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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. B-1935
            v.                    )
                                )
KOKOMO REGENCY MOBILE HOME PARK,        )
(a/k/a Country Park Estates Mobile Home Park)        )
CHURCHILL GROUP, LTD., OWNER            )
                                )
            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 Kokomo Regency Mobile Home Park (a/k/a Country Park Estates Mobile Home Park), Churchill Group, Ltd, Owner, located approximately 3 miles southeast of Kokomo, near the intersection of C.R. 200 South and C.R. 400 East of Kokomo, Howard County, Indiana. In accordance with the terms and conditions of National Pollution Discharge Elimination System (NPDES) Permit No. IN 0031844 ("the Permit"), Respondent is authorized to discharge to waters of the state named Kokomo Creek to Wildcat Creek to the Wabash River. Mr. Michael Mannion is the Certified Operator at the facility.

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


    4.    Pursuant to IC 13-7-11-2(b) (currently IC 13-30-3-3), a Notice of Violation         was duly served via Certified Mail on May 15, 1996 to:    

        Anne Marie Wiseman            Mr. Michael Mannion
        Director of Operations            Certified Operator
        Churchill Group, Ltd., Owner        Kokomo Regency Mobile Home Park
        Kokomo Regency Mobile Home Park     4508 E. 200 S.    
        40 North 4th Street                Kokomo, Indiana 46901
        Carbondale, Colorado 81623

    5.    Rule 327 IAC 5-2-8(1)(a) requires that a permittee shall comply with all terms and conditions of its NPDES permit. Any permit non-compliance constitutes a violation of the Clean Water Act (CWA) and the Environmental Management Act (EMA) and is grounds for enforcement action, for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

    6.    Part II.A.1. of the Permit states, in part, "All discharges authorized herein shall be consistent with the terms and conditions of this permit. Except as provided in paragraph I of Part II on bypassing, the discharge of any pollutant more frequently than, or at a level in excess of that identified and authorized by this permit constitutes a violation this permit, Rule 330 IAC 3 [revised and now referred to as 327 IAC 5], the Act [the Clean Water Act], and the Environmental Management Act. Such a violation may result in revocation or modification of this permit, denial of future applications for permit renewal, or the imposition of civil and/or criminal penalties as provided for in IC 13-7-13 [currently IC 13-30] ."

    7.    Part I.B.1. of the Permit authorizes the Respondent to discharge from outfall 001 in accordance with the discharge limitations and monitoring requirements for Flow, BOD5, Suspended Solids, Fecal Coliform, Residual Chlorine, and pH.

    8.    The discharge limitations contained in Part I.B.1 of the Permit for BOD5 are 15 mg/l for Weekly Average concentration, 10 mg/l for Monthly Average concentration, and 7.7 lbs/day for Monthly Average mass loading.

    9.    For the period of August 1992 through October 1995, the Respondent reported the following values for BOD5, all in exceedence of the discharge limitations contained in Part I.B.1. of the Permit for BOD5, and in violation of Part II.A.1. of the Permit and 327 IAC 5-2-8(1)(a):

    Month of        Monthly Ave.    Maximum Weekly Ave.    Monthly Ave.
    Violation        concentration        concentration            mass loading

    August, 1992        62 mg/l         73.8 mg/l            12.9 lbs/day
    September, 1992    50.3                70                15.1
    October, 1992    14.75                17                --
    November, 1992    16.35                27.2                10.31
    December, 1992    35                44                22
    January, 1993    42                58.8                30
    February, 1993    55                72.5                33
    March, 1993        30                42.5                18
    April, 1993        18.2                40.8                15
    May, 1993        55                76                30
    June, 1993        20                20                10
    July, 1993        20.0                27.0                17.6
    March, 1994        27.8                38.0                16.0
    April, 1994        25.2                50.0                16.0
    May, 1994        31.9                35.5                12.8
    June, 1994        24.9                29.0                --
    July, 1994        23.9                27.5                --
    August, 1994        12.1                17.0                --
    September, 1994    25.8                33.0                8.1
    October, 1994    19.2                28.0                7.8
    November, 1994    13.8                26.0                --
    February, 1995    20.8                25.0                10.4
    March, 1995        16.6                19.0                13.9
    April, 1995        12.4                15.5                8.1
    May, 1995        28.4                69.0                13.5
    June, 1995        16.1                26.5                10.8
    July, 1995        13.6                19.5                9.1
    August, 1995        11.9                17.0                7.9
    September, 1995    24.8                30.0                16.5
    October, 1995    19                29                12.7

