xvEPA
United States
Environmental Protection
Agency
Office of Water
Office of Pollution Prevention and Toxics
Washington, DC 20460
EPA-821-B-98-017
June 1998
http://www.epa.gov
Final
Pollution Prevention (P2)
Guidance Manual for the
Pesticide Formulating,
Packaging, and
Repackaging Industry:
Implementing the
P2 Alternative
Printed on paper that contains at least
20 percent postconsumer fiber.
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EPA-821-B-98-017
June 1998
Final
(P2)
for the
the P2
Office of Water
and
Office of Pollution Prevention and Toxics
U.S. Environmental Protection Agency
Washington, DC 20460
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Notice
This manual was made available in draft form to regulators and members
of the regulated community. Comments received on the draft manual have
been incorporated into this final manual. Mention of trade names or com-
mercial products does not constitute endorsement or recommendation for
use. The policies set forth in this manual are not final Agency actions but
are intended solely as guidance. The manual does not substitute for the
Clean Water Act or EPA's regulations; nor is it a regulation itself. Thus, it
cannot impose legally-binding requirements on EPA, States, or the regu-
lated community, and may not apply to a particular situation based upon
the circumstances. EPA and local decisionmakers retain the discretion to
adopt approaches on a case-by-case basis that differ from this guidance
where appropriate. EPA may change this guidance in the future.
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Foreword
This Pollution Prevention (P2) manual discusses the applicability and
implementation of effluent limitations guidelines and standards covering
the pesticide formulating, packaging, and repackaging (PFPR) industry.
The main purpose of the manual is to provide guidance to industry and
permitters in the process of complying with this rule, in particular, com-
plying with the P2 Alternative Option. EPA has received numerous re-
quests from refilling establishments questioning how the final rule applies
to them. This foreword is an aid to facilities in determining if the informa-
tion contained in this manual is applicable to them.
The final rule is applicable to
two subcategories of new and
existing PFPR operations as
discussed in the box to the
right. In general, because refill-
ing establishments covered
under Subcategory E must
achieve zero discharge, the P2
alternative guidance provided
in this manual is not appli-
cable. However, if a refilling es-
tablishment also performs
PFPR operations covered un-
der Subcategory C, for which
the P2 alternative is an
option,that facility may be in-
terested in obtaining a copy of
this manual, as they could
commingle their Subcategory
E wastewater with their Sub-
category C wastewater and
choose to follow the Subcategory
Pollution Prevention Alternative)
PFPR Subcategories
Subcategory C: Pesticide formulating, packaging, and
repackaging (PFPR), including pesticide formulating,
packaging, and repackaging occurring at pesticide
manufacturing facilities (PFPR/Manufacturers) and at stand-
alone PFPR facilities (does not include research and
development operations).
Subcategory E: Repackaging of agricultural pesticide
products at refilling establishments. Refilling establishments
are defined as establishments where the pesticide product
is repackaged into refillable containers. The limitations and
standards of the rule covered under Subcategory E apply
only to the repackaging of pesticide products performed by
refilling establishments: (a) that repackage agricultural
pesticides; (b) whose primary business is wholesale or
retail sales; and (c) where no pesticide manufacturing,
formulating, or packaging occurs. Custom application and
custom blending operations are not covered under
Subcategory E.
C regulations (i.e., zero discharge or the
More specifically, the final rule for Subcategory C facilities requires either
zero discharge of pollutants or the P2 alternative, which allows a dis-
charge of pollutants if certain P2 practices are implemented, followed by
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treatment as necessary. Facilities can choose the P2 alternative on a
facility-wide basis or by product family/process line/process unit.
The final rule for Subcategory E facilities requires zero discharge of pol-
lutants; there is no option for an allowable discharge after implemeting
approved P2 practices. The zero discharge limitation is based on. collec-
tion and storage of process waste waters, including rinsates from clean-
ing minibulk containers and their ancillary equipment and wastewaters
from secondary containment and loading pads, with the exception of
contaminated storm water. In most cases, refilling establishments hold
wastewater until it can be applied as pesticide in accordance with the
product label or reused as make-up water in an application of pesticide
chemical to an appropriate site. Data collected by EPA show that 98% of
all refilling establishments already achieve zero discharge, primarily by
holding contaminated wastewater and reusing it as make-up water.
IV
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of
Chapter 1 Introduction[[[ 1
Chapter 2 PFPR Operations[[[ 7
Chapter 3 Pollution Prevention Glossary............................................... 15
Chapter 4 Conducting the P2 Audit[[[ 23
Chapter 5 Wastewater Treatment Technologies ................................... 41
Chapter 6 Conducting the Treatability Test.......................................... 47
Chapter 7 Regulatory Compliance Documentation............................. 77
Chapter 8 Case Studies [[[ 87
Chapter 9 Where to Get Additional P2 Help ........................................ 97
Chapter 10 Workshop Questions and Answers.................................... 103
Feedback Survey[[[ 159
Appendix A Final Regulation (40 CFR Part 455)......................... 161
Appendix B PFPR Compliance Documentation (Sample Forms)....... 213
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s
Shari Zuskin of the U.S. Environmental Protection Agency (EPA), Office of
Water, Engineering and Analysis Division, was the work assignment man-
ager responsible for the preparation and review of this guide. Holly Elwood
of EPA's Office of Pollution Prevention and Toxics, Pollution Prevention
Division, also contributed heavily to the preparation and review of this
manual. This manual was prepared with the support of Eastern Research
Group (Contract No. 68-C5-0023) under the direction and review of the
Office of Science and Technology.
VI
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CHAPTER 1
Introduction
This manual is designed to provide guidance on how to assess pollution
prevention (P2) opportunities at pesticide formulating, packaging, and
repackaging (PFPR) facilities and to assess compliance with the P2 Al-
ternative Option of the effluent limitations guidelines and standards for the
PFPR industry (61 FR 57517). The opportunities and compliance methodolo-
gies discussed in this manual specifically relate to water use and reuse, waste-
water generation, and wastewater treatment and disposal. The manual is
intended for use by PFPR facility managers, publicly owned treatment works
(POTWs), permit writers and other regulatory agency representatives, fed-
eral and state auditors, and consultants.
Why Implement P2?
Effective P2 programs offer several benefits, summa-
rized in Table 1-1, when incorporated as part of facil-
ity operations. Although this manual concentrates on
water management practices, a P2 assessment and the
resulting operation changes often lead to overall im-
provements in the efficiency of PFPR process opera-
tions through decreasing the loss of raw materials and
minimizing waste disposal costs.
Information contained in the manual is not meant to
represent an exhaustive list of P2 opportunities that
may exist or should be put to use at any one facility;
rather, it is intended to identify P2 practices currently
in use in the industry and to provide additional infor-
mation on how to implement these and other prac-
tices as well as aid in compliance with the PFPR effluent
guidelines and standards. The Environmental Protec-
tion Agency's (EPA's) Office of Research and Devel-
opment previously published P2 guides for the
pesticide formulating industry and for nonagricultural pesticide users. These
guides evaluated waste minimization options for formulating facilities, and
were not specifically focused on water management practices.
In addition, many states have developed P2 guidance applicable to PFPR
facilities. Members of the PFPR industry and their trade associations have
also spent time and money evaluating the incorporation of P2 into facility
operations and have developed effective tools to assist that process.
Table 1-1
Examples of Benefits of Pollution
Prevention
Cost Benefits of Pollution Prevention
• Cost savings from recovery of active
ingredients
• Cost savings from recovery of water
• Reduction in cost of waste disposal
• Reduction in permitting costs
Other Advantages of Pollution Prevention
• Improved corporate image
• Improved worker and community safety
• Compliance with effluent guidelines
• Assistance with environmental programs
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CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry
What is P2?
The Pollution Prevention Act of 1990 established a national policy to prevent
or reduce pollution at the source whenever feasible as the first and preferred
choice for environmental management. This policy is referred to as pollution
prevention, or source reduction, and may include in-process recycling prac-
tices. Table 1-2 shows EPA's preferred hierarchy of environmental manage-
ment options, of which pollution prevention is the first choice. Table 1-2 also
presents a definition of source reduction/pollution prevention as it pertains
to the environmental hierarchy.
Table 1-2
Environmental Management Hierarchy
1. Pollution should be prevented or reduced at the source whenever feasible ("source reduction");
Z. Pollution that cannot be prevented should be recycled in an environmentally safe manner whenever
feasible;
3. Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner
whenever feasible; and
4. Disposal or other release into the environment should be employed only as a last resort and should
be conducted in an environmentally safe manner.
Source Reduction m Any practice that reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released
into the environment prior to recycling, treatment, or disposal;
• Any practice that reduces the hazards to public health and the
environment associated with the release of such substances, pollutants, or
contaminants; and
• Equipment or technology modifications, process or procedure
modifications, reformulation or redesign of products, substitution of raw
materials, and improvements in housekeeping, maintenance, training, or
inventory control.
EPA is required by the Pollution Prevention Act of 1990 to incorporate P2 into
all of EPA's activities, including rulemaking and implementation. The Source
Reduction Review Project was established in 1992 to instill the tenets of the
Pollution Prevention Act into every phase of EPA's rulemaking process. As a
part of this effort, EPA has focused on incorporating P2 practices, specifically
the reuse and recycle of process wastewaters, into effluent limitations guide-
lines and standards for the PFPR industry.
PFPR Pollution Prevention Alternative
On September 30, 1996, EPA promulgated effluent limitations guidelines and
standards for the PFPR industry. A copy of the final rule is contained in Ap-
pendix A. The final rule covers process wastewater discharges from PFPR
operations occurring at facilities in two subcategories, as defined in Table 1-3.
The formulation, packaging, and/or repackaging of all pesticide products
fall within the rule's applicability, with the exception of the six groups of
products listed in Table 1-4. (The regulatory definitions of these excluded pes-
ticide products can be found starting on page 57548 of the final rule FR no-
tice, in Appendix A of this manual.)
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
Table 1-3
PFPR Industry Definitions
Subcategories
Subcategory C: Pesticide formulating, packaging, and repackaging (PFPR), including PFPR operations at
pesticide manufacturing facilities and at stand-alone PFPR facilities (Note: does not include
research and development operations).
Subcategory E: Repackaging of agricultural pesticide products at refilling establishments (Note: does not
include custom application).
PFPR Operations
Formulating: The process of mixing, blending, or diluting one or more pesticide active ingredients with
one or more active ingredients, without an intended chemical reaction, to obtain a
manufacturing use product or end use product.
Packaging: The process of enclosing or placing formulated pesticide product into a marketable container.
Repackaging: The direct transference of a pesticide active ingredient or formulated product from any
marketable container into another marketable container, without a change in composition of
the formulation or the labeling content, for sale or distribution.
Table 1-4
Excluded Pesticide Products
A flow chart depicting the process to determine whether a facility is subject
to the PFPR effluent guidelines or pretreatment standards is shown in Figure
1-1. The first step is to determine if the facility formulates, packages, and/or
repackages pesticide products based on the industry definitions presented in
Table 1-3. If the answer is no, the facility is not subject to this rule. If the
answer to any of these questions is yes, the next step is to determine whether
the pesticide products contain active ingredients that are within the scope of
the rule based on the exemptions listed in Table 1-4. If they do, the facility
must operate in compliance with the PFPR effluent guidelines.
The final rule requires facilities to meet zero dis-
charge of process wastewater pollutants. The
rule also offers the option of a Pollution Pre-
vention Alternative to Subcategory C facilities
that agree to implement certain P2, reuse, and
recycle practices (and treatment when neces-
sary). These facilities receive a discharge allow-
ance referred to as the P2 allowable discharge
(see Appendix A for the definition of allowable
discharge). As shown in Figure 1-1, if the fa-
cility does not generate any wastewater from
their PFPR operations, they are not covered
by the rule (no potential to discharge). If they
generate a pesticide-containing wastewater, a determination must be made
of whether the wastewater is covered under the final rule; the rule does ex-
empt from regulation certain wastewater sources, which are discussed in
Chapter 4.
If it is determined that the facility generates a wastewater covered under the
rule and does not discharge this wastewater, but has the potential to dis-
charge, they are covered and are in compliance with zero discharge. If they
wish to discharge that wastewater, they must comply with the P2 alternative.
Sanitizer products;
Microorganisms;
Group 1 and Group 2 mixtures;
Inorganic wastewater treatment chemicals;
Chemicals that do not pass through POTWs; and
Certain liquid chemical sterilants.
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
Determining Applicability of Rule
Facility
Formulates
Pesticide
Products
YES
*
Facility
Packages
Pesticide
Products
Facility
Repackages
Pesticide
Products
NO Not Within
Scope of Rule
YES
J
YES
Pesticide Products
Within Scope or
Containing Active
Ingredients Within
Scope
NO
^^H
YES
Facility Must Comply
with PFPR Effluent Guideline
I
Facility Has
In-Scope
Products
Facility Generates
Wastewater
No Potential to Discharge
(not covered by rule)
^^
YES
Wastewater
Generated Is Defined
in Rule as PFPR
Process Wastewater
NO
Not covered by rule
^m
YES
Facility Discharges
Process Wastewaters
•
Facility Has Potential
(e.g., hookups to POTW
in process areas) to
Discharge PFPR Process
Wastewaters
NO
Not covered by rule
YES
^^H
YES
Facility Is Candidate
for P2 Alternative
Facility Is In Compliance
with Zero Discharge
(and candidate for P2 Alternative)
Figure 1-1. Determining Applicability of Rule
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CHAPTER I Introduction Pollution Prevention Guidance Manual for the PFPR Industry
Each facility subject to the final PFPR rule will need to make an initial choice
of how to comply with the regulation. They will need to choose to either
comply with the zero discharge effluent limitation/pretreatmeiit standard or
agree to conduct the P2 practices listed in Table 8 of the rule (and conduct
treatment where necessary). The facility can also use a variation of a listed
practice based on modifications listed in Table 8 of the final rule or those
agreed to by the permitting/control authority. Facilities will also need to agree
to make the practices and the P2 discharge allowance enforceable; for ex-
ample, the facility would agree to include them in their NPDES permit for
direct discharges or in an individual control mechanism with the control au-
thority for indirect discharges. This choice can be made either on a facility-
wide basis or on a process basis (i.e., product family/process line/process
unit). Each of the P2 practices listed in Table 8 of the rule is described more
fully in Chapter 3 of this manual.
EPA's Office of Water and Office of Pollution Prevention and Toxics have
created this guidance manual to facilitate compliance with this rule. P2 prac-
tices that are required as part of compliance with the P2 alternative form the
basis of the manual; however, other nonrequired P2 opportunities that a fa-
cility may choose to implement are also presented. Because the manual fo-
cuses on water use and wastewater generation, it is not intended to offer
guidance on the development of state P2 plans; however, P2 opportunities
discussed here may also be incorporated into PFPR facility state P2 plans. The
manual does not include an exhaustive list of all possible P2 opportunities,
but provides a framework for an initial assessment of PFPR operations as
they pertain to water use and wastewater generation and to compliance with
the P2 alternative.
to
This manual is organized into 10 chapters and six appendices:
• Chapter 2 provides basic descriptions of PFPR operations (e.g., dry formu-
lating, aerosol packaging, and drum rinsing) for those readers unfamiliar
with this industry;
• Chapter 3 provides a glossary of the specific P2 practices and equipment
required to implement the P2 alternative, as well as other P2 practices and
equipment found in the industry, including illustrations and benefits of
use;
• Chapter 4 presents instructions and an example for conducting P2 audits
to evaluate water management practices at PFPR facilities and to aid in
making compliance decisions;
• Chapter 5 discusses wastewater treatment technologies;
• Chapter 6 presents information on how to conduct a treatability test;
• Chapter 7 discusses evaluation of wastewater treatment system perfor-
mance, compliance with the PFPR effluent guidelines rule, and certifica-
tion paperwork;
• Chapter 8 presents case studies to provide guidance to the user in comply-
ing with the PFPR regulation;
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CHAPTER I Introduction Pollution Prevention Guidance Manual for the PFPR Industry
• Chapter 9 provides a list of resources for additional help in complying
with the regulation;
• Chapter W presents questions asked at the five workshops EPA conducted
on the PFPR rule in July through September 1997 and EPA's responses to
those questions, which are grouped by topic;
• Appendix A presents the final rule for the PFPR industry;
• Appendix B presents tables that can be used to document the results of P2
audits, wastewater treatment tests, and compliance decisions related to
the final PFPR rule;
• Appendix C lists the pesticide active ingredients presented in Table 10 to
Part 455 (in Appendix A) together with their Shaughnessy codes and CAS
numbers;
• Appendix D provides an excerpt on test procedures for an EPA-spon-
sored treatability test.
• Appendix E presents guidance on requirements of the Baseline Monitor-
ing Report (BMR) and the applicability of categorical pretreatment stan-
dards to industrial users, including zero discharge facilities; and
• Appendix F presents a list of terms, and their definitions, commonly used
in the PFPR industry (regulatory definitions are included in the final rule).
This is the first time that EPA has written a P2 Guidance Manual in conjunc-
tion with a rule, and we would like your valuable input on how useful this
document is to you. On page 159, you will find a short survey requesting
your input. Please take a moment to evaluate the manual's usefulness in de-
scribing P2 opportunities for the PFPR industry and evaluating compliance
with the PFPR effluent guidelines rule, and whether you thought the manual
was "user friendly."
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CHAPTER!
PFPR Operations
Table 2-1
PFPR Operations
Because of the large number of pesticide products a
facility may handle, most PFPR facilities operate on
This chapter describes seven types of basic operations, shown in Table
2-1, used in the PFPR industry. The descriptions presented are simpli-
fied and will be most useful for those readers unfamiliar with the
industry. They are intended to be used in conjunction with the P2 glossary
located in Chapter 3 to help identify and implement specific P2 opportunities.
Facilities in the PFPR industry formulate, package,
and repackage a variety of pesticide products, includ-
ing herbicides, insecticides, and fungicides. These fa-
cilities typically have physical divisions between
formulating and packaging operations, and between f Liquid Formuiating
dry and liquid operations. _ ,. ...
J n r - Dry Formulating
Liquid Packaging
Dry Packaging
the principle of "just-in-time" production. This prin- m Aeroso| Packaging
ciple basically dictates that products are made on cus-
tomer demand to reduce the space needed to keep ' Pressurized Gas Formulating and Packaging
large inventories on hand. However, because produc- • Repackaging
tion is tied to customer orders, the specific products
that are formulated, packaged, or repackaged can vary
from day to day and hour to hour. Therefore, facilities often use an equip-
ment line (e.g., a liquid formulating line) to make multiple products over the
course of a day, or week, or month.
Facilities typically formulate, package, or repackage these products in batches.
They also usually have the flexibility to "mix and match" equipment as needed.
For example, a facility may have two formulation mix tanks, Tank A with a
capacity of 100 gallons and Tank B with a capacity if 500 gallons. Both mix
tanks have piping connections to a product storage tank (Tank C) with a
capacity of 500 gallons. The facility can configure these tanks two ways, de-
pending on the amount of product to be formulated. If 100 gallons of product
or less are scheduled to be made, the facility connects Tank A with Tank C
and uses Tank A to formulate the product. If more than 100 gallons of prod-
uct are scheduled to be made, the facility connects Tank B with Tank C and
uses Tank B to formulate the product. In both cases, the facility is attempting
to maximize their production while minimizing the amount of equipment
that will need to be cleaned prior to formulating a new product.
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Liquid Formulating
Liquid formulations contain mixtures of several raw mate-
rials, including pesticide active ingredients, inert ingredi-
ents, and a base solvent, and may also contain emulsifiers
or surfactants. The solvent may be water or an organic
chemical, such as isopropyl alcohol or petroleum distillate.
In some cases, the formulation is an emulsion and contains both water and
an organic solvent. Solid materials, such as powders or granules, may also be
used as part of a liquid formulation by being dissolved or emulsified in the
solvent to form a liquid or suspension. The formulated product may be in a
concentrated form requiring dilution before application, or may be ready to
apply.
An example of a liquid-based formulating line is shown in Figure 2-1. Typical
liquid formulating lines consist of storage tanks or containers to hold active
and inert raw materials, and a mixing tank for formulating the pesticide prod-
uct. A storage tank may also be used on the formulating line to hold the
formulated pesticide product, prior to a packaging step. Facilities may re-
ceive their raw materials in bulk and store them in bulk storage tanks, or they
may receive the raw materials in smaller quantities, such as 55-gallon drums,
50-pound bags, or 250-gallon minibulk containers or "totes" (smaller, refill-
able containers). These raw materials are either piped to the formulation ves-
sel from bulk storage tanks, or added directly to the vessel from drums, bags,
or minibulks. Typically, water or the base solvent is added to the formulation
vessel in bulk quantities.
The formulating line may also include piping and pumps for moving the raw
material from the storage tanks to the mixing tank, and for moving formu-
lated pesticide product to the packaging line. Other items that may be part of
the line are premixing tanks, stirrers, heaters, bottle washers, and air pollu-
tion control equipment. Some lines may also contain refrigeration units for
formulation, storage units, scales, and other equipment.
WATER OR BASE
SOLVENT
DRUMS
FORMULATION
VESSEL
FORMULATED
PRODUCT
STORAGE
MINIBULK
Figure 2-1. Liquid-Based Formulation Line
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Dry Formulating
Dry formulations contain active and inert in-
gredients; the final product may be in many
different forms, such as powders, dusts,
granules, blocks, solid objects impregnated
with pesticide (e.g., flea collars), pesticides
formed into a solid shape (e.g., pressed tab-
lets), or microencapsulated dusts or granules. They are formu-
lated in various ways, including mixing powdered or granular
actives with dry inert carriers, spraying or mixing a liquid active
ingredient onto a dry carrier, soaking or using pressure and heat
to force active ingredients into a solid matrix, mixing active in-
gredients with a monomer and allowing the mixture to poly-
merize into a solid, and drying or hardening an active ingredient
solution into a solid form. These dry pesticide products may be
designed for application in solid form or to be dissolved or emul-
sified in water or solvent prior to application.
Because of the many types of dry pesticide products, dry
pesticide formulating lines can vary considerably. Figures
2-2 and 2-3 are examples of granular and dry spray-coated
formulation lines. Dry formulating lines typically have tanks
or containers to hold the active ingredients and inert raw
materials, and may include mixing tanks, ribbon blenders,
extruding equipment, high-pres-
sure and temperature tanks for
impregnating solids with active
ingredient, a vacuum or other
type of drying equipment, tanks
or bins for storage of the formu-
lated pesticide product, pelletiz-
ers, presses, milling equipment,
sieves, and sifters.
Raw materials for dry pesticide
products may be liquid or solid.
Liquid raw materials may be
stored in rail tank cars, tank
trucks, minibulks, drums, or
bottles. Dry raw materials may be
stored in silos, rail cars, tank
trucks, minibulks, supersacks,
metal drums, fiber drums, bags, or
boxes. Liquid raw materials may
be pumped, poured, or sprayed
into formulation vessels, while dry
raw materials are frequently trans-
ferred to formulation equipment
by screw conveyors (consisting of
a helix mounted on a shaft and
turning in a trough), through el-
evators, or by pouring.
BAGS
FORMULATED
PRODUCT
STORAGE
Figure 2-2. Granular Formulation Line
CYCLONE
FINAL
PRODUCT BIN
Figure 2-3. Dry Spray-Coated Formulation Line
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Dry formulating lines may also include piping and pumps for moving raw
materials from storage tanks to the formulation equipment, and for moving
formulated pesticide product to the packaging equipment. Other items that
may be included in the dry pesticide formulating line are premixing tanks,
tanks for storing formulated product prior to packaging, stirrers, heaters, re-
frigeration units on formulation and storage equipment, scales, and air pollu-
tion control equipment (e.g., cyclones, filters, or baghouses). Dry pesticide
products may be packaged into rail tank cars, tank trucks, totes, minibulks,
and water-soluble packaging, but are typically packaged into bags, boxes, or
drums.
Liquid Packaging
Many liquid formulations are packaged by simply
transferring the final product into containers. Fig-
ure 2-4 depicts a liquid packaging line. Small quan-
tities of product are often manually packaged by
gravity feeding the product directly from the formulation tank into
the product container. For larger quantities, the process is often auto-
mated. Formulated product is transferred to the packaging line through
pipes or hoses, or is received from a separate formulating facility, and placed
in a filler tank. A conveyor belt is used to carry product containers, such as
jugs, bottles, cans, or drums, through the filling unit, where nozzles dispense
the appropriate volume of product. The belt then carries the containers to a
capper, which may be automated or manual, and then to a labeling unit.
Finally, the containers are packed into shipping cases.
Dry Packaging
Dry formulations are also pack-
aged by simply transferring the
final product into boxes, drums,
jugs, or bags. Figure 2-5 depicts a
dry packaging line. Again, small
quantities or bags are typically
packaged manually using a gravity feed to carry
the product from the formulating unit into the con-
tainers or bags. Larger quantities may be packaged
on an automated line, similar to liquid packaging
lines.
Figure 2-4. Liquid
Packaging Line
Figure 2-5. Dry Packaging Line
10
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Aerosol Packaging
Some water- or solvent-based liquid pesticide products are
packaged as aerosols. Figure 2-6 is an example of an aerosol
packaging line. The product is placed in spray cans that are
put under pressure, and a propellant is added. When the end
user sprays the aerosol, the propellent forces the product out
of the can and allows the product to be applied to surfaces or to be dispersed in
the air. An aerosol packaging line typically includes a filler, a capper, a propel-
lant injector, and a U.S. Department of Transportation (DOT) test bath. In the
filler, formulated pesticide product is dispensed into empty aerosol cans, in much
the same way that the liquid packaging lines fill containers. The cans are then
sent to the capper, where a cap with nozzle is placed on the can. The can enters
a separate room, where the propellent is injected into the can, a vacuum is pulled,
and the cap is crimped to make the can airtight. In order to comply with DOT
regulations on the transport of pressurized containers, each can must then be
tested for leaks and rupturing in a DOT test bath. The DOT test bath is a 130°F
hot water bath into which cans are submerged and observed for leaks or rup-
tures. The aerosol packaging line may also include a can washer to remove resi-
due from can exteriors prior to entering the test bath (to reduce contaminant
buildup in the bath), a dryer to dry can exteriors, and machinery to package
aerosol cans into boxes for shipment.
FORMULATED
PRODUCT
AEROSOL
PRODUCT
Figure 2-6. Aerosol Packaging Line
^s> Pressurized Gas Formulating and Packaging
Some pesticide products are formulated and packaged as
pressurized gases. Figure 2-7 depicts a pressurized gas pro-
duction line. The active and inert ingredients are received
as liquids, pressurized liquids, or gases, and are stored in
tanks, tank trucks, rail cars, or minibulk storage contain-
ers. Liquid ingredients are placed in a holding tank prior to formulation. For-
mulating and packaging operations for these products typically occur in one
11
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
FILLED
CYLINDER
Figure 2-7. Pressurized Gas Formulating and Packaging Line
step in a closed-loop system. The ingredients are metered by weight through
pressurized transfer lines into DOT-approved steel application cylinders. Other
equipment that may be included in a pressurized gas line includes pumps,
piping, and heating and refrigerating units to maintain gas pressures and
temperatures in storage.
The cylinders may be refilled at a later date, after they have been tested to
ensure that they are still capable of containing pressurized fluids. DOT requires
hydrostatic pressure testing, as well as visual examination of the cylinder. Hy-
drostatic pressure testing involves filling the tank with water to a specified
pressure and volume. If more water can be held in the cylinder than its original
volume, or if the cylinder weighs less than 10% of its original weight, it is
possible the cylinder walls are deformed, and the cylinder fails the test. Visual
inspection entails purging the cylinder of its vapors using an inert gas such as
nitrogen, and inspecting the inside for pitting and other defects with a fiber
optic probe. The cylinder is then rinsed with water and dried.
Repackaging
Repackaging operations are similar to packaging opera-
tions, except the "raw material" is an already formulated
product that has been packaged for sale. Repackagers of-
ten purchase formulated pesticide products, transfer the
product to new containers with customer-specific labeling,
and sell them to distributors.
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CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry
A separate type of repackaging, called refilling, is usually performed by
agrichemical facilities that transfer pesticide products from bulk storage tanks
into minibulks. These refillable containers are constructed of plastic and typi-
cally have capacities ranging from 100 to 500 gallons. Minibulks may be owned
by the refilling establishment, the pesticide registrant, or by the end user. Pro-
duction lines usually consist of a bulk storage tank, a minibulk tank into which
the product is repackaged, and any interconnecting hoses or piping. The bulk
storage tanks are usually dedicated by product and clustered together in a
diked area. The products are dispensed to the minibulks either manually or
by using a computer-regulated system of pumps and meters. The minibulks
are typically reused by farmers or custom applicators and returned to the refill-
ing establishment.
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CHAPTER 3
Pollution Prevention Glossary
Many PFPR facilities use P2 practices that conserve water, reduce the
amount of pollutants in wastewater, or eliminate wastewater gen-
eration altogether. This chapter presents alphabetic glossaries for
two basic types of P2 techniques: (1) implementation of P2 practices; and (2)
use of P2 equipment. For the P2 practices, a description of the practice and its
benefits and an icon representing the practice are provided. For the P2 equip-
ment, a picture or illustration and description of the equipment is provided.
Throughout the manual, terms defined in this glossary will be shown in itali-
cized bold print.
The techniques presented in this chapter have been identi-
fied through site visits to almost 60 PFPR facilities, where
EPA observed the techniques in use. By implementing these
P2 techniques (e.g., use of flow reduction equipment), many
PFPR facilities generate less wastewater volume. By con-
trolling the volume of wastewater generated, facilities can
often reuse a larger overall percentage of their wastewa-
ter. Additionally, facilities can achieve optimal P2 benefits
by combining P2 techniques (e.g., use of flow reduction
equipment, dedication of equipment, and interior storage
and reuse) to reduce or eliminate wastewater generation and to increase the
level of reuse and recycle. [Note: This P2 glossary presents not only those
practices listed in Table 8 of the final PFPR rule, but also other P2 tech-
niques that were observed in the industry.]
PZ Practices
These practices reduce the amount of
active ingredients and other raw materials
lost in wastewater discharges, and may
also decrease the volume of PFPR
process wastewater generated.
Pollution Prevention Practices
Dedication of Equipment
PFPR facilities use production lines to formulate, package, and repackage a
wide range of products. When switching a production line from one product
to another (i.e., product changeover), the facility cleans the equipment (typi-
cally with water) to prevent cross-contamination of products. Dedicating
equipment on formulating and/or packaging lines to the production of one
product or product type can reduce or eliminate the need to clean that piece
of equipment for product changeover. In addition, because of the elimination
of cross-contamination concerns, routine cleaning typically uses less water.
NOTICE
Use For
Herbicides Only
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Some facilities dedicate just their formulation tanks, thereby eliminating one
of the most highly concentrated wastewater streams generated at their facil-
ity Other facilities have dedicated storage tanks or entire formulating, pack-
aging, or repackaging lines, if they produce large quantities of that product
over long periods of time. Still other facilities dedicate transfer hoses, pumps,
and other miscellaneous equipment. These PFPR facilities have implemented
this practice by using equipment that is:
• Dedicated to one product—a piece of equipment, or an entire formulating
or packaging line, that is used to produce only one specific product. This
type of dedication eliminates product changeover cleaning, and signifi-
cantly reduces routine cleaning. In addition, most cleaning rinsates can be
reused directly into the process (see Interior Rinsate Storage and Reuse).
* Dedicated to a product family—a piece of equipment, or an entire formu-
lating or packaging line, that is used to make products that have common
ingredients (such as s-triazine pesticides) or similar uses (such as herbi-
cides used on corn crops). This type of dedication can significantly reduce
product changeover cleaning and routine cleaning. In addition, most clean-
ing rinsates can be reused directly into the process (see Interior Rinsate
Storage and Reuse).
• Dedicated to solvent-based versus water-based products—a piece of
equipment, or an entire formulating or packaging line, that is used for prod-
ucts that have a common base solvent (e.g., water, isopropyl alcohol). This
type of dedication eliminates water-contaminated solvent rinses and sol-
vent-contaminated water rinses that are generated during product
changeover from water-based to solvent-based products and solvent-based
to water-based products. Dedicating equipment to a common base can
eliminate solvent-water rinsates, which typically cannot be reused, and
can significantly reduce product changeover cleaning and routine clean-
ing. In addition, most cleaning rinsates from common-base-dedicated equip-
ment can be reused directly into the process for future formulation of the
same or compatible product (see Interior Rinsate Storage and Reuse).
Direct Reuse of Drum Rinsate
PFPR facilities frequently receive raw materials in drums, such as 55-gallon
steel or 30-gallon fiber drums. Empty drums may be returned to the supplier,
or the facility may by responsible for disposal. To prepare the drums for re-
use, facilities "triple rinse" the drum (i.e., rinse out the inside of the drum
with water three times) or pressure rinse the drum according to procedures
provided in 40 CFR, Part 165. A "triple rinse" is defined in Part 165 as flush-
ing the container three times, using a volume of the diluent equal to approxi-
mately 10% of the container's capacity. When preparing drums for disposal
that contained nonhazardous materials, facilities should consult 40 CFR, Part
165.9 to determine if a triple rinse is required.
If the drum contained a material that is a listed hazardous waste, facilities
must also follow procedures provided in 40 CFR, Part 261.7(b) to empty the
container and dispose of or recycle it as nonhazardous. For example, "U"
listed wastes (40 CFR, Part 261.33(f)) must be removed so that no more than
2.5 centimeters (or one inch) of residue remains on the bottom of the con-
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CHAPTER 3 Pollution Prevention Glossary
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tainer, no more than 3% by weight of the container capacity remains in con-
tainers less than or equal to 110 gallons, and no more than 0.3% by weight of
the container capacity remains in containers larger than 110 gallons. It may
not be necessary to rinse the container if the material can be sufficiently re-
moved by draining, pouring, pumping, or aspirating, unless rinsing is re-
quired by 40 CFR, Part 165. Other wastes, such as "P" listed wastes (40 CFR,
Part 261.33(e)), must be removed by triple rinsing the container using a sol-
vent capable of removing the material.
The simplest, most cost-effective method of handling the subsequent rinsate
is to reuse it directly in the product formulation at the time of formulation.
This method eliminates the water from the facility's waste stream and recov-
ers the remaining raw material in the drum without the costs and space needed
for storage of the rinsate. If the product is a solvent-based product, the drums
can be rinsed with the base solvent of the product instead of water to prevent
creating a rinsate that cannot be added directly to the formulation.
In addition to reusing rinsate, some PFPR facilities use flow reduction equip-
ment, such as high-pressure washers, to effectively clean drums, while mini-
mizing the amount of rinsate generated (generally 5 to 15 gallons of rinsate
per drum).
Formulating and Packaging Small Batches in Containers
Facilities that generate small quantities of product may formulate that prod-
uct directly in the final shipping container (e.g., 55-gallon drum or minibulk
tank) to eliminate the use of a separate formulation tank. Facilities may also
package products directly from the formulation tank or blender into the final
shipping container to eliminate using interim storage tanks, packaging tanks,
and transfer hoses. These practices eliminate the need to use and clean cer-
tain formulating and packaging equipment, thereby reducing the amount of
rinsates generated during cleaning.
Good Housekeeping Practices
Good housekeeping practices are simple, straightforward operating practices
that can significantly reduce wastes. These practices include performing pre-
ventive maintenance on all valves, fittings, and pumps; placing drip pans
under valves and fittings where hoses or lines are routinely connected and
disconnected; and cleaning up spills and leaks in outdoor bulk storage and
process areas to prevent contamination of stormwater or exterior rinsewaters.
Other good housekeeping practices include repairing leaky valves and fit-
tings in a timely manner and reusing the material collected in drip pans.
Interior Rinsate Storage and Reuse
PFPR facilities use production lines to formulate, package, or repackage a
wide range of products. When switching a production line from one product
to another, the facility cleans the equipment (typically with water) to ensure
product quality. This interior equipment rinsate (either water or base solvent)
can be collected and stored in 55-gallon drums or small tanks for reuse as
make-up water in the next batch of that formulation or a compatible formu-
lation (e.g., product with same ingredients but at varying concentrations). In
REUS
REDUCE
RECYCLE
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Pollution Prevention Guidance Manual for the PFPR Industry
some cases, the rinsate can be reused immediately in the product if additional
water or solvent is needed for the final product (e.g., refilling establishments
preparing the product for application on fields).
When facilities combine this practice with the use of flow reduction equip-
ment, dedication of equipment, and other production practices, they can mini-
mize the volume of rinsates generated during production of pesticide products
and are often able to reuse all interior equipment cleaning rinsates. Benefits
from these practices include reduced costs for raw materials and waste dis-
posal or treatment.
Inventory Management
Many PFPR facilities operate inventory management systems to track raw
materials, finished products, and waste products. These systems are also use-
ful for tracking cleaning rinsates that can be reused at a later date in product
formulations. Some facilities log these rinsates into their inventory as raw
materials to ensure reuse as soon as possible and to eliminate the possibility of
forgetting about them once they are stored. In addition, quick reuse can re-
duce shelf-life expiration problems. These inventory systems may be manual
(for smaller operations) or computerized (for larger operations), and may
also contain other environmental data, such as waste disposal information.
Non-Water Interior Equipment Cleaning
PFPR facilities can use several cleaning techniques in addition to dry process
cleaning equipment to reduce or eliminate wastewater generation. After for-
mulating or packaging, dry carriers used in the final product (e.g., clay) are
often used to initially clean the equipment. These materials are run through
the equipment to absorb residual product that may be present and stored for
use in a future batch of that product. A production line may also be "blown"
clean by forcing air through the equipment and collecting the material that
exits the system for reuse. Hoses and transfer piping may be cleaned in this
manner. A water rinse may follow this procedure. Cleaning a line with dry
materials increases recovery of raw materials and reduces the amount of water
used during cleaning operations.
Operation of Air Pollution Control Devices
Air pollution control devices, including baghouses, cyclones, filters, and wet scrub-
bers, are sometimes installed on formulating or packaging lines to control the
release of volatile or dust emissions.
• "Dry" Devices—Baghouses, filters, or cyclones reduce air pollution with-
out the use of water by collecting dust and other particles generated dur-
ing production, particularly on dry product lines. Some facilities are able to
reuse the solid materials collected from those devices in the pesticide pro-
duction process.
• "Wet" Devices—Wet scrubbers also reduce air pollution by simultaneously
removing soluble and wettable particulates and soluble gases from an air
stream. To minimize wastewater generation from wet scrubbers, facilities
can either operate them with continuously recycled water until replace-
ment of the contaminated water is necessary, or with a bleed stream
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CHAPTER 3 Pollution Prevention Glossary
Pollution Prevention Guidance Manual for the PFPR Industry
(blowdown) on a continuous basis. However, facilities should not reduce
their flow to the point where it hinders their ability to meet Clean Air Act
or other requirements. In some cases, if a wet scrubber is dedicated to a line
that formulates a water-based product, the blowdown from the scrubber
can be reused in that formulation.
Operation of Department of Transportation (DOT) Test Baths
DOT test baths are used to test aerosol cans for leaks or weaknesses under
pressure. The cans are visually examined for leaks while in the test bath.
Because drips on the outside of cans, or occasionally exploding cans, can
contaminate the water bath, the water in batch baths must be changed peri-
odically to ensure visibility and to reduce the presence of residues that may
adhere to cans leaving the bath. Facilities operating DOT test baths with con-
tinuous overflow can recirculate the water for reuse. If necessary for visual
clarity, PFPR facilities can recirculate the water through a filter (e.g., diato-
maceous earth or activated carbon) to remove dirt and oils. The use of filters
allows water to be recirculated for longer periods of time before changeout is
necessary.
Production Scheduling
If a facility is not able to practice dedication of equipment, they often can
manage their production schedules to minimize product changeover clean-
ing operations. To do so, facility personnel can develop cleaning procedures
specific to each potential changeover. They can examine which products can
be formulated in succession without the need for cleaning (e.g., they contain
the same ingredients but in varying concentrations) or with a minimal clean-
ing. On any given day, production can be scheduled to minimize the cleaning
efforts and therefore the wastes that are generated during cleaning. In some
cases, facilities are able to schedule production so that the cleaning rinsates
generated are able to be reused in subsequent processes.
Training and Written Standard Operating Procedures
Employee training and well-written standard operating procedures (SOPs)
are an integral part of any pollution prevention program. Training will en-
sure that all employees are aware of the goals of current pollution prevention
initiatives and how the initiatives will improve operations. Written SOPs will
reinforce operator training and ensure that all functions are performed effi-
ciently. It is important to obtain both management and employee buy-in to
the program, and to view pollution prevention as a way of doing business.
Some PFPR facilities have formed pollution prevention teams or coordinators
to develop SOPs for cleaning procedures and for reuse of cleaning rinsates
into formulations. Some facilities have also integrated an evaluation of an
employee's adoption of P2 practices into performance reviews or provided
awards or incentives for innovative P2 ideas.
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Pollution Prevention Guidance Manual for the PFPR Industry
Pollution Prevention Equipment
Drum Rinsing Station
A drum rinsing station consists of a series of three
cells that are used to triple rinse drums. A typical
station uses a spray nozzle to shoot water at high
pressure into a drum that is inverted over the cell.
The rinsate flows out of the drum into the cell, the
drum is moved to the next cell, and the process is
repeated. The first cell is used for the first rinse, which
results in the most removal of pollutants and the most
contaminated rinsewater. The second cell is used for
the second rinse, which removes additional pollut-
ants, but the rinsewater is not as contaminated as
the first cell. The third cell is used for the final rinse, at which point most of
the pollutants have been removed by prior rinses and the rinsewater is the
least polluted of the three cells.
By rinsing the drum in stages (i.e., cells), the volume of rinsewater is reduced.
The rinse water in the first cell is reused until it is visibly too contaminated to
be used further. At that time, it is removed from the cell and treated or dis-
posed of. The cleaner rinsewater from the second cell is transferred into the
first cell and the cleanest rinsewater from the third cell is moved to the second
cell. Fresh water is added only to the third cell. As a result, two cells of water
are recycled, only one cell is filled with new water, and the quantity of water
used is reduced by about two thirds. Some PFPR facilities using a drum rins-
ing station with 100-gallon water cells have cleaned as many as 70 drums
before changing water.
Dry Process Cleaning Equipment
Dry process formulating and packaging lines, which do not generate waste-
water, are often cleaned using equipment such as brushes, scrapers, and vacu-
ums. This cleaning equipment will physically remove solids that have adhered
to process equipment during the formulating or packaging step. Examples of
dry process cleaning equipment include the following:
• Brushes/Scrapers—Wire brushes and scrapers are used to remove packed
or dried materials from the equipment that would not be removed with
vacuuming alone. This material can then be vacuumed or swept up for
reuse.
• Vacuums—A standard industrial shop vacuum (with appropriate electri-
cal classification and exhaust filtration) can be used to collect solids and
dusts that have settled on dry formulating and packaging equipment dur-
ing processing. It can also be used to clean floors in the dry process area
and to collect spilled product. The collected material can often be reused in
the formulating process.
Cleaning the equipment with brushes, scrapers, or vacuums may result in
recovery of dry product that can be reused in the process, and significantly
reduce or eliminate the need for water washes and the subsequent water
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Pollution Prevention Guidance Manual for the PFPR Industry
rinsates that cannot be directly reused. For example, a facility may initially
scrape off dried material from the process line equipment, vacuum loosened
materials, and finally perform a quick water rinse. The rinsate will contain
significantly less contaminants than if the facility had relied upon only water
to clean the equipment.
Floor Scrubbers
Floor scrubbers are mechanical devices that continually recirculate cleaning
water to clean flat, smooth surfaces with circulating brushes. They come in a
variety of shapes and sizes. During operation, the scrubber collects the clean-
ing water in a collection tank, which is easily emptied after the cleaning pro-
cess, or at a later date.
Cleaning floors by other methods, such as a mop and bucket or garden hose,
requires larger amounts of water. Floor scrubbers will significantly reduce the
amount of water used for floor cleaning while increasing the effectiveness of
the cleaning operation. A typical floor scrubber can clean large processing
areas in one hour but use only 10 to 20 gallons of water. The use of floor
scrubbers also reduces labor costs and water costs.
Flow Reduction Equipment
Flow reduction equipment includes simple mechanical devices that control
how water is sprayed during cleaning operations. The use of flow reduction
equipment reduces the volume of water generated during cleaning opera-
tions, as well as increases efficiency in the cleaning process. Examples of flow
reduction equipment are:
• Spray Nozzles—Nozzles are the most common form of flow reduction equip-
ment used in the PFPR industry. Spray nozzles are used to regulate the
amount of water used to clean both the interior and exterior of process
equipment. They also direct the water at a higher pressure than from an
unequipped hose, resulting in a more effective cleaning stream.
• High-pressure, low-volume washers—These washers provide a higher degree
of cleaning than a spray nozzle. Typical pressures range from 500 to 3,000
pounds per square inch (psi).
• Spray balls—These balls direct water through multiple nozzles or drilled holes
to efficiently clean the inner surfaces of closed or open tanks or trucks. Typi-
cal water pressures range from 45 to 75 psi; flow rates range from 10 to 48
gallons per minute (gpm), depending on the size of the spray ball and the
size of the tank to be cleaned.
• Hot water/steam cleaners—These cleaners are similar to high-pressure, low-
volume washers except they use steam or hot water. They are useful for
hard-to-clean products, such as emulsified formulations or highly viscous
materials. Typical operating pressures range from 230 to 3,000 psi; flow rates
range from 1 to 6 gpm.
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Without the use of this equipment, facilities may generate more wastewater,
particularly interior equipment rinsates, during the cleaning process than can
possibly be reused in product formulation. Other benefits to the use of flow
reduction equipment include lower water costs, increased cleanliness, and
reduced storage, treatment, or disposal costs. In addition, use of flow reduc-
tion equipment aids in avoiding free flow of water from unattended hoses.
Solvent Recovery Equipment
Solvent recovery equipment primarily consists of flash distillation units, which
use the difference in boiling points to physically separate organic solvent from
wastewaters. Some facilities may generate solvent-contaminated wastewa-
ters during cleaning operations that are unable to be reused in water-based
products; other facilities generate water-contaminated solvent wastes that
are unable to be reused in solvent-based products. These wastes are fed through
the distillation unit at a temperature where the solvent is vaporized from the
waste stream. The solvent vapor is then condensed to liquid. These efficient
units recover high yields of spent solvent for reuse in later formulations.
The use of solvent recovery equipment can reduce raw material (i.e., solvent)
usage and cost. In addition, this equipment can reduce disposal costs by recov-
ering solvent for reuse and reducing the quantity of solvent-aqueous
changeover water that is disposed of as waste.
22
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CHAPTER 4
Conducting the P2 Audit
The PZ Audit
One way facilities subject to the final PFPR rule can determine which
compliance option to choose is to use a four-part process: (1) conduct
a P2 audit, (2) make preliminary compliance decisions, (3) evaluate
wastewater treatment technologies, and (4) make and document final
compliance decisions. This chapter discusses the P2 audit and how a facility
can use that tool to make preliminary decisions on which compliance strategy to
choose. Chapters 5 and 6 present the ways in which a facility can treat the
wastewater remaining after the P2 practices have been implemented and evaluate
the economic impacts of wastewater treatment
compared to contract hauling. Chapter 7 presents
ways for facilities to make and document their final
compliance decisions.
A comprehensive P2 opportunities assessment
(or audit) is the first step in implementing an
effective P2 program and in determining com-
pliance with the final rule. However, this P2
audit is not required by the rule and is not man-
datory. The P2 audit described in this chapter
focuses on water use and wastewater genera-
tion. This audit is not designed to be a compre-
hensive P2 audit, as it does not fully evaluate solid
waste and air emissions; however, it will assist
users in identifying PFPR wastewater sources and
P2, recycle, and reuse practices and in making
compliance decisions for the PFPR effluent guide-
lines and standards. For information on P2 au-
dit tools that will help you analyze your solid
waste and air emissions, see the resources listed
in Chapter 9.
Each PFPR facility will need to make an initial
choice of how to comply with the regulation. A
facility may choose to either comply with the
zero discharge effluent limitation/pretreatment
standard or implement the P2 alternative (prac-
tices listed in Table 8 of the final rule plus waste-
water treatment when necessary). The choice of
zero discharge or the P2 alternative can be made
on either a facility-wide basis or on a process
Completing a PZ audit is not mandatory, but
may be helpful to:
• Decide whether to comply with the P2
alternative or the zero-discharge option;
• Assess whether a facility is in compliance with
the P2 alternative;
• Identify production changes that could result in
cost savings;
• Identify P2, recycle, and reuse opportunities for
wastewater discharges; and
• Organize paperwork documenting compliance
with the P2 alternative.
PZ Alternative
The P2 alternative permits a "P2 allowable discharge"
as an alternative to zero discharge of process
wastewater when facilities implement the specific P2
practices listed in Table 8 of Appendix A of this
manual and wastewater treatment when necessary.
These practices reduce the amount of active
ingredients and other raw materials lost in wastewater
discharges, and may also decrease the volume of
PFPR process wastewater generated.
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
basis (i.e., product family/process line/process unit). Facilities that imple-
ment the P2 alternative will also need to agree to make the practices and the
P2 discharge allowance enforceable.
The tools presented in this chapter to conduct a P2 audit are based on the
practices included in the effluent limitations guidelines and standards for the
PFPR industry as well as other P2 practices that are in use in the PFPR indus-
try. The audit may be used to identify waste sources at the point of generation
and to match each source with applicable P2, recycle, and reuse practices.
Identifying these P2 opportunities can help facilities reduce costs even when
not choosing to comply with the P2 alternative.
The P2 audit tables discussed in this chapter (Tables A through C) and the
wastewater treatment tables presented in Chapter 6 (Tables D and E) are
offered as one way to conduct an audit and/or to demonstrate compliance
with the P2 alternative. It is not required that facilities, permitters, or other
auditors use these tables. However, the tables discussed in this chapter
summarize the types of information that are useful in conducting a P2 oppor-
tunities assessment. Since it is very difficult to construct one table or checklist
with a format useful for all PFPR facilities, EPA hopes that the tables pre-
sented in this manual are a useful tool as they are, or can be adapted in
whatever way the user feels is appropriate. P2 audit tables are available in an
electronic format in Excel 5.0 and may be requested from Shari Zuskin of
EPA's Engineering and Analysis Division (see Chapter 9 for fax, E-mail, and/
or mailing address).
The information necessary to complete the tables may be collected in a vari-
ety of ways. Much of the information may already be available in production
records, state P2 plans, stormwater plans, inventory management systems,
or facility permits. In addition, the information gathered for the checklist may
also be used to help complete other types of plans (e.g., stormwater or state
P2 plans) in the future.
P2 Audit Tables
Table Title
Table A Identification of
Wastewater Sources
Table B Evaluation of PFPR P2,
Recycle, and Reuse
Practices
Table C Summary of PFPR
Compliance Decisions
Purpose
Helps users summarize in detail
potential wastewater sources through
review of process operations.
Helps users summarize in detail P2,
recycle, and reuse practices, and evaluate
their current use, whether they can be
implemented by the facility, and any
required modifications.
Helps users summarize the compliance
decision for each wastewater source
identified in Table A. The completion
of the P2 audit results in a preliminary
compliance decision for each source.
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CHAPTER 4 Conducting the P2 Audit
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Nonpesticide Operations and Industries
A P2 audit is also useful in identifying wastewater P2 opportunities
in other industries, such as those industries listed to the right. In
fact, many PFPR facilities also engage in formulating and packaging
of these nonpesticide products. Although the P2 audit tables are
designed specifically for the PFPR industry, the P2 opportunities
listed may be advantageous for other operations and industries.
Other chemicals
formulating, packaging,
and repackaging;
Pharmaceuticals;
Animal feed products;
Cosmetics; and
Fertilizers.
The P2 audit tables are designed for use by PFPR facility managers, POTWs,
permit writers and other regulatory agency representatives, federal and state
auditors, and consultants (referred to as the "user" throughout this chapter).
Example pages of the audit tables (completed for a fictitious facility) are shown
throughout this chapter to illustrate the types of information captured on the
tables. The blank tables are presented in their entirety in Appendix B. Specific
P2 equipment and practices listed on the table instructions in italicized,
bold print are defined in the P2 glossary in Chapter 3.
Conducting The Audit
In order to thoroughly assess P2, recycle, and reuse opportunities, detailed
information pertaining to all source identification and P2, recycle, and reuse
practices must be available to the user. This information is best obtained
through interviews with facility personnel, review of facility records, and
first-hand observation via a plant tour. The user can also incorporate, where
applicable, any personal knowledge of or experience with the facility. It is
helpful to review all information with facility personnel so that data gaps
may be filled, and to discuss facility-specific benefits or problems associated
with implementation of different P2, recycle, and reuse practices. Some of the
information, such as wastewater generation volumes and frequency, may not
be readily available the first time such an audit is completed; however, over
time a facility may implement systems to track these types of data to facilitate
future P2 assessments.
Each page of the P2 audit tables has space to enter the name and location of
the facility, the name of the user, and the date the audit is completed.
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CHAPTER 4 Conducting the P2 Audit
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Table A: Identification of Wastewater Sources
Table A of the P2 audit is not only the starting point but also the focal point of
the P2 audit. The wastewater streams and sources identified on Table A will
be linked to potential P2 opportunities on Table B and waste management
options in Chapter 6. Completing this table will enable facility personnel to begin
assessing whether to choose to comply with the P2 alternative, and if so, whether
to comply on a facility-wide basis or on a product family/process line/process
unit basis.
Table A is used to identify all PFPR wastewater sources at the facility and to
gather general operations and treatment information (e.g., frequency of waste-
water generation) about each source. The table includes a comprehensive list
of the wastewater streams and sources found in the PFPR industry; however,
space is also included for additional wastewater streams that may be identi-
fied for a specific facility. Three steps that can be used to complete Table A are
detailed below.
Step 1: Identify Wastewater Stream Types and Sources
The user should take time to accurately and completely identify all PFPR
wastewater stream types and sources at the facility. Figure 4-1 presents an
example of the types of information collected while completing Step 1. In
particular, the unshaded columns "Stream Type", "Source", and "Com-
ments" illustrate this example.
Table A
Table A. Identification of Wastewater Sources
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
5>xBulk Tank Rinsate - cleaning^
ofthtNqterior of any bulk stpfnge
tank containing raw majJrials,
products assoc^iatea^ith PFPR
operations^ ^^\
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
the interior of any formulating
equipment, inc ludingform u lot ion
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
metolachlor, and
inert drums
l.b.
copper naphthenate
2. a.
2.b.
3. a.
tank # 1
3.b.
tank # 2
3.c.
liquid formulation
tank # 3
3.d.
dry formulation tank
Batch or
Continuous
Volume
Generated
Generation
Frequency
Location:
Prepared by:
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management2
Comments
20 drums ofatrazine, 5 drums of
metolachlor, and 5 drums ofinerts
used each week.
5 drums of copper naphthenate and 5
drums of solvent used each week.
Stream type not generated at this
facility.
Stream type not generated at this
facility.
Herb. #J/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Herb. #l/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Herb. #l/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Dry process line, rinsed monthly after
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incrneration, DP=off-site disposal
Figure 4-1. Identifying Wastewater Stream Types and Sources
26
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
The "Stream Type" column lists potential wastewater stream types. An en-
try of "Other" is also provided at the end of Table A for facility-specific waste
stream types. It is most useful for the user and facility personnel to discuss
each stream type to decide whether it exists at the facility. After consider-
ation, if it is determined that a wastewater stream does not exist at the facil-
ity, the user can draw an "X" through the box in the "Stream Type" column.
Any pertinent information (e.g., stream type not generated at facility, opera-
tion not performed at facility) can be noted in the "Comments" column. In
the example shown in Figure 4-1, the facility does not have bulk tanks; there-
fore, bulk tank rinsate has been crossed off as a source.
If it is determined that the stream type does exist at the facility, the source of
each stream type can be noted in the "Sources" column. In the example in
Figure 4-1, it is noted in Box 3a that one source of wastewater from formulat-
ing equipment interior cleaning is a liquid formulation tank identified as
Tank #1. In the "Comments" column, the user has also provided details on.
the number of times the tank is used in production and some details on the
cleaning process.
Space is provided on Table A to include multiple sources of a single wastewater
stream type. For example, Figure 4-1 presents information on two types of
shipping container and drum rinsing operations that occur at the facility. If
the checklist or similar form is being used to demonstrate compliance with
the P2 alternative, the user should be as clear as possible when identifying
sources of wastewater stream types. If abbreviations, process line numbers,
production line codes, or other notations are used on the form to designate
sources, the user should ensure that supporting information (e.g., process
diagrams, process line names or products, and a key to the abbreviations) is
attached to the table.
The "Stream Type" and "Sources" columns can be initially completed in the
office prior to a plant tour by using prior knowledge of the facility and its
operations. The stream types and sources listed can then be refined through
discussions with facility personnel during a plant tour.
A
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 2: Collect Operations Data
Operations information (e.g., how a wastewater is generated) should be
weighed heavily when evaluating potential P2 opportunities. For example, if
a waste stream is only generated in small volumes one time per year at the
facility, then examining P2 practices for that waste stream may be a lower
priority than a waste stream that is generated every day. Figure 4-2 presents
an example of the types of information collected when completing Step 2.
The unshaded portions of columns "Batch or Continuous", "Volume Gen-
erated", and "Generation Frequency" illustrate this example.
For each stream type and source identified, enter operations data on Table A.
Indicate whether the waste stream is generated from a batch or continuous
process by entering either a "B" for batch or a "C" for continuous in the "Batch
or Continuous" column. Enter the volume (either batch volume or daily vol-
ume), including measurement units, generated in the "Volume Generated" col-
umn. Enter how often the wastewater is produced (e.g., once per day, once per
year) in the "Generation Frequency" column. For example, in Figure 4-2, the
user noted that the facility has a wastewater stream generated from a batch
cleaning process for 55-gallon drums that contained atrazine. Five gallons of
wastewater are generated per drum and 20 drums are cleaned weekly
The accuracy of the operations information may vary from source to source.
Many times, facility personnel may only have approximate waste stream vol-
umes available. Through continued use of the P2 audit, however, the waste
stream data should become more accurate, since operations data play an
important role in deciding the most cost-effective compliance strategy.
Record pertinent information regarding operations data in the "Comments"
column and, if necessary, attach to the form the key to any abbreviations or
notations.
Table A. Identification of Wastewater Sources
Table A
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
JxBulk Tank Rinsate - cleanup
oftne^terior of any bulksfdrage
tank contai-tamg raw nwttfrials,
intermediate oi^nd^or finished
products assof(atea^ith PFPR
operations \^
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaningdue to product
changeover, or special cleaning of
the interior of any formulating
e quipm ent, in c luding formulation
and/or storage tanks, pipes, and
include water, detergent, or
solvent.
Source
l.a.
atrazine,
metolachlor, and
inert drums
l.b.
copper naphthenate
and solvent drums
2.a.
2.b.
3. a.
liquid formulation
tank#l
3.b.
liquid formulation
tank #2
3.c.
liquid fa rmulatio n
tank #3
3.d.
dry formulation tank
Batch or
Continuous
B
B
B
B
B
B
Location:
Prepared by:
Volume
Generated
5 gal/ drum
5 gal/ drum
50 gal/run
50 gal/run
50 gal/run
100 gal
Generation
Frequency
30 drums
per week
10 drums
per week
1 run/week
2 runs/week
1 run/week
Monthly
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management2
Comments
20 drums of atrazine, 5 drums of
metolachlor, and 5 drums ofinerts
used each week.
5 drums of copper naphthenate and 5
drums of solvent used each week.
Stream type not generated at this
facility.
Stream type not generated at this
facility.
Herb. #J/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Herb. #l/#2: tank rinsed w/ water (TD)
Fungicide: tank rimed with solvent (RE),
then water (TD)
Herb. #l/#2: tank rimed w/ water (TD)
Fungicide: tank rimed with solvent (RE),
then water (TD)
Dry process line, rinsedmonthly after
sweeping.
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
Figure 4-2. Collecting Operations Data
28
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 3: Collect Waste Characterization Data
The quality and composition of the waste stream is directly related to the
potential P2, recycle, and reuse practices that may be implemented by the
facility Therefore, the next step of a P2 audit is to collect waste characteriza-
tion information (e.g., the constituents in the wastewater). This information
may also be useful when exploring wastewater treatment technologies, as
described in Chapter 5. As shown in Figure 4-3, the facility generates an
interior equipment cleaning rinsate containing carbaryl, listed in Box 3d, from
rinsing a dry formulation tank with water once per month. The facility is
unable to reuse this wastewater in the formulation because the product is
dry. However, they do sweep out the equipment prior to the water rinse to
minimize the presence of pesticide in the wastewater.
The user should try to identify waste characterization data for each stream
type and source identified on Table A. Enter the name or abbreviation for the
active ingredients present in the waste stream in the "Active Ingredients"
column. In some instances, the facility may use more active ingredients than
can be listed in the space provided. In those cases, the user can attach a sepa-
rate sheet listing additional active ingredients present in the waste stream.
Next, record the other constituents (e.g., solids, solvents, detergents, emulsifi-
ers) in the wastewater that may affect reuse or implementation of a P2 initia-
tive under the "Wastewater Matrix" column. Finally, enter wastewater
management and treatment information using the codes provided in the foot-
note in the "Wastewater Management" column. As shown in Figure 4-3, the
facility discharges the carbaryl wastewater to a POTW without pretreatment.
Again, record any pertinent information regarding operations data in the
"Comments" column and attach the key to any abbreviations or notations
used on the table. The "Comments" column may also be used to note any
unique aspects in the generation or handling of each source, including mul-
tiple discharge practices for the same source.
Table A. Identification of Wastewater Sources
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
i\Bulk Tank Rinsate - cleaning^
of thfaqterior of any bulk stpmge
tank containing raw mqftfials,
intermediate ^bt&whf'or finished
products assoft&et^iith PFPR
operation?? \^
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
atrazine,
metolachlor, and
inert drums
l.b.
copper naphthenate
and solvent drums
2. a.
2.b.
3. a.
liq uidform ulation
tank # 1
3.b.
liquid formulation
tank #2
3.c.
liq uidform ulation
tank # 3
3.d.
dry formulation tank
Batch or
Continuous
B
B
B
B
B
B
Volume
Generated
5 gal/drum
5 gal/drum
50 gal/run
50 gal/run
50 gal/run
100 gal
Generation
Frequency
25 drums
per week
10 drums
per week
1 run/week
2 runs/week
1 run/week
Monthly
Location:
Prepared by:
Active
Ingredients
atrazine,
metolachlor
copper
naphthenate
~:,:ri'
copper niphttenate
~:,:ri'
carbaryl
Wastewa er
Matr x1
water, nerts
water,
solvent
solvent,
wate
inert
solve
wate
inert
solve
water,
inerts
water, solids
Wastewater
Management2
RE
DI
RE, TD
RE, TD
RE, TD
DI
Comments
20 drums of atrazine, 5 drums of
metolachlor, and 5 drums of inerts
used each week
5 drums of copper naphthenate and 5
drums of solvent used each week
Stream type not generated at this
facility.
Stream type not generated at this
facility.
Herb. #J/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Herb. #l/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Herb. #J/#2: tank rinsed w/ water (TD)
Fungicide: tank rinsed with solvent (RE),
then water (TD)
Dry process line, rinsed monthly after
sweeping.
Table A
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
Figure 4-3. Collecting Waste Characterization Data
29
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
B: of P2,
Practices
Table B of the P2 audit is used to evaluate the P2, recycle, and reuse practices
in place at the facility and to consider the feasibility of implementing addi-
tional P2, recycle, and reuse practices at the facility. Each facility subject to
the final PFPR rule will have three options in choosing how to comply with
the regulation: (1) comply with the zero discharge effluent limitatioii/pre-
treatment standard, (2) incorporate the P2 practices listed in Table 8 of the
final rule with wastewater treatment when necessary, or, (3) if the facility has
an approved justification, incorporate the P2 practices with modifications
and wastewater treatment when .necessary. The column "Table 8 Listed Prac-
tice" lists the P2, recycle, and reuse practices found in the final rule (see Ap-
pendix A). A facility that wishes to discharge wastewater must incorporate
these P2, recycle, and reuse practices into their process. The column entitled
"Practice" describes recycle and reuse practices that are demonstrated in the
PFPR industry These practices include P2, recycle, and reuse practices from
Table 8 of the final regulation and other recycle and reuse practices that PFPR
facilities can choose to incorporate. The "Comments" column should be used
to note any unique circumstances surrounding the facility-specific applica-
tion of a particular P2 practice.
It is helpful if the person(s) conducting the P2 audit and completing Table B
reads and understands the instructions for the intended use of Table B, and is
familiar with the available P2 equipment and practices presented in Chapter
3. Table B will not only aid in deciding whether to choose the P2 alternative
and in documenting current practices at the facility, but will also be a guide to
implementing successful P2 practices. Four steps that can be used to com-
plete Table B are detailed below.
1
30
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 1: Identify Practices Reported by Facility
Figure 4-4 presents an example of the types of information recorded when
completing Step 1. Page 3 of Table B is shown so that the P2 practices match
the source codes from Page 1 of Table A (shown in Figures 4-1 through 4-3).
The unshaded columns "Practice," "Does Facility Use This Practice?," and
"Source Code from Table A" illustrate this example.
The "Table 8 Listed Practice" column cross-references the practices listed in
Table B with the corresponding practices listed in Table 8 of the final regula-
tion. If there is no corresponding practice in the final regulation, "NA" ap-
pears in the "Table 8 Listed Practice" column. The P2, recycle, and reuse
practices listed in the "Practice" column in Table B should be discussed with
plant personnel to identify if they are utilized by the facility. For each P2
practice the facility uses, note which facility operation implements the prac-
tice by transferring the source code from Table A into the "Source Code"
column. In the "Does Facility Use this Practice?" column, answer "Yes" or
"No."
Table B
Table B. Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
7. D
7-1
8. Tn
8-1
8-2
8-3
Table 8
Listed
Practice1
clicatecl Eq
9
terior Rins
10
4
4
Practice
pment for Solvent- and Water-Based P
Facility dedicates PFPR production
quipmentto water-based vs. solvent-
lased products. Dedicated solvent-based
non-routine basis for non-dedicated
operations, but facility may not discharge
le aqueous changeover rinsate as part of
leir P2 allowable discharge.
e Storage and Reuse
Interior rinsate is stored for reuse in
uture formulations of the same or
ompatible product (note: does not
)ry carrier material is stored and reused
n future formulation of the same or
ompatible product or disposed of as
olid waste.
Interiors of dry formulation equipment
are cleaned with dry carrier prior to water
Does
Facility
Use this
Practice?
roducts
No
Yes
No
Yes
No
Source Code
from
Table A
1,3,4
3
3
3
3.d
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Practice in the
Future?
Required
Justification for
Modification2
_
40CFR455.67
Figure 4-4. Identifying P2 Practices
31
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 2: Identify Practices In Use
During the plant tour, note in the column entitled "Extent of Use of this
Practice Observed During Audit" the locations and operations where each
practice has been implemented. Figure 4-5 presents an example of the types
of information a user may note while touring a facility. If a particular practice
is not used (such as low-volume/high-pressure rinsing equipment or other
flow reduction devices), answer "NA" in the "Extent of Use of this Practice
Observed During Audit" column.
Table B
Table R Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
7. D
7-1
8. In
8-1
8-2
8-3
Table 8
Listed
Practice1
clicatecl Eq
9
erior Rinsa
10
4
4
Practice
lipment for Solvent- and Water-Based P
Facility dedicates PFPR production
equipment to water -based vs. solvent-
based products. Dedicated solvent-based
or water-based equipment may be used on
a non-routine basis for non-dedicated
operations, but facility may not discharge
the aqueous changeover rinsate as part of
their P2 allowable discharge.
te Storage and Reuse
Interior rinsate is stored for reuse in
future formulations of the same or
compatible product (note: does not
include drum/shipping container rinsate).
Dry carrier material is stored and reused
in future formulation of the same or
compatible product or disposed of as
solid waste.
are cleaned with dry carrier prior to water
Does
Facility
Use this
Practice?
roducts
No
Yes
No
Yes
No
Source Code
from
Table A
1,3,4
3
3
3
3.d.
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
NA
Fungicide formulation tank
solvent rinsate is stored for
reuse.
NA
Dry material is reused in
product.
NA
Could Facility
Practice in the
Future?
Required
Justification for
Modification2
„
1 40 CFR 455.67
2 Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
Figure 4-5. Identifying Use of P2 Practices
32
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 3: Identify Practices That Could Be Implemented
In The Future
During the plant tour, identify locations and operations where each practice
could be implemented. Indicate "Yes" or "No" for each practice in the col-
umn entitled "Could Facility Implement this Practice in the Future?" If a
particular practice is already in use at the facility, answer "NA" in this col-
umn. A facility may choose to implement a modification to a P2 practice
listed in Table 8 of the final rule. In this case, the facility must write in the
"Required Justification for Modification" column the appropriate code for
the modification from Footnote 2. The list of codes and their explanations
appears at the end of Table B. Use the "OTHER" code if the modification is
not one that is listed in the final rule and describe the modification in the
"Comments" column. Note that if the selected modification is not listed in
the final rule, a facility must submit a request to the control authority or per-
mitting authority for the modification and have it approved prior to imple-
menting the modification. Figure 4-6 presents an example of the types of
information recorded when completing Step 3.
Table B
Table R Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
7. Df
7-1
8. In
8-1
8-2
8-3
Table 8
Listed
Practice1
dicated Eoi
9
erior Rinsa
10
4
4
Practice
ioment for Solvent- and Water-Based P
Facility dedicates PFPR production
equipment to water-based vs. solvent-
aased products. Dedicated solvent -based
or water-based equipment may be used on
a non-routine basis for non-dedicated
operations, but facility may not discharge
the aqueous changeover rinsate as part of
their P2 allowable discharge.
e Storase and Reuse
Interior rinsate is stored for reuse in
future formulations of the same or
compatible product (note: does not
include drum/ shipping container rinsate).
Dry carrier material is stored and reused
in future formulation of the same or
compatible product or disposed of as
solid waste.
Interiors of dry formulation equipment
are cleaned with dry carrier prior to water
rinse.
Does
Facility
Use this
Practice?
roducts
No
Yes
No
Yes
No
Source Code
from
Table A
1,3,4
3
3
3
3.d
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
NA
Fungicide formulation tank
solvent rinsate is stored for
reuse.
NA
Dry material is reused in
product.
NA
Could Facility
Implement this
Practice in the
Future?
Yes
NA
No
NA
No
Required
Justification for
Modification2
BIOGROWTH
Comments
Facility could dedicate one of the tanks
to solvent-based products.
Solvent-based fungicide
For the water-based herbicides, facility
has demonstrated evidence of
biological growth over a typical
1 40 CFR455.67
2 Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
Figure 4-6. Identifying Future Use of P2 Practices
33
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 4: Identify Information for the "Comments" Column
For each practice listed on Table B, additional information may be collected
by the user to further evaluate implementing P2 at the facility.
Information for the Comments Column
Suggest practice-specific implementation and compliance demonstration
methodologies;
Differentiate between similar practices within the same general heading
(such as under "Reuse of Drum Rinsate") in place at the facility;
Discuss modification justifications; and
Provide additional information for specific practices.
Table B
The following instructions contain suggested ways to use Table B, special items
or information that can be sought out by the user, and important follow-up
ideas, such as review of facility documentation. Where a P2 term has been de-
fined and/or described in Chapter 3, the term is in italicized bold print.
1. Water Conservation
Examine how all rinsing operations are conducted at the facility, and determine
whether the facility is taking any measures to minimize rinse-water flow.
• 1-1: Interior Equipment Rinsing—Note the use of spray nozzles or other
flow reduction equipment (high-pressure/loiv-volume washers, spray balls,
or steam cleaners) that are used to rinse PFPR equipment interiors. Iden-
tify and note cases in which the facility would not be able to reuse rinsate,
and if the facility has a wastewater treatment system that can treat small-
volume interior rinsate discharges.
PZ Alternative Compliance
A modification to this practice is allowed if the facility is rinsing narrow transfer
lines or piping where cleaning is better achieved by a water flush.
1-2: Floor Cleaning—Identify the facility's floor-washing procedures (e.g.,
if a floor scrubber is used) and identify and record the chemicals used to
clean floors (e.g., water, detergent) in the "Comments" column.
1-3: Dry Process Cleaning Equipment—Identify how dry production ar-
eas are cleaned. In particular, note the type of dry process cleaning equip-
ment used, whether the production areas are swept or vacuumed prior to
rinsing with water, or if the dry production areas are cleaned with water
at all.
34
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
2. Good Housekeeping Practices
Identify and record all preventive maintenance, leak control, spill cleanup,
and other good housekeeping practices used at the facility.
• 2-1: Preventive Maintenance—Identify if the facility has written proce-
dures regarding the maintenance schedule for each major valve and fit-
ting, and whether they have documented the performance of the
maintenance checks.
Table B
• 2-2: Valves/Fittings—Identify if valves and leaky fittings have some form
of containment (e.g., drip pans) to enable the reuse or disposal of collected
product or wastewater.
2-3: Spill Cleanup—Identify if the facility has prepared training and writ-
ten standard operating procedures for cleanup of leaks and spills, and if
the facility has records demonstrating quick cleanup of actual leaks and
spills in outdoor bulk storage or process areas.
PZ Alternative Compliance
All records documenting training programs and preventive maintenance
schedules should be attached to the completed P2 audit form.
3. Department of Transportation (DOT) Test Bath
If the facility produces aerosols that require the operation of DOT test baths,
identify how the bath is operated. Note in the "Comments" column if the
DOT test bath is operated as batch discharge. If the DOT test bath is operated
in a continuous overflow mode, identify and note if the facility recirculates
water back to the bath.
4. Air Pollution Controls
Identify if wet air scrubbers are operated with recirculation. Note the percent
blowdown of the system in the "Comments" column.
5. Reuse of Drum Rinsate of Water-Based Products
Identify how empty drums or shipping containers are cleaned and handled
at the facility. Note the ultimate disposal of the drums in the "Comments"
column.
• 5-1: Direct Reuse of Drum Rinsate—Note if the facility has implemented
direct reuse of drum rinsate into product formulations from the triple rins-
ing of drums.
• 5-2: Storage and Reuse of Drum Rinsate—Note if the facility collected drum
and/or shipping container rinsate for reuse in subsequent formulations.
35
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
PZ Alternative Compliance
A modification to practices 5-1 and 5-2 is allowed if the facility is using a staged
drum rinsing station that minimizes wastewater volume required for drum
cleaning (typically 100 gallons for every 70 drums).
A modification is also allowed in a case where the drum/shipping container
holds an inert ingredient(s) only, and 1) the facility can demonstrate that, even
after using water conservation practices, there is more volume of water
generated from rinsing the drums than can be reused in the formulation, or 2)
the facility can demonstrate that the concentration of the inert ingredient in the
formulation is so small (e.g., perfume) that the amount of inert ingredient in the
rinsate is more than can be reused in the formulation without exceeding the
ranges allowed in the Confidential Statement of Formula (CSF) (40 CFR 158.155).
Note whether the facility reused as much rinsate as possible and whether the
documentation on the formulation ingredients substantiates this modification.
Table B
• 5-3: Staged Drum Rinsing Station—If the facility is using a staged drum
rinsing station, briefly describe the system, including the amount of water
contained in each cell and the frequency with which the water is changed.
The facility may use more than one drum rinsate P2 practice; discuss these
practices in the "Comments" column.
6. Drum Rinsing for Formulation of Solvent-Based Products
This practice is similar to the practices detailed in Section 5 above, but it ap-
plies to the rinsing of drums or shipping containers containing solvents or
solvent-based materials. Note the ultimate disposal of the drums or shipping
containers in the "Comments" column.
• 6-1: Direct Reuse of Drum Solvent Rinsate—Note if the facility has
implemented direct reuse of drum rinsate into solvent-based product
formulations.
PZ Alternative Compliance
A modification to these practices is allowed if the facility sends the drums and/or
shipping containers to a refurbisher or recycler that only accepts drums triple
rinsed with water. Note whether the facility has documentation from the drum
recycler to substantiate this modification.
A modification is also allowed in a case where the drum/shipping container
holds an inert ingredient(s) only, and 1) the facility can demonstrate that, even
after using water conservation practices, there is more volume of base solvent
generated from rinsing the drums than can be reused in the formulation, or 2)
the facility can demonstrate that the concentration of the inert ingredient in the
formulation is so small (e.g., perfume) that the amount of inert ingredient in the
rinsate is more than can be reused in the formulation without exceeding the
ranges allowed in the Confidential Statement of Formula (CSF) (40 CFR 158.155).
Note whether the facility reused as much rinsate as possible and whether the
documentation on the formulation ingredients substantiates this modification.
36
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
• 6-2: Cleaning Material—Note the material used to clean the drums and if
the material is the base solvent in one of the facility's formulations.
• 6-3: Storage and Reuse of Drum Solvent Rinsate—Note if the facility
collected drum solvent rinsate for reuse in subsequent formulations.
It is possible that the facility uses several different drum rinsate practices.
Note each of these practices in the "Comments" column.
Table B
7. Dedicated Equipment for Solvent- and Water-Based Products
Determine if water-based and solvent-based products are formulated and
packaged using process equipment dedicated by water-based and solvent-
based production.
PZ Alternative Compliance
A modification to this practice is allowed if the product is only sporadically
produced, such that the expense of dedicated equipment outweighs the P2
benefit. The facility should be able to demonstrate sporadic production through
the use of production records. Note in the "Comments" column whether the
documentation supports any claims of sporadic production. Another
modification to this practice is allowed if the facility has installed and is
operating a solvent recovery system.
8. Interior Rinsate Storage and Reuse
Identify if the facility uses interior rinsate storage and reuse, specifically not-
ing if the rinsate is reused immediately in the next batch or is reused after
being stored while other products are formulated and packaged.
PZ Alternative Compliance
Several modifications to the practice of storing and reusing interior rinsate are
listed by code in Footnote 2 on Table B. List all reasons why the facility would
not be able to reuse interior rinsate, and obtain documentation supporting these
claims. Examples of this documentation include data demonstrating biological
growth in stored rinsate, site plans illustrating space limitations precluding
storage containers, manufacturer or original formulator directions requiring a
specific form of disposal, or facility plans to drop the registration or production
of a particular formulation. Document other reasons in the "Comments"
column.
9. Dedicated Process Equipment (non-Table 8 practice)
If the facility is unable to reuse all interior rinsate (as identified by the user in
Section 8 of the "Practices" column), indicate if the facility has used dedica-
tion of process equipment and production scheduling practices.
• 9-1: Equipment Dedication—Identify if the facility has dedicated some
equipment (e.g., mix tank or agitator) to (1) the top production formula-
tion, (2) products that are hard to clean up after production, or (3) product
families. Identify and record in the "Comments" column what pieces of
process equipment are dedicated.
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CHAPTER 4 Conducting the P2 Audit
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• 9-2: Production Sequencing—Review production records to identify
whether production sequencing is implemented and whether it reduces or
eliminates the generation of equipment cleaning rinsates.
10. (non-Table 8
Inventory management systems for raw materials, finished products, and
waste products typically include centralized sheltered storage, access con-
trols (e.g., locked storage areas), and, in some cases, computerized inventory
control. These systems increase wastewater reuse opportunities. Most, if not
all, PFPR facilities have some degree of inventory management, although the
increased use of "just-in-time" production may have decreased the need for
inventory management at some facilities. However, an inventory manage-
ment system is a key to using the P2 practice of interior rinsate storage and
reuse.
B
10-1: Inventory Management System-
ment system is in place at the facility.
-Identify if an inventory manage-
• 10-2: System Control—Identify which of the system controls listed in Sec-
tion 10 of the "Practices" column are in place at the facility, and how these
controls have benefited P2 at the facility. Also identify potential applica-
tions of inventory management to facilitate additional wastewater reuse.
II. Training Written (non-
Table 8
Employee training and written standard operating procedures and incentive
programs have been shown to be useful tools in identifying and implement-
ing P2 opportunities.
• 11-1: Training—Identify if the facility has a formal P2 training program.
The facility should be able to provide training materials and records of
attendance to document that the program is operational.
• 11-2: Incentive Program—Identify if the facility has employee incentive
programs in place that encourage P2.
» 11-3: Implementation of P2—Note if the facility has documentation of the
implementation of the P2 practices summarized on Table B.
12. P2
List and describe innovative or otherwise unique P2 techniques in the "Com-
ments" column when these practices are not claimed as confidential. When
the user is a permitting official or a facility with multiple locations, provide
enough detail to determine if these practices could be used by other PFPR
facilities.
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CHAPTER 4 Conducting the P2 Audit
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Table C: Summary of PFPR Compliance Decisions
After completing Tables A and B, the user has the information necessary to make
a preliminary compliance decision for each waste stream identified in Table A.
The compliance options include zero discharge, P2 alternative, and P2 alterna-
tive with modification. Wastewater that is completely reused or recycled on or
off site or is contract hauled for off-site disposal is considered zero discharge.1
Waste streams that will be discharged to a POTW or receiving stream must com-
ply with either the P2 alternative or the P2 alternative with modification.
The user should copy all of the sources for all stream types from Table A to
Table C ("Source" column). Based on the information in Table A, the user can
make the preliminary decision on whether the source is zero discharge. If the
source is not zero discharge, then the user should evaluate the information in
Table B to decide whether the P2 alternative can be implemented, with or
without modification. In the column entitled "Preliminary Compliance De-
cision", write "P2 alternative", "P2 alternative with mod", or "Zero dis-
charge."1 If "P2 alternative with mod" is selected, write the applicable
modification code in the "Comments" column. Figure 4-7 presents an ex-
ample of the preliminary compliance decisions for the example sources pre-
sented previously in Table A.
Table C
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
Sv^Bulk Tank Rinsate - cleaning
ofme^interior of any bulk storage
tank containing raw materials,
intermediatem$ji
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CHAPTEE 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry
If the preliminary compliance decision is zero discharge for all waste streams
at the facility, and the facility is not interested in implementing the P2 alterna-
tive, the user can skip to Chapter 7 for the discussion on compliance paper-
work. If the facility decides to implement the P2 alternative or P2 alternative
with modification for any of its waste streams, the user should continue to
Chapters 5 and 6 to evaluate treatment technologies appropriate for the al-
lowable discharge. The remaining columns are discussed in Chapters 6 and
7, as facilities should assess their need for treatment and the associated costs
prior to making their final compliance decision.
40
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CHAPTER 5
Wastewater Treatment Technologies
Wastewater treatment technologies are used by PFPR facilities to re-
move or destroy pesticide active ingredients and other pollutants
in facility Wastewater. The treated effluent may be reused in PFPR
operations or may be discharged to a receiving stream or treatment facility
(such as a publicly owned treatment works (POTW)). This chapter describes
five cost-effective technologies that remove or destroy pesticide active ingre-
dients and priority pollutants, and references other technologies that also
effectively treat PFPR wastewaters. A list of documents that contain more de-
tailed information on these technologies is included at the end of this chapter.
The technologies presented in this chapter have been identified through sam-
pling visits to PFPR and pesticide manufacturing facilities and through EPA-
sponsored treatability tests. The implementation of these, or equivalent,
technologies has allowed PFPR facilities to reuse a greater percentage of waste-
water in their operations without risking the quality of their final products.
Additionally, by implementing these technologies, these facilities are able to
discharge effluents that might otherwise require disposal.
Pretreatment Technologies
Emulsion Breaking
Many pesticide products are formulated by mixing pesticide active ingredi-
ents with inert materials (e.g., surfactants, emulsifiers, petroleum hydrocar-
bons) to achieve specific application characteristics. When these "inerts" mix
with water, emulsions may form. These emulsions reduce the performance
efficiency of many treatment unit operations, such as chemical oxidation and
activated carbon adsorption. In many situations, emulsion breaking is a nec-
essary pretreatment step to facilitate the removal of pollutants from PFPR
wastewaters. Although emulsion breaking is a pre-
treatment step, its importance in the treatment of PFPR
wastewaters can make it a major part of the technol-
ogy train for treating PFPR wastewaters.
Facilities can break these emulsions through several
methods. Temperature control and acid addition are
common in the PFPR industry and are discussed in
more detail below. Other methods of emulsion break-
ing, such as chemically assisted clarification, are not
Types of Emulsions
O/W Emulsion - a hydrophobic solvent, such
as oil, dispersed in an aqueous medium
W/O Emulsion - an aqueous medium
dispersed in a hydrophobic solvent, such as
oil.
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CHAPTER 5 Wastewater Treatment Technologies
Pollution Prevention Guidance Manual for the PFPR Industry
discussed in this manual. Additional information on these methods may be
found in the Final PFPR Technical Development Document (EPA 821-R-96-
019).
Temperature control and acid addition are simple, inexpensive methods of
breaking emulsions in a variety of PFPR wastewaters. Acid (e.g., sulfuric acid)
added to emulsified wastewater dissolves the solid materials that hold the
emulsions together. The demulsified oil floats because of its lower specific
gravity and can be skimmed off the surface, leaving the wastewater ready for
subsequent treatment. The demulsification also causes suspended solids with
a higher specific gravity to settle out of the wastewater. Heating the emulsion
lowers the viscosities of the oil and water and increases their apparent spe-
cific gravity differential. The oil, with a significantly lower apparent specific
gravity, rises to the surface of the wastewater. Heating the wastewater also
increases the kinetic energy of the individual molecules in the wastewater,
causing the molecules to collide with each other more frequently. The increased
number of molecule collisions aids in breaking the film present between the
oil and the water. Once freed from the water, the oil rises, where it can be
skimmed from the surface of the wastewater. Emulsion breaking on PFPR
wastewater has been effective in EPA-sponsored treatability tests when con-
ducted at pH 2 and 60°C.
Other Pretreatment Technologies
In addition to emulsion breaking, a variety of other technologies effectively
pretreat PFPR wastewater, including membrane filtration (ultrafiltration),
chemically assisted clarification, and settling. Although these technologies
are not discussed here, additional information on the treatment tests con-
ducted by EPA using these technologies can be found in the Final PFPR Tech-
nical Development Document (EPA 821-R-96-019) and in the administrative
record supporting the final PFPR rulemaking.
Treatment Technologies
Activated Carbon Adsorption
Activated carbon effectively removes organic constituents from wastewater
through the process of adsorption. The term "activated carbon" refers to car-
bon materials, such as coal or wood, that are processed through dehydration,
carbonization, and oxidation to yield a material that is highly adsorbent due
to a large surface area and high number of internal pores per unit mass. As
wastewater flows through a bed of carbon materials, molecules that are dis-
solved in the water may become trapped in these pores.
In general, organic constituents (including many pesticide active ingredients)
with certain chemical structures (such as aromatic functional groups), high
molecular weights, and low water solubilities are amenable to activated car-
bon adsorption. These constituents adhere to the stationary carbon material,
so the wastewater leaving the carbon bed has a lower concentration of pesti-
cide than the wastewater entering the carbon bed. Eventually, as the pore
spaces in the carbon become filled, the carbon becomes exhausted and ceases
42
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CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry
to adsorb contaminants. Spent carbon may be regenerated or disposed of; the
choice is generally determined by cost and/or other regulatory factors (e.g.,
RCRA).
Carbon adsorption depends on process conditions such as temperature and
pH and process design factors such as carbon/wastewater contact time and
the number of the carbon columns. If performed under the right conditions,
activated carbon adsorption can be an effective treatment technology for PFPR
industry wastewaters. Carbon adsorption capacity depends on the charac-
teristics of the adsorbed compounds, the types of compounds competing for
adsorption, and characteristics of the carbon itself. If several constituents that
are amenable to activated carbon adsorption are present in the wastewater,
they may compete with each other for carbon adsorption capacity. This com-
petition may result in low adsorption or even desorption of some constitu-
ents.
Activated carbon comes in two sizes: powdered carbon has a diameter of less
than 200 mesh, while granular carbon has a diameter greater than 0.1 milli-
meter. Granular carbon is more commonly used in wastewater treatment;
powdered carbon is used less frequently because the small particle size cre-
ates regeneration and design problems. Activated carbon is obtained from
vendors in bulk or in a variety of container sizes. At smaller facilities, the
container in which the carbon is sold is intended to be used as the carbon bed,
with influent wastewater passing into one end of the container and treated
effluent water passing out of the opposite end. At larger facilities, carbon is
purchased and added to a column that is installed at the facility.
Carbon is regenerated by removing the adsorbed organic compounds through
steam, thermal, or physical/chemical methods. Thermal and steam regen-
eration are the most common methods to regenerate carbon used for waste-
water treatment. These methods volatilize the organic compounds that have
adsorbed onto the carbon. Afterburners are required to ensure destruction of
the organic vapors; a scrubber may also be necessary to remove particulates
from the air stream. Physical/chemical regeneration uses a solvent, which
can be a water solution, to remove the organic compounds. Carbon is usually
shipped back to the vendor for regeneration, although some facilities with
larger carbon beds may find it economical to regenerate carbon on site.
Chemical Oxidation
Chemical oxidation modifies the structure of pollutants in wastewater to simi-
lar, but less harmful, compounds through the addition of an oxidizing agent.
During chemical oxidation, one or more electrons transfer from the oxidant
to the targeted pollutant, causing its destruction.
One common method of chemical oxidation, referred to as alkaline
chlorination, uses chlorine (usually in the form of sodium hypochlorite) under
alkaline conditions to destroy pollutants such as cyanide and some pesticide
active ingredients. However, facilities treating wastewater using alkaline
chlorination should be aware that the chemical oxidation reaction may
generate toxic chlorinated organic compounds, including chloroform,
bromodichloromethane, and dibromochloromethane, as byproducts.
43
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CHAPTER 5 Wastewater Treatment Technologies
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Adjustments to the design and operating parameters may alleviate this
problem, or an additional treatment step (e.g., steam stripping, air stripping,
or activated carbon adsorption) may be required to remove these byproducts.
Chemical oxidation can also be performed with other oxidants (e.g., hydro-
gen peroxide, ozone, and potassium permanganate) or with the use of ultra-
violet light. Although these other methods of chemical oxidation can effectively
treat PFPR wastewaters, they typically entail higher capital and/or operat-
ing and maintenance costs, greater operator expertise, and/or more exten-
sive wastewater pretreatment than alkaline chlorination. Additional
information about these other methods can be found in the Final PFPR Tech-
nical Development Document (EPA 821-R-96-019).
Chemical Precipitation
Chemical precipitation is a treatment technology in which chemicals (e.g.,
sulfides, hydroxides, and carbonates) react with organic and inorganic pol-
lutants present in wastewater to form insoluble precipitates. This separation
treatment technology is generally carried out in the following four phases:
1. Addition of the chemical to the wastewater;
2. Rapid (flash) mixing to distribute the chemical homogeneously through-
out the wastewater;
3. Slow mixing to encourage flocculation (formation of the insoluble solid
precipitate); and
4. Filtration, settling, or decanting to remove the flocculated solid particles.
These four steps can be performed at ambient conditions and are well suited
to automatic control.
Hydrogen sulfide or soluble sulfide salts (e.g., sodium sulfate) are chemicals
commonly used in the PFPR industry during chemical precipitation. These
sulfides are particularly effective in removing complexed metals and heavy
metals (e.g., mercury, lead, and silver) from industrial wastewaters. Hydrox-
ide and carbonate precipitation can also be used to remove metals from PFPR
wastewaters, but these technologies tend to be effective on a narrower range
of contaminants.
Hydrolysis
Hydrolysis is a chemical reaction in which organic constituents react with
water and break into smaller (and less toxic) compounds. Basically, hydroly-
sis is a destructive technology in which the original molecule forms two or
more new molecules. In some cases, the reaction continues and other prod-
ucts are formed. Because some pesticide active ingredients react through this
mechanism, hydrolysis can be an effective treatment technology for PFPR
wastewater.
The primary design parameter considered for hydrolysis is the half-life, which
is the time required to react 50% of the original compound. The half-life of a
reaction generally depends on the reaction pH and temperature and
the reactant molecule (e.g., the pesticide active ingredient). Hydrolysis reac-
OH
44
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CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry
tions can be catalyzed at low pH, high pH, or both, depending on the reac-
tant molecule. In general, increasing the temperature increases the rate of
hydrolysis.
Identifying the best conditions for the hydrolysis reaction results in a shorter
half-life, thereby reducing both the size of the reaction vessel required and
the treatment time required. A more thorough discussion of hydrolysis of
pesticide active ingredients can be found in the Final Pesticides Formulators,
Packagers, and Repackagers Treatability Database Report (DCN F7185) or the
Final Pesticide Manufacturing Technical Development Document (EPA-821-
R-93-016 or DCN F6442).
In addition to the technologies listed above, a variety of other technologies
effectively treat PFPR wastewater, including reverse osmosis and ultraviolet
light assisted ozonation. Although these technologies are not discussed here,
additional information on the treatment tests conducted by EPA can be found
in the Final PFPR Technical Development Document (EPA 821-R-96-019) and
in the administrative record supporting the final PFPR rulemaking.
