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VIA CERTIFIED MAIL:

    INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

STATE OF INDIANA            )    BEFORE THE INDIANA
                        )SS:    DEPARTMENT OF
COUNTY OF MARION            )    ENVIRONMENTAL MANAGEMENT
                        )
COMMISSIONER, INDIANA        )
DEPARTMENT OF                )
ENVIRONMENTAL MANAGEMENT,    )
                        ) Cause B-2506
            Complainant,        )
                        )
                        )
LAKE & FOREST CLUB, INC.        )
                        )
                        )
            Respondent        )

NOTICE OF UNLAWFUL ACTS AND
ORDER TO CEASE AND DESIST UNLAWFUL ACTS

    Follows is a Notice of Unlawful Acts and an Order to Cease and Desist Unlawful Acts of the Commissioner of the Indiana Department of Environmental Management issued to Lake & Forest Club, Inc. This Notice and Order is issued pursuant to IC 13-18-4-6 and IC 4-21.5-4.

NOTICE OF UNLAWFUL ACTS

    1. Complainant is the Commissioner (hereinafter referred to as "Complainant") of the Indiana Department of Environmental Management (hereinafter referred to as "IDEM"), a department of the State of Indiana created by Indiana Code (IC) 13-13-1-1.

    2. Respondent is Lake & Forest Club, Inc., which owns and operates a wastewater collection and treatment facility in Jackson County.

    3. The Complainant has jurisdiction over the Respondent and the subject matter of this action.

    4. IC 13-30-2-1 states, in substance, that no person may emit or allow or threaten to emit or allow any contaminant, either alone or in combination with contaminants from other sources, into the environment which causes pollution that violates rules, standards, or discharge requirements of the state.

    5. IC 13-18-4-5 states, in part, that it is unlawful for any person to throw, run, drain, or otherwise dispose into any of the streams or waters of the 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.

    6. 327 IAC 5-2-2 states, in substance, 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. 327 IAC 2-1-6(a)(1) states, in part, that all waters at all times and at all places shall meet the minimum conditions of being free from substances and materials attributable to discharges that are in amounts sufficient to produce conditions in such a degree as to create a nuisance or in amounts sufficient to severely injure or kill aquatic life.
    
    8. In September of 1978, the Respondent's National Pollutant Discharge Elimination System (NPDES) Permit, which authorized the discharge of treated wastewater from the Lake & Forest Club, Inc. wastewater treatment facility to waters of the state, was voided at the Respondent's request, due to the construction by the Respondent of an absorption field. Accordingly, since September of 1978, the Respondent has not had authorization to discharge wastewater from the Lake & Forest Club, Inc. wastewater treatment facility to waters of the state.
    9. On January 3, 1995, the Jackson County Health Department performed a dye test of the absorption field to determine whether there was a discharge of wastewater from the absorption field to waters of the state. The test results revealed that the dye that was deposited in the absorption field was discharged into an unnamed tributary ditch, which flows directly into Hough Creek.

    10. On March 25, 1996, IDEM representatives met with representatives of Lake & Forest Club, Inc. to discuss the unlawful discharge of wastewater to waters of the state. During the meeting, IDEM representatives collected two samples from the wastewater treatment plant. The first sample was taken from the top of the sand beds where wastewater was discharging over the sidewalls to waters of the state. The second sample was taken from the unnamed tributary ditch where the presence of dye was found as a result of the January 3, 1995 dye test conducted by the Jackson County Heath Department. The sample results revealed elevated levels of ammonia, total

phosphorus, CBOD, total suspended solids, and E. coli bacteria.

    11. As a result of the meeting, Lake & Forest Club, Inc. committed to eliminating the unlawful discharge by either upgrading the wastewater treatment plant or connecting the subdivision to the Town of Brownstown's wastewater treatment plant.

    12. On January 14, 1997, an IDEM representative conducted an inspection of the
Lake & Forest Club, Inc. wastewater treatment facility and observed and documented a discharge of wastewater from the facility to waters of the state.

    13. In a letter dated January 29, 1997, IDEM advised Lake & Forest Club, Inc. of the results of the January 14, 1997 inspection and requested the submittal of a written response setting forth the actions which would be taken to rectify the problem.

