&EPA
          United States
          Environmental Protection
          Agency
            Office of
            Water Enforcement
            and Permits
October 1983
Procedures Manual
for Reviewing a POTW
Pretreatment Program
Submission
                  01A0004413
                        Stream/Ocean

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
                          GOT  5 1983                   OFFICE OF
                                                        WATER
MEMORANDUM
SUBJECT:  Pretreatment Program Guidance

TO:     	 Users of the Procedures Manual for Reviewing a
          iPOTW Pretreatment Program Submission
         , .tA-CX>Cx««-  \rJ •  /-]"*.
FROM:     Kebecca W. Hanmer
          Acting Assistant Administrator for Water  (WH-556)


     This manual presents the procedures for EPA Regions and
approved States to review local POTW pretreatment program submis-
sions.  It facilitates the determination whether the submittal
contains the data and information required by the General Pretreat-
ment Regulations (.40 CFR Part 403), and whether the program is
approvable.  It provides the reviewers with a suggested separate
checklist for reviewing each program element.

     EPA Regional offices and States with approved programs must
continue their efforts to review and approve local POTW pretreat-
ment programs in their respective geographical areas.  The approval
of local POTW pretreatment programs is the cornerstone of the
Agency's national pretreatment program.

     While this approval is critical to the success of the national
pretreatment program, Approval Authorities must ensure that all
substantive parts of the local pretreatment program are present
when the program is approved.  Prematurely approving incomplete
programs may cause major problems in the future.  In instances
where a segment of the program is not fully developed when the
program is approved, then the Approval Authority and the POTW
should publicly document (preferably in writing) that a segment
of the program is not fully established and that it will be
developed after approval in accordance with an agreed upon time
table.

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                              - 2 -
     Approval Authorities can use this manual to review and
approve any local POTW pretreatment program.  However, when using
the manual and its checklists, these Authorities must understand
that the manual is for guidance and its use must be tailored to
the complexity and size of the program under review.  A program
developed by a small POTW with relatively few industrial users
should not be reviewed in the same manner as a program developed
by a large POTW with many industrial users.  The level of detail
and sophistication in the former program will naturally be less
than in the latter program.  Approval Authorities must bear this
fact in mind when using this manual.

     I believe that Approval Authority personnel will find this
manual to be a useful tool in reviewing local POTW pretreatment
program submissions on a consistent basis.  As this guidance may
be revised periodically to reflect program experience or changes
in program regulations, please feel free to write to the Office
of Water Enforcement and Permits (EN-336) if you have suggestions
on how the guidance may be improved or areas which should be
addressed.  Thank you.

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                PROCEDURES MANUAL
                       FOR
                REVIEWING A POTW
         PRETREATMENT PROGRAM SUBMISSION
                 Rebecca Hanmer
 Acting Assistant Administrator, Office of Water
              Bruce R. Barrett, Jr.
Director, Office of Water Enforcement and Permits
                Martha G. Prothro
           Director, Permits Division
               Dr. James D. Gallup
        National Pretreatment Coordinator
                  October 1983
     Office of Water Enforcement and Permits
                 Office of Water
      U.S. Environmental Protection Agency
               401 M Street, S.W.
             Washington, D.C.  20460

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                     ACKNOWLEDGEMENTS
     This document was prepared with guidance from EPA
Headquarters, Office of Water Enforcement and Permits
and EPA Regional Offices.  The State of Maryland Water
Resources Administration and New York State Department
of Environmental Conservation participated as peer
reviewers and provided valuable comments which have been
incorporated into this document.  This Procedures Manual
was prepared by JRB Associates under EPA Contract No.
68-01-6514.

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                               TABLE OF CONTENTS


                                                                        Page

1.  INTRODUCTION	1-1

    1.1  PURPOSE OF THIS MANUAL	1-1

    1.2  HOW TO USE THIS MANUAL	1-2

    1.3  COMMENTING ON PROGRAM SUBMISSIONS 	  1-3


2.  LEGAL AUTHORITY	2-1

    2.1  SUBMISSION COMPLETENESS 	  2-2

         2.1.1  Relevant Regulations 	  2-2
         2.1.2  Evaluation of Completeness 	  2-2

    2.2  EVALUATION OF ATTORNEY'S STATEMENT	2-3

         2.2.1  Relevant Regulations 	  2-3
         2.2.2  Evaluation of Statement	2-4

    2.3  LEGAL ADEQUACY	2-5

         2.3.1  Relevant Regulations 	  2-5
         2.3.2  Evaluation of Adequacy	2-5

    2.4  MULTIJURISDICTIONAL SUBMISSIONS 	  2-13

    2.5  LEGAL AUTHORITY CHECKLIST 	  2-14


3.  TECHNICAL INFORMATION	3-1

    3.1  INDUSTRIAL WASTE SURVEY 	  3-1

         3.1.1  Adequacy of the Survey Master List	3-2
         3.1.2  Thoroughness of Survey Questionnaire 	  3-3
         3.1.3  Response to Survey	3-5
         3.1.4  Completeness of Summary Information	3-5

    3.2  LOCAL EFFLUENT LIMITS 	  3-6

         3.2.1  Identification of Past POTW Operating Problems ....  3-7
         3.2.2  Sampling and Analysis to Determine Fate and Effect . .  3-8
         3.2.3  Development of Local Effluent Limits 	  3-10

         TECHNICAL INFORMATION CHECKLIST 	  3-12

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                           TABLE OF CONTENTS (cont)


                                                                        Page

4.  PROGRAM IMPLEMENTATION PROCEDURES	4-1

    4.1  UPDATE THE INDUSTRIAL WASTE SURVEY	4-1

    4.2  NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS
         AND REQUIREMENTS	4-2

    4.3  UNDERTAKE COMPLIANCE MONITORING PROCEDURES	4-3

         4.3.1  Receive and Analyze Self-Monitoring Reports
                and Other Notices	4-4
         4.3.2  Conduct Compliance Sampling and Analysis 	  4-5
         4.3.3  Investigate Noncompliance	4-7

    4.4  PUBLIC PARTICIPATION	4-9

         PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST 	  4-12


5.  ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING 	  5-1

    5.1  RELEVANT REGULATIONS	5-1

    5.2  EVALUATION OF ORGANIZATION AND STAFFING 	  5-2

         5.2.1  Clear and Appropriate Lines of Authority 	  5-3
         5.2.2  Identification of Staff Responsibilities 	  5-4
         5.2.3  Staff Qualifications 	  5-5
         5.2.4  Staffing Levels	5-5
         5.2.5  Coordination with Other Departments	5-6

    5.3  EVALUATION OF EQUIPMENT	5-6

    5.4  EVALUATION OF FUNDING	5-11

         5.4.1  Implementation Costs 	  5-12
         5.4.2  Financing Sources and Cost Recovery Systems	5-15

         RESOURCES CHECKLIST 	  5-18


APPENDIX A  BIBLIOGRAPHY OF PRETREATMENT REFERENCES	A-l

APPENDIX B  DEVELOPMENT OF DISCHARGE LIMITATIONS TO CONTROL
            INCOMPATIBLE POLLUTANTS	B-l

APPENDIX C  PRIORITY POLLUTANTS AND CATEGORICAL INDUSTRY INFORMATION  .  C-l
                                      ii.

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                         LIST OF TABLES AND WORKSHEETS
WORKSHEET 1

WORKSHEET 2

WORKSHEET 3

WORKSHEET 4

TABLE 5-1


TABLE 5-2


TABLE 5-3


TABLE 5-4

TABLE 5-5

TABLE 5-6


TABLE 5-7
                                                        Page

LEGAL AUTHORITY CHECKLIST	2-15

TECHNICAL INFORMATION CHECKLIST	3-12

PROGRAM IMPLEMENTATION PROCEDURES CHECKLIST	4-12

RESOURCES CHECKLIST	5-18

POTW PRETREATMENT PROGRAM PERSONNEL
REQUIREMENT RANGES 	  5-7

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES 	  5-8

ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
PRETREATMENT PROGRAM BY PROGRAM ACTIVITY 	  5-9

TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW. .  5-13

TYPICAL COMMERCIAL LABORATORY COSTS	5-14

FACTORS AFFECTING POTW LEVELS OF EFFORT FOR
PRETREATMENT PROGRAM OPERATING TASKS 	  5-16

HYPOTHETICAL POTW PRETREATMENT PROGRAM
OPERATIONAL COSTS	5-17
                                  iii

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                               1.  INTRODUCTION

1.1  PURPOSE OF THIS MANUAL
     This document has been prepared to assist States and EPA Regional Offices
in reviewing local pretreatment program submissions.  It is intended to pro-
vide a framework for the review of local programs as well as general criteria
for evaluating these programs.  The document can also serve as a starting
point for States to develop individualized checklists for review of local pro-
grams under their jurisdiction, if such checklists have not yet been devel-
oped.

     A successful pretreatment program cannot be developed without adequate
legal authority, technical information, implementation procedures, and re-
sources.  Each of these elements is essential in a successful program, and the
pretreatment program submission must demonstrate that all are present if it is
to be approved.  A separate chapter in this manual is devoted to each element.
Each chapter contains:

     •  A summary of pertinent regulatory requirements
     •  A discussion of key items that should be included in the submission
     •  General guidelines and criteria for assessing the adequacy of the
        approaches proposed by the POTW
     •  A checklist to aid the reviewer in evaluating completeness and
        adequacy.

     The focus of the review is to determine that the program not only meets
regulatory requirements, but also that it will function well once it is
implemented.

     A majority of the regulatory requirements associated with a local pre-
treatment program are addressed in the legal authority chapter.  Other
chapters identify activities, staff roles, and program items that are most
likely to be included in a well-planned program.
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1.2  HOW TO USE THIS MANUAL
     Each of the four checklists is intended to be photocopied and used in
actual reviews.  Agencies using these checklists may wish to separate the
various sections and delegate portions of the review to individuals who have
expertise in the appropriate areas.  For example, a review of the technical
information chapter may be assigned to an engineer.  A lawyer may be assigned
the task of reviewing the legal authority chapter, while someone with manage-
ment or administrative experience might be responsible for reviewing the pro-
gram implementation and resources sections of the submission.  Each checklist
allows the reviewer to indicate whether the section as a whole adequately
satisfies Federal requirements, and to sign or initial this decision.

     Not every item on a checklist must necessarily be included in the submis-
sion to satisfy Federal requirements for an approvable program.  Optional
items are recommended on the checklists for a more comprehensive pretreatment
program, but these items are not required.  The review must be flexible, since
the features necessary to operate a pretreatment program in a large community
may not be necessary or appropriate for a smaller one with few industrial
users.  Where tables have been included in this manual to identify levels of
staff and costs associated with operating a program, they are intended to be
used as general guidance for the reviewer, not as rigid requirements for the
program submission.  Program approval must ultimately be based on the best
professional judgement of the reviewer.

     To make this manual most useful, the reviewer should be familiar with its
companion document, Guidance Manual for POTW Pretreatment Program Development.
The Preparation Manual is intended to assist municipalities in developing
their pretreatment programs and in preparing their program submissions.  It is
important for the  reviewer to understand both the objectives that the local
program is designed to achieve, and the process followed by a POTW in devel-
oping its program.
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1.3  COMMENTING ON PROGRAM SUBMISSIONS
     A pretreatment program submission may be inadequate in some areas.
Inadequacies can be expected because the level of guidance and expertise
available to POTWs developing pretreatment programs varies across the country.
The reviewer should look upon weaknesses in a submission not as a problem,  but
as an opportunity to give constructive guidance to the POTW authorities.
Comments should be designed to assist a particular POTW in preparing an
approvable submission, not simply make the submission package look good or
enable the POTW to comply quickly with a deadline.

     The reviewer should point out specific weaknesses in the submission to
the POTW and offer suggestions to correct these weaknesses.  By providing
clear and specific comments to the POTW, the reviewer can save the POTW time
in revising its submission.  Written comments should be provided to the POTW
to ensure clarity, perhaps by sending a copy of the checklist with an explana-
tory cover letter that outlines the submission's inadequacies.  The EPA
Regional Offices have a number of guidance documents, such as the Preparation
Manual, that contain information useful to a POTW developing its pretreatment
program.  These documents (or relevant portions of them) could be attached to
the cover letter and sent to the POTW as additional assistance in program
development.  Appendix A lists several guidance documents relevant to program
development.

     The agency's review of a program submission should be complete before it
is transmitted to the POTW.  All comments and questions should be sent to the
POTW at one time.  The POTW should have a reasonable time period within which
to respond to the comments.  If better documentation only is needed to com-
plete the submission, a few weeks will probably be sufficient.  However, if
major areas were not addressed (such as sampling and analysis, or local pol-
lutant limits), as is often the case in first submissions, many months may be
needed to develop the required information.
                                     1-3

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                              2.  LEGAL AUTHORITY


     The ability to develop and implement a successful pretreatment program

depends upon the existence of adequate legal authority.  Since program imple-

mentation and control rest with local government, it is important that legal

authority be present at this level.  The POTW must be able to respond to

challenges by industrial users, to protect its investment in the treatment

plant, to ensure the beneficial uses of its waters, and to protect the health

and welfare of its citizens.


     The legal authorities needed to implement a pretreatment program are

listed in 40 CFR 403.8(f)(l).  In summary, a POTW must be able to:
     •  Deny or condition new or increased contributions of pollutants, or
        changes in the nature of the pollutants discharged to the POTW

     •  Require compliance with applicable pretreatment standards and require-
        ments by industrial users

     •  Control, through permit, contract, or other means, the contribution to
        the POTW by each industrial user

     •  Require the development of a compliance schedule by each industrial
        user, and the submission of all notices and self-monitoring reports as
        necessary to assure compliance

     •  Carry out all inspection, surveillance, and monitoring procedures to
        determine compliance, independent of information supplied by the
        industrial user

     •  Obtain remedies for noncompliance, including the ability to seek
        injunctive relief, seek civil or criminal penalties, and/or collect
        liquidated damages

     •  Comply with the confidentiality requirements and limitations on data
        restrictions specified in 40 CFR 403.14.


To document these authorities, the materials submitted by the POTW must

include a statement from the city solicitor or comparable official, and copies

of all pertinent statutes, ordinances, and related material.
                                     2-1

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     Determining the adequacy of a POTW s legal authorities requires a two-
part review.  First, the submission must  be reviewed to ensure that it is
complete.  Second, if the submission is complete, the individual items must be
reviewed in more detail to determine that the legal authorities are adequate.
The checklist for evaluating legal authority is divided into two parts to
facilitate this review.  The remaining sections of this chapter explain how to
use the checklist, and how to evaluate each of the items on the checklist.

2.1  SUBMISSION COMPLETENESS

2.1.1  Relevant Regulations
     40 CFR 403.9(b) identifies the information that must be submitted to
document legal authority, including:

     1.  A statement from the city solicitor or a city official acting in a
         comparable capacity (or the attorney for those POTWs which have in-
         dependent legal counsel) that the POTW has authority to carry out the
         program.
     2.  A copy of any statute, ordinance, regulation, contract, agreement, or
         other authority that will be relied upon by the POTW to administer
         the program.
     3.  A statement reflecting the endorsement or approval of local boards or
         bodies responsible for supervising and/or funding the program.

2.1.2  Evaluation of Completeness
     Part I of the Legal Authority Checklist is designed to evaluate complete-
ness.  The final pretreatment program submission should be reviewed to ensure
that all of the items listed above are included.  If they are not, the re-
viewer should notify the POTW that the submission is incomplete, noting  the
specific deficiencies.

