IE0
    AUG
    272009
    OFFICE OF THE
    ATTORNEY GENERAL
    STATE
    OF ILLINOIS
    P0IIL,t’on
    co,J10is
    O
    Bo
    Lisa Madigan
    ATTORNEY
    GENERAL
    August
    25, 2009
    John Therriult, A:iznt Ocrk
    Ilinois
    Pollution
    Control
    Board
    State of Illinois Center
    100
    West
    Randolph
    Chicago, Illinois 60601
    Re:
    People v. Barger Engineering,
    Inc.
    PCB
    06-82
    Dear Mr.
    Therriault:
    Enclosed for
    filing please find
    the
    original
    and ten copies
    of a Notice of Filing, MOTION
    FOR RELIEF FROM HEARING
    REQUIREMENT
    and STIPULATION
    AND PROPOSAL
    FOR
    SETTLEMENT in regard to the
    above-captioned
    matter.
    Please
    file the originals and return
    file-
    stamped copies
    to
    me in the
    enclosed,
    self-addressed envelope.
    Thank you
    for your
    cooperation and consideration.
    Very
    truly
    yours,
    Thomas Davis,
    Chief
    Environmental
    Bureau
    500 South
    Second Street
    Springfield, Illinois
    62706
    (217)
    782-9031
    TD/pjk
    Enclosure
    500 South Second Street, Springfield,
    Illinois 62706
    °
    (217) 782-1090 • TTY: (877) 844-5461
    • Fax: (217) 782-7046
    100 West Randolph
    Street,
    Chicago,
    Illinois 60601
    • (312)
    814-3000
    • ‘FI’Y: (800) 964-3013
    • Fax:
    (312)
    814-3806

    BEFORE
    THE ILLINOIS POLLUTION
    CONTROL
    BOARD
    PEOPLE OF THE STATE OF
    ILLINOIS,
    Complarnant,
    vs.
    )
    PCB No. 06-82
    )
    (Enforcement)
    BARGER ENGINEERING, INC., an
    Indiana
    corporation,
    )
    Respondent.
    NOTICE_OF FILING
    ECElVEO
    To:
    Ms.
    Claire
    A.
    Manning
    CLERK’S
    OFFG
    Brown Hay & Stephens,
    LLP
    i )f19
    205 S. Fifth Street, Suite
    700
    Ui.,
    ,.
    Springfield, IL 62701
    JF%LUNOSd
    PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
    Control
    Board of the State of
    Illinois, a MOTION FOR RELIEF FROM HEARING
    REQUIREMENT
    and
    STIPULATION
    AND PROPOSAL
    FOR SETTLEMENT, copies of which are attached
    hereto
    and
    herewith
    served upon you.
    Respectfully submitted,
    PEOPLE OF THE STATE OF
    ILLINOIS
    LISA MADIGAN,
    Attorney General of the
    State of Illinois
    MATTHEWJ. DUNN, Chief
    Environmental Enforcement/Asbestos
    Litigation Division
    BY________________
    THOMAS DAVIS, Chief
    Assistant Attorney General
    Environmental Bureau
    500
    South
    Second Street
    Springfield,
    Illinois 62706
    21
    7/782.9031
    Dated:
    August 25,
    2009

    CERTIFICATE
    OF
    SERVICE
    I hereby certify
    that I
    did
    on
    August
    25,
    2009,
    send by First
    Class
    Mail, with postage
    thereon
    fully
    prepaid,
    by depositing
    in
    a United
    States Post
    Office Box
    a
    true
    and correct
    copy
    of the
    following
    instruments
    entitled
    NOTICE
    OF FILING,
    MOTION
    FOR
    RELIEF
    FROM
    HEARING
    REQUIREMENT and
    STIPULATION
    AND PROPOSAL
    FOR
    SETTLEMENT:
    To:
    Ms:
    Claire
    A.
    Manning
    Brown
    Hay &
    Stephens,
    LLP
    205
    S. Fifth
    Street,
    Suite
    700
    Springfield,
    IL 62701
    and
    the
    original
    and
    ten copies
    by
    First
    Class
    Mail
    with
    postage
    thereon fully
    prepaid
    of the
    same
    foregoing
    instrument(s):
    To:
    John
    T. Therrault,
    Assistant
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    Suite
    11-500
    100
    West
    Randolph
    Chicago,
    Illinois
    60601
    A
    copy
    was also
    sent
    by First
    Class
    Mail with
    postage
    thereon
    fully prepaid
    to:
    Carol
    Webb
    Hearing
    Officer
    Illinois Pollution
    Control
    Board
    1021 North
    Grand
    Avenue
    East
    Springfield,
    IL
    62794
    THOMAS
    DAVIS,
    Chief
    Assistant
    Attorney
    General
    This
    filing is
    submitted
    on
    recycled
    paper.

