NOTICE OF VIOLATION

Via Certified Mail#

To: Jack Hanlon, President CT Corporation System

Globe Valve Corporation Registered Agent for

4600 W. Touhy Globe Valve Corporation

Chicago, Illinois 60646 36 S. Pennsylvania St., Suite 700

Indianapolis, Indiana 46204

Case No. 2002-11372-A

Based on investigation by designated representatives of the Indiana Department of Environmental Management (IDEM) on February 7, 2002; July 10, 2002; and July 17, 2002, Globe Valve Corporation, 1514 West Washington Street, Delphi, Indiana, was in violation of the following environmental statute(s), rule(s), and/or permit(s):

• Pursuant to Part 70 Operation Permit T015-7521-00011, Condition C.17, the Permittee is required to implement a compliance plan to ensure that reasonable information is available to evaluate its continuous compliance with applicable requirements. During the February 7, 2002 inspection it was noted that records of daily Visible Emission Evaluations (VEEs) and weekly pressure-drop readings for baghouses C4, C8, C10, and C13 were unavailable for inspection. Those records were subsequently submitted to IDEM, and they revealed abnormal VEEs and excessive pressure-drop readings above 6.0 during the weeks of April 2, 2001, July 16, 2001, October 1, 2001, and October 22, 2001 without evidence of the implementation of a compliance plan and response steps, violations of Part 70 Operation Permit T015-7521-00011, Condition C.17.

B. Pursuant to Part 70 Operation Permit T015-7521-00011, Condition B.12 (a)(3), the Permittee shall prepare and maintain a Preventive Maintenance Plan which include the identification and quantification of the replacement parts that will be maintained in inventory for quick replacement. During the July 17, 2002 inspection it was observed that the Preventive Maintenance Plan failed to include the identification and quantification of the replacement parts that will be maintained in inventory for quick replacement, a violation of Part 70 Operation Permit T015-7521-00011, Condition B.12 (a)(3).

C. Pursuant to Part 70 Operation Permit T015-7521-00011, Condition D.2.7, the Permittee shall maintain records to document compliance with Conditions D.2.2 and D.2.4, including records of the date and time that fume suppressants are added to the electroplating bath(s). During the July 10, 2002 and July 17, 2002 inspections it was observed that the date and time that fume suppressants are added to the electroplating bath(s) were not recorded on May 29, 2002, violations of Part 70 Operation Permit T015-7521-00011, Condition D.2.7.

• Part 70 Operation Permit T015-7521-00011, Condition D.4.1(c), the owner or operator shall close the degreasing unit cover whenever parts are not being handled in the cleaner. During the July 10, 2002 and July 17, 2002 inspections it was observed that the owner or operator failed to close the degreasing unit cover when parts were not being handled in the cleaner, violations of Part 70 Operation Permit T015-7521-00011, Condition D.4.1.



• Part 70 Operation Permit T015-7521-00011, Condition D.4.1(e), the owner or operator shall provide a permanent, conspicuous label summarizing the operation requirements of the degreasing unit. During the July 17, 2001 inspection it was observed that the owner or operator failed to provide a permanent, conspicuous label summarizing the operation requirements of the degreasing unit, a violation of Part 70 Operation Permit T015-7521-00011, Condition D.4.1.

In accordance with IC 13-30-3-3, the Commissioner is required to notify an alleged violator in writing that a violation may exist and offer an opportunity to enter into an Agreed Order providing for the actions required to correct the violations and for the payment of a civil penalty. The Commissioner is not required to extend this offer for more than sixty (60) days.

Entering into an Agreed Order will prevent the issuance of a Notice and Order of the Commissioner under IC 13-30-3-4, or the filing of a civil court action under IC 13-14-2-6. IDEM encourages settlement by Agreed Order, thereby saving time and resources. Timely settlement by Agreed Order may result in a reduced civil penalty. Settlement discussions will also allow the opportunity to present any mitigating factors that may be relevant to the violations. In addition, as provided in IC 13-30-3-3, an alleged violator may enter into an Agreed Order without admitting that the violation occurred.

If settlement is not reached within sixty (60) days of receipt of this Notice of Violation, the Commissioner may issue a Notice and Order containing the actions that must be taken to achieve compliance, the required time frames, and an appropriate civil penalty. Pursuant to IC 13-30-4-1, the Commissioner may assess penalties of up to $25,000 per day for each violation.

To discuss this matter further, please contact Eric Larsen at (317) 233-1133 within fifteen (15) days after receipt of this Notice to request a conference. If settlement is reached, an Agreed Order will be prepared and sent for review and signature.

For the Commissioner:

Date: _______________ Signed on 03/14/03

Felicia A. Robinson

Deputy Commissioner

for Legal Affairs

cc: Jean Bauer, US EPA Region 5

Carroll County Health Department

Eric Larsen, Office of Enforcement

Dave Rice, Office of Air Quality

Richard Sekula, Office of Air Quality

Enforcement File

OAM Public File

http://www.ai.org/idem/