     To determine that statements of all local boards/bodies are present, the
reviewer may first refer to the organizational portion of the submission  to
identify the local boards/bodies  involved  in the program.  It is also a good
idea to check the technical information portion of the submission because data
                                     2-2

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from the industrial waste survey, service area description, or maps might
indicate participation by other jurisdictions.  In several cases, a check of
the letterhead has also identified other boards/bodies.

     Finally, if any of the legal authorities cited are discretionary on the
part of an official, the reviewer should look for a statement endorsing the
program by that official.  While such an endorsement is not mandatory, it is
highly desirable.  This endorsement is separate and distinct from the "funding
endorsement."

     Having completed this review, the next and more difficult step is to
review the adequacy of the documentation itself.  While the documentation may
be complete, even extensive, the requisite legal authority may not be present.
Conversely, legal authority may be adequate, but poorly documented due to a
lack of understanding.

2.2  EVALUATION OF ATTORNEY'S STATEMENT

2.2.1  Relevant Regulations
     40 CFR 403.9(b)(l) requires a statement from the POTW attorney, city
solicitor, or another city official acting in a comparable capacity.  The
individual who signs this letter should be the person who is responsible for
bringing an enforcement action in court.  An acceptable statement must
identify:

     1.  The provision of the legal authority under section 403.8(f)(l), which
         provides a basis for each procedure under section 403.8(f)(2)
     2.  The manner in which the POTW will implement the program requirements
         set forth in section 403.8, including the means by which pretreatment
         standards will be applied to individual industrial users (e.g., by
         order, permit, ordinance, contract, etc.)
     3.  How the POTW intends to ensure compliance with pretreatment standards
         and requirements and to enforce them in the event of noncompliance by
         industrial users.
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It is important to keep in mind the following:
     •  The statement must cite the provision of the POTWs legal authority
        that fulfills each 403.8(f)(l) requirement, be it in the sewer use
        ordinance, city code, or some other document
     •  If the legal authority for each 403.8(f)(2) procedural requirement is
        not clear, the statement should elaborate on where the requisite
        authority lies
     •  Whatever legal authorities exist in the permit, contract, etc., should
        also be cited
     •  The statement must specify the legal remedies that will be used to
        ensure compliance with pretreatment standards and to enforce against
        violators.
2.2.2  Evaluation of Statement
     Part I of the Legal Authority Checklist is also used to evaluate the
attorney's letter.  In evaluating an attorney's statement, look for evidence
that the attorney understands the scope of the POTWs pretreatment program.
Three basic questions should be answered in the evaluation:

     (1)  Does the statement identify the provision of legal authority for
          each procedural requirement under 403.8(f)(2)?
     The attorney's letter must specifically refer to the basic statutory
authority for the entire program (usually a provision in State law authorizing
the municipality to enact certain local ordinances or to enter into con-
tracts) , and cite particular ordinance (or contract or permit) provisions for
each authority listed in 403.8(f)(l).  Where this has not been done or where
the cited provisions are found to be inadequate, the reviewer should note the
insufficiencies and a letter asking for clarification should be sent to the
attorney.  Copies of this letter should also be sent to the POTW, EPA, and/or
the State.  Any clarification received should be reviewed for completeness and
inserted into the submission package.

     (2)  Does the statement identify the manner in which pretreatment program
          requirements of 403.8 will be implemented?
     The attorney must state the control mechanism(s) to be employed in
applying pretreatment standards to industrial users.  These include permits,
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contracts, ordinance provisions, and orders, among others.  Most attorneys'
statements will not contain a detailed listing of 403.8 procedures, and this
is not necessary.  A general description of the procedures %nd relevant con-
trol raechanism(s) is sufficient—provided the submission contains detailed
descriptions elsewhere.  Often, the attorney's statement will simply refer to
the appropriate portions of the submission.  This is acceptable if the submis-
sion itself is found to be adequate.  If it is not, the attorney, POTW, and
other parties (e.g., EPA, State) should be notified of the problem with the
submission.

     (3)  Does the statement identify how the POTW intends to ensure compli-
          ance?
     A detailed explanation of compliance procedures does not necessarily have
to appear in the attorney's statement as long as these procedures are de-
scribed elsewhere in the submission.  If the attorney's statement refers to
such a description or generally describes enforcement procedures that will be
followed, this portion of the statement should be judged adequate.  However,
if enforcement is the responsibility of more than one jurisdiction, the state-
ment must explain how the POTW will ensure that the other jurisdictions carry
out their responsibilities, typically through a joint powers agreement (see
Section 2.4, Multijurisdictional Submissions, if more information is needed or
desired to make a determination).  The statement should specify remedies
available in the event such an agreement is breached.  A letter from the
attorney for each jurisdiction is required.

2.3  LEGAL ADEQUACY

2.3.1  Relevant Regulations
     The legal authorities required for a local pretreatment program are
listed in 40 CFR 403.8(f)(l) and summarized in the introduction to this
chapter (page 2-1).  Each is discussed in turn below.

2.3.2  Evaluation of Adequacy
     The reviewer should look first for a reference to the State law author-
izing a municipality to enact an ordinance controlling use of the public sewer
                                     2-5

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system and treatment plant.  In some situations, several municipalities may
join in an agreement forming a new entity to operate and control a POTW and
its users.  The te%ms of such an agreement must be examined to determine the
new entity's powers and to ensure that State law authorizes these powers.

      Part II of the Legal Authority Checklist is used to assess the adequacy
of the authorities available for a POTWs pretreatment program.  The required
legal authorities may be contained in a sewer use ordinance, joint powers
agreement, series of contracts, local regulations, or a combination of these
documents.  Pretreatment programs that include many jurisdictions must contain
legal documentation from each participating jurisdiction.

     The submission must show that the POTW has authority to:

     (1)  Deny or condition new or increased contributions
     A POTW must have the power to regulate the discharge of pollutants which
may cause pass-through, interference, or sludge contamination problems, or may
exceed Federal categorical standards.  Any ordinance or other written manifes-
tation that provides authority to effectively control such discharges by in-
dustrial users will satisfy this requirement.  The reviewer should look for a
general prohibition of unauthorized (unpermitted) discharges and the authority
to deny or place conditions on discharges that change in character or volume
(e.g., a permit that can be modified upon notice of changed discharges).  It
is recommended that a POTW require an industrial user to provide timely notice
of any substantial change in the quantity or quality of its industrial waste
discharge.

     (2)  Require compliance with applicable pretreatment standards
     The POTW must be able to prohibit the introduction of pollutants into the
system which pass through or interfere with the operation or performance of
the treatment works.  To accomplish this, the POTW must be able to enforce:

     *  General prohibitions against interference and pass-through
     •  The five specific prohibitions listed under 403.5(b)
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        Any local limits developed to implement the general and specific
        prohibitions
        National categorical pretreatment standards as they are promulgated.
     The POTW must be able to require compliance with national categorical
pretreatment standards as they are promulgated.  This prohibition should be
spelled out in the ordinance.  The ordinance should explicitly reference
Federal pretreatment regulations and standards as an indication that these
standards have been fully incorporated and made enforceable by the ordinance.
Since not all of the national categorical standards have been promulgated, it
is unlikely that a complete list of the standards will be included in an
ordinance.  Authority is adequate if the ordinance states that national
categorical standards will apply to industrial users once such standards are
promulgated, or that such standards will be imposed as a permit or contract
condition.

     When operational problems arise, POTW officials must have the legal
authority to impose or revise local effluent limits to correct the problem.
Any generic authority to establish specific effluent limits is adequate.
Ordinance language indicating that local effluent limits may be made more
stringent than prevailing Federal standards in order to meet the POTW's NPDES
permit limitations or State water quality standards is recommended, but not
required.

     Another operational problem that must be considered is sludge contami-
nation, which often limits disposal options.  This concern stems from the
Federal pretreatment regulations which define a POTW interference to encompass
any discharge that prevents sludge use or disposal in accordance with Federal,
State, and local laws.  Accordingly, either the ordinance definition of inter-
ference or effluent limits set in the ordinance should effectively prohibit
discharges which prevent proper sludge use or disposal.

     Usually prohibited discharge standards are spelled out in an ordinance.
If they are not, authority may be adequate so long as the prohibitions can and
will be imposed as permit or contract conditions.  General language is
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sufficient for prohibited discharge standards.  Numerical limits are not
mandatory, for example, in defining explosive discharges.  Since similar
questions often arise in reviewing programs, a few special cases are discussed
here for guidance.  Where an industrial user end-of-pipe heat limitation is
set at a temperature higher than 104°F (as is often the case), the POTW should
demonstrate, as part of its technical submission, that the higher end-of-pipe
heat limitation will not cause the treatment plant influent temperature to
exceed the prohibited discharge standard of 104°F.  In addition, it is
preferred that the dilution prohibition and the accompanying authority to
impose mass effluent limits be explicit in the POTW ordinance, and that these
authorities be extended to noncategorical industrial users.

     Sometimes ordinances allow POTWs to establish special agreements with
industrial users to accept industrial waste discharges which otherwise do not
conform to effluent limits contained in the ordinance.  Such provisions must
not allow the waiver of national pretreatment standards.  Local standards may
be waived, but national pretreatment standards may not, unless such a waiver
is granted by mechanisms established under the General Pretreatment Regula-
tions (such as removal credits, fundamentally different factors variances, or
net/gross calculations).

     (3)  Control through permit, contract to ensure compliance
     The POTW must be able to control the discharge of each industrial user.
This individual control can be accomplished by a permit that allows discharges
conforming to the standards set forth or by contract where the POTW provides
its services subject to agreed upon terms and conditions (similar to permit
provisions).  An order to an industrial user is another acceptable technique.
Each of these approaches establishes a legal framework that controls the
volume and constitutents discharged, and establishes penalties for noncompli-
ance.

     For larger systems, the establishment of a discharge permit system to
administer and enforce pretreatment standards and requirements is strongly
recommended.  It should be noted that the regulations imply the use of a
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discharge permit, not a connection permit.  A connection permit merely allows
individuals to hook up to the sewer system, and is similar to a building
license or construction permit.  A discharge or sewer use permit regulates
continuing use of the sewer system and imposes conditions on discharges to the
system.  Once adopted, a permitting mechanism should contain the following
components:

     •  Permit application - used to collect pertinent data; often appended to
        final industrial discharge permit
     •  Limited duration - preferably no more than five years; allows periodic
        review of discharge conditions
     •  Non-transferability - any transfer of a discharge permit must, at a
        minimum, be subject to POTW approval
     •  Modification - allows incorporation of categorical standards and any
        specific effluent limits necessary to correct operational problems at
        the POTW; useful in dealing with noncompliance
     •  Conditions - conditions for discharge should be clearly stated in the
        discharge permit
     •  Revocation - excellent enforcement tool; permit system can be used
        effectively to enforce against detrimental activities besides illegal
        waste discharges (e.g., falsification of self-monitoring reports,
        tampering with monitoring equipment and methods, refusal to allow
        timely access to industrial premises, etc.).

     A discharge permit system should allow adequate flexibility in altering
discharge conditions to correct any operational problems at the POTW or to
reflect changes in environmental regulations.  An industrial discharge permit
should never grant excessive legal right to pollute, as may occur, for exam-
ple, if permits are issued for indefinite duration or made freely transferable
without the need for POTW approval.

     (4)(a)  Require development of compliance schedules for installation of
             technology
     A POTW must have the authority to establish and enforce deadlines for the
installation by an industrial user of any treatment facilities needed to meet
applicable pretreatment standards.  "Compliance schedules" should either be
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specifically mentioned in the ordinance or be imposed under some broad author-
ity (e.g., permits).  The authority to require installation of pretreatment
technology and impose in a permit any conditions necessary to ensure compli-
ance with the ordinance is adequate.  These conditions should include time
limits that ensure progress is being made in discrete steps.

     (4)(b)  Require submission of notices and self-monitoring reports
     The POTW must be able to require the five reports listed in 403.12 and
any reports listed separately as part of a categorical standard, including:

     •  Baseline monitoring reports
     •  Compliance schedule progress reports
     •  Compliance report on categorical standards deadlines
     •  Periodic reports on continued compliance
     •  Notice of slug loading.

The reviewer should look in the ordinance (or contract) for either a detailed
description of the reports or a provision stating that reporting will be re-
quired at a particular official's discretion or as a permit condition.  If the
ordinance actually details what the reports will contain, the reviewer must
ensure that the reports required by the ordinance meet the specifications
listed in 403.12.

     A POTW must also have the authority to require industrial users to pro-
vide prompt notification upon the discharge of any slug load or accidental
discharge which may contribute to an interference at the treatment plant.  In
addition, it is recommended that a POTW establish penalties for any action
taken by an industrial user which affects the integrity of monitoring proce-
dures, such as falsifying self-monitoring reports or tampering with monitoring
equipment and methods.

     (5)  Carry out inspection, surveillance, and monitoring procedures
     A POTW must have the authority to enter industrial premises for the pur-
poses of inspecting, sampling and monitoring industrial waste discharges, and
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reviewing any records required to be kept onsite.  POTW officials must be
allowed to enter the premises at any reasonable time, not just during normal
working hours.  This additional flexibility may be necessary for handling
emergency situations, suspected illegal nonwork hour discharges, and cases of
suspected tampering with monitoring equipment.  No language in a POTW ordi-
nance shall require the POTW to afford prior notice of inspection, sampling,
and monitoring activities.  Although prior notice may be given to ensure
cooperation, it is not always a good idea because it may enable the user to
alter conditions being investigated.

      The checklist identifies several items that might be included in the
right to inspect.  It is not important for the ordinance to specifically list
these things so long as they are permissible interpretations of a given
authority.  The reviewer should beware of any language limiting the right of
an inspector to enter any premises where effluent sources, treatment systems,
or records are located (e.g., process investigation restrictions or limita-
tions on access to records).  A POTW must also have the authority to require
industrial users to install, use, and maintain monitoring equipment that en-
ables effective self-monitoring by the industrial user and compliance moni-
toring by the POTW.

     (6)(a)  Obtain remedies for noncompliance
     Two remedies for noncompliance must be available: injunctive relief, and
civil or criminal penalties.  An injunction may be necessary to prevent irrep-
arable harm to the treatment plant, to the health and safety of plant workers
and other individuals, or to the environment—those situations where damages
at law would not be an adequate remedy.  Injunctive relief might not be spe-
cifically mentioned in the sewer use ordinance.  It might still be available,
however, as a matter of common law.  In such a circumstance, the attorney
should explain precisely how the POTW can seek injunctive relief.

     Where a POTW has police powers, it must establish the authority to
enforce civil or criminal penalties against industrial users that violate
pretreatment standards or requirements.  An ordinance provision granting a
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POTW the authority to impose a penalty or fine of at least $300/violation/day
constitutes an adequate civil or criminal penalty for the purposes of this
requirement.  EPA regulations specify that, where State law does not permit a
municipality to impose civil or criminal penalties, the municipality must
enter into contracts that provide for liquidated damages for a violation of
pretreatment standards and requirements.  This type of contract should be
avoided if at all possible for two reasons.  First, courts generally do not
enforce penalty clauses in contracts.  A liquidated damages clause is likely
to be perceived as a penalty substitute and therefore held unenforceable.
Second, even if the clause is held enforceable, most POTWs would not want to
be limited in the amount recoverable for actual plant damages caused by an
illegal discharge.  The establishment of an administrative/adjudicative
mechanism (e.g., show-cause hearing) to resolve conflicts between industrial
users and the POTW is also recommended.

