HomeMy WebLinkAboutNC0006254_Draft Permit_20200325ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. David Hallock, General Manager
Blue Ridge Tissue Corporation
1427 Yadkin River Road
Lenoir, NC 28645
Dear Mr. Hallock:
NORTH CAROLINA
Environmental Quality
March 25, 2020
Subject: Draft NPDES Permit NC0006254
Patterson Mill
Grade 2 Biological WPCS
Caldwell County
The Division has reviewed your request to renew the subject permit. Please review this draft carefully
to ensure your thorough understanding of the information, conditions, and requirements it contains.
The draft permit includes the following significant changes from the existing permit:
1. Language has been updated in Sections A. (1), A. (2), and A. (5) to require electronic submission
of effluent data. Federal regulations require electronic submittal of all discharge monitoring
reports (DMRs).
2. Outfall map has been updated.
3. Regulatory citations have been added.
4. Facility address has been updated on the Cover Sheet based on the permit renewal application.
5. Permit expiration date has been updated to match the proper subbasin. The permit is being short
cycled due to this.
6. Components list on the Supplement to Permit Cover Sheet has been updated based on the
renewal application.
7. Receiving stream characteristics on the Supplement to Permit Cover Sheet has been updated.
8. The facility grade has been added in Section A. (1).
9. Parameter codes have been added in Section A. (1).
10. Toxicity language in Section A. (3) has been updated.
11. Groundwater monitoring special condition has been added as Section A. (6).
With this notification, the Division will solicit public comment on this draft permit by publishing a
notice in newspapers having circulation in the general Caldwell County area, per EPA requirements.
Please provide your comments, if any, to me no later than 30 days after receiving this draft
permit.
Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft, please
contact me at 919-707-3619, or via e-mail [Brianna.Young@ncdenr.gov].
D E Ql� North Carolina Department of Environmental Quality I Division of Water Resources
5 _ 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
o.P.rtm.ocofE,,im m-tal0-ri /� 919.707.9000
Sincerely,
Brianna Young
Compliance and Expedited Permitting Unit
cc: NPDES Files
Asheville Regional Office
Wastewater Operator Certification Group
WSS/Aquatic Toxicity Branch
Permit NC0006254
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
N( PDES)
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Blue Ridge Tissue Corporation
is hereby authorized to discharge wastewater from a facility located at
Patterson Mill
1427 Yadkin River Road
Lenoir
Caldwell County
to receiving waters designated as the Yadkin River in the Yadkin -Pee Dee River Basin in accordance
with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and
IV hereof
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on October 31, 2023.
Signed this day
S. Daniel Smith
Director, Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 13
Permit NC0006254
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein
Blue Ridge Tissue Corporation
is hereby authorized to:
1. Continue to operate an existing 0.45 MGD process wastewater treatment facility with a discharge
mixed with boiler blowdown to Outfall 001, and consisting of the following treatment components:
• Two (2) filter trap basins
• One (1) aeration basin with surface aerators
• One (1) sedimentation basin
• Effluent flume with continuous flow meter
• Effluent composite sampler
• One (1) surplus aeration basin
This facility is located at Blue Ridge Tissue Corporation, 1427 Yadkin River Road, Lenoir,
Caldwell County.
2. Continue to discharge water filter backwash and stormwater wastewater from Outfall 002.
3. Discharge from said treatment works at the location specified on the attached map into the Yadkin
River, a waterbody currently classified C; Trout [Stream Index: 12-(1)] in subbasin 03-07-01 [HUC:
030401010102] in the Yadkin -Pee Dee River Basin.
Page 2 of 13
Permit NC0006254
PART I.
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - OUTFALL 001
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade II Biological WPCS [15A NCAC 08G .0302]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from Outfall 001 [process water]. Such discharges shall be limited
and monitored' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING
REQUIREMENTS
Monthly
Daily
Measurement
Sample
Sample
Parameter Code
Average
Maximum
Frequency
Type
Location 2
Flow 50050
0.450 MGD
Weekly
Continuous
Effluent
BOD, 5 day, 20°C C0310
63.
701.4
Weekly
Composite
Effluent
you da
ndsTotal
pounds da
Suspended Solids C0530
471.0 ounds da
o 873. da
Weekly
Composite
Effluent
pH 00400
Between 6.0 s.u. — 9.0 s.u.
Weekly
Grab
Effluent
Temperature (°C) 3 00010
Weekly
Grab
Effluent
U & D
Total Mercury n /L Method 1631E
Annually
Grab
Effluent
Chronic Toxicit 4 TGP38
I
Quarterly
I Composite
1 Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see Section A. (7)].
2. D = 100 ft downstream from discharge Outfall 001. U = 25 ft upstream from discharge Outfall 001, between
Outfalls 001 and 002.
3. The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving
stream of more than 0.5°C and in no case cause the ambient water temperature to exceed 20°C.
