Ohio EPA (addressee — Justin Williams, DSW Northwest District Office)

extension request letter (SECAP plan update, per DFFO Section V(1)(E)(iii))

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Allen County Sanitary Engineering Department (Stephen M. Kayatin, P.E., Sanitary Engineer) on behalf of the Board of Commissioners

Shawnee II POTW; American-Bath POTW (background)

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2011-12-09

requests modification of the 2005-05-31 DFFO SECAP schedule (2015-12-31 eliminate-all-SSOs deadline -> +5 years)

granted in substance by the 2014 Modified DFFO (journalized 2014-01-06)

The county's five-year-extension request that became the 2014 modification. Documents the strategic pivot from collection-system rehabilitation to COLLECT-PUMP-TREAT after the Seriff Sub-Basin pilot showed rehabilitation flows "still too great and the cost ... too excessive"; SECAPs for both POTWs approved by OEPA April 2009; the American-Bath trunk replacement (completed late 2009) closed that system's one SSO ~6 years early, and — per a 2011-09-26 county letter — OEPA authorized FOREGOING the American-Bath WWTP expansion after wet-weather monitoring, saving "nearly $7,000,000". Rates: +64% over the prior 6 years with a further 10% scheduled ("80% higher than they were 6 years ago"). The county argues designing Shawnee WWTP improvements from modeled rather than monitored flows risks "overdesign of wastewater treatment plant improvements".

[verified] as the county's statements in its own letter. The overdesign concern and the design-from-actual-flows sequencing are the stated rationale for the five added years — the letter defers Phase 2 WWTP sizing to a post-construction flow-monitoring period rather than stating any capacity figure.