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NC0023906_Authorization to Construct_20011129
NPDES DOCIMENT !;CANNING COVER SHEET NPDES Permit: NC0023906 Wilson — Hominy Creek WWTP Document Type: Permit Issuance Wasteload Allocation r ''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 29, 2001 This document is printed on reuse paper - ignore any content on the reirerse ,side Permit No. NC0023906 Authorization To Construct City of Wilson Engineer's Certification I, Ronald L. Taylor , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically, , full time) the construction of the project, Hominy Creek WWMF Upgrade & Expansion to 14 MGD, City of Wilson, N.C. for the Project Name Location Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation of the construction such that construction was observed to be built within substantial compliance and intent . he approved plans and specifications. Signature / li. ./ /Pk � Registration No. 14176 Date 11/29/01 The Division of Water Quality hereby acknowledges receipt and acceptance of ibis 13ngineers t rdfication --� sue- GL RTFP ECEIVED U4I SECTION DEC ; u Non-DischargePermitting HAZENAND SAWYER Environmental Engineers & Scientists Permits and Engineering Unit P.O. Box 29535 Raleigh, NC 27626-0535 November 29, 2001 Re: Certificate of Completion Permit No. 023906 City of Wilson - Hominy Creek H&S Job No. 3011 Hazen and Sawyer, P C. 4011 WestChase Blvd. Raleigh, NC 27607 919 833-7152 Fax: 919 833-1828 Dear Sirs: Enclosed is the Engineer's Certification of Completion for the Hominy Creek Wastewater Management Facilities Upgrade and Expansion to 14 MGD. if you have questions or need additional information, please advise. Very truly yours, HAZEN AND SAWYER, P.C. R aylo Senior Associate f.E. cc: Russell Brice - City of Wilson Ken Schuster - Raleigh Regional Office R E� v E D Don Cordell WATER QUALITY SECTION DEC 1 U 2uu I Non -Discharge Permitting New York, NY • Armonk, NY • Woodbury, NY • Upper Saddle River, NJ • Detroit, MI • Raleigh, NC • Charlotte, NC • Fairfax, VA • Hollywood, FL • Boca Raton, FL • Fort Pierce, FL • Gainesville, FL • Sarasota, FL • Miami, FL • JAMES B. HUNT JR. 7;;: ;;GOVERNOR „WAYNE MCDEvIrr SECRETARY, •>;' ,Y1.4 !!H' `A.'PREOttOW D =,•E,,*l+f ;- t JR ,'P ' r ,. c; DIRECTOR 4. 1lr 4 NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY February.24, 1998 Mr. Charles Pittman, Deputy City Manager City of Wilson P. O. Box 10 Wilson, North Carolina 27893-0010 SUBJECT: City of Wilson Permit No. NC0023906 Authorization to Construct Wastewater Treatment Facilities Project No. CS370381-04 Wilson County Dear Mr. Pittman: The final plans and specifications for the subject project have been reviewed and found to be satisfactory. Authorization is hereby granted for the construction of modifications and additions to the existing 12.0 MGD WWTP with an increase in capacity to 14.0 MGD to provide biological and chemical nutrient re oval to consist of a new clarifier flow distribution structure; a nerim clarifier effluent flow � p � collection/distribution structure; a nv biological treatment basin influent distribution channel with 10 - 1.5 Hp mixers; thfr(3) new biological treatment units with 17,850 ft3 anoxic zones each with 1 - 15 Hp, 1000 - 2000 gpm jet mixer, 56,090 ft3 aeration zones each with fme bubble diffusers with dual 15 Hp, 2750 - 3750 gpm internal recycle pumps, second stage 17,850 ft3 anoxic zones each with 1 - 15 Hp, 1000 - 2000 gpm jet mixer, 6,665 ft3 reaeration zones with fme bubble diffusers; modification of the three (3) existing aeration basins to provide arrangements similar to the new basins; rebuild the 3 existing 350 Hp multistage centrifugal blowers to provide from 4000 - 7500 ICFM utilizing the existing motors; a new 130 ft diameter, 14 ft SWD fmal clarifier; a new RAS pump station with dual 2500 - 4000 gpm, 50 Hp pumps; a new fmal clarifier effluent collection box; 2,518 ft2 effluent filters; a new 10,000 gal methanol storage facilty with four (4) 9 gph feed pumps; modifications to the existing CONSTRUCTION GRANTS & LOANS SECTION P.O. BOX 29579, RALEIGH, NORTH CAROLINA 27626-0579 PHONE 919-733-6900 FAX 919-715-6229 AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER — 50% RECYCLED/10% POST -CONSUMER PAPER ::Sx�'.�..,. ri`:..s ..,.:ti,..�.... l.fcr: R• J 1is..