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HomeMy WebLinkAboutNCGNE0020_COMPLETE FILE - HISTORICAL_20050427STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. NCGNE oba D DOC TYPE O HISTORICAL FILE DOC DATE ❑ _ �VVS GPI a YYYYMMDD STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. /V DOC TYPE ❑ HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ YYYYM M DD Brooks A Agnew Cataler North America Corp 2002 Cataler Dr Lincolnton, NC 28092 Dear Permittee: Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P. E. Director r � DEPT. Oi• oDrviston oriWa±ar Quality AND N.G5leen 11. Sullins,U c u6 �recsor P Y art} a Division of Va Quality :-AL OFiR10 April 20, 2006 APR 2 7 2005 S• WATER Subject: No Exposure Certification NCGNE0020 Cataler North America Corp - 2002 Cataler Dr Lincoln County The Division has reviewed your submittal of the No -Exposure Certification for Exclusion from NPDES Stormwater Permitting form, which we received on July 12, 2002. We apologize for the extended period it has taken us to get back to you on this request and we appreciate your patience as we have worked through this process. Based on your submittal and signed certification of no exposure at the above referenced facility the Division is granting your certification as provided for under 40 CFR 126.22(g) which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no exposure certification, you are obligated to maintain no exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no - exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your conditional no -exposure exclusion expires in five years (April 30, 2010). At that time you must re -certify with the Division, or obtain NPDES permit coverage for any stormwater discharges from your facility. Your certification of no exposure does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Jonathan Diggs at (919) 733-5083 ext. 537, or at jonathan.diggs@ncmail.net. Sincerely, for Alan W. Klimek, P.E. cc: Mooresville Regional Office Central Files -- wlattachments Stormwater Permitting Unit Files V.Xv Ni..DCllIR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-7015 Customer Service 1-877-623-6748 WA ]�Cn 9pG Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P. E. Director Division of Water Quality Coleen li. Sullins, Deputy Director Division of Water Quality April 20, 2005 Brooks A Agnew Cataler North America Corp 2002 Cataler Dr Lincolnton, NC 28092 Subject: No Exposure Certification NCGNE0020 Cataler North America Corp - 2002 Cataler Dr Lincoln County Dear Permittee: The Division has reviewed your submittal of the No -Exposure Certification for Exclusion from NPDES Stormwater Permitting form, which we received on July 12, 2002. We apologize for the extended period it has taken us to get back to you on this request and we appreciate your patience as we have worked through this process. Based on your submittal and signed certification of no exposure at the above referenced facility the Division is granting your certification as provided for under 40 CFR 12622(g) which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no exposure certification, you are obligated to maintain no exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no - exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your conditional no -exposure exclusion expires in five years (April 30, 2010). At that time you must re -certify with the Division, or obtain NPDES permit coverage for any stormwater discharges from your facility. Your certification of no exposure does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Jonathan Diggs at (919) 733-5083 ext. 537, or at jonathan.diggs@ncmail.net. Sincerely, for Alan W. Klimek, P.E. cc: Mooresville Regional Office _ Central Files — wlattachments Stormwater Permitting Unit Files N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 (919) 733-7015 NCDENR Customer Service 1-877-623-6748 C) WArFR r 0 - Y NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY WETLANDS AND STORMWATER BRANCH 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 FAX: 919-733-9612 PHONE: 919-733-5083 TELECOPY TO - FAX NUMBER- � Z V— cfZ � a2 -3 9-0 FROM: PHONE: 90- 1 � 3— 4�9 # OF PAGES INCLUDING THIS SHEET: x S(:n 2— COMMENTS: " - Qll�p aS_ r LAW RESOURCES CREATING SOLUTIONS Mr. Bradley Bennett Supervisor, Stormwater Quality Section NCDENR Division of Water Quality 1617 Mail Service Center ,- Raleigh, North Carolina •27699-1617 Q r� May 22, 2002 f I Subject: No Exposure Certification for Stormwater Cataler North America Corporation LAW Project No. 30100-1-0440 Dear Mr. Bennett: On behalf of Cataler North America Corporation (Cataler), Law Engineering and Environmental Services, Inc. (LAW) is submitting this No Exposure Certification for Exclusion from NPDES Storm Water Permitting. Cataler is a newly constructed manufacturing facility located at the Lincoln County Industrial Park in Lincolnton, North Carolina, Beginning in July 2002, the facility will manufacture catalytic substrate used for vehicle exhaust systems (SIC 3714). We understand that under the new Phase 11 regulations, all industrial categories are eligible for exclusion from