Item 7ICity of Southlake, Texas
MEMORANDUM
April 1, 2003
To: Billy Campbell, City Manager
From: Pedram Farahnak, P.E., Director of Public Works, ext. 2308
Subject: Resolution No. 03 -024, endorsing the implementation of a continuing
Pretreatment Program as required by 40 Code of Federal Regulations (CFR)
403 for the Central Regional Wastewater System.
Action Requested: Approve Resolution No. 03 -024, endorsing the implementation of a
continuing Pretreatment Program as required by 40 Code of Federal
Regulations (CFR) 403 for the Central Regional Wastewater System.
Background
Information: On March 18, 2003, the City Council unanimously approved first reading
of Ordinance No. 836, Industrial Wastewater Ordinance for the City of
Southlake. The City Council will consider the 2 nd reading of Ordinance
No. 836 on April 1, 2003.
The purpose of Ordinance No. 836 is compliance with the Federal Clean
Water Act, 40 CFR 403. The objective of Ordinance No. 836 is to enable
the Publicly Owned Treatment Works (POTW) to operate at optimum
level, improve quality of sludge for beneficial use and meet the National
and Texas Pollution Discharge Elimination System Permits Parameters.
Resolution No. 03 -024 confirms City Council's commitment for
continuing Pretreatment Program for protection of POTW and a
cleaner environment.
Financial
Consideration: The Trinity River Authority includes pertinent charges for this work, if
required in their monthly billing to the Public Works annual operating
budget for wastewater maintenance.
Citizen Input/
Board Review: Not applicable.
Legal Review: City attorney has reviewed and commented on Ordinance 836.
Alternative: Not applicable.
Supporting
Documents: Resolution No. 03 -024
TNRCC /TCEQ correspondence of September 24, 2002
Staff
Recommendation: Approve Resolution No. 03 -024, endorsing the implementation of a
continuing Pretreatment Program as required by 40 Code of Federal
Regulations (CFR) 403 for the Central Regional Wastewater System.
Staff Contact: Pedram Farahnak, P.E., Director of Public Works, ext. 2308
Valerie Bradley, Assistant to the Director of Public Works, ext. 2342
RESOLUTION NO. 03 -024
A RESOLUTION OF THE CITY OF SOUTHLAKE TEXAS, ENDORSING
THE IMPLEMENTATION OF A CONTINUING PRETREATMENT
PROGRAM AS REQUIRED BY 40 CFR 403 FOR THE CENTRAL
REGIONAL WASTEWATER SYSTEM
Preamble
WHEREAS, on June 26, 1978, the United States Environmental Protection Agency
published a rule (Amended January 28, 1981) which established mechanisms and procedures for
enforcing National Pretreatment Standards controlling the introduction of wastes from non -
domestic sources into Publicly Owned Treatment Works (POTWs); and
WHEREAS, this rule, 40 CFR 403, requires that a Pretreatment Program be developed
for the Regional Wastewater System; and
WHEREAS, the Trinity River Authority of Texas, as the owner and operator of a POTW,
must comply with rule 40 CFR 403; and
WHEREAS, the City, as a contracting party of the Regional Wastewater System, has
entered into an Amendatory Wastewater Contract with the Trinity River Authority of Texas
whereby the City has enacted ordinances that are necessary to implement and enforce the National
Pretreatment Standards; and
WHEREAS, 40 CFR 403.9 (b) requires a statement or resolution reflecting the
endorsement or approval of the local boards or councils responsible for supervising and /or
funding the POTW;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
SOUTHLAKE, TEXAS,
That the City of Southlake hereby endorses the implementation of a pretreatment program
as required by 40 CFR 403 for the Regional Wastewater System with such program to continue
as long as 40 CFR 403 remains in effect.
PASSED AND APPROVED THIS DAY OF 2003.