{�:I -2- chlorination/ dechlorination facilities to include dual 7000 gal sodium hypochlorite storage tanks with dual 80 - 120 gpm transfer and recirculation pumps and five (5) 25 gph feed pumps, a 7000 gal sodium bisulfite storage tank with dual 25 gph feed pumps, and modifications to the existing chlorination facilities building; modifications to the chlorine contact basin influent flow distribution box; conversion of fme solids settling basins 2 & 3 to effluent flow equalization; conversion of one existing fme solids settling basin to a 4,200,000 gal WAS storage basin with a new synthetic liner (with owner provided decant pump); and associated yard piping site work and electrical work. Operation of these facilities is authorized only at the existing 12.0 MGD permitted flow. Upon the issuance of an NPDES permit for an expanded flow, the Division will authorize operation at 14 MGD under a separate approval letter. When funding is desired, construction should not proceed until the Authorization - to -Award package, EEO, and MBE documentation/certification have been reviewed, and you are in receipt of our approval. The Permittee shall employ a State certified wastewater treatment plant operator to be in responsible charge of the wastewater treatment facilities. Such operator must hold a valid State Certificate of the grade at least equivalent to the classification assigned to the wastewater treatment facilities by the Certification Commission. When a new chief operator must be obtained to be in responsible charge of the new facilities, it is required that this be done by the time the construction of the facilities is 50% complete. The Authorization -to -Construct is issued in accordance with Part III, Paragraph A of NPDES Permit No. NC0023906, issued July 22, 1994 and shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the approved plans, specifications, and supporting documents; and are in compliance with the conditions and limitations specified in Permit No. NC0023906. Should the City of Wilson be deemed by the Division of Water Quality to be noncompliant with the weekly average and/or monthly average fecal coliform limit after completion of expansion to 14 MGD, The City shall submit plans and specifications within 90 days after notification by the Division. The plans and specifications shall provide for an adequately designed chlorine disinfection facility. If another method of disinfection is proposed, it should conform to conventional design parameters, as well as any minimum requirements specified by the Division. Bidding and subsequent construction of the project shall commence immediately after the issuance of the Authorization to Construct permit. -3- The Permittee shall have an acceptable sludge analysis and a sludge toxicity analysis which have been approved by the Division of Water Quality prior to the disposal of any sludge from the new wastewater treatment plant. Copies of the analyses, supporting documents, and approvals shall be submitted to the Division of Water Quality's Raleigh Regional Office. Prior to the initial operation of these modifications, the City of Wilson will need to modify its residuals permit (WQ0001896) to increase the amount of dry tons per year produced. Also the permit modification will need a detailed review of the number of acres needed versus the number of acres provided. The disposing, selling or free distribution of wet, dried, composted sludge or sludge -like materials from wastewater facilities without prior review and approval by this Division is illegal. During the construction of the proposed additions/modifications, the permittee shall continue to properly maintain and operate the existing wastewater treatment facilities at all times, and in such a manner, as necessary to comply with the effluent limits specified in the NPDES Permit. You are reminded that it is mandatory for the project to be constructed in accordance with the North Carolina Sedimentation Pollution Control Act, and, when applicable, the North Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's responsibilities shall be in complying with these Acts. One (1) set of final approved plans and specifications is to be forwarded to you for your files. The copy of the approved plans and specifications shall be maintained on file by the Owner for the life of the project. Upon completion of construction and prior to operation of this permitted facility, a certification must be received from a Professional Engineer certifying that the permitted facility has been installed in accordance with the approved plans and specifications. Mail the Certification to the NPDES Unit, P. O. Box 29535, Raleigh, North Carolina 27626- 0535. (Engineer's Certification Form is attached.) -4- If you have any questions or need additional information, please contact Mr. Cecil G. Madden Jr., PE (919) 715-6203. Sincerely, A. Preston Howard, Jr., P.E. Attachment BG:nw cc: Central Files Hazen & Sawyer NPDES Unit, Paul Clark DWQ Raleigh Regional Office Mr. Tom Fahnestock Mr. Don Evans Ms. Valerie Lancaster Mr. Bennie Goetze, Jr., P. E. Technical Assistance and Certification Unit DMU SRF 02/06/1998 09:10 9197156229 F62b-05-98 08:26A Hazen and Sawyer DWQ CMG&L PAGE 02 919 B33 1$28 P.O1 To: Company: Fax #: Message: Mr. Goetz: fax Transmission Mr. Rennie Goetz NC DEHNR 919-715-6229 Hazen and Sawyer, P.C. 4011 Westchase Blvd. Suite 500 Raleigh, NC 27607 919-833.7152 Fax: 919-833-1828 From: David Naitor Date: February 5, 1998 You should receive page(s) including this one. Wm do not receive all pages, please can 833-7152. AMIN Re: Hominy Creek WWMF Expansion Contract 3A H&$ No. 3008 Sludge management plan is attached for your review. if you have any questions, please advise. Egagn FEB 5 1998 CONSTRUCTION Q / MTS & WAN SECTION - 02/06/1998 09:10 9197156229 DWQ CG&L Frb-05-98 O8226A Hazen and 8awyor 919 833 1828 PAGE 03 P.02 City of Wilson, North Carolina Hominy Creek Wastewater Management Facility Sludge Management Plan Introduction The Hominy Creek Wastewater Management Facility is to be expanded to a capacity of 14 mgd. The existing sludge handling facilities are adequate to handle the additional sludge production produced at the design flow. The existing facilities include secondary sludge thickening, sludge storage tanks (modified anaerobic digesters) and a liquid lime stabilization batch tank. Additional storage for unthickened waste activated sludge is to be provided under the 14 mgd expansion. It is anticipated that a project to increase plant capacity to 16 mgd will follow the present expansion as required to meet increased plant flows. The City intends to include sludge handling and stabilization facilities in the 16 mgd project as follows: additional sludge thickening facilities, dewatering facilities, alkaline stabilization or composting facilities, and dewatered sludge storage . Sludge Production Sludge production at the Hominy Creek Wastewater Management Facility is projected to be as follows at the 14 mgd design flow. Average Month Maximum Month Primary Sludge, lb/day 15643 21245 Secondary Sludge, lb/day 7421 11636 Total Sludge, lb/day 23064 32661 Sludge Thickening Primary sludge is thickened in the primary clarifiers and pumped directly to the sludge storage tanks (modified anaerobic digesters). Primary sludge solids content is projected to be 4%. The plant currently experiences primary sludge solids content of 5%. Secondary sludge (WAS) is pumped to the gravity belt thickener located in the thickening building. Thickened secondary sludge (TWAS) is pumped to the sludge storage tanks where it is mixed with primary sludge prior to treatment. WAS may also be pumped to the sludge storage basin for storage prior to thickening. WAS solids 02/06/1998 09:10 9197156229 DWQ CG&L Twc.,_ub-uti o8:26A Haze and Sawyer PAGE 04 919 833 1828 p_03 content Is estimated to be in the range of 0.75 to 1% and TWAS solids content is estimated at 5%. Plant experience indicates that WAS and TWAS solids content are 0.75% and 5.5% respectively. Projected liquid sludge loadings are as follows : Average Month PS Production, gpd @ 4% 48891 WAS Production, gpd @ 0.75% 1 16641 Maximum Month TWAS Production, gpd (05% 17796 63684 186027 - 27904 PS +`TWAS Production, gpd 64657 91588 Sludge Stabilization The Hominy Creek plant has four anaerobic digesters, two, of which have recently been converted (by removal of the covers and installation of mixdn9 and pumping equipment) to liquid sludge storage and lime stabilization tanks. The two remaining digesters will be used primarily for storage of primary sludge although they may also be used for partial stabilization by digestion. Primary and thickened secondary sludge are stored in one of the s►udge storage tanks until the tank is full. The contents of the tank are batch mixed with lime for stabilization. The contents of the tank are then hauled away for land application. While the patch tank is being emptied, primary and secondary sludge are stored in the second storage tank. The City presently has a contract with AMSCO, Inc. for liquid lime stabilization and land application. Sludge Storage When the batch tank is full, PS and TWAS are stored In the second storage tank while the batch tank is being emptied. If the second tank is filled prior to the batch tank being emptied, PS Is to be stored in the two remaining digesters and WAS is to be stored In the sludge storage basin prior to