STATE OF INDIANA

COUNTY OF MARION

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SS:

BEFORE THE INDIANA DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT,

Complainant,

v.

TIM PURCELL d/b/a PURCELL AUTO PARTS,

Respondent.

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Case No.
2005-15757-H




 

 

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.

 

 

I.  FINDINGS OF FACT

 

1.         Complainant is the Commissioner (“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 Tim Purcell d/b/a Purcell Auto Parts ("Respondent"), which owns and/or operates the company located at 1602 N. Center Street, in Kramer, Hamilton County, Indiana (“Site”).

 

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

 

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

 

Tim Purcell, Owner

Tim Purcell d/b/a Purcell Auto Parts

1602 N. Center Street

Kramer, IN 47918

 

5.         Respondent owns and operates an auto salvage yard and processes scrap metal.  Respondent processed about 150 vehicles last year.  At the time of the inspection, Respondent was storing over 1,000 waste tires on-site.

 

6.         An inspection on April 17, 2006 was conducted at the Site by a representative of IDEM’s Office of Land Quality (“OLQ”).  The following violations were in existence or observed at the time of this inspection:

 

a.         Pursuant to 329 IAC 13-4-3(d), generators must label all used oil containers and aboveground tanks with the words “Used Oil.”  Respondent did not label four (4) used oil containers with the words “Used Oil.”

 

b.         Pursuant to 327 IAC 15, a person who has a point source discharge of storm water associated with industrial activity and meets the general and applicability requirements of 327 IAC 15-2-2(a)(1), 15-2-3, and 15-6-2, must comply with, among other things, the requirements of 327 IAC 15-2-5, 15-6-5, 15-6-7, 15-6-7.3, and 15-6-7.5.  Point source discharges of storm water associated with industrial activity have occurred at the Site, and Respondent’s industrial activity meets the general and applicability requirements of 327 IAC 15-2-2(a)(1), 15-2-3, and 15-6-2, but Respondent had not complied with the requirements of 327 IAC 15-6-7, 15-6-7.3, and 15-6-7.5

 

c.         Pursuant to 327 IAC 15-6-2(a)(5)(E), the requirements of this rule apply to all facilities involved in the recycling of materials, including metal scrap yards, battery reclaimers, salvage yards, and automobile junkyards, including those classified under the following SIC codes:

 

(i)         5015 (motor vehicle parts, used), and

 

(ii)        5093 (scrap and waste materials).

Respondent failed to comply with the requirements of 327 IAC 15-6, including, but not limited to, the following:

 

(a)       Failure to develop, implement, update, and maintain a Storm Water Pollution Prevention Plan as required by 327 IAC 15-6-7.

 

(b)       Failure to monitor as required by 327 IAC 15-6-7.3.

 

(c)        Failure to submit an annual report to the commissioner as required      by 327 IAC 15-6-7.5.

 

d.         Pursuant to 329 IAC 15-3-2, the owner or operator of a waste tire storage site shall possess a valid certificate of registration issued under 329 IAC 15-3; comply with all applicable requirements of 329 IAC 15-3; and maintain financial assurance as required by 329 IAC 15-5.  Respondent stored at least one thousand waste tires outside without a valid certificate of registration under 329 IAC 15-3; did not comply with all applicable requirements of 329 IAC 15-3; and did not maintain financial assurance as required by 329 IAC 15-5.

 

e.         Pursuant to 329 IAC 10-4-2, no person shall cause or allow the storage, containment, processing, or disposal of solid waste in a manner which creates a threat to human health or the environment, including the creating of a fire hazard, vector attraction, air or water pollution, or other contamination.  Respondent caused and/or allowed solid waste, waste tires, automotive fluid, oil, and fuel, to be stored and/or disposed at the Site in a manner that creates a threat to human health or the environment in violation of 329 IAC 10-4-2.

 

f.          Pursuant to IC 13-20-13-1.5(1) & (3), a person that stores waste tires shall     do so in a manner that does not pose a threat to human health or the environment, and controls vectors that pose a threat to human health.  Respondent failed to take actions to prevent the breeding and control of vectors, and mosquitoes, that pose a threat to human health.

 

g.         Pursuant to IC 13-30-2-1(14), no person shall apply or allow the application of used oil to any ground surface.  Respondent allowed the application of used oil to the ground surface.  Oil sheen was observed on ponds of water at the Site.

 

h.         Pursuant to IC 13-30-2-1(5), no person shall dump or cause or allow the open dumping of garbage or any other solid waste in violation of 329 IAC 10-4-2 and 329 IAC 10-4-3. Respondent caused and/or allowed waste tires, automotive fluid, oil, fuel, and other solid wastes to be open dumped at the Site.

 

i.          Pursuant to 329 IAC 10-4-3, open dumping and open dumps, as those terms are defined in IC 13-11-2-146 and IC 13-11-2-147, are prohibited.  Respondent caused and/or allowed waste tires, automotive fluids, oil, fuel, and other solid wastes, to be open dumped at the Site.

 

7.         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.         Upon the Effective Date of this Order, Respondent shall comply with 329 IAC 13-4-3(d).  Specifically, Respondent shall ensure that all containers of used oil are labeled with the words “Used Oil.”

 

3.         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(3).  Specifically, Respondent shall remove all tires from the Site and dispose of them at a permitted solid waste management facility.

 

4.         Within forty-five (45) days of the Effective Date of this Agreed Order, Respondent shall submit written documentation that the tires removed from the Site have been taken to a permitted solid waste management facility.

