40 CFR Appendix Table 8 to Part 455 - 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.
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).
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).
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.
(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).
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.
(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.]
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)).
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.