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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. H-13569
                            )
THE HAMILTON FOUNDRY & MACHINE CO., )
DECATUR CASTING DIVISION            )
                            )
        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, a department of the State of Indiana created by IC 13-13-1-1.

    2.    Respondent is The Hamilton Foundry & Machine Company, Decatur Casting Division (hereinafter referred to as "Respondent"), who is a company doing business at 822 Dayton Avenue, located in Decatur, Indiana. The U.S. EPA I.D. number of the facility is IND 005 081 682.

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


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

        Mr. Charles Rentschler, President        Mr. Dennis M. Borda
        The Hamilton Foundry & Machine Co.    Registered Agent for The Hamilton
        200 Industrial Drive                Foundry & Machine Co.
        Harrison, Ohio 45030            822 Dayton Avenue
                                Decatur, Indiana 46733

    5.    Respondent operates a gray iron foundry utilizing scrap cast iron and scrap steel. Electrostatic precipitator ("EP") dust (hazardous waste codes D006 and D008) is the sole hazardous waste generated at the facility. Respondent notified the U.S. EPA as a large quantity generator of hazardous waste on June 22, 1984, under the name, Hamilton Allied Corporation Decatur Casting. Respondent notified the U.S. EPA on June 15, 1990, of its name change to The Hamilton Foundry & Machine Company, Decatur Castings Division.

    6.    The IDEM contends that the following violations were in existence or observed by the Office of Solid and Hazardous Waste Management (OSHWM) of IDEM during a Compliance Evaluation Inspection of the facility on September 25, 1997.

        a.    Pursuant to IC 13-30-2-1(1) and 40 CFR 265, Subpart C, no person may discharge, emit, cause, allow or threaten to discharge, emit, cause, or allow any contaminant or waste, including any noxious odor, either alone or in combination with contaminants from other sources into the environment in any form that causes or would cause pollution in violation of 40 CFR 265.31. A facility must be maintained and operated to minimize the possibility of any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment. Based upon information gathered by IDEM, Respondent allowed the spillage of EP dust underneath the conveyor leading from the EP stack to a roll-off box. Both the concrete slab and the ground surrounding the concrete slab were discolored.

    7.    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 the Order, Respondent shall submit to IDEM a site assessment plan. The purpose of this plan will be to conduct sampling and analysis in order to assess the degree and extent of contamination of the soil and any impact on the groundwater from releases of EP dust. The plan must:

        a.    Address all areas of contamination at this site. This must include, at a minimum, areas at the site where waste spillage occurred;

        b.    Include a soil sampling grid that overlaps the area;

        c.    Specify the method of determining the number and location of samples to be taken within the grid to yield a representative assessment of the contaminated area as outlined in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication", SW-846;

        d.    Include the method of sample collection, per SW-846;

        e.    State the maximum distance between each sample location. This distance is not to exceed ten (10) feet;

        f.    State the soil samples will not be composited;

        g.    Clearly define all sampling and analytical protocol designed to identify hazardous waste or its constituents and to determine the physical extent of the contamination per 40 CFR Part 261.30(a) and 40 CFR Part 261, Appendices I, II and III;

        h.    Specify that chain-of-custody of the samples shall be maintained and Quality Assurance and Quality Control (QA/QC) procedures shall be followed;

        i.    Include a statement in the initial proposal that a contingent plan for sampling outside the grid area will be submitted in the event that sampling shows contamination to exist at the limit of the grid area;

        j.    Include time frames for implementation of the site assessment plan; and

        k.    Be approved by IDEM prior to implementation of the plan.

    3.    Within fifteen (15) days of notice of approval of the site assessment plan by IDEM, Respondent shall implement the plan as approved and in accordance with the time frames contained therein. Respondent shall submit the results of the analyses to IDEM.

    4.    If contamination is found as a result of the site assessment, within sixty (60) days of completion of the analyses, Respondent shall submit a cleanup plan to IDEM for approval. The cleanup plan must:

        a.    Include the results of the analyses, chain-of-custody information, and the Quality Assurance and Quality control records;

        b.    Address all areas determined by the analyses to be contaminated;

        c.    Address the groundwater, if it is determined to be affected;

        d.    Include a soil sampling and analysis plan to be performed after the cleanup has been done which verifies that all contamination has been removed; and

        e.    Include a time frame for implementation of the cleanup plan.

    5.    Within fifteen (15) days of IDEM's notice of approval of the cleanup plan, Respondent shall implement the plan as approved and in accordance with the time frames contained therein.

    6.    Within thirty (30) days of completion of the cleanup, Respondent shall submit to IDEM certification by an independent registered professional engineer that the cleanup has been completed as outlined in the approved plan.

    7.    For additional information on sampling, analysis and remediation, please see Parts 14 (a and b) and 15 of the attached Hazardous Waste Management Unit Closure Guidance.

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

        Ms. Dianna Schlicher
        Office of Enforcement
        Hazardous Waste Section
        Indiana Department of Environmental Management
        100 N. Senate Avenue
        P. O. Box 6015
        Indianapolis, IN 46206-6015

    9.    Respondent is assessed a civil penalty of Three Thousand Four Hundred Dollars ($3,400). 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.

    10.    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 the time frame        $1,000 per day per violation
        requirements of Orders #2-6 of the Agreed Order.

    11.    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 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 13-30-4-1.

    12.    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 N. Senate Avenue
            P. O. Box 7060
            Indianapolis, IN 46207-7060

    13.    In the event that the civil penalty required by paragraph 9 is not paid within specified time frames 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.

    14.    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.

    15.    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.


    16.    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.

    17.    This Agreed Order shall remain in effect until IDEM issues a Resolution of Cause letter to Respondent.

TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By: _________________________            By: _________________________
Nancy L. Johnston, Section Chief
Hazardous Waste Section            Printed: ______________________
Office of Enforcement
                            Title: ________________________

Date: ________________________            Date: ________________________

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

By: _________________________            By: ________________________
Scott R. Storms
Office of Legal Counsel

Date: _______________________            Date: ______________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS _____ DAY OF ____________________, 1998.

                            For the Commissioner:

                            Signed on July 2, 1998
                            David J. Hensel
                            Director
                            Office of Enforcement

Converted by Andrew Scriven