UnitedStates Permits Division September 1985 Environmental Protection Washington, DC20460 Agency
Water 

# EPA 

# Guidance Manual

for Implementing Total Toxic Organics (TTO) Pretreatment StandardsGUIDANCE MANUAL FOR IMPLEMENTING TOTAL TOXIC ORGANICS PRETREATMENT STANDARDS

Prepared by Permits Division (EN-336) Office of Water Enforcement and Permits

Office of Water

September 1985
U.S. Environmental Protection Agency

401 MStreet, S.W. Washington, D.C. 20460TABLE OF CONTENTS

Chapter Page 1.

2.

3.

4.

5. INTRODUCTION 1.1. DEFINITION OFTTO

.................................. 1.2. GENERAL ORGANIZATION

............................... 1.3. LIMITATIONS OFTHIS MANUAL

......................... REPORTING REQUIREMENTS 2.1. BASELINE MONITORING REPORT

......................... 2.2. PROGRESS REPORTS

................................... 2.3. 90-DAY COMPLIANCE REPORT

........................... 2.4. INDUSTRIAL USER SEMI-ANNUAL COMPLIANCE REPORT

...... INDUSTRIAL CATEGORIES WITH TTO REQUIREMENTS 3.1. ELECTROPLATING AND METAL FINISHING 3.1.1. TTO Limits

.................................. 3.1.2. Alternative to TTO Monitoring

............... 3.1.3. Sources of Toxic Organics

................... 3.2. ELECTRICAL AND ELECTRONIC COMPONENTS (PHASES I AND II) 3.2.1. TTO Limits

.................................. 3.2.2. Alternative to TTO Monitoring

............... 3.2.3. Sources of Toxic Organics

................... 3.3. COPPER FORMING 3.3.1. TTO Limits

.................................. 3.3.2. Alternative to TTO Monitoring

............... 3.3.3. Sources of Toxic Organics

................... 3.4. ALUMINUM FORMING 3.4.1. TTO Limits

.................................. 3.4.2. Alternative to TTO Monitoring

............... 3.4.3. Sources of Toxic Organics

................... 3.5. COIL COATING 3.5.1. TTO Limit

................................... 3.5.2. Alternative to TTO Monitoring

............... 3.5.3. Sources of Toxic Organics

................... GUIDANCE FORTHE PREPARATION OF A TOXIC ORGANIC MANAGEMENT PLAN

......................................... USE OF THE COMBINED WASTESTREAM FORMULA 5.1 DEFINITIONS

........................................ 5.2 CWFCONDITIONS

..................................... 5.3 CALCULATION OFALTERNATIVE TTO LIMITS USING THE CWF

...................................... 1-2 1-2 1-3
2-1 2-3 2-3 2-3

3-1 3-2 3-3

3-4 3-5 3-6 3-6 3-8 3-8 3-8 3-13 3-13 3-14 3-16 3-16

4-1

5-1 5-1 5-2TABLE OF CONTENTS (cont.)

Chapter Page
6. REMOVAL CREDITS 6.1 REMOVAL CREDITS FORTTO

............................ 6.2 REMOVAL CREDITS FORTTO SURROGATE OR INDICATOR POLLUTANTS

............................... 7. TTO MONITORING GUIDANCE 7.1. SAMPLING CONSIDERATIONS 7.1.1. Sampling Location

........................... 7.1.2. Sample Collection Techniques

................ 7.1.3. Sample Volumes

.............................. 7.1.4. Sample Equipment and Containers

............. 7.1.5. Sample Preservation and Holding Times

....... 7.1.6. Sample Type and Frequency for TTO

Monitoring

.................................. 7.2. LABORATORY CONSIDERATIONS 7.2.1. Analytical Procedures

....................... 7.2.2. Laboratory Quality Control

.................. 7.3. OIL AND GREASE MONITORING CONSIDERATIONS 7.3.1. Oil and Grease Sampling Considerations

...... 7.3.2. Analytical Considerations for
APPENDIX A:
APPENDIX B:

APPENDIX C:

APPENDIX D: APPENDIX E: Oil and Grease

..............................

40 CFR Section 403.12: Reporting Requirements for POTWsand Industrial Users

................. Electroplating and Metal Finishing Category: List of Toxic Organic Compounds Regulated as Components of Total Toxic Organics

............. Electrical and Electronic Components Category: List of Toxic Organic Compounds Regulated as Components of Total Toxic Organics (By Subcategory)

............................... Example Toxic Organic Management Plan

.......... 40 CFR Section 465.03: Monitoring and Reporting Requirements

.................................. 6-1 6-2

7-1 7-2 7-3 7-12 7-13 7-13 7-20 7-21 7-21 7-21
A-1

B-1

C-1 D-1
E-1

ii1. INTRODUCTION

The National Pretreatment Program establishes an overall strategy for controlling the introduction of nondomestic wastes to publicly owned treatment works (POTWs) in accordance with the overall objectives of the Clean Water Act. Sections 307(b) and (c) of the Act authorize the Environmental Protection Agency to develop national pretreatment standards for new and existing dischargers to POTWs. The Act made these pretreatment standards enforceable against dischargers to publicly owned treatment works. The General Pretreatment Regulations (40 CFR Part 403) established administrative mechanisms requiring certain POTWs to develop local pretreatment programs to enforce the general discharge prohibitions and specific Categorical Pretreatment Standards. These Categorical Pretreatment Standards are designed to prevent the discharge of pollutants which pass through, interfere with, or are otherwise incompatible with the operation of the POTWs. The standards are technology-based for removal of toxic pollutants and contain specific numerical limitations based on an evaluation of specific technologies for each individual industry category. Categorical Pretreatment Standards have been or at-e being established for different categories of industries. Twenty-one of these industrial categories must presently meet numerical Limits for certain pollutants that are typically present in the waste discharges from those industries. All categories must comply with the generic prohibited discharge standards specified in 40 CFR 403.5(b) and any local limits established by the POTWin which the industry is located pursuant to the General Pretreatment Regulations. Six of the industrial categories have a pretreatment standard established for total toxic organics (TTO). The categories affected by a TTO limit are:

• Electroplating • Metal Finishing

• Electrical and Electronic Components (Phases I and II)

• Copper Forming • Aluminum Forming

• Coil Coating (Can-Making Subcategory only) The reason for a TTO limit in each of these categories is that industry studies have shown there is a significant potential for TTO discharge by these industries.

l-l1.1. DEFINITION OF TTO

The TTO is defined as the sum of the masses or concentrations of specific toxic organic compounds found in the industrial user’s process discharge at a concentration greater than 0.01 mg/l. Each Categorical Standard lists the specific toxic organic compounds that are to be included in the summation to define TTO for the category. 1.2. GENERAL ORGANIZATION This manual will be useful to both POTWs and their indirect dischargers/industrial users (IUs) who are subject to a categorical pretreatment standard for TTO. It will help POTWs by providing them with a better understanding of how to implement the TTO standard and how the alternative provided in each regulation may be useful in lieu of IUs monitoring their TTO discharges to document their compliance status. Through this manual, IUs will understand their reporting responsibilities relative to TTO and the available alternative under the applicable regulation. Chapter 2, REPORTING REQUIREMENTS, provides information on the various reports which a regulated IU must submit under the General Pretreatment Regulations (40 CFR Part 403). This chapter will be most useful for IUs subject to the Electrical and Electronic Components (Phase I and II), the Copper Forming, the Aluminum Forming, and the Coil Coating regulations. Industrial users subject to the Electroplating and Metal Finishing regulations, have already received similar guidance in the Guidance Manual for Electroplating and Metal Finishing Pretreatment Standards (February 1984). Chapter 3, INDUSTRIAL CATEGORIES WITH TTO REQUIREMENTS, discusses each industry category that contains a TTO pretreatment standard. It presents the individual toxic organic compounds which are regulated as a component of TTO, the specific TTO limitations and the applicable compliance date for both existing and new source pretreatment standards. It also discusses the TTO monitoring alternative and potential sources of toxic organics in each category. Chapter 4, GUIDANCE FORTHE PREPARATION OF ATOXIC ORGANIC MANAGEMENT PLAN, walks an industrial user and a Control Authority through the steps necessary to develop an acceptable management plan. Chapter 5, USE OFTHE COMBINED WASTESTREAM FORMULA, and Chapter 6, REMOVAL CREDITS, discuss the applicability of these two provisions of the General Pretreatment Regulations to TTO pretreatment standards. Chapter 7, TTO MONITORING GUIDANCE, presents specific guidance on sampling and analyzing TTO and on oil and grease monitoring for the industry categories which provide that TTO monitoring alternative.

1-21.3. LIMITATIONS OF THIS MANUAL

This manual presents information and guidance only on the implementation of categorical pretreatment standards for TTO. It does not deal with any problems or issues related to any individual toxic organic compounds regardless of whether they are regulated as a TTO component. These more specific, localized problems are better addressed on a case-by-case basis by the industrial users and their Control Authority.

1-32. REPORTING REQUIREMENTS

The General Pretreatment Regulations (40 CFR Part 403) require that indirect dischargers regulated under a National Categorical Pretreatment Standard submit various reports at specified times. Section 403.12 of the General Pretreatment Regulations delineates what reports each regulated indirect discharger must submit, the information to be contained in each report, and when each report must be submitted to the Control Authority. Appendix A contains a copy of Section 403.12. The Control Authority is the indirect discharger's receiving POTWif its pretreatment program has been approved. If the POTW's program has not been approved, the Control Authority is the State if its pretreatment program has been approved or the appropriate EPA Regional Office if the State does not have an approved pretreatment program.
2.1 BASELINE MONITORING REPORT Under the provisions of Section 403.12 of the General Pretreatment Regulations, all industrial users (IUs) of a publicly owned treatment works (POTW) subject to categorical pretreatment standards are required to submit a Baseline Monitoring Report (BMR). The BMRmust be submitted by an existing source within 180 days after the effective date of an applicable categorical pretreatment standard or within 180 days after the final decision on a category determination request submitted under Section 403.6(a). New sources must submit a report which contains the information delineated in 40 CFR Section 403.12(b)(l) to (5). The term "New source" means any building, structure, facility, or installation from which pollutants are discharged or may be discharged and the construction of which was started after the publication of any proposed applicable pretreatment standard under section 307(c) of the Clean Water Act if such standard is finally promulgated in accordance with section 307(c). The BMRmust contain the name and address of the facility including the name of the operator and owners; a list of environmental control permits held by or for the facility; a brief description [including a flow-diagram of regulated processes] of the nature, average rate of production, and SIC codes of the operations; the measured average daily and maximum daily flow from regulated process streams and other streams as necessary for using the combined wastestream formula; and the results of sampling and analysis identifying the nature and concentration or mass of the regulated pollutants in each regulated process' discharge. The indirect discharger shall provide the concentration or mass as required by either the pretreatment standard or the Control Authority. Where feasible, the indirect discharger shall use flow proportional composite sampling techniques specified in the applicable standard. If flow metering is not available, then time proportional composite sampling techniques may be used. When composite sampling is not feasible, a grab sample is acceptable. 2-1The BMRshall indicate the time, date, and place of sampling,

the methods of analysis, and shall certify that the sampling and analysis is representative of normal work cycles and expected pollutant discharges. Additionally, the BMRshall include an authorized representative's certification, endorsed by a qualified professional, that pretreatment standards are or are not being met on a consistent basis. If not being met, the BMRshall also contain a compliance schedule for implementing additional operation and maintenance (O & M) and/or pretreatment necessary for meeting the applicable standards and requirements. An authorized representative as a minimum shall be a vice president-level individual if the indirect discharger is a corporation: a general partner or proprietor if the discharger is a partnership or sole proprietorship, respectively: or an authorized representative if the representative is responsible for the facility’s operation. If a regulated indirect discharger is not meeting the applicable pretreatment standards and his BMRcontains a compliance schedule, the compilance schedule must contain the shortest schedule by which the industrial user (IU) will provide the additionalO & Mand/or pretreatment necessary to comply with the standards. The schedule will contain increments of progress for the start and finish of major events leading to construction and operation of the necessary O&M and/or pretreatment. No increment of progress shall exceed 9 months; the completion date shall not be later than the compliance date for the applicable pretreatment standards. TTO monitoring must be submitted in the BMRfor all categorical industries subject to a TTO standard except those facilities that plan to use alternate oil and grease limits provided in the Aluminum Forming, Copper Forming, and Coil Coating regulations. The General Pretreatment Regulations establish a sampling frequency which IUs must use in preparing their BMRs. The sampling frequency is related to the flow of the stream being sampled. If the flow is less than or equal to 950,000 liters per day (approximately 250,000 gpd), the IU must take three samples within a two-week period. If the flow is greater than 950,000 liters/day (approximately 250,000 gpd), the IU must take six samples within a two-week period. 2.2 PROGRESS REPORTS

No later than 14 days following each date in its compliance schedule and the final compliance date, the IU must submit a progress report to the Control Authority. The report must state whether or not it complied with the increment of progress to be met. If the increment step was not met, the report must further state when that step will be finished, the reason for the delay, and the steps which will be taken by the IU to get back on schedule.

2-2IUs can not exceed 9 months between any two progress reports.

These reports will not contain any sampling and analysis results for TTO or any available alternative. 2.3 NINETY-DAY COMPLIANCE REPORT Section 403.12(d) of the General Pretreatment Regulations requires categorical industrial facilities subject to pretreatment standards to submit a 90-day compliance report to the POTW. This report provides initial verification that the IU is in compliance with the applicable standards and requirements for their discharge. Existing categorical industrial users must file a final compliance report within 90 days following the final compliance date specified in a categorical regulation or within 90 days of the compliance date specified by the Control Authority, whichever is earlier. New source industrial users must file a compliance report within 90 days after the commencement of a discharge to the POTWsystem. The contents of this report must include: results of sampling of industrial wastestreams for regulated pollutants: average and maximum daily flow for industrial process wastewaters being regulated; a statement of compliance; and, where necessary, a statement as to whether additionalO & Mchanges and/or pretreatment equipment are needed to bring the industrial user into compliance. Control Authorities must require that IUs include in their 90-day compliance report the results of their sampling and analysis for TTO unless an alternative oil and grease limitation is provided and adopted. If an IU elects to use an alternative oil and grease limitation, then the 90-day compliance report must contain results of oil and grease sampling and analysis. An authorized representative as discussed above must sign this report. Additionally, a qualified professional must certify the report. For the 90-day compliance report, Control Authorities should require that their regulated IUs use the sampling frequency specified for BMRs in 40 CFR Section 403.12(b)(5)(iv). 2.4 INDUSTRIAL USER SEMI-ANNUAL COMPLIANCE REPORTS The General Pretreatment Regulations require categorical industrial users to report the results of self-monitoring of their regulated waste discharges to the Control Authority at least semiannually. The regulations [Section 403.12(e)(l)] state that the reports are to contain information "indicating the nature and concentration of pollutants in the effluent which are limited by such Categorical Pretreatment Standards. In addition, this report shall include a record of measured or estimated average and maximum daily flows for the reporting period..." The reports must be submitted at least semi-annually in June and December.

2-3However, the regulations state that the Control Authority may

at its discretion alter the specific months during which the self-monitoring reports are due to account for such factors as high or low flow rates, budget cycles, holidays, etc. In all cases, the self-monitoring reports should be required to be submitted within fifteen calendar days of the date on which the last sample analysis is received. The report should include all self-monitoring data for the semi-annual period just ended. At a minimum, the following information should be reported to the Control Authority:

0 Date the sample and flow measurement was taken

0 Results of analysis for all required parameters

0 Other information (unusual process or operating conditions, equipment, problems, etc.) that may affect sample results

0 Signed statement of accuracy by an authorized representative. In these reports, the IU is n3t required to submit the results of TTO monitoring and analysis to demonstrate continued compliance with the applicable TTO pretreatment standard if he elects to use the applicable alternative available to his facility. Where TTO monitoring is required, the Control Authority will establish the required monitoring frequency.

2-43. INDUSTRIAL CATEGORIES WITH TTO REQUIREMENTS

This chapter presents information concerning the TTO limits, alternatives to the requirement for TTO monitoring (where available) and brief discussions of potential sources of the regulated toxic organics within each category affected by a TTO standard. Each category with a TTO standard is addressed. Discussion of the Electroplating and Metal Finishing categories is combined as is the discussion of the Electrical and Electronic Components Phase I and Phase II categories because of the similarity of operations and standards. 3.1 ELECTROPLATING AND METAL FINISHING 3.1.1 TTO Limits The Electroplating/Metal Finishing regulations include a TTO pretreatment standard. Appendix Bcontains a list of the individual toxic organic compounds which must be included in the TTO summation when they are present in a regulated wastestream in a concentration greater than 0.01 mg/l. Industrial users subject to these regulations must sample and analyze their wastestreams for TTO and report the results of this TTO monitoring in their BMRs and in their 90-day compliance report. However, these IUs are only required to sample and analyze for those individual compounds listed in Appendix B which would reasonably be expected to be present in their wastestream. This is in accordance with 40 CFR Section 413.03(c) and 40 CFR Section 433.12(a) of the Electroplating and Metal Finishing Regulations, respectively. Before regulated IUs conduct any BMRand 90-day compliance report monitoring for TTO, they should seek their Control Authority's agreement on which of the individual toxic organics listed in Appendix B can reasonably be expected to be present in their regulated wastestreams. Control Authorities should require that their regulated IUs support with appropriate documentation their determination of reasonably expected presence, Appropriate documentation may include a new material inventory, an engineering study, and/or a process balance. The following table gives the TTO pretreatment standards for the Electroplating and Metal Finishing categories and the applicable compliance date for each.

