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 wastes and air emissions) associated with their processes to identify potential P2 opportunities that limit cross-media transfers.
Related Questions
- In Reckoner we have various Items which could be a raw material or a product, i.e., a finished product. Does Reckoner track any as to whether a type of Item is produced or purchased,etc.?
- Does a facility need to track raw material bags, which are emptied and disposed of, during the P2 audit?
- Who is the entity that conducts a P2 audit and regulates a facility?
