The process utilized by IWD to identify and categorize new IU’s includes the following:

• Canvas inspections
• Referrals from the Hazardous Materials Spill Prevention and Control Program
• Referrals from the Department of Health and DOW
• New customer data referrals from the Louisville Water Company
• City / County tax base referrals and Economic Development
• Regular phone book and newspaper review
• Citizen / public referrals
• Plan Review

Once IU’s are identified, IWD formally reviews the proposed IU’s processes to determine regulatory requirements that may need to be established. The assessment process includes a commercial/industrial process plan review. This function is housed within the Permit Section. It is a part of the city/county Building Permit approval process and, therefore, assures that targeted IU’s are accounted for and assessed, prior to construction. Once the Plan Review process is complete, identified IU’s are reviewed relative to permitting concerns.

Permits issued to the industrial discharges are either classified as Significant Industrial User (SIU) Permits, General Permits, Hauled Waste Permits, or Unusual Discharge Permits. The breakdown of number of the various permits well as the capacities of the four largest treatment plants are shown in the following table based on data from 1998:

A discharger is classified as an SIU if it is an industrial discharger which:

• is subject to Categorical Pretreatment Standards (under 40 CFR 403.6 and 40 CFR Chapter I, Subchapter N); or,
• discharges an average of:
  • 25,000 gallons per day of process wastewater to the Morris Forman WWTP
  • 15,000 gallons per day of process wastewater to the West County WWTP
  • 5,000 gallons per day of process wastewater to the Jeffersontown WWTP
  • 5,000 gallons per day of process wastewater to the Hite Creek WWTP; or,
• contributes a process waste stream which makes up five percent or more of the average dry weather hydraulic or organic capacity of the treatment plant; or,
• is any other industrial user that is designated as such by MSD as defined in 4 CFR 403.12 (a) on the basis that the industrial user has a reasonable potential for adversely affecting MSD’s treatment works operation or for violating any pretreatment standard or requirement (in accordance with 40 CFR 403.8 (f) (6)).

Besides the previously described permits, MSD also issues Hazardous Materials Use and Spill Prevention Control (HMPC) plans to local companies that use or store a reportable quantity of a Resource Conservation Recovery Act (RCRA) listed hazardous material. This program is authorized and mandated by the Louisville and Jefferson County Hazardous Materials Ordinance (HMO). MSD is the administrative and enforcement agency over the HMO. There are currently over 2,200 HMPC plans and over 1,500 Exemptions issued.

The HMPC plans list 24-hour emergency contacts, hazardous materials descriptions, inventories, and storage locations. Maps are required detailing the facility and where particular materials are stored at the facility. Spill response supplies, personal protective equipment, security measures, training procedures and clean-up / recovery and mitigation procedures are addressed. The plan also requires the businesses to post a summary of the emergency procedures at strategic locations, as well as develop / implement a formal Employee Training program.

Limits:  Categorical Pretreatment Standards are Federally established standards developed for the specific type of industrial process. Of the 119 SIUs, only 38 were subject to Categorical Pretreatment Standards during the last reporting period. There are also Local Limits developed by MSD for the Morris Forman, West County, Hite Creek, and Jeffersontown treatment plants’ collection systems. Local limits are site specific for each treatment plant. They are technically based limits based on Water Quality, Inhibition Criteria, and Treatment Plant Removal Efficiency. Information regarding industrial loadings, non-industrial loadings, and the treatment plant removal efficiency are also factored into the calculation. MSD currently allocates the Local Limits by uniform distribution. For Categorical Industries, MSD is required to apply the most stringent of the Categorical and Local Limits to Categorical IUs.

Pretreatment continued

Pretreatment Index