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December 7, 1979 Mr. Douglas M. Costle Administrator U. S. Environmental Protection Agency 401 M Street, S. W. Washington, D. C. 20460 Desr Mr. Costle: Under the provisions of PL 92-500 the City of Portsmouth developed a 201 Fac~]~ties Plan in 1975 to upgrade the Pip/~ers Point waste water treatment plant frc~ pr~ to secondaz!; as required by EPA regulation. This is a 15 I~/~D plant owned and operated by the city and treats t-%e bu3_k of the sewage in the city. The Hampton Roads Sanitation District trea~s a relatively ~mz~! amount of s~.zage in the nortIm~estern p~m~c of t-he city. ~ae facilities plan estimated the total cost of the plant to be $23,643,000_.00. The city was not fur~ed for a Step II grant until FY 78. Design of the plant has been completed ar~ sutmlitted to state rec3l~atory agencies for approval. The prOject ~as b~l parhially funded in FY 80 and t~he city is in the process of preparing a Steep III grant application. The estimated cost of the plant by our consultants is ~ $29,000,000.00 based.on an ERR index of 3150. Our consult~nnts have a~vised us ~oftso that the operating ancl maintenance costs of the proposed facilities will approxi.~atety double that of the ey~isting plant. The Federal Register, Pe~t IV, dated June 15, 1979, promu!gaqed t_he final rules for establish/rog the criteria to be applied by EPA in acting upon applications for issuance of an NPDES permit, which modifies the requireT~_nts of secondary %rea~=~nt ra~er Section 301(h) of the Clean Water Act. The city was urm~are of the deadline for the prelLminary application and was advis~ed by consultants %=hat it %~s i~possible to prepare the full application in ~e 90 day time 1L~it. Subsecfden% to the devel~t of the Pinners Point 201 plan ~nd cu~le~ion of the design, hhe Hmmpton Roads Water Quality Agenclz co~.~pleted the 208 study vJlich included the Southern Branch of the Elizabeth River. ~ne outfal! Qf ~he Pitiers Point plant flc~s into this run of ~the river. The 208 s~/dy clearly indicated that utx3radLng to secondary ~reatment by the exis~Jing pt~nts ~rith outfatls in the Elizabeth v~uld have no appreciable effect on t~_e quality of ~hat body Of water. That study fu=-~ rec~n~ed that ~he portion of the Elizabeth River affected by the Pinners Point discharge be designated as an Urban Use Segn~nt.