STATE OF INDIANA    )        BEFORE THE INDIANA DEPARTMENT
                )    SS:    OF ENVIRONMENTAL MANAGEMENT
COUNTY OF MARION    )

COMMISSIONER OF THE DEPARTMENT        )
OF ENVIRONMENTAL MANAGEMENT,        )
                                )
            Complainant,                )                
                                )     CAUSE NO. A-3002
            v.                    )    CAUSE NO. A-3395
                                )    CAUSE NO. A-3564
NOBLESVILLE CASTING, INC.,                )    CAUSE NO. A-3565
                                )    CAUSE NO. SW-256
            Respondent.                )

    The Complainant and the Respondent desire to settle and compromise this action without hearing or adjudication of any issue of fact or law, and consent to the entry of the following Findings of Fact and Order.

          Complainant is the Commissioner (hereinafter referred to as "Complainant") of the Indiana Department of Environmental Management, a department of the State of Indiana created by IC 13-13-1-1.

          Respondent is Noblesville Casting, Inc. ("Respondent"), a company doing business at 1600 South Eighth Street, in Noblesville, located in Hamilton County, Indiana (hereinafter referred to as “the Site”).

          The Indiana Department of Environmental Management ("IDEM") has jurisdiction over the parties and subject matter of this action.

          In recognition of the settlement reached, Respondent waives any right to administrative and judicial review of this Agreed Order.

          Pursuant to IC 13-30-3-3, entry into the terms of this Agreed Order does not constitute an admission of any violation contained herein, or in the Notices of Violation issued on April 10, and May 12, 1995.

B.    Air: Cause Nos. A-3002, A-3395, A-3564, A-3565

          On April 10, 1995, pursuant to IC 13-7-11-2(b) [currently IC 13-30-3-3], IDEM issued a Notice of Violation for the alleged violations of 326 IAC 6-4 discovered on December 2, 1994, and February 21, 1995, via Certified Mail to:

            M.R. Jacoby, Registered Agent
            Noblesville Casting, Inc.
            1600 South Eighth Street
            Noblesville, IN 46060

          Rule 326 IAC 6-4 prohibits fugitive dust from visibly crossing the boundary or property line of the source.

          On December 2, 1994, and February 21, 1995, a qualified representative of the Complainant observed that visible emissions from Respondent's cupola scrubber stack were not adequately dispersing and were crossing the property line at ground level, alleged violations of 326 IAC 6-4.

          Rule 326 IAC 5-1-2(1)(A) states that, for sources or facilities of visible emissions located in attainment areas for particulate matter, visible emissions observed in accordance with the procedures set forth in section 4 of this rule shall not exceed an average of forty percent (40%) opacity in twenty-four (24) consecutive readings.

          On March 14, 1995, a qualified representative of the Complainant performed a Visible Emissions Evaluation in accordance with 326 IAC 5-1-4 on the plume from Respondent's cupola scrubber stack for at least 24 consecutive readings (one reading every 15 seconds) and a six-minute average exceeded forty percent (40%), an alleged violation of 326 IAC 5-1-2(1)(A).

          On May 18, 1995, Jake Jacoby, representing Respondent, met with representatives of IDEM to discuss the above alleged violations and possible compliance plans.

          On August 18, 1995, an IDEM inspector observed several of the dust collector hoods for the sand conveyor system on the shakeout line had been removed and one of the wet scrubbers was not operating but the shakeout line was still in operation, an alleged violation of 326 IAC 1-6-4(b) and Respondent's Operation Permit Condition (d).

          On February 6, 1996, Respondent was acquired by new owners.

          On March 4, 1996, a qualified representative of IDEM observed visible emissions escaping from the cupola cap exceeding the average forty percent (40%) limit, an alleged violation of rule 326 IAC 5-1-2(1)(A), and, due to the fact that emissions escaping from the cupola cap were bypassing the emissions control device, i.e. the venturi scrubber, an alleged violation of 326 IAC 1-6-4(b) and Permit Condition (a) also occurred. The inspector also observed a portion of the shakeout line was still operating without emission controls, another alleged violation of 326 IAC 1- 6-4(b) and Permit Condition (d).

