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Show epa position The following letter, detailing the Environmental Protection Agency's position on the regional treatment plant and the history of their involvement, was sent to Mayor Leon Uriarte by EPA Regional Administrator John Green. Dear Mayor Uriarte: This is in reference to the Snyderville Basin Sewer Improvement District meeting of February 14, 1977. This meeting, open to the public was called to discuss a proposed bond election necessary to raise the local matching share for the cost of a sewage treatment works project to be funded in part by a 75 EPA construction grant. In attendance for the District at this meeting was Mr. Jim Brooks, EPA, Region VIII, Office of Grants, and Mr. Fred Pherson, Bureau of Water Quality, Utah Division of Health. Most of the public input at the meeting opposed the bond election for various reasons. The impression obtained by both Mr. Brooks and Mr. Pherson was that a concentrated effort would be undertaken by a number of Park City's citizens to defeat any bond election and to moe to have Park City withdraw from the District. Apparently their reasoning was that Park City would benefit by upgrading their present treatment system instead of participating in the approved plan to provide a regional treatment system and management to serve the Snyderville Basin area. The regional concept is described in the Snyderville Basin Facilities Plan for the area designated by the State as required under the Federal Water Poll ion Control Act of 1972 as amended (FWPCAA) as a Section 201 j anning area. In conjunction with the plan, a public hearing was held at the Masonic Hall, Park City, Utah, on October 22, 1974. The purpose of this meeting was to discuss the proposed project and environmental impacts. No opposition to the proposed project was voiced at that meeting. A negative declaration and environmental appraisal for the project was published by EPA on July 29, 1975, and the facility plan was approved by this Office on September 19, 1975. On September 12, 1975, the Snyderville Basin Sanitary Improvement District was awarded a Step 2 grant for the preparation of plans and specifications for the proposed project and the rehabilitation of Park City's sew age collection system. The plans and specifications are complete and are being reviewed by the Utah Bureau of Water Quality. After a facility plan for a specific planning area has been approved by the EPA, the Act requires that all subsequent grants please turn to page seven - ( - r - ;0 .:. .. .: .. s!iR'.liut' from page t'0 ijr iiir.st.-uclifn .i cwupt treatment v. .irks ."nrvrro will; the :;rp;: niili' j.art ol the ph n ;i:nl thai v rants be made to thr ciiMvuatcii management agency. Planrrng tor the Park Ci'y area ;.. cm tred in the Snvderviile Basin Facilities Fian and the Snvderviile Basin .Sewer Improvement District is the designated in a n a ge ment age n cy . Further, provisions of the Federal Water Pollution Control Aei require that any discharge from a publicly owned wastewater treatment plant must meet applicable effluent limitations of an effective NPDES permit, and by July 1. 1977, attain a minimum quality level identified as secondary treatment. To assist publicly owned treatment systems in obtaining this minimum level of waste treatment, the FWPCA provides assistance in funding of any necessary projects through the construction grants progrm. Also, the State has established more stringent discharge requirements which must be attained by 1980. EPA recognizes the State's legal authority to impose the more stringent effluent limits. The present design for the regional system incorporates treatment to meet the State's 1980 effluent standards. As you are aware, Park City Municipal Corporation as a member of the Snyderville Basin Sewer Improvement District is involved in this assistance program in order to insure compliance with its NPDES permit. Failure to maintain compliance with permit conditions or attain the July 1, 1977, secondary treatment level is a violation of the FWPCA, which normally results in legal proceedings being brought against the permit violator. However, if a sincere and diligent effort to fund a compliance program is being made, and the existing treatment system is operated at its.maximum efficiency, this agency has taken the posture of allowing additional compliance time extending, within reason, beyond the July 1, 1977 statutory deadline. If, on the otherhand, the efforts or circumstances are such that the community is not making every possible effort, then EPA has little alternative but to seek the legal relief available to the agency. The difficulty in passing a bond issue to fund Park City's shareof a new regional Treatment system jeopardizes the City in three ways. If, within the time constraints given by the Construction grants program,' adequate local share funding cannot be raised, the, availalbe Federal share will be lost. Secondly, civil penalty provisions for failure to maintain NPDES permit compliance will have to be utilized if violations continue to occur and no efforts to proceed with compliance measures are made. Thirdly, the imposition of what is called a 402(h) tap ban must also have to be addressed. Section 402(h) of the FWPCA provides that the agency can request the United States District Court to place a moritorium on new hook-ups to a publicly owned treatment system if that system is in violation of its discharge permit. This measure is designed to act as an assurance against further degradation of a non-compliance situation by preventing any additional wastewater contribution to an overloaded treatment facility. We respectfully request that the facts of this matter be brought to the attention of the people of Park City while they are in the process of considering the bond proposal. Upon the outcome of the bond election, we also request that this office be immediately informed of Park City's position relative to the status of its wastewater treatment system. Sincerely yours, John A. Green Regional Administrator |