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STATE OF INDIANA    )            BEFORE THE INDIANA DEPARTMENT
                )    SS:
COUNTY OF MARION    )            OF ENVIRONMENTAL MANAGEMENT

COMMISSIONER OF THE DEPARTMENT    )
OF ENVIRONMENTAL MANAGEMENT,    )
                            )
                Complainant,        )
                            ) Cause No. H-12979
            v.                )
                            )
UNION TANK CAR COMPANY            )
                            )
                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 Union Tank Car Company ("Respondent"), who operates a company at 1100 East 145th Street, located in East Chicago, Indiana.

     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 April 8, 1997, to:

        R. A. Pritzker, President
        Union Tank Car Company
        225 West Washington
        Chicago, Illinois 60606



        U.S. Corporation, Resident Agent for
        Union Tank Car Company
        2 Market Square Center
        Indianapolis, Indiana 46204

     5.    Respondent submitted notification of hazardous waste activities to the United States Environmental Protection Agency (U.S. EPA) on December 26, 1989, as a large quantity generator of hazardous waste. Respondent paints the interior of railway cars. Respondent was assigned the U.S. EPA I.D. No. IND 173 429 903.

     6.    Based upon an investigation of the facility on September 23, 1996, by the Office of Solid and Hazardous Waste Management (hereinafter referred to as the "OSHWM") of the IDEM, the IDEM contends that the following violations were in existence or observed at the time of the inspection.

        a.    Pursuant to 40 CFR 262.34(a)(2) and (3), a generator must properly mark or label all hazardous waste containers. Based on information gathered by the IDEM, Respondent failed to properly label one (1) 55-gallon hazardous waste drum of MEK (F005), located in the container storage building. While the IDEM inspector was still at the facility, Respondent corrected the omission of the drum in question.

        b.    Pursuant to 40 CFR 262.11 and 40 CFR 268.7, a person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste using the methods described in 40 CFR 262.11, which include use of analytical testing or the generator's knowledge of the process that generates the solid waste and a determination of whether the waste is listed as a hazardous waste in subpart D of 40 CFR Part 261. Based on information gathered by the IDEM, Respondent had made a hazardous waste determination for the absorbent paper and wipes, used to clean the paint guns, based on Respondent's interpretation of 40 CFR Part 260. Respondent based its hazardous waste determination on its knowledge of the concentration of the solvent remaining on the wipes at the time they became a waste, and that the wipes contained a lower concentration of MEK than the threshold for characterizing the wipes as a hazardous waste due to ignitability or toxicity. The rags should be classified as a hazardous waste because of the listings in subpart D of 40 CFR Part 261.

        c.    Pursuant to 40 CFR 262.12(c) and IC 13-30-2-1(11), a generator must not offer his hazardous waste to transporters or to treatment, storage, or disposal facilities that have not received an EPA identification number.

Based on information gathered by the IDEM, Respondent offered hazardous waste absorbent paper and wipes, contaminated with MEK (F005), to Deercroft Recycling and Disposal Facility, which had not received an EPA identification number. Respondent disposed of the absorbent paper and wipes at Deercroft Recycling and Disposal Facility because Respondent had intended and believed that the absorbent paper and wipes would be subject to a special waste certification issued by IDEM to Respondent.

        d.    Pursuant to 329 IAC 3.1-7-3 and IC 13-30-2-1(12), a generator who transports, or offers for transport, hazardous waste for off-site treatment, storage, disposal, or recovery, must complete the manifest adopted by the Board. Based on information gathered by the IDEM, Respondent failed to use the manifest adopted by the Board for the hazardous waste absorbent paper and wipes contaminated with MEK (F005) that were transported and disposed at Deercroft Recycling and Disposal Facility. Respondent disposed of the absorbent paper and wipes without a manifest at Deercroft Recycling and Disposal Facility because Respondent had intended and believed that the absorbent paper and wipes would be subject to a special waste certification issued by IDEM to Respondent.

     7.    A settlement conference was held on May 6, 1997, to discuss the issues contained in this Agreed Order.

     8.    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.    Upon the effective date of the Order, Respondent shall ensure that all hazardous waste containers are properly marked or labeled, pursuant to 40 CFR 262.34(a)(2) and (3).

     3.    Upon the effective date of the Order, Respondent shall ensure that any and all absorbent paper and wipes contaminated with MEK (F005) shipped off-site are sent to a permitted treatment, storage, or disposal facility with the appropriate manifest and land disposal restriction notification.


     4.    Upon the effective date of the Order, Respondent shall not offer absorbent paper and wipes contaminated with MEK (F005) to a transporter or to a treatment, storage, or disposal facility that has not received an EPA identification number.

     5.    Respondent is assessed a civil penalty of $6,937.50. 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.

     6.    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
        IDEM
        100 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46206-7060

     7.    In the event that the civil penalty required by paragraph 5 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.

     8.    This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, and assigns. The 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.

     9.    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.

    10.    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 by contract require that all contractors, firms, and other persons acting for it comply with the terms of this Agreed Order.

    11.    This Agreed Order shall remain in effect until IDEM issues a Resolution of Cause letter to Respondent.


TECHNICAL RECOMMENDATIONS:            RESPONDENT:
Department of Environmental Management            Union Tank Car Company

By:    ________________________            By:    ________________________
    Nancy L. Johnston, Acting Chief
    Hazardous Waste Section                Title:    ________________________
    Office of Enforcement

Date:    ________________________            Date:    ________________________

LEGAL RECOMMENDATION:                COUNSEL FOR RESPONDENT:
Department of Environmental Management

By:    ________________________            By:    ________________________
    Loraine Seyfried/Scott Storms
    Office of Legal Counsel

Date:    ________________________            Date:    ________________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT
     OF ENVIRONMENTAL MANAGEMENT

    THIS _______ DAY OF ________________ 1997.

                                FOR THE COMMISSIONER:

                                ________________________
                                David J. Hensel
                                Director of Office of
                                 Enforcement

Converted by Andrew Scriven