Arizona Clean Water Act Inspections Support

As authorized by the U.S. Environmental Protection Agency, the Arizona Department of Environmental Quality (AZDEQ) administers the state’s Clean Water Act permit program, which regulates discharges of pollutants to waters of the United States. Under this program, any Arizona facility that discharges pollutants from a point source must obtain a permit, and Arizona inspects facilities to ensure they operate in accordance with their permit conditions. However, due in part to staff turnover, AZDEQ became constrained to inspect facilities at the frequency needed to meet the commitment established with EPA under the state’s CWA permit program. Facing a backlog of inspections, AZDEQ contracted with ERG to provide support in addressing this issue. 

ERG has provided support to enhance AZDEQ’s inspection capacity continuously since 2015. We began by working with AZDEQ to streamline its inspection process, so that each inspector could inspect a larger number of facilities. For example, we developed a streamlined inspection protocol and inspection report templates to improve both the efficiency and effectiveness of AZDEQ’s inspection process, and we revised AZDEQ’s inspection reports to clearly communicate findings with facilities to expedite their return to compliance. Since then, ERG has helped AZDEQ meet its CWA inspection commitments by providing expert inspectors who have used the protocol and templates to conduct more than 400 inspections of permitted facilities over the past 11 years. ERG-inspected facilities have included wastewater treatment plants ranging from small rural utilities to the largest facility in the state; industrial facilities ranging from open pit mines to food manufacturers; all phases of construction sites; biosolids generators and land and surface disposal facilities; and every municipality in Arizona that has a Municipal Separate Storm Sewer System (MS4) permit. In addition, ERG senior inspectors have provided on-the-job training to new AZDEQ inspectors as the department rebuilds its inspection team.