Abstract
A properly functioning wastewater treatment Pretreatment Program will protect the Publicly Owned Treatment Works (POTW), its employees, and the environment from the hazards (i.e. plant upsets, expensive sludge disposal, or discharge variances) resulting from the acceptance of industrial wastewater. However, from time to time a nondomestic user of the POTW may become out of compliance with the Pretreatment Program. When this happens, the POTW needs to take some kind of enforcement action, as detailed in the POTW's Enforcement Response Plan (ERP), to assist the user in returning to compliance. The Approval Authority (i.e. State or Federal EPA) periodically conducts a review to ensure that the Pretreatment Program is operating in accordance with the applicable (State and Federal) regulations. However, the Control Authority (i.e. the POTW) should not rely solely on this inspection of its program to determine how well its program is operating. In order to prevent the negatives that are associated with the Approval Authority identifying a deficiency in the Control Authority's Pretreatment Program, this paper proposes an internal review program for the POTW. The purpose of the internal review is to identify deficiencies in the Pretreatment Program before they become a problem and/or are identified by the Approval Authority. In addition, the internal audit program will allow the Control Authority to identify portions of the Pretreatment Program that are in compliance with the regulations but are not producing the desired results. This will give the Control Authority an opportunity to improve the Pretreatment Program and allow the program to operate to its fullest potential.
Published Version
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