Water Services is proposing two changes to the City Code.  The first change is an update to the current local discharge limits for permitted industrial users within the City limits.  The second change is a revision to clean up and clarify the cross-connection code. 

The first change will impact the permitted industrial users within City limits by updating the standards for discharge, changing sampling requirements, and other miscellaneous updates.  The desired outcome is to adopt these changes and issue new permits to the industries.  This change may require a slight change to the Council-approved enforcement response plan.

The second change has the potential to impact all water users that have backflow prevention devices or could use in the future.  These users consist of industrial and commercial customers.  The desired outcome is the adoption of these changes to clarify rules governing cross-connection control devices and protect our drinking water distribution system.

Water Services has provided outreach to permitted industries and customers with a cross-connection control device to solicit comments regarding the changes.

Water Services is proposing changes to the City Code.  The first changes include an update and clarification to the current local discharge limits for permitted industrial users within the City limits.  The second change is a revision to clean up and clarify the cross-connection code. 

The first 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 pretreatment 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 1^st and 3^rd quarters of the year.  SIUs are currently conducting self-monitoring in the 2^nd and 4^th 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.  

The second proposed change has the potential to impact most of our industrial and commercial water customers that have backflow prevention or cross-connection devices, as well as any future installation of these devices.  The proposed changes are to Flagstaff City Code 7-03-01-0015.  These changes will streamline code language to increase clarity and reduce redundancy.  These changes will make code easier to understand and provide better guidance to the public as to the expectation of the cross-connection program. 

Flagstaff Water Services has conducted outreach to the permitted SIUs, customers that may be impacted by the cross-connection changes 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 held to address questions/comments to the cross-connection changes.

These recommended code changes will serve to protect our water reclamation plants, bring clarity to the City's code, and ensure staff's consistency in administering the program.

The City of Flagstaff has a pretreatment program as required by USEPA and ADEQ to protect the water reclamation plants and the wastewater collection system.  The pretreatment program monitors all businesses to find actual or potential threats to this system.  We currently have 6 businesses or SIUs that have industrial discharge permits.  The proposed code changes will keep the permitted industries from impacting plant operations and meet our compliance obligations to the state ADEQ and USEPA.  The state-mandated cross-connection control program is housed within the pretreatment program.  The cross-connection oversees protecting the water distribution system through the use of backflow devices.  These devices are very important to keep any contaminants and pollutants from entering the drinking water distribution system.  This program continues to enforce cross-connection compliance and protect Flagstaff’s drinking water.