3-1Limit

Industry Category (Daily Maximum) (mg/l) Compliance Date Electroplating

< 10,000 gpd 4.57 July 15, 1986 > 10,000 gpd 2.13 July 15, 1986 Metal Finishing Interim 4.57 June 30, 1984 Final 2.13 February 15, 1986

3.1.2 Alternative to TTO Monitoring

Rather than monitor TTO, IUs may request that their Control Authority allow them to make the following certification:

"Based on my inquiry of the person or persons directly responsible for managing compliance with the pretreatment standard for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the wastewater has occurred since filing of the last semiannual compliance report. I further certify that this facility is implementing the solvent management plan submitted to the Control Authority." The IUs must include this certification in each semi-annual compliance report which they submit to their Control Authority. The IUs' use of the certification statement is solely at their Control Authority's discretion. When requesting to use this certification as an alternative to TTO monitoring the IUs must submit a toxic organic management plan (TOMP) that satisfies the Control Authority regarding: (1) the identification of the toxic organics listed in AppendixB which the IU uses; (2) the method of disposal, such as incineration, contract hauling, or reclamation; and (3) procedures for assuring that toxic organics do not routinely spill or leak into the wastestream.

3-2The IUs must submit and implement this TOMPas early as

possible in order to demonstrate that it will provide the degree of control necessary for the IU to achieve compliance with the TTO pretreatment standard. Chapter 4 presents guidance on the development of a TOMP. Appendix D is an example of such a plan. However, if the Control Authority samples and analyzes its IUs' wastestream to confirm compliance with an applicable TTO pretreatment standard and the results show non-compliance, the Control Authority can require that the IU initiate TTO sampling and analysis on a frequency which the Control Authority establishes. The Control Authority must also require that the IU take the remedial actions necessary to come into compliance with the applicable TTO standard as expeditiously as possible. 3.1.3 Sources of Toxic Organics Toxic organics are used extensively in electroplating and metal finishing processes. The list of regulated toxic organics includes 110 compounds, as noted in Appendix B. The main sources of the toxic organics generated by these industries are primarily from the dumping of spent solvents or dragout of organic compounds used in degreasing and paint stripping operations. Other sources may include parts washing and various surface preparation and painting operations. Degreasing, however, is the most prevalent source. Both production/process areas and storage areas are potential sources for the introduction of toxic organics into the POTWsewer system. Production/process introductions can be in the form of solvent rinse dragout, spray/mist wash runoff, paint booth runoff, and spent solvent dumping. Storage area toxic organic introductions can occur from spills which enter floor drains. The dumping of spent, contaminated or unwanted solvents into the sewer system is also a significant source. Industrial users have the responsibility to identify the toxic organic constituents of any solvents and degreasers that use commercial or trademark names and do not list the actual chemical name(s). Control Authorities may verify that its IUs' commercial degreasers and solvents do not contain any toxic organics by requesting that the IUs submit a list of components for any commercial or trademark solvents and degreasers which they may use. Table 3.1 presents some examples of halogenated and nonhalogenated toxic organic compounds which may be found in commercial grade solvents and degreasers.

3-3TABLE 3.1 Example Toxic Constituents of

Organic Solvents Halogenated Solvent Constituents Di,tri,tetra-chloromethanes Di,tri,tetra-chloroethanes Di,tri,tetra-chloroethylenes Chlorinated Benzenes Methylene Chloride Non-Halogenated Solvent Constituents - Benzene Phenol Nitrobenzene Ethylbenzene Toluene Acrylonitrile Napthalene

3.2 ELECTRICAL AND ELECTRONIC COMPONENTS (PHASES I AND II) 3.2.1. TTO Limits The Electrical and Electronic Components category has four subcategories: (a) Semiconductors,, (b) Electronic Crystals, (c) Cathode Ray Tubes, and (d) Lurrinescent Materials. Semiconductors, Electronic Crystals, and Cathode Ray Tubes all have TTO limits. The remaining subcategory, Luminescent Materials, has no TTO restrictions. The following table gives the limitation and compliance date for each regulated subcategory.
Subcategory Limit (Daily Max.) (mg/l)l Compliance Date Semiconductors 1.37 July 1, 1984 Electronic Crystals 1.37 July 1, 1984 Cathode Ray Tubes 1.58 July 14, 1986

1 Limits in each subcategory apply to both new and existing sources in that subcategory.

3-4The specific toxic organic compounds regulated as TTO are

delineated in Appendix C. These compounds must be included in the TTO summation when they are present in a regulated wastestream in concentrations greater than 0.01 mg/l. Additionally, IUs in these subcategories must sample and analyze for all the toxic organics listed in Appendix C. They may not limit their testing to those toxic organics reasonably expected to be present in their regulated wastestreams. The Agency has already determined that all these pollutants are reasonably expected to be present. Regulated IUs must report the results of their TTO sampling and analysis in their BMRs and in their go-day compliance reports. The applicable sampling frequency for these two reports is found in Sections 2.1 and 2.3, respectively, of this manual. 3.2.2 Alternative to TTO Monitoring Industrial users as an alternative to monitoring TTO to determine compliance with the applicable standard may certify with the Control Authority's approval that there has been no dumping of concentrated toxic organics into the wastewater and that it is implementing the solvent management plan submitted to the Control Authority. The regulated IUs must submit this certification as a comment to their semi-annual compliance reports. The specific certification language is found in 40 CFR Section 469.13(c) and the requirement that the IUs electing to use this certification submit and then implement a solvent managment plan is found in 40 CFR Section 469.13(d). The specific certification language is as follows: "Based on my inquiry of the person or persons directly responsible for managing compliance with the pretreatment standard for total toxic organics (TTO), I certify that to the best of my knowledge and belief, no dumping of concentrated toxic organics into the wastewater has occurred since filing of the last semi-annual compliance report. I further certify that this facility is implementing the solvent management plan submitted to the Control Authority." 3.2.3 Sources of Toxic Organics Toxic organics are used similarly in the three regulated subcategories. They appear almost exclusively as constituents of solvents. These solvents are used in cleaning, degreasing, and some etching operations. Both production/process areas and storage areas are potential sources for the introduction of toxic organics into the POTWsewer system. Production/process introductions can be in the forms of solvent rinse dragout, spray/mist wash runoff, etching solution dumping, and spent solvent dumping. Storage area toxic organic introductions can occur from spill entry via floor drains and dumping of spent or unwanted solvents in the sewer system. Industries are responsible for identifying the toxic organic constituents in any solvents that use commercial or trademark names and do not list the actual chemical name(s). 3-53.3 COPPER I’ORMING

3.3.1 TTO Limits Copper forming consists of five basic processes used to form copper or copper alloys: hot rolling, cold rolling, extrusion, ~lrawinq, and forging. These are tha core processes; ancillary operations consist of annealing witn oil or water, pickling, alkaline cleaning, solution heat treatment, tumblirvg, burnishinq, surface coating, hydrotesting, surface mil1int.l and sawing. The toxic organic compounds idtzntifiel! as comprising TTO under the categorical standards for copper forming are: Benzene Napthalene l,l,l-Trichloroethane N-nitrosodiphenylamine Chloroform Anthracene 2,6-dinitrotoluene Phenanthrene Ethylbenzene Toluene Yethylene chloride Trichloroethylene

The final compliance datr- for the pretreatment standards for existing sources is 4ulJust 15, 198(+; new sr>llrces must comply on the (late they berlin operation. Table 3.2 presents the TTO pretreatment standards for both existiny an3 new sources ft-)t- each of the regulated core processes and anti 11ary operations. Req la ed IUs subject t., this rec_)ulation :nust sa.mple and analyze for a-.1 the above compounds unless they r?lect to use the oil and greac;t: .llternative; they can not -- sample and analyze for those compounds which are reasonably espl--:telI to be in their wastestreams. 111s qust su!>mit their TTO or oil anil r;lrease sampling and analysis results in their RMRs drrld in their 90-day compliance rep,>rts. The applicable sampling frequency for these two reports is found in Sections 2.1 and 2.3 of the marlual, respectively

. Monitoring fre,Juency for TTO or c-,i1 arid qrease in their semi-annual c21-1plisnce reports will be *established !)y the Control Authority. Section 468.01(b) of the Copper Forming regulation limits the applica:>ility of the existing source and new source pretreatment +,tandards for drawing spent lubricant discharges (40 CFR Section 4Gd.l4(c) and 468,15(c) 1. These standards only apply to those copper forming facilitit!s which actually discharge this spent lubricant wastestream to their POTW. These starrl:Iards do not apply when this spent lubricant is hauled off-site for disposal? 1s otherwise not discharqed from the facility.

3-6Subpart A copper or Max. for copper lllay any I dey

.. Nat Rollln(l Spwt Lubr lcent hot rolled

b. Cold Rolling Spent Lubrlcent cold rolled

c. Drewlng Spent Lubrlcent drew

d. Solutlon beet treetwnt heat treeted 0.419 0.219 12.920 7.752 0.219 6.b60

C. Cxtruelon beet treatunt

f. Anneellng ulth water hcet treeted on an lxtrualoe prceo lnneeled ulth vater g. Annceling vlth lnneeled vlth 011 all h. Alkellne Clcmlng Rlnre 1. Alkellne Cleenlng Illnee for forged perte J. Alkmllnc Clrnnlng lath llkal Ine cleened llkeltne cleaned

k. Plckllng Rlnee 1. Plckllng Rlnee for forged perte

l . Plckllng beth

n. Plckllng rum scrubber rlkrllne cleaned plcklcd forged prrte plckled plckled plcklcd

o. Tumhllng or llurnlehlng p. Surfncc Cortlng tumblcd or burnlrhed surface coated

,. Ml*ccllrncour Ueatestreems formed TABLE 3.2
Mghff-Kg or Ibe/Mllllon off-lb6 of lT0 COPPERFORHINC CATECORT TTOANDOIL ANDCREASE STANDARDS PSLS 011 6Creaee

0.066 Monthly Flax. for Monthly Mar. for Monthly Mar. for Honthlr

max. fwg. any 1dry .*x. lug. lny 1dey u-x. mq. my I de7 max. aufl. 0.035 2.060 1.236 0.015 I.OlO

0.216 0.120 1.500 1.548 0.1211 J.790

o.oss 0.020 1.700 1.020 0.021 0.150

0.0010 0.0006g 0.040 0.02b 0.0006g 0.020

0.006 0.421 2b.mOO 14.ago 0.421 12.400

0 0 0 0 0 0

2.739 1.432 0b.200 SO.560 1.432 b2.140

I.217 4.290 ts2.040 151.704 4.29U 116.410

0.010 0.01s 0.03 0.56 0.015 0.46
o.g4g O.&b4 26.120 15.672 0.191 5.n50 2.s40 I.132 ?ll.J60 47.016 0.596 17.550

0.015 0.406 2.320 1.392 O.OJ9 1.160 12.520 7.512 0.212 6.260

0.170 11.660 6.996 0. I96

0.402 0.019

0.212

0.191

0.252

0.007 14.060 0.916 0.252

0.014 0.4J6 0.261 0.007 5.1)JO

7.430
0.21g
3-7 PSNS lT0 011 6Creeee3.3.2 Alternative to TTO Monitoring

As an alternative to TTO monitoring, regulated IUs may monitor for oil and grease (O&G) and meet the O&Gmonitoring standards. The alternate &G monitoring standards are included in Table 3.2. The maximum monthly average is the same value as the one-day maximum although the monthly values are not shown in the table. Any IU choosing the alternative O&Gmonitoring standards is not subject to the -per Fonning'I70 stand.u-d. Regulated IUs electing to use this alternative must sample and analyze for OSGand submit these results in their BMRs, their go-day compliance reports, and their subsequent semi-annual compliance reports. Additionally, Section 468.03(a) requires that regulated IUs comply with the monthly discharge limit regardless of the number of samples analyzed and averaged. Sampling frequency for BMRs and for go-day compliance reports is discussed in Sections 2.1 and 2.3 of this manual. Sampling frequency for the semi-annual compliance report will be established by the Control Authority. 3.3.3 Sources of Toxic Organics Wastewater from copper forming plants is generated by both the core and ancillary operations. The core operations utilize oil/water emulsions as lubricants to reduce wear on the forming equipment and to prevent adhesion of the copper to the equipment. The spent lubricants become part of the regulated wastestream. Ancillary operations use water and/or oil to cool, clean and rinse the formed metal. Wastestreams from these ancillary operations are also regulated. The lubricants and cleaners used in these operations usually contain one or more of the toxic organics regulated by the Copper Forming regulation as a TTO component.
3.4 ALUMINUM FORMING 3.4.1 TTO Limits The Aluminum Forming category is divided into six subcategories: A) Rolling with Neat Oils B) Rolling with Emulsions C) Extrusion

3-8D) Forging

E) Drawing with Neat Oils F) Drawing with Emulsions. The various processes used by the industry required this division into subcategories based on differences in the methods of production. Each subcategory listed above has pretreatment standards for the core operation and ancillary operations that may be associated with the core process. Each subcategory is discussed separately in this document identifying the core process and noting all sources for contaminated wastestreams. The toxic organic compounds regulated under the TTO standards for each subcategory are listed below. The term "Total Toxic Organics" for this category is the sum of the masses or concentrations of each of the following toxic organic compounds found at a concentration greater than 0.01 mg/l in a regulated wastestream p-chloro-m-cresol 2-chlorophenol 2,4-dinitrotoluene 1,2-diphenylhydrazine ethylbenzene fluoranthene isophorone napthalene N-nitrosodiphenylamine phenol benzo(a)pyrene benzo(ghi)perylene fluorene phenanthrene dibenzo(a,h)anthracene indeno(l,2,3,-c,d)pyrene pyrene tetrachloroethylene toluene trichloroethylene endosulfan sulfate bis(2-ethyl hexyljphtalate diethylphthalate 3,4-benzofluoranthene benzo(k)fluoranthene acenaphthylene anthracene chrysene di-n-butyl phthalate endrin endrin aldehyde PCB 1242, 1254, 1221 PCB 1232, 1248, 1260, 1016 acenaphthene

Table 3.3 presents the applicable TTO limits for each subcategory. The final compliance date for the pretreatment standards for existing sources was October 24, 1983; new sources must comply on the date they begin operating. The sampling frequency which the regulated IUs must use for TTO or oil and grease sampling for its BMRand go-day compliance report is specified in Sections 2.1 and 2.3, respectively, of this manual. For these two reports, all the toxic organics listed above must be analyzed for. The IUs will only sample and analyze TTO for inclusion in these reports if they elect, not to use the available alternative described in the next section. If they elect to use the oil and grease alternative, then they must report their oil and grease sampling and analysis results in these reports.

3-9TABLE 3.3 AI.IR(1NlJM FnRHlNC

CATtCnAY ?-fO ANDOIL ANDCREASESTANDARD%

Subprrt A: RollingwIth Heat 0118 __---- Core1 --- Core vlthaut lnAnneallog Furnace Scrubber Core vlth an Annealing Furnace Scrubber Degreaslng
Sawing Opererlonr Ancillary Proceamear Conrlnuouo Sheet Cmtlng 50l~i 1.16,Ilrat trcotment Clcanlng or Ctchlng Bath HK/Of f-Kg or Ih/Hlllton off-lb of alUmlnU= l-TO Her. for .ny I day 011 4CreneeAlternatIve Parameter Mar. for Max. for .ny I day Monthly avg. l-m OIL ACrcarr - Altrrn.lt Ivr Hmx. for He*. for any I drv awl Has. ~1 day for Monthly Avrr.lrv

Spent Lubr Icant rolled with neal ollm 0.051 I.64 0.98 0.051 n.nl?
Spent Lubr Icant Scrubber Liquor Spent Solvent Spent Lubr Icant rolled vlth orat olle 0.034
part of core proccmr part of core procera --

-- 1.11

--

-- 0.67 O.OM 0.54

--

-- --

--

Spent Lubricant Cnnrrrt Cooling Water Bath Water Rlnrr Water cast 0.0014 0.040 0.024 0.0014 0.20 quenched 1.41 40.74 24.45 I.41 20.31 cleaned or etched 0. I24 3.58 2.15 O.I24 1.19 cleaned or etched 0.96 27.a2 lb.69 0.96 13.91 cleaned or etched 1.M 38.7 23.20 1.34 19.33 ctrsning or Ctchlng Scrubber Scrubber Liquor Subpart 6: Rolling with Cmulrlonm Core: IlollIng ulth Culrlona Spent CNlslonr Swing Spent Lubrleent Ancillary Proceaaer Direct Chill Cmtlng Contact Coollm# Water Solut Ion lieat troatwnt Contact Cwllmg Wetor Clcmlng ,or Ctchlng Bath Bath Yator Clcenlng or Etchlnc Ilnee Rlnao Uatmr rl-dnlng or ttchly Scrubkr Sccrrbber Llqwr rolled vlth eulrlono part of core

cmmt qwnched chew4 or etched
clwwd or etched clwwd or 8tdud 0.090

--

0.92 1.41

0.124
O.%

1.34 PSES

2.60

-

26.58 40.14 3.58 21.82 38.66 1.56

t5.w 8.82
24.44 1.4;
2.15 0. I24 16.49 0.96 23.20 1.w --

0.90 PSNS

1.m

3-10TABLE 3.3 (cont.)

