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DATA TRACKING AND TECHNICAL FACT SHEET WPED PRETREATMENT PERMIT REISSUANCE

APPLICANT Metal Finishing Technologies, LLC

PERMIT NO. SP0001442

APPLICATION NO. 201614909

DATE APPLICATION RECEIVED November 28, 2016

LOCATION ADDRESS 60 Wooster Court Bristol, CT 06010

FACILITY CONTACT Francine Ocampo Office Phone: (860) 582-9517 ext:15 Email: [email protected]

MAILING ADDRESS 60 Wooster Court Bristol, CT 06010

DMR CONTACT Francine Ocampo Office Phone: (860) 582-9517 ext:15 Email: [email protected]

PERMIT TERM 5 Years

PERMIT CATEGORY PRETREATMENT SIGNIFICANT INDUS USER(SIU) PRETREATMENT CATEGORICAL (CIU)

SIC CODE(S) 3471

PERMIT TYPE Reissuance

OWNERSHIP Private

WATER POLLUTION CONTROL FACILLITY Discharge to City of Bristol Water Pollution Control Facility via (“WPCF”) THAT RECEIVES THE DISCHARGE its collection system. NPDES Permit No.CT0100374 Receiving Waterbody: Pequabuck River

DEEP STAFF ENGINEER Patrick Bieger

TENTATIVE DECISION FACT SHEET DATE April 20, 2020

SOLVENT MANAGEMENT PLAN ☒ ☐ Is the facility operating under an approved solvent management plan (SMP)? Yes No ☐ N/A If yes, indicate date issued: October 30, 2019

PERMIT FEES

Application Fee: Filing Fee Cost: $1,300 Date Paid: 11/29/2016 Processing Fee Cost: $18,462.50 Date Paid: 12/21/2016

Annual Fee: MAXIMUM Gallons DISCHARGE ANNUAL CATEGORY Per Day (“GPD”) or DSN CODE (per 22a-430-7) FEE CATEGORY (per 22a-430-7) 501935Z Metal Finishing (to POTW’s) 225,000 001-1 $8,425 Blowdown from Heating and Cooling Equipment 5170000 ---- 001-1 $4,337.50 (Boiler Blowdown: Chiller Blowdown) Water Production (Backflow preventer test water; Reject 5060000 and backwash water from deionization system) ---- 001-1 $775 TOTAL 225,000 $13,537.50

I. APPLICANT

On November 28, 2016 the Department of Energy and Environmental Protection received an application (Application No. 20161409) from Metal Finishing Technologies, LLC seeking renewal of Permit No. SP0001442 authorizing the discharge of wastewater associated with metal finishing at its facility in Bristol. This application was public noticed in The Bristol Press on November 3, 2016. On April 10, 2017, the application was determined to be timely and administratively sufficient.

II. NATURE OF THE BUSINESS GENERATING THE DISCHARGE

The applicant seeks authorization for the following: PROPOSED PROPOSED AVERAGE MAXIMUM TREATMENT DISCHARGE DSN MONTHLY DAILY PROPOSED WASTESTREAMS TYPE TO FLOW FLOW (gpd) (gpd) Acid/Alkaline rinse waters, copper cyanide rinse waters, chromate rinse waters, acid solutions, electroless nickel solution rinses, copper and cadmium cyanide rinse waters, Equalization, dye rinse waters, zinc chloride rinse waters, dye and sealer pH rinse waters, copper and zinc cyanide rinse waters, Neutralization, acidic/basic solutions, alkaline permanganate solution rinse Hexavalent City of waters, zinc nickel rinse waters, scrubber water, wash water Chromium Bristol Water 001-1 175,000 225,000 generated from rinsing drums/containers, cleaning parts, Treatment, Pollution and cleaning filters, laboratory wastewaters, floor spillage, Cyanide Control floor cleaning wastewater, groundwater infiltration, boiler Destruction, Facility blowdown and condensate, chiller blowdown, backflow Flocculation, preventer test water, reject and backwash water from the and Settling deionization system, fire suppression test water, storm water SIC: 3471

III. BACKGROUND/PERMIT HISTORY

Metal Finishing Technologies, LLC is a business that performs metal finishing processes as a job shop. The treatment system is used to treat wastewater from metal finishing processes, boiler blowdown, chiller blowdown, backwash from deionization system, and backflow preventer test water. This wastewater is discharged to The Bristol Water Pollution Control Facility by way of DSN 001-1 under this proposed permit.

