How to Survive an EPA Audit

HOW TO REALLY SURVIVE AN EPA AUDITGreg V. Arthur, US EPA, Region 9California Water Environment Association1999 Industrial and Hazardous Waste Conference, Long BeachNovember 15, 1999GOALS - No WWTP violations due to non-domestic flows- Technically-based local limits- BAT in place plus consistent compliance at CIUs- Consistent compliance with local limits associated with WWTP violations- Representative and statistically usable sample records- No long-term or unaddressed SIU violations- Cost effective wastewater handlingSCOPE - Selected inspections of CIUs and non-cat SIUs- Walk-through inspection of WWTP(s)- Preliminary interviews- Review of SIU and WWTP sampling data- Issue SIU inspection reports plus enforcement if warranted- Final interview- PPE report issued to POTWREPORT - 1. Wastewater Treatment Plant(s) Performance- 2. Technically-based Local Limits- 3. Industrial User Inventory- 4. Local Industrial User Permits- 5. Industrial User Compliance with Federal Standards- 6. Industrial User Compliance with Local Limits- 7. Industrial User Self-Monitoring- 8. Pretreatment Program Monitoring and Inspections- 9. Enforcement and IncentivesHow to Survive an EPA Audit • Page 1 of 101. Wastewater Treatment Plant Performance______________________________________________________________________________THE WASTEWATER TREATMENT PLANT(S) MUST MEET PERMIT EFFLUENT LIMITS FOR CONVEN-TIONAL POLLUTANTS, NUTRIENTS, SALTS, METALS, TOXIC ORGANICS AND ...