United States Permits Division September 1985 

Environmental Protection Washington, DC 20460 

Agency 

Water 

EPA Guidance Manual 

for Implementing 

Total Toxic Organics (TTO) 

Pretreatment Standards 
GUIDANCE 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 M Street, S.W. 

Washington, D.C. 20460 
TABLE OF CONTENTS 

Chapter Page 

1. 

2. 

3. 

4. 

5. 

INTRODUCTION 

1.1. DEFINITION OF TTO .................................. 

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

1.3. LIMITATIONS OF THIS 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 FOR THE PREPARATION OF A TOXIC ORGANIC 

MANAGEMENT PLAN ......................................... 

USE OF THE COMBINED WASTESTREAM FORMULA 

5.1 DEFINITIONS ........................................ 

5.2 CWF CONDITIONS ..................................... 

5.3 CALCULATION OF ALTERNATIVE 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 

5-2 
TABLE OF CONTENTS (cont.) 

Chapter Page 

6. REMOVAL CREDITS 

6.1 REMOVAL CREDITS FOR TTO . . . . . . . . . . . . . . . . . . . . . . . . . . . . 

6.2 REMOVAL CREDITS FOR TTO 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 POTWs and 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 

ii 
1. 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 POTW in 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-l 
1.1. 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 FOR THE PREPARATION OF A TOXIC ORGANIC 

MANAGEMENT PLAN, walks an industrial user and a Control Authority 

through the steps necessary to develop an acceptable management plan. 

Chapter 5, USE OF THE 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. 

1-2 
1.3. 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. 

1-3 
2. 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 POTW if 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 BMR must 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 BMR must 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. 

2-1 
The BMR shall 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 BMR shall 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 BMR shall 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 BMR contains a compliance schedule, 

the compilance schedule must contain the shortest schedule by which 

the industrial user (IU) will provide the additional O & M and/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 BMR for 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. 

2-2 
IUs 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 POTW system. 

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 additional O & M changes 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. 

2-3 
However, 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. 

2-4 
3. 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 B contains 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 BMR and 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. 

3-1 
Limit 

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 

Appendix B 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. 

3-2 
The IUs must submit and implement this TOMP as 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 POTW sewer 

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. 

3-3 
TABLE 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. 

3-4 
The 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 POTW sewer 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). 

3-5 
3.3 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 11 ary 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-,i 1 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. 

3-6 
Subpart A 

copper or Max. for 

copper l l lay 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 

t reetwnt 

heat treeted 0.419 0.219 12.920 7.752 0.219 6.b60 

C. Cxtruelon beet 

t reatunt 

f. Anneellng ulth 

water 

hcet t reeted 

on an l xtrualoe 

prceo 

l nneeled ulth 

vater 

g. Annceling vlth l nneeled vlth 

011 all 

h. Alkellne 

Clcmlng Rlnre 

1. Alkellne 

Cleenlng Illnee 

for forged perte 

J. Alkmllnc 

Clrnnlng lath 

l lkal Ine 

cleened 

l lkeltne 

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 

COPPER FORHINC CATECORT 

TTO AND OIL AND CREASE STANDARDS 

PSLS 

011 6 Creaee 

0.066 

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

max. fwg. any 1 dry .*x. l ug. l ny 1 dey 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 6 Creeee 
3.3.2 Alternative to TTO Monitoring 

As an alternative to TTO monitoring, regulated IUs may monitor 

for oil and grease (O&G) and meet the O&G monitoring 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&G monitoring standards is not 

subject to the -per Fonning'I70 stand.u-d. 

Regulated IUs electing to use this alternative must sample 

and analyze for OSG and 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 

3-8 
D) 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 BMR and 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. 

