1) The permittee has informed EPA that it cannot meet the dates in the permit to complete the local limit development process. Since the permittee will not complete the development process by finalizing and incorporating the proposed local limits into the industrial user permits as established in its NPDES permit, the permittee will be in noncompliance with requirements in its NPDES permit.
2) The permittee shall comply with the requirements in accordance with the new schedule which will extend its time from 4 months to 12 months. By Noveember 30, 2007, the permittee shall have incorporated final local limits into industrial users permits. No later than fourteen (14) calendar days following a date identified in the above schedule, the permittee shall submit a report of progress and a written notice of compliance or noncompliance with the condition. In the case of noncompliance, the notice shall include the cause of the noncompliance, any remedial actions taken, and the time it will take to complete the required action.