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STATE OF INDIANA    )        BEFORE THE INDIANA DEPARTMENT
                )    SS:    OF ENVIRONMENTAL MANAGEMENT
COUNTY OF MARION    )

COMMISSIONER OF THE DEPARTMENT        )
OF ENVIRONMENTAL MANAGEMENT,        )
                                )
        Complainant,                )
                                )
                    v.            )CAUSE NO. B-2413(b) or
                                ) 1998-4703-W
ROJO DEVELOPMENT, INC.,                )
A.J. HICKEY, PRESIDENT,                )
                                )
        Respondent.                    )

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 (hereinafter referred to as "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 ROJO Development, Inc., A.J. Hickey, President (hereinafter referred to as "Respondent"), which owns the property where Mishawaka Dome Sport Complex, Inc. initiated the development known as Mishawaka Sport Dome Complex (the "Development"), located in St. Joseph County, Indiana.

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, IDEM issued a Notice of Violation via Certified Mail on January 28, 1999 to:

    ROJO Development, Inc.     and to:    Mishawaka Dome Sport Complex, Inc.
    A.J. Hickey, President            Dean Schmidt, Registered Agent
    C/O Thomas Lewis, Secretary        214 West 7th Street
    1800 Valley American Bank Building    Mishawaka, Indiana 46544    
    South Bend, Indiana 46601

5.    This Agreed Order settles issues concerning violations of rules and statutes that occurred in 1998 and 1999 for which ROJO Development, Inc. was responsible, and not those issues concerning Mishawaka Dome Sport Complex, Inc. which are addressed under Agreed Order, Cause No. B-2413(b), adopted on October 15, 1999.

6.    327 IAC 15-5-2 pertains to storm water run-off associated with construction activity. The requirements under this rule apply to all persons who:

    (1)     do not obtain an individual NPDES permit under 327 IAC 15-2-6;
    (2)     meet the general permit rule applicability requirement under 327 IAC 15-2-3;         and
    (3)    are involved in construction activity, which includes clearing, grading, excavating, and other land disturbing activities, except operations that result in the disturbance of less than five (5) acres of total land area and which are not part of a larger common plan of development or sale.

7.    327 IAC 15-2-5(a) states, "Any person subject to the requirements of this article shall submit a Notice of Intent (NOI) letter that complies with this section, 327 IAC 15-3, and the additional requirements in any applicable general permit rule."

8.    327 IAC 15-2-5(b) states, "A NOI letter shall be submitted to the commissioner by the time specified under 327 IAC 15-3 or the time indicated in the applicable general permit rule."

9.    327 IAC 15-2-5(c) states, "The person responsible for the operation of the facility from which a point source discharge of pollutants and/or stormwater occurs must submit a NOI letter."

10.    327 IAC 15-2-3 states in part, "A general permit rule may regulate all designated categories of point sources for which a general permit rule exists..."

11.    327 IAC 15-5-6, pertains to the deadline for submittal of a Notice of Intent (NOI) letter and additional information. All information required under 327 IAC 15-3 and 327 IAC 15-5-5 shall be submitted to the Commissioner prior to the initiation of land disturbing activities.

12.    327 IAC 15-5-5 states, "In addition to the NOI letter requirements under 327 IAC 15-3, the following information must be submitted by the operator with NOI letter under this rule:

    (1)    A brief description of the construction project, including, but not limited to, a statement of the total acreage of the site.
    (2)    Estimated timetable for land disturbing activities and installation of erosion control measures.
    (3)    Statement of the number of acres to be involved in land disturbing activities.
    (4)    A written certification by the operator that:

        (A)    the erosion control measures included in the erosion control plan comply with the requirements under sections 7 and 9 of this rule and that the plan complies with applicable state, country, or local erosion control requirements;
        (B)    the erosion control measures will be implemented in accordance with the plan;
        (C)    verification 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; and
        (D)    verification that implementation of the erosion control plan will be conducted by personnel trained in erosion control practices.
    (5)    Proof of publication in a newspaper of general circulation in the affected area that notified the public that a construction activity under this rule is to commence."