3-9 
TABLE 3.3 

AI.IR(1NlJM FnRHlNC CATtCnAY 

?-fO AND OIL AND CREASE STANDARD% 

Subprrt A: 

RollingwIth Heat 0118 __---- 

Core1 

--- 

Core vlthaut l n Anneallog 

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 4 CreneeAlternatIve Parameter 

Mar. for Max. for 

.ny I day Monthly avg. 

l-m OIL A Crcarr - 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 I cant 

Scrubber Liquor 

Spent Solvent 

Spent Lubr I cant 

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 

ctrsning or Ctchlng Scrubber Scrubber Liquor cleaned or etched 1.M 38.7 23.20 1.34 19.33 

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 

3-10 
TABLE 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 

Dummy Block 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?. *>I Ecrhlng Scrubber Scrubber Llquor 

Stohp*rt D: 

Fnrglnfi 

Corr: 

Forfil”l. e-e 

l)rErr.,*lng Spent Solvent 

S.,Vl nl! Spent Lubrlrrnt 

Ancl I Inry 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 L CrcarcAlternaclve 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 

l lu=Jnur 

011 L Creasel-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 l vK. 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 I I lorry Frnccrner 

Contlnunur Kod CaatJng Spent Lubrlcent rod caet 

Cnnt I mmum 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 Ynt cr 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( 

3-12 
3.4.2 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. 

3-13 
Subpart 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 

3-14 
exempted 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 BMR and 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. 

3-15 
3.5.2 Alternative to TTO Monitoring 

As an alternative to TTO, regulated IUs may elect to monitor 

for and comply with the O&G standards listed in Table 3.4 above. 

IUs subject these O&G standards, will not be subject to the TTO 

standards. 

Again the BMR and 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&G alternative 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 POTW can 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. 

3-16 
4. GUIDANCE FOR THE 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 TOMP must 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 TOMP are 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. 

4-1 
Step 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. 

4-2 
Step 4 - Submission of Toxic Organic Management Plan and Certification Statement 

The TOMP should 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 TOMP and 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. 

4-3 
5. APPLICATION OF THE 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 

CWF is a mechanism for calculating alternative limitations when 

regulated wastestreams are mixed with unregulated or dilution 

streams. The CWF is 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 CWF CONDITIONS 

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 CWF will 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 

5-2 
TABLE 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) 

Y 

c 

- alcernatlvt mass limit for the pollutant 

Hi - Categorical Pretreatment Standard MIS limit for the pollutant in 

regc!ateC stream i 

F i - 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. 

5-3 
different categorical standards with specific TTO limits, the 

alternative TTO limit calculated using the CWF would 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 CWF would 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 CWF is 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 CWF must be used 

to calculate both an alternative TTO and an alternative oil and 

grease limit. 

5-4 
Example 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 

5-5 
electing 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 CWF to 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 CWF as 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 

I Q = 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-t 
Exmple 3: Calculation of alternative TIO discharge limit for an integrated 

industrial facility after October 24, 1986 (corrpliance date for Aluninun 

Formiry) when the Alminun Forming oil and grease alternative is not used. 

Wcause the TTO limit for Aluninun Forming is expressed as a productionbased limit, the first step necessary is the conversion of the production-based 

?TO limit to the equivalent concentration-based 'IT0 limit. Based on 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 

12 Wnt.hs per day 

Average Daily Water Usage in Forging 

IZlring Previous 12 Rmths 

= 75,000 gpd 

,The conversion of production-based TTO limit to a concentration-based ?To limit 

is as follows: 

TTtJ (concentration = (Production-Based Limit)(Ava. Dailv Production) 

Once 

equivalent) (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 now a 

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 

5-7 
TTOcwf = (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 CWF must 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 CWF must develop an alternative O&G limitation 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. 

5-3 
Calculation of the alternative 0 & G production-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 1 OSG = 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 & G standard, the calculation of the alternative 

0 & G concentration-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 

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

concentration-based 0 & G limit 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-10 
6. 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 POTW may 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 FOR TTO 

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. POTWs under §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 POTW may 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 POTW treatment (which may be hazardous 

to POTW workers and the environment). 

Based on the previous factors, the Agency does not 

encourage applications for TTO removal credits. 

6.2 REMOVAL CREDITS FOR TTO 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. 

6-2 
7. 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 Inspection Manual, 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 

7-2 
0 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 TTO value. 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. 

