1. Streamlining Rules for Pretreatment Regulation Requested changes to Chapters 922 & 923 of the City of Zanesville Codified Ordinances Presentation to City Council November 9, 2015

2. City Council requested a presentation on proposed Ordinance No. 15-123 Amending Chapters 922 and 923 of the City of Zanesville Codified Ordinances (Sewer User Ordinances) Why are we discussing this?

3. In the beginning…  February 1, 2007 Streamline Rules went into affect for all Publicly Owned Treatment Works (POTW’s) and their related Pretreatment Programs as provided by the Ohio Environmental Protection Agency (OEPA)

4. Was this handled previously?  The City staff examined the Streamlining Rules changes;  December 8, 2008 The City submitted a modification request to OEPA that included only changes to Slug Control requirements.  The programmatic modification was accepted by OEPA.

5. But wait… upon further review, …the call on the field was overturned!

6. What happened?…  OEPA inspected the City’s Pretreatment Program on March 6, 2014; and  While the City was not cited in ‘Violation’… was directed to bring Pretreatment Program Codes into accord with 2007 Streaming Rules.

7. So, what did we do?  The City submitted another modification request to OEPA earlier this year  The proposed language was deemed acceptable by OEPA on August 25, 2015

8. Two Categories of the Rule Changes:  Required changes by OEPA What are we forced to do?  Optional changes What are options that we have control over?

9. Five OEPA Required Changes… Slug Control Requirements Significant Non-Compliance (SNC) Requirements Best Management Practices (BMP’s) as Local Limits Flow Proportional Sampling Requirements Signatory Requirements

10. Changes to meet compliance: Slug Control Requirements (Refer to Ordinance 15-123) 923.16 - Language added to include Slug Control plans in City issued permits - City is given authority over Slug Control plans 922.01 - “Slug load” is defined in accordance with Rule

11. Changes to meet compliance: Significant Non-Compliance (SNC) Requirements (Refer to Ordinance 15-123) 923.23 – Additional determination when a user may be in SNC - 15 more days allowed for submitting reports (now 45 total) 922.01 - Definitions added for clarity

12. Changes to meet compliance: Best Management Practices (BMP) as Local Limits (Refer to Ordinance 15-123) 923.12 - Industries allowed to use BMP’s in place of local limits 923.17 - How a BMP is determined 922.01 - A BMP’s are defined

13. Changes to meet compliance: Flow Proportional Sampling (Refer to Ordinance 15-123) 923.17 – Industries are now required to provide flow proportional sampling

14. Changes to meet compliance: Signatory Requirements (Refer to Ordinance 15-123) 923.17 – Industry site Managers must sign compliance reports

15. So, what’s not required… Optional OEPA Changes in Ordinance 15-123:  Alternative National Categorical Standards  Non-Significant Categorical Industrial Users  Mid-Tier Categorical Industrial Users  Monitoring Waivers  General Control Mechanisms

16. Optional Changes… Alternative Categorical Standards;Non-Signif. Users; Mid-Tier Categorical Users and Monitoring Waivers City can: Grant sampling waivers where CIU demonstrates that a regulated pollutant is neither present nor expected to be present; and Clarifies and updates sampling requirements; Provides flexibility to City in certain sampling protocols.

17. Optional Changes… General Control Mechanisms (Refer to Ordinance 15-123) City may issue general control mechanisms to groups of SIUs that are substantially similar 923.14 - Wastewater Discharge Permit Required: We must have a control mechanism in which to permit Industries Also affects 922.01, 923.17 923.11 - Trucked waste discharge location defined - Misc. items moved due to the previous changes

18. An Ordinance for Ratification OEPA accepted the draft modifications… now require City Council ratification in order to satisfy Streamlining Rule and COZ’s NPDES permit. Once ratified, OEPA issues a 30-day public notice period (40CFR403.18.c)

19. Why should these be ratified?  OEPA Requirement – several of these changes satisfy the streamlining rules, as stated in the letter from OEPA.  Strengthens the City’s ability to protect the Wastewater system & Treatment plant.

20. Questions?