STATE OF INDIANA

)

SS:

BEFORE THE INDIANA DEPARTMENT OF

 

)

 

 

COUNTY OF MARION

)

 

ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT

)

 

OF ENVIRONMENTAL MANAGEMENT,

 

)

 

 

 

)

 

Complainant,

 

)

 

 

 

)

 

 

v.

 

)

Case # 2005-14614-W

 

 

)

 

DODDS PROPERTY MANAGEMENT, LLC

 

)

 

 

 

)

 

Respondent.

 

)

 

 

NOTICE AND ORDER OF THE

COMMISSIONER OF THE

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 

Via Certified Mail#:______________

Via Certified Mail#:______________

 

 

 

 

To:

James Dodds

To:

Dean L. Knapp, Registered Agent for

 

Dodds Property Management, LLC

 

Dodds Property Management

 

2300 Hancel Parkway

 

543 E. Market Street

 

Mooresville, IN 46158

 

Indianapolis, IN 46204

 

This Notice and Order of the Commissioner of the Department of Environmental Management ("Order") is issued against Dodds Property Management, LLC (“Respondent”) pursuant to IC 13-30-3-4, IC 13-30-3-10, and IC 13-30-3-11, and is based on violations found during an investigation conducted by the Indiana Department of Environmental Management (“IDEM”).  During the investigation it was determined that the Respondent is in violation of     327 IAC 15-5 as specified below:

 

FINDING OF VIOLATION

 

1.                  Complainant is the Commissioner of the IDEM, a department of the State of Indiana created by IC 13-13-1-1.

 

2.                  Respondent owns, operates, and/or develops Jamestown Estates, aka Jamestown Commons, a residential subdivision located at the northeast corner of Slideoff and Hadley Roads, in Morgan County, Indiana (the “Site”).

 

3.                  IDEM has jurisdiction over the parties and subject matter of this action.

 

4.                  All references in these Findings of Fact to 327 Indiana Administrative Code (IAC) 15-5 and its various subparts are to the version in effect prior to the rule change effective November 26, 2003.

 

5.                  Pursuant to 327 IAC 15-5-7(a), the operator shall develop an erosion control plan, (also known as an erosion and sediment control plan or ESCP), in accordance with the requirements under this section.  The ESCP must assure that erosion control measures are implemented and maintained, and that off-site sedimentation does not occur during the period of construction activity at a site.

 

6.                  Pursuant to 327 IAC 15-5-5(4), the operator must certify that the erosion control measures in the ESCP comply with applicable state, county, or local erosion control requirements; the erosion control measures will be implemented in accordance with the plan; and that an appropriate state, county, or local erosion control authority and the soil and water conservation district office have been sent a copy of the plan for review.

 

7.                  Pursuant to 327 IAC 15-5-7(b), both before and after its November of 2003 revisions, the following requirements shall be met on all sites during the period when active land disturbing activities occur:

a.                  Sediment-laden water shall be detained on-site by erosion control practices that minimize sedimentation in the receiving stream.

b.                  Sediment tracked from the site onto public or private roadways shall be minimized.

c.                  Public and private roadways shall be kept clear of accumulated sediment.

d.                  All on-site storm drains shall be protected against sedimentation by appropriate and acceptable methods.

e.                  Storm water drainage from adjacent areas that naturally pass through the site shall either be diverted from disturbed areas or the existing channel must be protected or improved to prevent erosion and sedimentation from occurring.

f.                    Run-off from a disturbed area shall be controlled by either appropriate vegetative practices, the implementation of an erosion control plan that includes appropriate erosion control measures, or both.

 

8.                  Pursuant to 327 IAC 15-5-7(c), during the period of construction at the site, all erosion control measures necessary to meet the requirements of this rule shall be maintained by the operator.

