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.

TOWN OF SPEEDWAY,

Respondent.

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Case No. 2005-15283-W




 

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, entry into the terms of this Agreed Order does not constitute an admission of any violation contained herein.  Respondent’s entry into this Agreed Order shall not constitute a waiver of any defense, legal or equitable, which the Respondent may have in any future administrative or judicial proceeding, except a proceeding to enforce this order.

 

 

I.  FINDINGS OF FACT

 

1.                  The Complainant is the Commissioner (Complainant) of the Indiana Department of Environmental Management, a department of the State of Indiana created by Indiana Code (IC) 13-13-1-1.

 

2.                  The Respondent is the Town of Speedway (Respondent), which operates a publicly owned treatment works (POTW) comprised of a combined storm and sanitary sewer collection system and a 7.5 MGD activated sludge wastewater treatment plant (WWTP), located at 4251 West Vermont Street, in Marion County, Indiana, (Site).

 

3.                  The Respondent’s NPDES permit No. IN0032972 (the Permit), effective November 1, 2001, authorizes the Respondent to discharge from the WWTP Outfall 001 to receiving waters named Lower Eagle Creek in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in the Permit.

 

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

 

5.                  Pursuant to IC 13-30-3-3, IDEM issued on March 21, 2006, a Notice of Violation (NOV), via Certified Mail to Lu Hillmer, President, Speedway Town Council.

 

6.                  Record reviews were conducted at the site on the dates specified below by a representative of IDEM’s Office of Water Quality (OWQ).  The violations described in the following paragraphs were in existence or observed at the time of these record reviews, and were cited in the NOV.

 

7.                  Pursuant to 327 Indiana Administrative Code (IAC) 5-2-8(1) and Part II.A.1 of the Permit, the permittee shall comply with all terms and conditions of its permit.

 

8.                  Pursuant to 327 IAC 5-2-8(1), Part II.A.1 of the Permit, 327 IAC 5-2-8(8), and Part II.B.1 of the Permit, the Respondent is required to, at all times, maintain in good working order and efficiently operate all waste collection, control, treatment, and disposal facilities.

 

9.                  Part I.A.1 of the Permit contains the final effluent limitations applicable to the discharge from the Respondent’s WWTP at Outfall 001 to Lower Eagle Creek.

Discharge Monitoring Reports and Monthly Reports of Operation submitted by the Respondent to IDEM for the period between May 2004 and August 2005 reveal that the Respondent failed to meet final effluent limitations contained in Part I.A.1 of the Permit as follows:

 

The weekly maximum and/or monthly average concentration effluent limitations for Ammonia Nitrogen (NH3) were exceeded in May, June, July, and December of 2004; and March, April, May, June, and August of 2005.

 

The weekly maximum and/or monthly average concentration effluent limitations for Total Suspended Solids (TSS) were exceeded in May, June,   November, and December of 2004.

 

The daily maximum effluent limitation for E.coli were exceeded in April, June, July, and August of 2005.

 

The Respondent's failure to meet effluent limitations contained in the Permit is in violation of 327 IAC 5-2-8(1), Part II.A.1 of the Permit, Part I.A.1 of the Permit,  327 IAC 5-2-8(8), and Part II.B.1 of the Permit.

 

10.             Pursuant to 327 IAC 5-2-8(10)(D) and Part II.C.4 of the Permit, the Respondent shall report noncompliance at the time the Discharge Monitoring Reports are submitted to IDEM.  The written noncompliance submission must include a description of the noncompliance and its cause; the period of noncompliance, including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance.

 

11.             The Respondent failed to report, at the time of submitting the Discharge Monitoring Reports to IDEM for a few of the months that effluent violations occurred, the steps taken or planned by the Respondent to reduce, eliminate and prevent the instances of noncompliance.  Such failure to report is in violation of 327 IAC 5-2-8(10)(D) and Part II.C.4 of the Permit.  The Respondent did provide a summary of the ammonia treatment problems in controlling the thickness of the moss-like growth on the fixed film bio-towers in October 2004, and in March, April and May 2005, including a comment of high ammonia concentration in the belt press filtrate.  To address E.coli noncompliance, the Respondent did provide multiple comments that the chlorine dosage was being increased and sampling and laboratory procedures were being reviewed. 

 

12.             In recognition of the settlement reached, the 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.                  The Respondent shall comply with 327 IAC 5-2-8(1), 327 IAC 5-2-8(8), 327 IAC 5-2-8(10)(D) and Parts I.A.1, II.A.1, II.B.1, II.B.2, and II.C.4 of the Permit.

 

3.                  Beginning on the Effective Date of this Agreed Order, and continuing until implementation of the Compliance Plan required pursuant to Order Paragraph 4 is complete, the Respondent shall, at all times, operate its wastewater treatment facility as efficiently and effectively as possible.

