4/6/10 - ADMINISTRATIVE ORDER ISSUED.
ON NOV 4, 2009, EPA IN CONJUNCTION WITH TDEC CONDUCTED A COMPLIANCE STORM WATER EVALUATION INSPECTION (CSWEI) AT THE DEVELOPMENT TO EVALUATE THE TREATMENT AND DISPOSAL OF STORMWATER.
DURING THE CSWEI, EPA OBSERVED THE FOLLOWING:
A. THE CITY OF MEMPHIS FAILED TO RETAIN A SWPPP ON-SITE AS REQUIRED BY SECTIONS 3.3.1 AND 5.2 OF THE PERMIT.
B. THE CITY OF MEMPHIS FAILED TO DESIGN AND IMPLEMENT EROSION PREVENTION AND SEDIMENT CONTROLS AS REQUIRED BY SECTIONS 3.5.3.1 AND 6.14 OF THE PERMIT. SILT FENCES THROUGHOUT THE DEVELOPMENT WERE NOT MAINTAINED, A STORMWATER INLET WAS NOT PROTECTED; AND AREAS OF THE DEVELOPMENT AND THE BANKS OF THE SEDIMENTATION POND WERE NOT STABILIZED WITHIN 15 DAYS OF DISTURBANCE.
D. THE CITY OF MEMPHIS FAILED TO ESTABLISH PROPER ENTRANCE/EXIT CONTROLS AS TO PREVENT OFF-SITE VEHICLE TRACKING OF SEDIMENTS AND THE GENERATION OF DUST, AS REQUIRED BY SECTION 3.5.5 OF THE PERMIT.
E. THE CIYT OF MEMPHIS FAILED TO PREVENT SEDIMENT DISCHARGES INTO FLETCHER CREEK BY FAILING TO DESIGN, INSTALL, AND MAINTAIN EROSION CONTROLS; BY NOT STABILIZING THE SOILS ON THE DEVELOPMENT; AND BY NOT CONTAINING AND/OR CONTROLLING STORM WATER RUN-OFF, AS REQUIRED BY SECTIONS 4.3.2 AND 6.4 OF THE PERMIT.
ORDER REQUIRES:
A. IMMEDIATELY, RETAIN A SWPPP ON-SITE. WITHIN 30 DAYS, SUBMIT A COPY OF THE DEVELOPMENT'S SWPPP.
B. IMMEDIATELY, DESIGN AND IMPLEMENT EROSION PREVENTION AND SEDIMENT CONTROLS ON THE DEVELOPMENT. SILT FENCE