     (6)(b)  Authority to immediately and effectively halt or prevent any
             discharge
     A POTW must be able to halt immediately any actual or threatened dis-
charge which may present an imminent or substantial endangerment to the health
and welfare of persons or the environment, or cause interference with the
treatment plant's operation.  An ordinance can provide this authority by
allowing the POTW to suspend wastewater treatment service and/or discharge
permits in such situations, and by requiring the discharger to immediately
stop or eliminate the contribution upon notification of the suspension.  The
ordinance should further provide that if the discharger fails to comply volun-
tarily with a suspension order, the POTW may take any steps necessary, in-
cluding severance of the sewer connection, to prevent further discharge.  If
the ordinance does not provide such authority, it may still be available as a
valid exercise of police powers.  The POTW attorney should explain emergency
procedures in his statement.

     (7)  Comply with confidentiality requirements
     While a POTW may establish procedures to protect confidential data, it
must be able to release effluent data to the public.  Effluent data as defined
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in 40 CFR 2.302 must be available to the public without restriction.  Effluent
data include:

     •  Information necessary to determine the identity, amount, frequency,
        concentration, temperature, or other characteristics of any pollutant
        discharged
     •  A description of the manner or rate of operation of any source to the
        extent necessary to determine what was discharged under an applicable
        standard or limitation
     •  A general description of the location and nature of the source to the
        extent necessary to distinguish it from others.

Data or information on research, products, processes, and methods can be pro-
tected to a large extent and need only be released if necessary to disclose
that a source is in or out of compliance or to allow a determination of feasi-
bility/attainability of a standard or limitation.  Information that is propri-
etary, a trade secret, or business confidential can be withheld provided it is
not "effluent data" as defined above.

2.4  MULTIJURISDICTIONAL SUBMISSIONS
     POTWs often serve more than one political jurisdiction.  In these
instances, the agency or entity holding the NPDES permit for the discharge of
municipal wastewater has primary responsibility to enforce pretreatment stan-
dards throughout the entire geographical area served by its conveyance and
treatment system.  A sufficient ordinance/resolution or regulation and
pretreatment program must be in place for each industrial user within the
treatment plant's service area.

     This requirement may or may not present a problem, depending upon how the
POTW is structured.  If a special sewer district encompassing the entire
service area has been created, and the sewer district has rulemaking authority
sufficient to implement a centralized pretreatment program, there is no
problem.  The typical case, however, involves municipal POTWs which service
industries lying beyond the municipal boundaries and thus beyond the reach of
municipal ordinances.  A mechanism to control the discharges of these
industries should be established.  In order to control the discharges of such
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industries, there must be either:  (1) an agreement between the POTW and the
outlying jurisdiction where the industry is located (this agreement should
specify that the outlying jurisdiction will enforce the POTW1s requirements or
else allow the POTW itself to undertake enforcement);  or (2) a contract
between each industry and the POTW which conditions the industry's receipt of
sewer service upon compliance with the POTW's requirements.

     It is recommended that the POTW and each outlying jurisdiction with a
categorical or significant industrial user enter into an interjurisdictional
pretreatment agreement.  This agreement should address the following:

     •  Ordinance or regulation
     •  Local discharge limit mechanism
     •  Pretreatment program administration
     •  Records transference
     •  Inspection and sampling authority
     •  Enforcement.

     In its final pretreatment submission, the POTW should include:

     •  The ordinance/resolution or regulation for each jurisdiction involved
     •  The POTW1s pretreatment agreements with the contributing jurisdic-
        tions.

Each ordinance should be evaluated individually for the required legal author-
ities discussed in Section 2.3.  It will be necessary for the reviewer to
complete a Legal Authority Checklist for each jurisdiction served.

2.5  LEGAL AUTHORITY CHECKLIST
     The Legal Authority Checklist (Worksheet 1) is divided into two parts.
Part I is designed to cover submission completeness, while Part II covers
legal adequacy.  Both parts reference the applicable sections of the Federal
pretreatment regulations.
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Worksheet 1
Legal Authority Checklist
                                                           Name of POTW
                                                                   Date
                                                                Yes    No
                                                                               Section
                                                                              of POTW s
                                                                             Submission
PART I.

     A.
         Submission Completeness Checklist (Legal Aspects)
         40 CFR 403.9(b) requirements for submission:
         (1)  Does the submission contain a statement from
              the city solicitor, POTW attorney, or other
              official?
         (2)  Does the submission contain a copy of every
              legal authority source cited in the attorney's
              statement or necessary for program implemen-
              tation?  (e.g., ordinances, contracts, statutes,
              joint agreements, permits, regulations, etc.)
         (3)  Does the submission contain endorsements from
              all local boards/bodies responsible for super-
              vising/funding the pretreatment program?
        k(4)  If any of the legal authorities cited are vested
              in a particular official's discretion, is there
              a statement of endorsement from such official?
     B.
     C.
         40 CFR 403.9(b)(l) requirements for attorney's
         statement:

         (1)  Does the statement identify the provision of
              legal authority for each requirement under
              403.8(f)(2)?
         (2)  Does the statement identify the manner in which
              403.8 program requirements will be implemented?
         (3)  Does the statement identify how the POTW intends
              to ensure compliance?

         If the POTW service area includes more than one
         agency, jurisdiction, government, or body, does the
         submission include all ordinances, resolutions,
         regulations, service agreements and other legal
         documents relevant to the analysis of multijuris-
         dictional issues?   (Use separate Part II forms
         for each jurisdiction.)
PART II.  Legal Adequacy [403,8(f)(l)]

     Does the POTW have the authority to:

     A.  Deny or condition new or increased contributions of
         pollutants?  [403.8(f)(l)(i)]
     B.  Require compliance with applicable pretreatment
         standards?  [403.8(f)(l)(ii)]
         (1)  General prohibitions:
              ference [403.5(a)]
                                     pass-through, inter-
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Worksheet 1
Legal Authority Checklist (Continued)
                                                      Name of POTW
                                                              Date
         (2)  Specific prohibitions [403. 5(b)]:
              •  Fire/ explosive hazard?
              •  pH/ corrosion?
              •  Solid or viscous - obstruction/ interference?
              •  Flow rate or concentration to cause inter-
                 ference?
              •  Heat - treatment plant influent 40 °C (104°F)?
              Locally developed limits?  [403. 5(c) and (d)]
              National categorical standards?
    (3)
    (4)
Yes
                                                                       No
                                                                          Section
                                                                         of POTW's
                                                                        Submission
C.  Control through permit, contract, etc., to ensure
    compliance?  [403.8(f)(l)(iii>]

D.  Require development of compliance schedules and
    submission of reports?  [403.8(f)(l)(iv)]

    (1)  Development of compliance schedules for
         installation of technology?
    (2)  Submission of notices and self-monitoring
         reports including 403.12 requirements (baseline
         report, compliance schedule progress report,
         report on final compliance with categorical
         pretreatment standards, periodic reports on
         continued compliance, notice of slug loading)?

E.  Carry out inspection, surveillance, and monitoring
    procedures:  [403.8(f)(l)(v)]

    (1)  Right to enter premises at any reasonable time?
    (2)  Right to inspect generally for compliance?
    (3)  Right to sample?
    (4)  Right to require installation of monitoring
         equipment?
    (5)  Right to inspect and copy records [403.12(n)]?

F.  Remedies for non-compliance by industrial users?
    [403.8(f)(l)(vi)J
    (1)  Obtain remedies for noncompliance:
         •  Injunctive relief?
         •  Are the civil or criminal penalties sufficient
            to bring about compliance , or act as a
            deterrent?
    (2)  Halt immediately and effectively any actual or
         threatened discharge?

G.  Comply with confidentiality requirements (protection
    of public access to effluent data)?  [403.8(f)(l)(vii)]
    [403.14]
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Worksheet 1
Legal Authority Checklist (Continued)
                   Name of POTW
                           Date
                                                                Yes
                               No
  Section
 of POTW's
Submission
     H.  Form special agreements (waivers):

         (1)  Does the ordinance contain a special agreement
              clause?                                           	    	   	
         (2)  If yes, does this special agreement clause
              specifically exclude the waiver of Federal
              categorical pretreatment standards?               	    	   	

     I.  Control extra-jurisdictional agencies, and industries
         which contribute industrial wastewaters to the POTW?   	    	   	

*Indicates item is recommended, but not mandatory.

     I have reviewed this submission in detail and have determined the legal authority
to be:
                        )  Adequate
Date:
      (	)  Inadequate

Reviewed by: 	
                                                                    (Name)
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                           3.  TECHNICAL INFORMATION

     Sound technical information is necessary to develop and implement a suc-
cessful pretreatment program.  Although the information available to a POTW
will increase and improve in accuracy once the pretreatment program is under-
way, the submission should contain sufficient, valid technical data to demon-
strate that:
     •  All industries discharging pollutants which may adversely impact the
        collection system or treatment works have been identified
     •  The pretreatment program (particularly procedures) is designed to
        control the number and type of industrial users discharging to the
        system
     •  Local effluent limits are adequate to protect the POTW and enable
        compliance with its NPDES permit.
Without this information, the ability to achieve the objectives of a pretreat-
ment program may be questioned.

     This chapter focuses on evaluating the completeness and adequacy of the
technical information upon which the local program is based.  Two major ele-
ments will be assessed:  (1) the industrial waste survey (IWS), the method by
which a POTW gathers relevant data on its industrial users, and (2) the local
effluent limits developed to prevent industrial discharges that might inter-
fere with POTW operations or cause permit violations.  A checklist is provided
to assist the reviewer in determining the completeness and adequacy of the
documentation provided in the submission.

3.1  INDUSTRIAL WASTE SURVEY
     40 CFR 403.8(f)(2) requires a POTW to identify and locate all possible
industrial users that might be subject to the pretreatment program and to
identify the volume and character of pollutants discharged to the treatment
plant.  The objective of these requirements is to ensure that the pretreatment
program includes those industries which can potentially cause pass-through,
interference, or sludge contamination problems*  The program submission must
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demonstrate that these requirements have been met.  A suggested method to
gather this required information involves the following steps:

     •  Develop a list of potential industrial users
     •  Eliminate industrial users that are not problems
     •  Survey remaining industrial users to gather pertinent data
     •  Follow up as necessary to ensure adequate response
     •  Compile and evaluate information collected.

While variations from this generic approach are acceptable, most approvable
submissions will include these elements.

3.1.1  Adequacy of the Survey Master List
     The pretreatment program submission should include a master list of all
industrial users discharging to the treatment plant.  The sources used to
develop this list should be documented, such as:

     •  Water use and billing records
     •  Sewer connection permits
     •  Business license records
     •  Chamber of Commerce rosters
     •  Local telephone directory
     •  Utility company records
     •  Property tax records
     •  Other standard listings of industrial firms.

     Lists based on current water use, sewer permits, and license records are
usually very complete.  If these are not available, several different sources
may be needed to develop a comprehensive master list.  In determining the
adequacy of the sources, the reviewer should examine critically the type and
number of sources used.  A small POTW with few industrial users will often
know its users well.  In such a case, the sources used to develop the master
list are not critical.  However, for a large POTW, this would not necessarily
be the case, and sources should be carefully reviewed.
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     Since the sources above may include insignificant industries, the POTW
will often establish criteria for eliminating industries from the list.  These
criteria should be valid and should be documented in the pretreatment program
submission.  For example, valid criteria for exclusion could include:

     •  A manufacturing operation which does not generate wastewater (dry
        manufacturing process)
     •  A direct discharger
     •  A discharger of sanitary wastewater only.

In reviewing the exclusion rationale, it is important to determine which
industries were eliminated from the list and why they were eliminated.  The
reviewer should determine (based upon experience with similar operations)
whether any of the eliminated industries might potentially affect the treat-
ment plant.  If this is the case, the POTW should be notified of the concern.

3.1.2  Thoroughness of Survey Questionnaire
     The POTW should gather discharge information from all industries on its
master list.  The submission should identify the procedure used to gather
information.  This procedure might include:

     •  Questionnaires mailed to industries
     •  Telephone calls
     •  Visits to industries
     •  Information already on file at POTW.

The submission should also provide the date of the industrial waste survey.
Survey information should be as current as possible, and preferably no more
than three years old.

     It is satisfactory for a small POTW with few industries to use telephone
calls or site visits to survey its industries.  This is usually not feasible
for a larger system with many industrial users.  Most large POTWs use ques-
tionnaires to collect survey information.  It is helpful for the submission to
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include a copy of the questionnaire, although this is not required.  If in-
cluded, the questionnaire should be reviewed to determine whether it requests
sufficient information to establish a basis for local limits development and
the compliance monitoring program.  The questionnaire should be easy to read
and understand.  It should require the signature of an official authorized to
sign for the company, as well as the name of a company representative who can
be contacted by the POTW to arrange site visits for inspection and monitoring.

     Information requested from industrial users, whether by questionnaire,
phone call, or visit, should be described.  At a minimum, the following infor-
mation must be requested:

     •  Name of industry
     •  Address of facility
     •  SIC code(s) or expected classification
     •  Wastewater flow (or water consumption rate if flow is not known)
     •  Quantities and concentrations of pollutants discharged
     •  Major products manufactured or services supplied
     •  Description of onsite pretreatment facilities and practices.

Although not required, it is recommended that the following information also
be requested:

     •  Locations of discharge points
     •  Raw materials used or stored at the site
     •  Flow diagram or sewer map for the industry
     •  Description of current wastewater treatment practices
     •  Number of employees
     •  Operation and production schedules.

A POTW which already has an existing pretreatment program may possess  files
containing information normally gathered by a survey.  If the information  is
current and includes both industrial classifications and pollutant  concentra-
tion/quantities, an additional survey may not be needed.
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3.1.3  Response to Survey
     The submission should describe the survey1s comprehensiveness by includ-
ing the number and percentage of industrial users responding to the survey.
It should also include a detailed description of follow-up procedures used to
obtain information from industries which either failed to respond or returned
incomplete surveys.  Follow-up measures would most likely include letters of
reminder, telephone calls, and/or site visits.  A response rate of less than
80 percent will most likely hinder the establishment of an effective program.
At lower rates, there would be less confidence in extrapolating survey re-
sults, since major classes of dischargers will probably be omitted or inappro-
priately represented.

3.1.4  Completeness of Summary Information
     Unless the State or EPA specifically requests the inclusion of all
responses to the industrial waste survey, it is not necessary that they be
included in the submittal.  It is usually more valuable to have the results of
the survey summarized.  Results should be tabulated in a format that includes
the number of industries in specific SIC categories and the quantities of
specific pollutants entering the POTW system.  This format will enable the
POTW to more easily identify industries which will be subject to categorical
standards and industries discharging pollutants controlled by local standards.

     Appendix C provides the reviewer with information concerning the 25 cate-
gorical industries.  Table C-l indicates which pollutants are commonly dis-
charged from each category of industries.  Table C-2 lists those categories or
subcategories which have been excluded from regulation and Table C-3 contains
a listing of SIC codes for industries affected by the categorical standards.

