Who is the entity that conducts a P2 audit and regulates a facility?
The control authority (for indirect dischargers) or the permitting authority (for direct dischargers) enforces the PFPR rule. The P2 audit is one way of determining compliance with the rule; however, the P2 audit is not required by the rule. The P2 audit was designed as a tool for the facilities, control/permitting authorities, consultants, etc. to help organize the various pieces of information that will aid in making compliance decisions. A control authority/permitting authority may ask a facility to conduct such an audit, or may conduct the audit themselves. The P2 audit tables were designed so that they could be used as part of the compliance paperwork, but they are not required.
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