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HomeMy WebLinkAboutNC0026654_Fact Sheet_20200511DENR/DWQ EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NC0026654 2020 Renewal This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Facility and Stream Information Applicant/Facility Name: Town of Crossnore Crossnore WWTP Applicant Address: PO Box 129; Crossnore, NC 28616 Facility Address: Sloop Mill Dam Road off US Hwy. 221, Crossnore, NC Facility Class Permit Status: Grade II Biological WPCS Renewal Permitted Flow 0.070 MGD Type of Waste 100% Domestic Receiving Stream Mill Timber Creek Stream Class ID C-Tr 11-29-10 7Q10 Sum Win cfs 2.4 3.4 30Q2 cfs 4.6 Avg. Stream Flow cfs 15 IWC % 4.33 % Subbasin 03-08-30 USG S Too C11SW Newland, NC County Avery I Regional Office ARO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / February 25, 2020 Does permit need daily max NHs limits? Already included in existing permit - see below Does permit need TRC limits/language? Already included in existing permit Does permit have toxicity testing? No - NIs-N limits instead (1991 WLA) Does permit have Special Conditions? No Does permit have instream monitoring? None Stream on 303(d) List? For w arameter? No Any compliance concerns? See compliance discussion below Any modifications since lastpermit? I None noted in application New expiration date: I January 31, 2025 FACILITY OVERVIEW: This facility is 100% domestic waste. The design capacity of the treatment system is 0.070 MGD and consists of the following wastewater treatment components: • Influent and effluent composite sampler • Influent bar screen • Equalization tank • Anoxic tank • Aeration tanks • Clarifiers • Sludge holding tank • UV disinfection systems • 602 V-notch weir • Flow Meter • Backup Generator No modifications were noted or proposed in the current application. Most recent inspection (11/14/2017) was associated with a bypass in October 2017. The November inspection found that the facility was in compliance and the bypass occurred due to a restriction in the UV channel during a large rainfall event. The regional office commented during the draft permit review that the facility location should be more specific by indicating the location as Sloop Mill Dam Road off of US Hwy 221. This change was made in the final permit. COMPLIANCE: The permittee had one civil penalty assessment action since issuance of the 2015 permit with total assessed amount of $1,702.36 ($1,500 in penalties). This action was for a bypass from the UV channel in 2017. The permittee has also had an NOV and NOD during the permit term associated with reporting frequency violations for flow as well as an NOV and NOD associated with two bypass events. MONITORING DATA REVIEW: Flow - Avg. 0.027 MGD with a range of 0.001 to 0.214 MGD. Less than 5% of values equaled or exceeded the flow limit of 0.070 MGD and no monthly averages exceeded the limit. Highest monthly flow was 0.050 MGD. Average flow is at only 39% of permitted flow. Year Max Min Avg. No. 2015 0.093 0.001 0.02 273 2016 0.063 0.001 0.012 365 2017 0.079 0.002 0.022 365 2018 0.214 0.011 0.044 365 2019 1 0.153 1 0.009 1 0.034 1 365 Permit Term 1 0.214 1 0.001 1 0.027 1 1733 • BOD - overall average removal at around 96%. • TSS - overall average removal at around 91%. • Temperature - only monitor at effluent. Values range from 0 to 29 with average of 16. No apparent issue • Fecal - only 10 of 267 values over 200. Two were at very high levels 4300 and 6000 but did not result in BIMS limit violations. • Mercury - once per term monitoring. Reported value of 0.73 ng/L. • pH - values ranged from 6 to 8.4 • WET - not requirement in the permit, permittee accepted NH3-N limit instead (see 1991 waste load allocation). • NH3-N - values range from0 