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Sparks City Council Meeting 11/26/2018

General Business: 9.10

Title: FIRST READING, of Bill No.2752, an ordinance amending Sparks Municipal Code Title 13 relating to the revision of limitations on wastewater strength applied to Significant Industrial Users (Local Limits) together with other matters properly relating thereto.
Petitioner/Presenter: John A. Martini, P.E. Community Services Director/Michael A. Drinkwater, P.E., TMWRF Treatment Plant Manager
Recommendation: That the City Council instruct the City Clerk to read the First Reading of the Bill by Title on November 26, 2018, and thereafter publish notice of a second reading and public hearing of this Bill for its possible adoption and possible approval on December 10, 2018.
Financial Impact: There are no direct economic burdens imposed on the City and there are no proposed new or increased fees.
Business Impact (Per NRS 237):
A Business Impact Statement is not required because this is not a rule.
Agenda Item Brief:

The proposed ordinance will amend Sparks Municipal Code Chapter 13.36 - Waste Water Regulations.  The proposed amendment will revise wastewater discharge limitations (Local Limits) as required by the US Environmental Protection Agency applicable to Significant Industrial Users (SIUs), which are industries discharging an average of 25,000 gallons or more of process wastewater per day to a Publicly Owned Treatment Works (POTW).  The changes to the Local Limits include the elimination of certain limits, an increase in the allowable concentrations for certain limits, and the addition of new limits for conventional pollutants.


A Pretreatment Compliance Inspection completed by the United States Environmental Protection Agency (EPA) in July 2015 identified the need for the City of Sparks to complete an updated evaluation of its Local Limits in conjunction with the other municipalities discharging to the Truckee Meadows Water Reclamation Facility (TMWRF).  Local Limits establish the maximum loading of pollutants that can be discharged to the Publicly Owned Treatment Works (POTW) by Significant Industrial Users (SIU).  The Local Limits are developed and enforced to prevent pass through, interference, protect sludge disposal practices, and prevent impacts to the health and safety of POTW staff.  Further, they help ensure that POTWs remain in compliance with their federal permitted effluent limitations, which are imposed and enforced on the water reclamation facilities via National Pollutant Discharge Elimination System (NPDES) permits.

CWA Consulting Services, LLC (CWACS) was retained jointly by the Cities of Sparks and Reno to perform a study to update the Local Limits in 2016.  Drafts of the Local Limits Report was completed in June of 2017.   Some of the currently established Local Limits will be eliminated or the allowable concentration will be increased, easing the burden on SIUs.  However, the evaluations also determined that new limits must be established for conventional pollutants, including biological oxygen demand (BOD) and total suspended solids, total nitrogen, total dissolved solids, and total phosphorus.  The limits for these conventional pollutants must be allocated to the SIUs in maximum pounds per day (lbs/day).  Since insufficient pollutant lbs/day data was available from SIU discharges for these conventional pollutants, adoption of revised Local Limits was delayed until sufficient data could be gathered. 

The pretreatment programs for both Sparks and Reno coordinated with the SIUs to accelerate wastewater discharge monitoring to acquire the necessary data.  Sufficient data has since been collected to establish the pollutant allocations to the SIUs.


The proposed ordinance will update the current Local Limits and establish the newly calculated Local Limits for Significant Industrial Users for TMWRF pursuant to Federal requirements.  The same limits are planned to be adopted by the City of Reno and Washoe County in their respective ordinances for dischargers in those municipalities that sewer to TMWRF. The Local Limits have been informally reviewed by the EPA, which confirmed that the evaluations were completed consistent with EPA guidance, and the proposed ordinance revision has been found to be approvable.

Some of the existing Local Limits are being eliminated, and some of the Local Limits are increasing in allowable concentrations. However, pursuant to Federal law, new limits for conventional pollutants will be allocated to the SIUs in lbs/day. The total allocations granted to SIUs will be tracked jointly between the City of Sparks, City of Reno and Washoe County.  The addition of these conventional pollutants loading limits has been discussed with the affected SIUs since the accelerated data gathering was initiated in 2017.

The Local Limits must be continually assessed and updated at a minimum of every 5 years, which corresponds with the 5-year permits issued to the POTWs.  Local Limits must also be updated if significant changes occur at a POTW, such as facility expansion, change in processes, or significant changes in flows. 

Notice of the proposed changes to the Local Limits was sent to all City of Sparks’ SIUs as well as US Environmental Protection Agency, the Nevada Division of Environmental Protection, US Fish and Wildlife Service and the Nevada Department of Wildlife.  No response was received from any of the notified parties.



Recommended Motion:


Attached Files:
     Bill 2752--Title 13 Amendment, Local Limits.pdf

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