          On May 15, 1996, a qualified representative of IDEM observed visible emissions escaping from the cupola cap exceeding the average forty percent (40%) limit, an alleged violation of 326 IAC 5-1-2(1)(A), and, due to the fact that emissions escaping from the cupola cap were bypassing the emissions control device, an alleged violation of 326 IAC 1-6-4(b) and Permit Condition (a) also occurred.

          On April 16, 1996, and July 19, 1996, representatives of Respondent met with representatives of IDEM to discuss the alleged violations and compliance plans. The new owners expressed their intent to comply with environmental requirements.

          Respondent has had a new cupola cap installed, and the crossover pipe manholes and the chimney duct stack have been repaired.

          Respondent has reestablished the integrity of the original emission capture hoods and duct work for the Disa #1 (a.k.a. Disa North) and the shakeout conveyors and has installed emission control hoods and ductwork on the Disa #2 (formerly Disa #3) molding machine.

          Respondent has installed a new fan and ductwork to capture the emissions from the basement sand return system.

          Respondent waives its right to issuance of a Notice of Violation for the March 14 and August 18, 1995, the March 4, and May 15, 1996, and the January 31, 1997, alleged violations and to the settlement period of sixty (60) days as provided for by IC 13-13-1-1 [IC 13-7-11-2(b) prior to July 1, 1996].

          Respondent has made some repairs to the cupola scrubber de-watering tank. The de-watering tank utilized a drag chain which was not functioning properly. The drag chain has been removed and a pump has been installed to accomplish the function of removing waste material from the tank.

          On June 16, 1997, Respondent re-installed a Disa machine (Disa #2) that had been in storage and began its operation on June 17, 1997. Respondent still plans to relocate the Disa #1 line (a.k.a. Disa North).

          Respondent's permit requires that emissions be in compliance with rule 326 IAC 6-3 which states that, for process operations, no person shall operate any process so as to produce, cause, suffer or allow particulate matter to be emitted in excess of the amounts shown in the table contained in rule 326 IAC 6-3-2(c).

          On March 18, 1998, representatives of IDEM observed the Disa #1 line operating with no suction of emissions to the scrubber. Therefore, a large amount of smoke was being emitted into the building and discharged uncontrolled to the outside air through four (4) roof fans. The uncontrolled operation of a Disa line results in a violation of 326 IAC 6-3-2(c).

          On April 8, 1998, a representative of IDEM observed gray/brown smoke plumes coming from the roof fans and crossing the property line at ground level, a

violation of 326 IAC 6-4. The six-minute average opacity of the plumes was 42%, a violation of 326 IAC 5-1.

          On April 16, 1998, a representative of IDEM observed the repairs of the duct for the Disa #1 line and it appeared to be capturing the emissions sufficiently.

C.     Solid Waste: Cause No. SW-256

          Pursuant to IC 13-30-3-3 [IC 13-7-11-2(b) prior to July 1, 1996], on May 12, 1995, IDEM issued a Notice of Violation via Certified Mail to:

        Merwyn R. Jacoby, President        M.R. Jacoby, Resident Agent
        Noblesville Casting, Inc.            Noblesville Casting, Inc.
        1600 South Eighth Street            1600 South Eighth Street
        P.O. Box 278                    P.O. Box 278
        Noblesville, Indiana 46060            Noblesville, Indiana 46060

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of 329 IAC 2-4-2 and -3 (329 IAC 10- 4-2 and -3 after April 13, 1996), which prohibit, respectively, any person from causing or allowing the storage, containment, processing, or disposal of solid waste in a manner which creates a threat to human health or the environment, and open dumping or open dumps, as defined in IC 13-7-1-16 (IC 13-11-2-146 and - 147 after July 1, 1996). These violations are based on the fact that during these inspections it was observed that the Respondent had caused and/or allowed an open dump containing municipal waste mixed with foundry waste.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of IC 13-7-4-1(3) and (4) [IC 13-30-2- 1(3), (4) and (5) after July 1, 1996], which provide, respectively, that no person shall deposit any contaminants upon the land in such place and manner which creates, or which would create, a pollution hazard, or deposit or cause or allow the deposit of any contaminants or solid waste upon the land except through the use of sanitary landfills or another method acceptable to the solid waste management board, and that no person shall dump, cause or allow the open dumping of garbage or any other solid waste in violation of rules adopted by the solid waste management board. These violations are based on the fact that during these inspections it was observed that the Respondent had caused and/or allowed an open dump on the Site.

