of the Permit by exceeding one or more of the discharge limits for TRC from the chlorine contact tank for the following months in violation of 327 IAC 2- 1-6 and 327 IAC 5-2-8:


Yogi Bear's Jellystone Park TRC Violations  
  Minimum   Maximum  
Permit Requirements   0.5 mg/l   1.0 mg/l  
Reported Quantities*    
Month   Year  
May   1992   0.2   3.5  
June   1992   0.0   1.4  
July   1992   0.3   1.0  
August   1992   0.0   0.8  
September   1992   0.3   0.7  
October   1992   0.0   0.4  
April   1993   0.0   0.7  
May   1993   0.0   3.03  
June   1993   0.06   2.11  
July   1993   0.0   0.09  
August   1993   0.0   0.20  
September   1993   0.1   3.5  
October   1993   0.0   0.06  
April   1994   0.0   3.0  
May   1994   0.2   1.0  
June   1994   0.4   0.6  
July   1994   0.3   0.6  
August   1994   0.3   0.5  
September   1994   0.0   0.2  
October   1994   0.0   0.1  
April   1995   0.04   3.67  
May   1995   0.09   2.23  
June   1995   0.26   3.67  
July   1995   0.46   3.67  
September   1995   0.01   3.67  
October   1995   0.32   0.73  
April   1996   0.5   1.3  
May   1996   0.0   1.0  
June   1996   0.5   1.2  
July   1996   0.0   0.9  
* Reported Quantities - Actual Violations are highlighted in bold.

13.    Part I.B.1. of the Permit states, in part, that BOD5, Suspended Solids, and Fecal Coliform are to be measured on a weekly basis. Residual Chlorine and pH are to be measured twice weekly.

14.    On November 29, 1994, it was noted during the inspection that no samples had been taken for three (3) months. The inspection report also noted, that "many months, samples were not taken for eight (8) to ten (10) days at a time, sometimes samples were only taken three (3) times per month." This is in violation of the Permit requirements.

15.    IC 13-18-11-14 requires, in substance, that water and wastewater treatment plants be operated by a certified operator.

16.    Part I.C. of the Permit, states, in part, that:

    a.    the facilities shall be operated as efficiently as possible and in a manner which will minimize upsets and the discharge of excessive pollutants.

    b.    The permittee shall provide an adequate operating staff which is duly qualified to carry out the operation, maintenance, and testing functions required to insure compliance... the sewage treatment facilities shall be properly and efficiently operated under the supervision of a certified wastewater treatment operator.

17.    On November 29, 1994, it was noted during the inspection that the WWTP did not have a certified operator for three (3) months, in violation of IC 13-18-11-14 and the Permit.

18.    On December 10, 1996, Respondent communicated to the IDEM that a certified operator had been employed during the three (3) month time period referenced in Paragraph 17.

19.    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 to the IDEM for its approval a Compliance Plan (CP) that addresses the deficiencies and violations noted herein. The CP is due within thirty (30) days from the Effective Date of this Order. The CP is subject to approval of the IDEM. If the plan is deemed inadequate by the IDEM, a revised plan shall be submitted within fifteen (15) days of receipt of notice from the IDEM of the inadequacies thereof. If after submission of the revised document(s), the IDEM still finds that the document(s) are inadequate, then the IDEM may require further modification of the CP as necessary to meet the IDEM's requirements. If further modification does not meet the IDEM's approval, the IDEM will suggest appropriate modification to be undertaken by Respondent within a specified timeframe. If such modification is not timely undertaken or an alternative plan timely submitted by the Respondent is not approved by the IDEM, the Respondent will be liable for stipulated penalties. Respondent, upon written notification by the IDEM, shall immediately implement the approved plan, including the dates for completion of the schedule. The approved plan shall be incorporated into the Agreed Order and shall be deemed an enforceable part thereof. The CP shall include, but not be limited to:
    
        A.    An Operations and Maintenance (O & M) Manual for the existing plant that addresses inspections, scheduled maintenance and operations.


        B.    A Quality Assurance/Quality Control (QA/QC) Laboratory Manual, that addresses all sampling and analytical procedures to assure compliance with the requirements of the NPDES permit.

        C.    A plan to maximize the efficiency of the existing treatment plant during the interim period, until a final solution is achieved.

    Upon approval of the CP and subsequent completion of each of the scheduled work items contained in the CP, the Respondent shall submit documentation of completion within fifteen (15) days of the completion of the item to the address in paragraph 5.

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

            Water Enforcement Section Chief
            Office of Enforcement
            Indiana Department of Environmental Management
            100 N. Senate Avenue
            P.O. Box 7060
            Indianapolis, Indiana 46206-7060.

4.    Respondent is assessed a Civil Penalty of Five Thousand Five Hundred Twenty Dollars ($5,520). 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.

5.    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

    Paragraph 2    Failure to timely submit compliance
            plan or revised compliance plan        $1,000 per week late

            Failure to implement approved
            compliance plan                $1,000 per week late

            Failure to meet completion dates
            specified in approved compliance plan    $1,000 per week late    


6.    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.

7.    Civil and stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the Cause Number (B-1887) of this action and shall be mailed to:

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

8.    In the event that the civil penalty required by paragraph 4 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.

9.    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.

10.    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.

11.    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.


14.    This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order, and IDEM has sent a close out letter resolving this cause.


TECHNICAL RECOMMENDATION            RESPONDENTS

By: _________________________                By: _________________________
    Mark W. Stanifer, Chief                    
    Water Enforcement Section                    
    Office of Enforcement                Date: _______________
    Department of Environmental
     Management

                                By: _________________________
                                    

Date: _______________                    Date: _______________

LEGAL RECOMMENDATION            COUNSEL FOR RESPONDENTS

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 _______________________, 1999.

                    
                            For the Commissioner

                            signed May 25, 1999                                          Felicia Robinson George
                            Assistant Commissioner of the
                            Office of Enforcement

                            
                            

Converted by Andrew Scriven