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CHAPTER 5 Wastewater Treatment Technologies
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Additional Treatability Documents (available through EPA's Office of Water)
General References
Development Document for Best Available Technology, Pretreatment Technology,
and New Source Performance Technology for the Pesticide Formulating,
Packaging, and Repackaging Industry—Final, EPA 821-R-96-019, September
1996
Development Document for Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance Standards for the Pesticide
Chemicals Manufacturing Point Source Category, EPA 821-R-93-016,
September 1993 (DCN F6442)
Final Pesticides Formulators, Packagers, and Repacl
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CHAPTER 6
Conducting the Treatability Test
The final PFPR rule allows facilities the choice of achieving zero discharge or
complying with the P2 alternative. Zero discharge can be achieved through
reuse, off-site disposal of wastewater, or discharge of treated wastewater with
pesticide active ingredients at levels below detection.1 The P2 alternative al-
lows PFPR facilities to discharge their wastewater after implementing listed
P2 practices and, in some cases, wastewater treatment. Facilities that treat
wastewater to comply with the P2 alternative or to reuse their wastewater
must use a technology that provides effective wastewater treatment.
Chapter 4 describes how facilities can use the P2 audit to
identify wastewater sources and applicable P2 practices,
and make an initial compliance decision for each waste-
water source. Chapter 5 describes the most cost-effective
wastewater treatment technologies that are demonstrated
to reduce the pesticide active ingredients present in PFPR
Treatability Test Components
• Identification of Wastewater Sources and
Treatment Technologies;
• Preparing the Test Plan; and
wastewater. Chapter 6 describes the three components ., ,,. , ,. ,T ,_ ,,
n .n. r n . n . n f .-,. . • Summary and Evaluation of Test Results.
of a treatability test and provides guidance to facilities
on selecting and testing appropriate wastewater treat-
ment technologies to determine if they are effective for a
facility's specific wastewater streams.
The first component of a treatability test is identifying the wastewater streams
that remain after implementation of the P2 practices and require treatment
prior to discharge. As discussed in Chapter 4, the facility can use the results
of the P2 audit as documented on Table C to identify the sources that will be
zero discharge or that will comply with the P2 alternative. As part of this first
component, the facility also needs to identify the wastewater technologies
appropriate to treat the constituents present in the waste streams requiring
treatment (including characteristics that may hinder treatment of the waste
streams), and then construct potential treatment trains. Table D, which is
described later in this chapter, can be used by facilities to identify the sources
that require treatment under the P2 alternative, the constituents in those
wastewater sources, and appropriate treatment technology(ies).
Based on this information, the facility can decide whether a treatability test is
necessary. A treatability test may be used by a facility to determine whether a
particular technology can treat the wastewater, identify analytical or design
1 If a facility chooses to meet zero discharge through discharge of wastewater with pesticide active
ingredients below detection, all pesticide active ingredients that are formulated, packaged, or repack-
aged at the facility must have analytical methods for use in wastewater.
47
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
and operating parameters to act as surrogates for pesticide active ingredient
analyses, comply with permitting requirements, or optimize treatment per-
formance.
If a test is warranted, the second component is preparing the test plan. The
facility's first step in writing a test plan is determining the size and scope of
the test and the sequence of treatment steps. The test plan also specifies the
written procedures of how to conduct the test, discusses the design and oper-
ating parameters to be evaluated for the specific treatment technologies, de-
termines the equipment and chemicals necessary to conduct the test, and
describes the samples to be collected and analyzed (including a discussion of
the quality assurance/quality control procedures).
The final component is evaluating the test results, which consists of calculat-
ing performance measures, comparing technology results, and evaluating the
cost-effectiveness of the individual treatment technologies.
The guidance presented in this chapter for conducting a wastewater
treatability test is based on EPA's procedures used during the development of
the PFPR effluent limitations guidelines and standards. The treatability test
tables discussed in this chapter (Tables D and E) are offered as one way to
conduct the test and/or document the test results. It is not required that fa-
cilities, permitters, or other auditors use Tables D and E; however, these tables
summarize the types of information that are useful in conducting a treatability
test. Since it is very difficult to construct one table or checklist with a format
useful for all PFPR facilities, EPA considers the tables presented in this manual
as a tool to be adapted in whatever way the user feels is appropriate. Ex-
ample pages of the treatability test tables are shown throughout this chapter
to illustrate the types of information captured on the tables. The blank tables
are presented in their entirety in Appendix B.
Treatability Test Tables
Table Title
Table D Identification of Wastewater Sources
and Technologies
Table E Summary and Evaluation of Test Results
Purpose
Helps users list wastewater sources requiring
treatment, the potential constituents, and the
appropriate treatment technologies.
Helps users summarize and evaluate the test
results for each technology and the final
treatment train.
Table D: Identification of Wastewater Sources and
Treatment Technologies
Before a treatability test is undertaken, the facility should identify the waste-
water sources that require treatment. These sources may include wastewater
to be reused in PFPR operations or wastewater to be discharged under the P2
alternative. Table D is the starting point for identifying these sources and the
potential treatment technologies to effectively treat them. Completing this
table will enable facility personnel to begin identifying the wastewater sources
Table D
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CHAPTER 6 Conducting Treatability Test
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Wastewater Sources Requiring Treatment Prior to a PZ Allowable Discharge
Direct Discharge
• All process wastewater.
Indirect Discharge1
• Interior equipment rinsate, including drum, bulk tank, and shipping container
rinsate;
• Leak and spill cleanup water; and
• Floor wash water.
In individual cases, the requirement of wastewater pretreatment prior to indirect discharge may
be removed for floor wash or the final rinse of non-reusable triple rinse by the control authority
when pollutant levels are too low to be effectively pretreated and those pollutants do not pass
through or interfere with POTW operations.
Table D
to include and potential treatment technologies to evaluate in a treatability
test. Five steps that can be used to complete Table D and decide whether to
conduct a treatability test are detailed below.
Step 1: Identify Wastewater Sources
The user should transfer from Table C to Table D all wastewater sources that
will potentially require treatment, prior to either reuse or discharge. In addi-
tion, the user should transfer from Table A to Table D a list of the pesticide
active ingredients or other constituents present in those wastewater sources.
Figure 6-1 presents an example of the types of information transferred while
completing this step. The unshaded columns "Stream Type", "Source", and
"Potential Pollutants" to illustrate this example.
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2.a.
2.b.
3. a.
liquid formulation
tank #2
3.b.
liquid formulation
tank #3
3.c.
dry formulation tank
3.d.
Potential Pollutants
Active
Ingredients
Metolachlor
Pendimethalin
Pyrethrinll
Metolachlor
Pendimethalin
Pyrethrinll
Linalool
Pendimethalin
Other
Pollutants
BOD 5,
TOO, TSS
BOD 5,
TOO, TSS
BOD 5,
TOO, TSS
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology1
Alternate
Treatment
Technology1
Source for
Alternative Technology
Characteristics That
Hinder Treatment
1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_
Figure 6-1. Identifying Wastewater Sources
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CHAPTER 6 Conducting Treatability Test
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Step 2: Identify Wastewater Treatment Technologies
The user should identify treatment technologies that could effectively treat
each potential pollutant listed in Step 1. Pollution control technologies for
many pesticide active ingredients are presented in Table 10 to Part 455 of the
final rule (located in Appendix A). A list of the pesticide active ingredients
from Table 10 with their corresponding Shaughnessy codes and CAS num-
bers is also included in Appendix C. These control technologies include acti-
vated carbon adsorption, chemical oxidation, chemical precipitation,
hydrolysis, and pollution prevention. EPA selected these technologies based
on their applicability to a broad spectrum of pesticides and their relative cost
and availability The user should list the technology for each pesticide active
ingredient present in their wastewater in the "Table 10 Technology" col-
umn.
Table D
Alternate technologies, such as membrane filtration, may also effec-
tively treat pesticide active ingredients present in the facility's waste-
water. In specific cases, these other technologies may be more
cost-effective than the technologies listed in Table 10 of the rule. Facili-
ties may choose to evaluate these other technologies in a treatability test
to determine whether they are equivalent in performance to the Table
10 technologies (Chapter 7 of this manual discusses equivalent tech-
nologies in more detail). Facilities may also need to identify treatment
technologies for pollutants other than pesticide active ingredients. For
example, wastewaters that contain emulsions may require an emulsion
breaking pretreatment step before using another technology (e.g., acti-
vated carbon adsorption or hydrolysis) to remove pesticide active ingredi-
ents. Other wastewaters may require activated carbon adsorption to remove
organic priority pollutants in addition to pesticide active ingredients.
If information is not available for a particular pollutant, it may be necessary
for the facility to identify a treatment technology based on their knowledge of
the pollutant. For example, a technology that is effective on one pesticide
active ingredient is often effective on other pesticide active ingredients with
similar chemical properties and structures. However, treatment effectiveness
should be verified through a treatability test. Table 6-1 provides sources of
information on identifying treatment technologies using similarities in chemi-
cal properties and structures.
Treatment technologies can be identified from a variety of sources, including
technical literature, treatability databases, and treatment vendors. A review
of technical literature may reveal information that is not contained in the
sources listed in Table 6-1. Treatability testing conducted on similar wastewa-
ters in the PFPR industry or in other industries may provide clues on how to
treat a particular wastewater. And treatment technology vendors should have
information on the capabilities of their treatment systems. A facility should
use all available information as well as knowledge of the various technologies
and wastewater to be treated to identify appropriate treatment technologies.
Alternate technologies to treat pesticide active ingredients or other pollutants
can be listed in the "Alternate Wastewater Technology" column. The source
for identification of those alternative technologies (e.g., literature, treatability
tests, or other sources) can be specified in the "Source for Alternative Tech-
Appropriate Technologies
• Table 10 listed technology
I§455.10(g)]
• Equivalent system
I§455.10(h)]
• Pesticide manufacturer
treatment system.
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Table 6-1
Sources of Treatment Technology Information
EPA Treatability Database1
The U.S. EPA National Risk Management Research Engineering Laboratory in
Cincinnati, Ohio maintains a Pesticide Treatability Database that contains
information on over 1,600 pesticides that are currently in use in the United States
or have been removed from the market in the past 20 years. For each compound,
the database contains the following information (where available):
• physical and chemical property data;
• treatability data; and
• Fruendlich isotherm (carbon adsorption) data.
EPA/EAD Treatability Database Report and Addendum2
During the development of the PFPR rule, EPA conducted extensive research into
the treatment of PAIs, including gathering information from technical literature,
analyzing data on treatability tests conducted by PFPR and pesticide manufacturing
facilities, sampling existing treatment trains at PFPR and pesticide manufacturing
facilities, and conducting bench- and pilot-scale treatability tests. These documents
summarize the treatability data collected and describe how treatability data can be
transferred to other pesticide active ingredients.
U.S. EPA, Risk Reduction Engineering Laboratory, 26 West Martin Luther King Drive, Cincinnati,
OH, 45268
Final Pesticides Formulators, Packagers, and Repackagers Treatability Database Report (DCN
F7185) and the Pesticide Formulators, Packagers, and Repackagers Treatability Database Report
Addendum (DCN F7700)
Table D
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2.a.
2.b.
3. a.
liquid formulation
tank # 2
3.b.
liquid formulation
tank # 3
3.c.
dry formulation tank
3.d.
Potential Pollutants
Active
Ingredients
Metolachlor
Pendimethalin
Pyrethrin II
Metolachlor
Pendimethalin
Pyrethrin II
Linalool
Pendimethalin
Other
Pollutants
BOD 5,
TOC, TSS
BOD 5l
TOC, TSS
BOD 5,
TOC, TSS
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology1
AC
AC
HD
AC
AC
HD
AC
AC
Alternate
Treatment
Technology1
HD
HD
HD
Source for
Alternative Technology
Treatability testing, Literature
Treatability testing, Literature
Treatability testing, Literature
Characteristics That
Hinder Treatment
1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_
Figure 6-2. Identifying Wastewater Treatment Technologies
51
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CHAPTER 6 Conducting Treatability Test
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nology" column. Figure 6-2 presents an example of the types of information
collected when completing Step 2. The unshaded columns under "Waste-
water Treatment Information" illustrate this example.
Step 3: Identify Characteristics That Hinder Treatment
Throughout the pesticide industry, many products may be formulated, pack-
aged, or repackaged using different types of equipment. This variety in prod-
ucts and equipment results in variable wastewater characteristics, which in
turn affects the treatability of those wastewaters. For example, a wastewater
with a high amount of organic compounds may be difficult to treat with
chemical oxidation, as the organic compounds may compete with the pesti-
cide active ingredients for the available oxidizing agent.
The application of treatment technologies to variable PFPR wastewater must
be tailored to the specific characteristics of the wastewater. Table 6-2 presents
some wastewater characteristics that may interfere with emulsion breaking,
activated carbon adsorption, hydrolysis, chemical oxidation, and chemical
precipitation technologies; however, these characteristics do not necessarily
preclude use of the technology. The degree to which a wastewater exhibits a
characteristic will affect the degree to which the technology is adversely af-
fected. In many cases, a wastewater displaying an adverse characteristic can
still be effectively treated through modifications of the treatment technology
or the addition of a pretreatment step. For example, a wastewater may be
difficult to treat using activated carbon adsorption if it has a high suspended
solids content, because the suspended solids may plug the carbon column.
However, it may be possible to remove the suspended solids through settling
or filtration before activated carbon treatment.
Table D
Table 6-2
Wastewater Characteristics That Adversely Impact Treatment Effectiveness
Technology
Wastewater
Characteristic
Organics
Suspended Solids
Buffered Solution
Temperature
pH
Detergents/ Surfactants
Oil and Grease
Activated Carbon Chemical Chemical
Emulsion Breaking Adsorption Hydrolysis Oxidation Precipitation
The most common pretreatment technologies used for PFPR wastewaters are
settling, filtration, emulsion breaking, chemically assisted clarification, neu-
tralization, and ultrafiltration. Table 6-3 lists the types of wastewater charac-
teristics that can be effectively treated by these pretreatment methods. EPA
conducted treatability tests to evaluate emulsion breaking, chemically assisted
clarification, and ultrafiltration as part of the development of the PFPR rule.
See Chapter 5 for more information on these technologies.
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Table 6-3
Pretreatment Technologies for Adverse Wastewater Characteristics
Technology
Wastewater
Characteristic
Organics
Suspended Solids
Buffered Solution
pH
Detergents/ Surfactants
Oil and Grease
Settling Filtration
Emulsion
Breaking
Neutralization
or pH
Adjustment
Chemical
Assisted
Clarification
Ultrafiltration
Wastewater characteristics that hinder treatment can be listed in the "Char-
acteristics That Hinder Treatment" column of Table D. Figure 6-3 presents
an example of the types of information that may be documented during the
completion of Step 3.
Table D
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Fquipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2. a.
2.b.
3. a.
liquid formulation
tank # 2
3.b.
liquid formulation
tank # 3
3.c.
dry formulation tank
3.d.
Potential Pollutants
Active
Ingredients
Metolachlor
Pendimethalin
Pyrethrin II
Metolachlor
Pendimethalin
Pyrethrin II
Linalool
Pendimethalin
Other
Pollutants
BOD 5,
TOC, TSS
BOD 5,
TOC, TSS
BOD 5,
TOC, TSS
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology1
AC
AC
HD
AC
AC
HD
AC
AC
Alternate
Treatment
Technology1
HD
HD
HD
Source for
Alternative Technology
Treatability testing, Literature
Treatability testing, Literature
Treatability testing, Literature
Characteristics That
Hinder Treatment
High solids content
1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_
Figure 6-3. Identifying Characteristics That Hinder Treatment
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Step 4: Construct Potential Treatment Trains
Often the wastewater at a PFPR facility contains more than one pesticide
active ingredient and may also have characteristics that require a pretreat-
ment step. In these situations, several technologies may be necessary to com-
pletely treat the wastewater. These technologies can be used in series in what
is called a treatment train.
For example, a facility generates wastewater from floor washing that con-
tains several pesticide active ingredients, including atrazine, metolachlor, and
copper naphthanate. In order to effectively treat this wastewater, the facility
may construct a treatment train, shown in Figure 6-4, which consists of emul-
sion breaking to remove oil and grease and suspended solids picked up from
the floor during floor washing, chemical precipitation to remove the copper
naphthanate, hydrolysis to treat the atrazine, and activated carbon adsorp-
tion to remove the metolachlor and other priority pollutants contained in the
wastewater.
Untreated
PFPR
Wastewater
Figure 6-4. Example Treatment Train
When conducting a treatability test, facilities may only test the individual
unit operations. However, if a facility intends to implement the entire treat-
ment train, testing the entire train may reveal important information about
how the wastewater characteristics change with each treatment step. Testing
the wastewater through the entire treatment train can help troubleshoot the
system and determine whether pretreatment steps are adequate to prevent
malfunctioning of other unit operations in the treatment train.
Table D
Emulsion
Breaking
Pretreatment
^
Chemical
Precipitation
^
^
Activated
Carbon
Adsorption
Final
Treated
Effluent
Step 5: Determine Whether to Conduct a
Treatability Test
After identifying wastewater streams that require treat-
ment and the appropriate technologies for the constitu-
ents in those streams, a facility should determine
whether a test is warranted for their circumstances.
Several factors should be considered in making this
determination. A treatability test can help a facility to
evaluate whether the selected technologies effectively
treat their wastewater and whether additional treat-
ment steps are necessary. If a facility chooses technolo-
gies different from the ones listed in Table 10 of the final
rule for the treatment or removal of pesticide active in-
gredients, a treatability test can be used to demonstrate
that treatment is equivalent (demonstration of equiva-
lent treatment is discussed more fully in Chapter 7).
The test can also be used to determine the optimum treatment conditions, or
may be required by permit writers or control authorities to evaluate treat-
ment effectiveness before they allow PFPR wastewater to be discharged.
WHY CONDUCT A TREATABILITY TEST?
• Find out what technologies work best for
your wastewater and optimize treatment
performance.
• Show that an alternative technology is
equivalent to a technology listed in Table 10
to Part 455.
• Meet the requirements of your NPDES
permit writer or control authority prior to
discharging PFPR wastewater.
• Identify surrogate parameters as an
alternative to traditional laboratory analysis.
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
A treatability test may also allow a facility to identify surrogate parameters
(e.g., total organic carbon) that will indicate the treatment effectiveness of their
system without analyzing the wastewater for each individual constituent.
Because of the number of pesticide active ingredients handled by some facili-
ties, surrogate parameters can reduce the analytical costs associated with
compliance. In addition, EPA-approved methods do not exist for all pesticide
active ingredients, while other chemicals may be difficult to quantify because
contaminants in the wastewater interfere with the analysis; in these cases,
surrogate parameters allow some measure of treatment effectiveness to be
quantified. To use surrogate parameters for any of these reasons, a facility
may be required to perform a treatability test to establish the relationship
between the surrogate parameter and the constituents it is meant to repre-
sent. The use of surrogates is not required by the rule.
Preparing The Test Plan
Once the decision to conduct a treatability test is made, the facility should
prepare a written test plan. A test plan contains a set of predetermined proce-
dures designed to ensure the
test's success. The test plan helps
facility personnel organize and Components of the Treatability Test Plan
prepare for the test, ensure that
the test is conducted properly,
provide documentation of the
test, and troubleshoot treatment
systems and procedures.
The test plan should have suffi-
ciently detailed and clearly writ-
ten instructions so that treatment
system operators can easily con-
duct the test as specified. The
plan should first of all clearly
state the goals that are to be ac-
complished through performing
the treatability test and the technologies to be evaluated. The plan should
then delineate the size of the test, the target design and operating parameters
for each treatment step, detailed instructions on how to perform each treat-
ment step (including who is to perform the action, when the action should be
performed, and the equipment and materials to be used), and sampling and
analysis procedures.
After the goals of the test are set, the facility can follow the following five
steps in preparing a test plan for conducting a treatability test.
Step 1: Determine the Size of the Test
Full-scale treatment systems at PFPR facilities vary in size from very small
systems (treating 100 gallons or less per year) to very large systems (treating
millions of gallons per year). When performing a treatability test, it is not
always necessary to treat a large volume of wastewater, and often valuable
information can be acquired from smaller scale tests. Treatability tests are
typically categorized based on size as bench-, pilot-, and full-scale tests.
55
Goals of test and the treatment technologies to be evaluated
(including the sequence of treatment steps);
Size of the test;
Target design and operating parameters;
Written instructions for each step of the test, including the date,
time, location, and personnel involved in the test;
Equipment and materials required for the test; and
Sampling plan specifying sample points, times, and procedures,
sample analyses, sample preservation and shipping, and quality
assurance/quality control procedures.
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A bench-scale test is useful to screen treatment technologies or determine
initial design and operating parameters, and is typically conducted on one
gallon or less of wastewater. Bench-scale tests use laboratory equipment (e.g.,
beakers, hot plates, and stirring rods), and may be conducted on synthetic
wastewater (i.e., distilled water spiked with a known concentration of con-
taminant). Abench-scale test requires less cost and effort because of the smaller
volume of wastewater tested and the basic equipment used. In addition, a
bench-scale treatability test may involve less sophisticated sampling and analy-
sis, and may use indicator parameters (e.g., turbidity) or visual appearance of
the wastewater instead of laboratory analysis to gauge test results.
A pilot-scale test is conducted on actual wastewater, and is used to optimize
design and operating parameters and to troubleshoot treatment problems
before constructing a full-scale treatment system. Actual wastewater may
contain surfactants, inerts, solvents, or other impurities that may interfere
with treatment. The test is intermediate in size, although for many PFPR fa-
cilities that generate small volumes of wastewater, a pilot-scale system is equiva-
lent in size to a full-scale system. Pilot-scale tests typically use smaller and
simpler equipment than would be found in a full-scale system, such as buck-
ets or drums instead of treatment tanks; portable mixers and pumps instead
of built-in mixers and pumps; and flexible hoses instead of hard piping. These
systems may also use temporary equipment that can be placed in storage or
disposed of after the test instead of permanently installed equipment.
A full-scale treatability test is conducted on actual wastewater using the ac-
tual size and type of equipment to be used for routine treatment.
Step 2: Determine the Design and Operating Parameters
The effectiveness of a treatment step is related to cer-
tain design and operating parameters that determine
how well the treatment system functions. The spe-
cific design and operating parameters differ for each
type of technology. Table 6-4 presents a list of com-
mon parameters used for wastewater treatment tech-
nologies. For the treatment of PFPR wastewater,
design and operating parameters typically include
the amount of chemicals and/or materials used, tem-
perature, pH, and wastewater flow rates.
Usually, a treatment technology will operate within
a range of design and operating parameters. The
point within that range at which the treatment sys-
tem performance and cost are optimized will depend
on site-specific factors such as wastewater charac-
teristics and volume.
Prior to the treatment test, target design and operating parameters appropri-
ate for each treatment technology should be identified in the test plan. Be-
cause it is difficult to control some parameters precisely, a range of values
(e.g., pH 2 to 12) to be evaluated during the test should also be identified.
During the treatability test, treatment system operators should record the
actual design and operating parameter values to identify at what values the
optimum treatment performance of the system was achieved.
Table 6-4
Common Design and Operating Parameters
• Temperature
• pH
• Pressure
• Treatment time
• Flow rate
• Amount of treatment chemicals/materials
• Mixing
• Visual appearance of wastewater
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-+ Identify relevant design and operating parameters
Treatment technologies for PFPR wastewaters use a variety of mechanisms to
achieve treatment. These mechanisms include physical separation of contami-
nants from wastewater, chemical reactions, phase separations, or a combina-
tion. With each technology, a unique set of design and operating parameters
relevant to that technology needs to be monitored to ensure that the treat-
ment technology is functioning properly. In some cases, the relevant design
and operating parameters to be monitored may depend upon the specific
characteristics of the wastewater to be treated as well as the treatment
technology.
Table 6-5 presents the design and operating parameters that are typically
monitored for the five technologies used by EPA in developing industry com-
pliance costs for the PFPR rule. These technologies are described more fully in
Chapter 5. Design and operating parameters are listed for these technologies
because they are the technologies that are most frequently used in on-site
Table 6-5
Treatment Technology Design and Operating Parameters
Activated Carbon Adsorption
Parameters
• Wastewater flow rate
• Type and amount of carbon used
• Saturation loading
• Temperature
• pH
• Carbon bed dimensions
Chemical Oxidation Parameters
• Temperature
• pH
• Amount and type of chemicals
added
• Free chlorine, peroxide, or other
chlorinating agent concentration
• Treatment time or wastewater flow
rate
Precipitation Parameters
• Temperature
• pH
• Amount and type of chemicals added
• Mixing
• Treatment time or wastewater flow rate
Emulsion Breaking Parameters
• Temperature
• pH
• Mixing
• Amount and type of chemicals
added
• Turbidity
Hydrolysis Parameters
• pH
• Temperature
• Mixing
• Amount and type of chemicals
added
• Treatment time or wastewater flow
rate
57
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
treatment of PFPR wastewaters and are the technologies for which EPA has
the greatest amount of information. Note that these are not the only treat-
ment technologies that can be successfully applied to PFPR wastewaters. In
some cases, facilities may wish to monitor other design and operating param-
eters in addition to the ones listed in Table 6-5. Technical literature on the
selected technology to be tested and previous wastewater treatability tests
can help in identifying relevant operating parameters.
-*•
After identifying the appropriate design and operating parameters, facilities
should set a range of values to be evaluated during the test. These values can
be estimated from several sources:
• Previous treatment tests on the same or similar chemicals or wastewaters;
• Technical literature on the treatment technology; and
• Technology vendors.
The first time a wastewater is treated through a particular technology, PFPR
facilities may wish to set the target design and operating parameter values at
conservative levels that will overtreat the wastewater. Because PFPR waste-
waters tend to be highly variable, and equipment and procedures may also
vary from test to test, a parameter value that proved to be effective in previ-
ous tests on different wastewaters may not be an appropriate value for a
specific facility's wastewater. By setting conservative parameter values dur-
ing an initial test, facilities will not wrongly conclude that a particular treat-
ment technology is ineffective when all that is necessary to achieve effective
treatment is to adjust the design and operating parameter values.
For example, if technical literature indicates that a chemical oxidation time of
six hours will effectively treat a chemical, a PFPR facility conducting an ini-
tial treatability test may wish to perform chemical oxidation for 8 or 12 hours.
By sampling the wastewater at one- or two-hour intervals, the facility can
ensure that effective treatment occurs during the test while also identifying
how much treatment time is needed for their particular wastewater.
-*>
Once a facility has performed a treatability test and identified an effective
technology, the design and operating parameters used in that test can be used
as a basis for future testing, provided the wastewater characteristics do not
significantly change. However, facilities may wish to increase treatment per-
formance, decrease treatment time, and reduce the cost of treatment. By op-
timizing design and operating parameters, facilities can achieve these
objectives.
A properly run and well-documented treatability test will give indicators as
to how to optimize treatment system performance. By reviewing the design
and operating parameters achieved during treatability testing in conjunction
with treatment system operator observations and laboratory analyses, facili-
ties can determine what changes are likely to result in treatment system
optimization.
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By reviewing the design and operating parameter measurements, adjustments
can be made either during the treatability test or in subsequent tests to opti-
mize performance. In some cases, facilities can monitor design and operating
parameters instead of using costly laboratory analyses to verify treatment
effectiveness. For example, facilities can monitor the pH, temperature, and
treatment time for a hydrolysis unit instead of having the treated wastewater
analyzed to verify that hydrolyzable chemicals are removed. However, sub-
stituting laboratory analyses with design and operating parameter monitor-
ing to demonstrate compliance will ultimately need to be approved by the
control authority. Occasional laboratory analyses may be required to confirm
that design and operating parameter monitoring accurately predicts treat-
ment effectiveness.
If one of the goals of a treatability test is to optimize the treatment system, the
facility may choose to monitor design and operating parameters and sample
the system for laboratory analyses more frequently than is necessary to deter-
mine treatment system performance. For example, during an emulsion break-
ing pretest, the facility may collect samples under both acidic and alkaline
conditions or at various temperatures to determine what conditions result in
the greatest degree of separation. Facilities may also optimize treatment sys-
tem performance by changing wastewater management methods. For ex-
ample, by segregating certain wastewaters with characteristics that make
them hard to treat, treatment system performance can be improved. In some
cases, exterior equipment cleaning or floor wash water may contribute large
amounts of suspended solids to a wastewater. By segregating the floor wash
and exterior cleaning waters from other wastewaters, the facility may elimi-
nate the need for emulsion breaking or other pretreatment for nonexterior
waters, thereby reducing the cost of pretreatment by reducing the volume of
wastewater requiring pretreatment. Alternatively, the facility may find that it
is less expensive to dispose of some wastewaters than to treat them. For ex-
ample, off-site disposal of floor wash water may cost less for some facilities
than adding an emulsion breaking step to a treatment train.
As discussed in Chapter 7, the final PFPR rule requires that facilities choosing
the P2 alternative must demonstrate, as part of their on-site compliance pa-
perwork, that the treatment technologies they are choosing are well-oper-
ated and maintained. By documenting the optimal design and operating
parameters that reflect the appropriate level of treatment for each treatment
technology, a facility can demonstrate that its treatment system is well-oper-
ated and maintained. The section of this chapter on evaluation of test results
and Chapter 7 discuss how Tables D and E can provide the documentation
for demonstrated effectiveness of a facility's treatment system.
3:
Clear and detailed written procedures will not only help ensure that treatability
testing is successful, but can also help in troubleshooting treatment systems
that are not performing as well as expected and in optimizing treatment per-
formance. See the references listed at the end of Chapter 5 and/or the ex-
ample in Appendix D for descriptions of treatability test procedures used for
EPA-sponsored tests.
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If a treatability test shows poor results, a review of the test plan, deviations
from the test plan, and observations made during the treatability test may
help identify whether the poor results are due to test procedures or whether
the selected treatment technology is not appropriate for the wastewater be-
ing treated. This review can also help facilities determine whether additional
pretreatment is necessary to allow treatment technologies to function properly.
Step 4: Identify Equipment and Chemicals
Equipment and chemicals are necessary in conducting the treatability test,
collecting and analyzing the samples, and monitoring the design and operat-
ing parameters. When performing a treatability test, the equipment used should
be cleaned to avoid introducing outside contaminants that may skew test
results. Facilities should also use equipment constructed of materials that are
compatible with the wastewater, contaminants, and treatment chemicals to
be used in the test.
The types and sizes of equipment and chemicals needed to perform treatability
tests to evaluate emulsion breaking, hydrolysis, activated carbon adsorption,
chemical oxidation, and chemical precipitation are discussed below. These
technologies, described in Chapter 5, are the most cost-effective technologies
that remove or destroy pesticide active ingredients and priority pollutants in
PFPR wastewater.
-+ Emulsion Breaking
Facilities performing an emulsion breaking test should use a tank sized for
the volume of wastewater to be tested. If the tank has an open top, the facility
should cover the tank to minimize evaporative and heat losses. If the tank
does not have graduated markings, an additional container may be neces-
sary to measure the volume of the wastewater. A pump may also be required
to transfer the wastewater to and from the tank.
Acid lowers the pH of the wastewater and encourages emulsion breaking. A
variety of acids can be used for this purpose, including sulfuric and hydro-
chloric acid. To further encourage emulsion breaking, the facility may heat
the wastewater in the tank. Heating equipment includes hot plates, electric
band heaters, immersion heaters, and steam jackets.
Emulsion breaking also requires stirring to mix treatment chemicals and to
encourage the breaking of the emulsion. Rapid and turbulent mixing may be
used initially to mix the treatment chemicals, but may cause contaminants to
remain emulsified in the wastewater if used throughout the test. It is recom-
mended that the facility use low-speed mixing and low-shear mixers such as
paddle mixers.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple. The facility may also
wish to neutralize the pH of the wastewater after emulsion breaking if other
portions of the treatment train are not compatible with a low pH.
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•* Hydrolysis
Facilities performing a hydrolysis test should use a tank sized for the volume
of wastewater to be tested. If the tank has an open top, the facility may cover
the tank to minimize evaporative and heat losses. If the tank does not have
graduated markings, an additional container may be necessary to measure
the volume of the wastewater. A pump may be required to transfer the waste-
water to and from the tank, and a mixer is typically used during hydrolysis to
homogenize the wastewater.
Hydrolysis reactions typically occur more rapidly in acidic or basic environ-
ments. A variety of bases and acids are acceptable to raise or lower the pH of
the wastewater. To further encourage the hydrolysis reaction, the facility may
heat the wastewater in the tank. Heating equipment includes hot plates, elec-
tric band heaters, immersion heaters, and steam jackets.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple. The facility may choose
to neutralize the wastewater after the treatability test; a variety of acids and
bases can be used for this purpose.
-* Activated Carbon Adsorption
Facilities performing an activated carbon adsorption test must use a carbon
bed or column sized for the volume of wastewater to be tested. Flexible tub-
ing or hard piping may be used to convey water to the column and remove
treated wastewater. The facility will need a pump to move the wastewater
through the bed or column. Many carbon treatment systems use several beds
in series. As the first bed becomes saturated, it is removed from the system.
The influent is then directed to the second bed in the series, and an additional
bed is added to the end of the series to replace the saturated bed that was
removed.
The facility may use prefilled carbon beds from a vendor or prepare its own
bed or column. If the facility is packing a carbon bed or column itself, it will
be necessary to prepare the carbon. A scale should be used to weigh the car-
bon used to pack the column. It may also be necessary to rinse the carbon to
remove fines and to deaerate the carbon.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple.
OH
-+ Chemical Oxidation (Alkaline Chlorination)
Facilities performing a chemical oxidation test via alkaline chlorination should
use a tank sized for the volume of wastewater to be tested. If the tank has an
open top, the facility may cover the tank to minimize evaporative and heat
losses. If the tank does not have graduated markings, an additional container
may be necessary to measure the volume of the wastewater. A pump may be
required to transfer the wastewater to and from the tank. An electric mixer or
a magnetic stirring bar is typically used to mix the wastewater during chemi-
cal oxidation.
Cl
61
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Chemical oxidation occurs more readily in an alkaline environment. While a
variety of bases are acceptable, sodium hydroxide is most commonly used to
raise the pH of the wastewater. A variety of chlorine-containing chemicals
are available to initiate chlorination; sodium hypochlorite is commonly used
during chemical oxidation. A facility may choose to neutralize the wastewa-
ter with an acid following treatment, or add sodium thiosulfate or other free
chlorine scavenger following treatment to reduce residual free chlorine in the
wastewater.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple. The level of free chlo-
rine or other oxidant can be determined using readily available test kits. Facilities
should contact laboratory equipment vendors for information on such test
kits.
-+ Chemical Precipitation (Sulfide Precipitation)
Facilities performing a chemical precipitation test should use a tank sized for
the volume of wastewater to be tested. If the tank does not have graduated
markings, an additional container may be necessary to measure the volume
of the wastewater. A pump may be required to transfer the wastewater to
and from the tank.
A facility can use a variety of chemicals to initiate sulfide precipitation, in-
cluding sodium sulfate. Mixing the wastewater will encourage flocculation
of the metal precipitates. Although rapid and turbulent mixing may be used
initially to mix the treatment chemicals, such mixing may cause precipitates
to deflocculate. It is recommended that the facility use low-speed mixing and
low-shear mixers such as paddle mixers. A filter or vacuum pump may be
used to remove the flocculated solid particles from the wastewater, or the
facility may decant the wastewater.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple.
Step 5: Prepare the Sampling Plan
During and after the test, the facility will need to sample the wastewater to
ensure that the technology selected to treat the wastewater is performing
adequately. Prior to the start of the test, the facility should pre-
pare a sampling plan to describe the planned data collection,
field measurements, and sample analyses. Table 6-6 lists the main
components of a comprehensive sampling plan.
-* Select Sampling Points
Facility-specific sampling points should be identified so that the
samples collected will represent the following types of streams:
• Influent to the treatment system (e.g., commingled waste-
water from PFPR operations and pretreatment steps);
• Influent to the individual treatment units;
Table 6-6
Components of a Sampling Plan
Selection of sampling points;
Field measurements and operating
parameters;
Sample analyses;
Sample preservation and shipping;
and
Quality assurance/quality control.
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m Effluent from individual treatment units (e.g., hydrolysis effluent); and
• Final effluent from the treatment system.
Sample point selection should be designed for the specific system. Typically,
wastewater samples are collected from the influent and effluent of each treat-
ment unit operation to evaluate the performance of the individual unit. The
initial influent and final effluent samples from the whole treatment system
are collected to evaluate the system's overall performance.
If the facility chooses to investigate whether individual wastewater streams
(e.g., floor wash) require pretreatment, the selected sampling points should
include those individual raw wastewater streams. The commingled influent
to the treatment system would then consist of the pretreatment unit effluent
and the raw wastewater streams that do not require pretreatment.
The facility may also wish to collect multiple samples during a treatment step
to better calculate technology-specific performance measures (described in
the Evaluation of Test Results section). Table 6-7 presents examples of the
sampling frequency and analysis that might be performed for various tech-
nologies on a pilot scale. Sample frequency should account for the variability
of the wastewater generated from the various processes at the facility.
Table 6-7
Example Sample Collection for Pilot-Scale Study
Technology
Any technology
Activated Carbon
Activated Carbon
Emulsion
Breaking
Hydrolysis
Performance Measure
Destruction and removal
efficiency
Carbon breakthrough
curve
Saturation loading/carbon
isotherm
Time for phase separation
Half-life calculation
Sampling Frequency
Collect influent and final effluent
samples
Collect effluent samples after every
60 liters has passed through the
carbon bed
Treat a set volume (e.g., one liter) of
wastewater through varying amounts
of carbon and collect effluent samples
Visually inspect samples hourly for
phase separation
Collect effluent samples every 2-6
hours of treatment
Typical Sample Analyses
Any constituent
Pesticides
Organics
Total organic carbon
Pesticides
Organics
Total organic carbon
Turbidity
Total suspended solids
Oil and grease
Pesticides
-+ Field Measurements and Operating Parameters
As part of the test documentation, facilities should prepare field logs for each
sample point. Typically, these logs will contain the types of information listed
in Table 6-8 and be included in the report documenting the test results.
Typical field sampling equipment includes pH meters or indicator paper, ther-
mometers, scoops or shovels, and bottle dippers. Noncontaminating pH indi-
cator papers are often used during sampling and preservation; however, if a
more precise pH determination is required, a pH meter, calibrated each day
in the field, can be used. The pH electrode should be decontaminated prior to
sampling by rinsing the probe in deionized water. Temperature can be mea-
sured from either an aliquot collection jar or from the process stream after
63
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CHAPTER 6 Conducting Treatability Test
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Table 6-8
Typical Field Log Data
Table 6-9
Decontamination Procedures
sample collection to ensure that the thermometers
do not contaminate samples. Other sampling equip-
ment that directly contacts the sample, such as
scoops, shovels, and bottle dippers, should be
precleaned and dedicated to each sample point or
cleaned prior to reuse. Table 6-9 lists the typical
decontamination procedures for sample collection
containers.
-* Sample Analyses
Wastewater samples may be analyzed for conven-
tional and selected nonconventional parameters,
priority pollutants, and nonpriority organic and
metal pollutants. For the PFPR industry, the no-
table nonconventional pollutants expected to con-
tribute a significant toxic loading to PFPR facility
wastewaters are the pesticide active ingredients
used in formulating, packaging, or repackaging
operations. PFPR wastewater may also contain
specific organic and metal pollutants used in the
facility's pesticide formulations or high levels of
oils or solids.
At a minimum, samples should be analyzed for
the facility's pesticide active ingredients (if a
method is available) and for priority pollutants.
A number of pesticide active ingredient methods
can be found in the Methods for the Determination
of Nonconventional Pesticides in Municipal and In-
dustrial Wastewater (EPA 821-R-93-010). It is also
helpful to analyze the samples for the classical
wet chemistry parameters listed in Table 6-10.
These parameters can sometimes be correlated to
the level of treatment achieved during a particu-
lar unit operation. For example, total organic car-
bon (TOC) is often used as an indicator for
activated carbon adsorption. During a treatability
test or during an initial monitoring period for a
full-scale treatment system, the samples should
be analyzed for both TOC and the specific pesticide active ingredients. If the
test results show a correlation between the two, then TOC can be used as a
surrogate monitoring parameter during normal treatment operations. If met-
als are not used in the facility's operations, samples for metals analyses may
be collected only at the treatment system influent and the final effluent to
evaluate the overall system removals for those constituents.
Facilities may also wish to analyze the samples for other parameters that may
affect the performance of the selected treatment technologies. For example, a
treatability test for activated carbon might include analysis of total suspended
solids, since solids can plug the carbon bed and reduce overall performance
of the system.
Sampling point description;
Date and time of sample collection;
Name or initials of sampler;
Deviations from the sampling plans or test plan;
Field measurements;
Flow data;
Production data;
Observations; and
Other comments.
For samples in which inorganic constituents are to be
analyzed, the following decontamination procedures
are effective:
• Wash in a nonphosphate detergent and water
solution;
• Rinse with dilute hydrochloric acid;
• Rinse with tap water; and
• Rinse with Type II reagent grade water.
For samples in which organic constituents are to be
analyzed, the following decontamination procedures
are effective:
• Wash with detergent;
• Rinse with tap water;
• Rinse with distilled water;
• Rinse with acetone; and
• Rinse with laboratory-grade hexane.
Equipment blanks should be collected as necessary to
verify adequate decontamination procedures.
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Different types of analyses are conducted using separate
analytical methods that have specific preservation meth-
ods. These analyses may also be conducted by separate
laboratories. As a result, wastewater collected at each
sample point is separated into one or more containers,
called a sample "fraction," for each analysis or set of simi-
lar analyses. A comprehensive water sample set typically
consists of the eight fractions listed in Table 6-11. The
pesticide active ingredients analyzed will be facility-spe-
cific. Some pesticides are analyzed by the same method;
a separate pesticide fraction is required for each analyti-
cal method. As mentioned previously, it may not be nec-
essary for the facility to analyze the wastewater for all
parameters.
-* Sample Preservation
Individual sample fractions must be preserved accord-
ing to the appropriate analytical method. Table 6-12 lists
the typical analytical fractions, along with the typical
sample volume, sample container, and on-site preserva-
tion for each fraction.
Sample volume, container type, preservation, and stor-
age requirements for each analytical method are speci-
fied in the Handbook for Sampling and Sample Preservation
of Water and Wastewater (EPA-600/4-82-029). During
sample collection, facilities should follow good housekeep-
ing and health and safety practices by avoiding cross-
contamination of samples and leaks and spills.
Table 6-10
Classical Wet Chemistry Parameters
• Ammonia as nitrogen;
• Biochemical oxygen demand (BOD);
• Chemical oxygen demand (COD);
• Cyanide, total;
• Fluoride;
• Hexane extractable material (HEM);
• Nitrate/nitrite nitrogen;
• pH;
• Total dissolved solids (IDS);
• Total organic carbon (TOC); and
• Total suspended solids (TSS).
Table 6-11
Typical Sample Fractions
Specific pesticide active ingredient(s);
Volatile organic pollutants;
Semi-volatile organic pollutants;
Metals;
Group I classical parameters (BOD, TSS,
TDS, pH, and fluoride);
Group II classical parameters (TOC, COD,
ammonia nitrogen, nitrate/nitrite nitrogen);
Hexane extractable material; and
Total cyanide.
Table 6-12
Typical Sample Fractions and Preservation
Sample Fraction
Typical Pesticide Method
Volatile Organics
Semivolatile Organics
Sample Volume
2 Liters
80 mL
2 Liters
Metals 1 Liter
Group I Parameters1 1 Liter
Group II Parameters2 1 Liter
Total Cyanide 1 Liter
Hexane Extractable 1 Liter
Material
'Group I parameters include BOD , pH, fluoride, TDS, and TSS.
2Group II parameters include ammonia nitrogen, nitrate/nitrite nitrogen, COD, and TOC.
Sample Container
1 Liter Amber Narrow-
Mouth Glass
40 mL VGA Vial
1 Liter Amber Narrow-
Mouth Glass
1 Liter Narrow-Mouth Plastic
1 Liter Narrow-Mouth Plastic
1 Liter Narrow-Mouth Glass
1 Liter Narrow-Mouth Plastic
1 Liter Wide-Mouth Glass
On-Site Preservation
4°C; pH 5-7 with NaOH or HC1
4°C
4°C
pH 2 with HNO3
4°C
4°C; pH 2 with H SO
1 24
4°C; pH 12 with NaOH
4°C; pH 2 with HC1
65
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CHAPTER 6 Conducting Treatability Test
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-* Quality Assurance/Quality Control
To ensure the accuracy of the data collected during the treatability test, it is
critical that proper quality assurance/quality control (QA/QC) procedures
be followed throughout the entire treatability test and during sampling and
analysis. The sample plan should identify the following three components of
the facility's QA/QC plan:
(1) Specify procedures to ensure that data quality is within prescribed limits
of acceptability;
(2) Provide QC data that may be used to assess data quality in terms of pre-
cision and accuracy; and
(3) List analytical methods to be used.
Appropriate QA/QC procedures should be followed by the facility and the
laboratory that the facility selects to analyze the samples.
For example, when collecting samples, the facility should also collect QA/
QC samples, including field duplicate samples, field blanks, equipment blanks,
and trip blanks.
• Field duplicate samples are two successive samples from the same sam-
pling point. Results of the field duplicate analyses are used to evaluate
overall precision and cover all sources of data variability, including sample
collection, handling, preparation, and analysis. Field duplicates are sub-
mitted to the laboratory as blind duplicates.
• Field blanks are samples of an analyte-free matrix (e.g., HPLC water), which
are prepared at the sampling site by pouring the HPLC water directly into
the sample bottles. Results are used to evaluate potential volatile organics
contamination from the ambient air arising during sample collection.
• Equipment blanks are samples of an analyte-free matrix that have been
used to rinse sampling equipment prior to sampling. The results are used
to evaluate contamination arising from contact with sampling equipment,
and to verify the effectiveness of equipment decontamination procedures.
• Trip blanks are samples of an analyte-free matrix that have been trans-
ported unopened from a controlled area to the sampling site and finally to
the laboratory. Trip blanks are used to monitor volatile organics contami-
nation of samples during transport, field handling, and storage.
Duplicate samples are typically collected at a
frequency of 10%, or at least once per sampled
media. Duplicate samples are best collected
at sample points with very high or very low
pollutant concentrations. The various blank
samples are also typically collected with a com-
bined frequency of approximately 10 percent.
The primary objective of establishing QA/QC
procedures is to ensure that data are of the
quality necessary to demonstrate that the
treatment technologies selected and tested
comply with the PFPR rule. Table 6-13 lists the
Table 6-13
Overall Quality Objectives
Obtain all the critical data necessary to support
decision-making;
Collect representative samples according to the
procedures established in the sampling and analysis
plan;
Ensure data comparability by using standard methods
and controlled systems to collect and analyze
samples; and
Provide analytical results of known and acceptable
precision and accuracy.
66
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
overall quality objectives that should be met. Both the facility and the labora-
tory performing the analyses are responsible for ensuring that the data qual-
ity objectives are met.
Table E: Summary and Evaluation of Test Results
Following the treatability test, the facility should summarize and evaluate the
results to determine whether the test goals were achieved. The facility can
use Table E as the starting point for compiling and evaluating the test results,
including all analytical data, records of design and operating parameters
achieved during the test, and treatability test operator observations. Com-
pleting this table will enable facility personnel to assess which treatment tech-
nologies were effective in reducing specific
constituents in the wastewater, and determine the
optimum operating parameters for each treatment
unit. Four steps that can be used to evaluate the
treatability test results are detailed below.
Table E
Treatability Test Goals
Step 1: Document Test Results
The purpose of the treatment system is to reduce
contaminant levels in PFPR wastewaters. The pri-
mary constituents of concern for the PFPR industry
are the pesticide active ingredients used in the
facility's products. Other constituents, such as sol-
vents or inert ingredients, may also be a concern,
depending on site-specific criteria.
To evaluate the effectiveness of the treatment system, a facility should first
document all test results on Table E. Figure 6-5 is an example of a completed
Table E that presents the types of data collected during the treatability test.
The unshaded "Technology", "Primary Constituents", "Design and Oper-
ating Parameters", and "Constituent Concentration" columns illustrate this
example. Note that test results can be documented for each technology, as
well as for the entire treatment system.
Step 2: Calculate Performance Measures
The effectiveness of a treatment step can be evaluated through performance
measures that look at how much contaminant is removed from the wastewa-
ter, the amount of other waste generated by the treatment step, and the cost
of the treatment. The most common measure of treatment effectiveness is the
destruction and removal efficiency (DRE), also known as percent removal,
which measures the amount of contaminant removed from the waste stream.
In addition to DREs, treatment effectiveness may be measured with technol-
ogy-specific measures, such as a hydrolysis half-life. These measures are of-
ten useful in comparing the results of different treatment tests using the same
technology.
As shown in Figure 6-6, facilities can use the "Performance Measures" col-
umns on Table E to document these measures. Once the treatment perfor-
mance is calculated, facilities can determine whether that technology was
successful in removing or destroying that constituent and document the re-
Determine treatment effectiveness;
Identify analytical parameters to act as
surrogates for pesticide active ingredient
analyses;
Identify design and operating parameters to act
as indicators for treatment effectiveness;
Comply with permitting requirements; and
Optimize treatment performance.
67
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared by:
Insert vnur ontpmal treatment train and oneratinp narameters in the snace nrovided below:
i ecnnoiogy
Emulsion
breaking
pretest
Emulsion
breaking
Hydrolysis
raw k-
wastewater
Primary
L,onst tuents
Sam-rile contained all the emulsion-
breaking constituents excent
Linalool and Pvrethrin II.
Cva.na.zine
Linalool.
Met.ola.cMor
Pendimethalin
Pvrethrin II
Biological Oxvven Demand. fROD < )
Hexane Extractable Material fHEM}
Total Organic Carbon (TOO
Total Suspended Solids (TSS)
Cva.na.zine
Linalool
Met.ola.cMor
Pendimethalin
Pvrethrin II
Biological Oxvven Demand. fROD < )
Hexane Extractable Material fHEM)
Total Organic Carbon (TOO
Total Sus-nended Solids tTSS}
Emulsion
breaking
Hydrolysis
pH = 2 pH= 12
T = 60°C T = 60°C
slow mix slow mix
24 hour settling time 24 hour settling time
Design and Operating Parameters
p±i
2.01
11.74
7
2
Emulsion b
2
2
Emulsion b
2
2
2
2
12
12
12
12
12
12
12
12
12
Temperature
IM
60
60
25
60
reakin-? data fo
60
60
reakinv data fo
60
60
60
60
60
60
60
60
60
60
60
60
60
Other
Treatment
1 me
1 hour
1 hour
1 hour
1 hour
r thvi constiftj
1 hour
1 hour
r this constitu
1 hour
1 hour
1 hour
1 hour
\
\
\
\
X
z
z
z
/
Other
Settling
1 me
24 hours
24 hours
24 hours
24 hours
entwere not.
24 hours
24 hours
entwere not
24 hours
24 hours
24 hours
24 hours
/
Z
/
/
\
\
\
\
Other
Reaction
i me
\ X"
X
/ \
*, /
-rhulable. /
\ /
\ /
-ivailame.
A
/ \
/ \
' \
24 hou
24 hou
24 hou
24 hou s
24 hou s
24 hou
24 hou
24 hou
24 hour
Activated
carbon
adsorption
^ Mscharse
pH=7
T = 25°C
flow rate = 87 mL/min
empty bed residence time = 15 min
Constituent Concentration
Influent
(Ug/l.)
NA
NA
NA
3 750
NA
15 700
110
NA
< 108
< 165
534
334
714
5 760
20400
49.0
81.1
< 35
56.0
534
600
Effluent
(Ug/l.)
NA
NA
NA
714
NA
20400
49.0
NA
<35
56.0
534
6.00
< 2
792
14 700
45.0
<5
45.0
44.0
505
303
Performan
Percent
Ke in oval
ce Measures
Other
Hvdrolvsis
tlalt-L re
Effectively
Treated?
(i;«)
NA=not analyzed, NC=not calculated.
Figure 6-5. Documenting Test Results
suits in the last column, "Effectively Treated?" A facility should evaluate
three measures to determine if the technology effectively removed that con-
stituent:
• Percent removal;
• Final effluent concentration; and
• Minimum detection limit.
For example, if 95% or more of a constituent is removed by a technology, that
technology would be considered effective. Conversely, if a technology only
removes 30% of a constituent, but the constituent is removed to below its
detection limit, the constituent is effectively treated.
For cost purposes, the facility should also evaluate the technology-specific
performance measures. For example, as shown in Figure 6-6, metolachlor is
somewhat reduced by the hydrolysis step; however, the half-life is almost 60
hours. Hydrolysis alone would not be a cost-effective treatment technology
for metolachlor in this wastewater.
In addition to the DRE calculation, a discussion of several technology-specific
measures typically used to evaluate hydrolysis and activated carbon adsorp-
tion treatability test results are described below. Requirements for measuring
treatment effectiveness for other technologies may be identified through re-
view of technical literature.
Table E
68
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared by:
Insert vour optimal treatment train and operating parameters in the space provided below:
raw ^
wastewater
Emulsion
breaking
r>H = 2
T = 60°C
slow mix
24 hour settling time
lecnnology
Emulsion
breaking
pretest
Emulsion
breaking
Hvdrolvsis
Primary
const tuents
Sample contained all the emulsion-
breaking constituents except
Linalool andPvrethrinll.
Cvanazine
Linalool
Metolachlor
Pendimethalin
Pvrethrin II
Biological Oxvpen Demand (ROD , )
Hexane Extractable Material (HEM)
Total Organic Carbon /TOO
Total Suspended Solids iTSS)
Cvanazine
Linalool
Metolachlor
Pendimethalin
Pvrethrin II
Biological OxvgenDemand (BOD < )
Hexane Extractable Material (HEM)
Total Organic Carbon (TOO
Tntal Susrte.nrle.rl Snlirls ITSS)
Hydrolysis
pH=12
T = 60°C
slow mix
24 hour settling time
Design and Operating Parameters
pll
2.01
11.74
7
2
Emulsion b
2
2
Emulsion b
2
2
2
2
12
12
12
12
12
12
12
12
17
Temperature
(C)
60
60
25
60
Other
Treatment
I me
1 hour
1 hour
1 hour
1 hour
"•eaking data for this constitu
60
60
making data fo
60
60
60
60
60
60
60
60
60
60
60
60
60
1 hour
1 hour
r this constitu
1 hour
1 hour
1 hour
1 hour
\
\
\
\
;>
Z
z
Z
/
Other
Settlins
1 me
24 hours
24 hours
24 hours
24 hours
ent were not
24 hours
24 hours
ent were not
24 hours
24 hours
24 hours
24 hours
/
/
/
/
.
\
\
\
\
Other
Reaction
1 me
\ /
X
/ \
^ /
-rhiilable /
\ /
\ /
-ivailaMe.
A
/ \
/ \
' \
24 hou s
24 hou s
24 hou s
24 hou
24 hou s
24 hou s
24 hou s
24 hou s
74 hou
Activated
carbon
adsorption
^ discharge
pH=7
T = 25°C
flow rate = 87 mL/min
empty bed residence time = 15 min
Constituent Concentration
Influent
(ug/1.)
NA
NA
NA
3 750
NA
15.700
110
NA
< 108
< 16.5
534
334
714
5.760
20.400
49.0
81.1
<35
56.0
534
600
Effluent
(ug/1.)
NA
NA
NA
714
NA
20.400
49.0
NA
< 35
56.0
534
6.00
<2
792
14.700
45.0
<5
45.0
44.0
505
303
Performance Measures1
Percent
Kemoval
NA
NA
NA
81.0%
NA
NC
55.3%
NA
NC
NC
NC
98.2%
> 99.7%
75.7%
27 9%
8.16%
93.8%
NC
NC
17.8%
NC
Other
Hvdrolvsis
tlalt-L te
\ /
X
/ \
\ /
\ /
\ /
\ /
X
/ \
/ \
/ \
f \
2.84
30.8
596
NC
7.46
NA
NA
NA
NA
Effectively
Treated?
(i;«>
excellent
good
minimal
Y
NA
N
N
NA
inconclusive
N
N
Y
Y
Y
N
Y
Y
N
N
N
N
1 NA=not analyzed, NC=not calculated.
Figure 6-6. Calculating Performance Measures
-* Destruction and Removal Efficiency Calculation
The DRE is an overall measure of the effectiveness of a treatment. While some
technologies, such as hydrolysis and chemical oxidation, destroy contami-
nants by breaking chemical bonds joining the atoms in a molecule, other tech-
nologies, such as activated carbon adsorption and emulsion breaking, remove
contaminants by separating the contaminants from the wastewater. Other
technologies may use a combination of destruction and removal.
The DRE of a particular technology is based on the sum of the destruction
and removal achieved by a technology and does not differentiate between
the two. Some facilities may need to differentiate between destruction and
removal technologies for practical purposes. Since destruction technologies
(e.g., hydrolysis) eliminate a contaminant, they typically do not generate a
residue that must be further disposed of, or if they do generate a residue, it is
generally of a smaller volume than removal technologies. Removal technolo-
gies (e.g., activated carbon adsorption) separate the contaminants from the
wastewater, but the separated contaminants then require additional man-
agement, such as reuse, recycling, or disposal.
As shown in Figure 6-7, the DRE is equal to the mass of contaminant in the
treatment system influent minus the mass of contaminant in the effluent,
divided by the mass of contaminant in the influent. This measure may also be
referred to as the percent removal when expressed as a percentage.
Table E
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
DRE = (Mass. , ) - (Mass m )
v influent' v effluent'
(Mass. „ )
influent
Figure 6-7. Destruction and Removal Efficiency Calculation
A mass balance constructed for the treatment system may help facilities iden-
tify areas of wastewater and contaminant gain and loss. Constructing a mass
balance requires listing all of the influent streams and all of the effluent streams
of a system and listing their masses. Using the law of conservation of mass,
the total system influent mass should equal the total system effluent mass
plus any mass that may have been destroyed through a chemical reaction. If
the mass does not balance, then it is likely that some influent or effluent stream
(e.g., adsorption to treatment system components or evaporation) has been
overlooked. A mass balance can be conducted on individual unit operations
or on an entire treatment train; it can also be performed on the entire waste-
water volume treated or on one specific contaminant. When the volume of
the wastewater does not significantly change during treatment, the DRE can
be calculated using the contaminant concentration rather than mass.
Determining the DRE may be difficult if contaminant concentrations are less
than the analytical detection limit, or if contaminants in the wastewater in-
terfere with laboratory analysis and cause a high detection limit. Table 6-14
contains some general rules of thumb to follow when estimating the DRE in
these circumstances.
When determining treatment efficiency, it may be helpful to calculate DREs
for each unit operation as well as for the entire treatment system. Informa-
tion on DREs for individual unit operations may help facilities identify which
unit operations in a treatment train are not performing optimally. In some
cases, it may even be possible to exclude individual unit operations from the
treatment train if the treatment effectiveness for one particular operation is
insignificant.
Table 6-14
Calculation of DREs When Constituents Are Below the Level of Detection
The DRE can be calculated, using the formula In Figure 6-7, if the following conditions apply:
• Both the influent and effluent concentrations are greater than the reported detection limits, and the influent
concentration is greater than the effluent concentration; and
• The influent concentration is greater than the reported detection limit, and the effluent concentration is less
than the reported detection limit. The DRE can be calculated using the reported detection limit for the
effluent concentration in the calculation in Figure 6-7. The percent removals calculated should be shown in
the test report with the "greater than" (">") symbol.
The DRE cannot be calculated if the following conditions apply:
• Both the influent and effluent concentrations are greater than the reported detection limits, and the influent
concentration is less than the effluent concentration;
• The influent concentration is less than the reported detection limit, and the effluent concentration is
detected; and
• Both the influent and effluent concentrations are less than the reported detection limits.
70
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-» Hydrolysis Half-Life Calculation
Hydrolysis is an aqueous chemical reaction in which a molecule is broken
into two or more organic molecules. Hydrolysis of most pesticide active ingre-
dients takes place at an elevated pH and temperature, although some pesti-
cides may be amenable to acid hydrolysis.
To evaluate the effectiveness of hydrolysis on PFPR wastewater, half-lives are
typically calculated for each pesticide active ingredient. The hydrolysis half-
life is defined as the time required for the reactant concentration to decrease
to half the initial concentration. When hydrolysis occurs in alkaline condi-
tions (e.g., pH = 12), the reaction can be modeled with a first-order rate equa-
tion, as shown in Figure 6-8.
_ In (2)
1/2 "
tl/2 = half-life (minutes)
kl = pseudo first-order rate constant (minutes^)
Figure 6-8. Hydrolysis Half-Life Equation
For alkaline hydrolysis, the half-life is de-
termined using the procedure detailed in
Table 6-15. For further information on hy-
drolysis rate reactions and the calculation
of half-lives under different treatment con-
ditions, consult a hydrolysis text
or see the references listed at the end of
Chapter 5.
-* Activated Carbon Adsorption
Performance Measures
Table 6-15
Alkaline Hydrolysis Half-Life Determination
1) Plot the natural logarithm of the constituent concentration
versus time.
2) Draw a trend line to linearly fit the data.
3) Calculate the slope of the line, which is equal to the
hydrolysis rate constant, \.
4) Calculate the half-life using the equation in Figure 6-8.
Activated carbon adsorption is a treatment
technology that removes certain organic constituents from wastewater through
physical and chemical forces that bind the constituents to the carbon surface.
The adsorption of pesticide active ingredients typically takes place at neutral
pH and ambient temperatures. Two performance measures are used to evalu-
ate the effectiveness of activated carbon adsorption on PFPR wastewater:
carbon saturation loadings and carbon breakthrough curves.
The carbon saturation loading is the mass of organic constituents that can be
adsorbed onto a unit mass of activated carbon. As wastewater is processed
through a carbon bed, organic constituents are adsorbed onto the activated
carbon. At the same time, other constituents may be desorbed from the car-
bon. When the rate of sorption and desorption reach equilibrium, the carbon
is said to be saturated, and no further removal of organic constituents is
achieved.
The saturation loading varies with the concentration of the compounds being
adsorbed, the wastewater pH and temperature, and the presence of other
adsorbable compounds. A carbon adsorption isotherm is typically constructed
71
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
to show the relationship between the saturation loading and the pollutant
equilibrium concentration at a given temperature. This information can be
used to determine how much carbon is necessary to remove a constituent to a
set effluent concentration. Figure 6-9 presents an example of a carbon ad-
sorption isotherm for metolachlor, a pesticide active ingredient.
Carbon Adsorption Isotherm
X/M = 135 Ce
10000
X a
II
OT re
C Q
as
re
O O)
1000
100
10
0.1
10
Equilibrium Concentration, Ce
(mg/L Metolachlor)
100
Figure 6-9. Carbon Adsorption Isotherm.
1000
Carbon isotherms can be found in literature for many pesticide active ingre-
dients; however, a facility may also conduct a separate treatability test to
construct their own isotherms, since precise saturation loadings are specific
to a facility's individual wastewater stream. One experimental technique for
determining saturation loadings is presented in Carbon Adsorption Isotherms
for Toxic Organics, listed in the references at the end of Chapter 5. For further
information on activated carbon treatment and the construction of adsorp-
tion isotherms, consult a wastewater treatment text or see the references listed
at the end of Chapter 5.
Carbon breakthrough curves are another useful measure of the performance
of an activated carbon system. Breakthrough curves are often used to esti-
mate how much wastewater can be treated through an activated carbon unit
before it is necessary to replace or regenerate the activated carbon. The curve
is constructed by plotting contaminant concentration in the effluent versus
volume of wastewater treated. When wastewater is first treated through a
bed of fresh carbon, the concentration of contaminant in the effluent is at a
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
minimum level. At some later time during treatment, the carbon becomes
saturated and the contaminant is no longer adsorbed completely. The con-
centration of the contaminant in the effluent increases as more wastewater
passes through the unit and more of the available pore space in the carbon
becomes filled with contaminant. At the point where no additional contami-
nant is being adsorbed, the carbon is said to be exhausted. Figure 6-10 pre-
sents an example of a breakthrough curve for a general pesticide active
ingredient. As seen in this example, carbon breakthrough occurred after about
10 liters of wastewater were treated through the carbon bed.
Example Carbon Breakthrough Curve
6000
5000
4000
3000
o
o
HI
2
2000
1000
10
15 20
Volume of Feed (Liters)
25
30
Figure 6-10. Carbon Breakthrough Curve
Step 3: Compare Treatment Technology Results
To identify the most appropriate treatment train, the facility needs to com-
pare the results of their treatability tests to previous treatability tests, either
conducted by the facility or contained in the technical literature. The facility
may wish to consider aspects other than overall treatment effectiveness, in-
cluding cost, reliability, residuals generated, and need for highly skilled op-
erators. When comparing treatability tests conducted using the same
technology, the comparison is more straightforward than when comparing
treatability tests using different technologies.
When comparing the same technologies, the facility can evaluate treatment
effectiveness measures, such as effluent concentrations and DREs, but they
can also compare technology-specific measures, such as hydrolysis half-lives.
The facility may also be able to compare factors other than treatment effec-
tiveness (e.g., reliability and cost) more directly.
35
73
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
When comparing different technologies, the comparisons may be more diffi-
cult. Although the facility can still compare final effluent concentrations and
DREs, technology-specific criteria are not directly comparable. In addition, it
may be more difficult to compare technologies on bases other than treatment
effectiveness, such as reliability and cost.
Facilities should exercise caution when comparing test results from different
wastewaters. Because of the high degree of variability of PFPR wastewaters,
treatment that is effective on some wastewaters might not be effective on
other wastewaters that are similar. For example, two separate facilities have
metolachlor in their wastewater, but one facility has a low TOC loading in
their wastewater, while the second facility has a high TOC loading. Acti-
vated carbon may effectively remove the metolachlor from the wastewater
with low TOC levels; however, the wastewater with high TOC levels may
have other organic constituents that compete with the metolchlor for adsorp-
tion, resulting in reduced removal of metolachlor.
Therefore, when comparing treatability test results from different facilities,
from EPA-sponsored treatability tests, or from technical literature, facilities
should take into account how their wastewater differs from the wastewater
tested. Differences in contaminant concentrations, combinations of contami-
nants, and levels of suspended solids, dissolved solids, TOC, surfactants, de-
tergents, and solvents may cause wastewater differences that can affect the
performance, cost, and/or reliability of a treatment technology.
Step 4: Cost-Effectiveness of Treatment
As discussed in Step 3, facilities should compare the treatment technology
test results to choose the technology(ies) that will treat their wastewater to
the level required to comply with the final rule and that will be the most cost-
effective for them to use. In determining cost-effectiveness, facilities .need to
examine factors such as the cost of installing new technologies and the an-
nual operation and maintenance costs for those technologies, as well as
whether the technologies will meet the regulatory requirements of the rule.
In evaluating the cost-effectiveness of different treatment technologies, facili-
ties should consider whether wastewater treatment is the most cost-effective
method for them to comply with the rule. One of the factors that should be
taken into consideration is the volume of wastewater generated. A facility
may be able to treat its wastewater adequately using available technologies;
however, because the facility's volume of wastewater is so small, it may be
less expensive for the facility to dispose of the wastewater off site than to
install a treatment system.
After conducting the treatability test to determine the most effective treat-
ment method, the facility may determine that the technologies they have tested
and compared simply are not cost-effective. For example, the facility has de-
termined through treatabilty testing that its floor wash water can be adequately
treated using activated carbon adsorption, preceded by an emulsion break-
ing pretreatment step. However, the cost of installing and operating this treat-
ment train is more than what the facility would pay to have the floor wash
water contract hauled off site for disposal. In this case, it would be more cost-
effective for the facility to segregate its floor wash water and store it until it
can be transferred for off-site disposal. Note that cost-effectiveness may not
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
be the only factor considered by facilities when choosing to install treatment
or contract off site for disposal. Some facilities may choose to limit the pos-
sible cross-media impacts associated with off-site disposal.
As discussed in Chapter 4, the facility can use Table C to reach a preliminary
decision on how to comply with the final rule for each wastewater stream
(i.e., zero discharge or wastewater treatment and discharge after implement-
ing approved P2 practices). For those wastewater streams for which the facil-
ity chose the P2 alternative and that would require treatment prior to discharge,
the facility now has the information necessary to make the final compliance
choice. In some cases, the facility may change its preliminary compliance
decision from the P2 alternative (including on-site wastewater treatment) to
contract hauling of its wastewater, based on its evaluation of its wastewater
treatment options. The final compliance decision and Table C are discussed
in more detail in the on-site compliance paperwork section of Chapter 7.
Step 5: Prepare the Test Report
For each treatability test, facilities should prepare
a final test report that presents the information
gathered during the test and the analysis of test
results. The report can serve as documentation f Recorded design and operating parameters;
of the test and as a reference for future testing.
- Observations made by treatability test personnel;
As mentioned previously in this chapter, Tables
D and E can be used by facilities to identify the
wastewaters and contaminants that will be _ , , ,. c^n. j iU ._ ^ ± -± •
, , , ,, , .,., j ,1 , , , , i i • Calculations of DREs and other treatment criteria.
treated at the facility and the treatment technolo-
Test Report Components
Deviations from the sampling and analysis plan;
Analytical results; and
gies within the facility's treatment train that are
expected to treat each contaminant. Many facili-
ties will find it helpful to use a block diagram to draw each treatment step of
a treatment train. In such a diagram, facilities can list the influent wastewa-
ter streams to each unit operation in a treatment train, the contaminants
within each wastewater stream, and the contaminants treated within each
unit operation block.
Tables D and E can also be used as compliance documentation to show that
appropriate treatment technologies are being used to treat each wastewater
stream. Chapter 7 discusses in detail the documentation needed to show com-
pliance with the final rule.
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CHAPTER 7
Regulatory Compliance Documentation
Necessary Paperwork for the PI Alternative
One-time initial certification statement
Each facility subject to the PFPR effluent guidelines and standards is re-
quired to keep certain paperwork on site to demonstrate compliance
with the rule. This paperwork must be available to the permitting agen-
cies, control authorities, and enforcement officials and must document the
compliance options chosen by the facility. As part of the on-site compliance
paperwork, the PFPR rule requires a one-time initial certification statement
and periodic certification statements to be submitted to the permitting agency
or control authority. The permitting agency or control authority may also
choose to require submittal of additional paperwork for approval, including
the supporting documentation for the facility's selected P2 practices and
wastewater treatment technologies. Indirect-discharging facilities must also
meet the paperwork requirements under the General Pretreatment Regula-
tion (40 CFR 403), such as submittal of a baseline monitoring report (BMR)
(40 CFR 403.12(b)). Guidance on the requirements of the BMR and applica-
bility of categorical pretreatment standards to industrial users, including zero
dischargers, is included in Appendix E.
As stated previously in this manual, each facility subject
to the rule must make an initial choice of how to comply
with the rule. This choice is documented in the initial /4Q
certification statement. The facility periodically reviews _ . ,. .... .
, , . ,, yr ,. . • Periodic certification statement
those choices and makes any necessary adjustment in ,4~ 0^455 41 (K)). ancj
the periodic certification statement. Chapter 4 discusses
the P2 audit and how a facility can use that tool to de- " n Sl e comPIance paperworc
termine which compliance strategy to choose (i.e., zero
discharge or P2 alternative). Chapter 6 discusses how to
choose appropriate wastewater treatment technologies and make a final com-
pliance decision after weighing the economic impacts of treatment. The infor-
mation in these two chapters provides the means with which a facility can choose
its method of complying with the PFPR regulation. This chapter discusses the
way in which a facility documents its compliance decisions.
Initial Certification Statement
The initial certification statement required for PFPR facilities includes four items.
As shown in Table 7-1, the requirements under these items can be met by com-
pleting Tables A through E (shown in Chapters 4 and 6). As discussed in Chap-
ter 4, Tables A and B walk the user through conducting a P2 audit. Table A
prompts the facility to identify its wastewater sources and Table B identifies P2
practices that are in use or potentially could be used to comply with the P2
alternative for those sources (Item 2). Tables B and C also provide a column for
listing modifications to the listed P2 practices (Item 3). After completing Tables A
Initial
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
Table 7-1 Initial Certification Statement Requirements
One-time submission to the appropriate control authority or permitting agency including the following: Table
(1) List and description of those product families, process lines, and/or process units for which the C
PFPR facility is implementing the P2 alternative and those for which it chooses to achieve zero
discharge;
(2) Description of the PFPR facility-specific practices for each product line/process line/process unit A, B
which are to be practiced as part of the P2 alternative;
(3) Description of any justification allowing modification to the practices listed on Table 8 of the final B, C
rule; and
(4) Description of the treatment system being used to obtain a P2 allowable discharge (as defined by D, E
the final rule).
and B, the facility can complete Table C through the preliminary compliance
decision (Item 1), which includes any modifications to listed P2 practices cho-
sen by the facility Note that Table C has a column to list the approval date for
modifications to any P2 practices chosen by a facility that are not listed in
Table 8 of the final rule. The facility will need to obtain approval for all
nonlisted modifications, and the on-site compliance paperwork should re-
flect this approval, prior to the facility implementing these modifications.
The fourth requirement for completing of the initial certification statement
can be met by filling out Tables D and E, as discussed in Chapter 6. Table D
identifies the treatment technologies that a facility will choose to treat its waste-
water remaining after implementation of P2 practices in order to meet the
allowable discharge requirement. Table E presents the results of the treatability
tests for the technologies identified in Table D. Once the facility has chosen
the best treatment options for its remaining wastewater (i.e., treatment and
discharge or contract haul), final compliance decisions can then be docu-
mented on Table C.
The initial certification statement must be submitted to the permitting
agency at the time of issuance, renewal, or modification of an NPDES
permit for direct dischargers and to the control authority (e.g., POTW)
prior to the November 6, 1999 compliance deadline for indirect discharg-
ers. The statement must be signed by the appropriate manager in charge
of overall operations at the site to ensure that information provided is
true, accurate, and complete to the best of his/her knowledge. This man-
ager should be the same person who signs the compliance status reports
as required by 40 CFR 403.12(1) or 40 CFR 122.22. The initial certification
statement should also be kept on file at the facility as part of the required
on-site compliance paperwork for as long as the facility is in operation.
Initial
Periodic Certification Statement
The periodic certification statement required for PFPR facilities consists of a
written submission to the appropriate permitting agency or control authority.
This submission states that the P2 alternative is being implemented in the
manner set forth in the local control mechanism/pretreatment agreement
(for indirect dischargers) or NPDES permit (for direct dischargers), as well as
the initial certification, or states that a listed justification from Table 8 of the
final regulation has been implemented at the facility allowing modification of
their P2 practices.
Periodic
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
If the information contained in the facility's permit or pretreatment agree-
ment and initial certification statement is still applicable, a facility may sim-
ply state that in a letter to the permitting authority, and that letter will constitute
the periodic statement. However, if the facility has modified their P2 prac-
tices in any way or is deciding to change their compliance status for one of
their product lines/process lines/process units (i.e., going from zero discharge
to a P2 practice followed by allowable discharge), they must include such
information in their periodic statement. To comply with this requirement, the
facility may submit a revised Table C, indicating the change on the table. To
modify a listed P2 practice for which a justification is not listed in the final
regulation, the facility must request the modification from the permitting
agency or the control authority (e.g., POTW). The permit writer/control au-
thority is expected to use Best Engineering Judgment/Best Professional Judg-
ment (BEJ/BPJ) to approve the modification.
The periodic certification statement must be submitted to the permitting
agency once a year for direct dischargers and to the control authority
twice a year for indirect dischargers. The statement must be signed by the
appropriate manager in charge of overall operations at the site to ensure
that information provided is true, accurate, and complete to the best of
his/her knowledge. Again, this manager should be the same person who
signs compliance status reports as required by 40 CFR 403.12(1) or 40 CFR
122.22. The periodic certification statements should also be kept on file at
the facility as part of the required on-site compliance paperwork for as
long as the facility is in operation. An example of a periodic certification
statement is shown in Figure 7-1.
Street, Anytown, VA 01110
(703)555-5555
1 July 1997
Anytown POTW
1 Main Street
Anytown, VA 01110
RE: PFPR Periodic Certification for ACME Formulating, Inc.
Dear Sir/Madam:
Please be advised that the facility located at 1234 Main Street has initiated production of two
new pesticide products: ACME Lawn and Garden Insect Control (dry) and ACME Lawn and
Garden Insect Spray (liquid). Both of these products contain diazinon, a pesticide active
ingredient not previously used at our facility. Attached please find a listing of the new
wastewater sources associated with the production of these products, and whether we intend to
comply with the zero discharge regulation or the P2 alternative.
As you will see from the attached list, our facility will generate two new sources of wastewater
containing diazinon that will be discharged to your POTW. No additional modifications to the
listed practices will be made. Our current treatment system consists of emulsion breaking,
followed by hydrolysis and activated carbon. Table 10 to Part 455 lists hydrolysis as the
appropriate treatment technology for diazinon; therefore, we do not intend to make any changes
to our treatment system. As stated in our pretreatment agreement, we will monitor our treatment
system effluent for diazinon for 60 days and provide you with copies of all results.
Please feel free to contact rne at (703) 555-5555 if you have any questions or comments regarding
our changes in operation.
Sincerely,
John Doe
President, ACME Formulating, Inc.
Periodic
Figure 7-1. Example of a Periodic Certification Statement
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
On-Site Compliance Paperwork
In addition to the initial and periodic certification statements, the on-site com-
pliance paperwork should include the four items listed in Table 7-2. This pa-
perwork must be available for review at any time by the permitting agency or
control authority. As discussed under the section describing the initial certifi-
cation statement, the on-site paperwork require-
ments may include the information documented on
Tables A through E, as described in Chapters 4 and
6. These tables document the wastewater sources,
P2 practices and modifications, if any, and waste-
water treatment technologies/disposal options cho-
sen by the facility.
On-site
Paperwork
The on-site paperwork should also include more de-
tailed materials supporting the decisions in the ini-
tial and periodic certification statements. The
appropriate documentation for each of these deci-
sions is discussed in more detail below.
Table 7-2
On-Site Compliance Paperwork Components
o;
Supporting documentation for P2
modifications;
(2) Discussion of treatment system
demonstrating removal of PAIs;
(3) Method for ensuring treatment system is
well operated and maintained; and
(4) Rationale for method shown in Item 3.
-+ P2 Modification Documentation
If a facility chooses to comply with the P2 alternative using a modification
listed in Table 8 of the final rule for any wastewater source, the facility must
detail those modifications in their on-site compliance paperwork. Table 7-3
presents the practices from the
rule that have listed modifica-
tions. Each of these listed modifi-
cations requires supporting
documentation, as described in
Table 8 of the final rule. For ex-
ample, a facility has determined
that they cannot store and reuse
the interior equipment rinsate
from a specific product because
the rinsate exhibits biological
growth that would affect the
product quality if reused in a sub-
sequent formulation. The facility lists "BIOGROWTH" as their modification
to Practice 10 for that product, and includes as documentation a picture of
the rinsate after growth has occurred and/or a copy of the product QA test
results showing unacceptable constituents present.
If a facility wishes to modify any P2 practice using a justification that is
not listed in Table 8, the facility must submit to the control authority or
permit writer the appropriate documentation stating their reasons for
modifying the practice. This documentation must be approved by the per-
mitting agency or control authority prior to implementation by the facil-
ity. Both the supporting documentation and the approval must be included
in the on-site compliance paperwork.
Table 7-3
PZ Practices With Listed Modifications Requiring Documentation
Practice 1 - Water Conservation
Practice 2 - Good Housekeeping
Practice 6 - Air Pollution Control Scrubbers
Practice 7 - Drum/Shipping Container Rinsing (water-based)
Practice 8 - Drum/Shipping Container Rinsing (solvent-based)
Practice 9 - Production Equipment Dedication
Practice 10 - Reuse of Interior Rinsate
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
Table 7-4
Treatment System Description
(1) List of pesticide active ingredients belived present in
wastewater to be treated;
(2) List of treatment technology(ies) believed effective at
removing each pesticide active ingredient listed in Item 1;
and
(3) Treatability test results supporting Item 2 or indication
that the treatment appears in 40 CFR 455, Table 10 as the
"appropriate treatment" for pesticide active ingredient(s).
-* Treatment System Discussion
If a facility chooses to install a wastewater treatment system to treat PFPR
wastewater prior to direct or indirect discharge, the facility must include a
complete description of the system in their on-site compliance paperwork.
This description should include the information listed in Table 7-4, as well as
any documentation necessary to support the conclusions drawn by the facility
Following completion of a P2 audit (de-
scribed in Chapter 4), the facility should
be able to identify the wastewater sources
that require treatment prior to discharge
under the P2 alternative. In the on-site
compliance paperwork, the facility must
list the specific pesticide active ingredients
expected to be present in the facility waste-
water. Facilities may use production
records or product labels listing the pesti-
cide active ingredients used at the facility
or wastewater monitoring data that spe-
cifically identifies the constituents. The fa-
cility should review the production and monitoring data covering a sufficient
time period to accurately capture all possible pesticide active ingredients
present in the wastewater.
Next, the facility must describe the treatment system, including a list of the
technologies and operating conditions, and document that the technologies
do, in fact, remove the pesticide active ingredients from the wastewater prior
to discharge. This documentation may simply state that the technology(ies) is
listed in Table 10 to Part 455 as the appropriate technology(ies) for the spe-
cific pesticide active ingredients present in the facility's wastewater or that
the technology(ies) removes the specific pesticide active ingredients from their
pesticide manufacturing wastewater. Chapters 5 and 6 discuss the test meth-
ods available to identify the specific pesticide active ingredients present in the
wastewater and the appropriate treatment technologies for their removal.
Chapter 6 also describes how to document those results on Tables D and E.
An example of a treatment system description using Tables D and E is shown
in Figure 7-2.
If the facility chooses to use different tech-
nologies than those listed in the final rule,
they must include treatability test results
or sampling test results (described in
Chapter 6) to show the system is equiva-
lent. The technologies listed in the final
rule were chosen because of their effec-
tiveness in removing or reducing pesticide
active ingredients. Following sufficient
pretreatment of PFPR wastewater to break emulsions and/or remove solids,
these listed technologies were generally successful in removing more than
95% of the pesticide active ingredients, typically to below detection limits. To
determine whether a different technology or set of technologies is equivalent
to the listed technologies, the facility should evaluate three measures:
On-site
Paperwork
Equivalent System (40 CFR 455.10)
A wastewater treatment system that is demonstrated in
literature, treatability tests, or self-monitoring data to
remove a similar level of pesticide active ingredients or
priority pollutants as the applicable appropriate pollution
control technology listed in Table 10 to Part 455.
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type
fcsShipping Container/ Drum/'
Cleaning - water or solvenjsfmses
of the comaifiers usedfrfship raw
material, finisbed&roducts, and/or
waste producp^no^o reuse or
disposal ofme containers.
ZXBulk Tank Rinsate - cleaning
of thetyterior of any bulk storage
tank conrniwmg raw materials,
intermediate Dfeqdgf or finished
products assqpiatecfaifith PFPR
operations x*.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/ or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2. a.
2.b.
3. a.
liquid formulation
tank # 2
3.b.
liquid formulation
tank # 3
3.c.
dry formulation tank
3.d.
Potentia
Active
Ingredients
Metolachlor
Pendimethalin
Pyrethrin II
Metolachlor
Pendimethalin
Pyrethrin II
Linalool
Pendimethalin
1 Pollutants
Other
Pollutants
BOD5,
TOC, TSS
BOD5,
TOC, TSS
BOD5,
TOC, TSS
Location:
Prepared by:
Wastew
Table 10
Technology1
AC
AC
HD
AC
AC
HD
AC
AC
ter Treatment
Alternate
Treatment
Technology1
HD
HD
HD
Information
Source for
Alternative Technology
Treatability testing, Literature
Treatability testing, Literature
Treatability testing, Literature
Characteristics That
Hinder Treatment
High solids content
HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared by:
fnsert vnur ontjmal treatment train and nneratinp narameters in the snace nrnvided below:
Technology
Overall
effectiveness
Raw
Wastewater
Primary
Constituents
Cyanazine
Linalool
Metolachlor
Pendimethalin
Pytrethrin II
Biological Oxygen Demand (BOD 5)
Hexane Extractable Material (HEM)
Total Organic Carbon (TOC)
Total Suspended Solids (TSS)
Emulsion
Breaking
Hydrolysis
pH = 2 pH= 12
T = 60°C T = 60°C
slow mix slow mix
24 hour settling time 24 hour settling time
Design and Operating Parameters
PH
^^
\
^
^
Temperature
(°Q
.
^\
\
^
^^
"^~
Other
Treatment
Time
^ ^
X
^
Other
Settling
Time
^^
~^
^
^^
^
Other
Reaction
Time
^
^
^
^^
Activated
Carbon
Adsorption
^ Discharge
pH=7
T = 25°C
flow rate = 87 mUmin
empty bed residence time = 15 min
Constituent Concentration
Influent
(ug/L)
3750
5760
15700
110
81.1
<108
56
534
334
Effluent
(ug/L)
<2
<100
<0.8
<0.5
<5
31
<5
63
<4
Performance Measures1
Percent
Removal
> 99.9%
> 98.3%
> 99.9%
> 99.6%
> 93.8%
<71.3%
>91.1%
88.2%
> 98.8%
Other
Hvdrolvsis
Half-Life
\ 1
\ 1
\ 1
\l
\
l\
/ \
/ \
' \
Effectively
Treated?
(Y/N)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Figure 7-2. Example of a Treatment System Description
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
• Percent removal of the pesticide active ingredient;
• Final effluent concentration of the pesticide active ingredi-
ent; and
• Minimum detection limit of the pesticide active ingredient.
These methods are not exclusive and are not ranked in order of
importance. All three methods may be useful when determin-
ing equivalency.
-* Treatment System Operation and Maintenance
Facilities that treat PFPR wastewater prior to discharge must also choose a
method to demonstrate that their treatment system is well operated and main-
tained. This method should be stated and the rationale for choosing it dis-
cussed in the on-site compliance paperwork.
Proper operation and maintenance of a system includes a qualified person to
operate the system, use of the correct treatment chemicals in appropriate
quantities, and operation of the system within the stated design parameters
(e.g., temperature and pressure). For example, if the facility is operating a
Percent removals and effluent
concentrations discussed in the final
PFPR effluent guidelines and
standards are shown for guidance
only.
On-site
Paperwork
Table 7-6
Operation and Maintenance Records
Emulsion Breaking
• Temperature and pH of the
emulsion breaking step
• Duration of the emulsion
breaking step
• Physical characteristics of the
wastewater before and after
emulsion breaking
Activated Carbon Treatment
Hydrolysis Treatment
• Temperature and pH of the
hydrolysis step
• Duration of the hydrolysis step
• Physical characteristics of the
wastewater before and after
hydrolysis
Dates and volumes of carbon changeouts
Amount of carbon used in the system
Flow rate through the carbon system and /or volume of wastewater treated
since the last carbon changeout
treatment system that consists of emulsion breaking, hydrolysis, and acti-
vated carbon, as described in Figure 7-2, the types of operation and mainte-
nance records detailed in Table 7-6 should be kept on site. The method for
determining whether the system is well operated can be as simple as keeping
the types of records shown in Table 7-6, or as complex as monitoring the
treated effluent for specific parameters (such as pesticide active ingredients,
priority pollutants, or other local parameters of concern).
The decision to use one method over another is connected to the consistency
of the facility's wastewater. If the facility formulates, packages, or repackages
the same or similar products for long periods of time, it is reasonable to expect
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
that a treatment system designed for the wastewater generated during those
production operations will be effective if operated and maintained as de-
signed. In these cases, the facility may monitor the effluent from the treat-
ment system for an initial period of time (typically set by the permitting agency
or control authority) to establish the typical effluent concentration or load for
the pollutants of concern. During the monitoring period, the facility may also
document the information detailed in Table 7-6 to establish the normal oper-
ating procedures. Following the monitoring period, the facility would only be
required to document the operating and maintenance information and may
periodically monitor the effluent for the pollutants of concern.
If a facility begins producing new products containing one or more pollut-
ants of concern, the typical concentration or load for those pollutants may
need to be revised through another monitoring period, as determined by the
permit writer or control authority.
Additional Considerations for Permit Writers and
Control Authorities/POTWs1
Permit writers and control authorities must use best professional judgement
when evaluating certification statements and reviewing on-site compliance
paperwork from PFPR facilities. Factors that may influence their decisions
include previous experience with the facility, the facility management's com-
mitment to program implementation, and the thoroughness and accuracy of
the supporting documentation.
One area subject to interpretation is the determination of treatment system
equivalency. When reviewing treatment system performance data, the per-
mit writer or control authority should review the source of the data, the time
period during which it was collected, and the type of data collected. The level
of performance should also be evaluated through one or more of the follow-
ing methods.
CERTIFIED
-* Calculate percent removals
The percent removal, as discussed in Chapter 6, is equal to the difference
between the influent and effluent values. The percent removal can be calcu-
lated on concentrations or on mass loadings. It is important to note that the
percent removal is highly dependent on the quantity of pollutant in the influ-
ent. For example, an activated carbon system removes bromacil to its target
effluent concentration of 0.431 mg/L. If the influent concentration was 100
mg/L, the percent removal is 99.6%, whereas if the influent concentration
was 5 mg/L, the percent removal is 91.4 percent.
-* Evaluate the final effluent concentrations
During development of the PFPR rule, EPA identified target effluent concen-
trations for pesticide active ingredients treated in systems using appropriate
treatment technologies, as specified in Table 10 of the final rule. These con-
centrations are not effluent limitations and do not account for the variability
that may occur in PFPR wastewaters and in treatment systems. Permit writ-
1 The term control authority refers to a POTW when the POTW has an approved pretreatment program.
Otherwise, the control authority is the State or EPA Region.
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CHAPTER 1 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry
ers and control authorities have the authority to request additional treatability
test results or monitoring to better evaluate the variability of the treatment
system effluent.
-*
It is important to note the minimum detection limit achieved by the analytical
laboratory that completed the analyses. If the laboratory neglects to perform
an appropriate number of dilutions, the results may be inconclusive. For ex-
ample, if the influent concentration of a pollutant is 100 mg/L and the efflu-
ent concentration is reported as <100 mg/L, it is impossible to conclude what
level of pollutant removal has been achieved by the treatment system.
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CHAPTER 8
Case Studies
This chapter describes the P2 practices implemented by two PFPR facili-
ties. The first facility, operated by Ertnis Agrotech and located in Ennis,
Texas, is a formulator and packager of agricultural products. Ennis
Agrotech uses a variety of P2 techniques, such as reuse of treated wastewaters,
to achieve zero discharge of PFPR process wastewaters. The second facility,
operated by MGK (McLaughlin Gormley King Company), was constructed in
1992 in Chaska, Minnesota, and illustrates how new facilities can incorpo-
rate P2 opportunities into their design.
In each case study, the following information is presented:
• An overview of the facility;
* A description of the PFPR operations, including wastewater generation; and
* A discussion of the P2 techniques implemented by the facility.
Each case study was prepared from information collected during site visits and
through follow-up telephone calls with facility personnel. This information
was correct at the time of development of the final rule, but operations may have
changed since that time. The P2 practices implemented and their benefits are
solely based on the opinions of the facilities presented here. Specific P2 prac-
tices and equipment presented in the case studies in italicized bold print are
defined in the P2 glossary in Chapter 3.
1:
Facility Owervlew
Ennis Agrotech, formerly Agriculture Warehouse, operates a contract (or toll)
PFPR facility that does not produce or market its own labeled products. In-
stead, the facility formulates registered pesticide products for about 20 domes-
tic and foreign companies. These companies supply Ennis Agrotech with the
necessary raw materials, product recipes, and packaging and labels required to
make the final product. Ennis Agrotech assembles a production line using the
customer's bench-scale process as a guide, formulates and packages the prod-
uct, and then turns the product over to the customer's marketing division. The
production line consists of equipment from Ennis Agrotech's inventory as well
as custom-designed equipment manufactured as needed by a local machine shop.
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
The facility operates eight independent process lines to formulate and pack-
age both liquid and solid pesticide products. The list of formulated products
varies over time due to changing contracts; however, Ennis Agrotech attempts
to schedule formulating and packaging contracts such that only compatible
pesticide products are being produced at the same time.
The eight production areas operated at the facility (termed "manufacturing
modules" by Ennis Agrotech) are individually configured to handle a certain
type, or formulation, of pesticide product. The equipment setup in each of the
process areas can be reconfigured to formulate .new products. New formula-
tion and packaging lines usually consist of a combination of existing and new
custom-designed equipment. Existing equipment is refurbished, pressure-
washed in a curbed area (if necessary), and stored in a warehouse building
(called the machine shop) when it is not being used on one of the process
lines. At the time this manual was written, Ennis Agrotech was conducting
formulating, packaging, and repackaging operations in the following eight
production areas:
:i"* The first manufacturing module is used to formulate and package
mosquito growth-regulator briquets. To produce the briquets, an
insecticide is mixed with carbon and gypsum cement, poured into
plastic trays with numerous quarter-sized molds, cured, and pack-
aged.
"••+• The second manufacturing module is a semiautomated line used
to produce various dry animal health products containing car-
baryl and/or phosmet. The products are formulated in grinding
and milling equipment, stored in tote bags, sampled and analyzed
to assure compliance with product specifications, and packaged.
:"-* The third manufacturing module is a pilot plant configured to for-
mulate and package a product that is used on cow ear tags. A
liquid active ingredient is combined with other raw ingredients in
a mixer and then sprayed onto a clay or granular carrier in a
Munson blender.