storm water permitting if industrial activities and materials are protected by storm resistant shelter to prevent exposure from precipitation. LAW has reviewed each of the specific criteria for exclusion from storm water permitting, and the applicable processes at Cataler. Based on this review, we find that Cataler is eligible for the exemption. Please feel free to contact us at (704) 357-8600 if you have any questions concerning this No Exposure Certification. Sincerely, LAW ENGINEERING AND ENVIRONMENTAL SERVICES, INC. �, c j hristine K. 13renk, CHMM Principal Scientist Attachment: No Exposure Certification Form ;64&Aa- Bruce D. Reilly, P.E. Principal Engineer BY � WITH PERMISSION LAW Engineering and Environmental Services, Inc. 2801 Yorkmont Road, Suite 100 • Charlotte, NC 28208 704-357-8600 • Fax: 704-357-8638 Serving the Charlotte area for over 50 years United States Environmental Protection Agency Form Approved � y OMB No. 2040-021 t NPDES �� Washington, DC 20460 FORM NO EXPOSURE CERTIFICATION for Exclusion from 3510-11„A� NPDES Storm Water Permitting Submission of this No Exposure Certification constitutes notice that the entity identified in Section A does not require permit authorization for its storm water discharges associated with industrial activity in the State identified in Section B under EPA's Storm Water Multi -Sector General Permit due to the existence of a condition of no exposure. A condition of no exposure exists at an industrial facility when all industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Industrial materials or activities include, but are not limited to, material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. A storm resistant shelter is not required for the following industrial materials and activities: -- drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means banded or otherwise secured and without operational taps or valves; — adequately maintained vehicles used in material handling; and — final products, other than products that would be mobilized in storm water discharges (e.g., rock salt). A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting is available on a facility -wide basis only, not for individual outfalls. It any industrial activities or materials are or will be exposed to precipitation, the facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, the entity in Section A is certifying that a condition of no exposure exists at its facilityor site, and is obligated to comply with the terms and conditions of 40 CFR 122.26(g). ALL INFORMATION MUST BE PROVIDED ON THIS FORM. Detailed instructions for completing this form and obtaining the no exposure exclusion are provided on pages 3 and 4. A. Facility Operator Information 1. Name: [CIAITIAlLIE IRI INIDIRITIHI IAIMIEIRIIICIAI IC101RrI 1 1 1 2.Phone: 012 18 191710 1010 1 3. Mailing Address: a. Street: 12 10 1 012 1 1 C IA IT iA IL IE IR I ID I R I I I V I E I I I I i I I I I I I I I I I b. City. I 14IINI CIO IL IN) TI as NL _1 -I- 1 I i -1 _ 1 I_ I _ I _ I c. state: EJ d. Zip Code: 12 18 12 1 Q i� i =-L_I _- L I I B. Facility/Site Location Information 1. Facility Name: I G A' T L E R N O T H A C A C O R P 2. a. Street Address: 12 I fll 01 A I CIA IT I AI LI EI RI I D I RI II VI EI I I I I I I I I 1 I I I I b. City: I LI 11 NI Cl 01 LiN. I T10.IN I I I 1 1 I 1 1 1 1 1 1 1 1 c. County: I Li I IN iC 10 IL N d. State: �i CI e. Zip Code: 1 2 �,S 101 & 2 I — I I I I I 3. Is the facility located on Indian Lands? Yes ❑ No Q 4. Is this a Federal facility? Yes ❑ No Q 5. a. Latitude: 13, 51 0 13, 2 1 13 19 1' b. Longitude: LI sll I 11131 14 161 6. a. Was the facility or site previously covered under an NPDES storm water permit? Yes ❑ No 0 b. If yes, enter NPDES permit number: 7. SIC/Activity Codes: Primary: 1317,1141 Secondary (if applicable): I I I 11 8. Total size of site associated with industrial activity: 30 acres 9. a. Have you paved or roofed over a formerly exposed, pervious area in order to quality for the no exposure exclusion? Yes ❑ No X❑ b. If yes, please indicate approximately how much area was paved or roofed over. Completing this question does not disqualify you for the no exposure exclusion_ However, your permitting authority may use this information in considering whether storm water discharges from your site are likely to have an adverse impact on water quality, in which case you could be required to obtain permit coverage. Less than one acre ❑ One to five acres ❑ More than five acres M EPA Form 3510-11 (10-99) Page 1 of 4 FORM „EPA NO EXPOSURE CERTIFICATION for Exclusion from OMB nom2Nao211 3510-11 NPDES Storm Water Permitting C. Exposure Checklist Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No" in the appropriate box.) tf you answer "Yes" to any of these questions (1) through (11), you are not eligible for the no exposure exclusion. Yes No 1. Using, storing or cleaning industrial machinery or equipment, and areas where residuals from using, storing El L:flj or cleaning industrial machinery or equipment remain and are exposed to storm water 2. Materials or residuals on the ground or in storm water inlets from spills/leaks ❑ 0 3. Materials or products from past industrial activity 4. Material handling equipment (except adequately maintained vehicles) ❑ RX 5. Materials or products during loading/unloading or transporting activities L:fjl 6. Materials or products stored outdoors (except final products intended for outside use [e.g., new cars) where RX exposure to storm water does not result in the discharge of pollutants) 7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers �X 8. Materials or products handled/stored on roads or railways owned or maintained by the discharger ❑ Q 9. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ ❑X 10. Application or disposal of process wastewater (unless otherwise permitted) Q N 11. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated QX (i.e., under an air quality control permit) and evident in the storm water outflow D. Certification Statement I certify under penalty of law that t have read and understand the eligibility requirements for claiming a condition of "no exposure" and obtaining an exclusion from NPDES storm water permitting. I certify under penalty of law that there are no discharges of storm water contaminated by exposure to industrial activities or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)). I understand that I am obligated to submit a no exposure certification form once every five years to the NPDES permitting authority and, if requested, to the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where applicable). I understand that I must allow the NPDES permitting authority, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and"to make such inspection reports publicly available upon request. I understand that I must obtain coverage under an NPDES permit prior to any point source discharge of storm water from the facility. Additionally, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Print Name: 113, A0 O 1 K S 1 A! 19 I C 14 t E �✓ Print Title: I EIA I G I, IN If It 0- ► f`I G 1t1 R N A"' E 2 Signature: � A Date: 101610 rq 1011 EPA Form 3510-11 (10-99) Page 2 of 4 or EP,A Storm Water Phase II Final Rule Fact Sheet Series Overview 1.0 - Slorm Water Phase li Final Rule: An Overview Small MS4 Program 2.0 - Small MS4 Storm Water Program Overview 2.1 -Who's Covered? Desi nation and Waivers of Regulatedmall MS4s 2.2 -- Urbanized Areas: Definition and Description Minimum Control Measures 2.3 - Public Education and Outreach 2.4 - Public Participation/ Involvement 2.5 - Illicit Discharge Detection and Elimination 2.6 -- Construction Site Runoff Control 2.7 - Post -Construction Runoff Control 2.8 - Pollution Prevention/Good Housekeeping 2.9 Permitting and Reporting: The Process and Requirements 2.10 - Federal and State -Operated MS4s: Program Implementation Construction Program 3.0 - Construction Program Overview 3.1 - Construction Rainfall Erosivity Waiver Industrial "No Exposure" 4.0 - Conditional No Exposure Exclusion for Industrial Activity United States Office of Water EPA 833-F-00-015 Environmental Protection (4203) January 2000 Agency Fact Sheet 4.0 Storm Water Phase II Final Rule Conditional No Exposure Exclusion for Industrial Activity Why is the Phase I No Exposure Exclusion Addressed in the Phase I1 Final Rule? The 1990 storm water regulations for Phase 1 of the federal storm water program identify eleven categories of industrial activities that must obtain a National Pollutant Discharge Elimination System (NPDES ) permit. Operators of certain facilities within category eleven (xi), commonly referred to as "light industry," were exempted from the definition of "storm water discharge associated with industrial activity," and the subsequent requirement to obtain an NPDES permit, provided their industrial materials or activities were not "exposed" to storm water. This Phase I exemption from permitting was limited to those facilities identified in category (xi), and did not require category (xi) facility operators to submit any infonnation supporting their no exposure claim. In 1992, the Ninth Circuit court remanded to EPA for further rulemaking the no exposure exemption for light industry after making a determination that the exemption was arbitrary and capricious for two reasons. First, the court found that EPA had not established a record to support its assumption that light industrial activity that is not exposed to storm water (as opposed to all other regulated industrial activity not exposed) is not a "storm water discharge associated with industrial activity." Second, the court concluded that the exemption impermissibly relied on the unsubstantiated judgment of the light industrial facility operator to determine the applicability of the exemption. This fact sheet describes the revised conditional no exposure exclusion as presented in the Phase 11 Final Rule. Who is Eligible to Claim No Exposure? As revised in the Phase If Final Rule, the conditional no exposure exclusion applies to ALL industrial categories listed in the 1990 storm water regulations, except for construction activities disturbing 5 or more acres (category (x)). What Is The Regulatory Definition of "No Exposure"? The intent of the no exposure provision is