 

4.                  Within 120 days of the Effective Date of this Agreed Order, the Respondent shall develop and submit to IDEM for its approval a compliance plan (CP) that includes, but is not limited to, the following:

 

A.                 A description of the actions that the Respondent will take and management systems that the Respondent will develop and implement to achieve and maintain continuous compliance with all terms and conditions contained in the Permit.  Such actions shall include, but not be limited to evaluation of the wastewater treatment process, evaluation of alternatives for improving and enhancing the treatment to improve effluent quality, and routine operation and maintenance of the treatment facilities.

 

B.                 A schedule for initiation and completion of all actions described in the CP, including specific milestone dates.

 

5.                  The Respondent shall, within 12 months of the completion of the portion of the CP required by Order Paragraph 4 (Performance Period), demonstrate compliance with effluent limitations for a period of 11 consecutive months.  In the event that noncompliance with Permit effluent limitations occurs during the Performance Period, the Respondent shall, within 60 days of becoming aware of the noncompliance, submit to IDEM for its approval, an Additional Effluent Limitation Compliance Plan, that includes a description of the additional actions that the Respondent will take to achieve and maintain compliance with the permit effluent limitations and a schedule, including specific milestone dates for initiating and completing such actions.

 

6.                  The plans required by Order Paragraphs 4 and 5 are subject to IDEM approval.  In the event that IDEM determines any plan to be deficient or otherwise unapprovable, the Respondent shall, upon written notice by IDEM, revise and resubmit the plan, in accordance with IDEM’s written notice.  If, after three submissions of the plan by the Respondent, IDEM finds the plan to be deficient or otherwise unapprovable, IDEM may require the Respondent to revise and resubmit the plan, or alternatively, may modify and approve the plan, in which case the Respondent shall implement the plan as modified and approved by IDEM.

 

7.                  Upon approval by IDEM, any plan required pursuant to this Agreed Order shall be incorporated into the Agreed Order and shall be deemed an enforceable part thereof.  The Respondent, upon receipt of written approval from IDEM, shall immediately implement the approved plan and adhere to the schedule contained therein.

 

8.                  The Respondent shall notify IDEM, in writing, within 10 days of completion of each action or milestone contained in any plan approved by IDEM pursuant to this Agreed Order. The notification shall include a description of the action completed and the date it was completed.

 

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

 

Paul Cluxton, Enforcement Case Manager

Indiana Department of Environmental Management

Office of Enforcement – Mail Code 60-02

100 North Senate Avenue

Indianapolis, IN  46204-2251

 

10.             The Respondent is assessed a civil penalty of Three Thousand  ($3,000) Dollars.  Said penalty amount shall be due and payable to the Environmental Management Special Fund within 30 days of the Effective Date.

 

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

 

Order Paragraph Number

Violation

Penalty Amount

4

Failure to submit the CP, as required.

$250 per each week or part thereof late

5

Failure to comply with effluent limitations subsequent to completion of implementation of the portion of the CP required pursuant to Order Paragraph 4.

$500 per violation

5

Failure to submit Additional Compliance Plan, if required.

$250 per each week or part thereof late

6

Failure to revise and resubmit any plan required pursuant to this Agreed Order, as required.

$250 per each week or part thereof late

7

Failure to implement an approved plan, or to meet any milestone date set forth in any approved plan.

$500 per each week or part thereof late

8

Failure to notify IDEM, in writing, within 10 days of completion of each action contained in the approved action plan.

$250 per each week or part thereof late

 

12.             Stipulated penalties shall be due and payable within 30 days after the 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 the Respondent's violation of this Agreed Order, or Indiana law, including but not limited to civil penalties pursuant to IC 13-30-4.

 

13.             Civil and stipulated penalties are payable by check to the Environmental Management Special Fund.  Checks shall include the Case Number (2005-15283-W) of this action and shall be mailed to:

 

Indiana Department of Environmental Management

Cashiers Office – Mail Code 50-10C

100 N. Senate Avenue

Indianapolis, IN 46204-2251

 

14.             In the event that the civil penalty required by Order Paragraph 10, is not paid when due, 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.

 

15.             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.

 

16.             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.

 

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

 

18.             "Force Majeure" for purposes of this Agreed Order, is defined as any event arising from causes totally beyond the control and without fault 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 changed business or economic conditions, 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 the case manager within three (3) calendar days and by writing no later than seven (7) calendar days after it has knowledge of 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 its 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.

 

IDEM agrees that, 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 directly attributable to the event constituting the force majeure.

 

19.             This Agreed Order shall remain in effect until the Respondent complies with the terms of Order Paragraphs 3 through 14 and until IDEM issues a Close-Out letter to the Respondent.

 

 

TECHNICAL RECOMMENDATION:

 

RESPONDENT:

Department of Environmental Management

 

Town of Speedway

 

By:

 

 

By:

 

 

Mark W. Stanifer, Chief

 

Printed:

 

 

Water Enforcement 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

 

, 200

 

.

 

 

For The Commissioner:

 

 

 

Signed on May 17, 2006

 

Matthew T. Klein

 

Assistant Commissioner for

 

Compliance and Enforcement