 

5.         Respondent shall ensure that all work conducted to satisfy the requirements of Order paragraph 2 above is done in compliance with all applicable federal, state, and local laws and regulations.

 

6.         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(5).  Specifically, Respondent shall remove all solid waste and garbage from the site and dispose of it properly.

 

7.         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with IC 13-30-2-1(3), (4) and (5).  Specifically, Respondent shall clean up all releases evident by soil staining by excavating the soil six inches beyond visible contamination:

 

8.         Within forty-five (45) days of the Effective Date of this Agreed Order, Respondent shall submit to IDEM documentation that releases in the above areas have been cleaned up.

 

9.         Within thirty (30) days of the Effective Date of this Agreed Order, Respondent shall comply with 327 IAC 15-2-5(a) and submit an NOI letter, which complies with all of the requirements of 327 IAC 15-3 and 327 IAC 15-6-5, to IDEM.

 

10.       In the event IDEM determines that the NOI letter submitted by Respondent is deficient or otherwise unacceptable, Respondent shall revise and resubmit the NOI to IDEM in accordance with IDEM’s notice.

 

11.       Within ninety (90) days of the Effective Date of this Agreed Order, Respondent shall conduct monitoring as required by 327 IAC 15-6-7.3.

 

12.       Within thirty (30) days after laboratory analyses conducted pursuant to Order paragraph 11 have been completed, Respondent shall submit sampling data results to IDEM for review.  Respondent shall also, in accordance with 327 IAC 15-6-7(b)(9), include the sampling data results in the Storm Water Pollution Prevention Plan required by Order paragraph 13.

 

13.       Within one hundred and eighty (180) days of the Effective Date of this Agreed Order, Respondent shall comply with 327 IAC 15-6-7.  Specifically, Respondent shall develop and submit to IDEM for approval a Storm Water Pollution Prevention Plan.

 

14.       Within ten (10) days of notice of IDEM’s approval of the Storm Water Pollution Prevention Plan, Respondent shall implement the plan as approved.

 

15.       In the event IDEM determines that any plan submitted by Respondent is deficient or otherwise unacceptable, Respondent shall revise and resubmit the plan to IDEM in accordance with IDEM's notice.  After three (3) submissions of such plan by Respondent, IDEM may modify and approve any such plan and Respondent must implement the plan as modified by IDEM.  The approved plan shall be incorporated into this Agreed Order and shall be deemed an enforceable part thereof.

 

16.       Within three hundred and ninety-five (395) days of the Effective Date of this Agreed Order, Respondent shall submit an Annual Report in accordance with 327 IAC 15-6-7.5

 

17.       All submittals required by this Agreed Order, unless notified otherwise in writing, shall be sent to:

 

Deirdre Wyatt, Enforcement Case Manager

Indiana Department of Environmental Management

Office of Enforcement            Mail Code 60-02

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

18.       In the event the terms and conditions of the following paragraphs are violated, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amount:

 

Violation

Penalty

Failure to comply with Order paragraph 4

$250 per week

Failure to comply with Order paragraph 6

$250 per week

Failure to comply with Order paragraph 8

$250 per week

Failure to comply with Order paragraph 9

$250 per week

Failure to comply with Order paragraph 10

$250 per week

Failure to comply with Order paragraph 11

$250 per week

Failure to comply with Order paragraph 12

$250 per week

Failure to comply with Order paragraph 13

$250 per week

Failure to comply with Order paragraph 14

$250 per week

Failure to comply with Order paragraph 15

$250 per week

Failure to comply with Order paragraph 16

$250 per week

 

19.       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.  Assessment and payment of stipulated penalties shall not preclude the Complainant from seeking any additional relief against the Respondent for violation of the Agreed Order.  In lieu of any of the stipulated penalties given above, the Complainant may seek any other remedies or sanctions available by virtue of Respondent’s violation of this Agreed Order or Indiana law, including, but not limited to, civil penalties pursuant to IC 13-30-4.

 

20.       Stipulated penalties are payable by check to the Environmental Management Special Fund.  Checks shall include the Case Number of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Cashier’s Office            Mail Code 50-10C

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

21.       This Agreed Order shall apply to and be binding upon the Respondent, its successors 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.

 

22.       In the event that any terms of the 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.

 

23.       Notwithstanding any other provision of this Agreed Order, the Complainant reserves, and this Agreed Order is without prejudice to, the right to institute proceedings in this action or in a new action for injunctive relief, costs, civil penalty and/or remediation of environmental contamination that is either discovered after the entry into the Agreed Order or that has not been adequately remedied despite compliance by Respondent with the terms of this Agreed Order.

 

24.       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.

 

25.       This Agreed Order shall remain in effect until IDEM issues a Resolution of Case letter to Respondent.

 

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

 

 

 

 

By:

 

 

By:

 

 

Nancy L. Johnston, Cheif

 

Printed:

 

 

Hazardous Waste Section

 

Title:

 

 

Office of Enforcement

 

 

 

Date:

 

 

Date:

 

 

 

 

 

 

 

 

 

COUNSEL FOR COMPLAINANT:

 

COUNSEL FOR RESPONDENT:

Department of Environmental Management

 

 

 

 

 

By:

 

 

By:

 

 

 

 

 

 

 

Office of Legal Counsel

 

 

 

Date:

 

 

Date:

 

 

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

 

DAY OF

 

, 2006.

 

 

For The Commissioner:

 

 

 

Signed on October 5, 2006

 

Matthew T. Klein

 

Assistant Commissioner

 

of Compliance and Enforcement