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NOTICE OF VIOLATION
        
    
    Via Certified Mail#            Via Certified Mail#
To:    Gary Greubel                C T Corporation
    Environmental Coordinator        Registered Agent for:
    Waupaca Foundry, Inc.        Waupaca Foundry, Inc.
    P. O. Box 189                One North Capitol
    Tell City, IN 47586            Indianapolis, IN 46204
    

Cause No. A-4538

    Based on investigation by designated representatives of the Indiana Department of Environmental Management (IDEM) on March 31, 1999, Waupaca Foundry, Inc., 9856 State Highway 66, Tell City, IN, ID # 123-00019 was in violation of the following environmental statute(s), rule(s), and/or permit(s):

    A.     Pursuant to Operation conditions #9 & #28 of Permit # CP 123-4593 Best Available Control Technology (BACT) shall be used to control particulate emissions from the charge make up and handling area. Emissions from the charge make up and handling area are exhausted at stack S10. This facility failed to install BACT, which is a baghouse for this operation, at the charge make up and handling area. This constitutes a violation of Operation conditions #9 & #28 of Permit # CP 123-4593.

          Pursuant to Operation condition #31 of Permit # CP 123-4593 visible emissions from building openings shall be limited to 3% opacity. This facility was observed with visible emissions from the opening above a cupola at 18% opacity for one six minute period. This constitutes a violation of Operation condition #31 of Permit # CP 123-4593.

          Pursuant to sections D.1.6 and D.1.7; D.2.5 and D.2.8; D.3.6 and D.3.7; D.4.13 and 4.14; D.5.7 and D.5.8 of CP 123-8451 a trained employee shall perform visible emission notations of particulate matter exhausted to the atmosphere from stacks S01, S04, S07, S08, S14, S15, S16 once per working shift and maintain records of the notations. This facility failed to record the visible emission

readings. This constitutes violations of sections D.1.6 and D.1.7; D.2.5 and D.2.8; D.3.6 and D.3.7; D.4.13 and 4.14; D.5.7 and D.5.8 of CP 123-8451.
    
    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 Craig Henry at 317-233-1136 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 October 4, 1999
                            Felicia Robinson George
                            Assistant Commissioner
                            Office of Enforcement
cc:    Jean Bauer, US EPA Region 5
    Perry County Health Department
    Aaron Schmoll, Office of Legal Counsel
    Craig Henry, Office of Enforcement
    Dave Holder, SWRO
    Judy Dicus Thomann, SWRO
    Public File
    Enforcement File
    http://www.state.in.us/idem

Converted by Andrew Scriven