NC0023965_staff comments_20041011

Re: Wilmington 1314,Cr i6 A-Ptivac
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Subject: Re: Wilmington 7'1Loo 23c{(oS� �� �' ` v' '
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From: Ed Beck <[e-mail]>���
Date: Mon, 11 Oct 2004 13: 57: 52 -0400 �' f2Z—� •��S to p"f°4
To: Dave Goodrich <[e-mail]>
CC: Susan Wilson <[e-mail]>, Mark Mcintire <[e-mail]>,
Mike Templeton <[e-mail]>, Rick Shiver <[e-mail]>
AM
I agree that it would be very problematic to meet their needs in this manner. I would think
that more than rerating would be needed. I was uncomfortable with the full design recently
approved for the expansion. I think it would be very difficult for them to support using only a
portion of the approved system at a higher flow rate. I think modification of the NPDES
permit would be needed if some reduced flow rate were proposed. I can't imagine that they
would want the NPDES permit modified to reduce the flow rate. They have been successful at
shifting flows between the northside and southside plants through the years to balance flows
and maintain compliance. In a meeting last week Hugh said, when asked about expansion of
the southside plant, that they would shift flow to the expanded northside plant to extend the
life of the southside plant. Let them keep shifting flows while the plant is being constructed.
Ed
Dave Goodrich wrote:
I do not believe we should agree to any kind of a re -rating in this case. Wilmington has
consistently maintained that they should be allowed to build part of their ATC while the
final TMDL was developed. This request may have nothing to do with that, but it seems to
me that in any case they've needed to expand for over a decade and have done a pretty good
job not violating their flow limit. They should be able to do the same for another 2-3 years
while under construction. I also think that this was not part of the overall plan put forward
in the Environmental Assessment document so there could be an inconsistency there, also.
Susan Wilson wrote:
OK - had a strange inquiry from Wilmington's consultant today. Wilmington is afraid that
during the time of construction, they may run into flow violations. (of course - they are
pointing out that due to the length of the EA and permitting process, etc., their original
construction schedule has been pushed back greatly - so they may run into flow
problems). He was asking how we would view the 80/90 rule and how we would view
flow violations. I told him that they would probably be OK with re. to the 80/90 rule -
since they already have approved plans/specs for the expansion, but any monthly
average flow violations would be problematic and they'd be assessed like everyone else.
he then asked if they constructed certain treatment units (which are necessary for the
final project) - could they get a re-reating until completion of the entire project? I've
never had a situation like this and I'm not sure if they're just broadly speculating, but he
seemed to indicate that they may be pushing the bounds of their flow limit and would like
the re -rating if possible. i told him we'd prefer them not to do this, but it was their
prerogative to request a re -rating.
(this is a real pain in the butt for us , really CG&L, but i don't see how we can object to it
as long as they can demonstrate that they can meet their limits). I told him if they
re -rated to a higher flow - they would still essentially have to meet the limits given for 16
MGD (5/1).
what do you guys think of this? i told him before he discussed with Wilmington, I wanted
to ask ya'll and see if this had come up before.
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