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Project XL: Pretreatment Reinvention
 
Jeffersontown and MSD Excel Nationally on Chenoweth Run Initiative
The City of Jeffersontown (Jeffersontown) and the Louisville and Jefferson County Metropolitan Sewer District (MSD) have partnered with local industries, environmental organizations, and enthusiastic residents on several projects to improve the quality of Chenoweth Run.
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(, 780K)

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(, 724K)
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PROJECT XL:  PRETREATMENT REINVENTION
Background
Over the years, MSD's Pretreatment Program has been considered very successful in fulfilling the requirements of the National Pretreatment Regulations, mostly because the Significant Non-Compliance (SNC) rate has been greatly reduced. The current SNC rate is less than 10% - which is down from 44% in the early 1990's. But EPA has begun to question the relevance of this "programmatic" measure to judge the effectiveness of the National Pretreatment Program. In examining the National Pretreatment Program, it can be seen that the program is primarily focused on procedural aspects of regulating indirect dischargers rather than on evaluating whether the environment (water quality) is being positively or negatively impacted. This focus is largely due to the lack of a direct link to environmental endpoints. A recent report to Congress stated:

"The lack of comprehensive environmental data makes it difficult to evaluate the program's effectiveness in achieving the goals of the Clean Water Act."

Grant & Project XL Initiation
As a result of the concerns with the programmatic approach, in September of 1998, the Federal EPA awarded a 104(b)(3) Grant to MSD for the Development of Pretreatment Performance Measures. The objective of this project was to develop, implement, and assess specific Performance Measures designed to measure the environmental impact of the Pretreatment Program in the Jeffersontown sewershed.

In order to apply the lessons learned from the Grant project, MSD applied for a Pilot Project through the XL (eXcellence in Leadership) program. EPA authorized the pilot study on September 28, 2000. MSD's Board approved modifications to MSD's Waste Discharge Regulations to include Project XL. Kentucky Division of Water incorporated Project XL into MSD's KPDES permit, which became effective on June 1, 2002.

With information gained from the Performance Measures project, and with the regulatory flexibility provided by the XL Pilot Project, resources can ultimately be shifted to address the greatest environmental concerns in the watershed. MSD's strategy is to use better information and reallocate resources with this XL program to create environmental benefits according to a specific prioritization strategy. It is expected that the lessons learned from this effort will be transferable to other sewersheds/watersheds in Jefferson County and to other municipalities.

Contact
For more information on this project or if you would like information about upcoming meetings, please contact Sharon Worley (502-540-6744). You may also refer to the following documents:

HISTORICAL DOCUMENTS:

MSD Proposal

Final Project Agreement

Stakeholder Meeting Summaries

Reports (The following reports are available upon request through Sharon Worley)

  • Project XL Year 2000 Annual Report (April 2001) - Contains background data and assessment of MSD's Jeffersontown sewershed for all data collected between 1999 and 2000.
  • Project XL Semi-Annual Report (September 2001) - Contains updated data assessment through June 2001.
  • Project XL Year 2001 Annual Report (April 2002) - Contains background data and assessment of MSD's Jeffersontown sewershed for all data collected between 1999 and 2001. This report also contains the status of the XL pilot project implementation.
  • EPA Grant Summary Report (April 2002) - The final report for the Pretreatment Performance Measures Grant project. This report contains proposed performance measures and pollutant of concern definitions. Both Jeffersontown and West County sewersheds were studied.
  • Project XL Semi-Annual Report (September 2002)  - Contains updated data assessment through June 2002.
  • Project XL Year 2002 Annual Report (April 2003)  (, 87K)
  • Project XL Semi-Annual Report (September 2003)  (, 14K) - Contains updated data assessment through June 2003.
  • Project XL Year 2003 Annual Report (April 2004)  (, 1.1M)

EPA's XL Project Webpage


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Pretreatment Index

Last Updated: December 17, 2007

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