4. Chronic Toxicity (Ceriodaphnia dubia) P/F at 8% during the months of March, June, September, and
December [see Section A. (3)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.
See Special Condition A. (4) BIOCIDE NOTIFICATION AND APPROVAL for details related to
biocide use.
Page 3 of 13
Permit NC0006254
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - OUTFALL 002
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade II Biological WPCS [15A NCAC 08G .0302]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge from Outfall 002 [filter backwash]. Such discharges shall be limited and
monitored' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
Parameter Code
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow MGD 50050
Monthly
Instantaneous 2
Effluent
Total Suspended Solids C0530
30 m /L
45 m /L
2/Month
Grab
Effluent
H 00400
Between 6.0 sm. — 9.0 s.u.
2/Month
Grab
Effluent
Turbidity NTU 00070
Monthly
Grab
Effluent
Total Iron m /L 010451
1 Quarterly
I Grab
I Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see Section A. (7)].
2. For instantaneous monitoring, the discharge duration along with total flow must be reported.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 4 of 13
Permit NC0006254
A. (3) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 8.0 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised December 2010) or subsequent versions. The tests will be performed during the months of
March, June, September, and December. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-
3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Page 5 of 13
Permit NC0006254
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
A. (4) BIOCIDE NOTIFICATION AND APPROVAL
[G.S. 143-215, 143-215.1]
a. Per 40 CFR 403.104 Subpart J, the Permittee must submit a statement in conjunction with the next
permit renewal that neither pentachlorophenol nor trichlorophenol biocides are being used by the
facility.
b. The Permittee shall use no biocide(s) other than approved by the Division for this specific
discharge. Should the Permittee intend to use a new biocide, an application for approval must be
submitted to the Division no later than 90 days prior to its intended first use. The Permittee's
application shall include both, 1) an accurately completed Biocide Form 101, and 2) a Material
Safety Data Sheet (MSDS) for each proposed biocide. Send biocide approval requests to:
NCDENR / WSS / Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
A. (5) NUTRIENT REOPENER FOR HIGH ROCK LAKE
[G. S. 143-215.1(b)]
This permit may be reopened and modified to implement nutrient requirements in accordance with any
future TMDL and/or nutrient management strategy for High Rock Lake.
A. (6) GROUNDWATER MONITORING REQUIREMENTS
1. Sampling Requirements:
Existing monitoring wells shall be sampled every March, July, and November. Detailed
sampling requirements are listed in the table below.
Page 6 of 13
Permit NC0006254
Groundwater
Well Location
Groundwater Characteristics
Monitoring Requirements
Monitoring
Wells
Latitude
Longitude
eDMR
Code
Parameter
Frequency
Sample
Type
MW-1
36.001173
-81.563835
00610
Ammonia, Total as NH3-N
March,
July
November
Grab
01002
Arsenic, Total as As
Grab
MW-2
35.999414
-81.565503
01007
Barium, Total as Ba
Grab
01034
Chromium, Total as Cr
Grab
MW-3
36.000065
-81.565029
01045
Iron, Total as Fe
Grab
01051
Lead, Total as Pb
Grab
MW-4
36.000214
-81.563068
01055
Manganese, Total as Mn
Grab
00620
Nitrate, Total as NO3-N
Grab
MW-6
35.999612
-81.567362
00615
Nitrite, Total as NO2-N
Grab
00400
pH
Grab
MW-7
35.998910
-81.565343
00625
Nitrogen, Total Keldahl as N
Grab
00945
Sulfate as SO4
Grab
MW-8
35.999486
-81.563700
85280
Water level from surface
Calculated
78732
Volatile Compounds (GS/MS)
Ammally
Grab
Footnotes
1. The measurement of water levels shall be made prior to purging the wells. The depth to water in
each well shall be measured from the surveyed point on the top of the casing. The measurement
of pH shall be made after purging and prior to sampling for the remaining parameters.
2. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide
the relative elevation of the measuring point for each monitoring well. The measuring points (top
of casing) of all monitoring wells shall be surveyed relative to a common datum.
3. Annual sampling for volatile organic compounds shall be conducted in the month of November
exclusively. Volatile organic compounds (VOCs) shall be analyzed for the following methods:
i. Standard Method 6200C (PQL at 0.5 µg/L or less),
ii. Standard Method 6200B (PQL at 0.5 µg/L or less),
iii. EPA Method 8021 (Low Concentration, PQL at 0.5 µg/L or less),
iv. EPA Method 8260 (Low Concentration, PQL at 0.5 µg/L or less), or
v. Another method with prior approval by the Water Quality Regional Office Section Chief.
Any of the referenced methods used for VOCs shall, at a minimum, include all of the
constituents listed in Table 6200: I of Standard Method 6200. Any method shall provide a PQL
at 0.5 µg/L or less, which shall be supported by laboratory proficiency studies required by the
Division's Laboratory Certification Unit. Any constituents detected above the MDL, but below
the PQL at 0.5 µg/L, shall be qualified (i.e., estimated) and reported.
