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 discharg
- There is no Nolle Prosequi (before prelim). How do we properly count those cases where the decision to not prosecute the case is made before the preliminary hearing?
- 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?
- What else factors into the decision of leasing versus buying?