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HomeMy WebLinkAboutWQ0037835_Final Permit_20201116ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANI£L SMITH Director NORTH CAROLINA Environmental Quality November 16, 2020 JAMEs R. FLECHTNER, PE — EXECUTIVE DIRECTOR CAPE FEAR PUBLIC UTILITY AUTHORITY 235 GOVERNMENT CENTER DRIVE WILMINGTON, NORTH CAROLINA 28403 Subject: Permit No. WQ0037835 Northside WWTP Reclaimed Water Bulk Distribution New Hanover County Dear Mr. Flechtner: In accordance with your permit renewal request received August 27, 2020, we are forwarding herewith Permit No. WQ0037835 dated November 16, 2020, to the Cape Fear Public Utility Authority for the continued operation of the subject reclaimed water bulk distribution facilities. Please note that this renewed permit shall become effective on February 1, 2021 (i.e., the day after the expiration date of the existing permit). This permit shall be effective from February 1, 2021 through February 28, 2027, shall void Permit No. WQ0037835 issued April 13, 2017, and shall be subject to the conditions and limitations therein. The Permittee shall submit a renewal application no later than September 1, 2026. Please pay attention to the monitoring requirements listed Attachments A and D for they may differ from the previous permit issuance. Failure to establish an adequate system for collecting and maintaining the required operational information shall result in future compliance problems. The Division has removed the following permit conditions since the last permit issuance dated April 13, 2017: ➢ Old Condition I.I. — This condition was met according to the July 28, 2020 inspection. ➢ Old Condition IIL4. — This condition was removed as the requirement is part of the Condition IV.6. ➢ Old Condition VL2. — The permit is not voidable. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 N11H fH (:Ai(1!.INA � 0­O'torenwm—talQ"I 919,707.9000 Mr. James R. Flechtner, PE November 16, 2020 Page 2 of 2 The following permit conditions are new since the last permit issuance dated April 13, 2017: ➢ Condition IIL5. — Metering equipment shall be tested and calibrated annually. ➢ Condition III.14. — A record keeping program shall be developed and maintained. ➢ Condition IIL 15. — A routine review and inspection program shall be developed and maintained. ➢ Conditions VL8. and VL9. — Updated general permit language. ➢ Condition VI.10. — Prevents the permit from being renewed if the Permittee has any unpaid overdue fees. If any parts, requirements, or limitations contained in this permit are unacceptable, the Permittee has the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding. If you need additional information concerning this permit, please contact Vivien Zhong at (919) 707-3627 or vivien.zhongkncdenr.gov. Sincerely, S. Daniel Smith, Director Division of Water Resources cc: New Hanover County Health Department (Electronic Copy) Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy) Laserfiche File (Electronic Copy) Digital Permit Archive (Electronic Copy) NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENTAL QUALITY RALEIGH RECLAIMED WATER BULK DISTRIBUTION PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations PERMISSION IS HEREBY GRANTED TO Cape Fear Public Utility Authority New Hanover County FOR THE continued operation of a 100,000 gallon per day (GPD) reclaimed water bulk distribution system extension consisting of Fill Station Location Owner County Latitude Longitude 1 Northside WWTP CFPUA New Hanover 34.2625420 -77.9214260 and all associated piping, valves, controls, and appurtenances to serve the Northside WWTP, with no discharge of wastes to surface waters, pursuant to the application received August 27, 2020, and in conformity with the Division -approved plans and specifications considered a part of this permit. Please note that an Alternative Design Criteria has been approved for this facility in accordance with 15A NCAC 02T .0105(n). The following administrative codes has been approved for alternative design criteria: ➢ 15A NCAC 02U .0401(b) —Continuous on-line monitoring and recording for turbidity and flow shall be provided prior to storage, distribution or utilization. Flow will be recorded at time of filling by using tank/container capacities and volumes. Monitoring of turbidity will be performed by a continuous on-line turbidity analyzer. This permit shall be effective from February 1, 2021 through February 28, 2027, shall void Permit No. WQ0037835 issued April 13, 2017, and shall be subject to the following conditions and limitations: I. SCHEDULES 1. The Permittee shall request renewal of this permit on Division -approved forms no later than September 1, 2026. [15A NCAC 02T .0105(b), 02T .0109] WQ0037835 Version 2.0 Shell Version 200201 Page 1 of 7 IL PERFORMANCE STANDARDS The Permittee shall maintain and operate the subject reclaimed water bulk distribution facilities so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate corrective actions, including Division required actions, such