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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-2454
                            )
UTILITY CENTER, INC.,                 )
dba AQUASOURCE                )
                            )
                            )

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.

     Respondent is Utility Center, Inc., dba AquaSource, (hereinafter referred to as "Respondent"), which owns and operates two wastewater treatment plants (WWTP), the Midwest plant and the Main Aboite plant.

     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, on October 14, 1999, IDEM issued a Notice of Violation via Certified Mail to:

    Stephen R. Tolliver Sr.
    Chief Operating Officer
    AquaSource
    1601 Greentree Court
    Clarksville, IN 47129
    
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.    that 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;

    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.    IC 13-30-2-1 requires, in substance, 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 of emission requirements adopted by the appropriate board pursuant to this article.

8.    IC 13-18-4-5 states, in part, that it is unlawful for any 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 shall cause or contribute to a polluted condition of any waters, according to any rule of the board under section 7 of this chapter.

9.    A record review for September 1996 through August 1999 indicates that Utility Center Inc.-Main Aboite exceeded permit final effluent limitations in violation of 327 IAC 5-2- 8, IC 13-30-2-1 and the Permit for:                    

    a.)    Total Suspended Solids (TSS) for the months of December 1997; February, June, July, December 1997; January, March 1998; and January, February, March 1999.

    b.)    Ammonia Nitrogen for the month of January 1999.

    c.)    E. coli for the months of September 1996; August, September 1997; April, May 1998;    and May, June 1999.    

    d.)    Total Residual Chlorine for the months of July, August, September, and October 1998.

    e.)    Carbonaceous Biochemical Oxygen Demand (CBOD5) for the months of December 1996; January, March, May, July, August 1998; and January 1999.

10.    A record review for September 1996 through August 1999 indicates that Utility Center Inc.-Midwest exceeded permit final effluent limitations in violation of 327 IAC 5-2-8, IC 13-30-2-1 and the Permit for:


    a.)    Total Suspended Solids (TSS) for the months of February, May, July 1997; August, September 1998; and January, February 1999.

    b.)    Ammonia Nitrogen for the months of May 1997 and August, September 1998.

    c.)    E. coli for the months of October 1996; April, May, July, September 1997; and June, July, August, September, October 1998.

    d.)    Carbonaceous Biochemical Oxygen Demand (CBOD5) for the month of May 1997.

11.    A records review from January 1, 1998 through September 13, 1999 of reported bypass events at Utility Center, Inc.- Midwest documents that bypasses resulting in the discharge of untreated wastewater occurred on 8 occasions in 1998 and on 6 occasions in 1999. This is in violation of 327 IAC 5-2-8(11)(D) and Part II. A.7 of the Permit.

12.    A records review from January 1, 1998 through September 13, 1999 of reported bypass events at Utility Center, Inc.-Main Aboite documents that bypasses resulting in the discharge of untreated wastewater occurred on 19 occasions in 1998 and on 66 occasions in 1999. A review of Inspection Reports from May 9, 1997 through April 14, 1999 documents that problems with Inflow and Infiltration (I/I) and bypassing had been consistently identified. This is in violation of 327 IAC 5-2-8(11)(D) and Part II. A.7 of the Permit.

13.    On January 23, 1992, IDEM issued an Agreed Order, Cause No. B-1391, requiring correction of identified problems at the Main Aboite plant. Subsequent amendments to the Agreed Order have been issued to address revised dates for completion of specific actions. The latest amendment was adopted on August 14, 1997 and included dates for the construction of a force main to the Midwest plant and the construction of sludge handling facilities, both of which were to be completed by December 31, 1998. As this deadline was not met, Respondent and IDEM negotiated a fourth Amendment to the Agreed Order. As, Respondent was purchased by AquaSource in February 1999, the fourth Amendment was not issued. The issuance of this Agreed Order for Cause No. B- 2454 will supercede any outstanding requirements in Cause No. B-1391.

14.    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 her delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the Effective Date.

     Within thirty (30) days of the Effective Date, the Respondent shall submit to IDEM for its approval a Compliance Plan (CP) that addresses the deficiencies and violations noted herein. The CP is subject to approval of IDEM. If the plan is deemed inadequate by IDEM, a revised plan shall be submitted within thirty (30) 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 a specified timeframe. 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 liable for stipulated penalties. Respondent, upon written notification by IDEM, shall immediately implement the approved plan, including the time lines for completion of the scheduled items. The approved CP shall be incorporated into the Agreed Order and shall be deemed an enforceable part thereof. The CP shall include:
    
        A.    An Operations and Maintenance (O & M) Manual for the existing plants that addresses inspections, scheduled maintenance and operations.

        B.    A plan to maximize the efficiency of the existing treatment plants during the interim period, until a final solution for staying in compliance is achieved.

        C.    Actions Respondent will take to assure consistent compliance with Permit effluent limitation requirements.
        
        D    Actions Respondent will take to address the bypass problems including: identification of all bypass and overflow points; permit modification request to include those points not included in the current NPDES permits; plan for elimination of all Sanitary Sewer Overflow (SSO) discharge events; plans to report all discharge events.                

              Actions Respondent will take to assure elimination of collection system I/I problems.

              A plan to assure that Respondent will be able to address anticipated population growth in service area.
    
    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 the completion of the item to the address in paragraph 5. This documentation may be included with the monthly report that Respondent will be submitting to IDEM and the Indiana Utility Regulatory Commission (IURC).

     Upon completion of the work items contained in the CP, the Respondent shall be under a performance period during which the Respondent shall maintain compliance with the Monthly Average effluent limitations of its NPDES permit. The performance period will end after IDEM serves notice that six (6) consecutive months of compliance with Monthly Average effluent limitations have been achieved. The performance period may not extend beyond twelve (12) months after completion of the CP. Should Respondent fail to demonstrate six (6) consecutive months of compliance with monthly average effluent limitations within twelve (12) months of completion of the CP, then IDEM may, at its discretion, initiate an additional enforcement action.

     In order to obtain construction permits for additional connections, AquaSource shall submit a letter certifying treatment capacity for additional connections and documentation of changes made to account for additional capacity and show compliance with the milestone dates in the Agreed Order.

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

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

     As the violations occurred either before the AquaSource, Inc. assumed ownership of Respondent or as a result of conditions that existed prior to the assumption of ownership, the Respondent is not assessed a civil penalty for the violations referenced in this Agreed Order.

     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 submit compliance plan or
            revised compliance plan            $1,000 per week late

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

     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 civil penalties pursuant to IC 13-30-4.

     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 46207-7060

     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.

     Upon the Effective Date of this Agreed Order, the Agreed Order and all subsequent Amendments in Cause B-1391 are terminated and Cause B-1391 is closed.    

     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: ________________________
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 12/27/99
                            ___________________________
                            Felicia A. Robinson
                            Assistant Commissioner of Enforcement

Converted by Andrew Scriven