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HomeMy WebLinkAboutNC0033782_Permit Issuance_20180228Water Resources w Environmental Quality February 28, 2018 Mr. Phillip Williams, Superintendent Public Schools of Gates County P.O. Box 125 Galesville, NC 27938-0125 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Subject: Issuance of NPDES Permit NCO033782 Gatesville Elementary School WWTP (WW-1) Gates County Dear Ms. Williams: The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject facility. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007, or as subsequently amended. The Division understands that you have made no significant changes to your facility since the last permit renewal. We have made the following updates for this permit renewal: 1. The facility map has been updated. 2. Regulatory citations have been added. 3. Electronic reporting of discharge monitoring reports (eDMR) has been added in Section A. (3.). 4. The coordinates for Outfall 001 have been corrected to Latitude 36' 24' 44" and Longitude -76 045' 12". If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B of North Carolina General Statutes, and you must file it with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall remain final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Resources or any other Federal, State, or Local governmental permits that may be required. If you have questions, or if we can be of further service, please contact Derek Denard at [derek.denard@ncdenr.gov] or call (919) 807-6307. asp 'fully, Linda Culpepper, late Director Division of Water Resources, NCDEQ Enclosure: NPDES Permit NCO033782 (renewal DRAFT) be: Central Files NPDES Program Files WaRO Files/ Attn: Robert Tankard ec: Gates County Schools, [greenejo@gatmcountyschools.net],[rountreelj@gatmcountyschools.net] State of North Carolina I Environmental Quality 1617 Mail Service Center I Raleigh, North Carolina 27699-1617 919-707-9000 NPDES permit NCO033782 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER 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, Gates County Board of Education is hereby authorized to discharge wastewater from a facility located at the Gatesville Elementary School WWTP 709 North Main Street, Gatesville 27938 Gates County to receiving waters designated as an unnamed tributary to Bennetts Creek in the Chowan 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 April 1, 2018. This permit and the authorization to discharge shall expire at midnight on March 31, 2023. Signed this day February 28, 2018. Lin ulpepper, Interim Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 6 NPDES permit NCO033782 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. Gates County Board of Education is hereby authorized to: 1. continue to operate an existing 0.005 MGD wastewater treatment system with the following components: • 3,000-gallon grease trap • 6,000 gallon septic tank • 1,500 gallon septic tank • 1,000-gallon wet well dosing tank • primary sand filter • secondary sand filter • recirculating sand filter tank divided into primary and secondary sides (10,000-gallon) • UV disinfection located at Gatesville Elementary School, 709 North Main Street, Gatesville, Gates County; and 2. discharge from said treatment works, via Outfall 001, at the location specified on the attached map, into an unnamed tributary to Bennetts Creek [stream index 25-17), currently classified C;NSW waters within sub -basin 03-01-01 [HUC: 030102030504] in the Chowan River Basin. Page 2 of 6 NPDES permit NCO033782 PART I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [I 5A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited, monitored and reported' by the Permittee as specified below: f SL " ryi 1-\� iaII.e 1. _ 3 1 Tj• R �.. .- -t }"aJll'/ f t `'i'. � j'�Jj`�...• P. 3R,`�{''.�����¢C\�^ ii '""� '1 .. Y ...�'S .i`s 11-LOXjliii VfAlwiK.�/ j. r �ie G"�FRISs.S "Mbn y 'Daily �` 'i�9e slaireme"�t a lea �amp [PdtQinrer Code) Average 1Vaaim `Free�icy T 'e. �._ ` ° on I.. ?, ''Sl (^a 1. '-d Y_ L .? i. •.._ Influent or Flow (MGD) 50050 0.005 MGD Weekly Instantaneous Effluent BOD, 5-day (mg/1) (20°C) C0310 30.0 mg/1 45.0 mg/l 2/Month Grab Effluent Total Suspended Solids (TSS) (mg/1) C0530 30.0 mg/1 45.0 mg/1 2/Month Grab Effluent Ammonia Nitrogen (NH3 as N) . C0610 2.0 mg/l 10.0 mg/l 2/Month Grab Effluent (mg/l) (April 1—October 31) Ammonia Nitrogen (NH3 as N) C0610 4.0 mg/1 20.0 mg/1 2/Month Grab Effluent (mg/1) (November 1—March 31) Fecal Coliform (#/100 ml) 2 31616 200/100 ml 1400/100ml 2/Month Grab Effluent Total Nitrogen (TN) (mg/1) 3 C0600 Monitor & Report Quarterly Grab Effluent Total Phosphorus (TP) (mg/1) C0665 Monitor & Report Quarterly Grab Effluent Temperature (°C) 00010 Monitor & Report Weekly Grab Effluent pH (su) 00400 Not < 6.0 nor > 1.0 2/Month Grab Effluent Standard Units Footnotes: 1. The Permittee shall begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Condition A. (3.). 