as the construction of additional or replacement reclaimed water bulk distribution facilities, or cessation of reclaimed water bulk distribution. [15A NCAC 02T .0108(b)(1)(A)] 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. [15A NCAC 02T .0108(b)(1)(A)] Effluent limitations for bulk distributed reclaimed water shall not exceed those specified in Attachment A. [15A NCAC 02U .0301] 4. Bulk distributed reclaimed water shall only be utilized in accordance with the approved uses specified in Attachment D. [15A NCAC 02T .0108(b)(1)(A)] The conjunctive utilization of bulk distributed reclaimed water permitted herein in no way negates, precludes, or invalidates Permit No. NCO023965. [15A NCAC 02T .0108(b)(1)(A)] 6. All reclaimed water valves, storage facilities, and outlets shall be tagged or labeled to warn the public or employees that the water is not intended for drinking. [15A NCAC 02U .0403(b)] 7. All reclaimed water piping, valves, outlets, and other appurtenances shall be color -coded, taped, or otherwise marked to identify the source of the water as being reclaimed water as follows: a. All reclaimed water piping and appurtenances shall be either colored purple (Pantone 522 or equivalent) and embossed or integrally stamped or marked "CAUTION: RECLAIMED WATER - DO NOT DRINK" or be installed with a purple (Pantone 522 or equivalent) identification tape or polyethylene vinyl wrap. The warning shall be stamped on opposite sides of the pipe and repeated every three feet or less; b. Identification tape shall be at least three inches wide and have white or black lettering on purple (Pantone 522 or equivalent) field stating "CAUTION: RECLAIMED WATER - DO NOT DRINK". Identification tape shall be installed on top of reclaimed water pipelines, fastened at least every 10 feet to each pipe length and run continuously the entire length of the pipe; and c. Existing underground distribution systems retrofitted for the purpose of convey reclaimed water shall be taped or otherwise identified as noted in IL7.a. and IL7.b. This identification need not extend the entire length of the distribution system but shall be incorporated within 10 feet of crossing any potable water supply line or sanitary sewer line. [15A NCAC 02U .0403(c)] 8. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that permits operation by personnel authorized by the entity that operates the reclaimed water system. [15A NCAC 02U .0403(d)] 9. Hose bibs shall be located in locked, below grade vaults that shall be labeled as being of non -potable quality. As an alternative to the use of locked vaults with standard hose bib services, other locking mechanisms such as hose bibs that can only be operated by a tool may be placed above ground and labeled as non -potable water. [15A NCAC 02U .0403(e)] 10. There shall be no direct cross -connections between the reclaimed water and potable water systems, unless such connection has been approved by the Department pursuant to 15A NCAC 18C .0406. [15A NCAC 02U .0403(f)] WQ0037835 Version 2.0 Shell Version 200201 Page 2 of 7 III. OPERATION AND MAINTENANCE REQUIREMENTS 1. The Permittee shall operate and maintain the subject facilities as anon -discharge system. [15A NCAC 02U .0101] 2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include: a. A description of the operation of the system in detail to show what operations are necessary for the system to function and by whom the operations are to be conducted; b. A sampling and monitoring plan to evaluate quality of reclaimed water within the bulk distribution system to provide quality assurance at the time of reuse, and specify actions to be taken in response to unsatisfactory monitoring results; c. A map of all reclaimed water bulk distribution points; d. A description of anticipated maintenance of the system; e. Provisions for safety measures, including restriction of access to the site and equipment; f. Spill control provisions that include response to upsets and bypasses, including control, containment, and remediation, and contact information for personnel, emergency responders, and regulatory agencies; g. Approval procedures for bulk distribution users; h. Operational requirements for bulk distribution users; and i. A description of how compliance with reclaimed water quality standards will be ensured the time of use if bulk distributed reclaimed water is stored for greater than 72 hours prior to use. [15A NCAC 02U .0801(a)] Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, the Permittee shall designate and employ a certified operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T .0117] 4. Only reclaimed water generated from the Northside WWTP (Permit No. NC0023965) shall be distributed from the reclaimed water bulk distribution facilities permitted herein. [15A NCAC 02U .0101] 5. Metering equipment shall be tested and calibrated annually. [15A NCAC 02U .0801(d)] 6. Reclaimed water shall not be bulk distributed if turbidity exceeds 10 NTUs or if the permitted pathogen levels cannot be met. [15A NCAC 02U .0401(c)] 