CITY OF SOUTHLAKE, TEXAS
Mayor Rick Stacy
ATTEST:
Lori A. Farwell
City Secretary
TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
Protecting Texas by Reducing and Preventing Pollution
September 24, 2002
Certified Mail
Mr. Warren N. Brewer, Manager, Northern Region
Trinity River Authority of Texas
P. O. Box 240
Arlington, Texas 76004 -0240
Re: Completion of Substantial Program Modifications to the Trinity River Authority -
Central Regional Wastewater System Pretreatment, Program
TPDES Permit Number 10303 -001 (EPA Identification Number TX0022802)
Dear Mr. Brewer:
This letter acknowledges receipt of the latest submittal, received by the Texas Commission on
Environmental Quality (TCEQ) Pretreatment Team on March 28, 2002, to the proposed Trinity
River Authority (TRA)- Central Regional Wastewater System (CRWS) Pretreatment Program. The
submittal included a revised copy of the Dallas/Fort Worth (DFW) International Airport's
Resolution, enforcement response plan (ERP) /enforcement response guide (ERG), and an example
permit that replaces the documents submitted for this multijurisdictional customer inl999. Included
in Attachment 1 are our comments pertaining to this submittal as well as other sections ofthe CRWS
proposed pretreatment program that are necessary to meet the requirements of current federal, State,
and local law.
In January 1997, the TRA originally submitted the substantial modification for the CRWS
pretreatment program to the U.S. Environmental Protection Agency (EPA) Region 6 as a
requirement of their National Pollutant Discharge Elimination System (NPDES) permit which
became effective on July 1, 1995. The EPA sent a letter, dated March 12, 1998, to the TRA which
included comments and requested revisions to the substantial modification submittal. On October
27, 2000, the TRA performed a reassessment of the proposed technically based local limits and.
certified that they are adequate to protect the Texas Surface Water Quality Standards [30 Texas.
Administrative Code (TAC) Chapter 307] in waters of the State and are adequate to prevent pass
through of pollutants, inhibition of or interference with the treatment facility, worker health and
safety problems, and sludge contamination. The EPA indicated in a letter to the Texas Natural
Resource Conservation Commission (TNRCC), now the TCEQ, dated March 20, 2001, that the
P.O. Box 13087 • Austin, Texas 78711 -3087 • 512/239 -1000 • Internet address: mVW.tnrcc.state.tx.us
prin[ed on recycled 1`aper using soy -based ink
\ 1 .
�j�
Robert J. Huston, Chairman
\ , �. , �
R. B. "Ralph" Marquez, Commissioner
r.
Kathleen Hartnett white, Commissioner
Jeffrey A. Saitas, Executive Director
TEXAS NATURAL RESOURCE CONSERVATION COMMISSION
Protecting Texas by Reducing and Preventing Pollution
September 24, 2002
Certified Mail
Mr. Warren N. Brewer, Manager, Northern Region
Trinity River Authority of Texas
P. O. Box 240
Arlington, Texas 76004 -0240
Re: Completion of Substantial Program Modifications to the Trinity River Authority -
Central Regional Wastewater System Pretreatment, Program
TPDES Permit Number 10303 -001 (EPA Identification Number TX0022802)
Dear Mr. Brewer:
This letter acknowledges receipt of the latest submittal, received by the Texas Commission on
Environmental Quality (TCEQ) Pretreatment Team on March 28, 2002, to the proposed Trinity
River Authority (TRA)- Central Regional Wastewater System (CRWS) Pretreatment Program. The
submittal included a revised copy of the Dallas/Fort Worth (DFW) International Airport's
Resolution, enforcement response plan (ERP) /enforcement response guide (ERG), and an example
permit that replaces the documents submitted for this multijurisdictional customer inl999. Included
in Attachment 1 are our comments pertaining to this submittal as well as other sections ofthe CRWS
proposed pretreatment program that are necessary to meet the requirements of current federal, State,
and local law.
In January 1997, the TRA originally submitted the substantial modification for the CRWS
pretreatment program to the U.S. Environmental Protection Agency (EPA) Region 6 as a
requirement of their National Pollutant Discharge Elimination System (NPDES) permit which
became effective on July 1, 1995. The EPA sent a letter, dated March 12, 1998, to the TRA which
included comments and requested revisions to the substantial modification submittal. On October
27, 2000, the TRA performed a reassessment of the proposed technically based local limits and.
certified that they are adequate to protect the Texas Surface Water Quality Standards [30 Texas.