Suhpert C: Cxlrllnlon -- Core: CxtruBlon

llcgrr~rlng Seulng Die Clcenlng
Ancillary Proccrree Direct Chill Csstlng Frers lIeat Treatment

Solut Ion llcat Treatment Cleaning or Etching Bath Clrnnlng or Etching Rlnme DummyBlock Coollng w4ter

Spent Solurnt Spent Lubr Icmt garb and Rlnee Water Scrubber Llquor

Contwt Cooling Water Contact CoolInK Water Contect Cooling Water 8ath Water Rinse Water Clrn,(n?. *>IEcrhlng Scrubber Scrubber Llquor Stohp*rt D: Fnrglnfi Corr: Forfil”l. e-e l)rErr.,*lng Spent Solvent S.,Vlnl! Spent Lubrlrrnt

Ancl IInry Proccsaes - .- ------. Forp.111~ Srrllhher Llquld Scrubber Llqoor S0lllt Ion Ilrrt Treatment Contrct Cooling Water Clc~nlnK or Etching geth Ilath Water ClrnrrlnK or Etrhlng Klnse Rlnse Water t:l-,ntn~ or FtchlnK Scrubber Scrubber Llluar HR/Of I-KK or lb/Mllllon off-lb of #lWi~ll~

extruded 0.21 6.70

herd alloy alum. extruded pert of core pert of core pert of core I.02 29.56

-- --

-- --

-- --

cast 0.92 26.31 IS.95 0.92 11.79 quenched I.41 40.74 24.15 I.61 20.3? quenched I.41 40.74 24.45 I.41 20.37 clemed or etched 1.24 3.50 2.16 0.126 I. 19 cleaned or etched 0.96 27.02 16.69 0.96 13.91 cleaned or etched 1.34 38.66 21.20 1.34 19.3)

forged pert of core prrt of core

forged quenched cleaned or etched cleaned or etched clowned or etched PSPIS

TTO 011 LCrcarcAlternaclve Perrmeter Hnm. for Mar. for Mar. for any I dny any I dsy Monthly avg.

4.07

17.74

--

--

--

0.035 I.OO

-- --

-- --

0.065 1.19 1.41 40.74 0.121 3.58 0.96 27.82 I.34 38.66 3-11 0.60

--

--

I.13 O.ll65 0.95 24.45 I.41 20.17 2.15 0. I24 1.79 16.70 0.96 13.91 23.20 I.I4 I?.)1 l-m Mar. for any I day

l-l.24

0.21

--

--

--

n.035

--

-- PCNS

-

011 6 Cresor - Attrrnallvr Max. for nr,y t Ilay ad Har. for Monthly AvrraRr __-

1.40

2.9A

--

-_

--

0.50

--

--TABLE 3.3 (cont.)

rscs rSNs

Subpart tr Drevlng with Weat 011s Core: Drewlog vlth Neat OJJe Degrrrrlng Saulng Ancillary Procermr Uaetcntrcrro

Spent Lubr Icant Spent Solvent Spent Lubricant HK/nff-Kg or lh/Hllllon off-lh of llu=Jnur 011 LCreasel-To Altcrnatlve Parawtrr l-f0 011 b Crrrrc - Altcrnat Ivr Mar. for Mar. for Mrs. for Mns. for IlaX. for my I dry nwl Mar. .n, I day any I day Monthly lvK. any I day for Honthlr Avrr.*r!- -- -__-

drawn with neat olle 0.035 I.00 part of core part of core 0.60

Cont Jnuoue Rod Certlng Spent Luhrlcent rod camt Cont lnuour god Carting Contart Coaling Ueter rod quenched Solution Meat frc4twnt Contmct Cooling thtar rod quenched Cleaning or Ctchlng gath Oath Water cleaned or etched CI*~nlnr nr Ktrhlng Rlnme Rlnmc Water cleaned or etched Clcnnlng or Ltchlng Scrubber Scrubher Liquor Suhrnrt r: ~rrvlnK vlth Cn~lslonm or Soaps cleaned or etched 0.0014 0.40 0.024 0.0014 0.133 3.87ll 0.134 0.072
1.41 40.14 2b.45 I .&I
0.124 3.50 2.15 0.125
0.96 27.82 16.70 0.96
1.33 38.66 23.20 I.34 0.021)
I.04
20.31
1.79 II.91
19.31

Core: -- drawn 0.32 9.33 5.60 0.32 4.61

Ih-Arr**lnK Spent Solvent SnwlnK Spent Lubrlcrnt

Ant IIlorry Frnccrner Contlnunur Kod CaatJng Spent Lubrlcent rod caet
Cnnt Immum Rod Cant lng Contact Cooling Vater rod quenched Sotut Ion Ilcat Trcatrnc Contact CwJJng Meter rod quenched Clcnnlny. or Etching Bath Bath Water cleaned or etched Clcnnlng or Etching Rlnme Rlnre Yntcr cleaned or etched Clernlng or Ktchlng Scrubber Scrub&r Ltquor cleaned or etched 0.0014 0.040 0.024 0.0014 0.02n 0.134 3.m 2.33 0.134 1.94 1.34 60.11 24.44 I.41 20.11
0.124 3.58 2.15 O.l24 I.?9
0.96 27.82 16.69 0.96 13.91 I.33 38.66 23.20 1.14 19.13 0.035 l.9(

3-123.4.2 Alternative to TTO Monitoring

Section 467.03(b) of the Aluminum Forming regulation provides regulated IUs with an alternative to TTO monitoring. The regulated IUs may measure and limit oil and grease (O&G) to the limits specified in Table 3.3. For BMRs and 90-day compliance reports, IUs must use the sampling schedules discussed in Section 2.1 and 2.3 of this manual. For the required semi-annual progress reports the Control Authority will establish the appropriate sampling schedules. 3.4.3 Sources of Toxic Organics The sources of toxic organics in the Aluminum Forming category are similar to the sources described for Copper Forming: lubricants and emulsified oils and associated degreasing/cleaning agents contain the regulated toxic organic compounds. This section briefly describes the operations of each subcategory as an aid in determining where the toxic organics originate in the wastewater discharged to the POTW. Subpart A: Rolling with Neat Oils This rolling operation uses cast aluminum ingots to form a variety of end products. Neat oils such as mineral oils or kerosenebased lubricants are applied to the rollers to prevent wear and adhesion. Coolants are sprayed directly onto the metal and the rollers to maintain a uniform operating temperature. The coolants and lubricants are collected, filtered and recycled: spent material is continuously bled or periodically batch dumped to the wastestream. Annealing furnaces can utilize wet scrubbers to control the atmospheric gases during the annealing process. The discharge of scrubber liquor results in a regulated wastestream. Wastestreams from degreasing and sawing operations containing spent solvents and lubricants are also considered in the core operations. Ancillary operations that produce wastestreams are continuous sheet casting and solution heat treatment contact cooling water, and cleaning or etching liquids, including the scrubber liquor. Subpart B: Rolling with Emulsions The rolling with emulsions process is very similar to rolling with neat oils. In this subpart, the coolants and lubricants used are oil/water emulsions that range from lo-15 percent oil. This process also uses lubricants in sawing operations. Annealing furnaces are not utilized although other heat treatments may be employed. Ancillary operations that produce contact cooling water wastestreams include solution heat treatment and direct chill casting. Cleaning or etching operations are also performed.

3-13Subpart C: Extrusion

This process uses pressure exerted on a cast aluminum billet to form the desired product. The aluminum is generally heated, extruded, and then subjected to heat treatment. Lubricants are used on the ale and the ingot container walls to prevent adhesion. However, in cold extrusion the walls and billet surface are lubricated with a thin film of viscous or solid lubricant. Occasionally, liquid nitrogen will be used in place of an oil-based lubricant. Contact cooling water applied to the product after extrusion carries away some of the lubricdnt that has not been vaporized. Die cleaning also produces a wastestream through the dressing and repair of dies. f\ncillary operations producing contaminated wastestreams include: contact cooling waters from direct chill casting, press heat treatment, solution heat treatment and wastewater from cleaning, etching, and scrubber liquor. Subpart D: Forging Forging consists of applying compression to hot aluminum to form the desired shape. Colloidal Graphite in water or oil is used as a lubricant for the dies. Although it is a dry process, smoke and particulate matter from partial combustion of the lubricants may require air pollution controls. If wet scrubbers are used to control the emissions they are considered part of an ancillary operaticIn and their wastewater is regulated. Additionally, all solution heat treatment and cleaning or etching wastewaters are regulated. Subpart E: Drawing with Neat Oils Drawing is a process of pulling metal through a series of dies to reduce its diameter. Lubricants are used on the dies to assure uniform drawing temperatures and to reduce wear on the dies. As in Subparts A and R, the difEerence is in the lubricants and coolants used in the process. Oil based lubricants are generally used for heavy draws (higher reduction in diameter), oil in water emulsions and soap solutions are used for some of the lighter draws. Annealin is required between ljraws. The metal is degreased prior to annealing so that the lubricant will not burn in the furnace. Solution heat treatment is also used, and is considered an ancillary operation along with continuous rod casting and cleaning or etching. 3.5 COIL COATING CATEGORY 3.5.1 TTO Limit The only TTO pretreatment standard in the Coil Coating Category is in Subpart D - Canmaking Subcategory. Within the subcategory, only the manufacture of seamless can bodies which are washed is regulated. Since no wastewater is generated from the three other manufacturing processes included ir the subcategory, they are
3-14exempted from all effluent limitations. These exempted processes

include: (a) manufacture of seamed cans, (b) manufacture of seamless cans fro71 coated stock, and (c) manufacture of can ends and tops. The limits promulgated for this category are production-based mass limits. The fourteen (14) toxic organics regulated under this category are: l,l,l-trichloroethane Pentachlorophenol l,l-dichloroethane Bis (2-ethylhexyl) phthalate 1,1,2,2-tetrachloroethane Butyl benzylphthalate Bis (2-chloroethyl) ether Di-N-butyl phthalate Chloroform Phenanthrene 1,1-dichloroethylene Tetrachloroethylene Methylene chloride (dichloromethane) Toluene Compliance with the TTO limit is demonstrated by summing the mass of the individual toxic organic compounds present in the regulated wastestream in concentrations above 0.01 mg/l. This summation is then compared with the TTO standard to determine the IU's compliance status. Both a maximum daily limit and a maximum monthly average have been promulgated. Roth limits must be met to achieve compliance. Table 3.4 presents the TTO limit for existing sources (PSES) and for new sources (PSNS). The compliance date for the PSES TTO limit is November 17, 1986. For the PSNS limit, it is when the new source commences its discharges. The sampling schedule for the IU's BMRand 90-day compliance report is found in Sections 2.1 and 2.3, respectively in this manual. All 14 toxic organics must be analyzed for unless the oil and grease alternative discussed in the next section is adopted by the IU. TABLE 3.4

COIL COATING - SUBCATEGORY D (CANMAKING) TTO AND OIL AND GREASE STANDARDS
Maximum Daily Maximum Monthly Average1 g/l 06 lb/lo6 g/l 06 lb/lo6 Pollutant cans manf. cans manf. cans manf. cans manf. PSES TTO 26.85 0.059 12.59 0.028 PSES O&G 1678.00 3.699 1006.80 2.220 PSNS T'I'O 20.35 0.045 9.54 0.0210 PSNS O&G 1272.00 2.804 763.20 1.683

1 Compliance is required regardless of the number of samples analyzed and averaged.

3-153.5.2 Alternative to TTO Monitoring

As an alternative to TTO, regulated IUs may elect to monitor for and comply with the O&Gstandards listed in Table 3.4 above. IUs subject these O&Gstandards, will not be subject to the TTO standards. Again the BMRand go-day compliance report sampling frequencies are discussed in Section 2.1 and 2.3, respectively, of this manual. Sampling frequencies for the semi-annual compliance reports shall be established by the Control Authority. Specific to this regulation is the Oil and Grease analytical method promulgated on November 17, 1983 (40 CFR Section 465.03(c); 48 FR 523991. Corrections were promulgated on April 10, 1984 (49 FR 14104). The corrected method is presented in Appendix E. Any IU electing to use the O&Galternative must use this methodology in determining the amount of hydrocarbon oil and grease in each sample analyzed. 3.5.3 Sources of Toxic Organics The 14 regulated toxic organics commonly occur as constituents in lubricants, solvents, and surface coatings. A recommended approach in identifying toxic organic sources is to compare the labels of these products to the list of regulated toxics above. Substitute compounds can often be found for these polyaromatic hydrocarbons and organic solvents, thus avoiding their use and introduction into the wastestream. Introduction of toxic organics into the wastestream entering the POTWcan occur from poor production/process management such as the dumping of spent solvents, sloppy use of lubricants and surface coatings, and release of highly contaminated rinse waters. Storage area spills entering through floor drains represent another possible source of toxic organic introdution into the POTW.

3-164. GUIDANCE FORTHE PREPARATION OF A TOXIC ORGANIC MANAGEMENT PLAN

As previously discussed, one alternative to routine TTO monitoring is the preparation of a toxic organic management plan (TOMP). This option is available to regulated industrial users in the Electroplating, Metal Finishing, and Electrical and Electronic Components (both Phase I and Phase II) categories. A TOMPmust specify the toxic organic compounds used, the method of disposal used (instead of discharge into wastestreams), and procedures for assuring that toxic organics do not routinely spill or leak into wastewater discharged to the POTW. Guidelines for preparation of a TOMPare presented below as four basic steps: Step 1 - Process engineering analysis A process engineering analysis should be conducted to determine the source and type of toxic organic compounds found in a facility's wastewater discharge, including sources and compounds that could reasonably be expected to enter the wastewater in the event of spills, leaks, etc., based on the type of operations conducted at a particular plant. Such an analysis should be based on the results of one or more analyses of the plant's wastewater for the toxic organic pollutants which are included in the definition of TTO for that industrial category and which can reasonably be expected to be present (see TTO monitoring guidance). The process engineering analysis should include:
a.
b.

c.

d.

e.

f. An examination of published reports on the specific industry; A water flow diagram to identify all possible wastewater sources; A list of raw materials used in the industrial processes, including chemical additives, water treatment chemicals and cleaning agents, and the wastewater stream that each regulated toxic organic could potentially enter: Comparison of the toxics found in the effluent with the list of raw materials and selection of the most probable wastewater source; Evaluation of the toxics found in the effluent, but not on the raw materials list and determination of thoseformed as reaction products or by-products; Examination of sources such as equipment corrosion or raw materials' impurities that could result in release to wastewaters of toxic organic pollutants.

4-1Step 2 - Pollutant control evaluation

An evaluation should be made of the control options that could be implemented to eliminate the toxic compound(s) or the source or potential source of toxic organic compound introduction to the treatment system. This may include in-plant modifications, solvent or chemical substitution, partial or complete recycle, reuse, neutralization, and operational changes. The analysis should be conducted on a case-by-case basis and will often result in one or more feasible options to control each source or potential source of toxic pollutant discharge. Finally, evaluation of the available control options, including the advantages and disadvantages of each, may lead to a decision of whether a TOMP is a feasible alternative to TTO monitoring. Step 3 - Preparation of Toxic Organic Management Plan A toxic organic management plan should include the following items at a minimum:

a.

b.

C.

d. A complete inventory of all toxic organic chemicals in use or identified through sampling and analysis of the wastewater from regulated process operations (organic constituents of trade-name products should be obtained from the appropriate suppliers as necessary); Descriptions of the methods of disposal other than dumping used for the inventoried compounds, such as reclamation, contract hauling, or incineration; The procedures for ensuring that the regulated toxic organic pollutants do not spill or routinely leak into process wastewaters, floor drains, non-contact cooling water, groundwater, surface waters (i.e., Spill Prevention, Control, and Countermeasures (SPCC) Plan) or any other location which allows discharge of the compounds; and Determinations or best estimates of the identities and approximate quantities of toxic organic pollutants used as well as discharged from the regulated manufacturing processes. Compounds present in wastestreams that are discharged to sanitary sewers may be a result of regulated processes or disposal, spills, leaks, rinse water carryover, air pollution control, and other sources.