        Note: "--" indicates the reported value was within the permit limit

    10.    The discharge limitations contained in Part I.B.1 of the Permit for Suspended Solids are 15 mg/l for Weekly Average concentration, 10 mg/l for Monthly Average concentration, and 7.7 lbs/day for Monthly Average mass loading.

    11.    For the period of August 1992 through October 1995, the Respondent reported the following values for Suspended Solids, all in exceedence of the discharge

limitations contained in Part I.B.1. of the Permit, and in violation of Part II.A.1. of the Permit and 327 IAC 5-2-8(1)(a):
    
    Month of        Monthly Ave.    Max Weekly Ave.        Monthly Ave.
    Violation        concentration        concentration            mass loading

    September, 1992    22 mg/l         34 mg/l            14 lbs/day
    January, 1993    25                46                18
    February, 1993    27                32                16
    March, 1993        54                144                32.8
    April, 1993        12.6                29                10.7
    May, 1993        27                36                14
    June, 1993        20                20                10
    March, 1994        17.8                26.0                10.7
    April, 1994        22.8                72.0                11.8
    May, 1994        20.8                45.0                7.4
    June, 1994        12.5                25.5                4.0
    February, 1995    20.8                30.5                9.9
    March, 1995        21.1                36.0                18.2
    May, 1995        42.8                130                18.4
    October, 1995    27.8                76.0                18.5
    
    12.    Part I.B.2. of the Permit allows the Respondent to sample and report chlorine content from a sample taken from the discharge from the chlorine contact tank during a period of high flow as an acceptable alternative to the weekly bacteria count. The discharge limitations contained in Part I.B.1 of the Permit for Residual Chlorine require the Respondent to maintain a Residual Chlorine content of at least 0.5 mg/l, but not more than 1.0 mg/l, of an effluent sample taken from the discharge from the chlorine contact tank during a period of high flow and requires twice weekly samples.

    13.    For the period of August 1992 through October 1995, the Respondent reported the following values for Residual Chlorine, all in violation of the discharge limitations contained in Part I.B.1. of the Permit for Residual Chlorine, and in violation of Part II.A.1. of the Permit and 327 IAC 5-2-8(1)(a):
    
        Month of        Minimum Reported    Maximum Reported
        Violation        concentration        concentration        
    
        August, 1992        0.0 mg/l            --
        September, 1992    0.0                --
        October, 1992    0.1                2.0 mg/l

        April, 1993        0.0                --
        May, 1993        0.0                1.9
        July, 1993        --                1.2
        August, 1993        0.2                --
        April, 1994        0.0                --
        May, 1994        0.0                --
        June, 1994        0.0                1.2
        July, 1994        0.15                1.5
        August, 1994        0.0                2.0
        September, 1994    0.3                1.5
        October, 1994    0.2                1.1
        April, 1995        0.0                1.1
        May, 1995        0.2                --
        June, 1995        0.0                1.6
        July, 1995        --                2.0
        August, 1995        0.0                1.4
        September, 1995    0.0                1.2
        October, 1995    0.0                --

        Note: "--" indicates the reported value was within the permit limit

    14.    On July 20, 1992, IDEM sent the Respondent a Warning of Noncompliance to the Respondent. The Warning of Noncompliance notified the Respondent that IDEM had reviewed the status of NPDES Permit No. IN 0031844 and the review indicated that the permit had been violated by exceeding NPDES permit effluent limits, having poor to no settling in the secondary clarifiers, having an improper flow meter and recorder installation, and allowing a wet well overflow.

    15.    An inspection of the Respondent's wastewater treatment facility conducted by IDEM staff on September 18, 1992, indicated, among other things, that the plant is subject to washouts whenever it rains.

