The Pretreatment section of KY Division of Water now has a Local Limits Re-evaluation Submission Document that needs to be submitted by the Publicly Owned Treatment Works (POTWs) at the time of re-evaluation of local limits.

The general Pretreatment Regulations establish responsibilities of Federal, State, and local government, industry and the public to implement Pretreatment Standards to control pollutants from the industrial users which may pass through or interfere with POTW treatment processes or which may contaminate sewage sludge. To protect its operations and to ensure that its discharge comply with State and Federal requirements, a POTW will design its local limits based on site-specific conditions. POTWs that are developing pretreatment programs must develop and enforce specific limits on prohibited discharges, or demonstrate that the limits are not necessary whereas POTWs that have approved pretreatment programs must continue to develop and revise local limits as necessary.

As local limits re-evaluations are a required condition of KPDES permits and federal regulations require a written technical evaluation of the need to revise local limits following permit issuance or re-issuance or any significant change that can trigger re-evaluation of the limits, KDOW has prepared this document to stream line both the submission process as well as to facilitate the approval process.

This document can be found at the Division of Water website.

Also, please note that there are some specific steps that are outlined in Section XIV of this document. According to these steps, POTW must submit a sampling plan for influent, effluent WWTP data and domestic/commercial data to KDOW for approval prior to the submission of a draft-re-evaluation document. A draft re-evaluation can be sent to the Division for review prior to the final submission of the document.

For additional information you can contact Shri Vani Sripada at shrivani@smithmanage.com or (859)-231-8936.