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HomeMy WebLinkAboutNC0050342_Correspondence_20041101NPDES DOCUMENT SCANNING; COVER SHEET NC0050342 Muddy Creek WWTP NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: November 1, 2004 This document is printed on reuse paper - ignore any content on the reirerse side imap://sergei.chernikov%40dwq.denr.ncmail.net@cros.ncmail.net:143/f... Subject: Re: re recent modification to NC0050342 - Winston Salem Muddy Cr WWTP From: Hyatt.Marshall@epamail.epa.gov Date: Mon, 01 Nov 2004 10:23:04 -0500 To: Sergei Chemikov <sergei.chernikov@ncmail.net> CC: mark.mcintire@ncmail.net thanks for the explanation - didn't mean to stir things up, but was responding to what was written. I understand what you did and why you did it. 1 of 1 11/1/2004 4:17 PM mailbox:///q/Documents%20and%20Settings/sergei_chernikov/Applica... Subject: Re: re recent modification to NC0050342 - Winston Salem Muddy Cr WWTP From: Sergei Chernikov <sergei.chernikov@ncmail.net> Date: Mon, 01 Nov 2004 10:11:31 -0500 To: Hyatt.Marshall@epamail.epa.gov Marshall, We don't consider all modifications as minor modifications. But these particular modifications were considered minor because they only involved relocation of sampling points and update of toxicity language. There was no change in flow or composition of the waste, no new limits, no changes in limits, etc. Sergei Hyatt.Marshall@epamail.epa.gov wrote: thanks for the explanation. 40 CFR Part 1122.63 spells out which changes to permits are considered to be minor modifications. If a given change does not fall into one of those categories, it must be considered a major mod under 40 CFR 122.62, must go to public notice, and be sent to EPA for review, according to the MOA. If NC really considers all mods as minor mods, that's a problem. Is it really typical practice for all mods to be considered as minor by NC? I understand changes needed to be made to this permit, but they don't seem to qualify as minor mods to me. Sergei Chernikov, Ph.D. Environmental Engineer NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 phone: 919-733-5083 ext. 594 fax: 919-733-0719 1 of 1 11/1/2004 4:18 I'M imap://sergei.chernikov%40dwq. denr.ncmail.net@cros.ncmail.net:143/f... Subject: Re: re recent modification to NC0050342 - Winston Salem Muddy Cr WWTP From: Hyatt.Marshall@epamail.epa.gov Date: Mon, 01 Nov 2004 09:57:26 -0500 To: Sergei Chemikov <sergei.chernikov@ncmail.net> CC: Susan.A.Wilson@ncmail.net, mark.mcintire@ncmail.net thanks for the explanation. 40 CFR Part 1122.63 spells out which changes to permits are considered to be minor modifications. If a given change does not fall into one of those categories, it must be considered a major mod under 40 CFR 122.62, must go to public notice, and be sent to EPA for review, according to the MOA. If NC really considers all mods as minor mods, that's a problem. Is it really typical practice for all mods to be considered as minor by NC? I understand changes needed to be made to this permit, but they don't seem to qualify as minor mods to me. 1 of 1 11/1/2004 4:16 PM imap://sergei.chernikov%40dwq.denr.ncmail.net@ems.ncmail net:143/f... Subject: re recent modification to NC0050342 - Winston Salem Muddy Cr WWTP From: Hyatt.Marshall@epamail.epa.gov Date: Mon, 01 Nov 2004 09:25:47 -0500 To: sergei.chernikov@ncmail.net just got this final modification. It looks like a number of non -minor mods were made to the permit, but I don't think a draft of those was sent here first for review. The MOA does require that major mods also be reviewed by EPA. wanted to bring this to your attention. thanks Marshall 1 of 1 11/1/2004 4:16 PM