4-2Step 4 - Submission of Toxic Organic Management Plan and Certification Statement The TOMPshould be submitted to the Control Authority at the time the baseline monitoring report is required if the IU's initial election is to choose this option. Alternatively, an IU may submit a TOMP at any later time and request that TTO monitoring requirements be discontinued upon approval and implementation of the TOMP. A prerequisite for use of this certification approach is a fully approved, implemented, and ongoing toxic organic management plan. In addition, a certification statement must be included at the time of submission of the TOMPand with each subsequent IU report (i.e., semi-annual compliance report). It must be signed by an officer of the company or manager responsible for overall plant operations. A statement such as the following should be required. "Based on my inquiry of the person or persons directly responsible for managing compliance with the TTO limitations, I certify that, to the best of my knowledge and belief, no dumping of concentrated toxic organics into the wastewaters has occurred since filing of the last report. I further certify that this facility is implementing the toxic organic pollutant management plan submitted to the Control Authority on (date to be specified).

(date) (Officer)

If the user is unable to make the above certification statement, the user should notify the Control Authority sixty days (60) prior to the due date for filing the compliance reports. At that time, the Control Authority should determine the appropriateness of requiring sampling and analysis for specific toxicants and notify the user accordingly. A sample Toxic Organic Management Plan and certification statement are included as Appendix D.

4-35. APPLICATION OFTHE COMBINED WASTESTREAM FORMULA

One provision of the General Pretreatment Regulations that will often be necessary for POTWs and industries to use for proper monitoring and reporting on compliance with an applicable TTO limit is the Combined Wastestream Formula (CWF) [40 CFR 403.6(d)]. The CWFis a mechanism for calculating alternative limitations when regulated wastestreams are mixed with unregulated or dilution streams. The CWFis applied to the mixed effluent to account for the presence of the additional wastestream. The following definitions and conditions are important for properly using the CWF. 5.1 DEFINITIONS

• Regulated Process Wastestream - an industrial process wastestream regulated by a national categorical pretreatment standard.

• Dilute Wastestream - Boiler blowdown, sanitary wastewater, noncontact cooling water, and certain process wastestreams that have been excluded from regulation in categorical pretreatment standards because they contain none of the regulated pollutant or only trace amounts of it.

• Unregulated Process Wastestream - any wastestream that is neither a regulated nor a dilute wastestream Note: Definitions apply to individual pollutants. A wastestream from a process may be "regulated" for one pollutant and "unregulated" for another. Example cases are presented later in this section to illustrate these distinctions.

• Concentration-based Limit - a limit based on the relative strength of a pollutant in a wastestream, usually expressed in mg/l.

• Production-based Limit - a limitation based on the actual quantity of a pollutant in a wastestream per unit of production. 5.2 CWFCONDITIONS To ensure proper application of the CWF, the following conditions must be met by a municipality and its regulated industries [40 CFR 403.6(d)]:

• Alternative discharge limits that are calculated in place of a categorical pretreatment standard must be enforceable as categorical standards.

5-1• Calculation of alternative limits must be performed by the Control Authority.

• Alternative limits must be established for all regulated pollutants in each of the regulated processes.

• The Control Authority and/or the industrial user may use production-based limitations in place of the concentrationbased limitations, when they are provided by a given categorical pretreatment standard such as electroplating or porcelain enameling.

• Both daily maximum and average (e.g., monthly) alternative limits must be calculated for each regulated pollutant, as required. [The TTO standard is generally only a daily maximum.]

• If process changes at an industry warrant, the Control Authority may recalculate the alternative limits at its discretion or at the request of the industrial user. The new alternative limits must be calculated and become effective within 30 days of the process change.

• The Control Authority may impose stricter alternative limits, but may not impose alternative limits which are less stringent than the calculated limits.

• A calculated alternative limit cannot be used if it is below the analytical detection limit for that pollutant. If a calculated limit is below the detection limit, the industrial user must either: 1) not combine the dilute streams prior to the sampling point, or 2) segregate all wastestreams entirely. 5.3 CALCULATION OF ALTERNATIVE TT0 LIMITS USING THE CWF The actual combined wastestream formula is presented in Table 5.1. When used for determining alternative TTO limits, the TTO limit for the applicable categorical standard (i) is presented in both the equations by Ci and Mi. The individual organic compounds that make up the TTO value vary depending on the applicable categorical standard. For example, for Copper Forming industries, TTO refers to the sum of 12 individual organic compounds, whereas for Aluminum Forming industries, TTO refers to the sum of 39 individual organic compounds. (Only six organic compounds are common to both industrial categories). The CWFwill only determine an alternative TTO value, independent of the individual organic compounds needed for each TTO limit. Therefore, if an industry has combined wastewater discharges from processes regulated by

5-2TABLE 5.1 COr!INED WAS?ESfEM

Al:crnaclvc Concentration Limit Formula:

/ N 7 

### I - c - l-1 

### t N 

### \- f i-1 

# SF1 Fi \

/ X FORHULAS



# /Ft-Fd 

# \ Ft \ (Eq. 5-l)

/ 

# ct - alternative concentration limit for the pollutaa:
5 - Categorical Pretreatment Standard concentration limit for the pollutant in regulated stream i
Fi - average daily flov (at least 30 day average) of regulated atream i

‘d - average daily flov (at least 30 day average) of dilute vasttstrtam(a)

Ft - average daily flov (at least 30 day average) through the combined :rea:ment facility (including regulated, unregulated and dilute uas:estreans) H - total number of regulated stream8

A?:crnace YISS Limit Formula
/ ‘t - ‘d \ N
\ f. 1-l Fi / (Eq. 5~-2)

Yc - alcernatlvt mass limit for the pollutant
Hi - Categorical Pretreatment Standard MIS limit for the pollutant in regc!ateC stream i
Fi - average daily flov (at least 30 day average) of regulated atraam i
Pd - average daily flov (at least 30 day average) of dilute vasttstrtao(s>
Fw - average daily flov (at least 30 day average) through chc combined - --ea -- tzenz facility (inc1uCir.g regulated, unrcgu:a:ed and dilute uas:estreamj $ - ;c:21 7.2:-,ber of regulitec streams.
5-3different categorical standards with specific TTO limits, the

alternative TTO limit calculated using the CWFwould refer to the sum of the individual toxic organic compounds that make up the TTO limit in each of the categorical standards. Thus, in the example given above, the alternative TTO limitation calculated by using the CWFwould be monitored by analyzing for all 45 toxic organic compounds regulated by one or both of the categorical standards (Copper Forming and Aluminum Forming) and summing the concentrations greater than 0.01 mg/l. 5.3.1 Example Calculation for Alternative TTO Limits Using

the CWF Following are three examples of how the CWFis used to calculate alternative TTO limits. The examples assume mixing prior to treatment of the following process wastestreams at an industrial facility:
Wastestream Flow Daily Max. Compliance Industrial Category Type (mgd 1 TTO Limit Date Metal Finishing Regulated 0.1 4.57 mg/l June 30, 1984 (Etching11 2.13 mg/l Feb. 15, 1986 Aluminum Forming Regulated 0.075 0.123 mg/l Oct. 24, 1986 (Forging: Etching off-kg3 BathI Sanitary Waste Dilution 0.05 N/A N/A
1 This is not a subcategory but a metal finishing process. 2 Aliminum Forming, Subpart D - Forging, Subcategory - Cleaning or Etching Bath. 3 Off-kg means the mass of aluminum removed from a forging or ancillary operation at the end of a process cycle for transfer to a different machine or process. Examples 1 and 2 are applicable in all cases because they reflect the situation prior to the Aluminum Forming final compliance date. Example 3 is applicable after the Aluminum Forming final compliance date when the IU does not use the Aluminum Forming oil and grease alternative. Example 4 is applicable after the Aluminum Forming compliance date when the IU does use the Aluminum Forming and the Metal Finishing TTO alternative. In this example, the CWFmust be used to calculate both an alternative TTO and an alternative oil and grease limit.

5-4Example 1: Calculation of alternative TTO discharge limit for an

integrated industrial facility from June 30, 1984 (compliance date for Metal Finishing, interim TTO limit) until February 15, 1986 (compliance date for Metal Finishing, final TTO limit).

Metal Finishing Aluminum Forming (Etching) (Forging) (Etching Bath) Sanitary Waste

Q= 0.1 mgd Q= 0.075 mgd TTO = 4.57 mg/l TTO = N/A I I Q= 0.225
Treatment Q= 0.05 mgd TTO = N/A

Q= Flow TTO = Applicable TTO Categorical Standard

A concentration limitation is being calculated. Therefore, Equation 5-1, Table 5-l is used. The flow from the Metal Finishing process is considered a regulated wastestream since it is subject to a TTO pretreatment standard. The flow from the Aluminum Forming operation is also subject to a TTO pretreatment standard. The Aluminum Forming flow, however, is at present considered an unregulated wastestream, since the compliance date for Aluminum Forming Standards (October 24, 1986) has not yet arrived. The sanitary waste is considered a dilute wastestream. The alternate TTO limitation is, then, calculated as follows:
TTOcwf = (4.57 mg/l x 0.1 mgd) X (0.1 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd)

0.1 mgd 0.225 mgd TTOcwf = 3.55 mg/l

Rather than monitor TTO to determine compliance with this alternative limit, the owner/operator may elect with the Control Authority's approval to exercise the available alternative under the Metal Finishing regulation, the certification procedure incorporating a toxic organic management plan. For an integrated facility subject to a TTO standard with this alternative, and

5-5electing to use the alternative, the required solvent management

plan should focus on the entire facility, not just on the regulated metal finishing operation(s). However, the Control Authority must still use the CWFto develop the alternative limit for its necessary monitoring activity. When the Control Authority conducts sampling and analysis to verify continued compliance, it will compare its sampling results with 1.he applicable alternative TTO limit developed using the CWFas in Example 1. Example 2: Calculation of alternative TTO discharge limit for an integrated industrial facility from February 15, 1986 (compliance date for Metal Finishing, final TTO limit) until October 24, 1986 (compliance (late for Aluminum Form:ng).



## I Metal Finishing Aluminum Forming Sanitary Waste (Etching) (Forging) (Etching Ra:h)

Q= 0.1 mgd Q= 0.075 mgd TTO = 2.13 my/l TTO = N/4 Q= 0.05 mgd TTO = N/A 

# IQ = 0.225 Q= Flow Treatment TTO = Applicable TTO Categorical Standard The difference between this example and the previous one is that the metal finishing wastewater is now subject to a more stringent limitation. Since the compliance date for aluminum forming has still not arrived it is still considered unregulated.
TTOcwf = (2.13 mg/l x 0.1 mgd) X (0.1 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd)

0.1 mgd 0.225 mgd TTO,,f = 1.66 mg/l
In this example, the use of the TTO alternative available under the Metal Finishing regulation follows the guidance discussed in Example 1.

5-tExmple 3: Calculation of alternative TIOdischarge limit for an integrated

industrial facility after October 24, 1986 (corrpliance date for Aluninun Formiry) whenthe Alminun Forming oil andgrease alternative is not used. Wcause the TTOlimit for Aluninun Forming is expressed as aproductionbased limit, the first step necessary is the conversion of the production-based ?TOlimit to the equivalent concentration-based 'IT0 limit. Basedon the following production data for the industry: Alminun Forming (Forging: Etching Bath) = 0.12 mg/off-kg of aluninun forged Maximm Daily Limit for TID Average Daily Production IXrirq Previous = 85,000 off-kg of aluninm forged 12Wnt.hs per day Average Daily Water Usage in Forging IZlring Previous 12Rmths = 75,000 gpd
,The conversion of production-based TTOlimit to aconcentration-based ?To limit is as follows: TTtJ(concentration = (Production-Based Limit)(Ava. Dailv Production)

Onceequivalent) (Avg. Daily Flow Fran Regulated P&ess)lConversion Factor) (concentration = (0.123 r&off-kg)(85,000-kg/day) =0.037 mg/l equivalent) 75,000 gpd (3.785 liters/gallon)
the equivalent concentration-based TIY)limit is determined the alternate limit can be calculated as follows (aluninun forming wastes are nowa regulated wastestream) :

Metal Finishing Aluminun Formirq Sanitary Waste (Etching) I Q=0.1 mgd 'ITO=2.13 mg/l (Forging) I I (Etching Bath)

Q= 0.075 nqd Q=0.05 mgd T-IO= 0.037 nq/l ?To=N/A

Q=0.225
Treatment

5-7TTOcwf = (2.13 w/l x 0.1 mgd) + (0.037 mg/l x 0.075 mgd) (0.1 mgd + 3.075 mgd) X (0.1 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd) 0.225 mgd TTOcwf = 0.96 mg/l
Note: The alternate TTO discharge limit is based on Metal

Finishing and Aluminum Forming Categorical Standards and is proportioned by the flow of both the regulated wastestreams. Due to dilution from sanitary waste, the alternate discharge limit is reduced. The TTO limit is the sum of the cor.centrations of the toxic organic compounds listed in the Metal Finishing and Aluminum Forming regulations, respectively, and found in the facility's discharge in concentrations greater than 0.01 mg/l. In this example, all Aluminum Forming TTO constituents and those Metal Finishing TTO constituents reasonably expected to be present must be analyzed for. Example 4: Calculation of alternative TTO and oil and grease discharge limits for an integrated facility after October 24, 1986 (compliance date for Aluminun Forming) when the Aluminum Forming oil and grease alternative is used. This example presents a somewhat rng>re complicated situation when considering the alternatives to TT3 monitoring. The Metal Finishing regulation provides the alternative certification procedure with a toxic organic management plan. The Aluminum Forming regulation provides alternative Oil and Grease (O&G) limitations. In this situation an industrial facility electing (with its Control Authority's approval) to exercise the TTO monitoring alternatives should proceed as follows. First, the owner/operator must make the necessary certification and develop and implement a toxic organic management plan (TOMP) as required by the Metal Finishing regulation. The TOMP should apply to all operations and facilities where toxic organics may enter the sewer. Then, the CWFmust be used to develop the alternative TTO limit. Example 2 should be used in this calculation because the Aluminum Forming wastestream is considered "unregulated" for TTO because the IU is using the Aluminum Forming oil and grease alternative. Second, the owner/operator using the CWFmust develop an alternative O&Glimitation for his facility. With the Control Authority's approval, the owner/operator can use either the stated production-based 0 &G limitation for developing the alternative limit or convert the given production-based limit to the equivalent concentration-based 0 & G limit and then calculate the alternative limit using the CWF.

5-3Calculation of the alternative 0 & Gproduction-based

limitation for an integrated facility after October 24, 1986 (compliance date for Aluminum Forming) is as follows. In this situation the metal finishing wastestream is an unregulated wastestream because it is not regulated for 0 6 G.

Metal Finishing (Etching) Aluminum Forming (Forging) (Etching Bath) Sanitary Waste

Q= 0.1 mgd Q= 0.075 mgd Q= 0.05 mgd TTO = 2.13 mg/l 1OSG= 3.58 mg/off-kc TTO = N/A
Q= 0.225 mgd
Treatment

O&G= (3.58 mg/off-kg) x (0.1 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd) 0.225 mgd O&G= 2.78 mg/off-kg
When the Control Authority allows conversion to a concentrationbased alternative 0 & Gstandard, the calculation of the alternative 0 & Gconcentration-based limitation after October 24, 1986 is as follows. Again, the metal finishing wastestream is an unregulated wastestream. Because the 0 & G limit is a production-based limit the first step is to convert this limit to its equivalent concentration-based limit. The following is hypothetical production data for the industry: Aluminum Forming (Forging & Etching Bath Maximum Daily 0 & G Limit = 3.58 mg/off-kg of Al forged Average Daily Production During Previous Twelve Months = 85,000 off-kg of Al forged per day Average Daily Water Use in Forging During Previous Welve Months = 75,000 gpd

5-9The conversion of the production-based 0 x G limit to an equivalent

concentration-based 0 & Glimit is 4s follows: O&G (concentration cquivalerlt) = (Production-Based Limit)(Avg. Daily Production) (Avg. Daily Flow From Reg. Process)(Conversion Factor)

= (3.58 mq/off-k )(85,000 off-kg/day) (75,000 qpd) 3.785 liters/qallon)

Now, the a =

lternat

1 Metal Finish I (Etchincl) inq 

# I I I 0 = 0.1 mqd O&G= N/.4

O&Gcwf # (1.07 mg/liter X 0.075 mgd) 1.07 mq/liter

ve 0 6 I; limit can be calculated as follows:

I ) Aluminum Forning I 1 Sanitary Waste I (Forging) I I I I (Etchinq Rat.h) 1 I I I

0 = 0.075 mqd 0 = 0.05 mgd O&G= 1.07 my/l 06G = N/A

0 = (I.225

I I 

# I Treatment

0.075 mqd
x (0.1 mgd + 0.075 mqd + 0.05 mgc - 0.05 mqd) 0.225 mqd

OSGcwf = 0.83 mq/l

S-106. REMOVAL CREDITS
Another provision of the General Pretreatment Regulations that POTWs and industrial users will sometimes use is the Removal Credit Provision. EPA promulgated on August 3, 1984 a revised §403.7, Removal Credits [49 FR 31212). This provision allows POTWs to provide their categorical industrial users with a credit (in the form of adjusted categorical pretreatment standards) for removal of pollutants by the POTWs' treatment systems. Industrial users of such a POTWmay be allowed by their POTWs to discharge greater quantities of regulated pollutants than otherwise permitted by applicable categorical standards. POTWs have complete discretion in deciding whether to grant removal credits to the industrial users after it has obtained the authority to grant such credits from its Approval Authority.