13.    327 IAC 15-5-7 pertains to general conditions for construction activity erosion control measures. It states, in substance, that the operator shall develop an erosion control plan in accordance with the requirements under this section. The following requirements shall be met on all sites during the period when active land disturbing activities occur:

    a.    Sediment-laden water which otherwise would flow from the site shall be detained by erosion control practices appropriate to minimize sedimentation in the receiving stream. No storm water shall be discharged from the site in a manner causing erosion in the receiving channel at the point of the discharge.
    b.    Appropriate measures shall be taken by the operator to minimize or eliminate wastes or unused building materials from being carried from a site by run-off.
    c.    Sediment being tracked from a site onto public or private roadways shall be minimized.
    d.    Public or private roadways shall be kept clear of accumulated sediment. Bulk clearing of accumulated sediment shall not include flushing the area with water. Cleared sediment shall be returned to the point of likely origin or other suitable location.
    e.    All on-site storm drain inlets shall be protected against sedimentation with barriers meeting acceptable design criteria, standards, and specification for that purpose.
    f.    The following items apply during the time construction activity is taking place:
        1)    Storm water drainage from adjacent areas that naturally pass through the site shall be controlled by diverting it around the disturbed area.
        2)    Run-off from a disturbed area shall be controlled by one or more of the measures required under this section.
        3)    During the period of construction activity at a site, all erosion control measures necessary to meet the requirements of this rule shall be maintained by the operator.

        4)    All erosion control measures required to comply with this rule shall meet the design criteria, standards, and specifications for erosion control measures established by the IDEM in guidance documents. The erosion control plan shall include, but is not limited to, a site map, a plan of final site conditions and a site construction plan, all as detailed in 327 IAC 15- 5-7(d).

14.    The Respondent's violations of the above noted Indiana Administrative Code provisions are based on the following:

    A)    The Mishawaka Sports Dome Complex falls under the applicability requirements of 327 IAC 15-5-2 in that five (5) or more acres of total land area are involved in construction activity. The construction activity at this site is not covered by an NPDES permit under 327 IAC 15-2-6, but meets the general permit rule applicability requirement under 327 IAC 15-2-3. The development is therefore categorized as a point source discharge of stormwater and is required by 327 IAC 15-2-5(c) to submit a NOI letter.

    B)    On September 1, 1998, the St. Joseph County Soil and Water Conservation District (SWCD) obtained an Erosion and Sediment Control Plan for the Mishawaka Sports Dome Complex in Mishawaka, Indiana from the City of Mishawaka Department of Engineering.

    C)    On September 17, 1998, SWCD and Indiana Department of Natural Resources, Division of Soil Conservation (IDNR) staff conducted a site visit to the Development and observed that the entire 60 acres site had been cleared and that the topography had been altered significantly. IDNR staff observed a construction crew on site installing rock check dams in the small ravine along with silt fences. IDNR staff were also informed that double silt fencing was being installed to help control the water and sediment. It was observed that there was an adjacent ravine approximately 10 to 15 feet to the north of the existing gully that was being worked on that was coming out of the corn field to the north of the project site. IDNR staff continued to walk the site and discovered that silt fencing needed to be placed at the southwest corner of the property to protect the adjoining wooded area. It was observed that sediment traps were definitely needed along with additional perimeter protection. IDNR staff discussed their concern of necessary silt fencing for the southwest corner with the construction crew and the construction crew noted that they were aware of the area and that the silt fencing would be installed.

    D)    On September 23, 1998, IDNR and SWCD staff visited the Development and, among other things, observed off-site sedimentation.

    E)    On September 28, 1998, IDNR and SWCD staff met with Mr. Schmidt, Mr. Hickey, and a representative of the excavating company that had performed the clearing and excavation work on the Development and discussed the existing sedimentation problems on site and off-site and what measures would need to be installed immediately to stop further sedimentation. During the site visit IDNR staff explained that the Erosion and Sediment Control Plan must be submitted to the SWCD for review and that IDNR and SWCD are not always notified if another county or city department receives a plan.

    F)    On October 1, 1998, IDNR staff sent a letter to Mr. Schmidt and a copy of the letter to Mr. Hickey that outlined the items concerning erosion and sediment control discussed during the September 28, 1998, meeting at the Development. The letter included recommendations for structural erosion and sediment control measures that needed to be installed.
    
