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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-2319
                            )
ALUMINUM COMPANY OF AMERICA,    )
        Lafayette Division             )
                            )
        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. Pursuant to IC 13-30-3-3, entry into the terms of this Agreed Order does not constitute an admission of the violations contained herein.

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.

     Respondent is Aluminum company of America (ALCOA), Lafayette Division (hereinafter referred to as "Respondent"), who operates and owns an aluminum forming facility in Lafayette, Tippecanoe County, Indiana.

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

     Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation via Certified Mail on May 27, 1998, to:

                Mr. Richard Melville
                Aluminum Company of America
                3131 Main Street
                P.O. Box 7500
                Lafayette, Indiana 47905

     IC 13-30-2-1 states, in part, that a person may not 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 or emission requirements adopted by the appropriate board pursuant to this article.

     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.

     327 IAC 5-2-2 prohibits any discharge of pollutants into waters of the state as a point source of discharge, unless in conformity with a valid NPDES Permit obtained prior to the discharge.

     On May 5, 1998, a milky white substance was found in Elliot Ditch and reported to IDEM's Office of Emergency Response (OER) by the Tippecanoe County Emergency Management Director, Steve Wettschurack. OER contacted the Indiana Department of Natural Resources (IDNR) who sent a Conservation Officer (CO) to the site. The CO investigated Elliot Ditch and observed stream pollution with a fish kill downstream from approximately Brandy Lane and Concord Road in Lafayette. On May 6, an IDEM OER responder together with the CO further investigated the spill in Elliot Ditch. This investigation revealed that the spill appeared to originate from ALCOA's outfall, which is

located along Elliot Ditch. Live fish and no presence of the substance were observed upstream from ALCOA's outfall. ALCOA was notified that their discharge from outfall 001 was believed to be the source of the spill. On May 7, 1998, ALCOA representatives informed the IDEM OER responder that they had found a spill of hydraulic fluid which had entered a storm drain that connects to outfall 001. ALCOA reported that the spill was estimated at 100 gallons of hydraulic fluid at 100% concentration and was caused due to employee error. The spill was discharged to Elliot Ditch via ALCOA's outfall 001, in violation of IC 13-30-2-1, 327 IAC 2-1-6(a)(1) and 327 IAC 5-2-2. The spill resulted in a fish kill in Elliot Ditch of a total of 4,881 fish, as reported by IDNR.

     Since the time of the incident the Respondent has taken the following measures to prevent a similar occurrence in the future:
    
         The hose used to fill the oil/water system has been eliminated.
         All piping for the system has been re-run inside the bermed area of the oil/water system.
    c.     An individual dedicated to operating the system has been provided.
    d.     Chemical feed lines have been locked out with only Alcoa supervision having the     key.
    e.     A log is maintained of chemical inventories and system additions.
    f.     Flow meters have been installed on the chemical feed lines.
    g.     The storm water catch basins, which received the spilled hydraulic material and     discharge to the storm sewer, have been filled with concrete.

     In recognition of the settlement reached, Respondent waives any right to administrative and judicial review of this Agreed Order.

II. ORDER

     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.

     The Respondent is hereby assessed a Civil Penalty of Twenty Two Thousand Dollars ($22,000). The Respondent has elected to perform and complete a Supplemental Environmental Project (SEP) in lieu of payment of a portion of the civil penalty. Contingent upon the approval by IDEM of the proposed SEP, the cash portion of the Civil Penalty is Four Thousand Four Hundred Dollars ($4,400) which shall be paid within thirty (30) days of the Effective Date of this Order.

    The proposed SEP plan will be submitted, within thirty (30) days of the Effective Date of this Order , to the Office of Enforcement, IDEM, for approval. Upon receipt of IDEM's written approval of the SEP, the Respondent will perform the SEP in accordance with a mutually approved schedule contained in the approved SEP. The

Respondent will complete the SEP and submit documentation of costs incurred in performing the SEP to IDEM for approval on or before November 1, 1999. Upon completing of all the requirements contained in this paragraph on or before November 1, 1999, the remaining $17,600 of the civil penalty will be waived. Should the cost incurred by the Respondent be less than the minimum amount as mutually agreed, then the remaining amount shall be paid within thirty days of notification from IDEM . OR If the Respondent fails to complete the project by November 1, 1999, the entire balance of civil penalty, plus interest on the unpaid balance at the rate established by IC 21-4.6- 1-101 from the Effective Date of this Order, shall be paid to the Environmental Management Special Fund on or before December 1, 1999.

     Civil 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 46207-7060

     In the event that the cash portion of the civil penalty ($4,400) required by paragraph 2 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.

     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.

     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.

     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.

     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:     _________________________
    Mark Stanifer, Section Chief
    Office of Enforcement            Printed: ________________________

                            Title:     ________________________

Date: _______________                Date:     _______________

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

By: _________________________            By: ________________________
Nancy Holloran
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 4/26/99
                            ___________________________
                            Felicia Robinson George
                            Assistant Commissioner of Enforcement

Converted by Andrew Scriven