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EPA Proposes Granting NYCDEP Conditional
Relief from Completing Final Design of the Cat/Del Filtration Facilities
EPA Proposes Granting NYCDEP Conditional Relie From Completing Final Design
of the Cat/Del Filtration Facilities
EPA is proposing to relieve New York City of its obligation to complete the final design of a drinking water filtration system for the Catskill/Delaware watershed as long as the City increases protections of the water supply. The FAD allows New York City to not filter the drinking water from this system, but does require it to complete a final design for a filtration system that could be used if filtration were deemed necessary in the future to protect the drinking water. The Agency is willing to drop the FAD requirement for a final filtration system design as long as the city completes its preliminary design, sticks to a strict schedule for upgrading sewage treatment plants that empty into the watershed, takes other watershed protection measures, and designs and builds a facility that would disinfect the Catskill/Delaware water using ultraviolet (UV) light. EPA is seeking public comment on its proposal.
According to the FAD, New York City could ask EPA for relief from proceeding with the final design of a filtration plant after it completed the draft preliminary design stage. NYCDEP did just that in December 2000. After careful review of information provided by the City and its commitment to a number of protections and improvements B including the UV light disinfection plant, and the upgrade of key sewage treatment plants B EPA believes that design of filtration facilities beyond the preliminary stage may not prove necessary. The City is required, however, to complete its preliminary design of a filtration system by September 2001. Should the City fail to meet the strict timetable set for the improvements, the final filtration plan design requirement of the FAD would be reinstituted.
Among many other watershed protection programs, EPA = s FAD required New York City to install microfiltration (or equivalent) in all wastewater treatment facilities located within the Catskill/Delaware watershed. In its mid-course review of how the City was faring in its commitments under the FAD, EPA expressed concern that the improvements were not being made fast enough. In its request to EPA for relief from having to complete the final design stages of a filtration system, NYCDEP committed to upgrading wastewater treatment facilities in the watershed that account for 83.3% of the wastewater flow in the area by end of June 2002. Failure of the City to meet these deadlines would result in the re-imposition of FAD requirements to complete the final design for a filtration system for the Catskill/Delaware.
NYCDEP will also complete a feasibility study on the use of UV light to disinfect Catskill/Delaware water, and will submit its findings to EPA by December 31, 2001. If feasible and if agreed to by EPA and the New York State Department of Health, the design and construction of a UV facility will proceed.
Correspondence on this issue is available in pdf format. Please use the following links:
Letter from NYCDEP to USEPA requesting relief,
dated 12/28/00-
Letter from EPA to NYCDEP requesting clarification,
dated 3/7/01
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Letter from NYCDEP to EPA providing additional
information, dated 6/29/01
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Letter from EPA to NYCDEP proposing conditional
approval of the City's request for relief, dated 7/13/01
