United States Office of Water EPA-821-B-98-017

Environmental Protection Office of Pollution Prevention and Toxics June 1998

Agency Washington, DC 20460 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.
Office of Water

and

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

Washington, DC 20460

EPA-821-B-98-017

June 1998

Final

Pollution Prevention (P2) Guidance Manual

for the

Pesticide Formulating, Packaging,

and Repackaging Industry:

Implementing the P2 Alternative
ii

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 commercial 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 regulated 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.
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, complying with the P2 Alternative Option. EPA has received numerous requests from refilling establishments questioning how the final rule applies

to them. This foreword is an aid to facilities in determining if the information 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 refilling establishments covered

under Subcategory E must

achieve zero discharge, the P2

alternative guidance provided

in this manual is not applicable. However, if a refilling establishment also performs

PFPR operations covered under Subcategory C, for which

the P2 alternative is an

option,that facility may be interested in obtaining a copy of

this manual, as they could

commingle their Subcategory

E wastewater with their Subcategory C wastewater and

choose to follow the Subcategory C regulations (i.e., zero discharge or the

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 standalone 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.

More specifically, the final rule for Subcategory C facilities requires either

zero discharge of pollutants or the P2 alternative, which allows a discharge of pollutants if certain P2 practices are implemented, followed by

iii
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 pollutants; there is no option for an allowable discharge after implemeting

approved P2 practices. The zero discharge 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, 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
Table of Contents

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 PFPR Final Regulation (40 CFR Part 455) ......................... 161

Appendix B PFPR Compliance Documentation (Sample Forms) ....... 213

Appendix C Table 10 to Part 455 (with CAS Numbers)........................ 241

Appendix D Example Treatability Test Procedures ............................... 261

Appendix E Guidance on the Baseline Monitoring Report (BMR)

and General Pretreatment Regulation Requirements ...... 279

Appendix F Definitions ............................................................................... 285

v
Acknowledgments

Shari Zuskin of the U.S. Environmental Protection Agency (EPA), Office of

Water, Engineering and Analysis Division, was the work assignment manager 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
1

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 Alternative Option of the effluent limitations guidelines and standards for the

PFPR industry (61 FR 57517). The opportunities and compliance methodologies discussed in this manual specifically relate to water use and reuse, wastewater 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, federal and state auditors, and consultants.

Why Implement P2?

Effective P2 programs offer several benefits, summarized in Table 1-1, when incorporated as part of facility operations. Although this manual concentrates on

water management practices, a P2 assessment and the

resulting operation changes often lead to overall improvements in the efficiency of PFPR process operations 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 information on how to implement these and other practices as well as aid in compliance with the PFPR effluent

guidelines and standards. The Environmental Protection Agency’s (EPA’s) Office of Research and Development 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.

CHAPTER 1

Introduction

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
CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry

2

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 practices. Table 1-2 shows EPA’s preferred hierarchy of environmental management 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.

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 guidelines 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 Appendix 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 pesticide products can be found starting on page 57548 of the final rule FR notice, in Appendix A of this manual.)

Table 1-2

Environmental Management Hierarchy

1. Pollution should be prevented or reduced at the source whenever feasible (“source reduction”);

2. 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 ■ 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.
CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry

3

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 discharge of process wastewater pollutants. The

rule also offers the option of a Pollution Prevention Alternative to Subcategory C facilities

that agree to implement certain P2, reuse, and

recycle practices (and treatment when necessary). These facilities receive a discharge allowance referred to as the P2 allowable discharge

(see Appendix A for the definition of allowable

discharge). As shown in Figure 1-1, if the facility 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 exempt 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 discharge, they are covered and are in compliance with zero discharge. If they

wish to discharge that wastewater, they must comply with the P2 alternative.

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

■ 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.
CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry

4

Determining Applicability of Rule

Figure 1-1. Determining Applicability of Rule

NO

YES

Facility Has

In-Scope

Products

No Potential to Discharge

(not covered by rule)

Facility Generates

Wastewater

Wastewater

Generated Is Defined

in Rule as PFPR

Process Wastewater

YES

YES

NO

NO

Facility Has Potential

(e.g., hookups to POTW

in process areas) to

Discharge PFPR Process

Wastewaters

NO

YES

Facility Is Candidate

for P2 Alternative

Facility Is In Compliance

with Zero Discharge

(and candidate for P2 Alternative)

Not covered by rule

Not covered by rule

Facility Discharges

Process Wastewaters

Facility

Packages

Pesticide

Products

Facility

Formulates

Pesticide

Products

Facility

Repackages

Pesticide

Products

Not Within

Scope of Rule

Facility Must Comply

with PFPR Effluent Guideline

Pesticide Products

Within Scope or

Containing Active

Ingredients Within

Scope

NO NO NO

NO

YES YES YES

YES
CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry

5

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/pretreatment 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 example, the facility would agree to include them in their NPDES permit for

direct discharges or in an individual control mechanism with the control authority for indirect discharges. This choice can be made either on a facilitywide 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 practices that are required as part of compliance with the P2 alternative form the

basis of the manual; however, other nonrequired P2 opportunities that a facility may choose to implement are also presented. Because the manual focuses 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.

How to Use This Manual

This manual is organized into 10 chapters and six appendices:

■ Chapter 2 provides basic descriptions of PFPR operations (e.g., dry formulating, 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 performance, compliance with the PFPR effluent guidelines rule, and certification paperwork;

■ Chapter 8 presents case studies to provide guidance to the user in complying with the PFPR regulation;
CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry

6

■ Chapter 9 provides a list of resources for additional help in complying

with the regulation;

■ Chapter 10 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-sponsored treatability test.

■ Appendix E presents guidance on requirements of the Baseline Monitoring Report (BMR) and the applicability of categorical pretreatment standards 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 conjunction 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 describing P2 opportunities for the PFPR industry and evaluating compliance

with the PFPR effluent guidelines rule, and whether you thought the manual

was “user friendly.”
CHAPTER 2

PFPR Operations

7

Table 2-1

PFPR Operations

■ Liquid Formulating

■ Dry Formulating

■ Liquid Packaging

■ Dry Packaging

■ Aerosol Packaging

■ Pressurized Gas Formulating and Packaging

■ Repackaging

This chapter describes seven types of basic operations, shown in Table

2-1, used in the PFPR industry. The descriptions presented are simplified 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, including herbicides, insecticides, and fungicides. These facilities typically have physical divisions between

formulating and packaging operations, and between

dry and liquid operations.

Because of the large number of pesticide products a

facility may handle, most PFPR facilities operate on

the principle of “just-in-time” production. This principle basically dictates that products are made on customer demand to reduce the space needed to keep

large inventories on hand. However, because production 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 equipment 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, depending 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 product 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.
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

8

Liquid Formulating

Liquid formulations contain mixtures of several raw materials, including pesticide active ingredients, inert ingredients, 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 product. A storage tank may also be used on the formulating line to hold the

formulated pesticide product, prior to a packaging step. Facilities may receive 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, refillable containers). These raw materials are either piped to the formulation vessel 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 formulated pesticide product to the packaging line. Other items that may be part of

the line are premixing tanks, stirrers, heaters, bottle washers, and air pollution control equipment. Some lines may also contain refrigeration units for

formulation, storage units, scales, and other equipment.

Figure 2-1. Liquid-Based Formulation Line
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

9

Dry Formulating

Dry formulations contain active and inert ingredients; 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 tablets), or microencapsulated dusts or granules. They are formulated 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 ingredients with a monomer and allowing the mixture to polymerize 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 emulsified 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-pressure and temperature tanks for

impregnating solids with active

ingredient, a vacuum or other

type of drying equipment, tanks

or bins for storage of the formulated pesticide product, pelletizers, 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 transferred to formulation equipment

by screw conveyors (consisting of

a helix mounted on a shaft and

turning in a trough), through elevators, or by pouring.

Figure 2-2. Granular Formulation Line

Figure 2-3. Dry Spray-Coated Formulation Line
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

10

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, refrigeration units on formulation and storage equipment, scales, and air pollution 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. Figure 2-4 depicts a liquid packaging line. Small quantities 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 automated. 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 packaged 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 containers or bags. Larger quantities may be packaged

on an automated line, similar to liquid packaging

lines.

Figure 2-5. Dry Packaging Line

Figure 2-4. Liquid

Packaging Line
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

11

Figure 2-6. Aerosol Packaging Line

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 propellant 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 ruptures. The aerosol packaging line may also include a can washer to remove residue 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.

Pressurized Gas Formulating and Packaging

Some pesticide products are formulated and packaged as

pressurized gases. Figure 2-7 depicts a pressurized gas production 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 containers. Liquid ingredients are placed in a holding tank prior to formulation. Formulating and packaging operations for these products typically occur in one
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

12

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. Hydrostatic 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 operations, except the “raw material” is an already formulated

product that has been packaged for sale. Repackagers often purchase formulated pesticide products, transfer the

product to new containers with customer-specific labeling,

and sell them to distributors.

Figure 2-7. Pressurized Gas Formulating and Packaging Line
CHAPTER 2 PFPR Operations Pollution Prevention Guidance Manual for the PFPR Industry

13

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 typically have capacities ranging from 100 to 500 gallons. Minibulks may be owned

by the refilling establishment, the pesticide registrant, or by the end user. Production 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 refilling establishment.
15

CHAPTER 3

Pollution Prevention Glossary

Many PFPR facilities use P2 practices that conserve water, reduce the

amount of pollutants in wastewater, or eliminate wastewater generation 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 equipment, a picture or illustration and description of the equipment is provided.

Throughout the manual, terms defined in this glossary will be shown in italicized bold print.

The techniques presented in this chapter have been identified 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 controlling the volume of wastewater generated, facilities can

often reuse a larger overall percentage of their wastewater. 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 techniques that were observed in the industry.]

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 (typically 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.

P2 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.
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

16

Some facilities dedicate just their formulation tanks, thereby eliminating one

of the most highly concentrated wastewater streams generated at their facility. Other facilities have dedicated storage tanks or entire formulating, packaging, 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 significantly 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 formulating or packaging line, that is used to make products that have common

ingredients (such as s-triazine pesticides) or similar uses (such as herbicides used on corn crops). This type of dedication can significantly reduce

product changeover cleaning and routine cleaning. In addition, most cleaning 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 products that have a common base solvent (e.g., water, isopropyl alcohol). This

type of dedication eliminates water-contaminated solvent rinses and solvent-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 cleaning. In addition, most cleaning rinsates from common-base-dedicated equipment 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 reuse, 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 flushing the container three times, using a volume of the diluent equal to approximately 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-
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

17

tainer, no more than 3% by weight of the container capacity remains in containers 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 removed by draining, pouring, pumping, or aspirating, unless rinsing is required 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 solvent 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 recovers 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 equipment, such as high-pressure washers, to effectively clean drums, while minimizing 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 product 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 certain 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 preventive 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 fittings 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 formulation (e.g., product with same ingredients but at varying concentrations). In
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

18

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 equipment, dedication of equipment, and other production practices, they can minimize 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 disposal or treatment.

Inventory Management

Many PFPR facilities operate inventory management systems to track raw

materials, finished products, and waste products. These systems are also useful 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 reduce 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 formulating 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 scrubbers, 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 without the use of water by collecting dust and other particles generated during production, particularly on dry product lines. Some facilities are able to

reuse the solid materials collected from those devices in the pesticide production 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 replacement of the contaminated water is necessary, or with a bleed stream
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

19

(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 periodically to ensure visibility and to reduce the presence of residues that may

adhere to cans leaving the bath. Facilities operating DOT test baths with continuous overflow can recirculate the water for reuse. If necessary for visual

clarity, PFPR facilities can recirculate the water through a filter (e.g., diatomaceous 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 cleaning 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 cleaning. 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 ensure 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 efficiently. 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.

Wed nesday
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

20

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 pollutants, 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 disposed 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 rinsing 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 wastewater, are often cleaned using equipment such as brushes, scrapers, and vacuums. 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 electrical classification and exhaust filtration) can be used to collect solids and

dusts that have settled on dry formulating and packaging equipment during 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

1 2 3
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

21

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 cleaning water in a collection tank, which is easily emptied after the cleaning process, 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 operations, 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 equipment 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. Typical 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, lowvolume 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.
CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry

22

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 reduction 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 wastewaters 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 recovering solvent for reuse and reducing the quantity of solvent-aqueous

changeover water that is disposed of as waste.
CHAPTER 4

Conducting the P2 Audit

23

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 compliance with the final rule. However, this P2

audit is not required by the rule and is not mandatory. The P2 audit described in this chapter

focuses on water use and wastewater generation. This audit is not designed to be a comprehensive 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 guidelines and standards. For information on P2 audit 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 (practices listed in Table 8 of the final rule plus wastewater 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

P2 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.

The P2 Audit

Completing a P2 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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

24

basis (i.e., product family/process line/process unit). Facilities that implement 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 industry. 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 opportunities 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 presented 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 variety 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 Purpose

Table A Identification of Helps users summarize in detail 

Wastewater Sources potential wastewater sources through

review of process operations.

Table B Evaluation of PFPR P2, Helps users summarize in detail P2,

Recycle, and Reuse recycle, and reuse practices, and evaluate

Practices their current use, whether they can be

implemented by the facility, and any

required modifications.

Table C Summary of PFPR Helps users summarize the compliance

Compliance Decisions decision for each wastewater source

identified in Table A. The completion

of the P2 audit results in a preliminary

compliance decision for each source.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

25

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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

26

Table A: Identification of Wastewater Sources Table A

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 wastewater 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 identified 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 “Comments” illustrate this example.

Figure 4-1. Identifying Wastewater Stream Types and Sources

Table A. Identification of Wastewater Sources

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a. 

atrazine, 

metolachlor, and 

inert drums

20 drums of atrazine, 5 drums of 

metolachlor, and 5 drums of inerts 

used each week.

waste products prior to reuse or 

disposal of the containers.

1.b. 

copper naphthenate 

and solvent drums

5 drums of copper naphthenate and 5 

drums of solvent used each week.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

Stream type not generated at this 

facility.

products associated with PFPR 

operations.

2.b.

Stream type not generated at this 

facility.

3. Formulating Equipment 

Interior Cleaning - routine 

3.a. 

liquid formulation 

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

cleaning, cleaning due to product tank # 1 then water (TD)

changeover, or special cleaning of 

the interior of any formulating 

3.b. 

liquid formulation 

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

equipment, including formulation tank # 2 then water (TD)

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

3.c. 

liquid formulation 

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

include water, detergent, or tank # 3 then water (TD)

solvent. 3.d. 

dry formulation tank Dry process line, rinsed monthly 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
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

27

The “Stream Type” column lists potential wastewater stream types. An entry 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 consideration, if it is determined that a wastewater stream does not exist at the facility, 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, operation 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; therefore, 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 formulating 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.

Table A
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

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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 Generated”, 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 volume), including measurement units, generated in the “Volume Generated” column. 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 volumes 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

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a. 

atrazine, 

metolachlor, and 

inert drums

B 5 gal/drum 30 drums 

per week

20 drums of atrazine, 5 drums of 

metolachlor, and 5 drums of inerts 

used each week.

waste products prior to reuse or 

disposal of the containers.

1.b. 

copper naphthenate 

and solvent drums B 5 gal/drum 10 drums 

per week

5 drums of copper naphthenate and 5 

drums of solvent used each week.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

Stream type not generated at this 

facility.

products associated with PFPR 

operations.

2.b.

Stream type not generated at this 

facility.

3. Formulating Equipment 

Interior Cleaning - routine 

3.a. 

liquid formulation B 50 gal/run 1 run/week

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

cleaning, cleaning due to product tank # 1 then water (TD)

changeover, or special cleaning of 

the interior of any formulating 

3.b. 

liquid formulation B 50 gal/run 2 runs/week

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

equipment, including formulation tank # 2 then water (TD)

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

3.c. 

liquid formulation B 50 gal/run 1 run/week

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

include water, detergent, or tank # 3 then water (TD)

solvent. 3.d. 

dry formulation tank B 100 gal Monthly Dry process line, rinsed monthly 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

Table A. Identification of Wastewater Sources
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

29

Table A

Figure 4-3. Collecting Waste Characterization Data

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 characterization 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 separate sheet listing additional active ingredients present in the waste stream.

Next, record the other constituents (e.g., solids, solvents, detergents, emulsifiers) in the wastewater that may affect reuse or implementation of a P2 initiative under the “Wastewater Matrix” column. Finally, enter wastewater

management and treatment information using the codes provided in the footnote 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 multiple discharge practices for the same source.

Table A. Identification of Wastewater Sources

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a. 

atrazine, 

metolachlor, and 

inert drums

B 5 gal/drum 25 drums 

per week

atrazine, 

metolachlor water, inerts RE

20 drums of atrazine, 5 drums of 

metolachlor, and 5 drums of inerts 

used each week.

waste products prior to reuse or 

disposal of the containers.

1.b. 

copper naphthenate 

and solvent drums B 5 gal/drum 10 drums 

per week

copper 

naphthenate

water, 

solvent DI 5 drums of copper naphthenate and 5 drums of solvent used each week.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

Stream type not generated at this 

facility.

products associated with PFPR 

operations.

2.b.

Stream type not generated at this 

facility.

3. Formulating Equipment 

Interior Cleaning - routine 

3.a. 

liquid formulation B 50 gal/run 1 run/week atrazine, metolachlor,

solvent, 

water, RE, TD

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

cleaning, cleaning due to product tank # 1 copper naphthenate inerts then water (TD)

changeover, or special cleaning of 

the interior of any formulating 

3.b. 

liquid formulation B 50 gal/run 2 runs/week atrazine, metolachlor,

solvent, 

water, RE, TD

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

equipment, including formulation tank # 2 copper naphthenate inerts then water (TD)

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

3.c. 

liquid formulation B 50 gal/run 1 run/week atrazine, metolachlor,

solvent, 

water, RE, TD

Herb. #1/#2: tank rinsed w/ water (TD) 

Fungicide: tank rinsed with solvent (RE),

include water, detergent, or tank # 3 copper naphthenate inerts then water (TD)

solvent. 3.d. 

dry formulation tank B 100 gal Monthly carbaryl water, solids DI Dry process line, rinsed monthly 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
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

30

Table B: Evaluation of PFPR P2, Recycle, and Reuse

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 additional 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 limitation/pretreatment 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 Practice” lists the P2, recycle, and reuse practices found in the final rule (see Appendix 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 application 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 complete Table B are detailed below.

Table B
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

31

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 regulation. If there is no corresponding practice in the final regulation, “NA” appears 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 practice 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

Figure 4-4. Identifying P2 Practices

Facility: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

7. Dedicated Equipment for Solvent- and Water-Based Products

Facility dedicates PFPR production 

equipment to water-based vs. solventbased products. Dedicated solvent-based 

No 1,3,4

7-1 9

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 10 Interior rinsate is stored for reuse in 

future formulations of the same or Yes 3

compatible product (note: does not 

include drum/shipping container rinsate). No 3

8-2 4

Dry carrier material is stored and reused 

in future formulation of the same or 

compatible product or disposed of as 

solid waste.

Yes 3

8-3 4

Interiors of dry formulation equipment 

are cleaned with dry carrier prior to water 

rinse.

No 3.d.

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.)

Table B. Evaluation of PFPR P2, Recycle, and Reuse Practices
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

32

Step 2: Identify Practices In Use Table B

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.

Figure 4-5. Identifying Use of P2 Practices

Table B. Evaluation of PFPR P2, Recycle, and Reuse Practices

Facility: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

7. Dedicated Equipment for Solvent- and Water-Based Products

Facility dedicates PFPR production 

equipment to water-based vs. solventbased products. Dedicated solvent-based 

No 1,3,4 NA

7-1 9

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 Fungicide formulation tank

8-1 10 Interior rinsate is stored for reuse in 

future formulations of the same or Yes 3 solvent rinsate is stored for 

reuse.

compatible product (note: does not 

include drum/shipping container rinsate). No 3 NA

8-2 4

Dry carrier material is stored and reused 

in future formulation of the same or 

compatible product or disposed of as 

solid waste.

Yes 3 Dry material is reused in 

product.

8-3 4

Interiors of dry formulation equipment 

are cleaned with dry carrier prior to water 

rinse.

No 3.d. NA

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.)
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

33

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 column entitled “Could Facility Implement this Practice in the Future?” If a

particular practice is already in use at the facility, answer “NA” in this column. 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 permitting authority for the modification and have it approved prior to implementing the modification. Figure 4-6 presents an example of the types of

information recorded when completing Step 3.

Table B

Figure 4-6. Identifying Future Use of P2 Practices

Facility: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

7. Dedicated Equipment for Solvent- and Water-Based Products

Facility dedicates PFPR production 

equipment to water-based vs. solventbased products. Dedicated solvent-based No 1,3,4 NA Yes Facility could dedicate one of the tanks 

to solvent-based products.

7-1 9

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 Fungicide formulation tank Solvent-based fungicide

8-1 10 Interior rinsate is stored for reuse in 

future formulations of the same or Yes 3 solvent rinsate is stored for 

reuse. NA

compatible product (note: does not 

include drum/shipping container rinsate). No 3 NA No BIOGROWTH

For the water-based herbicides, facility 

has demonstrated evidence of 

biological growth over a typical 

8-2 4

Dry carrier material is stored and reused 

in future formulation of the same or 

compatible product or disposed of as 

solid waste.

Yes 3 Dry material is reused in 

product. NA

8-3 4

Interiors of dry formulation equipment 

are cleaned with dry carrier prior to water 

rinse.

No 3.d. NA No

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.)

Table B. Evaluation of PFPR P2, Recycle, and Reuse Practices
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

34

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.

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 defined 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/low-volume washers, spray balls,

or steam cleaners) that are used to rinse PFPR equipment interiors. Identify 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 smallvolume interior rinsate discharges.

• 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 areas are cleaned. In particular, note the type of dry process cleaning equipment 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.

Table B

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.

P2 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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

35

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 procedures regarding the maintenance schedule for each major valve and fitting, and whether they have documented the performance of the

maintenance checks.

• 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 written 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.

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 rinsing 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.

Table B

P2 Alternative Compliance

All records documenting training programs and preventive maintenance

schedules should be attached to the completed P2 audit form.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

36

• 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 applies 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.

P2 Alternative Compliance Table B

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.

P2 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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

37

• 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.

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 solventbased production.

8. Interior Rinsate Storage and Reuse

Identify if the facility uses interior rinsate storage and reuse, specifically noting if the rinsate is reused immediately in the next batch or is reused after

being stored while other products are formulated and packaged.

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 dedication 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 formulation, (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.

Table B

P2 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.

P2 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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

38

• 9-2: Production Sequencing—Review production records to identify Table B

whether production sequencing is implemented and whether it reduces or

eliminates the generation of equipment cleaning rinsates.

10. Inventory Management (non-Table 8 practice)

Inventory management systems for raw materials, finished products, and

waste products typically include centralized sheltered storage, access controls (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 management system is a key to using the P2 practice of interior rinsate storage and

reuse.

• 10-1: Inventory Management System—Identify if an inventory management system is in place at the facility.

• 10-2: System Control—Identify which of the system controls listed in Section 10 of the “Practices” column are in place at the facility, and how these

controls have benefited P2 at the facility. Also identify potential applications of inventory management to facilitate additional wastewater reuse.

11. Training and Written Standard Operating Procedures (nonTable 8 practice)

Employee training and written standard operating procedures and incentive

programs have been shown to be useful tools in identifying and implementing 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. Other P2 Practices/Equipment

List and describe innovative or otherwise unique P2 techniques in the “Comments” 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.
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

39

Table C: Summary of PFPR Compliance Decisions Table C

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 alternative 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 comply 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 Decision”, write “P2 alternative”, “P2 alternative with mod”, or “Zero discharge.”1

 If “P2 alternative with mod” is selected, write the applicable

modification code in the “Comments” column. Figure 4-7 presents an example of the preliminary compliance decisions for the example sources presented previously in Table A.

1

 Note: In the example in Figure 4-7, “Zero Discharge” rather than “P2 Alternative” is entered for any

stream that is completely reused. This convention was chosen to differentiate between streams that are

not discharged and streams that may be discharged and, therefore, may require treatment. Alternatively,

wastewater that is completely recycled or reused could be recorded as “P2 Alternative.”

Figure 4-7. Making Preliminary Compliance Decisions

Facility: Location:

Date: Prepared by:

Stream Type Source

Preliminary 

Compliance 

Decision Comments1

Wastewater 

to be 

Treated?

Final

Compliance 

Decision

Approval Date 

for Nonlisted 

Modifications

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a. 

atrazine, metolachlor, and 

inert drums Zero discharge

waste products prior to reuse or 

disposal of the containers.

1.b. 

copper naphthenate and 

solvent drums

P2 alternative 

with 

modification

REFURB - Drum 

refurbisher will not accept 

solvent-rinsed drums

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

3.a. 

liquid formulation 

tank # 1

Zero discharge

Dedicate Tank # 1 to 

solvent-based fungicide 

production

changeover, or special cleaning of 

the interior of any formulating 

equipment, including formulation 

3.b. 

liquid formulation 

tank # 2

P2 alternative 

with mod

BIOGROWTH 

Dedicate Tank # 2 and # 3 

to herbicide production

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

include water, detergent, or 

3.c. 

liquid formulation 

tank # 3

P2 alternative 

with mod

BIOGROWTH 

Dedicate Tank # 2 and # 3 

to herbicide production

solvent. 3.d. 

dry formulation tank P2 alternative

1

 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.)

Table C: Summary of PFPR Compliance Decisions
CHAPTER 4 Conducting the P2 Audit Pollution Prevention Guidance Manual for the PFPR Industry

40

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 alternative, the user can skip to Chapter 7 for the discussion on compliance paperwork. 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 allowable 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.
41

Wastewater treatment technologies are used by PFPR facilities to remove 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 ingredients and priority pollutants, and references other technologies that also

effectively treat PFPR wastewaters. A list of documents that contain more detailed information on these technologies is included at the end of this chapter.

The technologies presented in this chapter have been identified through sampling visits to PFPR and pesticide manufacturing facilities and through EPAsponsored treatability tests. The implementation of these, or equivalent,

technologies has allowed PFPR facilities to reuse a greater percentage of wastewater 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 ingredients with inert materials (e.g., surfactants, emulsifiers, petroleum hydrocarbons) 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 necessary pretreatment step to facilitate the removal of pollutants from PFPR

wastewaters. Although emulsion breaking is a pretreatment step, its importance in the treatment of PFPR

wastewaters can make it a major part of the technology 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 breaking, such as chemically assisted clarification, are not

CHAPTER 5

Wastewater Treatment Technologies

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.
CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry

42

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 specific 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 conducted 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 conducted by EPA using these technologies 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.

Treatment Technologies

Activated Carbon Adsorption

Activated carbon effectively removes organic constituents from wastewater

through the process of adsorption. The term “activated carbon” refers to carbon 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 dissolved 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 carbon adsorption. These constituents adhere to the stationary carbon material,

so the wastewater leaving the carbon bed has a lower concentration of pesticide than the wastewater entering the carbon bed. Eventually, as the pore

spaces in the carbon become filled, the carbon becomes exhausted and ceases
CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry

43

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 characteristics 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 competition may result in low adsorption or even desorption of some constituents.

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 millimeter. Granular carbon is more commonly used in wastewater treatment;

powdered carbon is used less frequently because the small particle size creates 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 regeneration are the most common methods to regenerate carbon used for wastewater 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 similar, 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.
CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry

44

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., hydrogen peroxide, ozone, and potassium permanganate) or with the use of ultraviolet light. Although these other methods of chemical oxidation can effectively

treat PFPR wastewaters, they typically entail higher capital and/or operating and maintenance costs, greater operator expertise, and/or more extensive wastewater pretreatment than alkaline chlorination. Additional

information about these other methods can be found in the Final PFPR Technical 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 pollutants 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 throughout 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. Hydroxide 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, hydrolysis is a destructive technology in which the original molecule forms two or

more new molecules. In some cases, the reaction continues and other products 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-
CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry

45

tions can be catalyzed at low pH, high pH, or both, depending on the reactant 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).

Other Treatment Technologies

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.
CHAPTER 5 Wastewater Treatment Technologies Pollution Prevention Guidance Manual for the PFPR Industry

46

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 Repackagers Treatability Database

Report, March 1994 (DCN F7185)

Pesticide Formulators, Packagers, and Repackagers Treatability Database Report

Addendum, September 1995 (DCN F7700)

Pilot-Scale Tests of the Universal Treatment System for the Pesticides

Formulating, Packaging, and Repackaging Industry, September 1996 (DCN

F7938)

Evaluation of the Universal Treatment System of Pesticide Formulator/Packager

Wastewater, September 1993 (DCN F6446)

Membrane Technologies

Membrane Filtration Treatability Study, July 1991 (DCN F5541)

Membrane Separation Study for the Pesticide Formulator Packager Project,

January 1994 (DCN F6445)

Final Pilot-Scale Membrane Separation Study, August 1996 (DCN F7939)

Hydrolysis

Hydrolysis

Treatability of PAIs by Hydrolysis - Bench-Scale Tests, November 1990 (DCN

F5544)

Hydrolysis Treatability Field Study, September 1990 (DCN F5546)

Pyrethrin Wastewater Treatability Report, June 1993 (DCN F6167)

Activated Carbon

Activated Carbon Isotherms for Pesticides, October 1989 (DCN F5885)

Accelerated Column Testing - Pesticide Manufacturing Wastewaters - Phase 2,

September 1991 (DCN F5884)

Carbon Adsorption Isotherms for Toxic Organics, April 1980 (DCN F5786)

Emulsion Breaking

Emulsion Breaking Performance Study - Final Report, August 1996 (DCN F7937)

Note: These documents can be found in the administrative record supporting the

final PFPR rulemaking, which can be accessed through EPA’s Office of Water. The

EPA Water Docket is open from 9 a.m. to 3:30 p.m. and can be reached at

(202)260-3027. The document control number (DCN) is included in parentheses at

the end of the reference. Reasonable fees may be charged for copying.

See Chapter 9 for a list of contacts.
47

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 allows 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 wastewater source. Chapter 5 describes the most cost-effective

wastewater treatment technologies that are demonstrated

to reduce the pesticide active ingredients present in PFPR

wastewater. Chapter 6 describes the three components

of a treatability test and provides guidance to facilities

on selecting and testing appropriate wastewater treatment 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

Treatability Test Components

■ Identification of Wastewater Sources and

Treatment Technologies;

■ Preparing the Test Plan; and

■ Summary and Evaluation of Test Results.

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 repackaged at the facility must have analytical methods for use in wastewater.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

48

and operating parameters to act as surrogates for pesticide active ingredient

analyses, comply with permitting requirements, or optimize treatment performance.

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 operating parameters to be evaluated for the specific treatment technologies, determines 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 calculating 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 facilities, 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. Example 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.

Table D: Identification of Wastewater Sources and

Treatment Technologies

Before a treatability test is undertaken, the facility should identify the wastewater 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

Treatability Test Tables

Table Title Purpose

Table D Identification of Wastewater Sources Helps users list wastewater sources requiring

and Technologies treatment, the potential constituents, and the

appropriate treatment technologies.

Table E Summary and Evaluation of Test Results Helps users summarize and evaluate the test

results for each technology and the final

treatment train.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

49

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 addition, 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.

Figure 6-1. Identifying Wastewater Sources

Table D Wastewater Sources Requiring Treatment Prior to a P2 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.

1

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.

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology1

Alternate 

Treatment 

Technology1

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 3.a. Metolachlor BOD 5 , 

Interior Cleaning - routine 

cleaning, cleaning due to product 

liquid formulation 

tank # 2

Pendimethalin 

Pyrethrin II

TOC, TSS

changeover, or special cleaning of 3.b. Metolachlor BOD 5 , 

the interior of any formulating 

equipment, including formulation 

liquid formulation 

tank # 3

Pendimethalin 

Pyrethrin II

TOC, TSS

and/or storage tanks, pipes, and 3.c. Linalool BOD 5 , 

hoses. Cleaning materials may 

include water, detergent, or 

dry formulation tank Pendimethalin TOC, TSS

solvent. 3.d.

Table D. Identification of Wastewater Sources and Treatment Technologies

 1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_______________________________
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

50

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 numbers is also included in Appendix C. These control technologies include activated 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” column.

Alternate technologies, such as membrane filtration, may also effectively treat pesticide active ingredients present in the facility’s wastewater. In specific cases, these other technologies may be more

cost-effective than the technologies listed in Table 10 of the rule. Facilities 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 technologies 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., activated carbon adsorption or hydrolysis) to remove pesticide active ingredients. 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 chemical 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 wastewaters 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 TechTable D

Appropriate Technologies

■ Table 10 listed technology

[§455.10(g)]

■ Equivalent system

[§455.10(h)]

■ Pesticide manufacturer

treatment system.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

51

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.

1

U.S. EPA, Risk Reduction Engineering Laboratory, 26 West Martin Luther King Drive, Cincinnati,

OH, 45268

2

Final Pesticides Formulators, Packagers, and Repackagers Treatability Database Report (DCN

F7185) and the Pesticide Formulators, Packagers, and Repackagers Treatability Database Report

Addendum (DCN F7700)

Figure 6-2. Identifying Wastewater Treatment Technologies

Table D

Table D. Identification of Wastewater Sources and Treatment Technologies

 1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_______________________________

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology1

Alternate 

Treatment 

Technology1

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 3.a. Metolachlor BOD 5 , AC 

Interior Cleaning - routine 

cleaning, cleaning due to product 

liquid formulation 

tank # 2

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

changeover, or special cleaning of 3.b. Metolachlor BOD 5 , AC

the interior of any formulating 

equipment, including formulation 

liquid formulation 

tank # 3

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

and/or storage tanks, pipes, and 3.c. Linalool BOD 5 , AC

hoses. Cleaning materials may 

include water, detergent, or 

dry formulation tank Pendimethalin TOC, TSS AC HD Treatability testing, Literature

solvent. 3.d.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

52

nology” column. Figure 6-2 presents an example of the types of information Table D

collected when completing Step 2. The unshaded columns under “Wastewater Treatment Information” illustrate this example.

Step 3: Identify Characteristics That Hinder Treatment

Throughout the pesticide industry, many products may be formulated, packaged, or repackaged using different types of equipment. This variety in products 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 pesticide 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 affected. 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.

The most common pretreatment technologies used for PFPR wastewaters are

settling, filtration, emulsion breaking, chemically assisted clarification, neutralization, and ultrafiltration. Table 6-3 lists the types of wastewater characteristics 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.

Table 6-2

Wastewater Characteristics That Adversely Impact Treatment Effectiveness

 Technology

Wastewater Activated Carbon Chemical Chemical

Characteristic Emulsion Breaking Adsorption Hydrolysis Oxidation Precipitation

Organics ✔ ✔

Suspended Solids ✔ ✔

Buffered Solution ✔ ✔ ✔

Temperature ✔ ✔

pH ✔ ✔

Detergents/ Surfactants ✔ ✔ ✔ ✔

Oil and Grease ✔ ✔
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

53

Figure 6-3. Identifying Characteristics That Hinder Treatment

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology1

Alternate 

Treatment 

Technology1

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 3.a. Metolachlor BOD 5 , AC 

Interior Cleaning - routine 

cleaning, cleaning due to product 

liquid formulation 

tank # 2

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

changeover, or special cleaning of 3.b. Metolachlor BOD 5 , AC

the interior of any formulating 

equipment, including formulation 

liquid formulation 

tank # 3

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

and/or storage tanks, pipes, and 3.c. Linalool BOD 5 , AC

hoses. Cleaning materials may 

include water, detergent, or 

dry formulation tank Pendimethalin TOC, TSS AC HD Treatability testing, Literature High solids content

solvent. 3.d.