"i-+ The fourth manufacturing module is used to formulate and pack-
age a fire ant control product. Liquid active ingredient is mixed in
a kettle and sprayed onto granulated clay material in a Continen-
tal blender. The product is then lifted by an elevator into a hopper,
screened to filter out oversized particles, and packaged into bags.
"••+• The fifth manufacturing module, called the "Pellet Mill System,"
is used to produce pelletized aquatic and pasture herbicides. Ac-
tive ingredients mixed with water, binding agents, and dispersion
agents are sprayed onto a solid carrier as it is mixed in a Marion
paddle blender. The formulated product is transferred via a con-
veyor to a mill where it is pelletized. The pellets are either pack-
aged "raw" or coated with sulfonates (a pulp and paper industry
byproduct) that act as a water-soluble coating to minimize dust
generation during pellet handling. The raw or coated pellets are
gravity fed through an elevator to a hopper and then packaged
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
into bags. Due to the large volume of water incorporated into the
product during the formulating and pelletizing process, the facil-
ity uses a combination of city water and treated water, which is
stored in a 5,000-gallon tank located outside of the laboratory. The
finished product contains 15 to 18% water.
•"•»• The sixth manufacturing module is used to repackage a finished
dry product supplied by the client company from bulk containers
to smaller containers. The product is removed from 2,000-pound
tote bags, agitated if necessary, and packaged into smaller con-
tainers, such as 2-pound application packs.
"••*• The seventh manufacturing module is used to produce a green-
house insecticide product that controls spider mites. The active
ingredient is mixed with three solvents in the first of three steel
formulation vessels operated in series. The product is transferred
to the second vessel where it is tested. Necessary formulation ad-
justments are made in this vessel if the product is found to be off-
spec. The product is then transferred to the third vessel where it is
held for packaging.
:"-* The eighth manufacturing module is the facility's primary liquid
production area. The line is currently configured to formulate and
package a solvent-based insecticide for use on cotton crops.
P2
Ennis Agrotech generates pesticide-containing wastewater from four sources:
(1) interior equipment cleaning; (2) exterior equipment cleaning and floor wash-
ing; (3) drum and shipping container rinsing; and (4) spill and leak cleanups.
The facility uses a local Texas-certified laboratory to analyze all raw materials,
products, and wastes; as a result, no laboratory wastewater is generated on
site. The facility has a stormwater runoff contingency plan, but does not cur-
rently collect precipitation.
Ennis Agrotech achieves zero discharge of all PFPR process wastewater through
a variety of P2 practices and wastewater management techniques. The benefits
associated with these practices include:
1. Enhanced reputation with their customers, due to the reduction of cross-
contamination liability;
2. Reduced raw material (i.e., active and inert formulation ingredients) costs
due to the recovery of these materials during equipment cleanouts; and
3. Positive relationships with local community and with state and federal
regulatory agencies.
Specifically, Ennis Agrotech uses the following P2 practices:
Interior Equipment Cleaning—Process wastewater associated with the for-
mulating and packaging of a given product is minimized through the dedica-
tion of equipment, the use of dry process cleaning equipment, and water
washes using/low; reduction equipment. In addition, effective inventory man-
agement practices enable the facility to maximize interior rinsate storage, and
reuse.
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CHAPTER 8 Case Studies
Pollution Prevention Guidance Manual for the PFPR Industry
Ennis Agrotech dedicates manufacturing modules to specific pesticide classes,
such as fungicides, herbicides, and insecticides, in order to minimize the po-
tential for cross-contamination between pesticide classes and to minimize the
number of product changeover cleaning operations. In addition, when mak-
ing products within the same pesticide class, formulating and packaging equip-
ment is cleaned before product changeover occurs to allay cross-contamination
concerns, and at set intervals during production, if needed. Typically, equip-
ment used to formulate water-dispersible granular products only requires
vacuum cleaning, while equipment used to formulate pellet products usually
requires water washing. The cleaning processes depend on the compatibility
of the pesticide products, and range in scope from multiple rinses to breaking
down all equipment and cleaning to nondetect levels for active ingredients.
Interior equipment cleaning due to a product changeover within a pesticide
class consists of scraping with wire brushes, flushing with the formulation
carrier (such as sand, limestone, or clay) or a solvent wash, and if product
residue or other buildup remains in the equipment, washing with water us-
ing high-pressure (3,500 pounds per square inch)/low-volume (1 gallon per
minute) equipment. About 70 to 80% of the changeovers only require dry
cleaning. The flushed formulation carrier is stored and reused in the next
formulation. If the high-pressure wash step is required, approximately 30 to
35 gallons of water are used to clean the interior of the mixing system. In
some cases, rinsates from interior equipment cleaning operations are collected
and stored for reuse in a subsequent batch of the product.
Ennis Agrotech manages wastewater (and solid
waste) reuse with the same computerized inventory
management control system used to track the stor-
age and use of all raw materials. This system is main-
tained by management personnel assisted by a
"waste movement" consultant. Equipment cleanouts
are documented on "Pre-Cleanout and Decontami-
nation Checklists" (shown in Figure 8-1). Separate
forms are used for each unit and product. Wastes
generated during these cleanouts (including wash
water, solvents, and dry formulation carriers) are col-
lected, weighed, labeled, and stored in the manufac-
turing module; the information is entered into the
computer system. When that product is formulated,
the computer generates a production sheet for that
batch, which tells the operator how much raw ma-
terial to use, including the amount of stored cleaning
material.
AGRICULTURE WAREHOUSE, INC
Pre-Qeanout/Decofrtanunation Checklist
Room*
1. Electrical lockout/layout procedures have been reviewed
By
2. Confined space entry procedures have been reviewed
By
3. Proper procedures for containing, drumming, and labeling (or
disposal of all rinse water have been reviewed
By
4. Proper procedures lor packaging, labeling, and sampling {if
necessary) of all solid material collected have been reviewed
By
5. The following special instructions and/or procedures were covered:
For example, production in the Pellet Mill system (Fig-
ure 8-2) uses a large amount of dry carrier left from
cleaning as raw formulation materials, as well as
cleaning rinsates. The Pellet Mill cleanout procedures
are documented on a checklist (Figure 8-3) that
clearly indicates how each piece of equipment is
cleaned, the type of cleaning materials used, and how
the residual cleaning materials are to be handled.
By
Management Approval By
Figure 8-1. General Pre-Cleanout/
Decontamination Checklist
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CHAPTER 8 Case Studies
Pollution Prevention Guidance Manual for the PFPR Industry
I. MHT1U*'
1. Sprout Wilb.n
OrtnriM
3. L LHtlll-l
4 H... - .1 Uliflr
^ Manon Mi*«'
0. Unnluiv I'ul^l Wi
7 r i-i.nf :-i ••:i]n
tA. Pon»M» Mn|in»r
Prncnr..-; Boom *? Plow Chan
Herbicide Only
* CmlbptFI'
U . HIM 6wt
e r«
. Hun
Nom* Bol'jiion hi* link
ot.
9. Pr:-:i :•• Svaicr Dry*!
in FT»..tinr
Flwiwt t
(Ihc i« * 12
Figure 8-2 Pellet Mill System
Cleaning water from the Pellet Mill production area
is stored in a 5,000-gallon bulk tank and treated
prior to the next production run of the same prod-
uct. The cleaning water is treated using a
microfiltration unit followed by an activated car-
bon filter system. The microfiltration unit is a verti-
cal, poly-type, cross-flow filtration system
manufactured by EPOC Water Systems of Fresno,
California. The Pellet Mill System uses approxi-
mately 12,000 gallons of water during each pro-
duction campaign, of which up to 4,000 gallons is
recycled wastewater; the balance is fresh make-up
water.
The Pellet Mill system cleaning material reuse "cycle"
is illustrated in Figure 8-4.
Exterior Equipment Cleaning—Exterior equip-
ment cleaning wash water and floor wash water
are controlled in the same way as the interior equip-
ment cleaning rinsates. These wash waters are gen-
erated during product changeover (the facility
vacuums the floors and walls at all other times).
The floors and walls are washed with water from
a high-pressure hose. The entire cleaning process
(including both interior and exterior cleaning) usu-
ally requires between 30 and 75 gallons of water.
Wastewater generated during product changeover
b
b
b
b
b
by_
by_
AGRICULTURE WAREHOUSE, INC.
Room 2 Pellet Mfll Clean & Flush
1. PRE-GLEAN
a. Scrape & sweep out pre-mixer
_b. Scrape & sweep out blenders #1 & #2
c. Scrape & sweep out elevators
_ d. Scrape & sweep out mill hopper and auger
e. Disassemble shaker and screens
_f. Dismantle duct work to dryer
_ g. Dust down all duct work pipes
ist ele
_i. Pull buckets from chain elevator
2. WASH
_a. Start at elevators on top of builing, dust & c
_ b. Wash down all duct work
_c. Wash down mill hopper & auger
_d. Wash" and scrape Sprout Walden
_ e. Wash top of dryer
_f. Wash down all platforms and walkways
_g. Wash down blenders #1 and #2
_ h. Wash down oscillator and belt
_ i. Wash down dryer oven, belt and brush
_j. Wash down pre-mixer
_ k. Wash down shker
_ I. Wash small Munson
m. Wash all portable hoppers
n. Wash down frame work in motors
_ o. Wash down bearing housing
_ p. Rinse all areas a - a
A// material to be field
for evaluation by
management, Latie/
and stretchtrrap clean
oat for use In futuro
campaign, rota/ weight
to oe entered into
inventory.
By
All material from wash
to be labeled and
moved to EPOC
System. Tftis wash
should be evaluated by
management prior to
treatment.
BY
3. PROBLEM AREAS
a. Ribbon in pre-mixar, rotate shaft for inspection
_ b. Blades and clamps in paddle blenders, rotate shafts for inspection
_ c. Elevator housings top to bottom
_ d. Milt hoppers, auger, mill face F/na/inspect/on of all
e. Oscillator and belt equipment and
~f. Mill platform recycling of clean out
~ g. Dryer anti wash down.
h. Shaker screens BJF
All areas must be totally cleaned and checked by
supervisor for shift
Figure 8-3. Pellet Mill System Cleanout Procedures
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CHAPTER 8 Case Studies
Pollution Prevention Guidance Manual for the PFPR Industry
Active Ingredients & Inert Formulation
Ingredients
Water
PRODUCTA
TO CUSTOMER
FORMULATION
OF PRODUCT A
FORMULATION
END PLAN
CLEAN OUT
CUSTOMER
ORDER
FOR PRODUCT A
*
a
DRY MATERIAL LIQUID RINSATE
STORAGE STORAGE
FORMULATION
EQUIPMENT
CLEAN OUT
Scraping
COMPUTERIZED
INVENTORY
MANAGEMENT
TRACKING
Clean Out
I Dry Material
WEIGHING AND STORAGE
OF DRY CLEANING MATERIAL
AND
TREATMENT AND STORAGE
OF CLEANING WATER RINSATE
Figure 8-4. Pellet Mill System Cleaning Material Reuse Cycle
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
is collected in a sump and ultimately pumped back into the next product
batch (solids, if present, are strained out). For example, four drums of marked
"rinsate" were present in the mosquito growth-regulator briquets process area
at the time of an EPA plant visit. This water was reused in the next formula-
tion batch of the briquets.
Drum and Shipping Container Cleaning—Ennis Agrotech operated a drum-
rinsing station to minimize the generation of water from drum rinsing op-
erations. Recently, however, the facility has implemented direct reuse of drum
rinsate. into product formulations. Drum shipping containers are triple-rinsed
with the same solvent that is used in the formulation to which the drummed
ingredient is being added. The solvent rinsate is added to the formulation at
the time of the formulation. The drums are then disposed of according to the
customer's instructions.
Spill and Leak Cleanup—Ennis Agrotech uses good housekeeping practices
to reduce waste. Spills and leaks that may occur are cleaned up with adsor-
bent material, which is disposed of off site.
Other—Any wastewater that cannot be reused at Ennis Agrotech is disposed
of off site at the direction of the client. Ennis Agrotech arranges for disposal
based on the client's direction, pays the disposal bill, and then invoices the
client. In some cases, Ennis Agrotech returns the wastewater to the client for
ultimate disposal. For example, rinsate from tank trucks used to transport
active ingredients is sometimes returned to the client.
2:
Facility Overview
MGK operates a combination pesticide manufacturing and PFPR facility that
produces manufacturing-use concentrates. These concentrates are sold to cus-
tomers who formulate them into consumer products for household and lawn
and garden use. The Chaska facility, constructed in 1992, currently includes one
active ingredient manufacturing line dedicated to the production of MGK 264
(n-2-ethylhexyl bicycloheptene dicarboximide), although the facility plans to
move additional manufacturing lines to this location in the future.
In addition, the facility operates several production lines used to formulate,
package, and repackage products containing MGK 264, MGK 326, pyrethrins,
and DEET. The PFPR portion of the Chaska plant consists of a formulating
room, three packaging lines, and a warehousing area. MGK currently holds
approximately 400 product registrations and typically formulates and packages
150 of those products in any one year.
PFPR
The MGK Chaska facility uses MGK 264, as well as other active ingredients
obtained from off-site sources, in the products formulated and packaged on
site. Active ingredients used in formulations that are not manufactured on site
are received in liquid and powder form. Liquid active ingredients are received
in drums and are placed in a heated storage room to ensure the ingredient's
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
flowability until needed for a formulation. Powders are stored in a separate,
enclosed dry formulations area for dust control. Solvent and inert ingredients
are stored in a tank farm located behind the facility.
In the formulating area, raw material active ingredients are stored in dedi-
cated day tanks with dedicated supply lines. The tanks are connected to two
mixing stations equipped with weigh scales. When a custom formulation or-
der is received, the required active ingredient is gravity fed through a dedi-
cated line into a drum, which is positioned on one of the weigh cells. The
appropriate amount of active ingredient, by weight, is pumped from the drum
to a formulation tank, along with water or solvent and any inert ingredients.
The volume of the formulation tanks ranges from 55 gallons to 6,500 gallons.
If the volume of an order is small enough, it may be custom formulated in the
appropriate size shipping container at the mixing station, instead of in a for-
mulation tank. MGK's formulation tanks are dedicated to specific products
or product groups based on estimated product volume requirements, prod-
uct similarity, or product compatibility. Dedication of tanks minimizes the
need for equipment cleaning between product formulations and maximizes
the flexibility of operations.
Formulated product is pumped directly from the tank to the packaging line.
MGK operates three packaging lines for formulated product. Product is pack-
aged into bags, 5-gallon pails, 55-gallon drums, and tote bins. MGK also pro-
vides packaging in bulk form, and is considering 1-gallon packaging. MGK
has the flexibility to reconfigure operations to meet the requirements of any
custom formulation.
The solvent used in the MGK's formulations is methylene chloride. In the
formulations area, a solvent recovery unit (still) is operated to recover meth-
ylene chloride used to clean equipment interiors and raw active ingredient
drums.
Equipment for formulation of dry product is dedicated by chemical type, which
eliminates the need for interior equipment cleaning. Methyiene chloride is also
used in this area to clean raw material tanks and drums, as necessary.
P2
MGK generates pesticide-containing wastewater associated with PFPR opera-
tions from three sources: (1) floor wash water; (2) exterior equipment cleaning
rinsate; and (3) spill and leak cleanup. MGK also generates pesticide-contain-
ing solvent from two sources: (1) interior equipment cleaning; and (2) drum
and shipping container rinsate. Noncontact wastewaters generated at the
Chaska facility and stormwater are collected in a 40,000-gallon stormwater
settling basin. These wastewaters are discharged directly without treatment
through a dedicated sewer line separate from the wastewater sewer line that
handles wastewater discharged from the pesticide manufacturing and PFPR
areas.
MGK incorporated P2 into the original design of the facility and follows cer-
tain wastewater management techniques to achieve P2 at their facility. The
benefits associated with these practices include:
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
1. Reduced raw material (i.e., active and inert formulation ingredient) costs
due to recovery of these materials in rinsates.
2. Reduced disposal costs due to recovery of solvent used for cleaning formu-
lation equipment and raw material drums.
3. Reduced water use; reduced hazards from slips, falls, and chemical resi-
dues; and decreased labor costs associated with floor cleaning through the
use of a floor scrubber.
4. Enhanced corporate image with the local community due to the implementa-
tion of practices that prevent or reduce pollution.
5. Reduced air emissions, leaks, and the need for drip pans through the use of
welded joints instead of flanges in process piping.
Specifically, MGK uses the following P2 practices:
Interior Equipment Cleaning Rinsate—Although MGK product formula-
tions include both solvent-based and water-based formulations, methylene
chloride solvent is used for all interior equipment cleaning operations. The
PFPR operations do not generate any interior equipment cleaning wastewa-
ter. A solvent recovery unit is operated in the PFPR area to recover methylene
chloride for reuse in the formulating processes. The heel from the distillation
unit is disposed of as hazardous waste.
In addition, waste associated with the formulating and packaging of a given
product is minimized through the dedication of equipment, production sched-
uling, and formulating and packaging small batches in containers. MGK
Chaska also uses effective inventory management systems to maximize inte-
rior rinsate storage and reuse.
MGK's Chaska facility uses dedication of equipment in a number of areas to
reduce the need for cleaning equipment, thus reducing waste solvent from
cleaning. Dry formulation equipment is dedicated, which eliminates the need
to clean dry formulation equipment interiors. Many of the bulk raw material
tanks and the piping leading from these tanks to formulating equipment are
dedicated to a specific active ingredient, eliminating the need to clean these
tanks and associated piping. Also, formulating equipment is dedicated by prod-
uct family to reduce the need to clean these tanks and to reduce the possibility
of cross-contamination between incompatible products. The facility also dedi-
cates totes used for special formulations to the specific customer and formula-
tion.
The facility also schedules production runs to minimize the need to clean for-
mulation equipment. For example, the facility may schedule the production of
two different products containing the same active ingredients but at different
concentrations to immediately follow each other, eliminating the need to clean
formulation equipment between the production runs.
MGK formulates small batches of product directly into 55-gallon drums. Piping
that is dedicated by active ingredient feeds to a scale upon which 55-gallon
drums can be placed. The appropriate weight of each active ingredient and
inert is measured directly into the drum. This practice eliminates the use of a
formulation tank and any associated formulation tank cleaning.
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CHAPTEE 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry
The facility also maintains an inventory management system for raw materi-
als, products, and solvents that are recovered for reuse. A computerized sys-
tem is used to keep track of raw materials and products, and to optimize
production runs to minimize cleanings for product changeovers. The facility
also maintains water meters throughout the facility, so that the amount of
water used by the facility used for specific purposes, such as sanitary waters
or cleaning water, can be determined.
Drum/Shipping Container Rinsate—Active ingredient drums are triple-rinsed
with methylene chloride, and the methylene chloride is recovered in the solvent
recovery unit for reuse in PFPR operations. Flow reduction equipment (i.e.,
spray guns) are used to rinse drums to improve the level of cleaning and to
reduce the amount of solvent used in cleaning operations.
Floor Wash Water—The MGK Chaska facility was specifically designed to
allow enough clearance to use a floor scrubber. This mechanical floor washer,
which operates on a 5-gallon recycled reservoir containing water and detergent,
is used to clean the floors in the PFPR area. When this reservoir is replaced with
new water and detergent, the spent cleaning solution is dumped in the floor
drains in the MGK 264 or PFPR process area. In MGK's older facilities, the
floors, which are sloped to a center drain, are sprayed down with water and
soap. Facility personnel stated that this method takes longer and has more
labor cost associated with it, and the floors tend to be more slippery.
Exterior Equipment Cleaning Rinsate—In addition, when deemed neces-
sary by plant personnel, a complete floor and equipment wash is conducted
by spraying walls, floors, and equipment exteriors with water from a hose
equipped with a spray nozzle. This cleaning is typically conducted once per
month. The MGK 264 floor drains, as well as the floor drains in the PFPR
area, feed into an equalization tank, located in the MGK 264 area, which is
ultimately discharged to the local POTW.
Spill and Leak Cleanup—Incorporation of good housekeeping practices at
the facility provides the facility with additional pollution prevention as well
as other benefits. Daily inspection of tanks and equipment for leaks is con-
ducted, and leaks and spills are cleaned up as quickly as possible after being
discovered. In addition, the facility incorporated welded joints instead of
flanges into the facility's design wherever possible to reduce the potential for
leaks and to reduce air emissions. Regularly scheduled maintenance is per-
formed on valves and fittings. The facility was also designed as a closed facil-
ity to minimize the accumulation of dust. When appropriate, material from spill
and leak cleanup operations are processed through the solvent recovery unit.
Other—MGK Chaska has incorporated training and written standard opera-
tion procedures into PFPR operations. Facility employees are provided with
initial training as well as yearly refresher training, which includes training in
pollution prevention and waste minimization. In addition, the facility conducts
bimonthly meetings at which pollution prevention topics are emphasized.
Records of employee training are maintained at the facility. In addition, the
facility has an employee incentive program that bases employee bonuses, in
part, on adherence to pollution prevention procedures.
Documentation of P2 practices include written P2 plans and procedures,
records of facility maintenance and inspections, such as floor washes, and daily
inspections for leaks and spills.
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9
Where to Get Additional P2 Help
This chapter presents additional sources of information, as well as EPA
contacts, that may help the user obtain additional information related
to P2 implementation. Specifically, the chapter presents a list of selected
federal P2 programs, a list of EPA regional P2 contacts, and a list of selected
periodicals and directories relating to P2. These lists also include information
on how to reach EPA program personnel and how to access periodicals and
directories.
For copies of documents directly related to the PFPR effluent guidelines, such
as the Technical Development Document (EPA 821-R-96-019), the Economic
Analysis (EPA 821-R-96-017), the Cost Effectiveness Analysis (EPA 821-R-96-
018), or additional copies of this guidance manual (EPA 821-B-98-017), con-
tact the Office of Water Resource'Center at (202) 260-7786 or by E-mail at:
waterpubs@epamail.epa.gov or fax: (202) 260-0386.
Questions specifically related to the effluent limitations guidelines and stan-
dards for the PFPR industry, including the P2 Alternative Option, should be
directed to:
Ms. Shari Zuskin
Engineering and Analysis Division
Office of Water
U.S. EPA (4303)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-7130
Fax: (202) 260-7185
E-Mail: zuskin.shari@epamail.epa.gov
P2
EnvlroSenSe
Enviro$en$e is EPA's new electronic library of information on pollution preven-
tion, technical assistance, and environmental compliance. With free public ac-
cess to the system, Enviro$en$e is aimed at facilitating the sharing of
technologies and experience across private and public sectors, and encourag-
ing pollution prevention technologies suitable for export. A list of topics
Enviro$en$e contains information on includes:
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CHAPTER 9 Where to Get Additional Help Pollution Prevention Guidance Manual for the PFPR Industry
• Contracts, training opportunities, and news;
• Federal regulations, executive orders, and laws;
• Pollution prevention technical information, databases, initiatives;
• Federal agency and facility information;
• Technology information, databases, and initiatives;
• Funding, grants, and contracts information; and
• International resources.
Other features include E-mail with thousands of environmental professionals
world-wide, electronic registration for EPA training courses, and key word
searching of full text or abstracts.
To access Enviro$en$e:
Via Internet
The address is:
http://www.epa.gov/envirosense/index.html
The World Wide Web hotline number is (208) 526-6956
Via Modem
Set communications to 8, N, 1; Emulation: ANSI or
VT-100. Telephone Number: (703) 908-2092
EPA Headquarters Information Center
The EPA Headquarters Information Resource Center provides information
support services to EPA staff and maintains a varied collection of environ-
mental resources, including CD-ROMs, an online catalog, and other program-
specific services. The library provides services to the general public and develops
several publications, including newsletters and brochures. Library hours are
8:00 a.m. to 5:00 p.m. ET, Monday through Friday. EPA's Online Library Ser-
vice (OLS) is available through telnet: "epaibm.rtpnc.epa.gov". (See Pollu-
tion Prevention Information Clearinghouse (PPIC) and EPA on the World
Wide Web.)
EPA on the
EPA's webserver is the primary public access mechanism on the Internet for
EPA. The webserver provides a range of EPA-generated information in elec-
tronic format, and also offers access to OLS, the national online catalog of the
EPA library network. It includes the catalogs of the Headquarters Informa-
tion Resource Center and all the Regional libraries. The special collection of
the PPIC is cataloged on OLS and is recognized with the call letters "PPC".
Via Internet
EPA's home page on the world wide web:
http://www.epa.gov
EPA's P2 home page on the world wide web:
http://www.epa.gov/opptintr/p2home/
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EPA's Pollution Prevention Branch Program
The Pollution Prevention Research Branch at EPA's National Risk Manage-
ment Research Laboratory supports projects and provides technical assis-
tance to encourage the development and adoption of technologies, products,
and P2 techniques to reduce environmental pollution. Pollution prevention
resources developed by the lab are available through the Technology Transfer
and Support Division at:
Technology Transfer and Support Division
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
Phone (513) 569-7562
Fax: (513) 569-7566
A compilation of summaries of current Branch Projects is available from:
Current Projects: Tomasina Bayliss
National Risk Management Research Laboratory
U.S. Environmental Protection Agency
26 West MArtin Luther King Drive
Cincinnati, Ohio 45268
Phone (513) 569-7748
Fax (513) 569-7566
Technical Service (NTIS)
Located in the U.S. Department of Commerce, the National Technical Informa-
tion Service (NTIS) is the central source for the public sale of U.S. Government-
sponsored research, development, and engineering reports. It is also a central
source for federally generated machine processible data files. It contains re-
ports on air pollution, acid rain, water pollution, marine pollution, marine eco-
systems, land use planning, fisheries management, solar energy, offshore oil
drilling, solid wastes, traffic noise, and radiation monitoring.
For more information, contact:
Chief, Order Processing Branch
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Tel: (703) 487-4650
Fax:(703) 321-8547
(PPD)
The Pollution Prevention Division (PPD) within EPA's Office of Pollution Pre-
vention and Toxics was established in 1988 to integrate a multimedia P2 ethic
within EPA and its developing programs, as well as to provide outreach sup-
port to the public and other government departments. Its primary role is to
ensure that EPA incorporates P2 into ruiemaking efforts and to support P2
efforts by EPA's program offices, EPA Regions, state and local governments,
industry, and the public, in keeping with the Pollution Prevention Act of 1990.
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CHAPTER 9 Where to Get Additional Help Pollution Prevention Guidance Manual for the PFPR Industry
PPD staff are involved with or assist EPA offices in a variety of ongoing
projects, including the Source Reduction Review Project, the Common Sense
Initiative, and Design for the Environment. PPD oversees the Pollution Pre-
vention Information Clearinghouse (see related listing), manages the Pollu-
tion Prevention Incentives for state grants program, and manages EPA's
Environmental Accounting project. In addition, PPD coordinates EPA's work
on environmental labeling issues, the development of guidance for environ-
mentally preferable products, and International Standards, and is a collabo-
rator on EPA's life cycle assessment work.
For more information, contact:
Pollution Prevention Division
Office of Pollution Prevention and Toxics
U.S. EPA (7409)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-3557
Pollution Prevention Information Clearinghouse (PPIC)
The Pollution Prevention Information Clearinghouse (PPIC) was established by
EPA in response to the Pollution Prevention Act of 1990 to promote source
reduction. It is a free service containing technical, policy, program, and legisla-
tive information relating to P2 and source reduction. PPIC has three primary
functions: (1) acting as a distribution center for documents; (2) maintaining a
telephone hotline to take document orders and refer callers to other EPA infor-
mation resources; and (3) maintaining a library collection of documents and
publications relating to P2, waste minimization, and alternative technologies.
The library collection is available for browsing in the EPA Office of Pollution
Prevention and Toxics (OPPT) Library during visitor hours (8:30 a.m. to 4:00
p.m. ET) and through EPA's Online Library System (OLS) (See EPA HQ In-
formation Resource Center above). PPIC currently publishes a list of avail-
able P2 resources that they distribute free of charge.
Some highlights of the resources available from PPIC:
Pollution Prevention Directory. Directory of publicly sponsored pollution
prevention sources and state contacts available across the United States.
Pollution Prevention Publications List. EPA fact sheet, updated periodically,
including forms for ordering documents. Available through PPIC, (202) 260-
1023.
Pollution Prevention News. Free bimonthly newsletter on pollution preven-
tion topics, including reports from EPA offices, people and places in the news,
state programs, and calendar of conferences and events.
Also available through PPIC are environmental accounting documents and
software, particularly spreadsheet software for "P2/FINANCE" (Pollution
Prevention Financial Analysis Cost Evaluation). This is a spreadsheet system
for conducting financial evaluations of current and potential investments.
P2/FINANCE differs from conventional capital budgeting tools because it
expressly addresses traditional obstacles to the financial justification of pollu-
tion prevention. (P2) investments. Specifically, it expands the cost and savings
inventory to include indirect and less tangible environmental costs, and uses
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CHAPTER 9 Where to Get Additional Help
Pollution Prevention Guidance Manual for the PFPR Industry
profitability indicators and time horizons that capture the longer-term sav-
ings typical of pollution prevention investments. It runs with either Lotus
1-2-3 Version 3.4a for DOS or Microsoft Excel Version 5.0 for Windows. (EPA
742-C-96-001/002)
For more information, contact:
Pollution Prevention Information Clearinghouse
U.S. EPA (MC 7409)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-1023, Fax: (202) 260-4659, E-mail: ppic@epamail.epa.gov
EPA Regional P2 Contacts
Contacts* for general P2 assistance are listed by each EPA Regional Office:
Region Address Name Telephone
Fax
8
10
JFK Federal Building
Boston, MA 02203
(617) 565-3420
(2-OPM-PPI)
290 Broadway
New York, NY 1007-1886
(212) 637-3000
841 Chestnut Building
Philadelphia, PA 19107
(215) 566-5000
345 Courtland Street, NE
Atlanta, GA 30365
(404) 562-8357
(HRP-8J)
77 W. Jackson Boulevard
Chicago, IL 60604-3590
(312) 353-2000
1445 Ross Avenue, Suite 1200
Dallas, TX 75270
(214) 665-6444
726 Minnesota Avenue
Kansas City, KS 66101
(913)551-7000
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 312-6312
75 Hawthorne Street, (H-l-B)
San Francisco, CA 94105
(415) 744-1305
1299 Sixth Avenue (MD-142)
Seattle,.WA 98101
(206) 553-1200
Abby Swaine
Mark Mahoney
Janet Sapadin
Jeff Burke
Cathy Libertz
Connie Roberts
Phil Kaplan
Marc Matthews
Linda Walters
(617) 565-4523
(617) 565-1155
(212) 637-3584
(215) 597-8327
(215) 597-0765
(312) 353-4669
Robert Lawrence (214) 665-6568
Linda Thompson (214) 665-6568
(913) 551-7517
(303) 312-6385
Bill Wilson (waste (415) 744-2192
minimization)
Eileen Sheehan (water) (415) 744-2190
(617) 565-3346
(212) 637-5045
(215) 597-7906
(404) 562-9084 (404) 562-9066
(312) 353-5374
(214) 665-7446
(913)551-7065
(303) 312-6339
(415) 744-1796
Carolyn Gangmark (206) 399-4072 (206) 553-4957
'Individual contacts may change over time; in such an event, call the main region phone number listed under the address.
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Access EPA. Directory published by EPA's Office of Information Resources
Management. Includes public information tools, major EPA dockets, clear-
inghouses and hotlines, library and information services, state environmental
libraries, and EPA acronyms. 1993 edition, EPA 220-B-008. Available from
the EPA HQ Information Resource Center, U.S. EPA (3404), 401 M Street SW,
Washington, DC 20460. Superintendent of documents, P.O. Box 371954, Pitts-
burgh, PA 15250-7954, Cost $24.
Guide to Pollution Prevention Funding Organizations. Directory of public
and private organizations that fund pollution prevention research. Available
from Pacific Northwest Pollution Prevention Research Center, 1218 Third Av-
enue #1205, Seattle, WA 98101. Tel: (206) 223-1151.
Pollution Prevention Review. Quarterly journal on source reduction and waste
minimization, with emphasis on technical and institutional issues encountered
in. industrial settings. Available from Executive Enterprises, Inc., 22 West 21st
Street, New York, NY 10010-6990. Tel: (800) 332-8804.
Pollution Prevention Update. Highlights federal legislation, EPA initiatives,
roundtable activities, and state pollution prevention program activities. Avail-
able from the National Pollution Prevention Roundtable, 218 D Street SE, Wash-
ington, DC 20003. Tel: (202) 543-7272.
Pollution Prevention Yellow Pages. Lists arid describes state and local pollu-
tion, prevention programs. Available from National Pollution Prevention
Roundtable, 218 D Street SE, Washington, DC 20003. Tel: (202) 543-7272.
Public Information Center Publications List. List of publications available
from the EPA HQ Information Resource Center, U.S. EPA (3404), 401 M
Street SW, Washington, DC 20460.
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CHAPTER 10
Workshop Questions and Answers
Introduction
EPA conducted five two-day workshops from July through September 1997 in
Chicago, IL, Atlanta, GA, Dallas, TX, Portland, OR, and Kansas City, MO to
help facilitate understanding of the final PFPR rule. The information presented
in the workshops mirrored the information presented in this P2 Guidance
Manual. In addition, at each workshop, participants were able to walk through
a P2 audit exercise and attend breakout sessions that presented more in-depth
material on various key aspects of implementation of the rule. Most impor-
tantly, the workshops offered participants the opportunity to ask questions
directly of EPA about the final PFPR rule.
This chapter includes questions that were asked at the five workshops and
presents EPA's responses to these questions. EPA attempted to address all
questions that were asked; some questions were consolidated because the same
or very similar questions were asked at multiple workshops. The questions
and answers are grouped by topic; a table of contents is included on the next
page for ease of finding topics of interest.
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Contents
Applicability
General 105
Facility Operations 105
Pesticide Active Ingredients and Pesticide Products 108
PFPR Wastewater 113
Zero Discharge
General 115
Potential to Discharge 117
P2 Alternative
General 118
P2 Practices/Best Management Practices 118
Listed Modifications to P2 Practices 123
Nonlisted Modifications 123
P2 Audit 124
P2 Allowable Discharge 125
Treatment/Treatability Issues
Wastewaters Requiring Treatment 126
Treatment Technology Operations 126
Determination of Treatment Equivalency 130
Treatability Testing 133
Sampling/Monitoring 134
EPA Test Methods 136
Determination of Sufficient Treatment 137
Well Operated Treatment Systems 141
Compliance
Baseline Monitoring Report 141
P2 Alternative/Allowable Discharge 143
Necessary Paperwork 144
Permit/Control Mechanism Issues 148
Potential to Discharge 153
Compliance Time Line 154
Other Questions 157
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Pollution Prevention Guidance Manual for the PFPR Industry
Applicability
General
How many facilities are covered
under the scope of this rule? How
many discharge wastewater?
EPA estimates that there are 2,631 facilities covered by the
PFPR rule, 443 of which discharge wastewater.
Facility Operations
How is toll formulating defined?
If an industry (i.e., a facility)
formulates a product, but does not
sell the product, is that operation
covered?
Formulation pilot (i.e., R&D)
facilities may also produce (for
sale) formulations in smaller
quantities until a contract/toll
formulating arrangement can be
established. Since these pilot
facilities change over frequently
and have a small portion of
commingled wastewater from
formulating operations, are they
covered under the PFPR
regulation? If so, can a control
authority grant a waiver to this
type of facility?
There is no regulatory definition of "toll formulating". Toll
formulators, as referred to by the PFPR rule, typically formu-
late, package, or repackage one or more products under con-
tract to another registrant. The toll formulator does not own
the registrations for these products. In addition, they may have
multiple contracts of varying length with several different
companies at the same time.
Registrants typically use toll formulators for one or more of
the following reasons:
• The toll formulator has specialized equipment for the for-
mulating or packaging of a product;
• The registrant does not have room at their facility to formu-
late, package, or repackage the product; or
• The registrant wishes to avoid potential cross contamination
concerns by segregating incompatible products (e.g., herbi-
cides and insecticides).
Yes, if the operation meets the definition of formulation of an
in-scope product/pesticide active ingredient, it is covered. It
does not matter whether the facility sells that product or uses
it internally. More specifically, the facility must have the po-
tential to discharge in-scope process wastewater from PFPR
operations to be covered by the rule.
Research and development facilities are not covered by the
PFPR rule. In addition, these facilities cannot sell unregistered
experimental pesticide products in the United States without
an Experimental Use Permit (EUP) granted by EPA. Therefore,
if the facility is producing a formulation for "sale" under a EUP
for that product, the facility is still performing R&D activities,
which would not be covered under the PFPR rule. However,
if the facility is producing an in-scope formulation for sale in
the U.S. as a registered product (or outside the U.S. without
registration), these formulation activities would be covered un-
der the PFPR rule.
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Why are R&D laboratories and
operations exempted from the
rule? These operations, due to the
use of new compounds and
formulations, appear to be
potentially more dangerous
polluters than PFPR operations
that have existing controls,
especially since the volume of
wastewater generated does not
necessarily increase or decrease
the pollutant load.
In general, research and development activities at PFPR facili-
ties do not generate the same wastewater volumes or pollutant
loads that are found in manufacturing R&D facilities. They are
generally very small operations that develop a new pesticide
product or a new formulation (e.g., concentrate, solution
ready-to-use, microencapsulated) of an existing product. They
cannot store and reuse rinsates for two main reasons: experi-
mental controls and they only make the product one time or
in one set of trials.
In addition, in a large number of effluent guidelines, including
the Pesticide Chemicals Manufacturing Point Source Category,
R&D activities are not covered by the rule and can be regulated
on a best professional judgement BPJ basis.
Whose responsibility is it to
dispose of wastewater generated
by contract packagers? For
example, a company formulates a
dry granular product containing
atrazine and sends it to another
company to package.
Is repackaging of pesticide active
ingredients as both pesticide and
nonpesticide products covered
under the PFPR standards no
matter what the product?
If a facility repackages a pesticide
active ingredient in a container for
ultimate sale, are they covered
under Subcategory C or
Subcategory E?
Are farm cooperatives that supply
products to farmers covered by
Subcategory E regulations?
Are farmers who repackage
pesticide products into smaller
containers for delivery to parts of
the farm covered by Subcategory
E regulations?
It is the responsibility of the facility that performs the covered
activity to comply with this rule, including all paperwork re-
quirements. Using the example in the question, the packager
would be required to comply for all in-scope wastewaters gen-
erated during or associated with their packaging operation.
No, only products that are pesticides and that meet the appli-
cability of the PFPR rule are covered by the standards. Non-
pesticide products that may contain the same active
ingredients are not covered by the rule.
This answer assumes that the product is not exempt from the
PFPR rule. If the product that is repackaged is an agricultural
pesticide product and is packaged in a refillable container and
the facility is not performing other pesticide formulating or
packaging operations, then the production is covered under
Subcategory E. Otherwise, the production is covered under
Subcategory C.
Yes, if those cooperatives formulate, package, or repackage
pesticide products that are covered by the scope of the rule,
and discharge or have the potential to discharge the resulting
wastewater. Many farm cooperatives package pesticides from
bulk into smaller minibulk (refillable) containers that are de-
livered to the end user (i.e., the farmer). The water used to
clean/rinse these minibulk containers is a covered wastewater
under the rule (Subpart E).
No. End users of the pesticide products are not covered by
either Subcategory C or E regulations.
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Are applicators covered by this
rule?
Is an applicator formulating a
product for its own use covered
under this rule?
Are aerial applicators/crop dusters
covered by this rule?
Less than 0.25% of a facility's
operation is the repackaging of
pesticides. Is the facility covered
by the rule?
Do all pesticide active ingredient
drums require rinsing?
Is wastewater from remedial
actions (e.g., groundwater
remediation operations) occurring
at a current or former PFPR
facility covered by these
categorical standards?
If a facility blends a pesticide
product with something else (e.g.,
grass or fertilizer), is that
production covered by the rule?
Are facilities required to rinse
inert drums?
In general, no. Wastewater generated from application of pes-
ticide products is not covered. Therefore, if the only operation
is application of the pesticide, they are not covered by the rule
(applicators are the end user). However, if they also formulate,
package, or repackage products, the wastewater from the for-
mulation, packaging, and repackaging operation is covered.
If the product is a registered FIFRA pesticide product or meets
the definition of making a pesticidal claim rule (see page 57549,
§455.40 of the preamble to the final rule in Appendix A for a
discussion of pesticidal claim, as well as 40 CFR 152.8, 152.10,
and 152.15) AND is being formulated as a manufacturing or
end use product (§455.10(1)) for use in the U.S. and is not
exempt from the PFPR rule, then the wastewater from formu-
lation is covered by the rule. However, the wastewater from
application services is not covered by the rule.
No, wastewaters related to custom application services are not
covered by this rule (see 40 CFR 455.60(b)).
Yes, the wastewater from such in-scope repackaging opera-
tions is covered if the facility discharges or has the potential
to discharge process wastewater from their repackaging opera-
tions. There is no de minimis production exemption.
The PFPR rule does not require rinsing of any drums or equip-
ment, although other regulations (e.g., 40 CFR 165.9 in FIFIRA
or 40 CFR 261.7(b)(3)) may require specific rinsing procedures
for certain drums containing pesticide active ingredients or
certain hazardous wastes. However, if a facility rinses these
drums, the wastewater generated is subject to the PFPR rule.
No, wastewater from remedial actions does not meet the defi-
nition of process wastewater. However, any treatment stand-
ards for the discharge of such wastewaters that may be
established through a remedial process may take into account
the PFPR regulation.
Yes, unless the operation is considered a custom blending op-
eration, as defined in 40 CFR 167.3.
No. The rinsing of drums containing pesticide active ingredi-
ents or inerts or other raw materials is not required by the
PFPR rule. However, if a facility does rinse their drums, the
wastewater generated by those rinsing operations is covered
by the rule.
Note that FIFRA (40 CFR 165.9(b)) requires that Group II con-
tainers (noncombustible containers which formerly contained
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Pollution Prevention Guidance Manual for the PFPR Industry
organic or metallo-organic pesticides, except organic mercury,
lead, cadmium, or arsenic compounds) should first be triple-
rinsed before reuse or disposal. Also, there are certain RCRA
regulations which require rinsing of containers that have held
certain types of hazardous waste (40 CFR 261.7(b)(3)).
Pesticide Active Ingredients and Pesticide Products
Is "Neem Oil," an active
ingredient similar in application
to citronella, covered by the rule?
Are Group I chemicals exempted
because they are exempted from
FIFRA?
Are pool chemicals exempt from
the rule?
Please clarify the sanitizer
exemption, specifically for those
products that are considered
sanitizers, but are not exempted
from the PFPR rule by the
sanitizer exemption.
EPA excluded two groups of chemical mixtures from the final
rule. The first group is defined at 40 CFR Part 455.10 (j) as "any
product whose only pesticidal active ingredient(s) is: a com-
mon food/food constituent or nontoxic household item; or is
a substance that is generally recognized as safe (GRAS) by the
Food and Drug Administration (21 CFR 170.30, 182, 184, and
186) in accordance with good manufacturing practices, as de-
fined by 21 CFR Part 182; or is exempt from FIFRA under 40
CFR 152.25." EPA believes that citronella is exempt from the
PFPR rule as a Group I mixture. Neem oil is an oil extract from
the seed kernels of the Indian Neem tree. If neem oil also meets
the Group I mixture definition, it is also excluded from the
rule.
EPA also excluded a second group of chemical mixtures, but
did not develop a definition for this group. The Group 2 mix-
tures are listed in Table 9 to Part 455; however, because Neem
Oil is not listed there, it is not excluded as a Group 2 mixture.
Some of the Group 1 chemicals are exempted from certain
FIFRA reporting and registration requirements under 40 CFR
152.25; however, Group 1 mixtures also include products
whose only pesticide active ingredients are chemicals that are
common food/food constituents or nontoxic household items
or substances generally recognized as safe (GRAS) by the Food
and Drug Administration (21 CFR 170.30,182,184, and 186) in
accordance with good manufacturing practices, as defined by
21 CFR Part 182.
Yes. Pool chemicals (as defined in 40 CFR 455.10(q)) are exempt
from this rule (40 CFR 455.40(d)).
The exempted sanitizer products, as defined in section 455.10,
are "pesticide products that are intended to disinfect or sani-
tize, reducing or mitigating growth or development of micro-
biological organisms including bacteria, fungi, or viruses on
inanimate surfaces in the household, instritutional, and/or
commercial environment and whose labeled directions for use
result in the product being discharged to ... POTWs. This
definition shall also include sanitizer solutions as defined by
21 CFR 178.1010 and pool chemicals as defined in section
455.10(q). This definition does not include liquid chemical ster-
ilants (including sporicidals) exempted by section 455.40(f) or
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Does chlorine gas meet the
definition for exemption as an
inorganic wastewater treatment
chemical?
Why is EPA interested in tracking
inert materials in a P2 audit? Are
inert materials covered under the
PFPR regulation?
What kind of treatment is
required for inert materials?
If a pesticide active ingredient
that a facility uses is not listed in
Table 10, does that mean it is not
covered by this rule or it does not
require treatment?
otherwise, industrial preservatives, and water treatment micro-
biocides other than pool chemicals."
In other words, sanitizers, as defined (and including pool
chemicals), are exempt from the rule when their labelled di-
rections for use (not disposal) result in discharge to POTWs.
The rule still covers certain liquid chemical sterilants, indus-
trial preservatives, and water treatment microbiocides other
than pool chemicals (e.g., cooling tower or boiler treatment
microbiocides). If one product is registered for use as a sani-
tizer, pool, and cooling tower product, is it exempt from the
rule?
In general, EPA intends to cover cooling tower biocides under
this rule. However, if one product recipe (i.e., registered for-
mulation) has the multiple uses listed above (meaning the
chemical is used in the same concentration (percent active in-
gredient) in both sanitizer and cooling tower uses), the regis-
trant can request their Regional Office or EPA's Office of Water
to determine whether the wastewater resulting from the for-
mulation, packaging, or repackaging of such a product is ex-
empt from this rule. EPA has determined that sodium
hypochlorite is not subject to the PFPR guideline. Contact in-
formation is provided in Chapter 9 of this guidance manual.
Chlorine gas is exempt from the final PFPR rule if it is used in
wastewater treatment operations.
Inert materials are covered in discharges from PFPR operations
if they are also priority pollutants. However, the reason EPA
suggests tracking inert materials during the P2 audit is to iden-
tify possible contaminants in wastewater that will require treat-
ment prior to discharge or to identify characteristics that may
hinder effective treatment of pesticide active ingredients or
priority pollutants.
The PFPR rule requires treatment of pesticide active ingredi-
ents and priority pollutants. No specific treatment technology
has been listed for inert materials, although activated carbon
is effective for many organic priority pollutants.
Are fertilizers covered by the rule? No.
No. Table 10 is not a list of all covered pesticide active ingre-
dients; it was developed to aid facilities, permit writers, and
control authorities in identifying appropriate treatment tech-
nologies for existing pesticide active ingredients. In order to
determine whether your pesticide active ingredient is covered
by the rule, you must review the rule applicability statements
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If a facility adds a biocide to their
product (e.g., adhesives), is it
covered under the rule?
As new pesticide active
ingredients come on the market,
how does one determine if they
are covered by this rule or
whether they require treatment?
If certain chemicals (e.g., zinc,
copper) are used for both
pesticide and nonpesticide
products, is the facility covered
under the PFPR categorical
standards only when they blend
these items with inert materials to
produce a product specifically
marketed as a pesticide product?
Does the PFPR rule apply to
herbicide growth regulators and
surfactants that may contain toxic
chemicals?
found in III.A (page 57523) of the final rule, located in Appen-
dix A of this guidance manual.
In order to determine the appropriate treatment technology for
pesticide active ingredients not listed in Table 10, the facility
and control/permitting authority must use best professional
judgement (BPJ).
If the facility claims that the final product has pesticidal quali-
ties (because of the addition of the biocide), the product would
be covered by the PFPR rule.
If the facility adds the biocide as a preservative (to protect the
quality of their product), and therefore is the end user of the
biocide, then the product is not covered under the PFPR rule.
If the pesticide active ingredient or product is a pesticide as
defined in FIFRA regulations (i.e., there is a pesticidal claim
made regarding that pesticide active ingredient or product)
and the pesticide active ingredient/product will be formu-
lated, packaged, or repackaged into a pesticide product that is
not exempted from the rule, then the pesticide active ingredi-
ent/product is covered by this rule (see page 57549, §455.40 of
the preamble to the final rule in Appendix A for a discussion
of pesticidal claim, as well as 40 CFR 152.8,152.10, and 152.15).
Also, the facility must have the potential to discharge waste-
water associated with in-scope PFPR production to be covered
by these PFPR effluent guidelines.
If wastewater containing a new pesticide active ingredient is
covered under the rule, treatment technologies can be deter-
mined by identifying the technology for a pesticide active in-
gredient with a similar chemical structure or through
treatability testing.
The PFPR rule covers the formulating, packaging, and repack-
aging of pesticide products that meet the applicability of the
PFPR rule. Nonpesticide products that may contain the same
active ingredients are not covered by the rule. See Chapter 1
of this document for definitions of formulating, packaging, and
repackaging.
The PFPR rule applies to all pesticide products that are formu-
lated, packaged, or repackaged and are not specifically ex-
empted from the rule. FIFRA regulations provide the following
definitions for pesticide and pesticide product (40 CFR 152.3),
as well as pest (40 CFR 152.5):
Pesticide means any substance or mixture of substances in-
tended for preventing, destroying, repelling, or mitigating any
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If a chemical can be shown not to
pass through a publicly owned
treatment works (POTW), can that
chemical be exempt from the
PFPR rule?
pest, or intended for use as a plant regulator, defoliant, or
desiccant, other than any article that:
(1) Is a new animal drug under FFDCA Sec. 201 (w), or
(2) Is an animal drug that has been determined by regulation
of the Secretary of Health and Human Services not to be a new
animal drug, or
(3) Is an animal feed under FFDCA Sec. 201(x) that bears or
contains any substances described by paragraph (s)(l) or (2) of
this section.
Pesticide product means a pesticide in the particular form (in-
cluding composition, packaging, and labeling) in which the
pesticide is, or is intended to be, distributed or sold. The term
includes any physical apparatus used to deliver or apply the
pesticide if distributed or sold with the pesticide.
Pest means an organism is declared to be a pest under circum-
stances that make it deleterious to man or the environment, if
it is:
(a) Any vertebrate animal other than man;
(b) Any invertebrate animal, including but not limited to, any
insect, other arthropod, nematode, or mollusk such as a slug
and snail, but excluding any internal parasite of living man or
other living animals;
(c) Any plant growing where not wanted, including any moss,
alga, liverwort, or other plant of any higher order, and any
plant part such as a root; or
(d) Any fungus, bacterium, virus, or other microorganisms,
except for those on or in living man or other living animals
and those on or in processed food or processed animal feed,
beverages, drugs (as defined in FFDCA sec. 201(g)(l)) and cos-
metics (as defined in FFDCA sec. 201(i)).
Growth regulators are considered pesticides as defined in the
FIFRA regulations. Therefore, the in-scope wastewater associ-
ated with the PFPR of growth regulators would be covered by
the PFPR rule. Surfactants are generally inert, not active, in-
gredients of the pesticide product; therefore, when formulated
into a pesticide product as an inert material, the surfactant isn't
specifically covered, but wastewater associated with the PFPR
of the pesticide product (which contains the surfactant) would
be covered, as long as the pesticide active ingredient (or the
product as a whole) is not exempt from the regulation.
The P2 alternative allows some amount of discharge when a
facility is following certain P2 practices set out by this rule and
is performing treatment where required by the rule, even if the
chemical is deemed to pass through. A facility can perhaps also
obtain removal credits from the POTW/control authority for
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How does a facility demonstrate
that a pesticide active ingredient
does not pass through the POTW?
What about the pesticide active
ingredient limits that were
developed for regulation of the
pesticide manufacturing industry
(58 FR 50637)?
a particular chemical (see page 57547 of the preamble to the
final PFPR rule in Appendix A). Basically, once compliance
with 40 CFR Part 403.7 (removal credit regulations) is shown
and removal credit authority is granted, the control authority
can remove the requirement for pretreatment of the pollutants
that remain in a PFPR facility's wastewater discharge after all
applicable P2 practices have been implemented and those pol-
lutants can be demonstrated to neither pass through nor inter-
fere with the operation of the POTW (in accordance with 40
CFR 403 provisions). The PFPR industrial user would also have
to continue to comply with the pollution prevention practices
as specified in the P2 alternative even if a removal credit has
been provided. Note that four organic chemicals considered to
be priority pollutants (phenol, 2-chlorophenol, 2,4-dichlo-
rophenol, and 2,4-demethyl phenol) are already excluded from
pretreatment standards of this regulation because they do not
pass through a POTW.
As defined at 40 CFR 403.3, pass-through occurs when a POTW
violates their NPDES permit. Pass-through of pesticide active
ingredients cannot be shown in this manner unless the POTW
has limits for specific pesticide active ingredients or has whole
effluent toxicity limits (and a toxicity event can be tied to one
or more pesticide active ingredients).
The POTW can also make a separate determination whether
pesticide active ingredients that are discharged from industrial
users are pollutants that could potentially pass through. In
this analysis, the POTW measures the level of pesticide ac-
tive ingredient in both the POTW's influent and effluent. The
pesticide active ingredient must be detected in the influent to
determine whether pass through occurs. In addition, the
POTW can decide whether the presence of the pesticide active
ingredient adversely impacts the POTW's treatment opera-
tions. If the POTW determines that the pesticide active ingre-
dient either passes through or adversely impacts operations,
local limitations may be assigned.
The limitations developed for the pesticide manufacturing in-
dustry covered a much smaller scope of chemicals than the
PFPR rule. In addition, the mass-based limitations for the
manufacturing industry were developed based on the variabil-
ity of their wastewaters. PFPR wastewaters can be more vari-
able than pesticide manufacturing wastewaters; therefore, in
some cases, it may not be appropriate to transfer the limitation
to the PFPR industry. However, it may be possible and desir-
able for a pesticide manufacturer to receive an additional al-
lowance in their discharge for their PFPR wastewater by
applying the pesticide manufacturing limits to the additional
production associated with PFPR operations after the facility
has incorporated the listed P2 practices into their PFPR opera-
tions.
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PFPR Wastewater
What is the difference between
drum rinsates and interior
equipment rinsates and their
respective P2 practices?
Does formulating equipment
interior cleaning include the
cleaning of piping and hosing,
too?
What if a facility produces a
water-based product followed by
a solvent-based product? The
facility cleans the equipment with
water, followed by alcohol, prior
to formulating the solvent-based
product. Is the alcohol rinse
covered by the PFPR rule? Since
the water picked up in the alcohol
rinse evaporates, is there anything
to preclude reusing the alcohol
continuously?
Are cleaning waters from a bulk
tank that contains a material used
in both pesticide and nonpesticide
products covered under this rule?
Both are defined as interior wastewater sources (which require
treatment prior to discharge); however, they are different
sources. Drum rinsates are generated from the cleaning of raw
material drums and can typically be used immediately in the
product formulation. Drum cleaning also includes the cleaning
of shipping containers that may be returned to the shipping
facility. The listed P2 practices for drum rinsing include direct
reuse, storage and reuse, or use of a countercurrent drum rins-
ing station.
Interior equipment cleaning rinsates are generated from the
cleaning of equipment used to formulate, package, or repack-
age products following the formulation, packaging, or repack-
aging of the product. Therefore, facilities are more likely to
store these rinsates for reuse in the next formulation of the
same or compatible product. The listed P2 practice for interior
equipment rinsates is storage and reuse.
Yes.
There is nothing to preclude reusing the alcohol continuously,
and achieving zero discharge for this cleaning operation. If the
facility is not able to reuse the alcohol for some reason, they
may choose to dispose of it. In that case, the alcohol rinse is
not considered a wastewater covered by the PFPR rule, but
would be subject to applicable solvent disposal regulations.
However, the P2 alternative encourages facilities to segregate
their solvent-based and water-based production to avoid the
generation of non-reusable rinsates requiring disposal.
Do DOT test bath waters require
treatment?
Yes. The intent of the rule is to cover wastewater associated
with pesticide production; therefore, cleaning rinsates of a bulk
tank containing a material used in PFPR production would be
covered under the PFPR rule.
If the facility has more than one bulk storage tank for a par-
ticular material, and can specify that only material from certain
tanks are used in PFPR production, then only the rinsate from
those tanks is covered under the PFPR rule; however, if the
facility cannot make this distinction, then rinsate from all tanks
containing that material is covered by the rule.
No; however, under the P2 alternative, DOT test bath water
from continuous overflow baths must include some recircula-
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If a facility manufactures a
pesticide active ingredient and
formulates a product with the
same pesticide active ingredient,
is the laboratory exemption only
applicable to the PFPR laboratory
wastewater?
If a facility only has safety
showers and eye washes, is it
within the scope of the
regulation? If so, what are the
implications of this rule?
tion or be a batch bath. Otherwise, they must meet zero dis-
charge.
Yes.
Are wastewaters associated with
the cleaning of coveralls covered
by the rule?
Are water emissions from research
and development pilot plant
operations exempt from the rule?
Is storm water completely exempt
from regulation? What about
contaminated storm water from
diked areas?
Assume a facility stores all
rinsates in an outdoor storage
tank. Are leaks and spills from
that tank covered, since storm
water is not covered?
Determining whether the facility is within the scope of the
regulation depends on whether they have a potential to dis-
charge process wastewater. EPA's Pretreatment Bulletin #13
(see Appendix E) states that it is possible to discharge non-
covered wastewater streams, in this case safety showers and
eye washes, in such a way that there is no potential for the
facility to also discharge process wastewater. However, if the
noncovered wastewater sources are located in an area (e.g., a
formulating area), where it is possible for the noncovered
wastewater discharge to become contaminated with process
wastewater, then the facility has a potential to discharge and
is within the scope of the regulation. Documentation that
would be required would depend on the facility's potential to
discharge.
On-site laundry operations are not covered under the scope of
this rule.
Yes. See 40 CFR 455.40(e) of the final rule.
Storm water is exempt from coverage under the final PFPR
rule (61 FR 57524), and therefore is not subject to the P2 prac-
tices and treatment requirements of that rule. However, a fa-
cility's storm water discharges are covered under Phases I or
II of the General Storm Water Regulations (61 FR 57524).
Leaks and spills are covered by this rule. All leaks and spills
must be cleaned up in a timely fashion, as discussed in P2
alternative practice #2 (61 FR 57553). Leaks and spills in out-
door storage tanks should be cleaned up prior to storm events;
the resulting storm water is not covered by the rule.
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Zero Discharge (see also Compliance—Potential to Discharge)
General
Does EPA have guidance on the
PFPR rule available for zero
discharge facilities? Are zero
dischargers covered by the rule?
The legal basis of this rule (i.e., the basis used to determine
whether a facility is covered by the rule) is the potential to
discharge process wastewater pollutants. A PFPR facility is a
categorical industrial user (CIU) and is subject to the PFPR
regulations of "no discharge of wastewater pollutants" (or the
P2 alternative) when there is a potential to discharge any PFPR
process wastewater covered by the PFPR regulation. If a facil-
ity has no potential to adversely affect a POTW's operation or
violate any pretreatment standard or requirement due to acci-
dental spills, operational problems, or other causes so that no
regulated process wastewater can reach the POTW, then the
facility is not covered under the PFPR rule and it is not legally
required at the Federal level for these facilities to submit pa-
perwork (i.e., BMR). In addition, if the only wastewater that a
PFPR facility discharges (or has the potential to discharge) is
not a regulated process wastewater under the PFPR effluent
guidelines (e.g., sanitary wastewater, employee showers, laun-
dry water), then the PFPR facility is not covered by the PFPR
effluent guidelines and the facility is not a CIU for that dis-
charge for purposes of 40 CFR Part 403 (General Pretreatment
Standards).
Facilities that are meeting zero discharge, but do have the po-
tential to discharge, are covered by the rule. However, they are
currently in compliance with the zero discharge portion of the
rule. These facilities must submit all paperwork required by
the rule for facilities that choose to comply with zero discharge,
including a BMR.
A PFPR facility that employs 100% recycle or claims no dis-
charge of regulated PFPR process wastewater should be thor-
oughly evaluated through an on-site inspection to determine
if there is any reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard
or requirement due to accidental spills, operational problems,
or other causes. If the control authority concludes that no regu-
lated process wastewater can reach the POTW (i.e., there is no
potential to discharge), and therefore the PFPR facility has no
reasonable potential for adversely affecting the POTW's opera-
tion or for violating the PFPR effluent guidelines, then the
PFPR effluent guidelines are not applicable to that PFPR facil-
ity
However, EPA Pretreatment Bulletin #13 (see Appendix E) sug-
gests that the control authority issue an individual control
mechanism containing the following conditions:
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Can a facility comply with zero
discharge by showing pollutant
levels below detection limits (for
pesticide active ingredients and/or
priority pollutants) in their
effluent? If so, what kind of
implications are there for
enforcement (e.g., what happens if
on occasion a facility discharges a
pollutant above the detection
limit)?
Why is zero discharge defined as
"no discharge of process
wastewater pollutants"?
Does "no discharge of process
wastewater pollutants" refer only
to the pesticide active ingredients
and priority pollutants?
Does a facility need to say they
are implementing the P2
alternative if they totally reuse
their wastewater, or if they do not
generate wastewater because they
use a solvent to rinse equipment?
No discharge of process wastewater is permitted;
Requirements to notify the POTW of any changes in opera-
tion resulting in a potential for discharge;
Requirements to certify semiannually that no discharge has
occurred;
Notice that the POTW may inspect the facility as necessary
to assess and assure compliance with the "no discharge"
requirement; and
Requirements to comply with Resource Conservation and
Recovery Act (RCRA) and state hazardous waste regulations
regarding the proper disposal of hazardous waste.
A facility may comply with zero discharge by demonstrating
that all pesticide active ingredients and priority pollutants are
below their method detection limits in the facility's final efflu-
ent, and only if all pollutants have approved analytical meth-
ods. A detection of any of these pollutants means the facility
is out of compliance with the rule.
Section 301 of the Clean Water Act prohibits the discharge of
"any pollutant" except if the discharge of such pollutant is in
compliance with a permit. Because it is impossible to achieve
an analytical detection of "zero" for a pollutant, facilities are
allowed to show compliance with zero discharge if each proc-
ess wastewater pollutant (e.g., the specific pesticide active in-
gredient) is not analytically detected in the effluent. Another
way to show zero discharge is to show no flow of process
wastewater from the facility.
In the PFPR rule, "no discharge of process wastewater pollut-
ants" refers only to pesticide active ingredients and priority
pollutants associated with in-scope pesticide products from
in-scope wastewater sources. However, there may also be local
limitations on additional pollutants.
A facility that completely reuses all PFPR wastewater (includ-
ing floor wash, leak and spill cleanup, etc.) meets the definition
of zero discharge and does not need to claim they are meeting
the requirements of the P2 alternative. However, even though
the facility is meeting zero discharge, they still have the choice
to say they are complying with the zero discharge requirement
(which has minor paperwork requirements) or the P2 alterna-
tive (which has more comprehensive paperwork requirements,
but may give the facility more flexibility if they decide to dis-
charge in the future).
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If a company has two facilities 150
miles apart, can wash water from
one facility be transported to the
other facility and used as make-up
water?
If the facility only generates spent solvent and generates no
wastewater (including floor wash, leaks and spills, etc.), then
the facility has no potential to discharge and is not covered by
the PFPR rule (see Appendix E for a definition of "potential to
discharge").
Yes. The first facility could transfer their wastewater off site
for reuse by their other facility, or for off-site disposal. How-
ever, the second facility (unless it is a centralized waste treat-
ment facility or an incinerator) must either achieve zero
discharge or incorporate the P2 alternative prior to discharge.
Potential to Discharge
Is a facility that currently has a
potential to discharge PFPR
regulated wastewater sources, but
does not discharge, a new or
existing source?
If a facility has safety showers
and/or eye wash stations, does
that constitute "potential to
discharge"?
Does a facility with permanently
plugged drains in the PFPR
process areas have a "potential to
discharge"?
How can a facility that uses water
have no potential to discharge if
there is a connection on site to the
POTW?
The facility is an existing source.
No. "Potential to discharge" only applies to regulated (i.e.,
in-scope) wastewater sources. As discussed earlier, if the only
wastewater that a PFPR facility discharges (or has the potential
to discharge) is not a regulated process wastewater under the
PFPR effluent guidelines (e.g., sanitary wastewater, employee
showers, laundry water), then the PFPR facility is not covered
by the PFPR effluent guidelines.
No. There is no potential to discharge from the process area.
If a facility has no potential to adversely affect a POTW's op-
eration or violate any pretreatment standard or requirement
due to accidental spills, operational problems, or other causes
so that no regulated process wastewater can reach the POTW,
then the facility is not covered under the PFPR rule.
The determination of "no potential" relates only to regulated
process wastewater sources that are addressed in the PFPR
rule. Therefore, a facility may have a connection to a POTW
and may use water, but still have no "potential to discharge"
if the control authority concludes that there are no regulated
process wastewater sources that can reach the POTW and
therefore, the industrial user has no reasonable potential for
adversely affecting the POTW's operation or for violating any
pretreatment standard or requirement.
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P2 Alternative
General
What is the difference between
listing a preliminary compliance
decision as "P2 alternative" versus
"P2 alternative with modification"
in Table C of the P2 Audit?
If an indirect discharger disposes
of interior wastewaters, leak/spill
water, and floor wash water off
site, can other PFPR process
wastewaters be discharged to the
POTW without implementing P2
practices?
Listing "P2 alternative" means that the facility will follow the
P2 practices listed in Table 8 of the final rule for that wastewa-
ter source without utilizing any of the listed (or nonlisted)
modifications. For example, if a facility generates an interior
equipment cleaning rinsate, they will store and reuse the rin-
sate in their PFPR operations.
Listing "P2 alternative with modification" means that the fa-
cility is claiming a modification (listed or nonlisted) to a Table
8 P2 practice, meaning they have a good justification to not
conduct that specific practice. For example, if a facility gener-
ates an interior equipment cleaning rinsate, but has docu-
mented that biological growth occurs when they store the
rinsate for that product, they could claim a listed modification
to release them from the requirement to reuse that rinsate in
their PFPR operations. However, the facility would still need
to treat this rinsate prior to discharge to the receiving stream
or POTW.
No. The reasoning behind allowing a discharge under the P2
alternative is to encourage greater use of the P2 practices.
Therefore, certain general practices, such as water conserva-
tion, would still need to be implemented even though other
P2 practices, such as the recycle of interior wastewater, would
not be applicable if interior wastewaters were disposed of off
site. However, if the facility was implementing P2 practices
and disposing interior wastewaters, leak/spill water, and floor
wash water off site, the facility could discharge the remaining
PFPR process wastewater sources to a POTW without prior
treatment.
PZ Practices/Best Management Practices
How does EPA define triple
rinsing of equipment?
EPA defines triple rinsing in 40 CFR 165.1 (Regulations for the
Acceptance of Certain Pesticides and Recommended Proce-
dures for the Disposal and Storage of Pesticides and Pesticides
Containers), as follows:
"Triple rinse means the flushing of containers three times, each
time using a volume of the normal diluent equal to approxi-
mately ten percent of the container's capacity, and adding the
rinse liquid to the spray mixture or disposing of it by a method
prescribed for disposing of the pesticide."
The Container regulation also allows for an equivalent pres-
sure rinse. Note that the final PFPR rule does not require triple
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Why is the drum rinsing station
referred to as countercurrent
rinsing?
rinsing as part of the P2 alternative, but when PFPR-related
equipment is triple rinsed/pressure rinsed, the wastewater
generated would be covered by the P2 alternative if it is gen-
erated from in-scope PFPR production and wastewater
sources.
The drum rinsing station is not true countercurrent rinsing;
however, it is operated in a countercurrent fashion, where the
drums are moved from station 1 to 2 to 3 and the water is
moved from Station 3 to 2 to 1, where station 1 contains the
most concentrated rinse and station 3 contains the least con-
centrated rinse. When station 1 becomes too contaminated to
effectively rinse drums, fresh water is used to replace it, and
station 1 becomes station 3, station 3 becomes station 2, and
station 2 becomes station 1.
Why didn't EPA include the
operation of a countercurrent
drum rinsing station that uses
solvent in the list of P2 practices?
Instead of using drip pans, can a
facility operate a general sump in
their compounding area?
Drum rinsing stations allow for the recycle (as opposed to
reuse) of drum rinsates (note: discharge from drum rinsing
stations must be treated prior to discharge). EPA did not spe-
cifically list the use of countercurrent drum rinsing stations for
solvent-containing drums because it is not common in the in-
dustry; however, a facility could seek an unlisted modification
for this practice.
A facility can operate a general sump in the compounding area
as part of the P2 alternative if they can demonstrate that they
are reusing the water collected in the sump. The intent of this
P2 practice is to reuse the collected drips and spills, or, at a
minimum, to prevent concentrated leaks and spills from in-
creasing the pollutant loading in the floor wash water. The
facility would need to request a nonlisted modification and
receive approval for that modification from the permit-
ting/control authority. If the water is not being reused, the
facility would need to provide justification as to why drip pans
could not be used.
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Does a facility have to use drip
pans, or could they use some
other method of collecting drips
and spills (e.g., hard pipe, welded
flanges, etc.)?
Do facilities that operate wet air
pollution control scrubbers
discharge that wastewater?
Can you store and reuse material
for greater than 90 or 180 days?
Many inerts at a facility are also
used in nonregistered products.
How is it determined which inert
drum rinsates are covered by the
PFPR regulations?
The facility could implement another practice, although they
would need to request a nonlisted modification. In addition,
the facility must show that the alternate method would ade-
quately prevent leaks and drips from occurring or would allow
reuse of the material (see above).
Yes, facilities that operate these devices typically discharge a
blowdown stream from the scrubber periodically. Some facili-
ties may also operate these devices with a continuous dis-
charge. Often, these facilities treat the scrubber water prior to
discharge to the POTW or receiving stream. Note: Under the
P2 alternative, facilities must employ some recirculation of
water used in air pollution control scrubbers.
If you are storing hazardous or characteristic material (e.g.,
rinsate) on site for reuse, it is not considered waste and therefore
is not covered by the 90- and 180-day storage limitation. How-
ever, the RCRA regulations require that materials being stored
for reuse not be accumulated speculatively Material not con-
sidered speculatively accumulated includes material that is
shown to be recyclable, to have a feasible means of being re-
cycled, and, that during the calendar year, the amount of ma-
terial recycled equals at least 75% by weight or volume of the
amount of that material accumulated at the beginning of the
period. This discussion is included on page 57529 of the pre-
amble to the final rule in Appendix A.
It is the intent of the rule to cover wastewater associated with
pesticide production; therefore, cleaning rinsates of drums con-
taining inert materials used in PFPR production would be cov-
ered under the PFPR rule. Many facilities are able to separate
pesticide and nonpesticide operations. Therefore, if the facility
can specify that only material from certain drums are used in
PFPR production, then only the rinsate from those drums is
covered under the PFPR rule. If the facility cannot make this
distinction, then rinsate from all drums containing that mate-
rial is covered by the rule. Note: Not all drums will need to be
rinsed. Many inert containing drums hold chemicals that do
not trigger the rinsing requirements under FIFRA or RCRA.
A facility may be able to request a nonlisted modification if
they are unable to reuse all inert drum rinsate; however, they
must show good justification as to why they cannot reuse it,
as well as demonstrating reuse of some of the rinsate in their
PFPR process.
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If a facility uses equipment to
produce both solvent- and
water-based products, at what
point after solvent rinsing is the
final water rinse considered
"clean" enough (i.e., no longer
containing detectable quantities of
pesticide active ingredient)?
Does a facility have to reuse
rinsates from the cleaning of
refillable containers? These
containers may contain impurities,
which precludes the reuse of the
rinsate in the product formulation
because of quality control
concerns.
If the shipping containers/drums
are metal, they may not need to
be rinsed since refurbishers have
a flame to clean drums.
A facility performs the first two
rinses of their pesticide active
ingredient raw material drums
with a solvent compatible with
the formulation. The third rinse
uses a water/detergent blend to
remove the solvent. This
water/detergent blend cannot be
used in the formulation or in any
formulation at the facility. Is the
water/detergent rinse eligible for
treatment and discharge under the
P2 alternative, or must it meet
zero discharge (through off-site
disposal)?
What does a facility do with
solvent used to rinse tanks, since
they will not be able to reuse the
solvent forever?
Practice 9 (listed in Table 8) states that facilities must dedicate
PFPR production equipment to water-based versus solvent-
based products. This practice is intended to eliminate the gen-
eration of solvent-contaminated wastewater, which are
typically unable to be reused in PFPR operations. By dedicat-
ing production equipment, facilities may reuse solvent rinses
and water rinses into solvent-based and water-based formula-
tions, respectively.
Facilities may also discuss incorporating a listed modification
(i.e., operation of a solvent recovery system) or nonlisted modi-
fication to this practice with their control/permitting authority.
Under the P2 alternative (for Subcategory C facilities), reusing
rinsates from the cleaning of refillable containers would be
required unless the facility requested a modification. Although
the stated reason for not reusing the rinsate is not a listed
modification, a facility could request a nonlisted modification
if they are also able to supply sufficient documentation of the
quality control issue.
The P2 alternative is not available to refilling establishments
(Subcategory E facilities); therefore, facilities are not required
to reuse rinsates. However, these facilities must achieve zero
discharge of all PFPR process wastewaters.
Drums may be metal, fiber, or plastic. The PFPR rule does not
require rinsing of drums; however, if drums are rinsed, the
drum rinsate is a covered wastewater source and is subject to
the P2 alternative.
If the facility must use the water/detergent blend for the final
rinse because a drum refurbisher requires such cleaning before
accepting the drums, the facility can meet the P2 alternative
by using the listed modification for Practice 8 ["REFURB"].
However, if the facility is not required by a drum refur-
bisher/recycler to rinse the drums in this manner, the facility
must either meet zero discharge for the final rinse or request
a nonlisted modification from their control authority/permit-
ter to allow treatment and discharge under the P2 alternative.
The facility could also use a drum rinsing station for the
water/detergent rinsing step, which would allow for recycle
of the water/detergent rinsate to clean a large number of
drums.
For solvent rinses associated with drum rinsing or interior
equipment cleaning rinsing operations, it is expected that, un-
der the P2 alternative, a facility will reuse the solvent into the
formulated product (or, at a minimum, they will segregate their
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Has EPA looked at any of the
"clean laboratory practices"? Are
they required for this rule and, if
so, how does that affect
compliance with this rule?
The PFPR rule states that
disposing of wastewater at a
RCRA incinerator complies with
"zero discharge." In addition,
incinerator scrubber water is not
considered a process wastewater.
Therefore, can a facility receive
BPJ allowances for incinerator
scrubber water pollutant loads
without implementing P2
practices?
solvent rinsates from their water rinsates). If the facility is not
able to completely reuse their solvent rinses in this manner,
they must dispose of the solvent in accordance with appropri-
ate disposal regulations; however, the PFPR rule only covers
wastewater discharges (not solid or hazardous waste disposal
operations).
The words "clean," "ultra-clean," "clean techniques," "clean
laboratory practices," and other words and phrases have been
used to describe additional steps taken to preclude contami-
nation during sampling and analysis of trace metals. These
techniques are not required for effluent monitoring. However,
EPA has been made aware that for some metals (e.g., zinc) it
may be prudent to apply some of these clean techniques in
effluent monitoring to assure that results are reliable and are
not the result of contamination.
This rule does not specifically require analytical testing, but
testing may be necessary to show that the facility's treatment
system is "well operated and maintained," as discussed in 40
CFR 455.41(c)(5) [page 57550 of the preamble to the final rule,
located in Appendix A of this guidance manual].
Yes, but such an allowance must be based on the PFPR contri-
bution to the facility's production.
If equipment used for dry
production is cleaned first by
running a dry carrier through to
pick up residual product,
followed by a water rinse, is the
water rinse considered "the final
rinse of a triple rinse" and
therefore eligible for a waiver
from pretreatment from the
control authority?
In general, that water rinse could be equated to the final rinse
of a triple rinse; however, the control/permitting authority will
use BPJ to determine whether a waiver is appropriate to be
granted.
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Does inventory management only
concern the management of
rinsates? May it also include
liquid and/or solid raw materials
and intermediates in order to
reduce waste generation due to
shelf-life limitations?
Inventory management systems can be used for the manage-
ment of raw materials, intermediates, finished products, rin-
sates, etc. that are associated with PFPR operations. Inventory
management is not a P2 practice required by the PFPR regu-
lation, but generally is a good practice to incorporate.
Listed Modifications to P2 Practices
If your formulation only requires
the amount of water generated
from the rinsing of pesticide
active ingredient drums, can you
discharge the rinsate from the
inert drums?
Is a one-time test per product
acceptable to justify the
"BIOGROWTH" modification?
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?
Assuming that the facility has already implemented flow re-
duction measures when rinsing their pesticide active ingredi-
ent and inert drums, the facility would be able to use the listed
inert modification. Note: many inert ingredients do not trigger
FIFRA or RCRA drum rinsing requirements; therefore, inert-
containing drums may not need to be rinsed prior to recycle
or disposal.
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 formu-
lation, as well as the typical storage period.
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 registration or production of the formula-
tion and there is no compatible formulation for reuse of the
rinsates or the facility can provide a reasonable explanation of
why it does not anticipate formulation of the same or compat-
ible formulation within the next 12 months.
Nonlisted Modifications
Can economics be taken into
account when asking for waivers
on interior rinsates (i.e., for a
nonlisted modification)?
EPA has not specified economics as a modification to Table 8;
however, local authorities have the opportunity to use best
professional judgement in considering nonlisted modifica-
tions. Note, though, that POTWs and control authorities may
not be able to be flexible in approving nonlisted modifications
for PFPR facilities if they are tied to what they are allowed to
discharge to their receiving streams.
EPA did evaluate the cost of PFPR facilities complying with
the P2 alternative and found that the P2 alternative (with listed
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Is there a listed modification for
toll formulators/packagers so that
they do not have to dedicate
solvent- vs. water-based
production equipment, since their
production changes so often and
they cannot control what products
are made when?
Practice 7 in Table 8 of the rule
allows for disposal of rinse water
from cleaning shipping containers
if a staged drum rinsing system is
used. Is this system an acceptable
alternative for solvent-based
products as well (i.e., Practice 8)?
In both practices, product quality
objectives generally dictate
disposal of drum rinsates. The use
of staged drum rinsing will
minimize the volume of waste
generated. With increasingly
stringent FIFRA regulations on
cross-contamination, we are
reluctant to reuse rinsate from
containers that have been out of
our direct control even though the
containers are in dedicated service.
modifications) is economically achievable for the industry. In
addition, EPA built in other types of waivers to treatment. EPA
will allow the control authority to waive the pretreatment re-
quirements for floor wash and the final interior rinse of a triple
rinse that has been demonstrated to be non-reusable when the
facility demonstrates that the level of pesticide active ingredi-
ents and priority pollutants in these wastewaters are present
in concentrations too low to be effectively pretreated at the
facility. In addition, these pollutants must neither pass through
nor interfere with the operation of the POTW (see 40 CFR
403.5). The control authority should take into account whether
the facility has used water conservation practices when gener-
ating such a non-reusable wastewater.
No. However, these toll formulators could install a solvent
recovery system (as some toll formulators have already done)
and take the listed modification ("RECOVERY"). In addition,
the facility may be able to justify an unlisted modification;
however, the fact that the facility is a toll formulator is not
justification enough.
Drum rinsing stations allow for the recycle (as opposed to
reuse) of drum rinsates (note: discharge from drum rinsing
stations must be treated prior to discharge). EPA did not spe-
cifically list the use of countercurrent drum rinsing stations for
solvent-containing drums because it is not common in the in-
dustry; however, a facility could seek an unlisted modification
for this practice.
P2 Audit
Does a facility need to track raw
material bags, which are emptied
and disposed of, during the P2
audit?
No, the P2 audit that is suggested by EPA for compliance with
the PFPR rule focuses on water use and wastewater sources.
Therefore, it is not intended to track nonwater waste sources
such as empty raw material bags. However, it may be useful
for facilities to evaluate all waste sources (including solid
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wastes and air emissions) associated with their processes to
identify potential P2 opportunities that limit cross-media trans-
fers.
P2 Allowable Discharge
What is the de minimis exemption
allowed by this rule?
Is there a de minimis
concentration of pesticide active
ingredient allowed in wastewater
(i.e., if the concentration is below
the de minimis value, is it
exempted from regulation)?
Is there a volume or upper limit
to the P2 allowable discharge?
How does a facility document
"insignificant" levels of pesticide
active ingredient and obtain a
waiver for floor wash and outside
packaging equipment wipe-down
rinsate?
The rule does not have any de minimis exemptions, but does
have a P2 allowable discharge, which is the discharge of any
remaining PFPR wastewaters after implementation of P2 prac-
tices and any necessary treatment. The amount is expected to
be small; however, it is not referred to as a de minimis exemp-
tion because it is not quantifiable.
No, there is no de minimis concentration of pesticide active
ingredient exempted from the rule. However, certain products
or pesticide active ingredients are exempted, and certain
wastewaters are exempted based on their source. For Subcate-
gory C, please refer to Section 455.40(c), (d), (e), and (f) for a
discussion of these exemptions. For Subcategory E, please refer
to Section 455.60(b) and (c). The final rule may be found in
Appendix A of this guidance manual.
No, a facility may discharge whatever remains after implemen-
tation of the specified P2 practices (and treatment when nec-
essary). Note: the P2 practices include water conservation
practices, which will reduce the volumes of wastewater to be
treated and discharged.
A control authority may grant a waiver that removes the re-
quirement to pretreat certain wastewaters prior to discharge.
This waiver may be granted to indirect dischargers for two
types of wastewaters: floor wash water or the final rinse of a
non-reusable triple rinse (note that under the P2 alternative,
exterior equipment cleaning rinsate is not required to be pre-
treated). The waiver may be granted only when the levels of
pesticide active ingredients and priority pollutants are too low
to be effectively pretreated and have been shown to neither
pass through nor interfere with the operation of the POTW (see
footnote 9 on page 57529 of the final rule, located in Appendix
A of this guidance manual). The granting of such a waiver is
through the best professional judgement of the control author-
ity/POTW; therefore, the facility must work with the control
authority/POTW to determine the documentation necessary
to demonstrate these items.
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Treatment/Treatability Issues
Wastewaters Requiring Treatment
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?
Does DOT test bath water require
treatment prior to discharge if a
can has burst in the bath?
The P2 alternative of the final PFPR rule stipulates that direct
discharging facilities must treat any PFPR wastewater that re-
mains 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 waste-
waters 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 Ap-
pendix A of this guidance manual).
If the bath is operated as a batch bath, the bath water may be
discharged indirectly without treatment, even if a can has burst
in the bath. Treatment is required prior to direct discharge.
If the bath is operated as a continuous overflow bath, the bath
water must either have some recirculation under the P2 alter-
native (and may be indirectly discharged without treatment)
or the facility must meet zero discharge for this source.
Many facilities have standard operating procedures in place
for when cans burst in a DOT bath. At many facilities, these
procedures include collecting the pesticide-containing waste-
water for off-site disposal.
Treatment Technology Operations
Activated Carbon
What is the difference between
the feed rate and the capacity of
the carbon?
The feed rate is the rate at which wastewater enters the acti-
vated carbon adsorption unit. It is a unit of flow (i.e., volume
per unit time), such as gallons per minute or liters per second.
The feed rate should allow the wastewater sufficient time to
contact the carbon so that contaminants can be adsorbed onto
the carbon. If the feed rate is too high, pesticide active ingre-
dients will pass through the carbon adsorption system that
otherwise could have been adsorbed. During its treatability
testing, EPA used a feed rate that gave the wastewater an
empty bed residence time of approximately 15 minutes.
The capacity is the amount of pesticide active ingredient that
will be adsorbed per amount of carbon. It is usually given in
units of weight of pesticide active ingredient removed per
weight of carbon, such as grams of pesticide active ingredient
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Does an activated carbon system
have to be run continuously?
Since the PFPR rule does not
require testing, how does one
determine when to change carbon
in an activated carbon system?
Can you use TOC to determine
carbon breakthrough?
When using activated carbon
adsorption as a treatment
technology, what does the facility
do with the carbon once it is
saturated? Must it be disposed of
as a hazardous waste?
removed per gram of carbon. Determining the capacity can
help one determine how much carbon is needed in the unit to
remove a particular amount of chemical.
No, an activated carbon system may be run in batch mode.
Facilities may store wastewater prior to treatment (storage of
wastewater is common in this industry). EPA observed PFPR
facilities treating wastewater with activated carbon in batch
mode and also performed activated carbon treatment in batch
mode on wastewaters collected from PFPR facilities. In addi-
tion, PFPR facilities with wastewater matrices that vary daily
may find that batches of stored wastewater may be more con-
sistent from treatment period to treatment period.
Although the rule does not require specific testing, it does
require that a treatment system be demonstrated to be well op-
erated and maintained. To demonstrate this, a facility may
need to perform some testing to determine when carbon break-
through occurs for their system and therefore when the carbon
needs to be changed.
In some cases, TOC or other parameters may be used as an
indicator of carbon breakthrough by a pesticide active ingre-
dient, but only after treatability testing or monitoring has been
conducted that demonstrates that TOC is a good indicator of
breakthrough of that pesticide active ingredient. A parameter
may be a good indicator of carbon breakthrough for a pesticide
active ingredient if it tends to break through before or about
the same time as the pesticide active ingredient, but not if it
breaks through after the pesticide active ingredient.
Spent activated carbon should be disposed of or regenerated.
Manufacturers of activated carbon may take the carbon back
for regeneration; however, the cost of regeneration typically
depends on the amount of carbon to be regenerated, the dis-
tance to the regeneration facility, and other factors. Some fa-
cilities may wish to dispose of their spent activated carbon
instead of having it regenerated. In this case, the activated
carbon would need to be disposed of as hazardous waste if it
meets the definition of hazardous waste in 40 CFR 261 A. Many
pesticide active ingredients are not RCRA-listed hazardous
wastes, and most PFPR wastewaters do not exhibit hazardous
waste characteristics. Residue from treatment of PFPR waste-
waters, such as spent activated carbon, would not be consid-
ered a hazardous waste if it did not contain a listed hazardous
waste and/or did not exhibit a characteristic of a hazardous
waste.
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Emulsion Breaking
When performing emulsion
breaking, won't the removal of the
oil/scum layer remove organic
pollutants?
Does a facility have to use
sulfuric acid or other concentrated
acid to perform the emulsion
breaking step?
Yes. The oil/ scum layer removed during emulsion breaking
typically contains some level of organic pollutants, and may
also include organic pesticide active ingredients. During treat-
ability tests conducted by EPA on wastewater collected from
PFPR facilities, the emulsion breaking step typically lowered
the pesticide active ingredient concentration in the remaining
wastewater. However, it did not typically reduce the pesticide
active ingredient concentration enough to be considered an
adequate pesticide active ingredient treatment technology.
In general, pretreatment technologies are meant to be used in
conjunction with the pesticide active ingredient destruction
and removal technologies listed in Table 10, or other technolo-
gies demonstrated to be equivalent to those listed in Table 10.
However, it is possible that some technologies that EPA has
identified as pretreatment technologies can provide treatment
equivalent to the technologies listed in Table 10. In many of
the treatment systems sampled by EPA, removal of pesticide
active ingredients was observed during pretreatment steps. For
example, emulsion breaking typically occurs at conditions of
low pH and temperature, which may also hydrolyze some
pesticide active ingredients. An equivalency demonstration as
described in Chapter 7 of the P2 Guidance Manual would be
required for any pretreatment technology that a facility wished
to use as the primary treatment technology for a pesticide
active ingredient.
No. It is not necessary to use a specific acid to perform emul-
sion breaking, as long as the selected acid lowers the pH to the
desired level. In general, any strong acid (e.g., sulfuric, hydro-
chloric, or nitric acid) could be used. During EPA treatability
studies on PFPR wastewater, sulfuric acid was used to lower
the pH of wastewaters for emulsion breaking and neutraliza-
tion after hydrolysis at high pH. However, facilities should be
aware that the addition of acid to PFPR wastewater may gen-
erate toxic or hazardous components, so an acid should be
chosen that will minimize the potential adverse health and
safety risks and the generation of toxic and hazardous com-
pounds. For chemicals that react to form hazardous or toxic
byproducts under acidic conditions, regardless of the acid
used, it may be advisable to use a different treatment technol-
ogy that does not lower the pH of the wastewater, or to use
P2 practices or off-site disposal instead of treating the waste-
water.
Hydrolysis
What types of acid are used to
perform acid hydrolysis?
There is no specific type of acid that must be used for any of
the processes used to treat PFPR wastewaters, including acid
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hydrolysis. The only requirement is that the acid be capable of
achieving the desired pH. In general, any strong acid, such as
sulfuric, hydrochloric, or nitric acid, could be used. During EPA
treatability studies on PFPR wastewaters, sulfuric acid was
used to lower the pH of wastewaters for emulsion breaking
and neutralization after hydrolysis at high (alkaline) pH. Fa-
cilities should also be aware that toxic or hazardous compo-
nents may be generated through the addition of acid to PFPR
wastewater, so an acid should be chosen that will minimize
the potential adverse health and safety risks and the generation
of toxic and hazardous compounds.
Precipitation
When performing hydrogen
sulfide precipitation, what does
EPA suggest to ensure that there is
no excess hydrogen sulfide in the
effluent from the system?
When performing chemical precipitation to remove metals or
organo-metallic pesticide active ingredients, sodium hydrox-
ide and/or sodium sulfide may be used to form these contami-
nants into a precipitate. EPA does not recommend adding
hydrogen sulfide to remove pesticide active ingredients, and
hydrogen sulfide should not form during sulfide precipitation
as long as a pH of 7 or above is maintained in the system.
In general, the amount of sodium hydroxide and sodium sul-
fide added to wastewater to perform chemical precipitation
should be based on the concentration of metals contained in
the wastewater. However, facilities should conduct bench- or
full-scale treatability tests to optimize the performance of their
chemical precipitation treatment step. To determine whether
excess sodium sulfide has been added during the chemical
precipitation step, a facility should monitor the chemical pre-
cipitation effluent during the treatability testing and during
full-scale treatment as it deems necessary. EPA based its cost
estimates on an addition of 0.416 pounds of sodium sulfide per
1,000 gallons of wastewater treated for all facilities because it
did not have information available on the specific concentra-
tions of metallic and organo-metallic contaminants in PFPR
wastewaters.
Treatment Residuals
How are the oil/sludge layers
disposed of from treatment
systems? Are they hazardous?
The oil/sludge layers from treatment systems may be disposed
of in a variety of ways. They may be reused in the PFPR prod-
uct, disposed of in an on-site treatment unit (such as an incin-
erator), or they may be disposed of off site. Off-site disposal
may be done at a centralized waste treatment facility, waste-oil
recovery facility, or other treatment and disposal facility. Oil,
sludge, and other residuals from treatment are hazardous
waste if they meet the definition of hazardous waste in 40 CFR
261.4.
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Determination of Treatment Equivalency
If a wastewater requires
treatment, does it have to be
treated using the treatment
technologies listed in Table 10?
How does one identify an
appropriate treatment technology
for a pesticide active ingredient
that is not listed in Table 10?
How does a facility justify using a
technology other than those listed
in Table 10?
No, facilities may use the appropriate Table 10 technology or
an equivalent technology or a pesticide manufacturing treat-
ment system that is treating the same pesticide active ingredi-
ents that are manufactured as are formulated/packaged/
repackaged.
EPA tried to include all pesticide active ingredients identified
at the time of promulgation of the regulation. As new pesticide
active ingredients come into being, one could apply the tech-
nology transfer methodology (described in the treatability da-
tabase reports, listed in Table 6-1 in Chapter 6 of this manual)
that EPA used to develop Table 10. Also, as a starting point,
one could identify the treatment technology(ies) listed in Table
10 for structurally similar pesticide active ingredients.
The facility must demonstrate that the technology will be just
as effective as the technology listed in Table 10 of the final rule
for the pesticide active ingredient in question, or that the tech-
nology is used in a pesticide manufacturing treatment system
used to treat the same pesticide active ingredient. Chapter 7 of
the P2 Guidance Manual discusses the requirements for dem-
onstrating that a technology will provide treatment perform-
ance equivalent to the technology listed in Table 10. In order
to demonstrate equivalence, a facility must include treatability
test results or sampling results (including those from literature,
similar wastewater matrices, or self-monitoring) in their on-site
compliance paperwork. A more detailed discussion of treata-
bility tests is contained in Chapter 6 of the P2 Guidance Man-
ual. The determination of equivalency will be based on a
combination of the percent removal of pesticide active ingre-
dient (in general, greater than 90% removal is required), final
effluent concentration of the pesticide active ingredient, and
the minimum detection limit for the pesticide active ingredient.
If treatability information is not available for a particular pol-
lutant, it may be necessary to identify a treatment technology
based on the facility's knowledge of the pollutant. For exam-
ple, a technology that is effective on one pesticide active ingre-
dient is often effective on other pesticide active ingredients
with similar chemical properties and structure. Treatment ef-
fectiveness should, however, be verified through a treatability
test. See Table 6-1 in Chapter 6 for sources of information on
identifying treatment technologies and transferring treatability
data from one pesticide active ingredient to another.