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    PEOPLE
    OF THE STATE OF ILLINOIS,
    )
    Complainant,
    )
    vs.
    )
    PCB
    No. 06-82
    )
    (Enforcement)
    BARGER ENGINEERING, INC,
    an
    )
    Indiana corporation,
    )
    AUG
    272009
    Respondent.
    )
    STATh
    OF
    ILLINOIS
    PoHutiri
    Control
    Board
    MOTION FOR RELIEF
    FROM HEARING
    REQUIREMENT
    NOW
    COMES Complainant,
    PEOPLE
    OF THE
    STATE OF ILLINOIS,
    by LISA
    MADIGAN,
    Attorney General
    of the State of Illinois,
    and pursuant to Section
    31(c)(2) of the
    Illinois Environmental Protection Act (“Act”), 415 ILCS
    5131(c)(2) (2008), moves
    that
    the Illinois
    Pollution Control Board grant the parties in the above-captioned
    matter relief from the
    hearing
    requirement imposed
    by Section 31(c)(1) of the Act, 415 ILCS
    5131(c)(1) (2008). In
    support of
    ‘this
    motion, Complainant states as follows:
    1.
    The parties have reached agreement on all
    outstanding issues in this
    matter.
    2.
    This agreement is presented to the Board in
    a Stipulation and Proposal for
    Settlement, filed contemporaneously with this motion.
    3.
    All parties
    agree
    that a hearing on the Stipulation
    and Proposal for Settlement
    is
    not
    necessary, and
    respectfully
    request
    relief
    from such a hearing
    as
    allowed
    by Section
    31
    (c)(2) of the Act, 415
    ILCS 5/31 (c)(2) (2008).
    I

    WHEREFORE,
    Complainant,
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS, hereby
    requests
    that the Board
    grant this
    motion
    for relief
    from the hearing requirement
    set
    forth in
    Section
    31(c)(1)
    of
    the Act,
    415 ILCS
    5/31(c)(1) (2008).
    Respectfully
    submitted,
    PEOPLE OF
    THE
    STATE
    OF ILLINOIS
    LISA MADIGAN
    ATTORNEY
    GENERAL
    MATTHEWJ.
    DUNN, Chief
    Environmental
    Enforcement/Asbestos
    Litigation Division
    BY:_______________________
    THOMAS DAVIS,
    Chief
    Environmental
    Bureau
    Assistant
    Attorney General
    500 South Second
    Street
    Springfield,
    Illinois
    62706
    217/782-9031
    Dated: August
    25, 2009
    2

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS,
    )
    )
    Complainant,
    )
    )
    v.
    )
    PCB
    NO.
    06-82
    )
    (Enforcement)
    BARGER
    ENGINEERING,
    INC.,
    an
    Indiana
    )
    ECEVED
    corporation,
    )
    CLERK’S
    OFFICE
    AUG
    27
    2009
    Respondent.
    )
    STATE
    OF
    ILLINOIS
    STIPULATION
    AND PROPOSAL
    FOR
    SETTLEMtIOfl
    Control
    Board
    Complainant,
    PEOPLE
    OF
    THE
    STATE OF
    ILLINOIS,
    by
    LISA
    MADIGAN,
    Attorney
    General
    of the
    State
    of
    Illinois,
    the
    Illinois
    Environmental
    Protection
    Agency (“Illinois
    EPA”),
    and
    BARGER
    ENGINEERING,
    INC.
    (‘Respondent”),
    (“Parties
    to
    the
    Stipulation”)
    have
    agreed
    to
    the
    making
    of
    this
    Stipulation and
    Proposal for
    Settlement
    (“Stipulation”)
    and
    submit
    it
    to
    the
    Illinois
    Pollution
    Control
    Board
    (“Board”)
    for
    approval.
    This
    stipulation
    of
    facts
    is made
    and
    agreed
    upon
    for
    purposes
    of
    settlement
    only
    and
    as a
    factual basis
    for
    the
    Board’s
    approval of
    this
    Stipulation
    and
    issuance of
    relief.
    None
    of
    the
    facts
    stipulated herein
    shall be
    introduced
    into
    evidence
    in
    any
    other
    proceeding
    regarding
    the
    violations
    of
    the
    Illinois Environmental
    Protection
    Act
    (“Act”),
    415
    ILCS
    5/1
    et
    seq.
    (2006),
    and
    the
    Board’s
    Regulations,
    alleged
    in
    the
    Complaint
    except
    as
    otherwise
    provided
    herein.
    It
    is
    the
    intent
    of
    the
    parties to
    this
    Stipulation
    that
    it
    be
    a
    final
    adjudication
    of
    this
    matter.
    I.
    STATEMENT
    OF
    FACTS
    A.
    Parties
    to
    the
    Stipulation
    I.
    On
    December
    1,
    2005,
    a
    Complaint
    was
    filed
    on
    behalf
    of
    the
    People
    of
    the
    State

