Does a POTW/control authority need to monitor specifically for pesticide active ingredients to ensure that a facility is complying with the PFPR rule?
No, monitoring may not be economically feasible and there may not be analytical methods available for all pesticide active ingredients. Compliance with the P2 alternative may be shown through ensuring that P2 practices have been implemented, the appropriate treatment is in place and is well operated and maintained, and documentation has been prepared and is readily available at the facility. If a facility chooses to comply with zero discharge through “no flow” of process wastewater, the POTW/control authority would mostly ensure compliance through facility inspection of the PFPR process areas. However, if a facility is complying with zero discharge by demonstrating non-detect levels of pesticide active ingredients and priority pollutants, analytical methods must exist and the POTW/control authority would monitor at a minimum for expected priority pollutants and those pesticide active ingredients used in PFPR production.
Related Questions
- Does a POTW/control authority need to monitor specifically for pesticide active ingredients to ensure that a facility is complying with the PFPR rule?
- Can a facility use toxicity measurements for their BMR if they haven been testing the specific pesticide active ingredients?
- How does a facility demonstrate that a pesticide active ingredient does not pass through the POTW?