7-3 
TABLE 7.1 

SAMPLE COLLECTION TECHNIQUES FOR ORGANIC PRIORITY POLLUTANT 

Parameter 

Purgeable Halocarbons 

(Includes : Btomoform 

Bromodichloromethane 

Bromome thane 

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 

7-4 
TABLE 7.1 

SAMPLE COLLECTION TECHNIQUES FOR ORGANIC PRIORITY POLLUTANT (Continued) 

Parameter 

Co1 lect 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: Benz ldene 

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) 

X it rosamines 

(Includes: N-nitrosodimethylamine 

9-nitrosodiphenylamfne 

N-nitrosodi-n-propylamine) 

X 

X 

x 

X 

X 

x 

7-5 
TABLE 7.1 

jAk!PLE COLLECTION TECHNIQUES FOR ORGANIC PRIORLTY POLLUTANT (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 

7-6 
TABLE 7.1 

SAMPLE COLLECTION TECHNIQUES FOR ORGANIC PRIORITY 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 CFR Part 136 

7-7 
TABLE i .2 

SWLE VOLUMES FOR ORGANIC PRLORITY POLLUTANT ANALYSIS* 

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 

7-8 
TABLE 7.2 

SMLE VOLUMES FOR ORGANIC PRIORITY POLLUTANT ANALYSIS* (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 

7-9 
TABLE 7.2 

SAMPLE VOLUMES FOR ORGANIC PRIORITY POLLUTANT ANALYSIS* (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 

7-10 
TABLE 7.2 

SAHEL VOLm FOR ORGANIC PRIORITY POLLUTANT ANALYSIS* (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) f luoranthene 

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 CFR Part 136 

7-11 
7.1.4 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. 

7-12 
7.1.5 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. 

7-13 
SAMPLE YKESERVAT I ON ANU WLDI NG TIMIIS FOK OKGANLC PRLOKITY YOLLUTANT ANALYSIS 

t’a rilme t e r 

Yurgc*;ible ttaloc~nrbons 

(Includes: Bromoform 

Hromod 1 chl orome t bane 

Hromamethane 

Carbon tetrachlorlde 

Ch 1 orohent~nr 

Ch I oroe t hancs 

2-Chloroethylvinyl ether 

Chloroform 

Ch 1 oromrt ham 

Di bromochLoromt?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~ 

Tr t~hlorot~~t~~~nc 

Tr ichlorol 1 wrorrwtharw 

Vinyl chloride) 

EPA Mel hod No. Prestrvat ive Maxlmtlm Holding Time 

---- 

601 Cool, 4°C I 14 days 

0.008X Na2S203 

7-14 
TABLE 7.3 (ConLinued) 

SAMPLE PKESEKVATION AND HOLDlNC; TIMES YOK OKCANIC PRIORITY POLLUTANT ANALYSIS (Continued) 

EPA Method No. Preservative Maximum Holding Time 

Purgeable AromaL 1 cs 

(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: Renz Idene 

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 I Ilued ) 

SAMPLE t’Kt$SEKVATtON AND tlOt.t)IN~~ I’IHES YUK OKCAN IC PKlOK L’TY POLLUTANT ANAt.YS IS (Corlt In&red) 

I’.,I .~mt~l cr 

- 

EPA Mt* L hod No . t’reservat ive M,lxirnum ttotdlng T11r I - 

PhLtl.llaLo EsLtbrs 

( I nc. 1 udcs : Htwzyl but yl /‘I.< ti,r I .)I c* 

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 af Ler exlracc ion 

Ni t rosamlncs 

( I nc 1 udtts : N-r~iLrosodlmt~Lhylamlrw 

N-ILL rosod I phenylaairte 

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“4 I 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 

Ch lordane 

4 ,4 -DDll 

4,4-DDE 

4 ,4 -DDT 

Dteldrtn 

Endosu I tan I 

Kndosu I tan 1 I 

Enclosultan Sul filtt’ 

End r 111 

Endr In Aldehyde 

Ilcpt achlor 

tl~rptachlor Epoxlde 

Toxaphcne 

tv;n-1016 

tu-tL2t 

KM- 12 12 

I’CR-I242 

KM-I 248 

I’CB - I 2 54 

KM-1260) 

EPA Mc t twd No. I’reservat ive Maximum llolding Time 

608 7 days unt 11 extract lou, 

40 days after extt(actlon 

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

Nl t ro,aromat 1t.s and Isophorone 

(llr~.\\ldes: I sophorone 

N t I rohenzene 

2,4-I)lnlLrotoluene 

2,6-l)trritrololuene) 

It t’A He I hod No. 