to provide facilities with industrial materials and activities that are entirely sheltered from storm water a simplified way of complying with the storm water permitting provisions of the Clean Water Act (CWA). This includes facilities that are located within a larger office building, or facilities at which the only items permanently exposed to precipitation are roofs, parking lots, vegetated areas, and other non -industrial areas or activities. The Phase 11 regulatory definition of "no exposure" follows. eVo exposure means all industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Industrial materials or activities include, but are not limited to, material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Fact Sheet 4.0 — Conditional No Exposure Exclusion for Industrial Activity Page 2 A storm resistant shelter is not required for the following industrial materials and activities: ❑ Drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means banded or otherwise secured and without operational taps or valves.. ❑ Adequately maintained vehicles used in materials handling; and ❑ Final products, other than products that would be mobilized in storm water discharges (e.g., rock salt). The term "storm -resistant shelter," as used in the no exposure definition, includes completely roofed and walled buildings or structures, as well as structures with only a top cover but no side coverings, provided material under the structure is not otherwise subject to any run-on and subsequent runoff of storm water. While the intent of the no exposure provision is to promote a condition of permanent no exposure, EPA understands certain vehicles could become temporarily exposed to rain and snow while passing between buildings. Adequately maintained mobile equipment (e.g., trucks, automobiles, forklifts, trailers, or other such general purpose vehicles found at the industrial site that are not industrial machinery, and that are not leaking contaminants or are not otherwise a source of industrial pollutants) can be exposed to precipitation or runoff. Such activities alone would not prevent a facility from certifying to no exposure. Similarly, trucks or other vehicles awaiting maintenance at vehicle maintenance facilities that are not leaking contaminants or are not otherwise a source of industrial pollutants, are not considered "exposed." In addition, EPA recognizes that there are circumstances where permanent no exposure of industrial activities or materials is not possible and, therefore, under such conditions, materials and activities can be sheltered with temporary covers (e.g., tarps) between periods of penmanent enclosure. The no exposure provision does not specify every such situation, but NPDES pennitting authorities can address this issue on a case -by -cast basis. The Phase 11 Final Rule also addresses particulate matter emissions from roof stacks/vents that are regulated by, and in compliance with, other environmental protection programs (i.e., air quality control programs) and that do not cause storm water contamination are considered not exposed. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control program) and evident in storm water outflow are considered exposed. Likewise, visible "track out" (i.e., pollutants carried on the tires of vehicles) or windblown raw materials is considered exposed. Leaking pipes containing contaminants exposed to storm water are deemed exposed, as are past sources of storm water contamination that remain onsite. General refuse and trash, not of an industrial nature, is not considered exposed as long as the container is completely covered and nothing can drain out holes in the bottom, or is lost in loading onto a garbage truck. Industrial refuse and trash that is left uncovered, however, is considered exposed. What is Required Under the No Exposure Provision? The Phase 11 Final Rule represents a significant expansion in the scope of the original no exposure provision in terms of eligibility (as noted above) and responsibilities for facilities claiming the exclusion. Under the original no exposure provision, a light industry operator was expected to make an independent determination of whether there was "exposure" of industrial materials and activities to storm water and, if not, simply not submit a permit application. An operator seeking to qualify for the revised conditional no exposure exclusion, including light industry operators (i.e., category (xi) facilities), must: ❑ Submit written certification that the facility meets the definition of "no exposure" to the NPDES permitting authority once every 5 years. The Phase 11 Final Rule includes a four -page No Exposure Certification form that uses a series of yes/no questions to aid facility operators in determining whether they have a condition of no exposure. It also serves as the necessary certification of no exposure provided the operator is able to answer all the questions in the negative. EPA's Certifrcatron is for use only by operators of industrial activity located in areas where EPA is the NPDES permitting authority. • A copy of the Certification can be obtained from the U.S. EPA