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Are any pretreatment technologies
alone effective enough to remove
pesticide active ingredients and
priority pollutants, or must they
be used in combination with other
technologies?
A facility that currently operates
an activated carbon column
generates wastewater containing
2,4-D, MCPP, and MCPA (all
structurally similar chemicals).
Table 10 lists chemical oxidation
for 2,4-D and MCPA, but lists
activated carbon for MCPP. Does
the facility have to install both
treatment technologies in an
on-site treatment system?
In general, pretreatment technologies are meant to be used in
conjunction with the pesticide active ingredient destruction
and removal technologies listed in Table 10, or other technolo-
gies demonstrated to be equivalent to those listed in Table 10.
However, it is possible that some technologies that EPA has
identified as pretreatment technologies can provide treatment
equivalent to the technologies listed in Table 10. In many of
the treatment systems sampled by EPA, removal of pesticide
active ingredients was observed during pretreatment steps. For
example, emulsion breaking typically occurs at conditions of
low pH and high temperature, which may also hydrolyze some
pesticide active ingredients. An equivalency demonstration
such as the one described in Chapter 7 of the P2 Guidance
Manual would be required for any pretreatment technology
that a facility wished to use as the primary treatment technol-
ogy for a pesticide active ingredient.
Not necessarily. The PFPR rule allows technologies other than
those listed in Table 10 to be used to treat wastewater contain-
ing a particular pesticide active ingredient, provided the facil-
ity can demonstrate that the technology is equivalent to the
one listed in Table 10 (Chapter 7 of the P2 Guidance Manual
discusses the requirements for demonstrating that a technol-
ogy will provide treatment performance equivalent to the
technology listed in Table 10). In this case, if the facility dem-
onstrates that chemical oxidation is equivalent to activated
carbon adsorption for MCPP, or that activated carbon adsorp-
tion is equivalent to chemical oxidation for 2,4-D and MCPA,
only one of the technologies would need to be installed.
The technologies listed in Table 10 to 40 CFR Part 455 are those
that are expected to effectively treat the PAL When more than
one technology can effectively treat a PAI, EPA listed the tech-
nology that is least expensive to employ. In the case of 2,4-D,
EPA has data indicating that it is treatable by either chemical
oxidation or activated carbon adsorption, but chemical oxida-
tion is expected to be less expensive, therefore this technology
is listed in Table 10. In the cases of MCPP and MCPA, EPA has
data indicating that activated carbon adsorption is an effective
treatment, but information on chemical oxidation is not avail-
able for these chemicals. Listed below are references gathered
by EPA concerning the treatability of 2,4-D, MCPP, and MCPA.
These documents can be found in the administrative record for
the final PFPR rule using the document control numbers
(DCNs) shown below.
Aly O.M. et al., Removal of 2,4-Dichlorophenoxyacetic Acid De-
rivatives from Natural Waters, Rutgers University, Dept. of En-
vironmental Science, New Brunswick, NJ, February 1965 (DCN
F6303).
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Is an incinerator treating
wastewater from pesticide
manufacturing and PFPR
operations that has an NPDES
discharge permit for scrubber
water considered a wastewater
treatment unit (i.e., is the
incinerator exempt from RCRA
Part B permit requirements)?
Can EPA provide a reference in
the pesticide manufacturing
development document/final rule
that demonstrates that
incineration is equivalent and/or
superior to treatment methods
listed in the PFPR rule for various
pesticide active ingredients?
Research Triangle Institute, Treatment Technology For Pesticide
Manufacturing Effluents: Atrazine, Maneb, MSMA, and Oryzalin,
Research Triangle Park, NC, February 2, 1980 (DCN F5795).
Environmental Science and Engineering, Inc., Final Report of
Laboratory Study of Pesticides Wastewater Treatability, November
11, 1985 and revised January 9, 1987 (DCN F6328).
No, the incinerator described above would not be exempt from
RCRA Part B permit requirements for the following reason.
A unit that satisfies the definition of "wastewater treatment
unit" set forth in 40 CFR 260.10 is exempt from Part 264 re-
quirements for treatment, storage, and disposal facilities
(TSDFs), Part 265 requirements for interim status TSDFs, and
Part 270 requirements for RCRA permits. See 40 CFR
264.1(g)(6), 265.1(c)(10), and 270.1 (c)(2)(v).
To satisfy the definition of "wastewater treatment unit" at 40
CFR 260.10, the unit must be a device that:
(1) Is part of a wastewater treatment facility that is subject to
section 402 or 307(b) of the Clean Water Act;
(2) Receives and treats or stores an influent hazardous
wastewater, or that generates and accumulates a hazardous
wastewater treatment sludge, or treats or stores a
hazardous wastewater treatment sludge; and
(3) Is a tank, as defined in § 260.10.
The incinerator described in the question would not satisfy the
third criterion. Although the incinerator generally meets the
broad definition of tank, it also meets the more specific defini-
tion of incinerator in § 260.10. EPA does not consider a unit to
be a "tank" if another, more immediately relevant term would
apply to that unit. Therefore, the incinerator would not be a
wastewater treatment unit, and thus, would not be exempt
from the requirements in Parts 264, 265, and 270. Instead, the
incinerator would be subject to the Subpart O requirements for
incinerators in Parts 264 and 265, permit requirements in Part
270, and any other relevant requirements.
Table 7-11 in the Development Document for Effluent Limitations
Guidelines, Pretreatment Standards, and New Source Performance
Standards for the Pesticide Chemicals Manufacturing Point Source
Category (EPA 821-R-93-016, September 1993) lists the BAT tech-
nologies used to establish numerical limitations for 120 pesti-
cide active ingredients in that industry. These BAT technologies
are considered to be equivalent to the technologies listed in
Table 10 of the final PFPR rule.
Table 7-11 of the Pesticide Manufacturing Development Docu-
ment lists incineration as the BAT technology for the following
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pesticide active ingredients: pendimethalin, acephate, phorate,
terbufos, captafol, fenarimol, isopropalin, and tebuthiuron.
In addition, the preamble to the PFPR regulation (61 FR 57517)
states that on-site incineration is equivalent to off-site incinera-
tion and is considered to meet zero discharge for the PFPR
rule. See page 57527 of the preamble to the final rule located
in Appendix A for more discussion regarding on-site incinera-
tion as a means to achieve zero discharge.
Treatability Testing
Did EPA evaluate inert materials
in treatability tests?
Are the EPA treatability reports,
including those reports listed at
the end of Chapter 5, available on
the Internet?
Do treatability tests require
elaborate QA/QC procedures?
What type of samples should a
facility collect to test how the
treatment system is operating
(grab vs. composite)?
Do bench-scale test results scale
up well to full scale?
EPA did not focus on the inert materials; however, in addition
to analyzing wastewaters for the specific pesticide active in-
gredients, EPA analyzed for a full scan of organic and metal
pollutants, including priority pollutants, to identify other po-
tential pollutants of concern from inert ingredients. Treatment
efficiencies were focused on pesticide active ingredients and
priority pollutants.
Not at this time, although all treatability reports generated
during the development of this PFPR effluent guideline are
available through EPA's Water Docket (see page 46 of Chapter
5 for information on contacting the EPA Water Docket). Please
note that some treatability reports contain confidential busi-
ness information and are available in a nonconfidential form.
No, the level of QA/QC conducted during EPA sampling and
treatability testing is not necessary for facility treatability test-
ing, but facilities should use a level of QA/QC that will ensure
the quality of their data. Chapter 6 of the P2 Guidance Manual
provides some direction on using QA/QC in treatability test-
ing. The QA/QC procedures include preparation of a QA/QC
plan and the collection of field duplicate, field blank, equip-
ment blank, and trip blank samples.
The type of samples collected to determine the efficiency of an
operating treatment system depends on whether the unit op-
eration is a batch or continuous operation. Generally, grab sam-
ples are collected for batch operations and composite samples
are collected for continuous operations. Samples collected to
characterize raw waste streams are typically grab samples be-
cause of the batch nature of wastewater generation. Samples
collected during treatability testing are typically grab samples.
The correlation between bench- and full-scale test results will
depend on a variety of factors, including how well the bench-
scale test was designed and performed, the difference in waste-
water volume treated between bench- and full-scale treatment,
the type of technology tested, the contaminants in the waste-
water treated, and other factors. If a bench-scale test is well
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What reference shows which
pesticide active ingredients in
Table 10 had treatment
technologies established based on
a transfer of treatability data?
designed and performed, it should scale up well. However, the
scale-up invariably results in some difference from bench-scale
results due to the different equipment, operating conditions,
and other parameters at the full scale. Although the bench-
scale test can provide valuable information for the design and
operation of a full-scale treatment system, it is commonly nec-
essary to adjust the full-scale treatment system design and
operating parameters to optimize performance. For scaling up
from a bench-scale test to a large-volume full-scale treatment
system, it may be advisable to perform a pilot-scale treatability
test on an intermediate scale. Also, in some PFPR facilities, the
volume of PFPR wastewater to be treated may only require
equipment that typically would be considered pilot- or bench-
scale.
An example that illustrates the difference in how different
treatment technologies compare in terms of scale-up is dis-
cussed below. Hydrolysis bench-scale tests typically correlate
well with full-scale treatment, provided an actual wastewater
was treated, the full-scale unit is well-mixed, and other oper-
ating parameters such as temperature, pH, and treatment time
are the same. However, activated carbon bench-scale tests may
not scale up as well. Activated carbon bench-scale tests fre-
quently use a beaker in which some activated carbon is al-
lowed to come into equilibrium with a wastewater to
determine the saturation loading. This is different from an ac-
tual treatment system in which wastewater passes through a
bed of activated carbon, and therefore can result in differences
between saturation loadings observed during bench- and full-
scale operation.
This information is presented in the Final Pesticide Formulators,
Packagers, and Repackagers Treatability Database Report and Ad-
dendum (see Chapter 5 for more detail on how to access these
sources).
Sampling/Monitoring
Why is it necessary to evaluate the
wastewater matrix, particularly as
it pertains to inert ingredients that
may be present in the wastewater?
Inert ingredients are covered in discharges from PFPR opera-
tions if they are also priority pollutants. However, the reason
EPA suggests evaluating the wastewater matrix during the P2
audit is to identify possible contaminants in wastewater that
may hinder effective treatment of pesticide active ingredients
or priority pollutants. In these cases, the wastewater may re-
quire pretreatment in order to allow the treatment system to
effectively remove the pesticide active ingredients.
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How does one determine if the
pesticide active ingredient is in
the water phase or oil/sludge
phase of a wastewater? Can one
use alcohol-water coefficients?
If a facility chooses to meet zero
discharge through no discharge of
process wastewater pollutants
(rather than no flow), how do they
show "zero"?
Does a facility need to monitor
for priority pollutants when
conducting a treatability test to
develop a relationship for
surrogate parameters used to
demonstrate a treatment system is
well operated and maintained? If
so, must they monitor for the
whole list of priority pollutants,
or only those pollutants that were
identified in the BMR?
Octanol-water coefficients can be used to determine whether
a pesticide active ingredient is likely to be in the water phase
or the oil phase of a wastewater. However, octanol-water co-
efficients are determined using a pure octanol-water system,
whereas PFPR wastewaters typically contain a variety of con-
taminants that may render the octanol-water coefficient invalid
for a particular wastewater. In addition, octanol-water coeffi-
cients are not available for many pesticide active ingredients.
Therefore, the various phases of a wastewater may need to be
chemically analyzed to determine what fraction of pesticide
active ingredient has partitioned to each phase.
In order to demonstrate zero discharge analytically (instead of
via "no flow"), any pesticide active ingredient potentially pre-
sent in the wastewater must have an EPA-approved analytical
method for use in wastewater, and the pesticide active ingre-
dient must not be present at or above the detection limit in the
approved method.
Some methods contain a detection limit, a method detection
limit (MDL; 40 CFR 136, Appendix B), an estimated detection
limit, or some other detection limit concept. The words "detec-
tion limit" are generally understood to encompass these terms.
The PFPR rule does not require monitoring or the estab-
lishment of a surrogate parameter for compliance. However, if
a facility chooses to use a surrogate parameter to demonstrate
that a treatment system is well operated and maintained, they
would monitor for specific pesticide active ingredients and the
constituent chosen as the surrogate to establish the relationship
between the surrogate and the PFPR process wastewater pol-
lutants. In terms of priority pollutants monitoring, a facility
could use a list of those priority pollutants identified in the
BMR; however, if products/raw materials have changed since
the BMR was developed, the facility should include any addi-
tional priority pollutants expected to be in the wastewater.
Are industrial users (ILJs) required
to submit monitoring data to the
POTW/control authority if
samples are collected in addition
to samples required by the PFPR
regulation?
Sample collection is not specifically by the PFPR regulation.
However, the individual control mechanism with the
POTW/control authority may require monitoring and analysis
to demonstrate continued compliance; this is described in 40
CFR 403.12(g).
If a facility is using certain monitoring data to back up or
demonstrate information in their initial or periodic certifica-
tions for the P2 alternative, then such data should be kept with
the facility's on-site compliance paperwork and would be
available to the POTW/control authority, as well as to enforce-
ment officials.
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EPA Test Methods
What if a wastewater matrix
causes interference with the
analytical method (and therefore,
the detection limit is higher than
normal)?
Are the EPA-approved methods
highly specific methods?
Does EPA have method detection
limits for each pesticide active
ingredient that has an
EPA-approved analytical method?
Is it possible to use a
non-EPA-approved method for
pesticide active ingredients that
do not have approved methods
promulgated (i.e., use a facility's
method)?
Are the methods promulgated
under Part 455 for pesticide active
ingredients valid for the NPDES
program and pretreatment
programs under Part 136?
The discharger must eliminate the interference using the pro-
cedures given in EPA's Guidance on Evaluation, Resolution, and
Documentation of Analytical Problems Associated with Compliance
Monitoring (EPA 821-B-93-001) or other interference elimination
procedures.
Many of the EPA-approved methods are based on methods
developed by pesticide active ingredient manufacturers. In
general, these methods are expensive to run and not performed
by many laboratories. However, there are several methods that
will detect a series of different pesticide active ingredients. For
example, Method 1656 is used to analyze organo-halide pesti-
cides. For more information on pesticide active ingredient
methods, please reference Methods for the Determination of Non-
conventional Pesticides in Municipal and Industrial Wastewater
(EPA 821-R-93-010).
EPA has also produced other reference materials on water and
wastewater methods, including the Environmental Monitoring
Methods Index (a powerful PC database that electronically
links over 4,000 substances with methods and regulations) and
the Methods and Guidance for the Analysis of Water (EPA 821/C-
97-001). These reference materials are available through the
National Technical Information Service (NTIS), which can be
reached between 8:30 a.m. and 5:00 p.m. Eastern Time at (703)
487-4639 or via the Internet at http://www.ntis.gov/ordernow.
Yes, although facilities must also take into account the waste-
water matrix and the number of dilutions performed by the
laboratory.
Yes. For pesticide active ingredients that have no EPA-ap-
proved analytical methods, PFPR facilities may use alternative
sampling and analytical methods as specified in 40 CFR 136.4
and 403(g)(4). See page 57548 in the preamble to the final rule
in Appendix A for more detail.
Yes. Language in 40 CFR 403 and 136 allows for analytical
methods found in Part 136, Section 304(h) of the Clean Water
Act, or that are approved by the Administrator (403.12(g)(4)
and 136.4,136.5). Therefore, although the Part 455 regulations
have not been incorporated into Part 136, the Administrator
has approved these analytical methods by signing the Pesticide
Manufacturing Effluent Limitations Guidelines and Standards
(58 FR 50637; September 28,1993). These pesticide active ingre-
dient methods have been published in a document entitled,
"Methods for the Determination of Nonconventional Pesticides in
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Are the methods part of the
AWWT (American Waste Water
Treaters) published methods?
How does a facility adjust to
changing method detection limits
(MDLs) for pesticide active
ingredients if the "zero discharge"
option (with flow) is the
compliance option of choice?
Would a capping of MDLs be
allowed?
Municipal and Industrial Wastewater, EPA-821-R-93-010-A, Revi-
sion 1, August 1993."
The EPA-approved pesticide active ingredient methods have
been published in the FR (40 CFR 455.5, Subpart D), and are
available from EPA (Methods for the Determination ofNonconven-
tional Pesticides in Municipal and Industrial Wastewater, EPA-821-
R-93-010-A, Revision 1, August 1993).
No. Facilities using MDLs to demonstrate compliance with
zero discharge are allowed to do so because MDLs are the
closest to zero that can be currently measured. The MDLs are
not the set limitation. If improvements in analytical instru-
ments leads to the lowering of MDLs, those facilities demon-
strating zero using MDLs would need to show compliance
with the lower MDLs.
Determination of Sufficient Treatment
What does EPA consider
"effectively treated" for this rule
(i.e., is it a certain percent
removal)?
If a facility generates high
concentrations of pesticide active
ingredients in rinsewaters, is the
goal to treat the wastewater to
nondetect levels of pesticide
active ingredients? If not, what
criteria determine whether a
wastewater is effectively treated?
A facility can evaluate the effectiveness of a treatment technol-
ogy by performance measures that look at how much contami-
nant is removed from the wastewater, the amount of other
waste generated by the treatment step, and the cost of the
treatment. The facility should evaluate three measures to de-
termine if the treatment technology effectively removed the
contaminant: percent removal, final effluent concentration, and
minimum detection limit. For example, if 95% or more of a
constituent is removed by a technology, that technology would
be considered effective. Conversely, if a technology only re-
moves 30% of a constituent, but the constituent is removed to
below its detection limit, EPA considers the constituent to be
effectively treated. The facility should also take cost into ac-
count. A technology may effectively remove a constituent, but
at a high cost relative to other treatment technologies that may
also effectively remove the constituent. Chapter 6 of the P2
Guidance Manual provides more detail on how to measure
treatment effectiveness.
Nondetect levels are a good goal, but are not required by the
P2 alternative. The goal of the P2 alternative is to use the
pollution prevention, recycle, and reuse practices in the rule
(in combination with treatment when necessary) to achieve a
reduction of pollutants, while preventing possible cross-media
impacts associated with zero discharge. Following the imple-
mentation of the P2 practices, evaluation of the percent re-
moval or destruction of the pesticide active ingredient, as well
as the final effluent concentration and detection limit, deter-
mines whether a wastewater has been effectively treated. In
most cases, these technologies can reduce the concentration of
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Will most PFPR facilities be able
to run a treatment system as
envisioned by EPA, in terms of
size and cost?
Is EPA concerned about reaction
byproducts that may be generated
during wastewater treatment
operations? Sometimes these
byproducts have a negative
impact on the environment, but
are not analyzed or treated.
the pesticide active ingredient to at or near detection limits. A
treatment goal may be set by the control/permitting authority
using best professional judgement.
Yes. Most PFPR facilities do not generate large volumes of
water, and will be able to store their wastewater over time and
treat the water in 3 to 4 batches per year. In many cases, facili-
ties will be able to implement P2 practices instead of treating
their wastewater. Some facilities may also choose to contract
haul small volumes of wastewater for off-site disposal.
The treatment systems effective on PFPR wastewaters gener-
ally use simple, easily operated unit operations that use stand-
ard, off-the-shelf equipment, particularly at the small scale
needed by the typical PFPR facility. The treatment system can
be designed to be operated in a batch mode, so facilities gen-
erating a small volume of wastewater can store it until a suf-
ficient volume is available for treatment. During the
rulemaking process, EPA designed a small-scale wastewater
treatment system that was then used to treat wastewaters col-
lected from PFPR facilities in batches of about 100 gallons. This
system used standard, off-the-shelf equipment. EPA also evalu-
ated the cost of compliance with the P2 alternative and found
that the P2 alternative (with listed modifications and appropri-
ate treatment) is economically achievable for the industry.
Yes, EPA is concerned about reaction byproducts; however, for
this rule, EPA focused on those reaction byproducts that are
pesticide active ingredients or priority pollutants. In general,
reaction byproducts have lower toxicity factors than the pesti-
cide active ingredients themselves.
The control/permitting authority should evaluate the possible
impacts on local limitations from specific chemical byproducts
that may form during treatment operations. The presence of
these byproducts may require additional treatment, or may
require a different primary treatment technology to be used in
specific instances.
In one treatabilty study conducted by EPA, chlorinated and
other organic compounds were generated from chemical oxi-
dation of PAIs using a chlorine-based oxidizer. Chemical oxi-
dation produced: chloroform, bromodichloromethane,
dibromochloromethane, and acetone in wastewater containing
Metam; 1,3,5-trithiane in wastewater containing KN-Methyl;
and N,N-dimethylformamide in wastewater containing
Namet. Polychlorinated dioxins were also detected in parts per
quadrillion concentrations in these wastewaters after treat-
ment. Where chemical oxidation with a chlorinating agent re-
sults in the generation of chlorinated organics, use of a
non-chlorinating oxidizer, such as ozone or peroxide may pro-
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Why is "pollution prevention"
listed as an appropriate treatment
technology?
Are all the different technologies
listed in Table 10 part of a
pretreatment system that a facility
should have in place to treat
wastewater prior to discharge to a
POTW?
Why isn't neutralization
considered treatment?
Is there any guidance on how
much money facilities should
spend on treatment of PFPR
wastewater?
vide effective treatment without generating chlorinated or-
ganics.
Based on available data, EPA was unable to identify a cost-ef-
fective technology for use in the PFPR industry for some pes-
ticide active ingredients on Table 10. Therefore, EPA
determined that, if a facility generates wastewater that only
contains such pesticide active ingredients, they are in compli-
ance with the rule if they have implemented the Table 8 pol-
lution prevention practices (i.e., such facilities do not have to
treat PFPR wastewaters containing these specific PAIs prior to
discharge).
The technologies required for an on-site treatment system are
identified based on the pesticide active ingredients present in
the wastewater discharged from the facility. These technologies
could be combined into one treatment train, or could be con-
ducted individually on separate wastewaters, depending on
how the facility chooses to treat their wastewater. In addition,
if emulsions exist, an emulsion breaking step (or equivalent
technology) is required to meet the definition of "appropriate"
treatment.
For this rule, treatment is intended to mean removal or de-
struction of pesticide active ingredients or priority pollutants.
Neutralization does not achieve that purpose.
There is no real guidance on the amount of money a facility
should spend on wastewater treatment; it depends on a num-
ber of factors and the facility should consider all of these fac-
tors in making a final compliance decision. These factors
include the amount of wastewater being generated, treatment
currently in place at the facility, the size of the facility, and the
how economically sound the facility is. A facility should con-
sider whether treatment is the most cost-effective solution for
their particular situation. A facility may be able to treat their
wastewater adequately using available technologies; however,
if the amount of wastewater that would need to be treated is
very small, the facility may find it more cost-effective to con-
tract haul it instead of installing or adding additional treatment
technologies.
EPA performed an economic assessment for this rulemaking to
determine the most cost-effective regulation for the PFPR in-
dustry. As part of this assessment, EPA estimated the cost to
comply with the regulation. Subcategory C facilities were es-
timated to incur an average annual cost of $39,900 for stand-
alone PFPR facilities and $373,000 for PFPR/manufacturing
facilities; refilling establishments (Subcategory E facilities)
would incur compliance costs of $1,000 or less. The estimated
total annual cost to the industry is $29.9 million.
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Why calculate the destruction and
removal efficiency (DRE) for a
constituent that is below the
detection limit in the effluent?
Can EPA clarify what is meant by
"organics" in Table 6-2,
Wastewater Characteristics That
Adversely Impact Treatment
Effectiveness, of the P2 Guidance
Manual (i.e., are there specific
organic chemicals that interfere
with activated carbon adsorption)?
Who makes the decision on how
much treatment is needed?
The PFPR regulation does not require facilities to calculate the
DRE of pesticide active ingredients or priority pollutants; how-
ever, it may be helpful to determine which treatment units in
a treatment train are providing significant removal of the con-
stituents of interest. For example, the following table summa-
rizes the removal of a constituent through a treatment system
consisting of hydrolysis and activated carbon. The DRE shows
that even though activated carbon removes the constituent to
below detection (i.e.,|ig/L), the hydrolysis unit achieves the
majority of the constituent's reduction (i.e., 98 percent).
Wastewater Source
Concentration (ug/L)
DRE
Raw wastewater
Hydrolysis effluent
Activated carbon effluent
1,000 ng/L
20ng/L
98%
>50%
In addition, calculating the DRE can help faciliites demonstrate
equivlency of an alternate technology and/or demonstrate that
the treatment system is "well operated and maintained."
"Organics" refers to any organic chemical contained in the
wastewater being treated. Due to the variable nature of PFPR
formulations and operations, the specific organic chemicals
contained in PFPR wastewaters and their concentrations vary
from facility to facility. Therefore, Table 6-2 does not identify
specific organic chemicals, but indicates where the presence of
organic chemicals may cause a technology to perform poorly.
In the case of activated carbon adsorption, organic chemicals
will compete with the pesticide active ingredient for available
adsorption sites on the carbon, reducing the total amount of
pesticide active ingredient that will be adsorbed by a given
amount of activated carbon, and resulting in more frequent
carbon changeouts. The degree to which organic chemicals will
affect the performance of activated carbon adsorption will de-
pend on the specific organic chemicals in the wastewater, the
concentrations of those chemicals, and the pesticide active in-
gredients targeted for removal by activated carbon adsorption.
In some cases, the presence of organics may not significantly
affect the performance of activated carbon, while in others it
may render it ineffective. Table 6-3 lists some pretreatment
technologies that may be useful in removing organics prior to
treatment by activated carbon adsorption.
The control/permitting authority must use BPJ to determine if
the facility has installed the appropriate treatment and if the
treatment system is well operated and maintained.
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What happens if a facility needs
to add different technologies to
their treatment system in the
future?
If a facility operates a treatment
system consisting of hydrolysis
and activated carbon, and decides
to drop hydrolysis and only run
activated carbon, would the
facility require approval first?
If a facility plans to add new production to their PFPR opera-
tions, they must incorporate the appropriate P2 practices into
their operations and identify the appropriate or equivalent
treatment technology(ies) to be put in place if the new produc-
tion generates wastewater to be discharged. The P2 practices
and treatment technologies must be certified (e.g., at the time
of submittal of the periodic certification) and approved by the
control/permitting authority before the facility can begin to
discharge wastewater associated with the new production.
If the Table 10 technologies for the pesticide active ingredients
present in the wastewater are both hydrolysis and activated
carbon, then the facility would need to show that activated
carbon is equivalent to hydrolysis for those pesticide active in-
gredients whose listed technology is hydrolysis before remov-
ing the hydrolysis unit from the treatment system. In addition,
the facility must also demonstrate that the activated carbon
system would be well operated and maintained. This would
include reevaluating the frequency of carbon changeout to ac-
count for the carbon removing more pesticide active ingredi-
ents (and therefore becoming saturated more quickly).
Well Operated Treatment Systems
If a facility adds a new product
(e.g., diazinon), which has a Table
10 technology of hydrolysis, can
the facility use different
surrogates (e.g., half-life,
treatment time, pH, temperature)
for that one pesticide active
ingredient than are being used for
the rest of the system (e.g., TOC
and carbon change-out for
activated carbon units)?
Yes. However, a surrogate parameter that is approved for a
facility's treatment system will depend on the treatability data
used to support the use of the surrogate and the ability to show
a relationship in the data between the pesticide active ingredi-
ent and the surrogate.
Compliance
Baseline Monitoring Report
Is guidance available for
completion of the baseline
monitoring report (BMR)?
To whom is the BMR submitted
and where is this stated?
See Appendix E for EPA's guidance memorandum on complet-
ing the BMR. The BMR was due on July 7, 1997 for existing
indirect dischargers.
The BMR is submitted to the control authority. For states that
have approved pretreatment programs, the BMR goes to the
POTW/control authority. In other states, the BMR may be sub-
mitted to the regional EPA office. Section 403 of Title 40 of the
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Does the PFPR regulation require
monitoring, other than priority
pollutant monitoring for the BMR?
How many samples are required
for the BMR?
If a facility is covered under other
categorical standards and already
has a BMR on file with the
control authority, do they need to
submit a new BMR? Does this
also apply to PFPR/manufacturing
facilities that commingle
wastewater from PFPR and
pesticide manufacturing
operations and that previously
submitted a BMR for compliance
with the pesticide manufacturing
regulations [58 FR 50637]; can they
revise that BMR or do they have
to perform separate BMR
monitoring for their PFPR
wastewater?
CFR, as well as EPA Pretreatment Bulletin #13 (included in
Appendix E), discuss these issues.
No. Facilities will be able to generate a list of pesticide active
ingredients based on the products made at their facilities. EPA
guidance has suggested that monitoring for priority pollutants
or other surrogate parameters (e.g., TOC) would be helpful
since facilities may not always be aware of sources of these
pollutants in their wastewater, particularly pollutants that may
be present through the addition of inert materials to the for-
mulated products.
40 CFR 403.12(b)(5)(iv) states, "The User shall take a minimum
of one representative sample to compile that data necessary to
comply with the requirements of this paragraph." The type of
sample will depend on the nature of the pollutant as described
in 40 CFR 403.12(b)(5)(iii), which states "a minimum of four
(4) grab samples must be used for pH, cyanide, total phenols,
oil and grease, sulfide, and volatile organics. For all other pol-
lutants, 24-hour composite samples must be obtained through
flow-proportional composite sampling techniques where fea-
sible. The Control Authority may waive flow-proportional
composite sampling for any Industrial User that demonstrates
that flow-proportional sampling is infeasible. In such cases,
samples may be obtained through time-proportional compos-
ite sampling techniques or through a minimum of four (4) grab
samples where the User demonstrates that this will provide a
representative sample of the effluent being discharged." If the
process produces a discharge that is a homogenous batch, one
grab sample may be taken.
At a minimum, the facility should update the non-monitoring
sections of the BMR (e.g., process information, flow). In addi-
tion, if the facility is choosing the P2 alternative, they would
need to list the P2 practices, if any, currently in place that affect
their PFPR production/wastewaters. The facility may have to
submit monitoring data for pollutants that were not present at
the time they submitted the BMR for the pesticide manufac-
turing effluent guidelines; otherwise, historical monitoring
would suffice.
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In submitting the BMR, do
PFPR/manufacturing facilities
have to test commingled
wastewater for the 126 priority
pollutants or for specific pesticide
active ingredient pollutants listed
in Table 10?
In submitting a BMR for the PFPR regulation, facilities must
monitor only for priority pollutants. Specific pesticide active
ingredients used in PFPR products must be listed in the BMR,
but do not require testing.
Can a facility use toxicity
measurements for their BMR if
they haven't been testing the
specific pesticide active
ingredients?
The BMR does not require pesticide active ingredient-specific
measurements, although if a facility is choosing the P2 alter-
native, they should list the pesticide active ingredients that are
present (or believed to be present) and monitor for the priority
pollutants. Facilities are certainly welcome to provide addi-
tional data (e.g., toxicity measurements).
P2 Alternative/Allowable Discharge
Can you choose zero discharge for
an individual source?
If a direct discharging PFPR
facility chose to comply with the
PFPR effluent guidelines by
meeting a zero discharge
limitation and were issued an
NPDES permit that included zero
discharge for their PFPR
wastewaters, at the time of permit
renewal or reissue, could that
facility choose to switch to the P2
alternative? Would there be any
"backsliding" implications?
Yes, as long as you clearly indicate it in your compliance pa-
perwork.
Yes, a facility could switch from zero discharge to the P2 alter-
native at the time of permit renewal without invoking any
regulations dealing with "backsliding," as it would not apply
in this situation.
"Backsliding" is a term that has been used to describe a cir-
cumstance where a facility has an NPDES permit that lists
certain effluent limitations and upon renewal/reissue of the
permit, the "new" effluent limitations are made less stringent
then those in the previous permit. In general, "backsliding" is
not allowed. The regulations that discuss "backsliding" are
found at 40 CFR 122.44(1). These regulations discuss the re-
newal or reissue of NPDES permits (for direct dischargers) and
say that the effluent limitations, standards, or conditions in the
renewed/reissued permit "must be at least as stringent" as the
effluent limitations, standards, or conditions in the previous
permit. The regulations do provide several exemptions which
would allow "backsliding" (e.g., circumstances have materially
and substantially changed since the time the permit was
issued).
However, EPA believes that the regulations of 40 CFR 122.44(1)
("backsliding") do not apply to the situation where a PFPR
facility switches from zero discharge to the P2 alternative at
the time of permit renewal. This is because EPA designed the
zero discharge and P2 alternative limitations of the PFPR
effluent guidelines (40 CFR 455.40) to be equivalent. Therefore,
the P2 alternative is not only "at least as stringent" as zero
discharge, but it is just as stringent.
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At first it may seem counter intuitive that some wastewater
discharge, even a very small amount, is just as stringent as zero
discharge. However, as discussed in the PFPR effluent guide-
lines preamble to the final rule (61 FR 57518; November 6,
1996), EPA believes that when considering the potential cross-
media impacts associated with zero discharge (e.g., impacts to
air from contract hauling for off-site incineration of dilute, low-
BTU-value, wastewaters), the P2 alternative may be more pro-
tective of the environment overall.
Necessary Paperwork
Are facilities required to complete
the P2 audit tables (Tables A
through C) and Tables D and E for
compliance documentation?
Who is the entity that conducts a
P2 audit and regulates a facility?
Who receives the initial
certification?
Under the General Pretreatment
Program (40 CFR 403), certain
sampling and analysis is required
to be defensible (for enforcement
procedures). How does that affect
the analysis that would be
conducted for the PFPR rule?
No, facilities are not required to complete these tables. They
are provided as a tool. However, if a facility chooses to com-
plete them, they can be used to meet some of the paperwork
requirements (see Chapters 4, 6, and 7 of this manual for more
detail).
The control authority (for indirect dischargers) or the permit-
ting authority (for direct dischargers) enforces the PFPR rule.
The P2 audit is one way of determining compliance with the
rule; however, the P2 audit is not required by the rule. The P2
audit was designed as a tool for the facilities, control/permit-
ting authorities, consultants, etc. to help organize the various
pieces of information that will aid in making compliance de-
cisions. A control authority/permitting authority may ask a
facility to conduct such an audit, or may conduct the audit
themselves. The P2 audit tables were designed so that they
could be used as part of the compliance paperwork, but they
are not required.
The control authority/permitting authority receives the certi-
fication from facilities that choose the P2 alternative and that
discharge or have the potential to discharge.
40 CFR 403.8(f)(2)(vi) requires the POTW to take care and es-
tablish procedures so that sampling data and analysis can be
admissible in enforcement procedures. However, Part 403.12(g)
requires that Industrial User (IU) sampling must be appropri-
ate/representative and in accordance with 40 CFR 136. There-
fore, Part 403 does not require IU sampling to be defensible in
enforcement procedures. This means that the sampling per-
formed by the IU for purposes of this rule (e.g., for collecting
data to demonstrate that the wastewater treatment system is
"well operated and maintained") must be appropriate and rep-
resentative. However, other state or local regulations may also
apply.
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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?
According to the Section 403
regulations, paperwork must be
kept on site for 3 years. How long
must on-site compliance
paperwork for the PFPR rule be
kept?
For on-site compliance paperwork,
may a facility cross-reference
other records at the facility, or
does a separate copy of those
records need to exist in their PFPR
compliance file?
For the initial certification
statement, do facilities need to use
the certification statement listed
in Section 403.6(a)(2)(ii)? Can the
same manager who certifies under
Section 403 also certify under the
PFPR rule?
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 demonstrat-
ing "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 in-
gredients expected to be used in production in the next 12
months.
PFPR facilities complying with the P2 alternative must keep
the compliance paperwork necessary to document their cur-
rent activities. In addition, facilities must keep "old" paper-
work for the three-year minimum discussed in 40 CFR
403.12(o).
Facilities may cross-reference records in other parts of the fa-
cility (e.g, production records), but must be able to produce
those records when requested by their permitting or control
authority.
Facilities may use the following certification statement listed
in Section 403, but they are not required to use that exact word-
ing for compliance with the PFPR rule:
"I certify under penalty of law that this document and all
attachments were prepared under my direction of supervision
in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information sub-
mitted. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting
false information, including the possibility of fine and impris-
onment for knowing violations."
Most importantly, the "responsible corporate official" (or gen-
eral partner or proprietor or duly authorized official), as de-
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fined in Section 403.12(1), must certify that the information is
true and accurate.
The Initial and Periodic certification statements of the PFPR
rule have the same signatory requirements as those listed in
Section 403.12(1) of the General Pretreatment Regulations:
(1) Signatory requirements for industrial user reports. The reports
required . . . shall be signed as follows:
(1) By a responsible corporate officer, if the Industrial User
submitting the reports required...is a corporation. For the
purpose of this paragraph, a responsible corporate officer
means (i) a president, secretary, treasurer, or vice-presi-
dent of the corporation in charge of a principal business
function, or any other person who performs similar policy
or decision-making functions for the corporation, or (ii)
the manager of one or more manufacturing, production,
or operation facilities employing more than 250 persons
or having gross annual sales or expenditures exceeding
$25 million (in second-quarter 1980 dollars), if authority
to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures.
(2) By a general partner or proprietor if the Industrial User
submitting the reports required ... is a partnership or sole
proprietorship, respectively.
(3) By a duly authorized representative of the individual
designated in paragraph (1)(1) or (1)(2) of this section if:
(i) The authorization is made in writing by the individ-
ual described in paragraph (1)(1) or (1)(2);
(ii) The authorization specifies either an individual or
a position having responsibility for the overall opera-
tion of the facility from which the Industrial Discharge
originates, such as the position of plant manager, op-
erator of a well, or well field superintendent, or a po-
sition of equivalent responsibility, or having overall
responsibility for environmental matters for the com-
pany; and
(iii) the written authorization is submitted to the Con-
trol Authority.
(4) If an authorization under paragraph (1)(3) of this sec-
tion is no longer accurate because a different individual
or position has responsibility for the overall operation of
the facility, or overall responsibility for environmental
matters for the company, a new authorization satisfying
the requirements of paragraph (1)(3) of this section must
be submitted to the Control Authority prior to or together
with any reports to be signed by an authorized repre-
sentative.
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If a facility certifies that no
process wastewater pollutants will
be detected in the effluent from
their treatment, does that mean
that the MDL is their compliance
limitation? What if the facility
certifies that their treatment
system will result in an effluent
below 10 g/L (or some other
number)?
This responsible corporate official can be the same person for
both Section 403 and 455 certifications. Note that the timing of
submittal of the PFPR Periodic Certification Statement and the
Part 403 periodic compliance reporting have been coordinated
so that a facility can submit them to the POTW/control author-
ity at the same time (and have them signed by the same per-
son).
If the facility chooses to meet zero discharge, then the limita-
tion is zero, not the method detection limit. However, the fa-
cility can demonstrate zero discharge by achieving no
detection of process wastewater pollutants. If the method de-
tection limit decreases over time, the facility would still need
to show no detection of process wastewater pollutants.
If the facility wishes to achieve compliance by meeting a num-
ber (e.g., less than 10 g/L), then that facility can choose to
comply with the P2 alternative.
How is CBI that is included as
part of compliance paperwork
(either initial or periodic
certification or other on-site
compliance paperwork) handled?
What can a facility claim as CBI?
Will the confidentiality
requirements described in 40 CFR
403 apply to on-site compliance
paperwork required by the P2
alternative?
Can a facility claim both
treatment system effluent and
outfall effluent data CBI?
At times, facilities may be
required to change to a new
contract/toll formulator at a
moment's notice due to unforseen
circumstances. Can a waiver be
granted (from the local control
authority) to the new contract/toll
formulator for the 90-day
notification?
The POTW/control authority is authorized to view CBI, but
they must have procedures in place to protect CBI from un-
authorized public access. POTWs and control authorities have
to allow access to the public at least to the extent that the EPA
confidentiality regulations allow public access. 40 CFR
403.8(f)(l)(vii) requires POTWs (with approved pretreatment
programs) to implement legal authority that complies with 40
CFR 403.14. 40 CFR 403.14(b) and (c) require that effluent data
not be considered confidential, and all other information must
be made available to the extent required under 40 CFR 2.302.
Most POTWs have an allowance in their local ordinances for
confidentiality.
Any data associated with the "point of compliance" cannot be
held as CBI. Therefore, it depends on the point of compliance,
which should be explicitly listed in the permit. The point of
compliance in many regulations is upstream from a commin-
gled outfall.
If the new toll formulator is performing any in-scope PFPR
operations, then they do not need to provide a 90-day notifi-
cation; however, they would need to notify the control author-
ity of the "change of discharge" [40 CFR 403.120] and would
indicate this change in their PFPR periodic certification paper-
work.
If the new toll formulator does not currently perform any PFPR
operations, the toll formulator may need to meet zero dis-
charge (e.g., through off-site disposal or through sending
wastewater back to the facility through which they are con-
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tracting) or store the wastewater until a proper control mecha-
nism is in place.
Permit/Control Mechanism Issues
How does the POTW/control
authority regulate pollutants if
one production line is achieving
zero discharge and another
production line is complying with
the P2 alternative and they are
only sampling the discharge four
times per year?
Is it up to the discharger whether
or not they are a discharger (i.e.,
whether they choose to meet zero
discharge versus the P2
alternative, what treatment they
will perform, etc.)?
In the end, does the permitter
come up with a mass- or
concentration-based limit?
How much flexibility does a
control authority/permitter have to
modify a practice?
Does the PFPR rule give the
criteria the control
authority/permitting authority
can/should use in modifying
practices?
The final PFPR rule is different from other effluent guidelines
and standards in that there is no set of limitations to meet for
discharge. Therefore, the rule cannot be enforced by monitor-
ing end-of-pipe pollutant concentrations. To ensure that the
production line using the P2 alternative is complying with the
rule, the control authority/permitter would need to tour the
facility to determine that the P2 practices are in place and in
use, that the treatment system is well operated and maintained,
and that the paperwork is in place to document compliance.
These decisions are initially made by the discharger; however,
approvals are needed/required by the control/permitting
authority. Local jurisdiction can be more stringent, but not less
stringent than the national guidelines and standards. There-
fore, the final approach to complying with the PFPR rule is
really up to both the discharger and the regulating authority.
If the control authority does not respond to the discharger's
compliance paperwork with an approval or a disapproval, the
facility is still responsible for ensuring that they are in compli-
ance with 40 CFR 455 Subcategory C requirements.
It is not necessary for the permitter to develop such a limit,
although they may choose to do so if there are sufficient data
and an appropriate analytical method for the specified pesti-
cide active ingredient.
A control/permitting authority has the authority to use best
professional judgement (BPJ) to modify any practice. In so
doing, they should use the environmental hierarchy to pro-
mote pollution prevention practices first, followed by recy-
cle/reuse, treatment, and finally disposal. In addition, the final
rule enables permitting/control authorities to add or replace
P2 practices specified in the rule with new or innovative prac-
tices that are more effective at reducing the pollutant loadings
from a specific facility to the environment (see page 57526 of
the preamble to the final rule in Appendix A).
As discussed in the answer to the previous question, the pre-
amble to the final PFPR rule provides guidance to permit-
ter s/control authorities on the criteria for modifying P2
practices under the P2 alternative. See page 57526 of the pre-
amble to the final rule in Appendix A.
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If the control authority or
permitter is touring a facility and
finds that the plant is obviously
not following a specified Table 8
practice, is that cause for an
enforcement action?
How do control
authorities/permitting authorities
use Table 10?
How do treatment decisions work
and how does a permit writer
determine limits for
PFPR/manufacturing facilities?
In order for a control authority to
give a waiver for floor wash or
the final rinse of a triple rinse,
first, the wastewater must be
unable to be reused and, second,
the pesticide active ingredients in
the wastewater must be at levels
too low to be effectively
pretreated and that will not cause
interference at the POTW. How
does the control authority
determine the second condition?
If the facility has certified they are implementing a specific
Table 8 practice, but the control authority or permitter observes
that the practice is not being implemented or utilized, then this
could be cause for an enforcement action. However, many
PFPR facilities produce nonpesticide products on the same
equipment as pesticide products. Therefore, the control author-
ity/permitter should be sure that they are observing opera-
tions related to in-scope PFPR production before taking any
action.
If a PFPR facility chooses the P2 alternative and generates
wastewaters that require treatment prior to discharge follow-
ing implementation of P2 practices, then the control/permit-
ting authority can use Table 10 as one way to identify that the
treatment being used is "appropriate."
If a PFPR/manufacturing facility chooses to comply with zero
discharge, there is no allowance ("zero" allowance) given for
pesticide active ingredients that they also manufacture (i.e., the
limit is based solely on their manufacturing production). Non-
manufactured pesticide active ingredients must not be de-
tected in their effluent (i.e., the permit should specify zero
discharge).
If the facility chooses to comply with the P2 alternative, the P2
practices would be included in the facility's permit. The limi-
tation for pesticide active ingredients that are also manufac-
tured could be adjusted to include the facility's PFPR
production. If the pesticide active ingredient is not manufac-
tured, that pesticide active ingredient would not require a spe-
cific limitation. See page 57528 of the preamble to the final rule
in Appendix A for a detailed discussion of compliance for
PFPR/manufacturers.
Determining the levels at which the pesticide active ingredient
is not effectively pretreated is based more on BPJ than on an
objective number (e.g., the pesticide active ingredient concen-
tration). EPA developed the waiver with the goal of providing
some relief to facilities that were already implementing P2
practices by reusing all wastewater streams that were reusable,
and that would otherwise have to build a treatment system to
treat the inherently non-reusable wastewater streams (e.g.,
floor wash and a non-reusable final rinse of a triple rinse).
Control authorities may look at a facility's operations and de-
termine that, if a facility has successfully implemented P2 prac-
tices, it can use the waiver to discharge whatever small amount
of floor wash is left (after water conservation) or the final rinse
of a triple rinse to the POTW when the volume of that final
rinse exceeds the volume that is reusable.
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How can an enforcement agency
determine if a treatment system is
well operated and maintained?
Does a POTW/control authority
need to monitor specifically for
pesticide active ingredients to
ensure that a facility is complying
with the PFPR rule?
For a POTW/control authority to
set more stringent limitations, do
they have to show some basis
(e.g., evidence of pass through)? If
not, can industry sue?
How is the control authority able
to show compliance when there
are no numeric limits?
The determination of whether a treatment system is well op-
erated and maintained will be based on the rationale and
"method of demonstration" chosen by the facility and ap-
proved by the control/permitting authority. For example, if a
facility chose an activated carbon adsorption treatment system
based on treatability test data (including carbon saturation
loading/carbon breakthrough curves) and used that data to
establish a relationship between TOC and pesticide active in-
gredient concentrations, they might demonstrate that the sys-
tem is well operated and maintained by monitoring TOC and
documenting the frequency of carbon changeout. The enforce-
ment agency would then be able to review the TOC data and
carbon records to determine if the facility was complying with
their method of demonstration.
No, monitoring may not be economically feasible and there
may not be analytical methods available for all pesticide active
ingredients. Compliance with the P2 alternative may be shown
through ensuring that P2 practices have been implemented,
the appropriate treatment is in place and is well operated and
maintained, and documentation has been prepared and is read-
ily available at the facility.
If a facility chooses to comply with zero discharge through "no
flow" of process wastewater, the POTW/control authority
would mostly ensure compliance through facility inspection of
the PFPR process areas. However, if a facility is complying with
zero discharge by demonstrating non-detect levels of pesticide
active ingredients and priority pollutants, analytical methods
must exist and the POTW/control authority would monitor at
a minimum for expected priority pollutants and those pesticide
active ingredients used in PFPR production.
POTWs/control authorities are required by Federal Regula-
tions to develop local limits to protect against pass through
and interference (40 CFR 403.5(c) and 403.8(f)(4)). This means
the POTW/control authority must develop local limits that
protect the treatment plant from pollutants that may upset the
plant, pass through the plant untreated (or inadequately
treated), may endanger the well being of workers, or would
inhibit sludge management options. Some of these limitations
may be more stringent than limitations found in national cate-
gorical standards. The basis for these limitations would not be
the evidence of pass through or interference, but rather the
potential for pass through or interference. The pretreatment
regulations are designed to protect against pass through and
interference rather than react to it.
By ensuring that their categorical industrial users are maintain-
ing their on-site compliance paperwork accurately, that the
specified P2 practices have been implemented, and that the
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Under Section 403, the POTW is
required to take a certain number
of samples from the regulated
facility. How do they complete
this item when the facility is
complying with the P2
alternative? What is the absolute
minimum that the POTW must do
to meet requirements for a control
authority?
When is a PFPR facility not in
compliance with the rule (i.e.,
how is noncompliance determined
when numeric limits are not in
the permit)?
Can EPA provide guidance to
permit enforcement officials on
allowing negotiation of a
compliance plan without
penalties?
treatment systems are appropriate and have been demon-
strated to be well operated and maintained.
The PFPR rule does not require monitoring for pesticide active
ingredients. Therefore, the POTW would only need to monitor
for their local limits. Note that if a POTW monitors their efflu-
ent for pesticide active ingredients at the point of discharge to
the receiving stream, the contribution of pesticide active ingre-
dients comes not only from PFPR facilities but also nonpoint
source dischargers (e.g., agricultural runoff).
A facility is not in compliance if they are not implementing the
P2 practices specified in Table 8, have not documented their
justifications for modifications to those P2 practices, have not
documented the equivalency of their treatment system to the
list of "appropriate" technologies listed in Table 10, and are not
able to demonstrate that the system is well operated and main-
tained based on the rationale discussed in their on-site com-
pliance paperwork.
EPA's Small Business Policy promotes environmental compli-
ance by providing incentives, such as penalty waivers and
penalty mitigation, to those small businesses that participate
in on-site compliance assistance programs or conduct environ-
mental audits to discover, disclose, and correct violations. A
small business may be eligible under the Agency's "Policy on
Compliance Incentives For Small Businesses" to have all po-
tential penalties for non-compliance waived if the companies
agree to come into compliance and meet other criteria.
The policy applies to a person, corporation, partnership, or
other organization that employs 100 or fewer individuals. EPA
may eliminate its penalty against the small business if:
• the business receives on-site compliance assistance or con-
ducts an environmental audit;
• the business identifies the violation(s) through the assistance
or audit, and discloses it within 10 days (or such shorter
period provided by law) to the appropriate government
agencies;
• it is the first violation of the requirement in a three-year
period and no environmental enforcement actions against
the business have been taken in the last five years; the vio-
lation is corrected within 180 days after detection of the vio-
lation (or 360 days if pollution prevention is employed); and
• the violation has not caused actual serious harm, and does
not pose a potentially imminent and substantial endanger-
ment to the public or environment, does not involve criminal
conduct, and did not result in a significant economic benefit.
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As a PFPR facility, the flexibility
of the rule to develop
documentation in numerous ways
is helpful. However, if an auditor
finds a better or different P2
practice than what the facility has
found, what action will EPA take?
How will enforcement occur?
Are there any RCRA issues
associated with the practices
mentioned (e.g., storage and
reuse)?
If treating wastewaters that are
listed or characteristic wastes, is a
RCRA permit required?
Do changes specified in the
periodic certification require
NPDES permits to be reopened?
How does a facility determine
what to put in the permit for
operation of the treatment system
if the volume and characteristics
of the water changes over time?
For more information on the EPA's audit policies, please see
the web site for EPA's Office of Enforcement and Compliance
Assurance at http://www.epa.gov/oeca/index.html.
Better or improved pollution prevention practices should not
be the basis of an enforcement action. Enforcement actions
related to the P2 practices would be more likely to be incurred
if a P2 practice is listed in the control mechanism/permit and
is not being performed. In the case of a new practice brought
up by the control/permitting authority, the new P2 practice
must be agreed upon by both the facility and the control/per-
mitting authority and included in the permit/control mecha-
nism. After that, if facility is not following the practices, then
enforcement actions may be taken.
Yes. There is a discussion of RCRA issues on pages 57528 and
57529 of the preamble to the final rule (located in Appendix
A).
If these wastewaters are treated in a treatment system covered
by a Clean Water Act effluent guideline, the treatment system
is exempted from needing a RCRA permit. However, this does
not necessarily mean that the wastewater being treated is ex-
empt from RCRA regulations.
The method in which changes are incorporated into NPDES
permits may vary depending on the locality, state, or region in
which the facility is located; however, it may be possible to set
up the permit to specify that the P2 practices and appropriate
treatment requirements for the PFPR rule are located in an
approved plan, as is done with spill control plans. This method
may allow changes in practices or treatment to be incorporated
without reopening the whole permit.
If a facility adds new production, they may need to reevaluate
what treatment is appropriate for their PFPR wastewater
sources. When initially determining treatment requirements,
the facility should keep in mind that most PFPR facilities (after
implementing P2 practices) generate volumes of wastewater
small enough to store and treat periodically. Therefore, even
though there may be a large variation in daily or weekly waste-
water characteristics, it is more likely that wastewater treated
periodically (e.g., one time per quarter) will be more consistent
from one treatment batch to the next. In addition, a facility may
find it most useful to evaluate a long-term plan of present and
future production.
Over time, the facility will need to demonstrate that the system
is well operated and maintained for their changing wastewater
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Does the P2 alternative override
or make a current discharge
permit obsolete?
by keeping logs/records of the volumes and characteristics of
their wastewater.
Facilities that directly discharge wastewater will incorporate
the requirements of the PFPR rule (either zero discharge
and/or the P2 alternative) at the time their permit is issued,
reissued, or renewed.
Facilities that indirectly discharge wastewater and choose to
comply with the P2 alternative will have a new permit/control
mechanism put in place prior to the compliance deadline of
November 6, 1999. This permit/control mechanism can still
include aspects of previous permits, as well as additional local
limitaitons, as long as it incorporates the information necessary
for complying with the P2 alternative.
Potential to Discharge (see also Zero Discharge)
What will a permit for a zero
discharge/no-flow PFPR facility
look like?
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?
Who determines whether a facility
has the "potential to discharge"?
Facilities with no potential for discharge are not covered under
the PFPR categorical standards. For facilities that achieve zero
discharge, but have the potential to discharge, the permit
would most likely only require a certification statement that
the facility is at zero discharge. It may also list inspections that
the facility would undergo.
A facility may comply with zero discharge by demonstrating
that all pesticide active ingredients and priority pollutants are
below their method detection limits in the facility's final efflu-
ent, and only if all pollutants have approved analytical meth-
ods. A detection of any of these pollutants means the facility
is out of compliance with the rule.
The potential to discharge only includes regulated wastewater
sources. Sanitary water, as well as employee shower and laun-
dry 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 em-
ployees may discharge regulated wastewater sources through
a sanitary hookup, they may want to establish a training pro-
gram, including standard operating procedures (SOPs) to
cover the management of wastes at their site.
The facility is not covered under the scope of the rule, but may
want to notify their control/permitting authority and/or sub-
mit a certification stating that they have "no potential to dis-
charge" regulated PFPR wastewater sources. This certification
would be submitted to (and approved by) the control/permit-
ting authority following inspection.
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Compliance Time Line
When do facilities have to start
certifying their operations (i.e.,
now versus November 6,1999)?
If a new indirect discharging
facility comes into being in 1998,
do they have until November 6,
1999 to come into compliance with
the rule? If not, why not?
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?
Existing indirect dischargers (i.e., those facilities that discharge
to a POTW) must determine a specific compliance schedule
with their POTW/control authority. This schedule must in-
clude milestones that lead to compliance with the rule no later
than November 6, 1999.
Existing direct dischargers (i.e., those facilities that discharge
directly to a river or receiving stream) must be in compliance
at the time of issuance, renewal, or modification of their exist-
ing NPDES permit.
New sources must be in compliance with the PFPR rule at the
commencement of discharge.
A new indirect source (any PFPR facility that meets the defi-
nition of new source in 40 CFR 403.3(k) as of April 14, 1994)
must come into compliance when they begin discharging. New
sources were given the opportunity to plan for requirements
of the final rule (new source determination is made based on
the proposed rule date). Existing indirect sources were already
operating prior to the proposed rule and therefore could not
plan the design of their facilities to meet the final regulation
(this is especially true in the case of an effluent guideline where
standards are more stringent for new sources). NOTE: The
pretreatment standards are equal for existing and new sources
under the final PFPR rule.
40 CFR 403.6(b) is the citation that explains the difference be-
tween new and existing sources - "(b) Deadline for Compliance
with Categorical Standards. Compliance by existing sources with
categorical Pretreatment Standards shall be within 3 years of
the date the Standard is effective unless a shorter compliance
time is specified in the appropriate subpart of 40 CFR chapter
I, subchapter N....Existing sources which become Industrial Us-
ers subsequent to promulgation of an applicable categorical
Pretreatment Standard shall be considered existing Industrial
Users except where such sources meet the definition of a New
Source as defined in § 403.3(k). New Sources shall install and
have in operating condition, and shall "start-up" all pollution
control equipment required to meet applicable Pretreatment
Standards before beginning to Discharge. Within the shortest
feasible time (not to exceed 90 days), New Sources must meet
all applicable Pretreatment Standards."
New sources must complete a BMR 90 days prior to discharge
and must be in compliance with the PFPR pretreatment stand-
ards (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 author-
ity and have their on-site compliance paperwork completed.
Ninety days following commencement of discharge, the facil-
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CHAPTER 10 Workshop Questions and Answers
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After November 6,1999, when are
facilities (new sources) required to
submit their initial certification?
Is any paperwork required
between now and November 6,
1999 for indirect dischargers?
When does the BMR get
submitted? Is it after the permit
has been issued and after
decisions have been made on
treatability for the wastewater to
be discharged?
Why aren't facilities required to
submit their initial certification at
the time the BMR is due?
How does the November 6,1999
date apply to facilities that either
choose to achieve zero discharge
or already achieve zero discharge?
ity 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 compli-
ance 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.
At the time of permit issuance prior to discharge.
In addition to submitting the BMR, if a facility is not in com-
pliance at the time they submit the BMR, then they must de-
velop a compliance schedule with milestones with their control
authority. The facility would need to show they are meeting
each milestone on their way to full compliance.
No. For indirect dischargers, it is prior to the initial certifica-
tion. The BMR is the first piece of compliance paperwork re-
quired and is submitted well ahead of choosing wastewater
treatment technologies. The BMR is supposed to reflect current
operations, not necessarily compliance levels. The BMR was
due on July 7, 1997 for existing indirect dischargers.
Initial certifications are due no later than November 6, 1999,
although they may be submitted earlier. The BMR measures
the baseline performance of the facility, but the initial certifi-
cation cannot be made until the facility has invested time (and
often money) to gather the information needed to make the
compliance decisions (i.e., zero discharge or P2 alternative) that
are documented in the initial certification.
Indirect dischargers would need to be achieving zero discharge
by November 6, 1999 for those wastewater sources for which
they chose zero discharge in the initial certification statement.
If the facility is already meeting zero discharge, then they
would not need to set up the 90-day compliance schedule with
milestones discussed in 40 CFR 403.
Direct dischargers must be in compliance at the time of issu-
ance, reissuance, or modification of their NPDES permit.
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CHAPTER 10 Workshop Questions and Answers
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Do all facilities within the scope
of the PFPR rule have to meet
zero discharge by the November
6,1999 compliance date?
Should initial certification
paperwork be completed before
installing full-scale treatment?
Does the 3-year compliance date
of November 6,1999 apply to
facilities choosing the P2
alternative (i.e., do they have until
November 6,1999 to install
treatment systems)?
Does the treatment system have to
be fully tested and operational at
the time the initial certification
statement is submitted?
When is a facility allowed to
discharge after selecting a
compliance option?
Must the control/permitting
authority approve the P2 practices
and modifications before they are
implemented?
No. Existing indirect discharging facilities have to be in com-
pliance with either zero discharge or the P2 alternative on a
source by source basis no later than November 6,1999. Existing
direct dischargers must be in compliance at the time of issu-
ance, reissuance, or modification of their NPDES permit.
Indirect dischargers must set up a compliance schedule with
their POTW or control authority that specifies milestones to be
achieved to assure compliance by November 6,1999, including
the installation and operation of any necessary treatment re-
quired prior to discharge. The initial certification paperwork
must be completed by or before the compliance deadline.
Direct dischargers must complete the initial certification pa-
perwork by the time of permit issuance, reissuance, or renewal.
The 3-year compliance date only applies to indirect dischargers
and this is the date at which they must be in compliance with
the rule. If the facility wishes to be discharging wastewater at
that time and treatment of that wastewater is necessary for
compliance, the appropriate treatment system would need to
be installed, tested, and a procedure for determining that it is
well operated and maintained determined. Indirect dis-
chargers must establish milestones with their control authority
that the facility must meet to achieve compliance with the rule
by November 6, 1999.
Indirect dischargers must set up milestones for achieving com-
pliance with the PFPR rule by November 6, 1999; therefore, it
is possible that the treatment system may be tested following
submission of the initial certification statement. However, the
system must be fully operational by the agreed date of com-
pliance or November 6, 1999, whichever is earlier.
Direct dischargers may also submit the initial certification
statement before the issue, reissue, or renewal of their permit
is complete. In such a situation, the treatment system may not
yet be fully operational.
If a facility is not currently discharging PFPR wastewater, they
may begin discharging wastewater under the terms of their
permit/control mechanism as soon as their permit/control
mechanism is in place.
If the P2 practice and modification are listed in Table 8 to Part
455, then the control/permitting authority does not need to
give prior approval; however, they do have the right to ensure
that the proper backup documentation is present at the facility
to justify the modification and to ensure that local limitations
are being complied with.
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CHAPTER 10 Workshop Questions and Answers
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When is the periodic certification
required, now or after November
6,1999?
If a customer asks a facility to
begin making a new product,
when must the control authority
be notified and when can
discharge begin?
If the P2 practice and modification are not listed in Table 8, the
control/permitting authority does need to approve the practice
with modification prior to discharge.
The periodic certification requirement begins after the facility
has submitted their initial certification and is required twice
per year for indirect dischargers and once per year for direct
dischargers. The timing of submittal can be coordinated with
the submittal of compliance paperwork required by the Gen-
eral Pretreatment Regulations or the NPDES regulations.
The facility must notify their control/permitting authority if a
change in discharge is occurring, implement the appropriate
P2 practices, update their treatment system to include the ap-
propriate or equivalent treatment if new pesticide active ingre-
dients exist in the wastewater to be treated, and receive
approval before discharging wastewater associated with the
new product. A facility is allowed to begin production at any
time; however, they may need to store the generated wastewa-
ter until discharge approval is received.
Other Questions
The Section 403 regulations were
revised to change the language
from a "pretreatment agreement"
to "control mechanism" because
of concerns regarding the legal
implications of that language. The
PFPR regulations seem to be
adding the pretreatment
agreement language back in. Why
are the two regulations
inconsistent?
Is there any way the government
can track the commodity
chemicals used in pesticide
products by PFPR and pesticide
manufacturing facilities?
The term "pretreatment agreement" in the PFPR regulation
was not used intentionally; it is intended to be a synonym for
an individual control mechanism or permit.
Facilities are required to submit Confidential Statements of
Formula (CSFs) to EPA, which include the specific "recipe" for
the product registered; however, these recipes are typically
considered confidential business information (CBI) under FI-
FRA.
Also, facilities are required to report emissions of toxic chemi-
cals under the SARA Section 313 program (i.e., the Toxic Re-
lease Inventory program). However, PFPR facilities often do
not use toxic chemicals in the amounts necessary to trigger
reporting under this program, although some pesticide manu-
facturers do.
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CHAPTER 10 Workshop Questions and Answers
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How did EPA come to the
conclusion that facilities would
store wastewater and treat it
quarterly?
Was toxicity testing considered in
lieu of the P2 alternative?
Will the P2 Guidance Manual be
available on the Internet?
Is there a place where treatability
data could be logged or collated
so all facilities can utilize the
results?
How do we determine the CAS
numbers of the pesticide active
ingredients listed on Table 10?
A storage period of 90 days or longer prior to treatment is not
uncommon in this industry, based on information EPA gath-
ered during site visits. EPA originally evaluated batch treat-
ment of PFPR wastewater on a quarterly basis because of
possible RCRA requirements that might be applicable if waste-
water was stored for more than 90 days on site (or 180 days
for small quantity generators). EPA determined that, under the
P2 alternative, wastewater stored for more than 90 days prior
to reuse would not need a RCRA storage permit if it was haz-
ardous. Most interior rinsates are expected to be reused and/or
be non-RCRA hazardous. See page 57529 of the preamble to
the final rule in Appendix A for more detail.
When facilities are treating RCRA-hazardous wastewaters
prior to discharge, the 90-day limit for large quantity gener-
ators (and the 180-day limit for small quantity generators) still
applies. In addition, EPA believes that facilities will wish to
limit the length of time that wastewater is stored prior to treat-
ment even when non-hazardous.
No, the Clean Water Act requires effluent limitations guide-
lines and standards to be technology-based, not risk-based.
However, toxicity-testing may be used in combination with the
P2 alternative to provide a surrogate measure for demonstrat-
ing that the treatment system is well operated and maintained.
Yes. The Guidance Manual can be found on EPA's Effluent
Guidelines web site (http://www.epa.gov/OST/guide) under
the Pesticide Formulating, Packaging, and Repackaging Indus-
try.
At this time, there is no specific clearinghouse for information
on PFPR treatment technologies or treatability data. However,
interested parties can check into other EPA clearinghouses or
databases on the Internet via the EPA Homepage:
http://www.epa.gov.
EPA has included a table in Appendix C that lists pesticide
active ingredients from Table 10 with their corresponding
Shaughnessey codes and CAS numbers.
158
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P2
1. of the
More Detail Right Amount Less Detail
Chapter—Title Needed of Detail Needed
I—Introduction Q Q Q
2^PFPR Operations Q Q Q
3—Pollution Prevention Glossary Q Q Q
4—Conducting the P2 Audit Q Q Q
5—Wastewater Treatment Technologies Q Q Q
6—Conducting the Treatability Test Q Q Q
7—Regulatory Compliance Documentation Q Q Q
8~-Case Studies Q Q Q
9—Where to Get Additional P2 Help Q Q Q
10—Workshop Questions and Answers Q Q Q
2. Is of
3. list you would suggest.
4. Are of are
5. How be to the of the rule?
6. Do you EPA communicated guidance Information pertaining to
in an
Q yes Q no (please elaborate)
7, If are a PFPR facility, or you to the P2
Alternative Option, are you to any P2 practices as a
of an EPA Pf PR P2 If so,
which one(s)?
159
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P2 Guidance Manual Feedback Survey Pollution Prevention Guidance Manual for the PFPR Industry
8. What additional Information could EPA provide to
» the P2 practices easier:
• the P2 Alternative Option easier:
9. Do you for:
Yes No
• Determining compliance with PFPR rule? Q Q
* Evaluating PFPR process(es) for P2 opportunities? Q Q
» Evaluating treatment technologies? Q Q
10. the your
Q Pesticide manufacturing/PFPR facility
Q PFPR facility
Q Trade association
Q POTW
Q State or regional EPA permitter
Q Other
II. the your
prior to
Very Somewhat Not at all
Familiar Familiar Familiar
PFPR Operations Q Q Q
Effluent Guidelines Q Q Q
P2 Alternative Option Q Q Q
Pollution Prevention Q Q Q
Wastewater Treatment Technologies Q Q Q
(foW fen? to mail)
Ms. Shari Zuskin
U.S. Environmental Protection Agency
Engineering and Analysis Division (4303)
401 M Street, SW
Washington, DC
160
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PFPR Final Regulation
(40 CFR Part 455)
161
-------
Wednesday
November 6, 1996
Part II
Environmental
Protection Agency
40 CFR Part 455
Pesticide Chemicals Category,
Formulating, Packaging and Repackaging
Effluent Limitations Guidelines,
Pretreatment Standards, and New Source
Performance Standards; Final Rule
57517
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57518 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 455
[FRL-5630-9]
RIN 2040-AC21
Pesticide Chemicals Category,
Formulating, Packaging and
Repackaging Effluent Limitations
Guidelines, Pretreatment Standards,
and New Source Performance
Standards
AGENCY: Environmental Protection
Agency.
ACTION: Final rule.
SUMMARY: This final regulation limits
the discharge of pollutants into
navigable waters of the United States
and into publicly owned treatment
works (POTWs) by existing and new
facilities that formulate, package and
repackage pesticide products. This
regulation covers two subcategories of
the Pesticide Chemicals Point Source
Category—Subcategory C: Pesticide
Formulating, Packaging and
Repackaging (PFPR) which includes
PFPR facilities that also manufacture
pesticide active ingredients (PFPR/
Manufacturers) and Subcategory E:
Agricultural Refilling Establishments.
EPA estimates that there are
approximately 2,600 facilities in the
industry. This regulation establishes
effluent limitations guidelines and
standards under the Clean Water Act
including "best conventional pollutant
control technology (BCT), and "best
available technology economically
achievable (BAT)" for existing direct
dischargers, "new source performance
standards (NSPS)" for new direct
dischargers and "pretreatment standards
for existing and new indirect
dischargers (PSES and PSNS)". This
regulation also amends and clarifies the
limitations based on "best practicable
control technology (BPT)" for direct
discharging facilities.
Under the final rule refilling
establishments (Subcategory E) will be
required to achieve zero discharge of
wastewater pollutants. The final
regulation provides Subcategory C
facilities (herein referred to as "PFPR
facilities") a choice between zero
discharge and the "Pollution Prevention
Alternative." This compliance
alternative was developed in response
to comments on the proposed rule from
the industry and has received a large
amount of industry support in
comments on the supplemental notice.
This structure provides a compliance
option to facilities who agree to
implement certain pollution prevention,
recycle and reuse practices. Facilities
choosing and implementing the
pollution prevention alternative will
receive a discharge allowance.
The final rule will benefit the
environment by removing toxic
pollutants (pesticide active ingredients
and priority pollutants) from water
discharges that have adverse effects on
human health and aquatic life. EPA has
estimated the compliance costs and
economic impacts expected to result
from the Zero Discharge/Pollution
Prevention Alternative (i.e., Zero/P2
Alternative). The Agency has
determined that the Zero/P2 Alternative
will result in a similar removal of toxic
pound equivalents per year
(approximately 7.6 million toxic pound
equivalents) as the zero discharge
option alone. At the same time, the
Zero/P2 Alternative is expected to result
in a reduced annualized cost ($29.9
million in 1995), no facility closures
and 150 moderate impacts. EPA has
determined that both Zero Discharge
and the Zero/P2 Alternative are
economically achievable. However,
EPA's addition of the pollution
prevention alternative to achieving zero
discharge provides benefits to the
environment by minimizing the
potential cross-media impacts that
would otherwise occur from hauling
and incinerating the non-reusable
portion of PFPR wastewaters. The
provision of an alternative compliance
method also provides flexibility to
industry in meeting the effluent
limitations guidelines and standards.
DATES: This regulation shall become
effective January 6, 1997. The
information collection requirements
contained in this rule are included in
two separate Information Collection
Request 0CR) documents. The NPDES/
Compliance Assessment/Certification
ICR (No. 1427.05) and the National
Pretreatment Program (40 CFR part 403)
ICR (No. 0002.08). OMB has not yet
approved these ICRs; therefore, the
information collection requirements
contained in this rule are not effective
until OMB has approved them. Once
OMB has approved the ICRs, EPA will
publish another notice in the Federal
Register to announce OMB's approval
and to amend 40 CFR Part 9 to indicate
the OMB approval number. The
compliance date for §§ 455.46 and
455.66 (PSES) is as soon as possible, but
no later than November 6, 1999. The
compliance dates for §§ 455.45 and
455.65 (NSPS) and §§455.47 and 455.67
(PSNS) are the dates the new sources
commence discharging. Deadlines or
compliance with §§ 455.42 and 455.62
(BPT), §§455.43 and 455.63 (BCT), and
§§455.44 and 455.64 (BAT) are
established in the National Pollutant
Discharge Elimination System (NPDES)
permits.
ADDRESSES: For additional technical
information write to Ms. Shari H.
Zuskin, Engineering & Analysis Division
(4303), U.S. EPA, 401 M Street SW,
Washington, D.C. 20460 or send e-mail
to: zuskin.shari@epamail.epa.gov or call
at (202) 260-7130. For additional
economic information contact Dr. Lynne
Tudor at the address above or by calling
(202) 260-5834.
The complete record (excluding
confidential business information) for
this rulemaking is available for review
at EPA's Water Docket; 401 M Street,
SW, Washington, DC 20460. For access
to Docket materials, call (202) 260-3027
between 9 a.m. and 3:30 p.m. for an
appointment. The EPA public
information regulation (40 CFR part 2)
provides that a reasonable fee may be
charged for copying.
The Technical Development
Document [EPA-821-R-96-019],
Economic Analysis [EPA-821-R-96-
017] and Cost-Effectiveness Analysis
[EPA-821-R-96-018] supporting
today's final rule may be obtained by
writing to the EPA Office of Water
Resource Center (RC-4100), 401 M
Street SW., Washington, DC 20460, or
calling (202) 260-7786.
FOR FURTHER INFORMATION CONTACT: For
additional technical information write
or call Ms. Zuskin at (202) 260-7130.
For additional information on the
economic impact analyses contact Dr.
Lynne G. Tudor at the above address or
by calling (202) 260-5834.
EPA is preparing a PFPR Pollution
Prevention Alternative Guidance
Manual and a series of regional
workshops to aid industry, permit
writers and control authorities in
implementing the final rule. A public
announcement will be published in
Federal Register regarding availability
of the guidance manual and the dates
and locations of the regional workshops.
SUPPLEMENTARY INFORMATION:
Regulated Entities
Entities potentially regulated by this
action are: (1) Those which generate
process wastewater from the
formulation, packaging and/or
repackaging of pesticide products
(excluding those pesticide active
ingredients not covered by the rule); or
(2) those which are agricultural refilling
establishments. Regulated categories
and entities include:
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57519
Category
Industry
Examples of regulated entities
Pesticide formulating, pack-
aging and repackaging
(PFPR) facilities;
PFPR facilities that also
manufacture pesticide ac-
tive ingredients;
Agricultural refilling estab-
lishments.
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
regulated by this action. This table lists
the types of entities that EPA is now
aware could potentially be regulated by
this action. Other types of entities not
listed in the table could also be
regulated. To determine whether your
facility is regulated by this action, you
should carefully examine the
applicability criteria in § 455.40 and
§455.60 of the rule. If you have
questions regarding the applicability of
this action to a particular entity, consult
the person listed in the preceding FOR
FURTHER INFORMATION CONTACT section.
Preamble Outline
I. Legal Authority
II. Background
A. Clean Water Act
B. Pollution Prevention Act
C. Updated Industry Overview
D. Final Rule
E. The Proposed Rule
F. The Supplemental Notice
III. Summary of Most Significant Changes
from Proposal
A. Scope
1. Pesticide Active Ingredients (PAIs)
a. Sanitizer Active Ingredients and Pool
Chemicals
b. Other Pesticide Active Ingredients
c. Liquid Chemical Sterilants
2. Wastewater Sources
B. Zero Discharge/Pollution Prevention
Alternative Option
1. Cross Media Impacts and Incineration
Issues
2. Cross-Contamination Policy
3. Request for De Minimis Discharge
4. Pollution Prevention Alternative
C. Applicability to On-Site and Stand-
alone Research & Development (R&D)
Laboratories
D. Clarification of Issues Concerning PFPR/
Manufacturers
1. Stabilizing versus Formulating
2. On-site Incineration as Zero Discharge
3. Amending and Clarifying of BPT
E. Clarification of Refilling Establishments
F. RCRA Issues
IV. The Final Regulation
A. Pretreatment Standards for Existing
Sources (PSES)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
B. Best Practicable Control Technology
Currently Available (BPT)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
C. Best Available Technology
Economically Achievable (BAT)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
D. New Source Performance Standards
(NSPS)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
E. Pretreatment Standards for New Sources
(PSNS)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
F. Best Conventional Pollutant Control
Technology (BCT)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
V. Economic Considerations
A. Introduction
B. Review of the Proposed Regulation
1. Subcategory C: PFPR and PFPR/
Manufacturers
2. Subcategory E: Refilling Establishments
C. Changes to the EIA Since Proposal:
Issuance of the June 1995 Supplemental
Notice
D. Assessment of Costs and Impacts for the
Final PFPR Regulations
1. Summary of Economic Impact Analysis
Methodology and Data
2. Estimated Facility Economic Impacts
a. Subcategory C: PFPR and PFPR/
Manufacturers
b. Subcategory E: Refilling Establishments
4. Regulatory Effects Not Re-Estimated
5. Impacts of Pretreatment Standards for
New Sources (PSNS) and New Source
Performance Standards (NSPS)
a. Subcategory C: PFPR and PFPR/
Manufacturers
(1) PSNS
(2) NSPS
b. Subcategory E: Refilling Establishments
6. Cost-Effectiveness Analysis
a. Subcategory C: PFPR and PFPR/
Manufacturers
b. Subcategory E: Refilling Establishments
E. Regulatory Flexibility Act
1. Analysis of Impacts on Small Business
Entities
2. Analysis of Impacts on Other Small
Entities
VI. Unfunded Mandates Reform Act
VII. Executive Order 12866
VIII. Small Business Regulatory Enforcement
Fairness Act of 1996 (SBREFA)
IX. Paperwork Reduction Act
X. Water Quality Analysis
XI. Non-Water Quality Environmental
Impacts
A. Air Pollution
B. Solid Waste
C. Energy Requirements
XII. Regulatory Implementation
A. Implementation of the Limitations and
Standards
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2. Refilling Establishments (Subcategory E)
B. Upset and Bypass Provisions
C. Variances and Modifications
1. Fundamentally Different Factors
Variances
2. Removal Credits
D. Analytical Methods
Appendix A—List of Abbreviations,
Acronyms and Other Terms Used In This
Document
I. Legal Authority
This final regulation establishes
effluent guidelines and standards of
performance for the Pesticide
Formulating, Packaging and
Repackaging Subcategories of the
Pesticide Chemicals Point Source
Category under the authorities of
sections 301, 304, 306, 307, and 501 of
the Clean Water Act ("the Act"), 33
U.S.C. 1311, 1314, 1316, 1317, and
1361.
In accordance with 40 CFR part 23,
this regulation shall be considered
promulgated for purposes of judicial
review at 1 p.m. Eastern time on
November 20, 1996. Under section
509(b)(l) of the Act, judicial review of
this regulation can be had only by filing
a petition for review in the United
States Court of Appeals within 120 days
after the regulation is considered
promulgated for purposes of judicial
review. Under section 509 (b)(2) of the
Act, the requirements in this regulation
may not be challenged later in civil or
criminal proceedings brought by EPA to
enforce these requirements.
II. Background
A. Clean Water Act
The Federal Water Pollution Control
Act Amendments of 1972 established a
comprehensive program to "restore and
maintain the chemical, physical, and
biological integrity of the Nation's
waters," (section 101(a)). To implement
the Act, EPA is to issue effluent
limitations guidelines, pretreatment
standards and new source performance
standards for industrial dischargers.
These guidelines and standards are
summarized in the proposed regulation
at 59 FR 17850, 17851-52 (April 14,
1994).
Section 304(m) of the Clean Water Act
(33 U.S.C. 1314(m)), added by the Water
Quality Act of 1987, requires EPA to
establish schedules for (1) reviewing
and revising existing effluent limitations
guidelines and standards ("effluent
guidelines"), and (2) promulgating new
effluent guidelines. On January 2, 1990,
EPA published an Effluent Guidelines
Plan (55 FR 80), in which schedules
were established for developing new
and revised effluent guidelines for
several industry categories. One of the
industries for which the Agency
established a schedule was the Pesticide
Chemicals Point Source Category.
Natural Resources Defense Council,
Inc. (NRDC) and Public Citizen, Inc.,
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challenged the Effluent Guidelines Plan
in a suit filed in U.S. District Court for
the District of Columbia (NRDC etalv.
Reilly, Civ. No. 89-2980). The plaintiffs
charged that EPA's plan did not meet
the requirements of sec. 304(m). A
Consent Decree in this litigation was
entered by the Court on January 31,
1992. The terms of the Consent Decree
are reflected in the Effluent Guidelines
Plan published on September 8, 1992
(57 FR 41000). This plan states, among
other things, that EPA will propose and
take final action on effluent guidelines
for the formulating, packaging and
repackaging subcategories of the
pesticide chemicals category by dates
certain.
B. The Pollution Prevention Act
The Pollution Prevention Act of 1990
(PPA) (42 U.S.C. 13101 etseq., Pub. L.
101-508, November 5, 1990) "declares it
to be the national policy of the United
States that pollution should be
prevented or reduced whenever feasible;
pollution that cannot be prevented
should be recycled in an
environmentally safe manner, whenever
feasible; pollution that cannot be
prevented or recycled should be treated
in an environmentally safe manner
whenever feasible; and disposal or
release into the environment should be
employed only as a last resort* * *"
(Sec. 6602; 42 U.S.C. 13101(b). In short,
preventing pollution before it is created
is preferable to trying to manage, treat
or dispose of it after it is created. This
effluent guideline was reviewed for its
incorporation of pollution prevention as
part of this Agency effort.
According to the PPA, source
reduction reduces the generation and
release of hazardous substances,
pollutants, wastes, contaminants or
residuals at the source, usually within a
process. The term source reduction
"include [s] equipment or technology
modifications, process or procedure
modifications, reformulation or redesign
of products, substitution of raw
materials, and improvements in
housekeeping, maintenance, training, or
inventory control." The term "source
reduction" does not include any
practice which alters the physical,
chemical, or biological characteristics or
the volume of a hazardous substance,
pollutant, or contaminant through a
process or activity which itself is not
integral to or necessary for the
production of a product or the providing
of a service."42 U.S.C. 13102(5). In
effect, source reduction means reducing
the amount of a pollutant that enters a
waste stream or that is otherwise
released into the environment prior to
out-of-process recycling, treatment, or
disposal.
The PPA directs the Agency to, among
other things, "review regulations of the
Agency prior and subsequent to their
proposal to determine their effect on
source reduction" (Sec. 6604; 42 U.S.C.
13103(b)(2). This directive led the
Agency to implement a pilot project
called the Source Reduction Review
Project that would facilitate the
integration of source reduction in the
Agency's regulations, including the
technology-based effluent guidelines
and standards.
C. Updated Industry Overview
The pesticide formulating, packaging
and repackaging industry is made up of
two distinct types of activities. These
activities result in subcategorization for
purposes of this rulemaking. The two
subcategories are referred to as:
• Subcategory C: Pesticides
formulating, packaging and repackaging
(PFPR) including pesticides
formulating, packaging and repackaging
occurring at pesticides manufacturing
facilities (PFPR/Manufacturer) and at
stand-alone PFPR facilities; and
• Subcategory E: Repackaging of
agricultural chemicals at refilling
establishments (Refilling
Establishments).
The pesticide formulating, packaging
and repackaging industry covered by
this rulemaking is made up of an
estimated 2,631 in-scope facilities.
These facilities are located throughout
the country, with greater concentrations
of refilling establishments located in the
Midwestern and southeastern states to
serve the agricultural market.
The Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) requires
that any substance intended to prevent,
destroy, repel or mitigate any pest must
be registered with EPA and bear a label
directing the safe use of the product. 7
U.S.C. 136a. In addition, production of
all pesticide products must be reported
annually to EPA. 7 U.S.C. 136e. Thus,
EPA has extensive data on the contents
of pesticide products, their annual
production, who formulates, packages
or repackages these products and the
uses for which these products are
registered. EPA's Office of Water made
extensive use of this data in its analysis
of the pesticide formulating, packaging
and repackaging industry.
Based on 1988 FIFRA establishment
registration data, EPA identified the
pesticide formulating, packaging, and
repackaging facilities in the United
States that were using one or more of
the active ingredients that were the
focus of the Pesticide Manufacturing
rulemaking. These pesticide active
ingredients are referred to as the "272
PAIs" and were the focus of the survey
questionnaire for the PFPR rule 1988
data collection.1 EPA sent out
approximately 700 questionnaires using
a stratified random sample of these
facilities. Based on these survey results,
EPA estimates that for all of the PAIs
covered by the final rule (in-scope 272
and non-272 PAIs), that in 1988 there
were approximately 1,497 facilities
involved in formulating, packaging and
repackaging pesticide products (of
which 413 facilities processed non-272
PAIs only) and approximately 1,134
refilling establishments.2
Included in the 1,497 PFPR facilities,
there were 48 pesticide manufacturing
facilities in the pesticide chemicals
manufacturing rulemaking survey
database (58 FR 50637, September 28,
1993) that also formulated and packaged
pesticide products containing any of the
272 PAIs which were the focus of that
rulemaking. A detailed description of
the development of this profile is
contained in Section 3 of the Technical
Development Document [EPA-821-R-
96-019] for this final rule.
Pesticide formulating is the mixing/
diluting of one or more PAIs with active
or inert ingredients, without a chemical
reaction, to obtain a manufacturing use
or end use product (see §455.10 of the
final regulation for the definitions of
formulating, packaging, repackaging and
refilling establishment). Pesticide
formulations take all forms: Water-based
liquid; organic solvent-based liquid; dry
products in granular, powder, solid
forms; pressurized gases; and aerosols.
The formulations can be in a
concentrated form requiring dilution
before application or can be ready to
apply. The packaging of the formulated
pesticide product is dependent on the
type of formulation. Liquids generally
are packaged into jugs, cans, or drums;
dry formulations generally are packaged
into bags, boxes, drums, or jugs.
Pressurized gases are packaged into
cylinders. Some formulations are
packaged into aerosol cans.
As described above, the formulating,
packaging and repackaging industry
produces products in different forms.
EPA has observed formulating,
packaging or repackaging performed a
number of different ways ranging from
very sophisticated and automated
1 All remaining pesticide active ingredients are
referred to in today's notice as the "non-272 PAIs."
In addition, not all non-272 PAIs are in the scope
of this rulemaking.
2 EPA has not re-estimated the number of
refilling establishments based on both 272 PAIs and
non-272 PAIs because EPA believes that there
would not be any refilling establishments that use
only non-272 PAIs.
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formulation and packaging lines to
completely manual lines. In general, for
liquid products the process involves
mixing the active ingredient with liquid
inert ingredients in a tank and then
transferring the product to containers.
For dry products, the active ingredient
may be sprayed in liquid form onto a
dry substrate or it may be mixed in dry
form. Dry products may undergo
processes for mixing, grinding, sifting
and finally packaging. The formulating
process for aerosol products is the same
as for liquid products, but the packaging
is more complex and involves filling the
container, capping it, drawing a vacuum
on the container, adding propellant
under pressure, and sealing the
container.
Some other types of pesticide
products include collars to repel and
kill fleas and ticks; pesticides that are
micro-encapsulated; and pesticides that
are formed into solid shapes.
The pesticide industry is changing
and efforts are being made to improve
products to meet demands of consumers
for less toxic and safer pesticides. For
example, water-based solutions are
gradually replacing organic solvents in
liquid pesticide formulations.
Developments in packaging also are
underway. For example, the growing
use of water soluble packages can
reduce worker exposure to pesticides
and minimize problems with disposal of
packaging.
The refilling establishments represent
a newer population of facilities that was
identified in the Agency's Survey of
Pesticide Producing Establishments.
EPA discovered a significant population
of facilities that reported repackaging
only. These facilities are retail and
wholesale dealers of agricultural
chemicals and farm supplies. These
facilities repackage pesticides, usually
herbicides, into refillable containers
which are used to transport the
pesticide to the site where it is applied.
The use of refillable containers began
to grow during the 1980's (and became
widespread in the 1990's) to reduce the
number of empty pesticide containers
needing to be disposed of by farmers. In
general, registrants distribute large
undivided quantities of pesticides to
dealerships (refilling establishments)
where the products are stored in large
bulk tanks. The dealer then repackages
the pesticide from the bulk storage tanks
to portable minibulk containers that
generally have capacities of about 110
gallons. The increased use of refillable
containers led to an increased amount of
herbicide stored in bulk quantities and
the need to have a secondary
containment system built around the
bulk storage tanks. Separate from this
rulemaking, EPA has proposed a
regulation under FIFRA that sets
standards for such secondary
containment structures (59 FR 6712;
February 11, 1994). In addition, many
states (22 have/are developing
secondary containment regulations)
now require secondary containment for
bulk pesticide storage and dispensing
operations.
D. Final Rule
Today's final rule sets forth an
innovative and flexible, yet
environmentally protective, approach
for the establishment of effluent
limitations and pretreatment standards
under the Act. For Subcategory C—
facilities that formulate, package, or
repackage pesticides—EPA is
establishing effluent limitations and
pretreatment standards which allow
each facility to choose to meet a zero
discharge limitation or comply with a
pollution prevention alternative that
authorizes discharge of PAI and priority
pollutants after various pollution
prevention practices are followed and
treatment is conducted as needed (now
characterized as the Zero/P2 Alternative
option). This rule also establishes a zero
discharge limitation and pretreatment
standard for agricultural pesticide
refilling establishments (Subcategory E).
EPA had originally proposed a zero
discharge limitation and pretreatment
standard for PFPR facilities. 59 FR
17850 (April 14, 1994). EPA received
comment which argued that the
proposed zero discharge limitation and
pretreatment standard would result in
adverse non-water quality
environmental impacts and that the
scope of the proposed rule should be
refined in a variety of ways. Various
members of the PFPR community
commented that the Agency should
adopt a final rule which would require
facilities to engage in pollution
prevention practices and thereafter
discharge de minimis levels of PAI and
priority pollutants in the process
wastewaters. Upon receiving these
comments, EPA published a
Supplemental Notice which described
the Zero/P2 alternative option in
addition to some potential changes in
the scope of the rule. 60 FR 30217 (June
8, 1995).
Today's rule adopts the Zero/P2
alternative option for PFPR facilities
and changes the scope by reducing the
number of PAIs and wastewater sources
which are addressed. Under the Zero/P2
option each owner or operator of a PFPR
facility in Subcategory C will make an
initial choice of whether the facility will
meet zero discharge or comply with the
P2 Alternative. This choice can be made
on a product family/process line/
process unit basis rather than a facility
wide basis. If the zero discharge option
is chosen, the facility owner/operator
will need to do whatever is necessary,
e.g., wastewater reuse or recycle, either
with or without treatment, incineration
on-site or haul the wastewater for
incineration off-site or underground
injection, so that zero discharge of PAIs
and priority pollutants in the
wastewater is achieved.
If the P2 Alternative portion of the
option is chosen for a particular PAI
product family/process line/process
unit, then the owner/operator of the
facility must agree to comply with the
P2 practices identified in Table 8 to Part
455 of today's rule for that PFPR family/
line/unit. This agreement to comply
with the P2 practices and any necessary
treatment would be contained in the
NPDES permit for direct discharging
PFPR facilities or in an individual
control mechanism with the control
authority, i.e., the POTW, for indirect
discharging PFPR facilities (see
403.12 (a) for the definition of control
authority). In general, PFPR facilities
choosing the P2 Alternative need only
to submit a small portion of the
paperwork to a permitting or control
authority (e.g., initial and periodic
certification statements). The on-site
compliance paperwork is described in
Part XII. A.I of today's notice.
Today's rule changes the scope of the
proposed rule in the following ways.
First, the rule does not cover PAIs
which are sanitizers, including pool
chemicals. Also certain liquid chemical
sterilants that are used on critical or
semi-critical medical devices are not
covered. Second, the rule does not
apply to PAIs that are microorganisms,
such as Bacillus thuringiensis (B.t).
Third, the rule does not apply to two
groups of PAIs that are mixtures—Group
1 Mixtures include substances which
pose no risks and Group 2 Mixtures
include substances whose treatment
technology has not been identified.
Fourth, the pretreatment standards
portion of the rule does not apply to one
PAI and three priority pollutants which
EPA has determined will not pass
through or interfere with POTWs.
Today's rule also does not cover
inorganic wastewater treatment
chemicals. With regard to wastewater
sources, EPA has decided not to cover
storm water at PFPR facilities or at
refilling establishments through this
rule. In addition, there are a few other
wastewater sources such employee
showers, on-site laundries, fire
equipment test water, eye washes and
safety showers, certain Department of
Transportation (DOT) aerosol leak test
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bath water and laboratory water that are
not considered process wastewater
under the final rule.
EPA believes that this rule is an
important example of how the Agency
is re-inventing environmental
regulation. The Zero/P2 alternative
option being promulgated today is
cheaper for the regulated community to
comply with than the proposed zero
discharge standard. The Zero/P2
alternative option is smarter than the
proposed zero discharge standard
because it incorporates flexibility in
choosing which option is best for a
particular product line. The Zero/P2
alternative option is cleaner than the
proposed zero discharge standard
because the P2 Alternative reduces
cross-media impacts to the environment
while still achieving, virtually, the same
level of pollutant removal from
discharges of PFPR process wastewaters
(see Section XI for a discussion on the
non-water quality impacts associated
with the final rule).
E. The Proposed Rule
On April 14, 1994 (59 FR 17850), EPA
proposed effluent limitations guidelines
and standards for the control of
wastewater pollutants from the
Pesticide Formulating, Packaging and
Repackaging (PFPR) Industry. The
proposed rulemaking covered two
subcategories. Subcategory C included
stand-alone PFPR facilities as well as
formulating, packaging and repackaging
at pesticide manufacturing facilities
(PFPR/Manufacturers). Subcategory E,
as proposed, included repackagers of
agricultural pesticides at refilling
establishments ("refilling
establishments"). These proposed
guidelines were not intended to apply to
the production of pesticide products
through an intended chemical reaction
(i.e., pesticide manufacturing). (For
definitions used in the final rule, see
§ 455.10 of the final regulation of this
notice.) Furthermore, as discussed in
Section 1 of the proposal Technical
Development Document [EPA-821-R-
94-002], Subcategory E (refilling
establishments) of these guidelines was
not intended to apply to wastewaters
generated by custom blending or custom
application operations when performed
independently or at refilling
establishments. The proposed
rulemaking would have established a
zero discharge limitation for wastewater
pollutants from the formulating,
packaging and repackaging of almost all
pesticide active ingredients for both
subcategories covered by this regulation.