    16.    An inspection of the Respondent's wastewater treatment facility conducted by IDEM staff on November 17, 1993, indicated, among other things, that a washout of the package wastewater treatment plant caused by a recent rain had occurred and that efforts made to remove clear water inflow had been unsuccessful.

    17.    A compliance sampling inspection conducted on Respondent's wastewater treatment facility conducted by staff on December 2-3, 1993, indicated that the Park's wastewater treatment facility was meeting effluent limitations for all

permit parameters.

    18.    An inspection of the Respondent's wastewater treatment facility conducted by IDEM staff on January 30, 1996, noted that the sewer type and maintenance was unsatisfactory and the inflow and infiltration (I&I) problems had not been addressed and that high flow was directly or indirectly responsible for most of the violations at the facility. It was also noted that the wastewater treatment facility screens were unsatisfactory in that they were clogged, being bypassed, and the screenings were on the ground. Additionally, it was noted that both cells of the treatment lagoon were being "short circuited" and that failure to use the lagoon capacity, along with high flow, negate any benefit from tertiary treatment.

    19.    Part I.A. of the Permit states, in substance, that the Respondent's treatment facility has design capacity of .0914 million gallons per day. On the Discharge Monitoring Report and Monthly Report of Operations for the Respondent's facility submitted for April of 1994, it was noted by the certified operator of the facility that, among other things, the facility had plant washout during heavy rains. Flows reported for April 12 and 13, 1994, were .2589 and .2009 million gallons per day respectively. Maximum 7 day average flows reported for January, February, April, and May of 1995, were .104 million gallons, .0969 million gallons, .0956 million gallons, and .1001 million gallons, respectively, all in excess of the design capacity of the treatment facility.

    20.    Part I.C.1. of the Permit states, "At all times, the facilities shall be operated as efficiently as possible and in a manner which will minimize upsets and discharge of excessive pollutants."

    21.    The Respondent has violated Part I.C.1 of the Permit by continuing to allow excessive inflow to cause plant upsets and discharge of excessive pollutants, as evidenced by inspections conducted by IDEM staff on September 18, 1992, November 17, 1993, and on January 30, 1996, and by the flow records and effluent limitation violations reported on Discharge Monitoring Reports for the facility.

    22.    On monthly reports submitted by the Respondent for the period of June through November of 1995, the Respondent submitted flow based on an estimated yearly average for 30 day average flow and 7 day average flow. The flows were not the actual flow and were not representative of the actual flows. On the Discharge Monitoring Report submitted for June of 1995, the certified operator noted that the flow results are submitted as yearly average due to the flow meter being in the factory for repairs. The inspection conducted by IDEM of the

Respondent's facility on January 30, 1996, noted that the flow meter and recorder was unsatisfactory in that it was out. Part I.B.8. of the Permit states that means shall be provided for accurate measurement and recording of the wastewater flow. The Respondent has allegedly violated Part I.B.8. of the Permit by failing to provide for measurement and recording of the wastewater flow. In response to the January 30, 1996, inspection, Michael Mannion, the Kokomo Regency Mobile Home Park's (the Park) certified wastewater treatment plant operator at that time, explained that the flow meter and recorder had been sent to its manufacturer for evaluation and repairs and that as soon as such evaluation and repairs had been completed the flow meter and recorder would be re-installed. During the interim period in which the flow meter and recorder were under evaluation and repair by its manufacturer, Mr. Mannion implemented his best alternative measures to monitor and record the effluent limit discharge from the Park's wastewater treatment plant. The flow meter and recorder was re-installed on the Park's wastewater treatment plant on or about August 15, 1996.

    23.    An inspection of the Respondent's wastewater treatment facility conducted by IDEM staff on June 2, 1997, alleges, among other things, that the discharge monitoring records and reports were not available for inspection on site. In response to this inspection, Mr. Mannion, the Park's certified wastewater treatment plant operator at that time, explained that he had inadvertently left such records at his home or another location. Upon notification of the deficiencies cited in the June 2, 1997, inspection, Respondent replaced Mr. Mannion with James Dougherty, another certified wastewater treatment plant operator.