7. The Permittee shall provide notification to the public and its employees about the use of bulk distributed reclaimed water, and that bulk distributed reclaimed water is not intended for drinking. Such notification shall be provided to employees in a language they can understand. [15A NCAC 02U .0501(a)(2)] 8. Bulk distributed reclaimed water used for activities other than irrigation shall not be used in a manner that causes exposure to aerosols. [15A NCAC 02U .0501(b)(6)] 9. Bulk distributed reclaimed water shall not be used for swimming pools, hot tubs, spas, or similar uses. [15A NCAC 02U .0501(c)] 10. Tank trucks and other equipment used to transport bulk distributed reclaimed water shall be identified with advisory signs stating that they contain reclaimed water that is not intended for drinking. [15A NCAC 02U .0601(a)] WQ0037835 Version 2.0 Shell Version 200201 Page 3 of 7 11. Tank trucks used to transport bulk distributed reclaimed water shall not be used to transport potable water. [15A NCAC 02U .0601(b)] 12. Tank trucks used to transport bulk distributed reclaimed water shall not be filled through on -board piping or removable hoses that may subsequently be used to fill potable water tanks. [ 15A NCAC 02U .0601(c)] 13. The Permittee shall develop and maintain an education and approval program for those accepting bulk distributed reclaimed water. Educational materials shall instruct those accepting bulk distributed reclaimed water about its proper use in accordance with Subchapter 02U and those approved activities in Attachment D. [15A NCAC 02U .0601(d)] 14. The Permittee shall develop and maintain a record keeping program for the bulk distribution of reclaimed water. [15A NCAC 02U .0601(e)] 15. The Permittee shall develop and maintain a routine review and inspection program of those accepting bulk distributed reclaimed water. [15A NCAC 02U .0601(f)] IV. MONITORING AND REPORTING REQUIREMENTS The Permittee shall conduct and report any Division required monitoring necessary to evaluate this facility's impact on groundwater and surface water. [15A NCAC 02T .0108(c)] 2. A Division -certified laboratory shall conduct all analyses for the required effluent, groundwater, and surface water parameters. [15A NCAC 02H .0800] 3. The Permittee shall monitor the bulk distributed reclaimed water at the frequencies and locations for the parameters specified in Attachment A. [15A NCAC 02T .0108(c)] 4. The Permittee shall maintain records tracking the amount of reclaimed water bulk distributed to each user and shall include the following information: a. Date and time of bulk distribution event; b. Name of receiver or town -issued bulk fill certification number; c. Intended use of the bulk distributed reclaimed water; d. Volume of reclaimed water per each bulk distribution event; and e. Monthly total volume of reclaimed water bulk distributed. Monthly tracking records for all users shall be summed and reported on Form NDMR. This value shall represent the total volume of reclaimed water bulk distributed to all users for that month. [ 15A NCAC 02T .0108(c)] 5. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for each PPI specified in Attachment A shall be submitted on or before the last day of the following month. If no activities occurred during the monitoring month, monitoring reports are still required documenting the absence of the activity. All information shall be submitted to the following address: Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [15A NCAC 02T .0105(1)] WQ0037835 Version 2.0 Shell Version 200201 Page 4 of 7 6. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall be made available to the Division upon request. This log shall include: a. Date of flow measurement device calibration; b. Date of turbidimeter calibration; c. Visual observations of the bulk distribution facilities; d. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.); and e. Record of all discharges of reclaimed water to surface waters or the land surface, including the date of occurrence, estimated volume, and corrective action taken. [15A NCAC 02U .0801(h)] 7. Noncompliance Notification: The Permittee shall report to the Wilmington Regional Office, telephone number (910) 796-7215, within 24 hours of first knowledge of the following: a. Any failure rendering the reclaimed water bulk distribution facilities incapable of adequately conveying reclaimed water (e.g., mechanical or electrical failures, etc.). b. Any failure resulting in a discharge to surface waters. c. Any discharge to land surface greater than or equal to 5,000 gallons. The Permittee shall document discharges less than 5,000 gallons to land surface, but do not require Regional Office notification. d. Any time self -monitoring indicates the facility has gone out of compliance with its permit limitations. Emergencies requiring reporting outside normal business hours shall call the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300. All noncompliance notifications shall file a written report to the Wilmington Regional