How did EPA come to the conclusion that facilities would store wastewater and treat it quarterly?
A storage period of 90 days or longer prior to treatment is not uncommon in this industry, based on information EPA gathered during site visits. EPA originally evaluated batch treatment of PFPR wastewater on a quarterly basis because of possible RCRA requirements that might be applicable if wastewater was stored for more than 90 days on site (or 180 days for small quantity generators). EPA determined that, under the P2 alternative, wastewater stored for more than 90 days prior to reuse would not need a RCRA storage permit if it was hazardous. Most interior rinsates are expected to be reused and/or be non-RCRA hazardous. See page 57529 of the preamble to the final rule in Appendix A for more detail. When facilities are treating RCRA-hazardous wastewaters prior to discharge, the 90-day limit for large quantity generators (and the 180-day limit for small quantity generators) still applies. In addition, EPA believes that facilities will wish to limit the length of time that wastewater is s