 1 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_______________________________

Table 6-3

Pretreatment Technologies for Adverse Wastewater Characteristics

Technology

Neutralization Chemical

Wastewater Emulsion or pH Assisted

Characteristic Settling Filtration Breaking Adjustment Clarification Ultrafiltration

Organics ✔ ✔ ✔

Suspended Solids ✔ ✔ ✔ ✔ ✔

Buffered Solution ✔

pH ✔

Detergents/ Surfactants ✔ ✔ ✔

Oil and Grease ✔ ✔ ✔

Wastewater characteristics that hinder treatment can be listed in the “Characteristics 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
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

54

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 pretreatment step. In these situations, several technologies may be necessary to completely 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 contains 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 emulsion 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 adsorption to remove the metolachlor and other priority pollutants contained in the

wastewater.

When conducting a treatability test, facilities may only test the individual

unit operations. However, if a facility intends to implement the entire treatment 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.

Step 5: Determine Whether to Conduct a

Treatability Test

After identifying wastewater streams that require treatment and the appropriate technologies for the constituents 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 treatment steps are necessary. If a facility chooses technologies different from the ones listed in Table 10 of the final

rule for the treatment or removal of pesticide active ingredients, a treatability test can be used to demonstrate

that treatment is equivalent (demonstration of equivalent 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 treatment effectiveness before they allow PFPR wastewater to be discharged.

Untreated Activated Final

PFPR Chemical

Precipitation

Carbon Treated

Wastewater Adsorption Effluent

Emulsion

Breaking

Pretreatment

Hydrolysis

Figure 6-4. Example Treatment Train

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.

Table D
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

55

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 facilities, 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 represent. 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 procedures designed to ensure the

test’s success. The test plan helps

facility personnel organize and

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 sufficiently detailed and clearly written instructions so that treatment

system operators can easily conduct the test as specified. The

plan should first of all clearly

state the goals that are to be accomplished 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 treatment 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.

Components of the Treatability Test Plan

■ 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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56

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 contaminant). A bench-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 analysis, 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 facilities that generate small volumes of wastewater, a pilot-scale system is equivalent 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 buckets 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 actual 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 certain design and operating parameters that determine

how well the treatment system functions. The specific design and operating parameters differ for each

type of technology. Table 6-4 presents a list of common parameters used for wastewater treatment technologies. For the treatment of PFPR wastewater,

design and operating parameters typically include

the amount of chemicals and/or materials used, temperature, 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 system performance and cost are optimized will depend

on site-specific factors such as wastewater characteristics and volume.

Prior to the treatment test, target design and operating parameters appropriate for each treatment technology should be identified in the test plan. Because 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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57

➟ 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 contaminants from wastewater, chemical reactions, phase separations, or a combination. With each technology, a unique set of design and operating parameters

relevant to that technology needs to be monitored to ensure that the treatment 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 compliance 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

Precipitation Parameters

■ Temperature

■ pH

■ Amount and type of chemicals added

■ Mixing

■ Treatment time or wastewater flow rate

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

Hydrolysis Parameters

■ pH

■ Temperature

■ Mixing

■ Amount and type of chemicals

added

■ Treatment time or wastewater flow

rate

Activated Carbon Adsorption

Parameters

■ Wastewater flow rate

■ Type and amount of carbon used

■ Saturation loading

■ Temperature

■ pH

■ Carbon bed dimensions

Emulsion Breaking Parameters

■ Temperature

■ pH

■ Mixing

■ Amount and type of chemicals

added

■ Turbidity

Table 6-5

Treatment Technology Design and Operating Parameters
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58

treatment of PFPR wastewaters and are the technologies for which EPA has

the greatest amount of information. Note that these are not the only treatment technologies that can be successfully applied to PFPR wastewaters. In

some cases, facilities may wish to monitor other design and operating parameters 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.

➟ Select design and operating parameter values

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 wastewaters 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 previous tests on different wastewaters may not be an appropriate value for a

specific facility’s wastewater. By setting conservative parameter values during an initial test, facilities will not wrongly conclude that a particular treatment 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 initial 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.

➟ Optimize treatment performance through design and

 operating parameters

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 performance, decrease treatment time, and reduce the cost of treatment. By optimizing 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, facilities 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 optimize 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, substituting laboratory analyses with design and operating parameter monitoring 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 treatment 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 determine treatment system performance. For example, during an emulsion breaking 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 system performance by changing wastewater management methods. For example, 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 eliminate 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 example, 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 paperwork, that the treatment technologies they are choosing are well-operated 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-operated 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.

Step 3: Prepare Detailed Instructions

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 performance. See the references listed at the end of Chapter 5 and/or the example 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 being 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 operating 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 necessary 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 hydrochloric 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 recommended 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 determined 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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61

➟ 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 wastewater 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 environments. 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, electric 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 determined 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 tubing 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 carbon 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 determined with a thermometer or with a thermocouple.

➟ 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 chemical oxidation.
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62

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 wastewater 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 determined with a thermometer or with a thermocouple. The level of free chlorine 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, including 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 determined 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 prepare 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 wastewater 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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63

■ 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 treatment 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 technologies on a pilot scale. Sample frequency should account for the variability

of the wastewater generated from the various processes at the facility.

➟ 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, thermometers, scoops or shovels, and bottle dippers. Noncontaminating pH indicator 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 measured from either an aliquot collection jar or from the process stream after

Table 6-7

Example Sample Collection for Pilot-Scale Study

Technology Performance Measure Sampling Frequency Typical Sample Analyses

Any technology Destruction and removal Collect influent and final effluent Any constituent

efficiency samples

Activated Carbon Carbon breakthrough Collect effluent samples after every Pesticides

curve 60 liters has passed through the Organics

carbon bed Total organic carbon

Activated Carbon Saturation loading/carbon Treat a set volume (e.g., one liter) of Pesticides

isotherm wastewater through varying amounts Organics

of carbon and collect effluent samples Total organic carbon

Emulsion Time for phase separation Visually inspect samples hourly for Turbidity

Breaking phase separation Total suspended solids

Oil and grease

Hydrolysis Half-life calculation Collect effluent samples every 2-6 Pesticides

hours of treatment
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

64

sample collection to ensure that the thermometers

do not contaminate samples. Other sampling equipment 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 conventional and selected nonconventional parameters,

priority pollutants, and nonpriority organic and

metal pollutants. For the PFPR industry, the notable nonconventional pollutants expected to contribute 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 Industrial 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 particular unit operation. For example, total organic carbon (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 metals 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.

Table 6-8

Typical Field Log Data

■ 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.

Table 6-9

Decontamination Procedures

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.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

65

Different types of analyses are conducted using separate

analytical methods that have specific preservation methods. 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 similar 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-specific. Some pesticides are analyzed by the same method;

a separate pesticide fraction is required for each analytical method. As mentioned previously, it may not be necessary for the facility to analyze the wastewater for all

parameters.

➟ Sample Preservation

Individual sample fractions must be preserved according to the appropriate analytical method. Table 6-12 lists

the typical analytical fractions, along with the typical

sample volume, sample container, and on-site preservation for each fraction.

Sample volume, container type, preservation, and storage requirements for each analytical method are specified in the Handbook for Sampling and Sample Preservation

of Water and Wastewater (EPA-600/4-82-029). During

sample collection, facilities should follow good housekeeping and health and safety practices by avoiding crosscontamination of samples and leaks and spills.

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 Sample Volume Sample Container On-Site Preservation

Typical Pesticide Method 2 Liters 1 Liter Amber Narrow- 4°C; pH 5-7 with NaOH or HCl

Mouth Glass

Volatile Organics 80 mL 40 mL VOA Vial 4°C

Semivolatile Organics 2 Liters 1 Liter Amber Narrow- 4°C

Mouth Glass

Metals 1 Liter 1 Liter Narrow-Mouth Plastic pH 2 with HNO3

Group I Parameters1 1 Liter 1 Liter Narrow-Mouth Plastic 4°C

Group II Parameters2 1 Liter 1 Liter Narrow-Mouth Glass 4°C; pH 2 with H2SO4

Total Cyanide 1 Liter 1 Liter Narrow-Mouth Plastic 4°C; pH 12 with NaOH

Hexane Extractable 1 Liter 1 Liter Wide-Mouth Glass 4°C; pH 2 with HCl

Material

1

Group I parameters include BOD5, pH, fluoride, TDS, and TSS.

2

Group II parameters include ammonia nitrogen, nitrate/nitrite nitrogen, COD, and TOC.

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 (TDS);

■ Total organic carbon (TOC); and

■ Total suspended solids (TSS).
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

66

➟ 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 precision 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 sampling 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 submitted 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 transported unopened from a controlled area to the sampling site and finally to

the laboratory. Trip blanks are used to monitor volatile organics contamination 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 combined 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.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

67

overall quality objectives that should be met. Both the facility and the laboratory performing the analyses are responsible for ensuring that the data quality 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. Completing this table will enable facility personnel to assess which treatment technologies 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.

Step 1: Document Test Results

The purpose of the treatment system is to reduce

contaminant levels in PFPR wastewaters. The primary constituents of concern for the PFPR industry

are the pesticide active ingredients used in the

facility’s products. Other constituents, such as solvents 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 Operating 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 wastewater, 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 technology-specific measures, such as a hydrolysis half-life. These measures are often 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” columns on Table E to document these measures. Once the treatment performance is calculated, facilities can determine whether that technology was

successful in removing or destroying that constituent and document the reTreatability Test Goals

■ 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.

Table E
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68

Table E sults in the last column, “Effectively Treated?” A facility should evaluate

three measures to determine if the technology effectively removed that constituent:

■ 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 adsorption treatability test results are described below. Requirements for measuring

treatment effectiveness for other technologies may be identified through review of technical literature.

Table E: Summary and Evaluation of Test Results

Figure 6-5. Documenting Test Results

Facility: Location:

Date: Prepared by:

Insert your optimal treatment train and operating parameters in the space provided below:

Emulsion Activated

raw breaking Hydrolysis carbon discharge

wastewater adsorption

pH = 2 pH = 12 pH = 7

T = 60 oC T = 60 o

C T = 25 oC

slow mix slow mix flow rate = 87 mL/min

24 hour settling time 24 hour settling time empty bed residence time = 15 min

Design and Operating Parameters Constituent Concentration Performance Measures1

Other Other Other Other Effectively

Primary Temperature Treatment Settling Reaction Influent Effluent Percent Hydrolysis Treated? Technology Const tuents pH ( C) T me T me T me (ug/L) (ug/L) Removal Half-L fe (Y/N)

Emulsion Sample contained all the emulsion- 2.01 60 1 hour 24 hours NA NA

breaking breaking constituents except 11.74 60 1 hour 24 hours NA NA

pretest Linalool and Pyrethrin II. 7 25 1 hour 24 hours NA NA

Cyanazine 2 60 1 hour 24 hours 3,750 714

Linalool Emulsion breaking data for this constituent were not available. NA NA

Metolachlor 2 60 1 hour 24 hours 15,700 20,400

Emulsion Pendimethalin 2 60 1 hour 24 hours 110 49.0

breaking Pyrethrin II Emulsion breaking data for this constituent were not available. NA NA

Biological Oxygen Demand (BOD5 ) 2 60 1 hour 24 hours < 108 < 35

Hexane Extractable Material (HEM) 2 60 1 hour 24 hours < 16.5 56.0

Total Organic Carbon (TOC) 2 60 1 hour 24 hours 534 534

Total Suspended Solids (TSS) 2 60 1 hour 24 hours 334 6.00

Cyanazine 12 60 24 hours 714 < 2

Linalool 12 60 24 hours 5,760 792

Metolachlor 12 60 24 hours 20,400 14,700

Hydrolysis Pendimethalin 12 60 24 hours 49.0 45.0

Pyrethrin II 12 60 24 hours 81.1 < 5

Biological Oxygen Demand (BOD5 ) 12 60 24 hours < 35 45.0

Hexane Extractable Material (HEM) 12 60 24 hours 56.0 44.0

Total Organic Carbon (TOC) 12 60 24 hours 534 505

Total Suspended Solids (TSS) 12 60 24 hours 6.00 303

1

 NA=not analyzed, NC=not calculated.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

69

Table E

Figure 6-6. Calculating Performance Measures

Table E: Summary and Evaluation of Test Results

Facility: Location:

Date: Prepared by:

Insert your optimal treatment train and operating parameters in the space provided below:

Emulsion Activated

raw breaking Hydrolysis carbon discharge

wastewater adsorption

pH = 2 pH = 12 pH = 7

T = 60 oC T = 60 o C T = 25 o C

slow mix slow mix flow rate = 87 mL/min

24 hour settling time 24 hour settling time empty bed residence time = 15 min

Design and Operating Parameters Constituent Concentration Performance Measures1

Other Other Other Other Effectively

Primary Temperature Treatment Settling Reaction Influent Effluent Percent Hydrolysis Treated? Technology Const tuents pH ( C) T me T me T me (ug/L) (ug/L) Removal Half-L fe (Y/N)

Emulsion Sample contained all the emulsion- 2.01 60 1 hour 24 hours NA NA NA excellent

breaking breaking constituents except 11.74 60 1 hour 24 hours NA NA NA good

pretest Linalool and Pyrethrin II. 7 25 1 hour 24 hours NA NA NA minimal

Cyanazine 2 60 1 hour 24 hours 3,750 714 81.0% Y

Linalool Emulsion breaking data for this constituent were not available. NA NA NA NA

Metolachlor 2 60 1 hour 24 hours 15,700 20,400 NC N

Emulsion Pendimethalin 2 60 1 hour 24 hours 110 49.0 55.3% N

breaking Pyrethrin II Emulsion breaking data for this constituent were not available. NA NA NA NA

Biological Oxygen Demand (BOD 5 ) 2 60 1 hour 24 hours < 108 < 35 NC inconclusive

Hexane Extractable Material (HEM) 2 60 1 hour 24 hours < 16.5 56.0 NC N

Total Organic Carbon (TOC) 2 60 1 hour 24 hours 534 534 NC N

Total Suspended Solids (TSS) 2 60 1 hour 24 hours 334 6.00 98.2% Y

Cyanazine 12 60 24 hours 714 < 2 > 99.7% 2.84 Y

Linalool 12 60 24 hours 5,760 792 75.7% 30.8 Y

Metolachlor 12 60 24 hours 20,400 14,700 27.9% 59.6 N

Hydrolysis Pendimethalin 12 60 24 hours 49.0 45.0 8.16% NC Y

Pyrethrin II 12 60 24 hours 81.1 < 5 93.8% 7.46 Y

Biological Oxygen Demand (BOD 5 ) 12 60 24 hours < 35 45.0 NC NA N

Hexane Extractable Material (HEM) 12 60 24 hours 56.0 44.0 NC NA N

Total Organic Carbon (TOC) 12 60 24 hours 534 505 17.8% NA N

Total Suspended Solids (TSS) 12 60 24 hours 6.00 303 NC NA N 1

 NA=not analyzed, NC=not calculated.

➟ 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 contaminants by breaking chemical bonds joining the atoms in a molecule, other technologies, 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 technologies (e.g., activated carbon adsorption) separate the contaminants from the

wastewater, but the separated contaminants then require additional management, 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.
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DRE = (Massinfluent) – (Masseffluent)

(Massinfluent)

Figure 6-7. Destruction and Removal Efficiency Calculation

A mass balance constructed for the treatment system may help facilities identify 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 wastewater 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 interfere 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. Information 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.
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71

➟ 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 ingredients takes place at an elevated pH and temperature, although some pesticides 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 halflife is defined as the time required for the reactant concentration to decrease

to half the initial concentration. When hydrolysis occurs in alkaline conditions (e.g., pH = 12), the reaction can be modeled with a first-order rate equation, as shown in Figure 6-8.

For alkaline hydrolysis, the half-life is determined using the procedure detailed in

Table 6-15. For further information on hydrolysis rate reactions and the calculation

of half-lives under different treatment conditions, consult a hydrolysis text

or see the references listed at the end of

Chapter 5.

➟ Activated Carbon Adsorption

Performance Measures

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 evaluate 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 carbon. 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

t

1/2 = half-life (minutes)

k1

 = pseudo first-order rate constant (minutes–1)

t

1/2 = ln (2)

k 1

Figure 6-8. Hydrolysis Half-Life Equation

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, k1.

4) Calculate the half-life using the equation in Figure 6-8.
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

72

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 adsorption isotherm for metolachlor, a pesticide active ingredient.

Carbon isotherms can be found in literature for many pesticide active ingredients; 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 adsorption 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 estimate 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

Figure 6-9. Carbon Adsorption Isotherm.

Carbon Adsorption Isotherm

X/M = 135 Ce

0.34

10

100

1000

10000

0.1 1 10 100 1000

Equilibrium Concentration, Ce

(mg/L Metolachlor)

Carbon Saturation Loading, X/M

(mg Metolachlor Removed/g Carbon)
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

73

minimum level. At some later time during treatment, the carbon becomes

saturated and the contaminant is no longer adsorbed completely. The concentration 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 contaminant is being adsorbed, the carbon is said to be exhausted. Figure 6-10 presents 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.

Step 3: Compare Treatment Technology Results

To identify the most appropriate treatment train, the facility needs to compare 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, including cost, reliability, residuals generated, and need for highly skilled operators. 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 effectiveness (e.g., reliability and cost) more directly.

Example Carbon Breakthrough Curve

0

1000

2000

3000

4000

5000

6000

0 5 10 15 20 25 30 35

Volume of Feed (Liters)

Pesticide Concentration (mg/L)

Figure 6-10. Carbon Breakthrough Curve
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

74

When comparing different technologies, the comparisons may be more difficult. 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. Activated 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 adsorption, 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 contaminants, and levels of suspended solids, dissolved solids, TOC, surfactants, detergents, and solvents may cause wastewater differences that can affect the

performance, cost, and/or reliability of a treatment technology.

Step 4: Evaluate 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 costeffective for them to use. In determining cost-effectiveness, facilities need to

examine factors such as the cost of installing new technologies and the annual 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, facilities 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 treatment method, the facility may determine that the technologies they have tested

and compared simply are not cost-effective. For example, the facility has determined through treatabilty testing that its floor wash water can be adequately

treated using activated carbon adsorption, preceded by an emulsion breaking pretreatment step. However, the cost of installing and operating this treatment 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 costeffective 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
CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry

75

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 possible 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 implementing approved P2 practices). For those wastewater streams for which the facility 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

of the test and as a reference for future testing.

As mentioned previously in this chapter, Tables

D and E can be used by facilities to identify the

wastewaters and contaminants that will be

treated at the facility and the treatment technologies within the facility’s treatment train that are

expected to treat each contaminant. Many facilities 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 wastewater 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 compliance with the final rule.

Test Report Components

■ Recorded design and operating parameters;

■ Observations made by treatability test personnel;

■ Deviations from the sampling and analysis plan;

■ Analytical results; and

■ Calculations of DREs and other treatment criteria.
Each facility subject to the PFPR effluent guidelines and standards is required to keep certain paperwork on site to demonstrate compliance

with the rule. This paperwork must be available to the permitting agencies, 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 Regulation (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 applicability 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

certification statement. The facility periodically reviews

those choices and makes any necessary adjustment in

the periodic certification statement. Chapter 4 discusses

the P2 audit and how a facility can use that tool to determine 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 compliance decision after weighing the economic impacts of treatment. The information 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 completing Tables A through E (shown in Chapters 4 and 6). As discussed in Chapter 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

77

CHAPTER 7

Regulatory Compliance Documentation

Initial

Necessary Paperwork for the P2 Alternative

■ One-time initial certification statement

(40 CFR 455.41(a));

■ Periodic certification statement

(40 CFR 455.41(b)); and

■ On-site compliance paperwork

(40 CFR 455.41(c)).
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

78

Initial

and B, the facility can complete Table C through the preliminary compliance

decision (Item 1), which includes any modifications to listed P2 practices chosen 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 reflect 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 wastewater 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 documented 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 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. This manager should be the same person who signs the compliance status reports

as required by 40 CFR 403.12(l) 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.

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

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).
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

79

If the information contained in the facility’s permit or pretreatment agreement and initial certification statement is still applicable, a facility may simply 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 practices 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 authority is expected to use Best Engineering Judgment/Best Professional Judgment (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(l) 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.

Periodic

Figure 7-1. Example of a Periodic Certification Statement
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

80

On-site On-Site Compliance Paperwork Paperwork

In addition to the initial and periodic certification statements, the on-site compliance paperwork should include the four items listed in Table 7-2. This paperwork must be available for review at any time by the permitting agency or

control authority. As discussed under the section describing the initial certification statement, the on-site paperwork requirements 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 wastewater treatment technologies/disposal options chosen by the facility.

The on-site paperwork should also include more detailed materials supporting the decisions in the initial and periodic certification statements. The

appropriate documentation for each of these decisions is discussed in more detail below.

➟ 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 modifications. Each of these listed modifications requires supporting

documentation, as described in

Table 8 of the final rule. For example, 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 subsequent 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 permitting agency or control authority prior to implementation by the facility. Both the supporting documentation and the approval must be included

in the on-site compliance paperwork.

Table 7-2

On-Site Compliance Paperwork Components

(1) 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.

Table 7-3

P2 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
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

81

On-site

Paperwork

➟ 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 (described 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 wastewater. Facilities may use production

records or product labels listing the pesticide active ingredients used at the facility

or wastewater monitoring data that specifically identifies the constituents. The facility 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 specific 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 methods 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 technologies 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 equivalent. The technologies listed in the final

rule were chosen because of their effectiveness 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:

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).

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.
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

82

1

 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other_____________

Figure 7-2. Example of a Treatment System Description

Table D: Identification of Wastewater Sources and Treatment Technologies

Table E: Summary and Evaluation of Test Results

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology1

Alternate 

Treatment 

Technology1

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 3.a. Metolachlor BOD5 , AC 

Interior Cleaning - routine 

cleaning, cleaning due to product 

liquid formulation 

tank # 2

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

changeover, or special cleaning of 3.b. Metolachlor BOD5 , AC

the interior of any formulating 

equipment, including formulation 

liquid formulation 

tank # 3

Pendimethalin 

Pyrethrin II

TOC, TSS AC 

HD

HD Treatability testing, Literature

and/or storage tanks, pipes, and 3.c. Linalool BOD5 , AC

hoses. Cleaning materials may 

include water, detergent, or 

dry formulation tank Pendimethalin TOC, TSS AC HD Treatability testing, Literature High solids content

solvent. 3.d.

Facility: Location:

Date: Prepared by:

Insert your optimal treatment train and operating parameters in the space provided below:

Emulsion Activated

Raw Breaking Hydrolysis Carbon Discharge

Wastewater Adsorption

pH = 2 pH = 12 pH = 7

T = 60 o C T = 60 o

C T = 25 oC

slow mix slow mix flow rate = 87 mL/min

24 hour settling time 24 hour settling time empty bed residence time = 15 min

Design and Operating Parameters Constituent Concentration Performance Measures1

Other Other Other Other Effectively 

Primary Temperature Treatment Settling Reaction Influent Effluent Percent Hydrolysis Treated?

Technology Constituents pH (o

C) Time Time Time (ug/L) (ug/L) Removal Half-Life (Y/N)

Cyanazine 3750 < 2 > 99.9% Y

Linalool 5760 < 100 > 98.3% Y

Metolachlor 15700 < 0.8 > 99.9% Y

Pendimethalin 110 < 0.5 > 99.6% Y

Overall Pytrethrin II 81.1 < 5 > 93.8% Y

effectiveness Biological Oxygen Demand (BOD5 ) < 108 31 < 71.3% Y

Hexane Extractable Material (HEM) 56 < 5 > 91.1% Y

Total Organic Carbon (TOC) 534 63 88.2% Y

Total Suspended Solids (TSS) 334 < 4 > 98.8% Y
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

83

■ Percent removal of the pesticide active ingredient;

■ Final effluent concentration of the pesticide active ingredient; 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 determining 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 maintained. This method should be stated and the rationale for choosing it discussed 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

On-site

Paperwork

Hydrolysis Treatment

■ Temperature and pH of the

hydrolysis step

■ Duration of the hydrolysis step

■ Physical characteristics of the

wastewater before and after

hydrolysis

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

■ 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

Percent removals and effluent

concentrations discussed in the final

PFPR effluent guidelines and

standards are shown for guidance

only.

treatment system that consists of emulsion breaking, hydrolysis, and activated carbon, as described in Figure 7-2, the types of operation and maintenance 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
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

84

that a treatment system designed for the wastewater generated during those

production operations will be effective if operated and maintained as designed. In these cases, the facility may monitor the effluent from the treatment 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 operating 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 pollutants 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 commitment 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 permit 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 following methods.

➟ 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 calculated 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 influent. 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 concentrations for pesticide active ingredients treated in systems using appropriate

treatment technologies, as specified in Table 10 of the final rule. These concentrations are not effluent limitations and do not account for the variability

that may occur in PFPR wastewaters and in treatment systems. Permit writ1 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.
CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry

85

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.

➟ Review the minimum detection limit

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 example, if the influent concentration of a pollutant is 100 mg/L and the effluent concentration is reported as <100 mg/L, it is impossible to conclude what

level of pollutant removal has been achieved by the treatment system.
CHAPTER 8

Case Studies

87

This chapter describes the P2 practices implemented by two PFPR facilities. The first facility, operated by Ennis 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 incorporate 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 practices and equipment presented in the case studies in italicized bold print are

defined in the P2 glossary in Chapter 3.

Case Study 1: Ennis Agrotech, Ennis, Texas

Facility Overview

Ennis Agrotech, formerly Agriculture Warehouse, operates a contract (or toll)

PFPR facility that does not produce or market its own labeled products. Instead, the facility formulates registered pesticide products for about 20 domestic 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 product, 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.
CHAPTER 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry

88

PFPR Operations

The facility operates eight independent process lines to formulate and package 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 formulation and packaging lines usually consist of a combination of existing and new

custom-designed equipment. Existing equipment is refurbished, pressurewashed 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:

➟ 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 packaged.

➟ The second manufacturing module is a semiautomated line used

to produce various dry animal health products containing carbaryl 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 formulate 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.

➟ The fourth manufacturing module is used to formulate and package a fire ant control product. Liquid active ingredient is mixed in

a kettle and sprayed onto granulated clay material in a Continental 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. Active 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 conveyor to a mill where it is pelletized. The pellets are either packaged “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
CHAPTER 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry

89

into bags. Due to the large volume of water incorporated into the

product during the formulating and pelletizing process, the facility 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 containers, such as 2-pound application packs.

➟ The seventh manufacturing module is used to produce a greenhouse 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 adjustments are made in this vessel if the product is found to be offspec. 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 Practices

Ennis Agrotech generates pesticide-containing wastewater from four sources:

(1) interior equipment cleaning; (2) exterior equipment cleaning and floor washing; (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 currently 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 crosscontamination 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 formulating and packaging of a given product is minimized through the dedication of equipment, the use of dry process cleaning equipment, and water

washes using flow reduction equipment. In addition, effective inventory management practices enable the facility to maximize interior rinsate storage and

reuse.
CHAPTER 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry

90

Ennis Agrotech dedicates manufacturing modules to specific pesticide classes,

such as fungicides, herbicides, and insecticides, in order to minimize the potential for cross-contamination between pesticide classes and to minimize the

number of product changeover cleaning operations. In addition, when making products within the same pesticide class, formulating and packaging equipment is cleaned before product changeover occurs to allay cross-contamination

concerns, and at set intervals during production, if needed. Typically, equipment 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 using 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 storage and use of all raw materials. This system is maintained by management personnel assisted by a

“waste movement” consultant. Equipment cleanouts

are documented on “Pre-Cleanout and Decontamination 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 collected, weighed, labeled, and stored in the manufacturing 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 material to use, including the amount of stored cleaning

material.

For example, production in the Pellet Mill system (Figure 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. Figure 8-1. General Pre-Cleanout/

Decontamination Checklist
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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 product. The cleaning water is treated using a

microfiltration unit followed by an activated carbon filter system. The microfiltration unit is a vertical, poly-type, cross-flow filtration system

manufactured by EPOC Water Systems of Fresno,

California. The Pellet Mill System uses approximately 12,000 gallons of water during each production 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 equipment cleaning wash water and floor wash water

are controlled in the same way as the interior equipment cleaning rinsates. These wash waters are generated 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) usually requires between 30 and 75 gallons of water.

Wastewater generated during product changeover Figure 8-3. Pellet Mill System Cleanout Procedures

Figure 8-2 Pellet Mill System
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Figure 8-4. Pellet Mill System Cleaning Material Reuse Cycle
CHAPTER 8 Case Studies Pollution Prevention Guidance Manual for the PFPR Industry

93

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 formulation 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 operations. 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 adsorbent 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.

Case Study 2: MGK, Chaska, Minnesota

Facility Overview

MGK operates a combination pesticide manufacturing and PFPR facility that

produces manufacturing-use concentrates. These concentrates are sold to customers 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 Operations

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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94

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 dedicated day tanks with dedicated supply lines. The tanks are connected to two

mixing stations equipped with weigh scales. When a custom formulation order is received, the required active ingredient is gravity fed through a dedicated 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 formulation tank. MGK’s formulation tanks are dedicated to specific products

or product groups based on estimated product volume requirements, product 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 packaged into bags, 5-gallon pails, 55-gallon drums, and tote bins. MGK also provides 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 methylene 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. Methylene chloride is also

used in this area to clean raw material tanks and drums, as necessary.

P2 Practices

MGK generates pesticide-containing wastewater associated with PFPR operations from three sources: (1) floor wash water; (2) exterior equipment cleaning

rinsate; and (3) spill and leak cleanup. MGK also generates pesticide-containing 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 certain wastewater management techniques to achieve P2 at their facility. The

benefits associated with these practices include:
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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 formulation equipment and raw material drums.

3. Reduced water use; reduced hazards from slips, falls, and chemical residues; 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 implementation 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 formulations 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 wastewater. 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 scheduling, and formulating and packaging small batches in containers. MGK

Chaska also uses effective inventory management systems to maximize interior 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 product family to reduce the need to clean these tanks and to reduce the possibility

of cross-contamination between incompatible products. The facility also dedicates totes used for special formulations to the specific customer and formulation.

The facility also schedules production runs to minimize the need to clean formulation 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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96

The facility also maintains an inventory management system for raw materials, products, and solvents that are recovered for reuse. A computerized system 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 necessary 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 conducted, 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 performed on valves and fittings. The facility was also designed as a closed facility 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 operation 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.
97

CHAPTER 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), contact 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 standards 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

Federal P2 Programs and Contacts

Enviro$en$e

Enviro$en$e is EPA's new electronic library of information on pollution prevention, technical assistance, and environmental compliance. With free public access to the system, Enviro$en$e is aimed at facilitating the sharing of

technologies and experience across private and public sectors, and encouraging pollution prevention technologies suitable for export. A list of topics

Enviro$en$e contains information on includes:
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98

■ 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 Resource Center

The EPA Headquarters Information Resource Center provides information

support services to EPA staff and maintains a varied collection of environmental resources, including CD-ROMs, an online catalog, and other programspecific 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 Service (OLS) is available through telnet: “epaibm.rtpnc.epa.gov”. (See Pollution Prevention Information Clearinghouse (PPIC) and EPA on the World

Wide Web.)

EPA on the World Wide Web

EPA’s webserver is the primary public access mechanism on the Internet for

EPA. The webserver provides a range of EPA-generated information in electronic format, and also offers access to OLS, the national online catalog of the

EPA library network. It includes the catalogs of the Headquarters Information 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/
CHAPTER 9 Where to Get Additional Help Pollution Prevention Guidance Manual for the PFPR Industry

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EPA’s Pollution Prevention Research Branch Program

The Pollution Prevention Research Branch at EPA’s National Risk Management Research Laboratory supports projects and provides technical assistance 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

National Technical Information Service (NTIS)

Located in the U.S. Department of Commerce, the National Technical Information Service (NTIS) is the central source for the public sale of U.S. Governmentsponsored research, development, and engineering reports. It is also a central

source for federally generated machine processible data files. It contains reports on air pollution, acid rain, water pollution, marine pollution, marine ecosystems, 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

Pollution Prevention Division (PPD)

The Pollution Prevention Division (PPD) within EPA’s Office of Pollution Prevention and Toxics was established in 1988 to integrate a multimedia P2 ethic

within EPA and its developing programs, as well as to provide outreach support to the public and other government departments. Its primary role is to

ensure that EPA incorporates P2 into rulemaking 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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100

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 Prevention Information Clearinghouse (see related listing), manages the Pollution 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 environmentally preferable products, and International Standards, and is a collaborator 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 legislative 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 information 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 Information Resource Center above). PPIC currently publishes a list of available 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 prevention 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 pollution 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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101

profitability indicators and time horizons that capture the longer-term savings 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

1 JFK Federal Building Abby Swaine (617) 565-4523 (617) 565-3346

Boston, MA 02203 Mark Mahoney (617) 565-1155

(617) 565-3420

2 (2-OPM-PPI) Janet Sapadin (212) 637-3584 (212) 637-5045

290 Broadway

New York, NY 1007-1886

(212) 637-3000

3 841 Chestnut Building Jeff Burke (215) 597-8327 (215) 597-7906

Philadelphia, PA 19107 Cathy Libertz (215) 597-0765

(215) 566-5000

4 345 Courtland Street, NE Connie Roberts (404) 562-9084 (404) 562-9066

Atlanta, GA 30365

(404) 562-8357

5 (HRP-8J) Phil Kaplan (312) 353-4669 (312) 353-5374

77 W. Jackson Boulevard

Chicago, IL 60604-3590

(312) 353-2000

6 1445 Ross Avenue, Suite 1200 Robert Lawrence (214) 665-6568 (214) 665-7446

Dallas, TX 75270 Linda Thompson (214) 665-6568

(214) 665-6444

7 726 Minnesota Avenue Marc Matthews (913) 551-7517 (913) 551-7065

Kansas City, KS 66101

(913) 551-7000

8 999 18th Street, Suite 500 Linda Walters (303) 312-6385 (303) 312-6339

Denver, CO 80202-2405

(303) 312-6312

9 75 Hawthorne Street, (H-1-B) Bill Wilson (waste (415) 744-2192 (415) 744-1796

San Francisco, CA 94105 minimization)

(415) 744-1305 Eileen Sheehan (water) (415) 744-2190

10 1299 Sixth Avenue (MD-142) Carolyn Gangmark (206) 399-4072 (206) 553-4957

Seattle,.WA 98101

(206) 553-1200

*Individual contacts may change over time; in such an event, call the main region phone number listed under the address.
CHAPTER 9 Where to Get Additional Help Pollution Prevention Guidance Manual for the PFPR Industry

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Periodicals and Directories

Access EPA. Directory published by EPA’s Office of Information Resources

Management. Includes public information tools, major EPA dockets, clearinghouses 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, Pittsburgh, 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 Avenue #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. Available from the National Pollution Prevention Roundtable, 218 D Street SE, Washington, DC 20003. Tel: (202) 543-7272.

Pollution Prevention Yellow Pages. Lists and describes state and local pollution 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.
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 importantly, 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.

