Agenda - 03-26-2009 - 4a7 - Laserfiche WebLink

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4a-72 Orange Water and Sewer Authority Jordan Lake Comments to NC Environmental Management Commission July 10, 2007 Page4of5 Wastewater Plant Optimization We encourage the Commission to clarify the text and intent of proposed Rule .0270 (5)(a), that requires the operation of existing wastewater plants to be o timized. Much of the wording of this section is identical to previous State guidance that required wastewater plants to optimize operations before constructing expensive nutrient reduction facilities. We believe that the Rule should also define and specify optimization requirements for wastewater plants, such as OWASA's, that have completed all or most of the capital improvements needed to achieve the nutrient reduction targets. This specification should provide adequate time to establish the realistic ranges of treatment plant operating conditions and process configurations needed to reliably achieve different degrees of nutrient removal. For example, OWASA will require additional time to fully evaluate the relative cost effectiveness of different carbon sources, such as methanol, acetic acid, sugar water, etc., needed to achieve denitrification in our new filter system. One of our goals is to maximize OWASA's reliance on biological treatment, rather than chemical addition, to achieve water quality goals. We urge the Commission to adopt rules with enough flexibility to ensure our customers that the millions of dollars they have already invested in capital improvements to our wastewater plant -and the millions of additional dollars they will spend to operate those new facilities for nutrient removal -will have the greatest likelihood of achieving measurable downstream water quality benefits. Nutrient Reduction Trading and Offsets OWASA supports and applauds the flexibility of proposed Rule .0269 that would allow wastewater dischargers to enter into compliance groups and to participate in nutrient trading and offset arrangements with both point and nonpoint source entities, such as municipalities, universities, and state agencies. Compliance Date for Point Source TN Reduction OWASA supports the proposed 2016 compliance date for total nitrogen reduction from point source dischargers. We do not believe that an earlier date will provide sufficient time and flexibility for the Commission to apply the adaptive management principles of Rule .0262 (7), but there may be merit to phasing in or gradually "ramping up" the TN reduction requirements with 2016 as the target date for full implementation. We note that an early compliance date would substantially limit the opportunities for wastewater dischargers and other local entities to earn and trade TN reduction credits through flexible arrangements that may be more cost effective than independent compliance by each individual entity. Between now and the eventual point source compliance date, OWASA will continue pursuing and implementing cost-effective methods to further reduce our wastewater contribution to the Upper New Hope nutrient load.