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HDR Engineering, Inc. 8400 Fairview Road RD. 8ox 11257 Telephone: of North Carolina Charlotte, Nor{h Carolina Charlotte; North Carolina 704 364-1800 28210 28220-1257 February 23, 1988 Mr. Charles McGinnis County Manager P. O. Box 707 Concord, N. C. 28025 Re: Rocky River Regional Wastewater Treatment Plant Proposed Wastewater Treatment and Pretreatment Agreement City of Concord HDR Project No. 187-21-18 Dear Cbarles: On Thursday, February 18, I received a telephone call from Doug Figan, NCDEM, concerning the proposed agreement referenced above and statements I made at the Commissioners meeting on February 15, 1988, and in my letter to you on February 4, 1988. Mr. Finan called to clear up the question of whether or not interjurisdictional agree- ments are required as a part of the pretreatment program the City is ~equired to set up under 40 CFR 403. While Mr. Finan did not remember my telephone conversation with him on February 4, 1988, he said that, in fact, interjurisdictional agreements are required when multiple municipalities or units of government are involved. That was not my understanding when I talked with him on February 4. While 40 CFR 403 itself does not require these agreements, Mr. Finan says that they are required when viewing 40 CFR 403 in combination with other regulations. I have requested information on these other regulations which were not cited. The primary reason for tile interjurisdictional agreements is to enable the NPDES holder for the Publicly Owned Treatment Works (POTW) to have an avenue for enforcement action against the violator of the pretreatment program requirements (The Industrial User). The interjurisdictional agreement sets up the methodology for enforcement action. Depending on how tile interjurisdictional agreement is set up, tile enforcement action can be either direct to tile Industrial User, or through a third party (the County or municipality where the Industrial User is located). Mr. Finan did state that while the agreement proposed to the County may have been reviewed by the State, their rDview did not mean the agreement was in final form and could not be amended.