103
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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CHAPTER 10 Workshop Questions and Answers
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? There is no regulatory definition of “toll formulating”. Toll

formulators, as referred to by the PFPR rule, typically formulate, package, or repackage one or more products under contract 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 formulating or packaging of a product;

• The registrant does not have room at their facility to formulate, package, or repackage the product; or

• The registrant wishes to avoid potential cross contamination

concerns by segregating incompatible products (e.g., herbicides and insecticides).

If an industry (i.e., a facility)

formulates a product, but does not

sell the product, is that operation

covered?

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 potential to discharge in-scope process wastewater from PFPR

operations to be covered by the rule.

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?

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 under the PFPR rule.

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CHAPTER 10 Workshop Questions and Answers
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 facilities 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: experimental 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.

It is the responsibility of the facility that performs the covered

activity to comply with this rule, including all paperwork requirements. Using the example in the question, the packager

would be required to comply for all in-scope wastewaters generated during or associated with their packaging operation.

Is repackaging of pesticide active

ingredients as both pesticide and

nonpesticide products covered

under the PFPR standards no

matter what the product?

No, only products that are pesticides and that meet the applicability of the PFPR rule are covered by the standards. Nonpesticide products that may contain the same active

ingredients are not covered by the rule.

If a facility repackages a pesticide

active ingredient in a container for

ultimate sale, are they covered

under Subcategory C or

Subcategory E?

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.

Are farm cooperatives that supply

products to farmers covered by

Subcategory E regulations?

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 delivered 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).

Are farmers who repackage

pesticide products into smaller

containers for delivery to parts of

the farm covered by Subcategory

E regulations?

No. End users of the pesticide products are not covered by

either Subcategory C or E regulations.

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CHAPTER 10 Workshop Questions and Answers
Are applicators covered by this

rule?

In general, no. Wastewater generated from application of pesticide 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 formulation, packaging, and repackaging operation is covered.

Is an applicator formulating a

product for its own use covered

under this rule?

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(i)) for use in the U.S. and is not

exempt from the PFPR rule, then the wastewater from formulation is covered by the rule. However, the wastewater from

application services is not covered by the rule.

Are aerial applicators/crop dusters

covered by this rule?

No, wastewaters related to custom application services are not

covered by this rule (see 40 CFR 455.60(b)).

Less than 0.25% of a facility’s

operation is the repackaging of

pesticides. Is the facility covered

by the rule?

Yes, the wastewater from such in-scope repackaging operations is covered if the facility discharges or has the potential

to discharge process wastewater from their repackaging operations. There is no de minimis production exemption.

Do all pesticide active ingredient

drums require rinsing?

The PFPR rule does not require rinsing of any drums or equipment, 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.

Is wastewater from remedial

actions (e.g., groundwater

remediation operations) occurring

at a current or former PFPR

facility covered by these

categorical standards?

No, wastewater from remedial actions does not meet the definition of process wastewater. However, any treatment standards for the discharge of such wastewaters that may be

established through a remedial process may take into account

the PFPR regulation.

If a facility blends a pesticide

product with something else (e.g.,

grass or fertilizer), is that

production covered by the rule?

Yes, unless the operation is considered a custom blending operation, as defined in 40 CFR 167.3.

Are facilities required to rinse

inert drums?

No. The rinsing of drums containing pesticide active ingredients 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 containers (noncombustible containers which formerly contained

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CHAPTER 10 Workshop Questions and Answers
organic or metallo-organic pesticides, except organic mercury,

lead, cadmium, or arsenic compounds) should first be triplerinsed 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?

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 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 accordance with good manufacturing practices, as defined 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 mixtures 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.

Are Group I chemicals exempted

because they are exempted from

FIFRA?

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.

Are pool chemicals exempt from

the rule?

Yes. Pool chemicals (as defined in 40 CFR 455.10(q)) are exempt

from this rule (40 CFR 455.40(d)).

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.

The exempted sanitizer products, as defined in section 455.10,

are “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, 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 sterilants (including sporicidals) exempted by section 455.40(f) or

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CHAPTER 10 Workshop Questions and Answers
otherwise, industrial preservatives, and water treatment microbiocides other than pool chemicals.”

In other words, sanitizers, as defined (and including pool

chemicals), are exempt from the rule when their labelled directions for use (not disposal) result in discharge to POTWs.

The rule still covers certain liquid chemical sterilants, industrial 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 sanitizer, 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 formulation) has the multiple uses listed above (meaning the

chemical is used in the same concentration (percent active ingredient) in both sanitizer and cooling tower uses), the registrant can request their Regional Office or EPA’s Office of Water

to determine whether the wastewater resulting from the formulation, packaging, or repackaging of such a product is exempt from this rule. EPA has determined that sodium

hypochlorite is not subject to the PFPR guideline. Contact information is provided in Chapter 9 of this guidance manual.

Does chlorine gas meet the

definition for exemption as an

inorganic wastewater treatment

chemical?

Chlorine gas is exempt from the final PFPR rule if it is used in

wastewater treatment operations.

Why is EPA interested in tracking

inert materials in a P2 audit? Are

inert materials covered under the

PFPR regulation?

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 identify possible contaminants in wastewater that will require treatment prior to discharge or to identify characteristics that may

hinder effective treatment of pesticide active ingredients or

priority pollutants.

What kind of treatment is

required for inert materials?

The PFPR rule requires treatment of pesticide active ingredients 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.

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?

No. Table 10 is not a list of all covered pesticide active ingredients; it was developed to aid facilities, permit writers, and

control authorities in identifying appropriate treatment technologies 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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CHAPTER 10 Workshop Questions and Answers
found in III.A (page 57523) of the final rule, located in Appendix 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 a facility adds a biocide to their

product (e.g., adhesives), is it

covered under the rule?

If the facility claims that the final product has pesticidal qualities (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.

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 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 formulated, packaged, or repackaged into a pesticide product that is

not exempted from the rule, then the pesticide active ingredient/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 wastewater 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 determined by identifying the technology for a pesticide active ingredient with a similar chemical structure or through

treatability testing.

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?

The PFPR rule covers the formulating, packaging, and repackaging 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.

Does the PFPR rule apply to

herbicide growth regulators and

surfactants that may contain toxic

chemicals?

The PFPR rule applies to all pesticide products that are formulated, packaged, or repackaged and are not specifically exempted 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 intended for preventing, destroying, repelling, or mitigating any

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CHAPTER 10 Workshop Questions and Answers
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)(1) or (2) of

this section.

Pesticide product means a pesticide in the particular form (including 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 circumstances 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)(1)) and cosmetics (as defined in FFDCA sec. 201(i)).

Growth regulators are considered pesticides as defined in the

FIFRA regulations. Therefore, the in-scope wastewater associated with the PFPR of growth regulators would be covered by

the PFPR rule. Surfactants are generally inert, not active, ingredients 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.

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?

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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CHAPTER 10 Workshop Questions and Answers
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 pollutants can be demonstrated to neither pass through nor interfere 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-dichlorophenol, and 2,4-demethyl phenol) are already excluded from

pretreatment standards of this regulation because they do not

pass through a POTW.

How does a facility demonstrate

that a pesticide active ingredient

does not pass through the 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 active 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 operations. If the POTW determines that the pesticide active ingredient either passes through or adversely impacts operations,

local limitations may be assigned. 

What about the pesticide active

ingredient limits that were

developed for regulation of the

pesticide manufacturing industry

(58 FR 50637)?

The limitations developed for the pesticide manufacturing industry 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 variability of their wastewaters. PFPR wastewaters can be more variable 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 desirable for a pesticide manufacturer to receive an additional allowance 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 operations.

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CHAPTER 10 Workshop Questions and Answers
PFPR Wastewater

What is the difference between

drum rinsates and interior

equipment rinsates and their

respective P2 practices?

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 rinsing station.

Interior equipment cleaning rinsates are generated from the

cleaning of equipment used to formulate, package, or repackage products following the formulation, packaging, or repackaging 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.

Does formulating equipment

interior cleaning include the

cleaning of piping and hosing,

too?

Yes.

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?

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.

Are cleaning waters from a bulk

tank that contains a material used

in both pesticide and nonpesticide

products covered under this rule?

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 particular 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.

Do DOT test bath waters require

treatment?

No; however, under the P2 alternative, DOT test bath water

from continuous overflow baths must include some recircula113

CHAPTER 10 Workshop Questions and Answers
tion or be a batch bath. Otherwise, they must meet zero discharge.

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?

Yes.

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?

Determining whether the facility is within the scope of the

regulation depends on whether they have a potential to discharge process wastewater. EPA’s Pretreatment Bulletin #13

(see Appendix E) states that it is possible to discharge noncovered 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.

Are wastewaters associated with

the cleaning of coveralls covered

by the rule?

On-site laundry operations are not covered under the scope of

this rule.

Are water emissions from research

and development pilot plant

operations exempt from the rule?

Yes. See 40 CFR 455.40(e) of the final rule.

Is storm water completely exempt

from regulation? What about

contaminated storm water from

diked areas?

Storm water is exempt from coverage under the final PFPR

rule (61 FR 57524), and therefore is not subject to the P2 practices and treatment requirements of that rule. However, a facility’s storm water discharges are covered under Phases I or

II of the General Storm Water Regulations (61 FR 57524).

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?

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 outdoor storage tanks should be cleaned up prior to storm events;

the resulting storm water is not covered by the rule.

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CHAPTER 10 Workshop Questions and Answers
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 facility has no potential to adversely affect a POTW’s operation 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 and it is not legally

required at the Federal level for these facilities to submit paperwork (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, laundry water), 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 CFR Part 403 (General Pretreatment

Standards).

Facilities that are meeting zero discharge, but do have the potential 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 discharge of regulated PFPR 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 (i.e., there is no

potential to discharge), and therefore the PFPR facility has no

reasonable potential for adversely affecting the POTW’s operation or for violating the PFPR effluent guidelines, then the

PFPR effluent guidelines are not applicable to that PFPR facility.

However, EPA Pretreatment Bulletin #13 (see Appendix E) suggests that the control authority issue an individual control

mechanism containing the following conditions:

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• 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; and 

• Requirements to comply with Resource Conservation and

Recovery Act (RCRA) and state hazardous waste regulations

regarding the proper disposal of hazardous waste.

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)?

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 effluent, and only if all pollutants have approved analytical methods. A detection of any of these pollutants means the facility

is out of compliance with the rule.

Why is zero discharge defined as

“no discharge of process

wastewater pollutants”?

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 process wastewater pollutant (e.g., the specific pesticide active ingredient) is not analytically detected in the effluent. Another

way to show zero discharge is to show no flow of process

wastewater from the facility.

Does “no discharge of process

wastewater pollutants” refer only

to the pesticide active ingredients

and priority pollutants?

In the PFPR rule, “no discharge of process wastewater pollutants” 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.

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?

A facility that completely reuses all PFPR wastewater (including 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 alternative (which has more comprehensive paperwork requirements,

but may give the facility more flexibility if they decide to discharge in the future).

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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”).

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?

Yes. The first facility could transfer their wastewater off site

for reuse by their other facility, or for off-site disposal. However, the second facility (unless it is a centralized waste treatment 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?

The facility is an existing source.

If a facility has safety showers

and/or eye wash stations, does

that constitute “potential to

discharge”?

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.

Does a facility with permanently

plugged drains in the PFPR

process areas have a “potential to

discharge”?

No. There is no potential to discharge from the process area.

If a facility has no potential to adversely affect a POTW’s operation 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.

How can a facility that uses water

have no potential to discharge if

there is a connection on site to the

POTW?

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?

Listing “P2 alternative” means that the facility will follow the

P2 practices listed in Table 8 of the final rule for that wastewater 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 rinsate in their PFPR operations.

Listing “P2 alternative with modification” means that the facility 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 generates an interior equipment cleaning rinsate, but has documented 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.

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?

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 conservation, 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.

P2 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 Procedures 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 approximately 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 pressure rinse. Note that the final PFPR rule does not require triple

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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 generated from in-scope PFPR production and wastewater

sources.

Why is the drum rinsing station

referred to as countercurrent

rinsing?

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 concentrated 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?

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 specifically list the use of countercurrent drum rinsing stations for

solvent-containing drums because it is not common in the industry; however, a facility could seek an unlisted modification

for this practice.

Instead of using drip pans, can a

facility operate a general sump in

their compounding area?

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 increasing 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 permitting/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.)?

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 adequately prevent leaks and drips from occurring or would allow

reuse of the material (see above).

Do facilities that operate wet air

pollution control scrubbers

discharge that wastewater?

Yes, facilities that operate these devices typically discharge a

blowdown stream from the scrubber periodically. Some facilities may also operate these devices with a continuous discharge. 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.

Can you store and reuse material

for greater than 90 or 180 days?

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. However, the RCRA regulations require that materials being stored

for reuse not be accumulated speculatively. Material not considered speculatively accumulated includes material that is

shown to be recyclable, to have a feasible means of being recycled, and, that during the calendar year, the amount of material 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 preamble to the final rule in Appendix A.

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?

It is the intent of the rule to cover wastewater associated with

pesticide production; therefore, cleaning rinsates of drums containing inert materials used in PFPR production would be covered 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 material 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)?

Practice 9 (listed in Table 8) states that facilities must dedicate

PFPR production equipment to water-based versus solventbased products. This practice is intended to eliminate the generation of solvent-contaminated wastewater, which are

typically unable to be reused in PFPR operations. By dedicating production equipment, facilities may reuse solvent rinses

and water rinses into solvent-based and water-based formulations, respectively.

Facilities may also discuss incorporating a listed modification

(i.e., operation of a solvent recovery system) or nonlisted modification to this practice with their control/permitting authority.

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.

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.

If the shipping containers/drums

are metal, they may not need to

be rinsed since refurbishers have

a flame to clean drums.

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.

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)?

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 refurbisher/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/permitter 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.

What does a facility do with

solvent used to rinse tanks, since

they will not be able to reuse the

solvent forever?

For solvent rinses associated with drum rinsing or interior

equipment cleaning rinsing operations, it is expected that, under 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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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 appropriate disposal regulations; however, the PFPR rule only covers

wastewater discharges (not solid or hazardous waste disposal

operations).

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 words “clean,” “ultra-clean,” “clean techniques,” “clean

laboratory practices,” and other words and phrases have been

used to describe additional steps taken to preclude contamination 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].

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?

Yes, but such an allowance must be based on the PFPR contribution 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 management of raw materials, intermediates, finished products, rinsates, etc. that are associated with PFPR operations. Inventory

management is not a P2 practice required by the PFPR regulation, 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?

Assuming that the facility has already implemented flow reduction measures when rinsing their pesticide active ingredient 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, inertcontaining drums may not need to be rinsed prior to recycle

or disposal.

Is a one-time test per product

acceptable to justify the

“BIOGROWTH” modification?

Yes, over the time period of the permit (usually three years),

unless the product formulation or method of production is

altered in a way that could affect the quality of the wastewater.

If a facility is going to use laboratory testing to demonstrate

biological growth (or other product deterioration), it should be

performed with a sample that is representative of the formulation, as well as the typical storage period.

A facility has very long

production runs (1 to 2 years) and

cannot predict when product

changeover will occur. When they

do change over production, they

generate a non-reusable rinsate. Is

this facility eligible for the

“DROP” modification?

After demonstrating the use of water conservation practices

(as specified in P2 practice #1 in Table 8 of the PFPR rule), a

facility could use historical production data to support the

“DROP” modification. This modification allows the facility to

discharge interior rinsates under the P2 alternative when the

facility is dropping registration or production of the formulation 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 compatible 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 modifications. 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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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 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 pesticide active ingredients 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 generating such a non-reusable wastewater.

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?

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.

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.

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 specifically list the use of countercurrent drum rinsing stations for

solvent-containing drums because it is not common in the industry; 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 transfers.

P2 Allowable Discharge

What is the de minimis exemption

allowed by this rule?

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 practices and any necessary treatment. The amount is expected to

be small; however, it is not referred to as a de minimis exemption because it is not quantifiable.

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)?

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 Subcategory 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.

Is there a volume or upper limit

to the P2 allowable discharge?

No, a facility may discharge whatever remains after implementation of the specified P2 practices (and treatment when necessary). Note: the P2 practices include water conservation

practices, which will reduce the volumes of wastewater to be

treated and discharged.

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?

A control authority may grant a waiver that removes the requirement 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 pretreated). 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 authority/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?

The P2 alternative of the final PFPR rule stipulates that direct

discharging facilities must treat any PFPR wastewater that remains 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 wastewaters 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 Appendix A of this guidance manual).

Does DOT test bath water require

treatment prior to discharge if a

can has burst in the bath?

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 alternative (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 wastewater 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 activated 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 ingredients 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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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.

Does an activated carbon system

have to be run continuously?

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 addition, PFPR facilities with wastewater matrices that vary daily

may find that batches of stored wastewater may be more consistent from treatment period to treatment period.

Since the PFPR rule does not

require testing, how does one

determine when to change carbon

in an activated carbon system?

Although the rule does not require specific testing, it does

require that a treatment system be demonstrated to be well operated and maintained. To demonstrate this, a facility may

need to perform some testing to determine when carbon breakthrough occurs for their system and therefore when the carbon

needs to be changed.

Can you use TOC to determine

carbon breakthrough?

In some cases, TOC or other parameters may be used as an

indicator of carbon breakthrough by a pesticide active ingredient, 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.

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?

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 distance to the regeneration facility, and other factors. Some facilities 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 261.4. 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 wastewaters, such as spent activated carbon, would not be considered 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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CHAPTER 10 Workshop Questions and Answers
Emulsion Breaking

When performing emulsion

breaking, won’t the removal of the

oil/scum layer remove organic

pollutants?

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 treatability 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 technologies 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.

Does a facility have to use

sulfuric acid or other concentrated

acid to perform the emulsion

breaking step?

No. It is not necessary to use a specific acid to perform emulsion breaking, as long as the selected acid lowers the pH to the

desired level. In general, any strong acid (e.g., sulfuric, hydrochloric, 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 neutralization after hydrolysis at high pH. However, facilities should be

aware that the addition of acid to PFPR wastewater may generate 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 compounds. 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 technology that does not lower the pH of the wastewater, or to use

P2 practices or off-site disposal instead of treating the wastewater.

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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CHAPTER 10 Workshop Questions and Answers
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. Facilities should also be aware that toxic or hazardous components 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 hydroxide and/or sodium sulfide may be used to form these contaminants 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 sulfide 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 precipitation 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 concentrations 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 product, disposed of in an on-site treatment unit (such as an incinerator), 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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CHAPTER 10 Workshop Questions and Answers
Determination of Treatment Equivalency

If a wastewater requires

treatment, does it have to be

treated using the treatment

technologies listed in Table 10?

No, facilities may use the appropriate Table 10 technology or

an equivalent technology or a pesticide manufacturing treatment system that is treating the same pesticide active ingredients that are manufactured as are formulated/packaged/

repackaged.

How does one identify an

appropriate treatment technology

for a pesticide active ingredient

that is not listed in Table 10?

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 technology transfer methodology (described in the treatability database 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.

How does a facility justify using a

technology other than those listed

in Table 10?

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 technology 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 demonstrating that a technology will provide treatment performance 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 treatability tests is contained in Chapter 6 of the P2 Guidance Manual. The determination of equivalency will be based on a

combination of the percent removal of pesticide active ingredient (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 pollutant, it may be necessary to identify a treatment technology

based on the facility’s 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 structure. Treatment effectiveness 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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CHAPTER 10 Workshop Questions and Answers
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?

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 technologies 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 technology for a pesticide active ingredient.

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?

Not necessarily. The PFPR rule allows technologies other than

those listed in Table 10 to be used to treat wastewater containing a particular pesticide active ingredient, provided the facility 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 technology will provide treatment performance equivalent to the

technology listed in Table 10). In this case, if the facility demonstrates that chemical oxidation is equivalent to activated

carbon adsorption for MCPP, or that activated carbon adsorption 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 PAI. When more than

one technology can effectively treat a PAI, EPA listed the technology 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 oxidation 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 available 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 Derivatives from Natural Waters, Rutgers University, Dept. of Environmental Science, New Brunswick, NJ, February 1965 (DCN

F6303).

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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).

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)?

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 requirements 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 definition 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.

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?

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 technologies used to establish numerical limitations for 120 pesticide 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 Document lists incineration as the BAT technology for the following

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CHAPTER 10 Workshop Questions and Answers
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 incineration 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 incineration as a means to achieve zero discharge.

Treatability Testing

Did EPA evaluate inert materials

in treatability tests?

EPA did not focus on the inert materials; however, in addition

to analyzing wastewaters for the specific pesticide active ingredients, EPA analyzed for a full scan of organic and metal

pollutants, including priority pollutants, to identify other potential pollutants of concern from inert ingredients. Treatment

efficiencies were focused on pesticide active ingredients and

priority pollutants.

Are the EPA treatability reports,

including those reports listed at

the end of Chapter 5, available on

the Internet?

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 business information and are available in a nonconfidential form.

Do treatability tests require

elaborate QA/QC procedures?

No, the level of QA/QC conducted during EPA sampling and

treatability testing is not necessary for facility treatability testing, 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 testing. The QA/QC procedures include preparation of a QA/QC

plan and the collection of field duplicate, field blank, equipment blank, and trip blank samples.

What type of samples should a

facility collect to test how the

treatment system is operating

(grab vs. composite)?

The type of samples collected to determine the efficiency of an

operating treatment system depends on whether the unit operation is a batch or continuous operation. Generally, grab samples are collected for batch operations and composite samples

are collected for continuous operations. Samples collected to

characterize raw waste streams are typically grab samples because of the batch nature of wastewater generation. Samples

collected during treatability testing are typically grab samples.

Do bench-scale test results scale

up well to full scale?

The correlation between bench- and full-scale test results will

depend on a variety of factors, including how well the benchscale test was designed and performed, the difference in wastewater volume treated between bench- and full-scale treatment,

the type of technology tested, the contaminants in the wastewater treated, and other factors. If a bench-scale test is well

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CHAPTER 10 Workshop Questions and Answers
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 benchscale test can provide valuable information for the design and

operation of a full-scale treatment system, it is commonly necessary 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 benchscale.

An example that illustrates the difference in how different

treatment technologies compare in terms of scale-up is discussed 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 operating 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 frequently use a beaker in which some activated carbon is allowed to come into equilibrium with a wastewater to

determine the saturation loading. This is different from an actual 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 fullscale operation.

What reference shows which

pesticide active ingredients in

Table 10 had treatment

technologies established based on

a transfer of treatability data?

This information is presented in the Final Pesticide Formulators,

Packagers, and Repackagers Treatability Database Report and Addendum (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 operations 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 require pretreatment in order to allow the treatment system to

effectively remove the pesticide active ingredients.

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CHAPTER 10 Workshop Questions and Answers
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?

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 coefficients are determined using a pure octanol-water system,

whereas PFPR wastewaters typically contain a variety of contaminants that may render the octanol-water coefficient invalid

for a particular wastewater. In addition, octanol-water coefficients 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.

If a facility chooses to meet zero

discharge through no discharge of

process wastewater pollutants

(rather than no flow), how do they

show “zero”?

In order to demonstrate zero discharge analytically (instead of

via "no flow"), any pesticide active ingredient potentially present in the wastewater must have an EPA-approved analytical

method for use in wastewater, and the pesticide active ingredient 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 "detection limit" are generally understood to encompass these terms.

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?

The PFPR rule does not require monitoring or the establishment 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 pollutants. 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 additional priority pollutants expected to be in the wastewater.

Are industrial users (IUs) 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 certifications 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 enforcement officials.

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CHAPTER 10 Workshop Questions and Answers
EPA Test Methods

What if a wastewater matrix

causes interference with the

analytical method (and therefore,

the detection limit is higher than

normal)?

The discharger must eliminate the interference using the procedures 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.

Are the EPA-approved methods

highly specific methods?

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 pesticides. For more information on pesticide active ingredient

methods, please reference Methods for the Determination of Nonconventional 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/C97-001). 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.

Does EPA have method detection

limits for each pesticide active

ingredient that has an

EPA-approved analytical method?

Yes, although facilities must also take into account the wastewater matrix and the number of dilutions performed by the

laboratory.

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)?

Yes. For pesticide active ingredients that have no EPA-approved 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.

Are the methods promulgated

under Part 455 for pesticide active

ingredients valid for the NPDES

program and pretreatment

programs under Part 136?

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 ingredient methods have been published in a document entitled,

“Methods for the Determination of Nonconventional Pesticides in

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CHAPTER 10 Workshop Questions and Answers
Municipal and Industrial Wastewater, EPA-821-R-93-010-A, Revision 1, August 1993.”

Are the methods part of the

AWWT (American Waste Water

Treaters) published methods?

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 of Nonconventional Pesticides in Municipal and Industrial Wastewater, EPA-821-

R-93-010-A, Revision 1, August 1993).

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?

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 instruments leads to the lowering of MDLs, those facilities demonstrating 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)?

A facility can evaluate the effectiveness of a treatment technology by performance measures that look at how much contaminant 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 determine 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 removes 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 account. 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.

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?

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 implementation of the P2 practices, evaluation of the percent removal or destruction of the pesticide active ingredient, as well

as the final effluent concentration and detection limit, determines whether a wastewater has been effectively treated. In

most cases, these technologies can reduce the concentration of

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CHAPTER 10 Workshop Questions and Answers
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.

Will most PFPR facilities be able

to run a treatment system as

envisioned by EPA, in terms of

size and cost?

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, facilities 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 generally use simple, easily operated unit operations that use standard, 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 generating a small volume of wastewater can store it until a sufficient volume is available for treatment. During the

rulemaking process, EPA designed a small-scale wastewater

treatment system that was then used to treat wastewaters collected from PFPR facilities in batches of about 100 gallons. This

system used standard, off-the-shelf equipment. EPA also evaluated the cost of compliance with the P2 alternative and found

that the P2 alternative (with listed modifications and appropriate treatment) is economically achievable for the industry.

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.

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 pesticide 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 oxidation of PAIs using a chlorine-based oxidizer. Chemical oxidation 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 treatment. Where chemical oxidation with a chlorinating agent results in the generation of chlorinated organics, use of a

non-chlorinating oxidizer, such as ozone or peroxide may pro138

CHAPTER 10 Workshop Questions and Answers
vide effective treatment without generating chlorinated organics.

Why is “pollution prevention”

listed as an appropriate treatment

technology?

Based on available data, EPA was unable to identify a cost-effective technology for use in the PFPR industry for some pesticide active ingredients on Table 10. Therefore, EPA

determined that, if a facility generates wastewater that only

contains such pesticide active ingredients, they are in compliance with the rule if they have implemented the Table 8 pollution prevention practices (i.e., such facilities do not have to

treat PFPR wastewaters containing these specific PAIs prior to

discharge).

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?

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 conducted 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.

Why isn’t neutralization

considered treatment?

For this rule, treatment is intended to mean removal or destruction of pesticide active ingredients or priority pollutants.

Neutralization does not achieve that purpose.

Is there any guidance on how

much money facilities should

spend on treatment of PFPR

wastewater?

There is no real guidance on the amount of money a facility

should spend on wastewater treatment; it depends on a number of factors and the facility should consider all of these factors 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 consider 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 contract 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 industry. As part of this assessment, EPA estimated the cost to

comply with the regulation. Subcategory C facilities were estimated to incur an average annual cost of $39,900 for standalone 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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CHAPTER 10 Workshop Questions and Answers
Why calculate the destruction and

removal efficiency (DRE) for a

constituent that is below the

detection limit in the effluent?

The PFPR regulation does not require facilities to calculate the

DRE of pesticide active ingredients or priority pollutants; however, it may be helpful to determine which treatment units in

a treatment train are providing significant removal of the constituents of interest. For example, the following table summarizes 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.,μg/L), the hydrolysis unit achieves the

majority of the constituent’s reduction (i.e., 98 percent).

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.”

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)?

“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 depend on the specific organic chemicals in the wastewater, the

concentrations of those chemicals, and the pesticide active ingredients 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.

Who makes the decision on how

much treatment is needed?

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.

Wastewater Source Concentration (μg/L) DRE

Raw wastewater 1,000 μg/L —

Hydrolysis effluent 20 μg/L 98%

Activated carbon effluent <10 μg/L >50%

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CHAPTER 10 Workshop Questions and Answers
What happens if a facility needs

to add different technologies to

their treatment system in the

future?

If a facility plans to add new production to their PFPR operations, 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 production 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 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 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 ingredients whose listed technology is hydrolysis before removing 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 account for the carbon removing more pesticide active ingredients (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 ingredient and the surrogate.

Compliance

Baseline Monitoring Report

Is guidance available for

completion of the baseline

monitoring report (BMR)?

See Appendix E for EPA’s guidance memorandum on completing the BMR. The BMR was due on July 7, 1997 for existing

indirect dischargers.

To whom is the BMR submitted

and where is this stated?

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 submitted to the regional EPA office. Section 403 of Title 40 of the

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CHAPTER 10 Workshop Questions and Answers
CFR, as well as EPA Pretreatment Bulletin #13 (included in

Appendix E), discuss these issues.

Does the PFPR regulation require

monitoring, other than priority

pollutant monitoring for the BMR?

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 formulated products.

How many samples are required

for the BMR?

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 pollutants, 24-hour composite samples must be obtained through

flow-proportional composite sampling techniques where feasible. 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 composite 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.

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?

At a minimum, the facility should update the non-monitoring

sections of the BMR (e.g., process information, flow). In addition, 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 manufacturing effluent guidelines; otherwise, historical monitoring

would suffice.

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CHAPTER 10 Workshop Questions and Answers
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 alternative, 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 additional data (e.g., toxicity measurements).

P2 Alternative/Allowable Discharge

Can you choose zero discharge for

an individual source?

Yes, as long as you clearly indicate it in your compliance paperwork.

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, a facility could switch from zero discharge to the P2 alternative 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 circumstance 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(l). These regulations discuss the renewal 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(l)

(“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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CHAPTER 10 Workshop Questions and Answers
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 guidelines preamble to the final rule (61 FR 57518; November 6,

1996), EPA believes that when considering the potential crossmedia impacts associated with zero discharge (e.g., impacts to

air from contract hauling for off-site incineration of dilute, lowBTU-value, wastewaters), the P2 alternative may be more protective 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?

No, facilities are not required to complete these tables. They

are provided as a tool. However, if a facility chooses to complete them, they can be used to meet some of the paperwork

requirements (see Chapters 4, 6, and 7 of this manual for more

detail).

Who is the entity that conducts a

P2 audit and regulates a facility?

The control authority (for indirect dischargers) or the permitting 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/permitting authorities, consultants, etc. to help organize the various

pieces of information that will aid in making compliance decisions. 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. 

Who receives the initial

certification?

The control authority/permitting authority receives the certification from facilities that choose the P2 alternative and that

discharge or have the potential to discharge.

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?

40 CFR 403.8(f)(2)(vi) requires the POTW to take care and establish 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 appropriate/representative and in accordance with 40 CFR 136. Therefore, Part 403 does not require IU sampling to be defensible in

enforcement procedures. This means that the sampling performed 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 representative. However, other state or local regulations may also

apply.

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CHAPTER 10 Workshop Questions and Answers
What kind of compliance

paperwork is required for zero

dischargers, including facilities

that do not generate wastewater

and facilities that totally reuse all

wastewater generated?

If the facility does not have a “potential to discharge,” such as

facilities that do not generate wastewater, they are not covered

by the scope of the regulation; however, a facility may want to

send a letter or certification statement to their POTW/control

authority stating that they have “no potential to discharge.”

If the facility does have the “potential to discharge,” even if

they are not actively discharging (which may be the case with

facilities that totally reuse wastewater), the facility needs to

complete a BMR. For the monitoring requirements portion of

the BMR, they should indicate that they will be achieving zero

discharge, and therefore, there is nothing to monitor.

If the facility is complying with zero discharge by demonstrating “nondetects” of pesticide active ingredients and priority

pollutants, the BMR should contain monitoring data for the

priority pollutants, as well as a list of the pesticide active ingredients expected to be used in production in the next 12

months.

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?

PFPR facilities complying with the P2 alternative must keep

the compliance paperwork necessary to document their current activities. In addition, facilities must keep “old” paperwork for the three-year minimum discussed in 40 CFR

403.12(o).

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?

Facilities may cross-reference records in other parts of the facility (e.g, production records), but must be able to produce

those records when requested by their permitting or control

authority.

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?

Facilities may use the following certification statement listed

in Section 403, but they are not required to use that exact wording 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 submitted. 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 imprisonment for knowing violations.”

Most importantly, the “responsible corporate official” (or general partner or proprietor or duly authorized official), as de145

CHAPTER 10 Workshop Questions and Answers
fined in Section 403.12(l), 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(l) of the General Pretreatment Regulations:

(l) 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-president 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 (l)(1) or (l)(2) of this section if:

(i) The authorization is made in writing by the individual described in paragraph (l)(1) or (l)(2);

(ii) The authorization specifies either an individual or

a position having responsibility for the overall operation of the facility from which the Industrial Discharge

originates, such as the position of plant manager, operator of a well, or well field superintendent, or a position of equivalent responsibility, or having overall

responsibility for environmental matters for the company; and

(iii) the written authorization is submitted to the Control Authority.

(4) If an authorization under paragraph (l)(3) of this section 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 (l)(3) of this section must

be submitted to the Control Authority prior to or together

with any reports to be signed by an authorized representative.

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CHAPTER 10 Workshop Questions and Answers
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 authority at the same time (and have them signed by the same person).

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)?

If the facility chooses to meet zero discharge, then the limitation is zero, not the method detection limit. However, the facility can demonstrate zero discharge by achieving no

detection of process wastewater pollutants. If the method detection 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 number (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?

The POTW/control authority is authorized to view CBI, but

they must have procedures in place to protect CBI from unauthorized 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.

Can a facility claim both

treatment system effluent and

outfall effluent data CBI?

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 commingled outfall.

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?

If the new toll formulator is performing any in-scope PFPR

operations, then they do not need to provide a 90-day notification; however, they would need to notify the control authority of the “change of discharge” [40 CFR 403.12(j)] and would

indicate this change in their PFPR periodic certification paperwork.

If the new toll formulator does not currently perform any PFPR

operations, the toll formulator may need to meet zero discharge (e.g., through off-site disposal or through sending

wastewater back to the facility through which they are con147

CHAPTER 10 Workshop Questions and Answers
tracting) or store the wastewater until a proper control mechanism 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?

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 monitoring 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.

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.)?

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. Therefore, 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 compliance with 40 CFR 455 Subcategory C requirements.

In the end, does the permitter

come up with a mass- or

concentration-based limit?

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 pesticide active ingredient.

How much flexibility does a

control authority/permitter have to

modify a practice?

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 promote pollution prevention practices first, followed by recycle/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 practices 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).

Does the PFPR rule give the

criteria the control

authority/permitting authority

can/should use in modifying

practices?

As discussed in the answer to the previous question, the preamble to the final PFPR rule provides guidance to permitters/control authorities on the criteria for modifying P2

practices under the P2 alternative. See page 57526 of the preamble to the final rule in Appendix A.

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CHAPTER 10 Workshop Questions and Answers
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?

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 authority/permitter should be sure that they are observing operations related to in-scope PFPR production before taking any

action.

How do control

authorities/permitting authorities

use Table 10?

If a PFPR facility chooses the P2 alternative and generates

wastewaters that require treatment prior to discharge following implementation of P2 practices, then the control/permitting authority can use Table 10 as one way to identify that the

treatment being used is “appropriate.”

