903R91050
    Targeted Permit Oversight
              EPA Region  III
      General Permits Section

       Francisco Cruz
       Leo Essenthler
       Larry Liu
       Rich Palste
       Kathleen Stager
       Dan Sweeney
       Dale Wlsmer
PA/DC Permits Section

Elaine Harbold
Thomas Henry
Victoria (off
Robert Koroncal
Kevin Magerr
Krlstlne Matzko
Ray Mlhallovlch
Alexander Sllnsky

       Augusts, 1991
TD
223.1
.T37
1991
    U.S. EPA Region III
    Regional Center for Environmental
     Information
    1650 Arch Street (3PM52)
    Philadelphia, PA 19103

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                                                                  Regional Center foi hn\in)rimt.'nt
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                    TARGETED  PERMIT OVERSIGHT
                                                                          U.S. EPA Region III   .
                                                                          Regional Center for Ermronme
                                   EPA  REGION  III
                                                                          Philadelphia, PA 19103

*   INTRODUCTION

          This project examined the problem of regional oversight of all major permits issued by

-         delegated states  in Region  3.   The analysis for Pennsylvania was conducted by the

          Pennsylvania team and the analysis for all other delegated states was conducted by the

          General Permit team.  While the analytical procedures used for all states were the same, the

          conclusions on which permits to target for review were different. This difference can mostly

          be attributed to differences in state programs. Specifically, Pennsylvania has a well defined,

          comprehensive chemical specific program whereas Pennsylvania has a minimal biomonitoring

          program as compared to other states.  A thorough description of  the approach,  data,

          analysis, and recommendations is provided for Pennsylvania. Since the procedures used for

•         the others states are similar, only summary data analysis and recommendations are provided

          after the complete analysis is presented for Pennsylvania.



t
    BACKGROUND


          The five states in Region III were delegated the NPDES permit program between 1974 and

*         1982.  Thus, EPA has been reviewing draft permits issued by each state in the Region for

          a minimum of 9 years as required by 40 CFR 123.24(d) which necessitates review of all draft

          permits in the following categories:
•
                (1) Discharges  into the territorial sea;

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      (2) Discharges which may affect the waters of a State other than the one in which the




          discharge originates;




      (3) Discharges proposed to be regulated by general permits (see 122.28);




      (4) Discharges from publicly owned treatment works with a daily average discharge




          exceeding 1 million gallons per day;




      (5) Discharges of uncontaminated cooling water with a daily average discharge




          exceeding 500 million gallons per day;




      (6) Discharges from any major discharger or from any discharger within any of the




          21 industrial categories listed in Appendix A to  Part 122;




      (7) Discharges from other sources with a daily average discharge exceeding 0.5 (one-




          half) million gallons per day, except that EPA review of permits for discharges of




         non-process wastewater may be waived regardless of flow.




      This requirement is further defined in 40 CFR 123.44 requiring EPA to make general




comments upon, objections to, or recommendations with respect to state proposed permits




as noted above.




      While such intensive oversight was necessary for some time after delegation, it stands




to reason that such oversight should be reduced as a state demonstrates competence in




implementing the permit  issuance program.




      The question for FY '91, is the same level of oversight necessary in light of recent




data?

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DATA




            In order to determine the effectiveness of EPA Region Ill's effort in overviewing




      states' NPDES permit issuance programs, a careful analysis was performed of all permit




      reviews  completed  in  FY'89  and  '90.  The  effectiveness of EPA's oversight  can be




      characterized through the following measures:




            (1) Total number of permit reviews;




            (2) Total number of permits reviews generating comments;




            (3) Total number of comments and permit reviews resulting in state action either by




               modification or explanation of the original draft;




            (4) Total number of comments and permit reviews resulting in  state  action and




               environmental benefit as determined by Section consensus. Environmental benefit




               is broadly defined as a decrease in pounds of pollutant discharged.









            A listing of all permits reviewed  in FY  '89 and '90 by the PA/DC Section with and




      without  comments divided into Industrial, Municipal, and Federal Facilities categories is




      included as Attachment No.  1. For Pennsylvania, verbal as well as written comments were




      included in the analysis.  Additionally, it was assumed that, in the case of permits not issued




      at  the time of this review, the state would incorporate EPA's comments in certain areas




      which historically were always included. For example,  the State of Pennsylvania always




      considers all of EPA's comments on pretreatment, most likely because the program is not




      delegated; therefore, it was assumed that all comments concerning pretreatment would result




      in  modification of the original drafts before issuance of the final  permit. The results of this




      data analysis are represented in Table 1 and in Figures 1 and 2.

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      It is important to note that almost half of all permit reviews (45%) generated no




comments whatsoever.  35% generated environmentally significant comments, while only




21% of permit reviews generated significant comments that were included in the final permit




by the state.




      Figure 1 is a classic Pareto relationship:  100% of our effort yielded only 20% of its




intended benefit.




      The question now becomes: How can we best direct our efforts to maximize benefit




to the environment?

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                                   TABLE I

                              State of Pennsylvania

                   Permit Review of Summary for FY '89 and '90

                          Total Permits Reviewed - 156

                        Total Permit Reviews Generating

                               No Comment - 70

                          Comments in FY '89 and '90
Limit Added

Explain WQ
Limit Derivation

Modify Analytical
Methods

Intern. Mon. Pt.
0
          0
                                                               State
                                                               Action and
Category
Sludge
304(L)
Biomonitoring
Pretreatment
cso
Non-304(l)
Toxics Policy
Include Non-
detect language
in Pt. C of Permit
Tighten Limit
Add Limit
Fecal Coliform
Total
Comments
24
22
15
12
2
14
10