to 15.8 with average of 2.15 mg/L. No single value above the monthly (18) or weekly (35) limits. The permit has a summer but no winter limit. See section below given recent discussion about seasonal limits [rule 213.0404]. • Total N - 1.88 to 18.4 with average of 13.21 mg/L. Monitored semi-annually. • Total P - 0.1 to 3.08 with average of 1.06 mg/L. Monitored semi-annually. NH3-N MONITORING: Current Requirement: 2/Month monitoring in Current Permit. Has summer limits of 18 and 35mg/L (monthly and weekly averages) and monitoring with no limit in winter. Town of Crossnore WWTP Fact Sheet NPDES Renewal 2020 Page 2 The NH3-N limit was set in 1991 to address potential toxicity issues rather than require WET monitoring. Based on the mass balance waste load allocation results the limits were set for summer and monitoring only for winter. These results were verified with the current NH3 WLA spreadsheet. Recent review by Division staff has noted that 15A NCAC 2B .0404(c) requires that winter waste load allocations for oxygen consuming waste be no less stringent than 2 times the summer waste load limit. To meet this rule requirement winter limits for NH3-N are being added to the permit. A review of the monitoring data over the permit cycle indicates that no NH3-N value has exceeded 16 mg/L. In accordance with the rule and results from the mass balance review, the winter limit could be set by doubling the summer limit. However, the Division has historically set NH3-N limits no higher than 35 mg/L. Winter NH3-N limits for the permit will be set at 35 mg/L for both monthly and weekly average. REGIONAL OFFICE COMMENTS: The renewal application and previous permit noted BESST package plant under treatment components, but specific components are included in the permit supplement page in the draft. Regional Office staff (Daniel Boss) requested the addition of these specification components in the description. The draft permit language was updated using the specific modifications outlined in the facility's February 27, 2012 Authorization to Construct. PROPOSED PERMIT CHANGES: • Modified treatment components in the supplement sheet of the permit to outline specific components of the BESST treatment system. • Updated eDMR requirements • Added regulatory citations throughout permit • Updated parameter codes • Updated NH3-N effluent limits to set winter limits at 35 mg/L. • Final Permit also reflects plant location on Sloop Mill Dam Road. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: March 11, 2020 Permit Scheduled Effective Date: May 1, 2020 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at (919) 707-3629. Town of Crossnore WWTP Fact Sheet NPDES Renewal 2020 Page 3 AFFIDAVIT OF PUBLICATION Acct. Name: NORTH CAROLINA-AVERY COUNTY DEQ - DIVISION OF WA Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by the Acct. # 265236 law to administer oaths, personally appeared: COST OF PUBLICATION / la Total $35.89 L .v1 may hold a public hearing Who being first duly sworn, deposes and says: that he (she) is should there be a significant de- gree of public interest. Please REPRESENTATIVE mail comments and/or informa- tion requests to DWR at the above address. Interested per- of a newspaper known as THE AVERY JOURNAL, published, sons may visit the DWR at 512 issued and entered as second class mail in Town of Newland, NainformationStreet, nle,iC to review fin said County and State; that he (she) is authorized to make Additional information on this affidavit and sworn statement; that the notice of other legal NPDES permits and this notice advertisement, a true copy of which is attached hereto, was may be found on our website: published in THE AVERY JOURNAL the following htto://deo.nc.gov/about/divi- p g dates sions/water-resou