Pretreatment Program (Prior to 1988)

EPA promulgated its General Pretreatment Regulations on June 26, 1978, and amended them on January 28, 1981. The pretreatment program at MSD predates EPA activity. MSD as a POTW was subject to regulation. High profile incidents in the Louisville area became a major driver for the national pretreatment program. The Hexa/Octa incident in 1977 and the February 13, 1981 sewer explosion created a clear community mandate to go beyond the confines of federal regulations, resulting in MSD’s program.

The collection system has been modified and administrative procedures adopted to protect MSD facilities and the public from dangerous or troublesome discharges. Key aspects include telemetered explosivity meters in key pump stations and manholes, pretreatment wastewater discharge permits, as well as pretreatment directives for industry. The program issues three types of permits: Federal Significant Industrial User (SIU) Permits, General Discharge Permits (GDP) and Unusual Discharge Request (UDR) Permits. In addition, unique user agreements supplement permits where pollution prevention (P2) goals have been recognized and joint ventures proposed with companies. All permits issued are directed towards collection system protection. Specifics of individual permits and agreements have been tailored to optimize the collection system to prevent dry-weather CSO situations. UDRs in particular have been successful in modifying the time, location and rate of discharges to avoid dry-weather releases from the combined system.

MSD submits several different reports under Federal and State laws. Kentucky State law reporting requirments for the Pretreatment Program are more stringent than Federal rules. The reports submitted are listed below:

• Pretreatment Discharge Monitoring Report (DMR)
• Pretreatment Annual Report
• Pretreatment Semi-annual Report
• Industrial User Report for Kentucky Pollutant Discharge Elimination System (KPDES) renewal

MSD submits an annual Pretreatment Discharge Monitoring Report (DMR) each February summarizing influent, effluent and biosolids data for the treatment plants with pretreatment requirements. The Pretreatment Annual Report is submitted each March. This report includes summaries for each individual permitted user and Pretreatment Program statistics, including compliance and enforcement activities. Publication of Users in Significant Non-Compliance is required annually and is publication in the Courier Journal newspapaer classified section. The Pretreatment Semi-Annual Report submitted each September summarizes program statistics for the first half of the calendar year. Every five years, summary industrial data, similar to the Pretreatment Annual Report, must be collected to satisfy permit application requirements of the KPDES renewal process.

Related Links

1988 to 1997 Pretreatment Program Efforts
1998 to 2002 Pretreatment Program Efforts
2002 to July 2003 Holistic Watershed Approach

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