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hearings, and litigation. In smaller agencies, part-time efforts of 
the City Law Director, Village Solicitor, or County Prosecutor will suffice. 
In some cases, outside counsel may be needed. Costs of legal services 
vary widely, depending on whether inhouse or outside counsel is-.utilized 
and upon the level of experience of the legal staff available. 
Adjudication 
Unfortunately, the implementation of a POTW pretreatment program will 
not always be rosey. Disputes will arise between the POTW and the industry 
Over interpretations and regulations. While every effort should be 
made to resolve these matters at the staff level, there will be the need 
for conflict resolution. Litigation should be the last resort due to 
the cost and time involved and the negative public relations impact. 
Most sewer use codes provide for some type of due process procedure 
when a violation or dispute evolves. Its exact nature, of course, varies 
from POTW to POTW2 In some cases, it may call for a hearing before a 
Commissioner or Utilities Director. In other cases, it might call for 
a hearing before the governing body of the sewerage agency or a sub- 
committee of the governing body. Other agencies have used the “hearing 
examiner" approach. Whatever approach is called for, a couple of cautions 
appear to be in order. First of all, it is essential that the person 
hearing the violation or dispute not be the person directly responsible 
for the pretreatment program. Such a person's objectivity would certainly 
be questioned. The other caution would be to be certain that the person 
or persons chosen to hear cases have sufficient time to hear the issues 
in a timely fashion. If a large number of cases are expected, there 
may be little practical choice but to go the hearing examiner route. 
Overall Administration 
A POTW Pretreatment Program will require a significant amount of 
program administration. Record keeping, report preparation, review, 
and submittals will require the full time services of one or more high 
quality clerical individuals. In addition, an overall Program Manager 
is essential. Which of the functions outlined above would actually be 
under his administration, of course, varies from POTW to POTW. In all 
probability, he would not be directly responsible for legal functions. 
In a large POTW, administration would be a full time effort. 
In addition to the day-to-day direction by a competent Program Manager, 
Particularly in the initial stages of the program, involvement by the 
Agency head is critical. A successful pretreatment program necessitates 
a good public relations effort and the establishment of firm groundwork 
with the local industrial associations and Chamber of Commerce. 
Summary 
The information presented in this section indicates that the actual 
capital costs relating to necessary monitoring, analysis, and laboratory 
equipment are significant. Assuming a POTW requires two field crews 
with two completely outfitted vans as well as one A.A. and one GC-MS, 
its total equipment cost would amount to $243,000. 
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