HomeMy WebLinkAbout7th Street PropertyNplesville 317/773-5487
FAX 317/776-644
Voi{e Mail: (317) 824-6321
rinejWF jeley
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Morgan 0 AQS.DCi3LC, Inc.
Title Insurance & Closin4CSerces
Emil"Ann Sbrq NiN esri lr. Indlnnn 46060:n d
A Ibll Sen*e fiillr lmura,tn Apmey
Ms. Susan Hunter
City of Carmel
One Civic Square
Carmel, In. 46032
Dear Ms. Hunter,
Amoctato6, Inc.
ice & Closing Services
lndinnn 46060-2279 317/773-5487 FAX 317/776-6444
Agency
I have been researching your request for Morgan & Associates, Inc.
to locate a right of way grant adjoining the north end of Lots 60
and 61 in C. W. Wiedlers Subdivision in the City of Carmel and
have not found any evidence of a grant for right of way purposes.
I am sending a copy of the recorded plat for C. W. Wiedlers
Subdivision and, as you can see, there is a strip along the north
end of the subdivision. I think there would be a good argument
that the strip is for access or street purposes.
If you add up all of the dimensions for Lots 61 through 71 and
thirty feet for the east -west street north of Lot 67, the total
is 1257 feet. The metes and bounds legal description of the
plat calls the eastern boundary 1267 feet, so the strip is ten
feet wide.
I believe there is also a gap between the north
adjoiner and the north boundary line of C. W. Wiedlers of
approximately sixteen feet. A surveyor would need to verify
the gap exists. There could possibly be twenty-six feet
of useable land, ten feet of which is already a platted right
of way.
We also found some evidence in an old book of plats that, at
one time, there was believed to be a thirty foot street that
appears to be an extension of 7th Street along the north
boundary of Lots 60 and 61.
I hope this information helps and if there is anything else I
can assist with, please do not hesitate to let me know.
Sincerely,
Cathy Whiteley
/caw
encls.
JAMES A. KNAUER
JOHN J. PETR
JAMES G. LAUCK
GARY A. SCHIFFLI
JAY P. KENNEDY
BRIAN C. BOSMA
WILLIAM C POTTER; II
GREGORY P. CAFOUROS
MARCIA ROAN
MADALYN S. KINSEY
WILLIAM BOCK, III
MARY E. BROWNS
MARK J. COLUCCI
ELIZABETH A. HUGHES
OfCoup,ci
JOHN E. GARDIS
MICHAEL J. HEBENSTREIT '
STEVEN R. SCHAFER
Retired .
R. M. KROGER
W B 11AM J. REGAS
August 14, 1998
Craig A. Carpenter
Office of the City Attorney
City of Carmel
One Civic Square
Carmel, Indiana 46032
FOUNDED 1937
Re: 7th Street Site
IDEM No Objection Letter
Dear Doug:
Pursuant to our telephone conversation of several months ago, we have conducted
several meetings with regulatory officials of the Indiana Department of Environmental
Management ("IDEM") regarding the receipt of a "no objection" letter for the fill site
located on Seventh Street in the City of Carmel. As your office is aware from our
August 14, 1997 correspondence (a copy of which is enclosed) the closure regulations
for this type of facilityare complex and potentially expensive. However, based on a
representation that only construction fill is contained at this site, and the commitment
that all fill materials will be covered with at least two feet of soil and that seeding of
the soil will occur, the IDEM has issued the enclosed "no objection" letter regarding
these activities to be performed by the City:.
In a nutshell, the vast majority of the site is most likely already covered by two feet
of clean soil, but city personnel should. investigate the site and be sure that all
construction materials are adequately covered." In addition, grass or. other
appropriate vegetation should be planted at this site to protect against erosion
and to meet the requirements of the IDEM letter. If these items are accomplished, the
City may produce the no objectionletter in the'event the IDEM or some other party
objects to the existence of the site or claims the more .detailed closure regulations
apply.