    of
    Illinois by
    Lisa
    Madigan,
    Attorney
    General
    of
    the
    State
    of
    Illinois, on
    her
    own
    motion
    and
    upon
    the
    request
    of
    the
    Illinois
    EPA,
    pursuant
    to
    Section 31
    of
    the
    Act,
    415
    ILCS
    5/31
    (2006),
    against
    the
    Respondent.
    On
    June
    29,
    2006,
    Complainant
    filed
    its
    first
    motion to
    amend
    the
    complaint
    and
    on
    October
    16,
    2007,
    Complainant
    filed
    its
    second motion to
    amend the
    complaint.
    Both
    motions
    were
    granted on
    November
    15,
    2007.
    On
    September
    15,
    2008,
    Complainant
    filed
    its
    third
    motion
    to
    amend
    the
    complaint,
    and
    that
    was
    granted on
    September
    30,
    2008.
    2.
    The
    Illinois EPA
    is
    an
    administrative
    agency
    of
    the
    State
    of
    Illinois, cieated
    pursuant
    to
    Section 4
    of
    the
    Act,
    415
    ILCS
    5/4
    (2006).
    3.
    At
    all
    times
    relevant
    to
    the
    Complaint,
    Respondent
    was
    and
    is
    an
    Indiana
    corporation
    that
    is
    authorized
    to
    transact
    business
    in
    the
    State
    of
    Illinois.
    Respondent
    owns,
    leases,
    and
    operates
    multiple
    oil
    wells,
    including
    salt
    water
    injection,
    in
    ‘White
    County,
    Illinois.
    At
    all
    times
    relevant
    to
    the
    Complaint,
    Respondent
    owned
    and
    operated
    the
    Phillipstown
    Unit
    Water
    Flood
    Plant
    located
    approximately
    five
    miles
    south
    of
    Crossville,
    two
    wells on
    the
    CT
    Spencer
    lease,
    1814
    County
    Road
    1750,
    Crossville,
    and
    a
    compression
    coupler
    located
    on
    a flow
    line
    at
    the
    Everett
    Spencer
    #9
    Production
    Well,
    1814
    County
    Road
    1720,
    Crossville,
    all
    in White
    County,
    Illinois.
    4.
    On
    September
    23,
    2005,
    a
    PVC
    transfer
    line
    located
    at
    the
    Phillipstown
    Unit
    Water
    Flood
    Plant
    had
    ruptured
    and
    released approximately
    1,000
    -
    1,500
    barrels
    of
    salt
    water
    and
    10
    to
    20
    barrels
    of
    crude
    oil.
    The
    salt
    water
    traveled
    approximately
    I ‘/2
    miles
    downstream
    from
    the
    facility
    into
    a
    drainageway
    and
    unnamed
    stream,
    which
    drains
    into
    the
    Wabash
    River.
    Crude
    oil
    and
    crude
    oil
    staining
    was
    approximately
    1
    mile
    downstream
    from
    the
    facility.
    The
    2

    chloride
    concentration
    of the
    water
    in
    the
    drainageway
    was
    at
    least
    6,722
    mg/L
    approximately
    I
    miles
    downstream
    of the
    facility.
    Over
    50
    small
    fish,
    including
    small
    minnows and
    catfish, died
    approximately
    1
    1/4
    miles
    downstream
    from
    the
    facility.
    5.
    On
    September
    26,
    2005,
    over
    100
    more
    small
    fish,
    including
    minnows
    and
    catfish,
    had
    been
    killed about
    1
    1/4
    to
    I V
    2
    miles
    downstream
    from
    the
    Phillipstown
    Unit
    Water
    Flood
    Plant.
    6.
    On
    May
    18,
    2006,
    a
    fiberglass
    pipeline from
    the
    Phillipstown
    Unit
    Water
    Flood
    Plant
    to
    the
    injection
    wells
    breached
    and
    released
    approximately
    200
    barrels
    of
    salt
    water. On
    May
    19,
    2006,
    the
    salt
    water
    had
    traveled
    approximately
    1
    V2 miles
    downstream
    from
    the
    pipeline
    into
    the
    same
    drainageway
    and
    unnamed
    stream
    that
    drains
    into
    the
    Wabash
    River as
    the
    September
    23,
    2005
    release. On
    May
    19,
    2006,
    the
    chloride
    concentration
    of the
    water
    approximately
    500
    feet
    downstream
    of
    the
    breached
    pipeline
    was
    approximately
    1,199
    ppm.
    On
    May
    25,
    2006,
    the
    chloride
    concentration
    of
    the
    water was
    approximately
    61
    9.640
    ppm
    downstream
    of
    the
    breached
    pipeline
    and
    upstream
    of
    a berm
    installed
    by
    the
    Respondent.
    7.
    On
    April
    20,
    2007, a
    steel
    section of a
    flow
    line
    pipe
    for
    two
    wells
    located at
    the
    CT
    Spencer
    lease
    failed,
    releasing
    approximately
    10 barrels
    of
    crude
    oil
    and
    200
    barrels of salt
    water.
    The
    salt
    water
    traveled
    approximately
    800
    feet
    through
    drain
    tiles
    and
    a
    water
    filled
    ditch
    into
    an
    unnamed
    creek.
    The
    chloride
    concentration
    of
    the
    water
    approximately
    700
    feet
    downstream
    of
    the
    where
    the
    salt
    water
    entered
    the
    stream
    was
    approximately
    800-900
    ppm.
    8.
    On
    August
    2,
    2007,
    a
    compression
    coupler
    located
    on
    a
    flow
    line
    at the
    Everett
    Spencer
    9 Production
    Well
    split
    releasing
    approximately
    3
    barrels
    of
    crude
    oil
    and
    30
    barrels
    of
    salt
    water,
    The
    salt
    water
    crossed
    the
    lease
    road
    and
    flowed
    into
    an
    unnamed
    creek.
    The
    3