How do treatment decisions work

and how does a permit writer

determine limits for

PFPR/manufacturing facilities?

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). Nonmanufactured pesticide active ingredients must not be detected 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 limitation for pesticide active ingredients that are also manufactured could be adjusted to include the facility’s PFPR

production. If the pesticide active ingredient is not manufactured, that pesticide active ingredient would not require a specific limitation. See page 57528 of the preamble to the final rule

in Appendix A for a detailed discussion of compliance for

PFPR/manufacturers.

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?

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 concentration). 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 determine that, if a facility has successfully implemented P2 practices, 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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CHAPTER 10 Workshop Questions and Answers
How can an enforcement agency

determine if a treatment system is

well operated and maintained?

The determination of whether a treatment system is well operated and maintained will be based on the rationale and

“method of demonstration” chosen by the facility and approved 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 ingredient concentrations, they might demonstrate that the system is well operated and maintained by monitoring TOC and

documenting the frequency of carbon changeout. The enforcement 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.

Does a POTW/control authority

need to monitor specifically for

pesticide active ingredients to

ensure that a facility is complying

with the PFPR rule?

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 readily 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.

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?

POTWs/control authorities are required by Federal Regulations 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 categorical 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.

How is the control authority able

to show compliance when there

are no numeric limits?

By ensuring that their categorical industrial users are maintaining their on-site compliance paperwork accurately, that the

specified P2 practices have been implemented, and that the

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CHAPTER 10 Workshop Questions and Answers
treatment systems are appropriate and have been demonstrated to be well operated and maintained.

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?

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 effluent for pesticide active ingredients at the point of discharge to

the receiving stream, the contribution of pesticide active ingredients comes not only from PFPR facilities but also nonpoint

source dischargers (e.g., agricultural runoff).

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)?

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 maintained based on the rationale discussed in their on-site compliance paperwork.

Can EPA provide guidance to

permit enforcement officials on

allowing negotiation of a

compliance plan without

penalties?

EPA’s Small Business Policy promotes environmental compliance by providing incentives, such as penalty waivers and

penalty mitigation, to those small businesses that participate

in on-site compliance assistance programs or conduct environmental 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 potential 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 conducts 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 violation is corrected within 180 days after detection of the violation (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 endangerment to the public or environment, does not involve criminal

conduct, and did not result in a significant economic benefit.

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CHAPTER 10 Workshop Questions and Answers
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.

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?

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/permitting authority and included in the permit/control mechanism. After that, if facility is not following the practices, then

enforcement actions may be taken.

Are there any RCRA issues

associated with the practices

mentioned (e.g., storage and

reuse)?

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 treating wastewaters that are

listed or characteristic wastes, is a

RCRA permit required?

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 exempt from RCRA regulations.

Do changes specified in the

periodic certification require

NPDES permits to be reopened?

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.

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?

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 wastewater 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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CHAPTER 10 Workshop Questions and Answers
by keeping logs/records of the volumes and characteristics of

their wastewater.

Does the P2 alternative override

or make a current discharge

permit obsolete?

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?

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 effluent, and only if all pollutants have approved analytical methods. A detection of any of these pollutants means the facility

is out of compliance with the rule.

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?

The potential to discharge only includes regulated wastewater

sources. Sanitary water, as well as employee shower and laundry water, are not regulated wastewater sources under the

PFPR rule. Therefore, a facility could have a sanitary hookup

and still be considered as having “no potential to discharge”

regulated wastewater. If a facility is concerned that their employees may discharge regulated wastewater sources through

a sanitary hookup, they may want to establish a training program, including standard operating procedures (SOPs) to

cover the management of wastes at their site.

Who determines whether a facility

has the “potential to discharge”?

The facility is not covered under the scope of the rule, but may

want to notify their control/permitting authority and/or submit a certification stating that they have “no potential to discharge” regulated PFPR wastewater sources. This certification

would be submitted to (and approved by) the control/permitting authority following inspection.

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CHAPTER 10 Workshop Questions and Answers
Compliance Time Line

When do facilities have to start

certifying their operations (i.e.,

now versus November 6, 1999)?

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 include 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 existing NPDES permit.

New sources must be in compliance with the PFPR rule at the

commencement of discharge.

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?

A new indirect source (any PFPR facility that meets the definition 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 between 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 Users 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.”

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?

New sources must complete a BMR 90 days prior to discharge

and must be in compliance with the PFPR pretreatment standards (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 authority and have their on-site compliance paperwork completed.

Ninety days following commencement of discharge, the facil154

CHAPTER 10 Workshop Questions and Answers
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 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.

After November 6, 1999, when are

facilities (new sources) required to

submit their initial certification?

At the time of permit issuance prior to discharge.

Is any paperwork required

between now and November 6,

1999 for indirect dischargers?

In addition to submitting the BMR, if a facility is not in compliance at the time they submit the BMR, then they must develop 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.

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?

No. For indirect dischargers, it is prior to the initial certification. The BMR is the first piece of compliance paperwork required 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.

Why aren’t facilities required to

submit their initial certification at

the time the BMR is due?

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 certification 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.

How does the November 6, 1999

date apply to facilities that either

choose to achieve zero discharge

or already achieve zero discharge?

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 issuance, reissuance, or modification of their NPDES permit.

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CHAPTER 10 Workshop Questions and Answers
Do all facilities within the scope

of the PFPR rule have to meet

zero discharge by the November

6, 1999 compliance date?

No. Existing indirect discharging facilities have to be in compliance 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 issuance, reissuance, or modification of their NPDES permit.

Should initial certification

paperwork be completed before

installing full-scale treatment?

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 required prior to discharge. The initial certification paperwork

must be completed by or before the compliance deadline.

Direct dischargers must complete the initial certification paperwork by the time of permit issuance, reissuance, or renewal.

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)?

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 dischargers must establish milestones with their control authority

that the facility must meet to achieve compliance with the rule

by November 6, 1999.

Does the treatment system have to

be fully tested and operational at

the time the initial certification

statement is submitted?

Indirect dischargers must set up milestones for achieving compliance 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 compliance 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.

When is a facility allowed to

discharge after selecting a

compliance option?

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.

Must the control/permitting

authority approve the P2 practices

and modifications before they are

implemented?

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
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.

When is the periodic certification

required, now or after November

6, 1999?

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 General Pretreatment Regulations or the NPDES regulations.

If a customer asks a facility to

begin making a new product,

when must the control authority

be notified and when can

discharge begin?

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 appropriate or equivalent treatment if new pesticide active ingredients 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 wastewater 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?

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.

Is there any way the government

can track the commodity

chemicals used in pesticide

products by PFPR and pesticide

manufacturing facilities?

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 FIFRA.

Also, facilities are required to report emissions of toxic chemicals under the SARA Section 313 program (i.e., the Toxic Release Inventory program). However, PFPR facilities often do

not use toxic chemicals in the amounts necessary to trigger

reporting under this program, although some pesticide manufacturers do.

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CHAPTER 10 Workshop Questions and Answers
How did EPA come to the

conclusion that facilities would

store wastewater and treat it

quarterly?

A storage period of 90 days or longer prior to treatment is not

uncommon in this industry, based on information EPA gathered during site visits. EPA originally evaluated batch treatment of PFPR wastewater on a quarterly basis because of

possible RCRA requirements that might be applicable if wastewater 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 hazardous. 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 generators (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 treatment even when non-hazardous.

Was toxicity testing considered in

lieu of the P2 alternative?

No, the Clean Water Act requires effluent limitations guidelines 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 demonstrating that the treatment system is well operated and maintained.

Will the P2 Guidance Manual be

available on the Internet?

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 Industry.

Is there a place where treatability

data could be logged or collated

so all facilities can utilize the

results?

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.

How do we determine the CAS

numbers of the pesticide active

ingredients listed on Table 10?

EPA has included a table in Appendix C that lists pesticide

active ingredients from Table 10 with their corresponding

Shaughnessey codes and CAS numbers.

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CHAPTER 10 Workshop Questions and Answers
159

P2 Guidance Manual Feedback Survey

1. Please rate each of the following chapters:

More Detail Right Amount Less Detail

Chapter—Title Needed of Detail Needed

1—Introduction q qq

2—PFPR Operations q qq

3—Pollution Prevention Glossary q qq

4—Conducting the P2 Audit q qq

5—Wastewater Treatment Technologies q qq

6—Conducting the Treatability Test q qq

7—Regulatory Compliance Documentation q qq

8—Case Studies q qq

9—Where to Get Additional P2 Help q qq

10—Workshop Questions and Answers q qq

2. What is the most useful part of the manual?

3. Please list any specfic changes you would suggest.

4. Are there any parts of the promulgated rule that are still unclear?

5. How can this manual be improved to relate the specifics of the rule?

6. Do you feel EPA has communicated guidance information pertaining to this rule

in an effective manner?

q yes q no (please elaborate)

7. If you are from a PFPR facility, whether or not you decide to implement the P2

Alternative Option, are you planning to implement any new P2 practices as a

result of reading this manual and/or attending an EPA PFPR P2 workshop? If so,

which one(s)?
P2 Guidance Manual Feedback Survey Pollution Prevention Guidance Manual for the PFPR Industry

160

(fold here to mail)

8. What additional information could EPA provide to make implementing:

• the P2 practices easier:

• the P2 Alternative Option easier:

9. Do you find this guidance manual useful 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. Please check the box that most closely describes your company:

q Pesticide manufacturing/PFPR facility

q PFPR facility

q Trade association

q POTW

q State or regional EPA permitter

q Other _________________________

11. Please check the box that most closely describes your familiarity with the

following topics prior to this guidance:

Very Somewhat Not at all

Familiar Familiar Familiar

PFPR Operations qq q

Effluent Guidelines qq q

P2 Alternative Option qq q

Pollution Prevention qq q

Wastewater Treatment Technologies qq q

Ms. Shari Zuskin

U.S. Environmental Protection Agency

Engineering and Analysis Division (4303)

401 M Street, SW

Washington, DC 20460

Place

Stamp

Here
161

APPENDIX A

PFPR Final Regulation

(40 CFR Part 455)
federal register

57517

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
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 (ICR) 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:
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57519

Category Examples of regulated entities

Industry ........ • Pesticide formulating, packaging and repackaging

(PFPR) facilities;

• PFPR facilities that also

manufacture pesticide active ingredients;

• Agricultural refilling establishments.

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 Standalone 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)(1) 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.,
57520 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

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.

challenged the Effluent Guidelines Plan

in a suit filed in U.S. District Court for

the District of Columbia (NRDC et al v.

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 et seq., 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57521

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.1 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
57522 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

3At 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.

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 lbs/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 lbs/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

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 crosscontamination 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57523

and pollutants that have been

determined to not pass through a

POTW. (See Section III.A.1 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.1.c. 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.
57524 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

4 Storm water at PFPR facilities and Refilling

Establishments is covered by the Storm water

Regulations Phase I and II, respectively.

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 semicritical devices as these terms are now

defined in FFDCA section 201 and

FIFRA section 2(u). See 40 CFR

455.40(f). 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
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 nonreusable 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 nonreusable 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 EI 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

PFP Facilities, 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 crosscontamination. 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 zerostandard 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 nonreusable 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
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 Standalone 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57527

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.

6A 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 nonpesticide chemical products and be considered a

‘‘stand-alone’’ PFPR facility.

7EPA 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.

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 packaging 5 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
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., offsite 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 ‘‘nonmanufactured’’ 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57529

8Section 402 of the Clean Water Act addresses

the NPDES requirements, while Section 307(b)

addresses the pretreatment standards.

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.

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 Act 8 (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

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)(1)). 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)(iii).

IV. The Final Regulation

A. Pretreatment Standards for Existing

Sources (PSES)

1. 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.1, 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
57530 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

10The 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 loadingweighted average of the toxic weighting factors for

the 272 PAIs.

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

equivalents 10.

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.

B. Best Practicable Control Technology

Currently Available (BPT)

1. 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.1. 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57531

11The 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 =

5.6 x 103.

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)

1. 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.1 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 lbs

(or 71.6 million lb-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)

1. 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.

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)

1. 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
57532 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

12 Due to changes in scope for the final regulation,

1,411 water using facilities will be potentially

subject to the final regulation.

13Many of these facilities also used non-272 PAIs

in addition to the 272 PAIs.

14The 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 loadingweighted average toxicity of the 272 PAIs.

16At proposal, EPA reported an average costeffectiveness, or the cost-effectiveness value

calculated relative to the baseline of no regulation,

and an incremental cost-effectiveness, or the costeffectiveness relative to the next less stringent

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

regulation 13 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 dollars 14 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 PAIusing 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 costeffectiveness of the proposed regulation

for Subcategory C facilities. Costeffectiveness is calculated as the ratio of

the incremental annual costs in 1981

dollars to the incremental poundsequivalent 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 16 EPA considers

the proposed option to be cost-effective.
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57533

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.

17A capital investment of approximately $500

was estimated for each of these facilities.

18The cost and impact values for the

Supplemental Notice regulation reflect updating of

the estimates of non-272 PAI-using facilities.

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 poundsequivalent, 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 VI.B.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

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 costeffectiveness 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

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 PFPRrelated employment. More realistically,

EPA expects that line conversions will

not generally lead to full loss of PFPRrelated 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
57534 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

19Although 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.

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.1). 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.

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).
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57535

20All comparisons with the proposed regulation

and supplemental notice are based on the analyses

including baseline closures.

21EPA 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.

TABLE 1.—ESTIMATED COSTS AND IMPACTS OF THE FINAL, PROPOSED AND SUPPLEMENTAL NOTICE PSES REGULATION

FOR SUBCATEGORY C FACILITIES

Number of facilities incurring costs

Total

annualized

compliance

cost ($1995,

millions)

Severe

impacts †

Moderate

impacts *

Maximum potential employment loss ††

Proposed Regulation ............................................................ 1,142 $71.9 3 327 890

Supplemental Notice ............................................................. 709 43.4 0 208 634

Final Regulation—Costs Including Baseline Closures ......... 506 29.9 0 150 458

Final Regulation—Costs Excluding Baseline Closures ........ 421 24.2

†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.

††Employment loss for the proposed regulation includes the estimated employment loss in facility closures and the worst case estimate of employment loss in facilities with line conversions. The reported employment loss for the Supplemental Notice and Final Regulation reflects no facility 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 (reestimated) 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

percent 20. 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 CostEffectiveness 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

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.
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 costeffectiveness 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. Costeffectiveness 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 ‘‘poundsequivalent.’’ The cost-effectiveness

value, therefore, represents the unit cost

of removing an additional poundequivalent (lb 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 poundsequivalent 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 costeffectiveness 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 costeffectiveness 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57537

22EPA 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.

23The re-calculated cost-effectiveness values for

the proposed regulation also reflect the updated

estimates of the number of facilities using non-272

PAIs.

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 costeffectiveness 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 million 22 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 costeffectiveness 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

Total

annualized

compliance

costs (millions

of $, 1981)

Pollutant

removals,

pounds

Pollutant removals,

(pounds-equivalent)

Cost-effectiveness

($/lb.-eq.)

No POTW Removals ................................................................................. $20.9 189,908 7.6 million ............. $2.74

POTW Removals per DSS ....................................................................... 20.9 165,460 5.8 million ............. 3.60

90 Percent Removal Efficiency ................................................................. 20.9 18,991 760,000 ................. 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 costeffectiveness 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 poundsequivalent). 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 toxicweighted 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]

Proposed regulation:

Zero discharge with

sanitizer exemption

(Option 3/S.1)

Supplemental notice:

Zero discharge/pollution prevention alternative

Final regulation: Zero

discharge/pollution

prevention alternative

Total Annualized Cost, $1981 .................................................................. $64.1 million .............. $32.7 million .............. $20.9 million.

Pollutant Discharges Subject to Regulation, pounds ............................... 505,235 ..................... 337,995 ..................... 192,789.

Pollutant Loadings Subject to Regulation, pounds-equivalent ................ 23.2 million ................ 15.4 million ................ 7.7 million.

Pollutant Removals, pounds .................................................................... 503,114 ..................... 333,731 ..................... 189,908.
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]

Proposed regulation:

Zero discharge with

sanitizer exemption

(Option 3/S.1)

Supplemental notice:

Zero discharge/pollution prevention alternative

Final regulation: Zero

discharge/pollution

prevention alternative

Pollutant Removals, pounds-equivalent ................................................... 23.2 million ................ 15.3 million ................ 7.6 million.

Cost-Effectiveness‡ .................................................................................. $2.77/lb-eq ................ $2.14/lb-eq ................ $2.74/lb-eq.

AAA‡Cost-effectiveness 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 costeffectiveness 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 costeffectiveness 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 smallbusiness 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 businessowned entities in the PFPR industry,

EPA exercised substantial care at

proposal and throughout development

of the final regulation, to ensure that the
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 businessfacilities 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—5and 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 costeffective 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
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)(1)(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 (ICR) 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
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 onsite (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 rulemaking

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 postcompliance (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
57542 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

24Criteria 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.

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.1 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 postcompliance (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 offsite 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 crossmedia 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57543

25EPA 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

use of open vessels during treatment which may

overestimate the emissions.

4, the emissions for criteria air

pollutants from the transport of

wastewaters and spent activated carbon

and from the incineration of the nonreusable 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 VOCs NOx PM CO SO2

Wastewater Transportation:

Zero/P2 Alternative ............................................................................ 14,720 121,200 6,800 175,400 ....................

Zero Discharge .................................................................................. 87,600 720,000 40,400 1,044,000 ....................

Wastewater Incineration:

Zero/P2 Alternative ............................................................................ 5 1,838 10 133 2

Zero Discharge .................................................................................. 264 94,600 530 6,880 106

Spent Activated Carbon Transportation:

Zero/P2 Alternative ............................................................................ 1,692 13,920 780 20,200 ....................

Zero Discharge† ................................................................................ NA NA NA NA ....................

Wastewater Treatment: ‡

Zero/P2 Alternative ............................................................................ 84,700 NA NA NA NA

Zero Discharge .................................................................................. 52,500 NA NA 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.

† There is no wastewater treatment system used under the zero discharge option and, therefore, no spent activated carbon to transport for regeneration.

‡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 lbs 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 release 25. It is also

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

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.
57544 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

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.

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

1. 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 selfimplemented 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 onsite 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
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 (June 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)(1)(ii)) and to

carry out inspections of the indirect

dischargers’ self-certifications and of the

paperwork described below. 40 CFR

403.8(f)(1)(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 ‘‘Onsite 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(l) 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
57546 Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations

27 In 40 CFR 403.7, removal is defined to mean

‘‘a reduction in the amount of a pollutant in the

POTW’s 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.’’

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 offsite 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)(1)(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 Pont v. 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 ‘‘removes 27 all or any

part of such toxic pollutant,’’ (2) the

POTW’s 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 POTW’s 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. NRDC v. 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
Federal Register / Vol. 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57547

28Under § 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 (iii).

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

CFR 403.7(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, nnitrosodimethylamine, n-nitrosodi-npropylamine, 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 nonconventional 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
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 nonpesticide 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 PAI’s 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.1, 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

FDF—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: Secs. 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 (33 U.S.C. 1311, 1314, 1316, 1317, and

1361).

1a. 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.

(l) Inorganic wastewater treatment

chemicals means inorganic chemicals

that are commonly used in wastewater

treatment systems to aid in the removal
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(f) 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 nonpesticide chemical products and be

considered a ‘‘stand-alone’’ PFPR

facility.

1b. 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 semicritical 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(l) 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
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(l) 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), 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.

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.
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
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.

455.61 Special Definitions.

455.62 Effluent limitations guidelines

representing the degree of effluent

reduction attainable by the application of

the best practicable pollutant control

technology (BPT).

455.63 Effluent limitations guidelines

representing the degree of effluent

reduction attainable by the application of

the best conventional pollutant control

technology (BCT).

455.64 Effluent limitations guidelines

representing the degree of effluent

reduction attainable by the application of

the best available technology

economically achievable (BAT).

455.65 New source performance standards

(NSPS).

455.66 Pretreatment standards for existing

sources (PSES).

455.67 Pretreatment standards for new

sources (PSNS).

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
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

Shaughnessey

code Chemical name1

002201 .......... Sabadilla alkaloids.

006501 .......... Aromatic petroleum derivative solvent.

006602 .......... Heavy aromatic naphtha.

0166012 ......... Dry ice.

022003 .......... Coal tar.

025001 .......... Coal tar neutral oils.

025003 .......... Creosote oil (Note: Derived

from any source).

025004 .......... Coal tar creosote.

031801 .......... Ammonium salts of C8–18

and C18’ fatty acids.

055601 .......... BNOA.

063501 .......... Kerosene.

063502 .......... Mineral oil—includes paraffin

oil from 063503.

063503 .......... Petroleum distillate, oils, solvent, or hydrocarbons; also

p.

063506 .......... Mineral spirits.

067003 .......... Terpineols (unspec.).

067205 .......... Pine tar oil.

067207 .......... Ester gum.

067302 .......... Amines, N-coco

alkyltrimethylenedi-, acetates.

069152 .......... Amines, coco alkyl,

hydrochlorides.

070801 .......... Red Squill glycoside.

TABLE 9 TO PART 455.—GROUP 2

MIXTURES—Continued

Shaughnessey

code Chemical name1

071004 .......... Cube Resins other than rotenone.

071501 .......... Ryania speciosa, powdered

stems of.

072602 2 ........ Silica gel.

072605 2 ........ Silicon dioxide.

079014 .......... Turkey red oil.

079021 .......... Potassium salts of fatty

acids.

079029 .......... Fatty alcohols (52–61% C10,

39–46% C8, 0–3% C6, 0–

3% C12).

079034 .......... Methyl esters of fatty acids

(100% C8–C12)

079059 .......... Fatty alcohols (54.5% C10,

45.1% C8, 0.4% C6)

086803 .......... Xylene range aromatic solvent

107302 .......... Polyhedral inclusion bodies

of Douglas fir tussock

moth nucl.

107303 .......... Polyhedral inclusion bodies

of gypsy moth

nucleopolyhedrosis.

107304 .......... Polyhedral inclusion bodies

of n. sertifer

116902 .......... Gibberellin A4 mixt. with

Gibberellin A7.

117001 .......... Nosema locustae.

128888 .......... Lactofen (ANSI).

1289342 ......... Nitrogen, liquid.

129029 .......... Bergamot Oil.

224600 .......... Diethanolamides of the fatty

acids of coconut oil (coded

079).

505200 .......... Isoparaffinic hydrocarbons.

1Shaughnessey codes and chemical names

are taken directly from the FATES database.

Several chemical names are truncated because the chemical names listed in the

FATES database are limited to 60 characters.

2EPA 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 name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Dicofol ........................................................... 001 10501 DDT .............................................................. Hydrolysis.

Maleic Hydrazide .......................................... 002 51501 Hydrazide ..................................................... Activated Carbon.

EDB ............................................................... 003 42002 EDB .............................................................. Activated Carbon.

Vancide TH ................................................... 004 82901 s-Triazine ...................................................... Activated Carbon.

1,3-Dichloropropene ...................................... 005 29001 EDB .............................................................. Hydrolysis.

Thenarsazine Oxide ...................................... 006 12601 Organoarsenic .............................................. Precipitation.

Dowicil 75 ...................................................... 007 17901 NR4 .............................................................. Activated Carbon.

Triadimefon ................................................... 008 109901 s-Triazine ...................................................... Activated Carbon.

Hexachlorophene .......................................... 009 44901 Chlorophene ................................................. Activated Carbon.

Tetrachlorophene .......................................... 010 ........................ Chlorophene ................................................. Activated Carbon.

Dichlorophene ............................................... 011 55001 Chlorophene ................................................. Activated Carbon.

Dichlorvos ..................................................... 012 84001 Phosphate .................................................... Hydrolysis.

Landrin-2 ....................................................... 013 ........................ Carbamate .................................................... Activated Carbon.

2,3,6-T, S&E or Fenac .................................. 014 82605 2,4-D ............................................................. Activated Carbon.

2,4,5-T and 2,4,5-T, S&E .............................. 015 (*) 2,4-D ............................................................. Activated Carbon.

2,4-D (2,4-D, S&E) ........................................ 016 (*) 2,4-D ............................................................. Chemical Oxidation.

2,4-DB, S&E .................................................. 017 (*) 2,4-D ............................................................. Activated Carbon.

Dyrene or Anilazine ...................................... 018 80811 s-Triazine ...................................................... Activated Carbon.

Dinocap ......................................................... 019 36001 Phenylcrotonate ........................................... Activated Carbon.

Dichloran or DCNA ....................................... 020 31301 Aryl Halide .................................................... Activated Carbon.

Busan 90 ....................................................... 021 8707 Miscellaneous Organic ................................. Activated Carbon.

Mevinphos ..................................................... 022 15801 Phosphate .................................................... Hydrolysis.

Sulfallate ....................................................... 023 ........................ Dithiocarbamate ........................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Chlorfenvinphos ............................................ 024 84101 Phosphate .................................................... Activated Carbon.

Cyanazine or Bladex ..................................... 025 100101 s-Triazine ...................................................... Activated Carbon.

Propachlor ..................................................... 026 19101 Acetanilide .................................................... Activated Carbon.

MCPA, S&E .................................................. 027 (*) 2,4-D ............................................................. Activated Carbon.

Octhilinone .................................................... 028 99901 Heterocyclic .................................................. Activated Carbon.

Pindone ......................................................... 029 67703 Miscellaneous Organic ................................. Activated Carbon.

Dichlorprop, S&E .......................................... 030 (*) 2,4-D ............................................................. Activated Carbon.

MCPP, S&E or Mecoprop ............................. 031 (*) 2,4-D ............................................................. Activated Carbon.

Thiabendazole ............................................... 032 60101 Heterocyclic .................................................. Activated Carbon.

Belclene 310 ................................................. 033 80815 s-Triazine ...................................................... Activated Carbon.

Chlorprop, S&E ............................................. 034 21202 2,4-D ............................................................. Activated Carbon.

Busan 72 or TCMTB ..................................... 035 35603 Heterocyclic .................................................. Hydrolysis.

Chlorophacinone ........................................... 037 67707 Miscellaneous Organic ................................. Activated Carbon.

Landrin-1 ....................................................... 038 ........................ Carbamate .................................................... Activated Carbon.

Pronamide ..................................................... 039 101701 Chlorobenzamide ......................................... Activated Carbon.

Methiocarb or Mesurol .................................. 040 100501 Carbamate .................................................... Hydrolysis.

Propanil ......................................................... 041 28201 Chloropropionanilide .................................... Activated Carbon.

Polyphase 6 ................................................... 042 107801 Carbamate .................................................... Activated Carbon.

Coumafuryl or Fumarin ................................. 043 86001 Coumarin ...................................................... Activated Carbon.

DNOC ............................................................ 044 ........................ Phenol .......................................................... Activated Carbon.

Metribuzin ...................................................... 045 101101 Triazathione .................................................. Activated Carbon.

CPA, S&E ..................................................... 046 (*) 2,4-D ............................................................. Activated Carbon.

MCPB, S&E .................................................. 047 19202 2,4-D ............................................................. Activated Carbon.

Aminocarb ..................................................... 048 ........................ Carbamate .................................................... Hydrolysis.

Etridiazole ..................................................... 049 84701 Heterocyclic .................................................. Activated Carbon.

Ethoxyquin .................................................... 050 55501 Quinolin ........................................................ Activated Carbon.

Acephate or Orthene .................................... 052 103301 Phosphoroamidothioate ............................... Activated Carbon.

Acifluorfen ..................................................... 053 114402 Benzoic Acid ................................................ Activated Carbon.

Alachlor ......................................................... 054 90501 Acetanilide .................................................... Activated Carbon.

Aldicarb ......................................................... 055 98301 Carbamate .................................................... Hydrolysis.

Allethrin ......................................................... 057 (*) Pyrethrin ....................................................... Activated Carbon.

Ametryn ......................................................... 058 80801 s-Triazine ...................................................... Activated Carbon.

Amitraz .......................................................... 059 106201 Iminamide ..................................................... Activated Carbon.

Atrazine ......................................................... 060 80803 s-Triazine ...................................................... Hydrolysis.

Bendiocarb .................................................... 061 105201 Carbamate .................................................... Hydrolysis.

Benomyl ........................................................ 062 99101 Carbamate .................................................... Hydrolysis.

BHC ............................................................... 063 ........................ Lindane ......................................................... Hydrolysis.

Benzyl Benzoate ........................................... 064 9501 Ester ............................................................. Activated Carbon.

Lethane 60 .................................................... 065 ........................ Thiocyanate .................................................. Activated Carbon.

Bifenox .......................................................... 066 104301 Nitrobenzoate ............................................... Activated Carbon.

Biphenyl ........................................................ 067 17002 Aryl ............................................................... Activated Carbon.

Bromacil (Lithium Salt) .................................. 068 (*) Uracil ............................................................ Activated Carbon.

Bromoxynil .................................................... 069 (*) Benzonitrile ................................................... Activated Carbon.

Butachlor ....................................................... 070 ........................ Acetanilide .................................................... Activated Carbon.

Giv-gard ........................................................ 071 101401 Miscellaneous Organic ................................. Activated Carbon.

Cacodylic Acid .............................................. 072 (*) Organoarsenic .............................................. Precipitation.

Captafol ......................................................... 073 ........................ Phthalimide ................................................... Hydrolysis.

Captan ........................................................... 074 81301 Phthalimide ................................................... Hydrolysis.

Carbaryl ......................................................... 075 56801 Carbamate .................................................... Hydrolysis.

Carbofuran .................................................... 076 90601 Carbamate .................................................... Hydrolysis.

Carbosulfan ................................................... 077 ........................ Carbamate .................................................... Activated Carbon.

Chloramben ................................................... 078 (*) Benzoic Acid ................................................ Activated Carbon.

Chlordane ...................................................... 079 58201 Tricyclic ........................................................ Activated Carbon.

Chloroneb ...................................................... 080 27301 Aryl Halide .................................................... Chemical Oxidation.

Chloropicrin ................................................... 081 81501 Alkyl Halide .................................................. Chemical Oxidation.

Chlorothalonil ................................................ 082 81901 Chloropropionanilide .................................... Activated Carbon.

Chloroxuron ................................................... 083 ........................ Urea .............................................................. Activated Carbon.

Stirofos .......................................................... 084 83701 Phosphate .................................................... Hydrolysis.

Chlorpyrifos Methyl ....................................... 085 59102 Phosphorothioate ......................................... Hydrolysis.

Chlorpyrifos ................................................... 086 59101 Phosphorothioate ......................................... Chemical Oxidation.

Mancozeb ...................................................... 087 14504 Dithiocarbamate ........................................... Activated Carbon.

Bioquin (Copper) ........................................... 088 24002 Organocopper .............................................. Precipitation.

Copper EDTA ................................................ 089 39105 Organocopper .............................................. Precipitation.

Pydrin or Fenvalerate ................................... 090 109301 Pyrethrin ....................................................... Activated Carbon.

Cycloheximide ............................................... 091 ........................ Cyclic Ketone ............................................... Activated Carbon.

Dalapon ......................................................... 092 (*) Alkyl Halide .................................................. Activated Carbon.

Dienochlor ..................................................... 093 27501 HCp .............................................................. Activated Carbon.

Demeton ........................................................ 094 ........................ Phosphorothioate ......................................... Hydrolysis.

Desmedipham ............................................... 095 104801 Carbamate .................................................... Hydrolysis.

Amobam ........................................................ 096 ........................ Miscellaneous Organic ................................. Activated Carbon.

DBCP ............................................................ 097 ........................ EDB .............................................................. 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Dicamba ........................................................ 098 (*) Aryl Halide .................................................... Activated Carbon.

Dichlone ........................................................ 099 29601 Quinone ........................................................ Activated Carbon.

Thiophanate Ethyl ......................................... 100 103401 Carbamate .................................................... Hydrolysis.

Perthane ........................................................ 101 ........................ DDT .............................................................. Activated Carbon.

EXD ............................................................... 102 ........................ Dithiocarbamate ........................................... Activated Carbon.

Diazinon ........................................................ 103 57801 Phosphorothioate ......................................... Hydrolysis.

Diflubenzuron ................................................ 104 108201 Urea .............................................................. Activated Carbon.

Dimethoate .................................................... 106 35001 Phosphorodithioate ...................................... Hydrolysis.

Parathion Methyl ........................................... 107 53501 Phosphorothioate ......................................... Hydrolysis.

Dicrotophos ................................................... 108 35201 Phosphate .................................................... Activated Carbon.

Crotoxyphos .................................................. 109 58801 Phosphate .................................................... Activated Carbon.

DCPA ............................................................ 110 78701 Aryl Halide .................................................... Activated Carbon.

Trichlorofon ................................................... 111 57901 Phosphonate ................................................ Activated Carbon.

Dinoseb ......................................................... 112 37505 Phenol .......................................................... Activated Carbon.

Dioxathion ..................................................... 113 37801 Phosphorodithioate ...................................... Hydrolysis.

Diphacinone .................................................. 114 67701 Indandione .................................................... Activated Carbon.

Diphenamide ................................................. 115 36601 Acetamide .................................................... Activated Carbon.

Diphenylamine .............................................. 116 38501 Aryl Amine .................................................... Activated Carbon.

MGK 326 ....................................................... 117 47201 Ester ............................................................. Activated Carbon.

Nabonate ....................................................... 118 63301 Isocyanate .................................................... Chemical Oxidation.

Diuron ............................................................ 119 35505 Urea .............................................................. Activated Carbon.

Metasol DGH ................................................ 120 44303 NR4 .............................................................. Activated Carbon.

Dodine ........................................................... 121 44301 NR4 .............................................................. Activated Carbon.

Endosulfan .................................................... 122 79401 Tricyclic ........................................................ Activated Carbon.

Endothall (Endothall S&E) ............................ 123 (*) Bicyclic ......................................................... Activated Carbon.

Endrin ............................................................ 124 41601 Tricyclic ........................................................ Activated Carbon.

Ethalfluralin ................................................... 125 113101 Toluidine ....................................................... Activated Carbon.

Ethion ............................................................ 126 58401 Phosphorodithioate ...................................... Hydrolysis.

Ethoprop ........................................................ 127 41101 Phosphorodithioate ...................................... Activated Carbon.

Fenamiphos .................................................. 128 100601 Phosphoroamidate ....................................... Activated Carbon.

Chlorobenzilate ............................................. 129 28801 Aryl Halide .................................................... Activated Carbon.

Butylate ......................................................... 130 41405 Thiocarbamate ............................................. Activated Carbon.

Famphur ........................................................ 131 ........................ Phosphorothioate ......................................... Hydrolysis.

Fenarimol ...................................................... 132 206600 Pyrimidine ..................................................... Activated Carbon.

Fenthion or Baytex ........................................ 133 53301 Phosphorothioate ......................................... Hydrolysis.

Ferbam .......................................................... 134 34801 Dithiocarbamate ........................................... Activated Carbon.

Fluometuron .................................................. 135 35503 Urea .............................................................. Activated Carbon.

Fluoroacetamide ........................................... 136 ........................ Acetamide .................................................... Activated Carbon.

Folpet ............................................................ 137 81601 Phthalimide ................................................... Hydrolysis.

Glyphosate (Glyphosate S&E) ...................... 138 (*) Phosphoroamidate ....................................... Chemical Oxidation.

Glyphosine .................................................... 139 ........................ Phosphoroamidate ....................................... Activated Carbon.

Heptachlor ..................................................... 140 44801 Tricyclic ........................................................ Activated Carbon.

