Title
Consider adopting Ordinance No. 3895, amending Chapter 86 Utilities, Article III, Division 2, providing updated pretreatment requirements; and take appropriate action.
Body
REQUESTOR:
Public Works Department
BACKGROUND:
The Texas Commission on Environmental Quality (TCEQ) oversees the Texas Pollutant Discharge Elimination System (TPDES) program designed to control and reduce the amount of pollutants released into the environment. One source of pollutants is the discharge of untreated wastewater. Wastewater from homes, commercial buildings, and industrial facilities is collected and transported through a series of pipes. These pipes are the collection system. Farmers Branch has a wastewater collection system that discharges into a system owned and operated by the Trinity River Authority (TRA). TRA provides large tunnel main lines that transport wastewater from contracting cities to TRA wastewater treatment plants. The plants treat the wastewater to remove harmful organisms and contaminants from the wastewater before it is discharged into receiving creeks, rivers, or lakes.
TRA operates a multi-jurisdictional regional wastewater facility, Central Regional Wastewater System (CRWS), which provides wastewater transportation and treatment by contract to the City of Farmers Branch. Post-treatment, water from the TRA plants is discharged into the waters of the state. Therefore, TRA must have a TPDES permit with the TCEQ authorizing this discharge. As part of its permit, TRA established controls or limits on the levels of certain pollutants in wastewater discharged into the system. These limits prevent interference with the operation of the wastewater treatment plant and prevent the introduction of pollutants into the wastewater system that could pass through the treatment facility untreated and into the receiving body of water, thus preventing the introduction of pollutants that could cause health and safety problems to the public or the environment.
Most publicly owned treatment works facilities are designed to treat sanitary or domestic wastes from households but not treat toxic pollutants from industrial or commercial facilities. These toxic pollutants can cause serious problems at these facilities. One of the ways these problems may be prevented is by pretreatment. Pretreatment is the reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in wastewater prior to or in lieu of discharging such pollutants into a wastewater system.
DISCUSSION:
Besides the wastewater treatment permit, TRA also holds a State of Texas-approved pretreatment program as part of existing TPDES permit requirements. As a contracting city, Farmers Branch must adhere to the requirements of the TRA’s pretreatment program. The City must:
• Establish the legal authority to implement and enforce the pretreatment program.
• Set up inspection, sampling, reporting, and other procedures to ensure compliance with the requirements of the pretreatment program through an ordinance.
• Dedicate necessary resources and qualified personnel to implement the program.
• Develop and enforce local pollutant limits.
• Prepare an enforcement response plan to investigate and respond to violations of the pretreatment program.
• Maintain an inventory of facilities that meet the criteria of significant industrial users.
The City, pursuant to the contract, is responsible for implementing the pretreatment program within the City limits. The city must initiate and follow through on all enforcement. The City is responsible for maintaining a City ordinance containing current local limits, which grants adequate legal authority to maintain, implement, and enforce the pretreatment program. This ordinance update aligns the City’s Code of Ordinance with TRA’s permit amendment with TCEQ.
FISCAL IMPACT:
Annual budget associated with permitting and enforcement for FY 24-25 is $23,100.
POSSIBLE COUNCIL ACTION:
1. I move to approve Ordinance No. 3895 as presented.
2. I move to table the issue for further study or take no action.
ATTACHMENT(S):
1. Ordinance No. 3895 Adoption
2. Ordinance No. 3895 Exhibit A
3. Pretreatment Informational Memo