thickening. Additional storage capacity can be provided in the sludge storage basin by decanting the liquid off the surface of the basin and allowing the sludge to thicken. WAS concentrations in the range of 1,5 to 2% can be obtained by decanting_ Available sludge storage Is summarized as follows: 02Iman 1999 09:10 9197156229 DWQ CG&L oF,-9t ors: ZEIA Hazen and Sawyer PAGE 05 919 833 1828 P.o4 PS +TWAS Storage in One Storage Tank, days PS Storage in Two Digesters, days Average Month Maximum Month 10 7 28 21 Total PS Storage, days 38 28 WAS Storage in Sludge Storage Bain; days Total TWAS/WAS Storage, days Total WAS Storage by Decanting Basin, days 38 24 48 31 86 55 Sludge Hauling Stabilized sludge is removed from the plant site in tanker trucks with a capacity of 6500 gallons each. The sludge hauler typically works 5 days a week, but can work 6 or 7 days a week if required. in order to make up for wet periods when sludge cannot be land applied, it is estimated that the capability must be provided to haul and dispose of sludge at a rate of 1.5 times the sludge production rate. Hauling requirements based on daily sludge production are as follows: Total Sludge Production, gpd # Trucks /day © 7 days !wk # Trucks /day @ 6 days /wk .110 Average Month Maximum Month -- # Trucks /day@5days /wk # Trucks /day 6 days /wk with peak factor of 1.5 # Trucks /day 5 days /wk with peak factor of 1.5 64687 10 12 14 18 21 01586 14 17 20 25 30 According to plant personnel, a hauling rate of 30 trucks per day is easily attainable and 02/06/1998 09:10 9197156229 DWG! CMG&L ,-D-Ub-sa o$:27A Hazen and Sawyer 919 833 l$28 PAGE 06 P.05 has been achieved In the past. Under normal operation, only 14 (average month) to 20 (maximum month) trucks will be loaded per day to keep up with sludge production. Land Application The City of Wilson owns or leases a total of 1451 acres of land for applying sludge. 1130 acres are corn, wheat, and soybean cropland which, due to the growing season, can only be utilized during the fall. winter and spring. 562 acres of cropland also hes seasonal restrictions due to high water table which, on average, disqualifies about 1/3 of the total or 187 acres per year from use, The City also has fescue and coastal bermuda hay land that can be used for land application during the summer months when cropland Is unavailable. sludge application rates vary based on the type of land. The following table summarizes acreage, application rates and seasonal restrictions: Season Usable Acreage .._ Fall/Winter/Spring Summer Total 943 321 1264 Application Rate Capacity Alliallokomftwas 4.3 tons/ac/yr 4050 tons/yr 8.6 tons/ec/yr 2760 tons/yr 6810 tons/yr Annual sludge production at 14 mgd is projected to be 23064 lb/day or 4210 tons/year. Given the total land application capacity of 6810 tons/year, the City appears to have adequate capacity for the 14 mgd sludge production, The City continues to evaluate additional sand for addition to their land application program, and are concentrating on land with fewer seasonal limitations. During extended periods of wet weather, land application of sludge can be limited. The "winter season° with regard to land application la considered to be the period from mid - December to the end of February (approximately 75 days), The Hominy Creek plant should have capacity available to store sludge that cannot be land applied during the wet season. The decanted sludge storage basin has the capacity to store 86 days production of WAS which would allow storage of the entire winter season (75 days) WAS production. Based upon discussions with AMSCO, the City will be able to land apply sludge a minimum of one day per week during the winter season. This is confirmed based on the City's recent experience during the extremely wet weather of December 1997 and January 1998. The City was able to land apply sludge 5 days in December and 5 days in January. Assuming a hauling rate of 30 trucks per day over 10 days cone day per week for the 75 day winter season), the City can dispose of 1,950,000 gallons of sludge. the equivalent of 41 days of production of primary sludge. If the City can 02/06/1998 09:10 9197156229 VuW-Libi-WN C?F3; a7A Haaon and Sawyer DWQ CG&L 919 033 1828 PAGE 07 P.06 dispose of 41 days of production during the 75 day wet weather season, 34 days production must be stored on site. A total of 38 days of primary sludge storage is available in the existing digesters. IF the amount of primary sludge storage Is exceeded, the City can set up a temporary pump to pump to the sludge storage basin. Once the new sludge storage basin is available, the City will have adequate storage available to accomodate the winter season. 