Industrial Pretreatment Coordinator PositionCopyrighted
January 17, 2023
City of Dubuque Consent Items # 011.
City Council Meeting
ITEM TITLE: Industrial Pretreatment Coordinator Position
SUMMARY: City Manager recommending City Council approval to create the
Industrial Pretreatment Coordinator position, which will be funded by
increasing the Industrial Pretreatment Customer fees and charges, as
determined through the budget process.
SUGGESTED Suggested Disposition: Receive and File; Approve
DISPOSITION:
ATTACHMENTS:
Description
MVM Memo
Type
Staff Memo
Staff Memo Staff Memo
THE C
DUjIBQTE
Masterpiece on the Mississippi
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Industrial Pretreatment Coordinator Position
DATE: January 12, 2023
Dubuque
WAWca 914
ii
2007-2012.2013
2017*2019
Water & Resource Recovery Center Manager William O'Brien is recommending City
Council approval to create the Industrial Pretreatment Coordinator position, which will
be funded by increasing the Industrial Pretreatment Customer fees and charges, as
determined through the budget process.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
v
Mic ael C. Van Milligen
MCVM:sv
Attachment
CC' Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
William O'Brien, Water & Resource Recovery Center Manager
THE CITYF
DiUjB_
Ehi
Masterpiece on the Mississippi
TO: Michael C. Van Milligen, City Manager
FROM: William O'Brien, W&RRC Manager
SUBJECT: Industrial Pretreatment Coordinator Position
DATE: January 12, 2023
Dubuque
All•pnteriea Cify
VA��NiAL[]YN� I F,4 i F
2007-2012.2013
2017*2019
INTRODUCTION: The purpose of this memo is to recommend the creation of a
dedicated Industrial Pretreatment Coordinator position.
BACKGROUND: The City of Dubuque developed, and implemented, the Industrial
Pretreatment Program, in 1983, as a requirement of the Clean Water Act of 1977
(Public Law 95-217), and General Pretreatment Regulations for Existing and New
Sources of Pollution (40 CFR, Part 403). These regulations require any Publicly Owned
Treatment Works (POTW) with a design flow over 5 million gallons per day and
receiving wastewater, from Industrial Users, which may cause interference with the
operation of the POTW, or are subject to Pretreatment Standards, to establish a POTW
Pretreatment Program.
State and Federal regulations designate the City of Dubuque as the Control Authority,
requiring the City to identify and locate all possible Industrial Users which might be
subject to the City's Pretreatment Program. All users of the POTW, including domestic
users and nonsignificant Industrial Users, are controlled through the City's Sewer Use
Ordinance. Industrial Users identified as significant must be controlled through
individual permits, or other equivalent control mechanisms. Significant Industrial Users
are those:
Contributing a flow of 25,000 gallons or more per average workday of process
wastewater;
Contributing a process waste stream which makes up five percent or more of the
average hydraulic flow or organic capacity of the POTW treatment plant;
Designated as such due to reasonable potential for affecting the POTW's
operation.
As the Control Authority, the City of Dubuque is required to:
Develop local pretreatment limits designed to protect POTW infrastructure,
processes, and human health
Identify and permit all Significant Industrial Users (The City of Dubuque currently
identifies 15 Industrial Users as significant)
• Monitor industrial discharges for compliance with local, State, and Federal
regulations
• Conduct inspections of industrial facilities for compliance with local, State, and
Federal regulations
• Conduct enforcement, according to the City's approved enforcement response
plan, when pretreatment requirements are not met
• File annual reports, with the State Pretreatment Coordinator, identifying
inspection and enforcement actions with all Significant Industrial Users
• Implement all additional requirements of local, State, and Federal pretreatment
regulations
As the Approval Authority, the Environmental Protection Agency (EPA) and the Iowa
Department of Natural Resources (IDNR) are responsible for:
• Approving local pretreatment programs
• Assessing compliance with state and Federal pretreatment regulations through
inspections and audits of industry practices and local pretreatment programs
• Enforcing regulations when noncompliance is determined
Costs of the City's Industrial Pretreatment Program are recovered through:
• General pretreatment administration fees based on discharge volume
• Surveillance monitoring and sampling fees
• Laboratory testing fees
• Fees for investigating incidents of program noncompliance
• Discharge permit application fees
• Fines
• Fees for the removal of pollutants
DISCUSSION: In November 2022, an Inspector, from EPA Region 7, conducted a
routine audit of the City's Industrial Pretreatment Program. The Inspection Report has
not yet been finalized, although in discussions with the EPA Inspector it was advised
that improvements will be required in the Industrial Pretreatment Program, mainly
around record keeping, monitoring, and reporting.
The EPA Inspector recommended two immediate steps:
• Provide additional staff and training
• Procure consultant services for assistance with program improvements
I am requesting to add the additional position of Industrial Pretreatment Coordinator.
Working with consultants, additional system improvements will be made through the
FY24 and FY25 budget process.
ACTION REQUESTED: Please request City Council approval to create the Industrial
Pretreatment Coordinator position, which will be funded by increasing the Industrial
Pretreatment Customer fees and charges, as determined through the budget process.
Cc: Cori Burbach, Assistant City Manager
Crenna Brumwell, City Attorney
Shelley Stickfort, Human Resources Director
John Klostermann, Public Works Director
Gus Psihoyos, City Engineer
Jill Connors, Economic Development Director