    chloride
    concentration
    of
    the
    water
    approximately
    150
    feet
    downstream
    was
    approximately
    598
    ppm. The
    chloride
    concentration
    of
    the
    water
    approximately
    700
    feet
    downstream
    was
    approximately
    1503
    ppm.
    9.
    On
    May
    3,
    2008,
    a
    transfer
    line
    connect
    to
    the
    L.G.
    Cleveland
    Tank
    Battery
    was
    damaged
    in
    a
    storm,
    resulting
    in
    a release
    of
    approximately
    50
    barrels
    of
    salt
    water,
    which
    flowed
    into
    a
    ditch
    leading
    to
    an
    unnamed
    creek.
    The
    chloride
    concentration
    of the
    water
    in
    the
    ditch
    was
    approximately
    1,200
    ppm.
    The
    incident
    number
    for
    this
    release
    is 2008
    0600.
    10.
    On
    August
    12,
    2008,
    an
    above
    ground
    injection
    line
    at the
    Phillipstown
    Unit
    Water
    Flood
    Plant
    failed,
    The
    line
    failure
    caused a
    release of
    approximately
    50
    barrels
    of
    salt
    water,
    which
    flowed
    into
    an
    unnamed
    creek.
    The
    chloride
    concentration
    of
    the
    water
    in
    the
    creek
    was
    approximately
    700
    to
    2,000
    ppm.
    B.
    Allegations
    of
    Non-Compliance
    Complainant
    and
    the
    Illinois
    EPA
    contend
    that
    the
    Respondent
    has
    violated the
    following
    provisionsof
    the
    Act
    and
    Board
    regulations:
    Count
    I:
    Section
    12(a)
    and
    12(f)
    of
    the
    Act,
    415
    ILCS
    5/12(a),
    (f) (2004)
    and
    Sections
    302.203
    and
    3 02.208(g)
    of
    the
    Board’s
    Water
    Quality
    Standards
    Regulations,
    35
    Ill.
    Adm.
    Code
    302.203,
    302.208(g)
    Count
    II:
    Section
    12(a),
    12(d)
    and
    12(f) of
    the
    Act,
    415
    ILCS
    5/12(a), (d),
    and
    (f)
    (2004)
    and
    Sections
    302.203
    and
    302.208(g)
    of
    the
    Board’s
    Water
    Quality
    Standards
    Regulations,
    35
    111.
    Adm.
    Code
    302.203,
    302.208(g)
    Count
    III:
    12(a),
    and
    12(d)
    of the
    Act,
    415
    ILCS
    5/12(a),
    (d),
    (2004)
    and
    Section
    302.208(g)
    of the
    Board’s Water
    Quality
    Standards
    Regulations,
    35
    Ill.
    Adm.
    Code
    302.208(g)
    Count
    IV:
    Section
    12(a),
    and
    12(d)
    of
    the
    Act,
    415
    ILCS
    5/12(a),
    (d),
    (2004)
    and
    Section
    302.208(g)
    of
    the
    Board’s
    Water
    Quality Standards
    4

    Regulations,
    35
    Ill.
    Adm.
    Code
    302.208(g)
    Count
    V:
    Section
    12(a), and
    12(d)
    of
    the
    Act,
    415
    ILCS
    5/12(a), (d),
    (2004)
    and
    Section
    302.208(g)
    of
    the
    Board’s
    Water
    Quality
    Standards
    Regulations,
    35
    III,
    Adm.
    Code
    3 02.208(g)
    C.
    Non-Admission
    of
    Violations
    The
    Respondent
    represents
    that
    it
    has
    entered
    into
    this
    Stipulation
    for
    the
    purpose
    of
    settling
    and
    compromising
    disputed
    claims
    without
    having
    to
    incur the
    expense
    of
    contested
    litigation.
    By
    entering
    into
    this
    Stipulation
    and
    complying
    with
    its
    terms,
    the
    Respondent
    does
    not
    affirmatively
    admit
    the
    allegations
    of
    violation
    within
    the
    Complaint
    and
    referenced
    within
    Section
    I.B
    herein,
    and
    this
    Stipulation
    shall
    not
    be
    interpreted
    as
    including
    such
    admission.
    D.
    Compliance
    Activities
    to
    Date
    1.
    In
    response
    to
    the
    September
    23,
    2005
    release,
    Respondent
    moved
    the
    line
    that
    leaked
    away
    from
    the
    road
    ditch and
    all
    steel
    fittings
    were
    removed from
    the
    line.
    Respondent
    also
    inspected
    other
    lines in
    the
    area
    and
    replaced sections
    of
    the
    line
    that
    appeared
    corroded.
    2.
    Respondent
    has
    prepared a
    Spill
    Prevention
    Control
    and
    Countermeasure
    (SPCC)
    Plan
    for
    each
    of
    Respondents
    eight
    Tank
    Batteries
    at the
    Phillipstown
    Waterflood
    facility.
    3.
    Respondent
    has
    completed
    the
    investigation
    and
    cleanup
    of all
    six
    incidents
    described
    above,
    including
    incident
    2008
    0600.
    II.
    APPLICABILITY
    This
    Stipulation
    shall
    apply
    to
    and
    be
    binding upon
    the
    Parties
    to
    the
    Stipulation,
    and
    any
    officer,
    director,
    agent,
    or
    employee
    of
    the
    Respondent,
    as well as
    any
    successors
    or
    assigns
    of
    the
    Respondent.
    The
    Respondent
    shall
    not
    raise as a
    defense to
    any
    enforcement
    action
    taken
    pursuant
    to
    this
    Stipulation
    the
    failure
    of
    any
    of
    its
    officers,
    directors,
    agents,
    employees
    or
    5

