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OF PORTSMOUTH December 6, 1979 Interdepartmental Correspondence SItee TO: R. T. Williams, City Manager FROM: J.A. Howell, D~rector. Pubt~c Ut~l~t~e~/~,/ COPIES TO:. C. H. McGinnfs SUBJECT: Modification of Secondary Treatment at Pinners Point This is not a draft letter as you requested, hut simply a recap of the situation as I see it. Mr. McGinnis has discussed this with members of the S~CB as well as HRSD and very likely has some informa- tion tha~ I do not have. The Federal Register', Part IV, June 15, 1979, promulgated' the final rules for establishing the criteria to be applied by EPA in acting upon applications for issuance of a National Pollutant Discharge Elemination System (}~P~ES) permit which modifies the requirements of secondary treatment under Section 301 (h) of the Clean Water Act. The rules required, among other things, that the application be filed within 90 days of the effective date of the regulations (September 13, 1979). ' This was discussed with ~r. McGinnis and he approved contacting Malcolm Pirnie~ Inc., who were preparing HRSD'~ application to get costs and a time frame for preparing a Portsmouth application. Malcolm Pirnie fel~ that the time frame could not be met. The costs were estimated to be between $25 and $30 thousand. The regulations contain the following statement which lends further credence to the ~mpossible time frame: "As a practical matter, it is highl~ unlikely that applicants which have not already undertaken, e~tensive, studies of less than secondary treatment options wilI be able. to comol'ete, a Section 301 (h) application or make. the showimgs requized~y tt~iS Subpart." Based on the above,, a 'Portsmouth apptiaatiom prepared. The HRWQA 208 Water Quality'Study clearly indicated that secondary treatment hy the existing plants-wi~h out,fails in the Elizabeth River would have no appreciable effect on' the quality of t~at body