STATE OF INDIANA

COUNTY OF MARION

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SS:

BEFORE THE INDIANA DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT

 

COMMISSIONER OF THE DEPARTMENT
OF ENVIRONMENTAL MANAGEMENT,

Complainant,

v.

NORTHWEST HAMILTON LAKE,
DEVELOPMENT CO., LLC

 

Respondent.

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Case No. 2004-14322-W




 

 

NOTICE AND ORDER OF THE

COMMISSIONER OF THE

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 

 

Via Certified Mail #:

 

 

Via Certified Mail #:

 

 

To:

Mr. Thomas Flegal

Project Site Owner

Northwest Hamilton Lake Dev. Co., LLC

6340 South 300 East

Hamilton, IN  46742

 

Mr. Kent Miller

Registered Agent

Northwest Hamilton Lake Dev. Co., LLC

5215 North State Road 9

Columbia City, IN  46725

 

 

This Notice and Order of the Commissioner of the Department of Environmental Management ("Order") is issued against Northwest Hamilton Lake Development Co., LLC (“Respondent”) for violation of the Indiana Environmental Management Act.  This Order is issued 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”). The investigation determined that the Respondent violated Indiana Code (“IC”) 13-18-4-5, IC 13-30-2-1, 327 Indiana Administrative Code (“IAC”) 2-1-6, 327 IAC 15-2-5, 327 IAC 15-5-5, 327 IAC 15-5-6, and 327 IAC 15-5-7.

 

FINDING OF VIOLATION

 

1.                  Respondent is Northwest Hamilton Lake Development Company, LLC (“Respondent”), which owns and develops residential subdivisions known as Crystal Bay (also known as “Phase I”) and Crystal Cove (also known as “Phase II”), located at the east side of County Road 300 East, south of Lane 280 in Hamilton, Steuben County, Indiana (“Site”).

 

2.                  Pursuant to 327 IAC 15-2-5(a), any person subject to the requirements of 327 IAC 15 shall submit a Notice of Intent (“NOI”) letter that complies with 327 IAC 15-2-5, 327 IAC 15-3, and the additional requirements in the applicable permit rule.

 

3.                  Pursuant to 327 IAC 15-5-6, all information required under 327 IAC 15-3 and 327 IAC 15-5-5, specifically a NOI letter and all related information, shall be submitted to the commissioner prior to the initiation of land disturbing activities.  Respondent failed to submit a NOI letter for Crystal Cove prior to initiating land disturbing activities at the Site on or about December 2002 in violation of 327 IAC 15-5-6 and 327 IAC 15-2-5(a).

 

4.                  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 327 IAC 15-5-7.  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.

 

5.                  Pursuant to 327 IAC 15-5-7(d), all erosion control measures required to comply with this rule shall meet the design criteria, standards, and specifications for erosion control established by the department in guidance documents similar to, or as effective as, those outlined in the Indiana Stormwater Quality Manual from the Division of Soil Conservation of the Indiana Department of Natural Resources (“IDNR”), and the Field Office Technical Guide from the Natural Resources Conservation Service.

 

6.                  Pursuant to 327 IAC 15-5-5(4), the NOI letter must include a written certification by the operator that the erosion control measures in the ESCP comply with 327 IAC 15-5-7 and, in addition, that the applicable state, county, or local erosion control authority and the soil and water conservation district office have been sent a copy of the ESCP for review.

 

7.                  Respondent failed to submit an ESCP for Crystal Cove to the IDNR or to the Steuben County Soil and Water Conservation District (“SWCD”) prior to initiating land disturbing activities on or about December 2002 in violation of 327 IAC 15-5-7(a) and (d), 327 IAC 15-5-5(4), and 327 IAC 15-5-6.

 

8.                  Pursuant to 327 IAC 15-5-7(b), 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.                  Appropriate measures shall be taken to minimize or eliminate wastes or unused building materials from being carried from the site by run-off.

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

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

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

f.                    Storm water drainage from adjacent areas that naturally passes 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.

g.                  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.

 

9.                  As documented during Site inspections at Crystal Bay and/or Crystal Cove conducted on December 9, 2003; and January 15 and 16, February 25, April 12, and May 11, 2004, the Respondent has failed to meet the requirements of 327 IAC 15-5-7(b) and thus has violated 327 IAC 15-5-7.

 

10.             Pursuant to 327 IAC 2-1-6(a), all waters at all times and at all places, shall meet the minimum conditions of being free from substances, materials, floating debris, oil, or scum attributable to municipal, industrial, agricultural, and other land use practices, or other discharges:

 

a.                  that will settle to form putrescent or otherwise objectionable deposits;

b.                  that are in amounts sufficient to be unsightly or deleterious;

c.                  that produce color, visible oil sheen, odor, or other conditions in such degree as to create a nuisance;

d.                  which are in amounts sufficient to be acutely toxic to, or to otherwise severely injure or kill aquatic life, other animals, plants, or humans; and

e.                  which are in concentrations or combinations that will cause or contribute to the growth of aquatic plants or algae to such degree as to create a nuisance, be unsightly, or otherwise impair the designated uses.