2. Fecal Coliform shall be calculated using the geometric mean, according to the procedure detailed in Part H. Section A. 3. For a given wastewater sample, TN = TKN + (NO2 N + NO3 N), where TN is Total Nitrogen and TKN is Total Kjeldahl Nitrogen, and (NO2 N + NO3 N) is Nitrite/Nitrate Nitrogen. Conditions: • There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 6 NPDES permit NCO033782 A. (2.) TEMPORARY MEANS OF DISINFECTION [G.S. 143-215. 1 (b)] In the event that the wastewater treatment plant's ultraviolet (UV ) disinfection system should fail, underperform, or otherwise be removed from effective service, the permittee or his agent should immediately inform the Water Quality Regional Operations Section staff of the Washington Regional Office of this development and discuss temporary, alternate means for disinfection of the effluent. If chlorine compounds are used as temporary means of disinfection, the total residual chlorine (TRC) concentration of the effluent must be monitored on a daily basis while this method of disinfection is in use and values must be reported on the discharge monitoring report. TRC in the effluent may not exceed 17 µg/L; therefore, dechlorination methods may also be necessary to ensure protection of water quality in the receiving stream. Use of a disinfection system other than the permitted UV system during circumstances not deemed as emergency and/or temporary (replacement of lamps, lamp cleaning or maintenance, etc.) will be considered a violation of the terms of this permit. A. (3.) ELECTRONIC REPORTING OF MONITORING REPORTS [G. S. 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.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reportinit Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1 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 Page 4 of 6 NPDES permit NC0033782 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 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: http://www2.epa. ov/cg=liancelfinal national-poffutant- discharae-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. Page 5 of 6 NPDES permit NC0033782 Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: hU://deg.nc.gov/about/divisions/water-resources/edmur 4. Signatory Requirements (Supplements Section B. (11.) (b) and Supersedes Section B. (11.) fE All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(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. 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: htlp://dgg.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: "1 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.)1 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 6 of 6 O �• i I Outfall001 _ mows southeast] M S U( a am t -ate ,• 1 .y --„atesvilte 'L UT to Bennetts Creek ./ Approximate Facility Boundary X 6Q C NC ,—/ — s x 7 Bennetts Creek I { - 37 [flows south] X�/ Public Schools of Gates County N r---- r Gatesville Elementary School WWTP NPDES Permit NCO033782 I15.0m.40U 709 North Main Street, Gatesville 27938 36.4122°N,-76.7533°w Receiving Stream: UT to Bennetts Creek Stream Class: C;NSW NC Grid: B31NE Stream Segment: 25-17 Sub -Basin 4: 03-01-01 SCALE USGS Quad: Galesville, NC River Basin: Chowan HUC: 030102030504 1:16,000 County: Gates Denard, Derek INS►2 UV14 VI/I &t"t� From: Bullock, Robert Sent: Wednesday, December 20, 2017 8:24 AM To: Denard, Derek Cc: Tankard, Robert Subject: RE: Draft NPDES Permit NC0033782 - Public Schools of Gates County - Gatesville Elementary School WWTP (WW-1) Derek, I see that there are no changes to the permit so Washington is good with the draft. Thanks, Robbie Bullock Senior Specialist Division of Water Resources Water Quality Regional Operations 252-948-3843 office Robert.e.bullock(o)ncdenr.cov Email 943 Washington Square Mall Washington NC 27889 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Tuesday, December 19, 2017 5:31 PM To: greenjo@gatescountyschools.net; rountreelj@gatescountyschools.net Cc: Tankard, Robert <robert.tankard@ncdenr.gov>; Bullock, Robert <robert.e.buIlock@ncdenr.gov>; Kinney, Maureen <Ma ureen.Kinney@ncdenr.gov> Subject: Draft NPDES Permit NC0033782 - Public Schools of Gates County - Gatesville Elementary School WWTP (WW-1) Please find the attached draft permit NC0033782 for Gatesville Elementary School WWTP. