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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,            )
                            )
            v.                )    CAUSE NO. B-2005
                            )
ACCORD CAPITAL, INC.                )
HIGHLANDER VILLAGE SUBDIVISION     )                     WASTEWATER TREATMENT PLANT        )
                            )
        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 Accord Capital, Inc., owner of Highlander Village Subdivision Wastewater Treatment Plant, located in Galena, Floyd County, Indiana. The wastewater treatment plant (WWTP) is located approximately one (1) mile East of Galena along U.S. 150 and operates under NPDES Permit No. IN 0052019 (the "Permit").

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 August 30, 1996, to:

                Daniel Page, Owner
                Highlander Village Subdivision WWTP
                P.O. Box 145
                Floyds Knobs, Indiana 47119

5.    Designated representatives of the Indiana Department of Environmental Management (IDEM) conducted inspections and a record review of the WWTP on July 27, 1993, December 12, 1994, February 20, 1995, February 21, 1995, March 3, 1995, November 6, 1995, January 5, 1996, January 22, 1996, July 1, 1996, and September 3, 1997. Based on the inspections and record review Respondent was found in violation of the Indiana Code (IC) and Indiana Administrative Code (IAC).

6.    327 IAC 2-4 requires, in substance, that a permittee submit Monthly Reports of Operation (MROs) to the Commissioner. Such reports shall:

    a.    include flow measurements and waste characteristics;

    b.    be prepared by a certified wastewater treatment plant operator;

    c.    be submitted prior to the 28th day of the following month.

7.    327 IAC 5-2-8 requires, 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;

    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.

8.    327 IAC 5-2-15 requires, in substance, that a permittee shall report to the commissioner, using Discharge Monitoring Reports (DMRs), the results of any monitoring specified by the permit.

9.    Respondent has not submitted or has been late in submitting DMRs and/or MROs to IDEM for the following periods in violation of 327 IAC 2-4, 327 IAC 5-2-15, 327 IAC 5- 2-8 and the Permit:


NOT SUBMITTED   SUBMITTED LATE  
MONTH   YEAR   MONTH   YEAR  
January   1994   January   1995  
February   1994   February   1995  
March   1994   March   1995  
April   1994   April   1995  
May   1994   May   1995  
June   1994   June   1995  
July   1994      
August   1994      
September   1994      
October   1994      
November   1994      
December   1994      
July   1995      
August   1995      
September   1995      
October   1995      
November   1995      
December   1995      
January   1996      
February   1996      
March   1996      
April   1996      
May   1996      
June   1996      
July   1996      
August   1996      
September   1996      
October   1996      
November   1996      
December   1996      
January   1997      
February   1997      
Total Missing   32   Total Late   6  

10.    IC 13-30-2-1 requires, in substance, that no person discharge, emit, cause, allow, or threaten to discharge, emit, cause, or allow any contaminant or waste including any noxious odor, either alone or in combination with contaminants from other sources, into the environment or into any publicly owned treatment works in any form which causes or would cause pollution which violates rules, standards, or discharge of emission requirements adopted by the appropriate board pursuant to this article.

11.    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.

12.    During inspections conducted on December 15, 1994, February 20, 1995, February 21, 1995, March 3, 1995, November 6, 1995, January 5, 1996, January 22, 1996, July 1, 1996, and September 3, 1997, substantial sludge deposits were observed in the receiving stream, in violation of 327 IAC 2-1-6, 327 IAC 5-2-8, IC 13-30-2-1 and the Permit.

13.    During the July 1, 1996 inspection, the IDEM representative observed that the entire facility was septic and sludge continued to accumulate in the tributary and was being discharged from the WWTP, in violation of 327 IAC 2-1-6, 327 IAC 5-2-8, IC 13-30-2-1, and the Permit. The overall operation and maintenance of the WWTP also continued to be unsatisfactory, in violation of the Permit.

14.    Respondent has reported the following effluent violations for Total Residual Chlorine (TRC) in violation of 327 IAC 5-2-8 and the Permit.