    successors or
    assigns
    to
    take
    such
    action
    as
    shall
    be required
    to
    comply
    with
    the
    provisions of
    this
    Stipulation.
    This
    Stipulation
    may
    be
    used
    against
    the
    Respondent
    in
    any
    subsequent
    enforcement
    action
    or
    permit
    proceeding
    as
    proof
    of a
    past
    adjudication
    of
    violation of the
    Act
    and
    the
    Board
    Regulations for
    all
    violations
    alleged
    in
    the
    Third
    Amended
    Complaint
    in
    this
    matter,
    and
    any
    violations
    that
    could
    have
    been
    alleged
    regarding incident 2008
    0600,
    for
    purposes
    of
    Sections
    39
    and
    42
    of
    the
    Act,
    415
    ILCS
    5/39
    and
    42
    (2006).
    No
    change
    in
    ownership,
    corporate
    status
    or
    operator
    of the
    facilities
    cited
    in
    the
    Third
    Amended
    Complaint
    or
    the
    facility
    where
    incident
    2008
    0600
    occurred
    shall
    in
    any
    way
    alter
    the
    responsibilities
    of the
    Respondent
    under
    this
    Stipulation.
    In
    the
    event
    that
    the Respondent
    proposes
    to sell
    or
    transfer any
    real
    property
    or
    operations
    subject
    to
    this
    Stipulation, the
    Respondent
    shall
    notify
    the
    Complainant
    and
    the
    Illinois
    EPA
    thirty
    (30)
    calendar
    days
    prior
    to
    the
    conveyance
    of
    title,
    ownership
    or
    other
    interest,
    including
    a leasehold
    interest
    in
    any
    of
    the
    facilities
    or-a
    portion
    thereof.
    The
    Respondent
    shall
    make
    as
    a
    condition
    of
    any
    such
    sale
    or
    transfer,
    that
    the
    purchaser
    or
    successor
    provide
    to Respondent
    site
    access and
    all cooperation
    necessary
    for
    Respondent
    to
    perform
    to
    completion
    any
    compliance
    obligations
    required
    by
    this
    Stipulation. The
    Respondent
    shall
    provide
    a
    copy
    of
    this
    Stipulation
    to any
    such
    successor
    in
    interest
    and
    the
    Respondent
    shall
    continue to
    be bound
    by
    and
    remain
    liable
    for
    performance
    of
    all
    obligations
    under
    this
    Stipulation.
    In
    appropriate
    circumstances,
    however,
    the
    Respondent
    and
    a
    proposed
    purchaser
    or operator
    of any
    of
    the
    facilities
    may
    jointly
    request,
    and
    the
    Complainant
    and
    the
    Illinois
    EPA,
    in
    their
    discretion, may
    consider
    modification
    of
    this
    Stipulation to
    obligate
    the
    proposed
    purchaser
    or operator
    to
    carry
    out
    future
    requirements
    of
    this
    Stipulation
    in
    place
    of, or
    in
    addition to,
    the
    Respondent.
    This
    provision does
    not
    relieve
    the
    6

    Respondent
    from
    compliance
    with
    any
    regulatory
    requirement
    regarding notice
    and
    transfer
    of
    applicable
    facility
    permits.
    Ill.
    IMPACT ON
    THE
    PUBLIC
    RESULTING
    FROM ALLEGED
    NON-COMPLIANCE
    Section
    33(c)
    of
    the
    Act,
    415
    ILCS
    5/33(c)(2006),
    provides
    as
    follows:
    In
    making its
    orders
    and
    determinations,
    the
    Board
    shall
    take
    into
    consideration
    all
    the
    facts
    and
    circumstances
    bearing
    upon
    the
    reasonableness
    of the
    emissions,
    discharges,
    or
    deposits
    involved
    including,
    but
    not
    limited to:
    I.
    the
    character
    and
    degree
    of
    injury
    to,
    or
    interference
    with
    the
    protection
    of
    the
    health,
    general
    cf
    arid
    iyici
    property
    oithe
    peDpI;
    2.
    the
    social
    and
    economic
    value
    of the
    pollution
    source;
    3.
    the
    suitability
    or
    unsuitability
    of
    the
    pollution
    source
    to the
    area
    in
    which
    it
    is located,
    including
    the
    question
    of
    priority
    of
    location
    in
    the
    area
    involved;
    4.
    the
    technical
    practicability
    and
    economic
    reasonableness
    of
    reducing or
    eliminating
    the
    emissions,
    discharges
    or
    deposits
    resulting from
    such
    pollution
    source;
    and
    5.
    any
    subsequent
    compliance.
    In
    response to
    these
    factors,
    the
    Parties
    to
    this
    Stipulation
    state
    the
    following:
    1.
    Human
    health was
    threatened
    and
    the
    environment
    was
    impacted
    by
    the
    Respondent’s
    violations.
    2.
    There
    is
    social
    and
    economic
    benefit
    to
    the
    operation,
    lease,
    and
    ownership
    of
    oil
    wells,
    including
    salt
    water
    injection, by
    the
    Respondent.
    3.
    Operation
    of
    the
    oil
    wells
    and
    the
    salt
    water
    injection is
    suitable
    for
    the
    area
    in
    which
    they
    are
    located.
    4.
    Refraining
    from
    releasing
    salt
    water
    and
    oil
    from
    the
    flow
    lines
    and
    disposal
    lines
    7