If the site is to be transferred in the future, I would ask that you refer to our August 14,
1997 letter for a proposed deed acknowledgment to • be included in the transfer.
Instead of the term "No Action". contained in the fifth line of the indented deed
paragraph, the phrase "No Objection" should be inserted. If you have any questions
in this regard, please be sure to let me know.
111 MONUMENT CIRCLE, SUITE 900
INDIANAPOLIS, INDIANA 46204-5175
(317) 6929000 FAX (317) 264-6832 -.
Page 2
August 14, 1998
It has been a pleasure to be of assistance to the City of Carmel on this matter, and if
you have any questions, or if we can be of assistance in any other way, I hope you will
let me know.
BCB/ak
Enclosures
Very, truly yours,
GER, GARDIS & REGA
IDEM
nwue o1ngnm OF EkYIIOmnu uYm WIO'
FnrnkCBannon
Govemor
John M. Hamilton
Commissioner
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We make Indiana a cleaner, healthier place to live
Mr. Gregory P. Cafouros
Kroger, Gardis & Regas
111 Monument Circle, Suite 900
Indianapolis, Indiana 46204-5175
Dear Mr. Cafouros:
July 8, 1998
100 North Senate Avenue
P.O. Box 6015
Indianapolis. Indiana 46206-6015
(317)232-8603
(800) 451-6027
www.ai.org/idem
RE: Closure of Construction Debris Site
City of Carmel
Hamilton County
This correspondence is in response to your letter dated June 5, 1998, regarding the above
referenced subject. The city of Carmel is proposing to close an old site, filled with what you have
described as basically unregulated materials, by covering the material with at least 2 feet of soil,
followed with top soil and then seeding to protect the cover. Based on the information provided
in your letter, this office has no objection to this approach.
Recycled Pup
If you have any additional questions concerning this matter, please contact Mr. Robert
Snodgrass at 317/233-6539.
Sincerely,
c&tt2 Ga
Bruce Palin
Assistant Commissioner
Office of Solid and Hazardous Waste Management
rds
cc: Hamilton County Health Department
Hamilton County Solid Waste Management District
An Equal Opportuniry Employer Plmu Renck C.)
JAMES A KNAUER
JOHN J. PETR
JAMES G. LAUCK
GARY A. SCHIFFLI
JAY P. KENNEDY
BRIAN C. BOSMA _
WILLIAM C. POTTER. II
GREGORY P. CAFOUROS
MARCIA ROAN
MADALYN 5. K NSEY
WILLIAM BOCK, III
MARY E. BROWNE
MARK J. COLUCCI
ELIZABETH A. HUGHES
Of Counsel
JOHN E. GARDIS
MICHAEL J. HEBENSTREIT
STEVEN R. SCHAFER
Re,ired
R. M. KROGER
WILLIAM J. REGAS
KROGER
4
((\t�� ARDIS,_
\1 REGAS
ATTORNEYS AT LAW.
FOUNDED 1937
June 5, 1998
Mr. Bruce Palin
Solid Waste Management Branch
Indiana Department of Environmental Management
Indiana Government Center North
100 North Senate Avenue
Indianapolis, Indiana 46204
RE: Closure of Construction Debris Site
City of Carmel
Dear Bruce:
As we have discussed in the past, the City of Carmel has operated a fill site at Seventh
Street, between Rangeline Road and U.S. 431, for an undetermined period of time,
commencing prior to 1975 through approximately 1990. The site was used primarily
for general construction debris and dirt, including uncontaminated concrete, asphalt,
brick, and block. The site is approximately 150 feet wide and 200 feet in length, and
approximately 15 feet deep.
We have interviewed those who have historically been involved with the activity at this
site and they indicate that no batteries, solvents, drums, old paint cans, liquid waste,
or other suspected hazardous materials were included in any fill material delivered to
the site, to their knowledge, at any time. We have checked the records at the Hamilton
County Health Department and IDEM and have uncovered no records relating to this
facility.
