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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-1862
                            )
                            )
COUNTRY AUTO PARTS,            )
BRADLEY TRIMBLE                )
                            )
            Respondent.            )

AGREED ORDER

    The Complainant and the Respondent(s) 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 13-7-2-11.

    2.    Respondent is Bradley Trimble, who owns Country Auto Parts, located in Spencer, Indiana.

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

    4.    Pursuant to IC 13-7-11-2(b) (currently IC 13-30-3-3) , on July 8, 1996, IDEM issued a Notice of Violation via Certified Mail to:

                Bradley Trimble, Owner
                Country Auto Parts
                RR 3 Box 531
                Spencer, IN 47460
        


    5.    327 IAC 15-6-2 establishes requirements for point source discharges of storm         water associated with industrial activity. The requirements under this rule apply         to all persons who:

        a.    are not prohibited from regulation under a NPDES general permit rule             under 327 IAC 15-2-6;

        b.    meet the NPDES general permit rule applicability requirements under 327 IAC 15-2-3; and

        c.    have a new or existing point source discharge composed entirely of storm water associated with industrial activity, except for categories in effect on February 12, 1992, of facilities that have storm water effluent guidelines for at least one of their subcategories.

    6.    327 IAC 15-6-4 (2) defines "storm water discharge associated with industrial         activity" as the discharge from any conveyance which is used for collecting and conveying storm water and which is directly related to manufacturing, processing, or raw materials storage areas at an industrial plant. 327 IAC 15-6-4 (2)(F) includes facilities involved in the recycling of materials, including metal scrap yards, battery reclaimers, salvage yards, and automobile junk yards, including but not limited to those classified as SIC codes:

            (i) 5015 (motor vehicle parts, used); and
            (ii) 5093 (scrap and waste materials).

    7.    327 IAC 15-6-6 establishes that "All information required under 327 IAC 15-3         and section 5 of this rule shall be submitted to the commissioner in accordance         with 327 IAC 15-3-3, except , for persons that operate under 327 IAC 15-5 and         that are affected by this rule, the NOI letter shall be submitted one hundred eighty         (180) days before completion of construction."

    8.    On June 1, 1995, IDEM inspected the area of the site and noted that the auto parts         facility should be operating under a general stormwater permit, as required by 327         IAC 15-6. Some erosion of soil sediments was observed to have reached              adjoining property. At a subsequent site visit on April 24, 1996, straw bales were          found to be installed along the east perimeter in an attempt to prevent sediment from escaping site. These bales were in need of maintenance and replacement at one or two points where sediment had recently escaped to neighbor's property. There were no waters of the state on the east perimeter, however, and sediment had only reached a distance of about fifty feet beyond the perimeter.

        Tires had been stacked across a natural drainage ditch leading from the south edge of the auto junkyard, also in an effort to prevent sediment from escaping to an intermittent-stream ditch leading through a wooded area of several acres. No

serious damage was seen in the area, however there was a sandy soil sediment in the ditch channel. No auto parts or fluid residue was noted except one tire laying outside the property line and a light sheen on a puddle of water inside the property line.

        In a follow-up phone call, IDEM suggested to the owner's representative that the straw bales be replaced and maintained where deteriorated on the east property line and tires be better maintained on the south property line. IDNR was also contacted for suggestions on sediment control for the facility.

    9.    Based on information described in a June 8, 1995 IDEM letter sent to Respondent,         Respondent violated the requirements of 327 IAC 15-6 by failing to apply for a         general stormwater permit and was asked for a Notice of Intent (NOI) letter.         Respondent's facility description fits that of the category of industries involved in recycling of materials, including metal scrap yards, salvage yards, and automobile junkyards. The deadline for submitting an application was December 29, 1992, and was so noted in the letter. A subsequent telephone conversation with IDEM confirmed the need for submission of an NOI.

    10.    Respondent failed to submit the initial information by December 29, 1992, as         required and further failed to submit the information as subsequently requested within thirty (30) days of receiving the June 8, 1995 IDEM letter described above. Respondent is therefore in violation of 327 IAC 15-6.

    11.    Respondent did immediately call Complainant upon receiving the Notice of         Violation and promise full cooperation toward resolving the problem, however         noting it is a small recycling business with little available financial capital.              Respondent requested assistance in determining the best method to comply.         Respondent also requested a telephone conference call in lieu of a settlement         conference to negotiate the civil penalty. IDEM agreed that a telephone              conference was acceptable as soon as some progress was achieved by Respondent         toward resolving the problems. IDEM immediately requested and was granted         limited technical assistance for Respondent from IDNR and provided a list of Best         Management Practices on September 25, 1996.