    G)    On October 2, 1998, SWCD staff conducted a site visit to the Development and observed and photographed areas of ponding water at the southeast corner bordering a county ditch and at the northeast corner bordering the woods. Signs of additional sediment occurring off slopes and entering into low lying areas were observed and photographed.

    H)    On October 6, 1998, IDEM sent a Warning of Noncompliance letter to Mr. Schmidt and a copy of the letter to Mr. Hickey. The letter stated that IDEM had been notified by IDNR staff that the Development was out of compliance with NPDES General Permit rule 327 IAC 15-5. The letter informed Mr. Schmidt and Mr. Hickey that 327 IAC 15-5-2 requires the submittal of a Notice of Intent (NOI) letter and payment of a $100 fee to the IDEM. The letter also noted that a soil erosion control plan was submitted for the Development but not before earth- moving activities began. It was noted that additional information needs to be submitted before the plan is deemed to be acceptable. The letter also noted the provisions of 327 IAC 15-5-7(c). It stated that it had been noted during an inspection that sediment had left the site and that this would not have occurred if proper erosion control measures had been in place before earth moving began.

    I)    On November 2, 1998, IDNR sent a letter to Larry R. Long and Associates, Inc., the consulting firm that submitted the erosion and sediment control plan for the Development. The letter included a checklist the IDNR staff used when reviewing the plan, and a Comments Sheet that was attached to the review. Comments included:

            The Erosion Control Plan doesn't provide a true reflection of what is occurring on the construction site. It does not show the soil stockpiles located in the southeast corner of the construction area. As I [IDNR Urban

Conservation Specialist, Larry Osterholz] discussed with Mr. Schmidt on October 29, 1998, silt fence should be extended along the south and east sides of the stockpiles to contain them on site until construction resumes next spring.

            The plan should also show the approximated locations of the sediment traps and rock dams that have been constructed on site as well as the temporary seeding and hydro-mulching that is taking place.

        The November 2, 1998, letter also included comments regarding the Phasing of Construction, the Existing Site Conditions, Soils, and Floodplains, and directed the consulting firm to make the necessary changes, and submit a revised plan to the St. Joseph County Soil and Water Conservation District by November 20, 1998.

    J)    On October 29, 1998, IDNR and SWCD staff met at the construction site with Mr. Schmidt and discussed the need for inspection and maintenance of existing erosion and sediment control measures. IDNR staff explained that some of the measures did not meet practice standards and specifications and that these on-site practices needed to be modified.

    K)    Mr. Schmidt submitted a NOI letter dated October 28, 1998, and payment of the $100 fee for the Development. The NOI letter listed the Operator Name as Dean Schmidt and the Company Name as Mishawaka Dome Sports Complex, Inc.

    L)    On November 4, 1998, IDNR sent a letter to Mr. Schmidt and a copy of the letter to Mr. Hickey that outlined the items that were discussed when they had met at the Development on October 29, 1998. The letter stated that the vegetative erosion and sediment control measures needed to be completed as soon as possible and that structural erosion and sediment control measures should be installed by early to mid-November or sooner if possible. The letter also recommended specific erosion control measures and noted that IDNR staff had discussed with the Developments consulting firm the fact that the erosion and sediment control measures that have been or are being install on-site should be included in the projects's Erosion Control Plan.

    M)    On November 9, 1998, IDEM sent a letter to Mr. Schmidt stating that upon review of the NOI letter submitted to IDEM in compliance with 327 IAC 15-5, it had been determined that the NOI letter was deficient and that an amendment to the NOI letter containing the deficient information must be submitted. The letter also stated that in accordance with 327 IAC 15-5-6, all information required under 327 IAC 15-3 and section 5 of this rule must be submitted prior to the initiation of land disturbing activities in order to be covered and in compliance with Rule 5.

The letter noted that the storm water general permit applicant was to provide proof of publication in a newspaper of general circulation in the affected area that notified the public that a construction activity under this rule is to commence.

