St Andrews Est-CS041104Katt~]een Hartnett White, Chairman
R. B. "Ralph" Marquez, 6~¢mmz;~sioner
Larry R. Soward, Comrni.~sioner
(;leml Shankle, ~'.¥eculive Direclor
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY
Proleclill,q 1'~¥a.~ bq ~'edu('t~?~.! arzd Prt~z'cntil~.q Pollzztiorz
Mr. Larry Davis
P.O. Box 478
255 Parkway Blvd
Coppell, TX 75019
November 4, 2004
ROUTE
KG
KM
ST
Glenn '""x/
RE: Complaint No. 48768
Dear Mr. Davis:
The Texas Commission on Environmental Quality (TCEQ) appreciates your interest in the above
referenced mancr. Your involvement is valuable in assisting the TCEQ in its efforts to protect the
State's water resources. Our investigation has been completed and the results are attached for your
information.
If you have additional questions or concerns, please contact Shane Isbell of my staff at (817) 588-
587I.
Sincerely,
S~d Slocum
Manager, Water Section
D/FW Region Office
SS/si
Attachment
I~Et;ION 4 DAI L.,Xs/Fow~ WowrH · 2309 (;R. Wl;]~ l)l~. · I~'owl \Vow!l~, TE?~\S 76118-6951 · 817/588 5800 · FAX 817/588 5700
P.O. Box 11087 · Austin, Texas 78711-3087 · 512/239-1000 · lnlern*zt address: www./ceq.slate.tx.us
STWFFXR15D967/CO
Texas Commission on Environmental Quality
Investigation Report
ST ANDREWS LAND COMPANY LTD
ST ANDREWS LAND COMPANY ST ANDREWS ESTATES
RN104300900
Investigation # 339931
Investigator: SHANE ISBELL
Conducted: 04/28/2004 -- 04/28/2004
Program(s): STORMWATER
Investigation Type: Compliance Investigation
Additional ID(s): TXR15D967
Incident # 48768
Site Classification
CONSTRUCT]ON GENERAL PERMIT
FOR STORMWATER
No Industry Code Assigned
Location: ST ANDREWS LANE AND
DEFOREST RD ON 400 BLK OF ST
ANDREWS
Address:;,
Activity Type: SWCCICGP
Principal(s):
Role Name
RESPONDENT ST ANDREWS LAND COMPANY LTD
Contact(s):
Role Title Name Phone
Regulated Entity Contact VICE PRESIDENT OF DEAN TRUDELL Work
CONSTRUCTION
Other Staff Member(s):
Role Name
QA REVIEWER JEFF TATE
SUPERVISOR JEFF TATE
(972) 242-1770 x. 228
Associated Check List
Checklist Name Unit Name
CONSTRUCTION CCI FOR LARGE SrTES St Andrews
CONSTRUCTION SWP3 CHECKLIST St Andrews
Investiqation Comments:
INTRODUCTION
On April 28, 2004, Mr. Shane Isbell, Storm Water Investigator of the Texas Commission on
Environmental Quality (TCEQ), conducted a Complaint Investigation for construction storm water at
The Homes Builders, St. Andrews Estates, located at the 400 block of St Andrews in Coppell, TX..
Mr. Dean Trudell, Vice President of Construction, was contacted on site and participated in the
investigation, This investigation was conducted in response to complaint ID# (48768). The
complaint alleged that the St. Andrews Estates is not in compliance with the Storm Water Pollution
Prevention PIan (SWPPP). Mr. Isbell, Water Quality II Investigator of the Texas Commission on
Environmental Quality (TCEQ), verified that the project was considered a large construction site
(over 5 acres).
GENERAL FACILITY AND PROCESS iNFORMATION
It was determined that the construction site, was currently permitted through the TPDES construction
storm water program, and the site's SWP3 was available at the site.
BACKGROUND
ST ANDREWS LAND COMPANY ST ANDREWS ESTATES - COPPELL
4/28/04
Page 2 of 5
This was the first storm water investigation conducted at this site.
ADDITIONAL INFORMATION
The investigator viewed the Storm Water Pollution Prevention Plan (SWPPP) to gain an
understanding of the construction site's physical lay-out, and conducted a walk-through and
evaluation. A comprehensive checklist was used by the investigator to note all items required by the
permit. Silt and sediment was observed migrating through the silt fencing. Furthermore, areas that
needed silt fencing did not have silt fencing installed. The construction representative was advised
to post the Construction Site Notice, Notice of Intent near the entrance of the facility. The violations
documented were as follows: Failure to post the Construction Site Notice, and Notice of Intent near
the entrance of the facility. Failure to revise the SWP3 due to a change in: design, construction,
operation or maintenance that had a significant effect on discharge of pollutants. Failure include in
the SWP3 data describing the soil or quality of any discharge from the site. Failure to include a copy
of the general construction permit in the SWP3. Failure to have adequate erosion add sediment
controls designed to retain sediment on-site. Failure to have adequate controls developed to limit
offsite transport of litter, construction debris, and construction materials. Failure to have BMPs
maintained in an effective operating condition. Failure to have inspections conducted at least once
every 14 days and within 24 hours of the end of a storm event of 0.5 inches or greater or once every
7 days in the following areas: disturbed areas of the construction site that have not been finally
stabilized, areas used for storage of materials that are exposed to precipitation, structural controls,
sediment and erosion controls, and locations where vehicles enter or exit the site. The investigator
reviewed the alleged violations found during the investigation and explained the verbal NOV policy to
Mr. Trudell.