4. Any laboratory selected to analyze parameters shall be Division -certified for those parameters
required.
2. Site Mapping Requirements:
The Permittee shall submit two original copies of a site map 90 days from the effective date of
the permit with a scale no greater than 1-inch equals 100 feet. At a minimum, the map shall
include the following information:
Page 7 of 13
Permit NC0006254
a. The waste boundaries for the for the fiber traps and the major components of the waste
treatment system.
b. The location of all property boundaries.
c. The location and identity of each existing monitoring well, new monitoring wells, and any
surface water monitoring locations associated with the fiber traps and the wastewater
treatment system.
d. Labels for each monitoring well site will include the following:
i. Elevation of the top of the well casing (i.e., measuring point) relative to a common datum,
ii. Depth of the water below measuring point at the time measuring point is established, and
iii. Well depth from the land surface.
e. One contiguous waste and compliance boundary associated with the fiber traps and the major
components of the waste treatment system. The compliance boundary, based on the
origination date of the permit, is defined as 500 feet from the waste boundary or at the
property boundary, whichever is closer to the source.
f. All NPDES outfalls associated with the fiber traps and the wastewater treatment system.
g. The date the map is prepared and/or revised.
h. The prepared maps shall be submitted to:
Attention: NC Division of Water Resources
Asheville Regional Office
2090 US 70 Highway
Swannanoa, North Carolina 28778
i. Updated blank forms may be downloaded from the website below or requested from the
address listed above.
https:Hdeq.nc. gov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/non-discharge-permittin -ug nit/reportin -fg orms
3. Low -Flow Sampling Requirements
The permittee is required to implement a low -flow sampling technique to ensure the turbidity
concentrations are less than 10 NTU's at the time groundwater samples are collected. Low -flow
sampling utilizes an adjustable rate pump (e.g. peristaltic pump) with typical flow rates of 0.03 —
0.13 gallons per minute (GPM). Water level, field parameters (e.g. temperature, pH, specific
conductivity, dissolved oxygen, & oxidation reduction potential), and turbidity are all measured
simultaneously. A groundwater sample is typically collected after the field parameters and water
level have stabilized and the turbidity concentration is below 10 NTU's.
4. Reporting/Documentation Requirements
a. The results of the sampling and analysis shall be received on the most recent version of
Groundwater Quality Monitoring: Compliance Report Forms (i.e. GW-59 & GW-59a Form)
with copies of the laboratory analyses to the Division on or before the last working day of the
month following the sampling month.
Page 8 of 13
Permit NC0006254
b. All reports, maps, and other documents required in the "Groundwater Requirements" section
of this permit, unless otherwise directed, shall be mailed to the following address:
Attention: NCDEQ — DWR
Information Processing Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
c. Updated blank forms may be downloaded from the website below or requested from the
address listed above.
https:Hdeq.nc. gov/about/divisions/water-resources/water-resources-
permits/wastewaterbranch/non-discharge-permittin -ug nit/reportin -fg orms
5. Applicable Boundary Requirements
The Compliance boundary is specified by regulations in 15A NCAC 02L .0107(a). For disposal
systems individually permitted prior to December 30, 1983, the compliance boundary is
established at a horizontal distance of 500 feet from the waste boundary or at the property
boundary, whichever is closer to the source. An exceedance of Groundwater Quality Standards at
or beyond the Compliance Boundary is subject to corrective action according to 15A NCAC 02L
.0106(c).
Page 9 of 13
Permit NC0006254
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Page 10 of 13
Permit NC0006254
A. (7) ELECTRONIC REPORTING OF MONITORING REPORTS
[NCGS 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December
21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)I
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring
data and submit DMRs electronically using the internet. Until such time that the state's eDMR
application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR),
permittees will be required to submit all discharge monitoring data to the state electronically using
eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one
signed original and a copy of the computer printed eDMR to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband access,
then a temporary waiver from the NPDES electronic reporting requirements may be granted and
discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms
approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See
"How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Page 11 of 13
Permit NC0006254
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the initial
recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for
receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each
type of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: https://www.federalregister.aov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver
shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be
submitted electronically to the Division unless the permittee re -applies for and is granted a new
temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may submit monitoring data
and reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on the
following web page:
h!Ltp:Hdeq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section
B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting
purposes.
Page 12 of 13
Permit NC0006254
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account
and login credentials to access the eDMR system. For more information on North Carolina's eDMR
system, registering for eDMR and obtaining an eDMR user account, please visit the following web
page:
h!Ltp:Hdeq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"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 gather and evaluate 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
fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
This period may be extended by request of the Director at any time [40 CFR 122.41].
Page 13 of 13
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