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When determining whether a facility has a “potential to discharge,” how are sanitary hookups viewed? For example, what if a worker dumps a bucket of floor wash into a toilet?

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When determining whether a facility has a “potential to discharge,” how are sanitary hookups viewed? For example, what if a worker dumps a bucket of floor wash into a toilet?

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The potential to discharge only includes regulated wastewater sources. Sanitary water, as well as employee shower and laundry water, are not regulated wastewater sources under the PFPR rule. Therefore, a facility could have a sanitary hookup and still be considered as having “no potential to discharge” regulated wastewater. If a facility is concerned that their employees may discharge regulated wastewater sources through a sanitary hookup, they may want to establish a training program, including standard operating procedures (SOPs) to cover the management of wastes at their site.

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