Pretreatment Streamlining Rule Overview of Changes to the Federal Pretreatment Regulations

Objectives of Briefing Provide history and background of the Rule Review all changes adopted in the final rule

History of Streamlining Rule 1995 – Office of Wastewater Management (OWM) initiates evaluation streamlining opportunities in Part 403 regulations May 1996 – OWM circulates issue papers to stakeholders for feedback September 1996 – Association of Metropolitan Sewerage Agencies (AMSA)/Water Environment Federation (WEF) present report summarizing multi-stakeholder experts workshops July 1999 – Environmental Protection Agency (EPA) proposes Streamlining Rule August 2003 – Streamlining Workgroup reconstituted March 2005 – Office of Management and Budget’s (OMB) Thompson Report published June 2005 – EPA formally submits final rule to OMB September 26, 2005 – Administrator Johnson signs final rule October 14, 2005 – Final Streamlining Rule Published in the Federal Register

Key Stakeholders Metal Finishers National Association of Clean Water Agencies, Water Environment Federation and Other POTWs Industrial Users Metal Finishers Synthetic Organic Chemical Manufacturers Assoc. (SOCMA) Food Industry Auto/Shipbuilding/Leather Tanning Small Business Administration Approval Authorities (Regions/States) Natural Resources Defense Council

Glossary of PT Terms Pretreatment-the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to or in lieu of discharging into a POTW. POTW-Publicly Owned Treatment Works, includes any devices and systems used in the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a liquid nature. Approval Authority – the Director in an NPDES State with an Approved Program and the appropriate Regional Administrator in a non-NPDES State or NPDES State without an approved State pretreatment program. Control Authority- The POTW, if there is an approved pretreatment program or the Approval Authority if there is not an approved pretreatment program. Also referred to as a CA. BMP-Best Management Practices SIU- All industrial users subject to Categorical Pretreatment Standards, and any other industrial user that discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary, non-contact cooling, and boiler blow-down wastewater); contributes a process wastestream which makes up to 5% or more of the average dry weather hydraulic or organic capacity of the POTW treatment plant, or is designated as such by the Control Authority on the basis the industrial user has the reasonable potential for adversely affecting the POTW’s operation or for violating any pretreatment standard. CIU- Categorical Industrial User- All industrial users subject to Categorical Pretreatment Standards Pass-Through- a discharge that exits the POTW into the waters of the United States in quantities or concentrations which, alone or inconjunction with a discharge or discharges from other sources, is a cause of a violation of any requirement of the POTW’s NPDES permit. Interference- a discharge which, alone or in conjunction with a discharge or discharges from other sources, both inhibits or disrupts the POTW, its treatment processes or operations, or its sludge processes, use or disposal.

Glossary of PT Terms (cont’d) SNC – Significant Non-Compliance-An Industrial User is in SNC, if one or more of the following occur: a.) Chronic violations of wastewater discharge limits, defined here as those in which 66% or more of the measurements taken within a six month period exceed (by any magnitude) the daily maximum limit or the average limit for the same pollutant b.) Technical Review Criteria (TRC) violations, defined here as those in which 33% or more of all of the measurements for each pollutant parameter taken during a six-month period equal or exceed the product of the daily maximum limit or the average limit multiplied by the applicable TRC (TRC=1.4 for BOD, TSS, & O+G, and 1.2 for all other pollutants except pH.) c.) Any other violation of a pretreatment effluent limit (daily maximum or longer-term average) that the Control Authority determines has caused, alone or in combination with other discharges, interference or pass-through. d.) Any discharge of a pollutant that has caused imminent endangerment to human health, welfare, or to the environment. e.) Failure to meet within 90 days of after the schedule date, a compliance schedule milestone contained in a local control mechanism or enforcement order for starting construction, completing construction, or attaining final compliance. f.) Failure to provide, with in 45 days after the due date, required reports such as baseline monitoring reports, 90 day compliance reports, and reports on compliance with compliance schedules. g.) Failure to accurately report noncompliance h.) Any other violation or group of violations which the Control Authority determines will adversely affect the operation or implementation of the local pretreatment program. Control Mechanism-permit issued to SIU/CIU by CA if approved pretreatment program or by AA if not.