rces/water-re- sources-oermits/wastewater- NC0022756 NC0026654 branch/nodes-wastewater/pub- 03�18�2020 lic-notices, or by calling (919) 707-3601. - The Town of Crossnore has re - Public Notice quested renewal of perinif North Carolina Environmental NCO026654 for its WWTP m Management Avery County; this facility dis- Commission/NPDES Unit charges treated domestic 1617 Mail Service Center Wastewater to Mill Timber Creek Raleigh, NC 27699-1617 in the Catawba River Basin. Notice of Intent to Issue a Linville Land Harbor PDA re- NPDES Wastewater Permit quested renewal of NPDES per- NC0026654 Crossnore WWTP mit NCO022756 for their WWTP and NCO022756 Linville Land in Avery County. Facility dis- Harbor WWTP charges to the Linville River/Catawba River Basin. The North Carolina Environ- Currently fecal coliform, ammo - mental Management Commis- nia nitrogen and total residual and that the said newspaper in which such notice, paper, sion r poses to as ue harga NPDESpermit chorine .are water quality limn -document or legal advertisement was published was, at the time to the person(s) listed - of each and every such publication, a newspaper meeting all of below. Written comments re- the requirements and qualifications of Section 1-597 of the gardinepte until 0 permit will be accepted until 30 days after General Statutes of North Carolina and was a qualified the publish date of this notice. newspaper within the meaning of Section 1-597 of the General The Director of the NC Division Statutes of North Carolina. of Water Resources (DWR) ,`�t111111t17� This 18th day of March, 2020 �% 014 M: 0, Q : OTA y' , Sworn to and subscribed before me, this CU EBth day of March, 2020 pUBL Ja�� �iy�rAti�Notary Public 3ACc1co.. m• 60-'4 My Commission Expires: /7. LL___ ---nL91 1 — . Bennett, Bradley From: exche <TownHal I@townofcrossnore.com> Sent: Friday, May 8, 2020 1:21 PM To: Bennett, Bradley Cc: 'eddie yarber' Subject: RE: [External] RE: Permit Documents for Crossnore WWTP - NCO026654 External emJk links or open attachments unless you verify. Send all suspicious email as an attachment t� report.spam@nc.gov Dear Mr. Bennett, I returned the application for 2020 permit to operate a community water system. I also wrote a check for $330.00 back on 09-23-19 with check # 9653. At that time Mayor Smith was still the mayor. Mr. Yarber was sworn in as of the first Tuesday in December. I also have a letter dated December 16, 2019 from Wren Thedford stating the NCDENR was in receipt of our permit renewal application and supporting documents. So I don't know if the draft permit that you sent to us in March is different from what I have or not. I just looked at the attached document that you enclosed in this email and found some things wrong on it. Where it says " legally responsible for permit", and it says owner affiliation is Jesse Smith, that should be David Edward "Eddie" Yarber, Mayor. Also, the work phone number is wrong. It should be 828-733-0360. Where it says Permit Billing Contact person is wrong. Edward T Vance was our old mayor, who passed away back in October ,2018. So I don't know if you want to put Eddie Yarber's name there or if you need to put my name in there since I am the clerk and I pay the bills. I think that is everything. Susie Potter, Town Clerk of Crossnore PO Box 129 Crossnore, NC 28616 828-733-0360 Fax 828-733-6393 From: Bennett, Bradley [mailto:bradley.bennett@ncdenr.gov] Sent: Friday, May 08, 2020 11:41 AM To: exche Subject: Re: [External] RE: Permit Documents for Crossnore WWTP - NCO026654 Ms. Potter, Thanks for getting in touch. I will touch base directly with Mr. Yarber. We did mail a draft permit back in early March when it went out to public notice. We also copied Jadd Brewer your consultant on the draft. If you would like me to