Industrial Pre-Treatment Program

The Industrial Pretreatment Program is an essential component of the National Pollutant Discharge Elimination System (NPDES) and water reclamation process. The national pretreatment program is designed to protect the public wastewater collection systems and treatment facilities from industrial discharges of concern. According to the U.S. Environmental Protection Agency (EPA), the national pretreatment program is responsible for a 50% decrease in pollutants transferred to public wastewater treatment facilities since 1987. JSA is required by our discharge permit with the Kentucky Division of Water (DOW) to implement the federal industrial pretreatment process.

Public collection and treatment facilities are designed to treat domestic wastewater and because wastewater from industries is dramatically different than domestic, it must be monitored and regulated through an industrial pretreatment program. Each establishment that discharges any non-domestic wastewater is subject to the industrial pretreatment program and may be required to have a permit to discharge. The type of processes performed at the facility, the pollutants that may be discharged, and the quantity of water sent to the collection system by the facility will all be considered when determining if a permit will be required.

Prohibited Discharges

There are certain substances and quantities of specific pollutants which cannot be discharged to the collection system. The sewer use ordinance for JSA gives further details on what these prohibitions are. The Code of Federal Regulations Title 40, Chapter I, Subchapter N, Part 403 list the requirements associated with the federal pretreatment program.

Permitting Process

The permitting process for industrial users located within the JSA system can be initiated by contacting the office at (270) 575-0056. Potential industrial discharge users will be given a survey form for an initial assessment. Further investigation may be required based on the submitted information. Once a determination has been made that a permit is necessary, JSA will develop and issue a permit with sampling and other requirements listed in the permit. There will be a schedule of required submittals to JSA over the period of the permit, as well as one-time reporting requirements. In addition, site inspections and site effluent sampling will also be performed by JSA over the length of the permit.

Fees/Surcharges

There are fees for new permits or permit renewals. The current fee is $300 per year. This fee covers a portion of the cost of JSA’s monitoring requirements.

Additionally, there are surcharges which are associated with extra strength wastewater: Total Suspended Solids (TSS), Biological Oxygen Demand (BOD), Oil & Grease, and
Ammonia as Nitrogen (NH3-N). The surcharge rates can be found in JSA’s rate ordinance.

Dental Amalgam Rule

EPA has promulgated pretreatment standards to reduce discharges of mercury from dental offices into publicly owned treatment works. Amalgam separators are a practical, affordable and readily available technology for capturing mercury and other metal before they are discharged into sewers. Dental Office Category requirements are summarized as follows:

1. Ensure the removal of dental amalgam solids from all amalgam process wastewater via amalgam separator(s) or equivalent device(s) that meet the standard of the final rule. See §441.30(a) (1-2) for an existing source and §441.40 for a new source.
2. Implementation of two best management practices. See § 441.30(b) for an existing source and §441.40 for a new source.
3. Comply with reporting requirements.
   See §441.50(a).
4. Maintain and make available for inspection certain records documenting compliance.
   See §441.50(b).