 

11.             Pursuant to IC 13-18-4-5, it is unlawful for any person to throw, run, drain, or otherwise dispose into any of the streams or waters of Indiana; or cause, permit, or suffer to be thrown, run, drained, allowed to seep, or otherwise disposed into any waters; any organic or inorganic matter that causes or contributes to a polluted condition of any waters, as determined by a rule of the board adopted under IC 13-18-4-1 and IC 13-18-4-3.

 

12.             Pursuant to IC 13-30-2-1, no person may discharge, emit, cause, allow, or threaten to discharge, emit, cause or allow any contaminant or waste, including any noxious odor, either alone or in combination with contaminants from other sources, into the environment or into any publicly owned treatment works in any form which causes or would cause pollution which violates or would violate rules, standards, or discharge or emission requirements adopted by the appropriate board.

 

13.             Site inspections conducted by representatives of IDNR during the period of construction activity and/or active land disturbing activity, revealed that the Respondent caused or allowed the discharge of sediment into Hamilton Lake and adjoining wetlands area, waters of the state, that settled to form objectionable deposits and/or in an amount sufficient to be unsightly or deleterious, in a manner that caused a polluted condition, in violation of IC 13-18-4-5, IC 13-30-2-1, and 327 IAC 2-1-6(a).

 

14.             On February 3, 2006, a Notice of Violation was issued, pursuant to IC 13-30-3-3 to the Respondent for violation of IC 13-18-4-5, IC 13-30-2-1, 327 IAC 2-1-6, 327 IAC 15-2-5, 327 IAC 15-5-5, 327 IAC 15-5-6, and 327 IAC 15-5-7.  The Notice of Violation sent via certified mail to Mr. Thomas Flegal was signed for on February 8, 2006.  The Notice of Violation sent via certified mail to Mr. Kent Miller was signed for on February 21, 2006.

 

15.             The Notice of Violation contained an offer to enter into an Agreed Order containing actions required to correct the violation.

 

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

 

17.             The Respondent has not entered into an Agreed Order resolving this violation.

 

ORDER

 

1.                  The Respondent shall immediately cease and desist violation of IC 13-18-4-5, IC 13-30-2-1, 327 IAC 2-1-6, 327 IAC 15-2-5, 327 IAC 15-5-5, 327 IAC 15-5-6, and 327 IAC 15-5-7.

 

2.                  For purposes of this Order, a construction plan (“CP”) is defined as a representation of a project site and all activities associated with the project.  The plan includes the location of the project site, buildings and other infrastructure, grading activities, schedules for implementation, and other pertinent information related to the project site.  A storm water pollution prevention plan (“SWPPP”) is a part of the construction plan, pursuant to 327 IAC 15-5-4(5) and 327 IAC 15-5-4(35).

 

3.                  The Respondent shall, immediately upon the Effective Date, implement the erosion and sediment control measures contained in the approved CP 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 327 IAC 2-1-6(a); 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 CP 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.  Respondent will be deemed to have satisfied the requirements of this paragraph when IDEM or the local SWCD 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 IDEM or the local SWCD for one (1) 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 to IDEM and accepted by it.

 

4.                  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; and

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

 

5.                  In the event that deficiencies are found during the inspections of the Site conducted pursuant to Order Paragraph No. 4, 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.

 

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

 

a.                  the date and time of the inspection;

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

c.                  the name of the individual conducting the inspection;

d.                  a description of the 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.

 

7.                  The Respondent shall make the records required pursuant to Order Paragraph No. 6 available for inspection and copying by representatives of IDEM, and the SWCD.

 

8.                  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.

 

9.                  The Respondent shall, within thirty (30) days of the Effective Date, submit to IDEM a copy of the notification required pursuant to Order Paragraph No. 8 and a statement certifying that the notification was provided to all parties with access to the Site.

 

10.             The requirements of Order Paragraph Nos. 3, 4, 5, 6, 7 and 8 shall remain in effect until the earlier of :

 

a.                  Respondent submits to IDEM a Notification of Termination of construction activity pursuant to 327 IAC 15-5-11 for the Site; or

b.                  one (1) year has passed from the Effective Date of this Order,

 

and a designated representative of IDEM approves the adequacy of the remaining permanent erosion control measures in accordance with 327 IAC 15-5-8(b).

 

11.             All submittals required by this Commissioner's Order, unless notified otherwise in writing, shall be sent to:

 

Christina Sorensen, Enforcement Case Manager

Indiana Department of Environmental Management

Office of Enforcement – Mail Code 60-02

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

12.             The Respondent shall pay a civil penalty of Fifty-Five Thousand Five Hundred Dollars ($55,500) for violation of IC 13-18-4-5, IC 13-30-2-1, 327 IAC 2-1-6, 327 IAC 15-2-5, 327 IAC 15-5-5, 327 IAC 15-5-6, and 327 IAC 15-5-7.  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 checks and mailed to:

 

Indiana Department of Environmental Management

Cashier’s Office – Mail Code 50-10C

100 North Senate Avenue

Indianapolis, Indiana 46204-2251

 

13.             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

Indianapolis, Indiana 46204

 

 

Failure to properly submit a request for review, before the twentieth (20th) 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.

 

 

 

Date:

 

 

Signed September 29, 2006

 

Thomas W. Easterly
Commissioner

 

cc:       Steuben County Health Department

Joseph Montel, Montel Law Firm

http://www.in.gov/idem