Compliance/Enforcement Below is a list of all WPED enforcement actions closed within the last 5 years or are currently open.

NOV No. WRIN14008 Issued: 04/21/2014 Closed: 8/16/19 The facility violated several effluent limitations for nickel, amenable cyanide, and pH.

FNOV No. WRIN15207 Issued: 07/21/2015 Closed: 8/31/15 The facility failed to report releases to the environment that were documented in monthly inspections and failed to follow up on the findings in their monthly inspections.

FNOV No. WRIN16210 Issued: 09/08/2016 Closed: 12/16/16 The facility failed to properly report hexavalent chromium violations and failed to monitor for silver in June 2016.

Metal Finishing Technologies, LLC had a compliance schedule for lead in the previous permit that required meeting a lower set of limits for lead. The facility was able to meet the conditions of the compliance schedule and has been able to meet the limits in section 4 of their previous permit before the end of the compliance schedule. The scope of study required by paragraph 7(A)(2) of the previous permit was approved on November 27, 2012. The comprehensive and thorough report which describes and evaluates alternative actions to achieve compliance required by paragraph 7(A)(3) of the previous permit was approved on June 3, 2014. Yes No Is the Permittee subject to an ongoing enforcement action? If yes, provide a brief explanation; include discussions of any issues relevant to the activities regulated under the permit.

Fact Sheet for PERMIT No. SP0001442 2

Yes No Does the Permit contain a compliance schedule? If yes, please check all that apply. Pollution Prevention Water Conservation Remediation

Water Quality Requirement Treatment Requirement Other

A compliance schedule is included in this permit to address structural repairs to Metal Finishing Technologies, LLC’s in-ground equalization tanks. During DEEP’s site visit on August 19, 2019 structural damage was observed in all four of Metal Finishing Technologies, LLC’s in-ground tanks. The facility has been collecting quotes for structural analysis and relining of these tanks. The first stage of structural analysis is tentatively planned for April 10th, 2020. The compliance schedule is being used as a mechanism to track the progress of the refurbishing process due to the complexity of the testing and potential repairs. The schedule requires the Permittee to create and follow improved operation and maintenance and best management practices for these tanks. The Permittee will also regularly investigate any possible release(s) that may have occurred from these in-ground storage tanks and properly respond to such release(s). No evidence of a release from the in-ground storage tanks has been previously reported by the Permittee or discovered during DEEP’s pretreatment permit compliance inspections.

Modifications Yes No Within the last five years, have there been any permit modifications?

January 15, 2015: Application No: 201410211, received 10/10/2014 and amended on 5/19/14, 7/21/14, 9/4/14, and 12/24/14. The approved RCSA section 22a-430-3(i)(3) modifications involved installing three permanent basins for acid/alkali, chromium-bearing and cyanide-bearing wastewaters, and to make piping modifications in the washout area.

September 2, 2015: Application No: 201505445, received 8/7/2015 the approved RCSA section 22a-430- 3(i)(3) modification requested to replace the pump that feeds caustic into the equalization tank in the system.

August 4, 2017: Application No. 201704133, received 5/5/2017 with supplemental documentation added 6/5/2017 and 7/18/2017. The approved RCSA section 22a-430-3(i)(3) modifications involved the use of Hubbard Hall Aquapure T-1000 as an additional metal precipitant during cold weather.

October 30, 2019: Application Nos. 201912307 and 201912309, received October 9, 2019 the approved RCSA section 22a-430-3(i)(2) modification requested to start an acid zinc nickel plating process, an alkali zinc nickel plating process, a nickel flash process, complete fluorescent penetrant inspections of parts, an in-line treatment tank with a 700 gallon working volume, and the usage of Aquapure OX-C as a treatment chemical.

IV. THE ON-SITE WASTEWATER TREATMENT SYSTEM

This Facility utilizes both equalization for chromium bearing waste waters and cyanide bearing waste waters, a floor spill equalization tank, and acid/alkali equalization tank.

All waters from the chromium equalization tank (“EQ tank) flow into the chromium treatment tank, where hexavalent chromium is converted to trivalent chromium. After this treatment the wastewaters gravity flow to the neutralization treatment tank.