6.1 REMOVAL CREDITS FORTTO The Electroplating, Metal Finishing, and Electrical Electronic Components (Phase I and Phase II), Copper Forming, Aluminum Forming and Coil Coating categorical pretreatment standards regulate TTO discharges to POTWs. POTWsunder §403.7 of the General Pretreatment Regulation can grant removal credits to IUs regulated under any of these standards. Before granting a removal credit to an IU, a POTW must first obtain the authority to do so from its Approval Authority. More complete information on the procedures which POTWs must use to obtain Removal Credit authority can be found in the Guidance Manual for Preparation and Review of Removal Credit Applications (September, 1985). POTWs should carefully consider any decision to seek removal credit authority for TTO. In assessing the appropriateness of a TTO removal credit the following should be considered:

• The specific organic compounds included as a TTO component in each regulation vary from regulation to regulation.

• Toxic organic removal by the POTWmay be for a different mixture of TTO constituents than those discharged by an industrial user.

• Easing of TTO limits in Electroplating, Metal Finishing, and Electrical and Electronic Components contradicts the policy promoting best management practices by the IU and negates the inherent benefits of such practices.

• For the Aluminum Forming, Coil Coating and Copper Forming regulations the Agency has provided an alternative oil and grease standard for easier implementation.

6-1• Most TTO constituents are stripped, not treated, by conventional POTWtreatment (which may be hazardous to POTWworkers and the environment). Based on the previous factors, the Agency does not encourage applications for TTO removal credits.

6.2 REMOVAL CREDITS FORTTO SURROGATE OR INDICATOR POLLUTANTS Section 403,7(a)(2) of the General Pretreatment Regulations states that removal credits may only be given for indicator or surrogate pollutants regulated in a categorical pretreatment standard when the categorical pretreatment standard specifically so authorizes. The Copper Forming, Aluminum Forming and the Coil Coating pretreatment standards regulate oil and grease as a surrogate or indicator pollutant for TTO monitoring. However, none of these regulations specifically authorizes removal credits for oil and grease. Therefore, POTWs shall not grant any oil and grease removal credit to IUs regulated under these regulations.

6-27. TTO MONITORING GUIDANCE

7.1 SAMPLING CONSIDERATIONS The representativeness and validity of industrial user (IU) discharge data is important to ensure compliance with categorical pretreatment standards. Monitoring to assess compliance with TTO discharge standards may involve monitoring simultaneously for several different organic pollutant parameters. Therefore, the validity of TTO discharge data, collected by either the Control Authority performing industrial compliance monitoring or an IU performing self-monitoring, is contingent upon utilization of the proper sampling and analytical procedures. This section will present guidelines and considerations for sampling and analysis of IU discharges to help ensure that a representative and uncontaminated TTO sample is collected and properly analyzed. Much of the following guidance was obtained from documents that address sample collection and preservation and flow measurement. Since this section presents only limited specific guidelines and considerations for TTO monitoring, it is recommended that these references be utilized by the IU and Control Authority to ensure proper sample collection techniques. They include, among others:

• Guidelines Establishing Procedures for the Analysis of Pollutants; Final Rule (40 CFR Part 136) October 26, 1984

• Handbook for Sampling and Sample Preservation of Water and Wastewater, U.S. Environmental Protection Agency, Environmental Monitoring and Support Laboratory, September 1982. Report No. EPA-600/4-82-029. NTIS PB83-124503.

• Methods for Chemical Analysis of Water and Wastes. U.S. Environmental Protection Agency, Environmental Monitoring and Support Laboratory, 1983. Report No. EPA-600/4-79-020. NTIS PB 297686.

• Compliance Evaluation InspectionManual, EPA, Office of Water Enforcement, July 1 1976.

• NPDES Compliance Sampling f Inspection Manual-MCD-51, USEPA Enforcement Division, Of ice of Water Enforcement, Compliance Branch.

7.1.1 Sampling Location The location of sampling points within an industry's pretreatment system or conveyance lines cannot always be specified by general rule as conditions (i.e., processes, rate of production) vary with each industry. Therefore, exact sampling locations must be identified on a case-by-case basis. However, certain general principles can be suggested for both IU self-monitoring and Control Authority monitoring as follows: 7-1• A permanent sampling location(s) should be identified for use by both the Control Authority and industry. This is typically accomplished during a Control Authority inspection of the IU so that both parties agree on and are familiar with the location(s).

• The sampling location should be easily accessible and relatively free of safety hazards (i.e., confined space)

• For categorical industries, there should, if possible, be no discharge present other than from the regulated process. If other wastestreams (regulated, unregulated, or dilution) are combined with the regulated wastestream prior to the sampling location, the combined wastestream formula (40 CFR 403.6(e)) will need to be utilized. Chapter 5 of this manual provides specific guidance for using the combined wastestream formula.

• If the rate of industrial process discharge flow is needed (i.e., where mass limitations are applied), the sampling location will need to be located where the flow of the wastestream is known or can be measured or estimated.

• Repetitive samples (both for IU self-monitoring and Control Authority compliance monitoring) should always be obtained from the same sampling location. 7.1.2 Sample Collection Techniques Generally, there are two types of samples (grab and composite samples) that can be collected either manually or with automatic sampling equipment. Grab samples are individual samples collected over a period not exceeding 15 minutes; the grab sample is usually collected manually. The collection of a grab sample is appropriate when a sample is needed to:

• Provide information about instantaneous concentrations of a pollutant at specific times

• Allow collection of a variable sample volume

• Gather information more quickly than composite sampling allows

• Collect samples for parameters not amenable to automatic sampling (e.g., oil and crease, volatile organics, coliform bacteria). Composite samples consist of: (1) grab samples collected at equal intervals and combined proportional to wastestream flow, (2) samples collected continuously and proportional to wastestream flow, or (3) equal volumes taken at varying time intervals. Composite samples are used when:

• Determining average pollutant concentration during the cornpositing period
7-20 Calculating mass/unit time loadings

0 Wastewater characteristics are significantly variable.
Particular regulated organic pollutants, each of which account for part of the applicable TTO value for an IU, have particular techniques that need to be followed during sample collection. For example, a sample for acrolein must be a discrete grab, whereas a sample for 1,3-dichlorobenzene may be a grab or composite sample. Table 7.1 presents the sampling techniques for all the organic parameters that may be included in an TTOvalue. For those parameters that can only be collected by a grab sample (Purgeable Halocarbons, Purgeable Aromatics, Acrolein and Acrylonitrile), a special sampling technique is used due to their volatile nature. A 40-milliliter glass sample bottle (or vial) should be filled in such a manner that no air bubbles pass through the sample as the bottle is being filled. The bottles then should be sealed so that ho air bubbles are entrapped in it. This hermetic seal must be maintained until the time of sample analysis. It is often difficult to fill the 40 milliliter bottle directly from the wastestream, in which case a larger glass bottle may be used to collect (grab) the sample from the wastestream and transfer the sample to the smaller sample container. It is also important to note that Purgeable Halocarbons, Purgeable Aromatics, Acrolein and Acrylonitrile samples can only be taken as discrete grab samples, and cannot be composited in the field. Compositing of purgeable parameter samples must be performed in the laboratory. 7.1.3 Sample Volumes The volume of samples collected depends on the type and number of analyses that are needed, as reflected in the parameters to be measured. The volume of the sample obtained should be sufficient to perform all the required analyses plus additional amounts to provide for any split samples or repeat analyses. Table 7.2 presents the sample volumes required for all the organic priority pollutants that may be analyzed as part of the TTO value. Note that required volumes are given for analysis of each class of organic compound (which include specific organic pollutants) even if only a specific pollutant analysis is needed. The volumes listed also include the two procedures that analyze for all the purgeable organic parameters and for all the remaining organic pollutant parameters (Acids, Base/Neutrals, Pesticides). It is important that the IU or Control Authority consult the laboratory performing the analysis to determine if any additional sample volume will be needed.

7-3TABLE 7.1 SAMPLECOLLECTIONTECHNIQUESFORORGANICPRIORITY POLLUTANT

Parameter Purgeable Halocarbons (Includes : Btomoform

Bromodichloromethane Bromomethane Carbon tetrachlortde Chlorobenzene Chloroethane Z-Chloroethylvinyl ether Chlorolorm Chloromethane Dibrornochloromethane 1.2~Dlchlorobenzene 1,3-Dichlorobenzene l,O-Dichlorobenzene Dichlorodifluoromethane l,l-Dichloroethane 1,2-Dichloroethane I,l-Dichlhloroethene trans-1,2-DLchloroethene 1.2~Dichloropropane cis-1,3-Dichloropropene trans-l,l-Dichloroporpene Yethylene chloride 1,1,2,2-Tetrachloroethane Tetrachloroethene l,l,l-Trichloroethane 1,1,2-Trichloroethane frichloroethene Trichlotofluoromethane Vinyl chloride)
Purgeable Aromatics (Includes: Benzene

Chlorobenzene 1,2-Dichlorobenzene 1,3-Dichlorobenzene I,&-Dichlorobenzene Ethylbenzene Toluene) Collection Technique Grab Composite X

X

4crolefn and Acrylonitrile X

7-4TABLE7.1 SAMPLECOLLECTIONTECHNIQUESFORORGANICPRIORITY POLLUTANT(Continued)

Parameter Co1lect ion Technique Grab Composite Phenols X X (Includes: 4-Chloro-3-methylphenol

2-Chlorophenol 2,4-Dfchlorophenol 2,4-Dimethylphenol 2-Hethyl-4,6-dinittophenol 2-Nftrophenol 4-Nitrophenol Pentachlorophenol Phenol 2,4,6-Trichlorophenol)

Benzidfnes (Includes: Benzldene

3,3-Dichlorobenzidene)

Phthalate Esters (Includes: Bentyl butyl phthalate

Bis(2-ethylexyl) phthalate Di-n-butyl phthalate Di-n-octyl phthalate Diethyl phthalate Dimethyl phthalate)

Xit rosamines (Includes: N-nitrosodimethylamine

9-nitrosodiphenylamfne N-nitrosodi-n-propylamine) X

X

x X

X

x

7-5TABLE 7.1

jAk!PLECOLLECTIONTECHNIQUESFORORGANICPRIORLTYPOLLUTANT(Continued)

Parameter Collection Technique Grab Composite Organochlorine Pesticides and PCB's (Includes: Aldrin

a-BHC b-BHC d-BHC g-BHC Chlordane i,i-DDD &,&-DDE k,i-DDT Dieldrin Endosul tan I Endosultan II Endosultan Sulfate Endrin Endrin Aldehyde Heptachlor Heptachlor Epoxide Toxaphene PCB-1016 PCB-12'1 PCB-1'37 PCB-l,i2 PCB-lL$d PCB-lJj& ?CB-1'60) x x

Sicrqaromatics and lsophorone (Includes: Isophorone

Nltrobenzene 2,&-Dinitrotoluene 2,6-Dinitrotoluene) x

7-6TABLE 7.1 SAMPLECOLLECTIONTECHNIQUESFORORGANICPRIORITY POLLUTANT(Continued)

Parameter Collection Technique Grab Composite Polynuclear Aromatic Hydrocarbons (Includes: Acenaphthene

Acenaphthylene Anthracene Eenzo(a)anthracene Benzo(b)pyrene Benzo(b)thuoranthene Benzo(g)perylene Benzo(k)fluoranthene Chrysene Dibenzo( a,h)anthracene Fluoranthene Fluorene Lndeno(l,2,3-cdjpyrene Naphthalene Phenanthrene Pyrene) X x

Haloethers (Includes: Bfs(Z- chloroethyl) ether

Bis(..?-chloroethoxy) methane Bfs(L- chloroisopropyl) ether i-Bromophenyl phenyl ether A-ChLJrophenyl phenyl ether)

Chlorinated Hy;irl>carbons !Includes: tiexachlorocyclopentadlene

Aexachlorobenzine Yexachlorobutadiene Hexachloroethane 1,2-Dichlorobenzene I,2,4-Dichlorobenzene 1,3-Dichlorobenzene I,4-Dichlorobenzene 2-chloronaphthalene)
2,3,7,8-Tetrachlorodibenzeno-p-dioxin Purqeables Base/Neutral, Acids and Pesttcides x

X
Source : $0 CFRPart 136 7-7TABLEi.2 SWLE VOLUMESFORORGANIC PRLORITY POLLUTANTANALYSIS*

Parameter Required Minimum Sample Volume (ml) Purgeable Halocarbons (Includes: Bromoform

Bromodlchloromethane Bromomcthane Carbon tetrachloride Chlorobentcne Chlorocthane 2-Chloroethylvlnyl ether Chlorofona Chloromcthane Dibromochloromethane 1,2-Dichlorobenzene 1,3-Dichlorobentene 1,4-Dichlorobenzene Dichlorodlfluoromethana l,L-Dlchloroethane A,2-Dichloroethane l,l-Dichlhloroethene trans-1,2-Dichloroethene 1,2-Dichloropropane cis-1,3-Dichloropropene trans-1,2-Dlchloroporpene Hethylene chloride 1,1,2,2-Tetrachlorocthane Tetrachloroethene l,l,l-Trichloroethane 1,1,2-Trfchloroethane Trfchloroethcne Trichlorofluoromethane Vinyl chloride) 40

Purgeable Aromatics (Includes: Benzene

Chlorobentene 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1,4-Dichlorobenzene Ethylbenzene Toluene) 40

Acrolein and Acrylonitrlle 40

7-8TABLE 7.2 SMLE VOLUMESFORORGANICPRIORITY POLLUTANTANALYSIS* (Continued)

Parameter Required Minimum Sample Volume (ml> Phenola 1,000 (Includes: 4-Chloro-3-methylphenol

2-Chlorophcnol 2,4-Dichlorophenol 2,4-Dimethylphenol 2-Methyl-4,6-dinitrophenol 2-Nitrophenol 4-Nit rophenol Pentachlorophenol Phenol 2,4,6-Trichlorophenol)

Bcnzidines (Includes: Benzidenc

3,3-Dichlorobenzidene)

Phthalate Esters (Includes: Benzyl butyl phthalate

Bis(2-ethylexyl) phthalate Di-n-butyl phthalate Di-n-octyl phthalate Diethyl phthalate Dimethyl phthalate)

Nit rosamines (Includes: N-nitrosodimethylamine

N-nitrosodfphenylamine N-nitrosodl-n-propylamine) 1,000

1,000

1,000

7-9TABLE7.2

SAMPLEVOLUMESFORORGANIC PRIORITY POLLUTANTANALYSIS* (Continued)

Parameter Required ?iinimum Sample Volume (ml> Organochlorine Pesticides and PCB's (Includes: Aldrln

a-BHC b-BHC d-BHC g-BHC Chlordane 4,4-DDD 4,4-DDE 4,4-DDT Dieldrin Endosultan I Endosultan 11 Endosultan Sulfate Endrin Endrin Aldehyde Heptachlor Heptachlor Epoxide Toxaphene PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260) 1,000

Nitroaromatics and Isophorone (Includes: Isophorone

Nitrobenzene 2,4-Dinitrotoluene 2,6-Dinitrotoluene) 1,000

7-10TABLE7.2 SAHEL VOLm FORORGANICPRIORITY POLLUTANTANALYSIS* (Cant inucd)

Parameter Required Minimum Sample Volume (ml) Polynuclear Aromatic Hydrocarbons (Includes: Acenaphthene

Acenaphthylene Anthracene Benzotalanthracene Benzo(b)pyrene Benzo(b)thuoranthene Benzo(g)perylene Bento( k)fluoranthene Chrysene Dibenzo(a,h)anthracene Fluoranthene Fluorene Lndeno(l,2,3-cdlpyrene Naphthalene Phenanthrene Pyrene > 1,000

Haloethers (Includes: Bis(2-chloroethyl) ether

Bi.s(Z-chloroethoxy) methane Bis(2-chloroisopropyl) ether b-Bromophenyl phenyl ether 4-Chlorophenyl phenyl ether)

Chlorinated Hydrocarbons (Includes: Hexachlorocyclopentadiene

Hexachlorobenzine Hexachlorobutadiene Hexachloroethane 1,2-Dichlorobenzene 1,2,4-Dichlorobenzene 1,3-Dichlorobenzene 1,4-Dichlorobenzene 2-chloronaphthalene)
2,3,7,8-Tetrachlorodfbenzeno-p-dioxfn Purgeables Base/Neutral, Acids and Pesticides 1,000

1,000

1,000 40 l,OOO-2,000
Source : 40 CFRPart 136

7-117.1.4 Sample Equipment and Containers

The equipment that can be used for sampling industrial process wastestreams ranges from a simple bucket to highly complex automatic samplers. The type of equipment that will be used by an IU and the Control Authority depends upon not only the pollutant parameter to be sampled, but also the sample location, sample frequency, sample volume, etc. When sampling activities are relatively complex, such as flow proportional composite sampling over extended time periods, automatic samplers may be much more efficient. Many automatic samplers can directly correlate process wastestream flow with both sample volume and time. In hazardous sampling situations, which may occur when sampling wastestreams containing organic priority pollutants, use of automatic samplers can reduce the risk of injury to sampling personnel. The disadvantages of autonatic samplers are high capital costs and maintenance requirements. However an IO or Control Authority can frequently offset these disadvantages through reduced labor requirements and a good equipment maintenance program. There are a number of commerically manufactured automatic samplers available for use by an IU or Control Authority. EPA has outlined criteria for selecting automatic samplers in their NPDES Compliance Sampling Inspection Manual. Examples of some of the criteria include weight of sampler, minimum sample, lift velocity, purge cycle, etc. When sampling for organic priority pollutants to de+--mine a TTO value, certain criteria for use of automatic samplers must be followed to ensure the collection of an uncontaminated sample. At a minium, these criteria include:

0 The automatic sample collection equipment must be free of tygon and other potential sources of contamination
0 The automatic sampler must be able to keep the samples refrigerated at all times
0 The automatic sampler must be able to accommodate glass collection containers. The selection and preparation of sample containers is based on the parameters to be measured. All organic priority pollutant samples (whether grab or composite) must be collected and stored using glass containers. Therefore, if manual grab samples will be cornposited, both the grab collection container and composite container must be made of glass. Before containers are transported to the laboratory, caps with a teflon lining (or foil for nonpurgeable parameters if the sample is, not corrosive) must be used to seal the sample container.

