VIA CERTIFIED MAIL #
To: Mr. Robert E. Finn, President C.T. Corporation System
RSR Corporation - Quemetco Resident Agent for
2777 Stemmons Freeway RSR Corporation - Quemetco
Suite 1800 One North Capitol Avenue
Dallas, Texas 75207 Indianapolis, Indiana 46204
Designated representatives of the Indiana Department of Environmental Management
(IDEM) conducted inspections of Quemetco, Incorporated, located in Indianapolis, Indiana.
IDEM conducted these inspections on June 4 and July 3, 1997.
The inspections revealed violations of the Indiana Code (IC) and Hazardous Waste Rules
under 329 IAC 3.1. This article incorporates July 1, 1995 federal standards for the management
of hazardous waste, which have been published in 40 CFR 260 through 40 CFR 273. The
violations observed are as stated in Finding No. 5 of the proposed Agreed Order.
In accordance with IC-13-30-3-3, the Commissioner is required to notify you in writing
that the Commissioner believes a violation exists and offer you 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.
If settlement is not reached within sixty (60) days of your receipt of this Notice, the
Commissioner may issue an Order pursuant to IC 13-30-3-4 containing the actions you must take
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 any violation.
The timely entry into an Agreed Order will prevent the necessity of an Order of the
Commissioner being issued under IC 13-30-3-4, or the filing of a civil court action under IC 13-
14-10 or IC 13-14-2-6. The advantages of entering into an Agreed Order are:
1. You may not be required to admit that any violation occurred.
2. The civil penalty may be less than that imposed under an Order of the
Commissioner.
Please contact Ms. Aubrey N. Sherif at 317/233-5970 within fifteen (15) days after receipt
of this Notice regarding your intent to settle this matter. If you are willing to resolve this matter
as provided for in the enclosed Agreed Order, please sign and return it to the Office of
Enforcement at the above address within the sixty (60) day settlement period.
For the Commissioner:
Date: Signed 2/27/98
David J. Hensel
Director
Office of Enforcement
cc: Marion County Health Department (without enclosure)
Office of Legal Counsel (with enclosure)
Ms. Nancy L. Johnston (with enclosure)
Mr. John Naddy (with enclosure)
Converted by Andrew Scriven