MEMO REGARDING SCHEDULE LETTER
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C I T Y
OF
CLEARWATER
POST OFFICE BOX 4748
CLEARWATER. FLORIDA 33518
January 28, 1977
PICOT B. FLOYD
CITY toeANAGER
Mr. George L. Harlow
Chief, Water Enforcement Branch
Enforcement Division
Environmental Protection Agency
Region N
345 Courtland Street
Atlanta, GA 30308
Attention: Mr. Will iam Taylor
Re: Enforcement Com pI iance Letter
NPDES Permit No. FL 0021865
Clearwater East Treatment FtJcil ity
Dear Mr. Harlow:
We have reviewed the Enforcement Compliance Schedule Letter from your office
dated January 19, 1977, relative to NPDES Permit No. FL 0021865 for the
Clearwater East Wastewater Treatment Facil ity.
On Attachment II, Item 1 of the Schedule of Compliance states, "Complete
construction and el iminate discharge not later than March 31, 1979. II On
November 16, 1976, our consulting engineer, Briley, Wild & Associates, sent
an application to your office for reissuance of the subject NPDES permit for the
Clearwater East Facility, together with a Compliance Schedule to meet the final
effl uent discharge I imitations. The Compliance Schedule recommended a date of
July, 1980 for meeting the discharge limitations for the following reasons:
The Water Quality Management Plan for the Tampa Bay Basin prepared by
the Tampa Bay Regional Planning Council in 1973 recanmended the construction
of a regional wastewater treatment facility in the northeast section of Clearwater
with advanced wastewater treatment and discharge of final effl uent into upper
Tampa Bay. The Clearwater East Facility would provide secondary treatment of
wastewater and the effluent would be pumped to the Clearwater Northeast
Facility for advanced wastewater treatment. The City of Clearwater immediately
proceeded with design of the facility and applied for federal grant assistance for
cc: Briley, Wild & Associates
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Mr. George L. Harlow
January 28, 1977
Page 2
construction. In mid-1975, the Environmental Protection Agency decreed
that deep well injection be studied as an al ternative to advanced wastewater
treatment and surface discharge for the Northeast Facility and the City received
a Step I EPA grant on September 7, 1976, to prepare a site evaluation study
and construct an injection test well and monitoring well to study the feasibility
of effluent disposal by deep well injection at the site of the Clearwater East
Plant. We estimate that the construction and testing of the deep well facility
and the feasibility study will not be complete until March, 1978, and that the
design and construction of the canplete deep well disposal system, including
pump stations and force mains will not be complete until July, 1980.
The City of Clearwater received a federal grant to construct the secondary
facilities for the Northeast Regional Treatment System on March 4, 1976, and
this project is now under construction. The effluent disposal system, pumping
stations, pipe lines, and other appurtenant facil ities which may be required
are not incl uded in the construction contract.
It should be emphasized that the dates listed on the Compliance Schedule
submitted with the NPDES application were based on the approval of deep well
injection as the effl uent disposal plan. If deep well injection should not prove
feasible, and it is necessary to provide advanced wastewater treatment facilities
at the Northeast Plant, the completion date could be later than July, 1980.
Therefore, the City of Clearwater will not be able to comply with the date of March,
1979, listed in your Enforcement Compliance Letter. We request that the date be
changed to JuJ y, 1980.
We are returning the Compliance Letter unsigned per Mr. Taylor's instructions to
Mr. John Dennis of Briley, Wild & Associates.
If you have any questions relative to the proposed Compliance Schedule, please contact
Mr. Anthony Shoemaker of the City of Clearwater or Mr. John Dennis of Briley, Wild
& Associates.
Very truly yours,
p~f3J'd-
Picot B. Floyd ICMA
City Manager
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. HARRY E. WILD, P.E.
(1914-19711
. HAROLD 0'. BAILEY, P.E.
(190&19701
. B. N. WILSON, P.E.
(t8SK-18731
J3'til~y, CWild 5- dfj.j.ociat~j.
CONSULTING ENGINEERS
ORMOND BEACH CLEARWATER
FLORIDA
. HARAV E. WILD,_ ..JR., P.E.
. .JOHN F. DENNIe, P.E.
January 24, 1977
. FEASIBILITY
. PLANNING
. AEPORTS
. APFlIAAISALS
. CONSULTATION
. DESIGN
. INSPECTION
. RESEARCH
. A. oJ. E!lIFIICHALL, ,",It.
. L.. ..I. DILLARD, .JR., P.E.
. WILLIAM Q. DUKE, M.E.
. STEVEN E. THAYER, FI.E.
WHELN REPLYING PL.EASE ADDRESS:
40e SOUTH PFIIOSPECT AVENUE
CLEARWATER, proLOptlCA 3351t!
813/_2-71'""
CL 7712-9 CE
Mr. Anthony L. Shoemaker
Assistant City Manager
City Hall
Clearwater, FL 33516
Dear Mr. Shoemaker:
Re: Enforcement Compl iance letter
NPDES Permit No. Fl0021865
CI earwater East T reaiment Faci Ii ty
We have reviewed the Enforcement Compliance Schedule letter from Mr. George
L. Har/ow, Chief of the Water Enforcement Branch of the Environmental Protection
Agency regarding the Compliance Schedule for the Clearwater East Treaiment
Facility, NPDES Permit No. Fl0021865.
As you know, if a municipality cannot meet the July 1, 1977, final effluent
limitations as defined in the Federal Water Pollution Control Act by July 1, 1977,
a Compliance Schedule must be submitted with the NPDES Permit Application stating
a date when it is anticipated that the municipality will be able to comply. The
application for reissuance of the NPDES Permit for the East Plant was submitted to
EPA on November 16, 1976. We included a Compliance Schedule as required which
indicated that the estimated date of compliance with the discharge I imitations would
be July, 1980.
In the letter sent by EPA to the City on January 19, 1977, Attachment II, Schedule
of Compliance, states, "Complete construction and eliminate discharge not later then
March 31, 1979. II According to the Compliance Schedule submitted by the City with
the application, completion of construction will be July, 1980.
Compliance with the discharge limitations will be dependent on the completion of
the 201 Facilities Plan, the deep well injection feasibility study, and approval by
cc: Mr. Max G. Battle
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Mr. Anthony L. Shoemaker
January 24, 1977
Page 2
the stote and federal agencies of an effluent disposal plan. If deep well injection
proves to be feasible, the East Plant effluent will be disposed by deep well injection.
However, if deep well injection is not approved, it will be necessary for East Plant
effluent to be pumped to the Northeast Plant for AWT and surface water discharge.
Any required design for the East Wastewater Treatment Facility cannot commence
until the effluent disposal plan is approved.
Therefore, Mr. Floyd should not sign the Enforcement Compliance Schedule committing
the City to eliminate discharge by March 21, 1979, and EPA should be so notified.
I am enclosing a copy of the letter of transmittal, NPDES PellT1it Application and our
Attachment No.1, Compliance Schedule for your use.
Very truly yours,
BRILEY, WILD & ASSOCIATES
CONSULTING ENG INEERS
JFD:mjc
Enclosures
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