Memorandum

City of Lawrence

Legal Services Department

TO:	David L. Corliss, City Manager
FROM:	Toni Wheeler, Director of Legal Services
CC:	Dave Wagner, Director of Utilities Aurora Shields, Water Quality Manager
Date:	September 16, 2008
RE:	Ordinance No. 8315 Amending Chapter 19, Article 6 of the City Code Concerning Pretreatment Regulations

Please include the following item on the City Commission agenda for consideration:

Request:

Consider adopting Ordinance No. 8315 amending Chapter 19, Article 6, Section 19-604 of the City Code concerning general discharge prohibitions under the City’s pretreatment regulations. 

Background

The Clean Water Act required EPA to develop pretreatment standards to control industrial discharges into the sanitary sewer collection system.  The City, as a Public Owned Treatment Works (POTW), must enforce federal pretreatment standards and establish a local pretreatment program.  The City’s pretreatment program was approved and implemented in 1986.  The City’s sewer use and pretreatment regulations are found in Chapter 19, Articles 5 and 6, respectively.

Ordinance No. 8315 removes the limitation on wastewater containing fats, wax, grease or oils (FOG) from Article 6.  Article 5, Section 19-505 contains the same limitation set forth in Section 19-604(M).  The City can enforce the FOG discharge limitations through Chapter 19, Article 5.  Article 5 of Chapter 19 has additional provisions which provide the Director of Utilities flexibility to accept discharges by agreement if the waste complies with federal and state regulations. 

The proposed ordinance was developed by City staff in coordination with EPA and KDHE representatives. EPA approved the proposed change.

Action Requested:

Staff recommends adoption of Ordinance No. 8315, if appropriate.