8
5
5
State
Action
24
22
1
12
1
0
10

8
5
5
Environmentally
Significant
0
4
15
12
1
14
0

8
5
0
Environmenta
Significant
0
4
1
12
1
0
0

8
5
0
          0
0
0
0

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                        Comments in FY'89 and '90 (Con't)
                     Total       State
                     Comments   Action
                                     State
                                     Action and
                    Environmentally   Environmentally
                    Significant	Significant
Redirect Flow to Main 1
Treatment Plant
Model Rerun 1
Separate Organic 1
Limit Into Isomers
Include WQ Limits 1
for Non-detectable
Toxic Review 1
Fish Tissue Sampling 1
Specify IWC 1
Metal Finishing
Guidelines 1
Confusing Footnotes 1
1

1
1

1

0
0
1

1
1
1

1
0

0

0
1
0

0
0
1

1
0

0

0
0
0

0
0
TOTALS
132
99*
64
                                                  **
33'
 * Multiple comments possible in one permit review
 ** Resulted from 55 separate permit reviews
*** Resulted from 32 separate permit reviews

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ANALYSIS
            The most effective use of EPA's permit review time from the summaries above is in




      the oversight of permits requiring pretreatment.  12 out of 33 environmentally beneficial




      comments acted upon by the state were in this category. The comments requested the state




      to modify the pretreatment special condition in  the permits to make the pretreatment




      program more enforceable by requiring local limits reevaluation,  development of an




      Enforcement Response Plan, and yearly monitoring. The repetition of this comment to the




      State can be seen as a problem in the issuance process; the state is unaware of the latest




      language approved by EPA to implement the pretreatment program.




            Let  us consider the  next category with the most repetitive comment, sludge.  24




      permit reviews resulted in the suggestion that the following special condition be included:




      "Slurries, sludges, and other solids shall be handled and disposed of in compliance with 25




      PA Code, Chapter 75, 40CFR 257, and Section 405 (d)(4) of the Clean Water Act and its




      amendments." Although incorporated by the state, it was thought that the comment was too




      general to be environmental significant; compliance with 25 PA Code, Chapter 75 is already




      anticipated and there is no way to determine  compliance through NPDES.  However, that




      the state needed to be reminded to include sludge language indicates an emerging process




      problem.   As federal sludge regulations  are promulgated,  much more specific special




      conditions with definitive environmental significance will be necessary.




            There were 15 comments made concerning the need for whole effluent biomonitoring




      requirements to be placed  in permits.  All were considered environmentally significant,




      although the state included only 1  such requirement in the final permit.  The  difficulties

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experienced in attempting  to initiate  whole effluent biomonitoring for  toxics  control in




Pennsylvania are well documented. FY'91 will mark concerted efforts  by the region to




involve the state in this approach to toxics monitoring.  Questions of funding, manpower,




laboratory  availability, central  office  management  decisions,  regional  office  personnel




training, and additional toxicity data collection must be answered. This is both a process and




an implementation problem.




      The 304(L) effort is reflected  in a variety of 22 comments, most of which were




administrative in nature  approving the format of the permit, or questioning the state




concerning scheduled effective dates for pollutants of concern.  These comments were the




result of process modifications to implement 304(L).




      Certain comments were obviously amendable to process modifications as soon as the




analysis was completed.   For example the non-304(L) toxics  policy  and non-detection




language (to specify analytical methods for minimum detection levels) together  accounted




for a total of 24  comments.   These comments  were all generated in  one  Region




(Williamsport) due to start-up problems with aspects of the non-304(L) toxics policy and all




were related to process concerns.  This region, since being advised, will take our  comments




into consideration in all future permits. Draft permits which have been reviewed since this




region was advised have indciated compliance with our comments.




      Additionally, utilization of the permit prep package, a computer driven aid to NPDES




permit writers in the State of Pennsylvania, will help to eliminate most of the  comments




made to tighten or include  new limitations in permits. Many of these comments  resulted




from typographical errors or incorrect  interpretation of a water quality model.




      The results of this data analysis  after process improvements can be seen in Figure 3,

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      which describes targeted review. From this figure it can be seen that if we focus our reviews




      on the first 5 permit review areas only  [sludge, 304(L), biomonitoring, pretreatment and




      CSO], we will risk not making environmentally significant comments  for only 6% of all




      permit reviews. This is clear when Figures 1 and 3 are considered simultaneously.  Out of




      156 total permit reviews from Figure 1,  we will, by reviewing the 5 categories above, only




      risk not making  approximately 10  environmentally  significant comments from Figure 3




      representative of implementation variability which process improvements cannot correct.










PROPOSED SOLUTION




            From this analysis it is apparent that the most expeditious way to direct regional




      manpower to benefit the environment regarding permit review is through targeting such




      reviews. The data suggests that only permits involving new or changing initiatives should be




      reviewed by regional staff.  This  includes all  permits related to pretreatment,  sludge,




      combined sewer overflows, 304(L),  and biomonitoring. All permits  to be issued in these




      categories can be readily identified  before submission to the region.




            It is important to note that we will be performing reviews of a predetermined portion




      of the targeted permits (only CSO or pretreatment language, for example) to obtain a clear




      understanding of how much time will be saved while at least 94%  of the environmental




      benefit achieved through total review is  preserved. Even  estimating generously , targeted




      review will take only 20% of the present level of effort necessary for total review.  This




      translates to a savings of 1 FTE in the PA/DC Permits Section every year that targeted




      review procedures are utilized.




            The trade off is obvious: 80%  of  saved effort  can be reinvested in other more

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                                            8
      pressing environmental initiatives, such as  biomonitoring,  stormwater, sludge,  CSO's,




      pollution prevention, and even additional Total Quality Improvement projects with minimal




      loss of environmental benefit from total permit review, approximately 6%. The relationship




      in resource savings and environmental benefit is demonstrated in Figure 3A.










FORCE-FIELD ANALYSIS




            A force-field analysis was completed and is represented in Figure 4. The major factor




      to be noted is that the environment benefits primarily from the use of targeted oversight.




      Cynthia Dougherty of HQ unofficially approved of a targeted approach, indicating that other




      EPA regions are already employing some variation of this approach.  It has already been




      demonstrated that regional staff will have considerable additional time for  more pressing




      environmental initiatives by targeting  permit reviews.