    14. A response letter, dated March 3, 1997, advised IDEM of the following: a) that a study conducted by Sieco Engineering indicated that an appropriate solution for the facility would be to abandon the treatment facility and connect to the Town of Brownstown Wastewater Collection system; b) that a proposal was presented to and preliminarily approved by the Brownstown Town Council, with final approval contingent upon review of detailed plans and specifications; and c) that detailed plans and specifications for the project would be completed in the near future and presented to the Town of Brownstown for final acceptance.

    15. On February 20, 1998, an IDEM representative conducted an inspection of the Lake & Forest Club, Inc. wastewater treatment facility and observed and documented a discharge of wastewater from the facility to waters of the state.

    16. In a letter to IDEM dated March 11, 1998, the president of Lake & Forest Club, Inc., David Jungclaus, advised IDEM that agreement had been reached with the Jackson County Fair Board for easements to run sewer lines across their property and that as soon as approval from the Town of Brownstown was received, a proposal would be submitted to IDEM. To date, no proposal for connection to the Town of Brownstown or for otherwise eliminating the unlawful discharge of pollutants to waters of the state has been received by IDEM.

     17. On July 14, 1999 an IDEM representative conducted an inspection of the Lake & Forest Club, Inc. wastewater treatment facility and observed and documented a discharge of wastewater to waters of the state.
    
    18. On September 21, 1999 an IDEM representative discussed this matter with Mr.
Tom Bryant, Chairman of the Sewer Committee for Lake & Forest Club, Inc. Mr. Bryant advised that Lake & Forest Club, Inc. was in the process of obtaining approval from the Town of Brownstown to connect to the town.

    19. The discharge of pollutants to waters of the state without a valid NPDES Permit is in violation of IC 13-30-2-1, IC 13-18-4-5, 327 IAC 5-2-2, and 327 IAC 2-1-6(a)(1).

ORDER TO CEASE AND DESIST UNLAWFUL ACTS

    1. Respondent shall immediately undertake corrective measures to improve the condition and operation of the existing wastewater treatment facility such that discharge of pollutants to waters of the state is minimized.

    2. Respondent shall, within seven (7) days of receipt of this Order, advise the IDEM, in writing, of the corrective measures which have been taken by the Respondent.

    3. Respondent shall, within seven (7) days of receipt of this Order, submit to the IDEM a plan, which includes an implementation and completion schedule, for eliminating the unlawful discharge of pollutants to waters of the state. The plan is subject to the approval of the IDEM. If the plan is deemed inadequate, the Respondent shall, within seven (7) days of receiving notice from the IDEM that the plan is inadequate, submit a revised plan to the IDEM. If the revised plan is deemed inadequate, the IDEM may specify the corrective measures which are to be taken and time frames for completion.

    4. Respondent shall, within forty-eight (48) hours of receipt of this Order, notify the IDEM in writing of its intent to comply with this Order.

    5. All submittals required by this Order shall be directed to the attention of:

         Mr. Mark Stanifer, Chief, Water Enforcement Section
        100 North Senate Avenue
        P.O. Box 6015
        Indianapolis, Indiana 46206-6015

THIS ORDER IS EFFECTIVE UPON ISSUANCE

    1. A party affected by this Order may request a hearing under IC 4-21.5-4-4 by submitting a written request to the Commissioner at the aforementioned address.

    2. This order expires ninety (90) days from the date of issuance and is subject to renewal under IC 4-21.5-4-5.

    3. Violation of this order may be enforced in civil court.

    4. Pursuant to IC 13-30-6-1, a person who intentionally, knowingly, or recklessly violates water pollution control laws commits a class D felony.


    5. Pursuant to IC 13-30-4-1, a person who violates an order made or issued by the commissioner under water pollution control laws is liable for a civil penalty not to exceed twenty- five thousand dollars ($25,000) per day of any violation.

Dated this _______ day of ___________________, 1999.

Original signed by Lori F. Kaplan, November 4, 1999

                            ___________________________
                            Lori F. Kaplan, Commissioner    

Converted by Andrew Scriven