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HomeMy WebLinkAboutNCG500661_Permit (Issuance)_20120430Avia NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor Director Secretary April 30, 2012 Robert Carter, Plan Manager Bonsai American 139 South Walnut Circle Greensboro, North Carolina 27409 Subject: Issuance under General Permit NCG500000 Certificate of Coverage (COC) NCG500661 Bonsai American Guilford County Dear Mr. McNamara: In accordance with your application, the Division of Water Quality (DWQ) hereby forwards this Certificate of Coverage to discharge under the subject general permit. We issue this permit pursuant to the requirements of North Carolina's General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection Agency dated July 17, 2007 (or as subsequently amended). The Division has discovered significant errors in your COC issued on April 25. Please disregard the previous copy and replace it with the attached. We regret any inconvenience this has caused. Please note that your facility discharges to a stream segment classified Water Supply (WS). The following information is included with your permit: • A copy of the Certificate of Coverage for your treatment facility • A copy of General Permit NCG500000 for non -contact cooling water, boiler blowdown • A copy of a Technical Bulletin for General Permit NCG500000 If any parts, measurement frequencies or sampling requirements contained in this general permit are unacceptable, you have the right to request an individual permit by submitting an individual NPDES permit application. Unless such demand is made, this Certificate of Coverage shall be final and binding. Please note that this Certificate of Coverage is not transferable except after notice to the Division of Water Quality. The Division may modify, or revoke and reissue this Certificate of Coverage. This issuance does not affect your legal obligations to obtain other permits that may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other Federal or Local government. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-6492 l Customer Service:1-877-623-6748 Internet www.ncwaterquality.org An Equal Opportunity l Affirmative Action Employer nTthCaT011Tla hatura!!y If you have any questions concerning this permit, please contact Joe Corporon at telephone number (919) 807-6394 or email (joe.corporon@ncdenr.gov). Charles Wakild, P.E. cc: Winston-Salem Regional Office, Surface Water Protection Section Central Files NPDES General Files • 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer NorthCarolina Naturally STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY General Permit NCG500000 Certificate of Coverage NCG500661 To discharge non -contact cooling water and boiler blowdown associated with the manufacture of coal tar emulsion -based pavement sealer, and similar wastewaters under the NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) 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, Bonsal American is hereby authorized to discharge wastewater from a facility located at Bonsal American 139 South Walnut Circle, Greensboro Guilford County to receiving waters designated as an unnamed tributary to South Buffalo Creek [stream segment 16-11-14-2, a waterbody currently classified WS-V; NSW within Subbasin 03-06-02 of the Cape Fear River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of the General Permit NCG500000, as attached. This permit shall become effective April 30, 2012. This Certificate of Coverage shall remain in effect for the duration of the General Permit July 31, 2012. Signed this day April 30, 2012. les Wakild, P.E., Directo ivision of Water Quality By Authority of the Environmental Management Commission Outfalls 001 and 002 Lat 36° 03' 58" Long79°52' 51" Flows east and south UT to South Buffalo Creek Bonsal American State Grid/Quad: C 19 SW / Guillbrd, NC Sub -Basin: 03-06-02 Drainage Basin: Cape Fear River Basin HUC: 03020201 Receiving Stream: UT to South Buffalo Creek [Stream Segment 16-11-14-21 Stream Class: WS-V; NSW Facility Location not to scale North GEN. NPDES Permit NCG500661 Guilford County Le ide: BIMS Tracking Slip NPDES PERMIT RENEWAL DRAFT & FINAL CHECK LIST Facility �^ vSekC i"cv LaS CA/ Permit No. %v J a NPDES Permit Writer: Right side: (in chronological order — newest