What kind of compliance paperwork is required for zero dischargers, including facilities that do not generate wastewater and facilities that totally reuse all wastewater generated?
If the facility does not have a “potential to discharge,” such as facilities that do not generate wastewater, they are not covered by the scope of the regulation; however, a facility may want to send a letter or certification statement to their POTW/control authority stating that they have “no potential to discharge.” If the facility does have the “potential to discharge,” even if they are not actively discharging (which may be the case with facilities that totally reuse wastewater), the facility needs to complete a BMR. For the monitoring requirements portion of the BMR, they should indicate that they will be achieving zero discharge, and therefore, there is nothing to monitor. If the facility is complying with zero discharge by demonstrating “nondetects” of pesticide active ingredients and priority pollutants, the BMR should contain monitoring data for the priority pollutants, as well as a list of the pesticide active ingredients expected to be used in production in the next 12 month
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- What kind of compliance paperwork is required for zero dischargers, including facilities that do not generate wastewater and facilities that totally reuse all wastewater generated?
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