On February 29, 2024, the Division Director of ECAD, EPA R3 issued an Administrative Order for Compliance on Consent ( Order ) under Section 309(a) of the Clean Water Act ( CWA or Act ), 33 U.S.C. 1319(a) to AdvanSix for their Hopewell Plant located at 905 East Randolph Road in Hopewell, VA. The violations include failing to minimize, reduce or eliminate benchmark pollutants to the extent achievable, and failure to contain unpermitted dry weather discharges through stormwater outfalls. These failures are ongoing violations of Respondent's individual Virginia Pollutant Discharge Elimination System ( VPDES ) permit (VA0005291) issued under 402 of the CWA, 33 U.S.C.1342 and Section 301 of the CWA, 33 U.S.C. 1311. Under the AOC, Respondent will perform corrective action measures which include: 1) submission of a Source Identification and Dry Weather Discharge Elimination Plan to identify, characterize and eliminate any unknown sources of water contributing to unpermitted, dry weather stormwater discharges; 2) revisions to Respondent's SWPPP to implement additional control measures to address the Benchmark exceedances; and 3) a formal request to VDEQ, seeking permanent retirement of a portion of AdvanSix's Total Nitrogen waste load allocation by 216,000 lbs/yr. and amend the Watershed General Permit Registration List effective January 1, 2024. Simultaneously, Respondent will voluntarily limit the discharge of Total Nitrogen from the Facility to 874,798 lbs./yr, 216,000 lb/yr