          IDEM conducted a records review of the Site on September 12, 1994. Respondent was found in violation of 329 IAC 2-12-1(c), which provides that solid waste land disposal facilities which have operating permits in effect on the effective date of Article 2 of 329 IAC shall not operate after September 1, 1989, unless, prior to that date, they have established financial responsibility for post- closure by choosing a financial assurance mechanism under section 3(a) of 329 IAC 2-12 and by funding the same under section 3(b) of 329 IAC 2-12. This violation is based on the fact that at the time of this review, the Respondent had not provided the financial responsibility for post-closure of the Site.

          IDEM conducted a records review of the Site on September 12, 1994. Respondent was found in violation of 329 IAC 2-12-1(d), which provides that solid waste land disposal facilities which have operating permits in effect on the effective date of Article 2 of 329 IAC shall not operate after September 1, 1992, unless, prior to that date, they have established financial responsibility for closure by choosing a financial assurance mechanism under section 2(a) of 329 IAC 2-12 and by the funding the same under 2(b) of 329 IAC 2-12. This violation is based on the fact that at the time of this review, the Respondent had not provided the financial responsibility for closure of the Site.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of its Operating Permit No. 29-3, Condition #2, which reads "[t]hat when any portion of the site reaches within two feet of final elevation, compacted final cover shall be applied, not less than two feet in depth. Vegetation shall be provided to prevent soil erosion. Final cover shall have a slope of not less than 100:2 (horizontal to vertical) nor exceed 3:1 (horizontal to vertical) to prevent ponded water and/or erosion." This violation is based on the fact that at the time of these inspections, the slope of the final cover of the site exceeded 3:1 (horizontal to vertical), final cover had not been applied, and vegetation provided, to the appropriate portions of the Site.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of its Operating Permit No. 29-3, Condition #5, which reads "[t]hat the only waste materials to be deposited in this site include pepset core and mold waste, oil core waste, insta-draw waste, shell core waste, isocure cold box core waste, mod and core lumps, cupola dragout sludge, shot bast tailings, shakeout sludge, grindings, shot blast dust, shot blast dropout dust, waste system sand, miscellaneous sweepings, and ladle slag." This violation is based on the fact that at the time of these inspections, waste metal, barrels, and trash bags were mixed with the permitted waste.

          IDEM conducted an inspection of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of its Operating Permit No. 29-3, Condition #6, which reads "[t]hat dust and waste core materials shall be placed at the base of each lift and that these materials shall be covered immediately with remaining waste. The cupola dragout sludge waste is to be mixed with other wastes before permanent placement in the site." This violation is based on the fact that at the time of these inspections, dust and waste core materials were observed uncovered on the top of the Site.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of its Operating Permit No. 29-3, Condition #9. Pursuant to Condition #9 of the current permit, the filling sequence should be from east to west for each phase, beginning with phase one (1). Before filling progresses 75 feet north of each of the three (3) phase boundaries delineated on the April 1984 plan, all areas to the south of these boundaries (ie. phase 1, 2, and 3) must be filled to final grade, covered and seeded. This violation is based on the fact that at the time of these inspections, the proposed phases for filling were not followed, each area has been over-filled, and final cover and seedings were missing.

          IDEM conducted a records review of the Site on September 12, 1994. Respondent was found in violation of its Operating Permit No. 29-3, Condition #12, which reads "[a]ll monitoring wells (MW-1, MW-2, and MW-3) shall be tested semiannually for the following chemical parameters: arsenic, barium, cadmium, total chromium, copper, iron, lead, nickel, zinc, alkalinity, chlorides, chemical oxygen demand, cyanide, fluoride, phenols, total dissolved solids, sulfate, pH, conductivity, color, turbidity, and odor. The following sampling periods have been set for this site: March and September. Sampling shall be conducted at the end of each of these months and water quality results shall be submitted to this office by the end of the following month. Along with each submittal the depth to water from the top of the casing, measured prior to purging and sampling of the wells, shall be reported. For proper sampling procedures, refer to the Technical Support Branch's advisory entitled 'Procedures for Water Quality Monitoring of Sanitary Landfills in Indiana,' a copy of which is enclosed." This violation is based on the fact that at the time of the records review, this information had not been provided to IDEM.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of Respondent's Operating Permit No. 29-3, Condition #13, which reads "[t]hat the access to all monitoring wells by vehicle be established within 45 days of receipt of this permit." This violation is based on the fact that at the time of these inspections, access to all monitoring wells by vehicle was not possible.