02/06/1998 . 09:10 9197156229 DWQ CG&L PAGE 01 MEMORANDUM To: Division of Water Quality January 7, 1998 Cecil G. Madden, Jr., P.E., Supervisor (Bennie Goetze, Review Engineer) Design Management Unit Construction Grants and Loans Section Dave Goodrich, Supervisor, NPDES Unit Through; Judy Garrett, Water Quality porvisor Raleigh Regional OQicc From: Susan Wilson, Environmental Engine r Raleigh Regional thrice Subject: City of Wilson Wastewater Treatment Plant Expansion Request Project No. C5370381-04 NPDES Permit No. NC0023906 Wilson County COUSTReffriON 'GRANTS & LOAN SECTION ^R!GINAL The RRO has reviewed the consultant's responses regarding the City of Wilyou'a plans and specifications for expansion 11 om 12 MOD to 14 MGD. S ccific;ally, this office still objects to the use of the current '`post aeration/chlorination" basin for chlorination. As stated in the stair report, the proposed configuration will not meet the recrommendo i detention time of 30 minutes, and fecal colifoim limits may not be consistently achieved. The RRO recommends that a special condition be: placed in the Authorization to Construct permit and the NPDES permit which *taws, generally: Should the City of Wilson be deemed by the Division of Water Quality as noncompliant with the weekly average and/or monthly average fecal colifonn limit alter completion of the expansion to 14 MOD, the City shall submit pains and specifications within 90 days after notification by the Division. The plans and spe uifications submitted shell cori ititutc a conventional disinfection system twilh a 30 minute contact time (in a baffled, quiescent %one), if chlorination is used for disinfection. It'another method of disinfection is proposed, it should conform to conventional accepted design parameters, as well as any minimum requirements specified by the Division. Bidding and subsequent construction of the project shall commence immediately after issuance of the Authorization to Construct permit. Plcaso review tho above language. ll is language should be reviewed by your office as well as the NPDES Unit prior to issuance of the Authorization to Construct permit and prior to public notice Lithe NPDI3S permit. Should you have: further questions or require clarification of the state d comment. please eentact.mc at 571-4700, ext. 251. VA J Post -IV Fax Note 7671 Date eestR G 9Y � mat Je (ojr e c4 From�. ti'Q� 3..- Phone #� 1 W - 12 Phone 5 — G 1,1 7 'Fax # 1- 671 / Fax 4 S...' 47. / Date: From: Subject: To: Cc: Hello Don, Tue, 6 Jan 1998 14:24:39 -0500 cecil_madden@mail.ehnr.state.nc.us Re[2]: City of Wilson A-to-C <dons @ dem.ehnr.state.nc.us> Bobby_Blowe@mail.ehnr.state.nc.us Bennie_Goetze@mail.ehnr.state.nc.us (Cecil Madden) (Bobby Blowe), (Bennie Goetze) The NPDES Permit is not ready for notice or issuance. I realize this is not the normal process, however; Preston Howard advised in a meeting with Hazen & Sawyer on November 1, 1997, that he would allow the authorization to construct to be issued prior to issuance of the NPDES Permit. In effect the City is proceeding at their own risk. If for some reason the permit never issues, they will be limited to their existing permitted flow. In reality, the permit is likely to issue long before the new facilities will be available. Construction is expected to take about two years. The primary function of this construction is to provide biological nitrogen removal. Preston agreed with Hazen & Sawyer that it made sfhw Co allow the City of Wilson proceed ahead of their Permit. Regardless of the ultimate decision on the permit, this action will prove to be beneficial to the Neuse River. Please advise if you have any further questions. Best Regards, Cecil. Reply Separator Subject: Re: City of Wilson A-to-C Author: <dons@dem.ehnr.state.nc.us> at Internet Date: 1/6/98 12:36 PM /44,07 601/y ottl��i livtiochnai Sounds good - I'm assuming the NPDES permit (at 14 mgd) is reacly for notice &/or issuance. Thanks, Don Date: From: Subject: To: Cc: Tue, 6 Jan 1998 12:02:38 -0500 cecil_madden@mail.ehnr.state.nc.us (Cecil Madden) City of Wilson A-to-C dons@dem.ehnr.state.nc.us Bobby_Blowe@mail.ehnr.state.nc.us (Bobby Blowe), Bennie_Goetze@mail.ehnr.state.nc.us (Bennie Goetze) Hello Don, This is written in response to your memorandum to Bobby Blowe about the Wilson A-to-C. A draft A-to-C is currently being reviewed by Dave Goodrich for format. We anticipate getting the regional office signoff by Friday. The consultant owes us an approval letter