            As  noted above however, CFR  123.24(d)  now requires review of all major draft




      permits. Environmental groups could become a problem if they interpret targeted review




      as opposing existing regulations.  Given proper background and  understanding of the




      benefits of targeted review, they  will see where the greater benefit lies.









PRESENT STATUS




            As  of this date, Headquarters,  Divisional, and PADER approval  have all been




      obtained.  The PA/DC Permits Section has implemented targeted oversight as proposed in




      this paper.




            It is the State's desire to continue forwarding all draft permits to EPA for review as




      agreed to  in the State/EPA Memorandum of Agreement based on CFR  123.24(d) The

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                              'I CURE 4
                 FORCE-FIELD  ANALYSIS
                 TOTAL PERMIT REVIEW
          TARGETED PERMIT REVIEW
       DRIVING-FORCES
   RESTRAINING FORCES
Jan 91  Proposed Regs CFR 123.24d
Public, Environmental Groups
	>
 - Given proper background to see
   more benefit to the environment

Environment
States
	>

Headquarters (Unofficial)
	>

Staff
	>
  - Allows  us to concentrate on
   upcoming initiatives of  more
   immediate benefit to the
   environment,  such as pollution
   prevention, stormwater, sludge.
Current Regulations  CFR 123.24d

Public,  Environmental Groups

 - If it is their opinion  that EPA
   must do  total review, according
   to the  regs as written today.

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      PA/DC Permits Section will forward a no comment letter on all non-targeted draft permits




      received for review. For FY'91, the PA/DC Permits Section will only review and comment




      on targeted portions of permits identified on the coded list (Attachment 2).




             As problems are found in targeted permit areas in the future, we will involve the state




      more closely in  the process of developing correct permit language to address targeted




      concerns.




             Our goal through this process is the eventual elimination of the need for any permit




      oversight, targeted or otherwise.
MONITOR
            At the beginning of the fourth quarter of FV92, an appropriate number and types




      of issued permits, depending on what the state has issued, will be selected for EPA review




      using the attached checklist (Attachment 3). The results of this review will determine if any




      modification is necessary to improve the process, the date for the next permit review and




      if targets should be added or deleted. Our goal here is to minimize problems in state issued




      permits with a minimum level of effort in  reviewing permits  by regional staff since it has




      been determined that the greatest environmental benefit  does  not result  from mass




      inspection of state draft permits.




            Our ultimate goal is the elimination of the need for any permit review in the State




      of Pennsylvania through the use of process controls.

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                                             10







OTHER DELEGATED STATES




            Similar to the Pennsylvania evaluations, an analysis was made of major permits




      reviewed in Delaware, Maryland, Virginia, and West Virginia covering the two-year period




      in Fiscal Years '89 and '90. During that time frame,  239 permits were reviewed by EPA




      Region III. Tables 2 through 5 and Figure 5 summarize the results of these permit reviews.




            Figure 6 is a Pareto chart showing the kinds of comments generated for the four




      states.  An evaluation of the data shows that a large portion of the comments relate to the




      toxics aspect of NPDES  permit  limitations.   In Figure 6  the  categories of 304(L),




      Biomonitoring, Monitoring, Add Limit, Compliance Date, and Tighten Limit account for 91




      of 111 comments generated, and are considered directly related to the toxics programs. The




      Combined Sewer Overflow (CSO) Control Program also generated a significant number of




      comments (14).  There were two cases where effluent guidelines interpretations were




      addressed and both of those dealt with the Organic Chemicals, Plastics, and Synthetic Fibers




      (OCPSF) industry.  Two comments addressed the pretreatment program which is now fully




      delegated in Maryland,  Virginia and West Virginia.




CONCLUSIONS




            The targeted permit review approach for the four states other than Pennsylvania will




      be limited in scope because all permits must be reviewed regarding water quality-based




      concerns where the vast  majority of comments were generated.  The exception is the




      technology-based requirements for municipal and industrial permits, i.e. secondary treatment




      for municipals and effluent guidelines-based requirements for industrials. However, since




      the OCPSF effluent guidelines  are  relatively new  and  complex and problems were




      encountered as a result of EPA reviews, draft permits involving these guidelines must still

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                                             11






      be reviewed by EPA.  Therefore, EPA should continue to review all major permits, but the



      reviews will focus on all aspects except the non-OCPSF technology-based requirements.  The




      targeted reviews in the four states will  achieve a 23 percent savings of EPA permit review




      resources by eliminating the technology-based portions (See Figure 7).




             Targeted review may be expanded in one or more of the four states during FY '92




      as each of these states establishes regulations and EPA approved programs for the control




      of toxic pollutants. Figure 8 shows a resource savings of 87 percent if water quality-based




      reviews were  not required for all permits.










FOLLOW-UP ACTIONS RECOMMENDED




      1.     During the remainder of FY'91, eliminate the review of technology-based aspects of




      municipal and industrials permits except for the application of OCPSF regulations.




      2.     Once each state finalizes their toxics regulations and procedures, EPA Region III will




      consider further targeting based on a track record of implementation.




      3.     Initially, permit reviews (utilizing Attachment 3) will be conducted of a representative




      sample of major  permits issued during the  12 month period  of targeted  reviews.   The




      reviews will be continued periodically at intervals deemed appropriate by EPA. The decision




      on continuing permit  reviews  periodically will be greatly influenced by the results of the




      initial review.




      4.     The goal of targeted oversight is to eliminate areas of concern for permit review,




      while concentrating on the remaining environmentally  critical areas.  Process controls will




      be utilized to maximize environmental benefit from any targeted  review  performed by




      regional staff.

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                                         12
5.     The ultimate  goal of the targeted approach  and permit review monitoring is to




eliminate all permit  review by regional personnel through process modifications thereby




allowing us to turn our attention to more pressing and rewarding environmental initiatives.