Office within five days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)] V. INSPECTIONS 1. The Permittee shall perform inspections and maintenance to ensure proper operation of the reclaimed water bulk distribution facilities. [15A NCAC 02U .0801(i)] 2. The Permittee shall inspect the reclaimed water bulk distribution facilities to prevent malfunctions, facility deterioration, and operator errors that may result in discharges of wastes to the environment, threats to human health, or public nuisances. The Permittee shall maintain an inspection log that includes the date and time of inspection, observations made, and maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the Division upon request. [15A NCAC 02U .0801(h), 02U .0801(i)] Division authorized representatives may, upon presentation of credentials, enter and inspect any property, premises, or place related to the reclaimed water bulk distribution facilities permitted herein at any reasonable time for determining compliance with this permit. Division authorized representatives may inspect or copy records maintained under the terms and conditions of this permit, and may collect groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)] 4. The Permittee shall inspect the utilization sites of all reclaimed water users who obtain more than 10,000 gallons per day of bulk distributed reclaimed water. Permittee inspection of these bulk distribution reclaimed water utilization sites shall need to exceed one inspection per quarter. The Permittee shall maintain records of these inspections for five years, and shall make them available to the Division upon request. [15A NCAC 02T .0108(b)(1)(A)] WQ0037835 Version 2.0 Shell Version 200201 Page 5 of 7 VI. GENERAL CONDITIONS 1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a Division enforcement action. [G.S. 143-215.6A, 143-215.613, 143-215.6C] 2. This permit is effective only with respect to the nature and volume of wastes described in the permit application, and Division -approved plans and specifications. [G.S. 143-215.1(d)] 3. Unless specifically requested and approved in this permit, there are no variances to administrative codes or general statutes governing the construction or operation of the facilities permitted herein. [15A NCAC 02T .0105(n)] 4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules, regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal) may require. [15A NCAC 02T .0105(c)(6)] 5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall submit a permit modification request on Division -approved forms. The Permittee shall comply with all terms and conditions of this permit until the permit is transferred to the successor -owner. [G.S. 143- 215.1(d3)] 6. The Permittee shall retain a set of Division -approved plans and specifications for the life of the facilities permitted herein. [15A NCAC 02T .0105(o)] 7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .01050)] 8. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in whole or part for: a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter 02U; b. obtaining a permit by misrepresentation or failure to disclose all relevant facts; c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials: I. to enter the Permittee's premises where a system is located or where any records are required to be kept; ii. to have access to any permit required documents and records; iii. to inspect any monitoring equipment or method as required in this permit; or iv. to sample any pollutants; d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or e. a Division determination that the conditions of this permit are in conflict with North Carolina Administrative Code or General Statutes. [15A NCAC 02T .0110] WQ0037835 Version 2.0 Shell Version 200201 Page 6 of 7 9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not occur if any of the following apply: a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of environmental crimes under G.S. 143-215.6B, or under Federal law that would otherwise be prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or exhausted. b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned a wastewater treatment facility without properly closing the facility. c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil penalty, and all appeals of this penalty have been abandoned or exhausted. d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant with any compliance schedule in a permit, settlement agreement, or order. e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual fee. [15A NCAC 02T .0120(b), 02T .0120(d)] 10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee. [15A NCAC 02T .0120(c)] Permit issued this the 16'h day of November 2020 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION 7L 4 S. Daniel Smith, Director Division of Water Resources By Authority of the Environmental Management Commission Permit Number WQ0037835 WQ0037835 Version 2.0 Shell Version 200201 Page 7 of 7 THIS PAGE BLANK ATTACHMENT A — LIMITATIONS AND MONITORING REQUIREMENTS PPI 001- Reclaimed