    is
    both
    technically
    practicable
    and
    economically
    reasonable.
    5.
    Respondent
    has
    subsequently
    complied
    with
    the
    Act
    and
    the
    Board
    Regulations.
    IV.
    CONSIDERATION
    OF
    SECTION
    42(h)
    FACTORS
    Section
    42(h)
    of the
    Act,
    415
    ILCS
    5/42(h)(2006),
    provides as
    follows:
    In
    determining
    the
    appropriate
    civil
    penalty
    to
    be
    imposed
    under.
    . .
    this
    Section,
    the
    Board
    is authorized
    to
    consider
    any
    matters
    of record
    in
    mitigation or
    aggravation
    of penalty,
    including but
    not limited to the
    following factors:
    1.
    the
    duration
    and
    gravity
    of the
    violation;
    2.
    the
    presence or
    absence
    of
    due
    diligence
    on
    the
    part
    of
    the respondent
    in
    attempting
    to comply
    with
    requirements
    of this
    Act
    and
    regulations
    thereunder or
    to secure
    relief
    therefrom
    as provided
    by
    this
    Act;
    3.
    any
    economic
    benefits
    accrued
    by
    the
    respondent
    because
    of
    delay
    in
    compliance
    with
    requirements,
    in
    which case
    the
    economic
    benefits
    shall
    be
    determined
    by
    the
    lowest
    cost
    alternative
    for
    achieving compliance;
    4.
    the
    amount
    of
    monetary penalty
    which
    will
    serve
    to deter
    further
    violations
    by
    the
    respondent
    and
    to otherwise
    aid
    in enhancing
    voluntary
    compliance
    with
    this
    Act
    by
    the
    respondent
    and
    other
    persons
    similarly
    subject
    to
    the
    Act;
    5.
    the
    number,
    proximity
    in
    time,
    and
    gravity of
    previously
    adjudicated
    violations
    of
    this
    Act
    by
    the
    respondent;
    6.
    whether
    the
    respondent
    voluntarily
    self-disclosed,
    in accordance
    with
    subsection
    i of
    this
    Section,
    the
    non-compliance
    to
    the
    Agency; and
    7.
    whether
    the
    respondent
    has
    agreed to
    undertake
    a
    “supplemental
    environmental
    project,”
    which
    means
    an environmentally
    beneficial
    project
    that
    a
    respondent
    agrees
    to
    undertake
    in
    settlement
    of
    an
    enforcement
    action
    brought
    under
    this
    Act,
    but
    which
    the
    respondent
    is
    not
    otherwise
    legally
    required
    to
    perform.
    In
    response to
    these
    factors,
    the
    Parties
    to
    this
    Stipulation state
    as
    follows:
    The
    Respondent
    released
    salt
    water
    and
    oil
    into
    waters
    of the
    State
    on
    six
    separate
    8

    occasions.
    The
    violations
    began
    on
    or
    around
    September
    23, 2005
    and
    were
    individually
    resolved
    at various
    times
    following
    each
    release.
    2.
    Respondent
    was
    diligent
    in
    attempting
    to
    come
    back
    into
    compliance
    with
    the
    Act,
    Board
    regulations
    and
    applicable
    federal
    regulations,
    once
    the
    Illinois
    EPA
    notified
    it
    of
    its
    noncompliance.
    3
    No
    economic
    benefit
    was
    accrued
    by
    the
    Respondent.
    4,
    Complainant
    and
    the
    Illinois
    EPA
    have
    determined,
    based
    upon
    the
    specific
    facts
    of
    this
    matter
    that
    a
    penalty
    of Fifty
    Thousand
    Dollars
    ($50,000.00)
    will
    serve
    to
    deter
    further
    violations
    and
    aid
    in future
    voluntary
    compliance
    with
    the
    Act
    and
    Board
    regulations.
    5.
    To
    Complainant’s
    and
    the
    Illinois
    EPA’s
    knowledge,
    Respondent
    has
    no
    previously
    adjudicated
    violations
    of
    the
    Act.
    6.
    Self-disclosure
    is
    not
    at
    issue
    in
    this
    matter.
    7.
    The
    settlement
    of
    this
    matter
    includes
    a supplemental
    environmental
    project
    of
    a
    $20,000
    donation
    to
    the
    Illinois
    Petroleum
    Resources
    Board.
    9

    V.
    TERMS
    OF
    SETTLEMENT
    A.
    Penalty
    Payment
    1
    The
    Respondent
    shall
    pay
    a
    civil
    penalty
    in
    the
    sum
    of Fifty
    Thousand Dollars
    ($50,000.00)
    within
    thirty
    (30)
    days
    from
    the
    date
    the Board
    adopts
    and
    accepts
    this
    Stipulation.
    B.
    Interest
    and
    Default
    1.
    If the
    Respondent
    fails
    to make
    any
    payment
    required
    by
    this
    Stipulation on
    or
    before
    the
    date
    upon
    which
    the
    payment
    is
    due,
    the Respondent
    shall
    be
    in default
    and
    the
    remaining
    unpaid
    balance
    of
    the penalty,
    plus
    any
    accrued
    interest,
    shall
    be
    due
    and
    owing
    immediately.
    In
    the event
    of default,
    the
    Complainant
    shall
    be
    entitled
    to reasonable
    costs
    of
    collection,
    including
    reasonable
    attorney’s
    fees.
    2.
    Pursuant
    to
    Section
    42(g)
    of
    the Act,
    interest
    shall
    accrue
    on
    any
    penalty
    amount
    owed
    by
    the
    Respondent
    not
    paid
    within
    the
    time
    prescribed
    herein.
    Interest
    on unpaid
    penalties
    shall
    begin
    to
    accrue
    from
    the date
    such
    are
    due
    and
    continue
    to
    accrue
    to
    the date
    full
    payment
    is
    received,
    Where
    partial
    payment
    is
    made
    on
    any
    penalty
    amount
    that is
    due,
    such
    partial
    payment
    shall
    be
    first
    applied
    to
    any
    interest
    on
    unpaid
    penalties
    then
    owing.
    C.
    Payment
    Procedures
    All
    payments
    required
    by
    this
    Stipulation
    shall
    be
    made
    by
    certified
    check
    or
    money
    order
    payable
    to
    the
    Illinois
    EPA
    for
    deposit
    into the
    Environmental
    Protection
    Trust
    Fund
    (“EPTF”).
    Payments
    shall
    be
    sent
    by
    first
    class
    mail and
    delivered
    to:
    Illinois
    Environmental
    Protection
    Agency
    Fiscal
    Services
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    10

