Municipalities should be aware that the Kentucky Division of Water (DOW) is taking a closer look at pretreatment local limits.

DOW has started adding new language to KPDES municipal permits that defines exactly when pretreatment local limits must be reevaluated. The following events may trigger a reevaluation: a permit issuance or reissuance, a change in water quality criteria, a significant change in conditions at the wastewater treatment plant or with industrial users, operational or performance problems, a change in sludge disposal method, or violations of the KPDES permit or water quality effluent limits. Once a precipitating event has occurred, the clock starts for the city to complete the following steps:

1)      30 days: The city must evaluate its current local limits to determine if changes are necessary

2)      45 days: The city must submit the findings of the evaluation to DOW

3)      90 days: The city must submit a complete local limits reevaluation to DOW

4)      Implement revised local limits within 60 days of approval from DOW

If a reevaluation is necessary, the city has only a short window to complete the review and reevaluation. Failure to complete these steps as required is a violation of the KPDES permit and can result in enforcement action.

For further information, check out DOW’s pretreatment program page at http://water.ky.gov/permitting/Pages/Pretreatment.aspx or contact William Shane at 859-231-8936.