7-127.1.5 Sample Preservation and Holding Times In most cases; industrial wastewater samples contain one or more unstable pollutants that require immediate analysis or prescrvation. Prompt analysis is the most positive assurance against error frorn sample deterioration, but this is not feasible for composite samples, in which portions may be store0 for as long as 24 hours. For some pollutants, deterioration can be sufficiently deferred by preservation of the samples during cornpositing and transfer to the laboratory. Procedures usecj to preserve samples include refrigeration, pH adjustment, and chemical treatment. Prior preservation and holding time for organic pollutant samples is essential to the integrity of any monitoring program. Table 7.3 provides the recommended preservatives and maximum holding times that should be used for the specific classes of organic pollutants. The procedures outlined in Table 7.3 should be used at the start of sample collection in the field. However, aliquots of a composite sample that would require multiple preservatives, can be preserved only by maintaining the sample aliquots at 4OC until cornpositing and sample splitting are completed. 7.1.6 Sample Type and Frequency for TTO Monitoring The type of sample and frequency of sampling necessary for reporting TTO compliance data depends upon: (1) IU self-monitoring requirements, and (2) Control Authority compliance monitoring procedures. The sample type prescribed for any of the above reports consists of a composite sample collected at intervals that would properly represent the process wastestream flows from typical daily operations at an IU. Where feasible, composite samples should be flow-proportioned. Depending on the types of organic pollutant parameters sampled for TTO and the wide variety of processes existing at different IUs, the IU may be allowed by the Control Authority to collect and report the results of a grab sample. Industrial self-monitoring requirements for each categorical standard have not been promulgated to date. However, Section 403.12 of the General Pretreatment Regulations requires the submission of self-monitoring reports to the Control Authority which must contain industrial process wastestream discharge data for the pollutant parameters regulated by the applicable categorical standard. These reports were discussed in Chapter 2 of this document. The frequency with which the above composite samples should be taken to comply with all industrial self-monitoring requirements depends on the discharge flow of each IU. The minimum number of consecutive sampling days for the reporting period is three in a two-week period for facilities discharging less than 250,000 GPD, and six in a two-week period for facilities discharging more than 250,000 GPD. Sampling must occur during peak operational periods.

7-13SAMPLE YKESERVATIONANU WLDI NGTIMIIS FOKOKGANLC PRLOKITY YOLLUTANT ANALYSIS

t’arilmeter Yurgc*;ible ttaloc~nrbons (Includes: Bromoform

Hromod 1chl orome tbane Hromamethane Carbon tetrachlorlde Ch1orohent~nr ChIoroe thancs 2-Chloroethylvinyl ether Chloroform Ch1oromrt ham DibromochLoromt?t haw 1,2-Dichlorohenzerw 1.3-Di chlorobenzene 1,4-Dictlloroht~nzericl Dichlorodif IuorowLhanc I, I-Dichlororthanc 1,2-DlchloroeLharw I, I-Dichl hloroelheno Lrans-I ,2-Dtchlorwthenc I,2-I)l(.t11oroprot)arlc’ cis-I ,3-DLct~Ioropropene Lrans-l ,2-I)ic:tllorot)ort)elle Mt~Lhylcne chloride 1,1,2,2-TcL rac.htorotzLtlcarle TeLrachloroc~Lt~ciit~ I,I, I-Tri~hloro~tt1.1rr~~ 1,1,2-Tr ichloroeLt~nnt~ Trt~hlorot~~t~~~nc Trichlorol 1wrorrwtharw Vinyl chloride) EPA Melhod No. Prestrvat ive Maxlmtlm Holding Time ---- 601 Cool, 4°C I 14 days

0.008X Na2S203

7-14TABLE 7.3 (ConLinued) SAMPLE PKESEKVATION AND HOLDlNC; TIMES YOK OKCANIC PRIORITY POLLUTANT ANALYSIS (Continued)

EPA Method No. Preservative Maximum Holding Time Purgeable AromaL 1cs (Includes: Benzene

Chlorobenzene 1,2-Dichlorobenzene 1,3-Dichlorobenzene I, C-Dlchlorobenzenc Ethylbenzene Toluene) 602 Cool, 4°C 14 0. 1:008%Na2S201 1 HCI to pf 1 Days

<2

Acrolein and Acrylonitrile

Phenols (Includes: 4-Chloro-3-methyLphenoL

2-Ch lorophenol 2,4-Dichlorophenol 2,4-Dimethylphenol 2-+lethyl-4,6-dinitrophcnol 2-NLtrophcnol 4-Ni trophenol Pentachlorophenol Phenol 2,4,6-Trichlorophenol)

Benz id lnes (Includes: RenzIdene

3,3-Dlchlorobenzldcnc) 603

604

605 Cool, 4°C 1

tl;::: ;lxg”$-5

Cool, 40c2 0.008% Na s2c$

Cool, 4Y 0.008% Na2S203 I 14 Days (3 days for acroleln if pH not adjusted)

7 days until extraction, 40 days after extraction

7 days until extraction, 40 days after extraction

7-15‘t’AHt.E 1.3 (ConL IIlued ) SAMPLE t’Kt$SEKVATtON AND tlOt.t)IN~~ I’IHES YUKOKCANIC PKlOKL’TY POLLUTANT ANAt.YSIS (Corlt In&red)

I’.,I .~mt~lcr - EPA Mt*Lhod No

. t’reservat ive M,lxirnum ttotdlng T11rI - PhLtl.llaLo EsLtbrs (Inc.1udcs : Htwzyl but yl /‘I.<ti,rI.)Ic*

Bls(Z-elhylexyl) phLt~,~laLc Dl-n-butyl phLhalaLe Dl-II-octyl phthalale t)leLhyl phlhalate t)imt~thyl t>hLhalaLr) Cool, 4’c 1 days UII~11 extraction, 40 days afLer exlracc ion

Nitrosamlncs (Inc1udtts : N-r~iLrosodlmt~Lhylamlrw

N-ILL rosod Iphenylaairte N-niLrosodI-n-propylaaine) bO1 Cool, 4’c Slore in dark I days until extracllon, 40 days at Ler extract ion

7-15‘rAttf.E 7.3 (Con1 Inued)

I“4I IllI,t,.‘ -- SAMPLE PtMSERVA’TLON AND tIOLDING TIMES FOK OKCANIC PRlOHLTY POLLUTANT ANALYSlS (Cant lnued)

0rganochlorIr)e Pest icldes and I’Ctl’s (Includes: AldrIll

a-BIIC b-nttc d-nttc g-nllc Chlordane 4,4-DDll 4,4-DDE 4,4-DDT Dteldrtn Endosu Itan I Kndosu Itan 1I Enclosultan Sul filtt’ Endr111 Endr In Aldehyde Ilcpt achlor tl~rptachlor Epoxlde Toxaphcne tv;n-1016 tu-tL2t KM- 1212 I’CR-I242 KM-I 248 I’CB-I254 KM-1260) EPA Mcttwd No. I’reservat ive Maximum llolding Time
608 7 days unt 11 extract lou, 40 days after extt(actlon

7-17SAMPLE WESEKVA’r LONAND IlOl.l)l NC;‘r[H~:s two OKGANLC PKIOKI’I‘Y tWI.LUTANT ANALYSIS (Cant tnued)

Nltro,aromat 1t.s and Isophorone (llr~.\\ldes: Isophorone

NtIrohenzene 2,4-I)lnlLrotoluene 2,6-l)trritrololuene) Itt’A He Ihod No. --- - Yreservatlve MaxImum Iloldlnp: Time
bO9 coo1, 4°C I diiys IIII~ I1 extract Ion, 40 days .!Iler extrection

bI0 / days III~L II ~8x1r;rcL Ion, 40 days ,1fter cxlractlon

7-18TABLE 7.3 (Cant inued)
sA~f~1.k: PKESEKVA’~‘ION ANI) 1101.1)INc; TIHES YOKOKGANIC PHIOKITY POLLUTANT ANALYSIS (COIIL lllued)

Chlorlua~ed Hydroc-arbons (1nl.1udcs : Ilrxcl(.hlorocy. l~l.~tlit~~le

Ilexachlotobe. GIL’ llexachlorobutadiene Ilexnc-hloroethane I,2-Dt chlorobentene I, 2,4-Olchlorobenzcnc I,.~-U~chlorobcnzenc 1,4-1)Lclrlorohenzerle 2-ctllorollaphthalene)

B;tse/Ntaut ra1, Acids and Pest icicles fCf’A MCLhod No. Prescrvat lve Maxlmum If014141~ 1L..
612 Cool, 4°C days IIIILII extraction, days .IfLer ext 1’

action

613

624

625

- 1Should only be used in the prescllce of residual chlorine 2For dlphcnylnl~rosamlne only 3Aldrin only Cool, 4°C 0.008% Na2S203 1

Cool, 4Oc 0.008% Na2S203’

Store in dark 7 days until extraction, 40 days afler extraction

14 days (3 days for acroleln and acrylonilrlte)

7 days unlil exlractlon, 40 days afler extraction

7-19Industri‘31 TTO compliance monitoring proctt~lureS will vary

between control Authorities and between IIJs regulated by a Control Authority. Some will take daily compclsite samples several times a year for each IU. :3t!lers will only take grab samples until rroncornpl iance is foclnd, which would then trigger a more frequent sample collection at the IU. 7.2 ',ABOR:4TOKY CONSI!)ERATIONS Vdlitj TTO discharge data not only hinges on proper sampling techniques, but also on the proper laboratory analysis of the semples collected. This section prov-.des guidance for the IU and Control Authority in performing the necessary TTO analyses.
7.2.1 4nalytical Procedures Determination of TTO in an indusrrial process wastestream involves the analysis of the individu,tl organic pollutant parameters specified in the applicable Categorical Standard. Procedures for the analysis of toxic organic pollutants have been mandated by EPA in Guidelines Establishing Test Procedures for the Analysis of Pollutants: Final Rule (40 CFR Part 136). Generally, the EPA guidelines recognize two methods for organic pollutant analyses: gas chromatography (GC) with selective detectors or GCcouple~l with mass spectrophotometry (CC/MS). The GCmethods are provided for the following 12 classes of organic pollutants:

Cl Turgeable Halocarbons (EPA Method 601) Purgeablc Aromatics (EPA Method 602) Acrolein/Acrylonitrile (EP.4 Methotl 603) Phenols (EPA Method 604) Benzidenes (EPA Method 605) Phthalate Esters (EPA Method 606) !difrosamines (EPA Method 607) ~3r~]dnochlorine Pesticides and PCRs (EPA Method 608) Nitroaromatics and Isophoront (EPA Method 609) Polynuclear Aromatic Hydrocarbons (EPA Method 610) Haloethers (EPA Metllod 611) Chlorinated Hydrocarbons (EPA Method 612).
I’he c;L',/qS methods can also be used to quantify organic pollutant levels in a sample. Although higher costs are associated with GC/MS analyses, simultaneous measurement of' large numbers of organic ;>ollutants are possible. Also GC/MS analyses can overcome specific i!lterferences that would mask organic: pollutant responses obtained with a c;C. Three specific K/MS methods have been promulgated by EPA:

0 Purgeable ("lethod 624) - Determines volatile organic pollutant concentrations, including those parameters covered by GC Methods 601, 602, and 603

7-200 Base/Neutral, Acids, and Pesticides (Vethod 625) - Determines numerous orflanic pollutant conc:Jnt rat ions, inc1udincJthr)se para:ictttrs covered by GC Methods 604 through 612

0 2,3,7,8-Tetrachlorodi!?enzene-p-Dioxin (Methocl 613) - I>eter.mines c::,rlcentration of 2,3,7,8-Tctra~tlll)~~)~liblrl%e:lt! (TCDD). The EPA proceclurt?s include quality contrc>l techniqut?s, sample contairler requirements, and sample preserv,jt ion procedures for toxic organic pollutants. All analytical laboratories utilized shoul(l have ready access to the October 26, 1954 Federal Register publication. This publication provides information necess;it-y for a trained laboratory technician to perfor- all analyses required for TTO analysis. 7.2.2 Laboratory Quality Control Although not as great as the error associated with poor sampling techniques, the potential for error occurring during analysis of industrial wastewater samples can have a great impact on the acceptability of TTO monitoring data. Without the aid of independent- checks and general quality cQntro1, a laboratory may report errcjlleous results without being aware that a problem exists. Analytical quality control guidance is available froln EPA in a document entitled Handbook for Analytical Quality Control in Water and Wastewater Laboratories (~~213884). This handbook is published by the EPA Technology Transfer Program and is available through NTIS. Specific information is provided that can guide the laboratory toward sound and reliable techniques and procedures. 7.3 OIL AND GREASE MONITORING CONSIDERATIONS In lieu of monitoring for TTO, the following categorical standards allow an IU to alternatively monitor for oil and grease?:

0 Aluminum Forming (40 CFR 467) - All subcategories Cl Coil Coating (40 CFR 465) - Subcategory D (Canmaking) only 0 Copper Forming (40 CFR 468) - All subcategories. This section provides guidance for the 11Jand Control Authority when monitoring for the alternative oil and grease parameter. 7.3.1 Oil and Grease Sampling Considerations Due to the potential losses of oil and grease on sampling equipment (including containers), the collection of a composite oil and grease sample would not be representative of an industrial wastestream discharge. Therefore, separate oil and grease :jrab samples must be taken at regular intervals throughout a required monitoring time period and analyzed separately to obtain the average concentration over the monitoring period.

7-217.3.2 Analytical Considerations for- Oil and Grease

The E.P.\approved method for r,il and ,qrca:;c analysis (liquidliquid extraction with trichl(,r(,trifiIul)rc,ethane; qravametric) can be founc‘l in the fol1r>winl sources:

J Yethods for Chemical Analysts of Water and Waste, Method 413.1 (19’1:), U.S. EPA, Cinc-innati, Ohio. EPA-600/4-79-020.