Administrative Code (TAC) Chapter 307] in waters of the State and are adequate to prevent pass
through of pollutants, inhibition of or interference with the treatment facility, worker health and
safety problems, and sludge contamination. The EPA indicated in a letter to the Texas Natural
Resource Conservation Commission (TNRCC), now the TCEQ, dated March 20, 2001, that the
P.O. Box 13087 • Austin, Texas 78711 -3087 • 512/239 -1000 • Internet address: mVW.tnrcc.state.tx.us
prin[ed on recycled 1`aper using soy -based ink
Mr. Warren N. Brewer, Manager
Page 2
September 24, 2002
TRA -CRWS substantial program modification meets all the requirements of 40 Code of Federal
Regulations (CFR) " § §403.8(f) and 403.9(b). With the revisions required in Attachment 1, the
revisions required by the EPA, and the previously submitted documentation, the cumulative
submission will be determined to be complete.
Once all revisions are complete, the TRA and the 21 multijurisdictional customers to the CRWS
should proceed with adequate public participation and obtain City Council or Board approvals ofthe
revised pretreatment program. Once each multijurisdictional customer's City Council or Board has
approved and adopted the respective ordinance or resolution (and other portions as necessary), the
TRA should submit to the Executive Director in care ofthe Wastewater Permitting Section (MC 148).
of the Water Quality Division, in writing, an .official request for approval of the substantial
modification.
The request must be signed by the Texas Pollutant Discharge Elimination System ( TPDES)
signatory authority. The request must be accompanied by the final attorney's statement (40 CFR
§403.9(b)(1)) and a resolution of funding/endorsement from each.ofthe governmental bodies (TRA
and multijurisdictional customers) responsible for funding and implementing the pretreatment
program. The substantial modifications package must include an updated industrial waste survey;
new legal authority including sewer use ordinance (referenced by number) and applicable
multijurisdictional agreements /contracts; technically based local limits; ERP/ERG; and Pretreatment
Program implementation procedures, including inspection forms, permits, permit applications,
samples of enforcement communications, sampling documentation and other relevant documents.
Four copies of the proposed substantial modification should accompany the request. Three copies
should be bound and one copy unbound. You should retain a copy for your files. Please fill out the
attached tables in Attachment 2 for the multijurisdictional customers and any other cities and
counties that will be directly affected by the TRA -CRWS approved pretreatment program and for
any interested parties who have specifically requested notice of your program modification.
Once the TCEQ has received your request, the TCEQ's Office of Chief Clerk will send a letter -with
instructions to publish public notice for a 30 day comment period. The EPA will have 45 days to
comment. After which time, if no comments have been received, it will be incorporated into your
TPDES permit by reference. The TRA will receive the final modified permit after the public notice
and comment period have expired. The TRA should begin implementation of the modified
pretreatment program upon the effective date of the modified TPDES permit.
During telephone conversations with Ms. Cynthia Belvin, TRA Pretreatment Coordinator, it was
requested that submittal of the official request for approval be within four months from receipt of
this letter. Therefore, please submit the complete substantial modification with any required changes
and your request for approval of the substantial modification to the Executive Director in care of the
Wastewater Permitting Section (MC 148) by December 30, 2002.
Mr. Warren N. Brewer, Manager
Page 3
September 24, 2002
If you should have any questions concerning the required modifications, please contact Ms. Rebecca
Villalba at (512) 239 -4784, or if by correspondence, include MC 148 in the letterhead address
following my name.
Sincerely yours,
j -
, ' t� C C6't�'�A
Jill C. Russell, Pretreatment Team Leader
Wastewater Permitting Section
Texas Commission on Environmental Quality
Enclosure
JCR/rly
ccs: Mr. Lee Bohme, Regional Pretreatment Coordinator, U.S. EPA Region 6 (6WQ -PO), 1445
Ross Avenue, Austin, Texas 75202
Mr. James Lee Murphy, Staff Attorney, TRA- General Office, P.O. Box 60, Arlington, Texas
76004
Ms. Patricia Cleveland, Manager of Operations, Northern Region, TRA, P. O. Box 240
Arlington, Texas 76004 -0240
Mr. William B. Cyrus, Manager, Technical Services, TRA -CRWS, 6500 West Singleton
Blvd, Dallas, Texas 75212
Ms. Cynthia Belvin, Pretreatment Coordinator, TRA -CRWS, P. 0. Box 240, Arlington,
Texas 76004 -0240
City Manager and City Pretreatment Contact for each ofthe 21 Multijurisdictional Customers
to the TRA -CRWS