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IPP
The Black Sheep of Wastewater Treatment
I had the pleasure (slight sarcasm) of going through an IPP audit so you don’t have to. Just kidding, if you have one, you’ll go through one eventually. I figured I’d share a few things I’ve learned from this experience. For those who don’t know, IPP stands for Industrial Pretreatment Program and is generally one of the lesser known aspects of running a wastewater treatment facility. It’s like that chore at your home you know you have to address at some point but keep putting off indefinitely. But then eventually that problem grows worse and you have to spend way more money and time than had you just addressed it in the first place. Sorta like that. The pretreatment programs are designed to prevent industrial users from dumping things they ought not discharge to the sanitary system that can then can wreak havoc on your wastewater process and pass through into the receiving body of water. Since this is the first plant where I am the one responsible for the pretreatment program, I wasn’t sure what to expect during this first audit. So, here are a few things I’ve learned that will hopefully help your audit go smoothly.
1) Have all your paperwork ready for the audit. Generally, the person conducting the site visit will request certain files such as your IPP permits that you use for your Industrial Users, correspondence between you and them, as well as lab results from split sampling, etc. Having this all ready for the audit will smooth things over A LOT.
2) Ask questions. If something they are requesting that you do is confusing, ask questions. I know this is a hard thing for a lot of people but there is no harm is asking questions and seeking clarification. You’re going to get a lot of fine details and legalese thrown at you, so ask for clarification when needed.
3) Don’t be afraid to push back on things. You’ll likely know something about your specific system that the auditor does not, and you definitely can voice your concern. There were several things during our audit that we politely and professional pushed back against, and in a lot of cases we succeeded in arguing the matter in our favor. There are differences between recommendations and requirements. Sometimes you cannot always feasible do all the recommendations but you’ll have to do all of the requirements. Know the difference.
4) Do what you say you’re going to do. There will likely things that you need to change or improve upon. This should be a no-brainer, but do the things that you say you are going to do in the follow-up letter to the regulatory authority.

Now that I’ve given a few pointers, I want to discuss IPP as a whole. It’s kind of an odd thing. You’ll work some plants that don’t even have one, and then you’ll work some plants that do have it and are very proactive with their IPP. I’ve been to a few places that only do what’s required of them and then others that go above and beyond. I think one major reason for this is that there is a lot of leeway in each program and a general lack of oversight overall on these programs from the regulatory authorities. My position is that if you do have one, you should do it correctly. Do more than just the SIU and CIU inspections. Do regular FOG inspections at the restaurants in your jurisdiction. I think this is a hugely overlooked aspect of an IPP program, and we all know how much an issue FOG can be. IPP is incredibly important to protecting and prolonging the whole process from the collection system to your plant. Ensuring your plant doesn’t take a slug load causing you to violate your permit on something that should have been preventable is sometimes easier said than done. The problem is that a lot of plants are reactive instead of proactive in general, and if you run your IPP that way you’ll be in for a lot headaches. Now more than ever the with the focus on emerging contaminants such as PFAS, there is more pressure on municipalities to deal with the issue. And the only way you can do that is through a solid IPP program that regulates the actual sources of these contaminants. And that starts with your Significant Industrial Users and Categorical Industrial Users. Your pretreatment program really matters when it comes to controlling these illicit discharges. So, work closely with your state IPP coordinator and really refine your program. It’ll take a lot of work but if you already have some procedures in place, you can really build upon those things and add more. While the IPP audit process wasn’t the easiest thing, it was very beneficial. We’re going to make some changes for the better, and ultimately that’s all we can do. Try and improve each and every year to protect our system as a whole.
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