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                                TABLE 2
                              DELAWARE
                      TOTAL PERMITS REVIEWED-20
                                               State Action and
Total
Category Comments
Sludge
cso
Biomonitoring
WET Limit
Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide
Compliance Date
Monitoring
OCPSF
0
0
0
0
0
7
3
0
0
0
6
0
State
Action
0
0
0
0
0
7
3
0
0
0
4
0
Environmentally Environmental!
Significant Significant
0
0
0
0
0
7
2
0
0
0
5
0
0
0
0
0
0
7
2
0
0
0
3
0
TOTAL
16
14
14
12

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                             TABLE 3




                           MARYLAND




                   TOTAL PERMITS REVIEWED-45
                                       State Action and
Total
Category Comments
Sludge 1
CSO 0
Biomonitoring 12
WET Limit 0
Pretreatment 0
ICS (304L) 12
Limit
Modification 1
Add Limit 0
Biocide 0
Compliance Date 0
Monitoring 0
OCPSF 0
State
Action
1
0
12
0
0
12
1
0
0
0
0
0
Environmentally
Significant
1
0
12
0
0
12
1
0
0
0
0
0
Environment*
Significant
1
0
12
0
0
12
1
0
0
0
0
0
TOTALS
26
26
26
26

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                                           TABLE 4

                                           VIRGINIA

                                TOTAL PERMITS RE VIEWED-104
                                                     State Action and
                  Total       State    Environmentally Environmentally
ft     Category    Comments   Action   Significant      Significant
Sludge
cso
Biomonitoring
WET Limit
Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide
Compliance Date
Monitoring
OCPSF
TOTALS
0
1
2
2
1
13
1
8
1
5
0
0
34
0
1
2
2
1
13
1
8
1
3
0
0
32
0
1
1
2
1
13
1
8
1
3
0
0
31
0
1
1
2
1
13
1
8
1
3
0
0
31

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                                     TABLES

                                 WEST VIRGINIA

                          TOTAL PERMITS REVIEWED-77
                                                State Action and
             Total       State    Environmentally  Environmentally
Category      Comments   Action   Significant       Significant

ft


ft



ft


ft


•
Sludge
cso
Biomonitoring
WET Limit

Pretreatment
ICS (304L)
Limit
Modification
Add Limit
Biocide

Compliance Data
Monitoring
OCPSF
0
13
8
4

1
2

0
0
0

1
4
2
0 0
0 2
5 8
0 4

1 1
1 1

0 0
0 0
0 0

1 1
2 4
0 1
0
0
5
0

1
1

0
0
0

1
2
0
     TOTALS    35         10        22                10

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                            ATTACHMENT NO.  1


         FY '89 MUNICIPAL PERMIT REVIEWS GENERATING COMMENTS
PA0020290
Quakertown Borough Mun. Treatment Plant
      A. ICS administrative

PA0025950
Monongahela STP
      A. Sludge language
      B. Sludge survey questions

PA0026468
Lower Bucks County Joint Municipal Authority
      A. Include pretreatment program as requirement

PA0026476
Coaldale-Lansford-Summit Hill
      A. Sludge language
      B. CSO language

PA0026492
Scranton Sewer Authority
      A. Biomonitoring
      B. Sludge language
      C. Sludge survey
      D. -I-A Toxic Review

PA0026531
Downingtown Area Regional Authority
      A. Develop permit limits for total trihalomethane and total halomethane
      B. Put limitations in Pt. C.

PA0026581
Westmoreland-Fazette Municipal Sewage Authority
      A. Sludge language

PA0026701
Morrisville Borough Municipal Authority
      A. Sludge language

PA0026751
Indiana Borough
      A. Sludge language
      B. Sludge survey questions

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PA0026883
Ciry o>r Beaver Falls
      A. Sludge language

PA0026921
Greater Hazleton Joint Sewer Authority
      A.  Sludge language
      B.  Sludge survey questions
      C.  CSO-the combined sewer overflows should be included in DER's CSO Strategy

PA0027316
City of Lebanon
      A. Biomonitoring

PA0029017
Schuylkill Haven
      A.  Sludge language
      B.  Sludge survey questions
      C.  Pretreatment language

PA0035360
Holiday Park STP
      A.  Sludge language
      B.  Sludge survey questions

PA0043729
Allison Park STP
      A.  Sludge language
       B.  Sludge survey questions
 Total      15

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         FY '89 INDUSTRIAL PERMIT REVIEWS GENERATING COMMENTS
PA002143
Penntech Papers, Inc.
      A. 0.02 ppq limit for dioxin in Part A
      B. More  sensitive analytical procedure in Pt. C.
      C. Fish tissue sampling
      D. Specify IWC in Pt. C.

PA0003239
Babcock and Wilcox Co.
      A. ICS administrative

PA0004073
U. S. Steel-Irwin Works
      A. ICS administrative

PA0004472
USS Div. of USX Corp.
      A. ICS administrative

PA0005037
Penelec  Homer City
      A. ICS administrative

PA0005754
J&L Specialty Products Corp.
      A. ICS administrative

PA0006467
Youngwood Electronic  Metals
      A. Biomonitoring

PA0007625
Hedstrom Co.
      A. ICS administrative
      B. Tighten total chromium limit to 2.44 mg/1, technical limit more stringent than
W.Q.

PA0008923
Corning Glass Works, State College
      A. Biomonitoring

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PA0010782
Met Ed-Titus
      A.  Include water quality standard for temperature
PA0022047
Crompton & Knowles Corp.
      A. ICS administrative
      B. Biomonitoring

PA0094510
USS, Div. of USX Corp.
      A. ICS administrative
Total      12

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         FY '90 MUNICIPAL PERMIT REVIEWS GENERATING COMMENTS

PA0020273
Milton Municipal Authority
      A.  Suspended Solids 110 mg/1 to 100 mg/1 (typo)
      B.  Non-304(l)  toxics policy
      C.  Non-detect language

PA0020460
Pennridge Authority
      A.  Pretreatment language

PA0020486
Bellefonte Borough
      A.  Non-304(l)  toxics policy

PA0020621
Waynesboro Borough Authority
      A.  Include footnote on fecal coliform limit

PA0021661
Mars Borough
      A.  Confusing footnote references

PA0021687
Wellsboro Municipal Authority
      A.  Non-304(l)  toxics policy
      B.  Non-detect language

PA0023043
North East Bord
      A.  water quality based effluent limitation needed in Pt. C.

