Within the Code of Federal Regulations (CFR), Regulation 40 CFR Part 136 establishes test procedures for the analysis of pollutants which applies to all Pretreatment Program activities. It is MSD’s responsibility to ensure the use of trained sampling personnel, utilization of protocol established by Regulation, appropriate data management and QA/QC methodology. The IUs are sampled for wastewater quality; some are also monitored for flow. The general Pretreatment Regulations require all SIUs to monitor and report their results a minimum of twice per year and the EPA requires the Control Authority (MSD) to inspect and sample the SIUs, at minimum, once per year. MSD’s Pretreatment Program adheres to these requirements but uses a risk based methodology, which considers many variables, to determine the frequency of sampling and inspection for SIUs, General Permittees and POTWs.

Sampling may be done for metals, cyanide, ammonia, organics, conventional pollutants, toxicity, surfactants, and pH. The monitoring data for the POTWs is submitted semi-annually to the Kentucky Department for Environmental Protection. Permit violations by the SIUs and General Permittees are also reported, as well as other required programmatic activities.

Some SIUs are continuously monitored for Lower Explosive Limits (LELs). MSD conducts additional Quality Charge tests and compliance sampling events throughout the year at various locations to assess applicable Quality Charge fee’s. Conventional pollutants (BOD, TSS, and flow) are used for the Quality Charge assessment.

Pretreatment continued

Pretreatment Index