     The summary data should be reviewed to determine whether the POTW has
full knowledge of the nature and extent of pollutant discharges affecting the
plant.  This summary should demonstrate that sufficient information is avail-
able to provide a sound foundation for all subsequent program development
activities.
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3.2  LOCAL EFFLUENT LIMITS
     40 CFR 403.5(c) requires the POTW to develop and enforce local effluent
limits to ensure that:
     •  Pollutants discharged by industrial users do not pass through or
        interfere with the operation and performance of the treatment plant
     •  Prohibited discharges (i.e., heat, explosive/fire hazards, corrosive
        agents, etc.) are avoided.
Local effluent limits must not be developed and enforced without providing
individual notice and an opportunity to respond to any affected party request-
ing such notification.

     In order to demonstrate the adequacy of local limits, the program submis-
sion should include the technical information on which these limits are based.
This information includes operation and maintenance data, a description of
current sludge disposal practices, and the nature and extent of sampling
activities.  It is not adequate to adopt, without any rationale, literature
values or values from other POTW ordinances as local limits.  Unique charac-
teristics at each POTW should preclude the uniform application of literature
values.

     Furthermore, it is not acceptable to have a pretreatment submission with-
out any numerical limits.  A pretreatment program is not in force in the
absence of limits, since limits supply the benchmark against which all non-
compliance enforcement activities will be measured.  Without specific limits,
monitoring will have very little meaning since the POTW will have no way of
knowing whether a violation exists.  If a violation does develop, there would
be no basis for enforcement.  As a result, limits on industrial pollutants,
including those limits that can be currently met by industry without any
treatment or in-plant control, are a minimum requirement.

     The major steps toward establishing local effluent limits include:
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     •  Identifying industrial pollutants entering the treatment system
     •  Identifying past POTW operating problems
     •  Sampling and analyzing to determine fate and effect
     •  Developing numerical limits.

The first step was discussed in Section 3.1.  The remaining steps will be
discussed in the following sections.  The intent is to provide the reviewer
with guidelines to ascertain the adequacy of the information presented.

3.2.1  Identification of Past POTW Operating Problems
     It is important for the reviewer to determine whether the POTW has taken
adequate steps to identify operating problems known or suspected to have been
caused by industrial discharges.  At a minimum, these steps would include a
review of operating records to identify the frequency of treatment plant
upsets and NPDES violations.  The submittal should indicate the number and
frequency of upsets, problems, or violations during a recent period (usually
the past 18 months) and the probable cause of such incidents.

     The submission should describe each known or suspected case of operating
problems caused by an industrial discharge, such as:

     •  Reductions in removal efficiency
     •  Degradation of the collection system facilities
     •  Emergencies such as sewer plugging, excessive corrosion, unusual
        odors, explosion hazards, explosions or fires
     •  Violation of NPDES permit conditions
     •  Water quality degradation and fish kills at the POTW1s effluent dis-
        charge point
     •  Sludge contamination.

These descriptions should be sufficiently detailed to determine the cause of
the problem (e.g., industrial discharge, equipment failure, or improper opera-
tion and maintenance), duration of the incident, magnitude of the damage done,
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and corrective actions taken.  In the case of permit violations, the specific
parameter(s) violated should also be identified.

     Although prevention of sludge contamination is a major objective of the
Federal regulations, this issue is often overlooked in preparing a local
pretreatment program.  The submission should include a description of the
volume and characteristics of sludges produced at the treatment facility and
discuss current methods of disposal.  The impact industrial contributors have
on current sludge disposal methods should be discussed, and any future dis-
posal methods should be evaluated.  The most stringent applicable standards,
whether Federal, State, or local sludge pollutant limits (other than for
conventionals), should be provided.

     If the program is for a new treatment plant, information on past perform-
ance will not be available.  In this case, it is important to ensure that the
POTW used the pollutant information obtained from its industrial waste survey
to assess:  (1) the treatment system's tolerance for pollutants; (2) the
effects of pollutants on proposed NPDES permit limits and/or on receiving
water quality; and (3) the effect of these pollutants on the POTWs sludge
disposal options.

3.2.2  Sampling and Analysis to Determine Fate and Effect
     The nature and extent of the POTW sampling program should be documented
in the program submission.  Often, POTWs sample and analyze influent and
effluent quality for parameters such as BOD, TSS, pH, fecal coliform, tempera-
ture, flow, chlorine demand or residual chlorine, and dissolved oxygen.
Sometimes, parameters such as COD, ammonia, total nitrogen, and total phospho-
rus are also measured.  Based on a review of both industries discharging to
the POTW and past operational problems, additional sampling and analysis may
be needed to quantify the extent of pollutant pass-through and sludge contami-
nation, and to provide a basis for establishing local limits.
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     Such a sampling program should be designed to obtain quantitative infor-
mation regarding the concentration, loads, and fluctuations of specific pollu-

tants identified from the industrial waste survey.  The program may include:


     •  Sampling of significant industries to quantify industrial pollutant
        loading

     •  Sampling of nonindustrial interceptors within the collection system to
        determine the background concentration and loading from nonindustrial
        sources

     •  Scan of the POTW influent, effluent, and sludge for the 126 priority
        pollutants

     •  Sampling within the treatment plant itself to determine, via mass
        balance calculation, the fate of the specific pollutants within the
        treatment plant, and to determine the areas within the system which
        are most heavily affected by the pollutants in question

     •  Sampling and analysis of POTW sludge for priority pollutants when the
        POTW uses land spreading or ocean dumping for sludge disposal

     •  Sampling and analysis of POTW sludge leachate when the POTW uses a
        sanitary landfill

     •  Sampling and analysis of ash resulting from incineration of POTW
        sludge.
     In evaluating a pretreatment sampling program, the reviewer needs to
determine if:


     •  The appropriate pollutants were sampled

     •  The appropriate sampling locations were chosen

     •  The appropriate type of sampling was performed (composite or grab)

     •  Sufficient samples were taken to acquire the necessary information to
        establish limits

     •  The data are adequate to support the limit-setting process

     •  The sampling and analysis procedures were adequate.
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3.2.3  Development of Local Effluent Limits
     Local effluent limits must be established in the following cases:

     •  If an industry is discharging pollutants which are harmful to the
        treatment system
     •  If categorical standards have not yet been promulgated for that
        industry
     •  If categorical standards are not sufficient to protect the treatment
        plant
     •  If significant industries are not covered by categorical standards.

The program submission should explain the basis for deciding what local limits
are required.  The reviewer should determine if the need for local limits has
been correctly assessed based upon information in the IWS, past operational
problems, and any sampling results presented.

     The program submission should document the procedures used, or proposed
to be used, to establish specific local limits.  The procedures should have a
strong scientific basis, and all industrial pollutants of concern should be
covered.  The reviewer should evaluate appropriateness, adequacy, and consis-
tency with applicable national and State pretreatment standards.  In no case
can local limits be less stringent than existing national and State pretreat-
ment standards for a given industry.

     The reviewer should also ascertain whether local limits are applied
equitably among the industries discharging the regulated pollutants.  Ideally,
the limits should be technically and economically achievable.  The criteria
for "economic" and "technical" feasibility, if used, must be stated and be
consistent with applicable Federal, State, and local laws.  As a general rule,
limits on specific pollutants should not be lower than the detection limits of
currently available standard laboratory analytical techniques.  Finally, the
reviewer should check to see that the procedures used to develop limits, the
data supporting the limits, and the rationale  for the limits have been made
                                     3-10

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available to industrial users and other interested parties.  These parties
must also have been given the opportunity to review and comment on the limits,

     A general methodology for establishing local limits is presented in
Appendix B.  If the reviewer is unfamiliar with the establishment of such
limitations, this Appendix may be useful in evaluating the methods and limits
contained in the POTW's submission.
                                     3-11

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Worksheet 2                                                Name of POTW
Technical Information Checklist                                    Date
                                                                               Section
                                                                              of POTW's
                                                                Yes    No    Submission
PART I.  Industrial Waste Survey [403.8(f)(2)(i) and (ii)]

     A.  Were the sources used sufficient to assure that all
         major industrial users were identified and located?

     B.  Were the criteria used to eliminate industries
         from the inventory appropriate?

     C.  Survey Questionnaire

         (1)  Did the POTW obtain the following information
              (either through the survey or other means):
              •  Name?
              •  Address?
              •  SIC code(s) or expected classification?
              •  Wastewater flow rate or water consumption
                 rate?
              •  Loads and/or concentrations of pollutants
                 in discharge?
              •  Major products manufactured or services
                 supplied?
             *•  Residuals generated by lU's disposal methods?
             *•  Locations of discharge points?
              •  Description of existing pretreatment
                 facilities and practices?
         (2)  Is the information current within the last
              3 years?
        *(3)  Does the questionnaire require the signature
              of an authorized company representative?

     D.  Follow-Up Procedures
         (1)  Did the POTW follow up the questionnaire (with
              additional written requests, telephone calls
              or site visits) to obtain a complete and
              accurate response?
     E.  Summary Information

         (1)  Were the users classified by industrial category
              and/or SIC code?
         (2)  Has the POTW correctly characterized the waste
              discharged from each industrial user or
              industrial type?
         (3)  Does the information obtained demonstrate
              sufficient characterization of  the lU's waste
              discharges to the POTW?
                                            3-12

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Worksheet 2
Technical Information Checklist (Continued)
Name of POTW
        Date
                                                                Yes    No

PART II.  Methodology for Establishing Discharge Limitations [403.5(c)]

     A.  POTW Operating Problems and Plant History

         (1)  Did the POTW adequately document instances of:
              •  Inhibition/upset?                              	    	
              •  Pass-through?                                  	    	
              •  Sludge contamination?                          	    	

     B.  Developmental Sampling Program

         (1)  Has the POTW recently sampled and analyzed:
                 Treatment plant influent?                      	    	
                 Treatment plant unit operations?               	    	
                 Plant effluent?                                ^^    ~^_
                 Sludge?                                        '  ""
                 Industrial effluents?                          	    	
         (2)  Did this analysis include pollutants of
              concern identified in the survey?                 	    	
         (3)  Were appropriate sampling locations chosen?
              •  In the treatment system?                       	    	
              •  In the collection system?                      	    	
              •  At the industries?                             	    	
         (4)  Was the appropriate type of sampling performed
              for each pollutant type (composite or grab)?      	    	
        *(5)  Was the sampling frequency sufficient to
              give an accurate characterization?
                    Section
                   of POTW's
                  Submission
     C.  Need for Locally Developed Discharge Limitations

         (1)  Did the POTW assess whether or not pollutants are
              present in the influent in amounts that inhibit
              treatment processes used by the POTW?
         (2)  Did the POTW assess whether or not toxic pollu-
              tants are present in the POTW effluent in
              amounts known to exceed water quality criteria?
         (3)  Are sludge disposal methods acceptable in view
              of pollutant load?
     D.  Methodology for Setting Local Discharge Limits
         (refer to Appendix B)

         (1)  Is the methodology appropriate?
         (2)  Were relevant numbers used for:
                 Inhibition/upset concentrations?
                 Background concentrations?
                 Removal efficiencies?
                 Water quality criteria/standards?
                 Land application criteria?
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Worksheet 2                                                Name of POTW
Technical Information Checklist (Continued)                        Date
                                                                               Section
                                                                              of POTW's
                                                                YejB    No    Submission

              •  Non-secured landfill disposal (including ash
                 disposal)?                                     	    	   	

     E.  Appropriateness of Locally Developed
         Discharge Limitations

         (1)  Are local limitations at least as stringent as
              national pretreatment standards for the
              appropriate categories?                           	    	   	
         (2)  Do local limitations enable the POTW to meet
              NPDES permit limits?                              	    	   	
         (3)  Will State water quality standards be met once
              local discharge limits are complied with?         	    	   	
         (4)  Will State sludge disposal guidelines/
              regulations be complied with?                     	    	   	

     F.  Multijurisdictional Submissions

         Were data from lUs and treatment plants in all
         jurisdictions considered in developing this
         technical information?                                 	    	   	

     *Indicates item is recommended, but not mandatory.

     I have reviewed this submission in detail and have determined the technical
information to be:

             (	)  Adequate                (	)  Inadequate

Date:	            Reviewed by:	
                                                                         (Name)
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                     4.  PROGRAM IMPLEMENTATION PROCEDURES

     Thorough and complete program implementation procedures are necessary
components of a pretreatment program.  The minimum procedures which must be
documented in the pretreatment program submission are detailed in 40 CFR
403.8(f)(2).  A POTW must be able to:

     •  Identify and locate all industrial users possibly subject to the pre-
        treatment program
     •  Identify the character and volume of pollutants discharged to the
        treatment works by these users
     •  Notify industrial users of applicable standards and requirements
     •  Receive and analyze self-monitoring reports and other notices from
        industrial users
     •  Randomly sample and analyze industrial effluents
     •  Investigate instances of noncompliance
     •  Comply with public participation requirements.

The procedures adopted by a POTW should be well thought out and easy to under-
stand.  They should be clear enough to be followed by all users, the public,
and POTW staff members.  Finally, the procedures should be flexible enough to
allow reaction to day-to-day operating situations.  In evaluating these proce-
dures, the reviewer needs to determine whether they are complete and respon-
sive to the Federal requirements outlined above, and whether they can be
effectively implemented.

     The first two requirements have already been covered in Section 3.1,
Industrial Waste Survey.  Accordingly, this chapter will focus only on updat-
ing the IWS and on the remaining five procedures.  As in earlier chapters, a
checklist is provided at the chapter's end.

4.1  UPDATE THE INDUSTRIAL WASTE SURVEY
     To adequately implement the pretreatment program, information on indus-
trial users should be updated on a regular basis.  Up-to-date information is
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essential not only for determining the nature and quantity of the waste
entering the system, but also for scheduling pretreatment activities and
allocating resources to meet changing program needs.  The submission should

include procedures for identifying and gathering information on new industries
moving into the POTW service area and for updating its existing user informa-

tion base.  There are various mechanisms through which new industrial users
can be identified, including:


     •  A requirement that new industries fill out applications for sewer use
        when they apply for business licenses

     •  Communication with other city departments (water, utilities, health,
        and building departments) concerning new industries in the POTW ser-
        vice area

     •  Continual review of business license records and/or other standard
        listings of industrial firms, such as Chamber of Commerce rosters or
        the telephone directory.


     In addition, the IWS should be updated on a continual basis.  Several
updating procedures are available, such as:


     •  A permit system which requires notification of changes in industrial
        processes, wastewater discharges, or industry ownership

     •  Ongoing POTW inspection and monitoring activities

     •  Periodic expiration of permits and subsequent reapplication by permit
        holders

     •  Periodic mailing of an IWS questionnaire to the  industry accompanied
        by a request to update the information.


4.2  NOTIFY INDUSTRIAL USERS OF APPLICABLE STANDARDS AND REQUIREMENTS

     The POTW is responsible for being up-to-date on all Federal pretreatment
standards and applicable requirements under the Clean Water Act and Resource

Conservation and Recovery Act.  Such standards and requirements include:


     •  Federal categorical  standards

     •  State standards
                                      4-2

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     •  Local limits
     •  Other pertinent requirements (e.g., user charges).

     A number of techniques are acceptable for obtaining current information
on the status of national categorical standards.  A POTW may assign a staff
member to review the Federal Register or it may rely upon an attorney to per-
form this function.  In some instances, the POTW may obtain the information
from the State pretreatraent coordinator, if the State provides such a service.
Periodic requests or phone calls to State or EPA officials may also be suffi-
cient.

     The POTW is also responsible for notifying any industrial user that may
be affected by existing or newly promulgated standards and requirements.
Ongoing procedures to do this should be identified in the program submission.
Suitable procedures include:

     •  General mailing list
     •  Individual letters to industries
     •  Permit/contract conditions
     •  Permit/contract modifications
     •  Published notices in newspapers, circulars, etc.