    24.    In agreeing to the issuance of and entering into this Agreed Order, Respondent neither admits nor denies the liability with respect to the alleged violations.
        
    25.    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.    The Respondent will comply with the following two-phased Compliance Plan ("CP"):

         Phase I - Wastewater Treatment Plant Study and Inflow and Infiltration         ("I/I")    Removal Program

        a.    Study of Wastewater Treatment Plant. Respondent shall perform a comprehensive evaluation of the Park's wastewater treatment plant, including collection system, which shall include the following:

            i.    Records Review. Respondent will review all relevant data related to the operation of the Park's wastewater treatment plant, including, but not limited to, a review of Permit No. IN 0031844, a review of the Park's daily records for wastewater usage and wastewater plant flow, daily and monthly discharge monitoring reports, and rainfall records for the City of Kokomo.

            ii.    Process Evaluation. Respondent will perform a comprehensive evaluation of the Park's wastewater treatment plant to determine what if any repairs or improvements are needed to allow the Park's wastewater treatment plant to maintain compliance with its Permit's effluent limitations.

            iii.    Flow Monitoring. Respondent will monitor plant flows during both dry and wet weather periods.

            iv.    Recommendations. Based upon the Respondent's review of the Park's data and records and the Respondent's evaluation of the Park's wastewater treatment plant, the Respondent will make specific recommendations to improve the Park's compliance with its Permit's effluent limitations.

            Respondent will complete its study and evaluation of the Park's wastewater treatment plant within eighty (80) days of the Effective Date of this Agreed Order.

        b.    I/I Removal Program. Respondent shall perform a comprehensive analysis of the Park's collection system. The purpose of the collection system analysis is to identify sources of potential inflow and infiltration into the Park's collection system. Respondent's collection system analysis may include the following: videotaping, smoke testing, and flow monitoring of the Park's collection system.

            i.    Videotaping. Respondent may videotape those portions of the Park's collection system where Respondent believes the collection system is experiencing excessive I/I.

            ii.    Smoke Testing. Respondent will smoke test the Park's collection system in those areas where Respondent believes the collection system is experiencing excessive I/I.

            Respondent will complete its study and evaluation of the Park's collection system within fifty (50) days of Respondent's completion of its study and evaluation of the Park's wastewater treatment plant.

        Phase II - Collection System Repairs

        a.    Repair Report. Upon completion of its study of the Park's wastewater treatment plant and collection system, Respondent will prepare a written report outlining Respondent's findings and recommendations which will propose, if necessary, specific repairs and improvements to be made to the Park's collection system (hereinafter referred to as "Phase I written report"). Respondent will submit to IDEM this written report within thirty (30) days of Respondent's completion of I/I Removal Program described in paragraph 2(b) above.

        b.    Design and Permits. If Respondent is required to submit plans and specifications to IDEM or any other federal, state or local government agency for a construction permit for the work identified in Respondent's Phase I written report, Respondent will submit complete plans to IDEM and/or such other governmental agency within ninety-five (95) days after submittal of Respondent's Phase I written report.

        c.    Construction. If a construction permit is required for collection system improvement, Respondent will begin construction promptly after approval of the construction permit and will complete all construction work on the Park's collection within eighty-seven (87) days of the start of construction.


        d.    Flow Monitoring and Report. Upon completion of collection system construction work, Respondent will monitor flow to demonstrate a reduction of influent flow to a level at or below the design capacity of the treatment plant and to determine compliance with effluent limitations. Monitoring is to be conducted for a period not to exceed three months in order to determine whether or not the collection system repairs or improvements were sufficient to reduce the influent flow to a level at or below the design capacity of the Park's treatment facility and to bring the facility into compliance with the Park's Permit. Respondent will submit a report on the results of the flow monitoring within eight-two (82) days following completion of the flow monitoring described above.

        e.    IDEM Review. If IDEM determines that the Respondent's flow monitoring report demonstrates that sufficient sources of I/I have been eliminated and that the Park's wastewater treatment plant is in compliance with its permitted limits, then Respondent will be deemed to have completed Phases I and II of the compliance plan.