0 Standard Methods for the Examination of Water and Wastewater, Method 503A 15th Edition (13201, r\Pfl:\, ANNA, IJPCF, Washin It-on, D.C. The Coil Coatin< Regulaticln 140 Ct‘R Pdrt 4653 delineates .1 specific procedure for analyzing wastewater samples to determine the concentration of oil and (It-ease in the s;Imple. Cant rol Authorities and IUs subject tt> this regulation :nilst use this procedure

. The procedure is 2,ntai:lerl in Section 465.03(c) arlcj is included in this manual in r1ppendi.u. E. Reference to the a5,ove documerts shoull~ Se made t3 ensure proper analysis of an oil and cJt-ease sample,

7-22APPENDIX A
40 CFR Section 403.12 Reporting Requirements for POTWsand Industrial Users9452 Federal Register/ Vol. 46, No. 18 / Wednesday, January 28, 1981 / Rules and Regulations

the Approval Authority shall commence shall be published in the same its review. Within 5 days after making a newspaper as the notice of the original determination that a submission meets request for approval of the Submission the requirements of §403.9(b), and under paragraph (b)(1)(i)(B) of this where removal allowance approval is section. In addition, notice of the sought, §§403.7(d) and 403.9(d), or at hearing shall be sent to those persons such later time under §403.7(c) that the requesting individual notice. Approval Authority elects to review the (3) Whenever the approval Authority removal allowance submission, the elects to defer review of a submission Approval Authority shall: which authorizes the POTW to grant (1) Issue a public notice of request for conditional revised discharge limits approval of the submission: under §403.7(b)(2) and 403.7(c), the (i) This public notice shall be Approval Authority shall publish public circulated in a manner designed to notice of its election in accordance with inform interested and potentially paragraph (b)(1) of this section. interested persons of the Submission (c) Approval authority decision. At Procedure for the circulation of public the end of the 30 day (or extended) notice shall include: comment period and within the 90 day (A) Mailing notice of the request for (or extended) period provided for in approval of the Submission to paragraph (a) of this section, the designated 206 planning agencies, Approval Authority shall approve or Federal and State fish, shellfish, and deny the Submission based upon the wildlife resource agencies; and to any evaluation in paragraph (a)_ of this section, the other person or group who has section and taking into consideration requested individual notice, including comments submitted during the those on appropriate mailing lists; and comment period and the record of the (B) Publication of a notice of request for approval of the Submission in the public hearing, if held. Where the Approval Authority makes a largest daily newspaper within the jurisdiction(s) served by the POTW. determination to deny the request, the Approval Authority shall so notify the (ii) The public notice shall provide a POTW and each person who has period of not less than 30 days following requested individual notice. This the date of the public notice during notification shall include suggested which time interested persons may modifications and the Approval submit their written views on the Authority may allow the requestor Submission. (iii) All written comments submitted additional time to bring the Submission into compliance with applicable during the 30 day comment period shall requirements. be retained by the Approval Authority (d) EPA objection to Director's and considered in the decision on decision. No POTW pretreatment whether or not to approve the program or authorization to grant Submissions. The period for comment removal allowances shall be approved may be extended at the discretion of the by the Director if following the 30 day Approval Authority: and (2) Provide an opportunity for the (or extended) evaluation period provided for in paragraph (b)(1)(ii) of applicant, any affected State, any this section and any hearing held interested State or Federal agency pursuant to paragraph (b)(2) of this person or group of persons to request a section of the Regional Administrator sets public hearing with respect to the forth in writing objections to the Submission. (i) This request for public hearing approval of such Submission and the reasons for such objections. A copy of shall be filed within 30 day (or the regional Administrator's objections extended) comment period described in shall be provided to the applicant, and paragraph (b)(1)(ii) of this section and each person who has requested shall indicate the interest of the person filing such request and the reasons why individual notice. The Regional Administrator shall provide an a hearing is warranted. (ii) The Approval Authority shall hold opportunity for written comments and a hearing if the POTW so requests. In may convene a public hearing on his or her objections. Unless retracted, the addition, a hearing will be held if there is a significant public interest in issues Regional Administrator's objections shall constitute a final ruling to deny relating whether or not the Submission should be approved. approval of a POTW pretreatment program or authorization to grant Instances of doubt should be resolved in removal allowances 90 days after the favor of holding the hearing. date the objections are issued (iii) Public notice of a hearing to (e) Notice of decision. The Approval consider a Submission and sufficient to Authority shall notify those persons who inform interested parties of the nature of submitted comments and participated in the hearing and the right to participate the public hearing, if held, of the

A-1 approval or disapproval of the Submission. In addition, the Approval Authority shall cause to be published a notice of approval or disapproval in the same newspapers as the original notice of request for approval of the Submission was published. The Approval Authority shall identify in any notice of POTW Pretreatment Program approval any authorization to modify 

### categorical Pretreatment Standards which the POTW may make, in accordance with §403.7, for removal of pollutants subject to Pretreatment Standards. (f) Public access to submission. The Approval Authority shall ensure that the Submission and any comments upon such Submission are available to the public for inspection and copying. §403.12 Reporting requirements for POTW's and industrial users. (a) Definition. The term "Control Authority" as it used in this section refers to: (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. (b) Reporting Requirement for industrial users upon effective date of categorical pretreatment standard-- baseline report. Within 180 day after the effective date of a categorical Pretreatment Standard, or 180 days after the final administrative decision made upon a category determination submission under §403.6(a)(4). whichever is later, existing Industrial User s subject to such categorical Pretreatment Standards and currently discharging to or scheduled to discharge to POTW shall be required to submit to the Control Authority a report which contains the information listed in paragraph (b)(1)--(7) of this section. Where reports containing this information already have been submitted to the Director or Regional Administrator in compliance with the requirements of 40 CFR 128.140(b), the industrial user will not be required to submit this information again. New sources shall be required to submit to the Control Authority a report which contains the information listed in paragraphs (b)(1)--(5) of this section: (1) Identifying information. The user shall submit the name and address of the facility including the name of the operator or owners. (2) Permits. The user shall submit a list of any environmental control permits held by or for the facility. (3) Description of operations. The User shall submit a brief description of the nature, average rate of productionFederrl Register I Vol. 48.No. 18 I M’edzesday. lanuav 28.19811RulesandRePuiatlons 0153 radStrndrrd IndustnrlClrssific8h0~of theopentlonis)crrncdoutbysuch lndustnd L’scrTh:rdcscnpuonshould Lncludreuhetartx pmcrsr Begrem whichindiutes pomtsofD&huge 10 thePOTW fromtheregulrtrd pmcerro. (4)Flow measumnenf. TheUsershall submitinform&ion show-q the mrrsured lversgedrily andmaximum dally flow. m/Illon, perdry,lothr PO-W km eachofthefollowul~ (I)regulrtrd processstnuna; end (II) other smamr aa naussuy 10 dew useofthecombinrdwrstrstra~ formuh ofj403.6(r).(Seepumgmph (b)(S)(v) of ltus secaon) TheCoatmlAuthority faeyeIlow for vertfleble lstietes oftheseflows wherejustified bycostorferribrllty coasidurtloas. supportq datashallbesubmitted 10 theControlAuthontyr* [vi)Sampirng

andrnrlyslsshd br performedtaeccohnce rnth the tcchmquas pnscnbed u40CFRPut 136 endemendmenuthento. Where40CFR Pert136doesno1wnUin runpiirq or uulytxd uctmiqura forthepollutanl h question,orwhen thrAdnun~sortor detenamesthetthePert130sampI.@ MCI luJytiuI tech.aIqueBu, iaeppmprirte forthepoilUIlt ill quesrroa. suapliag md udyslr hll be performedbyusingvrlidatrd anriyticel IWthodr ormy 0th lpFLUble sunpIing rod~~Iytkel procedurer tdUdh( pmcedurn suegrsled bythe yti;:pr peniu lppmvedbythr (ii)IItbecrtcgonul Pntresbcnt StrndardumodifiedbyInmovsl allOWMU(0403.7).heCOp.blned WrJlJJtrrUl fO.Yt9h (f 4Q6(J)), Jndjor aFundamenuliy3ZerentFacton vanance0Q3.151

af:ertheLisu subrmtsthereportnquusd by paragnph 03)oftussecuon any necessuyemend=cnts10

the Lnformrhoanquestedbyp~sgr~n:~ ibIte)md(7)ofhs srcaonanalibe Jubatted byh UsertotheConvoi Adonty wkrllhm

UQ drysafterthe modeledlima1scppmvrd (4 ComPLax@ Schedulr for Mectrng cal@pn’Cd htneotment Standa:as The fOliOWIng con&aoaa JhaU rppiy to thescheduienqwred byparegraph (b)(7)ofthissectloaz (5)Ahu8umment ofPoflutanU (i)The uaushd idenafy thePmtzeraamt Stendenie rppliublr torrch r@eted Pm-= (II)Inrddiuou theUmrrhlll rubmit thrresultsofrunpling Mdumlysir LdenUfylagthecutumendwnuntmtion (ormur. whm mquirodbythe Sundud orControlAuthority)of -TP ilutanu inth Dirfrom .a reguleted pmcesr Bothdeily m*r(mm ead rverege canceatretioa (or mass,whm required)shallbereportad Tbaample rhdI berepresenteuvr of ddy opu8tionr (vii)TheCokol Authcrity my dlow thesubmisstonofl brselme repoti which uhliMl only historiuI fiAtaso loagesthedrtr providesiaformeQoa sufedeat lodrtennme theneedfor Iadustrial pretreetmoatmeuures(v!li)ThebMdiwNportshdllndiute thrtim. dauendpleu. of sampling. endmethods ofenelysis. end sbeUfxrtUythrtmcllsuaplla#ead Mdyr1s ianpmsaltAuve ofIlormd work cydesandarpoctd pollutant DkbAqes tothePonw (1)Thescheduleshelleoatain Iawmmu ofpmgmr lotheformof deterfortheWmEUwent Md completion ofmajorrvrats lrrdrnq :o thewnrauction endoperation of ldditloael pmtreeuoent requhd forthe Iadueulel User10meettherppkabir ubgoriul FmtrrrtmenlStandmu(e.g.. hlrbgMengtnru. completing pmIimiauy piuu. wmpirw fLaal plum bcuting wnmct formajor wmpowau wmmcncq coMmleion wmplrw coasmlction rte).

(iii)WherefeesibIs. umphs muslbe obteiaed thmu& tbr flow-pmportiunel composite remphp uehnrquessprufied iathrlppliceble umgorical Pmtrrrtmrat SUrdud Whem wmpodtr ruapling ISa01feulble, l grebsuaple isrccepteblc (Iv)When thellow ofthr streun bein( rempledislessthenoreqd to 950.000liters/dry (rppmutely 2MJXXlgpd).theUsermusttekethree sampleswdia l two-wrek penod whem lb. now ofthestnambeq sampledbgreetertheaos~a00liters/ dry (eppmxmulely 25O.WO gpd).the Usermuattake JU( samplrs ~thn l two-wnk penod;

,(VISemplesshouldbstekea lnuwdiauly downstreamfmm pmtreetmenl feciiities ifsuchaxut or lmmedietely downsueua brn the rtgdrt8d pacers Ua0prelrmtmeat lxisU.Ifotherwestrwaun ueauxed with theregulrted westeweter pnor10 pntmrtmnrn~theUsershouldmersun theflowsend~aunrretloas ne~8~au-y toallow luaoftheumointi wuusmam fomluia oii403.61@’ in ordu tolvaiwtr comowce wxa*a PretreetmentStenduar. Wheree.a dqmau conuamtlon ormur &nit hrs beeaulculeted LO lccordsnceWIU j403&(r)thisrdiusted Lmrlsioag~vlth (61Cetifiarrion. Astawmenf nvlrwad byeneuthorlud mpmmtrtirr oftheladustrlel User(as definediarubpemgrepb (k)ofthl~ swtloa) cadtied toby?quaufied pmfessrond indiaUnp whether Remreneat Stead&s erebeiagnut onacoaaistrat brsia,eadifaof whetherrdd.itionel operationcad atah- (0cadM)aadlor lldit&wI pretrertmeat :Jnquimd for theIndustriel Usertomeetthr Rntmatmmt sundub MCI Rquimment* cad (7)Comp~aace

Schduie. IIldditionel premrmon~ d/or 0endMti be nqvrd tomeetthePretrertmeaot Stmdudr: theshonerl scheduleby whichtheladusti User.d pmndr ruch rd&Uoad pnueranent end/or 0 andM.Thewmphuon artr lathls ubduh shall a01beIetrr tbea the complianu detelsteblishsd forthe lppliuble PremetmeacSt&. (3)Notleter&a 14dayafollowing erch&u IntheschedulecadtheihI datrfor complimca tne lndusmsl User shd submiteproperr reporttothe ControlAuthonty mzlxdiag,etl minimum whetherornotitcomplied withtheinwmmt o!pmgreo tobeme1 onsuch deteandUnot,thedateon whchItrxprcu 10

complyw7thtOls lnuement ofprogress. he nrson for deley,eadthestepsbeq takenbyhe lndusti her tontum thr constmctioatoticscheduleestrbkshed. lnnoweat rhd morethan9montcJ elrpsaberwrrn 8uchpmgrerr reportslo thiControlAulbority.

(I)Wbm thrtadustnel User’s augoricd htrwtmmt Sundd has bmamodifiedbyl remove1elloweace Ij403.7).thecombiaedwrstesarem fonnulr 0 4034r)l. and/or l iadmtdy DiYemztFacton 7an~ca Ij403.13~

atoil tametheuser suomu ulerwon rwurra cy pamgrapn101

oi rnis secuon. rho informrtron requiredbyprrsqrphs tX6I, ann,;f z,cllon shdl peruin (d)Aeporr oncompliuno with carqor~cdprermaanent standard deodhc Witi 90drysfollo~ng the dete forArul comptiencewrath rppkublr utego&el Pmtmtment Sunduda orintheuse ofaNew Souru following coaua8amnent oithe lntmductioa ofwesIewelsr iatothe POTS. My hdustnal Usersublect10 ReuehtmnrntSlmduds end Rtqwmenu shrllsubmit10the Con& Autbontysrrzx7 ;~&x~~ ‘A2 Ylur8 Ma wtcM~cc3 ?Iai 30~utlllu ~1*aehcunr z3m-2e mgulrua pmcns wiliw U8U3;;ZG;Y Pretreranenl Standaxis end Requmments and*heavenge and mmumm ddy flow forthere?rcc-s A-2Federal Rcgs:er II‘~‘6. 46

(ii)The deUreMlym w@rB perfonk (iii) Who pWfORMd tit8Mdy@eS: (iv)Tltc mrlytd techntqucs/ marhodsue: end (v)TheresultaofruchMdysrs. (2)Anylndusmel UserorPOTW rubjed tothrreportingrrquiremenU csublirbed inrheamction Ihell be tqutred torotemforl aummum of3 yrrn my fWCOrdJ ofmonitotig rcUtitlu endresulte(whetbrr ornot ruch monitorulg lcuvltlu armrquurd bythfesection)endshellmrkr such mauda lveileble formspectton end copyingbytheDtmctorendthe RegionelAdministretor (endPOIW in theceu ofanlndustnel User).This periodofntentton shellbeextended dunngthecourseofanywrrcrolved Liu~ationrepding thrlndu,uiel User orfW2-Worwhenrequestedbythe DtrectorortheRc~onel Adminirtretor. [3)hy POT-Wtowhich reporteere rnbmittd byMtndusuiel User powant toperegrephs(b).Id).end(e) oftbbBe&on rbdl ntem ruchrrpom forenunitnumof3yrucald~heIlmeko rtgbmpom lveileble forimprctIon endcopyingbytheDirectorendthe ReglonelAdmirustretor. Thisperiodof nmntion shellbeextendedduringthe courseofanyumesolvedlitigation merdltq tbedhcherge ofpoUutenteby thelndustrlel Userortheoperetloa of thePOTW~treetmeat Rvgremor whenrequestedbytheDirectororthe Regioml Adminirtretor.