The TCEQ Regional Office received corrective action documentation on May 11,2004 to resolve the
violations. The violations observed during the investigation have been resolved and no further action
is needed.
NOV Date Method
04/28/2004 VERBAL
ALLEGED NONCOMPLIANCESNOTEDAND RESOLVED
Track No: 182778 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part II, Section D(3)(c)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
Failure't0 p0st t~e NOi and Site Notice near the entrance of the construction site.
Recommended Corrective Action: Post the NOI and Site Notice posted near the
entrance of the construction site.
Resolution: The TCEQ received corrective action documentation on May 11, 2004 to
resolve the violation. The violation is resolved and no further ation is needed.
Track No: 182780 Resolution Date: 1113/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section E (1)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
Failure t~ r~ise'th~ ~WP3 due to a change in! d~sign.construction '~tion ~r
maintenance that had a significant effect on discharge of pollutants.
Recommended Corrective Action: If a change occurs in: design, construction,
operation or maintenance of the SWP3 that had a significant effect on discharge of
pollutants the SWP3 should reflect the changes made.
Resolution: The TCEQ received corrective action documentation on May 11,2004 to
resolve the violation. The violation is resolved and no further ation is needed.
ST ANDREWS LAND COMPANY ST ANDREWS ESTATES - COPPELL
4~28~04
Page 3 of 5
Track No: 182781 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section F(1)(e)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
~aiJur~ includ~ in the ~/~3 data ~iescribing the soil o~qua~ity of any discharge from
the site.
Recommended Corrective Action: Include in the SWP3 data describing the soil or
quality of any discharge from the site.
Resolution: The TCEQ Regional Office received corrective action documentation on
May 11,2004 to resolve the violation. The violation is resolved and no further ation is
needed.
Track No: 182783 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section F(1){h)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
F'ailure t-o include a ~opy of the ~neral cons{ruction permit in the SWP3.
Recommended Corrective Action: The SWP3 must include a copy of the general
construction permit in the SWP3.
Resolution: The TCEQ Regional Office received corrective action documentation on
May 11, 2004 to resolve the violation. The violation is resolved and no further ation is
needed.
Track No: 182790 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section F(2)(a)(i)
Alleged Violation:
Investigation: 339931
Comment Date: 11/03/2004
Failure to have adequate erosion and sediment controls designed to retain sediment
on-site along the west side of the facility aswell as stock piles of dirt.
Recommended Corrective Action: Mr. Trudeil was advised to have adequate erosion
and sediment controls designed to retain sediment on-site.
Resolution: On May 11, 2004, Mr. Trudell submitted documentation to the TCEQ
Regional office stating that the west side of the project had silt fence installed, and that
there had been silt fence reinforced where needed. Furthermore, he added larger rock
to help stabilize the construction entrance.
Track No: 182795 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section F(2)(a)(v)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
Failure to have ad~;quate c~)ntrols devei0ped to timit offsite ti'ansport~f i~tter, '
construction debris, and construction materials.
Recommended Corrective Action: Mr. Trudell was advised to he add larger rock to
help stabilize the construction entrance.
Resolution: On May 11, 2004, Mr. Trudell submitted documentation to the TCEQ
Regional office stating that he added additional larger rock to help stabilize the
construction entrance.
ST ANDREWS LAND COMPANY ST ANDREWS ESTATES - COPPELL
4/28/04
Page 4 of 5
Track No: 182797 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGPPart III, Section F(7)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
Failur~ to have BMP~maintained i~'~ effective operating conditi~
Recommended Corrective Action: Mr. Trudell was advised to have BMPs
maintained in an effective operating condition.
Resolution: On May 11, 2004, Mr. Trudell submitted documentation to the TCEQ
Regional office stating that the west side of the project had silt fence installed, and that
there had been silt fence reinforced where needed.
Track No: 182798 Resolution Date: 11/3/04
30 TAC Chapter 281.25(a)(4)
PERMIT CGP Part III, Section F(8)(a)
Alleged Violation:
Investigation: 339931 Comment Date: 11/03/2004
Failure to have inspections conducted at least once every 14 days and within 24
hours of the end of a storm event of 0.5 inches or greater or once every 7 days in the
following areas: disturbed areas of the construction site that have not been finally
stabilized, areas used for storage of materials that are exposed to precipitation,
structural controls, sediment and erosion controls, and locations where vehicles enter
or exit the site.
Recommended Corrective Action: Mr. Trudell was advised to have inspections
conducted at least once every 14 days and within 24 hours of the end of a storm event
of 0.5 inches or greater or once every 7 days in the following areas: disturbed areas of
the construction site that have not been finally stabilized, areas used for storage of
materials that are exposed to precipitation, structural controls, sediment and erosion
controls, and locations where vehicles enter or exit the site.
Resolution: The TCEQ Regional Office received corrective action documentation on
May 11,2004. Mr. Trudell's documentation stated inspections will be conducted once
every 7 days.
Signed
Environmental Investigator
Date //,/- '~--C:? y
Signed
Date
Attachments: (in order of final report submittal)
Enforcement Action Request (EAR)
Letter to FaciIify (specify type):
Investigation Report
Maps, Plans, Sketches
Photographs
Correspondence from the facility
ST ANDREWS LAND COMPANY ST ANDREWS ESTATES - COPPELL
4/28/04
Page 5 of 5
~am~i~An~ly~i; Results
Manifests
Other (specify):
NOR