Federal Regulations (40 CFR) require an Environmental Control Program for all publicly owned wastewater treatment plants with flow greater than 5 Million Gallons per Day (MGD).  Because the TMWRF tributary area encompasses portions of three political subdivisions, each must provide inspection services for their respective industrial and commercial dischargers.   In lieu of providing the inspection services directly, Washoe County has historically contracted with the City of Sparks to provide pretreatment inspection services for Sun Valley and the unincorporated portion of Spanish Springs.  The current agreement for inspection services was approved in 2000.

The need to update the ILA was identified during the USEPA audit of the pretreatment programs conducted in 2015.  In the resultant Report, USEPA required that the cities and County work together to “ . . . ensure there is adequate legal authority to regulate industrial users and enforce pretreatment requirements within Washoe County”.  The current ILA does not expressly grant the City of Sparks’ inspectors the necessary authority to enforce the pretreatment regulations in Washoe County.  This omission is being corrected by revisions to the County sewer discharge ordinance and by this proposed update to the ILA.  This updated ILA will also formalize the support provided to the County by the City of Sparks with environmental control services related to the stormwater permitting and regulation processes for commercial and industrial development in the unincorporated area. 

The proposed interlocal agreement will provide the City of Sparks’ Environmental Control Inspectors the legal authority to inspect and require corrective action, including issuing citations, to industrial and commercial dischargers in the unincorporated areas of Sun Valley and Spanish Springs.  Additionally, these inspectors will be authorized to enforce all required stormwater controls on construction in these areas.  The cost of these inspections is recovered through fees paid by the dischargers for the discharge permit.  These fees are identical to the fees paid by dischargers within the City of Sparks. 

1. City Council can approve the interlocal agreement as presented.
2. City Council could direct the Manger to have staff provide other alternatives.

I move to approve the Interlocal Agreement with Washoe County to allow the City of Sparks Environmental Control Section to provide pre-treatment inspection services in Sun Valley and unincorporated Spanish Springs.