Purposes and Objectives for Inspecting and Sampling

Having National Pollutant Discharge Elimination System (NPDES) permit holder, each industrial facility with an approved pretreatment program with/without working with a publicly owned treatment works (POTW), must implement its compliance monitoring program that (i) meets the requirements and intent of the General Pretreatment Regulations, (ii) is effective and timely in determining compliance with categorical standards, local limits, and discharge prohibitions, (iii) provides representative data required to meet reporting requirements to POTW, the state and/or the EPA, and (iv) provides sampling data that would be admissible in court, if an enforcement action were to be undertaken by the POTW, state, or federal government.

Table 4.3 Basic information on common use of inorganic chemicals in process water.

Source: Adapted from Hammer and Hammer (2012).

^a N.A., not applicable.

Specifically, the objectives of the industrial facility’s compliance monitoring program are as follows:

• Evaluate industrial user compliance
  • Verify the completeness, accuracy, and representativeness of self‐monitoring data from the industrial user as well as whether required sampling and analysis techniques were used.
  • Verify production/flows at applicable production‐based categorical industrial users to validate accurate equivalent concentration permit limits.
  • Determine compliance with all applicable requirements, such as industrial user permit conditions and sewer use ordinance provisions.
  • Evaluate best management practices (BMPs) and pollution prevention measures.
  • Evaluate the industrial user’s standard operating procedures (SOPs), chemical waste handling procedures, preventative maintenance programs, process/pretreatment equipment and general housekeeping.
  • Determine if the industrial user has corrected problems identified in previous inspections.
  • Support past and future enforcement actions against noncompliant industrial users, including ensuring the industrial user complies with obligations imposed through prior enforcement actions.
  • Assess the potential for spills and slug discharges and evaluate the effectiveness of slug discharge control measures.
  • Evaluate the adequacy of the industrial user’s hazardous waste management and disposal practices.
  • Consider potential compliance issues with other statutes or regulations [e.g. Occupational Safety and Health Administration, Resource Conservation and Recovery Act (RCRA), etc.].
• Develop and revise industrial user permit requirements
  • Confirm applicability of appropriate categorical standards for the facility.
  • Confirm the accuracy of information in the most current permit application (or survey form) with respect to the industrial user’s operations. Specifically, assure raw materials and chemicals used, production, treatment, disposal practices, and all wastestreams are accurately captured in the application (or survey form).
  • Evaluate the impacts of the industrial user on the POTW’s influent, treatment processes, sludge, and effluent (including water quality impacts from the effluent).
  • Assess the adequacy of the industrial user’s self‐monitoring program and permit, and support permit revisions as appropriate.
  • Confirm comprehensive process narrative and wastewater flow schematics coincide with current operations at the industrial user (i.e. have there been any changes in either that have not been reported?).
  • Evaluate and document pollution prevention (also known as P2) activities and opportunities (source reduction, environmental management system (EMS), BMPs, water/energy re‐use/conservation, in‐situ recycling, etc.).
  • Provide a basis for establishing the sampling requirements of the industrial user (above the federal minimums).
  • Evaluate the adequacy of the industrial user’s operation and maintenance (O&M) activities on its pretreatment system.
• Maintain a strong local pretreatment program
  • Evaluate the need for revised local limits.
  • Inform the regulated community of pretreatment requirements.
  • Maintain current data on each regulated industrial user.
  • Generate data that can be used by the POTW in its annual report to the Approval Authority.
  • Establish and maintain good working relationships with the industrial user.
  • Provide a presence in the field so that industrial users understand that the POTW is serious about its regulatory oversight duties.

Industrial user sampling and inspections are the cornerstone of the POTW’s pretreatment compliance and enforcement program. The inspector’s presence helps to establish the POTW’s role as a responsible public agency observing the actions of the regulated industry. Without the inspector on the scene, industrial processes/practices that violate federal, state, or local laws could jeopardize the POTW, the environment, and public health. The inspector may be the only person from the POTW who regularly visits the industrial user’s facility. Furthermore, the knowledge that an inspection could occur unannounced encourages industrial plant managers to keep their operations in compliance.