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 pro
- 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?
- 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?
- Are inert ingredients used in products other than pesticides?