Does a facility need to say they are implementing the P2 alternative if they totally reuse their wastewater, or if they do not generate wastewater because they use a solvent to rinse equipment?
A facility that completely reuses all PFPR wastewater (including floor wash, leak and spill cleanup, etc.) meets the definition of zero discharge and does not need to claim they are meeting the requirements of the P2 alternative. However, even though the facility is meeting zero discharge, they still have the choice to say they are complying with the zero discharge requirement (which has minor paperwork requirements) or the P2 alternative (which has more comprehensive paperwork requirements, but may give the facility more flexibility if they decide to discharge in the future). If the facility only generates spent solvent and generates no wastewater (including floor wash, leaks and spills, etc.), then the facility has no potential to discharge and is not covered by the PFPR rule (see Appendix E for a definition of “potential to discharge”).
