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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-1278
                            )
                            )
TOWN OF GRANDVIEW,         )
                        )
            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.

    2.    Respondent is the Town of Grandview, which operates its municipal wastewater treatment system located in Grandview, Spencer County, Indiana. The two-cell Class I waste stabilization lagoon system is designed for 0.12 million gallons per day and is authorized to discharge at Outfall 001 under the terms and conditions of National Pollutant Discharge Elimination System (NPDES) permit No. IN 0038300.

    3.    The IDEM has jurisdiction over the parties and subject matter of this action.


    4.    Pursuant to IC 13-30-3-3 (formerly IC 13-7-11-2), IDEM issued a Notice of Violation via Certified Mail on January 29, 1990, to:

                Ms. Claudia Stuteville, President
                Town Council of Grandview
                P.O. Box 638
                Grandview, Indiana 47615        

    5.    Designated representatives of the IDEM conducted inspections of Respondent's wastewater treatment facility on April 21, 1989, and September 18, 1989. Based on the inspections and a record review, Respondent was found in violation of the following provisions of the Indiana Code (IC) and the Indiana Administrative Code (IAC).

         6.    327 IAC 5-2-2 states, in part, that any discharge of pollutants into waters of the state as a point source discharge, except for exclusions made in 327 IAC 5-2-4, is prohibited unless in conformity with a valid NPDES permit obtained prior to the discharge.

    7.    IC 13-30-2-1 (formerly IC 13-7-4-1) 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.

          IC 13-18-4-5 (formerly IC 13-1-3) 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.

          The following conditions in 327 IAC 5-2-8 are included in Respondent's NPDES permit No. IN 0038920:

        a.    The permittee must comply with all terms and conditions of the permit. Any permit 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.

    10.    On April 21, 1989, IDEM field staff conducted an inspection of Respondent's wastewater treatment facility. During the inspection it was determined the Respondent allowed the discharge of lagoon effluent from an effluent pipe line manhole to enter the wetland area east of the lagoons. Also, no flow meter was in service for measurement of the volume of influent or effluent. The deficiency in flow monitoring was also noted in the inspection on September 18, 1989. Proper documentation of sampling was not being done as required by the NPDES permit. Monthly reports of operation were not submitted as required by the permit. Respondent's failure to document sampling, submit complete reports, and accurately measure the flow of wastewater constitute violations of the NPDES permit and 327 IAC 5-2-8. Respondent's unauthorized discharge to the wetland area constitutes violation of the NPDES permit, 327 IAC 5-2-2, IC 13-30-2-1 (formerly IC 13-7-4-1), and IC 13-18-4-5 (formerly IC 13-1-3).

    11.    The IDEM record review of Respondent's 1990 evaluation of the factors involved in the unauthorized discharge from effluent manholes east of the lagoon reveals that the approximate 7000 feet of effluent pipe line from the lagoon to Outfall 001 was constructed with a diameter and slope that limits the volume per day it could convey to the receiving stream. The attempt to release more volume per day than the effluent pipe could carry resulted in the overflow from an effluent manhole.

    12.    The IDEM report of an inspection of the Grandview wastewater treatment facility, dated June 1, 1998, reveals that the Respondent is currently in compliance with sampling and reporting requirements of the NPDES permit. There was no discharge from the lagoons at the time of the inspection.

    13.    The Respondent has recently used a temporary V-notch weir and Stevens head recorder for effluent measurement. The Respondent must arrange for accurate influent and effluent measurement, assure elimination of discharges from effluent manholes to the wetlands east of the lagoons, and develop a plan to identify and reduce the infiltration and inflow into its sanitary sewer system.

          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 terms and conditions of its NPDES permit No. IN 0038300 and applicable sections of the Indiana Code and the Indiana Administrative Code.

         Within ninety (90) days of the Effective Date of this Agreed Order, Respondent shall develop and submit to IDEM a Work Plan for IDEM approval. The Plan shall include Respondent's schedule for achieving accurate influent and effluent monitoring, elimination of unauthorized discharge from manholes along the lagoon effluent pipe, and identification and reduction of inflow and infiltration sources in the municipal sewer system. Respondent shall respond within the time frame of any requested revision of the Plan. Respondent shall implement the approved Plan according to its milestone schedule.

         All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:
                Paul Cluxton, Case Manager
                Office of Enforcement
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 6015
                Indianapolis, IN 46206-6015

         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 Failure to submit Work Plan, make requested $500 per week late revisions, or implement the approved Plan


    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.    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:
                
                IDEM Cashier
                100 N. Senate Avenue
                P.O. Box 7060
                Indianapolis, Indiana 46207-7060.

    8.    In the event that any stipulated civil penalty amounts assessed by paragraph 5 are 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.

         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

                            
By: _________________________                By: _________________________
    Mark W. Stanifer, Chief                 Steve Haaff, President
    Water Enforcement Section                 Town Council of Grandview
    Office of Enforcement                Date: _______________
    Department of Environmental
     Management

Date: _______________                    

COUNSEL FOR COMPLAINANT        COUNSEL FOR RESPONDENT

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 _______________________, 1998.

                            For the Commissioner:

                            _signed January 21, 1999_
                            Felicia Robinson George
                            Assistant Commissioner of Enforcement

Converted by Andrew Scriven