Cycloprate ..................................................... 141 ........................ Thiocarbamate ............................................. Activated Carbon.

Hexazinone ................................................... 142 107201 s-Triazine ...................................................... Activated Carbon.

Isofenphos ..................................................... 143 109401 Phosphoroamidothioate ............................... Activated Carbon.

Isopropalin ..................................................... 144 100201 Toluidine ....................................................... Activated Carbon.

Propham ........................................................ 145 ........................ Carbamate .................................................... Hydrolysis.

Karabutilate ................................................... 146 97401 Carbamate .................................................... Hydrolysis.

Lindane ......................................................... 147 9001 Lindane ......................................................... Activated Carbon.

Linuron .......................................................... 148 35506 Urea .............................................................. Chemical Oxidation.

Malachite Green ............................................ 149 39504 NR4 .............................................................. Activated Carbon.

Malathion ....................................................... 150 57701 Phosphorodithioate ...................................... Hydrolysis.

Maneb ........................................................... 151 14505 Dithiocarbamate ........................................... Activated Carbon.

Manam .......................................................... 152 ........................ Dithiocarbamate ........................................... Activated Carbon.

Mefluidide ...................................................... 153 114002 Carbamate .................................................... Activated Carbon.

Methamidophos ............................................. 154 101201 Phosphoroamidothioate ............................... Activated Carbon.

Methidathion .................................................. 155 100301 Phosphorodithioate ...................................... Activated Carbon.

Methomyl ....................................................... 156 90301 Carbamate .................................................... Hydrolysis.

Methoprene ................................................... 157 (*) Ester ............................................................. Activated Carbon.

Methoxychlor ................................................. 158 34001 DDT .............................................................. Hydrolysis.

Methyl Bromide ............................................. 160 53201 Alkyl Halide .................................................. Activated Carbon.

Monosodium Methyl Arsenate ...................... 161 (*) Organoarsenic .............................................. Precipitation.

Nalco D-2303 ................................................ 163 68102 Thiocyanate .................................................. Activated Carbon.

Quinomethionate ........................................... 164 54101 Miscellaneous Organic ................................. Activated Carbon.

Metolachlor .................................................... 165 108801 Acetanilide .................................................... Activated Carbon.

Mexacarbate ................................................. 166 ........................ Carbamate .................................................... Hydrolysis.

Metiram ......................................................... 167 14601 Dithiocarbamate ........................................... Activated Carbon.

Monuron TCA ................................................ 168 35502 Urea .............................................................. Activated Carbon.

Monuron ........................................................ 169 35501 Urea .............................................................. Activated Carbon.

Napropamide ................................................. 170 103001 Carbamate .................................................... Activated Carbon.

Deet ............................................................... 171 80301 Toluamide ..................................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Nabam ........................................................... 172 14503 Dithiocarbamate ........................................... Chemical Oxidation.

Naled ............................................................. 173 34401 Phosphate .................................................... Hydrolysis.

Norea ............................................................ 174 ........................ Urea .............................................................. Activated Carbon.

Norflurazon .................................................... 175 105801 Heterocyclic .................................................. Activated Carbon.

Naptalam or Neptalam .................................. 176 30703 Phthalamide ................................................. Activated Carbon.

MGK 264 ....................................................... 177 57001 Bicyclic ......................................................... Activated Carbon.

Benfluralin ..................................................... 178 84301 Toluidine ....................................................... Activated Carbon.

Sulfotepp ....................................................... 179 79501 Phosphorothioate ......................................... Activated Carbon.

Aspon ............................................................ 180 ........................ Phosphorothioate ......................................... Activated Carbon.

Coumaphos ................................................... 181 36501 Phosphorothioate ......................................... Hydrolysis.

Fensulfothion ................................................. 182 32701 Phosphorothioate ......................................... Hydrolysis.

Disulfoton ...................................................... 183 32501 Phosphorodithioate ...................................... Hydrolysis.

Fenitrothion ................................................... 184 105901 Phosphorothioate ......................................... Hydrolysis.

Phosmet ........................................................ 185 59201 Phosphorodithioate ...................................... Hydrolysis.

Azinphos Methyl (Guthion) ........................... 186 58001 Phosphorodithioate ...................................... Hydrolysis.

Oxydemeton Methyl ...................................... 187 58702 Phosphorothioate ......................................... Activated Carbon.

Organo-Arsenic Pesticides ........................... 188 ........................ Organoarsenic .............................................. Precipitation.

Organo-Cadmium Pesticides ........................ 189 ........................ Organocadmium ........................................... Precipitation

Organo-Copper Pesticides ............................ 190 (*) Organocopper .............................................. Precipitation.

Organo-Mercury Pesticides .......................... 191 (*) Organomercury ............................................ Precipitation.

Organo-Tin Pesticides .................................. 192 (*) Organotin ...................................................... Precipitation.

o-Dichlorobenzene ........................................ 193 59401 Aryl Halide .................................................... Activated Carbon.

Oryzalin ......................................................... 194 104201 Sulfanilamide ................................................ Activated Carbon.

Oxamyl .......................................................... 195 103801 Carbamate .................................................... Hydrolysis.

Oxyfluorfen .................................................... 196 111601 Miscellaneous Organic ................................. Activated Carbon.

Bolstar ........................................................... 197 111501 Phosphorodithioate ...................................... Activated Carbon.

Sulprofos Oxon ............................................. 198 ........................ Phosphorothioate ......................................... Hydrolysis.

Santox (EPN) ................................................ 199 41801 Phosphorodithioate ...................................... Hydrolysis.

Fonofos ......................................................... 200 41701 Phosphorodithioate ...................................... Hydrolysis.

Propoxur ........................................................ 201 47802 Carbamate .................................................... Hydrolysis.

p-Dichlorobenzene ........................................ 202 61501 Aryl Halide .................................................... Activated Carbon.

Parathion Ethyl .............................................. 203 57501 Phosphorothioate ......................................... Hydrolysis.

Pendimethalin ............................................... 204 108501 Benzeneamine ............................................. Activated Carbon.

PCNB ............................................................ 205 56502 Aryl Halide .................................................... Activated Carbon.

PCP or Penta ................................................ 206 (*) Phenol .......................................................... Activated Carbon.

Perfluidone .................................................... 207 ........................ Sulfonamide ................................................. Activated Carbon.

Permethrin ..................................................... 208 109701 Pyrethrin ....................................................... Activated Carbon.

Phenmedipham ............................................. 209 98701 Carbamate .................................................... Hydrolysis.

Nemazine ...................................................... 210 64501 Heterocyclic .................................................. Activated Carbon.

Phorate .......................................................... 212 57201 Phosphorodithioate ...................................... Hydrolysis.

Phosalone ..................................................... 213 97701 Phosphorodithioate ...................................... Hydrolysis.

Phosphamidon .............................................. 214 18201 Phosphate .................................................... Hydrolysis.

Picloram ........................................................ 215 (*) Pyridine ........................................................ Activated Carbon.

Piperonyl Butoxide ........................................ 216 67501 Ester ............................................................. Activated Carbon.

PBED or WSCP (Busan 77) ......................... 217 69183 NR4 .............................................................. Activated Carbon.

Busan 85 or Arylane ..................................... 218 34803 Dithiocarbamate ........................................... Chemical Oxidation.

Busan 40 ....................................................... 219 102901 Dithiocarbamate ........................................... Chemical Oxidation.

KN Methyl ..................................................... 220 39002 Dithiocarbamate ........................................... Chemical Oxidation.

Metasol J26 ................................................... 221 101301 Miscellaneous Organic ................................. Activated Carbon.

Profenofos ..................................................... 222 111401 Phosphorothioate ......................................... Activated Carbon.

Prometon or Caparol .................................... 223 80804 s-Triazine ...................................................... Chemical Oxidation.

Prometryn ...................................................... 224 80805 s-Triazine ...................................................... Activated Carbon.

Propargite ...................................................... 225 97601 Miscellaneous Organic ................................. Activated Carbon.

Propazine ...................................................... 226 80808 s-Triazine ...................................................... Activated Carbon.

Propionic Acid ............................................... 227 77702 Alkyl Acid ...................................................... Activated Carbon.

Previcur N ..................................................... 228 119301 Carbamate .................................................... Hydrolysis.

Pyrethrin Coils ............................................... 229 69004 Pyrethrin ....................................................... Activated Carbon.

Pyrethrum I ................................................... 230 69001 Pyrethrin ....................................................... Hydrolysis.

Pyrethrum II .................................................. 231 69002 Pyrethrin ....................................................... Hydrolysis.

Pyrethrins ...................................................... 232 (*) Pyrethrin ....................................................... Hydrolysis.

Resmethrin .................................................... 233 (*) Pyrethrin ....................................................... Activated Carbon.

Fenchlorphos or Ronnel ............................... 234 58301 Phosphorothioate ......................................... Hydrolysis.

Mexide or Rotenone ..................................... 235 71003 Miscellaneous Organic ................................. Activated Carbon.

DEF ............................................................... 236 74801 Phosphorotrithioate ...................................... Activated Carbon.

Siduron or Tupersan ..................................... 237 35509 Urea .............................................................. Activated Carbon.

Silvex ............................................................. 238 (*) 2,4-D ............................................................. Activated Carbon.

Simazine ....................................................... 239 80807 s-Triazine ...................................................... Activated Carbon.

Sodium Bentazon .......................................... 240 103901 Heterocyclic .................................................. Chemical Oxidation.

Carbam-S or Sodam ..................................... 241 34804 Dithiocarbamate ........................................... Chemical Oxidation.

Sodium Fluoroacetate ................................... 242 75003 Acetamide .................................................... Activated Carbon.

Vapam or Metham Sodium ........................... 243 39003 Dithiocarbamate ........................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Sulfoxide ....................................................... 244 57101 Miscellaneous Organic ................................. Activated Carbon.

Cycloate or Ro-Neet ..................................... 245 41301 Thiocarbamate ............................................. Activated Carbon.

EPrecipitationC or Eptam ............................. 246 41401 Thiocarbamate ............................................. Activated Carbon.

Molinate ......................................................... 247 41402 Thiocarbamate ............................................. Activated Carbon.

Pebulate or Tillman ....................................... 248 41403 Thiocarbamate ............................................. Activated Carbon.

Vernolate or Vernam ..................................... 249 41404 Thiocarbamate ............................................. Activated Carbon.

HPrecipitationMS .......................................... 250 35604 Thiosulphonate ............................................. Activated Carbon.

Bensulide or Betesan .................................... 251 9801 Phosphorodithioate ...................................... Activated Carbon.

Tebuthiuron ................................................... 252 105501 Urea .............................................................. Activated Carbon.

Temephos ..................................................... 253 59001 Phosphorothioate ......................................... Hydrolysis.

Terbacil ......................................................... 254 12701 Uracil ............................................................ Activated Carbon.

Terbufos or Counter ...................................... 255 105001 Phosphorodithioate ...................................... Activated Carbon.

Terbuthylazine ............................................... 256 80814 s-Triazine ...................................................... Activated Carbon.

Terbutryn ....................................................... 257 80813 s-Triazine ...................................................... Activated Carbon.

Tetrachlorophenol ......................................... 258 63004 Phenol .......................................................... Activated Carbon.

Dazomet ........................................................ 259 35602 Heterocyclic .................................................. Chemical Oxidation.

Thiophanate Methyl ...................................... 260 102001 Carbamate .................................................... Hydrolysis.

Thiram ........................................................... 261 79801 Dithiocarbamate ........................................... Activated Carbon.

Toxaphene .................................................... 262 80501 Bicyclic ......................................................... Activated Carbon.

Merphos ........................................................ 263 74901 Phosphorotrithioate ...................................... Hydrolysis.

Trifluralin or Treflan ....................................... 264 36101 Toluidine ....................................................... Activated Carbon.

Warfarin ......................................................... 265 (*) Coumarin ...................................................... Activated Carbon.

Zinc MBT ....................................................... 266 51705 Organozinc ................................................... Precipitation.

Zineb ............................................................. 267 14506 Dithiocarbamate ........................................... Activated Carbon.

Ziram ............................................................. 268 34805 Dithiocarbamate ........................................... Activated Carbon.

Triallate ......................................................... 269 78802 Thiocarbamate ............................................. Activated Carbon.

Phenothrin ..................................................... 270 69005 Pyrethrin ....................................................... Activated Carbon.

Tetramethrin .................................................. 271 69003 Pyrethrin ....................................................... Activated Carbon.

Chloropropham ............................................. 272 18301 Carbamate .................................................... Hydrolysis.

Non-272 PAIs

CFC 11 .......................................................... ............ 13 Alkyl Halide .................................................. Activated Carbon.

CFC 12 .......................................................... ............ 14 Alkyl Halide .................................................. Activated Carbon.

Polyethylene .................................................. ............ 152 Polymer ........................................................ Activated Carbon.

Acrolein ......................................................... ............ 701 Alcohol .......................................................... Activated Carbon.

Dimethyl-m-dioxan-4-ol acetate .................... ............ 1001 Heterocyclic .................................................. Activated Carbon.

Dodecyl alcohol ............................................. ............ 1509 Alcohol .......................................................... Activated Carbon.

Tetradecyl alcohol ......................................... ............ 1510 Alcohol .......................................................... Activated Carbon.

Rosin amine D acetate ................................. ............ 4201 Alkyl Acid ...................................................... Activated Carbon.

Dihydroabietylamine acetate ......................... ............ 4213 Alkyl Acid ...................................................... Activated Carbon.

Amitrole ......................................................... ............ 4401 Heterocyclic .................................................. Activated Carbon.

Allyl isothiocyanate ....................................... ............ 4901 Thiocyanate .................................................. Activated Carbon.

AMS .............................................................. ............ 5501 Inorganic ....................................................... Pollution Prevention.

Calcium sulfate ............................................. ............ 5602 Inorganic ....................................................... Pollution Prevention.

Tartar emetic ................................................. ............ 6201 Inorganic ....................................................... Pollution Prevention.

Diphenylstibene 2-ethylhexanoate ................ ............ 6202 Aryl ............................................................... Activated Carbon.

Streptomycin ................................................. ............ 6306 Heterocyclic .................................................. Activated Carbon.

Oxytetracycline hydrochloride ....................... ............ 6308 Phthalamide ................................................. Activated Carbon.

Streptomycin sesquisulfate ........................... ............ 6310 Heterocyclic .................................................. Activated Carbon.

Neomycin sulfate .......................................... ............ 6313 Benzeneamine ............................................. Activated Carbon.

Antimycin A ................................................... ............ 6314 Heterocyclic .................................................. Activated Carbon.

Calcium oxytetracycline ................................ ............ 6321 Phthalamide ................................................. Activated Carbon.

Espesol 3A .................................................... ............ 6601 Phosphorothioate ......................................... Activated Carbon.

Arsenic acid .................................................. ............ 6801 Metallic ......................................................... Precipitation.

Arsenic acid anhydride ................................. ............ 6802 Metallic ......................................................... Precipitation.

Arsenous acid anhydride .............................. ............ 7001 Metallic ......................................................... Precipitation.

Copper oxychloride ....................................... ............ 8001 Metallic ......................................................... Precipitation.

Basic cupric sulfate ....................................... ............ 8101 Metallic ......................................................... Precipitation.

Basic copper III—zinc sulfate complex (Declare copper and............. 8102 Metallic ......................................................... Precipitation.

Bromophos .................................................... ............ 8706 Phosphorothioate ......................................... Activated Carbon.

Benzyl bromoacetate .................................... ............ 8710 Benzoic acid ................................................. Activated Carbon.

Benzoic acid .................................................. ............ 9101 Benzoic acid ................................................. Activated Carbon.

Benzyl diethyl ((2,6-xylylcarbamoyl)methyl)

ammonium benzoate.

............ 9106 NR4 .............................................................. Activated Carbon.

Benzyl alcohol ............................................... ............ 9502 Aryl ............................................................... Activated Carbon.

3–Chloro-p-toluidine hydrochloride ............... ............ 9901 Chloropropionanilide .................................... Activated Carbon.

Butoxyethoxy)ethyl thiocyanate .................... ............ 10002 Thiocyanate .................................................. Activated Carbon.

2-Naphthol ..................................................... ............ 10301 Phenol .......................................................... Activated Carbon.

Boric acid ...................................................... ............ 11001 Inorganic ....................................................... Pollution Prevention.

Barium metaborate ....................................... ............ 11101 Inorganic ....................................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Boron sodium oxide (B8Na2O13), tetrahydrate (12280–03–4)............. 11103 Inorganic ....................................................... Pollution Prevention.

Sodium metaborate (NaBO2) ....................... ............ 11104 Inorganic ....................................................... Pollution Prevention.

Boron sodium oxide (B8Na2O13) (12008–

41–2).

............ 11107 Inorganic ....................................................... Pollution Prevention.

Boron sodium oxide (B4Na2O7),

pentahydrate (12179–04–3).

............ 11110 Inorganic ....................................................... Pollution Prevention.

Boron sodium oxide (B4Na2O7) (1330–43–

4).

............ 11112 Inorganic ....................................................... Pollution Prevention.

Polybutene .................................................... ............ 11402 Polymer ........................................................ Activated Carbon.

Polyisobutylene ............................................. ............ 11403 Polymer ........................................................ Activated Carbon.

Butyl cellosolve ............................................. ............ 11501 Alcohol .......................................................... Activated Carbon.

Butoxypolypropylene glycol .......................... ............ 11901 Polymer ........................................................ Activated Carbon.

Neburon (ANSI) ............................................ ............ 12001 Chloropropionanilide .................................... Activated Carbon.

Methyltrimethylenedioxy)bis(4-methyl-1,3,2-

dioxaborinane).

............ 12401 Bicyclic ......................................................... Activated Carbon.

Oxybis(4,4,6-trimethyl-1,3,2-dioxaborinane) ............ 12402 Bicyclic ......................................................... Activated Carbon.

Cadmium chloride ......................................... ............ 12902 Metallic ......................................................... Precipitation.

Lead arsenate, basic .................................... ............ 13502 Metallic ......................................................... Precipitation.

Lead arsenate ............................................... ............ 13503 Metallic ......................................................... Precipitation.

Sodium arsenate ........................................... ............ 13505 Metallic ......................................................... Precipitation.

Sodium arsenite ............................................ ............ 13603 Metallic ......................................................... Precipitation.

Potassium bromide ....................................... ............ 13903 Inorganic ....................................................... Pollution Prevention.

Camphor ....................................................... ............ 15602 Bicyclic ......................................................... Activated Carbon.

Carbon disulfide ............................................ ............ 16401 Inorganic ....................................................... Pollution Prevention.

Carbon tetrachloride ..................................... ............ 16501 Alkyl Halide .................................................. Activated Carbon.

Barban (ANSI) ............................................... ............ 17601 Carbamate .................................................... Activated Carbon.

Chloro-2-propenyl)-3,5,7,triaza-1-azo

niatricyclo(3.3.1.1)sup.

............ 17902 Tricyclic ........................................................ Activated Carbon.

Chlormequat chloride .................................... ............ 18101 NR4 .............................................................. Activated Carbon.

Chloromethoxypropylmercuric acetate ......... ............ 18401 Metallic ......................................................... Precipitation.

Allidochlor ...................................................... ............ 19301 Acetanilide .................................................... Activated Carbon.

Chromic acid ................................................. ............ 21101 Metallic ......................................................... Precipitation.

Chromic oxide ............................................... ............ 21103 Metallic ......................................................... Precipitation.

Cresol (unspec) (Cresylic acid) ..................... ............ 22101 Phenol .......................................................... Activated Carbon.

Cresol ............................................................ ............ 22102 Phenol .......................................................... Activated Carbon.

Copper (metallic) ........................................... ............ 22501 Metallic ......................................................... Precipitation.

Copper ammonium carbonate ...................... ............ 22703 Metallic ......................................................... Precipitation.

Copper carbonate ......................................... ............ 22901 Metallic ......................................................... Precipitation.

Copper hydroxide .......................................... ............ 23401 Metallic ......................................................... Precipitation.

Copper chloride hydroxide (Cu2Cl(OH)3) ..... ............ 23501 Metallic ......................................................... Precipitation.

Copper oxychloride sulfate ........................... ............ 23503 Metallic ......................................................... Precipitation.

Copper sulfate ............................................... ............ 24401 Metallic ......................................................... Precipitation.

Copper (from triethanolamine complex) ....... ............ 24403 Metallic ......................................................... Precipitation.

Copper as metallic (in the form of chelates

of copper citrat).

............ 24405 Metallic ......................................................... Precipitation.

Copper as elemental from copper—ethylenediamine complex............. 24407 Metallic ......................................................... Precipitation.

Copper sulfate (anhydrous) .......................... ............ 24408 Metallic ......................................................... Precipitation.

Copper(I) oxide ............................................. ............ 25601 Metallic ......................................................... Precipitation.

Cuprous thiocyanate ..................................... ............ 25602 Metallic ......................................................... Precipitation.

Cyclohexane ................................................. ............ 25901 Aryl ............................................................... Activated Carbon.

Cyclohexanone ............................................. ............ 25902 Cyclic Ketone ............................................... Activated Carbon.

Dichlobenil ..................................................... ............ 27401 Chloropropionanilide .................................... Activated Carbon.

Diquat dibromide ........................................... ............ 32201 NR4 .............................................................. Activated Carbon.

Dimethrin (ANSI) ........................................... ............ 34101 Pyrethrin ....................................................... Activated Carbon.

Dicapthon ...................................................... ............ 34502 Phosphorothioate ......................................... Activated Carbon.

Ziram, cyclohexylamine complex .................. ............ 34806 Dithiocarbamate ........................................... Activated Carbon.

Butyl dimethyltrithioperoxycarbamate ........... ............ 34807 Dithiocarbamate ........................................... Activated Carbon.

Daminozide ................................................... ............ 35101 Acetanilide .................................................... Activated Carbon.

Bis(trichloromethyl) sulfone ........................... ............ 35601 Miscellaneous Organic ................................. Activated Carbon

Bis(bromoacetoxy)-2-butene ......................... ............ 35605 Alkyl Halide .................................................. Activated Carbon.

Dazomet, sodium salt ................................... ............ 35607 Heterocyclic .................................................. Activated Carbon.

Butonate ........................................................ ............ 35701 Phosphonate ................................................ Activated Carbon.

Trifluoro-4-nitro-m-cresol(**)=alpha,alpha,alpha-............. 6201 Phenol .......................................................... Activated Carbon.

Triethanolamine dinoseb (2-sec-Butyl-4,6-

dinitrophenol).

............ 37506 Phenol .......................................................... Activated Carbon.

Sodium 4,6-dinitro-o-cresylate ...................... ............ 37508 Phenol .......................................................... Activated Carbon.

Dinitrophenol ................................................. ............ 37509 Phenol .......................................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Alkanol* amine dinoseb (2-sec-butyl-4,6-

dinitrophenol) *(s.

............ 37511 Phenol .......................................................... Activated Carbon.

Sodium dinoseb (2-sec-Butyl-4,6-

dinitrophenol).

............ 37512 Phenol .......................................................... Activated Carbon.

Nitrilotriacetic acid, trisodium salt ................. ............ 39106 Acetamide .................................................... Activated Carbon.

Trisodium(2-hydroxyethyl)ethylene

diaminetriacetate.

............ 39109 Acetanilide .................................................... Activated Carbon.

Ammonium ethylenediaminetetraacetate ...... ............ 39117 Acetamide .................................................... Activated Carbon.

Pentasodium

diethylenetriaminepentaacetate.

............ 39120 Acetanilide .................................................... Activated Carbon.

Ethyl-1,3-hexanediol ..................................... ............ 41001 Alcohol .......................................................... Activated Carbon.

Ethylene ........................................................ ............ 41901 Miscellaneous Organic ................................. Pollution Prevention.

EDC ............................................................... ............ 42003 EDB .............................................................. Activated Carbon.

Methylene chloride ........................................ ............ 42004 Alkyl Halide .................................................. Activated Carbon.

Methoxyethanol ............................................. ............ 42202 Alcohol .......................................................... Activated Carbon.

Ethylene glycol .............................................. ............ 42203 Alcohol .......................................................... Activated Carbon.

Butylene glycol .............................................. ............ 42205 Alcohol .......................................................... Activated Carbon.

Ethylene oxide .............................................. ............ 42301 Miscellaneous Organic ................................. Pollution Prevention.

Copper(II) oxide ............................................ ............ 42401 Metallic ......................................................... Precipitation.

Cuprous and cupric oxide, mixed ................. ............ 42403 Metallic ......................................................... Precipitation.

Propylene oxide ............................................ ............ 42501 Miscellaneous Organic ................................. Pollution Prevention.

Formaldehyde ............................................... ............ 43001 Miscellaneous Organic ................................. Pollution Prevention.

Paraformaldehyde ......................................... ............ 43002 Polymer ........................................................ Activated Carbon.

Bis(2-butylene) tetrahydro-2-furaldehyde ..... ............ 43302 Tricyclic ........................................................ Activated Carbon.

Giberellic acid ............................................... ............ 43801 Tricyclic ........................................................ Activated Carbon.

Potassium gibberellate .................................. ............ 43802 Tricyclic ........................................................ Activated Carbon.

Glutaral .......................................................... ............ 43901 Alcohol .......................................................... Activated Carbon.

Copper citrate ............................................... ............ 44005 Metallic ......................................................... Precipitation.

Methyl nonyl ketone ...................................... ............ 44102 Miscellaneous Organic ................................. Activated Carbon.

Methyl-2-pentanone ...................................... ............ 44105 Miscellaneous Organic ................................. Activated Carbon.

Monosodium 2,2’-methylenebis (3,4,6-trichlorophenate)............. 44902 Chlorophene ................................................. Activated Carbon.

Potassium 2,2’-methylenebis (3,4,6-trichlorophenate)............. 44904 Chlorophene ................................................. Activated Carbon.

Hexachloroepoxyoctahydro-endo, exodimethanoaphthalene 85%............. 45001 Tricyclic ........................................................ Activated Carbon.

Chlorhexidine diacetate ................................ ............ 45502 Chloropropionanilide .................................... Activated Carbon.

Hydrocyanic acid ........................................... ............ 45801 Inorganic ....................................................... Activated Carbon.

Hydroxyethyl octyl sulfide ............................. ............ 46301 Alcohol .......................................................... Activated Carbon.

Heptadecenyl-2-(2-hydroxyethyl)-2-i

midazolinium chloride.

............ 46608 NR4 .............................................................. Activated Carbon.

Hydroxyethyl)-2-alkyl-2-imidazoline (as in

fatty acids of t.

............ 46609 NR4 .............................................................. Activated Carbon.

IBA ................................................................ ............ 46701 Bicyclic ......................................................... Activated Carbon.

Dihydropyrone ............................................... ............ 46801 Cyclic ketone ................................................ Activated Carbon.

Butoxypolypropoxypolyethoxyethanol-iodine

complex.

............ 46901 Polymer ........................................................ Activated Carbon.

Polyethoxypolypropoxyethanol-iodine complex............. 46904 Polymer ........................................................ Activated Carbon.

Use code no. 046904

(polyethoxypolypropoxy ethanol-iodine

complex).

............ 46909 Polymer ........................................................ Activated Carbon.

Iodine-potassium iodide complex ................. ............ 46917 Inorganic ....................................................... Pollution Prevention.

Alkyl-omega-hydroxypoly(oxyethylen e)-iodine complex *(100%............. 46921 Polymer ........................................................ Activated Carbon.

Lead acetate ................................................. ............ 48001 Metallic ......................................................... Precipitation.

Nickel sulfate hexahydrate ............................ ............ 50505 Metallic ......................................................... Precipitation.

Maleic hydrazide, diethanolamine salt .......... ............ 51502 Hydrazide ..................................................... Activated Carbon.

Maleic hydrazide, potassium salt .................. ............ 51503 Hydrazide ..................................................... Activated Carbon.

Sodium 2-mercaptobenzothiolate ................. ............ 51704 Heterocyclic .................................................. Activated Carbon.

Mercuric chloride ........................................... ............ 52001 Metallic ......................................................... Precipitation.

Mercurous chloride ....................................... ............ 52201 Metallic ......................................................... Precipitation.

Metaldehyde .................................................. ............ 53001 Miscellaneous Organic ................................. Activated Carbon.

Methylated naphthalenes .............................. ............ 54002 Aryl ............................................................... Activated Carbon.

Sodium 2,2’-methylenebis(4-chlorophenate) ............ 55005 Chlorophene ................................................. Activated Carbon.

Naphthalene .................................................. ............ 55801 Aryl ............................................................... Activated Carbon.

NAD ............................................................... ............ 56001 Benzoic Acid ................................................ Activated Carbon.

NAA (1–Naphthaleneacetic Acid) ................. ............ 56002 Benzoic Acid ................................................ Activated Carbon.

Potassium 1-naphthaleneacetate ................. ............ 56003 Benzoic Acid ................................................ Activated Carbon.

Ammonium 1-naphthaleneacetate ................ ............ 56004 Benzoic Acid ................................................ Activated Carbon.

Sodium 1-naphthaleneacetate ...................... ............ 56007 Benzoic Acid ................................................ 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Ethyl 1-naphthaleneacetate .......................... ............ 56008 Benzoic Acid ................................................ Activated Carbon.

Nitrophenol .................................................... ............ 56301 Phenol .......................................................... Activated Carbon.

Nicotine ......................................................... ............ 56702 Pyridine ........................................................ Activated Carbon.

Carbophenothion (ANSI) ............................... ............ 58102 Phosphorodithioate ...................................... Activated Carbon.

Sodium 5-chloro-2-(4-chloro-2-(3-(3,4-

dichlorophenyl)ureido).

............ 58802 Aryl Halide .................................................... Activated Carbon.

Monocrotophos ............................................. ............ 58901 Phosphate .................................................... Activated Carbon.

Chlordimeform ............................................... ............ 59701 Chloropropionanilide .................................... Activated Carbon.

Chlordimeform hydrochloride ........................ ............ 59702 Chloropropionanilide .................................... Activated Carbon.

Thiabendazole hypophosphite ...................... ............ 60102 Hydrazide ..................................................... Activated Carbon.

Hexachlorobenzene ...................................... ............ 61001 Lindane ......................................................... Activated Carbon.

Butyl paraben ................................................ ............ 61205 Phenol .......................................................... Activated Carbon.

Paraquat dichloride ....................................... ............ 61601 Pyridine ........................................................ Activated Carbon.

Chloro-4-phenylphenol .................................. ............ 62206 Chlorophene ................................................. Activated Carbon.

Chloro-2-phenylphenol .................................. ............ 62208 Chlorophene ................................................. Activated Carbon.

Chloro-2-biphenylol, potassium salt .............. ............ 62209 Chlorophene ................................................. Activated Carbon.

Chloro-2-phenylphenol .................................. ............ 62210 Chlorophene ................................................. Activated Carbon.

Chloro-2-phenylphenol, potassium salt ........ ............ 62211 Chlorophene ................................................. Activated Carbon.

Sodium phenate ............................................ ............ 64002 Phenol .......................................................... Activated Carbon.

Butylphenol, sodium salt ............................... ............ 64115 Phenol .......................................................... Activated Carbon.

Ammonium 2-phenylphenate ........................ ............ 64116 Phenol .......................................................... Activated Carbon.

Chloro-2-cyclopentylphenol ........................... ............ 64202 Chlorophene ................................................. Activated Carbon.

Bithionolate sodium ....................................... ............ 64203 Chlorophene ................................................. Activated Carbon.

Chloro-3-cresol .............................................. ............ 64206 Chlorophene ................................................. Activated Carbon.

Sodium 2,4,5-trichlorophenate ...................... ............ 64217 Chlorophene ................................................. Activated Carbon.

Aluminum phosphide .................................... ............ 66501 Inorganic ....................................................... Pollution Prevention.

Phosphorus ................................................... ............ 66502 Inorganic ....................................................... Pollution Prevention.

Magnesium phosphide .................................. ............ 66504 Inorganic ....................................................... Pollution Prevention.

1-(Alkyl*amino)-3-aminopropane* (Fatty

acids of coconut oil).

............ 67301 Iminamide ..................................................... Activated Carbon.

Alkyl* amino)-3-aminopropane *(53%C12,

19%C14, 8.5%C16, 7%C8.

............ 67305 Iminamide ..................................................... Activated Carbon.

Alkyl*amino)-3-aminopropane

benzoate*(fatty acids of coconut.

............ 67307 Iminamide ..................................................... Activated Carbon.

Alkyl* dipropoxyamine *(47% C12, 18%

C14, 10% C18, 9% C10, 8.

............ 67308 Iminamide ..................................................... Activated Carbon.

Alkyl*amino)-3-aminopropane

hydroxyacetate* (acids of coconut.

............ 67309 Iminamide ..................................................... Activated Carbon.

Alkyl* amino)-3-aminopropane *(42%C12,

26%C18, 15%C14, 8%C16.

............ 67310 Iminamide ..................................................... Activated Carbon.

Alkyl*amino)-3-aminopropane diacetate*

(fatty acids of coconut.

............ 67313 Iminamide ..................................................... Activated Carbon.

Octadecenyl-1,3-propanediamine

monogluconate.

............ 67316 Acetamide .................................................... Activated Carbon.

Alkyl* amine acetate *(5%C8, 7%C10,

54%C12, 19%C14, 8%C16,.

............ 67329 Iminamide ..................................................... Activated Carbon.

Pindone sodium salt ..................................... ............ 67704 Indandione .................................................... Activated Carbon.

Diphacinone, sodium salt .............................. ............ 67705 Indandione .................................................... Activated Carbon.

Isovaleryl-1,3-indandione, calcium salt ......... ............ 67706 Indandione .................................................... Activated Carbon.

Methyl isothiocyanate ................................... ............ 68103 Thiocyanate .................................................. Pollution Prevention.

Potassium dichromate .................................. ............ 68302 Inorganic ....................................................... Pollution Prevention.

Sodium chromate .......................................... ............ 68303 Inorganic ....................................................... Pollution Prevention.

Sodium dichromate ....................................... ............ 68304 Metallic ......................................................... Precipitation.

Alkenyl* dimethyl ethyl ammonium bromide

*(90%C18’, 10%C16’).

............ 69102 NR4 .............................................................. Activated Carbon.

Alkyl*-N-ethyl morpholinium ethyl sulfate

*(92%C18, 8%C16).

............ 69113 Heterocyclic .................................................. Activated Carbon.

Alkyl* isoquinolinium bromide *(50% C12,

30% C14, 17% C16, 3).

............ 69115 Quinolin ........................................................ Activated Carbon.

Alkyl* methyl isoquinolinium chloride

*(55%C14, 12%C12, 17%C).

............ 69116 Quinolin ........................................................ Activated Carbon.

Cetyl trimethyl ammonium bromide .............. ............ 69117 NR4 .............................................................. Activated Carbon.

Cetyl pyridinium bromide .............................. ............ 69118 Pyridine ........................................................ Activated Carbon.

Dodecyl dimethyl benzyl ammonium

naphthenate.

............ 69127 NR4 .............................................................. Activated Carbon.

Alkyl* dimethyl ethylbenzyl ammonium

cyclohexylsulfamate *(5).

............ 69135 NR4 .............................................................. Activated Carbon.

Alkyl*-N-ethyl morpholinium ethyl sulfate

*(66%C18, 25%C16).

............ 69147 Heterocyclic .................................................. Activated Carbon.

Alkyl* trimethyl ammonium bromide

*(95%C14, 5%C16).

............ 69153 NR4 .............................................................. 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Benzyl((dodecylcarbamoyl) methyl)di methyl

ammonium chloride.