Summary of Final Rule Changes Issue Rule Change Pollutants not present CAs can grant sampling waivers where CIU demonstrates that a regulated pollutant is neither present nor expected to be present General control mechanisms CAs may issue general control mechanisms to groups of SIUs that are substantially similar BMPs as local limits BMPs may be used in lieu of numeric local limits Slug control plans POTWs may determine how often they evaluate SIUs for the need for slug control plans or other requirements Any requirements must be reflected in control mechanism or permit. Equivalent Conc. Limits CAs can use existing concentration-based standards instead of converting to flow-based mass limits for CIUs in Organic Chemical, Plastics, and Synthetic Fibers, Petroleum Refining, and Pesticide Chemicals Grab and Composite Sampling Clarifies and updates application of sampling requirements; Provides flexibility to CA in certain sampling protocols SNC – Publication POTW can publish SNC violations in any paper of general circulation

Summary of Final Rule Changes (cont’d) Issue Rule Change SNC – Applicability SNC criteria apply only to SIUs and to those IUs that have adversely affected pretreatment program SNC – Daily Max. or Avge. Limits Broadens scope of violations covered by chronic, TRC, and other violations SNC – Late Reports SNC violation occurs when reports submitted more than 45 days after deadline SNC – TRC, Rolling Quarters, pH No changes made to current rules Removal Credits - Overflows Retains and updates current formula to adjust removal credits by number of hours of sewer overflows per year Removal Credits – Sewage Sludge Advanced Notice of Proposed Rulemaking (ANPRM) asks for comment on adding pollutants to list of chemicals eligible for removal credits, and on potential ways to streamline consistent removal requirements Miscellaneous Changes Updates or corrects provisions re: to signatory requirements, net/gross calculations, requirement to report all monitoring data, and notification of changes

Summary of Final Rule Changes (cont’d) Issue Rule Change Equivalent Mass Limits CIUs can request, and Control Authorities have discretion to approve, the conversion of concentration-based categorical standards to equivalent mass limits CIU Oversight Establishes Non-Significant CIU (NSCIU) category (discharges < 100 gpd) CIU reporting can be reduced to yearly compliance certification CA oversight can be reduced to annual evaluation of the CIU’s certification Establishes “Middle Tier” CIU category (discharges don’t exceed (a) the smaller of 5,000 gpd or 0.01 % of POTW design dry weather hydraulic capacity; (b) 0.01 % of POTW design organic treatment capacity; and (c) 0.01 % of the Maximum Allowable Headworks Loadings CIU reporting can be reduced to once annually CA oversight can be reduced to one inspection and sampling event every other year

Pollutants Not Present Current Rules CIUs must sample for all pollutants covered by the categorical standard, regardless of whether pollutant is present (unless the categorical standard allows for surrogate pollutant sampling or alternative certifications) Proposed Rule If CIU can demonstrate a pollutant is not present in its process waste stream or is present only in background levels in intake water, the CA may authorize a sampling waiver for that pollutant Must still comply with categorical standards OCPSF (Organic Chemicals, Plastics, and Synthetic Fibers) facilities not eligible

Pollutants Not Present Final Rule Adopted proposed rule, with the following modifications: OCPSF facilities are eligible for waiver At least one representative process wastewater sample must be taken prior to treatment CIU must notify CA if pollutant found, and must immediately resume monitoring CA must: include waiver and notification requirement in control mechanism, document reasons for granting waiver and maintain information for 3 years after control mechanism expires Waiver valid for one term of control mechanism (like NPDES provision) Waiver does not replace any certification requirements established in specific categorical standards Waiver may be granted where pollutant present solely due to sanitary wastewater except if covered by categorical standard

Pollutants Not Present Where to find rule changes? 40 CFR 403.8(f)(2)(v) 40 CFR 403.12(e)(2)

General Control Mechanisms Current Rules SIUs must be controlled through permits or equivalent mechanisms EPA has emphasized the importance of evaluating each SIU individually Proposed Rule Allow POTWs to control SIUs through general permits where the necessary legal authority exists and the SIUs meet the criteria for being substantially similar SIU must file a Notice of Intent or similar application device Coverage by general control mechanism doesn’t relieve SIU of reporting requirements Coverage not allowed for SIUs subject to mass limits CA may choose to make coverage optional or required

