If a chemical can be shown not to pass through a publicly owned treatment works (POTW), can that chemical be exempt from the PFPR rule?
The P2 alternative allows some amount of discharge when a facility is following certain P2 practices set out by this rule and is performing treatment where required by the rule, even if the chemical is deemed to pass through. A facility can perhaps also obtain removal credits from the POTW/control authority for a particular chemical (see page 57547 of the preamble to the final PFPR rule in Appendix A). Basically, once compliance with 40 CFR Part 403.7 (removal credit regulations) is shown and removal credit authority is granted, the control authority can remove the requirement for pretreatment of the pollutants that remain in a PFPR facility’s wastewater discharge after all applicable P2 practices have been implemented and those pollutants can be demonstrated to neither pass through nor interfere with the operation of the POTW (in accordance with 40 CFR 403 provisions). The PFPR industrial user would also have to continue to comply with the pollution prevention practices as specified i
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