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File #: 2019-411    Version: 1 Name:
Type: Resolution Status: Passed
File created: 11/8/2019 In control: Board of Directors Workshop Meeting
On agenda: 11/13/2019 Final action: 11/13/2019
Title: 2019 Industrial Pretreatment Program Rules
Sponsors: Randal Brown, Navid Mehram
Indexes: General Counsel, Wastewater Operations
Attachments: 1. GLWA Reso 2019-410 IPP Rules_Clean_Incl_ Comments_Oct_2019
Related files: 2019-329, 2019-387, 2019-410

2019 Industrial Pretreatment Program Rules

Agenda of: November 13, 2019
Item No.: 2019-411
Amount: N/A

TO: The Honorable
Board of Directors
Great Lakes Water Authority

FROM: Sue F. McCormick
Chief Executive Officer
Great Lakes Water Authority

DATE: November 13, 2019

RE: Approval of 2019 Industrial Pretreatment Program Rules

Upon recommendation of Navid Mehram, Chief Operating Officer, the Board of Directors (Board) for the Great Lakes Water Authority (GLWA), recommends the approval of the 2019 Industrial Pretreatment Program Rules and authorizes the Chief Executive Officer to take such other action as may be necessary to accomplish the intent of this vote.

The Industrial Pretreatment Program ("IPP") is a program for enforcement of local pollution controls in accordance with the objectives of the National Pollutant Discharge Elimination System ("NPDES") permit and the Clean Water Act ("CWA"). On July 1, 2019, the Michigan Department of Environment, Great Lakes, and Energy (EGLE) processed and issued GLWA/DWSD's NPDES Permit. The 2019 IPP Rules have been updated to incorporate relevant changes to the NPDES Permit.

In 1972, the CWA created the NPDES program and requirements for Publicly Owned Treatment Works ("POTWs") to control indirect dischargers. In 1977 the Environmental Protection Agency ("EPA") initiated a lawsuit in the Federal District Court for the Eastern District of Michigan against the City of Detroit (United States v City of Detroit, Case No. 77-1100), alleging violations of the CWA involving the Detroit Waste Water Treatment Plant ("WWTP") and its' NPDES permit.

In the following years, a number of consent judgements were entered wherein Detroit was required to develop a Sewer Use Ordinance and an Industrial Waste Control Ordinance, and to develop a user charge program in order to comply with the CWA's requirement that recipients of federal grants proportionately share cost...

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