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NOTICE OF VIOLATION

    
Via Certified Mail # _______________         Via Certified Mail #_______________

To:    Mr. Peter Good, Plant Manager        CT Corporation System, Registered Agent
    Greene Manufacturing Company        One North Capitol Avenue
    1740 Georgia Avenue            Indianapolis, Indiana 46204
    Connersville, Indiana 47331
    

Cause No. B-2477

    Based on investigation by designated representatives of the Indiana Department of Environmental Management (IDEM) on August 9, 1999, Greene Manufacturing Company, 1740 Georgia Avenue in Connersville, Fayette County, Indiana, (hereinafter referred to as "the Plant") has been in violation of the following environmental rules, statute, and industrial pre-treatment permit:

    1.    Pursuant to IC 13-30-2-1, 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 or into any publicly owned treatment works in any form which causes or would cause pollution which violates or would violate rules, standards, or discharge emission requirements adopted by the appropriate board pursuant to this article.

    2.    Pursuant to 327 IAC 5-12, all discharges to POTWs shall comply with State and Federal pretreatment standards. The Plant fell under 40 CFR 433.17 and 40 CFR 466.14 Federal Categorical pre-treatment standards as well as local pretreatment standards as stated in the Permit.

    3.    The Federal categorical pretreatment standards contained in 40 CFR 433.17 and 40 CFR 466.14 are incorporated by reference into 327 IAC 5-12-6.


    4.    The Permit (CU-109) issued by the City of Connersville became effective on May 4, 1998, and expires May 4, 2001. The Permit lists under Part 7, "Effluent Limitations" and Attachment B, the effluent limitations and monitoring requirements for the Plant. These are based, in part, on the Federal categorical pretreatment standards limiting concentrations of certain metals and total toxic organics. In addition, the Permit lists in Attachment B, discharge limitations based on general prohibitive discharge standards, as contained in the Connersville Sewer Usage Ordinance, Section 51.05 of Chapter 51, per the requirements of 40 CFR 403.5. These limitations concern conventional pollutants including pH, Suspended Solids (SS), and Chemical Oxygen Demand (COD). These standards are deemed pretreatment standards under 327 IAC 5-11-1 through 327 IAC 5-15- 12, through authority of 327 IAC 5-12-2.

    5.    Based on the metals discharge limitations contained in the Plant's Industrial Wastewater Discharge Permit and reported by the Plant to Connersville Utilities, the Plant exceeded the:

        a.    Zinc Daily Maximum limit a total of sixty-one (61) times between June 1, 1998 and May 31, 1999;

        b.    Zinc 4-day Average limit a total of fifteen (15) times between June 1, 1998 and May 31, 1999;

        c.    Chromium Daily Maximum limit a total of eighteen (18) times between June 1, 1998 and May 31, 1999;

        d.    Chromium 4-day Average limit a total of two (2) times between June 1, 1998 and May 31, 1999;

        e.    Copper Daily Maximum limit a total of forty-five (45) times between June 1, 1998 and May 31, 1999;

        f.    Copper 4-day Average limit a total of two (2) times between June 1, 1998 and May 31, 1999;

        g.    Cyanide Daily Maximum limit a total of fifty-eight (58) times between June 1, 1998 and May 31, 1999; and

        h.    Cyanide 4-day Average limit a total of fourteen (14) times between June 1, 1998 and May 31, 1999;


    Based on the conventional pollutant discharge limitations contained in the Plant's Industrial Wastewater Discharge Permit and reported by the Plant to the City of Connersville Utilities, the Plant exceeded the:

    a.    TSS concentration limit a total of twenty-six (26) times between June 1, 1998 and May 31, 1999;

    b.    COD limit a total of three (3) times between June 1, 1998 and May 31, 1999; and

    c.    pH limit a total of three (3) times between June 1, 1998 and May 31, 1999.

    These exceedances are violations of IC 13-30-2-1 and the State pretreatment rules, 327 IAC 5-11-1 through 327 IAC 5-15-12, through authority of 327 IAC 5-11-5.

    Pursuant to 327 IAC 5-11-5, the commissioner may (independently of any enforcement proceedings by the POTW) take enforcement measures (including the assessment of civil penalties) against the industrial user for violations of pretreatment standards and requirements contained in the pretreatment rules 327 IAC 5-11-1 through 327 IAC 5-15-12.

    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 Steven Judith at 317-232-8409 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:    SEPTEMBER 7, 1999            _________________________
                            Felicia A. Robinson
                            Assistant Commissioner of Enforcement

cc:    Jim Filippini, Chief, Compliance Unit 2
     U.S. EPA, Region 5, Water Section
    Fayette County Health Department
    Maryellen Blanton, Pretreatment Coordinator
     City of Connersville

Converted by Andrew Scriven