Technical Bulletin No. 0366: Quality Assurance Considerations for Pulp and Paper Industry NPDES Self-Monitoring Facilities

In the late 1970s, the pulp and paper industry requested that NCASI examine quality assurance-oriented regulatory agency inspections of its NPDES self-monitoring facilities. But study revealed that this subject was not well-defined. This was due to several factors, among them that (a) quality assurance-oriented inspections were not defined in Federal regulations, so that their existence was a result of interpretation by of existing regulations by members of the regulatory community; (b) a limited amount of documentation existed on the subject, so permitees and regulators were often forced to use their own judgment regarding what constituted acceptable practice; (c) the significance of a quality assurance-oriented inspection, and most importantly, the significance of a deficiency cited by an inspector in such an inspection, was not well understood, and it varied from state to state and EPA region to EPA region; and (d) the criteria by which inspectee practice was judged varied from inspection to inspection.