Water Generation System Effluent' Permit Number: WQ0037835 Version: 2.0 EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS PCs Code Parameter Description Units of Measure Monthly Monthly Daily Minimum Average Geometric Mean Daily Maximum Measurement Frequency Sample Type 00310 BOD, 5-Day (20 °C) mg/L 10 15 2 x Week 2 Composite 31616 Coliform, Fecal MF, M-FC Broth, 44.5 °C #/100 mL 14 25 2 x Week z, s Grab 00610 Nitrogen, Ammonia Total (as N) mg/L 4 6 2 x Week 2 Composite 00530 Solids, Total Suspended mg/L 5 10 2 x Week 2 Composite 1. Monitoring parameters are set to match the facility NPDES permit (Permit No. NC0023965). If no bulk reclaimed water distribution occurs over a month, no reporting of any analytical data is required, except for the indication of zero flow "0 gallons of reclaimed water distributed" on the NDMR form which is still required. 2. The monthly sampling (at PPI 001) must be at least one representative sample for each month. Therefore, the monthly average and daily maximum effluent limits will only apply to the single sample submitted each month. The Permittee (CFPUA) proposes to report the data closest to and immediately prior to the fast bulk reclaimed water distribution occurring any month, providing that all data recorded up until that point meets the Attachment A limits to satisfy the once monthly minimum sampling requirement. 3. Monitoring for Fecal Coliform may be substituted with Enterococci. However, the Permittee shall conduct sample analysis for Fecal Coliform if any of the Enterococci results exceed the established Enterococci Daily Maximum limit of 14 #/100 mL unless no reclaimed water distribution occur during the sampling period (i.e. should CFPUA elect not to distribute bulk reclaimed water until enterococci is retested and complies, testing for fecal coliform is not required and non-compliance reporting to the Wilmington Regional Office is also not required). PPI 002 — Reclaimed Water Bulk Fill Station EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS PCS Code Parameter Description Units of Measure Monthly Total Monthly Daily Minimum Daily Maximum Geometric Mean Measurement Frequency Sample Type WQO1 Flow, Reclaimed Water Distributed gallons Monthly Estimate 00076 Turbidity, HCH Turbidimeter NTU 10 Continuous Recorder 1. If no bulk reclaimed water distribution occurs over a month, no reporting of any analytical data is required, except for the indication of zero flow "0 gallons of reclaimed water distributed" on the NDMR form which is still required. WQ0037835 Version 2.0 Attachment A Page 1 of 1 THIS PAGE BLANK ATTACHMENT D — APPROVED RECLAIMED WATER BULK DISTRIBUTION USES Cape Fear Public Utility Authority — Northside WWTP Permit Number: WQ0037835 Version: 2.0 APPROVED PERMITTEE USES' ADDITIONAL REQUIREMENTS AND COMMENTS Firefighting and fire extinguishing Must meet Public Water Supply requirements per 15A NCAC 18C .0100 - .2200 Reclaimed water distribution line flushing and pressure testing Provided the water is returned to the sanitary sewer, or used for other approved reclaimed water uses after testing. Vehicle and equipment washing Provided that no ponding or run-off of the reclaimed water occurs. 1. All employees shall complete educational training prior to utilizing bulk distributed reclaimed water. APPROVED USES FOR BULK DISTRIBUTED RECLAIMED WATER RECIPIENTS 2 ADDITIONAL REQUIREMENTS AND COMMENTS Concrete cutting Decorative ponds and fountains that drain to sanitary sewer systems Hydro -seeding and fertilizer mixing Industrial and commercial cooling water or boiler blow down water Provided that cooling water or boiler blow down water is disposed of according to any necessary disposal permit. Industrial and commercial fire prevention systems where there are separate non -potable plumbing lines Irrigation of public and private landscapes and turf Make-up water for brine slurry or similar Brine slurry to be applied to roads to prevent freezing. Irrigation of food chain crops Provided that all conditions of 15A NCAC 02U .1401 are met. Make-up water for preparation of pesticide solutions or similar Use of reclaimed water does not exempt user from meeting the use and disposal requirements of the created solution. Non -potable processes such as asphalt reclamation, concrete production and compost production Must meet compost permit requirements. Sewer cleaning Soil compaction and dust suppression May include irrigation to clay or synthetic clay tennis courts, or similar. Street sweeping and washing Subsurface Directional Boring Does not include borings into bedrock or installation of any wells subject to 15A NCAC 02C - Well Construction Regulations. Vehicle washing and power washing Provided that dual disinfection with UV and chlorination is provided, and that no ponding or run- off of the reclaimed water occurs. 2. All recipients of bulk distributed reclaimed water users shall complete educational training and be Permittee-certified prior to receiving reclaimed water. WQ0037835 Version 2.0 Attachment D Page 1 of 1