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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-13762
            v.                )
                            )
STARCRAFT AUTOMOTIVE GROUP, 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. Pursuant to IC 13-30-3-3(c), entry into the terms of this Agreed Order does not constitute an admission of any violation contained therein.

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 Starcraft Automotive Group, Inc. (hereinafter referred to as "Respondent"), which operates a place of business, located at 2703 College Avenue, Goshen, 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 to:
        
        Kelly L. Rose, President        Michael Schoeffler, Registered Agent for
        Starcraft Automotive Group, Inc.    Starcraft Automotive Group, Inc.
        2703 College Avenue            2703 College Avenue
        Goshen, Indiana 46526        Goshen, Indiana 46526    
        
    5.    Respondent notified the U.S. EPA of its hazardous waste activities on February 13, 1984. The U.S. EPA I.D. No. of the facility is IND 057388266. Respondent operates as a large quantity generator of hazardous waste.
    
    6.    Respondent converts full-size vans and mini vans into luxury recreational vehicles.

    7.    IDEM contends that the following violations were in existence or observed by the Office of Solid and Hazardous Waste Management at the time of an inspection conducted on March 5, 1999.

            a.    Pursuant to 40 CFR 262.11 and 40 CFR 268.7(a), a person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste. If a generator's waste is hazardous, the generator must determine if the waste is restricted from land disposal under 40 CFR 268. Based on information gathered by IDEM, Respondent failed to make a proper hazardous waste determination and failed to determine if the waste is restricted from land disposal for the following waste streams:

                    (1)    Waste paint identified as a D001 hazardous waste by the facility. The waste paint contains spent lacquer thinner, consisting of toluene, methyl isobutyl ketone, and methyl ethyl ketone. Additionally, spent parts washer solvent that contains carburetor cleaner, consisting of xylene, methyl ethyl ketone, and acetone, is mixed with the waste paint. The waste paint should be identified as D001/F003/F005;

                    (2)    Two (2) 55-gallon drums, located in the southwest

corner of the less than ninety day storage area;

                    (3)    Spent rags used throughout the facility for wiping and cleaning, some which are contaminated with lacquer thinner. The facility generates 2,000 lbs/month of spent rags and disposes of them at the Allen County Landfill and the Elkhart County Landfill, special waste landfills; and

                    (4)    Spent spray booth filters generated at the UV Booth, Paint Booth, Prep Booth, Sealer Booth, and Varnish Booth. The spent filters are disposed of in the Allen County Landfill and the Elkhart County Landfill.

                         Waste paint has since been identified with the proper
                    waste codes, D001/F003/F005. The two (2) 55-gallon drums were identified as waste paint with the waste codes, D001/F003/F005. Respondent is managing and disposing of all spent rags and spray booth filters as hazardous waste.     

            b.    Pursuant to 40 CFR 262.12(c), a generator may only offer his hazardous waste to transporters and to treatment, storage, or disposal facilities that have received an EPA identification number. Based on information gathered by IDEM, Respondent offered hazardous waste to transporters and to treatment, storage, or disposal facilities that have not received an EPA identification number and/or that do not have a permit from IDEM. Specifically, Respondent offered spent rags contaminated with lacquer thinner for transport by National Serv-all, a solid waste transporter which does not have an EPA identification number, to the Allen County Landfill and the Elkhart County Landfill, special waste landfills that are not permitted by IDEM for treatment, storage, and disposal of hazardous waste.     

            c.    Pursuant to IC 13-30-2-1(12), 329 IAC 3.1-7-3, and 329 IAC 3.1- 7-4, 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 Indiana Solid Waste Management Board on EPA Form 8700-22. Based on information gathered by IDEM, Respondent offered hazardous waste for transport without completing the required manifests. Specifically,

Respondent offered spent rags contaminated with lacquer thinner for off-site transport by National Serv-all for disposal at the Allen County and Elkhart County Landfills without using the required Indiana hazardous waste manifest adopted by the Board.

