If an indirect discharging facility is interested in entering the PFPR market in the next 1-2 years, what steps should that facility take before production begins and after production begins?
New sources must complete a BMR 90 days prior to discharge and must be in compliance with the PFPR pretreatment standards (PSNS) at the commencement of discharge. This means the facility must submit their initial certification statement (or certify that they achieve zero discharge) to the control authority and have their on-site compliance paperwork completed. Ninety days following commencement of discharge, the facility must complete their 90-day compliance report. If the facility chooses the P2 alternative, they will also need to complete their periodic certification statement in June and December of each year. If the facility is not a new source, the facility will have to be in compliance with the PFPR regulation by November 6, 1999. At this point, the BMR (which was due by July 7, 1997) and the initial certification statement must be submitted and the on-site paperwork completed. Ninety days following commencement of discharge, the facility must complete their 90-day compliance rep
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