          IDEM conducted inspections of the Site on October 18, 1994, and January 5, 1995. Respondent was found in violation of Respondent's Operating Permit No. 29-3, Condition #15, which reads "[t]hat the perimeter ditches and sedimentation basin be cleaned out periodically to maintain proper drainage." This violation is based on the fact that at the time of these inspections, the Respondent had not installed a sedimentation ditch nor a perimeter ditch for proper drainage of surface water.

          The permit violations noted above constitute violations of IC 13-7-4-1(6) and 329 IAC 2-8-11(c) [IC 13-30-2-1(7) and 329 IAC 10-13-6(d) after July 1, 1996, and April 13, 1996, respectively], which require that a modification request and supporting rationale be submitted to, and granted by IDEM before a permittee may make a modification in facility plans or operations. These violations are based on the fact that at the time of the records review and the site inspections, conditions related to the Site, which correspond to the above noted violations, were noted by IDEM staff.

          Attached as Exhibit 1 is a map dated May 4, 1998, which the parties have agreed define the areas referenced as Area B and C for purposes of this Agreed Order.

          On June 25 1998, IDEM issued a Final Renewal Permit and Closure/Post-Closure Plan Approval to the Respondent.
                            

          This Agreed Order shall be effective ("Effective Date") when it is approved by the Complainant or his delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the Effective Date.

A.     Air Cause Nos. A-3002, 3395, 3564, 3565

          Respondent shall employ appropriate hoods and controls for all casting, pouring, cooling and sand handling systems to comply with 326 IAC 6-3.

          Respondent shall operate the casting, pouring and cooling lines (a.k.a. Disa lines) and sand handling systems simultaneously with the associated capture hoods and control devices, in accordance with the provisions of 326 IAC 1-6-4.

          After Respondent has determined its long-range production strategy, Respondent shall submit any appropriate construction permit application to the Office of Air Management.

          By January 31, 1999, Respondent shall install a new high efficiency venturi scrubber, afterburners, and electro mechanical controls to improve the operation of the cupola and its emission control equipment or an electric induction furnace(s) with appropriate air emission control equipment to replace the cupola.

          Within 180 days of the start up of the cupola air pollution controls or the electric induction furnace and its control equipment mentioned in paragraph 5, Respondent shall perform a stack test for particulate matter on the stack. The stack test shall be performed in accordance with 326 IAC 3-2.1 and any applicable permit requirements.

          Within thirty (30) days of the Effective Date of this Order, Respondent shall submit the configuration of the capture hood and associated control device for the re-installed Disa #2 line.

                  the date construction was completed,
                  the date of the proposed operation, and
                  the configuration of capture hood and associated control device.

        This notification does not relieve Respondent from complying with any applicable permit requirements.

          Within 180 days from the completion of the relocation and/or installation of the Disa lines, Respondent shall perform stack tests for particulate matter on the East and West Schneible scrubber stacks. The stack tests shall be performed in accordance with 326 IAC 3-2.1 and any applicable permit requirement.

          For a period of two years after the controls mentioned in paragraph 5 are installed, Respondent shall perform, at a minimum, the following maintenance procedures on the cupola scrubber and the molding and shakeout scrubber systems:

            a.    Inspect pressure drop gauges on scrubber every shift during process operation.
            b.    Check cupola cap daily for visible emissions during cupola operation.
            c.    Check all scrubber stack exits daily for visible emissions during operation.
            d.    Inspect for proper grate/grit removal in slag tank weekly.
            e.    Wash emission bed weekly.
            f.    Check pH of slag tank water weekly to ensure proper pH level of water.
            g.    Inspect water pumps weekly.
            h.    Inspect slag tank sump pumps weekly.
            i.    Inspect venturi spray nozzles weekly.
            j.    Inspect exhaust fan assembly weekly.
            k.    Inspect gas take-off spray nozzles monthly.
            l.    Clean emission screens every three months.

