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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-2287
                            )
DAVID SHOCKLEY,                )
                            )
        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 (the "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 David Shockley (the "Respondent"), who is the developer of the six (6) lot housing project located in the 1600th block of Henry Street in Huntington, Indiana (the "Project"). Development of the Project included the construction of a sanitary sewer extension measuring approximately two hundred ninety five (295) feet in length.

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

4.    Pursuant to IC 13-30-3-3, on March 9, 1998, IDEM issued a Notice of Violation via Certified Mail to:
                     David Shockley
                     3446 North, 300 East
                    Huntington, Indiana 46750


     327 IAC 3-2-1 states, "No person shall cause or allow the construction, installation, or modification of any water pollution treatment/control facility or sanitary sewer, without a valid construction permit issued by the commissioner."

     327 IAC 3-2-2 (b) states, "A completed application shall be submitted together with the required plans, specifications, and description of project a minimum of sixty (60) days in advance of the proposed date of start of construction. Construction shall not commence until all necessary state approvals and permits are obtained."

     327 IAC 4-1-4 (a) states, "Whenever, in the determination of the commissioner, hydraulic or organic overloading of a semipublic facility or POTW exists or is impending and the introduction into the semipublic facility or POTW of additional wastewater from new or existing sources is likely to result in the discharge or bypassing of insufficiently treated sewage, the commissioner may impose a ban on further sewer connections to the semipublic facility or POTW."

     327 IAC 4-1-4 (b) states, "Such sewer connection ban shall prohibit the connection or introduction of additional wastewater or sewage into the semipublic facility or POTW, except as otherwise provided under this article."

     The Huntington Municipal Waste Water Treatment Plant was placed on a sewer connection ban, pursuant to 327 IAC 4-1-4 (a), on August 27, 1993. This ban was still in effect on January 13, 1998. The sewer ban was lifted by IDEM on March 26, 1998.

     The violations of the above noted rules are based on a January 9, 1998, record review and a January 13, 1998, complaint investigation conducted by designated representative(s) of IDEM. The record review and complaint investigation indicate that the Respondent did not submit a completed application within sixty (60) days in advance of the proposed date of start of construction of the sanitary sewer extension included in construction of the Project. Additionally, the record review and complaint investigation indicate that the Respondent did not receive permission from the City of Huntington to connect the sanitary sewer extension to the Huntington Municipal Waste Water Treatment Plant's collection system.

     The Respondent has violated 327 IAC 3-2-1 in that the Respondent allowed the construction of a sanitary sewer without a valid construction permit issued by the commissioner.

     The Respondent has violated 327 IAC 3-2-2 (b) in that the Respondent did not submit a completed application together with the required plans, specifications, and description of project a minimum of sixty (60) days in advance of the proposed date of start of construction.

     The Respondent has violated 327 IAC 4-1-4 (b) in that the Respondent allowed the connection or introduction of additional wastewater or sewage into the POTW when such connection or introduction of additional wastewater or sewage into the POTW was prohibited by a sewer connection ban.

     Subsequent to the issuance of the NOV, Respondent sold the Henry Street property. The City of Huntington did not find the sewers as-built to be acceptable and informed Respondent that they would not be accepted. The new owner is Stan Dyke. There are no plans by the new owner to construct additional homes on this location, and the sewer which was illegally constructed will not be used.

     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, the Respondent shall submit a written certification that the sewer line which was installed will not be used.

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

                Terry Ressler, Case Manager, Water Enforcement
                Office of Enforcement
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 6015
                Indianapolis, IN 46206-6015

4.    Respondent is assessed a civil penalty of Three Thousand Dollars ($3,000). 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.

5.    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:

        Paragraph 2                    $500 per weekfor failure to timely submit the certification

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 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.

7.    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
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 7060
                Indianapolis, IN 46207-7060

8.    In the event that the civil penalty required by Paragraph 4 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.

9.    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.

10.    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.

11.    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.

12.    This Agreed Order shall remain in effect until Respondent has complied with Paragraphs 2 and 4 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: ________________________
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:

                        Original signed by David Hensel August 19, 1998                                                                              David J. Hensel
                            Director
                            Office of Enforcement

Converted by Andrew Scriven