            d.    Pursuant to 40 CFR 268.7(a)(2), with the initial shipment of waste to each treatment or storage facility, the generator must send a one-time written land disposal restrictions (LDR) notice to each treatment or storage facility receiving the waste, and place a copy in the file. Based on information gathered by IDEM, Respondent offered hazardous waste to treatment, storage, and disposal facilities without providing a one-time written LDR notice with the initial shipments. Specifically, Respondent offered spent rags contaminated with lacquer thinner for disposal at the Allen County Landfill and the Elkhart County Landfill without providing a one- time written LDR notice with the initial shipments.

            e.    Pursuant to 40 CFR 262.34(c)(1)(ii), a generator may accumulate as much as fifty-five (55) gallons of hazardous waste or one (1) quart of acutely hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with 40 CFR 262.34(a) provided that he marks his containers either with the words "Hazardous Waste" or with other words that identify the contents of the containers. Based on information gathered by IDEM, Respondent failed to label the following satellite accumulation containers of hazardous waste with the words "Hazardous Waste" or with other words to identify the contents of the containers:

                    (1) Four (4) 5-gallon containers of waste paint, located in the Paint Booth satellite accumulation area; and

                    (2) One (1) 5-gallon container of spent varnish, located in the Varnish Booth satellite accumulation area.

                
             f.    Pursuant to 40 CFR 262.34(c)(1)(i) referencing 40 CFR 265.173(a), a generator may accumulate as much as fifty-five (55) gallons of hazardous waste or one (1) quart of acutely hazardous waste in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of

the process generating the waste, without a permit or interim status and without complying with 40 CFR 262.34(a) provided the containers are kept closed, except when it is necessary to add or remove waste. Based on information gathered by IDEM, Respondent failed to keep the following containers closed, except when it was necessary to add or remove waste:

                    (1) Four (4) 5-gallon containers of waste paint, located in                      the Paint Booth satellite accumulation area;

                    (2) One (1) 5-gallon container of spent varnish, located in the Varnish Booth satellite accumulation area; and

                         (3) One (1) 55-gallon container of spent sealant, located in the UV Booth satellite accumulation area.

             g.    Pursuant to 40 CFR 262.34(a)(2), a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that the date upon which each period of accumulation begins is clearly marked and visible for inspection on each container. Based on information gathered by IDEM, Respondent failed to provide the start of accumulation date on the following containers of hazardous waste, located in the less than ninety day storage area:

                    (1) Four (4) 55-gallon containers of sealant and topcoat;

                    (2) Five (5) 55-gallon containers of floor sealant;

                    (3) Two (2) 55-gallon containers of unidentified waste; and

                    (4) One (1) 55-gallon container of sikaflex adhesive.

             h.    Pursuant to 40 CFR 262.34(a)(3), a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that, while being accumulated on-site, each container and tank is labeled or marked clearly with the words "Hazardous Waste." Based on information gathered by IDEM, Respondent failed to label the following containers of hazardous waste, located in the less than ninety day storage area, with the words "Hazardous Waste:"

                    (1) Four (4) 55-gallon containers of sealant and topcoat;


                    (2) Five (5) 5-gallon containers of floor sealant;

                    (3) Two (2) 55-gallon containers of unidentified waste; and

                    (4) One (1) 55-gallon container of sikaflex adhesive.     
             i.    Pursuant to 40 CFR 262.34(b), IC 13-30-2-1(10), and 40 CFR 270.1(c), a generator who accumulates hazardous waste for more than ninety (90) days is an operator of a storage facility and is subject to the requirements of 40 CFR Part 264 and the permit requirements of 40 CFR Part 270. A person may not commence or engage in the operation of a hazardous waste facility without having first obtained a permit from IDEM. Based on information gathered by IDEM, Respondent stored hazardous waste for greater than ninety (90) days without obtaining a permit from IDEM or complying with the 40 CFR Part 264 requirements. One (1) 55- gallon container of waste paint (D001/F003/F005) in the less than ninety day storage area was dated February 5, 1998, indicating that the container had been stored greater than ninety (90) days.

             j.    Pursuant to 329 IAC 3.1-1-10, every hazardous waste generator, transporter, or owner or operator of a hazardous waste facility shall notify the Commissioner of such activities on forms provided by the Commissioner. Based on information gathered by IDEM, Respondent failed to notify the Commissioner of its hazardous waste storage activities.
    