    The
    name,
    case
    number
    and
    the
    Respondents
    federal
    tax
    identification
    number
    shall
    appear
    on
    the
    face
    of
    the
    certified
    check
    or
    money
    order.
    A
    copy
    of
    the
    certified
    check
    or
    money
    order and
    any
    transmittal
    letter
    shall
    be
    sent
    to:
    Environmental
    Bureau
    Illinois
    Attorney
    General
    s
    Office
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    D.
    Future
    Compliance
    1.
    In
    addition
    to
    any
    other
    authorities,
    the
    Illinois
    EPA, its
    employees
    and
    representatives,
    and
    the
    Attorney General,
    her
    employees
    and
    representatives,
    shall
    have
    the
    right
    of
    entry
    into
    and
    upon
    any
    of
    the
    Respondent’s
    facilities
    which
    is
    the
    subject
    of
    this
    Stipulation,
    at
    all
    reasonable
    times
    for
    the
    purposes
    of
    conducting
    inspections
    and
    evaluating
    compliance
    status.
    In
    conducting
    such
    inspections,
    the
    Illinois
    EPA,
    its
    employees
    and
    representatives,
    and
    the
    Attorney
    General,
    her
    employees
    and
    representatives,
    may
    take
    photographs,
    samples,
    and
    collect
    information,
    as
    they
    deem
    necessary.
    2.
    This
    Stipulation
    in
    no
    way
    affects
    the
    responsibilities
    of
    the
    Respondent
    to
    comply
    with
    any
    other
    federal,
    state
    or
    local
    laws
    or
    regulations,
    including
    but
    not
    limited
    to
    the
    Act
    and
    the
    Board
    Regulations.
    3.
    The
    Respondent
    shall
    cease
    and
    desist
    from
    future
    violations
    of
    the
    Act
    and
    Board
    Regulations
    that
    were the
    subject
    matter
    of
    the
    Complaint.
    4.
    Respondent
    shall
    inspect
    on
    a
    monthly
    basis
    all
    flow
    and
    disposal
    pipelines
    crossing
    any ditch
    or
    creek
    that
    would
    eventually
    flow
    to
    a
    “blue
    line” as
    shown
    in
    the
    7.5
    minute
    11

    series
    topographic maps
    printed
    and
    produced
    by
    the
    United
    States
    Geological
    Survey
    (scale
    1:24,000).
    If any
    of
    the
    flow
    and
    disposal
    pipelines
    are
    found
    to
    be corroded,
    have
    otherwise
    failed,
    or
    have
    the
    potential
    to fail,
    Respondent
    shall
    replace
    the
    pipeline
    immediately,
    5.
    Respondent
    shall
    inspect
    daily
    the
    oil
    production
    and
    storage
    facilities
    and
    salt
    water
    injection
    facilities.
    If any
    of
    the facilities
    are
    found
    to
    need
    repair,
    the
    Respondent shall
    repair
    the
    facilities
    immediately.
    E.
    Supplemental
    Environmental
    Project
    1.
    In
    order
    to
    promote
    the
    goals
    of
    the Act
    to restore,
    protect
    and
    enhance
    the
    quality
    of the
    environment,
    the
    Respondent
    shall
    perform
    the
    following
    supplemental
    environmental
    project
    (“SEP”).
    The
    monetary
    value
    of the
    SEP
    is
    Twenty
    Thousand
    Dollars
    ($20,000.00). The
    Parties
    to the
    Stipulation
    agree
    that
    this
    SEP
    shall
    consist
    of a
    donation
    to
    the
    Illinois
    Petroleum
    Resources
    Board.
    2.
    The
    Defendant
    shall
    pay
    the
    amount
    of Twenty
    Thousand
    Dollars
    ($20,000.00),
    within
    30 days
    after
    the
    date
    the Board
    accepts
    this
    Stipulation,
    to the
    Illinois
    Petroleum
    Resources
    Board
    to
    fund
    cleanups
    of
    abandoned
    oil
    production
    sites.
    The
    payment
    shall
    be
    paid
    by
    certified
    check
    or money
    order
    made
    payable
    to
    Illinois
    Petroleum
    Resources
    Board.
    The
    certified
    check
    or
    money
    order
    shall
    be
    sent
    by
    first
    class
    mail
    to:
    Charles
    Williams,
    Executive
    Director
    Illinois
    Petroleum
    Resources
    Board
    P.O.
    Box
    941
    Mt.
    Vernon,
    IL 62864
    Copies
    of
    the
    check
    and
    the
    transmittal
    letter
    shall
    be
    sent
    to:
    Thomas
    Davis
    12