forward a copy of that document in an email let me know. Our records still currently List Mr. Smith as the permit Owner in our database and it doesn't appear that we have received a request from the Town to update this. I have attached a contact list from our database. If you can let me know what changes need to be made to this we can make those adjustments in our records. You can mark up this document, scan it in and email it back to me or if you want you can send us a letter with needed changes. You can email me the letter if you would like. Thanks Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@ncdenr.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws From: exche <TownHaII@townofcrossnore.com> Sent: Friday, May 8, 2020 9:00 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov> Cc: 'eddie yarber' <eddieyarber84@gmail.com> Subject: [External] RE: Permit Documents for Crossnore WWTP - NC0026654 External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to �t.spam@nc.gov Dear Mr. Bennett, Mayor Smith is no longer the Mayor as of the November 2019 election. Our new mayor is David Edward "Eddie" Yarber. His personal email is eddieyarber84@gmail.com. This is the town's email. We have not received any documents yet from NCDENR. I hope this helps. Susie Potter, Town Clerk From: Bennett, Bradley [mailto:bradley.bennett@ncdenr.gov] Sent: Thursday, May 07, 2020 1:15 PM To: townhaII@townofcrossnore.com; jaddbrewer@rocketmail.com Subject: Permit Documents for Crossnore WWTP - NC0026654 Mayor Smith, The wastewater discharge permit renewal for the Crossnore WWTP was publicly noticed in early March. Division staff are now working to finalize the permit and get the renewal out to you and your staff. We wanted to contact you regarding transmittal of the final permit documents to you. In order to provide more convenience, control, and security to our permittees and assist them in processing their transactions, The Division of Water Resources is currently transitioning towards electronic correspondence. This will hopefully provide more efficient service to our permittees and other partners and will allow us to more effectively process and track documents. We are writing to ask you for your approval of the transmittal of documents related to your permitting and related activities with the Division in an electronic format. Documents will be emailed to the appropriate contact person(s) in your organization in a PDF format. Please respond to me through email with verification that transmittal of your documents in an electronic manner is acceptable to you. If you have any questions, please feel free to contact me. Currently I am working from home so the best contact method is through this email address. If you need to have a discussion, please email and we can set up a time for a call. Thank You 4/2/2020 Mail - Bennett, Bradley - Outlook RE: Crossnore Draft Permit - NCO026654 Boss, Daniel J <daniel.boss@ncdenr.gov> Mon 3/9/2020 10:26 AM To: Bennett, Bradley <bradley.bennett@ncdenr.gov>; Heim, Tim <Tim.Heim@ncdenr.gov> Cc: Wiggs, Linda <linda.wiggs@ncdenr.gov> Hi Bradley, The location of the plant can be more specific: The WWTP is on Sloop Mill Dam Rd off US Hwy 221. Everything else looks good to me. Thanks, Daniel Boss Environmental Specialist- Asheville Regional Office Water Quality Regional Operations Section NCDEQ- Division of Water Resources Office Phone: 828-296-4658 Email: daniel.boss@ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 From: Bennett, Bradley Sent: Monday, March 9, 2020 7:50 AM To: Boss, Daniel J <daniel.boss@ncdenr.gov>; Heim, Tim <Tim.Heim@ncdenr.gov> Cc: Wiggs, Linda <linda.wiggs@ncdenr.gov> Subject: Crossnore Draft Permit - NCO026654 Hey Guys, I have attached the draft permit for Crossnore. This