How can an enforcement agency determine if a treatment system is well operated and maintained?

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How can an enforcement agency determine if a treatment system is well operated and maintained?

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The determination of whether a treatment system is well operated and maintained will be based on the rationale and “method of demonstration” chosen by the facility and approved by the control/permitting authority. For example, if a facility chose an activated carbon adsorption treatment system based on treatability test data (including carbon saturation loading/carbon breakthrough curves) and used that data to establish a relationship between TOC and pesticide active ingredient concentrations, they might demonstrate that the system is well operated and maintained by monitoring TOC and documenting the frequency of carbon changeout. The enforcement agency would then be able to review the TOC data and carbon records to determine if the facility was complying with their method of demonstration.

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