 

9.                  Based on site visits and inspections conducted by Division of Soil Conservation representatives and/or the Morgan County Soil and Water Conservation District (SWCD) on August 15, September 19, October 17, and November 25, 2003; and March 4, April 12,  September 21 & 22, and November 8, 2004, the Respondent failed to assure that erosion control measures were implemented and maintained at the Site and assure that off-site sedimentation did not occur during the period of construction activity from August 15, 2003 to November 8, 2004.  Specifically, the Respondent failed to:

a.                  Adequately protect disturbed areas through seeding or other appropriate rosion and sediment control measures in accordance with the ESCP;

b.                  Implement appropriate perimeter sediment control measures;

c.                  Properly install erosion and sediment control measures;

d.                  Protect storm drain inlets adequately; and

e.                  Maintain existing erosion and sediment control measures.

 

Additionally, inspections conducted during the above referenced time period documented evidence of off-site sedimentation, in which sediment entered into the local ditch which is a tributary of Sinking Creek.            The Respondent’s failure to implement and maintain erosion and sediment control measures and prevent off-site sedimentation is in violation of 327 IAC 15-5-7(b) and (c).

 

10.             On August 25, 2005, a Notice of Violation was issued, pursuant to IC 13-30-3-3 to the Respondent for violations cited above.  The Respondent received this Notice of Violation on September 1, 2005.

 

11.             The Notice of Violation contained an offer to enter into an Agreed Order in compliance with IC 13-30-3-3.  Additionally, IDEM provided the Respondent with a proposed Agreed Order.

 

12.             More than sixty (60) days have elapsed since Respondent was offered the opportunity to enter into an Agreed Order.

 

13.             The Respondent has not entered into an Agreed Order resolving the violations cited above.

 

ORDER

 

1.                  Immediately, upon the Effective Date of this Order, the Respondent shall implement the erosion and sediment control measures contained in the approved ESCP for the Site and any other erosion and sediment control measures necessary to:

 

a.                  Ensure compliance with the requirements of 327 IAC 15-5-7; and

b.         prevent sediment from leaving the site and entering or threatening to enter waters of the state.

 

This effort should include basin outlets identified in the on-site evaluations in accordance with the ESCP and the methods outlined in the Indiana Stormwater Quality Manual.  These measures shall be adequate in size and location to control the area of run-off and to prevent off-site sedimentation. The Respondent will be deemed to have satisfied the requirements of this paragraph when the designated representative of IDEM verifies that adequate vegetative cover has been established and/or that appropriate erosion control measures have been put into place, and Respondent has no “unsatisfactory” ratings in

inspections from the designated representative of IDEM for one year, or until the project termination conditions of 327 IAC 15-5-8 have been met at the site and a notice of termination (“NOT”) has been submitted and accepted.

 

2.                  The Respondent shall, within ten (10) days of the Effective Date of this Order, submit to IDEM documentation of completion of actions to comply with Order Paragraph Nos. 1(a) and (b).

 

3.                  The Respondent shall, upon the Effective Date, implement a self-monitoring program as required by 327 IAC 15-5-7(18), including assuring that a trained individual performs a written evaluation of the project site by the end of the next business day following each measurable storm event; and at a minimum of one time per week, in order to determine whether the erosion and sediment controls are:

 

a.                  properly installed and maintained;

b.                  adequate to ensure compliance with the requirements of 327 IAC 15-5-7; and

c.                  to prevent sediment from leaving the site and entering or threatening to enter waters of the state.

 

For the purposes of this Order, a “measurable storm event” is defined as a precipitation event that results in a total measured precipitation accumulation equal to or greater than 0.5 inches of rainfall.

 

4.                  In the event that deficiencies are found during the inspections of the Site conducted pursuant to Order Paragraph No. 3, the Respondent shall immediately take all actions necessary to correct the deficiencies.  Such actions may include, but are not necessarily limited to, removal of accumulated sediment from behind silt fences and storm inlets, assurance that conveyance channels and swales are stabilized, and installation of additional erosion control measures if determined necessary.

 

5.                  The Respondent shall maintain records of the inspections conducted pursuant to Order Paragraph No. 3 and corrective actions taken pursuant to Order Paragraph No. 4.  The records shall include, but not necessarily be limited to:

 

a.                  the date and time of inspection;

b.                  the weather conditions at the time of the inspection;

c.                  the name of the individual conducting the inspection;

d.                  a description of observations made during the inspection, specifically including a description of any deficiencies that were found; and

e.                  a description of the corrective actions taken as a result of deficiencies found during the inspection.