The floor spill equalization tank is tested for the presence of chromium. If hexavalent chromium is found present, it is treated with sodium hydrosulfate in the floor spill EQ tank. After treatment the pH is raised to 10-11 S.U. and pumped into the CN 1 treatment tank.

The cyanide bearing wastewater is pumped from the CN EQ tank to the CN 1 treatment tank where cyanide is destroyed at a pH between 11.0 and 11.5 S.U. where a solution of sodium hypochlorite is added. This water then gravity flows into the CN 2 treatment tank where the pH is reduced to between 8.0 and 9.5 S.U. In this range cyanide is further destroyed through the addition of a sodium hypochlorite solution. After this treatment the waters gravity flow to the neutralization treatment tank for further treatment.

Fact Sheet for PERMIT No. SP0001442 3

The Acid/Alkali equalization tank is pumped into the neutralization treatment tank. The neutralization tank is pH adjusted to treat for heavy metals. Coagulants are added to the neutralization tank and the wastewaters are pumped to a pump station tank. A vacon pump then carries water from the pump station tank to the flocculation tank where polymer is added and metals begin to precipitate. This wastewater then gravity flows into a small mixing tank that will gravity flow into a where the metals settle out. The settled metals are gravity fed from the bottom of the clarifier into a transfer tank. This tank is then pumped to a sludge holding tank where the sludge settles. Water from this tank is decanted and pumped back into the CN equalization tank. The sludge is filter pressed and the filtrate is pumped into the CN equalization tank. The dried sludge is then stored for removal as F006 hazardous waste.

V. EFFLUENT GUIDELINES

Metal Finishing Technologies, LLC is subject to 40 CFR 433.17 Pretreatment standards for new sources because the facility performs coating and plating of metals, which are listed as core metal finishing operations as defined in 40 CFR 433.10. The discharge started in 1987 which is after the promulgation of limits for the metal finishing category. This classifies the effluent of Metal Finishing Technologies, LLC as a new source.

VI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

DISCHARGE BASIS FOR LIMITS, STANDARDS OR CONDITIONS REGULATION POINT(S) Federal Effluent Limitation Guideline (“ELG”) Pretreatment Standards for Existing Sources (“PSES”) Pretreatment Standards for New Sources (“PSNS”) 40 CFR 433.17 001-1 Performance Standards Section 22a-430-4(s) of the Regulations of Connecticut State 001-1 Agencies (“RCSA”) Case-by-Case Determination using Best Professional 001-1 Judgment (“BPJ”) Other (i.e. Department File Information, Treatability

Manual, Federal Development Document)

A. MONITORING PARAMETERS & LIMITS:

DSN 001-1 40 CFR 433.17 RCSA section 22a-430-4(s)(2) BPJ Average Maximum Instantaneous Average Maximum Instantaneous Average Maximum PARAMETER Units Instantaneous Monthly Daily Monthly Daily Monthly Daily

Cadmium, Total mg/l 0.07 0.11 NA 0.07 0.11 0.75 0.07 0.11 0.16 Chromium, Total mg/l 1.71 2.77 NA 1.0 2.0 3.0 1.0 2.0 3.0 Cobalt, Total mg/l NA NA NA NA NA NA 1.0 2.0 3.0 Copper, Total mg/l 2.07 3.38 NA 1.0 2.0 3.0 1.0 2.0 3.0 Cyanide, Total Amenable mg/l NA NA NA 0.1 0.2 0.3 0.1 0.2 0.3 Cyanide Total mg/l 0.65 1.2 NA 0.65 1.2 NA 0.65 1.2 1.2 Flow, Average Daily gpd NA NA NA NA NA NA 175,000 NA NA Flow, Maximum Daily gpd NA NA NA NA NA NA NA 225,000 NA Flow (Day of Sampling) gpd NA NA NA NA NA NA NA 225,000 NA Fluoride, Total mg/l NA NA NA 20 30 40 10 15 22 Hexavalent Chromium, mg/l NA NA NA 0.1 0.2 0.3 0.1 0.2 0.3 Total Gold Total mg/l Parameter removed from permit Lead, Total mg/l 0.43 0.69 NA 0.1 0.5 0.75 0.03 0.06 0.09 Nickel, Total mg/l 2.38 3.98 NA 1.0 2.0 3.0 1.0 2.0 3.0 pH, Day of Sampling S.U. NA NA NA NA NA NA NA NA 6-10 pH, Minimum S.U. NA NA NA NA NA NA NA NA 6 pH, Maximum S.U. NA NA NA NA NA NA NA NA 10 Phosphorus, Total mg/l NA NA NA NA NA NA ------NA Silver, Total mg/l 0.24 0.43 NA 0.1 0.5 0.75 0.1 0.43 0.64 Tin, Total mg/l NA NA NA 2.0 4.0 6.0 2.0 4.0 6.0 mg/l NA NA NA NA NA NA ------Total Toxic Organics mg/l NA 2.13 NA NA NA NA NA 1.0 1.0