    N)    The NOI letter that was submitted by Mr. Schmidt dated October 28, 1998, for the Mishawaka Sports Dome Complex included language for public notice and stated, "This Public Notice is to appear, twice, one week apart, in a newspaper of local distribution." However, the NOI did not include proof of publication in a newspaper of general circulation and as of December 17, 1998, IDEM had not received a proof of publication as required by 327 IAC 15-5-5(5) for the Development. The NOI letter also stated that the `Start Date' for the Development would be March 15, 1999. However, as noted by inspections and site visits to the Development by IDNR staff in September and October 1998, indicate that the site had been cleared and land disturbing activities had been initiated on or before September 17, 1998.

    O)    On November 20, 1998, IDNR sent a letter to the Department of Engineering of the City of Mishawaka with copies of the letter sent to Mr. Schmidt and Mr. Hickey. The letter stated that a follow-up inspection had been conducted of the Development on November 19, 1998 and noted that some erosion and sediment control measures had been constructed and should provide for minimal off-site sediment damage during the winter months. However, IDNR staff stated that some of the practices that had been installed did not fully meet the design criteria as outlined in the Indiana Handbook for Erosion Control in Development Areas and the site was seeded at such a late date that the vegetation had not had a chance to develop a dense cover and well established rooting system. The letter also outlined areas of erosion and sediment control of concern that were noted during the inspection, and recommended that the owner/developer inspect the Development on regular basis.

    P)    On December 3 and December 15, 1998, IDNR and SWCD staff conducted On- Site Evaluations for Erosion and Sediment Control at the Development and noted on the evaluation reports: there was evidence of sediment in a legal ditch; silt fencing was down throughout the southeast drainage channel; rills were forming throughout the site; sediment traps in the northeast and southwest corners were at peak capacity; there was little germination on the flat areas above the draws; and gullies were enlarging on property to the north of the complex site. The evaluation reports noted that there was evidence of off-site sedimentation that was described as deposition of sediment in a county ditch and also onto an adjacent landowner's property to the east of the project. The evaluation reports also noted that repairs as outlined in a letter from IDNR dated November 20, 1998, had not been implemented to date, and that SWCD had still not received the additional information from the project's consulting firm as requested on Technical Review

Comments Statement dated November 2, 1998. The reports also noted that it was necessary to repair the check dam in the woods to the east of the site.

    Q)    On March 12, 1999, the Respondent submitted a letter to IDEM that stated, in substance, that ROJO Development, Inc. had been negotiating the sale of the property with Dean H. Schmidt and Tracy L. Schmidt, however the sale was never finalized. The letter stated that Mr. Schmidt began construction activity without ROJO Development's knowledge or permission, and did not have permission to be on the property. After the contract to purchase the property was appropriately canceled and terminated, ROJO Development, Inc. has taken and will take appropriate measures to control sediment runoff.

    R)    On April 14, 1999, and on November 3, 1999, IDNR staff met with the Respondent's representatives at the Development and inspected the site. After each inspection IDNR staff sent a letter to Respondent (on April 15, 1999, and November 15, 1999) and made recommendations as to installation of additional erosion control measures and maintenance of the erosion control measures. The Respondent responded to IDNR's recommendations and the site conditions related to erosion control have improved. However, the Respondent will need to continue to install additional erosion control measures and maintain the existing erosion control measures as necessary until site conditions at the Development are permanently stabilized.

15.    The information outlined in item 14 of these "Findings of Fact" from site visits, letters, photographs, and other correspondence indicates that Mishawaka Dome Sport Complex, Inc., which initiated the Development on or before September 17, 1998, and ROJO Development, Inc., which owns the real estate and took responsibility for installation and maintenance of erosion control measures after Mishawaka Dome sport Complex, Inc. ended its involvement in the Development in late 1998 or early 1999, have violated provisions of 327 IAC 15-5-5 and 327 IAC 15-5-6, in that they did not submit a NOI letter with necessary information to the Commissioner or an Erosion Control Plan to the appropriate soil and water conservation district office for review prior to the initiation of land disturbing activities at the Development.