    12.    Further discussions in October and November, 1996 led to the realization that soil         samples would be necessary to determine whether further remediation measures are needed at the site. Also, Respondent will need to hire a professional engineer or other appropriately trained engineer for certification of Respondent's storm water pollution prevention plan. These discovered needs were made known to Respondent in a November 22, 1996 letter from IDEM.

    13.    IDEM inspected the site again on April 9, 1997, following renewed complaints         from the neighbor and no progress reported by Respondent. Sediment erosion to         the neighbor's property was found to have increased, and the perimeter straw bales

were again in need of replacement. Discussions with Respondent's representatives indicated no progress had yet occurred.

    14.    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.    Within thirty (30) days of the Effective Date of this Agreed Order, the Respondent         shall submit a complete Notice of Intent (NOI) letter, as required by 327 IAC 15- 6.

    3.    Within thirty (30) days of the Effective Date of this Agreed Order, the Respondent         shall also submit a plan to conduct appropriate and representative soil sampling         and analysis of the site for Total Petroleum Hydrocarbons (TPH), as an indicator of the extent and location of any potentially contaminated groundwater.

    4.    Upon submission of the NOI letter, Respondent shall begin developing and         implementing a pollution prevention plan.

    5.    Within sixty (60) days of submission of the NOI, the Respondent shall submit an acceptable stormwater pollution prevention plan, as required by 327 IAC 15-6-7. Such plan shall include time tables for compliance with the terms of the plan. The plan shall be incorporated into and made an enforceable part of this Agreed Order.

    6.    Within sixty (60) days of soil sampling, analyses results shall be submitted to         IDEM, including a copy of the chain of custody record. If sample analyses         indicate TPH concentration of greater than one hundred (100) grams per kilogram,         then Respondent shall submit a signed statement to be included with the analyses         results to certify that Respondent will take appropriate steps to remediate any and         all environmental damages at the site.

    7.    If site remediation is found to be necessary, Respondent shall submit a plan         of action, including a schedule of milestone dates, within ninety (90) days of         submitting soil sample analyses results and certification statement required by         Paragraph six (6) above.

    8.    The stormwater pollution prevention plan, as required by 327 IAC 15-6, shall be completely implemented within sixty (60) days after submission of the NOI.


    9.    If site remediation is found to be necessary, Respondent shall complete all          necessary work within one (1) year of the date of adoption of this Agreed Order,

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

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

    11.    Respondent is assessed a Civil Penalty of Five Hundred Dollars ($500). 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.

    12.    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

            Paragraphs 2, 3            $500 per week either the NOI or                                 soil analyses is late being submitted;

            Paragraph 4                $500 per week the pollution                                      prevention plan is late being                                      submitted or milestones contained                                  therein are late in being                                      implemented;

            Paragraph 5                $500 per week the complete                                      implementation of the milestone                                  dates contained in the plan are late                                  being implemented.

            Paragraphs 6, 9            $500 per week sample analyses                                 and/or signed statement not                                      submitted, and/or remediation not                                 completed, if necessary.

    13.    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 13-7-13.

    14.    Civil and stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the Cause Number (B-1862) of this action and shall be mailed to:

                Cashier
                IDEM
                100 N. Senate Avenue
                P.O. Box 7060
                Indianapolis, Indiana 46206-7060.

    15.    In the event that the civil penalty required by paragraph 11 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.

    16.    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.

    17.    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.

    18.    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.

    19.    This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order.



TECHNICAL RECOMMENDATION            RESPONDENT

By: _________________________                By: _________________________
    Mark W. Stanifer, Chief                    Bradley Trimble, owner
    Water Enforcement Section                    Country Auto Parts         Office of Enforcement                
    Department of Environmental            
     Management

Date:                 Date: _______________________

COUNSEL FOR COMPLAINANT            COUNSEL FOR RESPONDENT

By:                 By: _________________________
    Office of Legal Counsel                                      Department of Environmental            Printed:
     Management

Date:                     Date: _______________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS ______________ DAY OF ___________________, 1997.

                            For the Commissioner:

                            Signed on 6/30/97
                            Patrick Carroll
                            Director
                            Office of Enforcement

Converted by Andrew Scriven