to oldest) ❑ Streamline Fact Sheet 2Draft Permit Cover Letter. iDraft Permit I" Facility Map ❑ Fact Sheet ❑ Permit Writer's Notes ❑ Staff Report from Region El/ Permit Application. Acknowledgement Letter ❑ Permittee Responses 0 'Joe R. Co (add new policy text; summarize major changes to pe/mit) (order: cover, supplement, map, effluent sheets, speynal condition (E-Map: include facility Outfalls; U and D sampleXocations) (new or complex renewal; documents permit writer's issues/re-issue justification) (if not in Facts Sheet -- chronology, strategy, DMR Review, RPA, etc.) (as appropriate — maybe not needed if expedited) (Text, Effluent Sheets and Special Conditions) (New Permit or Renewal; any additional permittee correspondence) (NPDES Unit written response to Renewal Application) (to acknowledgement letter, if any) Waste Load Allocation (reference date; notes if recalculated for current action) Note: Italics indicate special conditions not always required or applicable. ❑ Submitted to ❑ Peer Review completed by �c y ❑ Updated Public Notice System [date] (if expedited) Submitted for Public Notice on Draft Permit [Mailed / L - Regional Office Reviewed / ❑ Review by [TOX/DWR] ❑ Additional Review by [TACU] for Peer Review: Date Admin cutoff date Date Updated BIMS Events: [date] . Newspaper Notice Received . Actual Notice date(s) 7 to (Regional Staff) it'¢ v yfckG 7' by 3Oc. Date/ I._ Received on [Date] initiated by initiated by Date (!/410rl- Date ❑ Additional Review/Completed by Date FINAL to John Jeff / Matt / Coleen for signature on [date] t9U (Y� EW Additional Review [other] Letter Dated 6<DI*S�c Ltd) (161M?-) ❑ Transferred Final Files to Server (Permits Folder) . Updates to BIMS Final: Events "Limits ❑ Emailed FINAL RDF to im Colson (CG&L) and Susan Meadows (TOX) [Date] cG--4 &Afr S sU' - 3640, 9-0 R— Version 04Apr2012 From: Corporon, Joe Sent: Tuesday, April 03, 2012 10:41 AM To: Mickey, Mike Cc: Hennessy, John; Romanski, Autumn Subject: RE: Bonsai American Application / NCG500661 Mike - Do you happen to know if they re -circulate cooling water, i.e., have potential to concentrate contaminants? We may want to take a closer look into their processes/discharge, particularly if it flows to Class WS [not yet established] - some have potential to exceed water supply (WS) Standards. They may get an ad -info letter from us — still working out the details with the NCG50 renewal. It has been suggested that we also update the application to include these details. However, no Staff Report needed at this time. We will follow your recommendation — issuance in progress. More later. Respectfully, Joe R Corporon, L.G. Environmental Specialist NPDES Program NCDENR/Division of Water Quality (DWQ) Surface Water Protection Section 919-807-6394; FAX 919-807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Mickey, Mike Sent: Monday, April 02, 2012 4:02 PM To: Corporon, Joe Subject: FW: Bonsai American Application / NCG500661 Joe — Never got an answer to my email below: From: Mickey, Mike Sent: Thursday, March 29, 2012 3:57 PM To: Corporon, Joe Subject: Bonsai American Application / NCG500661 Joe —The acknowledgment letter requested a staff report. Do you really need it? If not, WSRO recommends issuance of the COC. The City of Greensboro discovered the non -permitted discharges of non -contact cooling water and boiler blowdown while performing a stormwater inspection at the facility. The daily flows are minimal. Mike. Mike Mickey M i ke. M i c kev@ N C D E N R. eov NC Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Phone: (336) 771-4962 2 Corporon, Joe From: Sent: To: Subject: Mickey, Mike Thursday, April 19, 2012 2:48 PM Corporon, Joe RE: Review of Bonsai American COC & Application / NCG500661 Joe - The plant manager said their cooling water is once -through. They do not recirculate. Mike. Mike Mickey Mike.Mickey@NCDENR.gov NC Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Phone: (336) 771-4962 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Corporon, Joe Sent: Thursday, April 19, 2012 1:49 PM To: Mickey, Mike Cc: Romanski, Autumn; Hennessy, John Subject: Review of Bonsai American COC & Application / NCG500661 Mike - this is the new discharge under NCGSO we discussed earlier. They manufacture a coal -tar emulsion -based pavement sealer. I have drafted the COC (attached). Their application lists cooling water/boiler blowdown (two outfalls —125 gpd and ' 1 gpd) with few other details. Disclosed chemicals include corrosion inhibitors [Paul's Water Treatment— B04, 810, B95, 8114 and B21]; discharge to a UT to South Buffalo Creek (WS-V; NSW). Can you advise if their processes have potential to concentrate parameters of concern? Thanks in advance for your input, Joe R. C'orporion, L.G. Environmental Specialist NPDES Program NCDENR/Division of Water Quality (DWQ) Surface Water Protection Section 919-807-6394: FAX 919-807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. 