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Facilities Plan and the SDC methodology. Mr. Noesen said the caPacity assessment that is in the NPDES fact sheet was from 1996 when the staff submitted the permit renewal application to DEQ. Staff took information from the 1997 Master Plan, which was under development at the time. It · took a number of years for DEQ to re-issue the permit and DEQ kept that 1996 data sheet and never re-evaluated it. There is a 12% increase in the maximum peaking faCtor between the 1997 data and today. Mr. Noesen said a critical point is CBOD and TSS are now surrogates for ammonia. Ammonia and thermal load are now in the permit and ~rameters were not in the permit in 1996, when the capacity assessment was done for the laster Plan. When the · SDC methodology was being evaluated, ammonia and not be capacity parameters. Mr. Noesen said the reason these could not for all the users (industrial, residential, and commercial) is because the to be able to implement SDCs and monthly user rates for these To pound of ammonia versus remOving one pound of CBOD is icant impact to ca thiS is captured in the current data but was not lyses, or' ~e permit, in Referring to the DEQ letter and statement, C Morrison asked when DEQ changed their policy to req to use flows instead of average flows when looking at capacity. Mr. Noesen pc changed in 1991, and in 1996 DEQ refined the change to that policy. 3at the Master Plan is in error and incorrectly assessed capacity. The Plan s month flows (in' his ' opinion) compared to the 4 ~ermal load and ammonia in the permit. Commission, Iow their own policy and Mr. Noesen agreed. Ms. Smith that ~n was not submitted to DEQ for review, because it was not like the 2004 Facilities plan. The 2004 Facilities ~ccordance with DEQ guidelines since the 208 Pla~ qoesen rewE projections that formed the base for the 2004 Facilities Pll ~e SDC data and growth rates were evaluated and used to pre' populatio ~e basis used for the Facility Plan. It reflects an antici [ced rate of I: lation growth. He said if the argument is used that the population' numbers are gh or too when it comes down to determining SDC rates and monthly sewer rates, ti' a big impact. Mr. Noesen the dry season maximum month flow historical and projected data. He said DEQ statistical method to arrive at the 10-year dry season and five-year wet season'data and staff is in ongoing discussions with DEQ to use the Plan's projections, which are conservative, instead of DEQ's numbers, which Would be even more conservative. He commented that the 2004 Facilities Plan is based on projections that are reasonable, lower than what was developed in 1997, and significantly lower than what DEQ would like to be used. 4-59