Item 4G - MemoItem 4G
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M E M O R A N D U M
August 5, 2025
To: Alison Ortowski, City Manager
From: Lauren LaNeave, Interim Director of Public Works
Subject: Ordinance No. 1294, 1st Reading, an amendment to
Chapter 9.5, Article 3 of the Southlake City Code,
updating the Industrial Wastewater Pretreatment
Program.
Action
Requested: Ordinance No. 1294, 1st Reading, an amendment to Chapter
9.5, Article 3 of the Southlake City Code, updating the
Industrial Wastewater Pretreatment Program.
Background
Information: The City of Southlake is contracted with the Trinity River
Authority (TRA) to treat received wastewater. All of
Southlake’s wastewater flows to either TRA’s Denton Creek
or Central Regional Wastewater facilities to be treated.
Similar to Southlake, TRA operates on a Texas Pollutant
Discharge Elimination System Stormwater permit, requiring
routine updates to control stormwater pollution. In 2024, the
City of Southlake adopted the Central Regional Wastewater
System’s revised Pretreatment Program, under Ordinance
No. 836-A and Funding Resolution No. 24-045.
In 2023, the Trinity River Authority Denton Creek facility
submitted a revised pretreatment program to the Texas
Commission on Environmental Quality (TCEQ), which
included updates to the hazardous waste discharge
notification process, the dental amalgam rule, and proposed
technically based local limits (including allowance decrease in
Copper and Lead and allowance increase in Cadmium, Nickel
and Zinc). As of May 6, 2025, the TCEQ has reviewed TRA’s
pretreatment program and designated it as “technically
complete.”
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As a customer city, Southlake must enact equally or more
stringent regulations pertaining to wastewater content and
pretreatment. All customer cities of TRA must obtain a signed
attorney statement, proceed with adequate public notice, and
pass the program through the City Council.
Compared to the ordinance passed for the Central Regional
Wastewater System in 2024, there are only three changes to
the ordinance: inclusive language to address both treatment
facilities in the preamble, the insertion of “categorical” under
the definition of Total Toxic Organics, and the local discharge
limits for the Denton Creek facility. All changes are marked in
the ordinance attachment.
Financial
Considerations: There is no cost associated with this program update at
present. If an industrial site enters Southlake, there would be
a cost to provide industrial sampling and analysis services
through TRA. While the cost is dependent on the number of
samples and contaminants analyzed, historically, we have
spent approximately $1,250 per quarter on industrial
sampling.
Strategic Link: The ordinance link to the City’s strategy map relative to the
focus area of Performance Management & Service Delivery.
The specific corporate objectives that are met by this
ordinance are B1 Achieving strong outcomes through
continual evaluation and pursuit of better practices that
improve core business operations.
Citizen Input/
Board Review: While this action does not require review by citizens or the
board, it is worth noting that the previous adoption of the
Pretreatment Program for the Central Regional Wastewater
System was approved without any public or board comments
Legal Review: The City Attorney reviewed Ordinance No. 1294.
Alternatives: The City Council may approve or deny Ordinance No. 1294.
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Supporting
Documents:
• Attachment A: Ordinance No. 1294
• Attachment B: Attorney Statement (to be signed following
approval)
• Attachment C: Enforcement Response Plan
• Attachment D: Resolution No. 25-028 (to be proposed at the
August 19th City Council meeting)
Staff
Recommendation: Approve Ordinance No. 1294, 1st Reading, an amendment to
Chapter 9.5, Article 3 of the Southlake City Code, updating
the Industrial Wastewater Pretreatment Program.
Staff Contact: Lauren LaNeave, Interim Director of Public Works
Jack Thompson, Deputy Director of Public Works
Madisson Dunn, Environmental and Regulatory Supervisor