2/10/17-AOC ISSUED.
ON DEC 2-5, 2014, A CONTRACTOR FOR EPA, EPA AND GAEPD, CONDUCTED AN INSPECTION OF RESPONDENT'S MS4 PROGRAM. ON APR 24, 2015, EPA SENT A NOV TO RESPONDENT FOR VIOLATIONS OF THE CWA AND THE PERMIT OBSERVED DURING THE INSPECTION AND REQUESTED THAT RESPONDENT CONTACT EPA TO SCHEDULE A SHOW CAUSE MEETING.
ON JUNE 9, 2015, EPA RECEIVED INFO FROM RESPONDENT IN RESPONSE TO THE NOV.
ON JUNE 10, 2015, A SHOW CAUSE MEETING WAS HELD.
ON JUNE 11, 2015, EPA RECEIVED ADD'L INFO IN RESPONSE TO THE NOV AND INFO REQUESTED DURING SHOW CAUSE.
THE FOLLOWING FINDINGS ARE BASED ON THE INSPECTION, EPA'S REVIEW OF THE DOCS PROVIDED AND THE SHOW CAUSE MTG AND ARE IN VIOLATION OF THE PERMIT:
- RESPONDENT SCREENED ONLY 41 OUTFALLS IN 2013-2014. THEREFORE, RESPONDENT FAILED TO SCREEN AT LEAST 20% OF THE 747 MS4 OUTFALLS THAT YEAR. ATTRIBUTABLE IN PART TO LOSS OF STAFF DURING HIRING FREEZE. CCG MADE UP SOME OF THESE INSPECTIONS AS PART OF A NEGOTIATED SCHEDULE WITH GAEPD.
-RESPONDENT HAS FAILED TO PROVIDE THE NUMBER OF OUTFALLS ADDED DURING THE REPORTING PERIOD AND THE TOTAL NUMBER OF OUTFALLS IN THE INVENTORY IN THE ANNUAL REPTS. ATTRIBUTABLE IN PART TO THE DIFFICULTY CCG HAD IN OBTAINING THEIR DATA FROM A CONTACTOR.
-CONTROL STRUCTURE INSPECTIONS. THE 2012-2013, 2013-2014, AND 2014-2015 ANNUAL REPORTS NOTE THAT THE TOTAL LENGTH OF THE STRUCTURAL CONTROL DITCHES IS UNKNOWN. BECAUSE THE TOTAL LENGTH OF THE DITCHES IS UNKNOWN, IT COULD NOT BE DETERMINED HOW RESPONDENT VE