--- - 

Yreservatlve MaxImum Iloldlnp: Time 

bO9 coo1, 4°C I diiys IIII~ I1 extract Ion, 

40 days .!I ler extrection 

b I 0 / days III~L I I ~8x1 r;rcL Ion, 

40 days ,1f ter cxlractlon 

7-18 
TABLE 7. 3 (Cant inued) 

sA~f~1.k: PKESEKVA’~‘ION ANI) 1101.1)INc; T IHES YOK OKGANIC PHIOKITY POLLUTANT ANALYSIS (COIIL lllued) 

Chlorlua~ed Hydroc-arbons 

( 1 nl.1 udcs : 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 ra 1, Acids and Pest icicles 

fCf’A MC L hod No. Prescrvat lve Max lmum If0 14 141~ 1 L.. 

612 Cool, 4°C days IIIILII extraction, 

days .IfLer ext 1’ action 

613 

624 

625 

- 

1 Should only be used in the prescllce of residual chlorine 

2 For dlphcnylnl~rosamlne only 

3 Aldrin 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 

7-19 
Industri‘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 GC couple~l with mass spectrophotometry (CC/MS). The GC methods 

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 

7-20 
0 Base/Neutral, Acids, and Pesticides (Vethod 625) - Determines 

numerous orflanic pollutant conc:Jnt rat ions, i nc 1 ud i ncJ t hr)se 

para:ictttrs covered by GC Methods 604 through 61 2 

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 i on 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 11J and 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. 

7-21 
7.3.2 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, 

7-22 
APPENDIX A 

40 CFR Section 403.12 

Reporting Requirements for 

POTWs and Industrial Users 
9452 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 production
Federrl Register I Vol. 48. No. 18 I M’edzesday. lanuav 28. 1981 1 Rules and RePuiatlons 0153 

rad Strndrrd Industnrl Clrssific8h0~ of 

the opentlonis) crrncd out by such 

lndustnd L’scr Th:r dcscnpuon should 

Lncludr e uhetartx pmcrsr Begrem 

which indiutes pomts of D&huge 10 

the POTW from the regulrtrd pmcerro. 

(4) Flow measumnenf. The User shall 

submit inform&ion show-q the 

mrrsured l versge drily and maximum 

dally flow. m /Illon, per dry, lo thr 

PO-W km each of the followul~ 

(I) regulrtrd process stnuna; end 

(II) other smamr aa naussuy 10 

dew use of the combinrd wrstrstra~ 

formuh of j 403.6(r). (See pumgmph 

(b)(S)(v) of ltus secaon) 

The Coatml Authority faey eIlow for 

vertfleble l stietes of these flows 

where justified by cost or ferribrllty 

coasidurtloas. 