        Respondent, upon adoption of this Agreed Order, shall immediately implement the CP, including dates for completion of the schedule. The CP is incorporated into the Agreed Order and is deemed an enforceable part thereof.

    3.    Upon completion of Phases I and II of the CP, Respondent shall enter a performance period where Respondent shall maintain compliance with the Monthly Average effluent limitations of its NPDES permit. The performance period shall end after IDEM serves notice that six (6) consecutive months of compliance with the Monthly Average effluent limitations have been achieved.

        If Respondent has not achieved six (6) consecutive months of compliance with Monthly Average effluent limitations within twelve (12) months after the completion of Phases I and II of the CP, Respondent shall submit a Phase III CP which will contain additional measures to maintain compliance at the Park's wastewater treatment plant. These additional measures may include wastewater treatment plant improvements or other measures which Respondent may take to increase the capacity of the Park's wastewater treatment plant.

    4.    If IDEM determines that Respondent is required to submit a Phase III CP, Respondent will submit a Phase III CP within sixty (60) days of IDEM's written request for a Phase III CP. IDEM may approve or disapprove of the actions proposed in Respondent's Phase III CP. IDEM may approve or disapprove of the actions proposed in Respondent's Phase III CP. In the event IDEM should disapprove of Respondent's Phase III CP or any portion thereof, IDEM and

Respondent shall negotiate to reach an agreement as to any additional work to be performed on the Park's wastewater treatment plant or collection system. Any Phase III CP submitted by Respondent shall provide Respondent with one year to complete all actions described in Phase III of the CP. Upon receipt of IDEM's approval of any proposed Phase III CP, Respondent shall proceed immediately to implement such Phase III CP.

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

            Water Enforcement Section Chief
            Office of Enforcement, IGCN, Rm. 1315
            Indiana Department of Environmental Management
            P.O. Box 6015
            Indianapolis, Indiana 46206-6015

    6.    Respondent is assessed a civil penalty of Two Thousand Five Hundred Dollars ($2,500). 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.

    7.    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            $200 per week for failure to comply with                             any milestone contained in the approved                             compliance plan.

    8.    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.

    9.    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
            Indiana Department of Environmental Management
             100 N. Senate Avenue
            P.O. Box 7060
            Indianapolis, Indiana 46206-7060.
    
    10.    In the event that the civil penalty required by paragraph 6 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 or stipulated penalty is paid in full.

    11.    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 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.

    12.    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.

    13.    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 acting for it comply with the terms of this Agreed Order.

    14.    "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 any obligation under 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 (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 cost to perform the work.


        The Respondent shall notify IDEM by calling within seven (7) calendar days and by writing no later that ten (10) business 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 time table 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 Force Majeure. Failure to comply with the above requirement 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 IDEM. Said decision shall be communicated to the Respondent.

        If a delay is attributable to a Force Majeure, IDEM 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.

    15.    This Agreed Order, and compliance with its terms, shall resolve all issues which have been raised and could have been raised in the Notice of Violation issued by the Complainant to Respondent on May 15, 1996. In addition, this Agreed Order, and compliance with its terms, shall resolve all issues raised in IDEM's inspections of the Park subsequent to Complainant's issuance of the NOV, but before the Effective Date of this Agreed Order including, but not limited to, Complainant's June 2, 1997 NPDES Facility Inspection Report.

    16.    This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order.

    17.    The terms of this Agreed Order may be modified by written consent of both parties hereto.


TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By:             By:
Mark W. Stanifer, Chief                 Anne Marie Wiseman
Water Enforcement Section             Director of Operations    
Office of Enforcement                   Churchill Group, Ltd.
                             40 North 4th Street
                             Carbondale, Colorado 81623

Date:                     Date:

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

By:                     By:
Nancy Holloran                     David Temple
Office of Legal Counsel                 Stewart & Irwin, P.C.
Department of Environmental             251 E. Ohio Street
Management                     Indianapolis, Indiana 46204
                                
Date:             Date:
        

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

THIS DAY OF , 199__.

                    For the Commissioner:
                        

                     Signed 5/7/98
                    David J. Hensel
                    Director
                    Office of Enforcement

Converted by Andrew Scriven