TOWN STAFF REPORT RECOMMENDATIONS
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Discuss, consider and act regarding Resolution 25-23 to adopt an Enforcement Response Plan (ERP) as part of the Town of Westlake Approved Pretreatment Program for the publicly owned treatment works to comply with and as required by the United States Environmental Protection Agency in Title 40 of the Code of Federal Regulations (CFR) ?403.8(f)(5) (Cheryl Taylor, P.E., Director of Public Works)
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STAFF: Cheryl Taylor, P.E., Director of Public Works
BACKGROUND:
Trinity River Authority (TRA) owns and operates the Denton Creek Regional Wastewater System (DCRWS) Wastewater Treatment Plant (WWTP) in Roanoke and provides either all or some wastewater treatment services to 12 customer cities. As a customer of TRA, Westlake is required to participate in the pre-treatment program which requires an approved Enforcement Response Plan Resolution.
DISCUSSION:
A pretreatment program is a set of regulatory requirements found in 40 CFR 403 that is intended to protect WWTP from receiving wastewater pollutants from industrial users in concentrations that the plant cannot handle. TRA does that largely through wastewater discharge permitting of industrial users that qualify according to the regulations, and through industrial inspections, sampling, and enforcement. For TRA WWTPs like DCRWS, TRA is the Control Authority responsible for maintaining compliance with the Texas Pollutant Discharge Elimination System (TPDES) Permit to discharge from TCEQ. TRA does not have any legal authority to permit or enforce on the industrial users discharging to the plant, so TRA has language in the customer Wastewater Contracts detailing the partnership between TRA and its customers, and how the customers (Westlake) would act as the Legal Authority capable for issuing permits and enforcement. Some customers chose to enlist TRA to do much of the pretreatment legwork, however they remain the party that authorizes, and issues permits and enforcement. A ...
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