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Effluent Guidelines
Chapter 4: Conducting the P2 Audit (Summary)
Instructions and an example for conducting P2 audits to evaluate water management practices at PFPR facilities and to aid in making compliance decisions.
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.
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.
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.
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.
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 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 Wastewater Sources | Helps users summarize in detail potential wastewater sources through review of process operations. |
| Table B | Evaluation of PFPR P2, Recycle, and Reuse Practices | Helps users summarize in detail P2, recycle, and reuse practices, and evaluate their current use, whether they can be implemented by the facility, and any required modifications. |
| Table C | Summary of PFPR Compliance Decisions | Helps users summarize the compliance decision for each wastewater source identified in Table A. The completion of the P2 audit results in a preliminary compliance decision for each source. |
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).
| Nonpesticide Operations and Industries | |
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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. |
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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.
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