Memorandum

TO:              Diane Stoddard, Assistant City Manager

FROM:         Dave Wagner, Director of Utilities

CC:                        Philip Ciesielski, Assistant Director of Utilities

Mike Lawless, Assistant Director of Utilities

DATE:           March 3, 2009

RE:                  NPDES Permit Process – Airport Options

I spoke to Rod Giesler with KDHE regarding the concept of on-site wastewater treatment systems for the airport. He indicated that getting a NPDES discharge permit approved for a facility would be “very difficult.” Specifically KDHE would require an anti-degradation study and the option would have to show the lowest cost based on a 20-year present worth analysis. This process is very similar to what we went through for the Wakarusa Water Reclamation facility permit. The process is costly and very time consuming. Past evaluations and considerations of how to serve the airport have indicated that on-site treatment is not the most cost effective or operationally / environmentally preferred option. With implementation of new nutrient standards for discharges since those evaluations, it is even more unlikely that on-site treatment is a feasible alternative worth considering.

Given the limited time frames and the limited services needs, the department recommends evaluating the possibility of a short-term solution of storage and hauling of the wastewater, with an option in a latter phase to convert the storage for use in a pump station. Further consideration of other alternatives could be included in an Airport Master Plan.