TOTAL RESIDUAL CHLORINE  

Limits
 
Quality or Daily Minimum (0.5)   Concentration Daily Maximum (1.0)  
Dates      
05/31/93   0.1    
04/30/95   0.2    
05/31/95   0.2    
Violations   3    


15.    During inspections conducted on December 15, 1994, February 20, 1995, February 21, 1995, March 3, 1995, November 6, 1995, January 5, 1996, January 22, 1996, and September 3, 1997, poor operation and maintenance (O&M) of the WWTP was documented on inspection reports. Each of the above noted inspection reports showed mostly "unsatisfactory" findings at Respondent's treatment plant, in violation of the Permit. O&M deficiencies noted at the above inspections included, but were not limited to:

    a.    inoperative flow meter and recorder;

    b.    sludge in the chlorine contact tank;

    c.    very thin mixed liquor;

    d.    floating sludge clumps in the secondary clarifier;

    e.    septic surge tank;

    f.    not using the sludge digester; and

    g.    not making records available at the time of inspections.

16.     On March 26, 1997, IDEM issued an "Imposition of Sewer Connection Ban" on Respondent's WWTP, which was not appealed by the Respondent.
                
17.    On August 26, 1997, the electrical power supply provided by the Harrison County REMC, was turned off. As a result of this, the biological treatment organisms died and the plant became septic. This resulted in untreated wastewater being discharged into the receiving stream. The untreated wastewater passed through the facility into the receiving stream, in violation of 327 IAC 2-1-6, 327 IAC 5-2-8, IC 13-30-2-1, and the Permit.

18.     On September 3, 1997, IDEM was notified about this discharge of untreated wastewater and sent Emergency Response Section (ERS) staff to respond to the WWTP to assess the environmental impact. It was determined that an emergency existed (Incident Number

9709015). The discharge of untreated wastewater necessitated the intervention of IDEM. IDEM hired the Reynolds Operating Corporation (ROC) to take over operation of the WWTP on September 3, 1997. ROC was hired by IDEM to stabilize the plant and eliminate the emergency condition. Respondent acknowledges the intervention of IDEM was appropriate and reasonable under the circumstances.

19.     On September 4, 1997, IDEM representatives and Respondent's attorney, David Mour, negotiated the signing of a "Grant of Access to Facilitate Repairs to Sewage Treatment Plant" by Respondent (Attachment A.). Respondent agreed to allow IDEM and ROC to stabilize the emergency situation. In conjunction therewith, Respondent agreed to permit IDEM and ROC to operate and maintain the facility for a temporary period in order to stabilize the emergency situation.

20.     On October 1, 1997, IDEM made written notification via Telefax and certified mail to Respondent and his attorney that the emergency condition had been eliminated at the WWTP and all operation and maintenance responsibilities were being restored to Respondent.

21.     On September 29, 1997, ROC provided IDEM with an itemized billing for services rendered relating to the emergency conditions at the WWTP in the amount of Thirty-Six Thousand Two Hundred Fifty-One Dollars and Seventeen Cents ($36,251.17). IDEM paid this amount in full from the Hazardous Substance Response Trust Fund (HSRTF), pursuant to IC 13-25-4. Respondent is now obligated to repay this amount to the HSRTF, with interest accruing at the rate of 5.25% upon the Effective Date.

22.     On October 17, 1997, Respondent and ROC entered into a written operating agreement (the "Agreement" and incorporated by reference to this Order as Attachment B.) that "secure[s] the services of ROC in providing total utility management of the Treatment Works for a period that will extend, subject to ROC's continued voluntary involvement, at least as long as monies are owed to IDEM by Page."

23.     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.    Within sixty (60) days from the Effective Date of this Order, the Respondent shall submit to IDEM for its approval a Compliance Plan (CP) which addresses the deficiencies and violations noted herein. The CP is subject to the approval of IDEM which shall not be unreasonably withheld or denied . If the plan is deemed inadequate by IDEM, a revised plan shall be submitted within fifteen (15) days of receipt of notice from IDEM of the inadequacies thereof. If after submission of the revised document(s) IDEM still finds that the document(s) are inadequate, then IDEM may require further modification of the CP as necessary to meet IDEM's requirements. If further modification does not meet IDEM's approval, IDEM will suggest appropriate modification to be undertaken by Respondent within specified time frames. If such modification is not timely undertaken or an alternative plan timely submitted by the Respondent is not approved by IDEM, the Respondent will be subject to stipulated penalties. Respondent, upon written notification by 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.    submittal of a Operation and Maintenance Manual;

        b.    submittal of a short-term sludge management plan;

        c.    submittal of a long-term sludge management plan;

        d.    installation of an approved chlorination system; and

        e.    installation of an approved flow monitoring device.