General Control Mechanisms Final Rule Adopted proposed rule, with the following modifications: Coverage available for CIUs granted a monitoring waiver for pollutants not present POTW must maintain the following for 3 years after expiration of general control mechanism: Copy of the general control mechanism Documentation to support POTW’s determination that the group of SIUs meets the criteria for coverage Copies of all written requests for coverage Still exempts SIUs subject to mass limits, but allows coverage for facilities subject to the same mass-based local limits

General Control Mechanisms Where to find rule changes? 40 CFR 403.8(f)(1)(iii)

BMPs as Local Limits Current Rules Pretreatment rules are silent on whether POTWs can use BMPs (rather than numeric limits) to satisfy their requirement to develop local limits Pretreatment rules do not explicitly require reporting compliance data for Industrial Users subject to BMPs as local limits or categorical standards Proposed Rule Clarify that: BMPs developed by POTWs may serve as local limits, and Full CIU reporting required where BMPs required for categorical standards

BMPs as Local Limits Final Rule Adopted proposed rule, with the following modifications: Specify the necessity for POTWs to document the supporting rationale for specific BMPs Include definition of BMPs Clarify in the preamble what EPA considers to be minimum elements that make BMPs enforceable Specific notice to IUs of requirements Equipment specifications O&M requirements Timeframes for key activities Compliance certification, reporting and recordkeeping Re-opener for revoking or modifying

BMPs as Local Limits Where to find rule changes? 40 CFR 403.5 40 CFR 403.8(f) 40 CFR 403.12(b), (e), (h)

Slug Control Plans Current Rules Slug discharges are prohibited POTWs must evaluate, at least once every two years, whether each SIU needs a plan to control slug discharges EPA has historically emphasized that a plan is not required Proposed Rule Provide POTWs the flexibility to review the need for a slug control plan or other action as necessary Clarifies that plan is not required outcome of evaluation Requirements must be included in control mechanism

Slug Control Plans Final Rule Adopted proposed rule, with the following modifications: POTWs must evaluate need for a plan at least one time for each SIU, by the following deadline: Within 1 year of the effective date of the rule if the IU was identified as “significant” prior to rule’s effective date Within 1 year of being designated as “significant”, if the IU is designated as “significant” after the rule’s effective date SIUs must immediately notify POTW of any changes at their facilities, not already addressed in their slug control plan or other slug requirements, affecting slug discharge potential Clarify annual slug-related inspections should continue as per existing guidance

Slug Control Plans Where to find rule changes? 40 CFR 403.8(f)(1)(iii)(B)(6) 40 CFR 403.8(f)(2)(vi)

Equivalent Concentration Limits Current Rules No allowance for equivalent concentration limits where categorical standard requires a mass limit to be calculated based on the facility’s flow Proposed Rule For CIUs subject to OCPSF, Petroleum Refining (Cr an Zn), and Pesticide Chemicals allow POTW to use concentration limit in categorical standard where flow from facility is so variable that use of mass limits is impractical

Equivalent Concentration Limits Final Rule Adopted proposed rule, with the following modifications: Eliminate condition requiring variable flows Require CA to document that dilution is not being substituted for treatment as prohibited by 40 CFR 403.6(d) Where to find rule changes? 40 CFR 403.6(c)(6)

Use of Grab/Composite Samples Current Rules Pretreatment regulations specify: Type of sampling method for baseline monitoring reports and 90-day compliance reports, but not for periodic compliance reports Minimum of 4 grab samples for pH, cyanide, total phenols, oil & grease, sulfides, and volatile organic compounds Composite samples must be flow-proportional unless the Industrial User demonstrates that this is “infeasible”

Use of Grab/Composite Samples Proposed Rule Clarify when different types of sampling methods may be used: Extend sampling requirements to periodic reports Give POTWs flexibility to determine appropriate number of grab samples to measure pH, CN, total phenols, oil and grease, sulfides and Volatile Organic Compounds (VOCs) Clarify composite samples for CN and VOCs may be done prior to analysis Remove requirement that flow-composite sampling must be “infeasible” in order to allow time-composite sampling (sampling must be “representative”)

Use of Grab/Composite Samples Proposed Rule (cont’d) Clarify when different types of sampling methods may be used: Clarify that although “24-hour composite sample” must be taken within a 24-hour period, this period only covers period during which IU is discharging Final Rule Adopted proposed rule, with minor editorial changes Where to find rule changes? 40 CFR 403.12(b), (d), (e), (g), (h)

