After much investigation in trying to identify the source of rubber masses at the Morris Forman Wastewater Treatment Plant (MFWTP), MSD has entered into a Consent Order with DuPont Dow Elastomer (DDE) effective February 12, 1999, the terms of which will provide the solution to the problem. Through analytical analysis performed each time there was interference from rubber accumulation at MFWTP, MSD was able to determine that 99% of the rubber was neoprene rubber, manufactured and discharged by only DDE to the Rubbertown Force Main. The force main discharges to the Morris Forman plant.

MSD and its consultant, CH2M Hill, undertook a study to develop pretreatment options to eliminate neoprene rubber mass interference at MFWTP. Several options were identified by the study. CH2M Hill completed bench and pilot scale testing of one of the options. At the conclusion of the testing, DDE agreed to install on-site pretreatment at its Rubbertown facility. The start up of the on-site pretreatment facility is to occur by December 31, 2000.

Since 1995, DDE has paid MSD a total of $447,500 in fines and $20,435 in cost recovery as a result of repetitive violations for rubber discharges interfering with the operations of the MFWTP. The number of size of the rubber incidents had decreased since MSD began meeting with DDE and are expected to be eliminated completely with the construction of pretreatment facilities.

If you have any questions concerning this development, please contact MSD Executive Director Gordon Garner at 540-6346, Marsha Jenkins, MSD Legal Counsel (assigned to this project) at 540-6320 or MSD Community Relations/Emergency Response Director, Bud Schardein, at 540-6319.

cc: Honorable David Armstrong, Mayor, City of Louisville
        Honorable Rebecca Jackson, County Judge/Executive
        MSD Board
        MSD Executive Team
        Marsha Jenkins
        Area Team Leaders
        Jolyn Colon