          For a period of two years after the controls mentioned in paragraph 5 are installed, Respondent shall keep a maintenance log for the items listed in paragraph 10 for the cupola system, and for the emission control system for the molding and shakeout lines, noting the date of the inspection, any deficiencies found in the inspection, the date deficiencies are noted, the corrective action taken and the date

the corrective action was taken, which shall be made available to IDEM upon request.

          Respondent shall submit Standard Operating Procedures for operation and maintenance procedures on all air emission control systems within thirty (30) days after the Effective Date of this Agreed Order.
    
          Any compliance monitoring plan associated with the Title V permit Respondent receives for this source shall supersede any conflicting or duplicative provision in this Agreed Order.

          Respondent shall comply with the Standard Operating Procedures noted in paragraph 12 and the compliance monitoring plan noted in paragraph 13 above.

          Respondent shall comply with 326 IAC 6-4 and 326 IAC 5-1.

          "Force Majeure", for purposes of this Agreed Order, is defined as any event arising from causes beyond the control of the Respondent that delays or prevents the performance of any obligation under this Agreed Order despite Respondent's best efforts to fulfill the obligation. The requirement that the Respondent exercise "best efforts to fulfill the obligation" includes using best efforts to anticipate any potential force majeure event and best efforts to address the effects of any potential force majeure event (1) as it is occurring and (2) following the potential force majeure event, such that the delay is minimized to the greatest extent possible. "Force Majeure" does not include financial inability to complete the work required by this Agreed Order or increases in costs to perform the work.

          The Respondent shall notify IDEM by calling within three (3) calendar days and by writing no later than seven (7) calendar days after any event which the Respondent contends is a force majeure. Such notification shall describe the anticipated length of the delay, the cause or causes of the delay, the measures taken or to be taken by the Respondent to minimize the delay, and the timetable by which these measures will be implemented. The Respondent shall include with any notice all available documentation supporting their claim that the delay was attributable to a force majeure. Failure to comply with the above requirements shall preclude Respondent from asserting any claim of force majeure for that event. The Respondent shall have the burden of demonstrating that the event is a force majeure. The decision of whether an event is a force majeure shall be made by IDEM and shall be communicated to the Respondent. Respondent may appeal the decision.

          If a delay is attributable to a force majeure, IDEM shall extend, in writing, the time period for performance under this Agreed Order, by the amount of time that is attributable to the event constituting the force majeure.

          Respondent is assessed a Civil Penalty of Sixteen Thousand One Hundred Twenty-Five Dollars ($16,125) for the air violations alleged in this section.

          All submittals required by this section of the Agreed Order, unless notified otherwise in writing, shall be sent to:

            Matthew Stuckey, Senior Environmental Manager
            Office of Enforcement/Air Section
            IDEM
            P.O. Box 6015
            Indianapolis, IN 46206-6015

          In the event the following Order terms and conditions are violated during the two- year period following the compliance dates listed below, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amounts:

        Violation            Penalty        Compliance Date
        paragraphs 2,3 (Disa controls)     $1000 per day        Effective Date of Order
        paragraph 5 (cupola controls)    $1000 per day        January 31, 1999
        paragraph 6 (cupola stack test)    $500 per day        180 days after start up
        paragraph 8 (Disa relocation)    $100 per day        15 days after construction
        paragraph 9 (Disa stack tests)    $500 per day        180 days after construction
        paragraph 10 (O&M)        $100 per violation     immediately after construction
        paragraph 11 (O&M log)    $100 per violation    immediately after installation
        paragraph 12 (submit SOPs)    $100 per day        30 days after Effective Date
        paragraph 14 (comply w/SOPs)    $100 per violation    upon submission
        paragraph 15 (rules 6-4, 5-1)     $3500 per violation    Effective Date of Order
        
B.    Solid Waste: Cause No. SW-256

          Respondent shall fund financial assurance for areas B and C of the landfill designated in Exhibit 1 in accordance with the approved Closure/Post-Closure Plan within forty-five (45) days of the Effective Date of the Agreed Order.
                    