Only a small number of PAIs were not
completely covered by the proposed
zero discharge, as a result of
disproportionate economic impacts to
small facilities.
Due to these impacts, EPA proposed
a partial exemption from these
guidelines for the exterior wastewaters 3
from small sanitizer facilities. Small
sanitizer facilities were defined as those
facilities which formulate, package or
repackage 265,000 Ibs/yr or less of all
registered products containing one or
more sanitizer active ingredients (listed
in Table 8 of the proposed regulation)
on sanitizer-only production lines. The
production cutoff of 265,000 Ibs/yr
represents the production level (of these
sanitizer products) at the largest facility
that would experience economic
impacts if there was no exemption for
non-interior wastewater sources. (See
Section III. A. 1 of this notice for a
description of revisions made to this
exemption).
In addition to the partial exemption
given to "small sanitizers," EPA
proposed to exempt sodium
hypochlorite from coverage under the
pretreatment standards for new and
existing sources (PSES and PSNS). (See
Section III. A. 1 of this notice for a
description of revisions made to this
exemption). EPA also proposed to
exempt wastewater generated by on-site
employee showers and laundries and
from the testing of fire protection
equipment from the applicability of
these effluent guidelines and standards.
In general, these wastewater sources
were excluded from the proposed
regulation because of worker health and
safety concerns. (See Section IX. A of the
proposed rule or Section 5 of the Final
Technical Development Document
(TDD) [EPA-821-R-96-019] for a more
detailed discussion of wastewater
sources excluded from regulation).
EPA based the proposed zero
discharge limitation for Subcategory C
on pollution prevention, recycle/reuse
and, when necessary, treatment through
the Universal Treatment System (UTS)
for reuse. EPA visualized the UTS as a
flexible system consisting of a variety of
treatment technologies that have been
determined to be effective for treating
PFPR wastewaters. In calculating
compliance costs, EPA included costs
for various combinations of treatment
technologies consisting of emulsion
breaking, hydrolysis, chemical
oxidation, metals precipitation and
carbon adsorption. EPA also included
costs for contract hauling treatment
3 At the time of proposal, exterior wastewaters
included: Exterior equipment cleaning water, floor
wash, leak and spill cleanup water, safety
equipment cleaning water, DOT (Department of
Transportation) aerosol test bath water, air
pollution control scrubber water, laboratory rinsate
and contaminated precipitation runoff.
residuals (sludges) from the UTS for
incineration. Because of the estimates of
reduced wastewater volumes based on
the increase in reuse/recycle practices,
the overall volume of wastewaters being
contract hauled off-site for incineration
was not expected to increase. Thus, EPA
did not include additional costs for
contract hauling of PFPR wastewaters in
the original proposal. Based on
comments, revised costs for the
proposed zero discharge option were
estimated for the Supplemental Notice
(60 FR 30217; June 8, 1995). (See the
Final Cost and Loadings Report
(September 1996) in the public record
for a discussion on the changes to the
costing methodology).
EPA based the zero discharge
limitation for Subcategory E on reuse of
wastewater as makeup water for
application to fields, in accordance with
the product label.
The subject of the comments on the
proposed rule spanned a variety of
topics, including changes to the scope of
the regulation, EPA's pesticide cross-
contamination policy and its effect on
the industry's ability to meet zero
discharge, increased cross-media
impacts due to contract hauling of
wastewater for incineration to meet zero
discharge, perceived conflicts with the
Resource Conservation and Recovery
Act (RCRA) requirements, and requests
for a discharge allowance when
following specific pollution prevention
practices. See Section III of today's
notice for a summary of the changes that
were made to the proposal in response
to comment.
F. The Supplemental Notice
In response to many of the comments
on the proposed rule, EPA published a
supplemental notice (60 FR 30217) in
the Federal Register on June 8, 1995.
EPA published the Supplemental Notice
to obtain public comment on two major
topics and several smaller issues. The
first major topic for which EPA
requested comments was related to the
scope and applicability of the
rulemaking. Commenters on the
proposed rule had requested that EPA
exempt certain pesticide active
ingredients (PAIs) and certain
wastewater sources from the scope of
the final rule.
EPA requested comment on
expansion of the "sanitizer exemption"
to exempt additional sanitizer active
ingredients, remove the exemption's
production limit, and to include both
interior and exterior wastewater sources
in the revised exemption. EPA also
requested comment on the exclusion of
some other chemicals including pool
chemicals, microorganisms, mixtures
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and pollutants that have been
determined to not pass through a
POTW. (See Section III.A.l of today's
notice for a discussion of these
exemptions; also see Comment
Response Document in the public
record).
In addition to the exclusion of certain
pesticide active ingredients, EPA
solicited comment on the partial or full
exclusion of certain wastewater sources.
These wastewater sources included
aerosol leak test bath water, safety
equipment cleaning water, laboratory
equipment rinse water, and storm water.
The second major topic for which
EPA solicited comments was a
regulatory option comprised of two
alternatives between which industry
could choose: (1) Achieving zero
discharge or (2) incorporating specific
pollution prevention practices and
treatment technologies at the facility
and allowing a discharge of very small
quantities of pollutants. This combined
regulatory approach is referred to as the
Zero Discharge/Pollution Prevention
Alternative (Zero/P2 Alternative).
In particular, the supplemental notice
requested comments on the structure of
the Zero/P2 Alternative, the extent of
best professional judgement (BPJ)
allowed, the specific practices included,
the modifications allowed and the
details of regulatory implementation.
Overall, the comments received on the
Supplemental Notice were
overwhelmingly supportive of the Zero/
P2 Alternative. Furthermore, EPA has
incorporated many of the suggestions
offered in the comments into the Zero/
P2 Alternative found in today's notice
(see Section XII of today's notice for a
discussion of regulatory
implementation).
The other issues for which EPA
solicited comments in the supplemental
notice included: the applicability of the
rule to PFPR research and development
facilities and stand alone direct
discharging facilities, the concentrations
found in second and third rinses of a
triple rinse, and the expected burden to
the permitting authorities.
III. Summary of Most Significant
Changes from Proposal
This section describes the most
significant changes to the rule since
proposal. Many of these changes have
resulted from the comments that are
discussed in more detail in the
Comment Response Document which is
contained in the record for this
rulemaking. This section will
summarize the changes in the rule
concerning: The scope of the rule, the
addition of the Zero/P2 Alternative,
applicability of the rule to research and
development facilities, clarification of
issues for PFPR/Manufacturers,
modification of the existing BPT for
direct dischargers, clarification of the
definition and applicability for refilling
establishments, and RCRA issues.
The major comments received on the
supplemental notice are described in
detail in the Comment Response
Document in the public record. Those
comments included: Support for the
pollution prevention alternative,
requests for self-certification as the
method of implementation for the final
rule, comments on the specific practices
listed in the P2 Alternative, and support
for the use of Best Professional or
Engineering Judgement (BPJ or BEJ) by
the permitting or control authority,
respectively.
A. Scope
At the time of proposal, the scope of
the rule would have included the
formulating, packaging and repackaging
of all pesticide active ingredients (with
the exception of sodium hypochlorite
and the partial exemption of small
sanitizers) and a wide variety of
associated wastewater sources. Since
the proposal, EPA has refined the scope
concerning pesticide active ingredients
(PAIs) and wastewater sources in
response to comments on both the
proposed rule and the supplemental
notice. The following discussion
summarizes these revisions. See the
Comment Response Document in the
rulemaking record for a more detailed
discussion on the changes.
1. Pesticide Active Ingredients (PAIs)
a. Sanitizer Active Ingredients and Pool
Chemicals
Several changes have been made to
the original "sanitizer exemption," as
proposed. In the proposed rule EPA
placed small sanitizer facilities in their
own subgroup within Subcategory C.
However, for the final rule, most
sanitizer products have been excluded
from Subcategory C (see §455.10 of the
final regulation of today's rule for the
definition of sanitizer products). This
exclusion is based on a number of
factors. The partial exemption for small
sanitizer facilities that was included in
the proposal was largely based on
disproportionate economic impacts.
However, based on comments EPA has
expanded the sanitizer exemption to
include additional chemicals for the
following reasons: (1) Sanitizer products
are formulated for the purposes of their
labeled end use to "go down the drain;"
(2) sanitizer active ingredients are more
likely to be sent to POTWs in greater
concentrations and volumes from their
labeled end use than from rinsing
formulating equipment at the PFPR
facility; (3) biodegradation data received
with comments on some of these
sanitizer active ingredients supports the
hypothesis that they do not pass
through POTWs; (4) these sanitizer
active ingredients represent a large
portion of the low toxicity PAIs
considered for regulation at the time of
proposal; and (5) many sanitizer
solutions containing these active
ingredients are cleared by the Food &
Drug Administration (FDA) as indirect
food additives under 21 CFR 178.1010.
The exemption now covers both
interior and exterior wastewater
sources. In addition, the proposed list of
28 sanitizer active ingredients has been
expanded to incorporate the pool
chemicals exemption as well as to
include home use, institutional and
most commercial antimicrobial active
ingredients, with the exception of liquid
chemical sterilants (including
sporicidals), industrial preservatives
and water treatment micro biocides
other than pool chemicals (as defined in
§455.10 of today's regulation). Certain
liquid chemical sterilant products are
exempt from today's rule, as discussed
in Section III.A.I.e. Furthermore, based
on comments, EPA has eliminated the
use of a list to define the exempted
sanitizer active ingredients and is
employing a written definition (see
§ 455.10 of the final regulation for the
definition used in today's final rule).
As mentioned above, EPA has
combined the pool chemicals exemption
into the sanitizer exemption. This was
based on comments on the
Supplemental Notice and information
gathered in post-proposal site visits (60
FR 30219). EPA believes that a large
portion of the pool chemicals that were
being reviewed for exemption can and
should also be classified as sanitizer
active ingredients. In order to avoid
possible confusion, EPA has decided to
combine these two groups and has
incorporated pool chemicals into the
definition for sanitizer active
ingredients. In addition to this change,
the pool chemicals exemption has
undergone another refinement. Under
the proposed rule, the only pool
chemical that was exempt was sodium
hypochlorite. Under the final rule, EPA
has added several other chemicals to the
exemption. These chemicals include
calcium hypochlorite, lithium
hypochlorite, potassium hypochlorite,
chlorinated isocyanurate compounds
and halogenated hydantoins. As with
the sanitizer chemicals, these chemicals
are not exempted via a list, but are
instead exempted by definition. See
§ 455.10 of the final regulation.
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57524 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
b. Other Pesticide Active Ingredients
EPA has excluded several other
groups of active ingredients from the
final regulation. As discussed in the
Supplemental Notice and in the
Comment Response Document,
microorganisms that are considered
PAIs under FIFRA will not be covered
by this regulation and will be excluded
by definition. Based on the available
information on the formulation,
packaging and repackaging of such
microorganisms and the generation and
characteristics of wastewaters from such
operations, EPA believes these
pesticides are not formulated in a
similar fashion as other PAIs covered by
this rule. Microorganisms which have
registered pesticidal uses are generally
created through a fermentation process,
similar to those found in some food
processing or pharmaceutical plants.
Fermentation is a biological process,
whereas other pesticides are
manufactured and formulated through
chemical and physical processes.
In addition, almost all the
microorganisms registered as pesticide
products are exempt from the
requirement of obtaining a (residue)
tolerance for pesticides in or on raw
agricultural commodities (40 CFR
180.1001). Under Part 180 Subpart D—
Exemptions From Tolerance—it states
that "an exemption from a tolerance
shall be granted when it appears that the
total quantity of the pesticide chemical
in or on all raw agricultural
commodities for which it is useful
under conditions of use currently
prevailing or proposed will involve no
hazard to the public health."
EPA has also excluded a group of
chemicals, referred to in today's notice
as "Group 1 mixtures." This group
includes many herbs and spices (e.g.,
rosemary, thyme, peppermint, cloves...),
foods/food constituents, plants/plant
extracts (excluding pyrethrins) and
many chemicals that are considered to
be GRAS (generally recognized as safe)
by the Food and Drug Administration as
well as those products exempt from
FIFRA under 40 CFR 152.25 (61 FR
8876; March 6, 1996)(see § 455.10 of the
final regulation of today's notice for the
definition of Group 1 mixtures).
There is a second group of mixtures,
"Group 2 mixtures," that are being
excluded from the regulation. EPA has
not been able to transfer treatability data
for many of these mixtures because the
characteristics that EPA uses for
technology transfer are not easily
identified (e.g., molecular weights,
solubilities and aromaticity). For
example, within a given structural
group, PAIs that are aromatic, have high
molecular weights or low solubility in
water have been found to be amenable
to activated carbon adsorption.
However, when such characteristics
cannot be identified, EPA cannot
transfer treatability data for carbon
adsorption.
EPA previously considered reserving
this group of chemicals for regulation at
a later time; however, after further
research EPA has decided to exclude
these chemicals from the scope of the
final rule. One reason, as mentioned
above, is that the treatability data is
insufficient and to obtain treatment
performance data on these mixtures
would be very difficult due to the
inability to transfer data. Also, most of
these chemicals in pesticide products
are used as inert ingredients rather than
active ingredients and the total volume
of these mixtures in use in pesticide
products is very small (i.e., Group 2
Mixture PAIs only represent
approximately eight percent of all of
pesticide products). EPA was not able to
develop a definition to cover all the
chemicals in this group due to the lack
of homogeneity between the chemicals.
Therefore, Group 2 mixtures will be
excluded from the scope of the final rule
by list as opposed to definition (see
Table 9 to Part 455 of the final
regulation).
There are two other groups of
chemicals that are being excluded from
the final rule: Inorganic wastewater
treatment chemicals and chemicals that
do not pass through POTWS. Based on
comments and data collected for the
Treatability Database Report and its
Addendum (see the public record for
the rulemaking), EPA has decided to
exclude, from the scope of the final
regulation, inorganic chemicals that are
commonly used as wastewater treatment
chemicals (e.g., ferric sulfate, potassium
permanganate, sulfuric acid, carbon,
chlorine, etc...). See Comment Response
Document for a discussion on the
rationale behind this exclusion. Many of
these chemicals are also excluded under
the sanitizer/pool chemicals exemption.
Again, the use of a definition will be
employed to exclude these chemicals.
(See §455.10 of today's final rule for the
definition). The four chemicals which
are excluded from the pretreatment
standards because EPA determined that
they do not pass through POTWs are
phenol, 2-chlorophenol, 2,4-
dichlorophenol and 2,4-
dimethylphenol. Phenol, as a
constituent in sanitizer products, is
excluded from the rule as it was
excluded under the proposed sanitizer
exemption due to disproportionate
economic impacts. See the Comment
Response Document in the rulemaking
record for a further discussion on the
decision to exclude these wastewater
treatment chemicals and the chemicals
that do not pass through.
c. Liquid Chemical Sterilants
Section 221 of the Food Quality
Protection Act of 1996 (Pub. L. 104-170)
amended the definition of "pesticide"
in FIFRA to exclude liquid chemical
sterilant products (including any
sterilant or subordinate disinfectant
claims on such products) which are
used on a critical or semi-critical device
(as defined in section 201 of the Federal
Food, Drug, and Cosmetic Act
("FFDCA") (21 U.S.C. 321). See 7 U.S.C.
136(u), as amended. Because Congress
has chosen to exclude such sterilant
products from the definition of
"pesticide", EPA has modified the
applicability provisions of this rule so
that the effluent limitations and
pretreatment standards do not cover the
wastewater discharges from the
formulation, packaging, and/or
repackaging of liquid chemical Sterilants
for use on critical devices or semi-
critical devices as these terms are now
defined in FFDCA section 201 and
FIFRA section 2(u). See 40 CFR
455.40(1). However, facilities which
formulate, package, or repackage
products containing liquid chemical
Sterilants into other types of products,
e.g., pesticide products which are not
used on critical or semi-critical devices
introduced directly into the human
body, should be aware that the
wastewaters resulting from the
formulating, packaging, and repackaging
activities are covered by this rule.
2. Wastewater Sources
In the proposal, EPA excluded water
from on-site employee showers,
laundries and testing of fire protection
equipment (59 FR 17903). EPA has
added several other wastewater sources
to the exclusion. These include: Storm
water,4 water used for testing and
emergency operation of safety showers
and eye washes; DOT leak test bath
water from non-continuous overflow
baths (i.e., batch baths) where no cans
have burst from the time of the last
water change out; and water used for
cleaning analytical equipment and
glassware and for rinsing the retain
sample container in on-site laboratories.
However, the initial rinse of the retain
sample container is considered a
process wastewater source for the final
regulation. (See the Comment Response
4 Storm water at PFPR facilities and Refilling
Establishments is covered by the Storm water
Regulations Phase I and II, respectively.
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57525
Document for a discussion on the
exclusion of these wastewaters).
B. The Zero Discharge/Pollution
Prevention Alternative Option
Commenters submitted a variety of
comments which prompted the Agency
to consider the Zero/P2 Alternative
option. The most significant are
summarized below. (See the Comment
Response Document in the public
record for additional summary of
comment responses and responses to
individual comments.)
1. Cross Media Impacts and Incineration
Issues
Commenters on the proposed rule
believe that the zero discharge standard,
as proposed, would lead to a large
increase in cross-media impacts because
the majority of facilities would be forced
to contract haul dilute non-reusable
wastewaters off-site for incineration (or
other off-site disposal). Commenters
questioned the goal of achieving zero
discharge when it leads to an increase
in cross-media impacts.
At the time of the proposed rule, EPA
believed that the proposed approach to
achieving "zero discharge" of
wastewater pollutants from PFPR
facilities would result in increasing the
recycling, reuse and recovery of
wastewater pollutants. In addition, EPA
based the requirements on the best
practices observed at PFPR facilities
studied as part of the development of
the rule. However, based on the
concerns raised by commenters about
the potential cross-media impacts EPA
decided to seek comment on the
pollution prevention (P2) alternative to
zero discharge in order to reduce these
impacts (60 FR 30217). The P2
Alternative to the zero discharge
standard will allow a discharge of
wastewater after waste discharge
reductions are achieved using certain
flow conservation, recycle or reuse and,
under certain circumstances,
wastewater treatment practices. Should
a facility choose to comply with the
regulation through the P2 Alternative
the need for off-site disposal is reduced;
thus, the cross-media effects are
reduced.
For those facilities that choose to
comply with the final rule by achieving
zero discharge, EPA has revised the cost
model. The revisions add costs to
account for increased volumes of non-
reusable wastewaters being contract
hauled for off-site incineration (see the
Final Cost and Loadings Report
(September 1996) for a discussion on
changes to the costing methodology).
The revised cost estimates for the
industry to achieve zero discharge of
wastewater pollutants, including the
additional contract hauling costs, are
still found to be economically
achievable for the industry. (See Section
V of today's notice for a discussion on
the economic achievability of the final
regulation.)
Commenters also commented that a
significant decrease in incineration
capacity and an increased cost would
result from EPA's combustion policy
which may limit the permitting of new
incinerators or the expansion of
capacity of existing incinerators. EPA
has addressed this concern in two ways.
First, through the use of the P2
Alternative to zero discharge, this final
rule will allow for the discharge of
much of the non-reusable PFPR
wastewaters that might otherwise be
contract hauled for incineration.
Second, as mentioned above, EPA has
revised its costing methodology for the
zero discharge option to include off-site
incineration of these additional non-
reusable wastewaters and has still found
the rule to be economically achievable
by the industry. In addition, EPA does
not believe an additional burden will be
placed on incineration capacity. This is
supported by a survey, "Hazardous
Waste Incineration 1994," published in
the El Digest, June 1994 which showed
that while there is increasing demand
for incineration there is still great
untapped capacity. The surveyed
commercial incinerators believe that
market saturation, competition with
cement kilns and successful waste
minimization efforts by industry
account for the unused capacity and the
decline in the average price for
incineration. [See the memo in the
record entitled Incineration Costs for
PFPFacilities, September 30, 1994.]
2. Cross-Contamination Policy
Commenters also stated that complete
reuse, as proposed, is not achievable
because of EPA's existing policy on
cross-contamination of pesticide
products. At the time of proposal EPA
was using a standard of zero for cross-
contamination. This meant that an
active ingredient may not be present at
any concentration in a FIFRA registered
product where it is not listed on the
confidential statement of formula (CSF)
of that product or reported to EPA as an
impurity. During the study phase for the
development of the proposal, the
industry practice was to triple rinse
containers and equipment. Because of
recent EPA enforcement actions,
industry commented that additional
rinsing is being used to comply with the
cross-contamination policy.
Commenters believe that more
aggressive enforcement of a zero-
standard cross-contamination policy
would increase wastewater volumes to
the point that it would not be feasible
to reuse these volumes. The commenters
also believe that these factors were not
taken into account when the proposed
zero discharge regulation was
developed. According to commenters, a
facility that performs a triple rinse of the
equipment interiors when changing
from formulating one product to
another, may have to perform additional
rinses (e.g., a five times rinse) to ensure
a level of zero cross-contamination.
Commenters stated that even in cases
where the rinsate from the "triple rinse"
could be stored for use in a future
formulation, the additional rinses create
more rinsewater than could be reused
and that these very dilute wastewaters
would have to be contract hauled for
off-site disposal to achieve zero
discharge. Commenters believe this
additional contract hauling of
wastewater not only makes the
proposed regulation economically
unachievable, but increases the
opportunity for cross-media impacts.
At the time of the supplemental
notice EPA was reviewing the pesticide
cross-contamination policy. EPA has
since published a Notice of Availability
on a more risk-based draft policy in the
Federal Register for public comment (61
FR 1928; January 24, 1996) and expects
publication of the final policy by the
end of 1996. In addition, EPA has
created the P2 Alternative to zero
discharge in this rulemaking which
would allow formulators, packagers and
repackagers to discharge these dilute
non-reusable rinses following the use of
specified pollution prevention practices.
3. Request for De Minimis Discharge
Due to the concerns described above,
many commenters requested a discharge
allowance for these excess or non-
reusable wastewaters. Commenters
suggested that they would be willing to
agree to use specified pollution
prevention practices and pointed to the
pollution prevention, recycle and reuse
practices described in the preamble to
the proposal (59 FR 17866) and the
technical development document for the
proposal [EPA #821-R-94-002]. In some
cases commenters provided examples of
possible additional practices they would
be willing to agree to use. EPA believes
that a discharge allowance ("pollution
prevention allowable discharge") may
provide an added incentive to increase
the use of pollution prevention and
recycle practices, while ensuring that
facilities are maximizing pollutant
reductions in the wastewater while
minimizing cross-media effects.
Therefore, in response to the request for
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57526 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
a "de minimis" discharge alternative,
EPA has incorporated the P2 Alternative
into the zero discharge standard for the
final regulation.
4. Pollution Prevention Alternative
Several changes have been made to
the P2 Alternative since it was first
presented in the Supplemental Notice.
The most significant revision is that a
facility will be able to choose between
achieving zero discharge or an allowable
discharge (using the P2 Alternative) on
a product family/process line/process
unit basis.
In the supplemental notice, this
choice was to be made on a facility wide
basis. However, based on comments,
EPA believes that the zero/P2
alternative option will be most practical
if facilities can choose zero discharge for
those processes/process units at their
facility that are most amenable to zero
discharge, while choosing the P2
Alternative for other portions of the
facility for which the pollution
prevention practices are most suited.
EPA believes that this change will also
reduce burden.
In addition, EPA has made some
changes to the listed pollution
prevention practices. First, the two
tables of listed practices, as found in
Appendix B of the Supplemental
Notice, have been combined into one
table. In addition, based on comments,
revisions have been made to the
language used on the table of listed
practices. Under the final rule, any
practice may be modified with an
adequate justification. When no
justification is listed for the specific
practice it can be modified via best
professional or engineering judgement
(BPJ or BEJ, respectively). EPA believes
this is appropriate due to the unique
and individual situations that may arise
at a particular facility (see the Comment
Response Document in the rulemaking
record or the P2 Guidance Manual for
the PFPR Industry for examples of such
situations). However, for listed practices
where no justification is listed on the
table, a facility will initially have to
submit a request for a modification to
the permitting/control authority for
review and approval. The permitting/
control authority is expected to use BPJ
or BEJ to decide if the justification
provided is adequate. In addition, the
permitting/control authority will be able
to add or replace practices specified by
the rule with new or innovative
practices that are more effective at
reducing the pollutant loadings from a
specific facility to the environment.
EPA has also added some additional
justifications to the table of listed
practices based on comments. For
example, EPA will allow facilities to
modify the practice of reusing and/or
storing and reusing rinsates generated
by rinsing of drums containing only
inerts when a facility can demonstrate
that the large concentration of the inert
in the formulation creates more volume,
after using water conservation practices,
than could feasibly be reused or when
the concentration of the inert is so small
(i.e., perfumes) that the reuse would
cause a formulation to exceed the ranges
allowed in the Confidential Statement of
Formula (CSF).
Based on comment, EPA has also
combined, added and removed other
practices. For example, EPA has added
a practice concerning dry formulation
interior equipment cleaning that
specifies that facilities must cleanout
such interiors with dry carrier prior to
any water rinse and that this carrier
material should preferably be stored and
reused in future formulation of the same
or compatible product (or, as a last
resort, properly disposed of as solid
waste). EPA has combined many of the
water conservation practices, such as
use of flow reduction on hoses, use of
low volume/high pressure rinsing
equipment and floor scrubbing
machines, into one listed practice.
Finally, EPA has removed the provision
for dedicated equipment that was
contingent on the inability to reuse
interior rinsates. Instead, this practice
will be discussed in the P2 Guidance
Manual for the PFPR Industry. (See
Table 8 to Part 455 of the final
regulation, for the listed practices and
listed justifications).
Furthermore, EPA has refined the
definition of P2 allowable discharge. In
response to comment, this definition
states that "appropriate pollution
control technologies" include not only
those technologies listed on Table 10 of
the regulation, but also include a
pesticide manufacturer's treatment
system or an equivalent system, used
individually or in any combination to
achieve the level of pollutant reduction
determined by the permitting authority
or control authority. An equivalent
system is a wastewater treatment system
that is demonstrated in literature,
treatability tests or self-monitoring data
to remove a similar level of pesticide
active ingredient (PAI) or priority
pollutants as the applicable treatment
technology listed in Table 10 to part 455
of the final regulation.
Finally, EPA has decided to allow the
control authority to use best engineering
judgement to waive pretreatment at the
PFPR facility prior to discharge to the
POTW under certain circumstances.
Under the final P2 Alternative to zero
discharge, an indirect discharger must
pretreat the portion of their allowable
P2 discharge that includes interior
equipment rinsates (including drum
rinsates), leak and spill cleanup water
and floor wash prior to discharge to the
POTW. However, EPA will allow the
control authority to waive the
pretreatment requirements for floor
wash and the final interior rinse of a
triple rinse that has been demonstrated
to be non-reusable when the facility
demonstrates that the level of PAIs and
priority pollutants in such wastewaters
are at a level that is too low to be
effectively pretreated at the facility and
have been shown to neither pass
through or interfere with the operations
of the POTW. The control authority
should also take into account whether
or not the facility has employed water
conservation when generating such a
non-reusable wastewater.
C. Applicability to On-Site and Stand-
alone Research & Development (R&D)
Laboratories
EPA has clarified the applicability of
the final PFPR regulations to on-site and
stand-alone R&D laboratories (i.e., no
PFPR on-site). The final PFPR effluent
guidelines and standards do not apply
to wastewater generated from the
development of new formulations of
pesticide products and the associated
efficacy and field testing (where
resulting product is not manufactured
for sale). This includes such
wastewaters generated at stand-alone
R&D laboratories as well as at R&D
laboratories located on-site at PFPR
facilities. EPA received many comments
describing the operations at both on-site
and stand-alone R&D facilities.
Commenters believe that wastewaters
generated at these R&D laboratories have
extremely limited reuse potential due to
their experimental nature, as such
formulations may only be produced
once or, at most, for one set of trials.
Therefore, commenters believe that the
pollution prevention practices listed in
the Supplemental Notice (for example,
reuse of interior rinsates in future
formulation) are not amenable to these
one-time wastewaters. In addition,
experiments require the use of
experimental controls. According to
commenters, the addition of rinsates
into the "experimental design could
alter the results of the experiment and
render the data obtained useless." EPA
has taken the above information into
account, in addition to the typically low
quantities discharged from these
operations and believes that the
wastewaters generated by experimental
formulation, efficacy and field testing
can be adequately addressed in permits
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57527
and pretreatment agreements through
BPJ and BEJ, respectively.
D. Clarification of Issues Concerning
PFPR/Manufacturers
Pesticide Manufacturing is covered by
40 CFR part 455 subparts A and B.
However, close to 50 pesticide
manufacturers also perform pesticide
formulating, packaging and repackaging
at their facility (called "PFPR/
Manufacturers"). EPA has included a
discussion, below, to aid in clarifying
how the final rule applies to the PFPR/
Manufacturers in regard to three specific
issues. First, EPA will clarify the
difference between adding a solvent to
stabilize an active ingredient and adding
a solvent (or other inert ingredients) to
formulate a pesticide product, and
which practice constitutes
manufacturing and which constitutes
formulation. Second, EPA will discuss
whether on-site incineration can be
considered as achieving zero discharge
under the PFPR final rule. Finally, EPA
will amend and clarify the
interpretation of the 1978 zero discharge
BPT rule for direct discharging PFPR/
Manufacturers and PFPR stand-alone
facilities.
1. Stabilizing versus Formulating
Pesticide manufacturers may
sometimes add a solvent (organic or
aqueous) to a manufactured PAI or
intermediate for the purpose of
stabilizing the product (e.g., for
transport or storage). The Pesticide
Manufacturing Final Technical
Development Document [EPA-821-R-
93-016; page 1-9] states that dilution of
the manufactured active ingredient is
only covered by the Pesticide
Manufacturing rule when it is "a
necessary step following a chemical
reaction to stabilize the product." Thus,
EPA would like to clarify that
manufacturers can perform such
operations without being subject to the
PFPR effluent guidelines as long as it is
a necessary step to stabilize the product
following a chemical reaction.
Typically, such operations are
performed without placing the pesticide
in a marketable container (i.e., they are
shipped in bulk via tank truck, rail car
or tote tank). However, PFPR facilities
should not conclude that they can
receive PAIs (that they do not
manufacture), even in bulk quantities,
and dilute it with solvent or other
carrier without being subject to the
PFPR effluent guidelines, as this would
be considered formulating under
§455.10.
2. On-site Incineration as Zero
Discharge
Although EPA proposed zero
discharge limitations based on pollution
prevention, recycle/reuse and treatment
for reuse, facilities may meet this zero
discharge requirement through a
number of other practices. These
practices include hauling wastewater to
off-site destinations, such as sites which
have incineration, deep well injection
disposal and centralized (commercial)
wastewater treatment and subsequent
discharge. In some cases, wastewaters
are returned to the registrant or
manufacturer. In a few instances, on-site
incineration of PFPR wastewaters is
being conducted.
EPA received comment requesting
clarification of whether on-site
incineration is an acceptable means of
achieving zero discharge. For purposes
of this rule, EPA considers on-site
incineration a valid option for achieving
zero discharge of PFPR process
wastewaters. Wet scrubbing devices
used for air pollution control on existing
on-site incinerators at PFPR facilities are
not subject to the PFPR effluent
guidelines. The only existing on-site
incinerators at facilities covered by the
PFPR regulation are at facilities which
also manufacture pesticide active
ingredients (PFPR/Manufacturers).
Scrubber wastewater discharges from
these incineration activities are
currently regulated under the pesticide
manufacturing effluent guidelines (40
CFR part 455, subparts A and B; see 58
FR 50638, September 28, 1993) for the
PAIs manufactured at these facilities.
On-site incineration at new sources
(i.e., NSPS and PSNS), would also
qualify as meeting zero discharge under
the PFPR regulation and scrubber water
discharges from these on-site
incinerators would be covered by the
pesticide manufacturing new source
standards. However, scrubber
wastewater discharges from the on-site
incineration of PAIs not regulated by the
pesticide manufacturing rule would
have to be controlled using a BPJ or BEJ
basis.
3. Amending and Clarifying of BPT
The 1978 BPT regulation (43 FR
44846; September 29, 1978) established
a zero discharge limitation for direct
discharges from pesticide formulating
and packaging5 facilities. This included
pesticide formulating, packaging and
repackaging that occurred at direct
discharge pesticide manufacturing
facilities as well as stand-alone PFPR
facilities.6 The basis for the 1978 zero
discharge BPT limitation was water
conservation, reuse and recycle
practices, with any residual water being
evaporated or hauled off-site to a
landfill. However, many facilities that
were direct dischargers in 1978
switched to indirect discharge of
wastewaters through POTWs instead of
achieving zero discharge via recycle and
land filling or evaporation. Due to the
1978 BPT regulation, presently, there
should be no direct discharging PFPR
facilities. However, the zero discharge
limitation was not interpreted or
implemented in the same way for PFPR/
Manufacturers as it was for stand-alone
PFPR facilities.
It is EPA's understanding that
permitting authorities incorporated the
BPT zero discharge standard for PFPR
wastewaters into the pesticide
manufacturers' NPDES permits as a
"zero allowance." A zero allowance
would let a PFPR/Manufacturer
discharge PFPR wastewaters along with
their pesticide manufacturing
wastewaters as long as they did not
exceed the pesticide limitations in the
Pesticide Manufacturing rule. The 1978
pesticide manufacturing BPT limitations
were presented as a total pesticides
limit for 49 specific PAIs. However, the
more recent BAT and NSPS limitations
(58 FR 50638; September 28, 1993) do
not set a total pesticides limit but,
instead set individual production-based
limitations. Since the pesticide
manufacturing limits are based solely on
the manufacturing production and do
not include the PFPR production,
permits could still use a zero allowance
approach to allow discharges of PFPR
wastewater from these combined
facilities.
At the time of proposal, EPA did not
believe it was necessary to amend the
1978 BPT because the zero discharge
limitation was comparable to the
proposed standard of zero discharge.7
EPA recognized that the bases for the
1978 BPT and proposed rule were not
identical and that land filling and
evaporation were no longer the best
options for achieving zero discharge (59
FR 17870). However, EPA believed that
5 In 1978 repackaging was not included in the
title of Subcategory C, but was covered by the BPT
regulation and, therefore, will be included in the
title for the final rule.
6 A stand-alone PFPR facility is a PFPR facility
where either: (1) No pesticide manufacturing
occurs; or (2) where pesticide manufacturing
process wastewaters are not commingled with PFPR
process wastewaters. Such facilities may formulate,
package or repackage or manufacture other non-
pesticide chemical products and be considered a
"stand-alone" PFPR facility.
7 EPA proposed a zero discharge standard for
PSES based on pollution prevention, recycle/reuse
and, when necessary, treatment and reuse and
expected it to be implemented via "no flow" of
process wastewater.
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57528 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
since both the 1978 BPT and the
proposed rule were largely based on
water conservation, recycle and reuse
practices, facilities could meet BPT in a
manner similar to the proposed rule.
Following proposal, EPA received
many comments on and requests for
revision of the BPT regulation from the
PFPR/Manufacturing facilities and trade
associations. Commenters raised issues
related to the technical feasibility of
zero discharge for both the proposed
rule and the 1978 BPT rule.
Commenters believed that, because
not all wastewaters were reusable as
EPA had assumed, the potential
increase in cross-media impacts
associated with a zero discharge
regulation in addition to the large costs
associated with contract hauling for
incineration made any zero discharge
regulation infeasible. The commenters
requested numeric discharge limitations
and/or a "de minimis" discharge
allowance (associated with pollution
prevention practices) for their PFPR
wastewaters and that BPT be revised
accordingly. Based on these and other
comments on the proposed rule, EPA
developed the Zero/P2 Alternative for
PSES and BAT (for Subcategory C
facilities) which was discussed in the
Supplemental Notice and revised based
on additional comment for today's final
rule.
Commenters also specifically
commented on the need for revision of
the 1978 BPT due to: (1) Certain
practices on which the 1978 BPT was
based (for example, land filling and
evaporation) are no longer desirable
because they may cause cross-media
impacts or may no longer be available;
and (2) the changes in PAIs and
pesticide formulation chemistries since
1978. For example, many pesticide
products have been reformulated from
an organic solvent-based product to a
water-based product to avoid the
generation of volatile organic
compounds (VOCs). This has, in many
cases, caused an increase in the volume
of wastewater generated by this
industry. In addition, many facilities are
switching to safer, more
"environmentally friendly" pesticide
active ingredients which would change
the characteristics of the wastewaters
from those determined in 1978.
Commenters believe that EPA must
revise BPT or account for the additional
costs associated with the current
practices that would be utilized to meet
the zero discharge limitation (i.e., off-
site incineration).
Based on the comments discussed
above, EPA has decided to amend BPT
for both the existing direct discharging
PFPR/Manufacturers and stand-alone
PFPR facilities to allow them to choose
between zero discharge and the P2
Alternative. EPA believes that although
the stand-alone PFPR facilities are
already achieving zero discharge, in
compliance with the 1978 BPT, the
methods they are employing may
potentially result in cross-media
impacts that the use of the P2
Alternative would potentially reduce.
Also, these changes will make BPT
consistent with BAT (and PSES) while
essentially achieving the same pollutant
removals and potentially decreasing
cross-media impacts associated with
various off-site disposal methods. In
addition, the change to the BPT
limitation that is being promulgated
today for PFPR/Manufacturers will
clarify that the method by which the
zero discharge limitation has been
implemented (i.e., use of a zero
allowance) is appropriate.
The final PFPR rule will allow
discharge of PFPR wastewaters from
PFPR/Manufacturing facilities in two
specific ways. For those facilities
choosing to comply with zero discharge
(as opposed to the P2 Alternative), their
permits should incorporate the "zero
allowance" approach for the PFPR
portion of their operations for the PAIs
that they manufacture. For those PAIs
formulated and not manufactured at the
facility, the permit should apply a strict
zero discharge. In part, this is because
their pesticide manufacturing
wastewater treatment system may not
consist of the appropriate treatment
technologies for such PAIs or the
treatment system may not be designed
to treat the additional volumes and/or
concentrations of the "non-
manufactured" PAIs.
However, PFPR/Manufacturers can
choose the P2 Alternative to zero
discharge. Such facilities would not
have to achieve zero discharge or zero
allowance of their PFPR wastewaters.
Instead, these facilities would comply
with the practices specified in the P2
Alternative and would receive a "P2
discharge allowance" following
treatment (see §455.41 of the final
regulation for the definition of P2
allowable discharge). The P2 discharge
allowance can be applied to both
pesticides that are formulated/
packaged/repackaged and manufactured
as well as those that are not
manufactured on-site. [Note: Facilities
can choose between zero discharge and
the P2 Alternative on a product family/
process line/process unit basis.]
The treatment system used to treat the
combined PFPR and pesticide
manufacturing wastewaters must
incorporate treatment that is appropriate
for those PAIs which are not also
manufactured on-site (i.e., those PAIs
for which individual pesticide
manufacturing production-based
limitations are not contained in the
NPDES permit). Treatment is deemed
appropriate through the use of:
treatability studies found in literature or
performed by the facility; long-term
monitoring data; or Table 10 of the final
rule.
As discussed above, EPA is also
amending BPT for stand-alone PFPR
facilities. Stand-alone facilities that do
not send their wastewaters to POTWs
can choose to comply with the P2
Alternative or can remain as zero
discharge. Facilities choosing the P2
Alternative may have to apply for an
NPDES permit if they do not already
have a permit.
E. Clarification of Refilling
Establishments
EPA has decided to use the same
general definition for "refilling
establishment" as in the proposed
effluent guideline and the proposed
FIFRA Standards for Pesticide
Containers and Containment rule (i.e.,
an establishment where the activity of
repackaging pesticide product into
refillable containers occurs). However,
EPA will use different applicability
statements in each of the regulations to
further define the term as appropriate
for the particular regulation. (See the
Comment Response Document for
additional discussion). The limitations
and standards of Subpart E of the PFPR
final rule apply to the repackaging of
pesticide products performed by
refilling establishments: (a) That
repackage agricultural pesticides; (b)
whose primary business is wholesale or
retail sales; and (c) where no pesticide
manufacturing, formulating or
packaging occurs. Subpart E (Refilling
Establishments) is not applicable to
wastewater generated from custom
application or custom blending.
F. RCRA Issues
A number of commenters requested
clarification concerning the potential for
conflict between the proposed zero
discharge effluent guidelines limitations
and standards and certain requirements
under the Resource Conservation and
Recovery Act (RCRA). Specifically,
commenters requested that EPA explain,
in the final rule, its interpretation of the
wastewater treatment unit exemption
under RCRA (40 CFR 264.1(g)(6),
265.1(c)(10)) with respect to facilities
regulated by a national effluent
guideline requirement of zero discharge
and how such an exemption would
apply to the Universal Treatment
System (UTS). They also requested
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57529
clarification on the 90-day RCRA
hazardous waste storage limitation.
In general, owners and operators of
hazardous waste treatment, storage, and
disposal (TSD) facilities must meet the
standards outlined in 40 CFR part 264
(and part 265 for interim status).
However, the wastewater treatment unit
exemption (40 CFR 264.1(g)(6), 40 CFR
265.1(c)(10)) is intended to exempt,
from certain RCRA requirements,
wastewater treatment units at facilities
that are subject to the NPDES or
pretreatment requirements under the
Clean Water Act8 (for example, PFPR
facilities). The specific definition of
wastewater treatment units that are
exempt from certain RCRA requirements
is found in 40 CFR 260.10. The RCRA
wastewater treatment unit exemption
does not exempt hazardous wastewaters
at these facilities from RCRA
requirements, but does exempt the
facilities from obtaining a TSD permit
for wastewater treatment systems
treating, storing, or generating listed (40
CFR 261.30-33) or characteristic (40
CFR 261.20-24) hazardous wastes. EPA
points out that many pesticide active
ingredients are not RCRA listed
hazardous wastes and most PFPR
wastewaters do not exhibit hazardous
waste characteristics; therefore, such
non-hazardous wastewaters would not
be covered by the RCRA Subtitle C
requirements.
As mentioned above, many
commenters requested that EPA clarify
whether or not the wastewater treatment
unit exemption can be applied to
facilities that are not discharging their
treated wastewater effluent due to a zero
discharge limitation in a national
effluent guideline. Facilities subject to
an effluent guideline which sets a zero
discharge or other limitations or
standards (such as the P2 Alternative)
can, in fact, be eligible for the RCRA
wastewater treatment unit exemption,
assuming that they also satisfy the
exemption's other criteria.
Commenters also requested
clarification on how the RCRA 90-day
limit on the storage of hazardous wastes
(40 CFR 262.34) applies to rinsates
being stored for subsequent reuse in
accordance with the PFPR effluent
guidelines. Generally, RCRA TSD
permits (or interim status) are required
for facilities that store hazardous waste
on site. However, the RCRA regulations
allow facilities that generate hazardous
waste to store the waste without a
permit or interim status provided that
certain criteria, including a 90-day limit
8 Section 402 of the Clean Water Act addresses
the NPDES requirements, while Section 307(b)
addresses the pretreatment standards.
on storage for large quantity generators,
are satisfied (these criteria are outlined
in 40 CFR 262.34). As mentioned earlier
in this section, most PFPR wastewaters
would not be defined as RCRA
hazardous waste, either because the
wastewater does not meet a RCRA
listing, or does not exhibit any
hazardous characteristic; of course,
generators are still required to make this
determination with respect to their own
wastes (40 CFR 262.11). If a material is
not a hazardous waste, the RCRA
regulations, including storage
requirements, do not apply.
For any rinsewaters that potentially
meet a RCRA listing or exhibit a RCRA
characteristic, such rinsewaters being
stored for direct reuse as outlined under
today's final PFPR effluent guidelines
and standards would not be considered
wastes by the Agency (see 40 CFR
261.2(e)(l)). As described elsewhere in
today's rulemaking, these rinsewaters
do not require treatment prior to reuse
and, due to stringent product
specifications, do not contain
constituents that are not needed in the
product being formulated. In these
situations where the rinsewaters are not
classified as a waste, the RCRA
regulations (including the generator
requirements and storage requirements)
do not apply. However, the RCRA
regulations do require that materials
being stored for reuse not be
accumulated speculatively
(speculatively accumulated materials
are classified as wastes). A material is
not accumulated speculatively if the
person accumulating it shows that the
material is recyclable, has a feasible
means of being recycled, and that
during the calendar year, the amount of
material recycled equals at least 75
percent by weight or volume of the
amount of that material accumulated at
the beginning of the period. See 40 CFR
261.1(c)(8) and 261.2(e)(2)(Hi).
IV. The Final Regulation
A. Pretreatment Standards for Existing
Sources (PSES)
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
Under the final rule, EPA is
establishing a zero discharge
pretreatment standard with a P2
Alternative which allows a discharge to
POTWs. The zero discharge standard is
based on pollution prevention, recycle
and reuse practices and, when
necessary, treatment (through the
Universal Treatment System) for reuse.
The basis also includes some amount of
contract hauling for off-site incineration
which may be necessary to achieve zero
discharge. Compliance with the
alternative (P2 Alternative) is based on
performing specific pollution
prevention, recycle, reuse and water
conservation practices (as listed in
Table 8 to part 455 of the final rule)
followed by a P2 allowable discharge
which requires treatment of interior
wastewater sources (including drum
rinsates), leak/spill cleanup water and
floor wash prior to discharge to a
POTW. 9
EPA visualized the Universal
Treatment System (UTS) as a flexible
system consisting of a variety of
treatment technologies that have been
determined to be effective for treating
PFPR wastewaters. The UTS can
include various combinations of
treatment technologies consisting of
emulsion breaking, hydrolysis, chemical
oxidation, metals precipitation and
carbon adsorption. See Section 7 of the
Final Technical Development Document
[EPA-821-R-96-019] for the PFPR
effluent guideline and the proposal (59
FR 17873) for a detail description of the
UTS.
EPA determines which pollutants to
regulate in PSES on the basis of whether
or not they pass through, interfere with,
or are incompatible with the operation
of POTWs (including interference with
sludge practices). A pollutant is deemed
to pass through when the average
percentage removed nationwide by
well-operated POTWs (those meeting
secondary treatment requirements) is
less than the percentage removed by
directly discharging facilities applying
BAT for that pollutant. In the pesticide
chemical manufacturing final rule,
phenol, 2-chlorophenol, 2,4-
dichlorophenol and 2,4-dimethylphenol
were found to not pass through POTWs
(58 FR 50649; September 28 1993).
Phenol is a PAI that is exempted from
this final rule under the sanitizer
exemption while the remaining three
chemicals are priority pollutants.
As discussed in Section III.A.I, based
on comments and the addition of the
pollution prevention alternative to the
zero discharge standard for the final
rule, EPA believes it is appropriate to
exempt phenol from the final PFPR
effluent guidelines and standards, and
to exclude 2-chlorophenol, 2,4-
dichlorophenol and 2,4-dimethylphenol
from regulation in the final categorical
pretreatment standards (PSES and
9 In individual cases the requirement of
wastewater pretreatment prior to discharge to the
POTW may be removed for floor wash or the final
rinse of a non-reusable triple rinse by the control
authority when the facility has demonstrated that
the levels of PAIs and priority pollutants in such
wastewaters are at a level that is too low to be
effectively pretreated at the facility and have been
shown to neither pass through or interfere with the
operations of the POTW.
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57530 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
PSNS) because these three pollutants
have been determined not to pass
through POTWs.
EPA has estimated the compliance
cost for the industry to achieve the
pretreatment standards (PSES)
contained in the final rule at $29.9
million annually ($1995). The current
PAI pollutant loading to POTWs is
estimated at 192,789 pounds with PAI
removals achieved by the final
regulation estimated at 189,908 pounds
(assuming zero removals by POTWs
currently—see Cost-Effectiveness
Analysis in Section V.D.6). This means
that compliance with the final rule
would remove almost 99% of the
current pollutant loading. Due to the
toxic nature of the majority of PAIs, the
equivalent toxic weighted pollutant
removals are 7.6 million pound
equivalents10.
2. Refilling Establishments (Subcategory
E)
EPA is establishing pretreatment
standards for existing refilling
establishments at zero discharge of
pollutants in process wastewaters to
POTWs. This standard is based on
collection and storage of process
wastewaters followed by reuse of the
wastewaters as make-up water for
application to fields in accordance with
the product label. Based on the PFPR
1988 questionnaire survey, 98 percent of
the existing refilling establishments
achieve zero discharge.
Only a small number of refilling
establishments are indirect dischargers
and EPA has estimated that they can
comply with the final pretreatment
standards at nearly zero cost. EPA has
estimated that only 19 facilities (of the
1134) do not achieve zero discharge and
they currently discharge to POTWs. EPA
estimates a capital cost of only $500
(i.e., the approximate cost of a minibulk
tank to store water for reuse) for each
the 19 facilities to meet the zero
discharge PSES standard.
10 The toxic weighted pollutant removals (in
pound-equivalents) for the final rule are not directly
comparable to the toxic weighted pollutant
removals presented in the proposal or supplemental
notice. This is because: (1) The method used to
convert acute toxicity values to chronic value was
revised from a 1:100 ratio to a 1:10 ratio and
reduces the toxic weighting factor for many PAIs;
(2) the toxic weighting factor for the pyrethrins was
revised: and (3) EPA is using an average non-272
PAI toxic weighting factor based on values for 91
non-272 PAIs instead of using the current loading-
weighted average of the toxic weighting factors for
the 272 PAIs.
B. Best Practicable Control Technology
Currently Available (BPT)
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
As discussed in Section III.D.3. of
today's notice, EPA has amended and
clarified the BPT limitations for the
PFPR/Manufacturers and established
BPT limitations for the stand-alone
PFPR facilities (ie., PFPR facilities
where no pesticide manufacturing
occurs or where pesticide
manufacturing process wastewaters are
not commingled with PFPR process
wastewaters). In addition to clarifying
the use of "zero allowance" for zero
discharge for PFPR/Manufacturers, EPA
is providing both the PFPR/
Manufacturers and the stand-alone
PFPRs with the opportunity to use the
P2 Alternative.
Under the final rule, EPA is amending
the 1978 BPT standard by establishing
a zero discharge limitation with a
compliance alternative which provides
for P2 allowable discharge to surface
waters. EPA is also establishing a zero
discharge limitation (without the use of
a "zero allowance" permitting
mechanism) with a compliance
alternative for a P2 allowable discharge
for the stand-alone PFPR facilities. (See
Section III.D.3. for additional
discussion.)
The zero discharge limitation is based
on pollution prevention, recycle and
reuse practices and, when necessary,
treatment and reuse for those PAIs that
are formulated, packaged and/or
repackaged but are not also
manufactured at the facility. The basis
also includes some amount of contract
hauling for off-site incineration.
Zero allowance is established for
PFPR/Manufacturers for those
pesticides that are formulated, packaged
and/or repackaged and manufactured at
the facility. Zero allowance is based on
pollution prevention, recycle and reuse
practices and treatment and discharge
through the manufacturer's wastewater
treatment system within the pesticide
manufacturing production-based
numeric limitations (i.e., giving no
allowance for the PFPR wastewater or
its production). This is consistent with
how the existing 1978 BPT zero
discharge requirements have been
implemented by permit writers.
The compliance alternative (P2
Alternative) is based on performing
specific pollution prevention, recycle,
reuse and water conservation practices
(as listed in Table 8 to part 455 of the
final rule) followed by a P2 allowable
discharge which requires treatment of
all process wastewaters prior to direct
discharge to surface waters.
EPA has estimated that there are no
additional costs or pollutant removals
associated with the BPT limitation for
the PFPR/Manufacturers, as these costs
have already been absorbed by the
industry over the past 18 years as a
result of the 1978 BPT regulation. (See
Section IV.C.I. for a discussion on BAT
and the associated costs of compliance).
EPA has not assigned any additional
costs to the stand-alone PFPR facilities
as they are also currently achieving zero
discharge. However, facilities may
choose to take advantage of the P2
Alternative in order to achieve a
decrease in cross-media impacts.
Depending on the current means of
achieving zero discharge, a facility's
costs may increase or decrease when
switching to the P2 Alternative. The
costs may increase initially due to the
cost of installing a wastewater treatment
system due to the associated capitol
costs; however, EPA believes that over
the long term, the annual costs for those
facilities which select the P2 Alternative
would be lower. EPA assumes that
facilities will make the choice, to
continue to comply with zero discharge
or to move to the P2 Alternative based,
in significant part, on economic
considerations. Therefore, EPA believes
that if the costs associated with the P2
Alternative were significantly higher,
the facility would not alter their current
means of compliance. Accordingly, EPA
has assumed no incremental costs as a
result of the addition of the P2
Alternative to BPT for stand-alone PFPR
facilities.
2. Refilling Establishments (Subcategory
E)
The existing BPT regulations did not
cover refilling establishments. As
discussed in the proposal (59 FR 17870),
the practice of refilling minibulks did
not begin until the late 1980's, i.e., after
the original BPT regulation was
promulgated in 1978. Based on the
PFPR survey, 98 percent of the existing
refilling establishments achieve zero
discharge. EPA proposed zero discharge
of process wastewater pollutants as the
BPT limitations for refilling
establishments.
In the final regulation EPA is
establishing a BPT limitation for
existing refilling establishments at zero
discharge of pollutants in process
wastewaters to waters of the U.S. This
limitation is based on collection and
storage of process wastewaters,
including rinsates from cleaning
minibulk containers and their ancillary
equipment; and wastewaters from
secondary containment and loading
pads. The collected process wastewater
would be reused as make-up water for
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application to fields in accordance with
the product label. Since greater the 98%
of these facilities already achieve zero
discharge and the remaining facilities
discharge to POTWs, the costs
associated for BPT have been estimated
to be nearly zero.
C. Best Available Technology
Economically Achievable (BAT)
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has established BAT limitations
that are equivalent to the limitations
established for BPT for PFPR/
Manufacturers and stand-alone PFPR
facilities (see Section IV.B.I for
discussion of BPT limitations).
Under the proposal, existing direct
discharge PFPR/Manufacturers were
expected to treat (for reuse) their PFPR
wastewaters in a separate treatment
system from their pesticide
manufacturing wastewater treatment
systems. EPA estimated the compliance
costs for these facilities by costing them
for separate PFPR universal treatment
systems.
Under the final rule, existing direct
discharging Subcategory C facilities will
have a choice of either complying with
a zero discharge limitation or the P2
Alternative (see Section III.D.3. for a
discussion on amending and clarifying
BPT). However, the rule clarifies that in
meeting the zero discharge limitation,
permitting authorities may authorize the
commingling of pesticide manufacturing
and PFPR process wastewaters to meet
the pertinent BAT limitations for
pesticide manufacturers with a zero
allowance for PAIs in PFPR
wastewaters. EPA has revised the cost
model to account for changes in the
final rule due to updated analytical
data, changes in scope and the addition
of the P2 Alternative. However, EPA
believes that an overestimate of the
costs would result if EPA included costs
for separate UTS systems when the
facilities' current controls, used for
treating PFPR wastewaters (i.e., prior to
commingling with pesticide
manufacturing wastewater) and/or
treating commingled wastewater (i.e.,
their pesticide manufacturing treatment
systems), already achieve the BAT
limitation of zero discharge or "zero
allowance."
Thus, EPA is not including these costs
and removals in the total industry
estimate. However, EPA has made a
determination of economic achievability
even if these costs would be incurred,
and is presenting the costs and pollutant
removals associated with the (17) direct
discharging PFPR/Manufacturers for
informational purposes. When current
treatment in place is not accounted for,
the estimated compliance cost for the
PFPR/Manufacturers to comply with
BAT is $2.8 million ($1995) and is
estimated to remove greater than 99% of
the pollutants. This equals 50,248 Ibs
(or 71.6 million Ib-eq.11) of PAIs. Again,
EPA believes this cost is economically
achievable.
2. Refilling Establishments (Subcategory
E)
EPA is establishing BAT limitations
for this Subcategory that are equivalent
to the limitations established for BPT.
Since BPT requires zero discharge of
process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge, EPA believes the same
technology basis and discharge
prohibition is appropriate and
economically achievable for BAT.
D. New Source Performance Standards
(NSPS)
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has set the new source
performance standards for PFPR/
Manufacturers and stand-alone PFPRs
the same as BPT and BAT. The new
source standards are established as
follows:
EPA has established NSPS limitations
equivalent to the limitations that are
established for BPT and BAT. Since
EPA found the Zero/P2 alternative to be
economically achievable for existing
facilities under BPT and BAT on a
facility basis and since new facilities
will be able to choose between zero
discharge and the P2 Alternative on a
product family/process line/process
unit basis, EPA believes that this NSPS
standard does not create a barrier to
entry.
2. Refilling Establishments (Subcategory
E)
EPA is establishing NSPS standards
for this Subcategory that are equivalent
to the limitation established for BPT and
BAT. Since BPT requires zero discharge
of process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge, EPA believes an equivalent
technology basis is appropriate for
NSPS and will not create a barrier to
entry.
11 The large number of toxic weighted pound
equivalents is driven by a large PFPR production
value reported from a single PFPR/Manufacturer
using coumaphos with a toxic weighting factor =
5.6x103.
E. Pretreatment Standards for New
Sources (PSNS)
1. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA is establishing PSNS standards
for this Subcategory that are equivalent
to the standards established for PSES
(i.e., zero discharge with a compliance
alternative for a P2 allowable discharge).
EPA believes that the standards
established for PSNS will not create a
barrier to entry as they are equivalent to
PSES which were found to be
economically achievable.
EPA did not propose to set PSNS (or
NSPS) equal to PSES (or BAT).
Although the PSNS Zero/P2 Alternative
standard discussed above is a change
from the proposed PSNS, it is consistent
with the Supplemental Notice and
comments submitted. At proposal, PSES
included a partial exemption for
exterior wastewater sources from small
sanitizer facilities (see Section II.E of
today's notice for a discussion of the
proposed partial sanitizer exemption);
however, the proposed PSNS did not
include such an exemption and was
found not to create a barrier to entry for
new facilities. The partial sanitizer
exemption no longer effects the
economic achievability of the standards
because in response to comments,
sanitizer products are no longer
included in the scope of the PFPR
effluent guidelines. Based on the
addition of the P2 Alternative option to
these effluent guidelines and standards
and the associated estimated reductions
in cross-media impacts, EPA believes
that it is appropriate to give new
facilities the opportunity to use the P2
Alternative to meet PSNS.
2. Refilling Establishments (Subcategory
E)
EPA is establishing PSNS standards
for this Subcategory that are equivalent
to the limitations established for PSES
(i.e., zero discharge). In addition, BPT,
BAT and NSPS also require zero
discharge of process wastewater
pollutants, and 98 percent of the
existing refilling establishments already
achieve zero discharge; thus, EPA
believes an equivalent technology basis
is appropriate for PSNS and will not
create a barrier to entry.
F. Best Conventional Pollutant Control
Technology (BCT)
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has established BCT limitations
that are equivalent to the limitations
established for BPT. This is because
BPT and BAT establish zero discharge
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57532 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
with a compliance alternative for a P2
allowable discharge and BCT can be no
less stringent than BPT and no more
stringent that BAT. EPA believes there
are no additional costs associated with
these limitations.
2. Refilling Establishments (Subcategory
E)
EPA is establishing BCT limitations
for this subcategory that are equivalent
to the limitations established for BPT.
Since BPT requires zero discharge of
process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge, EPA believes an equivalent
technology basis is appropriate for BCT.
V. Economic Considerations
A. Introduction
Promulgation of the final PFPR rule
requires that the discharge limitations
be both technically and economically
achievable. This section of today's
notice reviews EPA's analysis of the
economic impacts of the regulation and
presents EPA's finding that the
limitations are economically achievable.
EPA's detailed economic impact
assessment can be found in the report
titled "Economic Analysis of Final
Effluent Limitations Guidelines and
Standards for the Pesticide Formulating,
Packaging, and Repackaging Industry"
(hereafter "final EA") [EPA-821-R-96-
017]. The report estimates the economic
effect on the industry of compliance
with the regulation in terms of facility
closures (severe impacts), and
conversions of production lines to
alternate activities and/or compliance
costs exceeding five percent of facility
revenues (moderate impacts). The report
also includes: Analysis of the effects of
the regulation on new pesticide
formulating, packaging, and repackaging
facilities and a Regulatory Flexibility
Analysis detailing impacts on small
businesses and small entities. A
separate report, "Cost-Effectiveness
Analysis of Final Effluent Limitations
Guidelines and Standards for the
Pesticide Formulating, Packaging, and
Repackaging Industry," presents an
analysis of the cost-effectiveness of the
final regulation. All of these analyses
support the conclusion that the effluent
limitations guidelines and standards
contained in the final PFPR regulation
are economically achievable by the
PFPR industry.
The discussion of economic
achievability is organized in three
sections, as follows. Section V.B.
summarizes the economic findings for
the regulation as proposed in April
1994. Section V.C. reviews certain
changes in the regulation since proposal
that were the basis of a supplemental
notice issued in June 1995; and Section
V.D. presents the economic analysis of
the final regulation, as delineated in the
preceding sections of this preamble.
B. Review of the Proposed Regulation
The April 14, 1994 notice of proposed
rulemaking (59 FR 17850) included a
description of the anticipated economic
impacts of proposed effluent limitations
guidelines and standards for the PFPR
industry. These economic impacts are
briefly reviewed below. (See Section
II.E. for a review of the proposed
regulation.)
At proposal, BCT and BAT
requirements were proposed to be
equivalent to the 1978 BPT
requirements; therefore, no additional
costs were expected for compliance
with the BCT and BAT limitations.
Accordingly, the EIA focused on
analyzing alternative PSES options for
the two industry subcategories.
1. Subcategory C: PFPR and PFPR/
Manufacturers
Since completion of the proposal EIA,
EPA has continued to review its
information regarding the structure of
the PFPR industry and has increased its
estimates of the numbers of facilities
using only non-272 PAIs that would
potentially be subject to the Subcategory
C regulation. As a result, EPA's
estimates of the number of affected
facilities and the impacts and costs of
the proposed regulation are higher than
those presented at proposal. For
example, at proposal, EPA estimated
that Subcategory C included 1,479
water-using facilities that were
potentially subject to regulation. Using
the newer population estimates, EPA
now estimates that under the proposal
a total of 2,018 water-using facilities
would have been potentially subject to
regulation. The increase in this estimate
comes entirely from the increased
estimate of the number of facilities
using only non-272 PAIs.12 The
following discussion of the proposed
Subcategory C regulation reflects these
updated estimates of the numbers of
facilities, costs, and impacts.
For the re-estimated proposed rule,
EPA estimates that 2,018 Subcategory C,
water-using facilities were potentially
subject to regulation. Of these 2,018
facilities, 943 used the 272 PAIs that
EPA originally considered for
regulation13 and 1,075 used only the
additional non-272 PAIs. EPA estimates
that 1,142 of these facilities would incur
total annualized compliance costs of
$71.9 million in 1995 dollars14 under
the proposed rule of zero discharge.
The EIA for the proposed regulation
used three primary impact measures:
• Severe impacts, which were defined
as facility closures;
• Moderate impacts or facility
impacts short of closure, which were
defined as line conversions or
incurrence of annualized compliance
costs exceeding five percent of facility
revenue; and
• Employment losses, which, for the
impact analysis, were assumed to
accompany facility closures and line
conversions (but not incurrence of
annualized compliance costs exceeding
5 percent of facility revenue).
Under the proposed PSES
requirements and using the updated
estimate for the number of non-272 PAI-
using facilities, EPA estimates that three
facilities would close as a result of
proposed regulation, while 327 facilities
would incur moderate impacts. In
addition, under the proposed zero
discharge rule, EPA conservatively
estimates total job losses at facilities
incurring impacts at 890 full-time
employment positions. EPA judges the
proposed regulation as economically
achievable using these updated impact
values that are based on the higher
number of non-272 PAI-using facilities.
In addition to the facility impact
analysis, EPA analyzed the cost-
effectiveness of the proposed regulation
for Subcategory C facilities. Cost-
effectiveness is calculated as the ratio of
the incremental annual costs in 1981
dollars to the incremental pounds-
equivalent of pollutants removed for
each option. Using the updated
estimates of costs and removals for the
proposed regulation, EPA estimates total
pollutant removals of 505,235 pounds,
or 38.9 million pounds-equivalent on a
toxic weighted basis, and an average
cost-effectiveness value of $1.65 per
pound-equivalent.15 le EPA considers
the proposed option to be cost-effective.
12 Due to changes in scope for the final regulation,
1,411 water using facilities will be potentially
subject to the final regulation.
13 Many of these facilities also used non-272 PAIs
in addition to the 272 PAIs.
14 The costs of regulatory compliance are all
reported in 1995 dollars. In the EIA and the Federal
Register Notice for the regulation at proposal and
in the Supplemental Notice, regulatory compliance
were reported in 1988 dollars, the base year of the
PFPR industry survey. All cost estimates, including
the proposal and the supplemental notice have been
brought forward to 1995.
15The toxicity of the non-272 PAIs used in
generating this cost-effectiveness value was
estimated as the average pre-compliance loading-
weighted average toxicity of the 272 PAIs.
16 At proposal, EPA reported an average cost-
effectiveness, or the cost-effectiveness value
calculated relative to the baseline of no regulation,
and an incremental cost-effectiveness, or the cost-
effectiveness relative to the next less stringent
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57533
For analysis of the final regulation,
EPA revised the toxic weighting factors
to reflect additional information on the
toxicity of the PAIs. In general, the
revisions reduced the estimated toxicity
of the PAIs subject to regulation (see
Section V.D.6, below, which contains
the discussion of the cost-effectiveness
analysis for the final regulation). Using
these revised toxic weighting factors
and also taking into account the
updated estimates of costs and pollutant
removals for non-272 PAI-using
facilities, EPA estimates that the
proposed regulation would remove an
estimated 23.2 million pounds-
equivalent, yielding a cost-effectiveness
value of $2.77 per pound-equivalent
($1981).
2. Subcategory E: Refilling
Establishments
At proposal, an estimated 1,134
refilling establishments (Subcategory E
PFPR facilities) were potentially subject
to regulation. EPA estimates that 98
percent of these facilities, were already
in compliance with the proposed
Subcategory E limitations and
pretreatment standards. All but 19 of the
1,134 existing facilities were expected to
incur no costs to comply with the
proposed option. The remaining 19
facilities were expected to achieve
compliance with no significant
additional cost17 (See Section VLB.2).
No economic impacts were estimated to
occur due to compliance with the
proposed rule.
C. Changes to the EIA Since Proposal:
Issuance of the June 1995 Supplemental
Notice
In response to public comments on
the regulation, EPA issued a
Supplemental Notice (60 FR 30217) on
June 8, 1995 that solicited comment on
proposed changes in the scope of the
PFPR regulation for Subcategory C
facilities and on the Zero/P2
Alternative. In addition, EPA revised
the cost estimating methodology and
economic impact estimates.
As discussed in Section III.B.4. of
today's notice, EPA estimated
compliance costs for each facility to
comply with the Zero/P2 Alternative
option. Each facility was assumed to
choose either zero discharge or the P2
Alternative for compliance, depending
regulatory option considered. However, the
incremental calculation and the comparison are no
longer relevant as the alternative options at
proposal are no longer under consideration. For this
reason, in the current discussion, EPA is reporting
only the cost-effectiveness value calculated relative
to the baseline of no regulation.
17 A capital investment of approximately $500
was estimated for each of these facilities.
on which alternative would impose the
lower annualized costs on the facility.
For the Supplemental Notice, EPA
estimated total annualized compliance
costs for facilities covered under PSES
at $43.4 million, in 1995 dollars, or 40
percent less than the costs for the
proposed regulation. Under the Zero/P2
Alternative option, no facilities were
assessed as closures as the result of the
compliance requirements, while 208
facilities were assessed as incurring
moderate impacts.18 The comparable
values for the regulation for the
proposal (re-estimated using the revised
cost previously discussed) are 3 facility
closures and 327 facilities with
moderate impacts.
D. Assessment of Costs and Impacts for
the Final PFPR Regulations
This section describes the impact
measures used in the Economic
Analysis, the estimated impacts
associated with the final rule, impacts
on new sources, and the cost-
effectiveness analysis. As discussed
below, EPA is promulgating the
regulation for Subcategory E facilities as
presented at proposal with storm water
now exempted, but the analysis of costs
and impacts for the Subcategory E
regulation remain the same as presented
at proposal. Accordingly, the following
discussion focuses on the Pretreatment
Standards for Existing Sources (PSES)
regulation for Subcategory C facilities.
1. Summary of Economic Analysis
Methodology and Data
The data sources and methodology for
analyzing economic impacts remain the
same as used at proposal and for the
Supplemental Notice. For a more
detailed discussion of the methodology
used in the economic impact analysis,
see the preamble for the PFPR
regulation at proposal (59 FR 17850),
the proposal EIA report and final EA
report.
The economic impact analysis
measures three types of primary
impacts: severe impacts (facility
closures), moderate impacts (facility
impacts short of closure), and job losses.
Each impact analysis measure is
reviewed briefly below.
• Severe Impacts. Severe impacts,
defined as facility closures, were
assessed on the finding that the
regulation would be expected to cause
a facility to incur, on average, negative
after-tax cash flow over the three-year
period of analysis. This analysis was
performed for PFPR/Manufacturers and
18 The cost and impact values for the
Supplemental Notice regulation reflect updating of
the estimates of non-272 PAI-using facilities.
for facilities that do not manufacture
PAIs, but receive at least 25 percent of
their revenue from PFPR activities.
Facilities with relatively low reliance on
PFPR activities as a source of revenue
(i.e., less than 25 percent of revenue)
were excluded from this analysis
because EPA does not anticipate that
such facilities would close in entirety
because of costs of regulatory
compliance associated with PFPR
activities. EPA also did not include
PFPR facilities from Subcategory E
(refilling establishments) in this analysis
largely because of their relatively low
reliance on PFPR activities as a source
of revenue (an average of 15 percent).
• Moderate Impacts. Moderate
impacts were defined as a financial
impact short of entire facility closure
and were analyzed in two ways. First,
PFPR facilities subject to the
Subcategory C regulation and with less
than 25 percent of revenue from PFPR
activities were assessed for line
conversions by comparing the after-tax
return on assets (ROA) from PFPR
activities after regulation with the ROA
estimated to be achievable in an
alternative line of business. Facilities for
which the post-compliance ROA for
PFPR activities was found to be less
than the return achievable in an
alternative line of business were
assumed to switch out of PFPR
operations. Second, all Subcategory C
and E facilities, regardless of PFPR
revenue reliance, were assessed for the
incurrence of total annualized
compliance costs exceeding five percent
of facility revenue.
• Employment losses. Possible
employment losses were assessed for
facilities estimated to close as a result of
regulation and for facilities estimated to
convert PFPR lines to an alternative
business activity. EPA believes that the
estimates of employment loss resulting
from this analysis are highly
conservative because of the assumption
that line conversions would result in
loss of employment for a facility's PFPR-
related employment. More realistically,
EPA expects that line conversions will
not generally lead to full loss of PFPR-
related employment.
As in the economic impact analysis
for the proposed PFPR regulation, these
analyses for the final regulation assume
that PFPR facilities would not be able to
pass the costs of compliance on to their
customers through price increases.
Analysis of pesticide product markets
and the likely response of pesticide
product customers to price increases (as
discussed in the proposal EIA),
indicates that a substantial number of
facilities should recover some part of
their compliance costs through price
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57534 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
increases. Thus, the analyses of
compliance cost and impacts overstate
the severity of the regulation's financial
burden on the PFPR industry.
EPA extrapolated information on
compliance costs, pollutant loadings,
and the frequency of facility-level
compliance impacts from data on
facilities in the original PFPR industry
survey to analyze the technical and
economic impacts of regulating the
additional non-272 PAIs.19 In the
following discussion, EPA has not
separated the estimated costs or impacts
according to which set of PAIs facilities
are estimated to use. Additional details
of the analysis of costs and impacts for
the facilities using the different sets of
PAIs may be found in the final EA.
Although the impact analysis
methodology for the final regulation is
unchanged from proposal (see the
Proposal EIA), its application has been
changed for analyzing the Zero/P2
Alternative. This regulatory option was
analyzed for each sample facility as part
of two separate compliance approaches:
(1) Zero discharge and (2) pollution
prevention in combination with
treatment followed by discharge (see
Section IV.A.I). Facilities were assumed
to adopt the compliance approach with
the lower total annualized compliance
cost including both annual operating
and maintenance costs and an annual
allowance for capital outlays. Although
most facilities were estimated to achieve
compliance by pollution prevention and
treatment, some were estimated to
comply by zero discharge. Thus, the
combination of the analyses for the two
separate compliance approaches yields
the aggregate analysis for the final
regulation for Subcategory C facilities.
19 Although the PFPR industry survey focused on
facilities using the original 272 PAIs, some of these
facilities were also found to use one or more of the
additional non-272 PAIs in their PFPR activities.
During site visits, EPA also observed PFPR
operations at several facilities that process both
original 272 and non-272 PAIs. Thus, the set of
facilities used for extrapolating financial and
technical information to facilities using the non-272
PAI chemicals and the impacts of bringing these
additional PAIs under regulation also includes
information on facilities that use these non-272
PAIs.
EPA believes this methodology provides
a realistic appraisal of the costs and
impacts of the final regulation as it
embodies the compliance decision that
facility management is expected to face
in deciding whether to comply by zero
discharge or by pollution prevention in
combination with treatment followed by
discharge. In addition, because EPA's
analysis considers both capital and
operating costs, EPA believes that the
findings from the compliance decision
analysis will reasonably approximate
facility managements' findings
regarding choice of the less financially
burdensome compliance approach. In
addition, under the final rule, facilities
will be able to make the choice between
zero discharge and the P2 Alternative on
a product family/process line/process
unit basis, which will give them even
more flexibility in their compliance
choice.
2. Estimated Facility Economic Impacts
a. Subcategory C: PFPR and PFPR/
Manufacturers
The costs and impacts for the final
regulation applicable to PSES
Subcategory C facilities are discussed in
this section and are compared with the
values estimated for the proposed and
supplemental notice regulations. In
addition, the cost and impacts for the
final regulation are compared with those
that EPA estimates would occur if
facilities were not provided the
flexibility to choose the preferred
compliance approach from the zero
discharge and pollution prevention
allowable discharge alternatives. These
comparisons show that the final
regulation provides a more economical
and less financially burdensome
approach to achieving desired discharge
reductions than the proposed, and
otherwise previously noticed,
requirements considered.
The following comparisons with the
proposed regulation are relative to the
cost and impact values based on the
new estimates of the number of facilities
using only non-272 PAIs. As noted
previously, these revisions increased the
costs and impacts estimated for the
proposed regulation. The following
discussion will show that the costs and
impacts for the final regulation are
substantially less than the updated
estimates for the proposed regulation.
Although this discussion will not
include comparisons with the values for
the proposed regulation as originally
published, EPA points out that the costs
and impacts for the final regulation are
also markedly less than the original
estimates of costs and impacts for the
proposed regulation.
Of the 2,018 water-using Subcategory
C facilities re-estimated to be subject to
the regulation at proposal, EPA
estimates that 506 facilities, or 25
percent, including baseline failures, will
incur costs in complying with the final
Subcategory C PSES regulation. Total
annualized compliance costs for these
facilities are estimated at $29.9 million,
in 1995 dollars (see Table 1, below).
Excluding baseline closures from the
cost analysis reduces the number of
facilities expected to incur costs to 421
facilities and total annual costs to $24.2
million, in 1995 dollars. In estimating
the costs of the final regulation,
facilities were assigned to the
compliance option—zero discharge or
the pollution prevention alternative—
with the lower total annualized
compliance cost. From this analysis, 69
percent of the cost-incurring facilities
(including baseline failures) were
expected to select the P2 Alternative
with the remaining 31 percent selecting
zero discharge.
No facilities are projected to close
under the final regulation. A total of 150
possible line conversions (a moderate
impact) are estimated. EPA does not
generally expect that line conversions
will result in employment losses.
However, to be conservative in its
analysis, EPA estimated the maximum
potential employment loss associated
with the regulation by assuming that all
PFPR employment would be lost in
facilities with line conversions. From
this assumption, the upper bound
employment loss for the final regulation
is estimated at 458 full-time
employment positions (FTEs).
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57535
TABLE 1 .—ESTIMATED COSTS AND IMPACTS OF THE FINAL, PROPOSED AND SUPPLEMENTAL NOTICE PSES REGULATION
FOR SUBCATEGORY C FACILITIES
Proposed Regulation
Supplemental Notice
Final Regulation — Costs Including Baseline Closures
Final Reaulation — Costs Excludina Baseline Closures
Number of fa-
cilities incur-
ring costs
1,142
709
506
421
Total
annualized
compliance
cost ($1995,
millions)
$71.9
43.4
299
24.2
Severe
impacts t
3
0
0
Moderate
impacts*
327
208
150
Maximum po-
tential employ-
ment losstt
890
634
458
t Severe impacts are defined as facility closures. All facility employment is assumed to be lost as the result of a facility closure.
'Moderate impacts are defined as line conversions and/or total annual compliance costs exceeding 5 percent of total facility revenue. EPA
does not expect that employment losses would generally accompany line conversions; however, for this analysis, EPA assessed the maximum
potential loss based on the assumption that all employment associated with PFPR activities would be lost as a result of a line conversion.
tt Employment loss for the proposed regulation includes the estimated employment loss in facility closures and the worst case estimate of em-
ployment loss in facilities with line conversions. The reported employment loss for the Supplemental Notice and Final Regulation reflects no facil-
ity closures and includes only the worst case employment loss in facilities with line conversions.
In addition to presenting the
estimated costs and impacts for the final
regulation, Table 1 also presents the
comparable values for the proposal (re-
estimated) and the supplemental notice.
As shown in the table, the expected
burden of the regulation has fallen
considerably from proposal through
supplemental notice to the final
regulation. From proposal (re-estimated)
to final, the number of Subcategory C
facilities expected to incur costs has
fallen from 1,142 to 506 facilities, or 56
percent20. This can be attributed to the
reduction in scope of certain PAIs and
wastewater sources as well as to the
addition of the P2 Alternative as a
compliance option to zero discharge.
The estimated drop in total annual
compliance cost, from $71.9 million to
$29.9 million ($1995), represents an
even greater reduction from proposal, at
58 percent. As noted above, no severe
impacts are assessed for the final
regulation while 3 facility closures were
estimated for the proposed regulation.
Finally, the number of moderate
impacts and potential employment
losses are also substantially reduced
from proposal, falling by 54 percent and
49 percent, respectively. In summary,
under the final regulation, the number
of facilities estimated to incur costs, the
expected cost, and the facility impacts
are considerably less than estimated for
the proposed regulation.
EPA also believes that the final
regulation is superior to the other
options considered because of the
flexibility it provides to facilities in
deciding how to achieve compliance. In
particular, by allowing facilities to
choose the less expensive compliance
approach—the pollution prevention
alternative or zero discharge—the
regulation achieves substantial
pollution reductions but at substantially
lower costs and economic impacts than
would occur if the regulation allowed
compliance by only one of the possible
approaches.21 Moreover, EPA notes that,
by encouraging consideration and use of
pollution prevention as a compliance
approach, the final regulation will
reduce the potential for cross-media
impacts that would occur under a strict
zero discharge requirement. The
regulation achieves these benefits with
only a very modest reduction in the
expected pollutant removals that would
be achieved under a zero discharge
regulation. Specifically, EPA estimates
that the final regulation will remove
189,908 pounds or 98.5 percent, of the
estimated 192,789 pounds of pollutant
discharges subject to control by the final
regulation (assuming zero removals by
POTWs currently—see Cost-
Effectiveness Analysis in Section V.D.6).
EPA estimates that only 2,881 pounds,
or about 1.5 percent of the pollutant
loadings subject to the final regulation
will continue to be discharged to
POTWs.
Finding of Economic Achievability
The final regulation achieves
substantial reductions in harmful
pollutant discharges at very modest
economic burden to the PFPR industry.
Under a conservative assumption that
facilities will recover none of their
compliance costs through price
increases, the regulation is estimated to
impose no severe impacts (i.e., facility
closures), 150 moderate impacts (i.e.,
line conversion or annualized
compliance cost exceeding 5 percent of
20 All comparisons with the proposed regulation
and supplemental notice are based on the analyses
including baseline closures.
21 EPA has worded the final regulation to allow
facilities to make the choice between zero discharge
and the pollution prevention alternative on a
product family/process unit/process line basis (as
opposed to a full facility basis). However, EPA
could not estimate costs on this basis.
facility revenue), and a worst-case
employment loss of 458 FTEs. In
addition, the final regulation provides
industry with considerable latitude in
deciding how to comply with the
regulation—that is, by zero discharge or
pollution prevention and treatment. In
this regard, EPA's analyses of the
selected compliance approach may
overstate compliance costs because the
analyses assume application of one
approach throughout the facility instead
of a more customized choice of
compliance approach by PFPR line.
Also, EPA estimates that a relatively
small fraction—25 percent—of the
facilities potentially subject to the
proposed regulation are likely to incur
costs in complying with the final
regulation. That such a small fraction of
the industry is expected to incur costs
reflects in large part EPA's decision to
exclude additional PAIs and
wastestreams from coverage under the
final regulation. Finally, EPA notes that
the aggregate costs and impacts
estimated for the final regulation are
substantially less than those estimated
for the proposed regulation, both as
analyzed for the original proposal and
as analyzed on the basis of the higher
estimate of non-272 PAI-using facilities.
In light of these very modest impacts
estimated for the final regulation, EPA
finds that the final PSES regulation for
Subcategory C facilities is economically
achievable.
b. Subcategory E: Refilling
Establishments
The regulatory approach and costing
methodology for Subcategory E facilities
is unchanged from that presented at
proposal with the exception that storm
water is no longer considered a process
wastewater subject to this regulation.
The analysis of costs, loadings, and
economic methodology at proposal
stands as previously presented.
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57536 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
EPA is establishing BPT and BAT
regulations for Subcategory E facilities
set to zero discharge (equivalent to
PSES). EPA's survey of the PFPR
industry indicated that no Subcategory
E facilities are direct dischargers.
Accordingly, EPA estimates that the
Subcategory E portion of the PFPR
industry will incur no costs for
complying with the BPT or BAT
requirements.
4. Regulatory Effects Not Re-Estimated
Because the aggregate compliance
costs and facility impacts estimated
under the final regulation are
substantially less than those estimated
for the regulation as presented at
proposal, EPA did not re-evaluate the
following economic measures for the
final regulation: community impacts,
foreign trade effects, impacts on firms
owning PFPR facilities, the direct
economic benefits to facilities of
pollution prevention practices, and the
labor requirements. The analysis of
these additional impact categories
depends on the estimated aggregate
costs for the regulation and on the
results of the facility impact analysis.
With the final regulation estimated to
impose aggregate compliance costs that
are 56 percent less than originally
estimated for the proposed regulation
and to cause no facility closures
(compared to the 2 closures originally
estimated at proposal), EPA concluded
that the analysis for these additional
impact categories under the final
regulation would find less
consequential effects than had been
originally estimated at proposal.
Because EPA had judged the slight
impacts estimated at proposal for the
additional impact categories to be
consistent with an economically
achievable regulation, EPA, therefore,
concluded that the impacts under the
final regulation for these additional
impact categories would also be found
consistent with an economically
achievable regulation. As a result, EPA
decided not to expend the resources that
would be necessary to re-estimate and
re-document the lower impact levels for
these additional impact categories.
5. Impacts of Pretreatment Standards for
New Sources (PSNS) and New Source
Performance Standards (NSPS)
a. Subcategory C: PFPR and PFPR/
Manufacturers
(1) PSNS
EPA is setting PSNS (Pretreatment
Standards for New Sources) for
Subcategory C facilities equal to PSES
limitations for existing sources. In
general, EPA believes that new sources
will be able to comply at costs that are
similar to or less than the costs for
existing sources, because new sources
can apply control technologies and P2
practices (including dedicated lines and
pressurized hoses for equipment
cleaning) more efficiently than sources
that need to retrofit for those
technologies and P2 practices. As a
result, given EPA's finding of economic
achievability for the final PSES
regulation for Subcategory C facilities,
EPA also finds that the PSNS regulation
will be economically achievable and
will not constitute a barrier to entry for
new sources.
(2) NSPS
EPA has established NSPS limitations
equivalent to the limitations that are
established for BPT and BAT. BPT and
BAT limitations allow facilities to use
the Zero/P2 Alternative and were found
to be economically achievable;
therefore, NSPS limitations will not
present a barrier to entry for new
facilities.
b. Subcategory E: Refilling
Establishments
EPA is setting NSPS/PSNS for
Subcategory E facilities equal to BAT/
PSES limitations for existing sources.
EPA estimates that compliance with
BAT/PSES will impose no costs on
existing facilities. Likewise, new
facilities are not expected to incur
additional annual costs due to the
regulation. Because EPA found
compliance with the final regulation to
be economically achievable for existing
facilities, EPA determined that
compliance with NSPS/PSNS will also
be economically achievable and not a
barrier to entry for new sources.
6. Cost-Effectiveness Analysis
EPA also performed a cost-
effectiveness analysis of the final PSES
regulation for Subcategory C facilities.
(A more detailed discussion can be
found in the final Cost-Effectiveness
Analysis (September 1996) [EPA-821-
R-96-018]. The cost-effectiveness
analysis compares the total annualized
cost incurred for a regulatory option to
the corresponding effectiveness of that
option in reducing the discharge of
pollutants.
Cost-effectiveness calculations are
used during the development of effluent
limitations guidelines and standards to
compare the efficiency of one regulatory
option in removing pollutants to
another regulatory option. Cost-
effectiveness is defined as the
incremental annual cost of a pollution
control option in an industry
Subcategory per incremental pollutant
removal. The increments are considered
relative to another option or to a
benchmark, such as existing treatment.
In cost-effectiveness analysis, pollutant
removals are measured in toxicity
normalized units called "pounds-
equivalent." The cost-effectiveness
value, therefore, represents the unit cost
of removing an additional pound-
equivalent (Ib eq.) of pollutants. In
general, the lower the cost-effectiveness
value, the more cost-efficient the
regulation will be in removing
pollutants, taking into account their
toxicity. While not required by the
Clean Water Act, cost-effectiveness
analysis is a useful tool for evaluating
regulatory options for the removal of
toxic pollutants. Cost-effectiveness
analysis does not analyze the removal of
conventional pollutants (e.g., oil and
grease, bio-chemical oxygen demand,
and total suspended solids).
For the cost-effectiveness analysis, the
estimated pounds-equivalent of
pollutants removed were calculated by
multiplying the number of pounds of
each pollutant removed by the toxic
weighting factor for each pollutant. The
more toxic the pollutant, the higher will
be the pollutant's toxic weighting factor;
accordingly, the use of pounds-
equivalent gives correspondingly more
weight to pollutants with higher
toxicity. Thus, for a given expenditure
and pounds of pollutants removed, the
cost per pound-equivalent removed
would be lower when more highly toxic
pollutants are removed than if
pollutants of lesser toxicity are
removed. Annual costs for all cost-
effectiveness analyses are reported in
1981 dollars so that comparisons of
cost-effectiveness may be made with
regulations for other industries that
were issued at different times.
a. Subcategory C: PFPR and PFPR/
Manufacturers
Table 2 provides estimates of the total
annualized compliance costs, in 1981
dollars, the total pollutant removals in
pounds and pounds-equivalent, and the
cost-effectiveness of the final PSES
regulation for Subcategory C facilities
with estimates of various POTW
removals. EPA has estimated the
pollutant removals and the cost-
effectiveness value for the final rule
using the same methodology as used in
the proposed rule and supplemental
notice (and the Pesticide Manufacturing
effluent guideline). This methodology
assumes that all PAIs pass through the
POTW (i.e., no removal by the POTW),
as there is little field data on the
effectiveness of POTWs removing PAIs.
However, EPA has developed
laboratory estimates for the percent
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57537
removals of a large number of pollutants
(including some PAIs) which were
published in the Domestic Sewage
Study (DSS), February 1986 [EPA/530-
SW-86-004]. For each pollutant
studied, two estimates were developed,
an "acclimated" removal percentage,
which might be achieved by a well-run
treatment facility with a constant flow
rate of the pollutant in question, and an
"unacclimated" removal percentage,
adjusted to account for the slug loadings
and batch discharges which POTWs
experience in everyday operation. While
the unacclimated removals were
intended to more accurately reflect real
world operating conditions, a limited
amount of test data on non-PAI
pollutants indicates that POTWs may
achieve or even exceed the acclimated
removal estimates in practice. Thus it is
not clear whether the acclimated or
unacclimated estimates more accurately
represent the removal percentages
achieved in practice for PAIs. EPA has
thus developed a range of cost-
effectiveness and total removals using
three different assumptions about the
removal efficiency of POTWs: zero
removals (this most conservative
estimate is included because of the lack
of actual data), unacclimated removals
(which range from 30% to 90% and
average 48%), and acclimated removals
(which range from 80% to 95%).
Using this range of POTW removals,
EPA has estimated the range of removal
to be between 18,991 and 189,908
pounds of pollutants, or 760,000 to 7.6
million toxic pounds-equivalent with
cost-effectiveness ranging from $2.74 to
$27.35 per pound-equivalent when
compliance costs are held constant at
$20.9 million22 in 1981 dollars. EPA
considers even the high end of this
range to be cost effective. In order to be
consistent with the proposed rule and
supplemental notice (and because of the
lack of actual POTW removal data for
PAIs), EPA is presenting the cost-
effectiveness and total removals for the
final rule as $2.74 per pound-equivalent
and 189,908 pounds or 7.6 million
pounds-equivalent, respectively.
TABLE 2.—NATIONAL ESTIMATES OF TOTAL ANNUALIZED COSTS, REMOVALS AND COST-EFFECTIVENESS VALUES FOR
SUBCATEGORY C PSES FACILITIES UNDER THE FINAL REGULATION
POTW removal assumption used
No POTW Removals
POTW Removals per DSS
90 Percent Removal Efficiency
Total
annualized
compliance
costs (millions
of $, 1981)
$209
209
20.9
Pollutant
removals,
pounds
1 89 908
1 65 460
18.991
Pollutant removals,
(pounds-equiva-
lent)
7 6 million
5 8 million
760.000
Cost-effective-
ness
($/lb.-eq.)
$274
360
27.35
Notes:
1. Includes estimated baseline failures.
2. Toxic weighting factors used in the analyses reflect more recent toxicological information and are generally lower than the factors used at
proposal and supplemental.
EPA has also estimated the removals,
annual compliance cost, and cost-
effectiveness excluding baseline
closures (when zero removal at POTWs
is assumed). Excluding estimated
baseline failures lowers the costs and
removals to $17.1 million ($1981) and
156,592 pounds (5.8 million pounds-
equivalent). The cost-effectiveness value
excluding baseline failures is $2.93 per
pound-equivalent, which EPA considers
to be cost-effective.
The cost-effectiveness value
(assuming no POTW removal) for the
final regulation is not directly
comparable to the values presented in
the previous Federal Register notices
for the proposed regulation and the
supplemental notice for two reasons.
First, the scope of the regulation has
changed with fewer PAIs and waste
streams covered under the final
regulation. As a result, the baseline
pollutant discharges and pollutant
removals estimated for the final
regulation are lower than the values
estimated for the proposed regulation.
Second, the toxic weighting factors
(TWFs) used by EPA for calculating the
cost-effectiveness of the final regulation
reflect more recent toxicological data
and, in general, are lower than the
values used for the proposal and
supplemental notice analyses. To
provide a consistent comparison of the
proposed, supplemental, and final
regulations, EPA re-calculated the toxic-
weighted baseline discharges, pollutant
removals, and cost-effectiveness values
for the proposed and supplemental
notice regulations using the more recent
toxic weighting factors (see Table 3).23
The calculations for the final regulation
also embody the changes in regulatory
scope.
TABLE 3.—ESTIMATED COST-EFFECTIVENESS OF THE FINAL PSES REGULATION FOR SUBCATEGORY C FACILITIES
COMPARED WITH THE PROPOSED AND SUPPLEMENTAL NOTICE REGULATIONS
[All toxic-weighted values based on toxic weighting factors developed for the Final Regulation]
Total Annualized Cost $1981
Pollutant Discharges Subject to Regulation, pounds
Pollutant Loadings Subject to Regulation pounds-equivalent
Pollutant Removals, oounds
Proposed regulation:
Zero discharge with
sanitizer exemption
(Option 3/S.1)
$64 1 million
505,235
23 2 million
503.114
Supplemental notice:
Zero discharge/pollu-
tion prevention alter-
native
$32 7 million
337,995
154 million
333.731
Final regulation: Zero
discharge/pollution
prevention alternative
$20 9 million
192,789.
7 7 million
189.908.