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ/ DWR / NPDES Program no later than January 12, 2018. If you have questions concerning this draft, please e-mail me or call my direct line (919) 807-6307. Sincerely, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(a)ncdenr.00v N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Denard, Derek From: Bullock, Robert Sent: Tuesday, December 12, 2017 9:09 AM To: Tankard, Robert Cc: Denard, Derek Subject: RE: Drafting Initiated for NC0033782 Gatesville Elementary School WWTP Derek, The permit application was attached to your email. Could you send me a copy of the draft permit? Also, looking at their application it appears they put their permitted limits under #12 and not the highest single reading over the past 36 months. They have had multiple violations for fecal coliform. Thanks, Robbie Bullock Senior Specialist Division of Water Resources Water Quality Regional Operations 252-948-3843 office Robert.e.bullockna ncdenr.gov Email 943 Washington Square Mall Washington NC 27889 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Tankard, Robert Sent: Tuesday, December 12, 2017 8:42 AM To: Bullock, Robert <robert.e.bullock@ncdenr.gov> Cc: Denard, Derek <derek.denard@ncdenr.gov> Subject: FW: Drafting Initiated for NC0033782 Gatesville Elementary School WWTP Robbie, will you please review the above permit and send comments if any to Derek. Thanks! Robert From: Denard, Derek Sent: Monday, December 11, 2017 4:54 PM To: Tankard, Robert <robert.tankard(dncdenr.gov> Subject: Drafting Initiated for NC0033782 Gatesville Elementary School WWTP Robert, I have initiated drafting for NCO033782 Gatesville Elementary School WWTP. Please let me know if you have comments. I do have a staff report dated September 26, 2017. 1 will be submitting a draft for public notice this week. Thanks, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard al�ncdenr.00v N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. a Publisher's Certificate of Publication STATE OF NORTH CAROLINA Public Notice North Carolina Environmental COUNTY OF GATES Management Commission/ NPDES Unit 1617 Mail Service Center Tony Clark, being du=stated n, on oath says he Raleigh, NC 27699-1617 is and during all times has been an Notice of Intent to Issue a employee of Roanoke-Chowan Publications, Inc. NPDES Wastewater Permit publisher and printer of the The Roanoke-Chowan News -Herald (the "Newspaper"), has full knowledge The North Carolina Environ- mental Management Com- of the facts herein stated as follows: mission proposes to Issue a NPDES wastewater discharge 1. The Newspaper printed the copy of the matter permit to the person(s) listed attached hereto (the "Notice") was copied from the below. Written comments columns of the Newspaper and was printed and beac re- garding the proposed dayspermwill columns P be accepted until 30 days after published in the English language on the following the publish date of this notice. days and dates: The Director of the NC Division of Water Resources (DWR) may hold a public hearing should 12/19/17 there be a significant degree of public interest. Please mad 2. The sum charged by the Newspaper for said comments and/or information publication is the actual lowest classified rate paid requests to DWR at the above p address. Interested persons by commercial customer for an advertisement of may visit the DWR at 512 N. similar size and frequency in the same newspaper Salisbury Street, Raleigh, NC to in which the Notice was published. review information on file. Ad- ditional information on NPDES permits and this notice may be 3. There are no agreements between the News- found on our website: http:// paper, publisher, manager or printer and the officer deq.nc.gov/about/divisions/ or attorney charged with the duty of placing the at- water-resources/water-resourc- tached legal advertising notice whereby any advan- es-ppermits/wastewater-branch/ 9 9 npdes-wastewater /ppublic-notic- tage, gain or profit accrued to said officer or attorney es,or