If notification by mail is proposed, it is usually a good idea to require a
signed acknowledgement of receipt to ensure that the notice has actually been
received by the industry.  Newspaper notices may be adequate if the notices
appear in the same section of the paper on a fixed schedule (e.g., once a
week), and if industrial users are informed of the location and time of
publication.  Permit and contract amendments are probably the best method of
notification since acknowledgement is ensured when a company official signs
the permit/contract.

4.3  UNDERTAKE COMPLIANCE MONITORING PROCEDURES
     Self-monitoring, compliance sampling, and noncompliance investigations
are closely related.  The first two activities determine an industrial user's
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compliance with pretreatment standards, limits, and other requirements.  The
third activity constitutes the POTW's response to potential instances of
noncompliance.  All three involve sampling and analysis of industrial efflu-
ents and data analyses.  Under self-monitoring, the sampling and analysis are
performed by the industrial user's staff or representative.  Under compliance
sampling and investigations, the work is carried out by the POTW's staff or
authorized representative.  Investigatory sampling and analysis must be per-
formed with sufficient care to produce evidence that is admissible in court,
and thus, it is normally more rigorous than compliance sampling and analysis.

4.3.1  Receive and Analyze Self-Monitoring Reports and Other Notices
     The program submission must describe the POTW's procedures for receiving,
analyzing, and storing self-monitoring reports, compliance schedule reports,
and other reports/notices submitted by industrial users.  A systematic
approach to managing the data collected from these sources should be evident.
The system may be manual or computerized depending upon the POTW's size and
number of industrial users.  The system should ensure that reports are
received on time, reviewed by a technical specialist, and ultimately filed in
a retrievable manner.  The system should facilitate a comparison between
discharge values reported by industrial self-monitoring or POTW compliance
monitoring, and discharge limits specified in the industry's permit or con-
tract or in the municipal ordinance.

     Basic features of a workable system include:

     •  A master list or log of expected reports during a specified time frame
        (monthly is sufficient)
     •  A procedure to enter date of receipt of each report (usually on the
        master list or log)
     •  A procedure to screen and compare reported values and  compliance
        information with discharge standards and compliance schedules
     •  A procedure (if the screening  is done  by a non-technical  person) to
        refer problem  submissions to a technical specialist for more thorough
        evaluation
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     •  A filing system to ensure that the data are retrievable and maintained
        for an appropriate period of time (three years or longer)
     •  The ability to cross reference to permit, contract, and POTW monitor-
        ing files, if applicable.

It is also important to ensure that the expected volume of reports can be
handled by the proposed procedures.  In addition, the submission should iden-
tify by title the individual responsible for evaluating self-monitoring and
compliance schedule reports.

4.3.2  Conduct Compliance Sampling and Analysis
     The submission must document and describe the POTW1s procedures for sam-
pling and analyzing industrial effluents.  Three basic types of compliance
sampling and analysis are commonly used:

     •  Scheduled monitoring (sampling and analysis on a fixed schedule)
     •  Random monitoring (sampling and analysis—scheduled or unscheduled—
        that is unannounced or performed with short notice)
     •  Demand monitoring (sampling and analysis triggered by an event such as
        a public complaint or an observed POTW operating problem).

The reviewer should note that monitoring for billing purposes (e.g., surcharge
for BOD or SS) is not compliance monitoring.  Compliance monitoring involves a
comparison of actual discharge amounts to permitted discharge amounts.
Although sometimes the two types of monitoring may be combined and conducted
at the same time, monitoring for billing purposes alone is not sufficient to
assess compliance.

     The regulations specifically call for program procedures to randomly
sample and analyze industrial discharges to the treatment works.  Random
sampling is intended to ensure that collected samples are representative of
actual operations.  It is particularly useful when industries can easily and
quickly alter their processes or operations to obtain more favorable results.
The requirement for random sampling does not mean that the events cannot be
scheduled.  A POTW may schedule its random monitoring activities on a
                                     4-5

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quarterly, semi-annual, or even annual basis, provided it does not inform the
industrial user of the specific time or day the sampling will take place far
enough in advance to enable the user to alter its discharge.  A limited amount
of advance notice, such as providing indefinite information about the day or
time of arrival, or telephoning the company representative just before arriv-
al, is acceptable, and is often necessary to ensure access to the sampling
point.

     Besides identifying the types of monitoring that the POTW will conduct,
the submission should also include:
        The minimum sampling frequency at each major industrial user (at least
        annually is necessary)
        A list of industries, both categorical and noncategorical, that will
        be included in the random sampling program (major or significant users
        should be noted)
        The activities or events that will trigger the demand sampling program
        (e.g., upsets, inhibitions, public complaints).
The reviewer should determine whether the sampling frequency assures reason-
able coverage each year of all categorical and significant users.

     The frequency and type of sampling (grab, composite, or flow proportion-
al) will vary depending on the type of industry, pollutants of concern, and
resources available (e.g., manpower and equipment).  Each submission should
identify the sampling approach, frequency, and technique as well as the pollu-
tants to be monitored for each group of industrial users.  The program's ade-
quacy can be determined by comparing it with the results of the industrial
waste survey.  The reviewer should check that each industrial user that is or
will be subject to national categorical standards will have its effluent moni-
tored by the POTW at appropriate intervals.  In addition, when an industrial
user is known to discharge a priority pollutant in its wastewater, the POTW
should sample and analyze for that pollutant.  A list of priority pollutants
usually present in the wastewaters of various industrial groups is included in
Appendix C.  POTWs will probably also monitor flow rates and measure
                                     4-6

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conventional pollutant parameters such as BOD, COD, TSS, pH, and others.
Whether the samples obtained are grab samples, a grab sample series, or com-
posite samples should also be identified.

     As part of this section's review, the reviewer should evaluate the appro-
priateness of sampling procedures.  Sampling procedures should conform with
those described in the EPA NPDES Compliance Sampling Inspection Manual.
Chain-of-custody procedures should be identified in the submission.

     The analysis of samples, as well as the sampling itself, may be performed
in-house or under contract by a commercial laboratory.  The submission should
describe the analytical methods to be employed and the quality assurance pro-
gram that will be followed.  When samples from categorical industries are
analyzed, the methods used must conform to those prescribed in the applicable
categorical standard.  Test procedures for other pollutants should conform to
one of the standard analytical methods cited in Table I of 40 CFR 136, "Guide-
lines Establishing Test Procedures for the Analysis of Pollutants."  Other
methods may be used only where they have been approved by the EPA Regional
Administrator.  Laboratory quality assurance procedures should conform to
specifications contained in EPA's Handbook for Analytical Quality Control in
Water and Wastewater.  Table C.4 in Appendix C lists the detection levels and
approved EPA methodologies for analysis of the priority pollutants.  If com-
mercial laboratory services are to be used, the POTW should provide the name
of the laboratory or a description of its criteria for selecting a laboratory.
Official certification of the laboratory is normally a good thing for the POTW
to require because the certification ensures that correct procedures and
equipment are used and that the appropriately trained staff are employed.

4.3.3  Investigate Noncompliance
     The pretreatment program submission must describe how the POTW will
investigate instances of noncompliance.  These methods should be capable of
handling three types of situations:
                                     4-7

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     •  An emergency situation when the POTW must move immediately to halt an
        industrial discharge that "reasonably appears to present imminent
        endangerment to health or welfare of persons."

     •  A nonemergency situation when the POTW desires to halt or prevent a
        discharge which "presents or may present an endangerment to the envi-
        ronment or threatens to interfere with the POTWs operation."

     •  A situation when an industrial user fails to comply with other pre-
        treatment requirements, such as timely submission of reports, achieve-
        ment of compliance schedule milestone(s), maintenance of sampling and
        pretreatment facilities, and maintenance of records.


The information gathered should be admissible as evidence in enforcement pro-
ceedings or judicial actions.  Thus, sampling and analysis, and other data
collection activities should be conducted with a greater degree of care than
would otherwise be required.


     Noncompliance investigation procedures may be detailed in the legal or
procedural section of the program submission.  If these procedures are dis-

cussed in the legal section (e.g., in the sewer use ordinance), the procedural
section of the submission should cite the appropriate legal document.  The

procedures that will be used to investigate instances of noncompliance should
include the following:


     •  Establish criteria for classifying situations as emergencies

     •  Notify industrial users of noncompliance incidents

     •  Provide for industry response to notification

     •  Take actions to correct identified problems

     •  Verify that violation has been corrected

     •  Resort to legal recourse to obtain industrial compliance and/or allow
        industry  to challenge POTW violation determination

     •  Perform quick response sampling, analysis, and  inspection  in  the event
        of emergency conditions such as  fire, explosion, corrosive action,
        acute upset, or imminent danger  to health and safety

     •  Gather data so that  it  is admissible in court proceedings  or  other
        enforcement actions.
                                     4-8

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     Informal notice of industrial user noncompliance usually involves
letters, telegrams, telephone calls, meetings, and visits.  It is always a
good idea for the industrial user to acknowledge receipt of the notice.
Formal notification methods include cease and desist orders, injunctions,
citations, and subpoenas.  Industrial users can respond through letters,
telephone calls, meetings, and show-cause hearings.

     To abate and control the problem discharge, the user may take corrective
procedures, such as process change, installation of new treatment technology,
improved operating practices, repair of faulty equipment, and termination of
discharge.  The time frame for correcting the violation which the POTW estab-
lishes should be flexible enough to cover both emergency and less severe
situations.  Under emergency conditions, the POTW may need to terminate the
discharge until other corrective measures are in place.  The POTW should have
this authority and provisions for using it.  A nonemergency violation may be
handled by modifying the permit, contract, or other provision.  The POTW can
verify corrective actions through certification by the industrial user that
the violations has been corrected, increased self-monitoring requirements, and
follow-up monitoring inspection by the POTW.  While certification is accept-
able for less serious violations, the POTW should verify corrective actions
first-hand in serious cases.

     Because it is impossible to predict which actions will require legal
proceedings, and because the integrity of data must be proved if the case
ultimately goes to trial, it should be assumed that any data collected during
an investigation will end up in court.  Thus, chain-of-custody and quality
assurance provisions become important aspects of a POTW's noncompliance inves-
tigation.  The program submission should indicate that the POTW will follow
proper chain—of-custody procedures.

4.4  PUBLIC PARTICIPATION
     The pretreatment program submission must describe the procedures used by
the POTW to ensure public participation in the program.  Specific requirements
include:
                                     4-9

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     •  Informing the public on the compliance status of industrial users
     •  Individual notice and comment on proposed local effluent limits
     •  Public access to nonconfidential data and records.

     Although usually not required by Federal regulation, it is a good idea
for the POTW to hold public meetings as it develops the local program.  In
situations where grant assistance is being provided, full-scale public partic-
ipation (citizen advisory committees, public meetings, or public hearings) may
be required.  If meetings were held, the results of these meetings and the
resolution of any issues should be documented in the submission in the form of
summaries, verbatim transcripts, or by attaching meeting notes.  A description
of the attendees (i.e., number, groups represented) should be included.

     The POTW must publish, at least annually, a list of significant indus-
trial violations in the largest local daily newspaper.  A significant viola-
tion is one that:

     •  Results in the exercise of emergency authority
     •  Remains uncorrected 45 days after notice of noncompliance is given to
        the industrial user
     •  Involves failure to accurately report.

The name of the newspaper should be specified and the frequency of publication
stated.  Information other than the name of the discharger may be included in
the notice, although this is not required.

     The requirement for individual notice of local limits was mentioned
earlier in  Section 4.2.  Since groups and individuals other than industrial
users may request notice, it is important that the submission described proce-
dures for accomplishing this notice.

     It is  recommended that public access to nonconfidential information
contained in the documents and records developed in the course of the program
be provided.   In this case, the submission should identify the steps  taken by
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the POTW to provide such public access.  The location or office where inter-
ested people can go to read or copy documents, permits (if a permit system is
used), and monitoring records should be specified.  The local library, city/
town hall, public works office, or POTW are acceptable locations.  The hours
of operation should include convenient times for the public at large.  These
provisions should also allow the POTW to restrict access to confidential
information about industrial users.
                                     4-11

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Worksheet 3
Program Implementation Procedures Checklist
Name of POTW
        Date
                                                                Yes

PART I.  Updating the Industrial Waste Survey [403.8(f)(2)(i)
         and (ii)]
     A.  Are procedures identified for updating (periodically)
         the waste survey information for existing users?       	
     B.  Do procedures require new industries to supply
         discharge information or otherwise ensure that it
         will be collected?                                     	
PART II.  Notification of Appropriate Federal, State, and/or Local
          Standards or Limitations [403 .8(f)(2)(iii)]
     A.  Are there procedures for keeping abreast of existing
         and newly promulgated standards and requirements?      	
     B.  Is there a mechanism to identify and notify
         industrial users of standards, limitations, or
         other requirements?                                    	
PART III.  Receipt and Analysis of Self-Monitoring Reports and
           Other Notices [403.8(f)(2)(iv)]
     A.  Are there procedures for determining what self-
         monitoring and other reports are due?                  	
     B.  Are values reported by industries compared  to
         discharge standards or compliance schedules?           	
     C.  Are problems referred to appropriate authorities
         for technical evaluation and follow-up?                	
PART IV.  POTW Compliance Sampling and Analysis [403.8(f)(2)(v)]

     A.  Does the description of the monitoring program
         include procedures for periodic random sampling
         of significant industrial dischargers?                 	
     B.  Are sampling and monitoring parameters identified
         for each firm or group of industries?                  	
     C.  Is the POTW sampling for the significant pollutants
         identified by the  Industrial Waste Survey or by  the
         priority pollutant/industry matrix?  (Appendix C)      	

     D.  Do the sampling and monitoring procedures conform to
         EPA requirements?  (40 CFR 136."Standard Methods")     	
     E.  Is the frequency adequate to determine compliance
         independent of information supplied by lUs
         (at least annually)?                                   	
            No
  Section
 of POTW1s
Submission
                                           4-12

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Worksheet 3
Program Implementation Procedures Checklist (Continued)
                       Name of POTW
                               Date
                                                                Yes
                                   No
  Section
 of POTW's
Submission
PART V.  Noncompliance Investigations and Enforcement
         [403.8(f)(2)(vl)l
     A.  Are follow-up activities described that include
         provisions to:
         (1)  Cover emergency situations?
         (2)  Notify industrial users of violations?
         (3)  Allow for response by industrial users?
         (4)  Abate and control problem discharges?
         (5)  Verify that corrective actions have worked?
         (6)  Obtain compliance through legal means if
              necessary?
         (7)  Assess penalties for noncompliance?

     B.  Are procedures for quick response sampling and
         analysis included (demand sampling)?
     C.  Are chain-of-custody and quality control provisions
         specified?
PART VI.  Public Participation

     A.  Do procedures include at least annual notice of
         violations published in local newspapers?
         [403.8(f)(2)(vii)]
     B.  Is notice and opportunity to respond provided, both
         to the industrial users and the general public, on
         the process of developing local industrial
         effluent limitations?  [403.5(c)(3))
    *C.  Are program records available to the public?

PART VII.  Multijurisdictional Submissions
     A.  Are there procedures to coordinate monitoring,
         enforcement, and implementation activities
         between the jurisdictions involved?
     B.  Has the NPDES permit holder assumed lead
         responsibility in program implementation?
*Indicates item is recommended, but not mandatory.