Fact Sheet for PERMIT No. SP0001442 4

40 CFR 433.17 RCSA section 22a-430-4(s)(2) BPJ Average Maximum Instantaneous Average Maximum Instantaneous Average Maximum PARAMETER Units Instantaneous Monthly Daily Monthly Daily Monthly Daily

Zinc, Total mg/l 1.48 2.61 NA 1.0 2.0 3.0 1.0 2.0 3.0

DSN 001-A Removed from Permit 40 CFR 433.17 RCSA section 22a-430-4(s)(2) BPJ Average Maximum Instantaneous Average Maximum Instantaneous Average Maximum PARAMETER Instantaneous Monthly Daily (mg/L) Monthly Daily (mg/L) Monthly Daily (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L) Hexavalent Moved to DSN 001-1 Chromium

B. COMMENTS ON SPECIFIC PARAMETERS:

State pretreatment permits fully incorporate the state's water discharge regulations at RCSA section 22a- 430 et.al., including the prohibitions of RCSA section 22a-430-4(t), the general pretreatment standards of 40 CFR 403 and federal categorical standards (as applicable), as well as technically-based local limits where necessary to control specific pollutants of concern. DEEP maintains full authority to enforce all conditions and requirements, including effluent limitations, incorporated into state pretreatment permits. EPA may also enforce limits incorporated into state permits that are technically-based and which have been developed in accordance with the general standards of 40 CFR 403. Local limits not incorporated into state pretreatment permits remain enforceable by the municipality as allowed by the local ordinance. At this time, no technically-based local limits for the monitoring parameters addressed by this permit have been developed to regulate discharges to the Bristol POTW.

DSN 001-A

DSN 001-A will be removed from this permit. During technical review it was discovered that additional hexavalent chromium is being treated in the floor spill equalization tank. This wastewater is not sampled and reported for hexavalent chromium concentrations as it does not flow through the hexavalent chromium treatment tank. Therefore, instead of making an additional sampling point from the floor spill equalization tank, discharge of the equalization tank hexavalent chromium will be sampled at the final discharge monitoring location only to be fully inclusive of all hexavalent chromium containing discharges.

DSN 001-1

Cadmium, Total

There are limits for cadmium in both 40 CFR 433.17 and RCSA section 22a-430-4(s)(2). The average monthly limit (AML) and maximum daily limit (MDL) are consistent with previous permit limits. The instantaneous limit (IL) of 0.16 mg/l is derived by multiplying the MDL of 0.11 by 1.5 and rounded down to two significant digits in accordance with RCSA section 22a-430-4(m) and standard practice. This IL is the most stringent and is implemented into this permit. These are the same limits as those found in the previous permit.

Chromium, Total

There are limits for chromium in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The limits found in RCSA section 22a-430-4(s) are most stringent and are used in this permit. These are the same limits as those found in the previous permit.

Cobalt, Total

There are no limits for cobalt in 40 CFR 433.17 or RCSA section 22a-430-4(s). The facility uses cobalt in its metal finishing processes and has had cobalt limits in its previous permits. Therefore, cobalt will remain a monitoring requirement with the same limits as those in the previous permit to prevent backsliding in accordance with RCSA section 22a-430-4(l)(4)(D)(vi).

Copper, Total

Fact Sheet for PERMIT No. SP0001442 5

There are limits for copper in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The limits found in RCSA section 22a-430-4(s) are the most stringent and are used in this permit. These are the same limits as those found in the previous permit.

