Is a one-time test per product acceptable to justify the “BIOGROWTH” modification?
Yes, over the time period of the permit (usually three years), unless the product formulation or method of production is altered in a way that could affect the quality of the wastewater. If a facility is going to use laboratory testing to demonstrate biological growth (or other product deterioration), it should be performed with a sample that is representative of the formulation, as well as the typical storage period. A facility has very long production runs (1 to 2 years) and cannot predict when product changeover will occur. When they do change over production, they generate a non-reusable rinsate. Is this facility eligible for the “DROP” modification? After demonstrating the use of water conservation practices (as specified in P2 practice #1 in Table 8 of the PFPR rule), a facility could use historical production data to support the “DROP” modification. This modification allows the facility to discharge interior rinsates under the P2 alternative when the facility is dropping registr
