September 28, 2010

 

 

Denise Bosnick

West Memphis Utility Commission

604 East Cooper

West Memphis, AR  72301

 

 

Dear Ms. Bosnick:

 

The Department has incorporated the changes in the City’s document attached to the WMUC email dated 3-3-2010.  Presently, the Department has some concerns:

 

1. The City did not address some of the changes proposed by the Department earlier.  These changes were not incorporated and are shown in either red or green in the attached proposed ordinance.
2. The City must accept the two (Waters of the “STATE” and User definition) changes shown in red in sections 1.4(35) & (57).  The City may elect either to accept and/or modify or to reject changes shown in green.
3. The City also included “Optional” Streamlining Updates.  The original intent of the Streamlining updates was to lessen the administrative burden on the POTWs but the optional updates actually increased the burden.  Most cities have elected to omit all optional updates.  In addition, if the City elects to include an optional update, the Department may decide to declare the modification as a Major Modification in accordance with 40 CFR 403.18 (b) & (c).  The Department has highlighted all optional updates in strike-out green.

 

Please make all the recommended/required changes and send the Department a new “Word” DRAFT in “ordinance format” acceptable for adopting by the City Council.  The Department will review this final draft and attach the approved version to the audit report.

 

The Department will expect to receive the DRAFT by October 22, 2010 if the City wishes to have an approved version included with the audit report.

 

If the City has concerns, please contact the Department at (501) 682-0626 or by email at  torrence@adeq.state.ar.us .

  

Sincerely,

Rufus Torrence, Pretreatment Engineer

Water Division