If a facility chooses the P2 alternative, will they always have to install and operate a wastewater treatment system? What PFPR wastewater requires treatment prior to discharge?
The P2 alternative of the final PFPR rule stipulates that direct discharging facilities must treat any PFPR wastewater that remains following implementation of the P2 practices. Direct discharging facilities that are also pesticide manufacturers may be able to use their current treatment systems to treat PFPR wastewaters. Indirect discharging facilities must only treat, prior to discharge, certain PFPR wastewaters that remain after the facility has implemented the P2 practices. These wastewaters are all interior equipment cleaning rinsates (including drum rinsates), leak and spill cleanup water, and floor wash water (see Section IV of the preamble to the final rule in Appendix A of this guidance manual).
