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Louisville MSD IWD OCPSF Project Permits – Louisville and Jefferson Counties, KY
The Louisville and Jefferson County Metropolitan Sewer District (MSD) retained Strand to assist their Industrial Waste Department (IWD) in the development of pretreatment permits for a number of Organic Chemical, Plastics, and Synthetic Fiber (OCPSF) Industries.  MSD owns and operates many treatment facilities throughout Jefferson County, Kentucky, the largest of which is the 105 mgd Morris Forman WWTP.  Tributary to the Morris Forman WWTP are five significant OCPSF industries, Rohm & Haas (ADF = 1.0 mgd), DuPont (ADF = 2.0 mgd), Geon/BF Goodrich/Zeon (ADF = 2.2 mgd), Engelhard (ADF = 0.6 mgd), and Akzo Coatings (ADF = 0.003 mgd).

All OCPSF industries are regulated under 40 CFR Part 414, and the general pretreatment standards 40 CFR Part 403.  The Part 414 Regulations have been very controversial since their inception.  Many changes have been made to the Part 414 Regulation including repeal and remand of several pollutants.  The Part 414 regulations are especially difficult to administer because they require mass-based permit limits that are developed based on long-term average regulated flow, as opposed to a production basis.  The calculation of the long-term average flow requires intimate familiarity with the entire facility and all waste streams such that only regulated waste streams are included in the long-term average flow.  As a result, unique approaches in determining regulated flows are necessary in order to ensure that dilution and unregulated flows are not included in the long-term average flow calculation. 

We were retained to provide the regulatory expertise required to perform field analyses to determine a technically correct limit setting methodology, and to determine discharge permit limits.  Our approach to the project resulted in the restoration of a cooperative relationship between the industries and MSD.  The industries were required to install flow metering devices to allow the long-term average flow to be measured.  The resulting mass-based permits are technically correct and both industry and MSD will rely on the flows used in determining the permit limits.  This project was highly successful because both MSD and the industries accepted the limit setting methodology and the resulting permits.

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