 

6.                  The Respondent shall make the records required pursuant to Order Paragraph No. 5  available for inspection and copying by representatives of IDEM, the Morgan County SWCD or Surveyor’s Office.

 

7.                  The Respondent shall, within fifteen (15) days of the Effective Date, provide written notification to all parties with access to the Site, including contractors and subcontractors, of the requirements contained in the approved ESCP.

 

8.                  The Respondent shall, within fifteen (15) days of the Effective Date, submit to IDEM a copy of the notification required pursuant to Order Paragraph No. 7 and a statement certifying that the notification was provided to all parties with access to the Site.

 

9.                  Upon completion of the current construction project at the Site, as required by 327 IAC 15-5-8 and 327 IAC 15-5-11, the Respondent shall submit to IDEM, the NOT, which states that the project is complete.  The NOT shall be submitted to the address below:

 

Rule 5 Stormwater Coordinator

Wet Weather Section

IDEM, Office of Water Quality – Mail Code 65-40

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

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

 

Paul Cluxton, Enforcement Case Manager

IDEM, Office of Enforcement – Mail Code 60-02

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

11.             The Respondent shall pay a civil penalty of Fifteen Thousand Dollars ($15,000) for the violations cited above.  This penalty shall be remitted to the Department of Environmental Management within thirty (30) days of the Effective Date of this Order.  Checks shall be made payable to the Environmental Management Special Fund, with the Case Number indicated on the check and mailed to:

 

Indiana Department of Environmental Management

Cashier’s Office – Mail Code 50-10C

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

12.             This Order shall apply to and be binding upon the Respondent, its successors and assigns.  No change in ownership, corporate, or partnership status of the Respondent shall in any way alter its status or responsibilities under this Order.

 

EFFECTIVE DATE OF ORDER

 

Pursuant to IC 13-30-3-5, this Order takes effect twenty (20) days following receipt unless you request review of this Order, before the twentieth day after receipt, by filing a written request for review with the Office of Environmental Adjudication, and serving a copy of the request for review upon the Commissioner of the Indiana Department of Environmental Management.  You may request that the Office of Environmental Adjudication conduct a hearing to review this Order, under IC 4-21.5, in its entirety, or you may limit your request for review to specific findings of fact and/or orders contained in this Order.  Requests for review must be submitted to the Office of Environmental Adjudication and the Commissioner of the Indiana Department of Environmental Management at the following addresses:

 

Director

Commissioner

Office of Environmental Adjudication

IDEM – Mail Code:  50-01

Indiana Government Center North

100 North Senate Avenue, Room 1301

100 North Senate Avenue, Room 1049

Indianapolis, Indiana 46204-2251

Indianapolis, Indiana 46204

 

Failure to properly submit a request for review, before the twentieth day following receipt of this Order of the Commissioner, waives your right to administrative review of this Order and your right to judicial review of the Order.  The petition for administrative review must contain the following information:

 

a.                  Name, address, and telephone number of each person filing the petition.

b.                  Identification of the interest of each petitioner in the subject of the petition.

c.                  Statement of facts demonstrating that the petitioner is:

(A)              a person to whom the order is directed;

(B)              aggrieved or adversely affected by the order; or

(C)              entitled to review under any law.

d.                  Statement with particularity the legal issues proposed for consideration in the proceedings.

 

The petition for administrative review should also contain the following information:

 

a.                  Identification of any persons represented by the person making the request.

b.                  Statement identifying the person against whom administrative review is sought.

c.                  A copy of the notice of the commissioner’s action issued by the department of environmental management which is the basis of the petition for administrative review.

d.                  Statement indicating the identification of petitioner’s attorney or other representative.

 

If you have procedural or scheduling questions regarding your request for review you may contact the Office of Environmental Adjudication at (317) 232-8591.

 

Dated at Indianapolis, Indiana this _____ day of ________________, 2006.

 

 

 

 

 

___(Signed July 13, 2006)__

Thomas W. Easterly

 

Commissioner

cc:       Mark Egbert, Swinney Bros.

 

Morgan County SWCD

 

http://www.in.gov/idem