Cyanide, Total Amenable

There are limits for total amenable cyanide in RCSA section 22a-430-4(s). These are the same limits as those found in the previous permit. Total amenable cyanide is monitored from the final outfall. Metal Finishing Technologies, LLC sent a report that was approved in 2002 showing that there was additional cyanide treatment in the final clarifier. Thus monitoring for total amenable cyanide is done at the end of pipe and not after the cyanide treatment tanks.

Cyanide, Total

There are limits for cyanide in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The AML and MDL are consistent with previous permit limits. The IL of 1.2 is implemented in this permit in accordance with RCSA section 22a-430-4(m) and standard practice.

Fluoride, Total

There are limits for fluoride in RCSA section 22a-430-4(s). These limits are less stringent than the limits used in the previous permit. The limits from the previous permit will be implemented into this permit to prevent backsliding in accordance with RCSA section 22a-430-4(l)(4)(D)(vi). These limits were derived from Metal Finishing Technologies, LLC’s 1992 permit and the maximum instantaneous limit has been updated in accordance with standard practice.

Hexavalent Chromium

There are limits for hexavalent chromium in RCSA section 22a-430-4(s). These limits are the most stringent and are implemented in this permit. These are the same limits as those found in the previous permit.

Gold, Total

Gold monitoring and limits are removed from this permit. Metal Finishing Technologies, LLC had a gold stripping process and a gold plating process when their first permit was issued. Metal Finishing Technologies, LLC has since removed these processes from their facility. Metal Finishing Technologies, LLC does clean airplane parts and this process does contain gold, however only the second rinse gets sent to the treatment system. A review of Metal Finishing Technologies, LLC’s reported monthly monitoring shows that gold has not been detected in their discharge since April 2015.

Lead, Total

There are limits for lead in both 40 CFR 433.17 and RCSA section 22a-430-4(s). Metal Finishing Technologies, LLC discharges to Bristol, which has POTW specific limits in the General Permit for the Discharge of Wastewaters from Categorical Industrial Users to a Publicly Owned Treatment Works. The limits found in the Categorical General Permit are the most stringent and are implemented in this permit. These limits are the same limits as those found in the previous permit.

Nickel, Total

There are limits for nickel in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The limits found in RCSA section 22a-430-4(s) are the most stringent and are implemented in this permit. These limits are the same limits as those found in the previous permit.

pH

Fact Sheet for PERMIT No. SP0001442 6

The limits for pH from the previous permit will be implemented into this permit. A low pH of 6.0 S.U. and a high pH of 10.0 S.U. are considered to be protective of systems.

Phosphorus, Total

Phosphorus monitoring is required for this permit renewal. Metal Finishing Technologies, LLC reported a phosphorus level of 17.6 mg/l in Attachment O of their renewal application (No. 201614909). Metal Finishing Technologies, LLC also uses phosphoric acid as a process chemical. DEEP is implementing lower phosphorus limits into NPDES discharge permits for POTWs and phosphorus monitoring from industrial users discharging to POTW’s will be necessary to determine loading to an individual POTW.

Silver, Total

There are limits for silver in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The AML from RCSA section 22a-430-4(s) and the MDL from 40 CFR 433.17 are implemented into this permit as they are the most stringent limits for silver. The IL of 0.64 mg/l is derived by multiplying the MDL of 0.43 by 1.5 and rounded down to two significant digits in accordance with RCSA 22a-430-4(m) and standard practice. This IL is the most stringent and is implemented into this permit. These are the same limits as those found in the previous permit.

Tin, Total

There are limits for tin in RCSA section 22a-430-4(s). These limits are the most stringent and are implemented in this permit. These are the same limits as those found in the previous permit. Total Suspended Solids

Suspended Solids, Total

There are no limits specified for total suspended solids in RCSA 22a-430-4(m). This parameter will remain monitoring only with no limits. DMRs from January 2017 to January 2020 show low levels for TSS with the maximum reported concentration of 26 mg/l, which are below the level that may pose an impact for the POTW. Monitoring for total suspended solids is used to evaluate the quality of the facilities discharge and efficiency of the treatment system.

Total Toxic Organics

There are limits for total toxic organics in 40 CFR 433.17. The previous permit used an IL of 1.0 mg/l. This permit adds a MDL of 1.0 mg/l and keeps the IL of 1.0 mg/l these are the most stringent limit for TTO’s. Metal Finishing Technologies, LLC has an approved solvent management plan that allows a monitoring waiver for total toxic organics.