from the Land Quality Section, A letter from the Corps of Engineers, and revised Plans & Specifications that reflect their written responses to our review comments. Upon receipt of the above information we will submit an A-to-C to Dave for signature. The ball is currently in Hazen & Sawyer's court. Best Regards Cecil Donald L. Safrit, P.E., Assistant Chief for Point Sources Water Quality Section - Division of Water Quality Department of Environment and Natural Resources 512 N. Salisbury Street - Post Office Box 29535 Raleigh, North Carolina 27626-0535 Telephone (919) 733-5083, extension 519 Fax (919) 733-9919 State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director MEMORANDUM To: wivr 1E3EHNF� FAX (4 total pages) December 30, 1997 Bobby Blowe Construction Grants and Loans FAX 715-6229 From: Don Safrit, Assistant Chie for oint Sources Water Quality Section Subject: City of Wilson - Hominy Creek WWTP NPDES Permit No. NC0023906 Authorization to Construct Neuse Nutrient Management Strategy Attached you will find a letter from the City regarding a recent meeting held with Preston and the need for issuance of the Authorization to Construct. Now that decisions have been made relative to the Neuse Nutrient Management Strategy, we should be in a position to move forward with appropriate action. Please review the attached letter and let me know the path we should take. If you have any questions, please feel free to contact me at (919) 733-5083, ext. 519. cc: Dave Goodrich Bob Sledge P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper HAZENA1 D SAWYER Environmental Engineers & Scientists December 18, 1997 Mr. A. Preston Howard Jr., P.E. Division of Water Quality NC Department of Environment and Natural Resources P O Box 29535 Raleigh, NC 27626-0535 Dear Mr. Howard: Hazen and Sawyer, PC. 4011 WestChase Blvd. Raleigh, NC 27607 919 833-7152 Fax: 919 833-1828 Re: Request for Authorization to Constuct City of Wilson EMC SOC WQ 95-21 NPDES NC0023906 3'i r • Thank you for meeting with representatives of the City to discuss the problems that we have faced in our attempts to upgrade the City's Hominy Creek wastewater treatment plant. As we discussed, the City's SOC requires construction of the wastewater treatment plant improvements to begin by November 1, 1997. Despite timely compliance with all necessary prerequisite steps, the City has not yet received the needed authorization to construct (A to C) from DWQ and accordingly has not met this milestone date. Additional milestone events in the SOC will be similarly be delayed due to failure to begin construction by Nov 1, 1997. With your assistance, we are hopeful that we can get the project back on track and complete the improvements as quickly as possible. As discussed in our meeting, we request your support in separatina the Authorization to Construct from the issuance of the NPDES permit. Issuance of the A to C has been delayed due to ongoing policy level debates relative to nitrogen limits in the Neuse River basin. This debate has in turn delayed consideration of the City's request for a NPDES permit revision. While progress has been made on the permit questions, we understand that formal issuance of the permit will probably not occur until sometime in the spring or summer of 1998. Continued delay in beginning construction of the plant improvements also further complicates the City problems with the flow restrictions contained in the SOC. We are actively working with the Construction Grants staff to resolve the remaining comments on the Contract Documents. We are hopeful that this effort can be New York, NY • Armonk. NY • Woodbury. NY • Upper Saddle River, NJ • Detroit, MI • Raleigh, NC • Charlotte, NC • Fairlax, VA • Hollywood, FL • Boca Raton, FL • Fort Pierce, FL • Gainesville. FL • Sarasota, FL • Miami, FL HAZEN AND SAWYER Mr. A. Preston Howard, Jr. P.E. December 18, 1997 Page 2 We are actively working with the Construction Grants staff to resolve the remaining comments on the Contract Documents. We are hopeful that this effort can be completed by early January. Subject to approval by the Construction Grants group, we would then be prepared to proceed immediately with the bidding process. We also understand that DWQ will acknowledge that the delays to date are not attributable to the City and support adjusting the dates for construction and final permit compliance set forth in SOC. Thank you again for your time and support of this request. Very truly yours, HAZEN AND SAWYER, P.C. Donald L. Cordell, P.E. Vice -President cc: Mr. Charles Pittman Mr. Jim Cauley