1 A7A NCDENR Division of Water Quality / Water Quality Section National Pollutant Discharge Elimination System ,A2,2 NCG500000 FOR AGENCY USE ONLY Dale Received Year Month Dar al 03 / ,poi Certificate etage NICIGr1O101616 Check a Amount f 44 48 /AO.ob Permit Assigned to Tr. (n/319ron NOTICE OF INTENT National Pollutant Discharge Elimination System application for coverage under General Permit NCG500000: Non -contact cooling water, boiler blowdown, cooling tower blowdown, condensate, and similar point source discharges 1) Mailing address Company Name Owner Name Street Address City Telephone No. (Please print or type) of owner/operator: L�DPd5FL AnnEr`tC.AfJ bLO GA.S'- LE i � C, 3 Sou f-1 w 4kLtthfc C.tczc t_C State ,J G ss/> 2,5z-,` (tfZoD Fax: T 6 * Address to which all permit correspondence will be mailed 2) Location of facility producing discharge: -GOO -.CA 1-- fYl E r i r P\ r� Facility Name Facility Contact Street Address City County Telephone No. I] t3rRY CA 2Te. cc (36) _St,rl-r/-/ U1ni-j0A t C1iPr,LE State p3 c__ 414 �3 4 > ' f-?c.2),(5 v Fax: -2, (-; ZIP Code r ZIP Code ar7 ?_5- 2 () Z 3) Physical location information: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). TRnrn '-}-t5 (A)l /Jogi- Dr) Cii-ct1L>�drD Cat tLFFF. RDJ) can R9H-r 6n0 W. MI\R KET 9 rnir<F tr, RIDFir on uJ1aLOv1- c rf�c (A co of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application) 4) This`isNPDES permit application applies to which of the following : 1/ New or Proposed ❑ Modification Please describe the modification: ❑ Renewal Please specify existing permit number and original issue date: 5) Does this facility have any other NPDES permits? ❑ o I,_,Q../Yes If yes, list the permit numbers for all current NPDES permits for this facility: t�1 C,G I D'ood 6) What is the nature of the business applying for this permit? A krmi L J o !J C E O p'A v t l'\E nT R IE@NOWRGI MAR 13 2012 I Page 1 of 4 04/05 NCG500000 N.O.I. 7). Description of Discharge: a) Is the discharge directlyto the receivingwater? 0 Yes No 9 If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge. b) Number of discharge points (ditches, pipes, channels, etc. that convey wastewater from the property):,,,, c) What type of wastewater is discharged? Indicate which discharge points, if more than one. Non -contact cooling water Discharge point(s) #: ) ,f8j Boiler Blowdown Discharge point(s) #: �- ❑ Cooling Tower Blowdown Discharge point(s) #: ❑ Condensate Discharge point(s) #: ❑ Other Discharge point(s) #: (Please describe "Other") d) Volume of discharge per each discharge point (in GPD): #1: i' #2: I #3: #4 e) Please describe the type of process (i.e., compressor, NC unit, chiller, boiler, etc.) the wastewater is being discharged from, per each separate discharge point (if applicable, use separate sheet): 8) Please check the type of chemical added to the wastewater for treatment , per each separate discharge point (if applicable, use separate sheet): ❑ Biocides Name: Manuf.: iiit Corrosion inhibitors Name: Fo ` f B? J0f B 114L) 3''$e g Manuf.: PA IAL. 5 W11 Al f: 3L TiizErrinbur ❑ Chlorine Name: J / Manuf.: ❑ Algaecide Name: Manuf.: ❑ Other Name: Manuf.: ❑ None 9) If any box in item (8) above, other than none, was checked, a completed Biocide 101 Form and manufacturers' information on the additive is required to be submitted with the application for the Division's review. 10) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? 