Zinc, Total

There are limits for zinc in both 40 CFR 433.17 and RCSA section 22a-430-4(s). The limits from RCSA section 22a-430-4(s) are the most stringent and are implemented in this permit. These limits are the same as those found in the previous permit.

Monitoring Frequency

DSN 001-1

Weekly monitoring is required by the monitoring schedule set forth in RCSA section 22a-430-3 for a metal finishing discharge with a flow above 5,000 gpd. Total cadmium, total chromium, total cobalt, total copper, hexavalent chromium, amenable cyanide, total cyanide, total fluoride, total nickel, total suspended solids, and total zinc have a weekly monitoring frequency, which are carried over from the previous permit. These parameters are all used in active processes at Metal Finishing Technologies, Inc.

Using case by case determination and best professional judgement pursuant to RCSA section 22a-430-4(m) the following monitoring frequency requirements will be at an alternative frequency;

Fact Sheet for PERMIT No. SP0001442 7

Total Tin has a semi-annual monitoring frequency. Metal Finishing Technologies, LLC previously had an active metal finishing line using tin and has not reported a detectable level of tin in its discharge since January 2016. This line is currently inactive but still at the facility so monitoring will still be required for this parameter.

Phosphorus has a weekly monitoring frequency. Data is needed to determine phosphorus loading to POTWs and to determine possible limits on discharges that contain phosphorus. A weekly monitoring frequency will allow for more data to be collected before the next permit renewal.

Silver remains a semi-annual monitoring requirement. Metal finishing Technologies, LLC does not use silver in its processes and has not reported a detectable level of silver in its discharge since June 2016. However, silver is a parameter that is required by 40 CFR 433.17. Therefore, silver will only be monitored on a semi- annual basis.

Total Toxic Organics remains a monthly monitoring requirement, which is carried over from the previous permit. Total toxic organics are not expected to be present in the discharge by following the approved solvent management plan.

Lead has a semi-annual monitoring frequency. Metal Finishing Technologies, LLC has discharged a recordable level of lead twice in the last two years. The max recorded value was 0.052 micrograms per liter. Due to this lead was changed to semi-annual monitoring from weekly monitoring.

Sample Type

Total cadmium, total chromium, total cobalt, total copper, total fluoride, total lead, total nickel, total silver, total tin, total phosphorus, total suspended solids, total zinc, and total toxic organics all have a sample type of daily composite required pursuant to 40 CFR 403.12 and RCSA section 22a-430-3(j)(7).

Amenable cyanide, total cyanide, and hexavalent chromium have a sample type of grab sample average. Due to hexavalent chromium’s test method requiring a short holding time a composite sample would not be appropriate to assure accurate results. Total Cyanide and amenable cyanide have a sample type of grab sample average pursuant to 40 CFR 403.12(g)(3).

VII. PERMITS FOR OTHER DISCHARGES

Stormwater Industrial Activity General Permit Permit No. GSI000301

VIII. COMMENTS RELATED TO THE PUBLIC NOTICE

Notice of Tentative Decision was published in ____ on ____. The comment period ended on _____. The Department has received [no] [the following] written comments on the proposed action: Pick the one that applies.

Comments If Any

The Bureau of Materials Management and Compliance Assurance staff has reviewed the written comments and does not feel that the tentative determination should be modified. Provide Reasons

The Bureau of Materials Management and Compliance Assurance staff has reviewed the written comments and recommends the following changes in the [tentative determination] [draft permit]. Pick the one that applies.

(NOTE: Staff needs to ensure that the language in this section matches what is in the Final Determination Memo)

Use this language if 15 day notice was used: A 15 Day Notice was signed ____. sent email correspondence on____ waiving the fifteen (15) day comment period offered in the notice.

Patrick Bieger was assigned this application on January 15, 2019

Fact Sheet for PERMIT No. SP0001442 8

Facility received draft permit and fact sheet on January 28, 2020. The facility requested to update the attached process diagrams, specify that phosphorus is used as a process chemical, and to change the floor spill treatment description.

POTW received draft permit and fact sheet on January 28, 2020 and acknowledged receipt of the drafts on January 28, 2020. No comments were received.

Fact Sheet for PERMIT No. SP0001442 9