one will be going to public notice hopefully later this week (but it could be next week). Take a look and let me know if you have any comments or concerns about the draft. The major changes are highlighted in the fact sheet. Dan — please look at the treatment system components on the supplement page. I used the last ATC to try and add in what I thought was needed to better describe the BESST treatment system. Let me know if I need to adjust this any. Also note the addition of NH3-N winter limits in the draft (explained in the Fact Sheet and cover letter). Thanks for your help on this one. We hope to be able to reissue this one at the end of April. -------------------------------------------------- Bradley Bennett Compliance and Expedited Permitting Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 -------------------- Phone: (919) 707-3629 email: bradley.bennett@ncdenr.gov https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E10DhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2 Town of Crossnore I Outfall 001 NCO026654 Freshwater RPA - 95% Probability/95% Confidence Using Metal Translators Qw - 0.07 MGD MAXIMUM DATA POINTS - 58 Qw (MGD) = 0.0700 1Q10S (cfs) = 2.01 7Q10S (cfs) = 2.40 7Q10W (cfs) = 3.40 30Q2 (cfs) = 4.60 Avg. Stream Flow, QA (cfs) = 15.00 Receiving Stream: Mill Timber Creek W WTP/WTP Class: 2 IWC% @ 1Q10S = 5.121548265 IWC% @ 7Q10S = 4.325294 IWC% @ 7Q10W = 3.092489668 IWC% @ 30Q2 = 2.304343209 IW%C @ QA= 0.718138796 Stream Class: C Tr COMBINED HARDNESS (mg/L) NO DATA NO DATA PARAMETER INC STANDARDS OR EPA CRITERIA F REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE � 0 z Applied Chronic Acute :3 n # Det. Max Pred Cw Allowable Cw Standard Acute: 331.93088 No RP, Predicted Max < 50 % of Allowable Cw - No Ammonia Nitorgen NC 1.9 FW(7Q10s) 17 mg/L 52 26 9.06290 ------------------------------------------------ Monitoring required Chronic: 43.92765 No RP, Predicted Max < 50 % of Allowable Cw - No No value > Allowable Cw Monitoring required Acute: 0 0 N/A —_ _ -Chronic: -- -------------------------- Acute: 0 0 N/A —_ _ -Chronic:---------- ------ ------------------- Acute: 0 0 N/A _ _ --Chronic:---------- -------------------------- 9595 Final FW RPA for NH3N_NC0026654, rpa Page 1 of 1 2/21/2020 REASONABLE POTENTIAL ANALYSIS JPar22 Use"PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 NO DATA NO DATA 0 N/A N/A ug/L N/A ug/L 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Par23 Use "PASTE SPECIAL Ammonia Nitorgen Values then COPY . Maximum data points = 58 Date Data BDL=1/2DL Results 1/3/18 8.2 8.2 Std Dev. 2.1091 1/11/18 3.68 3.68 Mean 1.1808 1/16/18 2.02 2.02 C.V. 1.7862 2/6/18 2.58 2.58 n 52 2/27/18 < 0.2 0.1 3/8/18 0.21 0.21 Mult Factor = 1.07 3/22/18 < 0.2 0.1 Max. Value 8.470000 mg/L 4/4/18 < 0.2 0.1 Max. Pred Cw 9.062900 mg/L 4/17/18 < 0.2 0.1 5/2/18 < 0.2 0.1 5/15/18 0.3 0.3 6/5/18 < 0.2 0.1 6/19/18 < 0.2 0.1 7/3/18 < 0.2 0.1 7/17/18 < 0.2 0.1 8/8/18 0.26 0.26 8/21/18 0.99 0.99 9/4/18 < 0.2 0.1 9/18/18 < 0.2 0.1 10/2/18 < 0.2 0.1 10/16/18 < 0.2 0.1 11/6/18 < 0.2 0.1 11/20/18 6.1 6.1 12/4/18 < 0.2 0.1 12/19/18 0.29 0.29 1/3/19 6.7 6.7 1/15/19 0.22 0.22 2/5/19 0.28 0.28 2/18/19 0.45 0.45 3/4/19 2.71 2.71 3/18/19 0.55 0.55 4/2/19 0.36 0.36 4/16/19 < 0.2 0.1 5/1/19 < 0.2 0.1 5/14/19 < 0.2 0.1 6/4/19 < 0.2 0.1 6/18/19 0.41 0.41 6/25/19 0.28 0.28 7/2/19 < 0.2 0.1 7/16/19 5.05 5.05 7/30/19 < 0.2 0.1 8/6/19 < 0.2 0.1 8/21 /19 < 0.2 0.1 9/4/19 < 0.2 0.1 9/17/19 1.69 1.69 10/1/19 2.91 2.91 10/8/19 8.47 8.47 10/15/19 < 0.2 0.1 11 /6/19 < 0.2 0.1 11/19/19 2.17 2.17 12/3/19 0.35 0.35 12/18/19 1.57 1.57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 0 Date Data BDL=1/2DL _12_ 9595 Final FW RPA for NH3N_NC0026654, data 2/21 /2020 NH3/TRC WLA Calculations Facility: Crossnore