supportq data shall be submitted 10 

the Control Authontyr* 

[vi) Sampirng and rnrlysls shd br 

performed ta eccohnce rnth the 

tcchmquas pnscnbed u 40 CFR Put 136 

end emendmenu thento. Where 40 CFR 

Pert 136 does no1 wnUin runpiirq or 

uulytxd uctmiqura for the pollutanl h 

question, or when thr Adnun~sortor 

detenames thet the Pert 130 sampI.@ 

MCI l uJytiuI tech.aIqueB u, 

iaeppmprirte for the poilUIlt ill 

quesrroa. suapliag md udyslr hll be 

performed by using vrlidatrd anriyticel 

IWthodr or my 0th l pFLUble 

sunpIing rod ~~Iytkel procedurer 

tdUdh( pmcedurn suegrsled by the 

yti;:pr peniu l ppmved by thr 

(ii) II tbe crtcgonul Pntresbcnt 

Strndard u modified by I nmovsl 

allOWMU (0 403.7). he COp.blned 

WrJlJJtrrUl fO.Yt9h (f 4Q6(J)), Jndjor 

a Fundamenuliy 3Zerent Facton 

vanance 0 Q3.151 af:er the Lisu 

subrmts the report nquusd by 

paragnph 03) of tus secuon any 

necessuy emend=cnts 10 the 

Lnformrhoa nquested by p~sgr~n:~ 

ibIte) md (7) of hs srcaon anali be 

Jubatted by h User to the Convoi 

Adonty wkrllhm UQ drys after the 

modeled lima 1s cppmvrd 

(4 ComPLax@ Schedulr for Mectrng 

cal@pn’Cd htneotment Standa:as 

The fOliOWIng con&aoaa JhaU rppiy to 

the scheduie nqwred by paregraph 

(b)(7) of this sectloaz 

(5) Ahu8umment of PoflutanU (i) The 

uau shd idenafy the Pmtzeraamt 

Stendenie rppliublr to rrch r@eted 

Pm-= 

(II) In rddiuou the Umr rhlll rubmit 

thr results of runpling Md umlysir 

LdenUfylag the cutum end wnuntmtion 

(or mur. whm mquirod by the 

Sundud or Control Authority) of 

-TP 

ilutanu in th Dirfrom .a reguleted pmcesr Both deily 

m*r(mm ead rverege canceatretioa (or 

mass, whm required) shall be reportad 

Tba ample rhdI be representeuvr of 

ddy opu8tionr 

(vii) The Cokol Authcrity my dlow 

the submisston of l brselme repoti 

which uhliMl only historiuI fiAta so 

loag es the drtr provides iaformeQoa 

sufedeat lo drtennme the need for 

Iadustrial pretreetmoat meuures 

(v!li)ThebMdiwNportshdllndiute thr tim. dau end pleu. of 

sampling. end methods of enelysis. end 

sbeUfxrtUythrtmcllsuaplla#ead 

Mdyr1s ia npmsaltAuve of Ilormd 

work cydes and arpoctd pollutant 

DkbAqes to the Ponw 

(1) The schedule shell eoatain 

Iawmmu of pmgmr lo the form of 

deter for the WmEUwent Md 

completion of major rvrats lrrdrnq :o 

the wnrauction end operation of 

l dditloael pmtreeuoent requhd for the 

Iadueulel User 10 meet the rppkabir 

ubgoriul Fmtrrrtmenl Standmu (e.g.. 

hlrbg M engtnru. completing 

pmIimiauy piuu. wmpirw fLaal 

plum bcuting wnmct for major 

wmpowau wmmcncq coMmleion 

wmplrw coasmlction rte). 

(iii) Where feesibIs. umphs musl be 

obteiaed thmu& tbr flow-pmportiunel 

composite remphp uehnrques sprufied 

ia thr l ppliceble umgorical 

Pmtrrrtmrat SUrdud Whem 

wmpodtr ruapling IS a01 feulble, l 

greb suaple is rccepteblc 

(Iv) When the llow of thr streun 

bein( rempled is less then or eqd to 

950.000 liters/dry (rppmutely 

2MJXXl gpd). the User must teke three 

samples wdia l two-wrek penod 

whem lb. now of the stnam beq 

sampled b greeter thea os~a00 liters/ 

dry (eppmxmulely 25O.WO gpd). the 

User muat take JU( samplrs ~thn l 

two-wnk penod; 

, (VI Semples should bs tekea 

lnuwdiauly downstream fmm 

pmtreetmenl feciiities if such axut or 

lmmedietely downsueua brn the 

rtgdrt8d pacers U a0 prelrmtmeat 

l xisU. If other westrwaun ue auxed 

with the regulrted westeweter pnor 10 

pntmrtmnrn~ the User should mersun 

the flows end ~aunrretloas ne~8~au-y 

to allow lua of the umointi 

wuusmam fomluia oi i 403.61@’ in 

ordu to l vaiwtr comowce wxa *a 

Pretreetment Stenduar. Where e.a 

dqmau conuamtlon or mur &nit 

hrs beea ulculeted LO lccordsnce WIU 

j 403&(r) this rdiusted Lmrl sioag ~vlth 

(61 Cetifiarrion. A stawmenf 

nvlrwad by en euthorlud 

mpmmtrtirr of the ladustrlel User (as 

defined ia rubpemgrepb (k) of thl~ 

swtloa) cad tied to by ? quaufied 

pmfessrond indiaUnp whether 

Remreneat Stead&s ere beiag nut 

on a coaaistrat brsia, ead if aof 

whether rdd.itionel operation cad 

atah- (0 cad M) aadlor 

l ldit&wI pretrertmeat :J nquimd for 

the Industriel User to meet thr 

Rntmatmmt sundub MCI 

Rquimment* cad 

(7) Comp~aace Schduie. II l dditionel 

premrmon~ d/or 0 end M ti be 

nqvrd to meet the Pretrertmeaot 

Stmdudr: the shonerl schedule by 

which the ladusti User .d pmndr 

ruch rd&Uoad pnueranent end/or 0 

and M. The wmphuon artr la thls 

ubduh shall a01 be Ietrr tbea the 

complianu dete l steblishsd for the 

l ppliuble Premetmeac St&. 