Office of Wastewater Management (OWM) web site, the Stomp Water Phase 11 Final Rule published in the Federal Register (Appendix 4), or by contacting OWM. ❑ Submit a copy, upon request, of the Certification to the municipality in which the facility is located. rJ Allow the NPDES permitting authority or, if discharging into a municipal separate storm sewer system, the operator of the system, to: ( l) inspect the facility; and (2) make such inspection reports publicly available upon request. Regulated industrial operators need to either apply for a permit or submit a no exposure certification form in order to be in compliance with the NPDES storm water regulations. Any permit held becomes null and void once a certification form is submitted. =r Fact Sheet 4.0 — Conditional No Exposure Exclusion for Industrial Activity Page 3 Even when an industrial operator certifies to no exposure, the NPDES permitting authority still retains the authority to require the operator to apply for an individual or general permit if the NPDES permitting authority has determined that the discharge is contributing to the violation of, or interfering with the attainment or maintenance of, %eater quality standards, including designated uses. Are There Any Concerns Related to Water Quality Standards? Yes. An operator certifying that its facility qualifies for the conditional no exposure exclusion may, nonetheless, be required by the NPDES permitting authority to obtain permit authorization. Such a requirement would follow the permitting authority's determination that the discharge causes, has a reasonable potential to cause, or contributes to a violation of an applicable water quality standard, including designated uses. Designated uses can include use as a drinking water supply or for recreational purposes. Many efforts to achieve no exposure can employ simple good housekeeping and contaminant cleanup activities such as moving materials and activities indoors into existing buildings or structures. In limited cases, however, industrial operators may make major changes at a site to achieve no exposure. These efforts may include constructing a new building or cover to eliminate exposure or constructing structures to prevent run-on and storm water contact with industrial materials and activities. Major changes undertaken to achieve no exposure, however, can increase the impervious area of the site, such as when a building with a smooth roof is placed in a formerly vegetated area. Increased impervious area can lead to an increase in the volume and velocity of storm water runoff, which, in turn, can result in a higher concentration of pollutants in the discharge, since fewer pollutants are naturally filtered out. The concern of increased impervious area is addressed in one of the questions on the Certification form, which asks, "Have you paved or roofed over a formerly exposed, pervious area in order to qualify for the no exposure exclusion'? If yes, please indicate approximately how much area was paved or roofed over." This question has no affect on an operator's eligibility for the exclusion. It is intended only to aid the NPDES permitting authority in assessing the likelihood of such actions interfering with water quality standards. Where this is a concern, the facility operator and its NPDES permitting authority should take appropriate actions to ensure that water quality standards can be achieved. What Happens if the Condition of No Exposure Is Not Maintained? Under the Phase II Final Rule, the no exposure exclusion is conditional and not an outright exemption. Therefore, if there is a change in circumstances that causes exposure of industrial activities or materials to storm water, the operator is required to comply irrunediately with all the requirements of the NPDES Storm Water Program, including applying for and obtaining a permit. Failure to maintain the condition of no exposure or obtain coverage under an NPDES storm water permit can lead to the unauthorized discharge of pollutants to waters of the United States, resulting in penalties under the CWA. Where a facility operator determines that exposure is likely to occur in the future due to some anticipated change at the facility, the operator should submit an application and acquire storm water permit coverage prior to the exposed discharge to avoid such penalties. For Additional Information Contact uW U.S. EPA Office of Wastewater Management • Phone: (202) 564-9537 • E-mail: SW2@cpa.gov cpa.gov • Internet: www,epa.gov/npdes/stormwater cw Your NPDES Permitting Authority. (A list of names and phone numbers for each U.S. EPA Region is included in Fact Sheet 2.9. Additional contact names, addresses, and numbers for each State can be obtained from the U.S. EPA Office of Wastewater Management) Reference Doetanents i uW Storm Water Phase II Final Rule Fact Sheet Series • Internet: www.epa.gov/npdes/stonnwater then click on "Phase 11" Ow Storm Water Phase 11 Final Rule (64 FR 68722) • Internet: www.epa.gov/npdes/stortnwater then click on "Phase 11" • Contact the U.S. EPA Water Resource Center — Phone: 202 260-7786 — E-mail: center.water-resource@epa.gov