3.    Respondent shall within thirty (30) days of the Effective Date of this Order provide copies of all DMRs and/or MROs that have not been submitted to IDEM as of the Effective Date of this Order. Respondent shall submit DMRs with available information. In the event any monitoring information is not available, after a good faith effort to obtain said data, the DMR shall be submitted with an explanation as to why said information is not available.

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


                Steven M. Judith, Senior Environmental Manager
                Office of Enforcement
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 6015
                Indianapolis, IN 46206-6015

5.    Respondent is assessed a civil penalty of Fifty Eight Thousand Six Hundred Ninety-Eight Dollars ($58,698), of which the included sum of Thirteen Thousand One Hundred Twenty-Five Dollars ($13,125) represents additional penalties for the violations described in Paragraph I.17. of the Findings of Fact. Said penalty amount shall be paid to the Environmental Management Special Fund in the following manner:

    a.    in accordance with the Operating Agreement provided said agreement is approved by the IURC; or

    b.    within five (5) days in the event of disapproval of the Operating Agreement by IURC.

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

        Paragraph 2                    $500 per week for late submittal of CP, revised CP, modified CP or failure to complete any of the scheduled milestones in the CP.

        Paragraph 3                    $500 per week late in submitting missing DMRs and/or MROs.

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 any of the stipulated penalties 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 stipulated 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
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 7060
                Indianapolis, IN 46206-7060

9.    In the event that the civil penalty required by paragraph 5 is not paid when due under the applicable time frame specified in paragraph 5 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.     Under the authority of IC 13-25-4-10, Respondent shall reimburse the Hazardous Substance Response Trust Fund (HSRTF) in the amount of Thirty-Six Thousand Two Hundred Fifty-One Dollars and Seventeen Cents ($36,251.17). This amount shall be paid to the Hazardous Substance Response Trust Fund in the following manner:

    a.    in accordance with the Operating Agreement provided said agreement is approved by the IURC; or

    b.    within five (5) days in the event of disapproval of the Operating Agreement by IURC.

    If the Operating Agreement is disapproved by the IURC, this amount shall be due and payable to the HSRTF by the Respondent, with interest accruing at the rate of 5.25% upon the Effective Date. The failure to reimburse the HSRTF according to the applicable time frames contained in this paragraph shall subject Respondent's Highlander Village Subdivision Wastewater Treatment Plant to a lien imposed by the State pursuant to IC 13- 25-4-11, and shall subject the Respondent to all other remedies available to the Complainant to satisfy Respondent's obligation to the HSRTF.


11.     Payments to reimburse the HSRTF are payable by check to the Hazardous Substance Response Trust 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, IN 46206-7060


12.    In regard to the Sewer Ban described in Paragraph I.16. of the Findings of Fact, on or after March 3, 1998, provided IDEM has six (6) consecutive months of the required flow data from Respondent, Respondent may apply to IDEM to make additional connections into its system, provided said additional connections do not cause the facility to use in excess of 90% of its available capacity. Provided IDEM is satisfied the proposed additional connections will not cause the facility to use in excess of 90% of its available capacity, and provided the Respondent is in compliance with the terms of this Agreed Order, said application will be approved by IDEM. This provision in no way shall be deemed a waiver or release of the Sewer Ban described in Paragraph I.16. of the Findings of Fact. Flow available to Respondent shall be based on the flow which occurs in the six (6) month period preceding the month in which the application for additional connections is made.

13.    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.

14.    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.

15.    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.


16.    This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order and Complainant has issued a close-out letter to Respondent.



TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By:     _________________________        By:     _________________________
    Mark Stanifer, Section Chief                Daniel Page
    Office of Enforcement                Highlander Village WWTP
                            Title:     ________________________

Date: _______________                Date:     _______________

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

By: _________________________            By:     ________________________
IDEM, Office of Legal Counsel                

Date: _______________                Date:     _______________

                            The execution and existence of this document is acknowledged by
                            REYNOLDS OPERATIONS CORP.

                             ________________________
                             Stephen R. Tolliver, Sr.
                            President

                            Date:    _______________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS 15th DAY OF JANUARY, 1998.

                            For the Commissioner:

                            ___________________________
                             David J. Hensel
                            Director
                            Office of Enforcement

Converted by Andrew Scriven