0 Yes fia No If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. Design criteria and operational data (including calculations) should be provided to ensure that the facility can comply with the requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the general permits. Note: Construction of any wastewater treatment facilities requires submission of three (3) sets of plans and specifications along with the application. Design of treatment facilities must comply with the requirements of 15A NCAC 2H .0138. If construction applies to this discharge, include the three sets of plans and specifications with this application. Page 2 of 4 04/05 NCG500000 N.O.I. 11) Discharge Frequency: a) The discharge is: ❑ Continuous ,t( Intermittent ❑ Seasonal❑ i) If the discharge is intermittent, describe when the discharge will occur: g. D p f nr) S'ocb(3m ii) If seasonal check the month(s) the discharge occurs: ❑ Jan. ❑ Feb. ❑ Mar. ❑ Apr. ❑ May ❑ Jun. ❑ Jul. ❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec. b) How many days per week is there a discharge? 5 c) Please check the days schargg occurs: ❑ Sat. ❑ Sun. Mon. tCJ Tue. VWed. Lei Thu. €rFri. 12) Pollutants: Please list any known pollutants that are present in the discharge, per each separate discharge point (if applicable, use separate sheet): 13) Receiving waters: a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility 5 RJ wastewater discharges end up in? If the site wastewater discharges to a separate storm sewer system (4S), name the operator of the 4S (e.g. City of Raleigh). bialanf.D f ribu(y 1 fl a te) egEE(\ b) Stream Classification: � 14) Alternatives to Direct Discharge: ids-\!) k-k-) Address the feasibility of implementing each of the following non -discharge alternatives a) Connection to a Municipal or Regional Sewer Collection System b) Subsurface disposal (including nitrification field, infiltration gallery, injection wells, etc.) c) Spray irrigation ITAIZ9-6 O �rc7Cr,--�2r The alternatives to discharge analysis should include boring Togs and/or other information indicating that a subsurface system is neither feasible nor practical as well as written confirmation indicating that connection to a POTW is not an option. It should also include a present value of costs analysis as outlined in the Division's "Guidance For the Evaluation of Wastewater Disposal Alternatives". 15) Additional Application Requirements: For new or proposed discharges, the following information must be included in triplicate with this application or it will be returned as incomplete. a) 7.5 minute series USGS topographic map (or a photocopied portion thereof) with discharge location clearly indicated. b) Site map, if the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. c) If this application is being submitted by a consulting engineer (or engineering firm), include documentation from the applicant showing that the engineer (Or firm) submitting the application has been designated an authorized Representative of the applicant. d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North Carolina registered Professional Engineer and stamped -"Final Design -Not released for construction". Page 3 of 4 04/05 NCG500000 N.O.I. e) Final specifications for all major treatment components (if applicable). The specifications must be signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative description of the treatment system to be constructed. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: 1TERT l (Z (2� T Titl pLf1 m N (Signature of Applicant) North Carolina General Statute 143-215.6 b (i) provides that: 3-7- 2- (Date Signed) Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Notice of Intent must be accompanied by a check or money order for $100.00 made payable to: NCDENR Mail three (3) copies of the entire package to: NPDES Permits. Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Final Checklist This application will be returned as incomplete unless all of the following items have been included: D Check for $100 made payable to NCDENR El .3 copies of county map or USGS quad sheet with location of facility clearly marked on map D 3 copies of this completed application and all supporting documents ❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E. D Thorough responses to items 1-7 on this application O Alternatives analysis including present value of costs for all alternatives Note The submission of this document does not guarantee the issuance of an NPDES permit Page 4 of 4 04/05 Name 'Description Six Runs Creek From source to Quewiffle Swamp