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D. Project Schedule <br />The City anticipates the local limits project to begin on or about March 29, 2017, and end <br />on or about June 2, 2017, covering a period of 68 days. The City may extend this <br />timeframe if the City believes it is necessary. To have a final draft on June 2, 2017, will <br />require that all data necessary for the calculation of local limits is available at project <br />initiation and review of drafts are completed by the City quickly. <br />Consistent with other local limit submittals to EPA Region 5 and requirements established <br />in NPDESpermits, CWACS believes that the requirement to submit a re-evaluation to EPA <br />and the State is specifically met by submitting a f nal draft of the Local Limits Report and <br />requesting informal review to resolve any comments before beginning a formal City <br />administrative process (e.g. before processing through the City Council and making a <br />formal submittal to EPA and the State). <br />Completing the steps by June 2, 2017 (68 calendar days), will require the following items <br />to be completed on or before the dates shown. The City may have to modify its <br />expectations if additional sampling is required, complications are identified or review times <br />cannot be met (a typical local limits project takes 6-8 months). In either case, the target <br />timeframe shown below will require that resources at CWACS and the City be dedicated to <br />this project during the period ofproject initiation to completing Draft I of the Local <br />Limits. The short timeframe would prohibit more draft local limits reports to be provided. <br />CWACS recommends timeframe flexibility to allow for more refinement to local limits <br />drafts. <br />Estimated Timeframes <br />Days are calendar days. <br />Target <br />Target <br />Project Steps <br />Timeframe where <br />Timeframe where <br />all data is <br />additional data is <br />available <br />needed <br />Written Notice to Proceed <br />Day 0 <br />Day 0 <br />CWACS provides checklist for local limits <br />Day 1 <br />Day 1 <br />information. <br />City provides data and information as <br />By day 7 <br />By day 7 <br />requested by CWACS. <br />CWACS provides initial list of Pollutants <br />of Concern (POCs) and sampling data <br />N/A <br />By day 21 <br />needed. <br />City provides additional sampling data <br />N/A <br />By day 56 <br />needs. Could take longer than shown. <br />CWACS provides the final list of POCs <br />By day 21 <br />By day 70 <br />and Draft 1 of Local Limits. <br />City provides review and comments on <br />By day 30 <br />By day 79 <br />Draft 1 of the local limits <br />CWACS provides Draft 2 of the local <br />By day 44 <br />By day 93 <br />limits for review <br />City provides review and comments on <br />Draft 2. Includes senior management/legal <br />By day 54 <br />By day 103 <br />review. <br />CWACS provides Final Draft intended for <br />By day 68 <br />By day 117 <br />informal EPA/State review. <br />