The City proposes to grade and cover the fill material with at least 2 feet of soil to
cover any of the fill material. Top soil and seeding would then be applied to restrict
exposure of the material below.
! \1C'>:1 \TENT CIRCLE. Si. ITE 'C•C
INPLANAPOLLS, INNAN:\=(_;4.5i73
FA\.°I-)_.--e
Mr. Bruce Palin
June 5, 1998
Page Two
Based on these commitments, we are requesting a letter from you indicating your
concurrence in this approach, or at least the lack of any objections to this approach, for
an informal closing of the site. I believe IDEM has authority for this approach under
329 IAC 10-4-4, as an alternative method or means for closure.
I appreciate your consideration to this request and I would be glad to answer any
further questions you may have. The City would like to commence this activity
promptly in order to establish a good cover material this summer.
Best regards,
KROGER.GARDIS$c REGAS
Gregory P. C
GPC/pad
JAMES A. KNAUER
JOHN J. PETR
JAMES G. LAUCK
GARY A. SCHIFFLI
JAY P. KENNEDY
BRIAN C. BOSMA
WILLIAM C. POTTER, 11
STEVEN R. SCHAFER
GREGORY P. CAFOUROS
MARCIA ROAN
WILLIAM BOCK. III
MARY E. BROWNE
STEPHANIE L. WEDDLE
Of Counsel
JOHN E. GARDIS
MICHAEL J. HEBENSTREIT
Raked
R. M. KROGER
WILLIAM J. REGAS
tA,ATTORNEYS ATJLAW
FOUNDED 1937
August 14, 1997
CONFIDENTIAL
PROTECTED BY ATTORNEY-CLIENT
AND WORK PRODUCT PRIVILEGES
Debra M. Grisham
City Attorney
City of Carmel
One Civic Square
Carmel, Indiana 46032
Re: 7th Street Site
Dear Deb:
Pursuant to your request and my discussions with Susan Hunter, our firm has looked
into the requirements for appropriately closing the 7th Street property formerly used
by the City of Carmel (the "City") as a site for the disposal of certain debris as
discussed further below (hereafter the "Site"). This letter will briefly detail our
findings and recommendations based on the expressed desire by the City to put the
Site to use, either through conversion to usable city property (such as a park), or
through sale to a third party.
SITE BACKGROUND
Based on my July 8 discussions with Bob Allen with the City Engineer's Office, the
Site was utilized from some undetermined period of time prior to 1975 through
approximately 1990 to dispose of certain materials by the City. Mr. Allen had
personal knowledge of the Site's use throughout most of this period, and indicated he
and one other City employee leveled out the piles of materials accumulating at the Site
with a bulldozer once or twice a year throughout the vast majority of this period.
In addition to uncontaminated dirt, Mr. Allen indicated that the fill placed at this Site
was primarily general construction debris including concrete, asphalt, brick, block, and
similar construction materials. Although Mr. Allen could not cite any specific
instances, he said it was also likely that railroad ties and metal objects such as pipe
or conduit had been disposed of at the Site, but he was absolutely certain that no
contaminated or potentially contaminated materials such as batteries, solvents, old
III
MONUMENT CIRCLE, SUITE 900
INDIANAPOLIS, INDIANA 46204-5175
(317) 692-9000 FAX (317) 264-6832
Page 2
August 14, 1997
drums or paint cans, liquid waste, asbestos materials, or any other suspected hazardous
materials had been disposed of at the Site. Mr. Allen, Susan and I walked over the
Site on July 5, and broken concrete, brick and other similar debris were visible in
some places. The Site was well vegetated and we saw no evidence of casual dumping
activities other than those historically conducted at the Site by the City.