22 EPA believes that if POTWs are removing PAIs,
the cost of compliance of the industry would be
lower than $20.9 million ($1981) due to the
reduction in operating and maintenance costs
associated with the treatment system used to
pretreat PFPR wastewaters prior to discharge to the
POTW.
23 The re-calculated cost-effectiveness values for
the proposed regulation also reflect the updated
estimates of the number of facilities using non-272
PAIs.
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57538 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 3.—ESTIMATED COST-EFFECTIVENESS OF THE FINAL PSES REGULATION FOR SUBCATEGORY C FACILITIES
COMPARED WITH THE PROPOSED AND SUPPLEMENTAL NOTICE REGULATIONS—Continued
[All toxic-weighted values based on toxic weighting factors developed for the Final Regulation]
Pollutant Removals pounds-equivalent
Cost-Effectivenessl
Proposed regulation:
Zero discharge with
sanitizer exemption
(Option 3/S.1)
23 2 million
$2.77/lb-ea
Supplemental notice:
Zero discharge/pollu-
tion prevention alter-
native
153 million
$2.14/lb-ea
Final regulation: Zero
discharge/pollution
prevention alternative
7 6 million
$2.74/lb-ea.
AAAJCost-effectiyeness analysis is conventionally calculated on an incremental basis: that is, the costs and removals of a given option are
calculated as the differences from the values for the next less stringent option. At proposal, the cost-effectiveness of Option 3/S.1 was calculated
on an incremental basis relative to the next less stringent option, Option 3/S. However, the cost-effectiveness values for the supplemental notice
and final regulations are relative to a next less stringent option of no regulation. To permit consistent comparison of the three regulations, the
cost-effectiveness of the proposed regulation has been restated relative to a no-regulation baseline.
The effect of the regulation's reduced
scope is seen by the reductions in
pollutant loadings subject to regulation
in pounds and pounds-equivalent (see
Table 3, lines 2 and 3). These results
show the pollutant loadings subject to
the rule at proposal to be 505,235
pounds, and on a toxic-weighted basis,
23.2 million pounds-equivalent; under
the final regulation, the pollutant
loadings within the scope of the
regulation fall to 192,789 pounds and
7.7 million pounds-equivalent on a
toxic-weighted basis. The cost-
effectiveness values of the regulations
using the current set of weighting
factors are: $2.77 per pound-equivalent
for the proposed regulation, $2.14 per
pound-equivalent for the supplemental
notice, and $2.74 per pound-equivalent
for the final regulation. The cost-
effectiveness value for the final
regulation is low in relation to the
values calculated for other effluent
limitations guidelines and standards
recently promulgated by EPA.
b. Subcategory E: Refilling
Establishments
Estimates of compliance costs and
pollutant removals associated with
Subcategory E facilities have not
changed since the proposed regulation.
EPA believes that the final regulation
can be implemented at a minimal cost
(i.e., a capital investment of
approximately $500 for a mini-bulk tank
to store water for reuse) at the 19
facilities not currently in compliance.
Therefore, EPA determines the final
regulation to be cost-effective for
Subcategory E facilities.
E. Regulatory Flexibility Act
Pursuant to section 605 (b) of the
Regulatory Flexibility Act, 5 U.S.C.
605(b), the Administrator certifies that
this rule will not have a significant
economic impact on a substantial
number of small entities. EPA analyzed
the potential impact of the rule on both
small businesses and small local
governments.
Under the Regulatory Flexibility Act,
an agency is not required to prepare a
regulatory flexibility analysis for a rule
that the agency head certifies will not
have a significant economic impact on
a substantial number of small entities.
While the Administrator has so certified
today's rule, the Agency nonetheless
prepared a regulatory flexibility
assessment equivalent to that required
by the Regulatory Flexibility Act as
modified by the Small Business
Regulatory Enforcement Fairness Act of
1996. The assessment for this rule is
detailed in the "Economic Analysis of
Final Effluent Limitations Guidelines
and Standards for the Pesticide
Formulating, Packaging, and
Repackaging Industry" [EPA-821-R-
96-017].
EPA received many comments
regarding the rule (see Section 15.6 of
the technical record and Section IV in
the economic record for the
rulemaking). A number of commenters
raised issues concerning small business
impacts and the need to reduce the
regulation's burden on small businesses.
Specifically, as a way of reducing
possible adverse impacts on smaller
businesses, some commenters requested
that EPA broaden its exemption from
the regulation to include all small
businesses. In addition, some
commenters argued that EPA did not
need to regulate the discharges of small
PFPR businesses because the pollutant
discharges of such facilities were not
likely to have a consequential
environmental impact.
EPA disagrees with this claim and
believes it is inappropriate to set small-
business and/or small-production
exemptions for all small businesses and/
or production volumes because of the
substantial toxicity of many of the PAIs.
The size of the business and/or the
volume of PAIs processed annually are
not a sufficient basis for determining
that a facility should be exempted from
regulation. Because of the high toxicity
of many of the PAIs, the processing of
even very small quantities of such PAIs
can result in pollutant discharges of
substantial toxicity. In addition, small
business size does not necessarily
equate with small pesticide production
volume, particularly in terms of toxicity.
Some small-business PFPR facilities
process a substantial volume of PAIs
and have the potential to discharge
substantial volumes of toxic pollutants
unless discharges are limited by the
PFPR regulation, (see the Comment
Response Documents in the rulemaking
record for more information on these
comments and EPA's response to them.)
Taking into account commenters"
concerns regarding possible impacts on
small entities, EPA introduced the Zero/
P2 Alternative Option and made
numerous changes to the rule designed
to reduce the burden upon all PFPR
facilities, particularly small business
entities. As previously discussed, the
final rule expands the sanitizer
exemption to exempt additional lower
toxicity PAIs from regulatory coverage
and gives facilities a Zero/P2
compliance choice on a line by line or
process by process basis.
The factual analysis and basis for the
"no significant impact" certification is
contained in Chapter 4 of the final EA
report referenced previously and is
summarized below.
1. Analysis of Impacts on Small
Business Entities
To gauge the impact of the final
regulation on small business, EPA
analyzed the impact of the final
regulation on Subcategory C facilities
according to the business size of the
owning firms and compared the
findings for the final regulation with
those for the proposed regulation. Given
the large presence of small business-
owned entities in the PFPR industry,
EPA exercised substantial care at
proposal and throughout development
of the final regulation, to ensure that the
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57539
final regulation would not impose a
significant impact on a substantial
number of small business-owned
facilities. This effort results in the
modest incurrence of both costs and
impacts by small business entities under
the final regulation.
EPA estimates that 1,513 (75.0
percent) of the 2,018 PFPR facilities
potentially subject to a Subcategory C
PSES regulation are owned by small
entities. Of the 506 facilities estimated
to potentially incur compliance costs
under the final rule (including baseline
failures), 357 (70.6 percent) are
estimated to be owned by small entities.
Excluding projected baseline failures,
421 facilities are expected to incur costs,
of which 274, or 65.1 percent are small
business-owned facilities.
No small business-owned facilities are
estimated to close as a result of
regulation. Less than 10 percent of small
business-owned facilities (137 facilities)
are estimated to incur a moderate
impact " that is, a line conversion or
annualized compliance cost exceeding 5
percent of facility revenue. The average
compliance cost burden among small
business-owned facilities is also small
in relation to facility revenue: on
average, annualized compliance costs
amount to 2.7 percent of facility revenue
for small business-owned facilities.
Finally, the number of small business-
facilities incurring costs, and the
numbers of small business-facilities
incurring severe or moderate impacts
are substantially less than estimated for
the proposed regulation. For the
proposed regulation (re-estimated), 859
small business-facilities were estimated
to incur costs, 3 facilities were assessed
as potential closures (severe impacts),
and 275 facilities were assessed as
moderate impacts; the comparable
values for the final regulation are 357
small-business facilities incurring costs,
zero severe impacts, and 137 moderate
impacts. The substantial reduction in
impacts among small business-owned
facilities from proposed to final
regulation reflects EPA's efforts to
moderate the burden of the regulation
by introducing a new option which
gives facilities the two compliance
alternatives, by reducing the PAIs and
wastestreams subject to the regulation,
and by providing facilities with greater
flexibility in deciding how to achieve
regulatory compliance. In light of these
findings, EPA certifies that the final
regulation does not impose significant
impacts on a substantial number of
small business-owned facilities.
2. Analysis of Impacts on Other Small
Entities
In addition to considering the impact
of the final regulation on small
business-owned facilities, EPA also
considered the regulation's likely effects
on two other categories of small entities
that will be affected by the regulation:
(1) Publicly Owned Treatment Works
operated by small governments, which
may be responsible for implementing
the regulation at the local level; and (2)
small communities, which may contain
businesses that are adversely affected by
the regulation. EPA concluded that the
final regulation would not impose
significant impacts on either of these
additional small entity categories.
In the course of developing the final
regulation, EPA solicited comments on
regulatory implementation issues from
over 76 POTWs that had been identified
as receiving PFPR facility discharges.
Fifteen of these are POTWs are
considered small—that is, POTWs that
are located in smaller jurisdictions (less
than 50,000 population) or that are
small POTWs on the basis of daily
treatment volume (less than or equal to
1 million gallons per day). Comments
were requested on such matters as the
burden of implementing the pollution
prevention/treatment alternative
element of the regulation. Although
small entity POTWs were afforded the
opportunity to comment on the
implementation requirements of the
proposed regulation, none chose to do
so. However, in response to the request
for comment on the supplemental
notice, EPA received responses from
eight POTWs. Several of these
comments indicated that POTWs might
face modestly higher burdens from
administering a regulation with the
compliance flexibility offered by the P2
Alternative than from administering a
regulation strictly based on zero
discharge. However, none indicated that
such a regulation would be expected to
impose a significant additional burden
beyond the requirements that POTWs
already face in administering permits
and compliance programs for industrial
facilities. In addition, POTWs also
indicated that the modest additional
burden seemed reasonable given the
regulation's expected discharge
reductions and its innovative structure,
which gives facilities greater flexibility
in designing a compliance approach and
which encourages use of pollution
prevention as a compliance method. In
view of these responses and given the
fact that no small entity POTWs
responded to the request for comments,
EPA certifies that the regulation will not
impose a significant impact on a
substantial number of small entity
POTWs.
In addition to the analysis required by
the Regulatory Flexibility Act, EPA also
considered the regulation's effect on
small communities in which PFPR
facilities might be located. Specifically,
in the community impact analysis
performed for the proposed PFPR
regulation, EPA examined the impact of
possible employment losses, including
multiplier effects, in communities in
which PFPR facilities with moderate or
severe impacts were located. Using the
criterion that an estimated aggregate
employment loss exceeding one percent
of community employment is
significant, EPA found no significant
community employment impacts for the
proposed regulation as originally
analyzed. At the same time, the final
regulation is estimated to have
substantially fewer facility and
employment impacts than those
estimated for the original proposed
regulation. Given that no significant
community impacts were found among
any communities for the original
proposed regulation—regardless of
community size—Sand that the final
regulation's impacts are expected to be
substantially less than those of the
proposed regulation, the final regulation
will not impose a significant burden on
small communities.
VI. Unfunded Mandates Reform Act
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA), Pub. L.
104-4 establishes requirements for
Federal agencies to assess the effects of
their regulatory actions on State, local,
and tribal governments and the private
sector. Under Section 202 of the UMRA,
EPA generally must prepare a written
statement, including a cost-benefit
analysis, for proposed and final rules
with "Federal mandates" that may
result in expenditures to State, local,
and tribal governments, in the aggregate,
or to the private sector, of $100 million
or more in any one year. Before
promulgating an EPA rule for which a
written statement is needed, Section 205
of the UMRA generally requires EPA to
identify and consider a reasonable
number of regulatory alternatives and
adopt the least costly, most cost-
effective or least burdensome alternative
that achieves the objectives of the rule.
The provisions of Section 205 do not
apply when they are inconsistent with
applicable law. Moreover, Section 205
allows EPA to adopt an alternative other
than the least costly, most cost-effective
or least burdensome alternative if the
Administrator publishes with the final
rule an explanation why that alternative
was not adopted. Before EPA establishes
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57540 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
any regulatory requirements that may
significantly or uniquely affect small
governments, including tribal
governments, it must have developed
under Section 203 of the UMRA a small
government agency plan. The plan must
provide for notifying potentially
affected small governments, enabling
officials of affected small governments
to have meaningful and timely input in
the development of EPA regulatory
proposals with significant Federal
intergovernmental mandates, and
informing, educating, and advising
small governments on compliance with
the regulatory requirements.
EPA has determined that this rule
does not contain a Federal mandate that
may result in expenditures of $100
million or more for State, local, and
tribal governments, in the aggregate, or
the private sector in any one year. Thus,
today's rule is not subject to the
requirements of Sections 202 and 205 of
the UMRA.
Although not subject to the UMRA
because the cost of the rule to all parties
that would be effected is well below
$100 million, EPA has complied with
numerous provisions of the UMRA.
Today's rule is the least costly, least
burdensome alternative that was
considered.
Consistent with the intergovernmental
consultation provisions, EPA has
already initiated consultations with the
Publicly Owned Treatment Works
(POTWs) that will be affected by the
rule and sought their input as part of the
regulation development process.
Specifically, after publication of the
Supplemental Notice (60 FR 30217),
EPA solicited comments from over 70
POTWs that had been identified as
receiving discharges from PFPR
facilities. This request sought input on
several aspects of the PSES regulation,
including allowance of self-certification
of compliance by PFPR facilities, use of
Best Professional Judgment to revise or
modify the pollution prevention
practices listed in the Supplemental
Notice, and the burden on POTWs from
administering the pollution prevention
compliance alternative as part of the
regulation proposed in the
Supplemental Notice.
In response to this request, EPA
received comments from eight POTWs.
Four of these included comment on the
expected burden to POTWs from
administering the pollution prevention
and treatment compliance alternative.
The general thrust of these comments is
that administering the pollution
prevention/treatment alternative will
impose somewhat higher burdens on
POTWs than administering a regulation
requiring compliance strictly by zero
discharge. POTWs stated that inspection
requirements for verification of
compliance will be more difficult and
time-consuming because inspectors will
have to review technical plans,
equipment, and processes to verify that
the specified pollution prevention and
treatment measures have been properly
implemented, maintained, and operated
by PFPR facilities. In contrast,
verification of compliance with a zero
discharge regulation would be more
straightforward. POTWs also stated that
the option of relying on Best
Engineering Judgment to alter
requirements on facilities would
increase, rather than reduce,
implementation burdens. However, at
the same time, POTWs also noted that
the burden of administering the PFPR
regulation did not seem unreasonable in
comparison to requirements for other
regulations and that the regulation's
implementation requirements are
necessary if the regulation is to be
effective.
In keeping with the provisions to
inform, educate, and advise small
governments, EPA will publish a
Guidance Manual prior to the
compliance deadline of the rule to
inform, educate, and advise interested
facilities, permit writers, and POTWs on
pollution prevention processes and
procedures applicable to the PFPR
industry. It will also serve as guidance
for the implementation of and
compliance with the P2 Alternative
requirements.
VII. Executive Order 12866
Under Executive Order 12866, (58 FR
51735 (October 4, 1993)) the Agency
must determine whether the regulatory
action is "significant" and therefore
subject to OMB review and the
requirements of the Executive Order.
The Order defines "significant
regulatory action" as one that is likely
to result in a regulation that may:
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
State, local, or tribal governments or
communities;
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another agency;
(3) Materially alter the budgetary
impact of entitlements, grants, user fees,
or loan programs or the rights and
obligations of recipients thereof; or
(4) Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in the Executive Order.
Pursuant to the terms of Executive
Order 12866, it has been determined
that this rule is a "significant regulatory
action." As such, this action was
submitted to OMB for review. Changes
made in response to OMB suggestions or
recommendations will be documented
in the public record for this rulemaking.
VIII. Small Business Regulatory
Enforcement Fairness Act of 1996
(SBREFA)
Under 5 U.S.C. 801(a)(l)(A) as added
by the Small Business Regulatory
Enforcement Fairness Act of 1996, EPA
submitted a report containing this rule
and other required information to the
U.S. Senate, the U.S. House of
Representatives and the Comptroller
General of the General Accounting
Office prior to publication of the rule in
today's Federal Register. This rule is
not a "major rule" as defined by 5
U.S.C. 804(2).
IX. Paperwork Reduction Act
The information collection
requirements in this rule have been
submitted for approval to the Office of
Management and Budget (OMB) under
the Paperwork Reduction Act, 44, U.S.C.
3501 et seq. Two separate Information
Collection Request 0CR) documents
have been prepared by EPA. Burden
estimates for PFPR direct dischargers to
comply with their NPDES permits and
the P2 Alternative are contained in the
"National Pollutant Discharge
Elimination System (NPDES)/
Compliance Assessment/Certification
Information" ICR (No.1427.05). Burden
estimates for indirect discharging PFPR
facilities to comply with 40 CFR part
403 and the P2 Alternative are included
in the "National Pretreatment Program
(40 CFR part 403)" ICR (No. 0002.08).
The approval of these ICRs is still
pending; therefore, the information
requirements contained in this rule are
not effective until OMB approves them.
A copy of these ICRs may be obtained
from Sandy Farmer, OPPE Regulatory
Information Division; U.S.
Environmental Protection Agency
(2136), 401 M St., NW., Washington, DC
20460, by calling (202) 260-2740, or
electronically by sending an e-mail
message to
"farmer.sandy@epamail.epa.gov".
Burden means the total time, effort, or
financial resources expended by persons
to generate, maintain, retain, or disclose
or provide information to or for a
Federal agency. This includes the time
needed to review instructions; develop,
acquire, install, and utilize technology
and systems for the purposes of
collecting, validating, and verifying
information, processing and
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57541
maintaining information, and disclosing
and providing information; adjust the
existing ways to comply with any
previously applicable instructions and
requirements; train personnel to be able
to respond to a collection of
information; search data sources;
complete and review the collection of
information; and transmit or otherwise
disclose the information.
EPA estimates that each water using
facility is expected to spend an average
of 20 to 60 hours preparing the initial
certification statement (including brief
descriptions) for submittal to the
permitting/control authority as well as
preparing the paperwork to be kept on-
site (i.e., treatment information,
supporting documentation for
modifications, etc. . .). EPA has
estimated less hours for direct
dischargers than for the indirect
dischargers (i.e., 20 hours versus 60
hours) because the direct dischargers are
typically also pesticide manufacturers
with treatment systems in place that are
well documented while most indirect
dischargers do not have treatment in
place and have less technical expertise
in the area of wastewater treatment.
However, some indirect dischargers will
use less than the 60 hours because they
are also pesticide manufacturers or they
may be able to reuse all of their
wastewater that would otherwise have
to be pretreated prior to discharge to the
POTW (i.e., interior wastewater sources,
floor wash and/or leak and spill cleanup
water).
Note: Although most indirect dischargers
will not implement the P2 Alternative prior
to the compliance deadline (3 years following
promulgation) and; therefore would not be
covered by the Pretreatment ICR (No.
0002.08) which expires in three years, EPA
has estimated that approximately ten percent
of the 1500 water-using PFPR facilities/new
facilities (i.e., 150 facilities) would
implement the P2 Alternative prior to the
compliance deadline. Therefore, the burden
presented in the Pretreatment ICR concerning
the P2 Alternative is estimated for 150
facilities over the 3 years of the ICR. EPA will
include burden for the remainder of the
water using PFPR facilities in the subsequent
Pretreatment ICR in 1999.
Beyond the initial submittal, a PFPR
facility is expected to spend 15 minutes
to prepare and sign the periodic
certification statement to be submitted
to the permitting authority once per year
and to the control authority twice per
year. If a facility has made changes in
the P2 practices they are using or in the
choice of zero discharge or P2
Alternative for a process line/product
family that was initially specified in the
initial certification (or previous period),
they must provide a brief description
with their periodic certification
statement. EPA assumes that ten percent
of facilities will have to prepare such a
description each year and that the
associated burden/facility is four hours
for direct dischargers and 10 hours for
indirect dischargers. EPA has also
included four hours per facility for
direct dischargers and 10 hours for
indirect dischargers for the burden
associated with a request for approval of
modifications where the justification is
not listed on Table 8 to part 455 of the
final regulation. Again, EPA has used
the assumption that ten percent of
facilities per year will have to prepare
such a request for modification.
An Agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a currently valid OMB
control number. The OMB control
numbers for EPA's regulations are listed
in 40 CFR part 9 and 48 CFR Chapter
15.
Send comments on the burden
estimates and any suggested methods
for minimizing respondent burden,
including through the use of automated
collection techniques to EPA at the
address provided above, with a copy to
the Office of Information and Regulatory
Affairs, Office of Management and
Budget, 725 17th St., NW., Washington,
DC 20503, marked "Attention: Desk
Officer for EPA." Please remember to
include the ICR number in any
correspondence.
X. Water Quality Analysis
Most of the PAIs being regulated have
at least one toxic effect (e.g., human
health carcinogen and/or systemic
toxicant or aquatic toxicant). Many of
these pollutants have the potential to
bioaccumulate and persist in the
environment. Various studies have
demonstrated the bioaccumulation of
pesticides in aquatic life and
accumulation of pesticides in
sediments. Documented human health
impacts at pesticide formulating,
packaging, and repackaging (PFPR)
facilities include respiratory disease and
impaired liver function, primarily
through worker exposure.
For example, 137 of the original 272
PAIs are known to be highly or
moderately toxic to aquatic life, 25 have
carcinogenic effects, 149 are known to
have systemic or other health effects, 24
have an established concentration limit
under the Safe Drinking Water Act and
134 have a high or moderate potential
to bioaccumulate in the environment.
(See the "Potential Fate and Toxicity
Categorization of Pollutants Associated
with PFPR Wastewater" Report;
September 1996 in the rule making
record).
Numerous incidents of groundwater
and soil contamination at refilling
establishments, largely due to spills, are
identified in the Office of Pesticide
Programs proposed "Standards for
Pesticide Containers and Containment"
(59 FR 6712, February 11, 1994). Several
examples cited in the Standards for
Pesticide Containers and Containment
proposed rule are summarized below.
Based on the 1991 study, "Report on
Wisconsin Pesticide Mixing and
Loading Site Study," an estimated 45 to
75 percent of the commercial
agrichemical facilities in Wisconsin will
require soil remediation and 29 to 63
percent of these sites potentially exceed
the State's groundwater standards for
pesticides. In the "Environmental
Cleanup of Fertilizer and Agricultural
Chemical Dealer Sites" report, the Iowa
Fertilizer and Chemical Association
estimates that 40 to 50 percent of
refilling establishments in Iowa may
require groundwater remediation. A
1992 letter from the National
Agricultural Retailers Association
(formerly NARA, now ARA) stated that
70 to 80 percent of the detections of
pesticides in groundwater in Kansas
could be traced back to refilling
establishments. Groundwater
contamination by pesticides is also
documented at numerous refilling
establishments in Michigan, Minnesota,
Illinois, and Utah.
The water quality benefits of
controlling the indirect discharges from
PFPR facilities are evaluated by
modeling the impact of those discharges
on receiving streams. This model
assumes that no additional removal
occurs at the POTW. EPA believes this
to be a valid assumption because the
PAIs that are still covered by the scope
of the final pretreatment standards
(PSES) are expected to pass-through
POTWs. The effects of POTW
wastewater discharges of 139 PAIs are
evaluated at current and post-
compliance (e.g., zero/P2 Alternative)
levels for 85 indirect discharging PFPR
facilities which discharge to 79 POTWs
on 77 receiving streams. Water quality
models are used to project pollutant
instream concentrations based on
estimated releases at current and zero/
P2 Alternative levels; the instream
concentrations are then compared to
EPA published water quality criteria or
to documented toxic effect levels.
The instream pollutant concentration
for one PAI is projected to exceed
human health criteria in two receiving
streams at current discharge levels. Both
excursions are projected to be
eliminated under the zero/P2
Alternative. The number of pollutants
with receiving streams projected to
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57542 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
exceed aquatic life criteria or aquatic
toxic effect levels would be reduced
from 21 PAIs in 23 streams at current
discharge levels to four PAIs in six
streams at zero/P2 Alternative levels.
The potential impacts of these
indirect discharging PFPR facilities are
also evaluated in terms of inhibition of
POTW operation and contamination of
sludge. Potential biological inhibition
problems are projected to occur for
current discharges at four POTWs for
three PAIs; sludge criteria are
unavailable for PAIs. No potential
biological inhibition problems are
projected to occur for the Zero/P2
Alternative option. The POTW
inhibition values used in this analysis
are not, in general, regulatory values.
They are based upon engineering and
health estimates contained in guidance
or guidelines published by EPA and
other sources. Thus, EPA is not basing
its regulatory approach for pretreatment
discharge levels upon the finding that
some pollutants interfere with POTWs
by impairing their treatment
effectiveness. However, the values used
in the analysis do help indicate the
potential benefits for POTW operation
that may result from the compliance
with the final regulation.
In addition, the water quality benefits
of controlling the direct discharges from
PFPR facilities were evaluated by
modeling the impact of direct
wastewater discharges on receiving
stream water quality. However, as
described in Section IV.C.I of today's
notice, EPA's estimates of costs and
current pollutant loadings for direct
discharges did not include pollutant
removals for treatment already in place
(i.e., pesticide manufacturing treatment
systems). Therefore, an estimate of the
water quality impacts resulting from
current direct discharges would result
in an overestimation of the current
water quality impacts because these
facilities do have treatment in place and
are already meeting zero discharge or
zero allowance (i.e., no additional
discharge allowance in the pesticide
manufacturers' limitations for PFPR
wastewaters). Thus, EPA is presenting
only those water quality impacts
associated with the final rule.
Seventeen (17) direct discharging
PFPR facilities, which discharge 61 PAIs
to 16 receiving streams, were evaluated.
Water quality models are used to project
pollutant instream concentrations based
on estimated releases at post-
compliance (e.g., zero/P2 Alternative)
levels; the instream concentrations are
then compared to EPA published water
quality criteria or to documented toxic
effect levels where EPA water quality
criteria are not available for certain
PAIs. The zero/P2 Alternative option is
projected to result in aquatic life
exceedances of three PAIs in two
receiving streams. No exceedances of
human health criteria are projected to
occur for the zero/P2 Alternative option.
XI. Non-Water Quality Environmental
Impacts
The elimination or reduction of one
form of pollution may create or
aggravate other environmental
problems. Therefore, Sections 304(b)
and 306 of the Act call for EPA to
consider the non-water quality
environmental impacts of effluent
limitations guidelines and standards.
Accordingly, EPA has considered the
effect of these regulations on air
pollution, solid waste generation, and
energy consumption. As discussed
throughout today's notice, EPA selected
to promulgate the Zero/P2 Alternative
option due to the cross-media impacts
that could occur under a zero discharge
regulation due to contract hauling to off-
site incineration of potentially large
volumes of non-reusable wastewaters.
EPA has estimated the non-water
quality impacts associated with the
selected option, i.e., the Zero/P2
Alternative, as well as a zero discharge
option. As discussed previously in this
notice, under the Zero/P2 Alternative,
facilities will be able to choose between
complying with zero discharge or the P2
Alternative on a line-by-line basis.
However, for the purposes of estimating
compliance costs and non-water quality
impacts, EPA has assumed that a facility
will choose between these compliance
options on a whole-facility basis.
Therefore, the non-water quality
estimates for the Zero/P2 Alternative
represent those cross-media impacts
associated with a percentage of the
facilities choosing to comply with the
P2 Alternative and others choosing to
comply with zero discharge.
EPA has used the assumption that,
under the zero discharge option,
facilities would recycle and reuse some
wastewaters while hauling the
remaining wastewaters off-site for
incineration. Under the P2 Alternative
portion of the Zero/P2 Alternative, some
facilities may be able to avoid the need
for wastewater treatment by
comprehensively applying source
reduction practices to all their
wastewater sources; however, it is more
likely that, following the use of recycle
and reuse practices, facilities will need
to employ some pollution control
treatment technologies prior to
discharging their wastewaters.
There are some cross-media impacts
that are associated with the Zero/P2
Alternative and its use of a wastewater
treatment system that are not associated
with a zero discharge option since
treatment is not utilized under the zero
discharge option. These cross-media
impacts include sludge generation and
energy consumption and air emissions
of criteria air pollutants 24 from the
trucks that transport spent activated
carbon for regeneration. However, the
zero discharge option relies heavily on
the contract hauling of wastewater for
incineration which significantly
increases the cross-media impacts due
to air emissions of criteria air pollutants
from the trucks that transport the
wastewater to incineration and from the
incineration of the wastewater itself.
EPA believes that selecting the Zero/
P2 Alternative option will minimize
these cross-media impacts, overall, as
compared to the zero discharge option.
In particular, the Zero/P2 Alternative
has a significantly lower cross-media
impact on air emissions of criteria air
pollutants than the zero discharge
option while still preventing the
discharge of 98.5 percent of the
pesticide active ingredients (PAIs) from
being discharged to the water. The
following sections present the estimates
for air emissions, solid waste generation
and energy consumption for the final
rule.
A. Air Pollution
For the purpose of preparing a cross-
media impact analysis, the air pollution
effects are divided into two separate
types of air emissions generated as a
result of the final rule. First, there are
air emissions estimated for the Zero/P2
Alternative based on the treatment of
wastewater through a treatment system,
such as the Universal Treatment
System, discussed in Section II.E. of
today's preamble. These emissions
consist mainly of volatile priority
pollutants. EPA does not anticipate that
there will be any significant losses of
PAIs into the atmosphere under the
Zero/P2 alternative, because most PAIs
have low volatility. The second type of
air emissions are those generated from
the transport (i.e., air emissions from the
trucks' exhaust and gasoline) of both
wastewater and spent activated carbon
as well as emissions from the
incineration of wastewater that is
hauled off-site for disposal. Estimates of
both types of air emissions are
presented on Table 4 of today's
preamble for the Zero/P2 Alternative
and for zero discharge. As seen on Table
24 Criteria air pollutants include: Volatile organic
compounds (VOCs), nitrogen oxides (NOx), sulfur
dioxide (SO2), particulate matter (PM) and carbon
monoxide (CO). Criteria air pollutants can injure
health, harm the environment and cause property
damage.
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57543
4, the emissions for criteria air
pollutants from the transport of
wastewaters and spent activated carbon
and from the incineration of the non-
reusable wastewaters under the zero
discharge option would create a
significant cross-media impact as
compared to the Zero/P2 Alternative.
TABLE 4: CRITERIA AIR POLLUTANT EMISSIONS (LB/YR)
Emission source
Wastewater Transportation:
Zero/P2 Alternative
Zero Discharge
Wastewater Incineration:
Zero/P2 Alternative
Zero Discharge
Spent Activated Carbon Transportation:
Zero/P2 Alternative
Zero Discharge!
Wastewater Treatment:!
Zero/P2 Alternative
Zero Discharae
VOCs
14720
87,600
5
264
1,692
NA
84,700
52.500
NOX
121 200
720,000
1 838
94600
13,920
NA
NA
NA
PM
6800
40,400
10
530
780
NA
NA
NA
CO
1 75 400
1 ,044,000
133
6880
20,200
NA
NA
NA
SO2
2
106
NA
NA
NA=not applicable
a: EPA estimates that under the Zero/P2 Alternative 69% of facilities incurring costs will choose the P2 Alternative and 31 % will choose to
comply with zero discharge.
t There is no wastewater treatment system used under the zero discharge option and, therefore, no spent activated carbon to transport for re-
generation.
{Air emissions estimates from wastewater treatment include only volatile priority pollutants.
EPA also estimates the reduction of
volatile priority pollutants emissions
that would occur under the Zero/P2
Alternative and under zero discharge.
EPA estimates that in addition to the
192,789 Ibs of PAIs that are currently
(i.e., prior to today's regulation) being
discharged to water, 381,000 pounds of
volatile priority pollutant are currently
emitted when wastewater is discharged
to POTWs or are emitted to the air from
the wastewater treatment process at the
POTWs. EPA estimates that under the
Zero/P2 Alternative, the air emissions
from wastewater reuse, treatment and
discharge to POTWs will be reduced to
84,700 pounds of volatile priority
pollutants. This means that
implementing the Zero/P2 Alternative
will reduce air emissions of volatile
priority pollutants from wastewater
reuse, treatment and discharge by
296,300 pounds annually. In addition,
the remaining emissions are localized
and in many cases may be more likely
to be captured and treated by the UTS.
The loss of priority pollutants to the
atmosphere is likely to occur during
reuse of wastewater and particularly
from the emulsion breaking, hydrolysis,
and/or chemical oxidation treatment
steps where the addition of heat is likely
to promote their release25. It is also
25 EPA believes that use of closed vessels in the
treatment system will additionally control the
release of volatile priority pollutants to the air and,
therefore; has used the costs associated with closed
vessels when estimating costs for the regulation.
However, for the analysis of the air pollution
emissions estimates for this rule, estimates on
volatile priority pollutant emissions from closed
vessels were not available. Therefore, the volatile
priority pollutant emissions estimate assumes the
possible that some emissions of priority
pollutants could occur during the
cleaning of equipment or containers,
particularly if high-pressure cleaning or
steam cleaning is used. Under the zero
discharge option, 52,500 pounds of
volatile priority pollutants are expected
to be emitted during the recycle and
reuse of wastewaters.
B. Solid Waste
EPA estimates that under the Zero/P2
Alternative there will be 856,000
pounds of sludge generated from
emulsion breaking and sulfide
precipitation treatment annually. EPA
has assumed that the sludge generated
via emulsion breaking and sulfide
precipitation will be hauled to
hazardous waste incinerators. In
addition to the sludge generated,
treatment of wastewater through the
Universal Treatment System will
generate 3,830,000 pounds annually of
spent activated carbon. It is assumed
that the activated carbon will be sent
off-site for regeneration, which means
that it is reused and would not become
a waste. See Section XI. A. for the
estimate of air emissions from
transporting the spent activated carbon
for regeneration and from the hauling of
wastewater/sludge to incineration as
well as the air emissions associated with
incineration.
EPA believes the Zero/P2 Alternative
is consistent with the goals established
for EPA's Hazardous Waste
Minimization and Combustion Strategy
(November, 1994). This draft
use of open vessels during treatment which may
overestimate the emissions.
combustion strategy establishes the goal
of a strong preference for source
reduction over waste management,
thereby reducing the long-term demand
for combustion and other waste
management facilities. In addition, the
strategy states that combustion does
have an appropriate role and that EPA
wants to ensure that combustion
facilities (such as incinerators and
boilers and industrial furnaces (BIFs))
are designed in a manner to protect
public health.
C. Energy Requirements
EPA estimates that compliance with
the final regulation will increase energy
consumption by a small increment over
present industry use. The main energy
requirement is the generation of steam
that is used in the wastewater treatment
system to accomplish emulsion breaking
and hydrolysis. Steam provides the heat
energy to assist with the separation of
emulsified phases and increases the rate
at which active ingredients hydrolyze. It
is estimated that about 6.28 x 107
pounds per year of steam would be
required by the Universal Treatment
System. This would require
approximately 13,581 barrels of oil
annually. This is, relatively, very small
compared to the 18 million barrels per
day that the United States currently
consumes.
Additionally, EPA estimates that the
operation of the Universal Treatment
System will consume 811,000 kilowatt
hours per year. This is expended by the
pumps and agitators used in treatment
and associated with the storage of water
until it can be reused.
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57544 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
XII. Regulatory Implementation
The purpose of this section is to
provide assistance and direction to
permit writers and control authorities to
aid in their implementation of this
regulation and its unique compliance
alternative. This section also discusses
the relationship of upset and bypass
provisions, variances and modifications,
and analytical methods to the final
limitations and standards.
A. Implementation of the Limitations
and Standards
I. Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
Each PFPR facility subject to this
regulation will need to make an initial
choice on either a facility-wide basis or
on a process basis (i.e., product family/
process line/process unit). They will
need to choose to either comply with
the zero discharge effluent limitation/
pretreatment standard or choose to agree
to conduct the listed pollution
prevention practices (or a variation of
the listed practices based on self-
implemented modifications or those
agreed to by the permit/control
authority) and also agree to make the
practices and the pollution prevention
discharge allowance enforceable (see
§ 455.41 of the final rule for the
definition of P2 allowable discharge).
However, beyond this initial choice,
much of the continued implementation
of the Zero/P2 Alternative will differ for
direct and indirect dischargers.
Direct Dischargers
For direct dischargers, the Zero/P2
Alternative will be implemented
through the NPDES permitting process.
For each new or existing direct
discharging facility, the facility would
need to make the initial choice at the
permitting stage or at the time for permit
modification or renewal, respectively.
Facilities that do not choose the P2
Alternative (or zero discharge) for the
facility in its entirety will be required to
clearly state in their NPDES permit each
product family, process unit or process
line and the option selected for each.
For those processes for which a direct
discharge facility chooses the P2
Alternative over the zero discharge
limitation, the permitting authority
would include all of the P2 practices
and any specified treatment
technologies in the facility's NPDES
permit. The definition of P2 allowable
discharge for direct dischargers requires
the appropriate treatment of all process
wastewater prior to discharge.
Therefore, permit writers may want to
include in the permit the method
chosen by the facility to demonstrate
that the treatment system: (1) Is
appropriate for the PAIs in their process
wastewaters (that are not also being
manufactured); and (2) is properly
operated and maintained; or the permit
writer can set numerical limitations
based on BPJ for any additional PAIs, as
necessary.
Today's final regulations do not
require facilities to submit all of the
necessary compliance paperwork to the
NPDES permit writer, but instead
require the facility choosing the P2
Alternative to keep the paperwork on-
site and available for the permitting
authority and enforcement officials.
However, EPA is requiring the submittal
of an initial certification statement at
the time of issuance, renewal, or
modification of an NPDES permit for
direct dischargers. In addition, as
suggested by a commenter, EPA is also
requiring the submittal of a periodic
certification statement to be submitted
every year to the NPDES permit writer.
The pollution prevention practices and
treatment technologies included in such
a NPDES permit would be enforceable
under CWA sections 309 and 505.
For those processes where a new or
existing direct discharge PFPR/
Manufacturer has chosen to comply
with zero discharge, the permit would
include: (1) The pesticide
manufacturing limitations (40 CFR part
455, subparts A and B) with no
additional allowance for the PFPR
wastewaters for those PAIs that are also
manufactured; and (2) limitations set
equal to the detection limit of the PAIs
expected to be in the wastewater (or no
PFPR process wastewater flow) for PAIs
that are not also manufactured at the
facility. The NPDES permits for new or
existing stand-alone direct discharging
facilities that choose to achieve zero
discharge from specified processes will
include either limitations set equal to
the detection limit of the analytical
method for the PAIs expected to be in
the wastewater or will allow no process
wastewater flow.
Indirect Dischargers
Existing and new PFPR facilities
(including PFPR/Manufacturers) which
are indirect dischargers would also need
to make an initial choice on a process
basis of meeting the zero discharge
pretreatment standard or adopting and
implementing the P2 practices and the
treatment technologies (if so specified).
Facilities that choose the zero discharge
option for specified processes (or for the
entire facility) would agree in their
control mechanism or pretreatment
agreement to demonstrate zero
discharge through no process
wastewater flow or compliance by
meeting a numerical standard be set
equal to the detection limit of the
analytical method for the PAIs expected
in the wastewater.
If the indirect discharging PFPR
facility chooses the P2 Alternative for
any or all processes/lines/product
families, the facility would need to
notify the Control Authority of its
intention by submitting an initial
certification statement as described in
§ 455.41 (a) of the final regulation.
Facilities that do not choose the P2
Alternative for the facility in its entirety
will be required to include a brief
description of each product family,
process unit or process line and the
option selected for each with the initial
certification statement. In addition, the
facility must include all of the P2
practices (or modifications) and any
specified treatment technologies that
will be implemented to meet the
requirements of the practices listed in
Table 8 to part 455 for those processes
which the P2 Alternative was chosen.
For indirect dischargers appropriate
pretreatment is required for any interior
equipment cleaning wastewater
(including drums), floor wash 26 or leak/
spill cleanup water that is part of the P2
allowable discharge. Other wastewater
sources can be discharged to the POTW
without pretreatment. The initial
certification statement to be submitted
requires a signature by the appropriate
manager in charge of overall operations
of the facility to assure that information
provided is true, accurate, and complete
to the best of his or her knowledge.
Other required paperwork can be kept
on-site (e.g., supporting documentation
for any modifications, treatment
technologies used that are not listed on
Table 10 to part 455 of the regulation,
the method chosen and supporting
documentation for demonstrating that
appropriate treatment is well operated
and maintained and the rationale for
choosing the method of demonstration).
Any modifications for a reason not
listed on Table 8 to part 455 of the
regulation must be submitted to the
control authority for approval.
Once an individual control
mechanism (or pretreatment agreement)
is in place, facilities need to submit a
26 In individual cases the requirement of
wastewater pretreatment prior to discharge to the
POTW may be removed by the control authority for
floor wash or the final rinse of a non-reusable triple
rinse when the facility has demonstrated that the
levels of PAIs and priority pollutants in such
wastewaters are at a level that is too low to be
effectively pretreated at the facility and have been
shown to neither pass through or interfere with the
operations of the POTW. The control authority
should also take into account whether or not the
facility has employed water conservation when
generating such a non-reusable wastewater.
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57545
periodic certification statement to the
control authority indicating that the P2
Alternative is being implemented as in
the previous period or that a
modification to the individual control
mechanism is needed. The certification
statement is to be submitted to the
control authority on the same time table,
i.e., twice per year Qune and December),
as the reporting required by 40 CFR
403.12(e). The control authority, as part
of its approved pretreatment program,
must have the authority to ensure
compliance with a pretreatment
standard (40 CFR 403.8(f)(l)(ii)) and to
carry out inspections of the indirect
dischargers' self-certifications and of the
paperwork described below. 40 CFR
403.8(1) (l)(v).
Necessary Paperwork for the P2
Alternative
As briefly mentioned above, both
direct and indirect discharging facilities
are required to keep certain paperwork
on-site and available for permitting/
control authorities and enforcement
officials.
Note: Although EPA is not requiring
submittal of all the paperwork for approval
in these national regulations, NPDES
programs and control authorities may choose
to require submittal of any of the paperwork
for approval.
The paperwork which is required to
be submitted includes the one-time
initial certification statement (see
§ 455.41 (a) of the final rule) and the
periodic certification statements (see
§455.41(b) of the final rule). The
paperwork which can be kept on-site is
referred to in this final rule as the "On-
site Compliance Paperwork" (see
§455.41 (c)). Each of these is described
below.
For each PFPR facility, the initial
certification statement would include, at
a minimum, a listing of and descriptions
of the processes (i.e., product families/
process lines/process units) for which it
chooses the P2 Alternative and those for
which it chooses to achieve zero
discharge; descriptions of the P2
practices (from Table 8 to part 455 of the
regulation) that are being employed and
how they are being implemented;
description of any justifications
allowing modification to the practices
listed on Table 8 to part 455; and a
description of the treatment system
being used to obtain a P2 allowable
discharge (as defined in §455.41). The
initial certification statement must be
signed by the responsible corporate
officer as defined in 40 CFR 403.12(1) or
40 CFR 122.22.
The periodic certification statement is
to be submitted twice per year for
indirect discharging facilities and once
per year for direct discharging facilities
and should indicate whether the P2
Alternative is being implemented as set
forth in the NPDES permit/control
mechanism or that a justification
allowing modification of the listed
practices has been implemented
resulting in a change in the P2 practices
conducted at the facility. If the
modification needed is not listed on
Table 8 of part 455, the facility should
request a modification from their
permitting/control authority if it has not
already done so.
The on-site compliance paperwork
should include the information from the
initial and periodic certifications but
must also include: (1) The supporting
documentation for any modifications
that have been made to the listed P2
practices (including records that
indicate/demonstrate, for example,
microbial growth, specific directions for
other disposal from the manufacturer,
use of a solvent recovery system, etc.);
(2) a written discussion demonstrating
that the treatment system being used
contains the appropriate treatment
technologies (i.e., listed by PAI in the
Table 10 to Part 455 of the final
regulation, equivalent system as defined
in §455.10(h), or pesticide
manufacturing system) for removing
PAIs that are used in production at their
facility and could be in their
wastewater; (3) a method for
demonstrating that the treatment system
is well operated and maintained; and (4)
a discussion of the rationale for
choosing the method of demonstration.
For example, a facility may utilize a
surrogate method for determining
breakthrough of their carbon adsorption
unit. This method could be used instead
of performing analytical testing for all or
any of the PAIs that may have been in
production at the facility over a specific
period of time. The facility could
possibly use records of carbon change
out/purchase to demonstrate that the
system is properly operated and
maintained and could describe the
initial testing and/or vendor information
used to determine the useful life of the
activated carbon.
Control authorities, at or any time
after entering into an individual control
mechanism, or permitting authorities, at
or any time after issuing, reissuing, or
modifying the NPDES permit, could
inspect the PFPR facility to see that the
listed practices are being employed, that
the treatment system is well operated
and maintained and that the necessary
paperwork provides sufficient
justification for any modifications.
When facilities need to modify a listed
P2 practice for which a justification is
not listed in the final regulation, the
facility must make a request for the
modification from the NPDES
permitting authority or the control
authority. The permit writer/control
authority is expected to use BPJ/BEJ to
approve the modification.
Note: EPA is preparing a guidance manual
to aid permit writers/control authorities as
well as PFPR facilities.
Compliance Dates
EPA has established a three-year
deadline for compliance with the PFPR
pretreatment standards for existing
sources (PSES). Under the zero/P2
alternative facilities will need time to
assess which process lines are amenable
to the P2 alternative and which lines
will have to comply with zero
discharge. This decision will most likely
be based on economics as well as the
characteristics of the individual process
line. In addition, facilities will have to
determine the treatment necessary for
the PAIs expected to be found in the
wastewater at their facility and they will
need time to design and install these
systems. Finally, facilities will need
time to prepare the on-site compliance
paperwork necessary to support the P2
alternative. Thus, EPA believes that a
full three-year compliance period is
appropriate.
Existing direct dischargers must
comply by the date of issue, reissue or
modification of the NPDES permit. New
source standards and limitations (PSNS
and NSPS) must be complied with when
a facility commences the discharging of
wastewater.
Note: For this rule, a direct discharge
facility is considered a new source if its
construction commenced following
promulgation of the final rule (40 CFR 122.2);
while an indirect discharge facility is
considered a new source if construction
commenced after proposal (April 1994) of the
pretreatment standards (40 CFR 403.3).
Direct dischargers may be subject to
the establishment, by the permitting
authority, of more stringent effluent
limitations based on applicable water
quality standards. See 40 CFR 122.44. In
addition, those PFPR facilities that are
indirect dischargers remain subject to
the Pass-Through and Interference
prohibitions contained in the general
pretreatment regulations. 40 CFR
403.5(a)(1). Indirect dischargers could
also be subject to local limits
established by the control authority
receiving the facility's wastewater. 40
CFR 403.5(c).
The Agency emphasizes that although
the Clean Water Act is a strict liability
statute, EPA can initiate enforcement
proceedings at its discretion. EPA has
exercised and intends to exercise that
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57546 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
discretion in a manner that recognizes
and promotes good faith compliance.
2. Refilling Establishments (Subcategory
E)
The limitations and standards for
existing and new refilling
establishments are set as zero discharge.
In addition, many states (with national
regulations soon to follow) require these
facilities to have secondary containment
systems and loading pads for their bulk
pesticide and pesticide dispensing
operations. Under these state and
eventual national secondary
containment regulations under FIFRA,
facilities are collecting process
wastewaters that were formerly
contaminating soil and groundwater.
Since the majority of these facilities
are not located in an area where direct
or indirect discharge is feasible, EPA
believes that the zero discharge can be
implemented as seen on site visits.
Typically, these facilities collect their
process wastewaters (including interior
equipment cleaning of minibulks, bulk
tanks and related ancillary equipment
and leak/spill cleanup water) and store
these collected rinsates for reuse. The
stored rinsates are then used as product
make-up water in future custom
application activities. Facilities that do
not operate their own custom
application services or that are located
in states where the purchase of make-up
water for reuse in applications is
prohibited have been known to give
away these rinsates to custom
applicators or directly to farmers. A
small number of facilities in such a
situation may choose some means of off-
site disposal, such as contract hauling to
incineration.
B. Upset and Bypass Provisions
A recurring issue is whether industry
limitations and standards should
include provisions authorizing
noncompliance with effluent limitations
during periods of "upset" or "bypass".
An upset, sometimes called an
"excursion," is an unintentional and
temporary noncompliance with
technology-based effluent limitations
occurring for reasons beyond the
reasonable control of the permittee. EPA
believes that upset provisions are
necessary to recognize an affirmative
defense for an exceptional incident
including "Acts of God". Because
technology-based limitations can
require only what properly designed,
maintained and operated technology
can achieve, it is claimed that liability
for such situations is improper.
While an upset is an unintentional
episode during which effluent
limitations are exceeded, a bypass is an
act of intentional noncompliance during
which wastewater treatment facilities
are circumvented in emergency
situations.
EPA has both upset and bypass
provisions in NPDES permits, and has
promulgated NPDES and pretreatment
regulations which include upset and
bypass permit provisions. (40 CFR
122.41(m), 122.41(n) and 40 CFR 403.16
and 403.17.) The upset provision
establishes an upset as an affirmative
defense to prosecution for violation of
technology-based effluent limitations.
The bypass provision authorizes
bypassing to prevent loss of life,
personal injury, or severe property
damage. Since there are already upset
and bypass provisions in NPDES
permits and pretreatment regulations,
EPA will let local permit and control
authorities deal with individual upsets
or requests for bypass.
C. Variances and Modifications
Upon the promulgation of these
regulations, the effluent limitations for
the appropriate subcategory must be
applied in all Federal and State NPDES
permits issued to direct dischargers in
the pesticide formulating, packaging or
repackaging industry. In addition, the
pretreatment standards are directly
applicable to indirect dischargers.
1. Fundamentally Different Factors
Variances
For the BPT effluent limitations, the
only exception to the binding
limitations is EPA's "fundamentally
different factors" ("FDF") variance (40
CFR part 125, subpart D). This variance
recognizes factors concerning a
particular discharger which are
fundamentally different from the factors
considered in this rulemaking. Although
this variance clause was set forth in
EPA's 1973-1976 effluent guidelines, it
is now included in the NPDES
regulations and not the specific industry
regulations. (See 44 FR 32854, 32893
[June 7, 1979] for an explanation of the
"fundamentally different factors"
variance). The procedures for
application for a BPT FDF variance are
set forth at 40 CFR 122.21(m)(l)(I)(A).
Dischargers subject to the BAT
limitations in these final regulations
may also apply for an FDF variance,
under the provisions of section 301(n) of
the Act, which regulates BAT, BCT, and
pretreatment FDFs. In addition, BAT
limitations for nonconventional
pollutants may be modified under
section 301(c) (for economic reasons)
and 301(g) (for water quality reasons) of
the Act. These latter two statutory
modifications are not applicable to
"toxic" or conventional pollutants.
Dischargers subject to pretreatment
standards for existing sources (PSES) are
also subject to the "fundamentally
different factors" variance provision (40
CFR 403.13) and credits for pollutants
removed by POTWs, as discussed in
Section XII.C.2. Dischargers subject to
pretreatment standards for new sources
(PSNS) are subject only to the removal
credit provision (see Section XII.C.2).
New sources subject to NSPS are not
eligible for EPA's "fundamentally
different factors" variance or any
statutory or regulatory variances. See
E.I. Du Pontv. Train, 430 U.S. 112
(1977).
2. Removal Credits
Congress, in enacting Section 307(b)
of the CWA, recognized that, in certain
instances, POTWs could provide some
or all of the treatment of an industrial
user's wastestream that would be
required pursuant to the pretreatment
standard. Consequently, Congress
established a discretionary program for
POTWs to grant "removal credits" to
their indirect dischargers. The credit, in
the form of a less stringent pretreatment
standard, allows an increased amount of
pollutants to flow from the indirect
discharger's facility to the POTW.
Section 307(b) of the CWA establishes
a three-part test for obtaining removal
credit authority for a given pollutant.
Removal credits may be authorized only
if (1) the POTW "removes27 all or any
part of such toxic pollutant," (2) the
POTWs ultimate discharge would "not
violate that effluent limitation, or
standard which would be applicable to
that toxic pollutant if it were
discharged" directly rather than through
a POTW and (3) the POTWs discharge
would "not prevent sludge use and
disposal by such [POTW] in accordance
with section [405] . . . ." Section
307(b).
EPA has promulgated removal credit
regulations in 40 CFR 403.7. The United
States Court of Appeals for the Third
Circuit has interpreted the statute to
require EPA to promulgate
comprehensive sewage sludge
regulations before any removal credits
could be authorized. NRDCv. EPA, 790
F.2d 289, 292 (3rd Cir. 1986) cert.
denied. 479 U.S. 1084 (1987). Congress
made this explicit in the Water Quality
Act of 1987 which provided that EPA
27In 40 CFR 403.7, removal is defined to mean
"a reduction in the amount of a pollutant in the
POTWs effluent or alteration of the nature of a
pollutant during treatment at the POTW. The
reduction or alteration can be obtained by physical,
chemical or biological means and may be the result
of specifically designed POTW capabilities or may
be incidental to the operation of the treatment
system. Removal as used (in §403.7) shall not mean
dilution of a pollutant in the POTW."
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57547
could not authorize any removal credits
until it issued the sewage sludge use
and disposal regulations required by
section 405 (d) (2) (a) (ii).
Section 405 of the CWA requires EPA
to promulgate regulations which
establish standards for sewage sludge
when used or disposed for various
purposes. These standards must include
sewage sludge management standards as
well as numerical limits for pollutants
which may be present in sewage sludge
in concentrations which may adversely
affect public health and the
environment. Section 405 requires EPA
to develop these standards in two
phases. On November 25, 1992, EPA
promulgated the Round One sewage
sludge regulations establishing
standards, including numerical
pollutant limits, for the use and disposal
of sewage sludge. 58 FR 9248. EPA
established pollutant limits for ten
metals when sewage sludge is applied to
land, for three metals when it is
disposed of at surface disposal sites and
for seven metals and total hydrocarbons,
a surrogate for organic pollutant
emissions, when sewage sludge is
incinerated. These requirements are
codified at 40 CFR part 503.
At the same time EPA promulgated
the Round One regulations, EPA also
amended its pretreatment regulations to
provide that removal credits would be
available for certain pollutants regulated
in the sewage sludge regulations. See 58
FR at 9386. The amendments to Part 403
provide that removal credits may be
made potentially available for the
following pollutants:
(1) If a POTW applies its sewage
sludge to the land for beneficial uses,
disposes of it on surface disposal sites
or incinerates it, removal credits may be
available, depending on which use or
disposal method is selected (so long as
the POTW complies with the
requirements in part 503). When sewage
sludge is applied to land, removal
credits may be available for ten metals.
When sewage sludge is disposed of on
a surface disposal site, removal credits
may be available for three metals. When
the sewage sludge is incinerated,
removal credits may be available for
seven metals and for 57 organic
pollutants. See 40 CFR
403.7(a)(3)(iv)(A).
(2) In addition, when sewage sludge is
used on land or disposed of on a surface
disposal site or incinerated, removal
credits may also be available for
additional pollutants so long as the
concentration of the pollutant in sludge
does not exceed a concentration level
established in part 403. When sewage
sludge is applied to land, removal
credits may be available for two
additional metals and 14 organic
pollutants. When the sewage sludge is
disposed of on a surface disposal site,
removal credits may be available for
seven additional metals and 13 organic
pollutants. When the sewage sludge is
incinerated, removal credits may be
available for three other metals. See 40
CFR403.7(a)(3)(iv)(B).
(3) When a POTW disposes of its
sewage sludge in a municipal solid
waste land fill that meets the criteria of
40 CFR part 258 (MSWLF), removal
credits may be available for any
pollutant in sewage sludge. See 40 CFR
403.7(a)(3)(iv)(C).
Thus, given compliance with the
requirements of EPA's removal credit
regulations,28 following promulgation of
the pretreatment standards being
proposed here, removal credits may be
authorized for any pollutant subject to
pretreatment standards if the applying
POTW disposes of its sewage sludge in
a MSWLF that meets the requirements
of 40 CFR part 258. If the POTW uses
or disposes of its sewage sludge by land
application, surface disposal or
incineration, removal credits may be
available for the following metal
pollutants (depending on the method of
use or disposal): Arsenic, cadmium,
chromium, copper, lead, mercury,
molybdenum, nickel, selenium and
zinc. Given compliance with § 403.7,
removal credits may be available for the
following organic pollutants (depending
on the method of use or disposal):
acrylonitrile, aldrin/dieldrin (total),
benzene, benzidine, benzo(a)pyrene,
bis(2-chloroethyl)ether, bis(2-
ethylhexyl) phthalate,
bromodichloromethane, bromoethane,
bromoform, carbon tetrachloride,
chlordane, chloroform, chloromethane,
DDD, DDE, DDT,
dibromochloromethane, dibutyl
phthalate, 1,2-dichloroethane, 1,1-
dichloroethylene, 2,4-dichlorophenol,
1,3-dichloropropene, diethyl phthalate,
2,4-dinitrophenol, 1,2-
diphenylhydrazine, di-n-butyl
phthalate, endosulfan, endrin,
ehtylbenzene, heptachlor, heptachlor
epoxide, hexachlorobutadiene,
alphahexachlorocyclohexane,
betahexachlorocyclohexane,
hexachlorocyclopentadiene,
hexachloroethane, hydrogen cyanide,
isophorone, lindane, methylene
chloride, nitrobenzene, n-
28 Under §403.7, a POTW is authorized to give
removal credits only under certain conditions.
These include applying for, and obtaining, approval
from the Regional Administrator (or Director of a
State NPDES program with an approved
pretreatment program), a showing of consistent
pollutant removal and an approved pretreatment
program. See 40 CFR 403.7(a)(3)(I), (ii), and (ill).
nitrosodimethylamine, n-nitrosodi-n-
propylamine, pentachlorophenol,
phenol, polychlorinated biphenyls,
2,3,7,8-tetrachlorodibenzo-p-dioxin,
1,1,2,2-tetrachloroethane,
tetrachloroethylene, toluene, toxaphene,
trichloroethylene, 1,2,4-
trichlorobenzene, 1,1,1-trichloroethane,
1,1,2-trichloroethane and 2,4,6-
trichlorophenol.
With regard to the use of removal
credit authority for any pollutant subject
to these pretreatment standards, a
POTW (once compliance with 40 CFR
403.7 is shown and removal credit
authority is granted) may be able to
effectively authorize the waiving of
what otherwise would be required
treatment of the PFPR wastewaters by
authorizing a removal credit to the PFPR
industrial user to the extent of any
pollutants remaining in its discharge
after all applicable pollution prevention
practices have been complied with.
However, removal credits could only be
granted to the extent that granting of
such credits would not result in pass
through or interference at the POTW as
defined in 40 CFR 403.3 and in
accordance with the provisions of
§ 403.5, and EPA would expect that the
PFPR industrial user would have to
continue to comply with the pollution
prevention practices as specified in the
P2 Alternative even if a removal credit
had been provided.
D. Analytical Methods
Section 304 (h) of the Act directs EPA
to promulgate guidelines establishing
test methods for the analysis of
pollutants. These methods are used to
determine the presence and
concentration of pollutants in
wastewater, and are used for
compliance monitoring and for filing
applications for the NPDES program
under 40 CFR 122.21, 122.41, 122.44
and 123.25, and for the implementation
of the pretreatment standards under 40
CFR 403.10 and 403.12. To date, EPA
has promulgated methods for
conventional pollutants, toxic
pollutants, and for some non-
conventional pollutants. The five
conventional pollutants are defined at
40 CFR 401.16. Table I-B at 40 CFR part
136 lists the analytical methods
approved for these pollutants. The 65
toxic metals and organic pollutants and
classes of pollutants are defined at 40
CFR 401.15. From the list of 65 classes
of toxic pollutants EPA identified a list
of 126 "Priority Pollutants." This list of
Priority Pollutants is shown, for
example, at 40 CFR part 423, appendix
A. The list includes non-pesticide
organic pollutants, metal pollutants,
cyanide, asbestos, and pesticide
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57548 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
pollutants. Currently approved methods
for metals and cyanide are included in
the table of approved inorganic test
procedures at 40 CFR 136.3, Table I-B.
Table I-C at 40 CFR 136.3 lists approved
methods for measurement of non-
pesticide organic pollutants, and Table
I-D lists approved methods for the toxic
pesticide pollutants and for other
pesticide pollutants.
EPA believes that the analytical
methods for pesticide active ingredients
contained in the promulgated pesticide
manufacturing effluent guidelines and
standards (see Methods for the
Determination of Nonconventional
Pesticides in Municipal and Industrial
Wastewater, Volumes I & II, EPA 821-
R-93-010-A&B, August 1993, Revision
1) will perform equally well on treated
pesticide formulating, packaging or
repackaging wastewaters as on pesticide
manufacturing wastewaters. Raw
wastewater samples may on occasion
require some separation prior to
analysis, analogous to the emulsion
breaking pretreatment included in
EPA's costed BAT technology. Many of
these methods have in fact been used on
the PFPR sampled wastewaters. All of
the active ingredient pollutant data that
supports the proposed effluent
limitations were generated using
analytical methods that employ the
approved methods or are based upon
the approved methods at 40 CFR part
136 or contained in Methods for the
Determination of Nonconventional
Pesticides in Municipal and Industrial
Wastewater. For PAFs that have no
EPA-approved analytical methods,
PFPR facilities may utilize alternative
sampling and analysis methods as
specified in 40 CFR 136.4 and
403.12(g)(4). At some future date, EPA
may transfer the analytical methods
promulgated at part 455 to part 136 as
a part of EPA's effort to consolidate
analytical methods and streamline
promulgation of new methods. As
discussed in Section XII.A.I, EPA
believes that those facilities choosing
zero discharge will either demonstrate
zero discharge through no process
wastewater flow or will demonstrate
compliance using the analytical
methods to show PAIs levels are at or
below detection (or meeting pesticide
manufacturing limitations with no
allowance given to PFPR wastewater).
Facilities choosing to demonstrate that
they are in compliance with the P2
Alternative will use submittal of
certification statements, inspections,
and demonstrated implementation of
the listed P2 practices to assure
compliance with the final rule.
However, some facilities, although not
required, may use analytical methods to
demonstrate that their treatment system
are "well operated and maintained," as
explained in the P2 Alternative. In
addition, permitting/control authorities
can set numerical limitations using BPJ/
BEJ which may rely on the use of
analytical methods for demonstrating
compliance.
List of Subjects in 40 CFR Part 455
Environmental protection, Chemicals,
Packaging and containers, Pesticides
and pests, Pollution prevention, Waste
treatment and disposal, Water pollution
control.
Dated: September 30, 1996.
Carol M. Browner,
Administrator.
Appendix A to the Preamble—
Abbreviations, Acronyms, and Other
Terms Used in This Document
B.t.—Bacillus thuringiensis
BAT—Best Available Control Technology
Economically Achievable
BCT—Best Conventional Pollutant Control
Technology
BEJ—Best Engineering Judgement
BIF—Boilers and Industrial Furnaces
BOD—Biochemical Oxygen Demand
BPJ—Best Professional Judgement
BPT—Best Practicable Control Technology
Currently Available
CAA—Clean Air Act
CO—Carbon Monoxide
CSF—Confidential Statement of Formula
CWA—Clean Water Act
DOT—Department of Transportation
FATES—FIFRA and TSCA Enforcement
System
FDA—Food and Drug Administration
PDF—Fundamentally Different Factors
FIFRA—Federal Insecticide, Fungicide,
Rodenticide Act
GMPs—Good Manufacturing Practices
GRAS—Generally Recognized As Safe
ICR—Information Collection Request
NOX—Nitrogen oxides
NPDES—National Pollutant Discharge
Elimination System
NSPS—New Source Performance Standards
P2—Pollution Prevention
PAI—Pesticide Active Ingredient
PFPR—Pesticide Formulating, Packaging and
Repackaging
PM—Particulate Matter
POTW—Publicly Owned Treatment Works
PPA—Pollution Prevention Act
PSES—Pretreatment Standards for Existing
Sources
PSNS—Pretreatment Standards for New
Sources
RCRA—Resource Conservation and Recovery
Act
R & D—Research and Development
SBREFA—Small Business Regulatory
Enforcement Fairness Act
SO2—Sulfur dioxide
SRRP—Source Reduction Review Project
TDD—Technical Development Document
TSCA—Toxic Substances Control Act
TSD—Treatment, Storage and Disposal
TSS—Total Suspended Solids
UMRA—Unfunded Mandate Reform Act
UTS—Universal Treatment System
VOCs—Volatile Organic Compounds
Zero/P2 Alternative—Zero Discharge/
Pollution Prevention Alternative Option
For the reasons set out in the
preamble, title 40, chapter I of the Code
of Federal Regulations is amended as
follows:
PART 455—PESTICIDE CHEMICALS
1. The authority citation for part 455
continues to read as follows:
Authority: Sees. 301, 304, 306, 307, and
501, Pub. L. 92-500, 86 Stat, 816, Pub. L. 95-
217, 91 Stat. 156, and Pub. L. 100-4, 101 Stat.
7(33U.S.C. 1311, 1314, 1316, 1317, and
1361).
la. Section 455.10 is amended by
adding paragraphs (g) through (u) to
read as follows:
§455.10 General definitions.
*****
(g) Appropriate pollution control
technology means the wastewater
treatment technology listed in Table 10
to this part 455 for a particular PAI(s)
including an emulsion breaking step
prior to the listed technology when
emulsions are present in the wastewater
to be treated.
(h) Equivalent system means a
wastewater treatment system that is
demonstrated in literature, treatability
tests or self-monitoring data to remove
a similar level of pesticide active
ingredient (PAI) or priority pollutants as
the applicable appropriate pollution
control technology listed in Table 10 to
this Part 455.
(i) Formulation of pesticide products
means the process of mixing, blending
or diluting one or more pesticide active
ingredients (PAIs) with one or more
active or inert ingredients, without an
intended chemical reaction to obtain a
manufacturing use product or an end
use product.
(j) Group 1 mixtures means any
product whose only pesticidal active
ingredient(s) is: a common food/food
constituent or non-toxic household
item; or is a substance that is generally
recognized as safe (GRAS) by the Food
and Drug Administration (21 CFR
170.30, 182, 184, and 186) in
accordance with good manufacturing
practices, as defined by 21 CFR part
182; or is exempt from FIFRA under 40
CFR 152.25.
(k) Group 2 mixtures means those
chemicals listed in Table 9 to this part
455.
(1) Inorganic wastewater treatment
chemicals means inorganic chemicals
that are commonly used in wastewater
treatment systems to aid in the removal
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57549
of pollutants through physical/chemical
technologies such as chemical
precipitation, flocculation,
neutralization, chemical oxidation,
hydrolysis and/or adsorption.
(m) Interior wastewater sources means
wastewater that is generated from
cleaning or rinsing the interior of
pesticide formulating, packaging or
repackaging equipment; or from rinsing
the interior of raw material drums,
shipping containers or bulk storage
tanks; or cooling water that comes in
direct contact with pesticide active
ingredients (PAIs) during the
formulating, packaging or repackaging
process.
(n) Microorganisms means registered
pesticide active ingredients that are
biological control agents listed in 40
CFR 152.20(a)(3) including Eucaryotes
(protozoa, algae, fungi), Procaryotes
(bacteria), and Viruses.
(o) Packaging of pesticide products
means enclosing or placing a formulated
pesticide product into a marketable
container.
(p) PFPR/Manufacturer means a
pesticide formulating, packaging and
repackaging facility that also performs
pesticide manufacturing on-site and
commingles their PFPR process
wastewaters and pesticide
manufacturing process wastewaters.
(q) Pool chemicals means pesticide
products that are intended to disinfect
or sanitize, reducing or mitigating
growth or development of
microbiological organisms including
bacteria, algae, fungi or viruses in the
water of swimming pools, hot tubs, spas
or other such areas, in the household
and/or institutional environment, as
provided in the directions for use on the
product label.
(r) Refilling establishment means an
establishment where the activity of
repackaging pesticide product into
refillable containers occurs.
(s) Repackaging of pesticide products
means the transfer of a pesticide
formulation (or PAI) from one container
to another without a change in
composition of the formulation or the
labeling content, for sale or distribution.
(t) Sanitizer products means pesticide
products that are intended to disinfect
or sanitize, reducing or mitigating
growth or development of
microbiological organisms including
bacteria, fungi or viruses on inanimate
surfaces in the household, institutional,
and/or commercial environment and
whose labeled directions for use result
in the product being discharged to
Publicly Owned Treatment Works
(POTWs). This definition shall also
include sanitizer solutions as defined by
21 CFR 178.1010 and pool chemicals as
defined in this section (455.10(q)). This
definition does not include liquid
chemical sterilants (including
sporicidals) exempted by § 455.40(1) or
otherwise, industrial preservatives, and
water treatment microbiocides other
than pool chemicals.
(u) Stand-alone PFPR facility means a
PFPR facility where either: No pesticide
manufacturing occurs; or where
pesticide manufacturing process
wastewaters are not commingled with
PFPR process wastewaters. Such
facilities may formulate, package or
repackage or manufacture other non-
pesticide chemical products and be
considered a "stand-alone" PFPR
facility.
Ib. Section 455.11 is revised to read
as follows:
§455.11 Compliance date for pretreatment
standards for existing sources (PSES).
All discharges subject to pretreatment
standards for existing sources (PSES) in
subparts A and B of this part must
comply with the standards no later than
September 28, 1993.
Subpart C—Pesticide Formulating,
Packaging and Repackaging (PFPR)
Subcategory
2. Section 455.40 is revised as to read
as follows:
§455.40 Applicability; description of the
pesticide formulating, packaging and
repackaging subcategory.
(a) The provisions of this subpart are
applicable to discharges resulting from
all pesticide formulating, packaging and
repackaging operations except as
provided in paragraphs (b), (c), (d), (e)
and (f) of this section.
(b) The provisions of this subpart do
not apply to repackaging of agricultural
pesticides performed at refilling
establishments, as described in §455.60.
(c) The provisions of this subpart do
not apply to wastewater discharges
from: the operation of employee
showers and laundry facilities; the
testing of fire protection equipment; the
testing and emergency operation of
safety showers and eye washes; storm
water; Department of Transportation
(DOT) aerosol leak test bath water from
non-continuous overflow baths (batch
baths) where no cans have burst from
the time of the last water change-out;
and on-site laboratories from cleaning
analytical equipment and glassware and
rinsing the retain sample container
(except for the initial rinse of the retain
sample container which is considered a
process wastewater source for this
subpart).
(d) The provisions of this subpart do
not apply to wastewater discharges from
the formulation, packaging and/or
repackaging of sanitizer products
(including pool chemicals);
microorganisms; inorganic wastewater
treatment chemicals; group 1 mixtures
and group 2 mixtures, as defined under
§455.10.
(e) The provisions of this subpart do
not apply to wastewater discharges from
the development of new formulations of
pesticide products and the associated
efficacy and field testing at on-site or
stand-alone research and development
laboratories where the resulting
pesticide product is not produced for
sale.
(f) The provisions of this subpart do
not apply to wastewater discharges from
the formulation, packaging and/or
repackaging of liquid chemical sterilant
products (including any sterilant or
subordinate disinfectant claims on such
products) for use on a critical or semi-
critical device, as defined in Section 201
of the Federal Food, Drug and Cosmetic
Act and in Section 2(u) of the Federal
Insecticide, Fungicide and Rodenticide
Act.
3. Section 455.41 is added to Subpart
C to read as follows:
§455.41 Special definitions.
(a) Initial Certification Statement for
this subpart means a written submission
to the appropriate permitting authority,
e.g., the local Control Authority (the
POTW) or NPDES permit writer which
must be signed by the responsible
corporate officer as defined in 40 CFR
403.12(1) or 40 CFR 122.22 and which:
(1) Lists and describes those product
families, process lines and/or process
units for which the PFPR facility is
implementing the Pollution Prevention
Alternative ("P2 Alternative");
(2) Describes the PFPR facility
specific practices for each product
family/process line/process unit which
are to be practiced as part of the P2
Alternative;
(3) Describes any justification
allowing modification to the practices
listed in Table 8 to this part 455; and
(4) Lists the treatment system being
used to obtain a P2 allowable discharge
(as defined in 455.41).
(b) Periodic Certification Statement
for this subpart means a written
submission to the appropriate
permitting authority, e.g., the local
Control Authority (the POTW) or
NPDES permit writer, which states that
the P2 Alternative is being implemented
in the manner set forth in the control
mechanism (for indirect dischargers) or
NPDES permit (for direct dischargers) or
that a justification allowing
modification of the practices listed in
Table 8 to this part 455 has been
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57550 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
implemented resulting in a change in
the pollution prevention practices
conducted at the facility. The Periodic
Certification Statement must be signed
by the responsible corporate officer as
defined in 40 CFR 403.12(1) or 40 CFR
122.22.
(c) On-site Compliance Paperwork for
this subpart means data or information
maintained in the offices of the PFPR
facility which supports the initial and
periodic certification statements as
follows:
(1) Lists and describes those product
families, process lines and/or process
units for which the facility is
implementing the P2 Alternative;
(2) Describes the facility specific
practices for each product family/
process line/process unit which are to
be practiced as part of the P2
Alternative;
(3) Describes any justification
allowing modification to the practices
listed in Table 8 to this part 455;
(4) Includes a written discussion
demonstrating that the treatment system
being used contains the appropriate
pollution control technologies (or
equivalent systems/pesticide
manufacturing systems) for removing
the PAIs which may be found in the
wastewater;
(5) Establishes a method for
demonstrating to the permitting/control
authority that the treatment system is
well operated and maintained; and
(6) Includes a discussion of the
rationale for choosing the method of
demonstration.
(d) For Indirect Dischargers:
Pollution prevention (P2) allowable
discharge (excluding interior wastewater
sources, leak and spill clean-up water,
and floor wash) for this subpart means
the quantity of/concentrations of
pollutants in PFPR process wastewaters
that remain after a facility has
demonstrated that it is using the
specified practices of the Pollution
Prevention Alternative as listed in Table
8 to this part 455.
Pollution prevention (P2) allowable
discharge for interior wastewater
sources, leak and spill cleanup water,
and floor wash for this subpart means
the quantity of/concentrations of
pollutants in PFPR process wastewaters
that remain after a facility has
demonstrated that it is using the
specified practices of the Pollution
Prevention Alternative as listed in Table
8 to this part 455 and that have been
pretreated using appropriate pollution
control technologies, as defined in
§455.10 (g), ora pesticide
manufacturer's treatment system, or an
equivalent system, used individually, or
in any combination to achieve a
sufficient level of pollutant reduction.
Pretreatment requirements may be
modified or waived by the Control
Authority (POTW) to the extent that
removal credits have been granted by
the POTW in accordance with 40 CFR
403.7, provided the granting of such
credits does not result in pass through
or interference as defined in 40 CFR
403.3 and complies with the provisions
of 40 CFR 403.5. The facility must
demonstrate that the appropriate
pollution control technology is properly
maintained and operated.
(e) For Direct Dischargers:
Pollution prevention (P2) allowable
discharge for this subpart means the
quantity of/concentrations of pollutants
in PFPR process wastewaters that
remain after a facility has demonstrated
that it is using the specified practices of
the Pollution Prevention Alternative as
listed in Table 8 to this part 455 and
that have been treated using appropriate
pollution control technologies, as
defined in § 455.10(g), or a pesticide
manufacturer's treatment system, or an
equivalent system, used individually, or
in any combination to achieve a
sufficient level of pollutant reduction.
The facility must demonstrate that the
appropriate pollution control
technology is properly maintained and
operated.
(f) Process wastewater, for this
subpart, means all wastewater
associated with pesticide formulating,
packaging and repackaging except for
sanitary water, non-contact cooling
water and those wastewaters excluded
from the applicability of the rule in
§455.40.
4. Section 455.42 is revised to read as
follows:
§455.42 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable control technology
currently available, (BPT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart shall
achieve the following effluent
limitations representing the degree of
effluent reduction attainable by the
application of the best practicable
control technology currently available.
(a) Except as provided in paragraph
(b) of this section, the following
limitations establish the quantity or
quality of pollutants or pollutant
properties controlled by this paragraph
which may be discharged from the
formulation, packaging or repackaging
of pesticides: There shall be no
discharge of process wastewater
pollutants to navigable waters.
Note: For existing PFPR/Manufacturer
facilities, as defined in §455.10(p), which are
also subject to the provisions of § 455.22 or
§455.32, "zero discharge" means that
permitting authorities shall provide no
additional discharge allowance for those
pesticide active ingredients (PAIs) in the
pesticide formulating, packaging and
repackaging wastewaters when those PAIs
are also manufactured at the same facility.
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455.41 (e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455);
(2) The discharger will notify its
NPDES permit writer at the time of
renewal or modification of its permit, of
its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455.41 (a);
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statements as described in
§ 455.41 (b) once each year of operation;
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
5. New §§ 455.43 through 455.47 are
added to subpart C to read as follows:
§455.43 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best conventional pollutant control
technology (BCT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve the effluent limitations
representing the degree of effluent
reduction attainable by the application
of the best conventional pollutant
control technology.
(a) Except as provided in paragraph
(b) of this section, the BCT limitations
are established as follows: There shall
be no discharge of process wastewater
pollutants to navigable waters.
Note: For existing PFPR/Manufacturer
facilities, as defined in § 455.10(p), which are
also subject to the provisions of §§ 455.23,
zero discharge means that permitting
authorities shall provide no discharge
additional discharge allowance for those
pesticide active ingredients (PAIs) in the
pesticide formulating, packaging and
repackaging wastewaters when those PAIs
are also manufactured at the same facility.
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57551
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455.41 (e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455);
(2) The discharger will notify its
NPDES permit writer at the time of
renewal or modification of its permit, of
its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455.41 (a);
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statement as described in
§ 455.41 (b) once each year of operation;
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
§455.44 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available control technology
economically achievable (BAT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve the effluent limitations
representing the degree of effluent
reduction attainable by the application
of the best available technology (BAT).
(a) Except as provided in paragraph
(b) of this section, the BAT limitations
are established as follows: There shall
be no discharge of process wastewater
pollutants to navigable waters.
Note: For existing PFPR/Manufacturer
facilities, as defined in § 455.10(p), which are
also subject to the provisions of §§ 455.24,
zero discharge means that permitting
authorities shall provide no additional
discharge allowance for those pesticide
active ingredients (PAIs) in the pesticide
formulating, packaging and repackaging
wastewaters when those PAIs are also
manufactured at the same facility.
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455.41 (e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
on Table 8 of this Part 455);
(2) The discharger will notify its
NPDES permitting authority at the time
of renewal or modification of its permit,
of its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455.41 (a);
(3) The discharger will submit to its
NPDES permit writer a periodic
certification statement as described in
§ 455.41 (b) once each year of operation;
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
§455.45 New Source Performance
Standards (NSPS).
(a) Any new source, except as
provided in paragraph (b) of this
section, subject to this subpart which
discharges process wastewater must
meet the following standards: There
shall be no discharge of process
wastewater pollutants to navigable
waters.
Note: For new PFPR/Manufacturer
facilities, as defined in §455.10(p), which are
also subject to the provisions of §§ 455.25,
zero discharge means that permitting
authorities shall provide no additional
discharge allowance for those pesticide
active ingredients (PAIs) in the pesticide
formulating, packaging and repackaging
wastewaters when those PAIs are also
manufactured at the same facility.
(b) Any new source subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455.41(e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455);
(2) The discharger will notify its
NPDES permit writer at the time of
submitting its application for a permit,
of its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455.41 (a);
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statement as described in
§ 455.41 (b) once each year of operation;
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
§455.46 Pretreatment standards for
existing sources (PSES).
(a) Except as provided in 40 CFR
403.7 and 403.13 or in paragraph (b) of
this section, no later than November 6,
1999, any existing source subject to this
subpart which introduces pollutants
into a publicly owned treatment works
must comply with 40 CFR part 403 and
achieve PSES as follows: There shall be
no discharge of process wastewater
pollutants.
(b) Except as provided in 40 CFR
403.7 and 403.13, any existing source
subject to paragraph (a) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
have a pollution prevention allowable
discharge of wastewater pollutants, as
defined in §455.41(d), if the discharger
agrees to control mechanism or
pretreatment agreement conditions as
follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Engineering
Judgement for modifications not listed
in Table 8 to this Part 455);
(2) The discharger will notify its local
Control Authority at the time of
renewing or modifying its individual
control mechanism or pretreatment
agreement of its intent to utilize the
Pollution Prevention Alternative by
submitting to the local Control
Authority an initial certification
statement as described in § 455.41 (a);
(3) The discharger will submit to its
local Control Authority a periodic
certification statement as described in
§ 455.41 (b) during the months of June
and December of each year of operation;
and
(4) The discharger will maintain at the
offices of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
(c) Except as provided in 40 CFR
403.7 and 403.13, any existing source
subject to §455.46(b) which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and may submit a request
to its Control Authority to waive
pretreatment of: floor wash; and/or a
non-reusable final rinse of a triple rinse,
if the concentrations of pesticide active
ingredients and priority pollutants in
those wastewater sources have been
demonstrated to be too low to be
effectively pretreated at the facility. The
Control Authority may waive
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57552 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
pretreatment for these two wastewaters
only if the existing source makes the
demonstrations and is in compliance
with 40 CFR 403.5.
§455.47 Pretreatment Standards for New
Sources (PSNS).
(a) Except as provided in 40 CFR
403.7 and 403.13 or in paragraph (b) of
this section, any new source subject to
this subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and achieve PSNS as
follows: There shall be no discharge of
process wastewater pollutants.
(b) Except as provided in 40 CFR
403.7 and 403.13, any new source
subject to paragraph (a) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
have a pollution prevention allowable
discharge of wastewater pollutants, as
defined in §455.41(d), if the discharger
agrees to control mechanism or
pretreatment agreement conditions as
follows:
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Engineering
Judgement for modifications not listed
in Table 8 to this Part 455);
(2) The discharger will notify its local
Control Authority at the time of
submitting its application for an
individual control mechanism or
pretreatment agreement of its intent to
utilize the Pollution Prevention
Alternative by submitting to the local
Control Authority an initial certification
statement as described in § 455.41 (a);
(3) The discharger will submit to its
local Control Authority a periodic
certification statement as described in
§ 455.41 (b) during the months of June
and December of each year of operation;
and
(4) The discharger will maintain at the
offices of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455.41 (c).
(c) Except as provided in 40 CFR
403.7 and 403.13, any new source
subject to paragraph (b) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
submit a request to its Control Authority
to waive pretreatment of: floor wash;
and/or a non-reusable final rinse of a
triple rinse, if the concentrations of
pesticide active ingredients and priority
pollutants in those wastewater sources
have been demonstrated to be too low
to be effectively pretreated at the
facility. The Control Authority may
waive pretreatment for these two
wastewaters only if the new source
makes the demonstrations and is in
compliance with 40 CFR 403.5.
6. A new subpart E consisting of
§§ 455.60 through 455.67 is added to
read as follows:
Subpart E—Repackaging of Agricultural
Pesticides Performed at Refilling
Establishments
Sec.
455.60 Applicability; description of the
repackaging of agricultural pesticides
performed by refilling establishments
subcategory.
.61 Special Definitions.
.62 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable pollutant control
technology (BPT).
.63 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best conventional pollutant control
technology (BCT).
.64 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available technology
economically achievable (BAT).
.65 New source performance standards
(NSPS).
.66 Pretreatment standards for existing
sources (PSES).
.67 Pretreatment standards for new
sources (PSNS).
455
455
455
Subpart E—Repackaging of
Agricultural Pesticides Performed at
Refilling Establishments
§455.60 Applicability; description of
repackaging of agricultural pesticides
performed by refilling establishments
subcategory.
(a) The provisions of this subpart are
applicable to discharges resulting from
all repackaging of agricultural pesticides
performed by refilling establishments,
as defined in § 455.10; whose primary
business is wholesale or retail sales; and
where no pesticide manufacturing,
formulating or packaging occurs, except
as provided in paragraphs (b), (c) and
(d) of this section.
(b) The provisions of this subpart do
not apply to wastewater discharges from
custom application or custom blending,
as defined in 40 CFR 167.3.
(c) The provisions of this subpart do
not apply to wastewater discharges
from: the operation of employee
showers and laundry facilities; the
testing of fire protection equipment; the
testing and emergency operation of
safety showers and eye washes; or storm
water.
(d) The provisions of this subpart do
not apply to wastewater discharges from
the repackaging of microorganisms or
Group 1 Mixtures, as defined under
§455.10, or non-agricultural pesticide
products.
§455.61 Special definitions.
Process wastewater, for this subpart,
means all wastewater except for sanitary
water and those wastewaters excluded
from the applicability of the rule in
§455.60.
§455.62 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable pollutant control
technology (BPT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
practicable pollutant control
technology: There shall be no discharge
of process wastewater pollutants.
§455.63 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best conventional pollutant control
technology (BCT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
conventional pollution control
technology: There shall be no discharge
of process wastewater pollutants.
§455.64 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available technology economically
achievable (BAT).
Except as provided in 40 CFR 125.30
through 125.32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
available technology economically
achievable: There shall be no discharge
of process wastewater pollutants.
§455.65 New source performance
standards (NSPS).
Any new source subject to this
subpart which discharges process
wastewater pollutants must meet the
following standards: There shall be no
discharge of process wastewater
pollutants.
§455.66 Pretreatment standards for
existing sources (PSES).
Except as provided in 40 CFR 403.7
and 403.13, no later than November 6,
1999 subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
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Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57553
CFR part 403 and achieve the
pretreatment standards for existing
sources as follows: There shall be no
discharge of process wastewater
pollutants.
§455.67 Pretreatment standards for new
sources (PSNS).
Except as provided in 40 CFR 403.7
and 403.13, any new source subject to
this subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and achieve the
pretreatment standards for existing
sources as follows: There shall be no
discharge of process wastewater
pollutants.
7. Tables 8, 9, and 10 are added to
part 455 to read as follows:
Table 8 to Part 455—List of Pollution
Prevention Alternative Practices
A modification to the list of practices
on this table that an individual facility
must comply with to be eligible for the
pollution prevention alternative is
allowed with acceptable justification as
listed on this table as approved by the
permit writer or control authority (using
BPJ/BEJ) after submittal by the facility of
a request for modification. A
modification, for purposes of this table,
means that a facility would no longer
have to perform a listed practice or
would need to comply with a modified
practice. However, the modification
only applies to the specific practice for
which the modification has been
justified and to no other listed practices.
Facilities are required to thoroughly
discuss all modifications in the on-site
compliance paperwork as described
above in the limitations and standards
(§ 455.41 (c)).
1. Must use water conservation
practices. These practices may include,
but are not limited to using: spray
nozzles or flow reduction devices on
hoses, low volume/high pressure rinsing
equipment, floor scrubbing machines,
mop(s) and bucket(s), and counter
current staged drum rinsing stations.
[Modification allowed when: Rinsing
narrow transfer lines or piping where
sufficient rinsing is better achieved by
flushing with water.]
2. Must practice good housekeeping:
(a) Perform preventative maintenance
on all valves and fittings and repair
leaky valves and fittings in a timely
manner;
(b) Use drip pans under any valves or
fittings where hoses or lines are
routinely connected and disconnected,
collect for reuse when possible; and
(c) Perform quick cleanup of leaks and
spills in outdoor bulk storage or process
areas.
3. Must sweep or vacuum dry
production areas prior to rinsing with
water.
4. Must clean interiors of dry
formulation equipment with dry carrier
prior to any water rinse. The carrier
material must be stored and reused in
future formulation of the same or
compatible product or properly
disposed of as solid waste.
5. If operating continuous overflow
Department of Transportation (DOT)
aerosol leak test baths—>
Must operate with some recirculation.
6. If operating air pollution control
wet scrubbers—>
Must operate as recirculating
scrubbers (periodic blowdown is
allowed as needed).
[Modification allowed when: Facility
demonstrates that they would not be
able to meet Resource Conservation
Recovery Act or Clean Air Act (CAA)
requirements.]
7. When performing rinsing of raw
material drums, storage drums, and/or
shipping containers that contained
liquid PAI(s) and/or inert ingredients for
the formulation of water-based
products—>
Must reuse the drum/shipping
container rinsate DIRECTLY into the
formulation at the time of formulation;
or store for use in future formulation of
same or compatible product; or use a
staged drum rinsing station (counter
current rinsing).
[Modification allowed when: the drum/
shipping container holds inert
ingredient(s) only and (1) the facility
can demonstrate that, after using water
conservation practices, the large
concentration of inert ingredient in the
formulation creates more volume than
could feasibly be reused; or (2) the
facility can demonstrate that the
concentration of the inert in the
formulation is so small that the reuse
would cause a formulation to exceed the
ranges allowed in the Confidential
Statement of Formula (CSF) (40 CFR
158.155).]
8. When performing rinsing of raw
material drums, storage drums, and/or
shipping containers that contained
liquid PAI(s) and/or inert ingredients for
the formulation of solvent-based
products—>
Must reuse the drum/shipping
container rinsate DIRECTLY into the
formulation at the time of formulation
or store for use in future formulation of
same or compatible product.
[Modification allowed when:
(a) The drum/shipping container
holds inert ingredient(s) only and: (1)
The facility can demonstrate that, after
using water conservation practices, the
large concentration of inert ingredient in
the formulation creates more volume
than could feasibly be reused; or (2) the
facility can demonstrate that the
concentration of the inert in the
formulation is so small that the reuse
would cause a formulation to exceed the
ranges allowed in the Confidential
Statement of Formula (CSF) (40 CFR
158.155); or
(b) Drums/shipping containers are
going to a drum refurbisher/recycler
who will only accept drums rinsed with
water.]
9. Must dedicate PFPR production
equipment by water-based versus
solvent-based products. Dedicated
solvent-based or water-based equipment
may be used on a non-routine basis for
non-dedicated operations; however the
facility may not discharge the solvent/
aqueous changeover rinsate as part of
their P2 allowable discharge (i.e., the
facility must achieve zero discharge of
those process wastewater pollutants).
[Modification allowed when: Facility
has installed and is using a solvent
recovery system for the changeover
rinsate (can also be used for other
solvent recovery).]
10. Must store the rinsate from
interior rinsing (does not include drum/
shipping container rinsate) for reuse in
future formulation of same or
compatible product.
[Modification allowed when:
(a) Facility has evidence of biological
growth or other product deterioration
over a typical storage period;
(b) Facility has space limitations, BUT
must still store rinsates for most
frequently produced products;
(c) Manufacturer (or formulator
contracting for toll formulating) has
directed otherwise (i.e., send back to
them or send for off-site disposal);
(d) Facility is dropping registration or
production of the formulation and there
is no compatible formulation for reuse
of the rinsates or facility can provide
reasonable explanation of why it does
not anticipate formulation of same or
compatible formulation within the next
12 months;
(e) Facility only performs packaging
of the pesticide product from which
interior rinsate is generated; or
(f) Facility has demonstrated that it
must use a detergent to clean the
equipment.]
Notes
For indirect dischargers: After following
the practices above, some wastewaters may
require pretreatment prior to discharge to
POTWs. See definition of pollution
prevention allowable discharge for indirect
dischargers (§455.41 (d)).
-------
57554 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
For direct dischargers: After following the
practices above, all wastewaters require
treatment prior to discharge directly to the
nation's waters. See definition of pollution
prevention allowable discharge for direct
dischargers (§455.41 (e)).
Additional information and guidance on
implementing these P2 practices as well as
evaluating compliance with these practices
will be available in a P2 Guidance Manual for
the PFPR Industry.
TABLE 9 TO PART 455.—GROUP 2
MIXTURES
TABLE 9 TO PART 455.—GROUP 2
MIXTURES—Continued
Shaughnessey
code
Shaughnessey
code
002201 .
006501 .
006602 .
0166012
022003 .
025001 .
025003 .
025004 .
031801 .
055601 .
063501 .
063502 .
063503 .
063506
067003
067205
067207
067302
069152
070801
Chemical name1
071004 ..
071501 ..
0726022
0726052
079014 ..
079021 ..
079029 ..
Sabadilla alkaloids.
Aromatic petroleum deriva-
tive solvent.
Heavy aromatic naphtha.
Dry ice.
Coal tar.
Coal tar neutral oils.
Creosote oil (Note: Derived
from any source).
Coal tar creosote.
Ammonium salts of C8-18
and C18' fatty acids.
BNOA.
Kerosene.
Mineral oil—includes paraffin
oil from 063503.
Petroleum distillate, oils, sol-
vent, or hydrocarbons; also
P-
Mineral spirits.
Terpineols (unspec.).
Pine tar oil.
Ester gum.
Amines, N-coco
alkyltrimethylenedi-, ace-
tates.
Amines, coco alkyl,
hydrochlorides.
Red Squill glycoside.
079034 .
079059 .
086803 .
107302 .
107303 .
107304 .
116902 .
117001 .
128888 .
1289342
129029 .
224600 .
505200 .
Chemical name1
Cube Resins other than rote-
none.
Ryania speciosa, powdered
stems of.
Silica gel.
Silicon dioxide.
Turkey red oil.
Potassium salts of fatty
acids.
Fatty alcohols (52-61% C10,
39-46% C8, 0-3% C6, 0-
3% C12).
Methyl esters of fatty acids
(100% C8-C12)
Fatty alcohols (54.5% C10,
45.1% C8, 0.4% C6)
Xylene range aromatic sol-
vent
Polyhedral inclusion bodies
of Douglas fir tussock
moth nucl.
