STATE OF INDIANA

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BEFORE THE INDIANA DEPARTMENT

 

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SS:

OF ENVIRONMENTAL MANAGEMENT

COUNTY OF MARION

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COMMISSIONER OF THE DEPARTMENT

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OF ENVIRONMENTAL MANAGEMENT,

)

 

 

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Complainant,

 

)

 

 

 

)

 

v.

 

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Case No. 2004-14290-W

 

 

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SENIOR LIVING PROPERTIES I, INC.,

 

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A/K/A  AUTUMN GLEN AT GREENCASTLE

 

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Respondent

 

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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 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 IC 13-13-1-1.

 

2.                  Respondent is Senior Living Properties, I, Inc. a/k/a Autumn Glen at Greencastle (“Respondent”), who owns and operates the Autumn Glen at Greencastle development, located at 98 North 10th Street, Greencastle, in Putnam County, Indiana (the “Site”).

 

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

 

4.                  Pursuant to IC 13-30-3-3, on January 19, 2005, IDEM issued a Notice of Violation via Certified Mail to:

 

Senior Living Properties I, Inc., a.k.a. Autumn Glen at Greencastle

Richard L. Johnson, President and Registered Agent

6214 Morenci Trail, Ste 210

Indianapolis, IN  46268

 

5.                  Pursuant to 327 IAC 15-5-7, as effective prior to November of 2003, during the period when active land disturbing activities occur, the operator was required to comply with the general conditions for construction activity erosion control measures set forth in Section 327 IAC 15-5-7 effective at the time.

 

6.                  Pursuant to 327 IAC 15-5-7, which was revised and became effective in November of 2003, during the period when active land disturbing activities occur:

 

(a)               All storm water quality measures and erosion and sediment controls necessary to comply with this rule must be implemented in accordance with the construction plan and sufficient to satisfy Subsection 327 IAC 15-5-7(b).

 

(b)               A project site owner shall, at least, meet the provisions for storm water quality control set forth in the subsection 327 IAC 15-5-7(b), including:

 

(1)               Sediment-laden water shall be treated by erosion and sediment control measures appropriate to minimize sedimentation.

(2)               Appropriate measures shall be taken to minimize or eliminate wastes or unused building materials being carried from the site by run-off.

(3)               A stable construction site access shall be provided at all points of construction traffic ingress and egress to the project site.

(4)               Public and private roadways shall be kept clear of accumulated sediment.

(5)               Storm water run-off leaving a project site must be discharged in a manner that is consistent with applicable state or federal law

(8)               The project site owner is responsible for implementing all measures necessary to adequately prevent polluted storm water run-off.

(10)          Phasing of construction activities shall be used, where possible, to minimize disturbance of large areas.

(11)          Appropriate measures shall be planned and installed as part of an erosion and sediment control system.

(13)          Collected run-off leaving a project site must be either discharge directly into a well-defined, stable receiving channel or diffused and released to adjacent property without causing an erosion or pollutant problem to the adjacent property owner.

(16)          Unvegetated areas that are scheduled or likely to be left inactive for fifteen days or more must be temporarily or permanently stabilized with measures appropriate for the season to minimize erosion potential.  Alternative measures to site stabilization are acceptable if the project site owner or their representative can demonstrated they have implemented erosion and sediment control measures adequately to prevent sediment discharge.  Vegetated areas with a density of less than seventy percent (70%) shall be restabilized using appropriate methods to minimize the erosion potential.

(17)          During the period of construction activities, all storm water quality measures necessary to meet the requirements of this rule shall be maintained in working order.

 

7.                  Based on inspections conducted by IDNR, the Respondent failed to assure that erosion control measures were implemented and maintained at the Site from August of 2003 to July of 2004, and assure that off-site sedimentation did not occur during the period of construction activity from September of 2003 to July of 2004.  Specifically, during one or more inspections conducted by IDNR on August 22, 2003, September 9, 2003, November 19, 2003, December 5, 2003, July 28, 2004, August 25, 2004, and September 14, 2004, among other things, the following were observed:

 

(a)               Erosion control practices were either not in place or not installed properly.

