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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-2343
                            )
                            )
HOCKING OIL COMPANY, INC.,     )
                        )
            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 ("IDEM"), a department of the State of Indiana created by IC 13-13-1-1.

          Respondent is the Hocking Oil Company, Inc., which owns and operates an oil production operation (hereinafter referred to as the "Site") located near County Road 875 W. at the Hilbert-Shelton Well #2 near Princeton in Gibson County, Indiana.
    
    3.    The 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. Andy G. Hocking, President     Ms. Andrea M. Richardson, Resident Agent
        Hocking Oil Company, Inc.        Hocking Oil Company, Inc.
        P.O. Box 162             P.O. Box 162             
        Mt. Carmel, IL 62863        Mt. Carmel, IL 62863

    5.    327 IAC 2-6.1-4 contains the following definitions:

        (15)    "Spill" means any unexpected, unintended, abnormal, or unapproved dumping, leakage, drainage, seepage, discharge or other loss of petroleum, hazardous substances, extremely hazardous substances, or objectionable substances.

        (16)    "Spill response"for purposes of this rule means the following:
             (A) the spill is contained; and
             (B) free material is removed

        (17)    "Spill report" means an oral report that includes .... the location and time of the spill; the identification of the substance spilled, the quantity of substance that has been or may further be spilled, the identification of the person making the spill report, and what measures have been or will be undertaken to perform a spill response and any other information that may be significant to the response action.

         6.    327 IAC 2-6.1-7, requires, in part, that any person who operates, controls or maintains any mode of transportation or facility from which a spill occurs shall, upon discovery of a reportable spill to the waters of the state, do the following:

        (1) Contain the spill, if possible, to prevent additional spilled material from entering the waters of the state.

        (2) Undertake or cause others to undertake activities needed to accomplish a spill response.

        (3) As soon as possible but within two (2) hours of discovery, communicate a spill report to the Department of Environmental Management, Office of Environmental Response: Area code 1-888-233-7745 for in state calls (toll free).


    7.    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 attibutable 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, visible oil sheen, 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.

             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.

    8.    IC 13-18-4-5 states, in part, that it is unlawful for a person to throw, run, drain, or otherwise dispose into any of the streams or waters of this state, or to cause, permit, or suffer to be thrown, run, drained, allowed to seep, or otherwise disposed into any waters, any organic or inorganic matter that causes or contributes to a polluted condition of any waters, as determined by a rule of the board adopted under section 1 and 3 of this chapter.

    9.    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 ...., either alone or in combination with contaminants from other sources, into the environment .... in any form that causes or would cause pollution that violates or would violate rules, standards, or discharge or emission requirements adopted by the appropriate board under the environmental management laws.

          On June 18, 1998, the Indiana Department of Natural Resources, Division of Oil and Gas, inspected Respondent's oil production and storage facilities and found the containment area at the tank battery to be filled with a mixture of water and crude oil. In a Warning of Noncompliance prepared during the inspection, IDNR requested that Respondent remove and dispose of the oil and fluids from inside the containment area. On June 19, 1998, the IDNR Oil and Gas representative

informed the IDNR Conservation Officer that appropriate action to remove and dispose of the oil had not been taken.

          On June 19, 1998, the IDEM Office of Environmental Response was informed by the Indiana Department of Natural Resources (IDNR) that there was a potential release from Respondent's facility of approximately 10 barrels of crude oil to the White River in Gibson County.

    12.    On June 20, 1999, a IDNR Conservation Officer inspected Respondent's oil tank battery site. The area was flooded by area flood waters from the Wabash, White, and Patoka Rivers. The oil spill was, at that time, still contained within the containment area of the oil tank battery. The flood waters were rising and threatened to breach the containment wall.
    
    13.    On June 23, 1998, the IDNR Oil and Gas and the Conservation Officer returned to the site. The flood waters had risen further and were near a crest. The only access to the tank battery was by motorboat. The flood waters were above the containment wall. Oil was spilled into the flood waters. An oil sheen was observed several hundred yards away from the tank site. The oil sheen was traced back to Respondent's oil tank battery site.

    14.    Respondent's failure to report the release, contain, and immediately clean-up the spill constitutes violations of 327 IAC 2-6.1-7.
        
    15.    Respondent's discharge of oil into the White River constitutes violation of 327 IAC 2-1-6(a)(1), IC 13-18-4-5 and IC 13-30-2-1.

    16. On April 7, 1999, Respondent provided IDEM with its account of clean up,
        improvements to the firewall which were completed on July 6, 1998, and
        commitment to routine inspection of the facilities to prevent a reoccurrence
        of an oil release.        
        
    17.    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 comply with all applicable sections of the Indiana Code and the Indiana Administrative Code referenced in the Findings of Fact of this Agreed Order.

         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall develop and submit to the IDEM, Office of Enforcement, for its approval a spill control and contingency plan for the Site. The plan shall include provisions for notification of spills of oil or brine to the IDEM, Office of Environmental Response and specifically detail steps to be taken for spill prevention, containment, and clean up. Respondent shall comply within specified time frames of any IDEM request for additional information or modification of the plan. IDEM's review of Respondent's spill control and contingency plan shall be solely as a requirement of settling this action and in no way relieves the Respondent of the obligation to comply with all applicable rules and statutes. Nothing in this provision prevents Complainant from exercising its full enforcement authority as to all permit requirements, rules or statutes. The submittals required by this paragraph shall be sent to:

            Office of Enforcement, Water Section Chief
            Indiana Department of Environmental Management
            100 N. Senate Avenue
            P.O. Box 6015
            Indianapolis, Indiana 46206-6015.

    4.    Respondent is assessed a Civil Penalty of Four Thousand Dollars ($4,000). Said penalty amount shall be due and payable to the Environmental Management Special Fund according to the following payment schedule:

            Penalty Payment Schedule

        Payment                Date

        Payment #1    $1,000            Within 30 days of the Effective Date


        Payment #2    $1,000            Within 120 days of the Effective Date

        Payment #3    $1,000            Within 210 days of the Effective Date

        Payment #4    $1,000            Within 300 days of the Effective Date

    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 #3            $500 per week the spill plan or requested modified plan is 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-2343) of this action and shall be mailed to:
                
                IDEM Cashier
                100 N. Senate Avenue
                P.O. Box 7060
                Indianapolis, Indiana 46207-7060.

    8.    In the event that the civil penalty amount required by paragraph 4 is not paid when due, Respondent shall pay interest on the unpaid, overdue balance at the rate established by IC 24-4.6-1-101. The interest shall continue to accrue until the installment payments or 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. 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.

    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.    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.

    12.    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
                                Hocking Oil Company, Inc.

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

                                
                                    

Date: _______________                    

COUNSEL FOR COMPLAINANT        COUNSEL FOR RESPONDENT

By: _________________________                By: _________________________
    Nancy A. 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 5/13/99_______
                            Felicia Robinson George
                            Assistant Commissioner of Enforcement

Converted by Andrew Scriven