............ 69159 NR4 .............................................................. Activated Carbon.

Cetyl pyridinium chloride ............................... ............ 69160 Pyridine ........................................................ Activated Carbon.

Alkyl* dimethyl ethyl ammonium bromide

*(85%C16, 15%C18).

............ 69186 NR4 .............................................................. Activated Carbon.

Cetyl-N-ethylmorpholinium ethyl sulfate ....... ............ 69187 Heterocyclic .................................................. Activated Carbon.

Use code no. 069102 (Alkenyl* Dimethyl

Ethyl Ammonium bromide).

............ 69198 NR4 .............................................................. Activated Carbon.

p-Aminopyridine ............................................ ............ 69201 Pyridine ........................................................ Activated Carbon.

Nitrapyrin (ANSI) ........................................... ............ 69203 Pyridine ........................................................ Activated Carbon.

Alkyl pyridines ............................................... ............ 69205 Pyridine ........................................................ Activated Carbon.

Pyrazon (ANSI) ............................................. ............ 69601 Heterocyclic .................................................. Activated Carbon.

Capsaicin (in oleoresin of capsicum) ............ ............ 70701 Phenol .......................................................... Activated Carbon.

Ryanodine ..................................................... ............ 71502 Tricyclic ........................................................ Activated Carbon.

Silver ............................................................. ............ 72501 Inorganic ....................................................... Pollution Prevention.

Silver chloride ............................................... ............ 72506 Inorganic ....................................................... Pollution Prevention.

Silver thiuronium acrylate co-polymer ........... ............ 72701 Polymer ........................................................ Activated Carbon.

Sodium chlorate ............................................ ............ 73301 Inorganic ....................................................... Pollution Prevention.

Calcium cyanide ............................................ ............ 74001 Inorganic ....................................................... Pollution Prevention.

Sodium cyanide ............................................ ............ 74002 Inorganic ....................................................... Pollution Prevention.

Cryolite .......................................................... ............ 75101 Inorganic ....................................................... Pollution Prevention.

Sodium fluoride ............................................. ............ 75202 Inorganic ....................................................... Pollution Prevention.

Ammonium fluosilicate .................................. ............ 75301 Inorganic ....................................................... Pollution Prevention.

Sodium fluosilicate ........................................ ............ 75306 Inorganic ....................................................... Pollution Prevention.

Potassium iodide ........................................... ............ 75701 Inorganic ....................................................... Pollution Prevention.

Potassium tetrathionate ................................ ............ 75903 Inorganic ....................................................... Pollution Prevention.

Potassium nitrate .......................................... ............ 76103 Inorganic ....................................................... Pollution Prevention.

Sodium nitrate ............................................... ............ 76104 Inorganic ....................................................... Pollution Prevention.

Sodium nitrite ................................................ ............ 76204 Inorganic ....................................................... Pollution Prevention.

Benzenesulfonamide, N-chloro-, sodium salt ............ 76501 Sulfonamide ................................................. Activated Carbon.

Salicyclic acid ................................................ ............ 76202 Benzoic Acid ................................................ Activated Carbon.

Ethoxyethyl p-methoxycinnamate ................. ............ 76604 Aryl ............................................................... Activated Carbon.

Calcium polysulfide ....................................... ............ 76702 Polymer ........................................................ Activated Carbon.

Strychnine ..................................................... ............ 76901 Tricyclic ........................................................ Activated Carbon.

Strychnine sulfate ......................................... ............ 76902 Tricyclic ........................................................ Activated Carbon.

Niclosamide ................................................... ............ 77401 Chlorobenzamide ......................................... Activated Carbon.

Dibromosalicylamilide ................................... ............ 77402 Chlorobenzamide ......................................... Activated Carbon.

Tribromsalan ................................................. ............ 77404 Chlorobenzamide ......................................... Activated Carbon.

Dibromosalicylanilide .................................... ............ 77405 Chlorobenzamide ......................................... Activated Carbon.

Chlorosalicylanilide ....................................... ............ 77406 Chlorobenzamide ......................................... Activated Carbon.

Sulfur ............................................................. ............ 77501 Inorganic ....................................................... Pollution Prevention.

Sulfaquinoxaline ............................................ ............ 77901 Sulfanilamide ................................................ Activated Carbon.

Sulfacetamide ............................................... ............ 77904 Sulfanilamide ................................................ Activated Carbon.

Sulfuryl fluoride ............................................. ............ 78003 Inorganic ....................................................... Pollution Prevention.

Sodium bisulfite ............................................. ............ 78201 Inorganic ....................................................... Pollution Prevention.

Tetrachloroethylene ...................................... ............ 78501 EDB .............................................................. Activated Carbon.

Ethoxylated isooctylphenol ........................... ............ 79004 Phenol .......................................................... Activated Carbon.

Lauric diethanolamide ................................... ............ 79018 Acetanilide .................................................... Activated Carbon.

Triethanolamine oleate ................................. ............ 79025 NR4 .............................................................. Activated Carbon.

Dioctyl sodium sulfosuccinate ....................... ............ 79027 Thiosulfonate ................................................ Activated Carbon.

Use code no. 069179 (alkyl*monoethanolamide)............. 79036 Miscellaneous Organic ................................. Activated Carbon.

Alkyl* diethanolamide *(70%C12, 30%C14) ............ 79045 Miscellaneous Organic ................................. Activated Carbon.

Tetradecyl formate ........................................ ............ 79069 Alkyl Acid ...................................................... Activated Carbon.

Polyoxyethylene sorbitol oleate-laurate ........ ............ 79075 Polymer ........................................................ Activated Carbon.

Polyethoxylated stearylamine ....................... ............ 79094 Polymer ........................................................ Activated Carbon.

Capric diethanolamide .................................. ............ 79099 Acetanilide .................................................... Activated Carbon.

Calcium thiosulfate ........................................ ............ 80101 Inorganic ....................................................... Pollution Prevention.

Ammonium thiosulfate .................................. ............ 80103 Inorganic ....................................................... Pollution Prevention.

Thymoxydichloroacetic acid .......................... ............ 80401 Benzoic Acid ................................................ Activated Carbon.

Thymol .......................................................... ............ 80402 Phenol .......................................................... Activated Carbon.

Sodium trichloroacetate ................................ ............ 81001 Alkyl Halide .................................................. Activated Carbon.

Trichloroacetic acid ....................................... ............ 81002 Alkyl Halide .................................................. Activated Carbon.

Hexahydro-1,3,5-tris(2-hydroxyethyl)-s-triazine............. 83301 s-Triazine ...................................................... Activated Carbon.

2-(Hydroxymethyl)-2-nitro-1,3-propanediol ... ............ 83902 Alcohol .......................................................... Activated Carbon.

Bomyl ............................................................ ............ 84201 Phosphate .................................................... Activated Carbon.

Turpentine ..................................................... ............ 84501 Miscellaneous Organic ................................. Activated Carbon.

Chloro-1-(2,5-dichlorophenyl)vinyl) O,Odiethyl phosphorothi............. 84901 Phosphorothioate ......................................... Activated Carbon.

Zinc chloride .................................................. ............ 87801 Metallic ......................................................... Precipitation.
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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Zinc 2-pyridinethiol-1-oxide ........................... ............ 88002 Metallic ......................................................... Precipitation.

Hydroxy-2-(1H)-pyridinethione, sodium salt ............ 88004 Pyridine ........................................................ Activated Carbon.

Omadine TBAO ............................................. ............ 88005 Pyridine ........................................................ Activated Carbon.

Zinc naphthenate .......................................... ............ 88301 Metallic ......................................................... Precipitation.

Zinc oxide ...................................................... ............ 88502 Metallic ......................................................... Precipitation.

Zinc phosphide (Zn3P2) ............................... ............ 88601 Metallic ......................................................... Precipitation.

Zinc phenol sulfonate .................................... ............ 89002 Metallic ......................................................... Precipitation.

Zinc sulfate, basic ......................................... ............ 89101 Metallic ......................................................... Precipitation.

Dimetilan ....................................................... ............ 90101 Carbamate .................................................... Activated Carbon.

Carboxin ........................................................ ............ 90201 Heterocyclic .................................................. Activated Carbon.

Oxycarboxin .................................................. ............ 90202 Heterocyclic .................................................. Activated Carbon.

Benzocaine ................................................... ............ 97001 Benzeneamine ............................................. Activated Carbon.

Piperalin ........................................................ ............ 97003 2,4-D ............................................................. Activated Carbon.

Tetracaine hydrochloride .............................. ............ 97005 Benzeneamine ............................................. Activated Carbon.

Formetanate hydrochloride ........................... ............ 97301 Toluamide ..................................................... Activated Carbon.

Azacosterol HCl ............................................ ............ 98101 Tricyclic ........................................................ Activated Carbon.

Use code no. 039502 (gentian violet) .......... ............ 98401 NR4 .............................................................. Activated Carbon.

Ammonium alum ........................................... ............ 98501 Inorganic ....................................................... Pollution Prevention.

Bismuth subgallate ........................................ ............ 98601 Metallic ......................................................... Precipitation.

Chlorflurenol, methyl ester ............................ ............ 98801 Aryl Halide .................................................... Activated Carbon.

Benzisothiazolin-3-one .................................. ............ 98901 Heterocyclic .................................................. Activated Carbon.

Methyl 2-benzimidazolecarbamate phosphate............. 99102 Carbamate .................................................... Activated Carbon.

Ethephon ....................................................... ............ 99801 Phosphate .................................................... Activated Carbon.

Pentanethiol .................................................. ............ 100701 Miscellaneous Organic ................................. Activated Carbon.

Nitrobutyl)morpholine .................................... ............ 100801 Heterocyclic .................................................. Activated Carbon.

Ethyl-2-nitrotrimethylene)dimorpholine ......... ............ 100802 Heterocyclic .................................................. Activated Carbon.

Tolyl diiodomethyl sulfone ............................ ............ 101002 Thiosulfonate ................................................ Activated Carbon.

Isobutyric acid ............................................... ............ 101502 Alkyl Acid ...................................................... Activated Carbon.

Dibromo-3-nitrilopropionamide ...................... ............ 101801 Acetamide .................................................... Activated Carbon.

Polyethoxylated oleylamine .......................... ............ 101901 Acetamide .................................................... Activated Carbon.

Dinitramine (ANSI) ........................................ ............ 102301 Nitrobenzoate ............................................... Activated Carbon.

Phenylethyl propionate ................................. ............ 102601 Phenylcrotonate ........................................... Activated Carbon.

Eugenol ......................................................... ............ 102701 Phenol .......................................................... Activated Carbon.

Tricosene ...................................................... ............ 103201 Miscellaneous Organic ................................. Activated Carbon.

Tricosene ...................................................... ............ 103202 Miscellaneous Organic ................................. Activated Carbon.

Sodium 1,4′,5′-trichloro-2′-(2,4,5-

trichlorophenoxy)methanes.

............ 104101 2,4-D ............................................................. Activated Carbon.

Hexahydro-1,3,5-tris(2-hydroxypropyl)-s-triazine............. 105601 s-Triazine ...................................................... Activated Carbon.

Methazole ...................................................... ............ 106001 Hydrazide ..................................................... Activated Carbon.

Difenzoquat methyl sulfate ........................... ............ 106401 Hydrazide ..................................................... Activated Carbon.

Butralin .......................................................... ............ 106501 Benzeneamine ............................................. Activated Carbon.

Fosamine ammonium ................................... ............ 106701 Carbamate .................................................... Activated Carbon.

Asulam .......................................................... ............ 106901 Carbamate .................................................... Activated Carbon.

Sodium asulam ............................................. ............ 106902 Carbamate .................................................... Activated Carbon.

Hydroxymethoxymethyl-1-aza-3,7-dioxabicyclo(3.3.0)octane............. 107001 Bicyclic ......................................................... Activated Carbon.

Hydroxymethyl-1-aza-3,7-dioxabicyclo(3.3.0)octane............. 107002 Bicyclic ......................................................... Activated Carbon.

Hydroxypoly(methyleneoxy)* methyl-1-aza3,7-dioxabicyclo(3.3)............. 107003 Bicyclic ......................................................... Activated Carbon.

Chloro-2-methyl-3(2H)-isothiazolone ............ ............ 107103 Heterocyclic .................................................. Activated Carbon.

Methyl-3(2H)-isothiazolone ........................... ............ 107104 Heterocyclic .................................................. Activated Carbon.

Trimethoxysilyl)propyl dimethyl octadecyl

ammonium chloride.

............ 107401 NR4 .............................................................. Activated Carbon.

Kinoprene ...................................................... ............ 107502 Ester ............................................................. Activated Carbon.

Triforine (ANSI) ............................................. ............ 107901 Hydrazide ..................................................... Activated Carbon.

Pirimiphos-methyl (ANSI) .............................. ............ 108102 Phosphorothioate ......................................... Activated Carbon.

Thiobencarb .................................................. ............ 108401 Thiocarbamate ............................................. Activated Carbon.

Ancymidol (ANSI) .......................................... ............ 108601 Pyrimidine ..................................................... Activated Carbon.

Oxadiazon (ANSI) ......................................... ............ 109001 Hydrazide ..................................................... Activated Carbon.

Mepiquat chloride .......................................... ............ 109101 NR4 .............................................................. Activated Carbon.

Fluvalinate ..................................................... ............ 109302 Toluamide ..................................................... Activated Carbon.

Chloro-N-(hydroxymethyl)acetamide ............ ............ 109501 Acetamide .................................................... Activated Carbon.

Dikegulac sodium .......................................... ............ 109601 Tricyclic ........................................................ Activated Carbon.

Iprodione (ANSI) ........................................... ............ 109801 Hydrazide ..................................................... Activated Carbon.

Phenylmethyl)-9-(tetrahydro-2H-pyran-2-yl)-

9H-purin-6-amine.

............ 110001 Pyrimidine ..................................................... Activated Carbon.

Prodiamine .................................................... ............ 110201 Benzeneamine ............................................. Activated Carbon.

Erioglaucine .................................................. ............ 110301 Benzeneamine ............................................. 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Tartrazine ...................................................... ............ 110302 Hydrazide ..................................................... Activated Carbon.

Dodemorph acetate ...................................... ............ 110401 Heterocyclic .................................................. Activated Carbon.

Ethofumesate (ANSI) .................................... ............ 110601 Bicyclic ......................................................... Activated Carbon.

Aldoxycarb (ANSI) ........................................ ............ 110801 Carbamate .................................................... Activated Carbon.

Diclofop-methyl ............................................. ............ 110902 Aryl Halide .................................................... Activated Carbon.

Bromo-1-(bromomethyl)-1,3-

propanediCarbon.itrile.

............ 111001 Isocyanate .................................................... Activated Carbon.

Poly (imino imidocarbonyliminoimidocarbonyliminohexamethylene)............. 111801 Polymer ........................................................ Activated Carbon.

Imazalil .......................................................... ............ 111901 Aryl Halide .................................................... Activated Carbon.

Bromadiolone ................................................ ............ 112001 Coumarin ...................................................... Activated Carbon.

Brodifacoum .................................................. ............ 112701 Coumarin ...................................................... Activated Carbon.

Bromethalin (ANSI) ....................................... ............ 112802 Aryl Amine .................................................... Activated Carbon.

Fluridone (ANSI) ........................................... ............ 112900 Aryl Halide .................................................... Activated Carbon.

Vinclozolin ..................................................... ............ 113201 Aryl Halide .................................................... Activated Carbon.

Metalaxyl ....................................................... ............ 113501 Benzeneamine ............................................. Activated Carbon.

Propetamphos (ANSI) ................................... ............ 113601 Phosphoroamidothioate ............................... Activated Carbon.

Methyl-1-naphthyl)maleimide ........................ ............ 113701 Phthalamide ................................................. Activated Carbon.

Hexadecadien-1-yl acetate ........................... ............ 114101 Ester ............................................................. Activated Carbon.

Hexadecadien-1-yl acetate ........................... ............ 114102 Ester ............................................................. Activated Carbon.

Epoxy-2-methyloctadecane ........................... ............ 114301 Heterocyclic .................................................. Activated Carbon.

Thiodicarb (ANSI) ......................................... ............ 114501 Thiocarbamate ............................................. Activated Carbon.

Dimethyloxazolidine (8CA & 9CA) ................ ............ 114801 Heterocyclic .................................................. Activated Carbon.

Trimethyloxazolidine ..................................... ............ 114802 Heterocyclic .................................................. Activated Carbon.

Hydroxyphenyl)oxoacetohydroximic chloride ............ 114901 Phenol .......................................................... Activated Carbon.

EEEBC .......................................................... ............ 115001 Carbamate .................................................... Activated Carbon.

MDM Hydantoin ............................................ ............ 115501 Hydrazide ..................................................... Activated Carbon.

DMDM Hydantoin .......................................... ............ 115502 Hydrazide ..................................................... Activated Carbon.

Triclopyr (ANSI) ............................................ ............ 116001 Pyridine ........................................................ Activated Carbon.

Triethylamine triclopyr ................................... ............ 116002 Pyridine ........................................................ Activated Carbon.

Butoxyethyl triclopyr ...................................... ............ 116004 Pyridine ........................................................ Activated Carbon.

Decenyl)dihydro-2(3H)-furanone ................... ............ 116501 Ester ............................................................. Activated Carbon.

Cytokinins ...................................................... ............ 116801 Toluidine ....................................................... Activated Carbon.

Benzyladenine ............................................... ............ 116901 Pyrimidine ..................................................... Activated Carbon.

Clopyralid, monoethanolamine salt ............... ............ 117401 Pyridine ........................................................ Activated Carbon.

Clopyralid (ANSI) .......................................... ............ 117403 Pyridine ........................................................ Activated Carbon.

Flucythrinate (ANSI) ...................................... ............ 118301 Pyrethrin ....................................................... Activated Carbon.

Hydramethylnon (ANSI) ................................ ............ 118401 Iminimide ...................................................... Activated Carbon.

Chlorsulfuron ................................................. ............ 118601 s-Triazine ...................................................... Activated Carbon.

Dimethipin ..................................................... ............ 118901 Heterocyclic .................................................. Activated Carbon.

Hexadecenal ................................................. ............ 120001 Miscellaneous Organic ................................. Activated Carbon.

Tetradecenal ................................................. ............ 120002 Miscellaneous Organic ................................. Activated Carbon.

Thidiazuron ................................................... ............ 120301 Urea .............................................................. Activated Carbon.

Metronidazole ................................................ ............ 120401 Hydrazide ..................................................... Activated Carbon.

Erythrosine B ................................................ ............ 120901 Tricyclic ........................................................ Activated Carbon.

Sethoxydim ................................................... ............ 121001 Cyclic Ketone ............................................... Activated Carbon.

Clethodim ...................................................... ............ 121011 Heterocyclic .................................................. Activated Carbon.

Cyromazine ................................................... ............ 121301 s-Triazine ...................................................... Activated Carbon.

Tralomethrin .................................................. ............ 121501 Pyrethrin ....................................................... Activated Carbon.

Azadirachtin .................................................. ............ 121701 Tricyclic ........................................................ Activated Carbon.

Tridecen-1-yl acetate .................................... ............ 121901 Ester ............................................................. Activated Carbon.

Tridecen-1-yl acetate .................................... ............ 121902 Ester ............................................................. Activated Carbon.

Sulfometuron methyl ..................................... ............ 122001 Pyrimidine ..................................................... Activated Carbon.

Metsulfuron-methyl ........................................ ............ 122010 s-Triazine ...................................................... Activated Carbon.

Propiconazole ............................................... ............ 122101 Aryl Halide .................................................... Activated Carbon.

Furanone, dihydro-5-pentyl ........................... ............ 122301 Cyclic Ketone ............................................... Activated Carbon.

Furanone, 5-heptyldihydro- ........................... ............ 122302 Cyclic Ketone ............................................... Activated Carbon.

Abamectin (ANSI) ......................................... ............ 122804 Tricyclic ........................................................ Activated Carbon.

Fluazifop-butyl ............................................... ............ 122805 Pyridine ........................................................ Activated Carbon.

Fluazifop-R-butyl ........................................... ............ 122809 Pyridine ........................................................ Activated Carbon.

Flumetralin .................................................... ............ 123001 Nitrobenzoate ............................................... Activated Carbon.

Fosetyl-Al ...................................................... ............ 123301 Phosphate .................................................... Activated Carbon.

Methanol, (((2-(dihydro-5-methyl-3(2H)-

oxazolyl)-1-methyl)et.

............ 123702 Heterocyclic .................................................. Activated Carbon.

Fomesafen .................................................... ............ 123802 Nitrobenzoate ............................................... Activated Carbon.

Tridiphane ..................................................... ............ 123901 Aryl Halide .................................................... Activated Carbon.

POE isooctadecanol ..................................... ............ 124601 Alcohol .......................................................... Activated Carbon.

Periplanone B ............................................... ............ 124801 Bicyclic ......................................................... Activated Carbon.

Fenoxycarb ................................................... ............ 125301 Carbamate .................................................... Activated Carbon.

Clomazone .................................................... ............ 125401 Aryl Halide .................................................... 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Clofentezine .................................................. ............ 125501 Aryl Halide .................................................... Activated Carbon.

Paclobutrazol ................................................ ............ 125601 Hydrazide ..................................................... Activated Carbon.

Flurprimidol ................................................... ............ 125701 Pyrimidine ..................................................... Activated Carbon.

Isoxaben ........................................................ ............ 125851 Heterocyclic .................................................. Activated Carbon.

Isazofos ......................................................... ............ 126901 Phosphorothioate ......................................... Activated Carbon.

Triadimenol ................................................... ............ 127201 Hydrazide ..................................................... Activated Carbon.

Fenpropathrin ................................................ ............ 127901 Pyrethrin ....................................................... Activated Carbon.

Sulfosate ....................................................... ............ 128501 Phosphorothioate ......................................... Activated Carbon.

Fenoxaprop-ethyl .......................................... ............ 128701 Heterocyclic .................................................. Activated Carbon.

Quizalofop-ethyl ............................................ ............ 128711 Phthalimide ................................................... Activated Carbon.

Bensulfuron-methyl ....................................... ............ 128820 Pyrimidine ..................................................... Activated Carbon.

Imazapyr ....................................................... ............ 128821 Hydrazide ..................................................... Activated Carbon.

Bifenthrin ....................................................... ............ 128825 Pyrethrin ....................................................... Activated Carbon.

Imazapyr, isopropylamine salt ...................... ............ 128829 Hydrazide ..................................................... Activated Carbon.

Sodium salt of 1-carboxymethyl-3,5,7-triaza1-azoniatricyclo............. 128832 s-Triazine ...................................................... Activated Carbon.

Linalool .......................................................... ............ 128838 Alcohol .......................................................... Activated Carbon.

Imazaquin, monoammonium salt .................. ............ 128840 Pyrimidine ..................................................... Activated Carbon.

Imazethabenz ................................................ ............ 128842 Pyrimidine ..................................................... Activated Carbon.

Thifensulfuron methyl .................................... ............ 128845 s-Triazine ...................................................... Activated Carbon.

Imazaquin ...................................................... ............ 128848 Pyrimidine ..................................................... Activated Carbon.

Myclobutanil (ANSI) ...................................... ............ 128857 s-Triazine ...................................................... Activated Carbon.

Zinc borate (3ZnO, 2B03, 3.5H2O; mw

434.66).

............ 128859 Metallic ......................................................... Precipitation.

Cyhalothrin .................................................... ............ 128867 Pyrethrin ....................................................... Activated Carbon.

Potassium cresylate ...................................... ............ 128870 Phenol .......................................................... Activated Carbon.

Triflumizole .................................................... ............ 128879 Toluidine ....................................................... Activated Carbon.

Tribenuron methyl ......................................... ............ 128887 s-Triazine ...................................................... Activated Carbon.

Cyhalothrin .................................................... ............ 128897 Pyrethrin ....................................................... Activated Carbon.

Chlorimuron-ethyl .......................................... ............ 128901 Pyrimidine ..................................................... Activated Carbon.

Dodecen-1-yl acetate .................................... ............ 128906 Ester ............................................................. Activated Carbon.

Dodecen-1-yl acetate .................................... ............ 128907 Ester ............................................................. Activated Carbon.

DDOL ............................................................ ............ 128908 Alcohol .......................................................... Activated Carbon.

Farnesol ........................................................ ............ 128910 Alcohol .......................................................... Activated Carbon.

Nerolidol ........................................................ ............ 128911 Alcohol .......................................................... Activated Carbon.

Tefluthrin ....................................................... ............ 128912 Pyrethrin ....................................................... Activated Carbon.

Bromoxynil heptanoate ................................. ............ 128920 Chloropropionanilide .................................... Activated Carbon.

Imazethapyr .................................................. ............ 128922 Pyrimidine ..................................................... Activated Carbon.

Imazethapyr, ammonium salt ........................ ............ 128923 Pyrimidine ..................................................... Activated Carbon.

Chitosan ........................................................ ............ 128930 Polymer ........................................................ Activated Carbon.

Sulfuric acid, monourea adduct .................... ............ 128961 Urea .............................................................. Activated Carbon.

Hydroprene ................................................... ............ 128966 Miscellaneous Organic ................................. Activated Carbon.

Triasulfuron ................................................... ............ 128969 Urea .............................................................. Activated Carbon.

Primisulfuron-methyl ..................................... ............ 128973 Urea .............................................................. Activated Carbon.

Uniconazole (ANSI) ...................................... ............ 128976 s-Triazine ...................................................... Activated Carbon.

Tetradecenyl acetate .................................... ............ 128980 Miscellaneous Organic ................................. Activated Carbon.

Chitin ............................................................. ............ 128991 Polymer ........................................................ Activated Carbon.

Sulfluramid .................................................... ............ 128992 Sulfonamide ................................................. Activated Carbon.

Dithiopyr (ANSI) ............................................ ............ 128994 Pyridine ........................................................ Activated Carbon.

Nicosulfuron .................................................. ............ 129008 Pyrimidine ..................................................... Activated Carbon.

Zinc ............................................................... ............ 129015 Metallic ......................................................... Precipitation.

Tetradecen-1-ol, acetate, (E)- ....................... ............ 129019 Alkyl Acid ...................................................... Activated Carbon.

Imazaquin, sodium salt ................................. ............ 129023 Pyrimidine ..................................................... Activated Carbon.

Dodecadien-1-ol ............................................ ............ 129028 Alcohol .......................................................... Activated Carbon.

Ionone ........................................................... ............ 129030 Miscellaneous Organic ................................. Activated Carbon.

Dicamba, aluminum salt ............................... ............ 129042 Aryl Halide .................................................... Activated Carbon.

Benzenemethanaminium, N-(2-((2,6-

dimethylphenyl)amino)-2-oxo.

............ 129045 NR4 .............................................................. Activated Carbon.

Fenoxaprop-p-Ethyl ....................................... ............ 129092 Tricyclic ........................................................ Activated Carbon.

Alkyl* bis(2-hydroxyethyl) ammonium acetate *(as in fatty ac............. 169103 NR4 .............................................................. Activated Carbon.

Alkenyl* dimethyl ammonium acetate *(75%

C18’, 25% C16’).

............ 169104 NR4 .............................................................. Activated Carbon.

Amines, N-coco alkyltrimethylenedi-,

adipates.

............ 169109 Iminamide ..................................................... Activated Carbon.

Dialkyl* dimethyl ammonium bentonite *(as

in fatty acids of.

............ 169111 NR4 .............................................................. Activated Carbon.

Alkyl* bis(2-hydroxyethyl) amine acetate

*(65% C18, 30% C16,.

............ 169125 Acetamide .................................................... Activated Carbon.

Dodecyl bis(hydroxy ethyl) dioctyl ammonium phosphate............. 169154 NR4 .............................................................. 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 1—Continued

PAI name 2 PAI

code 3

Shaughnessy

code 4 Structural group 5 Treatment technology

Dodecyl bis(2-hydroxyethyl) octyl hydrogen

ammonium phosphat.

............ 169155 NR4 .............................................................. Activated Carbon.

Didecyl-N-methyl-3-

(trimethoxysilyl)propanaminium chloride.

............ 169160 NR4 .............................................................. Activated Carbon.

Cholecalciferol ............................................... ............ 202901 Bicyclic ......................................................... Activated Carbon.

Use code no. 202901 (Vitamin D3) .............. ............ 208700 Bicyclic ......................................................... Activated Carbon.

Alkyl* N,N-bis(2-hydroxyethyl)amine *(100%

C8–C18).

............ 210900 NR4 .............................................................. Activated Carbon.

Bromo-2-nitropropane-1,3-diol ...................... ............ 216400 Alcohol .......................................................... Activated Carbon.

Use code no. 114601 (cyclohexyl-4, 5-

dichloro- 4-isothioazolin-3-one).

............ 229300 Heterocyclic .................................................. Activated Carbon.

Diethatyl ethyl ............................................... ............ 279500 Toluidine ....................................................... Activated Carbon.

Hydroprene (ANSI) ....................................... ............ 486300 Miscellaneous Organic ................................. Activated Carbon.

Zinc sulfate monohydrate ............................. ............ 527200 Metallic ......................................................... Precipitation

Geraniol ......................................................... ............ 597501 Alcohol .......................................................... Activated Carbon.

1The 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. 2The 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. 3The non-272 PAIs do not have PAI codes.

4All Shaughnessy codes are taken from the 1988 FATES database. Some of the 272 PAIs are not listed in the 1988 FATES database; therefore, no Shaughnessy codes are listed for these PAIs. 5Structural groups are based on an analysis of the chemical structures of each PAI.

6EPA 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.

[FR Doc. 96–25771 Filed 11–5–96; 8:45 am]

BILLING CODE 6560–50–P
213

APPENDIX B

PFPR Compliance Documentation

(Sample Forms)

Table A Identification of Wastewater Sources

Table B Evaluation of PFPR P2, Recycle, and Reuse Practices

Table C Summary of PFPR Compliance Decisions

Table D Identification of Wastewater Sources and Treatment

Technologies

Table E Summary and Evaluation of Test Results
Table A: Identification of Wastewater Sources

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

3.a.

changeover, or special cleaning of 

the interior of any formulating 

equipment, including formulation 

3.b.

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

include water, detergent, or 

3.c.

solvent. 3.d.

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: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

4. Packaging Equipment Interior 

Cleaning - routine cleaning, 

cleaning due to product 

changeover, or special cleaning 

4.a.

of the interior of any packaging 

equipment, including filling or 

storage tanks,pipes, and hoses. 

Cleaning materials may include

4.b.

water, detergent, or solvent. 4.c.

5. Repackaging Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

5.a.

changeover, or special cleaning of 

the interior of any repackaging 

equipment, including filling 

5.b.

or storage tanks, pipes, and hoses. 

Cleaning materials may include 

water, detergent, or solvent.

5.c.

5.d.

6. Aerosol (DOT) Leak Testing - 

water used to perform aerosol leak 

tests for Department of

6.a.

Transportation (DOT) 

requirements (when cans have 

burst).

6.b.

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 Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

7. Exterior Equipment Cleaning - 

cleaning of the exterior of any 

formulating, packaging, or 

repackaging equipment, including 

7.a.

tanks, pipes, hoses, conveyors, etc. 

Cleaning materials may include 

water, detergent, or solvent.

7.b.

7.c.

8. Exterior Wall Cleaning - 

cleaning of walls in the PFPR 

operations areas.

8.a.

8.b.

9. Floor Washing - cleaning of 

floors in the PFPR operations 

areas.

9.a.

9.b.

9.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

217
Table A: Identification of Wastewater Sources

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 Comments

10. Leaks and Spills - cleaning of 

leaks and/or spills which occur 

during PFPR operations.

10.a.

10.b.

11. Safety Equipment Cleaning - 

cleaning of personal protective 

equipment (e.g., gloves, splash 

aprons, boots, respirators)

11.a.

worn by employees in PFPR 

operations areas.

11.b.

12. Air Pollution Control 

Scrubbers - wet scrubbers used to 

control air emissions from PFPR 

operations.

12.a.

13. Laboratory Equipment 

Cleaning - Initial rinse of the retain 

sample container.

13.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

218
Table A: Identification of Wastewater Sources

Facility: Location:

Date: Prepared by:

Stream Type Source

Batch or 

Continuous

Volume 

Generated

Generation 

Frequency

Active 

Ingredients

Wastewater 

Matrix1

Wastewater 

Management2 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 

14.a.

production areas. 14.b.

15. Laboratory Equipment 

Cleaning - Water used to clean 

analytical equipment and 

glassware.

15.a.

16. Aerosol (DOT) Leak Testing - 

Water used in non-continuous 

overflow baths to perform aerosol 

leak tests for DOT requirements 

16.a.

when no cans have burst from the 

last water change out.

16.b.

17. Other Sources - other sources 

of waste not specifically mentioned 

(please specify).

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: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

1. Flow Reduction

Hoses used for rinsing have spray nozzles 

or other flow reduction devices.

1-1 1 Low-volume/high-pressure rinsing 

equipment is used for rinsing PFPR 

equipment interiors (specify type of 

equipment) when rinsing with water.

1-2 1

A floor scrubbing machine and/or mop 

and bucket is used to clean floors in 

liquid production areas.

1-3 3

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 2a

Facility performs preventive maintenance 

on valves and fittings and repairs leaks in 

a timely manner.

2-2 2b

Facility places drip pans under valves and 

fittings where hoses and lines are 

routinely connected and disconnected.

2-3 2c

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.

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.) 221
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices

Facility: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

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 7

Facility reuses drum/shipping container 

rinsate directly into product formulations.

5-2 7

Facility stores drum/shipping container 

rinsate for use in future formulations of 

same or compatible products.

5-3 1,7 Facility operates a staged drum rinsing 

station (countercurrent rinsing).

6. Drum Rinsing for Formulation of Solvent-Based Products

6-1 8

Facility reuses drum/shipping container 

rinsate directly into product formulations.

6-2 8

Facility stores drum/shipping container 

rinsate for use in future formulations of 

same or compatible products.

6-3 NA Facility uses base solvent to rinse drums.

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: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

7. Dedicated Equipment for Solvent- and Water-Based Products

Facility dedicates PFPR production 

equipment to water-based vs. solventbased products. Dedicated solvent-based 

7-1 9

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 10

Interior rinsate is stored for reuse in 

future formulations of the same or 

compatible product (note: does not 

include drum/shipping container rinsate).

8-2 4

Dry carrier material is stored and reused 

in future formulation of the same or 

compatible product or disposed of as 

solid waste.

8-3 4

Interiors of dry formulation equipment 

are cleaned with dry carrier prior to water 

rinse.

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.)

223
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices

Facility: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

9. Dedicated Process Equipment

Facility dedicates some portion of 

equipment to:

 i. Top production products

9-1 NA

 ii. Hard-to-clean products

 iii. Product families (attach definition 

of product families)

9-2 NA Facility sequences production on 

dedicated process equipment.

10. Inventory Management

10-1 NA

Facility has an inventory management 

system for raw material, product, and 

wastewater rinsate.

System includes one or more of the 

following:

10-2 NA

 i. Central storage and access controls.

 ii. Computerized inventory control.

 iii. Protection from precipitation.

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: Location:

Date: Prepared by: 

Table 8 

Listed 

Practice1 Practice

Does 

Facility 

Use this 

Practice?

Source Code 

from 

Table A

Extent of Use of this 

Practice Observed During 

Audit

Could Facility 

Implement this 

Practice in the 

Future?