(3) Not leter &a 14 daya following 

erch &u In the schedule cad the ihI 

datr for complimca tne lndusmsl User 

shd submit e properr report to the 

Control Authonty mzlxdiag, et l 

minimum whether or not it complied 

with the inwmmt o! pmgreo to be me1 

on such dete and U not, the date on 

whch It rxprcu 10 comply w7th tOls 

lnuement of progress. he nrson for 

deley, ead the steps beq taken by he 

lndusti her tontum thr 

constmctioa to tic schedule estrbkshed. 

ln no weat rhd more than 9 montcJ 

elrpsa berwrrn 8uch pmgrerr reports lo 

thi Control Aulbority. 

(I) Wbm thr tadustnel User’s 

augoricd htrwtmmt Sundd has 

bma modified by l remove1 elloweace 

I j 403.7). the combiaed wrstesarem 

fonnulr 0 4034r)l. and/or l 

iadmtdy DiYemzt Facton 

7an~ca I j 403.13~ at oil tame the user 

suomu ule rwon rwurra cy 

pamgrapn 101 oi rnis secuon. rho 

informrtron required by prrsqrphs 

tX6I, ann,;f z,cllon shdl peruin 

(d) Aeporr on compliuno with 

carqor~cdprermaanent standard 

deodhc Witi 90 drys follo~ng the 

dete for Arul comptience wrath 

rppkublr utego&el Pmtmtment 

Sunduda or in the use of a New 

Souru following coaua8amnent oi the 

lntmductioa of wesIewelsr iato the 

POTS. My hdustnal User sublect 10 

Reuehtmnrnt Slmduds end 

Rtqwmenu shrll submit 10 the 

Con& Autbonty s rrzx7 ;~&x~~ ‘A2 

Ylur8 Ma wtcM~cc3 ?I ai 

30~utlllu ~1 *ae hcunr z3m -2e 

mgulrua pmcns wiliw U8 U3;;ZG ;Y 

Pretreranenl Standaxis end 

Requmments and *he avenge and 

mmumm ddy flow for there ?rcc-s 

A-2 

Federal Rcgs:er II ‘~‘6. 46 

(ii) The deUr eMlym w@rB 

perfonk 

(iii) Who pWfORMd tit8 Mdy@eS: 

(iv) Tltc mrlytd techntqucs/ 

marhods ue: end 

(v) The resulta of ruch Mdysrs. 

(2) Any lndusmel User or POTW 

rubjed to thr reporting rrquiremenU 

csublirbed in rhea mction Ihell be 

tqutred to rotem for l aummum of 3 

yrrn my fWCOrdJ of monitotig 

rcUtitlu end resulte (whetbrr or not 

ruch monitorulg l cuvltlu arm rquurd 

by thfe section) end shell mrkr such 

mauda l veileble for mspectton end 

copying by the Dtmctor end the 

Regionel Administretor (end POIW in 

the ceu of an lndustnel User). This 

period of ntentton shell be extended 

dunng the course of any wrrcrolved 

Liu~ation repding thr lndu,uiel User 

or fW2-W or when requested by the 

Dtrector or the Rc~onel Adminirtretor. 

[3) hy POT-W to which reporte ere 

rnbmittd by M tndusuiel User 

powant to peregrephs (b). Id). end (e) 

of tbb Be&on rbdl ntem ruch rrpom 

forenunitnumof3yrucald~heIlmeko 

rtgb mpom l veileble for imprctIon 

end copying by the Director end the 

Reglonel Admirustretor. This period of 

nmntion shell be extended during the 

course of any umesolved litigation 

merdltq tbe dhcherge of poUutente by 

the lndustrlel User or the operetloa of 

the POTW ~treetmeat Rvgrem or 

when requested by the Director or the 

Regioml Adminirtretor. 