by calling (919) 807-6397. Public Schools of Gates County applied to renew NPDES permit for their Galesville Elementary School WWTP [NC0033782], 709 North Main Street, Gates- ville, discharging treated do- mestic wastewater to Bennett LV Creek, Chowan River Basin. Tony Clark, publisher Subscribed and sworn to before me this 19th Day of December, 2017 1 f _Il1 _ / . , sr-.2 A- . Terri L. Smith, Notary Public State of North Carolina My commission expires March 3, 2021 Account # WNL00006744 Ad # 395911 NCDENR-DIVISION OF WATER RESOURCES 1617 MAIL SERVICE CENTER RALEIGH NC 27699 State of North Carolina Division of Water Resources Water Quality Regional Operations Section Environmental Staff Report Quality To: M NPDES Unit ❑ Non -Discharge Unit Attn: Derek Denard From: Will Hart Washin on Regional Office 33782 Application No.: NC003= Facility name: Galesville Elementary School WWTP Note: This form has been adapted from the non -discharge facility staff report to document the review of both non discharge and NPDES permit applications and/or renewals Please complete all sections as they are applicable I. GENERAL AND SITE VISIT INFORMATION RECEIVEMCDEUDWR 1. Was a site visit conducted? ❑ Yes or M No a. Date of site visit: SEP 2 6 2017 b. Site visit conducted by: Water Q alitY c. Inspection report attached? ❑❑ Yes or No Permitting Section d. Person contacted: _ and their contact information: (_) ext. e. Driving directions: 2. Discharge Point(s): BIMS location coordinates are inaccurate. Following are more accurate: Latitude: 36.24.44 Longitude: 76.45.12 3. Receiving stream or affected surface waters: UT to Bennett's Creek Classification: C; NSW River Basin and Subbasin No. Chowan River (03-01-01) Describe receiving stream features and pertinent downstream uses: H. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? M Yes ❑ No ❑ N/A ORC: Certificate #: Backup ORC: _ Certificate #: 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? M Yes or ❑ No If no, please explain: Description of existing facilities: The description in the current permit appears to be correct. Proposed flow: 0.005 MGD Current permitted flow: 0.005 MGD Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc.) 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? M Yes or ❑ No If no, please explain: FORM: WQROSSR 04-14 Page I of 3 e 4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? ❑ Yes or ® No If yes, please explain: 5. Is the residuals management plan adequate? ® Yes or ❑ No If no, please explain: 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No If no, please explain: 7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A If no, explain and recommend any changes to the groundwater monitoring program: 8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No If yes, attach a map showing conflict areas. 9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No If no, please explain: 10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no, please explain: 11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A 12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No Please summarize any findings resulting from this review: Self monitoring does not reveal any compliance issues. Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. 13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No If yes, please explain: 14. Check all that apply: ® No compliance issues ❑ Notice(s) of violation ❑ Current enforcement action(s) ❑ Currently under JOC ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been working with the Permittee? Is a solution underway or in place? Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A If no, please explain: 15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ®No❑N/A If yes, please explain: 16. Possible toxic impacts to surface waters: 17. Pretreatment Program (POTWs only): M. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No If yes, please explain: 2. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office ® Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ❑ Issue ❑ Deny (Please state reasons: ) FORM: WQROSSR 04-14 Page 2 of 3 3. Signature of report preparer: Signature of regional supervisor: Date: � Z � 7— IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS An inspection was not conducted for this review. The Regional Office inspector is scheduled to perform a routine compliance inspection in October 2017 FORM: WQROSSR 04-14 Page 3 of 3