    Environmental
    Bureau
    Illinois Attorney
    General’s
    Office
    500
    South Second
    Street
    Springfield,
    Illinois
    62706
    John
    Waligore
    Division
    of Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    3.
    By
    signature
    on
    this
    Stipulation,
    the
    Respondent
    certifies that,
    as
    of
    the
    date
    of
    entry
    of
    this
    Order,
    it is
    not
    required
    to
    perform or
    develop
    the
    foregoing
    SEP
    by
    any
    federal,
    state
    or
    local
    law
    or
    regulation,
    nor
    is
    it
    required
    to
    perform or
    develop
    the
    SEP
    by
    agreement
    or
    injunctive
    relief
    in
    any
    other
    case.
    The
    Respondent
    further
    certifies
    that
    it has
    not
    received,
    and
    is
    not
    presently
    negotiating
    to receive
    credit
    for,
    the
    SEP
    in
    any
    other
    enforcement
    action.
    4.
    Any
    public
    statement,
    oral
    or written,
    in
    print,
    film
    or
    other
    media,
    made
    by
    the
    Respondent
    making
    reference
    to any
    SEP
    shall
    include
    the
    following
    language:
    “This
    project
    was
    undertaken
    in
    connection
    with
    the
    settlement
    of
    an enforcement
    action
    taken
    by
    the
    Illinois
    Attorney
    General
    and
    the
    Illinois
    EPA
    for
    alleged
    violations
    of the
    Illinois
    Environmental
    Protection
    Act
    and
    regulations
    promulgated
    thereunder.”
    F.
    Release
    from
    Liability
    In
    consideration
    of the
    Respondent’s
    payment
    of the
    $50,000.00
    penalty,
    the
    $20,000
    SEP
    donation,
    its
    commitment
    to
    cease
    and
    desist as contained
    in
    Section
    V.D.,
    completion
    of
    all
    activities required
    hereunder,
    and
    upon
    the
    Board’s approval
    of
    this
    Stipulation,
    the
    Complainant
    releases,
    waives
    and
    discharges the
    Respondent
    from
    any
    further
    liability
    or
    penalties
    for
    the
    violations
    of
    the
    Act
    and
    Board
    Regulations
    that
    were
    the
    subject
    matter
    of the
    third
    Amended
    13

    Complaint
    herein
    and
    any violations
    associate
    with
    incident
    2008
    0600.
    The release
    set
    forth
    above
    does
    not
    extend
    to
    any
    matters
    other than
    those
    expressly
    specified
    in
    Complainant’s
    Complaint
    filed on
    December
    1,2005
    and
    amended
    on
    November
    15, 2007
    and September
    15,
    2008.
    The
    Complainant
    reserves,
    and
    this
    Stipulation
    is
    without
    prejudice
    to,
    all
    rights
    of
    the
    State
    of
    Illinois
    against
    the
    Respondent
    with
    respect
    to
    all
    other
    matters,
    including
    but
    not
    limited
    to,
    the
    following:
    a.
    criminal
    liability;
    b.
    liability
    for
    future
    violation
    of
    state,
    federal,
    local,
    and
    common
    laws
    and/or
    regulations;
    c.
    liability
    for
    natural
    resources
    damage
    arising
    out of
    the
    alleged
    violations;
    and
    d.
    liability
    or
    claims
    based
    on
    the
    Respondent’s
    failure
    to
    satisfy
    the
    requirements
    of
    this
    Stipulation.
    Nothing
    in
    this
    Stipulation
    is
    intended
    as
    a
    waiver,
    discharge,
    release,
    or
    covenant
    not
    to
    sue
    for
    any
    claim or
    cause
    of
    action,
    administrative
    or
    judicial,
    civil
    or
    criminal,
    past
    or
    fiTture,
    in
    law
    or
    in
    equity,
    which
    the
    State
    of
    Illinois
    or
    the
    Illinois
    EPA may
    have
    against
    any
    person,
    as
    defined
    by
    Section
    3.3
    15
    of
    the
    Act,
    415 ILCS
    5/3.3
    15,
    or
    entity
    other
    than
    the
    Respondent.
    G.
    Enforcement
    of
    Stipulation
    1.
    Upon
    the
    entry
    of
    the
    Board’s
    Order
    approving
    and
    accepting
    this
    Stipulation,
    that
    Order
    is
    a
    binding
    and
    enforceable
    order
    of
    the
    Board
    and
    may
    be
    enforced
    as
    such
    through
    any
    and
    all
    available
    means.
    14

    H.
    Execution
    of
    Stipulation
    The
    undersigned
    representatives
    for
    the
    Parties
    to
    this
    Stipulation
    certify
    that
    they
    are
    fully
    authorized
    by
    the
    party
    whom
    they
    represent
    to enter
    into
    the
    terms
    and
    conditions
    of
    this
    Stipulation
    and
    to
    legally
    bind
    them
    to
    it.
    WHEREFORE,
    the Parties
    to
    this
    Stipulation
    request
    that the
    Board
    adopt
    and
    accept
    the
    foregoing
    Stipulation
    and
    Proposal
    for Settlement as
    written.
    PEOPLE
    OF
    THE
    STATE
    OF
    ILLINOIS,
    FOR
    THE
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    LISA
    MADIGAN
    Attorney
    General
    State
    of
    Illinois
    DOUGLAS
    P.
    SCOTT,
    Director
    Illinois
    Environmental
    Protection
    Agency
    MATTHEW
    J.
    DUI’ThJ,
    Chief
    Environmental
    Enforcement!
    Asbestos
    Litigation
    Division
    BY:
    BY:
    THOMAS
    DAVIS,
    Chief
    Environmental
    Bureau
    ief
    Legal
    Cou
    Assistant
    Attorney
    General
    DATE:
    ://2
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    DATE:
    (0
    BARGER
    ENGINEERING,
    INC.
    BY:
    DATE:
    in.
    2009
    Name:
    Matthew
    S.
    Stone
    Title:
    Vice
    preien
    15

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