          Respondent shall close areas B and C of the landfill as designated in Exhibit 1 in accordance with the approved Closure/Post-Closure Plan.

          Respondent shall complete closure activities for areas B and C of the landfill as designated in Exhibit 1 within one hundred eighty (180) days of receipt of the approved Closure/Post-Closure Plan.

          Respondent shall submit closure certification in accordance with 329 IAC 10-37-7 within sixty (60) days of completion of closure of areas B and C of the landfill.

          Respondent shall begin post-closure activities for areas B and C of the landfill as designated in Exhibit 1 upon receipt of the approved closure certification.

          Respondent shall immediately cease and desist from the unpermitted depositing of solid waste at the Site and shall effectively restrict access.

          All submittals required by this section of the Agreed Order, unless notified otherwise in writing, shall be sent to:

            Solid Waste Enforcement Section Chief
            Office of Enforcement                        
            IDEM
            P.O. Box 6015                        
            Indianapolis, IN 46206-6015

          Respondent is assessed a civil penalty of Thirty Thousand Eighty-Four Dollars ($30,084) for the solid waste violations alleged in this section.

          In the event the following Order terms and conditions are violated, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amounts:

        Violation                        Penalty
        Condition #22, #24 and #25             $500 per week per violation

C.     General Provisions

          Respondent is assessed a civil penalty of Sixteen Thousand One Hundred Twenty- Five Dollars ($16,125) for air violations and a civil penalty of Thirty Thousand Eighty-Four Dollars ($30,084) for solid waste violations for a total combined civil penalty of Forty-Six Thousand Two Hundred Nine Dollars ($46,209). This penalty reflects a reduction by IDEM based upon evidence submitted by the Respondent which adequately demonstrated an inability to pay a penalty in the amount commensurate with the violations. Said penalty amount shall be payable to the Environmental Management Special Fund in twelve (12) equal quarterly

installments. The first installment of Three Thousand Eight Hundred Fifty Dollars and Seventy-Five Cents ($3,850.75) shall be due within thirty (30) days of the Effective Date of this Agreed Order. Subsequent payments shall be due every ninety (90) days thereafter until the balance is paid in full.

          Stipulated penalties shall be due and payable within thirty (30) days after Respondent receives written notice that the Complainant has determined a stipulated penalty is due.

          Civil and stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the Cause Numbers of this action and shall be mailed to:

            Cashier
            IDEM
            P.O. Box 7060
            Indianapolis, IN 46207-7060.
    
          In the event that the combined civil penalty of $46,209 is not paid as required by paragraph 31 of this Agreed Order, Respondent shall pay interest on the unpaid balance at the rate established by IC 24-4.6-1-101. The interest shall continue to accrue until the civil penalty is paid in full.

          This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, successors, subsidiaries, and assigns. The signatories to this Agreed Order certify that they are fully authorized to execute this document and legally bind the parties they represent. No change in ownership, corporate, or partnership status of the Respondent shall in any way alter its status or responsibilities under this Agreed Order.

          In the event that any terms of this Agreed Order are found to be invalid, the remaining terms shall remain in full force and effect and shall be construed and enforced as if the Agreed Order did not contain the invalid terms.

          The Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred. Respondent shall require, by contract, that all contractors, firms, and other persons performing work related to complying with this Agreed Order, comply with the terms of the Agreed Order.

          This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order and IDEM issues a Resolution of Cause letter to Respondent.

Date:             Title:

By:___________________________        Date:
Paul Higginbotham, Chief
Solid Waste Section, Office of Enforcement    

Date:_________________________

COUNSEL FOR COMPLAINANT:            COUNSEL FOR RESPONDENT:
Department of Environmental Management            

By:             By: _________________________
Office of Legal Counsel-Air Section

Date:             Date: ________________________

By: _________________________
Office of Legal Counsel-Solid Waste Section

Date: ________________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

THIS DAY OF , 199 .

                            For the Commissioner:    

                             Signed on 9/25/98
                            David J. Hensel, Director
                            Office of Enforcement

Converted by Andrew Scriven