SNC - Publication Current Rule Pretreatment regulations require SNC violations to be published in largest daily newspaper Proposed Rule Allow publication in any paper of general circulation within the jurisdiction that provides meaningful public notice Final Rule Adopted proposed rule Where to find rule changes? 40 CFR 403.8(f)(2)(viii)

SNC – Application to SIUs Only Current Rules SNC can apply to any IU Proposed Rule Apply SNC to Significant Industrial Users only Final Rule Adopted proposed rule, with the following modifications: Apply SNC to other IUs if they cause pass through, interference, imminent endangerment, or adversely affect pretreatment program Where to find rule changes? 40 CFR 403.8(f)(2)(viii)

SNC – Daily Maximum or Avg. Limits Current Rule SNC determinations for chronic violations, technical review criteria violations, and pass through or interference violations limited to daily maximum or average limits Proposed Rule Include broader array of numeric or narrative violations Final Rule Adopted proposed rule Where to find rule changes? 40 CFR 403.8(f)(2)(viii)(A), (B), (C)

SNC – Late Reports Current Rule SNC applies if a required report is submitted more than 30 days late Proposed Rule No changes were proposed due to the wide variety of suggestions EPA solicited comments on recommended approaches Final Rule Extended 30-day deadline to 45 days Where to find rule changes? 40 CFR 403.8(f)(2)(viii)(F)

SNC – Technical Review Criteria Current Rules TRC are numeric thresholds used to define a subcategory of SNC based on the magnitude of an effluent violation TRC violation occurs when 33 percent or more of all measurements taken for the same pollutant during a 6-month period equal or exceed the product of the applicable limit multiplied by the TRC Proposed Rule No changes proposed, but solicited comment on workable alternatives to current TRC Final Rule Retained current TRC, with slight wording changes

pH Current Rules IUs prohibited from discharging at pH < 5.0 w/o exception Proposed Rule Allow temporary excursions for discharges with pH < 5.0 to POTWs provided POTW first conducts a technical evaluation to support lower pH Final Rule EPA did not take action due to insufficient data on relationship between pH and corrosion Clarified current enforcement flexibility

Removal Credits - Overflows Current Rule POTWs may grant removal credit to a CIU which equals or is less than the consistent removal of the pollutant provided by the treatment plant Where annual overflows occur, the amount of consistent removal claimed by the POTW is reduced by a mathematic formula that takes into account the number of hours of overflows in a year As a condition of using this overflow formula, the POTW must be in compliance with certain guidance documents related to combined sewer overflows, which are now obsolete Proposed Rule Delete the current overflow formula CIUs that are upstream from overflows are ineligible for removal credits unless they can establish that their discharges are consistently treated

Removal Credits - Overflows Final Rule Retains current overflow formula Updates references to obsolete guidance, and replaced with requirement for POTWs to be in compliance with all NPDES permit requirements and other requirements in any orders or decrees issued pursuant to the CSO Control Policy Makes one technical correction to a footnote in Appendix G, Table 1 THC or carbon monoxide concentrations can be used to represent organic compounds in exit gas from incinerators Where to find rule changes? 40 CFR 403.7(h)

Removal Credits – Sewage Sludge Current Rule Removal credits can be granted to a CIU where: The POTW demonstrates its ability to “consistently remove” the pollutant at issue, The Pollutant is among those listed in Appendix G, Table I or Table II, If the pollutant isn’t listed in Table I or Table II, it isn’t eligible for removal credits Potential additions to Appendix G EPA has identified 15 pollutants for refined risk assessments will be conducted, which could result in part 503 amendments EPA has concluded that an additional 20 pollutants did not fail the Agency’s exposure and hazard screening process, and could be considered for inclusion in the Appendix G, Table II list if upper concentrations are developed

Removal Credits – Sewage Sludge Proposed Rule No specific revisions to the Appendix G list or the consistent removal provisions proposed Public comments on the overflow provision indicated support changes to the removal credit provisions to make them available for a broader range of pollutants Several public comments highlighted in the Office of Management & Budget’s 2004 Report to Congress on costs and benefits of Federal regulations supported revisions to the “consistent removal” provisions to more accurately reflect total removal by POTWs