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A-4APPENDIX B
ELECTROPLATING & METAL FINISHING CATEGORY: List of Toxic Organic Compounds Regulated as a Component of Total Toxic OrganicsAPPENDIX B TOXIC ORGANIC COMPOUNDSREGULATED UNDER ELECTROPLATING & METAL FINISHING TTO PRETREATMENT STANDARD Acenaphthene Bis (2-chloroethyl) ether Acrolein 2-chloroethyl vinyl ether (mixed) Acrylonitrile 2-chloronaphthalene Benzene 2,4,6-trichlorophenol Benzidine Carbon tetrachloride (tetrachloromethane) Parachlorometa cresol chloroform (trichloromethane)

Chlorobenzene 2-chlorophenol 1,2,4-trichlorobenzene 1,2-dichlorobenzene Hexachlorobenzene 1,3-dichlorobenzene 1,2-dichloroethane l,l,l-trichloroethane 1,4-dichlorobenzene N-nitrosodi-n-propylamine Hexachloroethane Pentachlorophenol l,l-dichloroethane 1,1,2-trichloroethane 1,1,2,2-tetrachloroethane Phenol Bis (2-ethylhexyl) phthalate Butyl benzyl phthalate Chloroethane Di-n-butyl phthalate Di-n-octyl phtalateDiethyl phthalate

Dimethyl phthalate 1,2-benzanthracene (benzo(a)anthracene) Benzo(a)pyrene (3,4+enzqyrene) 3,4-Benrofluoranthene (benzo(b)fluoranthenee) 11,12+enzofluoranthene (benzo(k)fluoranthen) Chrysene Acenaphthylene Anthracene 1,12+enzoperylene (benzo(ghi)perylene) FluOrene Phenanthrene 1,2,5,6-dibenzanthracene (dibenzo(a,h)anthracne) Indeno (1,2,3-cd)pyrene (2,3-o-phenylene pyrene) Pyrene Tetrachloroethylene Toluene Trichloroethylene Vinyl Chloride (chlorcethylene) 3,3-dichlorobetuidine l,l-dichloroethylene 1,2-trans-dichloroethylene 2,4-dichlorcphenol 1,2-dichloropropan (1,3-dichloroprwene) 2,4-dimethylphenol 4-chlorophenyl phenyl ether 4-brmzphenyl phenyl ether Bis (2-chloroisomopyl) ether Bis (2-chlolroethoxy) methane Methylene chloride (dichloronethane) Methyl chloride (chlorcmethane) Methyl bromide (brcmme thane) Bromoform (tribrmcmthane) Dichlorobrumnethane Chlorcdibrmawthane Hexachlorobutadiene Hexachlorocyclcpentadiene Isophorone Naphthalene Nitrobenzene 2-nitrophenol 4-nitrophenol 2,4-dinitrophenol N-nitrosodimethylamine N-nitrosodiphenylamine Aldrin Dieldrin Chlordane (technical mixture and metatolites)
4,4-DDT 4,4-DDE (p,p-DDX) 4,4-DDD (p,p-TDE) Alpha-ehdosulf an Beta-endosulfan
B-22,6-dinitrotoluene 1,2-diphenylhydrazine Ethylbenzene Fluoranthene Heptachlor epoxide (BHC- hexachlorocyclohexanee) Alpha-BHC Beta-BHC Gamna-BHC Delta-BHC (PC&oolychlorinated biphenyls) PCB-1242 (Arochlor 1242) PCB-1254 (Arochlor 1254) PCB-1221 (Arochlor 1221) PCB-1232 (Arochlor 1232) PC&1248 (Arochlor 1248) PCB-1260 (Arochlor 1260) PCB-1016 (Arochlor 1016) Toxaphene ETndcsulfan sulfate Endrin Endrin aldehyde Heptachlor 4,h-dinitro-o-cresol 2,4-dinitmtoluene

2,3,7,8-tetrachlorodibenz*tiioxin (TCDD)

B-3APPENDIX C
ELECTRICAL AND ELECTRONIC COMPONENTS CATEGORY List of Toxic Organic Compounds Regulated as a Component of Total Toxic Organics (By Subcategory)APPENDIX C TOXIC ORGANIC COMPOUNDSREGULATED UNDER ELECTRICAL AND ELECTRONIC COMPONENTS TTO PRETREATMENT STANDARDS Subcategories A and B (Seminconductors and Electronic Crystals) 1,2,4 trichlorobenzene chloroform 1,2 dichlorobenzene 1,3 dichlorobenzene 1,4 dichlorobenzene ethylbenzene 1,1,1,trichloroethane methylene chloride napthalene 2 nitrophenol phenol bis (2-ethylhexyl) phthalate tetrachloroethylene toluene trichloroethylene 2 chlorophenol 2,4 dichlorophenol 4 notrophenol pentachlorophenol di-n-butyl 1,2 diphenylhydrazine isophorone butyl benzyl phthalate 1,1 dichloroethylene 2,4,6 trichlorophenol carbon tetrachloride 1,2 dichloroethane 1,1,2 trichloroethane dichlorobromoethane Subcategory C (Cathode Ray Tubes) chloroform trichloroethane methylene chloride bis(2-ethylhexyl) phthalate toluene trichloroethylene
C-1APPENDIX D Analytical Procedure for Determining Oil and Grease Concentrations Under Coil Coating RegulationAPPENDIX D
TOXIC ORGANIC MANAGEMENT PLAN ABC REFRIGERATION CORPORATION

HIGH POINT PLANT

I. Description of Facilities and Solvent Use A. Process Description The ABC Refrigeration Corporation, High Point Plant, manufactures automotive radiators, condensers, and compressors from metal coils and metal castings manufactured by other suppliers. The forming and assembly processes include metal forming, degreasing, chromating, and brazing in preparation for painting and final assembly. The metal castings are machined, washed, assembled, and degreased prior to final assembly. Wastewater types and volumes and the current wastewater treatment system are depicted in Figure 1. The primary sources of process wastewater are the degreasing, chromating, fluxing, and parts washing operations. Other sources of wastewater are cooling tower blowdown and boiler blowdown. Wastewater from the degreasing operations is treated by dispersed air floatation for oil and grease removal and then discharged to a combined wastestream containing the wastewater from all other sources. The combined wastestream is then treated by coagulation/flocculation with chemical and polymer addition for solids and metals reduction. The treated effluent is discharged to the city sewer system. B. Identification of Toxic Organic Chemicals Entering the Plant Wastewaters 1. Chemical Analysis of Treated Wastewaters Samples were taken of the plant's treated wastewaters for analysis for the 110 toxic organics regulated under the metal finishing categorical pretreatment standards. Samples collected were 24-hour flow proportioned composite samples for acid extractible and base/neutral compounds. Grab samples for volatile organics were taken every four hours and were cornposited before analysis. Samples were taken over a period when all production lines were operating at peak production rates. Samples were analyzed by gas chromatography with compound identification and quantification by mass spectrophotometer (GC/MS). EPA procedures 624 and 625 were followed for GC/MS analysis. Toxic organic compounds detected at concentrations greater than 0.01 mg/l are listed in Table 1.

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a YTable 1 Compound Concentration (mg/l) l,l,l-Trichloroethane 1.320 Napthalene 0.210 Chloroethane 0.131 Benzene 0.532 Phenol 0.681

2. Identification of Solvents Used in Manufacturing Operations
a. Greasefree is a degreasing solvent usecl in the forming process. Greasefree's principle ingredient is l,l,ltrichloroethane. We have contacted the manufacturer of Greasefree, Doubt Chemical Corporation, who informs us that their analysis of Greasefree indicates that no other priority toxic pollutants are contained in Greasefree. Doubt's letter confirming its analysis is enclosed as Attachment 1.
b. Rinsewash is a d-greasing solvent used in the metal castings process. Rinsewash is a multicomponent solvent we purchase from Pound Chemical Corporation. At our request Pound has analyzed Rinsewash and found it contains napthalene, benzene, and phenol. Pound represents that no other toxic organic pollutants were identified in its analysis of Rinsewash. Pound's letter documenting its analysis is enclosed as Attachment 2.
C. Rustaway is a corrosion inhibitor used during the metal castings washing process to prevent rust formation. Webuy Rustaway from the Exit Chemicals Corporation. The primary ingredient of Rustaway is carbon disulfide. Exit refused our request for a chemical analysis of Rustaway. We, therefore, submitted an aliquot of Rustaway to Whatsinit Laboratories, Inc. for analysis. Whatsinit's report is enclosed as Attachment 3 and documents that Rustaway contains chloroethane. No other toxic organics were detected. 3. Identification of Other Potential Sources of Toxic Organic Pollutant Introduction to the Wastewater Treatment System
a. Durable Paints are used to finish the forminl] process items. Although not detected in the wastewater analysis, Durable Paints are known to contain toluene. The floor drains in the forming process painting area discharge to the wastewater treatment system. Therefore, any spilled paint would enter the process wastewater treatment system.

D-3b. Degreasing Areas - Floor rjrdins in both de(jre‘isin:j areas

sirqilarly are connected to the main wastewdter system. Therefore, spills of degrensing agents could enter the treatment system.
C. Solvent Storage Areas - Solvents, paints, and corrosion inhibitors are storell in bulk quantities in four different areas of the plant--the two degreasinq areas, the washing area, and the painting area. Spills could occur by accicdental dumpinq, spillage Idurinq rr,lltine transfer, etc. Such spills woul(I enter the wastewater treatmert syste-n through the floor drains. II. Description of Control Options Explored A. Solvent Substitution For the deqreasing, corrosion inhibitor, and painting sources of toxic organics, ABC explored the feasibility of substituting another pro(Juct that does not conttiin toxic organic materials. Obviously, this would be the most effective manner of eliminatinq toxic organic discharges both Eroln process operations and from potential spillage into floor drairs. ABC obtained samples of degreasing agents, corrosion inhibitors, and paints that do not contain toxic organics fro,m ven~J~:,r:. and conducted pilot tests of tileir effectiveness. ABC concluded aftt?r these tests that the alternative degreasing agents and paints could not be used without adversely affectinq the process ant! final protlucts. The alternative degreasinq agents were not nearly as effective as the ones currently used and, therefore, would impair the effectiveness of subsequent operations. Alternative paints could not be applied evenly to our products. One alternative corrosion inhibitor, Chromisorb, appears to be an acceptable alternative to the Rustdway and contains the toxic metals zinc and chromium. Thus, the option of eliminatinq chloroethane discharges by substituting Chromasorb for Rustaway as a corro!;ion inhibitor was considered. B. Process Modifications The major alternative to the substitution of deqredsiny agents is to institute changes in the deqreasinq process that do not result in wastewater discharge. This would be accomplished by wiping parts rather than rinsing them. After a thorough wipedown, parts would be air dried in an area under a vacuum hood. The vacuum hood is integrated with the facility’s air pollution control devices. Any material used for wiping would, of course, be treated as a hazardous material. It would be transferred to <IL-urnsand disposed of to a licensed disposer or reclaimer. Thus, process changes could be made that woul(d eliminate discharge of process wastewaters containing l,l,l-trichloroethane, napthalene, benzene, and phenol. Solid waste (generation would, of course, increase.

B-4C. Segregated Drain System Spills of toxic organics could be eliminated from the process wastewater stream if a segregated floor drain system were constrticted. ABC investigated this option and found that, because of the location of some existing drain pipes, such modification would require a major disruption of the plant and would cost far more than routine TTO monitoring. Moreover, such an option would create a significant additional wastewater treatment problem for those cases in which drained water is not contaminated by spilled material.
D. Sealing Floor Drains Introduction of toxic organics to wastewaters through floor drains could be eliminated if floor drains were sealed. In the process areas this option is not feasible because of State safety requirements. In storage areas, however, such an option may be practical.
E. Installing Sumps in the Floor Drains Under this option sumps would be installed such that prior to entering the drain, floor waters would pass through a sump or holding tank. The sump would be as large as the largest spill of solvent reasonably expected plus a 10 percent freeboard allowance. Thus, if a solvent spilled, the discharge to the drain would be turned off. The solvent could, then, collect in the sump and be recovered. III. Toxic Organic Management Plan As a result of the above analyses, ABC believes that all of its toxic organic pollutant discharges can be controlled by a toxic organic management plan in lieu of routine toxic organic monitoring. A. Solvent Substitution Discharge of chloroethane will be eliminated by use of a substitute rust inhibitor. ABC will discontinue use of Rustaway as a rust inhibitor. Instead, ABC will use Chromasorb to prevent rust formation in its metal casting line. Chromasorb is a zinc-chromate rust inhibitor that can be used to prevent rust formation in place of Rustaway. Chromasorb contains the toxic metals chromium and zinc. The existing wastewater treatment system, however, is designed to remove metallic pollutants. By adjustment of the chemical and polymer feed, ABC anticipates that it can maintain current levels of metals discharge while eliminating chloroethane discharges.

D-5B. Process Changes

ABC will eliminate discharge oE process wastewaters containing l,l,l-trichloroethane, n‘3pthalene, benzene, and phenol by instituting chttn(Jes in the degre.3sing process. Solvent cleaning will be accomplished by immersion and manual wipedown. Parts will !,e allowed to air dry in an area covered by a vacuum hood prior to any water washing. Materials used for wipedown will be collected in drums, sealed, stored in a secure area and transferred to Usitagin Reclamation Company. Usitagin is a licensed hazardous waste disposer.
C. Solvent Storage Procedures Storage procedures for all solvents containing toxic organic compounds will be changed. Storage will be in a central location for all such materials, including paints. The storage area will be diked to contain a volume equal to the largest container stored, 55 gallons, plus 50 percent. There will be no floor drains in this area. All incoming containers of solvents or paints will be labeled upon receipt with the following information: ****************************************************************~***

l Material Contains Regulated Orgar.ic Solvents * * *

l 1. Use only in designated areas * * * * 2. Do not permit this material to enter plant wastewater * * stream * * * * 3. Dispose of only in designated and identified containers * * * **********************************t*****~********~***********~**~***~ All in-plant usage containers will also be marked with the above information.
D. Installation of Sumps in Process Areas

In all process areas where materials containing toxic organic compounds are used, sumps will be installed prior to any floor drains. The sumps will be designed to allow rapid shut-off of flow to the drain and to hold a volume equal to the largest container of solvent used in that area plus ten percent. E. Spent Solvent Disposal Practices - Spent solvents are collected in 55 gallon drums, sealed, and stored in an existing, secured stcrage area. The storage area contains no floor drains. ABC sells spent solvent to the Usitagin Reclamation Company.

D-6F. Training All personnel involved in degreasing, chromating, paintin#A, and clean-up activities will receive instruction in the proper handling and disposal of solvents and clean-up materials in order to keep regulated toxic organics out of industrial wastewater. New employees will be trained in these procedures immediately. All personnel working in these activities are familiar with this toxic organic lnanagement plan and will follow the procedure established in that standard to eliminate regulated organics from entering the water wash system. Training consists of classroom instruction which reviews the following: 1. The organic solvents and cleaners known to be in use at the plant and the areas in which they are used. 2. The location of lift stations and drains with emphasis upon the location of pretreatment sewer systems for each area in the plant. 3. The Toxic Organic Management Plan and the proper procedures for handling and disposing of the respective solvents. G. Inspections 1.

2. Degreascrs, spray booths, and cleaning operations will be inspected routinely by the area supervisor to verify cleaning procedures and adherence to this Toxic Organic Management Plan to insure that TTO does not spill or leak into plant sewers. Centrally located cleaning and solvent handling, reuse, and collection areas, as well as raw material and waste solvent storage areas, will be inspected weekly by a designated environmental representative to verify proper solvent storage, handling, and collection. A log of inspections and sign-off will be maintained by the designated environmental representative. H. Implementation All provisions of this plan will be fully implemented by April 1, 1984.

D-7IV. Certification

"Based on my inquiry of the person or persons directly responsible for managing compliance with the TTO limitations, I certify that, to the best of my knowledge and belief, no dumping of concentrated toxic organics into the wastewaters has occurred since filing of the last report. 1 further certify that this facility is implementing this toxic organic pollutant management plan submitted to the Control Authority on January 2, 1984." John Smith Plant Manager High Point Plant Telephone: (617) 617-6176

D-8APPENDIX E

Analytical Procedure for Determining Oil and Grease Concentrations Under Coil Coating Regulation§465.03 Monitoring and reporting requirements (c) The following determination method shall be used for the determination of the concentration of oil and grease in wastewater samples from all subcategories of coil coating (Based on Standards Methods, 15th Edition. methods 503A and 503E). In this method, a partition gravimetric procedure is used to determine hydrocarbon (petroleum based) oil and grease (O&G-E). (1) Apparatus. (i) Separatory funnel. 1 liter, with TFE stopcock. (ii) Glass stoppered flask, 125 ml. (iii) Distilling flask, 125 ml. (iv) Water bath. (v) Filter paper, 11 cm diameter.2 (vi) Glass Funnel. (vii) Magnetic stirrer and Teflon coated stir bar. (2) Reagents. (i) Hydrochloric acid. HCl. 1+1. (ii) Trichlorotrifluoroethane.3(1.1.2- trichloro-1.2.2-trifluoroethane), boiling point 47°C. The solvent should leave no measurable residue on evaporation: distill if necessary. Do not use any plastic tubing to transfer solvent between containers. (iii) Sodium sulfate. Na2SO4 anhydrous crystal. (iv) Silica gel, 60 to 200 mesh. Dry at 110°C for 24 hours and store in a tightly sealed container. (3) Procedure. To determine hydrocarbon oil and grease, collect about 1 liter of sample and mark sample level in a bottle for later determination of sample volume. Acidify to pH 2 or lower; generally, 5 ml HCl is sufficient Transfer to separatory funnel. Carefully rinse sample bottle with 30 ml trichlorofluoroethane and add solvent washings to separatory funnel. Preferably shake vigorously for 2 minutes. However, if it is suspected that a stable emulsion will form, shake gently for 5 to 10 minutes. Let layers separate. Drain solvent layer through a funnel containing solvent-moistened filter paper into a tared clean flask. If a clear solvent layer cannot be obtained. add 1g Na2SO4to the filter paper cone and slowly drain emulsified solvent onto the crystals. Add more Na2SO4if necessary. Extract twice more with 30 ml solvent each but first rinse sample container with each solvent portion. Combine extracts in tared flask and wash filter with an additional 10 to 20 ml. solvent. Add 3.0 g silica gel. Stopper flask and stir on a magnetic stirrer for 5 minutes. Filter solution through filter paper and wash silica gel and filter paper with 10 ml solvent and combine with filtrate in tared distilling flask. Distill solvent from distilling flask in a water bath at 70°C. Place flask on a water bath at 70°C for 15 minutes and draw air through it with an applied vacuum for the final 1 minute. Cool in a desiccator for 30 minutes and weigh. (4) Calculations.-Calculation of O&G-E: If the organic solvent is free of residue the gain in weight of the tared distilling flask is due to hydrocarbon oil and grease. Total gain in weight, E, is the amount of hydrocarbon oil and grease in the sample (mg): mg (hydrocarbon oil and grease)/1 =
(3) Use of O&G-E: The value, O&G-E shall be used as the measure of compliance with oil and grease limitations and standards set forth in this regulation except where total O&G is specifically required. 1Teflon or equivalent. 2Whatman No. 40 or equivalent. 3Freon or equivalent. 4Davidson Grade 950 or equivalent.

U.S. Government Printing Office: 1986 - 491-191/46114

E-1