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

COMMISSIONER OF THE DEPARTMENT    )
OF ENVIRONMENTAL MANAGEMENT,    )
                            )
            Complainant,            )
                            )    CAUSE NO. SW-355
            v.                )
    )
    )
WASTE MANAGEMENT OF ILLINOIS, INC.    )
                            )
            Respondent.            )

AGREED ORDER

    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. Pursuant to IC 13-30-3-3(c), entry into the terms of this Agreed Order does not constitute an admission to any finding of fact, conclusion of law or allegation of a violation contained herein. This Agreed Order is entered into solely for the purpose of resolving this disputed matter.

I. FINDINGS OF FACT

1.    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.

2.    Respondent is Waste Management of Illinois, Inc. (hereinafter referred to as the "Respondent"), who owns and operates the CID Chicago Sorting Center Transfer Station at 13707 South Jeffrey, Chicago, Illinois, 60633.

3.    The Indiana Department of Environmental Management ("IDEM") has jurisdiction over the subject matter of this action. For the purpose of resolving this matter, the Respondent agrees to submit to the personal jurisdiction of IDEM.

4.    Pursuant to IC 13-30-3-3, IDEM issued a Notice of Violation via Certified Mail to:

        CID Chicago Sorting Center
        13707 South Jeffrey
        Chicago, Illinois 60633

5.     IDEM has reviewed two hundred sixty-five (265) municipal waste transfer manifests, which reveal that the Respondent has engaged in municipal waste transfer activities in Indiana between the dates of October 6, 1997 and October 18, 1997. These activities relate to the shipment of municipal waste from the Respondent's CID Chicago Sorting Center to Deercroft RDF (an Indiana disposal facility). The above mentioned manifests contain an acknowledgement number not assigned to the Respondent's CID Chicago Sorting Center. IDEM has also reviewed its disclosure statement files, which reveal that the Respondent has not submitted a disclosure statement specifically for the CID Chicago Sorting Center. Instead, the Respondent has used an acknowledgement number, IL-02- 0013, issued to the Respondent to operate a transfer station at 62105 W. 101st Street, Chicago Ridge, Illinois location. Information which the Respondent would have provided for this transfer station (other than its address) would not have differed from that it did provide for its other waste transfer activities. Based upon the reviews, the Respondent has violated Indiana Code (IC) 13-20-6-2 and IC 13-20-4-7(c)(5), for not having a separate acknowledgement number for the CID Chicago Sorting Center. Every shipment of municipal waste, as evidenced by a manifest, constitutes a separate violation of these statutory provisions.

6.    IC 13-20-6-2 states:
        (a) Before an operator engages in municipal waste transfer activities, the operator and each responsible party must submit a disclosure statement to the department that:
            (1) meets the requirements set forth in subsection (b); and         
             (2) is executed under subsection (c).
         (b) The disclosure statement required under this section must set forth the          following information:

            (1) The name, business address, and Social Security number or federal taxpayer identification number of the operator or responsible party.
            (2) A description of the operator's or responsible party's experience in the collection, transportation and disposal of municipal waste.
            (3) A description of all civil and administrative complaints against the operator or responsible party for the violation of a state or federal environmental protection law that:
                (A) have resulted in a fine or civil penalty of more than ten thousand dollars ($10,000) within five (5) years before the date of the submission of the disclosure document; or
                (B) allege an act or omission that:
                      (i) constitutes a material violation of the state or federal environmental protection law; and
                     (ii) presented a substantial endangerment to the public health or the environment;
              within (5) years before the date of the submission of the disclosure document.
             (4) A description of all pending criminal complaints alleging the violation of a state or federal environmental protection law that have been filed against the operator or responsible party within five (5) years before the date of the submission of the disclosure statement.
            (5) A description of all judgments of criminal conviction entered against the operator or responsible party within (5) years before the date of submission of the disclosure statement for the violation of a state or federal environmental protection law.
            (6) A description of all judgments of criminal conviction of a felony constituting a crime of moral turpitude under the laws of a state or the United States that are entered against the operator or responsible party within five (5) years before the date of submission of the disclosure statement.
            (7) A description of federal, state, and local environmental permits, including identification numbers, that the operator or responsible party holds.
        (c) A disclosure statement submitted under subsection (a) must be:
            (1) executed under oath or affirmation; and
            (2) subject to the penalty for perjury under IC 35-44-2-1.
        (d) The department may investigate and verify the information set forth in a

statement required under this section.

        (e) Before December 31 of each year, an operator or a responsible party who has submitted a disclosure statement under this section must submit to the department a statement that:
            (1) describes changes that have:
                (A) occurred since the filing of the disclosure statement; and
                (B) made the information contained in the disclosure statement no longer current; or
             (2) indicates that no changes described in subdivision (1) have occurred.

7.    Although the Respondent submitted a disclosure statement as an operator who manages the activities of a transfer station, the Respondent has not submitted a disclosure statement to IDEM for this particular transfer station. Therefore, IDEM finds the Respondent to be in violation of IC 13-20-6-2.

