Consideration and Adoption of Ordinance No. 2021-10 and Resolution No. 2021-14:  An ordinance amending multiple portions Chapter 7-02 with respect to local limits for significant industrial users of the water reclamation system, and a resolution amending the Enforcement Response Plan.

This change will impact the permitted industrial users within City limits by updating the standards for discharge, changing sampling requirements, and other miscellaneous updates.  The United States Environmental Protection Agency (USEPA) recommends that pre-treatment programs reevaluate their local limits every 5 years.  This 5-year recommendation coincides with the Arizona Pollutant Discharge Elimination System (AZPDES) permit issued by the state Arizona Department of Environmental Quality (ADEQ) to our water reclamation plants. 

Water Services contracted with Brown and Caldwell in 2020 to complete a local limit study for the Pretreatment Program.  The proposed standards for discharge are taken from this study and will be used to issue revised discharge permits to our significant industrial users (SIU).  Included in the local limit code change is a requirement for SIUs to conduct self-monitoring in the 1st and 3rd quarters of the year.  SIUs are currently conducting self-monitoring in the 2nd and 4th quarters.  This change will allow SIUs to conduct any required confirmation sampling within the same calendar year.  If an SIU collects a sample in the 4th quarter that exceeds a local limit, there may not be sufficient time to collect a confirmation sample within the same calendar year.

The change to the local limits will also require a slight change to the Council-approved Enforcement Response Plan (ERP).  Sewer rates are set up in code with different classes, depending on the user.  Users with a higher Biological Oxygen demand (BOD) and Total Suspended Solids (TSS) have a class with a higher rate.  This higher rate is based on the costs the wastewater plant encounters to treat these wastes.  However, some of these BOD and TSS limits are above our already existing local limits.  City Code also allows the use of surcharges to be assessed to a user that exceeds the local limits.  A change in the ERP is necessary to allow staff the flexibility to not enforce exceedances to Local Limits of BOD and TSS.  All other local limits will remain in the ERP as approved. 

Flagstaff Water Services has conducted outreach to the permitted SIUs and the general public through individual email, information included in customer water bills, a notice published in the Arizona Daily Sun, information published on Flagstaff Water Services website, and in a presentation to the Water Commission.  Staff also conducted public on-line meetings with potentially impacted customers.  One meeting was held with the permitted SIUs and a second meeting was presented to the general public. These recommended code changes will serve to protect our water reclamation plants, bring clarity to the City Code, and ensure staff's consistency in administering the program.

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The changes to the industrial pre-treatment program support the Priority Based Budget Key Community Priorities and Objectives: Sustainable, Innovative Infrastructure - Deliver outstanding services to residents through a healthy, well-maintained infrastructure system by protecting our wastewater collection system and water reclamation plants from materials that can interfere with the function of both systems.

A presentation was made to Council during the Work Session on March 30, 2021.