(e) D8finirion Ibe term -quest& 

meeMimkrdurtMlUluotePO?WtX 

other bltem#tod prtwtl seeking e 

varhwe from tbe lhtr ~pdfied In 8 

U~ricel mmrrmeat sturdeni 

(b) Rupasr and scope. La rrteblirhiry 

utagoriul Preotetznent Stenderdr for 

**ml aourcea, the EPA will take into 

l cwunt Au thr informehtIa 11 can 

collect. develop end rolidt regerding the 

rectors relevent to pnmeaaeat 

rtandeh under wcaoa XV(b). In come 

UMI. Anforme~on which may effect 

lheu mun5mt stuldudr wtll not 

k l veileblo or. for other reuom. will 

not be canaide& during their 

developmennl. Ae l mult It mey be 

nrceruy oa a cram-by-cue beets to 

edjust the limitr m utegoncel 

Pretrartmeat stMderd& mektng theta 

either more or lest tUUl8eat U thy 

apply to a cerma lndustnal U8er within 

M indurtnel cetqory or rubcetrgm. 

This wUI only be done if dete ~peuAc to 

that lndustnel UW mdxeter It pnseau 

frcton fundementelly different from 

thaw conridered by EPA 10 developmg 

thr limit et i8nre. Any intefwted paraoa 

bslievutg thet fecton reletmg to en 

hduttiel Usrr em fundemmtelly 

dihmt ,Lom 9e Izcto:s considend 

dunng development oi a ategoricef 

Prttroeanrnt Stendud eppliable to 

that User end further. thet the rxlstcwe 

of there frcton futiflrr a tufhr8at 

diaha~r limit from that rpdied in th8 

l ppliceble utrpriul Reueeanmt 

Stenderd. mey request e fundementelly 

dufwaat frctom vutAncr under til& 

Mcuatl or mtch a vukaca wquut may 

tm ~tieted b+ thr mA. 

(c) CnUrio.-(l~ Geneml cdm’a A 

request for a vrrhce besed upon 

fuademrntdly diffrrent factors shell be 

l pproved only LE (r) Then ts en l pRliable atagorkd 

mtwr5eat stended which 

8peu!kally cantml the polluteat for 

Whld rltemeovo Illah hew bua 

rqurstedz and 

(ii) Fecton mletig to the dirchqr 

controlled by thr ute 

Rme5eat s terdaxEd 

fundemeatelly dill-t km the feetom 

~m.$mhra b&EPA la eatebu the 

(2) CMenb appfiallde co&e 

rrmgmr J!itnia A verienu rqwst f-a 

the ertabliahmmt of li&s less s mt 

olenrqtdmdbythesteJldudrhll0 -7 

Approved only LE 

(i) 7%. eltunaUv0 limM mqweted L 

noIeurUtngentthenjuett&dbythe 

~m~-wMd di&macu 

(ii) Thr eltenleuw Limit wul wt nsldt 

bt a vloleuoa of prohiblun me 

rtmderda pmscribed by or at&&shed 

und8rf403.3 

(iii) The dternedw limit will wl 

mmlt la a MO-w8ter quebty 

envtroxlmeatel impact (bdudlag mtrly 

-U fuaduaMtAuy mom 

edvme thea thr Lmpect consIdered 

dur@ developmeat of LY Prmuutmeat 

sllndudr wd 

(iv) hplieaa with the Steader& 

(either by tutq the technologiee upon 

whkhthrS-urbeMdaby 

tu$go~,y~ttd ehetaetIvee1 would 

(A) A rem&al coat (rd@tad for 

innetitm) wholly out of pwptdoll to tfl, 

rawvJ wet uxuiderod dttrbq 

developmeat of the Standards or 

(B) A wa-water qurlity 

exxvtrowlentll impecl (~dOdiag eaergy 

reqmts) fundemtlltelly more 

edvcrse tbhm the impect cooridered 

durtt devrloomeat of -he SW 

(3) Cnteno appiicobir w mom 

rumgent limits. A vuirnu request for 

the crteblirhmeat of liaitr mom 

aeinlrnt tba nqpfnd by the Stander& 

ahell be epproved only (1: 

11) The dWtAUW limit nqwst Is no 

mom thinyen then jurtiflrd by the 

fundunentel diffetunu: od 

(ii) COmpliMC8 rvlth the dl*mUve 

IlmAt would not rerult in either. 

