8/27/08 - ADMINISTRATIVE ORDER ISSUED. ON NOV 14, 2007, EPA AND MDEQ PERFORMED A COMPLIANCE STORMWATER EVALUATION INSPECTION (CSWEI) AT BASS PRO DRIVE TO EVALUATE THE TREATMENT AND DISPOSAL OF STORMWATER. DURING THE CSWEI, EPA OBSERVED THE FOLLOWING:
A. THE CITY FAILED TO INSTALL NECESSARY BMPs REQUIRED IN THEIR SWPPP; I.E., SILT FENCES, HAY BALES, DITCH CHECKS ETC.
B. THE SILT FENCING ALONG THE BANK AREA OF CONWAY SLOUGH DID NOT EXIST, OR WAS IN NEED OF MAINTENANCE. THE CITY FAILED TO PROVIDE FOR ADEQUATE MAINTENANCE OF SILT FENCING.
C. NO VELOCITY DISSIPATION DEVICES REQUIRED IN THE SWPPP ALONG CONWAY SLOUGH WERE IN PLACE TO PROVIDE FOR A NON-EROSIVE FLOW. THE CITY FAILED TO PROVIDE FOR VELOCITY DISSIPATION DEVICES.
D. AN OPEN DIVERSION DITCH WAS EXCAVATED TO DIVERT WATER IN CONWAY SLOUGH AROUND THE AREA OF CONSTRUCTION OF A CONCRETE BOX CULVERT AND BACK INTO CONWAY SLOUGH. THE DITCH WAS ROUTED DIRECTLY T THE SLOUGH WITHOUT INSTALLATION OF BMPs SPECIFIED IN THE SWPPP. THE CITY FAILED TO PROVIDE INSTALLATION OF NEEDED BMPs BEFORE COMMENCEMENT OF CONSTRUCTION.
E. UNCONTROLLED SEDIMENT HAD BEEN ALLOWED TO ENTER THE DIVERSION DITCH AND CONWAY SLOUGH. THE CITY FAILED TO ENSURE THAT STORMWATER DISCHARGES WERE FREE OF EXCESSIVE SEDIMENT AND FLOATING MATERIALS.
F. THE DIVERSION DITCH AND THE AREA AROUND THE CONCRETE CULVERT HAVE SHOWN EVIDENCE OF POTENTIAL DISCHARGE OF STORMWATER DIRECTLY TO CONWAY SLOUGH. THESE DISCHARGE POINT SOURCES WERE NOT IDENTIFIED IN THE S