HomeMy WebLinkAboutA001 - Council Action Form dated May 23, 2023 ITEM #: 39
DATE: 05-23-23
DEPT: W&PC
COUNCIL ACTION FORM
SUBJECT: INDUSTRIAL PRETREATMENT PROGRAM — LOCAL LIMITS
BACKGROUND:
On March 1, 2022, the Water Pollution Control Facility (WPCF)was issued a new National
Pollutant Discharge Elimination System permit from the Iowa Department of Natural
Resources (DNR). One requirement of the NPDES permit is to evaluate the adequacy of
the Local Limits that are established as part of the Industrial Pretreatment Program (IPP).
The objective of the IPP is to protect the WPCF by:
• Preventing discharge of pollutants to the WPCF that will inhibit treatment plant
operations or pass through untreated;
• Protecting the safety of workers and the general public;
• Improving the ability to recycle and reclaim wastewater and biosolids; and,
• Enabling compliance with any permits or other laws or regulations that the WPCF
may be subjected to.
Staff completed the required Local Limit evaluation earlier this year and on March
28, 2023, Council adopted on third reading the amended limits. Staff submitted the
Local Limit evaluation to the Iowa DNR for review and approval. After reviewing the
submission, DNR required that the Local Limit for mercury be recalculated to
account for a site-specific water quality standard. Staff performed the recalculation
which resulted in a proposed Local Limit of 0.0056 mg/L which is more restrictive
than the current Local Limit of 0.01 mg/L. This revision to the Local Limit for
mercury, when compared to monitoring data from the past three years, would not
have caused any industrial user to be classified as being in "significant non-
compliance" with the new limit.
The recalculated Local Limit for mercury was submitted to the Iowa DNR for review.
The full set of Local Limits, including mercury, has now received approval by the
Iowa DNR. As part of the approval process, a 45-day public comment period provided
interested parties an opportunity to object to the proposed limits. Additionally, on May 15,
2023, staff notified all industrial users of the proposed Local Limit revisions. Included in
the letter was the timeline for formally revising the Local Limit for mercury in Chapter 28
of the Municipal Code. As of May 19, no responses were received to either the public
notice or the letters sent to local industries.
Following Council approval, staff will formally amend all Industrial Pretreatment Program
permits to reflect the revised Local Limits.
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ALTERNATIVES:
1. Approve on first reading the attached ordinance revising Chapter 28 of the
Municipal Code to amend the Industrial Pretreatment Program Local Limits.
2. Direct staff to modify the attached ordinance.
3. Do not approve the ordinance.
CITY MANAGER'S RECOMMENDED ACTION:
Approval of the Local Limits is required by the Iowa Department of Natural Resources as
part of the National Pollutant Discharge Elimination System permit received on March 1,
2022. Staff has completed the evaluation. The proposed Local Limits are expected to
allow the Industrial Pretreatment Program to meet its goals and are not expected
to cause negative consequences for industrial users. Therefore, it is the
recommendation of the City Manager that the City Council adopt Alternative No. 1, as
described above.
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