Via Certified Mail # Via Certified Mail #

To: Mr. Larry E. Bagwell, President CT Corporation System, Registered Agent

REA Magnet Wire Company, Inc. For REA Magnet Wire Company, Inc.

3600 East Pontiac Street 36 South Pennsylvania Street, Suite 700

Fort Wayne, IN 46803 Indianapolis, IN 46204

Case No. 2002-12522-A

Based on investigation by designated representatives of the Indiana Department of Environmental Management (IDEM) on August 28, 2002, REA Magnet Wire Company, Inc. ("Respondent"), which owns and operates eight (8) V-22 gas fired wire enameling ovens, identified as unit numbers 451-453, 454-456, 461-463, 464-466, 475, 476, 479, and 480, controlled by integral internal thermal oxidizer, at its electric wire coating/enameling facility, located at 2800 Concord Road, Lafayette, Indiana, Tippecanoe County, was in violation of the following environmental statute(s), rule(s), and/or permit(s):

Pursuant to permit condition number D.4.3 of the Title V operating permit number T157-6960-00032, issued on February 18, 1999, the integral internal thermal oxidizer that control VOC emissions from the V-22 magnet wire enameling oven, shall operate with an overall efficiency of 98.5% at all time when the wire enameling oven is in operation, while maintaining operating temperature at or above 1250F.

On August 28, 2002, during a stack test, the thermal oxidizer was operating at an average overall control efficiency of 94.8%, while maintaining an average temperature of 1375F, a violation of the permit condition.

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 Mr. Michael Stonik at (317) 233-0033 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:

Signed on June 6, 2003

Date:

Felicia A. Robinson

Deputy Commissioner

for Legal Affairs

cc: Jean Bauer, US EPA Region 5

Tippecanoe County Health Department

Jay Rodia, Office of Legal Counsel

Michael Stonik, Office of Enforcement

Steven Friend, Office of Air Quality

Wanda Stanfield, Office of Air Quality

Peter P. von Stein, REA Magnet Wire Company, Inc.

2800 Concord Road, Lafayette, IN 47909

Enforcement File

Public File

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