PA0024068
Kennett Square Boro
      A.  Pretreatment language
      B.  Biomonitoring

PA0025933
City of Lock Haven
      A. Biomonitoring
      B. Non-304(l) toxics policy
      C. Non-detect language

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PA0026000
Allentown City Authority
      A.  Pretreatment language

PA0026191
Huntington Boro
      A.  Include footnote on fecal coliform limit

PA0026239
University Area Joint Authority
      A.  Non-304(l) toxics policy

PA0026247
Hatfield Twp. Mun. Auth.
      A.  Explanation of 304(1) pollutant removal

PA0026263
York City WWTP
      A.  Explanation of 304(1) pollutant removal

PA0026361
Lower Lackawanna Valley Sanitary Authority
      A.  Pretreatment language
      B.  Sludge
      C.  Biomonitbring

PA0026387
Saint Mary's Borough Mun. Auth.
      A.  Explain elimination of 304(1) pollutant

PA0026492
Scranton Sewer Auth.
      A.  Include footnote in fecal coliform  limit

PA0026549
Reading City
      A.  Correct schedule dates
      B.  Include WQ limits  for non-detectable
      C.  Tighten silver limit by 2 ug/1 in accordance with WQ model

PA0026662
City of  Philadelphia, S. E. Plant
      A.  Sludge language
      B.  Pretreatment

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PA0026671
City of Philadelphia, S.W. Plant
      A. Sludge language
      B. Pretreatment language

PA0026689
City of Philadelphia, N.E. Plant
      A. Sludge language
      B. Pretreatment language

PA0026786
Pottstown Boro Council, WWTP
      A. Pretreatment language

PA0026972
Exeter Twp WWTP
      A. Pretreatment language

PA0026808
Springettsbury Twp. S.A.
      A. Include WQ limit for nickel

PA0027049
Williamsport San. Auth.
      A.  Non-304(l) toxics policy
      B. Biomonitoring
      C. Non-detect language

PA0027057
Williamsport San. 'Auth.
      A.  Non-304(l) toxics policy
      B.  Biomonitoring
      C.  Non-detect language

PA0027073
Lackawanna River Basin Sewer Auth.
      A.  Sludge language
      B.  Biomonitoring
      C.  Schedule correction

PA0027090
Lackawanna River Basin Sewer Authority
Throop STP
      A. Biomonitoring

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PA0027405
Ephrata Borough WWTP
      A. Internal Monitoring point needed

PA0027553
Pine Creek Mun. Auth.
      A. Non-304(l) toxics policy
      B. Non-detect language

PA0028576
Clarks Summit-South Abington Joint
      A. Sludge language
      B. Schedule correction

PA0028681
Kelly Twp. Mun. Auth.
      A. Non-304(l) toxics policy
      B. Non-detect language
      C. Biomonitoring

PA00371SO
Perm Twp. STP
      A. Include footnote on fecal coliform limit

PA0038482
Fox Twp.
      A. Instantaneous max. for chloroform 0.002 mg/1, not 0.003 mg/1

PA0043257
New Freedom WVYTP
      A. Include footnote on fecal coliform limit
                r
               t
PA0044661
Lewisburg Area Joint Sewer Auth.
      A. Non-304(l) toxics policy
      B. Non-detect language

PA0051624
Square D. Co.
      A. Pretreatment language

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PA0060089
Fernwood STP
      A.  Add Chlorine limit

Total  38

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         FY '90 INDUSTRIAL PERMIT REVIEWS GENERATING COMMENTS
PA0001201
Powerex, Inc.
      A. Explanation of removal of TCE from 304(1) pollutant list

PA0001627
Duquesne Light Co.
      A. Non-detect language

PA0005975
St. Mary's Carbon Co., Inc.
      A. Explain eliminated 304(1) parameter

PA0006254
Arco Chemical Co.
      A. Backsliding - Mercury "monitoring only" to 0.0015 mg/1

PA0006378
Cyclops Corp.
      A. Explain WQ limit derivation

PA0007510
International Paper Co.
      A. Non-304(l) toxics policy

PA0008443
Pennsylvania Power and Light Co.
Montour Steam Electric Station
      A. Non-304(l) toxics policy
      B. Non-detect language

PA0008800
Westfield Tanning Co.
      A. Minor  schedule change for 304(1) limits effective date

PA0008869
PH Glatfelter CCK
      A. Dioxin/Furan -  more sensitive analytical method

PA0008923
Corning Asahi Video Products Co.
      A. Non-304(l) toxics policy

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PA0009202
Cerro Metal Products Co.
      A.  Suspended solids - 110 to 100 mg/1  (typo)
      B.  Non-304(l) toxics policy

PAGO10031
Penelec
Shawmill Steam Elec. Station
      A.  Reroute pollutant  stream in outlying outfall to main treatment plant when
pollutants detected

PA0011134
AT&T Technologies, Inc.
      A.  Biomonitoring
      B.  Include silver in TRE

PA0011762
American Nickeloid
      A.  Biomonitoring
      B.  Explanation of silver limit

PA0012751
Zinc Corp. of America
      A.  New application data not used in model

PA0013129
Carpenter Tech. Corp, Reading
      A.  Hex. chromium limit modified from 0.03 mg/1 to 0.014 mg/1 based on model
recalculation     , .