Required 

Justification for 

Modification2 Comments

11. Training and Written Standard Operating Procedures

11-1 NA Facility provides personnel with P2 

training.

11-2 NA Facility has employee incentive programs 

encouraging P2.

11-3 NA Facility has documentation of P2 

practices and procedures.

12. Other P2 Practices/Equipment

12-1 NA

12-2 NA

12-3 NA

12-4 NA

12-5 NA

12-6 NA

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

Table 8 

Listed 

Practice

Modification 

Code Description

1-1 1 NARROW Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by 

flushing with water.

4-1 6 BREAKCAA Facility demonstrates that would not be able to meet Resource Conservation Recovery 

Act (RCRA) or Clean Air Act (CAA) requirements.

5-1 to 5-3 7 INERT 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).

6-1 to 6-3 8 REFURB Drums/shipping containers are going to a drum refurbisher/recycler who will only accept 

drums rinsed with water.

INERT 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).

7-1 9 RECOVERY Facility has installed and is using a solvent recovery system for the changeover rinsate 

(can also be used for other solvent recovery).

8-1 10 ALTDISPOSE PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise 

(i.e., send back to them or send for off-site disposal).

BIOGROWTH Facility has evidence of biological growth or product deterioration over a typical storage 

period (review facility data).

DETERGENT Facility has demonstrated that it must use a detergent to clean equipment.

DROP 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.

PACKAGE Facility only performs packaging of the pesticide product from which interior rinsate is 

generated.

SPACE Facility has space limitations, BUT must still store rinsates for most frequently produced 

products.

NA NA OTHER1

1

 Other practices must be approved by the permitting/control authority prior to discharge.

226
Table C: Summary of PFPR Compliance Decisions

Facility: Location:

Date: Prepared by:

Stream Type Source

Preliminary 

Compliance 

Decision Comments1

Wastewater 

to be 

Treated?

Final 

Compliance 

Decision

Approval Date 

for Nonlisted 

Modifications

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

3.a.

changeover, or special cleaning of 

the interior of any formulating 

equipment, including formulation 

3.b.

and/or storage tanks, pipes, and 

hoses. Cleaning materials may 

include water, detergent, or 

3.c.

solvent. 3.d.

1

 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: Location:

Date: Prepared by:

Stream Type Source

Preliminary 

Compliance 

Decision Comments1

Wastewater 

to be 

Treated?

Final 

Compliance 

Decision

Approval Date 

for Nonlisted 

Modifications

4. Packaging Equipment Interior 

Cleaning - routine cleaning, 

cleaning due to product 

changeover, or special cleaning 

4.a.

of the interior of any packaging 

equipment, including filling or 

storage tanks,pipes, and hoses. 

Cleaning materials may include 

4.b.

water, detergent, or solvent. 4.c.

5. Repackaging Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

5.a.

changeover, or special cleaning of 

the interior of any repackaging 

equipment, including filling 

5.b.

or storage tanks, pipes, and hoses. 

Cleaning materials may include 

water, detergent, or solvent.

5.c.

5.d.

6. Aerosol (DOT) Leak Testing - 

water used to perform aerosol leak 

tests for Department of

6.a.

Transportation (DOT) 

requirements (when cans have 

burst).

6.b.

1

 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: Location:

Date: Prepared by:

Stream Type Source

Preliminary 

Compliance 

Decision Comments1

Wastewater 

to be 

Treated?

Final 

Compliance 

Decision

Approval Date 

for Nonlisted 

Modifications

7. Exterior Equipment Cleaning - 

cleaning of the exterior of any 

formulating, packaging, or 

repackaging equipment, including 

7.a.

tanks, pipes, hoses, conveyors, etc. 

Cleaning materials may include 

water, detergent, or solvent.

7.b.

7.c.

8. Exterior Wall Cleaning - 

cleaning of walls in the PFPR 

operations areas.

8.a.

8.b.

9. Floor Washing - cleaning of 

floors in the PFPR operations 

areas.

9.a.

9.b.

9.c.

1

 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: Location:

Date: Prepared by:

Stream Type Source

Preliminary 

Compliance 

Decision Comments1

Wastewater 

to be 

Treated?

Final 

Compliance 

Decision

Approval Date 

for Nonlisted 

Modifications

10. Leaks and Spills - cleaning of 

leaks and/or spills which occur 

during PFPR operations.

10.a.

10.b.

11. Safety Equipment Cleaning - 

cleaning of personal protective 

equipment (e.g., gloves, splash 

aprons, boots, respirators)

11.a.

worn by employees in PFPR 

operations areas.

11.b.

12. Air Pollution Control 

Scrubbers - wet scrubbers used to 

control air emissions from PFPR 

operations.

12.a.

13. Laboratory Equipment 

Cleaning - Initial rinse of the retain 

sample container.

13.a.

1

 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: Location:

Date: Prepared by:

Stream Type Source

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 

14.a.

production areas. 14.b.

15. Laboratory Equipment 

Cleaning - Water used to clean 

analytical equipment and 

glassware.

15.a.

16. Aerosol (DOT) Leak Testing - 

Water used in non-continuous 

overflow baths to perform aerosol 

leak tests for DOT requirements 

16.a.

when no cans have burst from the 

last water change out.

16.b.

17. Other Sources - other sources 

of waste not specifically mentioned 

(please specify).

17.a.

17.b.

17.c.

1

 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

Table 8 

Listed 

Practice

Modification 

Code Description

1-1 1 NARROW Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by 

flushing with water.

4-1 6 BREAKCAA Facility demonstrates that would not be able to meet Resource Conservation Recovery 

Act (RCRA) or Clean Air Act (CAA) requirements.

5-1 to 5-3 7 INERT 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).

6-1 to 6-3 8 REFURB Drums/shipping containers are going to a drum refurbisher/recycler who will only accept 

drums rinsed with water.

INERT 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).

7-1 9 RECOVERY Facility has installed and is using a solvent recovery system for the changeover rinsate 

(can also be used for other solvent recovery).

8-1 10 ALTDISPOSE PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise 

(i.e., send back to them or send for off-site disposal).

BIOGROWTH Facility has evidence of biological growth or product deterioration over a typical storage 

period (review facility data).

DETERGENT Facility has demonstrated that it must use a detergent to clean equipment.

DROP 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.

PACKAGE Facility only performs packaging of the pesticide product from which interior rinsate is 

generated.

SPACE Facility has space limitations, BUT must still store rinsates for most frequently produced 

products.

NA NA OTHER1

1

 Other practices must be approved by the permitting/control authority prior to discharge.

232
Table D: Identification of Wastewater Sources and Treatment Technologies

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type1Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology2

Alternate 

Treatment 

Technology2

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 

Cleaning - water or solvent rinses 

of the containers used to ship raw 

material, finished products, and/or 

1.a.

waste products prior to reuse or 

disposal of the containers.

1.b.

2. Bulk Tank Rinsate - cleaning 

of the interior of any bulk storage 

tank containing raw materials, 

intermediate blends, or finished 

2.a.

products associated with PFPR 

operations.

2.b.

3. Formulating Equipment 3.a.

Interior Cleaning - routine 

cleaning, cleaning due to product 

changeover, or special cleaning of 3.b.

the interior of any formulating 

equipment, including formulation 

and/or storage tanks, pipes, and 3.c.

hoses. Cleaning materials may 

include water, detergent, or 

solvent. 3.d.

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_______________________________

233
Table D: Identification of Wastewater Sources and Treatment Technologies

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type1Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology2

Alternate 

Treatment 

Technology2

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

4. Packaging Equipment Interior 

Cleaning - routine cleaning, 

cleaning due to product 

changeover, or special cleaning 

4.a.

of the interior of any packaging 

equipment, including filling or 

storage tanks,pipes, and hoses. 

Cleaning materials may include

4.b.

water, detergent, or solvent. 4.c.

5. Repackaging Equipment 

Interior Cleaning - routine 

cleaning, cleaning due to product 

5.a.

changeover, or special cleaning of 

the interior of any repackaging 

equipment, including filling 

5.b.

or storage tanks, pipes, and hoses. 

Cleaning materials may include 

water, detergent, or solvent.

5.c.

*6. Aerosol (DOT) Leak Testing - 

water used to perform aerosol leak 

tests for Department of

6.a.

Transportation (DOT) requirements 

(when cans have burst).

6.b.

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_______________________________

234
Table D: Identification of Wastewater Sources and Treatment Technologies

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type1Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology2

Alternate 

Treatment 

Technology2

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

+7. Exterior Equipment Cleaning 

- cleaning of the exterior of any 

formulating, packaging, or 

repackaging equipment, including 

7.a.

tanks, pipes, hoses, conveyors, etc. 

Cleaning materials may include 

water, detergent, or solvent.

7.b.

7.c.

+8. Exterior Wall Cleaning - 

cleaning of walls in the PFPR 

operations areas.

8.a.

8.b.

9. Floor Washing - cleaning of 

floors in the PFPR operations 

areas.

9.a.

9.b.

9.c.

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_______________________________

235
Table D: Identification of Wastewater Sources and Treatment Technologies

Facility: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type1Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology2

Alternate 

Treatment 

Technology2

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

10. Leaks and Spills - cleaning of 

leaks and/or spills which occur 

during PFPR operations.

10.a.

10.b.

*11. Safety Equipment Cleaning - 

cleaning of personal protective 

equipment (e.g., gloves, splash 

aprons, boots, respirators)

11.a.

worn by employees in PFPR 

operations areas.

11.b.

*12. Air Pollution Control 

Scrubbers - wet scrubbers used to 

control air emissions from PFPR 

operations.

12.a.

*13. Laboratory Equipment 

Cleaning - Initial rinse of the 

retain sample container.

13.a.

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: Location:

Date: Prepared by:

 Potential Pollutants Wastewater Treatment Information

Stream Type1Source

Active 

Ingredients

Other 

Pollutants

Table 10 

Technology2

Alternate 

Treatment 

Technology2

Source for 

Alternative Technology

Characteristics That 

Hinder Treatment

1. Shipping Container/ Drum 1.a. 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 

14.a.

production areas. 14.b.

*15. Laboratory Equipment 

Cleaning - Water used to clean 

analytical equipment and 

glassware.

15.a.

*16. Aerosol (DOT) Leak Testing - 

Water used in non-continuous 

overflow baths to perform aerosol

16.a.

leak tests for DOT requirements 

when no cans have burst from the 

last water change out.

16.b.

17. Other Sources - other sources 

of waste not specifically mentioned 

(please specify).

17.a.

17.b.

17.c.

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_______________________________

237
Table E: Summary and Evaluation of Test Results

Facility: Location:

Date: Prepared by:

Insert your optimal treatment train and operating parameters in the space provided below:

Design and Operating Parameters Constituent Concentration Performance Measures

Other Other Other Other Effectively 

Primary Temperature . . . Influent Effluent Percent . Treated?

Technology Constituents pH (

oC) . . . (ug/L) (ug/L) Removal . (Y/N)

239
Table E: Summary and Evaluation of Test Results

Facility: Location:

Date: Prepared by:

Design and Operating Parameters Constituent Concentration Performance Measures

Other Other Other Other Effectively 

Primary Temperature . . . Influent Effluent Percent . Treated?

Technology Constituents pH (

oC) . . . (ug/L) (ug/L) Removal . (Y/N)

240
APPENDIX 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

243

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5

Dicofol 1 010501 115-32-2

Maleic Hydrazide 2 051501 123-33-1

EDB 3 042002 106-93-4

Vancide TH 4 082901 7779-27-3

1,3 Dichloropropene 5 029001 542-75-6

Thenarsazine Oxide 6 012601 58-36-6

Dowicil 75 7 017901 4080-31-3

Triadimefon 8 109901 43121-43-3

Hexachlorophene 9 044901 70-30-4

Tetrachlorophene 10 ................................................

Dichlorophene 11 055001 97-23-4

Dichlorvos 12 084001 62-73-7

Landrin 2 13 102402 2655-15-4

2,3,6 T, S&E or Fenac 14 082605 69462-13-1

2,4,5 T and 2,4,5 T, S&E 15 * *

2,4 D (2,4 D, S&E) 16 * *

2,4 DB, S&E 17 * *

Dyrene or Anilazine 18 080811 101-05-3

Dinocap 19 036001 39300-45-3

Dichloran or DCNA 20 031301 99-30-9

Busan 90 21 008707 2491-38-5

Mevinphos 22 015801 7786-34-7

Sulfallate 23 039001 95-06-7

Chlorfenvinphos 24 084101 470-90-6

Cyanazine or Bladex 25 100101 21725-46-2

Propachlor 26 019101 1918-16-7

MCPA, S&E 27 * *

Octhilinone 28 099901 26530-20-1

Pindone 29 067703 83-26-1

Dichlorprop, S&E 30 * *

MCPP, S&E or Mecoprop 31 * *

Thiabendazole 32 060101 148-79-8

Belclene 310 33 080815 22936-75-0

Chlorprop, S&E 34 021202 53404-22-1

Busan 72 or TCMTB 35 035603 21564-17-0

Chlorophacinone 37 067707 3691-35-8

Landrin 1 38 102401 2686-99-9

Pronamide 39 101701 23950-58-5

Methiocarb or Mesurol 40 100501 2032-65-7

Propanil 41 028201 709-98-8

Polyphase 42 107801 55406-53-6

Coumafuryl or Fumarin 43 086001 117-52-2

DNOC 44 037507 534-52-1

Metribuzin 45 101101 21087-64-9

CPA, S&E 46 * *
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

244

MCPB, S&E 47 019202 6062-26-6

Aminocarb 48 044401 2032-59-9

Etridiazole 49 084701 2593-15-9

Ethoxyquin 50 055501 91-53-2

Acephate or Orthene 52 103301 30560-19-1

Acifluorfen 53 114402 62476-59-9

Alachlor 54 090501 15972-60-8

Aldicarb 55 098301 116-06-3

Allethrin 57 * *

Ametryn 58 080801 834-12-8

Amitraz 59 106201 33089-61-1

Atrazine 60 080803 1912-24-9

Bendiocarb 61 105201 22781-23-3

Benomyl 62 099101 17804-35-2

BHC 63 008901 608-73-1

Benzyl Benzoate 64 009501 120-51-4

Lethane 60 65 010101 301-11-1

Bifenox 66 104301 42576-02-3

Biphenyl 67 017002 92-52-4

Bromacil (Lithium Salt) 68 012302 53404-19-6

Bromoxynil 69 * *

Butachlor 70 112301 23184-66-9

Giv gard 71 101401 7166-19-0

Cacodylic Acid 72 * *

Captafol 73 081701 2939-80-2

Captan 74 081301 133-06-2

Carbaryl 75 056801 63-25-2

Carbofuran 76 090601 1563-66-2

Carbosulfan 77 090602 55285-14-8

Chloramben 78 * *

Chlordane 79 058201 57-74-9

Chloroneb 80 027301 2675-77-6

Chloropicrin 81 081501 76-06-2

Chlorothalonil 82 081901 1897-45-6

Chloroxuron 83 025501 1982-47-4

Stirofos 84 083701 961-11-5

Chlorpyrifos Methyl 85 059102 5598-13-0

Chlorpyrifos 86 059101 2921-88-2

Mancozeb 87 014504 8018-01-7

Bioquin (Copper) 88 024002 10380-28-6

Copper EDTA 89 039105 12276-01-6

Pydrin or Fenvalerate 90 109301 51630-58-1

Cycloheximide 91 043401 66-81-9

Dalapon 92 * *

Dienochlor 93 027501 2227-17-0

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

245

Demeton 94 057601 8065-48-3

Desmedipham 95 104801 13684-56-5

Amobam 96 014502 3566-10-7

DBCP 97 011301 96-12-8

Dicamba 98 * *

Dichlone 99 029601 117-80-6

Thiophanate Ethyl 100 103401 23564-06-9

Perthane 101 032101 72-56-0

EXD 102 086501 502-55-6

Diazinon 103 057801 333-41-5

Diflubenzuron 104 108201 35367-38-5

Dimethoate 106 035001 60-51-5

Parathion Methyl 107 053501 298-00-0

Dicrotophos 108 035201 141-66-2

Crotoxyphos 109 058801 7700-17-6

DCPA 110 078701 1861-32-1

Trichlorofon 111 057901 52-68-6

Dinoseb 112 037505 88-85-7

Dioxathion 113 037801 78-34-2

Diphacinone 114 067701 82-66-6

Diphenamide 115 036601 957-51-7

Diphenylamine 116 038501 122-39-4

MGK 326 117 047201 136-45-8

Nabonate 118 063301 138-93-2

Diuron 119 035505 330-54-1

Metasol DGH 120 044303 13590-97-1

Dodine 121 044301 2439-10-3

Endosulfan 122 079401 115-29-7

Endothall (Endothall S&E) 123 * *

Endrin 124 041601 72-20-8

Ethalfluralin 125 113101 55283-68-6

Ethion 126 058401 563-12-2

Ethoprop 127 041101 13194-48-4

Fenamiphos 128 100601 22224-92-6

Chlorobenzilate 129 028801 510-15-6

Butylate 130 041405 2008-41-5

Famphur 131 059901 52-85-7

Fenarimol 132 206600 60168-88-9

Fenthion or Baytex 133 053301 55-38-9

Ferbam 134 034801 14484-64-1

Fluometuron 135 035503 2164-17-2

Fluoroacetamide 136 075002 640-19-7

Folpet 137 081601 133-07-3

Glyphosate (Glyphosate S&E) 138 * *

Glyphosine 139 103602 2439-99-8

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

246

Heptachlor 140 044801 76-44-8

Cycloprate 141 115601 54460-46-7

Hexazinone 142 107201 51235-04-2

Isofenphos 143 109401 25311-71-1

Isopropalin 144 100201 33820-53-0

Propham 145 047601 122-42-9

Karabutilate 146 097401 4849-32-5

Lindane 147 009001 58-89-9

Linuron 148 035506 330-55-2

Malachite Green 149 039504 569-64-2

Malathion 150 057701 121-75-5

Maneb 151 014505 12427-38-2

Manam 152 034802 15339-36-3

Mefluidide 153 114002 53780-36-2

Methamidophos 154 101201 10265-92-6

Methidathion 155 100301 950-37-8

Methomyl 156 090301 16752-77-5

Methoprene 157 * *

Methoxychlor 158 034001 72-43-5

Methyl Bromide 160 053201 74-83-9

Monosodium Methyl Arsenate 161 * *

Nalco D 2303 163 068102 6317-18-6

Quinomethionate 164 054101 2439-01-2

Metolachlor 165 108801 51218-45-2

Mexacarbate 166 044201 315-18-4

Metiram 167 014601 9006-42-2

Monuron TCA 168 035502 140-41-0

Monuron 169 035501 150-68-5

Napropamide 170 103001 15299-99-7

Deet 171 080301 134-62-3

Nabam 172 014503 142-59-6

Naled 173 034401 300-76-5

Norea 174 035801 18530-56-8

Norflurazon 175 105801 27314-13-2

Naptalam or Neptalam 176 030703 132-67-2

MGK 264 177 057001 113-48-4

Benfluralin 178 084301 1861-40-1

Sulfotepp 179 079501 3689-24-5

Aspon 180 079101 3244-90-4

Coumaphos 181 036501 56-72-4

Fensulfothion 182 032701 115-90-2

Disulfoton 183 032501 298-04-4

Fenitrothion 184 105901 122-14-5

Phosmet 185 059201 732-11-6

Azinphos Methyl (Guthion) 186 058001 86-50-0

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

247

Oxydemeton Methyl 187 058702 301-12-2

Organo Arsenic Pesticides 188 * *

Organo Cadmium Pesticides 189 * *

Organo Copper Pesticides 190 * *

Organo Mercury Pesticides 191 * *

Organo Tin Pesticides 192 * *

o Dichlorobenzene 193 059401 95-50-1

Oryzalin 194 104201 19044-88-3

Oxamyl 195 103801 23135-22-0

Oxyfluorfen 196 111601 42874-03-3

Bolstar 197 111501 35400-43-2

Sulprofos Oxon 198 219900 38527-90-1

Santox (EPN) 199 041801 2104-64-5

Fonofos 200 041701 944-22-9

Propoxur 201 047802 114-26-1

p Dichlorobenzene 202 061501 106-46-7

Parathion Ethyl 203 057501 56-38-2

Pendimethalin 204 108501 40487-42-1

PCNB 205 056502 82-68-8

PCP or Penta 206 * 87-86-5

Perfluidone 207 108001 37924-13-3

Permethrin 208 109701 52645-53-1

Phenmedipham 209 098701 13684-63-4

Nemazine 210 064501 92-84-2

Phorate 212 057201 298-02-2

Phosalone 213 097701 2310-17-0

Phosphamidon 214 018201 13171-21-6

Picloram 215 * *

Piperonyl Butoxide 216 067501 51-03-6

PBED or WSCP (Busan 77) 217 069183 31512-74-0

Busan 85 or Arylane 218 034803 128-03-0

Busan 40 219 102901 51026-28-9

KN Methyl 220 039002 137-41-7

Metasol J26 221 101301 53404-62-9

Profenofos 222 111401 41198-08-7

Prometon or Caparol 223 080804 1610-18-0

Prometryn 224 080805 7287-19-6

Propargite 225 097601 2312-35-8

Propazine 226 080808 139-40-2

Propionic Acid 227 077702 79-09-4

Previcur N 228 119301 24579-73-5

Pyrethrin Coils 229 069004 ...........

Pyrethrum I 230 069001 8003-34-7

Pyrethrum II 231 069002 8003-34-7

Pyrethrins 232 * *

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

248

Resmethrin 233 * *

Fenchlorphos or Ronnel 234 058301 299-84-3

Mexide or Rotenone 235 071003 83-79-4

DEF 236 074801 78-48-8

Siduron or Tupersan 237 035509 1982-49-6

Silvex 238 * *

Simazine 239 080807 122-34-9

Sodium Bentazon 240 103901 50723-80-3

Carbam S or Sodam 241 034804 128-04-1

Sodium Fluoroacetate 242 075003 62-74-8

Vapam or Metham Sodium 243 039003 137-42-8

Sulfoxide 244 057101 120-62-7

Cycloate or Ro Neet 245 041301 1134-23-2

EPrecipitationC or Eptam 246 041401 759-94-4

Molinate 247 041402 2212-67-1

Pebulate or Tillman 248 041403 1114-71-2

Vernolate or Vernam 249 041404 1929-77-7

HPrecipitationMS 250 035604 29803-57-4

Bensulide or Betesan 251 009801 741-58-2

Tebuthiuron 252 105501 34014-18-1

Temephos 253 059001 3383-96-8

Terbacil 254 012701 5902-51-2

Terbufos or Counter 255 105001 13071-79-9

Terbuthylazine 256 080814 5915-41-3

Terbutryn 257 080813 886-50-0

Tetrachlorophenol 258 063004 25167-83-3

Dazomet 259 035602 533-74-4

Thiophanate Methyl 260 102001 23564-05-8

Thiram 261 079801 137-26-8

Toxaphene 262 080501 8001-35-2

Merphos 263 074901 150-50-5

Trifluralin or Treflan 264 036101 1582-09-8

Warfarin 265 * *

Zinc MBT 266 051705 155-04-4

Zineb 267 014506 12122-67-7

Ziram 268 034805 137-30-4

Triallate 269 078802 2303-17-5

Phenothrin 270 069005 26002-80-2

Tetramethrin 271 069003 7696-12-0

Chloropropham 272 018301 101-21-3

Non-272 PAIs

CFC 11 .................... 000013 75-69-4

CFC 12 .................... 000014 75-71-8

Polyethylene .................... 000152 9002-88-4

Acrolein .................... 000701 107-02-8

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

249

Dimethyl m dioxan 4 ol aceta .................... 001001 828-00-2

Dodecyl alcohol .................... 001509 112-53-8

Tetradecyl alcohol .................... 001510 112-72-1

Rosin amine D acetate .................... 004201 2026-24-6

Dihydroabietylamine acetate .................... 004213 53466-80-1

Amitrole .................... 004401 61-82-5

Allyl isothiocyanate .................... 004901 57-06-7

AMS .................... 005501 7773-06-0

Calcium sulfate .................... 005602 7778-18-9

Tartar emetic .................... 006201 28300-74-5

Diphenylstibene 2 ethylhexan .................... 006202 5035-58-5

Streptomycin .................... 006306 57-92-1

Oxytetracycline hydrochlorid .................... 006308 2058-46-0

Streptomycin sesquisulfate .................... 006310 3810-74-0

Neomycin sulfate .................... 006313 1405-10-3

Antimycin A .................... 006314 1397-94-0

Calcium oxytetracycline .................... 006321 7179-50-2

Espesol 3A .................... 006601 68602-80-2

Arsenic acid .................... 006801 7778-39-4

Arsenic acid anhydride .................... 006802 1303-28-2

Arsenous acid anhydride .................... 007001 1327-53-3

Copper oxychloride .................... 008001 1332-40-7

Basic cupric sulfate .................... 008101 *

Basic copper III zinc sulf .................... 008102 55072-57-6

Bromophos .................... 008706 2104-96-3

Benzyl bromoacetate .................... 008710 5437-45-6

Benzoic acid .................... 009101 65-85-0

Benzyl diethyl ((2,6 xylylca .................... 009106 3734-33-6

Benzyl alcohol .................... 009502 100-51-6

3 Chloro p toluidine hydroch .................... 009901 7745-89-3

Butoxyethoxy)ethyl thiocyana .................... 010002 112-56-1

2 Naphthol .................... 010301 135-19-3

Boric acid .................... 011001 10043-35-3

Barium metaborate .................... 011101 13701-59-2

Boron sodium oxide (B8Na2O13 .................... 011103 12280-03-4

Sodium metaborate (NaBO2) .................... 011104 7775-19-1

Boron sodium oxide (B8Na2O13 .................... 011107 12008-41-2

Boron sodium oxide (B4Na2O7) .................... 011110 12179-04-3

Boron sodium oxide (B4Na2O7) .................... 011112 1330-43-4

Polybutene .................... 011402 9003-29-6

Polyisobutylene .................... 011403 9003-27-4

Butyl cellosolve .................... 011501 111-76-2

Butoxypolypropylene glycol .................... 011901 9003-13-8

Neburon (ANSI) .................... 012001 555-37-3

Methyltrimethylenedioxy)bis( .................... 012401 2665-13-6

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

250

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5

Oxybis(4,4,6 trimethyl-1,3,2 .................... 012402 14697-50-8

Cadmium chloride .................... 012902 10108-64-2

Lead arsenate, basic .................... 013502 1327-31-7

Lead arsenate .................... 013503 7784-40-9

Sodium arsenate .................... 013505 13464-38-5

Sodium arsenite .................... 013603 7784-46-5

Potassium bromide .................... 013903 7758-02-3

Camphor .................... 015602 76-22-2

Carbon disulfide .................... 016401 75-15-0

Carbon tetrachloride .................... 016501 56-23-5

Barban (ANSI) .................... 017601 101-27-9

Chloro 2 propenyl) 3,5,7,tri .................... 017902 51229-78-8

Chlormequat chloride .................... 018101 999-81-5

Chloromethoxypropylmercuric .................... 018401 1319-86-4

Allidochlor .................... 019301 93-71-0

Chromic acid .................... 021101 7738-94-5

Chromic oxide .................... 021103 1308-38-9

Cresol (unspec) (Cresylic ac .................... 022101 1319-77-3

Cresol .................... 022102 108-39-4

Copper (metallic) .................... 022501 7440-50-8

Copper ammonium carbonate .................... 022703 33113-08-5

Copper carbonate .................... 022901 12069-69-1

Copper hydroxide .................... 023401 20427-59-2

Copper chloride hydroxide .................... 023501 1332-65-6

Copper oxychloride sulfate .................... 023503 8012-69-9

Copper sulfate .................... 024401 7758-99-8

Copper (from triethanolamine .................... 024403 82027-59-6

Copper as metallic (in the f .................... 024405 *

Copper as elemental from cop .................... 024407 13426-91-0

Copper sulfate (anhydrous) .................... 024408 7758-98-7

Copper(I) oxide .................... 025601 1317-39-1

Cuprous thiocyanate .................... 025602 1111-67-7

Cyclohexane .................... 025901 110-82-7

Cyclohexanone .................... 025902 108-94-1

Dichlobenil .................... 027401 1194-65-6

Diquat dibromide .................... 032201 85-00-7

Dimethrin (ANSI) .................... 034101 70-38-2

Dicapthon .................... 034502 2463-84-5

Ziram, cyclohexylamine compl .................... 034806 16509-79-8

Butyl dimethyltrithioperoxyc .................... 034807 3304-97-0

Daminozide .................... 035101 1596-84-5

Bis(trichloromethyl) sulfone .................... 035601 3064-70-8

Bis(bromoacetoxy) 2 butene .................... 035605 20679-58-7

Dazomet, sodium salt .................... 035607 53404-60-7

Butonate .................... 035701 126-22-7
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

251

Trifluoro 4 nitro m cresol ( .................... 036201 88-30-2

Triethanolamine dinoseb (2 s .................... 037506 6420-47-9

Sodium 4,6 dinitro o cresyla .................... 037508 2312-76-7

Dinitrophenol .................... 037509 51-28-5

Alkanol* amine dinoseb (2 se .................... 037511 8048-12-2

Sodium dinoseb (2 sec Butyl .................... 037512 35040-03-0

Nitrilotriacetic acid, triso .................... 039106 5064-31-3

Trisodium(2 hydroxyethyl)eth .................... 039109 139-89-9

Ammonium ethylenediaminetetr .................... 039117 7379-26-2

Pentasodium diethylenetriami .................... 039120 140-01-2

Ethyl 1,3 hexanediol .................... 041001 94-96-2

Ethylene .................... 041901 74-85-1

EDC .................... 042003 107-06-2

Methylene chloride .................... 042004 75-09-2

Methoxyethanol .................... 042202 109-86-4

Ethylene glycol .................... 042203 107-21-1

Butylene glycol .................... 042205 107-88-0

Ethylene oxide .................... 042301 75-21-8

Copper(II) oxide .................... 042401 1317-38-0

Cuprous and cupric oxide, mi .................... 042403 82010-82-0

Propylene oxide .................... 042501 75-56-9

Formaldehyde .................... 043001 50-00-0

Paraformaldehyde .................... 043002 30525-89-4

Bis(2 butylene)tetrahydro-2 .................... 043302 126-15-8

Gibberellic acid .................... 043801 77-06-5

Potassium gibberellate .................... 043802 125-67-7

Glutaral .................... 043901 111-30-8

Copper citrate .................... 044005 10402-15-0

Methyl nonyl ketone .................... 044102 112-12-9

Methyl 2 pentanone .................... 044105 108-10-1

Monosodium 2,2' methylenebis .................... 044902 5736-15-2

Potassium 2,2' methylenebis( .................... 044904 67923-62-0

Hexachloroepoxyoctahydro end .................... 045001 60-57-1

Chlorhexidine diacetate .................... 045502 56-95-1

Hydrocyanic acid .................... 045801 74-90-8

Hydroxyethyl octyl sulfide .................... 046301 3547-33-9

Heptadecenyl 2 (2 hydroxyeth .................... 046608 53466-82-3

Hydroxyethyl) 2 alkyl 2 imid .................... 046609 61791-39-7

IBA .................... 046701 133-32-4

Dihydropyrone .................... 046801 532-34-3

Butoxypolypropoxypolyethoxye .................... 046901 68610-00-4

Polyethoxypolypropoxyethanol .................... 046904 26617-87-8

Use code no. 046904 (polyeth .................... 046909 26617-87-8

Iodine potassium iodide co .................... 046917 12298-68-9

Alkyl omega hydroxypoly(oxye .................... 046921 68439-47-4

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

252

Lead acetate .................... 048001 301-04-2

Nickel sulfate hexahydrate .................... 050505 10101-97-0

Maleic hydrazide, diethanola .................... 051502 5716-15-4

Maleic hydrazide, potassium .................... 051503 28382-15-2

Sodium 2 mercaptobenzothiola .................... 051704 2492-26-4

Mercuric chloride .................... 052001 7487-94-7

Mercurous chloride .................... 052201 10112-91-1

Metaldehyde .................... 053001 108-62-3

Methylated naphthalenes .................... 054002 1321-94-4

Sodium 2,2' methylenebis(4 c .................... 055005 10254-48-5

Naphthalene .................... 055801 91-20-3

NAD .................... 056001 86-86-2

NAA (1 Naphthaleneacetic Aci .................... 056002 86-87-3

Potassium 1 naphthaleneaceta .................... 056003 15165-79-4

Ammonium 1 naphthaleneacetat .................... 056004 25545-89-5

Sodium 1 naphthaleneacetate .................... 056007 61-31-4

Ethyl 1 naphthaleneacetate .................... 056008 2122-70-5

Nitrophenol .................... 056301 100-02-7

Nicotine .................... 056702 54-11-5

Carbophenothion (ANSI) .................... 058102 786-19-6

Sodium 5 chloro 2 (4 chloro .................... 058802 3567-25-7

Monocrotophos .................... 058901 6923-22-4

Chlordimeform .................... 059701 6164-98-3

Chlordimeform hydrochloride .................... 059702 19750-95-9

Thiabendazole hypophosphite .................... 060102 28558-32-9

Hexachlorobenzene .................... 061001 118-74-1

Butyl paraben .................... 061205 94-26-8

Paraquat dichloride .................... 061601 1910-42-5

Chloro 4 phenylphenol .................... 062206 92-04-6

Chloro 2 phenylphenol .................... 062208 *

Chloro 2 biphenylol, potassi .................... 062209 53404-21-0

Chloro 2 phenylphenol .................... 062210 85-97-2

Chloro 2 phenylphenol, potas .................... 062211 18128-17-1

Sodium phenate .................... 064002 139-02-6

Butylphenol, sodium salt .................... 064115 5787-50-8

Ammonium 2 phenylphenate .................... 064116 52704-98-0

Chloro 2 cyclopentylphenol .................... 064202 13347-42-7

Bithionolate sodium .................... 064203 6385-58-6

Chloro 3 cresol .................... 064206 59-50-7

Sodium 2,4,5 trichlorophenat .................... 064217 136-32-3

Aluminum phosphide .................... 066501 20859-73-8

Phosphorus .................... 066502 7723-14-0

Magnesium phosphide .................... 066504 12057-74-8

1 (Alkyl*amino) 3 aminopropa .................... 067301 61791-63-7

Alkyl* amino) 3 aminopropane .................... 067305 61791-58-0

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

253

Alkyl*amino) 3 aminopropane .................... 067307 68188-29-4

Alkyl* dipropoxyamine *(47% .................... 067308 68516-06-3

Alkyl*amino) 3 aminopropane .................... 067309 68155-43-1

Alkyl* amino) 3 aminopropane .................... 067310 68155-37-3

Alkyl*amino) 3 aminopropane .................... 067313 61791-64-8

Octadecenyl 1,3 propanediami .................... 067316 83542-86-3

Alkyl* amine acetate *(5%C8 .................... 067329 61790-57-6

Pindone sodium salt .................... 067704 6120-20-3

Diphacinone, sodium salt .................... 067705 42721-99-3

Isovaleryl 1,3 indandione, c .................... 067706 23710-76-1

Methyl isothiocyanate .................... 068103 556-61-6

Potassium dichromate .................... 068302 7778-50-9

Sodium chromate .................... 068303 7775-11-3

Sodium dichromate .................... 068304 10588-01-9

Alkenyl* dimethyl ethyl ammo .................... 069102 *

Alkyl* N ethyl morpholinium .................... 069113 61791-34-2

Alkyl* isoquinolinium bromid .................... 069115 53466-68-5

Alkyl* methyl isoquinolinium .................... 069116 71820-38-7

Cetyl trimethyl ammonium bro .................... 069117 57-09-0

Cetyl pyridinium bromide .................... 069118 140-72-7

Dodecyl dimethyl benzyl ammo .................... 069127......................