            k.    Pursuant to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.171 40 CFR 265.173(b), a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that, if a container holding the hazardous waste is not in good condition, or if it begins to leak, the hazardous waste is transferred from this container to a container that is in good condition, or managed in a way that ensures compliance with this requirement. A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak. Based on information gathered by IDEM, Respondent stored two (2) 55- gallon containers of spent sealant and two (2) 55-gallon containers of waste paint, located in the less than ninety day area, in poor condition. Respondent failed to transfer the hazardous waste from the damaged containers to containers in good condition, or manage the waste in some other way to ensure compliance with the

requirement. Both of the spent sealant containers were bulging and one was dented. Of the two waste paint containers, one container had a hole punctured in the side and the other container was bulging and showed evidence of leakage. The latter container had been stored for greater than ninety (90) days.

             l.    Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.16, a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that facility personnel involved with hazardous waste management are provided with a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures compliance with 40 CFR 265.16. Based on information gathered by IDEM, Respondent failed to provide facility personnel involved in hazardous waste management with the required training specific to their particular duties. Respondent had provided employees with OSHA Hazwoper training, but not with training specific to their hazardous waste duties.    

             m.    Pursuant to 40 CFR 262.34(a)(1)(i) referencing 40 CFR 265.174, a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that areas where containers are stored are inspected at least weekly in order to look for leaks and for deterioration caused by corrosion or other factors. Based on information gathered by IDEM, Respondent failed to conduct weekly inspections of the less than ninety day storage area for leaks and for deterioration caused by corrosion or other factors.

             n.    Pursuant to 40 CFR 262.34(a)(4) referencing 40 CFR 265.31, a generator may accumulate hazardous waste on-site for ninety (90) days or less without a permit or without having interim status provided that the facility is maintained and operated to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Based on information gathered by IDEM, Respondent failed to maintain the facility to minimize the possibility of a fire, explosion, or release of hazardous waste or hazardous waste constituents. Specifically, Respondent stored two (2) bulging 55-gallon containers of spent sealant, one (1) bulging 55-gallon container of waste paint, and one (1) punctured 55- gallon container of waste paint in the less than ninety day storage

area. One of the containers of spent sealant was dented and the bulging container of waste paint showed signs of leakage.

            o.    Pursuant to 329 IAC 13-4-3(d), containers and aboveground tanks used to store used oil at generator facilities must be labeled or marked clearly with the words "Used Oil." Based on information gathered by IDEM, Respondent failed to label one (1) 55-gallon container of used oil, located at the maintenance shop, with the words "Used Oil."
                                             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 her delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the effective date.

    2.    In the future, Respondent shall ensure that it makes a proper hazardous waste determination, including whether the waste is restricted from land disposal, for all waste streams generated at the facility.
        
    3.    Upon the effective date of the Order, Respondent shall ensure that spent rags contaminated with lacquer thinner are properly managed, transported, and disposed of as hazardous waste, or document to IDEM that the rags are being laundered.

    4.    Upon the effective date of the Order, Respondent shall ensure that spent spray booth filters are properly managed, transported, and disposed of.

    5.    In the future, Respondent shall ensure that no hazardous waste is stored at the facility for greater than ninety (90) days without a permit from IDEM.
    
    6.    Within sixty (60) days of the effective date of this Order, Respondent shall decontaminate the container storage area where waste was stored for greater than ninety (90) days, and document to the IDEM that it has been completed, in the following manner:

        a.    Remove all wastes from the pad;
    
        b.    Mechanically clean the pad by scraping, sweeping, or other methods to

remove all physical contamination;

        c.    Inspect the pad for cracks. If cracks are detected, perform Item i. at this point;

        d.    Wash the pad with a high pressure steam cleaner, mop, or other means with detergent or appropriate solvent to remove the previously stored waste materials;

        e.    Rinse the pad three (3) times with water;

        f.    The third (final) rinsate shall be collected separately and analyzed to show that the pad's surface meets the cleanup level. The cleanup level of the rinsate shall be based on the Maximum Contaminant Levels (MCLs) of the National Primary Drinking Water Regulations (40 CFR 141) and 40 CFR 264.94(a)(2) for inorganic and certain organic parameters with MCLs and the Practical Quantitation Limits (PQLs) as defined by SW- 846 for the organic parameters without MCLs (PCBs, chlorinated dioxins, volatile organic compounds, and semi-volatile organic compounds) previously stored on the pad;