     I have reviewed this submission in detail and have determined the implementation
procedures to be:
          (	)  Adequate
Date:
(	)  Inadequate

    Reviewed by:
                                                                     (Name)
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              5.  ORGANIZATION, STAFFING, EQUIPMENT, AND FUNDING

     The ability to develop and implement a successful pretreatment program
depends upon a number of factors.  The importance of legal authority, sound
technical information, and proper procedures has already been discussed.  This
chapter focuses on needed resources and an organization to apply them effi-
ciently and effectively.  An acceptable submission will demonstrate that the
POTW has:

     •  A workable organization to integrate elements of the program
     •  A staff of appropriate size and training to carry out program
        requirements
     •  The necessary equipment to fulfill monitoring and other program needs
     •  Adequate funds to support the proposed program.

The above elements are closely interrelated, and all should be present in a
successful program.

     While the level, type, and kind of resources will vary from program to
program, it is possible to establish guidelines for use in evaluating the sub-
mission's adequacy.  This is the approach taken in this chapter.  Rather than
attempting to cover all possible solutions to the resources problem, each ele-
ment is discussed generically.  Key factors are identified, "rules of thumb"
are provided for evaluating staffing and funding levels, and a framework for
review is established.  A checklist is provided to assist the reviewer.

5.1  RELEVANT REGULATIONS
     40 CFR 403.8(f)(3) requires that the POTW have "sufficient" resources and
qualified personnel to implement the authorities and procedures called for in
the program.  Although the regulations do not specify what is "sufficient,"
they do require that the POTW submit certain items:

     •  A brief description (including organization charts) of the POTW orga-
        nization which will administer the program
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     •  A description of funding levels and full- and part-time manpower
        available to implement the program.

If more than one agency is responsible for administering the program, each
agency must be identified.  The responsibilities of each participating agency
must also be delineated and procedures for coordination described in the sub-
mission.

     In some instances, a submission may indicate that certain equipment,
staff, and/or funds are not yet available to carry out the program.  Such a
program can be approved conditionally pending the acquisition of complete
funding, manpower, and/or equipment, provided that:

     •  The inadequately supported aspect(s) of the program does not need to
        be implemented immediately
     •  Adequate legal authority and procedures exist for the complete pro-
        gram, including the aspect(s) not being implemented immediately
     •  The necessary resources will be available when such aspect(s) is
        implemented.

This provision for conditional approval [40 CFR 403.9(c)] is designed to avoid
the unnecessary costs that can result from acquiring and maintaining resources
(particularly staff and equipment) before they are  needed.

5.2  EVALUATION OF ORGANIZATION AND STAFFING
     Organization and staffing requirements will vary according to  the com-
plexity and comprehensiveness of the local program.  Whether the staff is
large or small, it must be organized in a way that  facilitates the  successful
completion of program responsibilities.  The adequacy of the program's organi-
zation and staffing is based not only on whether essential functions are
covered, but also on whether the number and type of staff are appropriate to
implement program requirements.  The following elements should be evident in
the submission:

     •  Clear and appropriate lines of authority
     •  Identification of  staff responsibilities
                                      5-2

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     •  Qualifications of staff
     •  Staffing levels related to required work effort
     •  Coordination with other departments
     •  Contract management (if required).

5.2.1  Clear and Appropriate Lines of Authority
     A description of the POTW organization is needed, including the func-
tional departments which will carry out the program.  This description may
include the titles and numbers of employees within each functional department,
and the employees (or department) within the POTW that will coordinate with
each service district in interjurisdictional programs.  It is recommended that
the functional departments identify services such as administration, engineer-
ing, sampling/inspection, laboratory analysis, legal work, accounting, and
billing.

     A POTW must submit either an organization chart for the entire wastewater
treatment program or a chart specifically structured for the pretreatment
program.  If the entire POTW organization is shown, notations on the chart or
an accompanying text should indicate where pretreatment responsibility rests.
In particular, responsibility for procedural functions such as notifying
industrial users of applicable standards, receiving and reviewing self-
monitoring reports, conducting sampling and analysis of industrial effluents,
and initiating enforcement actions should be clearly identified.  If the
pretreatment organization is provided, its relationship to the overall POTW
organization is provided, its relationship to the overall POTW organization
should be described.

     A variety of different organizational systems and structures are approv-
able.  The key is to determine whether the proposed structure is workable.
In evaluating the program's organization, the reviewer may ask the following
questions:

     •  Are authorities and responsibilities clearly designated?
     •  Do supervisors have direct responsibility for the appropriate number
        of employees (usually no more than six or eight staff members)?
                                     5-3

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        Is the program effectively integrated with the rest of the POTW's
        activities?
5.2.2  Identification of Staff Responsibilities

     Text accompanying the organization chart should identify the responsi-

bilities and duties of each staff member or department involved in the pro-

gram , including:


     •  Technical assistance.  A staff member or department should have the
        responsibility of evaluating data that industrial users supply on
        their IWS forms, self-monitoring reports, and compliance schedule
        reports.  This person or department also should have responsibility
        for reviewing results of POTW monitoring and sample analyses and for
        industrial inspections.

     •  Industrial monitoring.  The submission should designate a staff member
        or department with responsibility for staffing and supervising field
        monitoring personnel.  It should also specify the number and qualifi-
        cations of personnel who will be assigned to the field monitoring
        crew(s) .

     •  Laboratory analysis.  As indicated earlier, a POTW may either perform
        its own sample analyses or contract with a commercial laboratory for
        analytical services.  If the work is done in-house, laboratory support
        staff must be identified.

     •  Legal assistance.  The person(s) providing legal assistance to the
        municipality will interpret regulations and other legal documents that
        affect pretreatment program operations and prepare contracts or other
        agreements.  This person also will initiate formal legal actions
        against violators, including injunctive relief when necessary.

     •  Administration.  The program administrator and administrative staff
        should have responsibility for data management, communication with
        lUs, program finances and accounting, personnel, and the public
        participation program.


     A  small POTW may have the same person performing the duties associated
with one or more of these five general work areas, while a large POTW may have

several people assigned  to each  functional group.  In addition, a large POTW

may wish to separate functions that are grouped together under administration.

Responsibility for some  of the work areas may be assigned to contractors or

other local agencies, but all areas of work and corresponding staff should be

identified  in the  submission.
                                      5-4

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5.2.3  Staff Qualifications
     The submission should include the qualifications for all key staff posi-
tions.  The qualifications of existing and proposed staff should be reviewed
to ensure that they are appropriate for the position.  While there are no
rigid guidelines that apply, there are several factors that can be used to
evaluate the adequacy of staff qualifications.  The education and experience
should match the functions to be performed.  Sampling and analysis functions,
for example, would normally be performed by a chemist experienced in effluent
monitoring (preferably industrial).  Tradeoffs between education and experi-
ence are acceptable, and certification in an appropriate discipline (e.g.,
professional engineer) is desirable, but not required.  Key disciplines that
one would expect to see are engineering (environmental, civil, sanitary,
chemical), chemistry (organic, inorganic, physical, analytical), public
administration, business administration, and law.

5.2.4  Staffing Levels
     The level of staff needed to implement a program depends on the size of
the treatment plant and the number of industrial users regulated under the
pretreatment program.  Small POTWs with few industrial users may be able to
implement a pretreatment program satisfactorily using only one or two person-
years of effort.  Large POTWs with many industrial users may need a pretreat-
ment program staff with as many as 30 to 50 people, depending on the number of
samples and measurements to be obtained, the frequency of monitoring, and the
number and complexity of analyses to be performed.  POTW staff requirements
will also vary significantly if work is performed by outside personnel (e.g.,
contract support).  These outside resources should be included when assessing
the adequacy of staffing levels.

     A quantitative estimate of the level-of-effort, including outside
support, should be provided in the submission for each staff position or
function.  Such estimates may be in the form of labor hours per year, person-
years, or percent involvement of a person in pretreatment program activities.
The amount of work required to perform necessary sampling and analysis,
technical reviews, and administrative tasks should be compared to the proposed
                                     5-5

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staffing levels.  Generalized estimates of personnel requirements as a func-
tion of POTW size and number of industrial users are shown in Table 5-1.  More
refined and detailed personnel estimates for a POTW having a flow of 5 mgd and
10 industrial users are shown in Tables 5-2 and 5-3.  These figures can be
used to gauge the adequacy of staffing levels for individual functions,
although they should not be treated as rigid requirements.

5.2.5  Coordination with Other Departments
     Interaction between groups within the pretreatment program and other POTW
departments in order to facilitate the program's smooth operation should be
clear in the submission.  A flow chart for routine program operations may be
included.  For example, the chart would show who receives and reviews self-
monitoring reports, what happens when the reports are acceptable, and what
happens when they indicate violations.

5.3  EVALUATION OF EQUIPMENT
     The major items of equipment necessary to implement a successful pre-
treatment program may include sampling gear, analytical instruments, vehicles,
office furniture and accessories, and data processing devices.  The type and
amount of equipment needed will vary as a function of program size, complex-
ity, and structure (i.e., contract or other outside services).  The pretreat-
ment program submission should list the major equipment to be used in the
program, including any commercial services or outside capabilities.  This list
should be reviewed for completeness and adequacy.  At a minimum, the POTW
should show that it has the capability to sample and analyze industrial waste-
waters for all pollutants of concern identified in the technical information
section of the submission (e.g., metals, priority pollutants, or special
pesticides).

     Some of the specific capabilities that the program submission should
demonstrate include grab and flow composite sampling, gas and liquid chroma-
tography, atomic absorption, and mass spectroscopy.  The equipment needed may
be available in-house or from external sources.  It is a good idea for all
analytical work to be performed by a certified laboratory to ensure the
                                     5-6

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                                   TABLE 5-1

                          POTW PRETREATMENT PROGRAM
                         PERSONNEL REQUIREMENT RANGES
     Ranges presented in this table are estimates based on anticipated
averages for typical programs.  Individual program personnel requirements may
vary significantly from the ranges shown here.
POTW
Flow Range
(MGD)
5
5-25
25-50
50
100
Relative Number of
Indirect Dischargers
small
large
small
large
small
large
small
large
large
Range of Personnel
Requirements for
Pretreatment Program
1-3
2-5
2-4
4-8
4-6
8-10
6-8
10-15
15-50*





*Special cases, such as large metropolitan systems, require more in-depth
 review.

Source:  Local Pretreatment Program Requirements and Guidance.
         Environmental Technology Consultants, Inc.:  September 1979.
                                     5-7

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                                   TABLE 5-2

               ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
                 PRETREATMENT PROGRAM BY PERSONNEL CATEGORIES
POTW AVERAGE DESIGN FLOW:  5 MGD

NUMBER OF INDUSTRIAL USERS IN PROGRAM:  10
PERSONNEL

1.  Supervisor - For delegating the responsibilities
                 and running the program

2.  Engineer   - To review reports and assist the
                 Supervisor

3.  Field Crew - To take samples and do all field
                 investigations

4.  Laboratory - For analyzing samples
    Technician

5.  Lawyer     - For all legal action and proceedings
 NUMBER
REQUIRED

   1
part-time


part-time
                 TOTAL FULL-TIME PERSONNEL REQUIRED
   5.0
                                      5-8

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                                  TABLE 5-3

               ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
                   PRETREATMENT PROGRAM BY PROGRAM ACTIVITY
Estimates presented in this table are based on anticipated averages for typi-
cal programs.  Individual program personnel requirements may vary significant-
ly from the estimates shown here.

POTW AVERAGE DESIGN FLOW:  5 MGD
NUMBER OF INDUSTRIAL USERS IN PROGRAM:  10
                            Frequency of                 Workdays
                            Activity per    Number of      per       Total
Program Activity            POTW or IU      Activities   Activity   Workdays
     Program Development

1.   Develop Pretreatment     once              1          15-25       25
     Program

2.   Conduct Industrial       once              1          15-25       25
     Waste Survey

3.   Determine POTW           once2             1          10-20       20
     Removal Allowance

4.   Review IU Pretreatment   once             10         0.5-2        20
     Facility Proposal
                              TOTAL WORKDAYS = 90
                              90 4 220 WORKDAYS/PERSON/YEAR = .41 Person-years
     Program Operation
1.   Review IU Compliance     3/year           30         0.5-1        30
     Schedule Reports

2.   Review IU Final Compli-  once             10         0.5-2        20
     ance Schedule Report

3.   Review IU Self-          2/year           20         0.1-0.5      10
     Monitoring Report

4.   Sample IU                I/year           10           2-4        40
     (spot-check)

5.   Investigate IU           	              5           1-5        25
     Non-compliance
                                     5-9

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                             TABLE 5-3 (Continued)

               ESTIMATED POTW PERSONNEL REQUIREMENTS FOR A POTW
                   PRETREATMENT PROGRAM BY PROGRAM ACTIVITY
Frequency of
Activity per
Program Activity POTW or IU
6.

7.
8.
9.
10.
11.
Administrative 	
Enforcement Action
Legal Enforcement 	
Actions
Comply with Public 1 /year
Notice Requirements
Sample POTW Influent, I/year
Effluent, and Sludge
Prepare Self-Monitoring 2/year
Report for Approval
Authority
Laboratory Analysis I/year
of Required Sampling
Workdays
Number of per Total
Activities Activity Workdays
3 3-10 30

1 15-20 20
1 1-3 3
1 5-10 10
2 5-10 20
13 1-2 26
                            TOTAL WORKDAYS =234
                            234 4 220 WORKDAYS/PERSON/YEAR = 1.06 Person-years

 IWS is periodically updated during program implementation procedures.
2
 Annual monitoring and reporting by the POTW is required during program
 implementation to maintain any removal credit allowance.

Source:  Local pretreatment Program Requirements and Guidance.  Environmental
         Technology Consultants, Inc.:  September 1979.
                                     5-10

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quality of results.  Other equipment that may or may not be necessary depend-
ing upon the size and complexity of the program includes vehicles for sampling
and inspection, computer terminals, software and hardware for data reduction
and analysis as well as for program administration, and office accessories,
such as word processing, duplication, and production devices.

5.4  EVALUATION OF FUNDING
     An itemized estimate of pretreatment program costs must be included.  The
submission must contain either projected costs for the first year of program
operation or the actual costs for the most recent operating year if the pre-
treatment program was fully implemented in that year.  These costs should be
itemized in the following areas:

     •  Labor (salaries, benefits)
     •  Annualized capital costs
     •  Operation and maintenance costs (travel, supplies, etc.)
     •  Overhead (rent, phones, etc.)
     •  Debt service
     •  Other applicable costs.

     The submission should also provide an account of the revenue sources to
be used to cover the annual costs of the pretreatment program.  This account
may be descriptive, or may be an itemization of each revenue source and
amount.  In addition, a system for continuous revenue generation (e.g., user
charges) should be discussed.  It is helpful if the POTW submits its most
recent annual financial statement showing actual expenditures and revenues so
that the reviewer can assess the POTW's financial base.  However, submitting
the financial statement is not a Federal requirement.

     In reviewing the funding section of the submittal, it will be necessary
to evaluate whether cost estimates are appropriate, and to determine whether
costs will be adequately met by the proposed sources of revenue.  Where short-
falls exist, the program may still be approvable if the inadequately funded
                                     5-11

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program element need not be implemented immediately and future funding will be
available when needed.

