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.

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