        g.    Respondent shall ensure that care is taken to prevent migration of cleaning liquids from the pad area;

        h.    All residues and rinsates shall be collected and disposed as hazardous waste unless the residues and rinsates are analyzed and determined to be nonhazardous;

        i.    The soil, underlying the cracks found in the inspection, shall be sampled for contamination within thirty (30) days of the effective date of the Order. If no contamination is found, seal the cracks and proceed with d. through h. If contamination is found, Respondent shall submit to the IDEM for approval, a closure plan for the pad in accordance with the provisions of 40 CFR 264, Subpart G, within forty-five (45) days of the effective date of the Order. Upon notice of approval of the closure plan by the IDEM, Respondent shall implement the approved plan in accordance with the time frames contained therein.
        
    7.    Upon the effective date of the Order, Respondent shall ensure that all containers holding hazardous waste in less than ninety day accumulation areas at the facility are clearly marked with the words "Hazardous Waste," per 40 CFR 262.34 (a)(3).

    8.    Upon the effective date of the Order, Respondent shall ensure that all satellite

accumulation containers holding hazardous waste at the facility are marked with the words "Hazardous Waste" or with other words to identify the contents of the containers, per 40 CFR 262.34(c)(1)(ii).

    9.    Upon the effective date of the Order, Respondent shall ensure that all containers holding hazardous waste at the facility in less than ninety (90) day accumulation areas are provided with the date upon which each period of accumulation begins, per 40 CFR 262.34(a)(2).

    10.    Upon the effective date of the Order, Respondent shall ensure that all containers holding hazardous waste at the facility are kept closed, except when it is necessary to add or remove waste, per 40 CFR 265.173(a).

    11.    Upon the effective date of the Order, Respondent shall ensure that it complies with all training requirements of 40 CFR 265.16.

    12.    Upon the effective date of the Order, Respondent shall ensure that all containers holding hazardous waste at the facility are opened, handled, and stored in a manner that does not cause them to rupture or leak, and that if a container is not in good condition, or if it begins to leak, the hazardous waste is transferred from this container to a container that is in good condition, or managed in a way that ensures compliance with 40 CFR 265. At all times, Respondent shall maintain and operate the facility to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.

    13.    Upon the effective date of the Order, Respondent shall ensure that at least weekly inspections are conducted at the less than ninety day container storage area.

    14.    Upon the effective date of the Order, Respondent shall ensure that all containers used to store used oil at the facility are labeled or clearly marked with the words "Hazardous Waste," per 329 IAC 13-4-3(d).    

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

        Brenda J. Lepter        
        Office of Enforcement
        Hazardous Waste Section
        Indiana Department of
         Environmental Management
        P.O. Box 6015

        Indianapolis, Indiana 46206-6015

     16.    Respondent is assessed a civil penalty of $59,812.48. Said penalty amount shall be due and payable to the Environmental Management Special Fund in four (4) installments of $14,953.12 each. The first installment is due within thirty (30) days of the effective date of this Agreed Order and the remaining payments are due in quarterly installments thereafter.

     17.    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

        Failure to comply with the time frame            $ 1000 per day
        requirements of Order No. 6 of the Agreed Order.                         

     18.    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 any 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.

     19.    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
        IDEM
        100 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46207-7060

     20.    In the event that the civil penalty required by paragraph 16 is not paid within the time frames contained in 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.

     21.    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.

    22.    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.

    23.    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.

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

TECHNICAL RECOMMENDATIONS:            RESPONDENT:
Department of Environmental Management            

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

Date:    ________________________            Date:    ________________________

LEGAL RECOMMENDATION:                COUNSEL FOR RESPONDENT:
Department of Environmental Management

By:    ________________________            By:    ________________________
    Office of Legal Counsel

Date:    ________________________            Date:    ________________________


APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT
     OF ENVIRONMENTAL MANAGEMENT

    THIS _______ DAY OF ________________ 1999.

    
                            For the Commissioner:

    Signed on 10/29/99
                            ________________________
                            Felicia A. Robinson
                            Assistant Commissioner
                            Office of Enforcement    

Converted by Andrew Scriven