WWTP PermitNo. NCO026654 Prepared By: Bradley Bennett Enter Design Flow (MGD): 0.07 Enter s7Q10 (cfs): 2.4 Enter w7Q10 (cfs): 3.4 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/1) Ammonia (Summer) Monthly Average Limit (mg NH3-N/1) s7Q10 (CFS) 2.4 s7Q10 (CFS) 2.4 DESIGN FLOW (MGD) 0.07 DESIGN FLOW (MGD) 0.07 DESIGN FLOW (CFS) 0.1085 DESIGN FLOW (CFS) 0.1085 STREAM STD (UG/L) 17.0 STREAM STD (MG/L) 1.0 Upstream Bkgd (ug/1) 0 Upstream Bkgd (mg/1) 0.22 IWC (%) 4.33 IWC (%) 4.33 Allowable Cone. (ug/1) 393 Allowable Cone. (mg/1) 18.3 Ammonia (Winter) Monthly Average Limit (mg NH3-N/1) Fecal Coliform w7Q10 (CFS) 3.4 Monthly Average Limit: 200/100ml DESIGN FLOW (MGD) 0.07 (If DF >331; Monitor) DESIGN FLOW (CFS) 0.1085 (If DF<331; Limit) STREAM STD (MG/L) 1.8 Dilution Factor (DF) 23.12 Upstream Bkgd (mg/1) 0.22 IWC (%) 3.09 Allowable Cone. (mg/1) 51.3 Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/l, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals) 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis) If the allowable ammonia concentration is > 35 mg/L, no limit shall be imposed Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NC0026654 Crossnore WWTP / Town of Crossnore Document Review ARO Comments / Notes from Application: • No noted changes in the renewal application • Application submitted for the town by Water Quality Lab and Operations, Inc. (Jadd Brewer). They are also listed as the operator on the application. Brewer signed application and he does have delegated authority. Facility address in application had street address transposed — NCSR 1143 not 1134. Review of Monitoring Data: • Hg — Once per term monitoring. Reported value of 0.73 ng/L. BOD average removal at around 96%. • TSS average removal at around 91%. • Flow average for permit term —0.027 MGD. Permitted flow of 0.070 MGD. There were a few weeks (probably storm events) when the daily flow values exceeded the permit limit, but monthly average was still below. Largest monthly average around 0.05MGD. Do have a couple of frequency violations for flow reporting. • Temperature — Only monitor at effluent. Values range from 0 to 29 with average of 16. No apparent issue. • Fecal Values — only 10 of 267 values over 200. Two were at very high levels 4300 and 6000 but did not result in BIMS limit violations. No way that these could have met the 400 weekly average? • pH — no issue from data (6.0 to 8.4). • NH3-N — 0 to 15.8 with average of 2.15 mg/L. No single value above the monthly (18) or weekly (35) limits. The permit has a summer but no winter limit. Given recent discussion about seasonal limits not exceeding 2x [rule 2B .0404], etc. how does this apply? Since they are meeting the limits all year should we just remove the seasonal limit and apply it year round? Or, make winter limit 2x summer? NH3 WLA spreadsheet results show summer allowable concentration of 18 and winter of 51. Previous approaches appear to set maximum NH3 limit at 35 mg/L so this may set both winter limits at 35 mg/L. • No WET requirement — permittee took NH3 limits (see 1991 WLA). • Total Nitrogen — 1.88 to 18.4 with average of 13.21 mg/L. Monitored semi-annually • Total Phosphorous — 0.1 to 3.08 with average of 1.06 mg/L. Monitored semi-annually Compliance / Enforcement: • NOD and NOV for frequency violations on flow (2016 and 2015) • NOD (2018) and NOV (2017) for bypass. • One enforcement (2017) related to bypass. $1,500 penalty, $202.36 enforcement, 1,702.36 total. Regional Comments: • Daniel Boss commented that the permit should include a better list of treatment components on the supplement sheet. BESST package should be broken down into individual pieces — bar screen, aeration basin, etc. Daniel okay with outlining components consistent with February 2014 ATC.