SOW - EEY Minor Industrial Treatment Flow_.pdf

This is a Statement of Work (SOW) for funding NPDES Minor Industrial Treatment flow services at Ensley Engineer Yard in compliance with Tennessee Department of Environment and Conservation (TDEC) stormwater permitting regulations.

The work encompasses payment of the Minor Industrial Treatment Fee to TDEC for the NPDES Permit associated with Ensley Engineer Yard, which is classified as a Minor Industrial Treatment facility with a permitted discharge flow between 1 and 10 million gallons per day (MGD). The SOW also includes regulatory compliance activities supporting TDEC's administration of the NPDES program, specifically permit oversight, compliance review, monitoring requirements, and renewal processing. The primary objective is to ensure uninterrupted regulatory coverage and maintain compliance with federal and state Clean Water Act requirements. The regulatory justification includes the federal Clean Water Act requirement (33 U.S.C. §1251 et seq.) mandating that all facilities discharging pollutants maintain valid NPDES permits with payment of applicable treatment flow fees, and the state requirement under Tennessee Rule 0400-40-05, which establishes annual fee schedules for industrial treatment facilities. Payment of the required fee is mandatory to maintain permit coverage and prevent permit lapse, enforcement actions, penalties, or operational discontinuity. Funding this fee ensures the facility maintains environmentally compliant operations and supports the organization's responsibility for environmental compliance across all facilities.