Removal Credits – Sewage Sludge Advance Notice of Proposed Rulemaking (ANPRM) EPA requests comment on options to amend the consistent removal provisions to simplify the process for obtaining removal credits EPA requests comment on whether the addition of the 20 pollutants to Appendix G, Table II would be helpful to POTWs and IUs

Miscellaneous Provisions Signatory Requirements for IU and POTW Reports (40 CFR 403.12(l) and (m)) Changes numeric criteria for designating an appropriate “responsible corporate officer” signer to more flexible narrative criteria (same as adopted by NPDES rules) Specifies general POTW or pretreatment personnel who can sign as a “duly authorized” employee Net / Gross Calculations (40 CFR 403.15) Corrects unintended error in net/gross procedures which appeared to make the test for using such procedures more difficult to meet (mirrors the NPDES provision)

Miscellaneous Provisions Requirement to Report All Monitoring Data (40 CFR 403.12(g)(6)) Corrects omission from earlier addition of reporting requirements (1990) for non-categorical SIUs to require such Users to report all monitoring data [this is a required change to approved pretreatment program] Notification by IUs of Changed Discharge (40 CFR 403.12(j)) Clarifies that when IU provides notification, notice must be given to the CA or to the AA where the POTW does not have an approved pretreatment program

Equivalent Mass Limits Current Rules 40 CFR 403.6(d) allows CA to impose equivalent mass limits in addition to concentration-based standards where the IU is using dilution to meet standards or where the imposition of mass limits is appropriate Current rules do not allow the equivalent mass limit to replace the concentration-based standard Some POTWs and CIUs argue that use of concentration-based standards discourages the adoption of water conservation measures

Equivalent Mass Limits Proposed Rule Allow POTW to set equivalent mass limits as an alternative to concentration limits where CIU has: Installed treatment equivalent to model technology, Is employing water conservation POTW would need to determine an appropriate flow from a CIU to set the alternative mass limit Flow based upon a reasonable estimate of the flow required to achieve the facility’s production goals using BAT and in the absence of water conservation technology

Equivalent Mass Limits Final Rule - Adopt proposed rule, with following modifications: Emphasized that CIU may request equiv. mass limits, and CA has discretion to authorize To be eligible for use of equiv. mass limits, CIU must: Implement water conservation measures that substantially reduce water use, Use control and treatment technologies adequate to achieve compliance with categorical standards, and demonstrate that dilution not used, Provide monitoring data to establish its actual average daily flow rate through the use of a continuous effluent flow monitoring device and its baseline long-term average production rate, Demonstrate that it doesn’t have daily flow rates, production rates, or pollutant levels that fluctuate so significantly that establishing equiv. mass limits would not be appropriate, and Have consistently complied with applicable categorical standards

Equivalent Mass Limits Final Rule (cont’d) If CA approves eligible CIU’s request, CA then calculates the equiv. mass limits: Concentration-based categorical standard × CIU’s actual average daily flow rate × unit conversion factor Once equiv. mass limit is effective in the CIU’s control mechanism, CIU must do the following to retain coverage: Maintain and effectively operate control and treatment technologies adequate to achieve compliance with the equiv. mass limits, Record the facility’s flow rates through use of a continuous effluent flow monitoring device, Continue to record facility’s production rates and notify CA if rates vary by more than 20 percent from production rates used as basis for equiv. mass limits Employ same or comparable water conservation measures used in setting the equiv. mass limits

Equivalent Mass Limits Final Rule (cont’d) After calculating equiv. mass limit, CA must reassess the limit and recalculate as necessary to reflect changed conditions, where the CIU notifies it of a revised production rate CA may retain the initial equiv. mass limits in subsequent control mechanism terms if: CIU’s actual average daily flow rate reduced solely as a result of water conservation methods and technologies, Actual average daily flows used for calculating limit weren’t based on use of dilution as substitute for treatment, and CIU doesn’t bypass treatment control and treatment technologies Equiv. mass limits are not authorized for pollutants such as pH, temperature, radiation, or other pollutants which cannot be appropriately expressed as mass

Equivalent Mass Limits Where to find rule changes? 40 CFR 403.6(c)(5)

