# CLARK CONSTRUCTION GROUP, LLC / SATOC TRAINEE BARRACKS / HARMONY CHURCH SITE (FF)
> **Administrative - Formal** · FY2009 · — · Unilateral Administrative Order Without Adjudication
## Case
- **Activity ID:** `1800015232`
- **Case Number:** 04-2009-4797
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Unilateral Administrative Order Without Adjudication
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- CLARK CONSTRUCTION GROUP, LLC (settlement)
- HARMONY CHURCH SITE (settlement)
- SATOC TRAINEE BARRACKS (settlement)
## Summary

7/9/09 - ADMINISTRATIVE ORDER ISSUED.  

ON FEB 26, 2009, EPA AND GAEPD, FORT BENNING DIRECTORATE OF PUBLIC WORKS ENVIRONMENTAL MANAGEMENT DIVISION, AND THE ARMY CORPS OF ENGINEERS PERFORMED A COMPLIANCE STORM WATER EVALUATION INSPECTION (CSWEI) AT CLARK CONSTRUCTION'S DEVELOPMENT TO EVALUATE THE TREATMENT AND DISPOSAL OF STORM WATER.  AS A RESULT OF THE CSWEI, EPA HAS DETERMINED THAT STORM WATER ASSOCIATED WITH INDUSTRIAL ACTIVITY WAS DISCHARGED FROM THE DEVELOPMENT WITHIN THE MEANING OF CWA SECTION 402(p) AND ITS IMPLEMENTING REGULATIONS.

DURING THE CSWEI, EPA INSPECTORS OBSERVED THE FOLLOWING:

A. SEDIMENT DEPOSITION WAS OBSERVED OFF SITE BEYOND OUTFALL B WITHIN A DESIGNATED WETLANDS AREA IN VIOLATION OF PART V.D OF THE PERMIT.

B. THE BMPs TO CONTROL VEHICLE TRACKING OF SEDIMENT WERE NOT EFFECTIVE AS REQUIRED BY PART IV.D.3.c(2) OF THE PERMIT. A LAYER OF SEDIMENT WAS OBSERVED ON THE ROAD ALONG THE CONSTRUCTION SITE.

C. BMPs WERE NOT IMPLEMENTED PROPERLY AS REQUIRED BY PARTS III.D.2 AND V.L OF THE PERMIT. SPECIFICALLY, THE ROCK PROTECTION AT THE OUTFALL FOR THE PIPED CREEK THRU THE DEVELOPMENT HAD SEDIMENT BUILD UP, AND THE CURB INLET PROTETION WAS NOT PROPERLY IMPLEMENTED.

D. THE PLAN SUBMITTED TO EPA DID NOT CONTAIN A DESCRIPTION OF PROCEDURES TO ENSURE THE TIMELY MAINTENANCE OF VEGETATION, EROSION AND SEDIMENT CONTROL MEANSURES AS REQUIRED BY PART IV.D.5 OF THE PERMIT.

ORDER REQUIRES:  
A. IMMEDIATELY, CLEAN OUT OR STABILIZE THE SEDIMENT WHICH HAS BEE

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*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*