8409-93 Amending Articles 1 & 2 of Chapter 17 Pretreatment Requirements the Public Sewers

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11.-JECAZNI.0 DEP.1R 2+iI TN'TEROFF'T CE MEMORANDUM TO - RICHARD A. NUSSBAUM, II DATE : August 3, 1993 CITY ATTORNEY FROM : MARY HALL MUELLER ASSISTANT CITY ATTORNEY RE : PROPOSED CHANGES TO THE CITY' S SEWAGE PRETREATMENT ORDINANCE - EXECUTIVE SUMMARY This memo is in response to your request that I provide an executive summary setting out the proposed changes to the City' s Sewage Pretreatment Ordinance. As you know, in June, 1992, the EPA conducted an audit of the City' s pretreatment program. This audit included a review of our pretreatment ordinance. The EPA later provided the City with a document containing a listing of the changes required to make our ordinance comply with current federal statutes and regulations relating to sewage pretreatment. Those changes are reflected in amendments to the ordinance as follows: 1. I have added definitions for Interference, Pass Through, New Source, Pretreatment Standard, Pretreatment Requirement, Significant Industrial User, and Significant Noncompliance. These are it is all terms of atrwe should adoptethem in EPA as defined regulations, and appropriate t terms in our Sewage Pretreatment Ordinance. 2. I have added a general prohibition against tausee introduction of substances into our treatment facility, which Pass Through or Interference. 3 . I have revised the ordinance in Section 17-8(b) to make it clear that certain substances may not be introduced into the City' s pretreatment plant under any circumstances. 4. Section 17-8(c) lists those substances that are prohibited unless the Board of Works specifically allows them to be introduced into the City' s sewage system. This section makes it clear, however, that the Board may not permit the introduction of a substance that is prohibited by federal law. 5. In conformance with federal requirements, the amended ordinance would now require each Significant Industrial User to provide an accidental discharge/slug control plan. This plan is intended to prevent accidental discharges n in case such an accidental discharge t the tvshould emergency response plan occur.