Alkyl* dimethyl ethylbenzyl .................... 069135 *

Alkyl* N ethyl morpholinium .................... 069147 61791-34-2

Alkyl* trimethyl ammonium br .................... 069153 1119-97-7

Benzyl((dodecylcarbamoyl)met .................... 069159 100-95-8

Cetyl pyridinium chloride .................... 069160 123-03-5

Alkyl* dimethyl ethyl ammoni .................... 069186 134595-54-3

Cetyl N ethylmorpholinium et .................... 069187 78-21-7

Use code no. 069102 (Alkenyl .................... 069198 *

p Aminopyridine .................... 069201 504-24-5

Nitrapyrin (ANSI) .................... 069203 1929-82-4

Alkyl pyridines .................... 069205 68391-11-7

Pyrazon (ANSI) .................... 069601 1698-60-8

Capsaicin (in oleoresin of c .................... 070701 404-86-4

Ryanodine .................... 071502 15662-33-6

Silver .................... 072501 7440-22-4

Silver chloride .................... 072506 7783-90-6

Silver thiuronium acrylate c .................... 072701 53404-00-5

Sodium chlorate .................... 073301 7775-09-9

Calcium cyanide .................... 074001 592-01-8

Sodium cyanide .................... 074002 143-33-9

Cryolite .................... 075101 15096-52-3

Sodium fluoride .................... 075202 7681-49-4

Ammonium fluosilicate .................... 075301 16919-19-0

Sodium fluosilicate .................... 075306 16893-85-9

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

254

Potassium iodide .................... 075701 7681-11-0

Potassium tetrathionate .................... 075903 13932-13-3

Potassium nitrate .................... 076103 7757-79-1

Sodium nitrate .................... 076104 7631-99-4

Sodium nitrite .................... 076204 7632-00-0

Benzenesulfonamide, N chloro .................... 076501 127-52-6

Salicylic acid .................... 076602 69-72-7

Ethoxyethyl p methoxycinnama .................... 076604 104-28-9

Calcium polysulfide .................... 076702 1344-81-6

Strychnine .................... 076901 57-24-9

Strychnine sulfate .................... 076902 60-41-3

Niclosamide .................... 077401 1420-04-8

Dibromosalicylanilide .................... 077402 87-12-7

Tribromsalan .................... 077404 87-10-5

Dibromosalicylanilide .................... 077405 2577-72-2

Chlorosalicylanilide .................... 077406 4638-48-6

Sulfur .................... 077501 7704-34-9

Sulfaquinoxaline .................... 077901 59-40-5

Sulfacetamide .................... 077904 144-80-9

Sulfuryl fluoride .................... 078003 2699-79-8

Sodium bisulfite .................... 078201 7631-90-5

Tetrachloroethylene .................... 078501 127-18-4

Ethoxylated isooctylphenol .................... 079004 9004-87-9

Lauric diethanolamide .................... 079018 120-40-1

Triethanolamine oleate .................... 079025 2717-15-9

Dioctyl sodium sulfosuccinat .................... 079027 1639-66-3

Use code no. 069179 (alkyl*m .................... 079036 68140-00-1

Alkyl* diethanolamide *(70% .................... 079045 52900-12-6

Tetradecyl formate .................... 079069 5451-63-8

Polyoxyethylene sorbitol ole .................... 079075 53466-71-0

Polyethoxylated stearylamine .................... 079094 26635-92-7

Capric diethanolamide .................... 079099 136-26-5

Limonene .................... 079701 138-86-3

Calcium thiosulfate .................... 080101 10124-41-1

Ammonium thiosulfate .................... 080103 7783-18-8

Thymoxydichloroacetic acid .................... 080401 22228-05-3

Thymol .................... 080402 89-83-8

Sodium trichloroacetate .................... 081001 650-51-1

Trichloroacetic acid .................... 081002 76-03-9

Hexahydro 1,3,5 tris(2 hydro .................... 083301 4719-04-4

2 (Hydroxymethyl) 2 nitro-1, .................... 083902 126-11-4

Bomyl .................... 084201 122-10-1

Turpentine .................... 084501 8006-64-2

Chloro 1 (2,5 dichlorophenyl .................... 084901 1757-18-2

Zinc chloride .................... 087801 7646-85-7

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

255

Zinc 2 pyridinethiol 1 oxide .................... 088002 13463-41-7

Hydroxy 2 (1H) pyridinethion .................... 088004 15922-78-8

Omadine TBAO .................... 088005 33079-08-2

Zinc naphthenate .................... 088301 12001-85-3

Zinc oxide .................... 088502 1314-13-2

Zinc phosphide (Zn3P2) .................... 088601 1314-84-7

Zinc phenol sulfonate .................... 089002 127-82-2

Zinc sulfate, basic .................... 089101 68813-94-5

Dimetilan .................... 090101 644-64-4

Carboxin .................... 090201 5234-68-4

Oxycarboxin .................... 090202 5259-88-1

Benzocaine .................... 097001 94-09-7

Piperalin .................... 097003 3478-94-2

Tetracaine hydrochloride .................... 097005 136-47-0

Formetanate hydrochloride .................... 097301 23422-53-9

Azacosterol HCl .................... 098101 1249-84-9

Use code no. 039502 (gentian .................... 098401 548-62-9

Ammonium alum .................... 098501 7784-25-0

Bismuth subgallate .................... 098601 99-26-3

Chlorflurenol, methyl ester .................... 098801 2536-31-4

Benzisothiazolin 3 one .................... 098901 2634-33-5

Methyl 2 benzimidazolecarbam .................... 099102 52316-55-9

Ethephon .................... 099801 16672-87-0

Pentanethiol .................... 100701 110-66-7

Nitrobutyl)morpholine .................... 100801 2224-44-4

Ethyl 2 nitrotrimethylene)di .................... 100802 1854-23-5

Tolyl diiodomethyl sulfone .................... 101002 20018-09-1

Isobutyric acid .................... 101502 79-31-2

Dibromo 3 nitrilopropionamid .................... 101801 10222-01-2

Polyethoxylated oleylamine .................... 101901 26635-93-8

Dinitramine (ANSI) .................... 102301 29091-05-2

Phenylethyl propionate .................... 102601 122-70-3

Eugenol .................... 102701 97-53-0

Tricosene .................... 103201 27519-02-4

Tricosene .................... 103202 35857-62-6

Sodium 1,4',5' trichloro-2'- .................... 104101 69462-14-2

Hexahydro 1,3,5 tris(2 hydro .................... 105601 25254-50-6

Methazole .................... 106001 20354-26-1

Difenzoquat methyl sulfate .................... 106401 43222-48-6

Butralin .................... 106501 33629-47-9

Fosamine ammonium .................... 106701 25954-13-6

Asulam .................... 106901 3337-71-1

Sodium asulam .................... 106902 2302-17-2

Hydroxymethoxymethyl 1 aza 3 .................... 107001 59720-42-2

Hydroxymethyl 1 aza 3,7 diox .................... 107002 6542-37-6

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

256

Hydroxypoly(methyleneoxy)* m .................... 107003 56709-13-8

Chloro 2 methyl 3(2H)-isothi .................... 107103 26172-55-4

Methyl 3(2H) isothiazolone .................... 107104 2682-20-4

Trimethoxysilyl)propyl dimet .................... 107401 27668-52-6

Kinoprene .................... 107502 65733-20-2

Triforine (ANSI) .................... 107901 26644-46-2

Pirimiphos methyl (ANSI) .................... 108102 29232-93-7

Thiobencarb .................... 108401 28249-77-6

Ancymidol (ANSI) .................... 108601 12771-68-5

Oxadiazon (ANSI) .................... 109001 19666-30-9

Mepiquat chloride .................... 109101 24307-26-4

Fluvalinate .................... 109302 69409-94-5

Chloro N (hydroxymethyl)acet .................... 109501 2832-19-1

Dikegulac sodium .................... 109601 52508-35-7

Iprodione (ANSI) .................... 109801 36734-19-7

Phenylmethyl) 9 (tetrahydro .................... 110001 2312-73-4

Prodiamine .................... 110201 29091-21-2

Erioglaucine .................... 110301 2650-18-2

Tartrazine .................... 110302 1934-21-0

Dodemorph acetate .................... 110401 31717-87-0

Ethofumesate (ANSI) .................... 110601 26225-79-6

Aldoxycarb (ANSI) .................... 110801 1646-88-4

Diclofop methyl .................... 110902 51338-27-3

Bromo 1 (bromomethyl)-1,3 pr .................... 111001 35691-65-7

Poly(iminoimidocarbonylimino .................... 111801 32289-58-0

Imazalil .................... 111901 35554-44-0

Bromadiolone .................... 112001 28772-56-7

Brodifacoum .................... 112701 56073-10-0

Bromethalin (ANSI) .................... 112802 63333-35-7

Fluridone (ANSI) .................... 112900 59756-60-4

Vinclozolin .................... 113201 50471-44-8

Metalaxyl .................... 113501 57837-19-1

Propetamphos (ANSI) .................... 113601 31218-83-4

Methyl 1 naphthyl)maleimide .................... 113701 70017-56-0

Hexadecadien 1 yl acetate .................... 114101 53042-79-8

Hexadecadien 1 yl acetate .................... 114102 52207-99-5

Epoxy 2 methyloctadecane .................... 114301 29804-22-6

Thiodicarb (ANSI) .................... 114501 59669-26-0

Dimethyloxazolidine (8CA & 9 .................... 114801 51200-87-4

Trimethyloxazolidine .................... 114802 75673-43-7

Hydroxyphenyl)oxoacetohydrox .................... 114901 34911-46-1

EEEBC .................... 115001 62732-91-6

MDM Hydantoin .................... 115501 6440-58-0

DMDM Hydantoin .................... 115502 116-25-6

Triclopyr (ANSI) .................... 116001 55335-06-3

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

257

Triethylamine triclopyr .................... 116002 57213-69-1

Butoxyethyl triclopyr .................... 116004 64700-56-7

Decenyl)dihydro 2(3H) furano .................... 116501 64726-91-6

Cytokinins .................... 116801......................

Benzyladenine .................... 116901 1214-39-7

Clopyralid, monoethanolamine .................... 117401 57754-85-5

Clopyralid (ANSI) .................... 117403 1702-17-6

Flucythrinate (ANSI) .................... 118301 70124-77-5

Hydramethylnon (ANSI) .................... 118401 67485-29-4

Chlorsulfuron .................... 118601 64902-72-3

Dimethipin .................... 118901 55290-64-7

Hexadecenal .................... 120001 53939-28-9

Tetradecenal .................... 120002 53939-27-8

Thidiazuron .................... 120301 51707-55-2

Metronidazole .................... 120401 443-48-1

Erythrosine B .................... 120901 16423-68-0

Sethoxydim .................... 121001 74051-80-2

Clethodim .................... 121011 99129-21-2

Cyromazine .................... 121301 66215-27-8

Tralomethrin .................... 121501 66841-25-6

Azadirachtin .................... 121701 992-20-1

Tridecen 1 yl acetate .................... 121901 65954-19-0

Tridecen l yl acetate .................... 121902 72269-48-8

Sulfometuron methyl .................... 122001 74222-97-2

Metsulfuron methyl .................... 122010 74223-64-6

Propiconazole .................... 122101 60207-90-1

Furanone, dihydro 5 pentyl .................... 122301 104-61-0

Furanone, 5 heptyldihydro .................... 122302 104-67-6

Abamectin (ANSI) .................... 122804 71751-41-2

Fluazifop butyl .................... 122805 69806-50-4

Fluazifop R butyl .................... 122809 79241-46-6

Flumetralin .................... 123001 62924-70-3

Fosetyl Al .................... 123301 39148-24-8

Methanol, (((2 (dihydro 5 me .................... 123702 97553-90-7

Fomesafen .................... 123802 72178-02-0

Tridiphane .................... 123901 58138-08-2

POE isooctadecanol .................... 124601 52292-17-8

Periplanone B .................... 124801 61228-92-0

Fenoxycarb .................... 125301 72490-01-8

Clomazone .................... 125401 81777-89-1

Clofentezine .................... 125501 74115-24-5

Paclobutrazol .................... 125601 76738-62-0

Flurprimidol .................... 125701 56425-91-3

Isoxaben .................... 125851 82558-50-7

Isazofos .................... 126901 42509-80-8

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
Appendix C Table 10 to Part 455 (with CAS Numbers) Pollution Prevention Guidance Manual for the PFPR Industry

258

Triadimenol .................... 127201 55219-65-3

Fenpropathrin .................... 127901 39515-41-8

Sulfosate .................... 128501 81591-81-3

Fenoxaprop ethyl .................... 128701 66441-23-4

Quizalofop ethyl .................... 128711 76578-14-8

Bensulfuron methyl .................... 128820 83055-99-6

Imazapyr .................... 128821 81334-34-1

Bifenthrin .................... 128825 82657-04-3

Imazapyr, isopropylamine sal .................... 128829 81510-83-0

Sodium salt of 1 carboxymeth .................... 128832 92623-86-4

Linalool .................... 128838 78-70-6

Imazaquin, monoammonium salt .................... 128840 81335-47-9

Imazethabenz .................... 128842 81405-85-8

Thifensulfuron methyl .................... 128845 79277-27-3

Imazaquin .................... 128848 81335-37-7

Myclobutanil (ANSI) .................... 128857 88671-89-0

Zinc borate (3ZnO, 2B03, 3.5 .................... 128859 *

Cyhalothrin .................... 128867 68085-85-8

Potassium cresylate .................... 128870 12002-51-6

Triflumizole .................... 128879 68694-11-1

Tribenuron methyl .................... 128887 101200-48-0

Cyhalothrin .................... 128897 91465-08-6

Chlorimuron ethyl .................... 128901 90982-32-4

Dodecen 1 yl acetate .................... 128906 28079-04-1

Dodecen 1 yl acetate .................... 128907 38363-29-0

DDOL .................... 128908 40642-40-8

Farnesol .................... 128910 4602-84-0

Nerolidol .................... 128911 7212-44-4

Tefluthrin .................... 128912 79538-32-2

Bromoxynil heptanoate .................... 128920 56634-95-8

Imazethapyr .................... 128922 81335-77-5

Imazethapyr, ammonium salt .................... 128923 101917-66-2

Chitosan .................... 128930 9012-76-4

Sulfuric acid, monourea addu .................... 128961 21351-39-3

Hydroprene .................... 128966 65733-18-8

Triasulfuron .................... 128969 82097-50-5

Primisulfuron methyl .................... 128973 86209-51-0

Uniconazole (ANSI) .................... 128976 83657-17-4

Tetradecenyl acetate .................... 128980 20711-10-8

Chitin .................... 128991 1398-61-4

Sulfluramid .................... 128992 4151-50-2

Dithiopyr (ANSI) .................... 128994 97886-45-8

Nicosulfuron .................... 129008 111991-09-4

Zinc .................... 129015 7440-66-6

Tetradecen 1 ol, acetate, (E .................... 129019 33189-72-9

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

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259

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.

Imazaquin, sodium salt ..................... 129023 81335-46-8

Dodecadien 1 ol ..................... 129028 33956-49-9

Ionone ..................... 129030 127-41-3

Dicamba, aluminum salt ..................... 129042.......................

Benzenemethanaminium, N (2 ( ..................... 129045 90823-38-4

Fenoxaprop p Ethyl ..................... 129092 71283-80-2

Alkyl* bis(2 hydroxyethyl) a ..................... 169103 61791-31-9

Alkenyl* dimethyl ammonium a ..................... 169104 22968-84-9

Amines, N coco alkyltrimethy ..................... 169109 68155-42-0

Dialkyl* dimethyl ammonium b ..................... 169111 68953-58-2

Alkyl* bis(2 hydroxyethyl) a ..................... 169125 ......................

Dodecyl bis(hydroxyethyl)dio ..................... 169154 68961-66-0

Dodecyl bis(2 hydroxyethyl) ..................... 169155 125091-04-5

Didecyl N methyl 3 (trimetho ..................... 169160 68959-20-6

Cholecalciferol ..................... 202901 67-97-0

Use code no. 202901 (Vitamin ..................... 208700 67-97-0

Alkyl* N,N bis(2 hydroxyethy ..................... 210900.......................

Bromo 2 nitropropane 1,3 dio ..................... 216400 52-51-7

Use code no. 114601 (cyclohe ..................... 229300 57063-29-3

Diethatyl ethyl ..................... 279500 38727-55-8

Hydroprene (ANSI) ..................... 486300 41096-46-2

Zinc sulfate monohydrate ..................... 527200 7446-19-7

Geraniol ..................... 597501 106-24-1 1

List of PAIs from Table 10 to Part 455 With Their

Corresponding Shaughnessy Codes and CAS Numbers1

PAI Name2 PAI Code3

Shaughnessy 

Code4

CAS 

Number5
261

APPENDIX D

Example Treatability Test Procedures

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 Formulating, Packaging, and Repackaging Industry, September 1996 (DCN F7938).

The report details the results of a series of pilot-scale treatability tests conducted 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 consists 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 physical/chemical treatment steps: emulsion breaking, hydrolysis, activated carbon adsorption, chemical oxidation, and precipitation.

4.0 TEST PROCEDURES

 This section provides a discussion of the equipment, procedures, and operating 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 organics, 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 analytical results were used to prepare hydrolysis half-life curves, which are presented 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 modified 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 Equipment

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 emulsionbreaking pretest.

4.1.1 Emulsion-Breaking Pretest

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 Tanks

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 Mixers

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 Pumps

Wastewater was transferred into and out of the various tanks and the activated 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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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 column. 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 carbon 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 deaerated 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

Measurements of pH were performed using an electronic pH meter, which

was calibrated daily, or using disposable pH strips. Temperature measurements 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. Wastewater collected from Facility A for treatability testing included formulation

vessel interior rinsates from the formulation of four separate products (referred 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 product 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.

Rinsate 1 was generated from the interior cleaning of a tank used to formulate 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 formulate 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 formulate 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

Table 4-1

Summary of Wastewater Collection for UTS Treatability Testing at Facility A

Carboy Carboy Contents (Pesticide Carboy Volume

Number Active Ingredients) (Liters) Wastewater Appearance

Carboy #1 Rinsate 1 (permethrin, methoprene) 60 Milky-white, opaque

Carboy #2 Rinsate 2 (linalool) 60 Light green, translucent

Carboy #3 Rinsate 2 (linalool) 50 Light green, translucent

Carboy #4 Rinsate 3 (pyrethrins, piperonyl butoxide) 60 Light green, translucent, foamy

Carboy #5 Rinsate 3 (pyrethrins, piperonyl butoxide) 60 Light green, translucent, foamy

Carboy #6 Rinsate 4 (permethrin, methoprene) 35 Milky-white, opaque, foamy

Carboy #7 Floor Wash Water (permethrin, methoprene, 20 Black, opaque

linalool, limonene, pyrethrins, piperonyl

butoxide)
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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 materials used to formulate the product.

Rinsate 4 was generated from the interior cleaning of a tank used to formulate 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 packaging area were cleaned using a mechanical floor scrubber. Wastewater collection 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 packaged 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 facility. In addition, the wash water contained detergents used in the floor scrubber 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 (approximately 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 Emulsion-Breaking Pretest

Table 4-3 lists the composition of each aliquot for the emulsion breaking pretest, including the initial pH and appearance, the volume of acid or base

added, the resulting pH, and the observations of the effects of the emulsionbreaking 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 emulsion breaking was not effective on the interior equipment rinsates or on the

commingled wastewater. However, emulsion breaking did appear to be effective on the aliquot that consisted only of floor wash water; a distinct sludge

phase settled out following heat and acidification.
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To determine whether alkaline conditions increased the effectiveness of emulsion 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 approximately 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 emulsion-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).

Table 4-2

Summary of Wastewater Sampling for UTS Treatability Testing of Facility A Wastewater

SCC Sample Sample Temp.

Sample Number Date Time pH (°C) Collection Method

Commingled Influent 27767 04/04/95 10:15 6.10 12.5 Scooped from tank using glass

to Hydrolysis measuring cup

Commingled Influent 27768 04/04/95 10:15 6.10 12.5 Scooped from tank using glass

to Hydrolysis measuring cup

 (duplicate)

Hydrolysis (first 27770 04/05/95 19:15 NA 60.7 Scooped from tank using glass

batch, 6-hour) measuring cup

Hydrolysis (first 27771 04/06/95 1:15 NA 55.1 Scooped from tank using glass

batch, 12-hour) measuring cup

Hydrolysis (first 27772 04/06/95 13:13 NA 57.9 Scooped from tank using glass

batch, 24-hour) measuring cup

Hydrolysis (second 27769 04/07/95 19:45 7.46 21 Scooped from tank using glass

 batch, 24-hour) measuring cup

Activated Carbon 27773 04/07/95 21:30 NA NA Collected in 4-L glass jar from

(60-liter) carbon column effluent tubing

Activated Carbon 27774 04/08/95 8:15-10:00 NA NA Collected in 9.6-L glass jar from

 (120-liter) carbon column effluent tubing

Activated Carbon 27775 04/08/95 19:30-21:15 NA NA Collected in 4-L glass jar from

(180-liter) carbon column effluent tubing

Activated Carbon 27776 04/09/95 8:38-1:30 NA NA Collected in stainless steel tank

(240-liter) from carbon column effluent

tubing

NA - Information not available.

SCC - Sample Control Center.
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Table 4-3

Emulsion-Breaking Pretest Data for UTS Treatability Testing of Site A Wastewater

Aliquot Sample Initial Initial Material Added

Number Rinsate Composition Appearance pH To Adjust pH pH Observations

1 Interior Rinse #1 1,000 ml Carboy #1 Milky-white, 8.17 0.4 ml H2

SO4 1.98 No separation

opaque (50% w/w)

2 Interior Rinse #2 500 ml Carboy #2 Light green, 6.65 0.4 ml H2

SO4 1.95 No separation

500 ml Carboy #3 translucent (50% w/w)

3 Interior Rinse #3 500 ml Carboy #4 Light green, 8.19 0.2 ml H2SO4 1.98 No separation

500 ml Carboy #5 translucent (50% w/w)

4 Interior Rinse #4 1,000 ml Carboy #6 Milky-white, 7.11 0.3 ml H2

SO4 1.98 No separation

opaque (50% w/w)

5 Floor Wash 1,000 ml Carboy #7 Black, 7.26 0.5 ml H2SO4 1.99 Settling of black

opaque (50% w/w) sludge

6 First 177 ml Carboy #1 Milky-white, 7.19 1.9 ml H2

SO4 1.98 Minor settling of

Commingled 165 ml Carboy #2 opaque (50% w/w) black material;

Aliquot 165 ml Carboy #3 may just be

170 ml Carboy #4 solids from floor

170 ml Carboy #5 sweepings

100 ml Carboy #6

 55 ml Carboy #7

7 Second 177 ml Beaker #1 Milky-white, 1.99 3.1 ml NaOH 12.03 Slight separation,

Commingled 330 ml Beaker #2 opaque (10 N) small amount of

Aliquot 340 ml Beaker #3 thick, viscous

100 ml Beaker #4 sludge at

 55 ml Beaker #5 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 overnight. 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 Treatability 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 resuspending the sludge was about 3 liters.

4.2.3 Hydrolysis

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 measuring 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 heaters 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 hydrolysis testing. After about three hours of heating, the tank achieved a temperature 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 malfunctioning 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 appropriate sample bottles. Approximately 26 liters of wastewater were collected

for the three sample volumes, an additional 12 liters were lost due to evaporation 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 ml of 50% (w/w) sulfuric acid. The wastewater, which was originally milky white, turned turbid yellow during pH adjustment. The wastewater was then pumped from the hydrolysis tank through a 10-mm filter to

the plastic activated carbon feed tank using the submersible sump pump. The

10-μm 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-1 in Appendix A1

 lists the operating 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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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 temperature 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 cooling 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 Appendix A1

 lists the operating data for the second hydrolysis treatment batch.

4.2.4 Activated Carbon Adsorption

Treatment of the wastewater from the first hydrolysis batch through activated 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 maintained 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 pouring the treated effluent from the glass jars into the appropriate sample bottles.

The wastewater from the second hydrolysis batch was pumped into the activated 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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second hydrolysis batch were added to the feed tank. The first activated carbon wastewater sample (i.e., the 60-liter sample) was collected immediately

after the wastewater from the second hydrolysis batch was added to the activated carbon feed tank. The activated carbon effluent did not have the turbid, 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.

4.3 Facility B Treatability 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 BOD5

 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 equipment, 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-gallon 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 testing 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 Emulsion-Breaking Pretest

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 vigorously 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-breaking 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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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 contained 156 liters of wastewater, was mixed using the paddle mixer, and Tank

2, which contained 163 liters of wastewater, was mixed using the Lightning®

Table 4-4

Summary of Wastewater Sampling for UTS Treatability Testing of Facility B Wastewater

SCC Sample Sample Temp.

Sample No. Date Time pH (°C) Collection Method

UTS Influent 28918 06/30/95 11:30 NA NA Half of sample volume measured from

each tank using glass measuring cup

UTS Influent 28919 06/30/95 11:30 NA NA Half of sample volume measured from

(duplicate) each tank using glass measuring cup

Settling 28920 07/04/95 11:20 5.85 NA Half of sample volume measured from

Supernatant each tank using glass measuring cup

Hydrolysis 28921 07/05/95 20:00 NA 57a Half of sample volume measured from

(6-hour) each tank using glass measuring cup

Hydrolysis 28922 07/06/95 2:14 NA 64.5a Half of sample volume measured from

(12-hour) each tank using glass measuring cup

Hydrolysis 28923 07/06/95 14:00 10.6a 63a Half of sample volume measured from

(24-hour) 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

a

Average of both tanks.

NA - Information not available.

SCC - Sample Control Center.
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mixer. Both mixers effectively mixed the contents of the tanks, so the difference 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 supernatant 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 volume. 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 plastic 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.

4.3.3 Hydrolysis

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 evaporation 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 Adsorption

The wastewater was removed from the walk-in refrigerator and approximately 38 liters were pumped from each tank into the plastic activated carbon 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 throughout the test. Samples were collected after 60, 120, and 180 liters of wastewater 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 refrigerator to prevent biological growth. About 27 liters remained in the activated

carbon feed tank following collection of the 120-liter sample. Another 38 liters of wastewater were pumped from each stainless steel tank into the plastic activated carbon feed tank. The stainless steel tanks were then returned to

the walk-in refrigerator to prevent biological growth. About 17 liters of wastewater 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 Facility C Treatability Test

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 PAIs ametryn, atrazine, cyanazine, ethalfluralin,

metolachlor, and pendimethalin. For four to five weeks prior to sample collection, 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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tank through a hose connected to a valve at the bottom of the tank into fourteen 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 wastewater 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.

Table 4-5

Summary of Wastewater Sampling for UTS Treatability Testing of Facility C Wastewater

SCC Sample Sample Temp.

Sample No. Date Time pH (°C) Collection Method

UTS Influent 29769 07/28/95 10:30 7 13 Half of sample volume measured from

each tank using glass measuring cup

UTS Influent 29770 07/28/95 10:30 7 13 Half of sample volume measured from

(duplicate) each tank using glass measuring cup

Emulsion-Breaking 29771 07/30/95 9:30 2.09 33 Half of sample volume measured from

Supernatant each tank using glass measuring cup

Hydrolysis 29772 07/31/95 20:15 12 NA Half of sample volume measured from

(6-hour) each tank using glass measuring cup

Hydrolysis 29773 08/01/95 2:30 NA NA Half of sample volume measured from

(12-hour) each tank using glass measuring cup

Hydrolysis 29774 08/01/95 2:00 12 59 Half of sample volume measured from

(24-hour) each tank using glass measuring cup

Activated Carbon 29775 08/02/95 7:50-8:40 7 21 Collected in 4-L glass jar from carbon

(60-liter) column effluent tubing

Activated Carbon 29776 08/02/95 22:15-23:00 7 18 Collected in 9.6-L glass jar from

(120-liter) carbon column effluent tubing

Activated Carbon 29778 08/03/95 9:00-14:30 7.9 NA Collected in stainless steel tank from

(200-liter) carbon column effluent tubing

NA - Information not available.

SCC - Sample Control Center.
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4.4.1 Emulsion-Breaking Pretest

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 remaining 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 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.

After the influent and influent duplicate samples were collected, three 1.5-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.

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 approximately 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 approximately 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 Emulsion Breaking

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 stainless 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 heaters. 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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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 supernatant began to occur as soon as the mixers were stopped. After settling overnight 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 supernatant with 2 ml (or 4%) of gray sludge.

The emulsion-breaking effluent sample was collected from the tanks by scooping the supernatant 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 supernatant from Tank 1 was pumped into a plastic tank using the sump

pump. However, turbulence from the sump pump caused the sludge to resuspend. The supernatant was then pumped back into Tank 1, and the emulsion-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 required 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 1

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 varied 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 yellow 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 Activated Carbon Adsorption

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 wastewater 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 filters 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 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

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 volume (35 liters) of wastewater from Tank 1 was pumped, using the submersible sump pump, through a 10-mm 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 process 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 activated 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-mm filter by pumping the wastewater from

the carbon feed tank through the 5-mm filter into a clean plastic tank.

Yellow-brown solids accumulated on the filter during the filtration. The activated 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 entrapped 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 because wastewater was lost to evaporation during the hydrolysis and emulsion-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 appendix comprises two attachments that consist or or are excerpted from already 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 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 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 1

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 Analysis 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 complying with both the P2 alternative and BMR requirements, and guidance for

PFPR facilities in fulfilling the BMR requirements until the General Pretreatment Regulations can be modified to accomodate the PFPR compliance requirements.
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ATTACHMENT 1: APPLICABILITY OF CATEGORICAL

PRETREATMENT STANDARDS TO “ZERO-DISCHARGE”

INDUSTRIAL USERS*

The Environmental Protection Agency (EPA) recently issued guidance concerning the applicability of categorical pretreatment standards to zerodischarge 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 requirements 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)(1)). For this purpose, an IU is deemed to be a categorical industrial user (CIU) 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 (PSNS).

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 reference to the general pretreatment provisions in 40 CFR Part 403 (or its predecessor, 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 Bulletin #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 IUs.

1. Where an IU operates a categorical process, but no regulated process wastewater 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 potentially 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, noncategorical IUs 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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ment Regulations and local limits, may warrant periodic inspection and monitoring 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 performs 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 certification 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 categorical pretreatment standard. Any IU that is subject to a categorical pretreatment 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 pretreatment standards which have PSES or PSNS requirements that contain such

language. An IU subject to this particular PSES or PSNS requirement is considered 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 1 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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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 CIU.

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 affecting the POTW’s operation or for violating any pretreatment standard or requirement, 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 containing 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 disposal 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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ATTACHMENT 2: BASELINE MONITORING REPORT REQUIREMENTS FOR

PESTICIDE FORMULATING, PACKAGING, AND REPACKAGING FACILITIES
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285

APPENDIX F

Definitions

Administrator: The Administrator of the U.S. Environmental Protection

Agency.

Aerosol container (DOT) leak testing wastewaters: Wastewaters from pressurization/leak testing of pesticide product containers to meet DOT

shipping requirements.

Agency: The U.S. Environmental Protection Agency.

Appropriate pollution control technology: The wastewater treatment technology listed on Table 10 to Part 455 (Appendix A) 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.

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 Section 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 decomposition of organic matter in a water sample. It is determined by

measuring the dissolved oxygen consumed by microorganisms to oxidize the organic contaminants in a water sample under standard laboratory 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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BPT: The best practicable control technology currently available, as described

in Section 304(b)(1) 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 Amendments 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 represent 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. Citations 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 product, 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 biodegradation. Refractory compounds slowly exert demand on downstream 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 expressed as the amount of oxygen consumed by a chemical oxidant in

a specific test.

Combustion device: An individual unit of equipment, including but not limited to, an incinerator or boiler, used for the thermal oxidation of organic 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 pretreatment program (§403.3(t)(1)) has been approved in accordance with

the requirements of §403.11; or (2) the approval authority if the submission has not been approved.

Conventional pollutants: Constituents of wastewater as determined in Section 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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CWA: Clean Water Act. The Federal Water Pollution Control Act Amendments 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 similar level of pesticide active ingredient or priority pollutants as the applicable appropriate pollution control technology listed in Table 10 to

Part 455 (Appendix A).

FATES: FIFRA and TSCA Enforcement System.

FDA: Food and Drug Administration.

FDF: 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 pesticide active ingredients with one or more other active or inert ingredients, 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, Washington, D.C. A publication making available to the public regulations

and legal notices issued by federal agencies. These include Presidential proclamations and Executive Orders and federal agency documents having general applicability and legal effect, documents required

to be published by act of Congress and other federal agency documents of public interest. Citations of the Federal Register include volume 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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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 accordance with good manufacturing practices, as defined by 21 CFR Part

182; or is exempt from FIFRA 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 organic 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 chemical precipitation, flocculation, neutralization, chemical oxidation, hydrolysis, and/or adsorption.

Interior wastewater sources: 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 during the formulating, 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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Line: Equipment and interconnecting piping or hoses arranged in a specific

sequence to mix, blend, impregnate, or package, or repackage pesticide 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 opening 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 (protozoa, 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 commenced (1) for purposes of compliance with New Source Performance

Standards, after the promulgation of such standards under CWA section 306; or (2) for the purposes of compliance with Pretreatment Standards for New Sources, after the publication of proposed standards

under CWA section 307(c), if such standards are thereafter promulgated in accordance with that section.

Noncontact cooling water: Water used for cooling in formulating/packaging 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 systems.

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 pollutants 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.

NOx

: Nitrogen oxides.
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NPDES: The National Pollutant Discharge Elimination System, a federal program requiring industry dischargers, including municipalities, to obtain 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 product 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, regardless of whether the site is independently owned or operated, and regardless of whether the site is domestic and producing a pesticidal

product for export only, or foreign and producing any pesticidal product 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 intermediate stage between laboratory experimentation and full-scale operation in the development of a new process or product.
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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, incinerator residue, filter backwash, sewage, garbage, sewage sludge, munitions, 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 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.

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, recycling 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 effluent 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 active ingredient(s) from a manufacturing or another formulating operation), including the physical mixing of these pesticide active

ingredients with each other or with nonpesticide materials, and concluding 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 wastewater stream. Examples of process wastewater collection system equipment include individual drain systems, wastewater tanks, surface

impoundments, and containers.

PSES: Pretreatment standards for existing sources of indirect discharges, under Section 307(b) of the CWA.
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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 practices commonly employed to remove materials from that type of container (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 marketable 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 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 Part 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(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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Septic system: A system which collects and treats wastewater, 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 rinsate: 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 industry. An SIC code refers to the principal product, or group of products, produced or distributed, or to services rendered by an operating

establishment. SIC codes are used to group establishments by the primary 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 equipment.

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 entering 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 associated with the release of such substances, pollutants, or contaminants.

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 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

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 occurring 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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Technical Development Document: Development Document for Best Available Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide Formulating, Packaging, and

Repackaging Industry (EPA 821-R-96-019).

Technical grade of active ingredient: A material containing an active ingredient: 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 technologies 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 equipment 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.