After obtaining a legal description of the Site from Susan Hunter, we contacted the
Indiana Department of Environmental Management ("IDEM"), the Hamilton County
Health Department, and the Indiana State Board of Health, and each of these agencies
indicated that there had been no open dumping complaints or citations filed in the past
in the general vicinity of the Site. In addition, no records were discovered indicating
that the Site had been permitted or registered at any time in the past. Of course, all of
these contacts were made without revealing the purpose or source of the inquiry, or
the exact location of the Site.
APPLICABLE REGULATIONS
IDEM's Construction/Demolition Site Rules (329 IAC 10-2-37, 10-9-3, and 10-32
through 10-38) (copies attached) define the different types of waste and the closure
and post -closure requirements for the Site. Uncontaminated rocks, bricks, concrete,
road demolition waste materials, and dirt constitute unregulated waste and disposal of
these materials is not subject to any restrictions as provided for in 329 IAC 12-3-1.
Consequently, if we can verify that these materials above are present at the Site, no
formal closure requirements are required, and the Site may be used or sold without
further regulatory involvement.
However, the presence of railroad ties and other wood materials or metal objects such
as pipe or conduit likely cause the Site to fall into the construction/demolition site
category. Construction/demolition waste includes waste resulting from the
construction, remodeling, repair or demolition of structures, including virtually
anything built by man. These wastes can include scrap lumber, wallboard, roofing,
plumbing fixtures, wiring and non -asbestos insulation as provided for in 329 IAC 10-
2-37. If any of these materials are present at the Site, closure of the Site falls under
IDEM relations.
Generally, a construction/demolition site closure requires a written closure plan
certified by a registered professional engineer and a final cover of two feet of material,
Page 3
August 14, 1997
sufficient to prevent settlement and exposure of the solid waste in the future. The
cover material does not need to be clay if it can be demonstrated that an alternate
cover or site design will provide an adequate level of environmental protection. A
closure certification must be filed, signed by both the owner and a registered P.E. as
required by 329 IAC 10-37. After closure, the owner must inspect and file a written
report twice a year with IDEM, meet certain financial responsibility requirements and
undertake other activities for a period of thirty years. Notwithstanding these
applicable requirements, we believe there may be a less onerous alternative available
for closure of the Site.
Considering the nature of the Site and the uncertainty that some of the regulated
construction debris (wood and metal materials) is present, we believe this Site could
be favorably viewed by IDEM for treatment under 329 IAC 10-4-4. This subsection,
which applies to "open dumping", provides the Commissioner of the IDEM the
latitude to avoid the more detailed closure requirements, testing and financial
responsibility requirements outlined above if "other methods or means for closure as
approved by the Commissioner" can be used. We have been involved in the closure
of a similar Site in Pendleton, Indiana in which this subsection was utilized to greatly
reduce the costs involved for closure.
If this subsection can be utilized, the IDEM would issue a "no objection letter" to an
informal closing of the Site, which would avoid the costs of a full-blown closure and
the thirty (30) year maintenance plan. The appropriate procedure would be for our
firm to draft a letter giving a brief history of the Site (similar the one set forth above)
and the type and thickness of the cover material the City proposes to use to cover this
Site. A clay cap is not necessary, and a soil cover of two or more feet over the debris
would probably be approved by the IDEM. A portion of the required cover may
already be present over much of the Site, and the City can likely use dean fill from
one of its own future or current projects to supplement the cover where necessary.
The IDEM could possibly ask for some minimal soil backup to confirm that
significant construction/demolition debris is not present and would also require
seeding of the Site to restrict exposure of the material below. I would presume much
of this work (other than any sampling) could be performed by City workers.
We have discussed this approach (of course, without mentioning the location of the
Site or of its ownership) with Bruce Palin, IDEM's Acting Assistant Commissioner for
Solid and Hazardous Waste, who has indicated that our suggested approach appears
Page 4
August 14, 1997
to be feasible. All that remains to be done is to decide what type of cover material will
be used (such as clean fill dirt) and at what depth (one to two feet). Once this decision
is made (but before any action is taken), we would forward our letter to IDEM making
the proposal and hopefully receiving a "no objection letter" back from them in return.
