NOTICE OF VIOLATION

 

Via Certified Mail #:

Via Certified Mail #:

_______________________________

_______________________________

To:

Mr. John R. Alm, President

Corporation Service Company, Registered Agent

 

Coca-Cola Enterprises, Inc.

Coca-Cola Enterprises, Inc.

 

2500 Windy Ridge Parkway

251 East Ohio Street, Suite 500

 

Atlanta, Georgia  30339

Indianapolis, Indiana  46204

 

Case No. 2004-14287-W

 

Based on an investigation, the Indiana Department of Environmental Management (IDEM) has reason to believe Coca-Cola Enterprises, Inc. (Respondent) has violated environmental rules and its permit.  The violations are based on the following:

 

1.                  Respondent owns and/or operates a soft drink bottling company known as Tri-State Coca-Cola Bottling Company with Industrial Wastewater Pretreatment (IWP) Permit No. INP000160 (the "Permit") located at 1617 North Meridian Street, Portland, in Jay County, Indiana (the "Site").

 

2.         Pursuant to 327 IAC 5-21-4(1), 327 IAC 5-21-6(a)(1), and Part II.A.1 of the Permit, the Respondent is required to comply with all terms and conditions of the Permit.

 

Part I.A.1 of the Permit contains the monitoring requirements applicable to the discharge from the Respondent’s WWTP Outfall 001 into the City of Portland sewage treatment system. 

 

Discharge Monitoring Reports (DMR) and Monthly Reports of Operation submitted by the Respondent to IDEM for the period between December 2001 and April 2004 reveal that Respondent failed to report daily maximum concentration of Biochemical Oxygen Demand (BOD) and Total Suspended Solids (TSS) at the frequency required in Part I.A.1 of the Permit as follows:

 

Week of:

December 4, 2001, only one BOD reported; sample on 12/4/01 had no BOD result.

December 17, 2001, only one BOD reported; sample on 12/18/01 had no BOD result.

January 21, 2002, only one BOD reported; sample on 1/23/02 had no BOD result.

February 11, 2002, only one BOD reported; sample on 2/12/04 had no BOD result.    

April 15, 2002, no BOD reported; BOD’s on 4/16/02 and 4/17/02 noted disqualified.

April 22, 2002, no BOD reported; BOD’s on 4/23/02 and 4/24/02 noted disqualified.

July 1, 2002, note on DMR states no testing for BOD or TSS done for the week.

November 11, 2002, note on DMR states did not complete BOD tests for 11/19,20.

November 25, 2002, note on DMR states no testing for BOD or TSS done for the week.

December 22, 2002, note on DMR states no testing for BOD or TSS done for the week.

January 1, 2003, note for 1/3/03 sample states no BOD results reported because dissolved oxygen depletion was less than 2 mg/l and blanks exceeded 0.2 mg/l.

July 1, 2003, note on DMR states no testing for BOD or TSS done for the week.

August 1, 2003, note on DMR states BOD incubator malfunction invalidated week test.

September 22, 2003, only one BOD reported; on 9/24/03 dissolved oxygen depletion less than 2.0 mg/l.

November 3, 2003, only one BOD reported; 11/1/03 sample dissolved oxygen depletion less than 2.0 mg/l.

November 17, 2003, no BOD reported; note on DMR states oxygen generated in blanks.

November 24, 2003, note on DMR states no testing for BOD or TSS done for the week.

December 1, 2003, no BOD results reported.  Blanks generated oxygen.

December 15, 2003, no BOD results reported.  Note states disqualified; incubation for seven days instead of the required standard five days.

December 22, 2003, note on report states no testing for BOD or TSS done for the week

December 29, 2003, no BOD results reported.  Blanks exceeded 0.2 mg/l depletion.

January 5, 2004, note on DMR states no BOD results reported for 1/6 and 1/7; blanks generated oxygen.

January 26, 2004, no BOD results reported; note on DMR states mixed up sample and seed causing results to not be valid. 

February 9, 2004, only one BOD reported; note states 2/10/04 BOD dissolved oxygen depletion was below 2 mg/l.

February 23, 2004, note on DMR states no testing for BOD or TSS done for the week.

 

The Respondent's failure to comply with these monitoring requirements contained in the Permit is in violation of 327 IAC 5-21-4(1), 327 IAC 5-21-6(a)(1), Part II.A.1 of the Permit, and Part I.A.1 of the Permit.

 

3.         Pursuant to 327 IAC 5-21-4(1), 327 IAC 5-21-6(a)(1), and Part I.C.4 of the Permit, the Respondent is required to comply with test procedure analytical methods that conform to 40 CFR 136, current version.

 

The Respondent failed to use proper technique to monitor BOD during the months of November 2002, January 2003, September 2003, November 2003, December 2003, and January 2004, in violation of 327 IAC 5-21-4(1), 327 IAC 5-21-6(a)(1), and Part I.C.4 of the Permit.

 

In accordance with IC 13-30-3-3, the Commissioner herein provides notice that a violation may exist and offers an opportunity to enter into an Agreed Order providing for the action required to correct the violation and for the payment of a civil penalty.  The Commissioner is not required to extend this offer for more than 60 days.

 

As provided in IC 13-30-3-4, an alleged violator may enter into an Agreed Order without admitting that the violation occurred.  IDEM encourages settlement by Agreed Order, thereby resulting in quicker correction of the environmental violation and avoidance of extensive litigation.  Timely settlement by Agreed Order may result in a reduced civil penalty.  Also, settlement discussions will allow the opportunity to present any mitigating factors that may be relevant to the violation.

 

If an Agreed Order is not entered into within 60 days of receipt of this Notice of Violation, the Commissioner may issue a Notice and Order under IC 13-30-3-4 containing the actions that must be taken to correct the violation and requiring the payment of 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.

 

Please contact Paul Cluxton at 317/232-8432 within 15 days after receipt of this Notice regarding your intent to settle this matter.

 

For the Commissioner:

Signed on 12/14/04

Felicia A. Robinson

Deputy Commissioner

for Legal Affairs

 

Enclosure

 

cc:        Ronald Stockton, Plant Manager

Byron Broussard, Director of Operation

http://www.state.in.us/idem