(b)               Roadways were not kept clear of sediment and tracked soil.

(c)               Silt fences were either not installed properly or not installed according to plans.

(d)               The sediment detention basin was not constructed properly.

(e)               Soil stockpiles were not stabilized with appropriate erosion control measures.

(f)                 Conveyance channels were not stabilized.

(g)               Perimeter sediment control measures had not been implemented.

(h)               Sediment was leaving the site at the north project line and sediment was entering unprotected storm drain inlets.

(i)                 Temporary and permanent seeding were not timely performed or not adequate.

(j)                  Erosion control measures were not adequately maintained.

 

The Respondent’s failure to implement and maintain all storm water quality measures and erosion and sediment controls necessary to comply with this rule and in accordance with the ESCP, as evidenced by the deficiencies observed during the above noted inspections, was in violation of 327 IAC 15-5-7 effective at the time.

 

8.                  On January 4, 2005, IDNR staff conducted an on-site evaluation for erosion and sediment control at the Site and observed that no areas of construction site management for erosion and sediment control were unsatisfactory.  On May 6, 2005, IDNR staff conducted another on-site evaluation at the Site and observed that the last unit was under construction and that over 95% of the site was sodded.  All areas of construction site management for erosion and sediment control were evaluated as satisfactory, with the exception of the north project line, where work was being done at the time.

 

9.                  On October 13, 2005, IDEM received a notice of termination (NOT) for the Site from the Respondent in accordance with 327 IAC 15-5-8, indicating that all land disturbing activities, including construction on all building lots, have been completed and the entire site has been stabilized.

 

10.             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 maintain compliance with the applicable provisions of 327 IAC 15-5.

 

3.                  The Respondent is assessed a civil penalty of Seven Thousand Dollars ($7,000).  Three Thousand and Five Hundred Dollars ($3,500) of said amount shall be due and payable to the Environmental Management Special Fund within 30 days of the Effective Date of this Agreed Order.  The remaining Three Thousand and Five Hundred Dollars ($3,500) of said amount shall be due and payable to the Environmental Management Special Fund within 120 days of the Effective Date of this Agreed Order.

 

4.                  The civil penalty is payable by checks to the Environmental Management Special Fund.  Payments shall include the Case Number (2004-14290-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

 

5.                  In the event that the civil penalty required by Order Paragraph 3, is not paid by the required deadlines, 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.

 

6.                  This Agreed Order does not, in any way, relieve the Respondent of its obligation to comply with the applicable requirements of federal or state law or regulation.

 

7.                  The Complainant does not, by its approval of this Agreed Order, warrant or aver in any manner that the Respondent's compliance with any aspect of this Agreed Order will result in compliance with the applicable requirements of federal or state law or regulation.

 

8.                  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.

 

9.                  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.

 

10.             The Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights are transferred.

 

11.             This Agreed Order shall remain in effect until the Respondent has complied with Order Paragraphs 3 through 5 of this Agreed Order and IDEM has issued a close-out letter to the Respondent.

 

TECHNICAL RECOMMENDATION:

RESPONDENT

Department of Environmental Management

 

 

 

By:

____________________

By:

____________________

 

Mark W. Stanifer

 

 

 

Section Chief, Water Section

 

 

 

Office of Enforcement

 

 

 

 

 

 

Date:

____________________

Date:

____________________

 

 

 

 

COUNSEL FOR COMPLAINANT:

COUNSEL FOR RESPONDENT:

Department of Environmental Management

 

 

 

 

 

 

By:

____________________

By:

____________________

 

Kyle Endris, Attorney

 

 

 

Office of Legal Counsel

 

 

 

 

 

 

Date:

____________________

Date:

____________________

 

 

 

 

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL

MANAGEMENT THIS

_______

DAY OF

__________________

, 20____.

 

 

 

For the Commissioner:

 

 

 

 

 

Signed 4/11/06

 

Matthew T. Klein

 

Assistant Commissioner of

 

Compliance and Enforcement