5.4.1  Implementation Costs
     A POTW program submission should provide an estimate of the annual cost
of implementing its pretreatment program.  The two types of costs involved are
capital costs and operating costs.  The capital cost of purchasing equipment
represents a single cash outlay, while labor, O&M, and the other items repre-
sent operating expenses that must be recovered yearly.  Equipment may be
purchased directly out of the POTWs budget if sufficient reserve cash is
available; its may also be financed or leased and then repaid annually as an
ongoing cost in the operating budget.

Capital Costs
     A major financial decision for a POTW implementing a program involves the
procurement of sampling and analysis equipment.  A POTW has the choice of
purchasing equipment, leasing equipment, contracting services, or any combina-
tion of these.  Depending on the level of monitoring required for the program,
a POTW should determine which of these options is the most cost-effective.  It
may be most feasible for small or medium-sized plants to buy equipment for
sampling and conventional pollutant analyses, while using a commercial
laboratory for metals and organics analyses.  Larger POTWs, conducting more
toxics analyses, may choose to buy equipment for full in-house capability.
Since sampling/analysis equipment can be expensive to purchase and maintain,
the POTW should determine what the impact of these costs would be on sewer and
monitoring charges to industries and whether purchase is warranted.  Typical
costs for sampling and analysis equipment for nonconventional pollutants are
shown in Table 5-4.  Typical analytical costs of a commercial laboratory are
shown in Table 5-5.

Operating Costs
     Annual operating costs will generally be based on the level of effort
estimated to conduct various tasks within the program.  While the majority of
operating costs may be attributed to labor, other significant costs may result
                                     5-12

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                                  TABLE 5-4
              TYPICAL EQUIPMENT FOR A TWO-MAN FIELD SAMPLING CREW
     EQUIPMENT                                             PURCHASE PRICE

   Van with two-way radio                                       $12,000
   Gas Detector                                                     450
   2 self-contained breathing units                               1,500
   4 portable samplers with bottles                               8,200
   1 portable pH meter                                              800
   2 flow meters                                                  3,000
   Flumes and weirs                                               1,600
   Velocity meter                                                   600
   Safety equipment                                                 400
   Miscellaneous tools and equipment                            	200

                                            TOTAL               $28,750
              ADDITIONAL LABORATORY EQUIPMENT FOR SAMPLE ANALYSIS
                                                   ESTIMATED
              EQUIPMENT                          PURCHASE PRICE
         -  Atomic absorption                        $ 25,000
            spectrometer (basic)

         -  Supplies for AA                             3,000

         -  Gas chromatograph                         120,000
            mass spectrometer (GC/MS)

         -  Accessories and glassware                  15,000
            for GC/MS (including  a yearly
            service contract)

         -  Reagents and other chemicals               15,000

                                         TOTAL       $178,000


Source:   Odeal, Erwin J.  "Economics of Local Pretreatment  Program Adminis-
         tration."  Proceedings;   National Pretreatment Symposium.  Duluth,
         Minnesota:  August 22-24, 1979.  Cost information  updated, 1983.
                                     5-13

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                              TABLE 5-5

                TYPICAL COMMERCIAL LABORATORY COSTS1
     Parameter                                   Price per Analysis

Conventional Analysis

Acidity/alkalinity                                     $ 9
BODS                                                    20
COD                                                     20
Chloride                                                15
Nitrogen (total)                                        20
Oil & grease                                            20
Suspended solids                                         8
Toxics Analysis

Metals (typical)                                     $10 - 18/metal
Organics by GC                                          60/compound
NPDES Analysis (scans)^

Base neutrals                                         $350
Acid extracts                                          200
Pesticide/PCBs                                         225
13 metals                                              300
Total 126 Compounds                                  800-1200
 Based on 1983 estimated costs from commercial laboratories
2
 Includes $300 for asbestos
                                 5-14

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from equipment O&M, overhead, and debt repayment.  For simplicity, some POTWs
estimate labor hours for each program task and then convert these to total
cost by multiplying by a gross factor that represents overhead and other
costs.  Table 5-6 lists program tasks and various factors affecting the level
of effort for each.  By combining labor costs with other direct and indirect
costs, the total annual budget for the program can be calculated.  See Table
5-7 for estimated operational costs of a POTW pretreatment program.

5.4.2  Financing Sources and Cost Recovery Systems
     The means for recovering program costs should be presented in the
submission.  Major capital expenditures, such as equipment purchase, may be
financed by municipal bonds or with surplus capital improvement revenues, if
available.  As mentioned earlier, leasing and contract services are viable
options that avoid large cash outlays.

     Continuous revenue sources from fees, charges, or interest are necessary
to recover annual operating costs, which include debt service payments if
loans are outstanding.  Ideally, revenues should be generated from the indus-
tries serviced by the program in proportion to their relative use.  However,
any means of generating continuous revenues adequate to recover costs is
acceptable.

     A cost allocation scheme should be used to recover pretreatment costs
from various groups or classes of users according to some basis, such as moni-
toring.  There are many types of charges or fees that may be used to generate
revenues from users.  The most appropriate types for a pretreatment program
include a service or monitoring charge, an industry surcharge, and a pollutant
strength surcharge.  The POTW should choose a justifiable and equitable
allocation basis when applying pretreatment charges to industrial users.
                                     5-15

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                                   TABLE 5-6

                  FACTORS AFFECTING POTW LEVELS OF EFFORT FOR
                     PRETREATMENT PROGRAM OPERATING TASKS
     Activities
        Factors
Sampling and Inspection
-Total number of lUs
-Frequency of sampling
Laboratory Analysis
-Number of samples
-Type of analysis
-Pollutants analyzed (i.e.,  toxics,
  conventionals,  metals,  etc.)
Technical Assistance
(including permitting
process and report
review)
-Treatment plant capabilities
-POTW influent and effluent characteristics
-Total number of lUs
-Number of lUs with pretreatment
Legal Assistance
-Number and seriousness of violations
-Availability of in-house counsel
-Burden of proof created by ordinance
Financial/
Administrative
-Total number of IDs
-Frequency of monitoring
-Size of service area
                                     5-16

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                                   TABLE 5-7

           HYPOTHETICAL POTW PRETREATMENT PROGRAM OPERATIONAL COSTS1

                                                     Size of POTW
     Cost Component                       Small         Medium       Large

(1)  Sampling & Industrial Review       $13,500       $ 26,000    $ 47,000
                Labor                    11,000          	         	
                Non-Labor                 2,500          	         	

(2)  Laboratory Analysis                $28,000       $ 51,000    $105,000
                Labor                     	           20,000      84,000
                Non-Labor                28,000         31,000      21,000

(3)  Technical Assistance                 	         $ 27,000    $ 54,000
                Labor                     	            	         	
                Non-Labor                 	            	         	

(4)  Legal Assistance                   $ 7,320       $ 13,300    $ 36.000
                Labor                     	            	         	
                Non-Labor                 	            	         	
(5) Program Administration
TOTAL

$25,000
$76,820

$ 28,000
$142,300

$ 31,000
$273,000

 Assumptions

(1)  Size is defined in terms of "significant" industrial users.  Small is
     assumed to include 40, medium 130, and large 300 industrial users.

(2)  Major metropolitan areas are excluded from this analysis.  They are
     considered special cases and should be evaluated on an individual basis.

(3)  A 33% overhead rate is assumed for municipal employees.

(4)  Sampling & Industrial Review.  Small POTW:  1 person half-time, medium
     POTW:  2 persons half-time, large POTW:  2 persons full-time.

(5)  Laboratory Analysis.   Small POTWs contract out all lab analysis.  Medium
     size POTWs possess AA capabilities.  Large POTWs possess both AA and
     GC-MS capabilities.

(6)  Technical Assistance.  For small POTWs, this service is performed by the
     program manager who is accounted for in program administration.  Assume
     senior and junior engineers part-time for medium-sized POTWs and full-
     time for large POTWs.

(7)  Legal Assistance.  Small POTWs obtain part-time assistance from municipal
     lawyer.  Medium-sized POTWs use one-third time of in-house legal counsel.
     Large POTWs have one person full-time.

(8)  Program Administration.  Includes program management and coordination as
     well as clerical support.

Source:  Odeal, Erwin J.  "Assessing Administrative and Financial Needs of a
         Local POTW Pretreatment Program."  Proceedings;  National Pre-
         treatment Symposium.  Duluth, Minnesota:  August 22-24, 1979.
                                     5-17

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Worksheet 4
Resources Checklist
Name of POTW
        Date
                                                                Yes
            No
  Section
 of POTW s
Submission
PART I.  Organization and Staffing [403.8(f)(3) and 403.9(b)(3)]
     A.  Is the description of the POTW organization clear
         and appropriate?

     B.  Are mechanisms identified for delegating pretreatment
         tasks to other local government agencies?

     C.  Are personnel or positions identified that are
         responsible for:
         (1)  Technical review?
         (2)  Monitoring?                                       "
         (3)  Laboratory analysis?
         (4)  Legal assistance and enforcement?
         (5)  Administration?                                   "

     D.  Have appropriate staffing levels been determined
         based on the program description?

PART II.  Equipment
     A.  Does the POTW have adequate sampling equipment or
         other provisions to conduct necessary sampling?

     B.  Does the POTW have adequate analytical capabilities
         to perform analyses for:
         (1)  Nutrients and other nonconventionals?
         (2)  Metals?                                           '
         (3)  Toxic organics?
     C.  If not, are other arrangements made to do so
         (e.g., contract with private laboratory,
         other agency)?
PART III.  Funding Estimates and Sources
     A.  Does the POTW present an itemized estimate of pre-
         treatment implementation costs?

     B.  Is there an account of revenue sources that will
         cover the annual costs of the pretreatment program?
                                            5-18

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Worksheet 4                                                Name of POTW
Resources Checklist (Continued)                                    Date
                                                                               Section
                                                                              of POTW's
                                                                Yes    No    Submission
PART IV.  Multijurisdictional Submissions

     A.  Does each jurisdiction participate in funding the
         pretreatment program?                                  	

     B.  Are the relationships between the staff (personnel)
         of the participating jurisdictions adequately
         described and documented?                              	

     I have reviewed this submission in detail and have determined the
resources to be:

          (	)  Adequate          (	)  Inadequate

Date: 	      Reviewed by: 	
                                           5-19

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APPENDICES

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              APPENDIX A
BIBLIOGRAPHY OF PRETREATMENT REFERENCES

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                                  APPENDIX A

                    BIBLIOGRAPHY OF PRETREATMENT REFERENCES
Association of Metropolitan Sewerage Agencies, Pretreatment Resource Reader.
  Washington, DC:  Association of Metropolitan Sewerage Agencies, 1982.  (NTIS
  Order No. PB82-181629) .

Dyer, J.,  Feiler, H.,  and Bernick, A., Handbook of Industrial Waste
  Pretreatment (Water Management Series).  New York:  Garland Publishing,
  Inc., 1981.

U.S. Environmental Protection Agency, Fate of Priority Pollutants in Publicly
  Owned Treatment Works, Volumes I and II (EPA Publication No. 440/1-82-303).
  Washington, DC:  U.S. Environmental Protection Agency, September 1982.
  (NTIS Order No. PB83-122788).

U.S. Environmental Protection Agency, Guidance Manual for POTW Pretreatment
  Program Development.  Washington, DC:  U.S. Environmental Protection Agency,
  October 1983.

U.S. Environmental Protection Agency, Handbook For Sampling and Sample
  Preservation of Water and Wastewater.  (EPA Publication No. 600/4-82-029).
  Washington, DC:  U.S. Environmental Protection Agency, September 1982.
  (NTIS Order No. PB83-124503).

U.S. Environmental Protection Agency, Industrial Residuals Manual, Volumes I,
  II, and III.  Washington, DC:  U.S. Environmental Protection Agency,
  November 1981.  (Available from EPA Office of Water Enforcement and
  Permits).

U.S. Environmental Protection Agency, Methods for Chemical Analysis of Water
  and Wastes.  (EPA Publication No. 600/4-79-020).Washington, DC:U.S.
  Environmental Protection Agency, March 1979.  (NTIS Order No. PB-297686).

U.S. Environmental Protection Agency, Treatability Manual, Volumes I, II, III,
  IV, and V.  (EPA Publication No. 600/8-80-042c).  Washington, DC:  U.S.
  Environmental Protection Agency, July 1980.  (NTIS Order Nos. PB80-223050,
  PB80-223068, PB80-223076, PB80-223084, and PB80-223092).

Water Pollution Control Federation, Industrial Wastewater Control Program for
  Municipal Agencies.   Washington, DC:  WPCF, 1982.  (WPCF Order No. MOP
  OM-4).

Water Pollution Control Federation, Joint Treatment of Industrial and
  Municipal Wastewaters.  Washington, DC:WPCF, 1976.(WPCF Order No.
  M0021).

Water Pollution Control Federation, Pretreatment of Industrial Wastes.
  Washington, DC:  WPCF, 1981.  (WPCF Order No. 'MOP FD-3).
                                       A-l

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Sources listed with an NTIS Order Number are available from:

                   National Technical Information Service
                   U.S. Department of Commerce
                   5285 Port Royal Road
                   Springfield, VA  22161

Sources listed with a WPCF Order Number are available from:

                   Water Pollution Control Federation
                   2626 Pennsylvania Avenue, N.W.
                   Washington, DC  20037
                                       A-2

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             APPENDIX B

DEVELOPMENT OF DISCHARGE LIMITATIONS
 TO CONTROL INCOMPATIBLE POLLUTANTS

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                                  APPENDIX B
                     DEVELOPMENT OF DISCHARGE LIMITATIONS
                      TO CONTROL INCOMPATIBLE POLLUTANTS
1.0  INTRODUCTION
     A critical part of a municipality's task in developing a local pretreat-
raent program is the development of defensible numerical effluent limitations
for the discharge of incompatible pollutants.  These limitations are often
incorporated directly into a municipal ordinance or are applied through indi-
vidual permits issued to nondomestic users of the sewerage system.  Such lim-
its are needed to enforce the prohibited discharge standards of the General
Pretreatment Regulations and to implement the three fundamental objectives of
the National Pretreatment Program:

     •  To prevent the introduction of pollutants into the POTW which could
        interfere with its operation
     •  To prevent the pass-through of untreated pollutants which could vio-
        late a POTW's NPDES permit limitations and applicable water quality
        standards
     •  To prevent the contamination of a POTW s sludge which would limit
        selected sludge uses or disposal practices.

Locally developed limits are also necessary in cases where categorical stan-
dards have not yet been promulgated for an industry, the industry is not
covered by categorical standards, or categorical standards are not adequate to
protect the municipal treatment plant, receiving stream, or sludge.

     This Appendix is intended to assist POTWs in calculating limits to imple-
ment these three objectives.  The first section of the Appendix outlines the
general methodology for determining allowable pollutant loadings, choosing the
appropriate level of protection, and allocating these loadings to dischargers.
Sections 2, 3, and 4 present equations and guideline data that can be used to
calculate the limiting pollutant concentrations at the influent of the munici-
pal treatment plant which will protect the wastewater treatment processes, the
receiving water, and sludge disposal options.  Section 5 discusses
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considerations for allocation of pollutant loadings to individual industrial
users.  Section 6 demonstrates the calculation of a discharge limit for one
pollutant, copper, using a hypothetical example.

     The methodology described here for determining allowable influent concen-
trations and setting industrial effluent limits is widely known and accepted.
The basis for some of the material that appears in this Appendix is a document
originally prepared by the State of Indiana and the EPA Region V Office.  The
original document has been reorganized and expanded to facilitate a better
understanding of the material.