Six Runs Creek From Quewiffle Swamp to Black River Skipper Hill Branch 'From source to Double Run Skunk Creek Index Number 18-68-2-(0.3) 18-68-2-(11.5) 18-66-6-2 17-40-1 Cape Fear River Basin Classification Class Date C;Sw Special Designation 04/01/59 C;Sw,ORW:+ 06/01/94 C;Sw 1From source to Big Buffalo Creek Slash Branch 18-23-16-6-1 WS-III From source to Roundabout Branch Smith Branch 18-20-31 WS-IV i15A NCAC 02B .0225 (e)(9) 04/01/59 From source to Upper Little River Smith Branch 16-11-11 From source to Reedy Fork Smith Creek 18-74-63 From source to Northeast Cape Fear River Smith Swamp (Jones Lake Drain) 'From Jones Lake to Turnbull Creek Smiths Creek 18-46-7 WS-V;NSW C;Sw C From source to Deep River Smiths Mill Pond Run (Smiths Mill Pond) From source to South River Smokehouse Creek 17-34 18-68-12-14 18-88-11 WS-IV C;Sw SC;HQW From source to Cape Fear River Snows Cut 18-87-31.5 SC From Carolina Beach Yacht Basin to Cape Fear River Snows Marsh !Entire Marsh South Buffalo Creek From source to Buffalo Creek South Fork Cane Creek 18-88-2 SC 5t t:......�.. 16-11-14-2 WS-V;NSW 16-28-5 WS-V;NSW 1From source to Cane Creek 03/01/77 ............. 08/03/92 08/03/92 08/11/09 09/01/74 09/01/74 08/03/92 07/01/73 08/01/90 08/09/81 08/09/81 08/11/09 08/11/09 Thursday, February 09, 2012 Based on Classifications as of 20120208 Page 81 of 98 Googleearth feet / 200 meters 60 /A4-; Ga' 631 Ee ),c)06 ?T'62' 5( wc-97-666( A F-P 2008-02.26 :add p'47071pemseafpreensaoro_7 msa SOURCE: MODIFIED FROM USGS, GUILFORD, NORTH CAROLINA QUADRANGLE, 1991, AND GREENSBORO, NORTH CAROLINA QUADRANGLE, 1994. 0 1,000 2.000 Feet GEM SEAL, INC. 139 SOUTH WALNUT CIRCLE GREENSBORO, NORTH CAROLINA FIGURE 1 SITE LOCATION MAP •y TETRA TECH All Waters in NC are in Category 5-303(d) List for Mercury due tostatewide fish consumption advice for several fish species AU Number AU_Name AU Description LengthArea AU_Units Classification Parameter Reason for Rating Use Category Collection Year 303(d)year Q 16-11-14-1a2 North Buffalo Creek From Philadelphia Lake to North Buffalo Creek WWTP 5 EcologicaUbiological Integrity Benthos Poor Bioclassification Aquatic Life 1.6 FW Miles C;NSW 1998 2008 Q 16-11-14-1b North Buffalo Creek From North Buffalo Creek WWTP to Buffalo 8.1 FW Miles C;NSW Creek 5 Copper Standard Violation Aquatic Life 2008 2008 5 Zinc Standard Violation Aquatic Life 2008 2008 Q 16-11-(1)b Reedy Fork 5 Ecological/biological Integrity FishCom From SR 2128 to a point 0.4 mile 4.2 FW Miles WS-III;NSW downstream of Moores Creek Fair Bioclassification Aquatic Lifc 2004 2006 Q 16-11-(9)b Reedy Fork (Hardys Mill Pond) 5 Fecal Coliform (recreation) From Buffalo Creek to Haw River 8.6 FW Miles C;NSW Standard Violation Recreation 2008 2004 5 Zinc Standard Violation Aquatic Life 2008 2008 Q 16-11-14-2b South Buffalo Creek From McConnell Rd to US 70 4.7 FW Miles C;NSW 5 Ecological/biological Integrity FishConi Poor Bioclassification Aquatic Life 2003 1998 Q 16-11-14-2c South Buffalo Creek From US 70 to Buffalo Creek 4.8 FW Miles C;NSW 5 Copper Standard Violation Aquatic Life 2008 2008 5 Zinc Standard Violation Aquatic Life 2008 2008 Q 16-11-5-1-(2) Unnamed Tributary at Guilford College 5 Ecological/biological Integrity Benthos From dam at Guilford College bathing lake 1.3 FW Miles WS-III;NSW to Horsepen Creek Poor Bioclassification Aquatic Life 2001 2006 Cape Fear River Basin Headwaters Haw River Watershed 0303000202 Q 16-(1)a HAW RIVER From source to SR 2109 7.8 FW Miles C;NSW 5 EcologicaUbiological Integrity Benthos Fair Bioclassification Aquatic Life 1998 2000 Q 16-(1)b HAW RIVER From SR 2109 to SR 2426 12.5 FW Miles C;NSW 5 Copper Standard Violation Aquatic Life 2008 2008 Q 16-7a Little Troublesome Creek 5 Ecological/biological Integrity Benthos From source to Reidsville WWTP 3.5 FW Miles C;NSW Fair Bioclassification Aquatic Life 1994 2000 Q 16-6-(3) Troublesome Creek 5 Low Dissolved Oxygen From dam at Lake Reidsville to Haw River 1.8 FW Miles C;NSW Standard Violation Aquatic Lifc 2008 2010 Cape Fear River Basin Big Alamance Creek Watershed 0303000203 5 ( Cs oe s - vj c)P he vAvv-eAt c 06-C-dbC76(rr-^/ NC 2010 Integrated Report Category 5-303(d) List EPA Submittal 20100329 f Monday, March 29, 2010 Page 4 of 115 an:ly e. Neff a er,ve ' a*� .: � -. f Goo*te earth feet km 4000 API clO �1c�s�6 C. i