8.    IC 13-11-2-148(c) states:
        "Operator", for purposes of IC 13-20-6, means a corporation, a limited liability company, a partnership, a business association, a unit, or an individual who is a sole proprietor that is one (1) of the following:
            (1)    A broker.
            (2)     A person who manages the activities of a transfer station that receives municipal waste.
            (3)    A transporter

9.    IC 13-20-6-5 states:
        When an operator or responsible party submits an initial disclosure statement or an annual update of a disclosure statement to the department under this chapter, the department shall send a letter to the operator or responsible party that:
            (1) acknowledges the receipt of the disclosure statement; and
            (2) contains an acknowledgment number issued to the operator by the department.

10.    IC 13-20-4-7(c)(5) states:
        A manifest required under subsection (b) must include the following information: If the municipal waste is transported from a transfer station that receives municipal waste, the identity of and acknowledgment number issued by the department under IC 13-20-6-5 or IC 13-7-10.5-14( before its repeal) to the following:

            (A) The transporter of the municipal waste.
            (B) The transfer station from which the municipal waste is transported.
            (C) A broker involved in the transportation of the municipal waste.

11.    Manifests reviewed by IDEM did not include an acknowledgment number, assigned by IDEM, for the CID Chicago Sorting Center. Therefore, IDEM finds that the Respondent has violated IC 13-20-4-7(c)(5).

12.    This Agreed Order resolves all violations for failing to file a disclosure statement (IC 13- 20-6-2) and to use the proper acknowledgement number (IC 13-20-4-7(c)(5)) committed by the Respondent prior to and including the date this Agreed Order is adopted by IDEM.    

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

            

II. ORDER

1.    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.

2.    Respondent shall maintain compliance with all applicable laws and rules from the date of the issuance of this Order.

3.    Respondent shall not engage in waste transfer activities in Indiana from the CID Chicago Sorting Center, including the shipping, transporting or brokering of shipments of municipal waste to an Indiana transfer station or disposal facility unless it has been issued an acknowledgement number in accordance with IC 13-20-6-5.

4.    As a result of the violations detailed in the FINDINGS, the Respondent shall pay a fine or penalty of four thousand six hundred dollars ($4,600) to the Indiana Environmental Management Special Fund (Fund) within ten (10) days of the Effective Date of this Agreed Order.                         

5.    Civil penalties are payable by check to the Fund. Checks shall include the Cause Number of this action and shall be mailed to:

        Cashier
        IDEM
        100 North Senate Avenue
        P.O. Box 7060
        Indianapolis, Indiana 46207-7060

6.    As a Supplemental Environmental Project (SEP), the Respondent will provide fifty-one thousand seven hundred fifty-seven dollars ($51,757) worth of disposal capacity free of charge at any Indiana landfill over which Waste Management of Indiana, L.L.C. has control for the remediation of improperly disposed solid waste, including waste tires, within Indiana. Each load will be subject to disposal in accordance with Waste Management of Indiana, L.L.C.'s random inspection program. This disposal capacity shall be used for the disposal of solid waste from the cleanups of illegal solid waste sites selected by IDEM on dates selected by IDEM. The value of this SEP is calculated at twenty dollars ($20.00) per gate ton and adjusted yearly per the consumer price index. The $20.00 per gate ton does not include any solid waste fees or solid waste district fees imposed under state statute. Also, the $20.00 per gate ton is dependent upon the waste for disposal consisting of municipal solid waste, construction/demolition waste or waste tires. Waste tires must not need further processing by the landfills to be legally disposed. This Condition shall remain in effect for a period of four (4) years from the Effective Date of this Agreed Order.        
                    
7.    In the event that the civil penalty required by Order Condition #4 is not paid within ten (10) days of the Effective Date of this Agreed Order, the 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.

8.    If the SEP described in Order Condition #6 is not completed in accordance with this Agreed Order, including the time frame set out in Order Condition #6, the Respondent shall be assessed, without any further action on part of the Complainant being necessary, a civil penalty of the outstanding balance of the SEP divided by 1.25. Such civil penalty amount shall be due and payable to the Environmental Management Special Fund within fifteen (15) days after receipt of a notice to pay from IDEM.

9.    This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, and assigns. The Respondent's 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.

10.    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.
            

11.    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 ensure that all contractors, firms and other persons performing work under this Agreed Order comply with the terms of this Agreed Order.

12.    This Agreed Order shall remain in effect until Respondent has complied with all terms and conditions of this Agreed Order.

                

    

                


TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By:___________________________        By:____________________________
Paul Higginbotham, Chief
Solid Waste Section                Printed:________________________
Office of Enforcement
                            Title:__________________________

Date:_________________________            Date:__________________________

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

By:___________________________        By:____________________________
Office of Legal Counsel
Department of Environmental Management

Date:__________________________        Date:___________________________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS __________ DAY OF __________________, 1998.

                            For the Commissioner:


                            signed 8/14/98                                         David J. Hensel
                            Director
                            Office of Enforcement

Converted by Andrew Scriven