16.    The information outlined in item 13 of these "Findings of Fact" from site visits, letters, photographs, and other correspondence also indicates that Mishawaka Dome Sport Complex, Inc., which initiated the Development on or before September 17, 1998, and ROJO Development, Inc., which owns the real estate and took responsibility for installation and maintenance of erosion control measures after Mishawaka Dome Sport Complex, Inc. ended its involvement in the Development in late 1998 or early 1999, have violated provisions of 327 IAC 15-5-7, in that during the period when active land disturbing activities occurred, they failed to detain sediment-laden water which otherwise would flow from the site by erosion control practices appropriate to minimize

sedimentation in the receiving stream. They failed to implement and maintain appropriate erosion control practices to control run-off from disturbed areas, resulting in sediment leaving the site. They have failed to appropriately incorporate erosion control measures established by the IDEM in guidance documents into land disturbing activities.

17.    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 her delegate, and has been received by the Respondent. This Agreed Order shall have no force or effect until the Effective Date.

2.    Within ten (10) days of the Effective Date, the Respondent shall assure that the recommended items A, B, C, and D outlined in IDNR's November 15, 1999 letter (see Attachment A) are completed at the property where the Mishawaka Sports Dome Complex development was initiated. Additionally, until the earlier of:

        1) the Respondent sells the entire property,

        2) the IDNR provides written documentation that the site is permanently              stabilized, or

         3) the Respondent re-initiates construction activities,

    the Respondent shall inspect the site on a weekly basis and during or after each storm event and maintain the erosion control measures as outlined in item E of IDNR's November 15, 1999 letter (see attachment A).

3.    If the Respondent decides to re-initiate construction activities at the property, then prior to initiation of associated land disturbing activities, the Respondent will submit a revised erosion control plan to the St. Joseph County SWCD, and a new NOI to IDEM. If the Respondent sells the property, then the Respondent will provide the purchaser with written notification of the provisions requiring submittal of a erosion control plan and NOI as required by 327 IAC 15-5.

4.    In the event the following terms and conditions are violated, the Complainant may assess and the Respondent shall pay a stipulated penalty in the following amounts:

         Violation                        Penalty

    Paragraph 2:            $1,000 per week for failure to timely assure that the recommended items A, B, C, and D outlined in IDNR's November 15, 1999 letter are completed at the property where the Mishawaka Sports Dome Complex development was initiated, and
                    $1,000 per week for failure to inspect the site on a weekly basis and during or after each storm event and maintain the erosion control measures as outlined in item E of IDNR's November 15, 1999 letter.

    Paragraph 3:            $1,000 per week for failure to submit a revised erosion control plan to the St. Joseph County SWCD, and a new

NOI to IDEM prior to initiating land disturbing activities at the property should the Respondent re-initiate construction activities at the property, and
                    $5,000 should the Respondent sell the property and fail to provide the purchaser with written notification of the provisions requiring submittal of a erosion control plan and a NOI as required by 327 IAC 15-5.

5.    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.

6.    Stipulated penalties are payable by check to the Environmental Management Special Fund. Checks shall include the Cause Number of this action and shall be mailed to:
                Cashier
                Indiana Department of Environmental Management
                100 N. Senate Avenue
                P. O. Box 7060
                Indianapolis, IN 46207-7060

7.    This Agreed Order shall apply to and be binding upon the Respondent, its officers, directors, principals, agents, successors, subsidiaries, 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.

8.    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.

9.    The Respondent shall provide a copy of this Agreed Order, if in force, to any subsequent owners or successors before ownership rights to the Mishawaka Sports Dome Complex development 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.

10.    This Agreed Order shall remain in effect until Respondent has complied with the requirements of paragraphs 2 and 3 of this Agreed Order.


TECHNICAL RECOMMENDATION:        RESPONDENT:
Department of Environmental Management

By:     _________________________        By:     _________________________
    Mark W. Stanifer, Section Chief
    Office of Enforcement            Printed: ________________________

                            Title:     ________________________

Date: _______________                Date:     _______________

COUNSEL FOR COMPLAINANT:        COUNSEL FOR RESPONDENT:
Department of Environmental Management

By: _________________________            By: _____________________
Nancy A. Holloran
Office of Legal Counsel                
Department of Environmental Management

Date: _______________                Date: _______________

APPROVED AND ADOPTED BY THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT THIS _____ DAY OF ____________________, 2000.

                            For the Commissioner,

                            __Signed 1/28/00______
                            Felicia A. Robinson
                            Assistant Commissioner of Enforcement
                    

Converted by Andrew Scriven