(A) A removal cat (edrusted for 

infletion) wholly out of prmponioa to the 

rwwvel cost considered d.w 

developmtnt of the Stende&z or 

(El A no&weta quebty 

envlronmrnt8l impact (mduding energy 

mquirameats) kndementelly.mon 

l dveree rhM the impecl corrrldend 

d 

“L”z 

development of the Stenderds. 

(d) OC~M conrrde&fu.~dommtally 

different Frctom whch may be 

conddered fundemeatelly dif!erent e: 

(1) TbO Mtpn 0? pudIty of poilutenu 

coataid in the mw weate !oed of the 

‘i$KXZ%Eiks process 

werteweter end d&mat die&-d: 

(3) Non-water qualiv eavimnmentrl 

Impact af waool end tmetrnrnt of the 

U&o mw weete Ioak 

(4) Eaergy mqldmmMta of the 

l ppliuUoa of con&d end tre85ent 

techM~ 

(61 M etze. lead evaileblllty. mad 

cton$gmual u they relet. tn ti Uur’r 

I-- 

a fedbUrr: proatwr 

=wMm-e-w~Md 

of tbe eppliuloa of 

*wa with nquired 

aiatrctlmchw&#y. 

(e) Foeram which tviff nor be 

wnei&.md)lidmwUy diflerwnl. A 

V~~MAt~pOPZiWOfAWll8 

tqueetuaderthiasecuonMynotbe 

pmtedoauryofthefallonnaggroundr: 

(1) The frasibtllty of instellIq thr 

rquhd weete treatmeat equipttunt 

wmathetimethbrAcldlowr: 

(2) The e8eedal that the stulderda 

CAnaot be l chieved with the rppropnete 

WUt@ tW8tmMt fUih88 ltUt&ed. if 

ruch eurrUon ir not berrd on factw 

listed in purgrepb (d] of this rrction; 

(3) The User’s ebility to pay for the 

required werte treetment: or 

(41 The bapea of a Diachuge on the 

quell of thr POTWI receiving wetrn. 

(f) r tat, or Iowf faw. Not&# in thin 

aecuoa dull be cun.sOurd to impeir the 

right of my Hate or 1ouuty under 

8ectioa S10 of tb8 Act to impou more 

rmngmt Utaiteuoaa then nqurnd by 

Federul lew. 

W Application dradhc 

(I] Request, for 8 venenu and 

rupportlng infometion must 90 

nummad in wrihtq to the 3rac:or or co 

the Ecifwemmt Diwcn 3imar. II 

l ppropMt0. 

(2) b order to be coneiderrd request 

for venences mmut be submitted wrthm 

A-4 
APPENDIX B 

ELECTROPLATING & METAL FINISHING CATEGORY: 

List of Toxic Organic Compounds Regulated as a 

Component of Total Toxic Organics 
APPENDIX B 

TOXIC ORGANIC COMPOUNDS REGULATED 

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 phtalate 
Diethyl 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-2 
2,6-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-3 
APPENDIX 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 COMPOUNDS REGULATED 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-1 
APPENDIX D 

Analytical Procedure for Determining 

Oil and Grease Concentrations Under 

Coil Coating Regulation 
APPENDIX 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. 

D-l 
: 

3 I 

c 

a 

R 

L 

w 

. 

3 

3 

= 

. 

LP 

8 

3 

D L 

. 

3 

a 

. c S 

3 

t 

a 

Y 
Table 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. We buy 

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-3 
b. 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-urns and 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-4 
C. 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-5 
B. 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- 6 
F. 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-7 
IV. 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-8 
APPENDIX 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 Na2SO4 to the filter paper cone

and slowly drain emulsified solvent onto

the crystals. Add more Na2SO4 if

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.

1

Teflon or equivalent.

2Whatman No. 40 or equivalent. 3

Freon or equivalent.

4Davidson Grade 950 or equivalent.

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

E-1