PA0033367
Gunnison Brothers Tannery
      A.  Phenol limit, 16 mg/1 to 16 ug/1 (typo)

PA0044342
International  Jensen
      A.  Explain WQ limit

PA0070S05
International  Minerals and Chemicals
      A.  Include all 304(1) pollutants in TRE
 Total:  19

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      FY '90 FEDERAL FACILITY PERMIT REVIEWS GENERATING COMMENTS
PAGO10502
Letterkenny Army Depot
      A.  Separate organic pollutant limit into isomers

PA0010987
Tobyhanna Army Depot
      A.  Metal finishing guidelines needed

TOTAL:  2

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        FY '89 MUNICIPAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0025976
PA0026018
PA0026107
PA0026182
PA0026239
PA0026450
PA0027031
PA0027146
PA0027235
PA0027383
PA0027618
PA0028380
PA0028584
PA0028801
PA0034576
PA0051934
PA0052167
PA0110582
Upper Moreland Hatboro Sewage
West Chester Borough Taylor
Wyoming Valley San. Auth.
Lansdale Sewage Treat. Plant
University Area Jt. Authority
Bristol Township
West Chester Borough
Ambridge Borough Municipal Auth.
Easton Area Joint Sewer Authority
South West Del. City Mun. Auth.
Bethel Park STP
Tinicum Township
West Goshen Sewage Treatment Plant
Montour Run Moon Twp.
Towanda Mun. Auth.
Limerick Twp Mun. Auth.
Wind Gap Mun. Auth.
Selinsgrove Mun. Auth.	
TOTAL:  18

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       FY '89 INDUSTRIAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0001554
PA0001716
PA0001791
PA0002054
PA0002372
PA0002925
PA0004481
PA0005011
PA0007137
PA0007510
PA0008419
PA0008451
PA0008664
PA0011363
PA0011631
PA0012963
PAOQ13463
Sharon Steel
FMC Corp.
GTE Sylvania Warren
Penelec Seward
Quaker State Oil
West Perm. Power
U.S. Steel-Homestead
Penelec Covenaugh
Season All Ind.
International Paper
Merck  & Co.
PP&L Co. (Shamokin)
UGI Hunlock
NGK Metals
Phila. Elect. Cromby
Rock Term. Co.
USX Inc. Fairless
TOTAL: -17

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       FY '90 MUNICIPAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0020168
PA0020664
PA0020893
PA0021580
PA0022535
PA0023108
PA0023124
PA0023256
PA0025976
PA0026034
PA0026042
PA0026085
PA0026557
PA0026794
PA0026859
PA0026964
PA0027065

PA0027081
PA0027090
PA0027669
PA0031127
PA0037290
PA0039004

PA0043729

PA0045985
PAOQ53147
East Stroudsburg Boro STP
Middletown WWTP
Manheim STP
Catasauqua Borough Authority
Millersburg Area Auth. STP
Elizabethtown Boro STP
Albion Borough
Upper Gwynedd Twp. Auth.
Upper Moreland-Hatboro Sewage
Johnstown City
Bethlehem Auth. WWTP
Upper Merion Twp. Auth.
Sunbury City Mun. Auth.
Conshohocken Boro Auth.
Coatsville Mun.  Auth. STP
Montgomery County Sewer Auth.
Lackawanna River Basin Sewer Auth.
Strahbard  STP
Clinton STP
Lackawanna River Basin Sewer Auth.
McCandless Twp. San. Auth.
Northampton Mun. WWTP
Wesland Development, Inc.
Upper Gwynedd
Towamencin Mun. Auth.
Hampton Twp.
Allison Park STP
Mountaintop Area WWTP
Upper Saucon Twp. Mun. Auth.
TOTAL:  26

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       FY '90 INDUSTRIAL PERMIT REVIEWS GENERATING NO COMMENTS
NPDES NO.
FACILITY
PA0010782
PA0011258
PA0033600
PA0034622
PA0044920
PA0047325

PA0091383
PA0103055
PA011183Q
Met Ed Titus
Cabot Corp./Kawecki Berylco Div.
James Austin Co.
Ajax/Acom Manufacturing, Inc.
Lehighton Electronics, Inc.
PA Power and Light Co.
Susquehanna
Paul Chrome Plating, Inc.
Custom Industrial Processing
Emporium Specialties Co.	
TOTAL: 9

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                              ATTACHMENT NO.  2
                     STATE OF PENNSYLVANIA

                        TARGETED PERMITS
                             FOR REVIEW
                                 FY'91
                       (Some Previously Issued)
SOUTHEAST REGIONAL OFFICE

U. S. Steel
Hatfield Twp. Municipal Authority
Abington Twp.
East Norriton-Plymouth Joint Authority
White Marsh Twp. Authority
Norristown Borough
Ambler Borough (South)
Upper Merion (Trout Creek)

WILKES-BARRE

Honesdale Borough
Borough of Stroudsburg
Cabot Corp.
The New Jersey Zinc Co., Inc.
Allentown City Authority
Bethlehem City (Bethlehem Authority)
Schuylkill Haven Borough
Scranton City S. Authority
LRBSA Throop Plant
Ashland Municipal Authority
Shenandoah Municipal S. Authority

HARRISBURG

Hollidaysburg WWTP
Tyrone Boro Sewer Authority
Lewistown Boro Municipal Authority
Huntingdon Water & S. A.
PA0013463 L
PA0026247 L
PA0026867 B
PA0026816 P.S.B
PA0026298 B
PA0027421 P.S.B
PA0026603 P.S.B
PA0026131 P.S.B
PA0023469 C
PA0029289 C
PA0011258L
PA0012751 L
PA0026000 L.P.S
PA0026042 P,S
PA0029017 B
PA0026492 L.C.P.S
PA0027090 L,C,P,S
PA0023558 C
PA0070386 C
PA0043273 C,B
PA0026727 P.S.B
PA0026280 B
PA0026191 L,C
(See Page 3 for Codes)

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Lowengart and Co. - Mercerburg
NGK Metals Corp.
Carpenter Tech. Corp.
Carlisle Bor. S. S. Authority
Letterkenny Army Depot
Highspire Boro STP
Hanover, Boro of
Manheim Boro Authority
Springettsbury Twp.
York City Sewer Authority
P. H. Glatfelter Co.
Penn Twp.
Lititz Sewer Authority
Millersville Borough
New Holland Boro Authority

WILUAMSPORT

Westfield Tanning Co.
Shamokin Coal Twp. Jt. S. A.
Clearfield Municipal Authority
Moshannon Valley Jt. S. A.

