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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,            )
                            )    CAUSE No. SW-281 & A-3275
            v.                )
    )
ARNOLD & DOVIE HOUSE    )
                            )
            Respondents.            )

AGREED ORDER

    The Complainant and the Respondents 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, entry into the terms of this Agreed Order does not constitute an admission of any violations contained herein.

I. FINDINGS OF FACT

     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.

     Respondents are Arnold & Dovie House (hereinafter referred to as "Respondents"), who own the property located at 255 North Clark Road, Gary, Lake County, Indiana ("Site").

     The Indiana Department of Environmental Management ("IDEM") has jurisdiction over the parties and subject matter of this action.

     Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation via Certified Mail to:

                    Arnold and Dovie House
                    1364 Rutledge Street
                    Gary, Indiana 46404

     On the January 10, June 14, 1991; June 6, June 8, November 3, 1995; and July 25, 1996; inspections you were found in violation of 329 IAC 10-4-2 and -3 (329 IAC 2-4-2 and -3 prior to April 13, 1996) which prohibit, any person from causing or allowing the storage, containment, processing, or disposal of solid waste in a manner which creates a threat to human health or the environment, and open dumping and open dumps, as defined in IC 13-11-2-146 and -147 ( IC 13-7-1-16 prior to July 1, 1996). This violation is based on the fact that during these inspections it was observed that solid waste materials (waste tires and solid waste debris) had been dumped at the Site.

     On the inspections noted above, you were found in violation of IC 13-30-2-1(3), (4) and (5) (IC 13-7-4-1(3) and (4) prior to July 1, 1996) which provide, respectively, that no person shall deposit any contaminants upon the land in such place and manner which creates, or which would create, a pollution hazard, or deposit or cause or allow the deposit of any contaminants or solid waste upon the land except through the use of sanitary landfills or another method acceptable to the solid waste management board, and that no person shall dump, cause or allow the open dumping of garbage or any other solid waste in violation of rules adopted by the solid waste management board. This violation is based on the fact that during these inspections it was observed that solid waste materials (waste tires and solid waste debris) had been dumped at the Site.

     On the September 6, 1996, inspection, IDEM area representative observed the open burning of an automobile at the Site, in violation of 326 IAC 4-1 which prohibits open burning unless exempted by rule or variance.

     On the September 11, 1996, inspection, IDEM area representatives observed the open burning of solid waste including approximately thirty (30) automobiles, a bus, and tires at the Site, in violation of 326 IAC 4-1 which prohibits open burning unless exempted by rule or variance.

     In recognition of the settlement reached, Respondents waive any right to administrative and judicial review of this Agreed Order.

II. ORDER

     This Agreed Order shall be effective ("Effective Date") when it is approved by the

Complainant or his delegate, and has been received by the Respondents. This Agreed Order shall have no force or effect until the Effective Date.

     Respondents shall immediately cease and desist from causing or allowing the storage or disposal of regulated solid waste at the Site.

     Respondents shall immediately cease and desist from causing or allowing open burning at the Site.

     Respondents shall, before December 31, 2000, properly remove and dispose all tires from the Site. Said tires must be taken to and disposed at a state approved solid waste management facility.

     Respondents shall submit progress reports every six (6) months after the Effective Date of this Order, until all waste tires from the Site have been properly removed and disposed.

     The removal and disposal of tires shall be done in compliance with 329 IAC 12.

     Respondents shall submit copies of all solid waste disposal receipts and waste tire manifests to IDEM within ten (10) days after each load of solid waste, including tires, is removed form the Site and properly disposed.

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

                    Brett E. DeBusk
                    Office of Enforcement
                    Indiana Department of Environmental Management
                    100 North Senate Avenue
                    P.O. Box 6015
                    Indianapolis, Indiana 46206-6015

     In the event the following terms and conditions are violated, the Complainant may assess and the Respondents shall pay a stipulated penalty in the following amounts:

        Violation            Penalty

    Order Condition #2            $100 per day of additional open dumping
    Order Condition #3            $1,000 per violation of open burning
    Order Condition #4             $100 per day violation continues

    Order Condition #5            $100 per violation
    Order Condition #6             $100 per violation

     Stipulated penalties shall be due and payable within thirty (30) days after Respondents receive 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 Respondents for violation of the Agreed Order. In lieu of assessment of any of the stipulated penalty given above, the Complainant may seek any other remedies or sanctions available by virtue of Respondents' violation of this Agreed Order, or Indiana Law, including but not limited to civil penalties pursuant to IC 13-30-4.

     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

     This Agreed Order shall apply to and be binding upon the Respondents, its officers, directors, principals, agents, successors, subsidiaries, and assigns. The Respondents' 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 Respondents shall in any way alter its status or responsibilities under this Agreed Order.

     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.

     The Respondents shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred. Respondents shall ensure that all contractors, firms and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

     This Agreed Order shall remain in effect until Respondents have complied with all terms and conditions of this Agreed Order.


TECHNICAL RECOMMENDATION:        RESPONDENTS:
Department of Environmental Management

By:___________________________        By:____________________________
Paul Higginbotham, Chief
Solid Waste Section                Printed:________________________
Office of Enforcement
                            Title:__________________________

Date:_________________________            Date:__________________________

                            By:__________________________

                            Printed:________________________

                            Title:__________________________

                            Date:__________________________

COUNSEL FOR COMPLAINANT:            COUNSEL FOR RESPONDENTS:
Department of Environmental Management

By:___________________________        By:____________________________
Deborah Rush, Attorney
Office of Legal Counsel
Department of Environmental Management

Date:__________________________        Date:___________________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS __________ DAY OF __________________, 1999.

                            For the Commissioner:

`                            Signed on March 4, 1999
                            Felicia Robinson George
                            Assistant Commissioner
                            Office of Enforcement

Converted by Andrew Scriven