Polyhedral inclusion bodies
of gypsy moth
nucleopolyhedrosis.
Polyhedral inclusion bodies
of n. sertifer
Gibberellin A4 mixt. with
Gibberellin A7.
Nosema locustae.
Lactofen (ANSI).
Nitrogen, liquid.
Bergamot Oil.
Diethanolamides of the fatty
acids of coconut oil (coded
079).
Isoparaffinic hydrocarbons.
1 Shaughnessey codes and chemical names
are taken directly from the FATES database.
Several chemical names are truncated be-
cause the chemical names listed in the
FATES database are limited to 60 characters.
2 EPA does not believe this PAI will persist
in sanitary streams long enough to reach a
POTW.
Table 10 to Part 455—List of
Appropriate Pollution Control
Technologies
This table contains those pollutant
control technologies, such as hydrolysis,
chemical oxidation, precipitation and
activated carbon adsorption, which have
been used for estimating compliance
costs on a PAI specific basis. In general,
these treatment technologies have been
determined to be effective in treating
pesticide containing wastewaters in
literature, in bench or pilot scale
treatability studies or in the Pesticide
Manufacturing effluent guidelines.
These are the same technologies that are
presented as part of the Universal
Treatment System. However, these
technologies are PAI specific and may
need to be used in conjunction with one
another to provide treatment for all PAIs
used at a facility over a period of time.
In addition, facilities may experience
difficulties treating wastewaters that
contain emulsions, therefore,
"appropriate" treatment for emulsified
wastewaters must include an emulsion
breaking step. For PAIs whose
technology is listed as "Pollution
Prevention", the permitting authority/
control authority can determine if
additional treatment is necessary
through best professional judgement/
best engineering judgement,
respectively.
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES 1
PAI name2
Dicofol
Maleic Hydrazide
EDB
Vancide TH
1 3-Dichloropropene
Thenarsazine Oxide
Dowicil 75
Triadimefon
Hexachlorophene
Tetrachlorophene
Dichlorophene
Dichlorvos
Landrin-2
2 3 6-T S&E or Fenac
2,4,5-T and 2,4,5-T, S&E
2 4-D (2 4-D S&E)
2,4-DB, S&E
Dyrene or Anilazine
Dinocap
Dichloran or DCNA
Busan 90
Mevinphos
Sulfallate
PAI
code3
001
002
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
Shaughnessy
code4
10501
51501
42002
82901
29001
12601
17901
109901
44901
55001
84001
82605
(*)
(*)
(*)
80811
36001
31301
8707
15801
Structural group5
DDT
Hydrazide
EDB
s-Triazine
EDB
Organoarsenic
NR4
s-Triazine
Chlorophene
Chlorophene
Chlorophene
Phosphate
Carbamate
2 4-D
2,4-D
2 4-D
2,4-D
s-Triazine
Phenylcrotonate
Aryl Halide
Miscellaneous Organic
Phosphate
Dithiocarbamate
Treatment technology
Hydrolysis
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis
Precipitation.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon.
Chemical Oxidation
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57555
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Chlorfenvinphos
Cyanazine or Bladex
Propachlor
MCPA S&E
Octhilinone
Pindone
Dichlorprop S&E
MCPP, S&E or Mecoprop
Thiabendazole
Belclene 310
Chlorprop S&E
Busan 72 or TCMTB
Chlorophacinone
Landrin-1
Pronamide
Methiocarb or Mesurol
Propanil
Polyphase6
Coumafuryl or Fumarin
DNOC
Metribuzin
CPA S&E
MCPB, S&E
Aminocarb
Etridiazole
Ethoxyquin
Acephate or Orthene
Acifluorfen
Alachlor
Aldicarb
Allethrin
Ametryn
Amitraz
Atrazine
Bendiocarb
Benomyl
BHC
Benzyl Benzoate
Lethane 60
Bifenox
Biphenyl
Bromacil (Lithium Salt)
Bromoxynil
Butachlor
Giv-gard
Cacodylic Acid
Captafol
Captan
Carbaryl
Carbofuran
Carbosulfan
Chloramben
Chlordane
Chloroneb
Chloropicrin
Chlorothalonil
Chloroxuron
Stirofos
Chlorpyrifos Methyl
Chlorpyrifos
Mancozeb
Bioquin (Copper)
Copper EDTA
Pydrin or Fenvalerate
Cycloheximide
Dalapon
Dienochlor
Demeton
Desmedipham
Amobam
DBCP
PAI
code3
024
025
026
027
028
029
030
031
032
033
034
035
037
038
039
040
041
042
043
044
045
046
047
048
049
050
052
053
054
055
057
058
059
060
061
062
063
064
065
066
067
068
069
070
071
072
073
074
075
076
077
078
079
080
081
082
083
084
085
086
087
088
089
090
091
092
093
094
095
096
097
Shaughnessy
code4
84101
100101
19101
(*)
99901
67703
(*)
(*)
60101
80815
21202
35603
67707
101701
100501
28201
107801
86001
101101
(*)
19202
84701
55501
103301
1 1 4402
90501
98301
(*)
80801
106201
80803
105201
99101
9501
104301
17002
(*)
(*)
101401
(*)
81301
56801
90601
(*)
58201
27301
81501
81901
83701
59102
59101
14504
24002
39105
109301
(*)
27501
104801
Structural group5
Phosphate
s-Triazine
Acetanilide
24-D
Heterocyclic
Miscellaneous Organic
24-D
2,4-D
Heterocyclic
s-Triazine
24-D
Heterocyclic
Miscellaneous Organic
Carbamate
Chlorobenzamide
Carbamate
Chloropropionanilide
Carbamate
Coumarin
Phenol
Triazathione
24-D
2,4-D
Carbamate
Heterocyclic
Quinolin
Phosphoroamidothioate
Benzole Acid
Acetanilide
Carbamate
Pyrethrin
s-Triazine
Iminamide
s-Triazine
Carbamate
Carbamate
Lindane
Ester
Thiocyanate
Nitrobenzoate
Aryl
Uracil
Benzonitrile
Acetanilide
Miscellaneous Organic
Organoarsenic
Phthalimide
Phthalimide
Carbamate
Carbamate
Carbamate
Benzole Acid
Tri cyclic
Aryl Halide
Alkyl Halide
Chloropropionanilide
Urea
Phosphate
Phosphorothioate
Phosphorothioate
Dithiocarbamate
Organocopper
Organocopper
Pyrethrin
Cyclic Ketone
Alkyl Halide
HCp
Phosphorothioate
Carbamate
Miscellaneous Organic
EDB
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis.
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis.
Hydrolysis
Hydrolysis.
Hydrolysis
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Precipitation
Hydrolysis.
Hydrolysis.
Hydrolysis
Hydrolysis
Activated Carbon.
Activated Carbon.
Activated Carbon
Chemical Oxidation
Chemical Oxidation.
Activated Carbon.
Activated Carbon
Hydrolysis
Hydrolysis.
Chemical Oxidation.
Activated Carbon
Precipitation
Precipitation.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Hydrolysis.
Hydrolysis
Activated Carbon
Activated Carbon.
-------
57556 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Dicamba
Dichlone
Thiophanate Ethyl
Perthane
EXD
Diazinon
Diflubenzuron
Dimethoate
Parathion Methyl
Dicrotophos
Crotoxyphos
DCPA
Trichlorofon
Dinoseb
Dioxathion
Diphacinone
Diphenamide
Diphenylamine
MGK326
Nabonate
Diuron
Metasol DGH
Dodine
Endosulfan
Endothall (Endothall S&E)
Endrin
Ethalfluralin
Ethion
Ethoprop
Fenamiphos
Chlorobenzilate
Butylate
Famphur
Fenarimol
Fenthion or Baytex
Ferbam
Fluometuron
Fluoroacetamide
Folpet
Glyphosate (Glyphosate S&E)
Glyphosine
Heptachlor
Cycloprate
Hexazinone
Isofenphos
Isopropalin
Propham
Karabutilate
Lindane
Linuron
Malachite Green
Malathion
Maneb
Manam
Mefluidide
Methamidophos
Methidathion
Methomyl
Methoprene
Methoxychlor
Methyl Bromide
Monosodium Methyl Arsenate
Nalco D-2303
Quinomethionate
Metolachlor
Mexacarbate
Metiram
Monuron TCA
Monuron
Napropamide
Deet
PAI
code3
098
099
100
101
102
103
104
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
160
161
163
164
165
166
167
168
169
170
171
Shaughnessy
code4
(*)
29601
103401
57801
108201
35001
53501
35201
58801
78701
57901
37505
37801
67701
36601
38501
47201
63301
35505
44303
44301
79401
(*)
41601
113101
58401
41101
100601
28801
41405
206600
53301
34801
35503
81601
(*)
44801
107201
109401
100201
97401
9001
35506
39504
57701
14505
114002
101201
100301
90301
(*)
34001
53201
(*)
68102
54101
108801
14601
35502
35501
103001
80301
Structural group5
Aryl Halide
Quinone
Carbamate
DDT
Dithiocarbamate
Phosphorothioate
Urea
Phosphorodithioate
Phosphorothioate
Phosphate
Phosphate
Aryl Halide
Phosphonate
Phenol
Phosphorodithioate
Indandione
Acetamide
Aryl Amine
Ester
Isocyanate
Urea
NR4
NR4
Tri cyclic
Bicyclic
Tri cyclic
Toluidine
Phosphorodithioate
Phosphorodithioate
Phosphoroamidate
Aryl Halide
Thiocarbamate
Phosphorothioate
Pyrimidine
Phosphorothioate
Dithiocarbamate
Urea
Acetamide
Phthalimide
Phosphoroamidate
Phosphoroamidate
Tri cyclic
Thiocarbamate
s-Triazine
Phosphoroamidothioate
Toluidine
Carbamate
Carbamate
Lindane
Urea
NR4
Phosphorodithioate
Dithiocarbamate
Dithiocarbamate
Carbamate
Phosphoroamidothioate
Phosphorodithioate
Carbamate
Ester
DDT
Alkyl Halide
Organoarsenic
Thiocyanate
Miscellaneous Organic
Acetanilide
Carbamate
Dithiocarbamate
Urea
Urea
Carbamate
Toluamide
Treatment technology
Activated Carbon.
Activated Carbon
Hydrolysis.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon
Hydrolysis.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Chemical Oxidation
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon
Hydrolysis.
Chemical Oxidation.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Hydrolysis.
Hydrolysis.
Activated Carbon
Chemical Oxidation
Activated Carbon.
Hydrolysis.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Hydrolysis
Activated Carbon.
Hydrolysis.
Activated Carbon
Precipitation
Activated Carbon.
Activated Carbon.
Activated Carbon
Hydrolysis
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57557
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Nabam
Naled
Norea
Norflurazon
Naptalam or Neptalam
MGK 264
Benfluralin
Sulfotepp
Aspon
Coumaphos
Fensulfothion
Disulfoton
Fenitrothion
Phosmet
Azinphos Methyl (Guthion)
Oxydemeton Methyl
Organo-Arsenic Pesticides
Organo-Cadmium Pesticides
Organo-Copper Pesticides
Organo-Mercury Pesticides
Organo-Tin Pesticides
o-Dichlorobenzene
Oryzalin
Oxamyl
Oxyfluorfen
Bolstar
Sulprofos Oxon
Santox (EPN)
Fonofos
Propoxur
p-Dichlorobenzene
Parathion Ethyl
Pendimethalin
PCNB
PCP or Penta
Perfluidone
Permethrin
Phenmedipham
Nemazine
Phorate
Phosalone
Phosphamidon
Picloram
Piperonyl Butoxide
PBED or WSCP (Busan 77)
Busan 85 or Arylane
Busan 40
KN Methyl
Metasol J26
Profenofos
Prometon or Caparol
Prometryn
Propargite
Propazine
Propionic Acid
Previcur N
Pyrethrin Coils
Pyrethrum I
Pyrethrum II
Pyrethrins
Resmethrin
Fenchlorphos or Ronnel
Mexide or Rotenone
DEF
Siduron or Tupersan
Silvex
Simazine
Sodium Bentazon
Carbam-S or Sodam
Sodium Fluoroacetate
Vaoam or Metham Sodium
PAI
code3
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
Shaughnessy
code4
14503
34401
105801
30703
57001
84301
79501
36501
32701
32501
105901
59201
58001
58702
(*)
(*)
(*)
59401
104201
103801
111601
111501
41801
41701
47802
61501
57501
108501
56502
(*)
109701
98701
64501
57201
97701
18201
(*)
67501
69183
34803
102901
39002
101301
111401
80804
80805
97601
80808
77702
119301
69004
69001
69002
(*)
(*)
58301
71003
74801
35509
(*)
80807
103901
34804
75003
39003
Structural group5
Dithiocarbamate
Phosphate
Urea
Heterocyclic
Phthalamide
Bicyclic
Toluidine
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorothioate
Phosphorodithioate
Phosphorothioate
Phosphorodithioate
Phosphorodithioate
Phosphorothioate
Organoarsenic
Organocadmium
Organocopper
Organomercury
Organotin
Aryl Halide
Sulfanilamide
Carbamate
Miscellaneous Organic
Phosphorodithioate
Phosphorothioate
Phosphorodithioate
Phosphorodithioate
Carbamate
Aryl Halide
Phosphorothioate
Benzeneamine
Aryl Halide
Phenol
Sulfonamide
Pyrethrin
Carbamate
Heterocyclic
Phosphorodithioate
Phosphorodithioate
Phosphate
Pyridine
Ester
NR4
Dithiocarbamate
Dithiocarbamate
Dithiocarbamate
Miscellaneous Organic
Phosphorothioate
s-Triazine
s-Triazine
Miscellaneous Organic
s-Triazine
Alkyl Acid
Carbamate
Pyrethrin
Pyrethrin
Pyrethrin
Pyrethrin
Pyrethrin
Phosphorothioate
Miscellaneous Organic
Phosphorotrithioate
Urea
24-D
s-Triazine
Heterocyclic
Dithiocarbamate
Acetamide
Dithiocarbamate
Treatment technology
Chemical Oxidation.
Hydrolysis
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis.
Hydrolysis
Hydrolysis.
Hydrolysis
Hydrolysis.
Hydrolysis
Activated Carbon.
Precipitation
Precipitation
Precipitation.
Precipitation
Precipitation.
Activated Carbon
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Hydrolysis.
Hydrolysis
Hydrolysis.
Hydrolysis
Activated Carbon
Hydrolysis.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis
Activated Carbon.
Hydrolysis.
Hydrolysis
Hydrolysis
Activated Carbon.
Activated Carbon.
Activated Carbon
Chemical Oxidation
Chemical Oxidation.
Chemical Oxidation.
Activated Carbon
Activated Carbon
Chemical Oxidation.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Hydrolysis.
Activated Carbon
Hydrolysis
Hydrolysis.
Hydrolysis.
Activated Carbon
Hydrolysis
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Chemical Oxidation.
Chemical Oxidation
Activated Carbon
Chemical Oxidation.
-------
57558 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Sulfoxide
Cycloate or Ro-Neet
EPrecipitationC or Eptam
Molinate
Pebulate or Tillman
Vernolate or Vernam
HPrecipitationMS
Bensulide or Betesan
Tebuthiuron
Temephos
Terbacil
Terbufos or Counter
Terbuthylazine
Terbutryn
Tetrachlorophenol
Dazomet
Thiophanate Methyl
Thiram
Toxaphene
Merphos
Trifluralin or Treflan
Warfarin
Zinc MBT
Zineb
Ziram
Triallate
Phenothrin
Tetramethrin
Chloropropham
Non-272 PAIs
CFC 11
CFC 12
Polyethylene
Acrolein
Dimethyl-m-dioxan-4-ol acetate
Dodecyl alcohol
Tetradecyl alcohol
Rosin amine D acetate
Dihydroabietylamine acetate
Amitrole
Allyl isothiocyanate
AMS
Calcium sulfate
Tartar emetic
Diphenylstibene 2-ethylhexanoate
Streptomycin
Oxytetracycline hydrochloride
Streptomycin sesquisulfate
Neomycin sulfate
Antimycin A
Calcium oxytetracycline
Espesol 3A
Arsenic acid
Arsenic acid anhydride
Arsenous acid anhydride
Copper oxychloride
Basic cupric sulfate
Basic copper III — zinc sulfate complex (De-
clare copper and.
Bromophos
Benzyl bromoacetate
Benzole acid
Benzyl diethyl ((2 6-xylylcarbamoyl)methyl)
ammonium benzoate.
Benzyl alcohol
3— Chloro-p-toluidine hydrochloride
Butoxyethoxy)ethyl thiocyanate
2-Naphthol
Boric acid
Barium metaborate
PAI
code3
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
Shaughnessy
code4
57101
41301
41401
41402
41403
41404
35604
9801
105501
59001
12701
105001
80814
80813
63004
35602
102001
79801
80501
74901
36101
(*)
51705
14506
34805
78802
69005
69003
18301
13
14
152
701
1001
1509
1510
4201
4213
4401
4901
5501
5602
6201
6202
6306
6308
6310
6313
6314
6321
6601
6801
6802
7001
8001
8101
8102
8706
8710
9101
9106
9502
9901
10002
10301
11001
11101
Structural group5
Miscellaneous Organic
Thiocarbamate
Thiocarbamate
Thiocarbamate
Thiocarbamate
Thiocarbamate
Thiosulphonate
Phosphorodithioate
Urea
Phosphorothioate
Uracil
Phosphorodithioate
s-Triazine
s-Triazine
Phenol
Heterocyclic
Carbamate
Dithiocarbamate
Bicyclic
Phosphorotrithioate
Toluidine
Coumarin
Organozinc
Dithiocarbamate
Dithiocarbamate
Thiocarbamate
Pyrethrin
Pyrethrin
Carbamate
Alkyl Halide
Alkyl Halide
Polymer
Alcohol
Heterocyclic
Alcohol
Alcohol
Alkyl Acid
Alkyl Acid
Heterocyclic
Thiocyanate
Inorganic
Inorganic
Inorganic
Aryl
Heterocyclic
Phthalamide
Heterocyclic
Benzeneamine
Heterocyclic
Phthalamide
Phosphorothioate
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Phosphorothioate
Benzole acid
Benzole acid
NR4
Aryl
Chloropropionanilide
Thiocyanate
Phenol
Inorganic
Inoraanic
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Hydrolysis.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Chemical Oxidation.
Hydrolysis
Activated Carbon.
Activated Carbon.
Hydrolysis
Activated Carbon.
Activated Carbon
Precipitation.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Hydrolysis.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Pollution Prevention.
Pollution Prevention.
Pollution Prevention
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Precipitation
Precipitation.
Precipitation.
Precipitation
Precipitation
Precipitation.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Pollution Prevention
Pollution Prevention.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57559
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Boron sodium oxide (B8Na2O13) tetra-
hydrate (12280-03-4).
Sodium metaborate (NaBO2)
Boron sodium oxide (B8Na2O13) (12008-
41-2).
Boron sodium oxide (B4Na2O7)
pentahydrate (12179-04-3).
Boron sodium oxide (B4Na2O7) (1330-43-
4).
Polybutene
Polyisobutylene
Butyl cellosolve
Butoxypolypropylene glycol
Neburon (ANSI)
Methyltrimethylenedioxy)bis(4-methyl-1 3 2-
dioxaborinane).
Oxybis(4 4 6-trimethyl-1 3 2-dioxaborinane)
Cadmium chloride
Lead arsenate basic
Lead arsenate
Sodium arsenate
Sodium arsenite
Potassium bromide
Camphor
Carbon disulfide
Carbon tetrachloride
Barban (ANSI)
Chloro-2-propenyl)-3 5 7 triaza-1-azo
niatricyclo(3.3.1 .1)sup.
Chlormequat chloride
Chloromethoxypropylmercuric acetate
Allidochlor
Chromic acid
Chromic oxide
Cresol (unspec) (Cresylic acid)
Cresol
Copper (metallic)
Copper ammonium carbonate
Copper carbonate
Copper hydroxide
Copper chloride hydroxide (Cu2CI(OH)3)
Copper oxychloride sulfate
Copper sulfate
Copper (from triethanolamine complex)
Copper as metallic (in the form of chelates
of copper citrat).
Copper as elemental from copper — ethyl-
enediamine complex.
Copper sulfate (anhydrous)
Copper(l) oxide
Cuprous thiocyanate
Cyclohexane
Cyclohexanone
Dichlobenil
Diquat dibromide
Dimethrin (ANSI)
Dicapthon
Ziram cyclohexylamine complex
Butyl dimethyltrithioperoxycarbamate
Daminozide
Bis(trichloromethyl) sulfone
Bis(bromoacetoxy)-2-butene
Dazomet sodium salt
Butonate
Trifluoro-4-nitro-m-cre-
sol(**)=alpha, alpha, alpha-.
Triethanolamine dinoseb (2-sec-Butyl-4 6-
dinitrophenol).
Sodium 4 6-dinitro-o-cresylate
Dinitroohenol
PAI
code3
Shaughnessy
code4
11103
11104
11107
11110
11112
11402
11403
11501
11901
12001
12401
12402
12902
13502
13503
13505
13603
13903
15602
16401
16501
17601
17902
18101
18401
19301
21101
21103
22101
22102
22501
22703
22901
23401
23501
23503
24401
24403
24405
24407
24408
25601
25602
25901
25902
27401
32201
34101
34502
34806
34807
35101
35601
35605
35607
35701
6201
37506
37508
37509
Structural group5
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Polymer
Polymer
Alcohol
Polymer
Chloropropionanilide
Bicyclic
Bicyclic
Metallic
Metallic
Metallic
Metallic
Metallic
Inorganic
Bicyclic
Inorganic
Alkyl Halide
Carbamate
Tri cyclic
NR4
Metallic
Acetanilide
Metallic
Metallic
Phenol
Phenol
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Metallic
Aryl
Cyclic Ketone
Chloropropionanilide
NR4
Pyrethrin
Phosphorothioate
Dithiocarbamate
Dithiocarbamate
Acetanilide
Miscellaneous Organic
Alkyl Halide
Heterocyclic
Phosphonate
Phenol
Phenol
Phenol
Phenol
Treatment technology
Pollution Prevention
Pollution Prevention.
Pollution Prevention.
Pollution Prevention.
Pollution Prevention
Activated Carbon.
Activated Carbon.
Activated Carbon.
Activated Carbon.
Activated Carbon.
Activated Carbon.
Activated Carbon
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Pollution Prevention
Activated Carbon
Pollution Prevention
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon.
Precipitation.
Activated Carbon.
Precipitation.
Precipitation.
Activated Carbon.
Activated Carbon
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation
Precipitation.
Precipitation.
Precipitation
Precipitation
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
-------
57560 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Alkanol* amine dinoseb (2-sec-butyl-4 6-
dinitrophenol) *(s.
Sodium dinoseb (2-sec-Butyl-4 6-
dinitrophenol).
Nitrilotriacetic acid trisodium salt
Trisodium(2-hydroxyethyl)ethylene
diaminetriacetate.
Ammonium ethylenediaminetetraacetate
Penta sodium
diethylenetriaminepentaacetate.
Ethyl-1 3-hexanediol
Ethylene
EDO
Methylene chloride
Methoxyethanol
Ethylene glycol
Butylene glycol
Ethylene oxide
Copper(ll) oxide
Cuprous and cupric oxide mixed
Propylene oxide
Formaldehyde
Paraformaldehyde
Bis(2-butylene) tetrahydro-2-furaldehyde
Giberellic acid
Potassium gibberellate
Glutaral
Copper citrate
Methyl nonyl ketone
Methyl-2-pentanone
Monosodium 2 2'-methylenebis (3 4 6-tri-
chlorophenate).
Potassium 2 2'-methylenebis (3 4 6-tri-
chlorophenate).
Hexachloroepoxyoctahydro-endo exo-
dimethanoaphthalene 85%.
Chlorhexidine diacetate
Hydrocyanic acid
Hydroxyethyl octyl sulfide
Heptadecenyl-2-(2-hydroxyethyl)-2-i
midazolinium chloride.
Hydroxyethyl)-2-alkyl-2-imidazoline (as in
fatty acids of t.
IBA
Dihydropyrone
Butoxypolypropoxypolyethoxyethanol-iodine
complex.
Polyethoxypolypropoxyethanol-iodine com-
plex.
Use code no 046904
(polyethoxypolypropoxy ethanol-iodine
complex).
Iodine-potassium iodide complex
Alky l-omega-hydroxy poly (oxyethylen e)-io-
dine complex "(100%.
Lead acetate
Nickel sulfate hexahydrate
Maleic hydrazide diethanolamine salt
Maleic hydrazide potassium salt
Sodium 2-mercaptobenzothiolate
Mercuric chloride
Mercurous chloride
Metaldehyde
Methylated naphthalenes
Sodium 2 2'-methylenebis(4-chlorophenate)
Naphthalene
NAD
NAA (1— Naphthaleneacetic Acid)
Potassium 1-naphthaleneacetate
Ammonium 1-naphthaleneacetate
Sodium 1-naohthaleneacetate
PAI
code3
Shaughnessy
code4
37511
37512
39106
39109
39117
39120
41001
41901
42003
42004
42202
42203
42205
42301
42401
42403
42501
43001
43002
43302
43801
43802
43901
44005
44102
44105
44902
44904
45001
45502
45801
46301
46608
46609
46701
46801
46901
46904
46909
46917
46921
48001
50505
51502
51503
51704
52001
52201
53001
54002
55005
55801
56001
56002
56003
56004
56007
Structural group5
Phenol
Phenol
Acetamide
Acetanilide
Acetamide
Acetanilide
Alcohol
Miscellaneous Organic
EDB
Alkyl Halide
Alcohol
Alcohol
Alcohol
Miscellaneous Organic
Metallic
Metallic
Miscellaneous Organic
Miscellaneous Organic
Polymer
Tri cyclic
Tricyclic
Tri cyclic
Alcohol
Metallic
Miscellaneous Organic
Miscellaneous Organic
Chlorophene
Chlorophene
Tricyclic
Chloropropionanilide
Inorganic
Alcohol
NR4
NR4
Bicyclic
Cyclic ketone
Polymer
Polymer
Polymer
Inorganic
Polymer
Metallic
Metallic
Hydrazide
Hydrazide
Heterocyclic
Metallic
Metallic
Miscellaneous Organic
Aryl
Chlorophene
Aryl
Benzole Acid
Benzole Acid
Benzole Acid
Benzole Acid
Benzole Acid
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Pollution Prevention.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Pollution Prevention.
Precipitation
Precipitation.
Pollution Prevention
Pollution Prevention.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Precipitation
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Pollution Prevention
Activated Carbon
Precipitation.
Precipitation
Activated Carbon
Activated Carbon.
Activated Carbon.
Precipitation
Precipitation
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57561
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Ethyl 1-naphthaleneacetate
Nitrophenol
Nicotine
Carbophenothion (ANSI)
Sodium 5-chloro-2-(4-chloro-2-(3-(3 4-
dichlorophenyl)ureido).
Monocrotophos
Chlordimeform
Chlordimeform hydrochloride
Thiabendazole hypophosphite
Hexachlorobenzene
Butyl paraben
Paraquat dichloride
Chloro-4-phenylphenol
Chloro-2-phenylphenol
Chloro-2-biphenylol potassium salt
Chloro-2-phenylphenol
Chloro-2-phenylphenol potassium salt
Sodium phenate
Butylphenol sodium salt
Ammonium 2-phenylphenate
Chloro-2-cyclopentylphenol
Bithionolate sodium
Chloro-3-cresol
Sodium 2 4 5-trichlorophenate
Aluminum phosphide
Phosphorus
Magnesium phosphide
1 -(Alkyl*amino)-3-aminopropane* (Fatty
acids of coconut oil).
Alkyl* amino)-3-aminopropane *(53%C12
19%C14, 8.5%C16, 7%C8.
Alkyl*amino)-3-aminopropane
benzoate*(fatty acids of coconut.
Alkyl* dipropoxyamine *(47% C12 18%
C14, 10% C18, 9% C10, 8.
Alkyl*amino)-3-aminopropane
hydroxy acetate* (acids of coconut.
Alkyl* amino)-3-aminopropane *(42%C12
26%C18, 15%C14, 8%C16.
Alkyl*amino)-3-aminopropane diacetate*
(fatty acids of coconut.
Octadecenyl-1 3-propanediamine
monogluconate.
Alkyl* amine acetate *(5%C8 7%C10
54%C12, 19%C14, 8%C16,.
Pindone sodium salt
Diphacinone sodium salt
lsovaleryl-1 3-indandione calcium salt
Methyl isothiocyanate
Potassium dichromate
Sodium chromate
Sodium dichromate
Alkenyl* dimethyl ethyl ammonium bromide
*(90%C18', 10%C16').
Alkyl*-N-ethyl morpholinium ethyl sulfate
*(92%C18, 8%C16).
Alkyl* isoquinolinium bromide *(50% C12
30% C14, 17% C16, 3).
Alkyl* methyl isoquinolinium chloride
*(55%C14, 12%C12, 17%C).
Cetyl trimethyl ammonium bromide
Cetyl pyridinium bromide
Dodecyl dimethyl benzyl ammonium
naphthenate.
Alkyl* dimethyl ethylbenzyl ammonium
cyclohexylsulfamate *(5).
Alkyl*-N-ethyl morpholinium ethyl sulfate
*(66%C18, 25%C16).
Alkyl* trimethyl ammonium bromide
*(95%C14, 5%C16).
PAI
code3
Shaughnessy
code4
56008
56301
56702
58102
58802
58901
59701
59702
60102
61001
61205
61601
62206
62208
62209
62210
62211
64002
64115
64116
64202
64203
64206
64217
66501
66502
66504
67301
67305
67307
67308
67309
67310
67313
67316
67329
67704
67705
67706
68103
68302
68303
68304
69102
69113
69115
69116
69117
69118
69127
69135
69147
69153
Structural group5
Benzole Acid
Phenol
Pyridine
Phosphorodithioate
Aryl Halide
Phosphate
Chloropropionanilide
Chloropropionanilide
Hydrazide
Lindane
Phenol
Pyridine
Chlorophene
Chlorophene
Chlorophene
Chlorophene
Chlorophene
Phenol
Phenol
Phenol
Chlorophene
Chlorophene
Chlorophene
Chlorophene
Inorganic
Inorganic
Inorganic
Iminamide
Iminamide
Iminamide
Iminamide
Iminamide
Iminamide
Iminamide
Acetamide
Iminamide
Indandione
Indandione
Indandione
Thiocyanate
Inorganic
Inorganic
Metallic
NR4
Heterocyclic
Quinolin
Quinolin
NR4
Pyridine
NR4
NR4
Heterocyclic
NR4
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Pollution Prevention.
Pollution Prevention
Pollution Prevention.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Pollution Prevention
Pollution Prevention.
Pollution Prevention.
Precipitation
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
-------
57562 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Benzyl((dodecylcarbamoyl) methyl)di methyl
ammonium chloride.
Cetyl pyridinium chloride
Alkyl* dimethyl ethyl ammonium bromide
*(85%C16, 15%C18).
Cetyl-N-ethylmorpholinium ethyl sulfate
Use code no 069102 (Alkenyl* Dimethyl
Ethyl Ammonium bromide).
p-Aminopyridine
Nitrapyrin (ANSI)
Alkyl pyridines
Pyrazon (ANSI)
Capsaicin (in oleoresin of capsicum)
Ryanodine
Silver
Silver chloride
Silver thiuronium acrylate co-polymer
Sodium chlorate
Calcium cyanide
Sodium cyanide
Cryolite
Sodium fluoride
Ammonium fluosilicate
Sodium fluosilicate
Potassium iodide
Potassium tetrathionate
Potassium nitrate
Sodium nitrate
Sodium nitrite
Benzenesulfonamide N-chloro- sodium salt
Salicyclic acid
Ethoxyethyl p-methoxycinnamate
Calcium polysulfide
Strychnine
Strychnine sulfate
Niclosamide
Dibromosalicylamilide
Tribromsalan
Dibromosalicylanilide
Chlorosalicylanilide
Sulfur
Sulfaquinoxaline
Sulfacetamide
Sulfuryl fluoride
Sodium bisulfite
Tetrachloroethylene
Ethoxylated isooctylphenol
Laurie diethanolamide
Triethanolamine oleate
Dioctyl sodium sulfosuccinate
Use code no 069179 (alkyl*mono-
ethanolamide).
Alkyl* diethanolamide *(70%C12 30%C14)
Tetradecyl formate
Polyoxyethylene sorbitol oleate-laurate
Polyethoxylated stearylamine
Capric diethanolamide
Calcium thiosulfate
Ammonium thiosulfate
Thymoxydichloroacetic acid
Thymol
Sodium trichloroacetate
Trichloroacetic acid
Hexahydro-1 3 5-tris(2-hydroxyethyl)-s-tri-
azine.
2-(Hydroxymethyl)-2-nitro-1 3-propanediol
Bomyl
Turpentine
Chloro-1-(2 5-dichlorophenyl)vinyl) O O-
diethyl phosphorothi.
Zinc chloride
PAI
code3
Shaughnessy
code4
69159
69160
69186
69187
69198
69201
69203
69205
69601
70701
71502
72501
72506
72701
73301
74001
74002
75101
75202
75301
75306
75701
75903
76103
76104
76204
76501
76202
76604
76702
76901
76902
77401
77402
77404
77405
77406
77501
77901
77904
78003
78201
78501
79004
79018
79025
79027
79036
79045
79069
79075
79094
79099
80101
80103
80401
80402
81001
81002
83301
83902
84201
84501
84901
87801
Structural group5
NR4
Pyridine
NR4
Heterocyclic
NR4
Pyridine
Pyridine
Pyridine
Heterocyclic
Phenol
Tri cyclic
Inorganic
Inorganic
Polymer
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Inorganic
Sulfonamide
Benzole Acid
Aryl
Polymer
Tri cyclic
Tricyclic
Chlorobenzamide
Chlorobenzamide
Chlorobenzamide
Chlorobenzamide
Chlorobenzamide
Inorganic
Sulfanilamide
Sulfanilamide
Inorganic
Inorganic
EDB
Phenol
Acetanilide
NR4
Thiosulfonate
Miscellaneous Organic
Miscellaneous Organic
Alkyl Acid
Polymer
Polymer
Acetanilide
Inorganic
Inorganic
Benzole Acid
Phenol
Alkyl Halide
Alkyl Halide
s-Triazine
Alcohol
Phosphate
Miscellaneous Organic
Phosphorothioate
Metallic
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Pollution Prevention.
Pollution Prevention.
Activated Carbon
Pollution Prevention.
Pollution Prevention
Pollution Prevention.
Pollution Prevention
Pollution Prevention.
Pollution Prevention
Pollution Prevention.
Pollution Prevention
Pollution Prevention.
Pollution Prevention
Pollution Prevention
Pollution Prevention.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Pollution Prevention
Activated Carbon
Activated Carbon.
Pollution Prevention.
Pollution Prevention
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Pollution Prevention
Pollution Prevention.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Precioitation.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57563
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Zinc 2-pyridinethiol-1 -oxide
Hydroxy-2-(1 H)-pyridinethione sodium salt
Omadine TBAO
Zinc naphthenate
Zinc oxide
Zinc phosphide (Zn3P2)
Zinc phenol sulfonate
Zinc sulfate basic
Dimetilan
Carboxin
Oxycarboxin
Benzocaine
Piperalin
Tetracaine hydrochloride
Formetanate hydrochloride
Azacosterol HCI
Use code no 039502 (gentian violet)
Ammonium alum
Bismuth subgallate
Chlorflurenol methyl ester
Benzisothiazolin-3-one
Methyl 2-benzimidazolecarbamate phos-
phate.
Ethephon
Pentanethiol
Nitrobutyl)morpholine
Ethyl-2-nitrotrimethylene)dimorpholine
Tolyl diiodomethyl sulfone
Isobutyric acid
Dibromo-3-nitrilopropionamide
Polyethoxylated oleylamine
Dinitramine (ANSI)
Phenylethyl propionate
Eugenol
Tricosene
Tricosene
Sodium 1 4' 5'-trichloro-2'-(2 4 5-
trichlorophenoxy)methanes.
Hexahydro-1 3 5-tris(2-hydroxypropyl)-s-tri-
azine.
Methazole
Difenzoquat methyl sulfate
Butralin
Fosamine ammonium
Asulam
Sodium asulam
Hydroxymethoxymethyl-1 -aza-3 7-dioxabicy-
clo(3.3.0)octane.
Hydroxymethyl-1 -aza-3 7-dioxabicy-
clo(3.3.0)octane.
Hydroxypoly(methyleneoxy)* methyl-1 -aza-
3,7-dioxabicyclo(3.3).
Chloro-2-methyl-3(2H)-isothiazolone
Methyl-3(2H)-isothiazolone
Trimethoxysilyl)propyl dimethyl octadecyl
ammonium chloride.
Kinoprene
Triforine (ANSI)
Pirimiphos-methyl (ANSI)
Thiobencarb
Ancymidol (ANSI)
Oxadiazon (ANSI)
Mepiquat chloride
Fluvalinate
Chloro-N-(hydroxymethyl)acetamide
Dikegulac sodium
Iprodione (ANSI)
Phenylmethyl)-9-(tetrahydro-2H-pyran-2-yl)-
9H-purin-6-amine.
Prodiamine
Erioalaucine
PAI
code3
Shaughnessy
code4
88002
88004
88005
88301
88502
88601
89002
89101
90101
90201
90202
97001
97003
97005
97301
98101
98401
98501
98601
98801
98901
99102
99801
100701
100801
1 00802
101002
1 01 502
101801
101901
102301
102601
102701
103201
1 03202
104101
105601
106001
106401
106501
106701
106901
1 06902
107001
1 07002
1 07003
107103
107104
107401
1 07502
107901
108102
108401
108601
109001
109101
1 09302
109501
109601
109801
110001
110201
110301
Structural group5
Metallic
Pyridine
Pyridine
Metallic
Metallic
Metallic
Metallic
Metallic
Carbamate
Heterocyclic
Heterocyclic
Benzeneamine
24-D
Benzeneamine
Toluamide
Tricyclic
NR4
Inorganic
Metallic
Aryl Halide
Heterocyclic
Carbamate
Phosphate
Miscellaneous Organic
Heterocyclic
Heterocyclic
Thiosulfonate
Alkyl Acid
Acetamide
Acetamide
Nitrobenzoate
Phenylcrotonate
Phenol
Miscellaneous Organic
Miscellaneous Organic
24-D
s-Triazine
Hydrazide
Hydrazide
Benzeneamine
Carbamate
Carbamate
Carbamate
Bicyclic
Bicyclic
Bicyclic
Heterocyclic
Heterocyclic
NR4
Ester
Hydrazide
Phosphorothioate
Thiocarbamate
Pyrimidine
Hydrazide
NR4
Toluamide
Acetamide
Tricyclic
Hydrazide
Pyrimidine
Benzeneamine
Benzeneamine
Treatment technology
Precipitation.
Activated Carbon
Activated Carbon.
Precipitation
Precipitation.
Precipitation
Precipitation
Precipitation.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Pollution Prevention.
Precipitation.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
-------
57564 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Tartrazine
Dodemorph acetate
Ethofumesate (ANSI)
Aldoxycarb (ANSI)
Diclofop-methyl
Bromo-1-(bromomethyl)-1 3-
propanediCarbon.it rile.
Poly (imino imidocar-
bonyliminoimidocar-
bonyliminohexamethylene).
Imazalil
Bromadiolone
Brodifacoum
Bromethalin (ANSI)
Fluridone (ANSI)
Vinclozolin
Metalaxyl
Propetamphos (ANSI)
Methyl-1 -naphthyl)maleimide
Hexadecadien-1-yl acetate
Hexadecadien-1-yl acetate
Epoxy-2-methyloctadecane
Thiodicarb (ANSI)
Dimethyloxazolidine (8CA & 9CA)
Trimethyloxazolidine
Hydroxyphenyl)oxoacetohydroximic chloride
EEEBC
MDM Hydantoin
DMDM Hydantoin
Triclopyr (ANSI)
Triethylamine triclopyr
Butoxyethyl triclopyr
Decenyl)dihydro-2(3H)-furanone
Cytokinins
Benzyladenine
Clopyralid monoethanolamine salt
Clopyralid (ANSI)
Flucythrinate (ANSI)
Hydra methyl no n (ANSI)
Chlorsulfuron
Dimethipin
Hexadecenal
Tetradecenal
Thidiazuron
Metronidazole
Erythrosine B
Sethoxydim
Clethodim
Cyromazine
Tralomethrin
Azadirachtin
Tridecen-1-yl acetate
Tridecen-1-yl acetate
Sulfometuron methyl
Metsulfuron-methyl
Propiconazole
Furanone dihydro-5-pentyl
Furanone 5-heptyldihydro-
Abamectin (ANSI)
Fluazifop-butyl
Fluazifop-R-butyl
Flumetralin
Fosetyl-AI
Methanol, (((2-(dihydro-5-methyl-3(2H)-
oxazolyl)-! -methyl)et.
Fomesafen
Tridiphane
POE isooctadecanol
Periplanone B
Fenoxycarb
Clomazone
PAI
code3
Shaughnessy
code4
110302
110401
110601
110801
110902
111001
111801
111901
112001
112701
1 1 2802
112900
113201
113501
113601
113701
114101
114102
114301
114501
114801
1 1 4802
114901
115001
115501
115502
116001
1 1 6002
1 1 6004
116501
116801
116901
117401
117403
118301
118401
118601
118901
120001
1 20002
120301
120401
120901
121001
121011
121301
121501
121701
121901
121902
122001
122010
122101
122301
1 22302
122804
122805
122809
123001
123301
1 23702
123802
123901
124601
124801
125301
125401
Structural group5
Hydrazide
Heterocyclic
Bicyclic
Carbamate
Aryl Halide
Isocyanate
Polymer
Aryl Halide
Coumarin
Coumarin
Aryl Amine
Aryl Halide
Aryl Halide
Benzeneamine
Phosphoroamidothioate
Phthalamide
Ester
Ester
Heterocyclic
Thiocarbamate
Heterocyclic
Heterocyclic
Phenol
Carbamate
Hydrazide
Hydrazide
Pyridine
Pyridine
Pyridine
Ester
Toluidine
Pyrimidine
Pyridine
Pyridine
Pyrethrin
Iminimide
s-Triazine
Heterocyclic
Miscellaneous Organic
Miscellaneous Organic
Urea
Hydrazide
Tri cyclic
Cyclic Ketone
Heterocyclic
s-Triazine
Pyrethrin
Tricyclic
Ester
Ester
Pyrimidine
s-Triazine
Aryl Halide
Cyclic Ketone
Cyclic Ketone
Tricyclic
Pyridine
Pyridine
Nitrobenzoate
Phosphate
Heterocyclic
Nitrobenzoate
Aryl Halide
Alcohol
Bicyclic
Carbamate
Arvl Halide
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
-------
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57565
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Clofentezine
Paclobutrazol
Flurprimidol
Isoxaben
Isazofos
Triadimenol
Fenpropathrin
Sulfosate
Fenoxaprop-ethyl
Quizalofop-ethyl
Bensulfuron-methyl
Imazapyr
Bifentnrin
Imazapyr, isopropylamine salt
Sodium salt of 1 -carboxymethyl-3 5 7-triaza-
1-azoniatricyclo.
Linalool
Imazaquin monoammonium salt
Imazethabenz
Thifensulfuron methyl
Imazaquin
Myclobutanil (ANSI)
Zinc borate (3ZnO, 2B03, 3.5H2O; mw
434.66).
Cyhalothrin
Potassium cresylate
Triflumizole
Tribenuron methyl
Cyhalothrin
Chlorimuron-ethyl
Dodecen-1-yl acetate
Dodecen-1-yl acetate
DDOL
Farnesol
Nerolidol
Tefluthrin
Bromoxynil heptanoate
Imazethapyr
Imazethapyr, ammonium salt
Chitosan
Sulfuric acid monourea adduct
Hydro prene
Triasulfuron
Primisulfuron-methyl
Uniconazole (ANSI)
Tetradecenyl acetate
Chitin
Sulfluramid
Dithiopyr (ANSI)
Nicosulfuron
Zinc
Tetradecen-1-ol, acetate, (E)-
Imazaquin sodium salt
Dodecadien-1-ol
lonone
Dicamba, aluminum salt
Benzenemethanaminium N-(2-((2 6-
dimethylphenyl)amino)-2-oxo.
Fenoxaprop-p-Ethyl
Alkyl* bis(2-hydroxyethyl) ammonium ace-
tate *(as in fatty ac.
Alkenyl* dimethyl ammonium acetate *(75%
C18', 25% C16').
Amines, N-coco alkyltrimethylenedi-,
adipates.
Dialkyl* dimethyl ammonium bentonite *(as
in fatty acids of.
Alkyl* bis(2-hydroxyethyl) amine acetate
*(65% C18, 30% C16,.
Dodecyl bis(hydroxy ethyl) dioctyl ammo-
nium phosphate.
PAI
code3
Shaughnessy
code4
125501
125601
125701
125851
126901
127201
127901
128501
128701
1 2871 1
128820
128821
128825
1 28829
1 28832
1 28838
1 28840
1 28842
1 28845
1 28848
1 28857
128859
128867
128870
1 28879
1 28887
128897
128901
128906
128907
1 28908
1 2891 0
1 2891 1
1 2891 2
128920
128922
128923
1 28930
128961
128966
128969
128973
1 28976
1 28980
128991
1 28992
1 28994
129008
129015
1 2901 9
1 29023
1 29028
1 29030
129042
1 29045
1 29092
169103
169104
169109
169111
169125
169154
Structural group5
Aryl Halide
Hydrazide
Pyrimidine
Heterocyclic
Phosphorothioate
Hydrazide
Pyrethrin
Phosphorothioate
Heterocyclic
Phthalimide
Pyrimidine
Hydrazide
Pyrethrin
Hydrazide
s-Triazine
Alcohol
Pyrimidine
Pyrimidine
s-Triazine
Pyrimidine
s-Triazine
Metallic
Pyrethrin
Phenol
Toluidine
s-Triazine
Pyrethrin
Pyrimidine
Ester
Ester
Alcohol
Alcohol
Alcohol
Pyrethrin
Chloropropionanilide
Pyrimidine
Pyrimidine
Polymer
Urea
Miscellaneous Organic
Urea
Urea
s-Triazine
Miscellaneous Organic
Polymer
Sulfonamide
Pyridine
Pyrimidine
Metallic
Alkyl Acid
Pyrimidine
Alcohol
Miscellaneous Organic
Aryl Halide
NR4
Tricyclic
NR4
NR4
Iminamide
NR4
Acetamide
NR4
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Precipitation.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon
Precipitation.
Activated Carbon.
Activated Carbon
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon
-------
57566 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
TABLE 10 TO PART 455.—LIST OF APPROPRIATE POLLUTION CONTROL TECHNOLOGIES"!—Continued
PAI name2
Dodecyl bis(2-hydroxyethyl) octyl hydrogen
ammonium phosphat.
Didecyl-N-methyl-3-
(trimethoxysilyl)propanaminium chloride.
Cholecalciferol
Use code no. 202901 (Vitamin D3)
Alkyl* N N-bis(2-hydroxyethyl)amine "(100%
C8-C18).
Bromo-2-nitropropane-1 ,3-diol
Use code no. 114601 (cyclohexyl-4, 5-
dichloro- 4-isothioazolin-3-one).
Diethatyl ethyl
Hydroprene (ANSI)
Zinc sulfate monohydrate
Geraniol
PAI
code3
Shaughnessy
code4
169155
169160
202901
208700
210900
216400
229300
279500
486300
527200
597501
Structural group5
NR4
NR4
Bicyclic
Bicyclic
NR4
Alcohol
Heterocyclic
Toluidine
Miscellaneous Organic
Metallic
Alcohol
Treatment technology
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Activated Carbon.
Activated Carbon
Activated Carbon.
Precipitation
Activated Carbon.
1 The 272 Pesticide Active Ingredients (PAIs) are listed first, by PAI code, followed by the non-272 PAIs from the 1988 FIFRA and TSCA En-
forcement System (FATES) Database, which are listed in Shaughnessy code order. PAIs that were exempted or reserved from the PFPR efflu-
ent guidelines are not listed in the table.
2 The non-272 PAI names are taken directly from the 1988 FATES database. Several of the PAI names are truncated because the PAI names
listed in the FATES database are limited to 60 characters.
3 The non-272 PAIs do not have PAI codes.
4AII Shaughnessy codes are taken from the 1988 FATES database. Some of the 272 PAIs are not listed in the 1988 FATES database; there-
fore, no Shaughnessy codes are listed for these PAIs.
5 Structural groups are based on an analysis of the chemical structures of each PAI.
6 EPA has also received data indicating that acid hydrolysis may also be effective in treating this PAI.
"This PAI code represents a category or group of PAIs; therefore, it has multiple Shaughnessy codes.
[FRDoc. 96-25771 Filed 11-5-96; 8:45 am]
BILLING CODE 6560-50-P
-------
1
A of
1 of P2,
C of
D of
Technologies
E of
213
-------
Table A: Identification of Wastewater Sources
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2.a.
2.b.
3.a.
3.b.
3.c.
3.d.
Batch or
Continuous
Location:
Prepared by:
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management
Comments
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
215
-------
Table A: Identification of Wastewater Sources
Facility:
Date:
Stream Type
4. Packaging Equipment Interior
Cleaning - routine cleaning,
cleaning due to product
changeover, or special cleaning
of the interior of any packaging
equipment, including filling or
storage tanks,pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
5. Repackaging Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any repackaging
equipment, including filling
or storage tanks, pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
6. Aerosol (DOT) Leak Testing -
water used to perform aerosol leak
tests for Department of
Transportation (DOT)
requirements (when cans have
burst).
Source
4.a.
4.b.
4.c.
5. a.
5.b.
5.c.
5.d.
6.a.
6.b.
Batch or
Continuous
Location:
Prepared by:
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management
Comments
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
216
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
7. Exterior Equipment Cleaning -
cleaning of the exterior of any
formulating, packaging, or
repackaging equipment, including
tanks, pipes, hoses, conveyors, etc.
Cleaning materials may include
water, detergent, or solvent.
8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
operations areas.
9. Floor Washing - cleaning of
floors in the PFPR operations
areas.
Source
7.a.
7.b.
7.c.
8.a.
8.b.
9.a.
9.b.
9.c.
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management
Comments
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
217
-------
Table A: Identification of Wastewater Sources
Facility:
Date:
Stream Type
10. Leaks and Spills - cleaning of
leaks and/or spills which occur
during PFPR operations.
11. Safety Equipment Cleaning -
cleaning of personal protective
equipment (e.g., gloves, splash
aprons, boots, respirators)
worn by employees in PFPR
operations areas.
12. Air Pollution Control
Scrubbers - wet scrubbers used to
control air emissions from PFPR
operations.
13. Laboratory Equipment
Cleaning - Initial rinse of the retain
sample container.
Source
lO.a.
lO.b.
ll.a.
ll.b.
12.a.
13.a.
Batch or
Continuous
Location:
Prepared by:
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management
Comments
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
218
-------
Table A: Identification of Wastewater Sources
Facility:
Date:
Stream Type
Source
Batch or
Continuous
Location:
Prepared by:
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management
Comments
Other streams not specifically included in the P2 Alternative
14. Contaminated Precipitation
Runoff- runoff from raw material
storage, loading pads, final product
storage, and outdoor
production areas.
15. Laboratory Equipment
Cleaning - Water used to clean
analytical equipment and
glassware.
16. Aerosol (DOT) Leak Testing -
Water used in non-continuous
overflow baths to perform aerosol
leak tests for DOT requirements
when no cans have burst from the
last water change out.
17. Other Sources - other sources
of waste not specifically mentioned
(please specify).
14.a.
14.b.
15.a.
16.a.
16.b.
17.a.
17.b.
17.c.
1 Inerts (e.g., emulsifiers, surfactants), solids, detergent, etc.
2 RE=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
219
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Table 8
Listed
Practice1
Practice
Does
Facility
Use this
Practice?
Source Code
from
Table A
1. Flow Reduction
1-1
1-2
1-3
1
1
3
Hoses used for rinsing have spray nozzles
or other flow reduction devices.
Low- volume/high-pressure rinsing
equipment is used for rinsing PFPR
equipment interiors (specify type of
equipment) when rinsing with water.
A floor scrubbing machine and/or mop
and bucket is used to clean floors in
liquid production areas.
Dry production areas are swept or
vacuumed prior to rinsing with water.
Dry production areas are rinsed with
water.
2. Good Housekeeping Practices
2-1
2-2
2-3
2a
2b
2c
Facility performs preventive maintenance
on valves and fittings and repairs leaks in
a timely manner.
Facility places drip pans under valves and
fittings where hoses and lines are
routinely connected and disconnected.
Facility immediately cleans up spills and
leaks in outdoor bulk storage and process
areas.
3. DOT Test Bath
3-1
5
Facility operates continuous overflow test
baths with some recirculation of water.
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
40 CFR 455.67
Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.) 221
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Table 8
Listed
Practice1
Practice
Does
Facility
Use this
Practice?
Source Code
from
Table A
4. Air Pollution Controls
4-1
6
Facility operates wet scrubbers with
recirculation (periodic blowdown is
allowed as needed).
5. Reuse of Drum Rinsate of Water-Based Products
5-1
5-2
5-3
7
7
1J
6. Drum Rinsing
6-1
6-2
6-3
8
8
NA
Facility reuses drum/shipping container
rinsate directly into product formulations.
Facility stores drum/shipping container
rinsate for use in future formulations of
same or compatible products.
Facility operates a staged drum rinsing
station (countercurrent rinsing).
for Formulation of Solvent-Based Products
Facility reuses drum/shipping container
rinsate directly into product formulations.
Facility stores drum/shipping container
rinsate for use in future formulations of
same or compatible products.
Facility uses base solvent to rinse drums.
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
1 40 CFR 455.67
2 Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
222
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Table 8
Listed
Practice1
Practice
Does
Facility
Use this
Practice?
Source Code
from
Table A
7. Dedicated Equipment for Solvent- and Water-Based Products
7-1
9
Facility dedicates PFPR production
equipment to water-based vs. solvent-
based products. Dedicated solvent-based
or water-based equipment may be used on
a non-routine basis for non-dedicated
operations, but facility may not discharge
the aqueous changeover rinsate as part of
their P2 allowable discharge.
8. Interior Rinsate Storage and Reuse
8-1
8-2
8-3
10
4
4
Interior rinsate is stored for reuse in
future formulations of the same or
compatible product (note: does not
include drum/shipping container rinsate).
Dry carrier material is stored and reused
in future formulation of the same or
compatible product or disposed of as
solid waste.
Interiors of dry formulation equipment
are cleaned with dry carrier prior to water
rinse.
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
40 CFR 455.67
Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
223
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Table 8
Listed
Practice1
Practice
Does
Facility
Use this
Practice?
Source Code
from
Table A
9. Dedicated Process Equipment
9-1
9-2
NA
NA
Facility dedicates some portion of
equipment to:
i. Top production products
ii. Hard-to-clean products
iii. Product families (attach definition
of product families)
Facility sequences production on
dedicated process equipment.
10. Inventory Management
10-1
10-2
NA
NA
Facility has an inventory management
system for raw material, product, and
wastewater rinsate.
System includes one or more of the
following:
i. Central storage and access controls.
ii. Computerized inventory control.
iii. Protection from precipitation.
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
1 40 CFR 455.67
2 Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.) 224
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Table 8
Listed
Practice1
Practice
Does
Facility
Use this
Practice?
Source Code
from
Table A
11. Training and Written Standard Operating Procedures
11-1
11-2
11-3
NA
NA
NA
Facility provides personnel with P2
training.
Facility has employee incentive programs
encouraging P2.
Facility has documentation of P2
practices and procedures.
12. Other P2 Practices/Equipment
12-1
12-2
12-3
12-4
12-5
12-6
NA
NA
NA
NA
NA
NA
Location:
Prepared by:
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
1 40 CFR 455.67
2 Insert the following modification codes in the column titled "Required Justification for Modification":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
225
-------
Modification Code Sheet
Table B
Practice
1-1
4-1
5-1 to 5-3
6-1 to 6-3
7-1
8-1
NA
Table 8
Listed
Practice
1
6
7
8
9
10
NA
Modification
Code
NARROW
BREAKCAA
INERT
REFURB
INERT
RECOVERY
ALTDISPOSE
BIOGROWTH
DETERGENT
DROP
PACKAGE
SPACE
OTHER1
Description
Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by
flushing with water.
Facility demonstrates that would not be able to meet Resource Conservation Recovery
Act (RCRA) or Clean Air Act (CAA) requirements.
Drum/shipping container holds inert ingredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused; or
(2) the facility can demonstrate that the concentration of the inert in the formulation is so
small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158.155).
Drums/shipping containers are going to a drum refurbisher/recycler who will only accept
drums rinsed with water.
Drum/shipping container holds inert ingredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused; or
(2) the facility can demonstrate that the concentration of the inert in the formulation is so
small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158.155).
Facility has installed and is using a solvent recovery system for the changeover rinsate
(can also be used for other solvent recovery).
PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise
(i.e., send back to them or send for off-site disposal).
Facility has evidence of biological growth or product deterioration over a typical storage
period (review facility data).
Facility has demonstrated that it must use a detergent to clean equipment.
Facility is dropping registration or production of the formulation and there is no
compatible formulation for reuse of the rinsates or facility can provide reasonable
explanation of why it does not anticipate formulation of same or compatible
formulation within the next twelve months.
Facility only performs packaging of the pesticide product from which interior rinsate is
generated.
Facility has space limitations, BUT must still store rinsates for most frequently produced
products.
Other practices must be approved by the permitting/control authority prior to discharge.
226
-------
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include water, detergent, or
solvent.
Source
l.a.
l.b.
2.a.
2.b.
3.a.
3.b.
3.c.
3.d.
Location:
Prepared by:
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
Insert the following modification codes in the column titled "Comments":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
227
-------
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
4. Packaging Equipment Interior
Cleaning - routine cleaning,
cleaning due to product
changeover, or special cleaning
of the interior of any packaging
equipment, including filling or
storage tanks,pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
5. Repackaging Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any repackaging
equipment, including filling
or storage tanks, pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
6. Aerosol (DOT) Leak Testing -
water used to perform aerosol leak
tests for Department of
Transportation (DOT)
requirements (when cans have
burst).
Source
4.a.
4.b.
4.c.
5.a.
5.b.
5.c.
5.d.
6.a.
6.b.
Location:
Prepared by:
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
Insert the following modification codes in the column titled "Comments":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
228
-------
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
7. Exterior Equipment Cleaning -
cleaning of the exterior of any
formulating, packaging, or
repackaging equipment, including
tanks, pipes, hoses, conveyors, etc.
Cleaning materials may include
water, detergent, or solvent.
8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
operations areas.
9. Floor Washing - cleaning of
floors in the PFPR operations
areas.
Source
7.a.
7.b.
I.e.
8.a.
8.b.
9.a.
9.b.
9.c.
Location:
Prepared by:
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
Insert the following modification codes in the column titled "Comments":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
229
-------
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
10. Leaks and Spills - cleaning of
leaks and/or spills which occur
during PFPR operations.
11. Safety Equipment Cleaning -
cleaning of personal protective
equipment (e.g., gloves, splash
aprons, boots, respirators)
worn by employees in PFPR
operations areas.
12. Air Pollution Control
Scrubbers - wet scrubbers used to
control air emissions from PFPR
operations.
13. Laboratory Equipment
Cleaning - Initial rinse of the retain
sample container.
Source
lO.a.
lO.b.
ll.a.
ll.b.
12.a.
13.a.
Location:
Prepared by:
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
Insert the following modification codes in the column titled "Comments":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
230
-------
Table C: Summary of PFPR Compliance Decisions
Facility:
Date:
Stream Type
Source
Location:
Prepared by:
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
Other streams not specifically included in the P2 Alternative
14. Contaminated Precipitation
Runoff- runoff from raw material
storage, loading pads, final product
storage, and outdoor
production areas.
15. Laboratory Equipment
Cleaning - Water used to clean
analytical equipment and
glassware.
16. Aerosol (DOT) Leak Testing -
Water used in non-continuous
overflow baths to perform aerosol
leak tests for DOT requirements
when no cans have burst from the
last water change out.
17. Other Sources - other sources
of waste not specifically mentioned
(please specify).
14.a.
14.b.
15.a.
16. a.
16.b.
17.a.
17.b.
17.c.
Insert the following modification codes in the column titled "Comments":
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code.)
231
-------
Modification Code Sheet
Table B
Practice
1-1
4-1
5-1 to 5-3
6-1 to 6-3
7-1
8-1
NA
Table 8
Listed
Practice
1
6
7
8
9
10
NA
Modification
Code
NARROW
BREAKCAA
INERT
REFURB
INERT
RECOVERY
ALTDISPOSE
BIOGROWTH
DETERGENT
DROP
PACKAGE
SPACE
OTHER1
Description
Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by
flushing with water.
Facility demonstrates that would not be able to meet Resource Conservation Recovery
Act (RCRA) or Clean Air Act (CAA) requirements.
Drum/shipping container holds inert ingredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused; or
(2) the facility can demonstrate that the concentration of the inert in the formulation is so
small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158.155).
Drums/shipping containers are going to a drum refurbisher/recycler who will only accept
drums rinsed with water.
Drum/shipping container holds inert ingredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused; or
(2) the facility can demonstrate that the concentration of the inert in the formulation is so
small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158.155).
Facility has installed and is using a solvent recovery system for the changeover rinsate
(can also be used for other solvent recovery).
PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise
(i.e., send back to them or send for off-site disposal).
Facility has evidence of biological growth or product deterioration over a typical storage
period (review facility data).
Facility has demonstrated that it must use a detergent to clean equipment.
Facility is dropping registration or production of the formulation and there is no
compatible formulation for reuse of the rinsates or facility can provide reasonable
explanation of why it does not anticipate formulation of same or compatible
formulation within the next twelve months.
Facility only performs packaging of the pesticide product from which interior rinsate is
generated.
Facility has space limitations, BUT must still store rinsates for most frequently produced
products.
Other practices must be approved by the permitting/control authority prior to discharge.
232
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type1
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the containers used to ship raw
material, finished products, and/or
waste products prior to reuse or
disposal of the containers.
2. Bulk Tank Rinsate - cleaning
of the interior of any bulk storage
tank containing raw materials,
intermediate blends, or finished
products associated with PFPR
operations.
3. Formulating Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any formulating
equipment, including formulation
and/or storage tanks, pipes, and
hoses. Cleaning materials may
include -water, detergent, or
solvent.
Source
l.a.
l.b.
2.a.
2.b.
3.a.
3.b.
3.c.
3.d.
Potential Pollutants
Active
Ingredients
Other
Pollutants
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology2
Alternate
Treatment
Technology2
Source for
Alternative Technology
Characteristics That
Hinder Treatment
Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards; however, facilities may be required to perform pretreatment
by the control authority to meet local limits. Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment.
HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
233
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type1
4. Packaging Equipment Interior
Cleaning - routine cleaning,
cleaning due to product
changeover, or special cleaning
of the interior of any packaging
equipment, including filling or
storage tanks,pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
5. Repackaging Equipment
Interior Cleaning - routine
cleaning, cleaning due to product
changeover, or special cleaning of
the interior of any repackaging
equipment, including filling
or storage tanks, pipes, and hoses.
Cleaning materials may include
water, detergent, or solvent.
"6. Aerosol (DOT) Leak Testing -
•water used to perform aerosol leak
tests for Department of
Transportation (DOT) requirements
(•when cans have burst).
Source
4. a.
4.b.
4.c.
5. a.
5.b.
5.c.
6. a.
6.b.
Potential Pollutants
Active
Ingredients
Other
Pollutants
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology2
Alternate
Treatment
Technology2
Source for
Alternative Technology
Characteristics That
Hinder Treatment
Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards; however, facilities may be required to perform pretreatment
by the control authority to meet local limits. Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment.
HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
234
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type1
+7. Exterior Equipment Cleaning
- cleaning of the exterior of any
formulating, packaging, or
repackaging equipment, including
tanks, pipes, hoses, conveyors, etc.
Cleaning materials may include
water, detergent, or solvent.
+8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
operations areas.
9. Floor Washing - cleaning of
floors in the PFPR operations
areas.
Source
7.a.
7.b.
I.e.
8.a.
8.b.
9.a.
9.b.
9.c.
Potential Pollutants
Active
Ingredients
Other
Pollutants
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology2
Alternate
Treatment
Technology2
Source for
Alternative Technology
Characteristics That
Hinder Treatment
Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards; however, facilities may be required to perform pretreatment
by the control authority to meet local limits. Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment.
HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
235
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type1
10. Leaks and Spills - cleaning of
leaks and/or spills -which occur
during PFPR operations.
*11. Safety Equipment Cleaning -
cleaning of personal protective
equipment (e.g., gloves, splash
aprons, boots, respirators)
•worn by employees in PFPR
operations areas.
*12. Air Pollution Control
Scrubbers - wet scrubbers used to
control air emissions from PFPR
operations.
*13. Laboratory Equipment
Cleaning - Initial rinse of the
retain sample container.
Source
lO.a.
lO.b.
11. a.
ll.b.
12.a.
13.a.
Potential Pollutants
Active
Ingredients
Other
Pollutants
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology2
Alternate
Treatment
Technology2
Source for
Alternative Technology
Characteristics That
Hinder Treatment
1 Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards; however, facilities may be required to perform pretreatment
by the control authority to meet local limits. Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment.
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
236
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Stream Type
Source
Potential Pollutants
Active
Ingredients
Other
Pollutants
Location:
Prepared by:
Wastewater Treatment Information
Table 10
Technology
Alternate
Treatment
Technology
Source for
Alternative Technology
Characteristics That
Hinder Treatment
Other streams not specifically included in the P2 Alternative
*14. Contaminated Precipitation
Runoff - runoff from raw material
storage, loading pads, final product
storage, and outdoor
production areas.
*15. Laboratory Equipment
Cleaning - Water used to clean
analytical equipment and
glassware.
*16. Aerosol (DOT) Leak Testing
Water used in non-continuous
overflow baths to perform aerosol
leak tests for DOT requirements
when no cans have burst from the
last -water change out.
17. Other Sources - other sources
of -waste not specifically mentioned
(please specify).
14. a.
14.b.
15.a.
16. a.
16.b.
17.a.
17.b.
17.c.
Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards; however, facilities may be required to perform pretreatment
by the control authority to meet local limits. Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment.
HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
237
-------
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared by:
Insert vour optimal treatment train and oneratine narameters in the snace nrovided below:
Technology
Primary
Constituents
Design and Operating Parameters
PH
Temperature
(°C)
Other
Other
Other
Constituent Concentration
Influent
(ug/L)
Effluent
(ug/L)
Performance Measures
Percent
Removal
Other
Effectively
Treated?
(Y/N)
239
-------
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Technology
Location:
Prepared by:
Primary
Constituents
Design and Operating Parameters
PH
Temperature
(°C)
Other
Other
Other
Constituent Concentration
Influent
(ug/L)
Effluent
(ug/L)
Performance Measures
Percent
Removal
Other
Effectively
Treated?
(Y/N)
240
-------
c
Table 10 to Part 455 (with CAS
Numbers)
241
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Dicofol
Maleic Hydrazide
EDB
Vancide TH
1,3 Dichloropropene
Thenarsazine Oxide
Dowicil 75
Triadimefon
Hexachlorophene
Tetrachlorophene
Dichlorophene
Dichlorvos
Landrin 2
2,3,6T, S&E orFenac
2,4, 5 land 2,4, 5 T, S&E
2,4 D (2,4 D, S&E)
2,4 DB, S&E
Dyrene or Anilazine
Dinocap
Dichloran or DCNA
Busan 90
Mevinphos
Sulfallate
Chlorfenvinphos
Cyanazine or Bladex
Propachlor
MCPA, S&E
Octhilinone
Pindone
Dichlorprop, S&E
MCPP, S&E or Mecoprop
Thiabendazole
Belclene 310
Chlorprop, S&E
Busan 72 orTCMTB
Chlorophacinone
Landrin 1
Pronamide
Methiocarb or Mesurol
Propanil
Polyphase
Coumafuryl or Fumarin
DNOC
Metribuzin
CPA, S&E
PAI Code3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
37
38
39
40
41
42
43
44
45
46
Shaughnessy
Code4
010501
051501
042002
082901
029001
012601
017901
109901
044901
055001
084001
102402
082605
*
*
*
080811
036001
031301
008707
015801
039001
084101
100101
019101
*
099901
067703
*
*
060101
080815
021202
035603
067707
102401
101701
100501
028201
107801
086001
037507
101101
*
CAS
Number5
115-32-2
123-33-1
106-93-4
7779-27-3
542-75-6
58-36-6
4080-31-3
43121-43-3
70-30-4
97-23-4
62-73-7
2655-15-4
69462-13-1
*
*
*
101-05-3
39300-45-3
99-30-9
2491-38-5
7786-34-7
95-06-7
470-90-6
21725-46-2
1918-16-7
*
26530-20-1
83-26-1
*
*
148-79-8
22936-75-0
53404-22-1
21564-17-0
3691-35-8
2686-99-9
23950-58-5
2032-65-7
709-98-8
55406-53-6
117-52-2
534-52-1
21087-64-9
*
243
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
MCPB, S&E
Aminocarb
Etridiazole
Ethoxyquin
Acephate or Orthene
Acifluorfen
Alachlor
Aldicarb
Allethrin
Ametryn
Amitraz
Atrazine
Bendiocarb
Benomyl
BHC
Benzyl Benzoate
Lethane 60
Bifenox
Biphenyl
Bromacil (Lithium Salt)
Bromoxynil
Butachlor
Giv gard
Cacodylic Acid
Captafol
Captan
Carbaryl
Carbofuran
Carbosulfan
Chloramben
Chlordane
Chloroneb
Chloropicrin
Chlorothalonil
Chloroxuron
Stirofos
Chlorpyrifos Methyl
Chlorpyrifos
Mancozeb
Bioquin (Copper)
Copper EDTA
Pydrin or Fenvalerate
Cycloheximide
Dalapon
Dienochlor
PAI Code3
47
48
49
50
52
53
54
55
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
Shaughnessy
Code4
019202
044401
084701
055501
103301
114402
090501
098301
*
080801
106201
080803
105201
099101
008901
009501
010101
104301
017002
012302
*
112301
101401
*
081701
081301
056801
090601
090602
*
058201
027301
081501
081901
025501
083701
059102
059101
014504
024002
039105
109301
043401
*
027501
CAS
Number5
6062-26-6
2032-59-9
2593-15-9
91-53-2
30560-19-1
62476-59-9
15972-60-8
116-06-3
*
834-12-8
33089-61-1
1912-24-9
22781-23-3
17804-35-2
608-73-1
120-51-4
301-11-1
42576-02-3
92-52-4
53404-19-6
*
23184-66-9
7166-19-0
*
2939-80-2
133-06-2
63-25-2
1563-66-2
55285-14-8
*
57-74-9
2675-77-6
76-06-2
1897-45-6
1982-47-4
961-11-5
5598-13-0
2921-88-2
8018-01-7
10380-28-6
12276-01-6
51630-58-1
66-81-9
*
2227-17-0
244
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Demeton
Desmedipham
Amobam
DBCP
Dicamba
Dichlone
Thiophanate Ethyl
Perthane
EXD
Diazinon
Diflubenzuron
Dimethoate
Parathion Methyl
Dicrotophos
Crotoxyphos
DCPA
Trichlorofon
Dinoseb
Dioxathion
Diphacinone
Diphenamide
Diphenylamine
MGK 326
Nabonate
Diuron
Metasol DGH
Dodine
Endosulfan
Endothall (Endothall S&E)
Endrin
Ethalfluralin
Ethion
Ethoprop
Fenamiphos
Chlorobenzilate
Butylate
Famphur
Fenarimol
Fenthion or Baytex
Ferbam
Fluometuron
Fluoroacetamide
Folpet
Glyphosate (Glyphosate S&E)
Glyphosine
PAI Code3
94
95
96
97
98
99
100
101
102
103
104
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
Shaughnessy
Code4
057601
104801
014502
011301
*
029601
103401
032101
086501
057801
108201
035001
053501
035201
058801
078701
057901
037505
037801
067701
036601
038501
047201
063301
035505
044303
044301
079401
*
041601
113101
058401
041101
100601
028801
041405
059901
206600
053301
034801
035503
075002
081601
*
103602
CAS
Number5
8065-48-3
13684-56-5
3566-10-7
96-12-8
*
117-80-6
23564-06-9
72-56-0
502-55-6
333-41-5
35367-38-5
60-51-5
298-00-0
141-66-2
7700-17-6
1861-32-1
52-68-6
88-85-7
78-34-2
82-66-6
957-51-7
122-39-4
136-45-8
138-93-2
330-54-1
13590-97-1
2439-10-3
115-29-7
*
72-20-8
55283-68-6
563-12-2
13194-48-4
22224-92-6
510-15-6
2008-41-5
52-85-7
60168-88-9
55-38-9
14484-64-1
2164-17-2
640-19-7
133-07-3
*
2439-99-8
245
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Heptachlor
Cycloprate
Hexazinone
Isofenphos
Isopropalin
Propham
Karabutilate
Lindane
Linuron
Malachite Green
Malathion
Maneb
Manam
Mefluidide
Methamidophos
Methidathion
Methomyl
Methoprene
Methoxychlor
Methyl Bromide
Monosodium Methyl Arsenate
Nalco D 2303
Quinomethionate
Metolachlor
Mexacarbate
Metiram
Monuron TCA
Monuron
Napropamide
Deet
Nabam
Naled
Norea
Norflurazon
Naptalam or Neptalam
MGK 264
Benfluralin
Sulfotepp
Aspon
Coumaphos
Fensulfothion
Disulfoton
Fenitrothion
Phosmet
Azinphos Methyl (Guthion)
PAI Code3
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
160
161
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
Shaughnessy
Code4
044801
115601
107201
109401
100201
047601
097401
009001
035506
039504
057701
014505
034802
114002
101201
100301
090301
*
034001
053201
*
068102
054101
108801
044201
014601
035502
035501
103001
080301
014503
034401
035801
105801
030703
057001
084301
079501
079101
036501
032701
032501
105901
059201
058001
CAS
Number5
76-44-8
54460-46-7
51235-04-2
25311-71-1
33820-53-0
122-42-9
4849-32-5
58-89-9
330-55-2
569-64-2
121-75-5
12427-38-2
15339-36-3
53780-36-2
10265-92-6
950-37-8
16752-77-5
*
72-43-5
74-83-9
*
6317-18-6
2439-01-2
51218-45-2
315-18-4
9006-42-2
140-41-0
150-68-5
15299-99-7
134-62-3
142-59-6
300-76-5
18530-56-8
27314-13-2
132-67-2
113-48-4
1861-40-1
3689-24-5
3244-90-4
56-72-4
115-90-2
298-04-4
122-14-5
732-11-6
86-50-0
246
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Oxydemeton Methyl
Organo Arsenic Pesticides
Organo Cadmium Pesticides
Organo Copper Pesticides
Organo Mercury Pesticides
Organo Tin Pesticides
o Dichlorobenzene
Oryzalin
Oxamyl
Oxyfluorfen
Bolstar
Sulprofos Oxon
Santox (EPN)
Fonofos
Propoxur
p Dichlorobenzene
Parathion Ethyl
Pendimethalin
PCNB
PCP or Penta
Perfluidone
Permethrin
Phenmedipham
Nemazine
Phorate
Phosalone
Phosphamidon
Picloram
Piperonyl Butoxide
PBED or WSCP (Busan 77)
Busan 85 or Arylane
Busan 40
KN Methyl
Metasol J26
Prof en of os
Prometon or Caparol
Prometryn
Propargite
Propazine
Propionic Acid
Previcur N
Pyrethrin Coils
Pyrethrum I
Pyrethrum II
Pyrethrins
PAI Code3
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
Shaughnessy
Code4
058702
*
*
*
*
*
059401
104201
103801
111601
111501
219900
041801
041701
047802
061501
057501
108501
056502
*
108001
109701
098701
064501
057201
097701
018201
*
067501
069183
034803
102901
039002
101301
111401
080804
080805
097601
080808
077702
119301
069004
069001
069002
*
CAS
Number5
301-12-2
*
*
*
*
*
95-50-1
19044-88-3
23135-22-0
42874-03-3
35400-43-2
38527-90-1
2104-64-5
944-22-9
114-26-1
106-46-7
56-38-2
40487-42-1
82-68-8
87-86-5
37924-13-3
52645-53-1
13684-63-4
92-84-2
298-02-2
2310-17-0
13171-21-6
*
51-03-6
31512-74-0
128-03-0
51026-28-9
137-41-7
53404-62-9
41198-08-7
1610-18-0
7287-19-6
2312-35-8
139-40-2
79-09-4
24579-73-5
8003-34-7
8003-34-7
*
247
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Resmethrin
Fenchlorphos or Ronnel
Mexide or Rotenone
DEF
Siduron orTupersan
Silvex
Simazine
Sodium Bentazon
Carbarn S or Sodam
Sodium Fluoroacetate
Vapam or Metham Sodium
Sulfoxide
Cycloate or Ro Meet
EPrecipitationC or Eptam
Molinate
Pebulate orTillman
Vernolate or Vernam
HPrecipitationMS
Bensulide or Betesan
Tebuthiuron
Temephos
Terbacil
Terbufos or Counter
Terbuthylazine
Terbutryn
Tetrachlorophenol
Dazomet
Thiophanate Methyl
Thiram
Toxaphene
Merphos
Trifluralin or Treflan
Warfarin
Zinc MET
Zineb
Ziram
Triallate
Phenothrin
Tetramethrin
Chloropropham
PAI Code3
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
Shaughnessy
Code4
*
058301
071003
074801
035509
*
080807
103901
034804
075003
039003
057101
041301
041401
041402
041403
041404
035604
009801
105501
059001
012701
105001
080814
080813
063004
035602
102001
079801
080501
074901
036101
*
051705
014506
034805
078802
069005
069003
018301
CAS
Number5
*
299-84-3
83-79-4
78-48-8
1982-49-6
*
122-34-9
50723-80-3
128-04-1
62-74-8
137-42-8
120-62-7
1134-23-2
759-94-4
2212-67-1
1114-71-2
1929-77-7
29803-57-4
741-58-2
34014-18-1
3383-96-8
5902-51-2
13071-79-9
5915-41-3
886-50-0
25167-83-3
533-74-4
23564-05-8
137-26-8
8001-35-2
150-50-5
1582-09-8
*
155-04-4
12122-67-7
137-30-4
2303-17-5
26002-80-2
7696-12-0
101-21-3
Non-272 PAIs
CFC11
CFC12
Polyethylene
Acrolein
000013
000014
000152
000701
75-69-4
75-71-8
9002-88-4
107-02-8
248
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Dimethyl m dioxan 4 ol aceta
Dodecyl alcohol
Tetradecyl alcohol
Rosin amine D acetate
Dihydroabietylamine acetate
Amitrole
Allyl isothiocyanate
AMS
Calcium sulfate
Tartar emetic
Diphenylstibene 2 ethylhexan
Streptomycin
Oxytetracycline hydrochlorid
Streptomycin sesquisulfate
Neomycin sulfate
Antimycin A
Calcium oxytetracycline
Espesol 3A
Arsenic acid
Arsenic acid anhydride
Arsenous acid anhydride
Copper oxychloride
Basic cupric sulfate
Basic copper III zincsulf
Bromophos
Benzyl bromoacetate
Benzole acid
Benzyl diethyl ((2,6 xylylca
Benzyl alcohol
3 Chloro p toluidine hydroch
Butoxyethoxy)ethyl thiocyana
2 Naphthol
Boric acid
Barium metaborate
Boron sodium oxide (B8Na2O13
Sodium metaborate (NaBO2)
Boron sodium oxide (B8Na2O13
Boron sodium oxide (B4Na2O7)
Boron sodium oxide (B4Na2O7)
Polybutene
Polyisobutylene
Butyl cellosolve
Butoxypolypropylene glycol
Neburon (ANSI)
Methyltrimethylenedioxy)bis(
PAI Code3
Shaughnessy
Code4
001001
001509
001510
004201
004213
004401
004901
005501
005602
006201
006202
006306
006308
006310
006313
006314
006321
006601
006801
006802
007001
008001
008101
008102
008706
008710
009101
009106
009502
009901
010002
010301
011001
011101
011103
011104
011107
011110
011112
011402
011403
011501
011901
012001
012401
CAS
Number5
828-00-2
112-53-8
112-72-1
2026-24-6
53466-80-1
61-82-5
57-06-7
7773-06-0
7778-18-9
28300-74-5
5035-58-5
57-92-1
2058-46-0
3810-74-0
1405-10-3
1397-94-0
7179-50-2
68602-80-2
7778-39-4
1303-28-2
1327-53-3
1332-40-7
*
55072-57-6
2104-96-3
5437-45-6
65-85-0
3734-33-6
100-51-6
7745-89-3
112-56-1
135-19-3
10043-35-3
13701-59-2
12280-03-4
7775-19-1
12008-41-2
12179-04-3
1330-43-4
9003-29-6
9003-27-4
111-76-2
9003-13-8
555-37-3
2665-13-6
249
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Oxybis(4,4,6 trimethyl-1 ,3,2
Cadmium chloride
Lead arsenate, basic
Lead arsenate
Sodium arsenate
Sodium arsenite
Potassium bromide
Camphor
Carbon disulfide
Carbon tetrachloride
Barban (ANSI)
Chloro 2 propenyl) 3,5,7,tri
Chlormequat chloride
Chloromethoxypropylmercuric
Allidochlor
Chromic acid
Chromic oxide
Cresol (unspec) (Cresylic ac
Cresol
Copper (metallic)
Copper ammonium carbonate
Copper carbonate
Copper hydroxide
Copper chloride hydroxide
Copper oxychloride sulfate
Copper sulfate
Copper (from triethanolamine
Copper as metallic (in the f
Copper as elemental from cop
Copper sulfate (anhydrous)
Copper(l) oxide
Cuprous thiocyanate
Cyclohexane
Cyclohexanone
Dichlobenil
Diquat dibromide
Dimethrin (ANSI)
Dicapthon
Ziram, cyclohexylamine compl
Butyl dimethyltrithioperoxyc
Daminozide
Bis(trichloromethyl) sulfone
Bis(bromoacetoxy) 2 butene
Dazomet, sodium salt
Butonate
PAI Code3
Shaughnessy
Code4
012402
012902
013502
013503
013505
013603
013903
015602
016401
016501
017601
017902
018101
018401
019301
021101
021103
022101
022102
022501
022703
022901
023401
023501
023503
024401
024403
024405
024407
024408
025601
025602
025901
025902
027401
032201
034101
034502
034806
034807
035101
035601
035605
035607
035701
CAS
Number5
14697-50-8
10108-64-2
1327-31-7
7784-40-9
13464-38-5
7784-46-5
7758-02-3
76-22-2
75-15-0
56-23-5
101-27-9
51229-78-8
999-81-5
1319-86-4
93-71-0
7738-94-5
1308-38-9
1319-77-3
108-39-4
7440-50-8
33113-08-5
12069-69-1
20427-59-2
1332-65-6
8012-69-9
7758-99-8
82027-59-6
*
13426-91-0
7758-98-7
1317-39-1
1111-67-7
110-82-7
108-94-1
1194-65-6
85-00-7
70-38-2
2463-84-5
16509-79-8
3304-97-0
1596-84-5
3064-70-8
20679-58-7
53404-60-7
126-22-7
250
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name^
PAI Code^
Shaughnessy
Code4
CAS
Number5
Trifluoro 4 nitro m cresol (
Triethanolamine dinoseb (2 s
Sodium 4,6 dinitro o cresyla
Dinitrophenol
Alkanol* amine dinoseb (2 se
Sodium dinoseb (2 sec Butyl
Nitrilotriacetic acid, triso
Trisodium(2 hydroxyethyl)eth
Ammonium ethylenediaminetetr
Pentasodium diethylenetriami
Ethyl 1,3 hexanediol
Ethylene
EDC
Methylene chloride
Methoxyethanol
Ethylene glycol
Butylene glycol
Ethylene oxide
Copper(ll) oxide
Cuprous and cupric oxide, mi
Propylene oxide
Formaldehyde
Paraformaldehyde
Bis(2 butylene)tetrahydro-2
Gibberellic acid
Potassium gibberellate
Glutaral
Copper citrate
Methyl nonyl ketone
Methyl 2 pentanone
Monosodium 2,2' methylenebis
Potassium 2,2' methylenebis(
Hexachloroepoxyoctahydro end
Chlorhexidine diacetate
Hydrocyanic acid
Hydroxyethyl octyl sulfide
Heptadecenyl 2 (2 hydroxyeth
Hydroxyethyl) 2 alkyl 2 imid
IBA
Dihydropyrone
Butoxypolypropoxypolyethoxye
Polyethoxypolypropoxyethanol
Use code no. 046904 (polyeth
Iodine potassium iodide co
Alkyl omega hydroxypoly(oxye
036201
88-30-2
037506
6420-47-9
037508
2312-76-7
037509
51-28-5
037511
8048-12-2
037512
35040-03-0
039106
5064-31-3
039109
139-89-9
039117
7379-26-2
039120
140-01-2
041001
94-96-2
041901
74-85-1
042003
107-06-2
042004
75-09-2
042202
109-86-4
042203
107-21-1
042205
107-88-0
042301
75-21-8
042401
1317-38-0
042403
82010-82-0
042501
75-56-9
043001
50-00-0
043002
30525-89-4
043302
126-15-8
043801
77-06-5
043802
125-67-7
043901
111-30-8
044005
10402-15-0
044102
112-12-9
044105
108-10-1
044902
5736-15-2
044904
67923-62-0
045001
60-57-1
045502
56-95-1
045801
74-90-8
046301
3547-33-9
046608
53466-82-3
046609
61791-39-7
046701
133-32-4
046801
532-34-3
046901
68610-00-4
046904
26617-87-8
046909
26617-87-8
046917
12298-68-9
046921
68439-47-4
251
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name^
PAI Code^
Shaughnessy
Code4
CAS
Number5
Lead acetate
Nickel sulfate hexahydrate
Maleic hydrazide, diethanola
Maleic hydrazide, potassium
Sodium 2 mercaptobenzothiola
Mercuric chloride
Mercurous chloride
Metaldehyde
Methylated naphthalenes
Sodium 2,2' methylenebis(4 c
Naphthalene
NAD
NAA (1 Naphthaleneacetic Aci
Potassium 1 naphthaleneaceta
Ammonium 1 naphthaleneacetat
Sodium 1 naphthaleneacetate
Ethyl 1 naphthaleneacetate
Nitrophenol
Nicotine
Carbophenothion (ANSI)
Sodium 5 chloro 2 (4 chloro
Monocrotophos
Chlordimeform
Chlordimeform hydrochloride
Thiabendazole hypophosphite
Hexachlorobenzene
Butyl paraben
Paraquat dichloride
Chloro 4 phenylphenol
Chloro 2 phenylphenol
Chloro 2 biphenylol, potassi
Chloro 2 phenylphenol
Chloro 2 phenylphenol, potas
Sodium phenate
Butylphenol, sodium salt
Ammonium 2 phenylphenate
Chloro 2 cyclopentylphenol
Bithionolate sodium
Chloro 3 cresol
Sodium 2,4,5 trichlorophenat
Aluminum phosphide
Phosphorus
Magnesium phosphide
1 (Alkyramino) 3 aminopropa
Alkyl* amino) 3 aminopropane
048001
301-04-2
050505
10101-97-0
051502
5716-15-4
051503
28382-15-2
051704
2492-26-4
052001
7487-94-7
052201
10112-91-1
053001
108-62-3
054002
1321-94-4
055005
10254-48-5
055801
91-20-3
056001
86-86-2
056002
86-87-3
056003
15165-79-4
056004
25545-89-5
056007
61-31-4
056008
2122-70-5
056301
100-02-7
056702
54-11-5
058102
786-19-6
058802
3567-25-7
058901
6923-22-4
059701
6164-98-3
059702
19750-95-9
060102
28558-32-9
061001
118-74-1
061205
94-26-8
061601
1910-42-5
062206
92-04-6
062208
062209
53404-21-0
062210
85-97-2
062211
18128-17-1
064002
139-02-6
064115
5787-50-8
064116
52704-98-0
064202
13347-42-7
064203
6385-58-6
064206
59-50-7
064217
136-32-3
066501
20859-73-8
066502
7723-14-0
066504
12057-74-8
067301
61791-63-7
067305
61791-58-0
252
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Alkyramino) 3 aminopropane
Alkyl* dipropoxyamine *(47%
Alkyramino) 3 aminopropane
Alkyl* amino) 3 aminopropane
Alkyramino) 3 aminopropane
Octadecenyl 1 ,3 propanediami
Alkyl* amine acetate *(5%C8
Pindone sodium salt
Diphacinone, sodium salt
Isovaleryl 1,3 indandione, c
Methyl isothiocyanate
Potassium dichromate
Sodium chromate
Sodium dichromate
Alkenyl* dimethyl ethyl ammo
Alkyl* N ethyl morpholinium
Alkyl* isoquinolinium bromid
Alkyl* methyl isoquinolinium
Cetyl trimethyl ammonium bro
Cetyl pyridinium bromide
Dodecyl dimethyl benzyl ammo
Alkyl* dimethyl ethylbenzyl
Alkyl* N ethyl morpholinium
Alkyl* trimethyl ammonium br
Benzyl((dodecylcarbamoyl)met
Cetyl pyridinium chloride
Alkyl* dimethyl ethyl ammoni
Cetyl N ethylmorpholinium et
Use code no. 069102 (Alkenyl
p Aminopyridine
Nitrapyrin (ANSI)
Alkyl pyridines
Pyrazon (ANSI)
Capsaicin (in oleoresin of c
Ryanodine
Silver
Silver chloride
Silver thiuronium acrylate c
Sodium chlorate
Calcium cyanide
Sodium cyanide
Cryolite
Sodium fluoride
Ammonium fluosilicate
Sodium fluosilicate
PAI Code3
Shaughnessy
Code4
067307
067308
067309
067310
067313
067316
067329
067704
067705
067706
068103
068302
068303
068304
069102
069113
069115
069116
069117
069118
069127
069135
069147
069153
069159
069160
069186
069187
069198
069201
069203
069205
069601
070701
071502
072501
072506
072701
073301
074001
074002
075101
075202
075301
075306
CAS
Number5
68188-29-4
68516-06-3
68155-43-1
68155-37-3
61791-64-8
83542-86-3
61790-57-6
6120-20-3
42721-99-3
23710-76-1
556-61-6
7778-50-9
7775-11-3
10588-01-9
*
61791-34-2
53466-68-5
71820-38-7
57-09-0
140-72-7
*
61791-34-2
1119-97-7
100-95-8
123-03-5
134595-54-3
78-21-7
*
504-24-5
1929-82-4
68391-11-7
1698-60-8
404-86-4
15662-33-6
7440-22-4
7783-90-6
53404-00-5
7775-09-9
592-01-8
143-33-9
15096-52-3
7681-49-4
16919-19-0
16893-85-9
253
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Potassium iodide
Potassium tetrathionate
Potassium nitrate
Sodium nitrate
Sodium nitrite
Benzenesulfonamide, N chloro
Salicylic acid
Ethoxyethyl p methoxycinnama
Calcium polysulfide
Strychnine
Strychnine sulfate
Niclosamide
Dibromosalicylanilide
Tribromsalan
Dibromosalicylanilide
Chlorosalicylanilide
Sulfur
Sulfaquinoxaline
Sulfacetamide
Sulfuryl fluoride
Sodium bisulfite
Tetrachloroethylene
Ethoxylated isooctylphenol
Laurie diethanolamide
Triethanolamine oleate
Dioctyl sodium sulfosuccinat
Use code no. 069179 (alkyl*m
Alkyl* diethanolamide *(70%
Tetradecyl formate
Polyoxyethylene sorbitol ole
Polyethoxylated stearylamine
Capric diethanolamide
Limonene
Calcium thiosulfate
Ammonium thiosulfate
Thymoxydichloroacetic acid
Thymol
Sodium trichloroacetate
Trichloroacetic acid
Hexahydro 1 ,3,5 tris(2 hydro
2 (Hydroxymethyl) 2 nitro-1 ,
Bomyl
Turpentine
Chloro 1 (2,5 dichlorophenyl
Zinc chloride
PAI Code3
Shaughnessy
Code4
075701
075903
076103
076104
076204
076501
076602
076604
076702
076901
076902
077401
077402
077404
077405
077406
077501
077901
077904
078003
078201
078501
079004
079018
079025
079027
079036
079045
079069
079075
079094
079099
079701
080101
080103
080401
080402
081001
081002
083301
083902
084201
084501
084901
087801
CAS
Number5
7681-11-0
13932-13-3
7757-79-1
7631-99-4
7632-00-0
127-52-6
69-72-7
104-28-9
1344-81-6
57-24-9
60-41-3
1420-04-8
87-12-7
87-10-5
2577-72-2
4638-48-6
7704-34-9
59-40-5
144-80-9
2699-79-8
7631-90-5
127-18-4
9004-87-9
120-40-1
2717-15-9
1639-66-3
68140-00-1
52900-12-6
5451-63-8
53466-71-0
26635-92-7
136-26-5
138-86-3
10124-41-1
7783-18-8
22228-05-3
89-83-8
650-51-1
76-03-9
4719-04-4
126-11-4
122-10-1
8006-64-2
1757-18-2
7646-85-7
254
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Zinc 2 pyridinethiol 1 oxide
Hydroxy 2 (1H) pyridinethion
Omadine TBAO
Zinc naphthenate
Zinc oxide
Zinc phosphide (Zn3P2)
Zinc phenol sulfonate
Zinc sulfate, basic
Dimetilan
Carboxin
Oxycarboxin
Benzocaine
Piperalin
Tetracaine hydrochloride
Formetanate hydrochloride
Azacosterol HCI
Use code no. 039502 (gentian
Ammonium alum
Bismuth subgallate
Chlorflurenol, methyl ester
Benzisothiazolin 3 one
Methyl 2 benzimidazolecarbam
Ethephon
Pentanethiol
Nitrobutyl)morpholine
Ethyl 2 nitrotrimethylene)di
Tolyl diiodomethyl sulfone
Isobutyric acid
Dibromo 3 nitrilopropionamid
Polyethoxylated oleylamine
Dinitramine (ANSI)
Phenylethyl propionate
Eugenol
Tricosene
Tricosene
Sodium 1,4',5'trichloro-2'-
Hexahydro 1 ,3,5 tris(2 hydro
Methazole
Difenzoquat methyl sulfate
Butralin
Fosamine ammonium
Asulam
Sodium asulam
Hydroxymethoxymethyl 1 aza 3
Hydroxymethyl 1 aza 3,7 diox
PAI Code3
Shaughnessy
Code4
088002
088004
088005
088301
088502
088601
089002
089101
090101
090201
090202
097001
097003
097005
097301
098101
098401
098501
098601
098801
098901
099102
099801
100701
100801
100802
101002
101502
101801
101901
102301
102601
102701
103201
103202
104101
105601
106001
106401
106501
106701
106901
106902
107001
107002
CAS
Number5
13463-41-7
15922-78-8
33079-08-2
12001-85-3
1314-13-2
1314-84-7
127-82-2
68813-94-5
644-64-4
5234-68-4
5259-88-1
94-09-7
3478-94-2
136-47-0
23422-53-9
1249-84-9
548-62-9
7784-25-0
99-26-3
2536-31-4
2634-33-5
52316-55-9
16672-87-0
110-66-7
2224-44-4
1854-23-5
20018-09-1
79-31-2
10222-01-2
26635-93-8
29091-05-2
122-70-3
97-53-0
27519-02-4
35857-62-6
69462-14-2
25254-50-6
20354-26-1
43222-48-6
33629-47-9
25954-13-6
3337-71-1
2302-17-2
59720-42-2
6542-37-6
255
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Hydroxypoly(methyleneoxy)* m
Chloro 2 methyl 3(2H)-isothi
Methyl 3(2H) isothiazolone
Trimethoxysilyl)propyl dimet
Kinoprene
Triforine (ANSI)
Pirimiphos methyl (ANSI)
Thiobencarb
Ancymidol (ANSI)
Oxadiazon (ANSI)
Mepiquat chloride
Fluvalinate
Chloro N (hydroxymethyl)acet
Dikegulac sodium
Iprodione (ANSI)
Phenylmethyl) 9 (tetrahydro
Prodiamine
Erioglaucine
Tartrazine
Dodemorph acetate
Ethofumesate (ANSI)
Aldoxycarb (ANSI)
Diclofop methyl
Bromo 1 (bromomethyl)-1,3 pr
Poly(iminoimidocarbonylimino
Imazalil
Bromadiolone
Brodifacoum
Bromethalin (ANSI)
Fluridone (ANSI)
Vinclozolin
Metalaxyl
Propetamphos (ANSI)
Methyl 1 naphthyl)maleimide
Hexadecadien 1 yl acetate
Hexadecadien 1 yl acetate
Epoxy 2 methyloctadecane
Thiodicarb (ANSI)
Dimethyloxazolidine (8CA & 9
Trimethyloxazolidine
Hydroxyphenyl)oxoacetohydrox
EEEBC
MDM Hydantoin
DMDM Hydantoin
Triclopyr (ANSI)
PAI Code3
Shaughnessy
Code4
107003
107103
107104
107401
107502
107901
108102
108401
108601
109001
109101
109302
109501
109601
109801
110001
110201
110301
110302
110401
110601
110801
110902
111001
111801
111901
112001
112701
112802
112900
113201
113501
113601
113701
114101
114102
114301
114501
114801
114802
114901
115001
115501
115502
116001
CAS
Number5
56709-13-8
26172-55-4
2682-20-4
27668-52-6
65733-20-2
26644-46-2
29232-93-7
28249-77-6
12771-68-5
19666-30-9
24307-26-4
69409-94-5
2832-19-1
52508-35-7
36734-19-7
2312-73-4
29091-21-2
2650-18-2
1934-21-0
31717-87-0
26225-79-6
1646-88-4
51338-27-3
35691-65-7
32289-58-0
35554-44-0
28772-56-7
56073-10-0
63333-35-7
59756-60-4
50471-44-8
57837-19-1
31218-83-4
70017-56-0
53042-79-8
52207-99-5
29804-22-6
59669-26-0
51200-87-4
75673-43-7
34911-46-1
62732-91-6
6440-58-0
116-25-6
55335-06-3
256
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Triethylamine triclopyr
Butoxyethyl triclopyr
Decenyl)dihydro 2(3H) furano
Cytokinins
Benzyladenine
Clopyralid, monoethanolamine
Clopyralid (ANSI)
Flucythrinate (ANSI)
Hydramethylnon (ANSI)
Chlorsulfuron
Dimethipin
Hexadecenal
Tetradecenal
Thidiazuron
Metronidazole
Erythrosine B
Sethoxydim
Clethodim
Cyromazine
Tralomethrin
Azadirachtin
Tridecen 1 yl acetate
Tridecen I yl acetate
Sulfometuron methyl
Metsulfuron methyl
Propiconazole
Furanone, dihydro 5 pentyl
Furanone, 5 heptyldihydro
Abamectin (ANSI)
Fluazifop butyl
Fluazifop R butyl
Flumetralin
Fosetyl Al
Methanol, (((2 (dihydro 5 me
Fomesafen
Tridiphane
POE isooctadecanol
Periplanone B
Fenoxycarb
Clomazone
Clofentezine
Paclobutrazol
Flurprimidol
Isoxaben
Isazofos
PAI Code3
Shaughnessy
Code4
116002
116004
116501
116801
116901
117401
117403
118301
118401
118601
118901
120001
120002
120301
120401
120901
121001
121011
121301
121501
121701
121901
121902
122001
122010
122101
122301
122302
122804
122805
122809
123001
123301
123702
123802
123901
124601
124801
125301
125401
125501
125601
125701
125851
126901
CAS
Number5
57213-69-1
64700-56-7
64726-91-6
1214-39-7
57754-85-5
1702-17-6
70124-77-5
67485-29-4
64902-72-3
55290-64-7
53939-28-9
53939-27-8
51707-55-2
443-48-1
16423-68-0
74051-80-2
99129-21-2
66215-27-8
66841-25-6
992-20-1
65954-19-0
72269-48-8
74222-97-2
74223-64-6
60207-90-1
104-61-0
104-67-6
71751-41-2
69806-50-4
79241-46-6
62924-70-3
39148-24-8
97553-90-7
72178-02-0
58138-08-2
52292-17-8
61228-92-0
72490-01-8
81777-89-1
74115-24-5
76738-62-0
56425-91-3
82558-50-7
42509-80-8
257
-------
Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name^
PAI CodeJ
Shaughnessy
Code4
CAS
Number5
Triadimenol
Fenpropathrin
Sulfosate
Fenoxaprop ethyl
Quizalofop ethyl
Bensulfuron methyl
Imazapyr
Bifenthrin
Imazapyr, isopropylamine sal
Sodium salt of 1 carboxymeth
Linalool
Imazaquin, monoammonium salt
Imazethabenz
Thifensulfuron methyl
Imazaquin
Myclobutanil (ANSI)
Zinc borate (3ZnO, 2B03, 3.5
Cyhalothrin
Potassium cresylate
Triflumizole
Tribenuron methyl
Cyhalothrin
Chlorimuron ethyl
Dodecen 1 yl acetate
Dodecen 1 yl acetate
DDOL
Farnesol
Nerolidol
Tefluthrin
Bromoxynil heptanoate
Imazethapyr
Imazethapyr, ammonium salt
Chitosan
Sulfuric acid, monourea addu
Hydroprene
Triasulfuron
Primisulfuron methyl
Uniconazole (ANSI)
Tetradecenyl acetate
Chitin
Sulfluramid
Dithiopyr (ANSI)
Nicosulfuron
Zinc
Tetradecen 1 ol, acetate, (E
127201
55219-65-3
127901
39515-41-8
128501
81591-81-3
128701
66441-23-4
128711
76578-14-8
128820
83055-99-6
128821
81334-34-1
128825
82657-04-3
128829
81510-83-0
128832
92623-86-4
128838
78-70-6
128840
81335-47-9
128842
81405-85-8
128845
79277-27-3
128848
81335-37-7
128857
88671-89-0
128859
128867
68085-85-8
128870
12002-51-6
128879
68694-11-1
128887
101200-48-0
128897
91465-08-6
128901
90982-32-4
128906
28079-04-1
128907
38363-29-0
128908
40642-40-8
128910
4602-84-0
128911
7212-44-4
128912
79538-32-2
128920
56634-95-8
128922
81335-77-5
128923
101917-66-2
128930
9012-76-4
128961
21351-39-3
128966
65733-18-8
128969
82097-50-5
128973
86209-51-0
128976
83657-17-4
128980
20711-10-8
128991
1398-61-4
128992
4151-50-2
128994
97886-45-8
129008
111991-09-4
129015
7440-66-6
129019
33189-72-9
258
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Appendix C Table 10 to Part 455 (with CAS Numbers)
Pollution Prevention Guidance Manual for the PFPR Industry
List of PAIs from Table 10 to Part 455 With Their
Corresponding Shaughnessy Codes and CAS Numbers1
PAI Name2
Imazaquin, sodium salt
Dodecadien 1 ol
lonone
Dicamba, aluminum salt
Benzenemethanaminium, N (2 (
Fenoxaprop p Ethyl
Alkyl* bis(2 hydroxyethyl) a
Alkenyl* dimethyl ammonium a
Amines, N coco alkyltrimethy
Dialkyl* dimethyl ammonium b
Alkyl* bis(2 hydroxyethyl) a
Dodecyl bis(hydroxyethyl)dio
Dodecyl bis(2 hydroxyethyl)
Didecyl N methyl 3 (trimetho
Cholecalciferol
Use code no. 202901 (Vitamin
Alkyl* N,N bis(2 hydroxyethy
Bromo 2 nitropropane 1 ,3 dio
Use code no. 114601 (cyclohe
Diethatyl ethyl
Hydroprene (ANSI)
Zinc sulfate monohydrate
Geraniol
PAI Code3
Shaughnessy
Code4
129023
129028
129030
129042
129045
129092
169103
169104
169109
169111
169125
169154
169155
169160
202901
208700
210900
216400
229300
279500
486300
527200
597501
CAS
Number5
81335-46-8
33956-49-9
127-41-3
90823-38-4
71283-80-2
61791-31-9
22968-84-9
68155-42-0
68953-58-2
68961-66-0
125091-04-5
68959-20-6
67-97-0
67-97-0
52-51-7
57063-29-3
38727-55-8
41096-46-2
7446-19-7
106-24-1
1 The 272 Pesticide Active Ingredients (PAIs) are listed first, by PAI code, followed by the non-272 PAIs
from the 1988 FIFRA and TSCA Enforcement System (FATES) Database, which are listed in
Shaughnessy code order. PAIs that were exempted or reserved from the PFPR effluent guidelines
are not listed in the table.
