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How do treatment decisions work and how does a permit writer determine limits for PFPR/manufacturing facilities?

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How do treatment decisions work and how does a permit writer determine limits for PFPR/manufacturing facilities?

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If a PFPR/manufacturing facility chooses to comply with zero discharge, there is no allowance (“zero” allowance) given for pesticide active ingredients that they also manufacture (i.e., the limit is based solely on their manufacturing production). Nonmanufactured pesticide active ingredients must not be detected in their effluent (i.e., the permit should specify zero discharge). If the facility chooses to comply with the P2 alternative, the P2 practices would be included in the facility’s permit. The limitation for pesticide active ingredients that are also manufactured could be adjusted to include the facility’s PFPR production. If the pesticide active ingredient is not manufactured, that pesticide active ingredient would not require a specific limitation. See page 57528 of the preamble to the final rule in Appendix A for a detailed discussion of compliance for PFPR/manufacturers. In order for a control authority to give a waiver for floor wash or the final rinse of a triple rinse, fi

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