The Pretreatment Press
Industrial Pretreatment Program
June 2013
 
Industrial Pretreatment Inspection Program

By Rodrigo Moriones, Natural Resource Specialist II

A good inspection program is essential for a successful Industrial Pretreatment Program (IPP). A good inspector is one who is able to deal fairly, effectively and tactfully with Industrial Users (IUs), regulators and the public. The Broward County Water and Wastewater Services’ IPP Enforcement Section conducts various types of inspections in the regulation of its industrial users which are discussed in the following paragraphs. 

The Industrial Wastewater Survey is used to identify and locate all possible industrial users subject to the pretreatment program, and to identify the volume and character of pollutants discharged by these users.

  • The survey allows the utility to determine which users need to be regulated by the program and, therefore, affects the resources dedicated to the program
  • Provides the basis for determining which users are subject to categorical pretreatment standards; and
  • Informs the utility of the character of the wastes being discharged to the WWF, thereby providing the basis for local limits for specific pollutants

A Permitting Inspection is conducted to verify data reported in the wastewater discharge permit application and to designate a sampling point. It is a special inspection conducted when a facility is initially permitted or the permit is renewed.

An Annual Inspection is undertaken to assure compliance with the requirements of the U.S. Environmental Protection Agency (EPA) Industrial Pretreatment Program in which a permitted facility must be inspected at least once per year. Inspectors determine if a facility is in compliance with their wastewater discharge permit by reviewing:

  • Production processes
  • Wastewater treatment processes
  • Monitoring equipment
  • Hazardous material and waste storage areas
  • Documentation and records
  • Housekeeping

During a Compliance Verification inspection, the inspectors determine whether:

  • The sampling location specified in the permit is adequate for the collection of a representative sample of the wastewater
  • The user's sampling technique is adequate to ensure the collection of a representative sample
  • The user's permit monitoring requirements will yield representative samples

After these initial inspections, a Follow up Inspection may be conducted to verify that required actions from the previous inspection (if applicable) are fulfilled and that the facility continues to be in compliance.

The Enforcement Section also performs Complaint Inspections as needed due to odor or illegal discharges brought to our attention by the public or other regulating agencies. Finally, a Closure Inspection is done when an IU ceases discharging, or is in the process of removing a regulated process and/or ceases operation in our service area.

In summary, the objectives of industrial pretreatment inspections are to:

  • Collect information and obtain samples to evaluate industry compliance with local, state and federal pretreatment standards and requirements.
  • Identify c