Water Pollution:

Improved Monitoring and Enforcement Needed for Toxic Pollutants Entering Sewers

RCED-89-101: Published: Apr 25, 1989. Publicly Released: May 25, 1989.

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In response to a congressional request, GAO assessed key elements of the Environmental Protection Agency's (EPA) National Industrial Pretreatment Program, focusing on whether: (1) industrial users of publicly owned treatment works (POTW) had discharges exceeding program discharge limitations; and (2) treatment plant enforcement over dischargers, and EPA and state enforcement over treatment plants, was sufficient to ensure that users met discharge limitations and other program requirements.

GAO found that: (1) 41 percent of the industrial users failed to comply with and violated one or more of their discharge limits; (2) 20 percent of the treatment plants also had one or more discharge limit violations; (3) the effects of the violations included the pass-through of untreated toxic pollutants to receiving waters, interference with treatment plant operations or damage to plant facilities, and exposure of treatment plant workers to health and safety problems; (4) treatment plants served about 60 percent of the industrial users with written notices of violations and levied administrative fines for only 5 percent; (5) approval authorities' enforcement against noncomplying treatment plants was also limited, since EPA concentrated its priorities on program start-up rather than on enforcement; and (6) although EPA took actions to address some enforcement problems, the effectiveness of the actions remained unclear.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: EPA stated that local discharge limits are evaluated through yearly on-site audits or inspections and through annual reports for POTW. However, these were the same procedures used by EPA at the time of the GAO audit. The EPA response was business as usual.

    Recommendation: The Administrator, EPA, should direct pretreatment program approval authorities to review all POTW programs to determine whether required local discharge limits have been issued and are technically sound.

    Agency Affected: Environmental Protection Agency

  2. Status: Closed - Implemented

    Comments: EPA stated that sampling locations are evaluated through yearly on-site audits or inspections and through annual reports from POTW. However, these were the same procedures used by EPA at the time of the GAO audit. The EPA response was business as usual.

    Recommendation: The Administrator, EPA, should direct pretreatment program approval authorities to review all POTW programs to determine whether sampling locations at industrial users have been selected properly and are clearly specified.

    Agency Affected: Environmental Protection Agency

  3. Status: Closed - Implemented

    Comments: EPA stated that sampling frequencies are evaluated through yearly on-site audits or inspections and through annual reports from POTW. However, these were the same procedures used by EPA at the time of the GAO audit. The EPA response is business as usual.

    Recommendation: The Administrator, EPA, should direct pretreatment program approval authorities to review all POTW programs to determine whether prescribed sampling frequencies provide reasonable assurance that discharge limit violations by industrial users will be detected.

    Agency Affected: Environmental Protection Agency

  4. Status: Closed - Implemented

    Comments: Since POTW are not required to develop ERP until their permits are renewed, EPA evaluation of these plans will not take place until after all permits are renewed over the next 5 years.

    Recommendation: In light of uncertainties about the effectiveness of recent EPA actions to correct other enforcement problems in the EPA treatment program, the Administrator should evaluate these actions at the end of FY 1989 and, for those approval authorities that do not sufficiently follow the agency's recent guidance on when to bring enforcement actions against POTW for failure to implement POTW pretreatment programs, the Administrator should require the use of EPA standards on the type of enforcement actions to be taken under specific circumstances.

    Agency Affected: Environmental Protection Agency

  5. Status: Closed - Implemented

    Comments: Since POTW are not required to develop Enforcement Response Plans (ERP) until their permits are renewed, EPA evaluation of these plans will not take place until after all permits are renewed over the next 5 years.

    Recommendation: In light of uncertainties about the effectiveness of recent EPA actions to correct other enforcement problems in the EPA pretreatment program, the Administrator should evaluate these actions at the end of fiscal year (FY) 1989 and, for those POTW that do not sufficiently incorporate existing guidance on enforcement response procedures into individual plant programs, the Administrator should require the use of EPA standards for timely and appropriate enforcement.

    Agency Affected: Environmental Protection Agency

  6. Status: Closed - Implemented

    Comments: On July 24, 1990, EPA issued final regulations that defined significant noncompliance for use by POTW in setting enforcement priorities.

    Recommendation: The Administrator, EPA, should follow through with the agency's plans to promulgate a regulatory definition for significant noncompliance to be used by POTW in setting enforcement priorities as soon as possible.

    Agency Affected: Environmental Protection Agency

  7. Status: Closed - Implemented

    Comments: The EPA response to prior recommendations indicates that deficiencies will not always be identified. In such cases, approval authorities will not amend POTW programs, as recommended.

    Recommendation: Where deficiencies in any of the areas are identified, the Administrator, EPA, should direct approval authorities to amend POTW pretreatment programs or issue administrative orders to correct deficiencies in those programs.

    Agency Affected: Environmental Protection Agency

 

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