At that point, the IDEM may ask for soil boring results to be submitted, but it is our
hope that they will not make this request. After a "no objection letter" is received, the
City should undertake the proposed covering activity and we should document both
of our files in this regard for the future. A follow-up letter to the IDEM upon
completion of the work would also be appropriate.
ADDITIONAL ACTIONS
In addition to the foregoing, in the event the City determines that it will be selling this
property to a third party at any time in the future, it may be advisable to include an
acknowledgment in any deed of transfer, acknowledging the fill and closure (if closure
is required), and releasing the City from any claims of the transferee or successors in
interest in form similar to the following:
The surface of the Real Estate transferred herein has been brought to
its current level by the placement on the Real Estate of fill which to the
best knowledge of the Transferor is clean, non -hazardous and
unregulated. [Optional: Closure of the Real Estate was performed
pursuant to a "No Action" letter issued by the Indiana Department of
Environmental Management dated .] Transferor makes
no warranty regarding the suitability of the Real Estate for any
particular use, and Transferee has undertaken it own investigation and
made its own determination regarding the suitability of the Real Estate
for the Transferee's purpose, and releases Transferor from any
obligation or liability related to the matters set forth herein. This
representation, statement and covenant shall run with the Real Estate
and shall be binding upon the Transferee and its successors -in -interest
and all future owners of the Real Estate.
In addition, any contract for sale of this property should contain appropriate releases
of the City from any liability or obligation related in any way to the condition of the
Site. While this approach no doubt presents an overabundance of caution, my concern
here is that any Purchaser be notified of the previous use of the Site, and that they do
Page 5
August 14, 1997
their own structural testing if they are going to place a house or other structure on the
Site. If constructed appropriately, the above release should run with the land and
release the City from any future liability to the Transferee and future title holders to
this piece of property.
With respect to use of the Site as a park, so long as the obvious surface hazards
(concrete, bricks, etc.) are addressed there appears to be no obligation to do anything
additional to the Site other than to take those closure steps outlined above.
I look forward to hearing from you regarding your thoughts on this matter and on any
other matter in which we can be of service to you and to the City of Carmel.
Personal regards,
KROGER, GARDIS & REGAS
Brian C. Bosma
BCB/db
cc: Susan Hunter
Enclosures
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This Indenture Witnesseth, That Bert T Hoover and Ella D Hoover, his wife
Hamilton
of County and State of Indiana
CONVEY AND WARRANT to Shubal E. White
of Hamilton County in the State of
for the sun of Two Hundred Dollars
the receipt of which is hereby acknowledged, the following REAL ESTATE, in Hamilton
County, in the State of Indiana, to -wit:
Lot number i xksidxsxxsixty one (61) in C.,W.,Weidler's
subdivision of a part of section thirty,Township Eighteen,
North, Range Four east
Indiana
Subjeot to current taxes,of 1926 payable in 1927,j
In Witness Whereof, The said .
Bert T. Hoover and Ella D. Hoover, his wife
ha !I' hereunto set their hand $ and seal this 19th day
of___ _Auguet...-192.6
STATE OF INDIANA
rV` County
Personally appeared before me
ss:
.6t&: in and for said County, and State
Lt.
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who acknowledged the execution of the annexed Deed to be voluntary act
and deed.
Witness my hand and
of ' /lr�s_ #/ 192'
My Commission Expires /7974
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the receipt of which is hereby acknowledged, the following R' A ESTATE, in
County in the State of Indiana, to -wit •
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In Witness Whereof, The said
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STATE OF INDIANA
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Hamilton County
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Personally appeared before me Bailey Haskins
a notary publics in and for said County, and State Bert T. HoQve. and
Ella D. Hoover,his wife
who acknowledged the execution of the annexed Deed to be their voluntary act
and deed.
notarial 19th day
Witness my hand and Seal, this
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