7/28/16 - ADMINISTRATIVE ORDER ON CONSENT.
ALLEGATIONS:
RESPONDENT HAS FAILED TO COMPLY WITH THE FOLLOWING PERMIT REQUIREMENTS:
A. RESPONDENT FAILED TO SAMPLE AND REPORT MONTHLY TOTAL HARDNESS CONCENTRATIONS IN ACCORDANCE WITH THE PERMIT FROM MARCH THRU OCT 2011, IN JULY 2013, IN OCT 2013, IN JULY 2014, IN SEPT 2014, AND IN JULY 2015.
B. RESPONDENT FAILED TO SAMPLE AND REPORT MONTHLY COPPER CONCENTRATIONS IN ACCORDANCE WITH THE PERMIT FROM JUNE THRU JULY 2015, AND IN OCT 2015.
C. RESPONDENT REPORTED COPPER CONCENTRATIONS IN UNITS OF MG/L INSTEAD OF UG/L CONVERTED REPORTED VALUES TO UG/L AND CALCULATING THE COPPER EFFLUENT LIMITATIONS IN ACCORDANCE WITH THE PERMIT, RESPONDENT EXCEEDED THE COPPER MONTHLY AVERAGE, WEEKLY AVERAGE, AND DAILY MAXIMUM.
EPA ISSUED A NOV TO RESPONDENT ON APR 25, 2016. IN RESPONSE, RESPONDENT SUBMITTED A PROPOSAL FOR CORRECTIVE ACTION ON MAY 6, 2016, TO ADDERSS DMR MONITORING AND REPORTING. IN ADDITION, RESPONDENT SUBMITTED A COMPLIANCE PLAN FOR COPPER TO ADDRESS THE COPPER VIOLATIONS. THE PLAN PROPOSES TO START WITH THE SIMPLEST, MOST BASIC STEPS AND TO MOVE TOWARD PROGRESSIVELY MORE SOPHISTICATED PROCEDURES, UNTIL AN APPROPRIATE SITE SPECIFIC LIMIT IS DETERMINED BY EPA. SPECIFICALLY, THE PLAN PROPOSES TO:
A. CONFIRM THE ACCURACY OF PREVIOUSLY-REPORTED COPPER PERMIT LIMITATION EXCEEDANCES IN THE CURRENT DATA, WITH CONTINUED MONITORING USING CLEAN SAMPLING AND ANALYTICAL TECHNIQUES.
B. CALCULATE THE DISSOLVED FRACTION OF COPPE