PITTSBURGH

Duquesne  Light - Cheswick Power Station
Penn Hills Twp. Sandy  Creek
Ebensburg Boro
Duquesne  STP
McKeesport Water Pol Control
Jeannette City M. A.
Charleroi Boro Authority
Pigeon Creek Sanitary Authority STP
California Boro
Westinghouse Elec.  - Semicord (POWEREX)
ARCO Chem. Co. Beaver Valley
Alcosan Waste Treatment Plant
Robinson Twp. - Campbells Run STP
Washington E. Wash. STP
PA0009521 L
PA0011363 L
PA0013129 L
PA0026077 P,S
PA0010502 L
PA0024040 B
PA0026875 P.S.B
PA0020893 L
PA0026808 L.P.S,
PA0026263 L.P.S
PA0008869 L
PA0037150 L.P.S
PA0020320 B
PA0026620 B
PA0021890 B
PA0008800 L
PA0027324 C.P.S
PA0026310 C
PA0037966 C
PA0001627 L
PA0026409 B
PA0022292 B
PA0026981 C
PA0026913 C.P.S
PA0027430 C
PA0026891 C
PA0044679 B
PA0022241 C
PA0001201 L
PA0006254 L
PA0025984 P.S.B
PA0036293 P.S.B
PA0026212 P.S.B
                           (See Page 3 for Codes)

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MEADVILLE

Gunnison Bro. Tannery                                PA0033367 L
Erie Sewer Authority                                  PA0026301 C.P.S.B
Meadville, City of                                     PA0026271 B
Conneaut Lake Jt. Mun. Auth.                          PA0021598 B
Titusville, City of                                      PA0036650 C.P.S.B
Punxsutawney M. A.                                  PA0020346 C.P.S
Ellwood City Boro                                    PA0026832 C
Butler Area S. A.                                     PA0026697 P,S

Codes:
  L - 304(L)
  C- CSO
  P - Pretreatment
  S - Sludge
  B - Biomonitoring

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                          ATTACHMENT NO.  3



Permit #:
Facility name:
Reviewer:
Permit Expiration Date:

                 PERMIT QUALITY REVIEW CHECKLIST

I.   ADMINISTRATIVE RECORDS


1.   Does the permit file contain each of the following  items?

     	  Permit application and supporting data

     	  Draft permit

     	  Statement of Basis or Fact Sheet

     	  All documents cited in Fact Sheet

     	  All comments received during public comment

     	  Transcripts and submissions from any hearing held

     	  Responses to significant comments

     	  Final permit

     	  Explanation of changes from draft to final permit

     	  Permit amendments or modifications

     	  Indication of new source

     	  Major/minor federal facility


II.  PUBLIC NOTICE AND COMMENT


1.   Was a public notice issued of the preparation of draft permit
     and providing  an opportunity for  comment at  least 30 days
     prior to final permit decision?  Was notice forwarded to all
     necessary parties including permittee?


2.   Was a public hearing held?


          Was a notice of public hearing  issued at least 30 days
          prior to the hearing?

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3.    Was a summary response to significant comments raised during
     comment period and/or hearing prepared and issued at time of
     final .permit decision?


III.  PERMIT MODIFICATIONS


1.    Does the permit  documentation indicate that  the permit was
     modified or revoked and reissued?


          What was the  reason  for the modification or reissuance
          (40 CFR 122.62(a) and (b))?


          Was the  permit modification or  reissuance  put through
          proper public notice?


IV.   BOILERPLATE/SPECIAL CONDITIONS
1.   Are the  following general conditions  incorporated into the
     permit, either directly or by reference to 40 CFR Part 122.41?

     	  (a) Duty to comply
     	  (b) Duty to reapply
     	  (c) Need to halt or reduce activity
     	  (d) Duty to mitigate
     	  (e) Proper operation and maintenance
     	  (f) Permit actions
     	  (g) Property rights
     	  (h) Duty to provide information
     	  (i) Inspection
     	  (j) Monitoring and records
     	  (k) Signatory requirements
     	  (1) Reporting requirements
     	  (m) Bypass
     	  (n) Upset
     	  (o) Penalties for violations
2.    Are there other conditions  that  are  included as part of the
     boilerplate instead of being specified in another part of the
     permit?


3.    Are any special conditions requiring best management practices
     (BMPs) included in the permit?  Identify.

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4.    Does  the   permit   application  indicate   that   there  are
     intermittent discharges at any outfall?  Are these addressed
     in the permit?


     A. INDUSTRIAL PERMITS

     1.   Does the permit  include any limitations or conditions for
          internal waste streams?  Describe.
     2.   Are limitations for all pollutants discharged expressed
          as both maximum daily and average monthly values.


     B.   MUNICIPAL PERMITS


     1.   Are septage haulers or other "mobile source" dischargers
          addressed in the permit?


     2.   Are flow limits contained in the permit?


     3.   Is inflow/infiltration correction addressed?


     4.   Are sewage sludge requirements (Section 405) included?


     5.   Are limitations for all pollutants discharged expressed
          as weekly and monthly daily averages.


     6.   Is  whole   effluent  biomonitoring  included   in  the
          application  for municipal facilities with flow greater
          than 1.0 mgd?

V.   PERMIT LIMITS

1.   Have a set of permit  limits been  included  in the permit for
     every outfall?


2.   Are all limits at least  as stringent  as in previous permit.
     If limits are less stringent in new permit,  does it meet new
     EPA backsliding requirements?

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3.   Complete the chart for each pollutant parameter with specific
    limits:
Pollutant
Basis of Limit
(Water Quality-Based)
State

EPA

Narrative

(Tech-Based)
BAT

BPT

BPJ

Sec.Trt.

Other

4.   Are there parameters for which  limits  (or monitoring) are not
     required,  but  which  might  be  appropriate  to  limit  (or
     monitor)?