Non-Significant CIU Current Rules SIUs include all IUs subject to categorical pretreatment standards POTW may exclude a non-categorical IU if demonstrates that it has no reasonable potential to adversely affect the plant or violate a standard No flexibility currently to exclude categorical IUs from SIU status Proposed Rule Define non-significant CIU (NSCIU) using 100 gpd flow cutoff Prohibited untreated, concentrated wastewater Requested comments on whether to allow averaging over 5-day period An NSCIU would be exempt from certain inspection and sampling requirements, and POTW can set appropriate frequencies

Non-Significant CIU Final Rule - Adopted proposed rule, with modifications: Clarified that 100 gpd cutoff is measured accurately to the amount of “total categorical wastewater” as opposed to “total process wastewater” Where categorical and non-categorical wastewaters are commingled, measure categorical wastewaters to the extent they can be reliably distinguished from non-categorical wastewater) If categorical and non-categorical wastewaters can’t be reliably distinguished, measure the combined flow 100 gpd is a daily maximum threshold, which cannot be met through averaging

Non-Significant CIU To be eligible, the CIU must: Have consistently complied w/ all applicable standards and requirements Annually submit certification statement indicating that it continues to meet the NSCIU definitional criteria and that it complied w/ applicable standards and requirements Requires annual certification statement to be signed in accordance w/ 403.12 requirements CA required to annually list out which CIUs are considered NSCIUs CA required to annually evaluate whether each NSCIU has submitted its certification statement and continues to meet the definitional criteria

Non-Significant CIU Where to find rule changes? 40 CFR 403.3(v)(2) 40 CFR 403.8(f)(2)(v), (6) 40 CFR 403.12(e)(1), (g), (i), (q)

Middle Tier CIU Proposed Rule In section discussing NSCIUs, EPA requested comment on “alternative criteria for determining non-significant status … [such as] the percentage of POTW’s total flow discharged by a particular CIU.” 18 POTW commenters suggested adoption of 3-tier system for CIUs 1st tier – categorical SIUs 2nd tier – non-significant CIUs: discharge less than a percentage of POTW’s design dry weather treatment capacity, design dry weather organic treatment capacity, and MAHL for any pollutant detected at headworks for which CIU is regulated 3rd tier – de minimis CIUs: discharge less than 100 gpd EPA approved Metropolitan Water Reclamation District of Greater Chicago’s pilot project for the 3-tier system (no longer active)

Middle Tier CIU Final Rule Adopts concept similar to 3-tier system 1st tier – categorical CIUs 2nd tier – “Middle Tier” CIUs 3rd tier – NSCIUs If designated “Middle Tier”: CIU can reduce reporting to one time per year POTW can reduce inspections/samplings to one time every other year “Middle Tier” CIUs discharge no greater than: 0.01% of POTW’s design dry weather hydraulic capacity, or 5,000 gpd, whichever is smaller (measured by continuous effluent flow monitor unless CIU is batch discharger) 0.01% of POTW’s design dry weather treatment capacity 0.01% of MAHL for any pollutant for which CIU regulated

Middle Tier CIU Final Rule Additional eligibility criteria: CIU has not been in SNC for any time in past 2 years CIU does not have daily flow rates, production levels, or pollutant levels that vary significantly that reduced reporting would be non-representative of operating conditions Middle Tier CIU must notify CA immediately of any changes that cause it to no longer meet eligibility conditions If CIU no longer meets Middle Tier criteria, it must immediately being complying w/ minimum reporting requirements for categorical SIUs CA must retain documentation to support CA’s determination that specific CIU qualifies as a Middle Tier CIU for 3 years after expiration of control mechanism

Middle Tier CIU Where to find rule changes? 40 CFR 403.8(f)(2)(v)(C) 40 CFR 403.12(e)(3), (i)

NSCIU v. Middle Tier CIU Control Mechanism Required? Minimum CIU Reporting Requirements Minimum POTW Inspection / Sampling Requirements NSCIUs No Certification only (no reporting), one time per year Not required Middle Tier CIUs Yes One time per year (if representative of operating conditions) One time every other year Categorical SIUs Two times per year (at a minimum) One time per year

EPA Webpage to read Final Rule http://cfpub.epa.gov/npdes/home

Questions ??? Call Dan or me at 502-564-3410