2 The non-272 PAI names are taken directly from the 1988 FATES database. Several of the PAI names
are truncated because the PAI names listed in the FATES database are limited to 60 characters.
3 The non-272 PAIs do not have PAI codes.
4 Shaughnessy codes are taken from the 1988 FATES database when available. Some of the 272 PAIs
are not listed in the 1988 FATES database; in these instances, the Shaughnessy codes are
taken from the Office of Pesticide Products (OPP) Chemical Database.
5 The CAS numbers are taken from a variety of sources including the Aldrich 1994-1995 Catalog,
the Chemical Synonyms Document, the Farm Chemicals Handbook, the Merck Index (11th edition), the Office
of Research and Development (ORD) Risk Reduction Engineering Laboratory (RREL) Database, and the OPP
Chemical Database.
* This PAI code represents a category or group of PAIs; therefore, it has multiple Shaughnessy codes
and/or CAS numbers.
259
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D
INTRODUCTION
The following test procedures have been excerpted from Section 4.0 of the
report Pilot-Scale Tests of the Universal Treatment System for the Pesticides For-
mulating, Packaging, and Repackaging Industry, September 1996 (DCN F7938).
The report details the results of a series of pilot-scale treatability tests con-
ducted by the U.S. Environmental Protection Agency during development of
the Pesticide Formulating, Packaging, and Repackaging effluent limitations
guidelines and standards. These tests evaluted the effectiveness of a flexible
treatment train that was referred to as the Universal Treatment System (UTS).
The UTS is simply a term used to describe a simple, flexible system that con-
sists of standard wastewater treatment equipment: tanks, pumps, piping, and
activated carbon columns that can be purchased individually off-the-shelf
from vendors. This equipment can be used to conduct the following physi-
cal/chemical treatment steps: emulsion breaking, hydrolysis, activated car-
bon adsorption, chemical oxidation, and precipitation.
4.0
This section provides a discussion of the equipment, procedures, and operat-
ing parameters used to perform the three pilot-scale UTS treatability tests.
Each pilot-scale test consisted of a bench-scale emulsion-breaking pretest,
emulsion breaking (where it was determined via bench-scale pretesting that
emulsion breaking would be effective) or settling, hydrolysis, and activated
carbon adsorption.
To characterize the performance of each UTS treatment step, samples were
collected before and after each step to gather data on the overall effectiveness
of the UTS in treating PFPR wastewater. Each of these samples was analyzed.
for pesticide active ingredients (PAIs), volatile organics, semivolatile organ-
ics, and classical wet chemistry parameters. The influent to and effluent from
the UTS system were also analyzed for metals.
Samples were also collected throughout hydrolysis treatment; these samples
were analyzed for PAIs and classical wet chemistry parameters. The PAI ana-
lytical results were used to prepare hydrolysis half-life curves, which are pre-
sented in Section 6.0. Samples were collected throughout activated carbon
treatment and analyzed for PAIs. The analytical results were used to prepare
carbon breakthrough curves for each of the PAIs, which are also presented in
Section 6.0.
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Section 4.1 provides a discussion of the test equipment used in all three UTS
treatability tests. Because each type of wastewater treated in the pilot-scale
UTS differed in composition and treatability, the UTS procedures were modi-
fied slightly for each test to achieve adequate treatment. Sections 4.2 through
4.4 describe the procedures and design and operating parameters for each
UTS test.
4.1 Test
The pilot-scale UTS treatability tests were conducted at Radian Corporation's
Milwaukee, Wisconsin laboratory facilities. The following subsections describe
the equipment used to perform the pilot-scale tests, as well as the emulsion-
breaking pretest.
4.1.1 Emulsion-Breaking
The bench-scale emulsion breaking pretest was conducted in glass beakers.
Hot plates were used to heat the aliquots. Magnetic stirrers with Teflon®-coated
stirring bars mixed the aliquots.
4.1.2
The pilot-scale emulsion-breaking tests and hydrolysis tests were conducted
in two 190-liter stainless steel tanks with open tops. These tanks were heated
using electric band heaters wrapped around the tanks. Aluminum foil was
used to cover the tops of the tanks during portions of the tests to reduce
evaporative losses. Several plastic tanks and a 40-liter graduated plastic tank
were used to hold and measure the volume of the wastewater. Plastic tanks
were used to hold the supernatant from the emulsion-breaking step while the
sludge layers were measured and washed out of the stainless steel tanks. The
graduated plastic tank was used to measure the volume of wastewater added
to the plastic activated carbon feed tank.
4.1.3
The wastewater tanks used for the pilot-scale emulsion breaking step were
mixed using milk-jug hand mixers, an electrically powered paddle mixer, or
an electrically powered Lightning® mixer. Each milk-jug mixer consisted of a
long stainless steel rod attached to the center of a stainless steel disc with
holes punched in it. Mixing was conducted by submerging the disc in the
liquid and moving it up and down. The paddle mixer consisted of an electric
motor that rotated a stainless steel paddle. The motor was clamped to a board
placed across the opening of a tank. The paddle remained submerged in the
liquid in the tank. The Lightning® mixer consisted of an electric motor that
rotated a stainless steel rod with a small, warped stainless steel disc at its tip.
The Lightning® mixer was clamped to the side of a tank so that the rod and
the disc remained submerged in the liquid in the tank.
4.1.4
Wastewater was transferred into and out of the various tanks and the acti-
vated carbon column either by pouring it or by pumping it through one of
three pumps: a sump pump (submersible pump), a centrifugal pump, and a
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
peristaltic pump. The sump pump consisted of a motor located in a plastic
housing with an open bottom. The motor was attached to a rope and was
lowered into the liquid to be pumped until the open bottom of the housing
was submerged in the liquid. The liquid was pumped through a tube at the
top of the motor housing. The sump pump had the highest flow rate but its
speed was not adjustable, and it tended to cause settled solids to resuspend
during pumping.
The centrifugal pump was used by attaching tubes to the pump inlets and
outlets. The open end of the tube attached to the inlet was submerged in the
liquid to be pumped, and the open end of the tube attached to the outlet was
placed in the empty container. The centrifugal pump had a variable speed
motor, which could be adjusted to minimize the resuspension of settled solids.
The peristaltic pump was used to pump the wastewater from the activated
carbon feed tank through a length of flexible tubing and into the carbon col-
umn. This pump was operated by wrapping a piece of flexible tubing around
a gear. As the gear rotated, the tubing was compressed, which caused the
liquid to flow through the tubing.
4.1.5 Activated Carbon Column
The activated carbon column consisted of a clear glass tube seven feet high
and one inch in diameter. The ends of the column were capped with plastic
plugs that had openings for stainless steel fittings. These fittings were used to
attach flexible tubing to the column inlet and outlet. For each UTS test, the
column was packed with 680 grams of granular activated carbon that had
been washed and deaerated. The carbon used in each of the three tests was
pulverized Filtrasorb 300, manufactured by Calgon Corporation. The carbon
had a mesh size of 300 to 400.
The carbon was weighed and washed by measuring a small amount of car-
bon into a glass flask. Distilled water was added to the flask and swirled to
cause the carbon fines to be suspended, which generated a black water above
the granular carbon. The water was decanted from the carbon. These steps
were repeated until the swirling no longer suspended many fines and the
water remained relatively clear after swirling. The carbon, was then deaer-
ated by placing the flask under a vacuum of about seven inches of mercury
using a vacuum pump. The flask was swirled to help release air bubbles from
the carbon. The vacuum and swirling were continued until the water above
the carbon became relatively free of air bubbles. The carbon was then scooped
from the flask or washed from the flask using distilled water, and loaded into
the carbon column.
4.1.6
Measurements of pH were performed using an electronic pH meter, which
was calibrated daily, or using disposable pH strips. Temperature measure-
ments were conducted using a portable electric thermocouple or a
mercury-filled glass thermometer. Prior to use, all equipment was washed
using water, detergent solution, scrubbers, and scouring pads, as needed,
and was triple-rinsed with distilled water.
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4.2 Facility A Treatability Test
Facility A is a toll formulator that formulates and packages home insecticides,
insect repellents, and pet-care products such as flea and tick shampoos. Waste-
water collected from Facility A for treatability testing included formulation
vessel interior rinsates from the formulation of four separate products (re-
ferred to in this report as Rinsates 1, 2, 3, and 4) and floor wash water from a
mechanical floor scrubbing machine used to clean floors in the facility's prod-
uct formulation areas. The wastewater was collected between March 27 and
March 29, 1995 and placed for transport in one of seven plastic carboys.
Table 4-1 provides a summary of the wastewater collection at Facility A.
Table 4-1
Summary of Wastewater Collection for UTS Treatability Testing at Facility A
Carboy Carboy Contents (Pesticide
Number Active Ingredients)
Carboy #1 Rlnsate 1 (permethrin, methoprene)
Carboy #2 Rinsate 2 (linalool)
Carboy #3 Rinsate 2 (linalool)
Carboy #4 Rinsate 3 (pyrethrins, piperonyl butoxide)
Carboy #5 Rinsate 3 (pyrethrins, piperonyl butoxide)
Carboy #6 Rinsate 4 (permethrin, methoprene)
Carboy # 7 Floor Wash Water (permethrin, methoprene,
linalool, limonene, pyrethrins, piperonyl
butoxide)
Carboy Volume
(Liters)
60
60
50
60
60
35
20
Wastewater Appearance
Milky-white, opaque
Light green, translucent
Light green, translucent
Light green, translucent, foamy
Light green, translucent, foamy
Milky-white, opaque, foamy
Black, opaque
Rinsate 1 was generated from the interior cleaning of a tank used to formu-
late an insecticide spray that contains the PAIs permethrin and methoprene.
The operator used about 95 liters of hot water in 10 minutes to clean the tank.
Sixty liters of the wastewater were collected into Carboy #1 from a valve
connected to the bottom of the tank. The wastewater had an opaque,
milky-white appearance.
Rinsate 2 was generated from the interior cleaning of a tank used to formu-
late an insecticidal pet shampoo that contains the PAI linalool. The operator
used about 230 liters of hot water in 20 minutes to clean the tank. Using a
hose connected to a valve at the bottom of the tank, wastewater collection
personnel put 60 liters of the wastewater into Carboy #2 and 50 liters of the
wastewater into Carboy #3. The wastewater had a translucent, slightly green
hue and contained surfactants from the raw materials used to formulate the
product.
Rinsate 3 was generated from the interior cleaning of a tank used to formu-
late another insecticidal pet shampoo that contains the PAIs pyrethrin and
piperonyl butoxide. The operator used about 150 liters of hot water in 10
minutes to clean the tank. Sixty liters of the wastewater were collected into
Carboy #4 and 60 liters were collected into Carboy #5 using a hose connected
264
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
to a valve at the bottom of the tank. The wastewater was foamy and had a
translucent, slightly green hue, and contained surfactants from the raw ma-
terials used to formulate the product.
Rinsate 4 was generated from the interior cleaning of a tank used to formu-
late an insecticide spray that contains the PAIs permethrin and methoprene.
The operator used about 35 liters of hot water to clean the tank. Wastewater
collection personnel placed all 35 liters of the wastewater into Carboy #6
using a valve connected to the bottom of the tank. The wastewater was foamy
and had an opaque, milky-white appearance.
Floor wash water was collected from a mechanical floor scrubber that is used
to clean the floors in the Facility A pesticide products packaging area. The
floor in the formulation area is rarely washed; however, the rest of the facility,
including the floors surrounding the packaging lines, is cleaned periodically.
While personnel were on site to collect wastewater, the floors in the packag-
ing area were cleaned using a mechanical floor scrubber. Wastewater collec-
tion personnel collected 20 liters of wash water into Carboy #7 from the water
reservoir in the floor scrubber. This water was generated over two floor
washings, with approximately 10 liters generated per washing. The wash
water had the potential to contain all of the PAIs used in the products pack-
aged at the facility, including the PAIs in Rinsates 1 through 4, and the PAI
limonene, which is contained in another product that is packaged at the fa-
cility. In addition, the wash water contained detergents used in the floor scrub-
ber to help clean floors, as well as surfactants from products that may have
leaked or spilled during packaging. The wastewater had an opaque, black
appearance.
The wastewater was shipped via air cargo to Radian's Milwaukee, Wisconsin
laboratory facilities and was immediately placed in cold storage (approxi-
mately 4°C). The UTS treatability testing of Facility A wastewater began on
March 30,1995 and was completed by April 9,1995. Table 4-2 lists the sample
point description, Sample Control Center (SCC) sample number, date and
time of sample collection, pH, and temperature and collection methods for
the samples collected during the Facility A treatability test.
4.2.1 Pretest
Table 4-3 lists the composition of each aliquot for the emulsion breaking pre-
test, including the initial pH and appearance, the volume of acid or base
added, the resulting pH, and the observations of the effects of the emulsion-
breaking pretest.
The emulsion-breaking pretest was initially conducted on six 1-liter aliquots,
with five aliquots of the individual wastewater and one aliquot of commingled
wastewater from all carboys. The five aliquots of individual wastewater and
the commingled aliquot were lowered to a pH of approximately 2 and raised
to a temperature of 60°C for 1 hour as they were mixed; the aliquots were
then allowed to cool and settle overnight. Observations indicated that emul-
sion breaking was not effective on the interior equipment rinsates or on the
commingled wastewater. However, emulsion breaking did appear to be ef-
fective on the aliquot that consisted only of floor wash water; a distinct sludge
phase settled out following heat and acidification.
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Table 4-2
Summary of Wastewater Sampling for UTS Treatability Testing of Facility A Wastewater
Sample
SCC Sample Sample
Number Date Time
Commingled Influent 27767 04/04/95 10:15
to Hydrolysis
Commingled Influent 27768 04/04/95 10:15
to Hydrolysis
(duplicate)
Hydrolysis (first
batch, 6-hour)
Hydrolysis (first
batch, 12-hour)
Hydrolysis (first
batch, 24-hour)
27770 04/05/95 19:15
27771
04/06/95 1:15
27772 04/06/95 13:13
Hydrolysis (second 27769 04/07/95 19:45
batch, 24-hour)
PH
6.10
6.10
NA
NA
NA
7.46
Activated Carbon 27773 04/07/95 21:30 NA
(60-liter)
Activated Carbon 27774 04/08/95 8:15-10:00 NA
(120-liter)
Activated Carbon 27775 04/08/95 19:30-21:15 NA
(180-liter)
Activated Carbon
(240-liter)
27776 04/09/95 8:38-1:30 NA
Temp.
(°C) Collection Method
12.5 Scooped from tank using glass
measuring cup
12.5 Scooped from tank using glass
measuring cup
60.7 Scooped from tank using glass
measuring cup
55.1 Scooped from tank using glass
measuring cup
57.9 Scooped from tank using glass
measuring cup
21 Scooped from tank using glass
measuring cup
NA Collected in 4-L glass jar from
carbon column effluent tubing
NA Collected in 9.6-L glass jar from
carbon column effluent tubing
NA Collected in 4-L glass jar from
carbon column effluent tubing
NA Collected in stainless steel tank
from carbon column effluent
tubing
NA - Information not available.
SCC - Sample Control Center.
To determine whether alkaline conditions increased the effectiveness of emul-
sion breaking for the commingled Wastewater, a second commingled aliquot
was prepared from the post-emulsion breaking aliquots of the five individual
wastewaters. The pH of this second commingled aliquot was raised to ap-
proximately 12 and heated to a temperature of 60°C for 1 hour as it was
mixed. This aliquot was then allowed to cool and settle overnight. The emul-
sion-breaking pretest results indicated that emulsion-breaking using alkaline
conditions was not effective on the second commingled aliquot. Therefore,
pilot-scale emulsion breaking was performed only on the floor wash water
(Carboy #1).
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Table 4-3
Emulsion-Breaking Pretest Data for UTS Treatability Testing of Site A Wastewater
Aliquot
Number
1
2
3
4
5
6
7
Rinsate
Interior Rinse # 1
Interior Rinse #2
Interior Rinse #3
Interior Rinse #4
Floor Wash
First
Commingled
Aliquot
Second
Commingled
Aliquot
Sample
Composition
1,000 ml Carboy # 1
500 ml Carboy #2
500 ml Carboy #3
500 ml Carboy #4
500 ml Carboy #5
1,000 ml Carboy #6
1,000 ml Carboy #7
177 ml Carboy # 1
165 ml Carboy #2
165 ml Carboy #3
170 ml Carboy #4
170 ml Carboy #5
100 ml Carboy #6
55 ml Carboy #7
177 ml Beaker # 1
330 ml Beaker #2
340 ml Beaker #3
100 ml Beaker #4
55 ml Beaker #5
Initial
Appearance
Milky-white,
opaque
Light green,
translucent
Light green,
translucent
Milky-white,
opaque
Black,
opaque
Milky-white,
opaque
Milky-white,
opaque
Initial Material Added
pH To Adjust pH
8.17 0.4 ml H2SO4
(50% w/w)
6.65 0.4 ml H2SO4
(50% w/w)
8.19 0.2 ml H2SO4
(50% w/w)
7.11 0.3 ml H2SO4
(50% w/w)
7.26 0.5 ml H2SO4
(50% w/w)
7.19 1.9 ml H2SO4
(50% w/w)
1.99 3.1 ml NaOH
(ION)
pH Observations
1.98 No separation
1.95 No separation
1.98 No separation
1.98 No separation
1.99 Settling of black
sludge
1.98 Minor settling of
black material;
may just be
solids from floor
sweepings
12.03 Slight separation,
small amount of
thick, viscous
sludge at
bottom
4.2.2 Emulsion Breaking
Based on the results of the emulsion-breaking pretest, the pilot-scale emulsion
breaking step was conducted only on the floor wash water. The 16 liters of
floor wash water remaining after the emulsion-breaking pretest were poured
into a 19-liter stainless steel bucket, the pH was adjusted to 2 using 70 ml of
50% weight of acid per weight of water (w/w) sulfuric acid, and the bucket
was heated to 60°C as it was stirred with a magnetic stirring bar. The bucket
was maintained at 60°C for one hour as the stirring continued. The stirring
was then stopped, and the wastewater was allowed to cool and settle over-
night. After one hour of cooling, a noticeable settling began to occur. After 24
hours, the supernatant was pumped into a plastic tank using the peristaltic
pump. The supernatant became progressively darker as the upper layers were
pumped into the plastic tank. However, a distinct sludge layer had settled to
the bottom of the bucket, and this layer began to resuspend as the superna-
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
tant was pumped out of the tank and the pump approached the level of the
sludge. The volume of the sludge and the supernatant that could not be
pumped out without resuspeiidiiig the sludge was about 3 liters.
4.2.3
Following the emulsion breaking of the floor wash water, the contents of
Carboys #1 through #6 were poured into a plastic tank with the floor wash
supernatant, and the tank was mixed with the milk-jug mixers. Influent and
influent duplicate samples were collected from the commingled wastewater
in the plastic tank by scooping the water from the tank using a glass measur-
ing cup and pouring it into the appropriate sample bottles. Approximately
293 liters of commingled wastewater remained in the tank following sample
collection, and was hydrolyzed in two treatment batches.
Batch 1—A volume of 171 liters of the well-mixed commingled influent was
pumped into a stainless steel tank using the sump pump. Electric band heat-
ers were used to heat the tank, and 175 ml of 10 N sodium hydroxide were
added to the tank to raise the pH of the wastewater to 12. Aluminum foil was
used to insulate the tank and reduce evaporation during the heating, and the
paddle mixer was used to keep the wastewater mixed throughout the hy-
drolysis testing. After about three hours of heating, the tank achieved a tem-
perature of 60°C. The temperature of the tank varied between 51°C and 82°C
over the next 24 hours. The variation in temperature was due to a malfunc-
tioning automatic temperature controller. The temperature had to be checked
periodically using an electronic thermocouple or a glass thermometer. The
control knobs on the band heaters were adjusted manually based on these
temperature readings, with the goal of maintaining the temperature at 60°C.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours
after the tank initially reached 60°C. Samples were collected, by scooping water
from the tank into a glass measuring cup, and then pouring it into the appro-
priate sample bottles. Approximately 26 liters of wastewater were collected
for the three sample volumes, an additional 12 liters were lost due to evapo-
ration and about 133 liters of wastewater remained in the tank.
After the 24-hour hydrolysis sample was collected, the tank was cooled by
submerging a length of stainless steel tubing in the wastewater; noncontact
cooling water was circulated through the tubing while the tank contents were
stirred with the paddle mixer. Cooling the tank from 56°C, its temperature at
the time of collection of the 24-hour sample, to 27°C required about 1.5 hours,
at which point the stainless steel cooling coil was removed from the tank and
cleaned for reuse. The pH of the wastewater was adjusted from 11.4 to 7.3
using 62 mi of 50% (w/w) sulfuric acid. The wastewater, which was origi-
nally milky white, turned turbid yellow during pH adjustment. The waste-
water was then, pumped from the hydrolysis tank through a 10-rnrn filter to
the plastic activated carbon feed tank using the submersible sump pump. The
10-um filter was used to remove filterable solids that could cause plugging
problems in the carbon column. The stainless steel tank, paddle mixer, and
sump pump were cleaned, for reuse. Table A-l in. Appendix A1 lists the oper-
ating data for the first hydrolysis treatment batch.
1 This is referring to Appendix A of Pilot-Scale Tests of the Universal Treatment System for the
Pesticides Formulating, Packaging, and Repackaging Industry, September 1996 (DCN F7938).
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
Batch 2—The remaining wastewater (about 122 liters) that had not been
treated with the first batch was transferred to the cleaned stainless steel tank
for hydrolysis treatment. Electric band heaters were used to heat the tank,
and 160 ml of 10 N sodium hydroxide were added to the tank to raise the pH
of the wastewater to 12. Aluminum foil was used to insulate the tank and to
reduce evaporation during the heating, and the paddle mixer was used to
keep the wastewater mixed throughout the hydrolysis testing. After about
2.5 hours of heating, the tank achieved a temperature of 60°C. The tempera-
ture of the tank varied between 39°C and 73°C over the next 24 hours.
A final sample of the hydrolysis wastewater was collected about 24 hours
after the tank initially reached 60°C by scooping water from the tank into a
glass measuring cup and then pouring it into the appropriate sample bottles.
No interim samples were collected at 6- and 12-hour intervals as was done
for the first batch. Approximately 4 liters of wastewater were collected for the
sample and an additional 8 liters were lost due to evaporation; about 110 liters
of wastewater remained in the tank upon completion of the treatment step.
Unlike the first hydrolysis batch, the tank was cooled, and the pH of the
wastewater was adjusted to a neutral level prior to collection of the 24-hour
sample. The tank was cooled by submerging a length of stainless steel tubing
in the wastewater; non-contact cooling water was circulated through the
tubing while the tank contents were stirred with the paddle mixer. The cool-
ing of the tank from 62°C to 22°C required about 1.5 hours. The pH of the
wastewater was then adjusted from 11.8 to 7.5 using 50% (w/w) sulfuric
acid. The wastewater turned from milky white to a turbid yellow during the
pH adjustment. The 24-hour sample was then collected, and the wastewater
was pumped from the hydrolysis tank through a 10-mm filter to the plastic
activated carbon feed tank using the sump pump. The stainless steel tank,
paddle mixer, and sump pump were cleaned for reuse. Table A-2 of Appen-
dix A1 lists the operating data for the second hydrolysis treatment batch.
4.2.4 Carbon
Treatment of the wastewater from the first hydrolysis batch through acti-
vated carbon adsorption was initiated during the hydrolysis treatment of the
second batch of wastewater. The wastewater from the activated carbon feed
tank was pumped by the peristaltic pump through flexible tubing into the top
of the column. The wastewater passed down, through the column, out the
bottom of the column, and into another length of flexible tubing from which
samples were taken. The wastewater flow rate through the column was main-
tained at a rate of 82 to 88 milliliters per minute throughout the test. Samples
were collected after 60, 120, 180, and 240 liters of wastewater had passed
through the column by collecting the column effluent into glass jars and pour-
ing the treated effluent from the glass jars into the appropriate sample bottles.
The wastewater from the second hydrolysis batch was pumped into the acti-
vated carbon feed tank after about 56 liters of water from the first batch had
passed through the column and about 76 liters of wastewater from the first
batch remained in the feed tank. About 100 liters of wastewater from the
1 This is referring to Appendix A of Pilot-Scale Tests of the Universal Treatment System for the
Pesticides Formulating, Packaging, and Repackaging Industry, September 1996 (DCN F7938).
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
second hydrolysis batch were added to the feed tank. The first activated car-
bon wastewater sample (i.e., the 60-liter sample) was collected immediately
after the wastewater from the second hydrolysis batch was added to the ac-
tivated carbon feed tank. The activated carbon effluent did not have the tur-
bid, yellow color of the influent, but it did have a milky-white color. In addition,
some white deposits were observed on top of the packed carbon and in the
pore spaces between the carbon granules.
43 1 Test
Facility B formulates and packages pesticide products primarily for use in the
agricultural market. The wastewater collected from Facility B for treatability
testing consisted of an interior cleaning rinsate from the washing of
formulating and packaging equipment dedicated to a product that contains
the PAI tetrachlorvinphos. The product also contained molasses, and the rinsate
was expected to have high BODS and TOC levels. The operator cleaned the
interior of the formulation vessel using a hot, high-pressure washer and about
430 liters of water over a 50-minute timeframe. The wastewater was allowed
to drain by gravity from the formulation vessel through the packaging equip-
ment, and it was collected from a hose connected to a manifold at the bottom
of the formulation equipment and from nozzles on the packaging equipment.
Wastewater collection personnel placed about 350 liters of the wastewater
into 5-galion carboys. The wastewater had an opaque, brown appearance.
The wastewater was collected on June 27, 1995, and was transported to
Radian's Milwaukee, Wisconsin laboratory facilities via Federal Express, where
it was placed in cold storage (approximately 4°C). The UTS treatability test-
ing of Facility B wastewater began on June 29, 1995 and was completed by
July 11, 1995. Table 4-4 lists the sample point description, SCC number, date
and time of sample collection, pH, temperature, and collection method for
the samples collected during the Facility B treatability test.
4.3.1
Upon receipt in Milwaukee, the wastewater was poured from the carboys
into two stainless steel tanks, Tank 1 and Tank 2. The wastewater was dark
brown, and clumps of solids had settled to the bottoms of the carboys. After
the wastewater was poured into the stainless steel tanks, the tanks were vig-
orously mixed using the milk-jug mixers to resuspend the solids, and two
1-liter aliquots were collected for the emulsion-breaking pretest. The tanks
were then placed, in a walk-in refrigerator at 4°C to prevent biological growth.
from occurring. Emulsion breaking at pH 2 and 60°C was performed on one
of the aliquots, and the second aliquot was used as a control sample.
The first aliquot of wastewater was lowered to a pH of 1.98 by adding 15.8
ml of 36 N sulfuric acid to the wastewater and was raised to a temperature of
60°C for one hour as it was mixed; the aliquot was then allowed to cool and.
settle overnight. The aliquot turned a slightly lighter shade of brown as the
pH was adjusted downward. The second aliquot was simply allowed to settle
overnight with no heating, mixing, or pH adjustment. The emulsion-break-
ing pretest results indicated that emulsion breaking by adding acid and heat
did not significantly improve the settling of the solids or the clarity of the
supernatant over the control sample. However, solids did settle out of both
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Table 4-4
Summary of Wastewater Sampling for UTS Treatability Testing of Facility B Wastewater
Sample
UTS Influent
UTS Influent
(duplicate)
Settling
Supernatant
Hydrolysis
(6-hour)
Hydrolysis
(12-hour)
Hydrolysis
(24-hour)
SCC Sample Sample
No. Date Time
28918 06/30/95 11:30
28919 06/30/95 11:30
28920 07/04/95 11:20
28921 07/05/95 20:00
28922 07/06/95 2:14
28923 07/06/95 14:00
Temp.
pH (°C) Collection Method
NA NA Half of sample volume measured from
each tank using glass measuring cup
NA NA Half of sample volume measured from
each tank using glass measuring cup
5.85 NA Half of sample volume measured from
each tank using glass measuring cup
NA 57a Half of sample volume measured from
each tank using glass measuring cup
NA 64.5a Half of sample volume measured from
each tank using glass measuring cup
10.6a 63a Half of sample volume measured from
each tank using glass measuring cup
Activated Carbon 28924 07/10/95 8:20-8:45 7.04 NA Collected in 4-L glass jar from carbon
(60-liter) column effluent tubing
Activated Carbon 28925 07/10/95 19:08-20:30 7.02 NA Collected in 9.6-L glass jar from carbon
(120-liter) column effluent tubing
Activated Carbon 28926 07/11/95 7:22-9:47 7.00 NA Collected in 4-L glass jar from carbon
(180-liter) column effluent tubing
Activated Carbon 28927 07/11/95 14:55-19:15 7.05 NA Collected in stainless steel tank from
(240-liter) carbon column effluent tubing
"Average of both tanks.
NA - Information not available.
SCC - Sample Control Center.
the emulsion-breaking aliquot and the control aliquot; therefore, a settling
step was used instead of an emulsion-breaking step for the pilot-scale UTS
treatment test.
4.3.2 Settling
After the emulsion-breaking pretest, the stainless steel tanks were removed
from the refrigerator and their contents were remixed. Tank 1, which con-
tained 156 liters of Wastewater, was mixed using the paddle mixer, and Tank
2, which contained 163 liters of Wastewater, was mixed using the Lightning®
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mixer. Both mixers effectively mixed the contents of the tanks, so the differ-
ence in mixer types should not have affected the test results. After mixing, the
influent and influent duplicate samples were collected by scooping the
well-mixed wastewater into a glass measuring cup and pouring it into the
appropriate sample bottles. For each sample bottle, a volume of wastewater
equal to half of its capacity was collected from one tank, and the remainder
of the volume was collected from the other tank.
The wastewater was allowed to settle overnight. After settling, the superna-
tant from Tank 1 was pumped into a plastic tank using the submersible sump
pump. The supernatant volume was about 92% of the original Tank 1 vol-
ume. The supernatant from Tank 2 was pumped into a separate plastic tank.
The supernatant volume was about 91% of the original Tank 2 volume. The
stainless steel tanks, sump pump, and Lightning® and paddle mixers were
cleaned for future use.
A sample of the supernatant was collected by scooping water from the plas-
tic tanks into a glass measuring cup and pouring the wastewater into the
appropriate sample bottles. For each sample bottle, a volume of wastewater
equal to half of its capacity was collected from one tank, and the remainder
of the volume was collected from the other tank. The wastewater was then
pumped back into the stainless steel tanks and placed in the walk-in
refrigerator.
43.3
A volume of 146 liters of wastewater was contained in each stainless steel
tank at the start of the hydrolysis testing. Electric band heaters were used to
heat the tanks, and 5.3 liters of 40% sodium hydroxide (w/w) were added to
the Tank 1 to raise its pH from 5.81 to 12.02. The pH of Tank 2 was raised
from 5.78 to 12.04 through the addition of 4.9 L of 40% sodium hydroxide
(w/w). Aluminum foil was used to insulate the tanks and to reduce evapora-
tion during the heating. The Lightning® mixer (Tank 1) and the paddle mixer
(Tank 2) were used to mix the wastewater throughout the hydrolysis test.
After about five hours of heating, the tanks achieved the target temperature
of 60°C. The temperatures of the tanks varied between 52°C and 74°C over
the next 24 hours. Table A-3 of Appendix A lists the operating data for the
hydrolysis test.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours
after the tanks initially reached 60°C by scooping the well-mixed wastewater
into a glass measuring cup and pouring it into the appropriate sample bottles.
For each sample bottle, a volume of wastewater equal to half of its capacity
was collected from one tank, and the remainder of the volume was collected
from the other tank. Approximately 20 liters of wastewater were collected for
the samples from each tank; about 135 liters of wastewater remained in each
tank following completion of hydrolysis. The volume of wastewater lost due
to evaporation during the hydrolysis step was negligible.
After the 24-hour hydrolysis sample was collected, the pH of Tank 1 was
reduced from 10.6 to 6.4 using 1.22 L of 36 N sulfuric acid, and the pH of
Tank 2 was adjusted from 10.8 to 7.2 using 1.22 L of 36 N sulfuric acid. The
wastewater was pumped from each of the hydrolysis tanks through a 10-mm
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filter into separate plastic tanks using the sump pump. The filter became
clogged several times with solids from the wastewater and was replaced twice
during the pumping of each tank. The wastewater was pumped from the
plastic tanks back into the stainless steel tanks, and was then placed in the
walk in-refrigerator to prevent biological growth. The plastic tanks, paddle
mixer, and sump pump were cleaned for reuse.
4.3.4 Activated Carbon
The wastewater was removed from the walk-in refrigerator and approxi-
mately 38 liters were pumped from each tank into the plastic activated car-
bon feed tank. The stainless steel tanks were then returned to the walk-in
refrigerator to prevent biological growth. The wastewater from the activated
carbon feed tank was pumped using the peristaltic pump through flexible
tubing into the top of the column. The wastewater passed down through the
column, out the bottom of the column, and into another length of flexible
tubing from which samples were taken. The wastewater flow rate through
the column was maintained at a rate of 85 to 98 milliliters per minute through-
out the test. Samples were collected after 60, 120, and 180 liters of wastewa-
ter had passed through the column. The column effluent was collected into
glass jars and poured from the glass jars into the appropriate sample bottles.
A final sample was collected after 240 liters of wastewater had passed through
the column. Throughout the test, the activated carbon effluent had the same
brownish color as the influent.
Additional wastewater from the stainless steel tanks was pumped into the
activated carbon feed tank after the first 60 liters had been treated and about
12 liters of wastewater remained in the feed tank. Approximately 38 liters of
wastewater were pumped from each tank into the plastic activated carbon
feed tank. The stainless steel tanks were then returned to the walk-in refrig-
erator to prevent biological growth. About 27 liters remained in the activated
carbon feed tank following collection of the 120-liter sample. Another 38 li-
ters of wastewater were pumped from each stainless steel tank into the plas-
tic activated carbon feed tank. The stainless steel tanks were then returned to
the walk-in refrigerator to prevent biological growth. About 17 liters of waste-
water remained in the feed tank following collection of the 180-liter sample,
and the remaining wastewater in the stainless steel tanks was pumped into
the plastic activated carbon feed tank. About 22 liters were pumped from
Tank 1, and about 34 liters were pumped from Tank 2.
4.4 C
Facility C formulates and packages fertilizer and herbicide products, and toll
formulates products for other companies. The products formulated in the dry
formulations area contain the PAls ametryn, atrazine, cyanazine, ethalfluralin,
metolachlor, and pendiinethalin. For four to five weeks prior to sample col-
lection, Facility C accumulated interior cleaning water from the washing of
formulating and packaging equipment for dry products and wash water from
floor washings in the dry formulation area. This wastewater was stored on
site in a 20,000-gallon stainless steel tank and based on the odor and scum
content, this wastewater supported biological growth. During wastewater
collection, the wastewater was allowed to drain by gravity from the storage
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Table 4-5
Summary of Wastewater Sampling for UTS Treatability Testing of Facility C Wastewater
Sample
UTS Influent
UTS Influent
(duplicate)
sec
No.
Sample
Date
Sample
Time
29769 07/28/95 10:30
29770 07/28/95 10:30
Emulsion-Breaking 29771 07/30/95 9:30
Supernatant
Hydrolysis
(6-hour)
Hydrolysis
(12-hour)
29772 07/31/95 20:15
29773 08/01/95 2:30
29774 08/01/95 2:00
PH
7
Activated Carbon 29776 08/02/95 22:15-23:00 7
(120-liter)
Temp.
(°C) Collection Method
13
13
2.09 33
12 NA
NA NA
12 59
Hydrolysis
(24-hour)
Activated Carbon 29775 08/02/95 7:50-8:40 7 21
(60-liter)
18
Activated Carbon 29778 08/03/95 9:00-14:30 7.9 NA
(200-liter)
NA - Information not available.
SCC - Sample Control Center.
Half of sample volume measured from
each tank using glass measuring cup
Half of sample volume measured from
each tank using glass measuring cup
Half of sample volume measured from
each tank using glass measuring cup
Half of sample volume measured from
each tank using glass measuring cup
Half of sample volume measured from
each tank using glass measuring cup
Half of sample volume measured from
each tank using glass measuring cup
Collected in 4-L glass jar from carbon
column effluent tubing
Collected in 9.6-L glass jar from
carbon column effluent tubing
Collected in stainless steel tank from
carbon column effluent tubing
tank through a hose connected to a valve at the bottom of the tank into four-
teen 30-liter carboys. Approximately 420 liters of wastewater were collected.
The wastewater had an opaque, gray appearance and a strong odor.
The wastewater was collected on July 27, 1995, and was transported by van
from Facility C to Radian's Milwaukee, Wisconsin laboratory facilities. The
wastewater arrived on July 27 and was placed in the walk-in refrigerator
until treatability testing began. The UTS treatability testing of Facility C waste-
water began on July 28, 1995 and was completed by August 3, 1995. Table
4-5 lists the sample point description, SCC number, date and time of sample
collection, pH, temperature and collection method for the samples collected
during the Facility C treatability test.
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4.4.1
On July 28, 1995, the wastewater in twelve of the carboys was poured into
two stainless steel tanks, Tank 1 and Tank 2. The wastewater in the remain-
ing two carboys was held in reserve. The wastewater was an opaque, gray
color. After the wastewater was poured into the stainless steel tanks, the tanks
were vigorously mixed using the milk-jug mixers, and the influent and influ-
ent duplicate samples were collected by scooping the well-mixed wastewater
into a glass measuring cup and pouring it into the appropriate sample bottles.
For each sample bottle, a volume of wastewater equal to half of its capacity
was collected from one tank, and the remainder of the volume was collected
from the other tank.
After the influent and influent duplicate samples were collected, three 1.5-li-
ter aliquots were collected for the emulsion-breaking pretest. The tanks were
then placed in a walk-in refrigerator at 4°C to prevent biological growth.
The pH of the first aliquot of wastewater was lowered from 7.38 to 2.01 by
adding 1.1 ml of 36 N sulfuric acid. The temperature was raised to 60°C for
one hour as it was mixed; the aliquot was then allowed to cool and settle
overnight. Visible settling of a brown flocculent began to occur when the
mixing was stopped. After settling overnight, a compact gray sludge had
settled out of a translucent, yellow supernatant. The sludge occupied ap-
proximately 3% of the original aliquot volume of 1.5 liters.
The pH of the second aliquot of wastewater was raised from 7.07 to 11.74 by
adding 6.1 ml of 10 N sodium hydroxide. The temperature was raised to
60°C for one hour as it was mixed; the aliquot was then allowed to cool and
settle overnight. Visible settling of a brown flocculent began to occur when
the mixing was stopped; however, this settling was not as dramatic as the
settling that occurred in the first aliquot. After settling overnight, a gray sludge
had settled out of an opaque, brown supernatant. The sludge occupied ap-
proximately 7% of the original aliquot volume of 1.5 liters, but was not as
compact as the sludge in the first aliquot. The third aliquot was simply
allowed to settle overnight with no heating, mixing, or pH adjustment. No
visible settling occurred immediately; however, after settling overnight, about
750 ml (50% of the original volume) exhibited signs of settling. As with the
second aliquot, the settling that was observed was not as complete and the
sludge was not as compact as the first aliquot.
4.4.2
Because the pretest of the first aliquot resulted in more complete settling of
the solids and a clearer supernatant, pilot-scale emulsion breaking using heat
and acid was conducted on the Facility C wastewater. Each of the two stain-
less steel tanks of wastewater, which contained approximately 170 liters of
wastewater, were removed from the walk-in refrigerator. The pH of the tanks
was adjusted from 7.2 to 2.1 using 175 ml of 36 N sulfuric acid per tank. The
tanks were heated from their initial temperature of 7°C using the band heat-
ers. During the heating, Tank 1 was stirred with the paddle mixer and Tank 2
was stirred with the Lightning® mixer. After about six hours the tanks reached
60°C; the tanks were maintained at a temperature between 60°C and 70°C
for one hour as the stirring was continued. A 50-ml aliquot of Tank 1 waste-
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Appendix D Example Treatabllity Test Procedures Pollution Prevention Guidance Manual for the PFPR Industry
water was collected in a 50-ml glass graduated cylinder for the purpose of
more accurately identifying the volume of sludge that would settle out of the
wastewater. The mixers were then stopped, and the wastewater was allowed
to cool and settle overnight.
A noticeable settling of a brown flocculent in a translucent yellow superna-
tant began to occur as soon as the mixers were stopped. After settling over-
night the supernatant in Tank 1 appeared to be a translucent yellow color,
while the supernatant in Tank 2 appeared to be a slightly turbid green color.
The 50-ml aliquot taken from Tank 1 contained a translucent, yellow super-
natant with 2 ml (or 4%) of gray sludge.
The emulsion-breaking effluent sample was collected from the tanks by scoop-
ing the supernatant into a glass measuring cup and pouring it into the appro-
priate sample bottles. For each sample bottle, a volume of wastewater equal
to half of its capacity was collected from one tank, and the remainder of the
volume was collected from the other tank.
The supernatant from Tank 1 was pumped into a plastic tank using the sump
pump. However, turbulence from the sump pump caused the sludge to resus-
pend. The supernatant was then pumped back into Tank 1, and the emul-
sion-breaking process was repeated by heating the tank back to 60°C and
stirring its contents with the paddle mixer. While Tank 1 was reheating, the
supernatant from Tank 2 was pumped to a plastic tank using a centrifugal
pump, which did not cause the supernatant to resuspend. About 8 liters (or
4.7%) of sludge remained in the tank after the supernatant was pumped from
Tank 2.
Because Tank 1 was already at a pH of about 2, no pH adjustment was re-
quired prior to performing the emulsion-breaking step on Tank 1 a second
time. The tank was reheated to 60°C and the temperature was maintained
for one hour as the contents of the tank were mixed with the paddle mixer.
The mixer was then turned off and the tank was allowed to cool and settle for
about three hours. A translucent, yellow supernatant was then pumped from
Tank 1, using the centrifugal pump, into a separate plastic tank, which left
about 4 liters (or 2.3%) of gray sludge in Tank 1. The sludge from both Tank 1
and Tank 2 was disposed of, and the tanks, mixers, and pumps were cleaned
for future use. The plastic tanks of supernatant were cooled overnight.
4.4.3 Hydrolysis
After cooling overnight, the supernatant from Tank 1 was pumped back into
Tank 1, and the supernatant from Tank 2 was pumped back into Tank 2.
Electric band heaters were used to heat the tanks, and 550 ml of 40% sodium
hydroxide (w/w) was added to each tank to raise the pH. The pH of Tank I
was raised from 2.05 to 11.33, and the pH of Tank 2 was raised from 2.05 to
11.43. During the hydrolysis testing, the paddle mixer was used to stir Tank
1, and the Lightning® mixer was used to stir Tank 2. After about five hours of
heating, the pH reading for each tank was approximately 11; therefore, an
additional 50 ml of 40% sodium hydroxide (w/w) was added to each tank to
raise its pH to 12. After about five and one-half hours of heating, the tanks
achieved the target temperature of 60°C. The temperatures of the tanks var-
ied between. 50°C and 70°C over the next 24 hours. The temperatures of the
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tank were not recorded; therefore, no table of operating data is provided for
the hydrolysis of wastewater from Facility C. About one hour after the tanks
achieved their target temperature, aluminum foil was placed over the tops of
the tanks to insulate the tanks and to reduce evaporation during the heating.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours
after the tank initially reached 60°C by scooping the well-mixed wastewater
into a glass measuring cup and pouring it into the appropriate sample bottles.
For each sample bottle, a volume of wastewater equal to half of its capacity
was collected from one tank, and the remainder of the volume was collected
from the other tank. The wastewater in both tanks appeared translucent yel-
low throughout the hydrolysis testing. Sampling personnel noted that a small
amount of brown sludge settled to the bottoms of the samples. However, this
sludge became resuspended in the samples that were preserved to neutral or
acidic pH, resulting in a slightly turbid brown sample.
After the 24-hour hydrolysis sample was collected, Tanks 1 and 2 were cooled
by submerging a length of stainless steel tubing in the two wastewaters;
noncontact cooling water was circulated through the tubing while the tank
contents were stirred with the paddle mixer. Approximately 45 minutes were
required to cool Tank 1 from its temperature of 59°C to 35°C; Tank 2 required
about 40 minutes to lower the temperature from 55°C to 35°C.
4.4.4 Carbon
Following hydrolysis, the pH of Tank 1 was adjusted from about 12 to 7 using
100 ml of 36 N sulfuric acid. The pH of Tank 2 was also adjusted using 100 ml of
36 N sulfuric acid, which lowered its pH from about 12 to 4. An additional 60 ml
of 40% sodium hydroxide (w/w) was added to Tank 2 to raise its pH to 7. The
wastewater turned a slightly turbid brown color during the pH adjustment.
Using the sump pump, 30 liters of wastewater from Tank 1 were pumped
through a 10-mm filter into a plastic tank with volume gradations marked on
the side of the tank. The filtered water was then poured into the plastic activated
carbon feed tank. This process was repeated with 30 liters of wastewater
from Tank 2; however, the filter became clogged with solids from the waste-
water and was replaced. An additional 30 liters of wastewater were pumped
again from each tank using the same procedures, but again the filter become
clogged and had to be replaced. Yellow-brown solids were caked on the fil-
ters when they were replaced. The total volume of wastewater pumped to
the activated carbon feed tank was 120 liters. Tank 1 and Tank 2 were then
placed in the walk-in refrigerator to prevent biological growth in the waste-
water.
The wastewater from the activated carbon feed tank was pumped by the
peristaltic pump through flexible tubing into the top of the column. The waste-
water passed down through the column, out the bottom of the column, and
into another length of flexible tubing from which samples were taken. The
activated carbon effluent was initially clear, but it developed a faint
yellow-green tinge after about 60 liters of wastewater had passed through
the column. The wastewater flow rate through the column was maintained
at a rate of 82 to 93 milliliters per minute throughout the test. A sample was
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collected after 60 liters of wastewater had passed through the column by
collecting the column effluent into a glass jar and pouring the treated effluent
from the glass jar into the appropriate sample bottles.
About six hours after the collection of the 60-liter sample, an additional vol-
ume (35 liters) of wastewater from Tank 1 was pumped, using the submers-
ible sump pump, through a 10-mrn filter into a plastic tank with volume
gradations marked on the side of the tank. The filtered water was poured
into the plastic activated carbon feed tank, and the filter, which had become
caked with yellow-brown solids during the pumping, was replaced. This pro-
cess was repeated with 35 liters of wastewater from Tank 2 and then with the
remaining 8 liters of wastewater from Tank 1 and the 22 liters from Tank 2.
About one hour after the remaining wastewater was filtered into the acti-
vated carbon feed tank, the flow rate through the carbon column decreased
to about 40 milliliters per minute, and a cake of solids was visible on top of the
carbon packed in the column. The wastewater in the activated carbon feed
tank was then refiltered using a 5-min filter by pumping the wastewater from
the carbon feed tank through the 5-inm filter into a clean plastic tank.
Yellow-brown solids accumulated on the filter during the filtration. The acti-
vated carbon column was then backwashed with about 1 liter of distilled
water, which caused the caked solids at the top of the column to break apart.
However, some air became entrapped in the column during the backwashing.
A vacuum of about 18 centimeters of mercury was applied to the column for
15 minutes while the column was tapped with a mallet to remove the en-
trapped air. Some air bubbles remained in the spaces between the carbon
granules following this procedure. The column was then restarted and the
flow rate of wastewater from the activated carbon feed tank was adjusted to
85 milliliters per minute.
A sample was collected after a total of 120 liters of wastewater had passed
through the column by collecting the column effluent into a glass jar and
pouring the treated effluent from the glass jar into the appropriate sample
bottles. Two additional samples of the carbon effluent were planned, one at
180 liters of effluent and one at 240 liters of effluent, but only a total of about
220 liters of wastewater was available for activated carbon treatment be-
cause wastewater was lost to evaporation during the hydrolysis and emul-
sion-breaking steps. Therefore, only one additional sample was taken after
200 liters of wastewater had passed through the column.
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APPENDIX E
Guidance on the Baseline
Monitoring Report (BMR) and
General Pretreatment Regulation
Requirements
Introduction
Appendix E includes guidance from EPA on requirements of the Baseline
Monitoring Report (BMR) and general pretreatment requirements. This ap-
pendix comprises two attachments that consist or or are excerpted from al-
ready issued EPA guidance.
Attachment 1 is an excerpt from the EPA Pretreatment Bulletin #13, which
discusses the applicability of categorical pretreatment standards in specific
situations, including zero discharge industrial users. A PFPR facility is a cat-
egorical industrial user (CIU) and is subject to the PFPR regulations of "no
discharge of wastewater pollutants" (or the P2 alternative) when there is a
potential to discharge any of the PFPR process wastewater covered by the
PFPR regulation. If the only wastewater that a PFPR facility discharges (or
has the potential to discharge) is not a regulated process wastewater under
the PFPR effluent guidelines, then the PFPR facility is not covered by the
PFPR effluent guidelines and the facility is not a CIU for that discharge for
purposes of 40 CDR Part 403 (General Pretreatment Stadards). Attachment I
provides more detail on the definition of potential to discharge for industrial
users.
Attachment 2 is a copy of a memornadum from the Engineering and Analy-
sis Division and the Permits Division with EPA's Office of Water to the Water
Management Division Directors of all 10 EPA regions, discussing the Baseline
Monitoring Report requirements for PFPR facilities. The memorandum briefly
discusses the background of the PFPR rule, the issues associated with com-
plying with both the P2 alternative and BMR requirements, and guidance for
PFPR facilities in fulfilling the BMR requirements until the General Pretreat-
ment Regulations can be modified to accomodate the PFPR compliance re-
quirements.
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Appendix E Guidance on the BME and Requirements Pollution Prevention Guidance Manual for the PFPR Industry
1: OF
TO
The Environmental Protection Agency (EPA) recently issued guidance con-
cerning the applicability of categorical pretreatment standards to zero-
discharge industrial users (IU) in a letter from Jeffrey Lape, Acting Chief,
Pretreatment and Multimedia Branch, to Robert Babcock, Pretreatment Field
Support Unit, Michigan Department of Natural Resources, dated April 16,
1993. If an IU is subject to categorical pretreatment standards, it satisfies one
of four criteria for an IU to be deemed a significant industrial user (SIU) as
defined by 40 CFR Part 403.3(t). Once defined an SIU, minimum require-
ments are established for the control authority (e.g., issuance of an individual
control mechanism, annual inspection and monitoring).
An SIU includes "All industrial users subject to Categorical Pretreatment
Standards under 40 CFR Part 403.6 and 40 CFR Chapter I, Subchapter N"
(40 CFR Part 403.3(t)(l)). For this purpose, an IU is deemed to be a categori-
cal industrial user (C1U) when it meets the applicability requirements for a
specific category and is subject to pretreatment standards for existing sources
(PSES) or pretreatment standards for new sources (PSN'S).
Although there are many industrial categories with promulgated effluent
guidelines and standards, not all contain PSES or PSNS requirements. Where
an IU falls within a promulgated industrial category that only provides refer-
ence to the general pretreatment provisions in 40 CFR Part 403 (or its prede-
cessor, Part 128), this alone would not be considered PSES or PSNS
requirements, and the IU would not be considered to be subject to categorical
pretreatment standards. This position was articulated in Pretreatment Bulle-
tin #3 (November 6, 1987) and in a memorandum entitled "Non-Consent
Decree Categorical Pretreatment Standards" from James Elder, Director, Office
of Water Enforcement and Permits, dated August 24, 1988.
The following address the applicability of categorical pretreatment standards
in specific situations, including zero-discharge lUs.
1. Where an IU operates a categorical process, but no regulated process waste-
water is discharged or has the potential to be discharged to the publicly owned
treatment works (POTW), should the IU be considered a CIU, and therefore
an SIU, even if it discharges other unregulated process or sanitary wastes?
Answer: No. If the only wastestream that an IU discharges or could poten-
tially discharge to the POTW is not subject to PSES or PSNS requirements, it is
not a CIU for purposes of that discharge or for purposes of 40 CFR Part 403.
An example of this situation would be a metal finisher that discharges its
sanitary wastes to the POTW and all of its regulated process wastewater to a
receiving water under a National Pollutant Discharge Elimination System
(NPDES) permit. This facility would not be considered a categorical industry
for purposes of the SIU definition since no PSES or PSNS requirements would
apply. Of course, rtoncategorical lUs are still subject to the General Pretreat-
*Reprinted from the U.S. EPA Pretreatment Bulletin #13, October 1993, Office of Wastewater
Enforcement and Compliance.
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Appendix E Guidance on the BME and Requirements Pollution Prevention Guidance Manual for the PFPR Industry
ment Regulations and local limits, may warrant periodic inspection and moni-
toring by the control authority, and may be considered an SIU because of the
other criteria in 40 CFR 403(t).
An important example to consider here would be a metal finisher that per-
forms any one of the six primary qualifying operations for which there is .no
potential to discharge at any time but also performs one of the 40 ancillary
process operations for which there is a corresponding indirect discharge. This
facility would be considered a categorical industry because PSES or PSNS
requirements would apply to the regulated wastestream from the ancillary
process. This position has been articulated in a letter from Baldwin Jarrett,
U.S. EPA, to Grace Scott, Michigan Department of Natural Resources, dated
April 28, 1992.
2.A. If a categorical pretreatment standard requires testing or a certification
statement (i.e., certification that a particular pollutant or process is not used,
as in the case of paper and pharmaceutical standards) and a facility certifies
that it does not use the pollutant of concern, is it still a CIU?
Answer: Yes. These are specific PSES and PSNS requirements and an IU that
meets the applicability requirements of the categorical standard would be
considered a CIU and thus an SIU.
2.B. Is the certification a one-time statement, or is it required as part of the
categorical industry's continued compliance report?
Answer: If the categorical pretreatment standard requires a testing or certifi-
cation statement, the CIU must report and certify that it is not using the
pollutant of concern, and this must be done semiannually as required by 40
CFR Part 403.12, unless specified otherwise by the categorical pretreatment
standard. This certification provision only applies where prescribed by a cat-
egorical pretreatment standard. Any IU that is subject to a categorical pre-
treatment standard (PSES or PSNS) that does not contain a certification
requirement must sample and report on all regulated pollutants at least twice
per year even if it is not using the pollutant of concern.
3. If an IU is subject to a categorical pretreatment standard which provides a
requirement of "no discharge of pollutants," or similar requirement, is the IU
considered a CIU?
Answer: Yes, provided that there is a potential to discharge a wastestream
that is subject to the standard. There are a number of categorical pretreat-
ment standards which have PSES or PSNS requirements that contain such
language. An IU subject to this particular PSES or PSNS requirement is con-
sidered a CIU, and thus an SIU. However, if the only wastestream that an IU
discharges or could potentially discharge to the POTW is not subject to PSES
or PSNS (i.e., sanitary wastes), then the analysis would be as set forth in
question I above and the facility would not be considered a CIU. This further
develops the position articulated in the memorandum referred to above from
James Elder, dated August 24, 1988, and another memorandum from James
Elder, dated February 16, 1989, entitled "Conventional Pollutants Regulated
by Categorical Pretreatment Standards."
4. If a facility has a regulated process wastestream and employs a treatment
system that results in 100% recycle, is it considered a CIU?
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Appendix E Guidance on the BME and Requirements Pollution Prevention Guidance Manual for the PFPR Industry
Answer: The situation here is essentially the same as in question 1. If the IU
uses a 100% recycle of regulated process wastewater and does not have the
potential to discharge regulated process wastewater to the POTW, the IU
would not be considered a C1U.
CIUs that employ a 100% recycle or claim, no discharge of regulated process
wastewater should be thoroughly evaluated through an. on-site inspection to
determine if there is any reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement
due to accidental spills, operational problems, or other causes. If the control
authority concludes that no regulated process wastewater can reach the
POTW, and therefore, the IU has no reasonable potential for adversely affect-
ing the POTW's operation or for violating any pretreatment standard or re-
quirement, the IU need not be designated a CIU and thus an SIU, as provided
by 403.3(t).
As a precaution, however, even if the control authority determines that a
zero discharge facility is not a CIU, it is suggested the control authority issue
a permit (or equivalent individual control mechanism) to the facility contain-
ing at least the following conditions:
• "No discharge of process wastewater is permitted."
• Requirements to notify the POTW of any changes in operation resulting in
a potential for discharge.
• Requirements to certify semiannually that no discharge has occurred.
• Notice that the POTW may inspect the facility as .necessary to assess and
assure compliance with the "no discharge requirement."
• Requirements to comply with Resource Conservation and Recovery Act
(RCRA) and state hazardous waste regulations regarding the proper dis-
posal of hazardous waste.
If you have any questions concerning this guidance, please contact: Permits
Division (4203), U.S. EPA, 401 M Street, SW, Washington, DC 20460, (202)
260-9545.
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Appendix E Guidance on the BMR and Requirements Pollution Prevention Guidance Manual for the PFPR Industry
ATTACHMENT 2: BASELINE MONITORING REPORT REQUIREMENTS FOR
PESTICIDE FORMULATING, PACKAGING, AND REPACKAGING FACILITIES
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
APR 3 I99T
OFFICE OF
MEMORANDUM WATER
SUBJECT: Baseline Monitoring Report Requirements for Pesticide Formulating, Packaging
and Repackaging Facilities
_il>iii&. 6 5tzc.Ci.
FROM: Sheila Frace, Acting Director
Engineering and Analysis Division
James F. Pendergast, Acting Director v^ t-lv**.. -7 . \
Permits Division
TO: Water Management Division Directors (Region 1-10)
Background
The Pesticide Formulating, Packaging and Repackaging (PFPR) final effluent guidelines
and pretreatment standards were published in the Federal Register on November 6, 1996 (61 FR
575 18) and became effective on January 6, 1997. The pretreatment regulations at 40 CFR
403 12(b) require PFPR facilities discharging to Publicly Owned Treatment Works (POTWs) to
submit a Baseline Monitoring Report (BMR) within 180 days of the effective date of the rule
(July 7, 1997). One of the requirements of the BMR is for the facility to "submit the results of
sampling and analysis identifying the nature and concentration ... of regulated pollutants in the
Discharge from each regulated process."
The final PFPR regulation provides PFPR facilities a choice between zero discharge and a
pollution prevention (P2) compliance alternative (referred to as the "P2 Alternative"). The P2
Alternative measures compliance against a set of pollution prevention, recycle and reuse practices
as well as the demonstration of "well operated and maintained" treatment system. The P2
Alternative does not include numerical standards for pesticide active ingredients (PAIs) that are
within the scope of the regulation; and therefore, does not specifically include monitoring
requirements.
Issues
The PFPR rule is the first rule of its kind to include a P2 compliance alternative. For this
reason the BMR requirements in 40 CFR 403 12 do not directly address a situation where
compliance is measured through a P2 Alternative rather than a numerical standard and
corresponding monitoring.
Prkttd «NH Soy/Canon f* x
oomm • MM S0% ^note •
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Appendix E Guidance on the BMR and Requirements Pollution Prevention Guidance Manual for the PFPR Industry
Recently, industry representatives, state coordinators, and POTW pretreatment personnel
have requested guidance on how to comply with the BMR requirements for those facilities
choosing the P2 Alternative.
We recognize that in order to address this situation, ultimately, the regulation requiring
submittal of the BMR (403.12(b)) will need to be modified. We plan to make these modifications
as part c/f the larger streamlining initiative that is currently underway. However, such
modifications will not be finalized prior to the BMR submittal date of July 7, 1997.
We have developed the following guidance in order to assist these facilities prior to the
modification of the Pretreatment Regulations.
Guidance
In order to comply with the requirements of 40 CFR 403.12(bX5), an Industrial User
(IU) subject to the PFPR pretreatment standards (40 CFR 455), should submit a BMR containing
the following: (1) information on the sampling and analysis of priority pollutants (see 40 CFR
423, Appendix A); (2) identification of PAI(s) which the IU expects to have in the discharge in
the next 12 months; and (3) a list of the P2 practices, if any, the IU currently engages in which.
affect the discharge of PAIs and priority pollutants. Note that the IU must still comply within1?
other sections of 403.12(b).
For additional information, contact Shari Zuskin at (202) 260-7130 or Patrick Bradley at
(202) 260-6963.
cc: Regional Pretreatment Coordinators (Region 1-10)
Susan Lepow, OGC-Water
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f
Definitions
Administrator: The Administrator of the U.S. Environmental Protection
Agency.
Aerosol container (DOT) leak testing wastewaters: Wastewaters from pres-
surization/Ieak testing of pesticide product containers to meet DOT
shipping requirements.
Agency: The U.S. Environmental Protection Agency.
Appropriate pollution control technology: The wastewater treatment tech-
nology listed on Table 10 to Part 455 (Appendix A) for a particular
PAI(s) including an emulsion breaking step prior to the listed technol-
ogy when emulsions are present in the wastewater to be treated.
B.t.: Bacillus thuringiensis, a microorganism pesticide active ingredient that
is excluded from the scope of the final PFPR rule.
BAT: The best available technology economically achievable, as described in
Section 304(b)(2) of the Clean Water Act.
BCT: The best conventional pollutant control technology, as described in Sec-
tion 304(b)(4) of the Clean Water Act.
BEJ: Best engineering judgment.
Bench-scale operation: Laboratory testing of materials, methods, or processes
on a small scale, such as on a laboratory worktable.
Binder: An ingredient added in order to form films, such as a drying oil or
polymeric substance.
BMP or BMPs: Best management practice(s), as described in Section 304(e)
of the Clean Water Act.
BOD5: Five-day biochemical oxygen demand. A measure of biochemical de-
composition of organic matter in a water sample. It is determined by
measuring the dissolved oxygen consumed by microorganisms to oxi-
dize the organic contaminants in a water sample under standard labo-
ratory conditions of five days and 20°C. BOD5 is not related to the
oxygen requirements in chemical combustion.
BPJ: Best professional judgment.
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
BPT: The best practicable control technology currently available, as described
in Section 304(b)(l) of the Clean Water Act.
Bulk product: Formulated product held in inventory prior to packaging into
marketable containers.
CAA: Clean Air Act. The Air Pollution Prevention and Control Act (42 U.S.C
7401 et. seq.), as amended, inter alia, by the Clean Air Act Amend-
ments of 1990 (Public Law 101-549, 104 Stat. 2399).
CFR: Code of Federal Regulations, published by the U.S. Government Printing
Office. A codification of the general and permanent rules published in
the Federal Register by the Executive departments and agencies of the
federal government. The Code is divided into 50 titles which repre-
sent broad areas subject to federal regulation. Each title is divided into
chapters which usually bear the name of the issuing agency, and each
chapter is divided into parts covering specific regulatory areas. Cita-
tions of the Code of Federal Regulations include title, part, and section
number (e.g., 40 CFR 1.1 - title 40, part 1, and section 1).
Changeover: Changing from one pesticide product to another pesticide prod-
uct, to a non-pesticide product, or to idle equipment condition.
CN: Abbreviation for total cyanide.
CO: Abbreviation for carbon monoxide.
COD: Chemical oxygen demand (COD) - A nonconventional bulk parameter
that measures the total oxygen-consuming capacity of wastewater.
This parameter is a measure of materials in water or wastewater that
are biodegradable and materials that are resistant (refractory) to bio-
degradation. Refractory compounds slowly exert demand on down-
stream receiving water resources. Certain of the compounds measured
by this parameter have been found to have carcinogenic, mutagenic,
and similar adverse effects, either singly or in combination. It is ex-
pressed as the amount of oxygen consumed by a chemical oxidant in
a specific test.
Combustion device: An individual unit of equipment, including but not lim-
ited to, an incinerator or boiler, used for the thermal oxidation of or-
ganic hazardous air pollutant vapors.
Contract hauling: The removal of any waste stream from the plant or facility,
excluding discharges to sewers or surface waters.
Control authority: (1) The POTW if the POTW's submission for its pretreat-
ment program (§403.3(t)(l)) has been approved in accordance with
the requirements of §403.11; or (2) the approval authority if the sub-
mission has not been approved.
Conventional pollutants: Constituents of wastewater as determined in Sec-
tion 304(a)(4) of the Clean Water Act and the regulations thereunder
(i.e., biochemical oxygen demand (BOD5), total suspended solids (TSS),
oil and grease, fecal coliform, and pH).
CSF: Confidential statement of formula.
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
CWA: Clean Water Act. The Federal Water Pollution Control Act Amend-
ments of 1972 (33 U.S.C. 1251 et seq.), as amended, inter alia, by the
Clean Water Act of 1977 (Public Law 95-217) and the Water Quality
Act of 1987 (Public Law 100-4).
Device (packaging): Any instrument or conveyance (other than a firearm)
which is intended for trapping, destroying, repelling, or mitigating
any pest or any other form of plant or animal life (other than man and
other than bacteria, virus, or other microorganism on or in living man
or other living animals), but not including equipment used for the
application of pesticides when sold separately therefrom.
Direct discharger: The discharge of a pollutant or pollutants directly to a
water of the United States with or without treatment by the discharger.
DOT: Department of Transportation.
Effluent: Wastewater discharges.
EPA: The U.S. Environmental Protection Agency.
Equivalent system: A wastewater treatment system that is demonstrated in
literature, treatability tests, or self-monitoring data to remove a simi-
lar level of pesticide active ingredient or priority pollutants as the ap-
plicable appropriate pollution control technology listed in Table 10 to
Part 455 (Appendix A).
FATES: FIFRA and TSCA Enforcement System.
FDA: Food and Drug Administration.
PDF: Fundamentally different factors.
FIFRA: The Federal Insecticide, Fungicide, and Rodenticide Act, as amended
(7 U.S.C. 135 et.seq.).
Formulation: The process of mixing, blending, or diluting one or more pesti-
cide active ingredients with one or more other active or inert ingredi-
ents, without a chemical reaction that changes one active ingredient
into another active ingredient, to obtain a manufacturing use product
or an end use product.
FR: Federal Register, published by the U.S. Government Printing Office, Wash-
ington, D.C. A publication making available to the public regulations
and legal notices issued by federal agencies. These include Presiden-
tial proclamations and Executive Orders and federal agency docu-
ments having general applicability and legal effect, documents required
to be published by act of Congress and other federal agency docu-
ments of public interest. Citations of the Federal Register include vol-
ume number and page number (e.g., 55 FR 12345).
GMPs: Good Manufacturing Practices.
GRAS: Generally Recognized as Safe (label given to certain items by the Food
and Drug Administration).
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
Group 1 mixtures: Any product whose only pesticidal active ingredient(s) is:
a common food/food constituent or nontoxic household item; or is a
substance that is generally recognized as safe (GRAS) by the Food and
Drug Administration (21 CFR 170.30, 182, 184, and 186) in accor-
dance with good manufacturing practices, as defined by 21 CFR Part
182; or is exempt from F1FRA under 40 CFR Part 152.25.
Group 2 mixtures: Those chemicals listed on Table 9 to Part 455 of the final
regulation, which is included in Appendix A of this document.
Hazardous waste: Any material that meets the Resource Conservation and
Recovery Act definition of "hazardous waste" contained in 40 CFR
Part 261.
Incinerator: An enclosed combustion device that is used for destroying or-
ganic compounds. Auxiliary fuel may be used to heat waste gas to
combustion temperatures. Any energy recovery section present is not
physically formed into one manufactured or assembled unit with the
combustion section; rather, the energy recovery section is a separate
section following the combustion section and the two are joined by
ducts or connections carrying flue gas.
Indirect discharge: The discharge of a pollutant or pollutants into a publicly
owned treatment works (POTW) with or without pretreatment by the
discharger.
Inert ingredient: Any substance (or group of structurally similar substances
if designated by EPA), other than a pesticide active ingredient, which
is intentionally included in a pesticide product.
Inorganic wastewater treatment chemicals: Inorganic chemicals that are
commonly used in wastewater treatment systems to aid in the removal
of pollutants through physical/chemical technologies such as chemi-
cal precipitation, flocculation, neutralization, chemical oxidation, hy-
drolysis, and/or adsorption.
Interior wastewater sources: Wastewater that is generated from cleaning or
rinsing the interior of pesticide formulating, packaging, or repackag-
ing equipment; or from rinsing the interior of raw material drums,
shipping containers or bulk storage tanks; or cooling water that comes
in direct contact with pesticide active ingredients during the formu-
lating, packaging, or repackaging process.
Leaks and spills: Leaks and spills to be quantified are those which contain a
pesticide active ingredient(s), or those which are combined prior to
disposal with leaks or spills containing an active ingredient(s).
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
Line: Equipment and interconnecting piping or hoses arranged in a specific
sequence to mix, blend, impregnate, or package, or repackage pesti-
cide products. These products contain one or more pesticide active
ingredients with other materials to impart specific desirable physical
properties for a product or device, or to achieve a desired pesticide
active ingredient concentration for a particular product or device, or
to package it into marketable containers. The line begins with the open-
ing of shipping containers or the transfer of active ingredient(s) and
other materials from a manufacturer or another formulator/packager,
or from inventory of bulk storage. The line ends with the packaging or
repackaging of a product into marketable containers or into tanks for
application.
Manufacture: The production of pesticide active ingredient(s) involving a
chemical change(s) in the raw material(s) or intermediate precursors.
Microorganisms: Registered pesticide active ingredients that are biological
control agents listed in 40 CFR 152.20(a)(3) including Eucaryotes (pro-
tozoa, algae, fungi), Procaryotes (bacteria), and Viruses.
Minimum level: The level at which an analytical system gives recognizable
signals and an acceptable calibration point.
New Source: As defined in 40 CFR 122.2, 122.29, and 403.3 (k), a new source
is any building, structure, facility, or installation from which there is
or may be a discharge of pollutants, the construction of which com-
menced (1) for purposes of compliance with New Source Performance
Standards, after the promulgation of such standards under CWA sec-
tion 306; or (2) for the purposes of compliance with Pretreatment Stan-
dards for New Sources, after the publication of proposed standards
under CWA section 307(c), if such standards are thereafter promul-
gated in accordance with that section.
Noncontact cooling water: Water used for cooling in formulating/packag-
ing operations which does not come into direct contact with any raw
material, intermediate product, by-product, waste product, or finished
product. This term is not intended to relate to air conditioning sys-
tems.
Non-water quality environmental impact: An environmental impact of a
control or treatment technology, other than to surface waters.
Noncontinuous or intermittent discharge: Discharge of wastewaters stored
for periods of at least 24 hours and released on a batch basis.
Nonconventional pollutants: Pollutants that are neither conventional pol-
lutants nor toxic pollutants listed at 40 CFR Section 401, including
many pesticide active ingredients.
Nondetect value: A concentration-based measurement reported below the
minimum level that can reliably be measured by the analytical method
for the pollutant.
NO%: Nitrogen oxides.
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
NPDES: The National Pollutant Discharge Elimination System, a federal pro-
gram requiring industry dischargers, including municipalities, to ob-
tain permits to discharge pollutants to the nation's water, under Section
402 of the CWA.
NRDC: Natural Resources Defense Council.
NSPS: New source performance standards. This term refers to standards for
new sources under Section 306 of the CWA.
OPCSF: Organic Chemicals, Plastics, and Synthetic Fibers Manufacturing
Point Source Category (40 CFR Part 414).
P2: Pollution prevention (see Source Reduction).
Packaging: Enclosing or placing a formulated pesticide active ingredient into
a marketable container.
PAI (Pesticide Active Ingredient): Any technical grade active ingredient used
for controlling, preventing, destroying, repelling, or mitigating any
pest. The PAIs may make up only a small percentage of the final prod-
uct which also consists of binders, fillers, diluents, etc.
Pesticide: A pesticide means any substance or mixture of substances intended
for preventing, destroying, repelling, or mitigating any pest or intended
for use as a plant regulator, defoliant, or desiccant other than any
article that:
1) Is a new animal drug under Federal Food, Drug, and Cosmetic
Act (FFDCA) Section 201 (w), or
2) Is an animal drug that has been determined by regulation of
the Secretary of Health and Human Services not to be a new
animal drug, or
3) Is an animal feed under FFDCA Section 201 (x) that bears or
contains any substances described by 1 or 2 above.
See CFR §122.5 for a definition of pest, §152.8 for a description of
products that are not pesticides because they are not for use against
pests. See §152.10 for a description of products that are not pesticides
because they are not deemed to be used for pesticidal effect and §152.15
for a description of pesticide products required to be registered under
the Federal Fungicide, Insecticide, and Rodenticide Act.
Pesticide-producing establishment: As defined under FIFRA, any site where
a pesticide product, active ingredient, or device is produced, regard-
less of whether the site is independently owned or operated, and re-
gardless of whether the site is domestic and producing a pesticidal
product for export only, or foreign and producing any pesticidal prod-
uct for import into the United States.
PFPR/Manufacturers: Pesticide manufacturers that also perform pesticide
formulating, packaging, and/or repackaging at their facilities.
PFPR: Pesticide formulating, packaging, and repackaging operations.
Pilot-scale: The trial operation of processing equipment which is the inter-
mediate stage between laboratory experimentation and full-scale op-
eration in the development of a new process or product.
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
PM: Particulate matter.
Point source category: A category of sources of water pollutants that are
included within the definition of "point source" in Section 502(14) of
the CWA.
Pollutant (to water): Chemical constituent, dredged spoil, solid waste, incin-
erator residue, filter backwash, sewage, garbage, sewage sludge, mu-
nitions, chemical wastes, biological materials, certain radioactive
materials, heat, wrecked or discarded equipment, rock, sand, cellar
dirt, and industrial, municipal, and agricultural waste discharged into
water. See CWA Section 502(6); 40 CFR 122.2.
Pool chemicals: Pesticide products that are intended to disinfect or sanitize,
reducing or mitigating growth or development of microbiological or-
ganisms including bacteria, algae, fungi or viruses in the water of
swimming pools, hot tubs, spas or other such areas in the household
and/or institutional environment, as provided in the directions for
use on the product label.
POTW or POTWs (Publicly owned treatment works): A treatment works as
defined by Section 212 of the CWA, which is owned by a state or
municipality (as defined by Section 502(4) of the Act). This definition
includes any devices and systems used in the storage, treatment, recy-
cling and reclamation of municipal sewage or industrial wastes of a
liquid nature. It also includes sewers, pipes, and other conveyances
only if they convey wastewater to a POTW Treatment Plant. The
term also means the municipality as defined in Section 502(4) of the
CWA, which has jurisdiction over the indirect discharges to and the
discharges from such a treatment works.
PPA: Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seq., Pub.L. 101-
508, November 5, 1990).
Pretreatment standard: A regulation specifying industrial wastewater efflu-
ent quality required for discharge to a POTW.
Priority pollutants: The toxic pollutants listed in 40 CFR Part 423, Appendix
A.
Process: The steps performed on a pesticide active ingredient or group of
pesticide active ingredients, beginning with the opening of shipping
containers containing pesticide active ingredient(s) (or transfer of ac-
tive ingredient(s) from a manufacturing or another formulating op-
eration), including the physical mixing of these pesticide active
ingredients with each other or with nonpesticide materials, and con-
cluding with the packaging of a product into marketable containers.
Process wastewater collection system: A piece of equipment, structure, or
transport mechanism used in conveying or storing a process waste-
water stream. Examples of process wastewater collection system equip-
ment include individual drain systems, wastewater tanks, surface
impoundments, and containers.
PSES: Pretreatment standards for existing sources of indirect discharges, un-
der Section 307(b) of the CWA.
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
psig: Pounds per square inch gauge.
PSNS: Pretreatment standards for new sources of indirect discharges, under
Section 307(b) and (c) of the CWA.
R&D: Research and Development.
RCRA: Resource Conservation and Recovery Act of 1976, as amended. (42
U.S.C. 6901, et seq.).
RCRA empty: A container or an. inner liner removed, from a container that
has held any hazardous waste, except a waste that is a compressed
gas or that is identified as an acute hazardous waste listed in 40 CFR
261.31, 261.32, or 261.33(e) is empty if:
(i) All wastes have been removed that can be removed using the prac-
tices commonly employed to remove materials from that type of con-
tainer (e.g., pouring, pumping, and aspirating), and
(ii) No more than 2.5 centimeters (one inch) of residue remain on the
bottom of the container or inner liner, or
(iii)(A) No more than 3 percent by weight of the total capacity of the
container remains in the container or inner liner if the container is less
than or equal to 110 gallons in size, or
(B) No more than 0.3 percent by weight of the total capacity of the
container remains in the container or inner liner if the container is
greater than 110 gallons in size. (40 CFR 261.7).
Reagents: Chemicals used to cause a chemical reaction.
Repackaging: The direct transference of a single pesticide active ingredient
or single formulation from any marketable container to another mar-
ketable container, without intentionally mixing in any inerts, diluents,
solvents, or other active ingredients, or other materials of any sort.
Reuse: The use in product formulation or cleaning operations of all or part of
a waste stream produced by an operation which would otherwise be
disposed of, whether or not the stream is treated prior to reuse, and
whether the reused waste stream is fed to the same operation or to
another operation.
Sanitizer products: Pesticide products that are intended to disinfect or sani-
tize, reducing or mitigating growth or development of microbiological
organisms including bacteria, fungi or viruses on inanimate surfaces
in the household, institutional, and/or commercial environment and
whose labeled directions for use result in the product being discharged
to Publicly Owned Treatment Works (POTWs). This definition shall
also include sanitizer solutions as defined by 21 CFR Part 178.1010
and pool chemicals as defined in this section (455.10(q)). This defini-
tion does not include liquid chemical sterilants (including sporicidals)
exempted by 455.40(f) or otherwise, industrial preservatives, and. water
treatment microbiocides other than pool chemicals.
SBREFA: Small Business Regulatory Enforcement Fairness Act of 1996 (5
U.S.C. 801).
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
Septic system: A system which collects and treats waste water, particularly
sanitary sewage. The system is usually composed of a septic tank which
settles and anaerobically degrades solid waste, and a drainfield which
relies on soil to adsorb or filter biological contaminants. Solid wastes
are periodically pumped out of the septic tank and hauled to off-site
disposal.
Shipping container rimsate: The water or solvent which is generated by the
rinsing of shipping containers.
SIC: Standard Industrial Classification. A numerical categorization system
used by the U.S. Department of Commerce to denote segments of in-
dustry. An SIC code refers to the principal product, or group of prod-
ucts, produced or distributed, or to services rendered by an operating
establishment. SIC codes are used to group establishments by the pri-
mary activity in which they are engaged.
Solvent: An ingredient added to a formulation in order to dissolve the active
ingredient to form a uniformly dispersed mixture. Also liquids, other
than water, used to clean pesticide formulating and packaging equip-
ment.
Source reduction: The reduction or elimination of waste generation at the
source, usually within a process. Any practice that: 1) reduces the
amount of any hazardous substance, pollutant, or contaminant en-
tering any waste stream or otherwise released into the environment
(including fugitive emissions) prior to recycling, treatment, or disposal;
and 2) reduces the hazards to public health and the environment as-
sociated with the release of such substances, pollutants, or contami-
nants.
SOx: Sulphur oxides.
Special or nonroutine conditions: Situations which do not normally occur
during routine operations. These may include equipment failure, use
of binders, dyes, carriers and other materials that require additional
cleaning time, or larger volumes of solvents and/or water.
SRRP: Source Reduction Review Project.
Stand-alone PFPR facility: A PFPR facility where either: 1) no pesticide manu-
facturing occurs; or 2) where pesticide manufacturing process waste-
waters are not commingled with PFPR process wastewaters. Such
facilities may formulate, package, or repackage or manufacture other
nonpesticide chemical products and be considered a "stand-alone"
PFPR facility.
Subcategory C: Pesticide formulating, packaging, and repackaging (PFPR),
including pesticide formulating, packaging, and repackaging occur-
ring at pesticide manufacturing facilities (PFPR/Manufacturers) and
at stand-alone PFPR facilities.
Subcategory E: Repackaging of agricultural pesticide products at refilling
establishments (refilling establishments).
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Appendix f Definitions Pollution Prevention Guidance Manual for the PFPR Industry
Technical Development Document: Development Document for Best Avail-
able Technology, Pretreatment Technology, and New Source Perfor-
mance Technology for the Pesticide Formulating, Packaging, and
Repackaging Industry (EPA 821-R-96-019).
Technical grade of active ingredient: A material, containing an active ingre-
dient: 1) which contains no inert ingredient, other than one used for
purification of the active ingredient and 2) which is produced on a
commercial or pilot-plant production scale (whether or not it is ever
held for sale).
Toxic pollutants: The pollutants designated by EPA as toxic in 40 CFR Part
401.15. Also known as priority pollutants.
TSCA: Toxic Substances Control Act (15 U.S.C. 2613).
TSS: Total suspended solids.
UIC: Underground Injection Control.
UMRA: Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4).
UTS: Universal Treatment System, a treatment system envisioned by EPA to
be sized to handle small volumes of wastewater on a batch basis and
would combine the most commonly used and effective treatment tech-
nologies for PAIs (hydrolysis, chemical oxidation, activated carbon,
and sulfide precipitation (for metals)) with one or more pretreatment
steps, such as emulsion breaking, solids settling, and filtration.
VOCs: Volatile organic compounds.
Waters of the United States: The same meaning set forth in 40 CFR 122.2.
Wet air pollution or odor pollution control system scrubbers: Any equip-
ment using water or water mixtures to control emissions of dusts, odors,
volatiles, sprays, or other air pollutants.
Zero/P2 Alternative Option: Regulatory option promulgated by EPA that
allows each Subcategory C facility a choice: to meet a zero discharge
limitation or to comply with a pollution prevention (P2) alternative
that authorizes discharge of PAIs and priority pollutants after various
P2 practices are followed and treatment is conducted as needed.
Zero discharge: No discharge of process wastewater pollutants to waters of
the United States or to a POTW.
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