5.   Is it clear whether daily maximum and/or daily average limits
     will be enforced if monitoring is once a month?  Is monitoring
     frequency adequate to judge compliance?


6.   If batch  discharged,  are limitations expressed in appropriate
     terms, max. daily, average monthly,  concentration, loading.
7.    Does  the  permit  contain   seasonal
     limitations justified?
limits?
Are  these
     A. INDUSTRIAL PERMITS
     1.   Were appropriate effluent guideline limitations used as
          a basis for permit effluent limitations?

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          Are all  pollutant  limitations  in  the  applicable
          guidelines included in the permit?


2.   Are applicable effluent  guideline  limitations based on
     production?


          Was production  basis in  the  permit  a  reasonable
          measure of average actual production?  (See form 2C,
          items III-B and C.)   Specify the production basis.


     •     Have alternate permit limitations been included to
          address different production  levels?   Specify the
          number of tiers of limits.
3.   Is a BPJ analysis used as a basis  for permit limitations?
          Which  of  the  following  sources  were  used  in
          establishing any BPJ limitations?

           Promulgated guidelines (Technology Transfer)
           Proposed guidelines
           Development document
           Treatability manual
           Treatability data base
           Past facility performance (DMR data)
           Other
          What  method was  used  to  establish  BPJ/BCT  for
          conventional pollutants?
B.   MUNICIPAL PERMITS
1.   Were secondary treatment  limitations  adjusted (for BOD
     or  SS)  because  of  industrial contributions?  Was  it
     appropriate and correctly computed (Special consideration
     40 CFR 133.103(8))?
2.   List any pollutants limited by mass or concentration that
     should have been listed in the other  form (i.e. secondary
     limits expressed as concentration).

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VI.  WATER QUALITY-BASED PERMITTING
1.   What is  the  source of facility  intake  water (ground water,
     municipal water supply, receiving stream)?

2.   What is  the  Instream Waste Concentration  (IWC)  or dilution
     factor?
3.   Why does this permit have water quality-based toxics control?

          	 effluent toxicity screening
          	 ambient stream monitoring results
          	 inspection
          	 DMR data
          	 304(1) listed receiving water
          	 other
4.   What type of water quality limitation is  stated  in the permit
     (narrative, numerical, or both)?


5.   Does the permit (fact sheet) document that water  quality based
     limitations  are at least  as stringent  as technology-based
     limitations  (industries)  or  secondary treatment regulations
     (POTWs)?


6.   Have  all  applicable  water  quality  standards  been clearly
     identified?  Have  all  such criteria  been correctly utilized
     in  determining effluent  limitations?    (Both  numerical  and
     narrative)


7.   What  is  the  designated  water  use or  classification  of
     receiving  stream?   (Is  stream  utilized  as  drinking water?
     Nearest  intake?)


8.   Have  huatan health concerns  been  considered  or specifically
     used  in  determining limits?


9.   In  what  terms are  whole  effluent   toxicity   (WET)  limits
     expressed  (in toxic units, as a 96 hour  LC50, etc)?

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10.   Identify toxicity testing methods:

          Type (acute /chronic, flow through/static):


          Species (Ceriodaphnia, fathead minnow):


          Duration (7 day, 96 hour):


11.   Was EPA  criteria for  toxic  units used  (0.3  acute  and 1.0
     chronic toxic units)?  Were both  acute and chronic criteria
     used?


12.   Was a mixing zone concept used for this permit?


          Is it  a complete mixing zone?   Where  do the toxicity
          limits apply?


     •     How  were   the  mixing  zones   determined  (dye  studies,
          desktop calculations, or others)?


13.   Are toxicity Identification Evaluations (TIEs) and/or Toxicity
     Reduction Evaluations (TREs)  required?  Describe briefly.


          Does TRE include appropriate completion date?


          Is follow-up toxicity testing required after the TRE?


14.   For this permit, was wasteload allocation (WLA)  modeling  [more
     detailed than dilution calculations]  for toxicity performed?


          What type of model was used  to  perform  the WLA (Steady
          state,  dynamic,  or  other)?   Describe  the  type  of
          calculation(s)  used.

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          What mechanisms  or  sources of  data were used  for WLA
          modeling?

          	 application form information
          	 DMRs
          	 308 letters
          	 administrative orders
          	 intensive stream survey
          	 other (explain)
15.   What stream  design  flow is  specified?   Is this  a seasonal
     flow?


16.   Was non-point source contribution estimated?  How?


17.   Were  the  impacts  of  other  major  dischargers  (multiple
     discharges) taken into account in determining the WLA?  How?


18.   Were  contributions  of  toxicants  to  overlying water  from
     sediments included in the assessment?  How?
VII. DISCHARGE SAMPLING

1.   Does the  permit  require monitoring for  every pollutant for
     which limitations are  included  in  the permit?  Are effluent
     sampling frequencies specified for every pollutant?


2.   Does the  permit require  monitoring  the volume  of effluent
     discharged from the outfall?   If not, is an explanation (in
     the fact sheet) provided?
VIII.DISCHARGE REPORTING


1.   Are  there  any  pollutants  for  which discharge  monitoring
     reports  are not  required at  lease  once  a year?   Specify
     discharge reporting frequency required in the permit.


2.   Is  reporting on  discharge  monitoring  report  (DMR)  forms
     required?


3.   Have  the water  quality-based limits  associated with this
     permit been entered into the PCS database?  If no, why not?

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IX.   COMPLIANCE AND ENFORCEMENT
1.    Does the permit include a compliance schedule for each outfall
     which is not in compliance with the limitations specified in
     the pejrmit? If not, is an explanation provided?  Construction
     grants schedules included for POTW's?


2.    Have any  enforcement  actions been  taken?   If  yes,  briefly
     describe  the  nature and  dates  of  the  actions.    Any minor
     compliance problems?
X.   SPECIAL CONDITIONS


     1.    Pretreatment

     2.    Sludge

     3.    Combined Sewer Overflow

     4.    Non-304(1) toxics policy (PA)

     5.    Non-detection language (PA)

     6.    Other

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