1.1  GENERAL METHODOLOGY
     An incompatible pollutant's effect on a POTW must be evaluated simul-
taneously from three perspectives — impact on the treatment plant, impact on
the receiving water, and impact on sludge described above.  The limit for that
pollutant can then be set to ensure that all pretreatraent program objectives
are met.  It should be pointed out that the limiting factor which meets the
most restrictive of the three objectives may vary from pollutant to pollutant.
For example, at a particular POTW, constraints on the land application of
sludge may limit the allowable influent concentration of cadmium, while the
effects on the receiving water may limit the influent concentration of copper.
The hypothetical example provided at the end of this document will demonstrate
the effect of these limiting factors on the influent pollutant limit for
copper.

     As a general procedure, influent concentration limits should be calcu-
lated for a particular pollutant based on each of the three factors (i.e.,
treatment processes, water quality, and sludge).  The most stringent of the
three will determine the influent limit to be used for that pollutant.  The
POTW will then have to translate that influent limit into discharge limits for
its industrial users that discharge the pollutant into its sewage system.

     Although this document provides some specific data on only cyanide and
nine metallic pollutants, a POTW may receive other industrial pollutants with
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toxic characteristics.  Industrial waste surveys and/or POTW sampling, if done
properly, should identify the existence of such pollutants.  Calculation of
limits for such pollutants would follow the same general methodology discussed
in this Appendix, although inhibition and removal data would have to be devel-
oped from other sources.  It should be noted that this methodology does not
account for any cumulative, synergistic, or antagonistic effects that may
occur when several toxic pollutants are present simultaneously.  Figure 1
shows an overview of the steps used in developing pollutant discharge limita-
tions.  Table 1 presents the two basic formulae used to determine local dis-
charge limitations.  The back calculation formula is used to calculate allow-
able POTW influent concentrations based on threshold concentrations from
various in-plant criteria.  The mass conversion formula allows for the deter-
mination of a mass loading (in Ibs/day) if the flow and concentration of the
wastewater are known.
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                                    FIGURE 1
                            BASIC STEPS IN DEVELOPING

                         POLLUTANT DISCHARGE LIMITATIONS
                                Influent to POTW
                                            NPDES
Activated             Anaerobic         Limitations or           Sludge
Sludge                Digestion     Water Quality Standards      Disposal
Determine
Inhibitory
Concentration
Value

Calculate
Influent
Concentration
that is not
Inhibitory
to this Process
Determine
Inhibitory
Concentration
Value

Calculate
Influent
Concentration
that is not
Inhibitory
to this Process
1.   Calculate
    Influent
    Concentration
    which will
    allow POTW to
    comply with
    its NPDES
    permit and/or
    protect water
    quality
Determine
Sludge Disposal
Method
Calculate
Influent
Concentration that
will allow Disposal
Option
                                        T
                                   Select Most
                                 Stringent Value
                                        t
                                 Calculate Load
                            Available for Industrial
                                   Dischargers
                                        t
                                Allocate Load to
                                  Industries By
                                 Permit or Order
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                                    TABLE 1

BACK CALCULATION FORMULA
Where:  Lp  *  Allowable POTW influent concentration (in mg/1)

        Li  =  Threshold concentration for the appropriate unit operation or
               appropriate permit limitation (in mg/1)

        Ep  =  Reduction in upstream unit processes (expressed as a decimal)
MASS CONVERSION FORMULA


     L = Q x C x 8.34


Where:    L  -  Mass loading (in Ibs/day)

          Q  =  Wastewater flow (in MGD)

          C  =  Concentration (in mg/1)


       8.34  =  Conversion factor
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2.0  PREVENTION OF INHIBITION OF TREATMENT PROCESSES
     One of the primary objectives of the National Pretreatraent Program is to
prevent the discharge to a POTW of incompatible pollutants that would inter-
fere with or inhibit the POTWs operation.  In the case of cyanides, "heavy"
metals, and other toxic pollutants, treatment plant upsets could result if the
pollutant's toxicity is great enough to inhibit the microbial activity of the
biological treatment system and cause a decrease in the pollution removal
efficiency of the municipal treatment facility.  Pollutant discharge limits
should be set to maintain the concentration of each toxic pollutant below the
inhibition threshold of the treatment unit.

2.1  ACTIVATED SLUDGE PROCESS
     To calculate a discharge limit that will prevent inhibition of an acti-
vated sludge process, it is necessary to determine if an inhibition or upset
condition exists.  This determination can be made by examining POTW operating
records for disruptions or changes (e.g., settling characteristics of second-
ary sludge, bacterial species populations in the mixed liquor of the aeration
basin, etc.).  If, after examining various operating parameters, no inhibition
or upset conditions can be found, but a POTW protection criteria is desired,
current levels of pollutants of concern should be used as threshold concentra-
tions to determine maximum allowable influent loadings based on prevention of
activated sludge inhibition.  If, however, inhibition or upset conditions are
found, the POTW must first determine the concentration of each pollutant of
concern entering the activated sludge process.  Care should be taken to
include all recycle and return lines which may be sources of these pollutants,
e.g., return activated sludge (RAS).

     After this concentration has been determined, it should be compared with
various inhibitory concentration values that can be found in the technical
literature.  Table 2 lists threshold concentrations for inhibitory effects of
several metallic pollutants and cyanide on activated sludge processes, nitri-
fication processes, and anaerobic sludge digestion.  These inhibitory values
are taken from technical literature and the experience of States and munici-
palities.
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                                    TABLE 2

                 THRESHOLD CONCENTRATIONS* OF TOXIC POLLUTANTS
               THAT COULD INHIBIT BIOLOGICAL TREATMENT PROCESSES
Toxic
Pollutant
Arsenic
Cadmium
Chromium (total)
Chromium (hex)
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Threshold of
Inhibitory Effect
on Activated Sludge
0.05 mg/1
1.0 mg/1
10.0 mg/1
1.0 mg/1
1.0 mg/1
0.1 mg/1
0.1 mg/1
0.1 mg/1
1.0 mg/1
1.0 mg/1
Threshold of
Inhibitory Effect
on Nitrification
	
	
	
	
0.1 mg/1
0.5 mg/1
0.5 mg/1
	
0.5 mg/1
0.1 mg/1
Threshold of
Inhibitory Effect
on Anaerobic
Sludge Digestion
1.5 mg/1
0.02 mg/1
100.0 mg/1
50.0 mg/1
10.0 mg/1
4.0 mg/1
	
	
10.0 mg/1
20.0 mg/1
*Concentrations are specified at influent of the unit process in dissolved
 form.

 References: (1), (3), and (5)
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     Some qualifications to the data in Table 2 should be noted.  The concen-
trations reported in Table 2 are for the dissolved form of each metal and
should be used only for comparison purposes and preliminary calculations if
the actual proportion of dissolved to total metal is unknown.  In addition,
concentrations reported in this table reflect the minimum concentration which
showed an inhibitory effect for all bench-scale and full-scale studies regard-
less of test conditions.  The result is that many of the values are contra-
dictory, with the same concentration having no inhibitory effects, some
inhibitory effects, or total upset effects.  Thus, in using the data in Table
2, it should be noted that these inhibitory concentrations are not absolute
and all other possibilities should be examined prior to adopting a value from
this table as a threshold concentration.

     Using an established threshold concentration, a maximum allowable influ-
ent concentration to the POTW (Lp) is calculated for each pollutant of concern
using the back calculation formula from Table 1, as follows:
                    Li
     Where:  Lp = Maximum allowable influent concentration to the POTW (in
                  mg/1)
             Li = Established threshold concentration for the pollutant of
                  concern (in mg/1)
             Ep = Reduction of the pollutant of concern through the primary
                  treatment processes (expressed as a decimal)

     Table 3 presents  typical removal rates through primary and secondary
treatment processes for several metals, but should only be used for comparison
purposes and preliminary calculations.  Plant-specific data are more valid and
should always be used  by the POTW for final calculations.

     If , after maximum allowable influent concentrations have been calculated
for all possible in- plant criteria, the activated sludge is selected as a
controlling in-plant criteria (i.e., having the lowest maximum allowable
influent concentration) , the maximum allowable influent concentration for
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                                    TABLE 3


                          TYPICAL POTW REMOVAL RATES

                          FOR INCOMPATIBLE POLLUTANTS
Toxic
Pollutant
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Percent Removal
Through Primary Treatment
Median Value1
7
16
18
—
20
22
6
26
Percent Removal Through
Primary and Secondary Units
Median Value
50
71
82
56
57
51
32
76
 Reference:  (1)

2
 Reference:  (2)
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sludge is converted to a mass loading (L) prior to the allocation procedure
(see Section 5.0), using the mass conversion formula from Table 1 as follows:
                L = Q x C x 8.34
     Where:     L = Maximum allowable mass loading to the POTW (in Ibs/day)
                Q = Design flow (in MGD) of the POTW
                C = Maximum allowable influent concentration (in mg/1)
             8.34 = Conversion factor

2.2  ANAEROBIC DIGESTION
     To calculate a discharge limit that will prevent inhibition of anaerobic
sludge digestion, the same basic procedure utilized for the activated sludge
process is followed.  First, it must be determined if an inhibition or upset
condition exists by examining POTW operation records for disruption or changes
in such operating parameters as digester supernatant volume and methane gas
production.  If no inhibition or upset conditions are found, a POTW can adopt
current concentration levels of pollutants of concern entering the digester as
threshold concentrations, if a POTW protection criteria is desired.  If an
inhibition condition does exist, the POTW must determine the concentration of
the pollutant of concern entering the digester, and only then compare the
actual value to the data contained in Table 2, being sure to take into account
all limitations of these literature data.

     After establishing a threshold concentration, the POTW must determine the
maximum allowable mass loading to the digester, using the mass conversion
formula, as follows:

                L = Q x C   x 8.34
     Where:     L = Maximum mass loading to the digestor (in Ibs/day)
                Q = Sludge flow to the digester (in MGD)
               C  = Established threshold concentration for the anaerobic
                    digestion process (in mg/1)
             8.34 = Conversion factor
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     After a maximum allowable loading to the digester is determined, the max-
imum allowable influent concentration to the POTW (C) is calculated, using
another form of the mass conversion formula, as follows:
               C =
                   Q x 8.34
     Where:    C = Maximum allowable influent concentration (in mg/1)
               L = Maximum allowable mass loading to digester (in Ibs/day)
               Q = Design wastewater flow of the POTW (in MGD)
            8.34 = Conversion factor

     However, the amount of a pollutant of concern in the sludge is limited by
the amount of pollutant removed from the wastewater.  In the case of metals,
all metals removed from the wastewater are generally deposited in the sludge.
Therefore, the maximum allowable influent concentration for metals must be
adjusted for the amount of metals which remain in the final effluent as
follows:
             C*
                   Ep
     Where:  C* = Adjusted maximum allowable influent concentration (in mg/1)
             C  = Unadjusted maximum allowable influent concentration (in
                  mg/D
             Ep = Reduction of pollutant of concern through the entire POTW
                  (expressed as a decimal)

     The final result is that the POTW maximum allowable influent concentra-
tion is allowed to increase by a factor of (1-Ep) to account for the pollutant
of concern (metal) in the final effluent.  For other types of pollutants,
other removal mechanisms such as air stripping of volatile pollutants (which
would reduce the amount of pollutant in the sludge) must be similarly con-
sidered.  Assuming that anaerobic digestion is selected as the controlling
in-plant criteria, the adjusted maximum allowable influent concentration to
the POTW is converted to a mass loading prior to the allocation procedure.
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This is performed using the mass conversion formula found in Table 1 as
follows:

             L = Q x C* X 8.34
     Where:  L = Maximum allowable influent mass loading (in Ibs/day)
             Q = Design wastewater flow of POTW (in MGD)
            C* = Adjusted maximum allowable influent concentration (in mg/1)
          8.34 = Conversion factor
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3.0  PREVENTION OF POLLUTANT PASS-THROUGH
     The second objective of the National Pretreatment Program is to prevent
the pass-through of incompatible pollutants, which could violate a POTW's
NPDES permit requirements and applicable water quality standards.  Two proce-
dures are presented below.  The first assists the POTW in developing pollutant
discharge limits to ensure that NPDES permit limitations or any applicable
State or local discharge limits are not violated.  The second provides the
POTW with a methodology for developing pollutant discharge limits to protect
water quality criteria if desired, in the absence of specific national, State,
or local discharge limitations.

3.1  COMPLIANCE WITH THE POTW NPDES PERMIT
      There is only a single step involved in determining the maximum allow-
able influent concentration to the POTW required for that POTW to comply with
its NPDES permit requirement for a particular pollutant of concern.  Using the
back calculation formula, the maximum allowable influent concentration is
determined as follows:
                        Li
          Where:  Lp = Maximum allowable influent concentration (in mg/1)
                  Li = NPDES permit limitation for the pollutant of concern
                       (in mg/1)
                  Ep = Reduction of pollutant of concern through the entire
                       POTW (expressed as a decimal)

If the NPDES compliance in-plant criteria controls, the maximum allowable
influent concentration is converted to a mass loading prior to the allocation
procedure, as shown in previous sections.

3.2  PROTECTION OF RECEIVING STREAM'S WATER QUALITY
     EPA and State publications contain information on the effects of toxic
pollutants on receiving water quality.  The main problems caused by toxic
pollutants are the restriction of domestic and industrial uses of surface
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water, toxicity to aquatic organisms, and the accumulation of toxics in the
food chain.  Also, there has been recent concern about trace organics that are
carcinogenic to humans.  For these reasons, a POTW can, in the absence of spe-
cific toxic pollutant effluent discharge limitations, develop specific local
discharge limitations to protect the receiving stream's quality by using
established national water quality criteria.  However, it should be noted that
the establishment of water quality standards for a particular receiving stream
is the responsibility of the NPDES authority and the POTW is under no obliga-
tion to develop these standards.  In addition, any effluent discharge limita-
tions based on water quality criteria that are developed by a POTW would still
be subject to revision by the NPDES authority and would require corresponding
revisions to a POTW's local discharge limitations.

     Exhibit A summarizes water quality criteria for 21 priority pollutants
contained in EPA's Ambient Water Quality Criteria, Series (1), as published in
the November 28, 1980, Federal Register.  These new criteria have replaced
those formerly established in the 1976 edition of quality Criteria for Water
(the "Red Book").  The criteria were derived by using "guidelines," which,
theoretically, would ensure protection of aquatic health and human health.
Officially, the criteria are only recommended values; they are not enforceable
as water quality standards.  However, they do provide useful documentation in
the interpretation of State water quality standards.

     To calculate the maximum allowable pollutant loading to the POTW's treat-
ment plants that will protect the receiving water quality from degradation,
the POTW has to determine the in-stream water quality standard (C  ) for the
pollutant of interest.  This may be available from the State water quality
agency.  Otherwise, data from Exhibit A-may need to be used even though they
are not specific and may be too stringent.  The maximum allowable pollutant
concentration in the POTW's effluent (C ff) can then be calculated, taking
into account the dilution factor of the receiving stream, as follows:

             C cc = (C  )(Dilution factor)
              err     wq
     Where:  C ff = Maximum allowable pollutant concentration (in mg/1) at the
                    POTW effluent to protect receiving stream's water quality
             C    = In-stream water quality standard (in mg/1)
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                            Qstr + Qeff
          Dilution Factor = -—•	—
                               Qeff
     Where:  Q    = Critical low flow of receiving stream (in mgd)
              SC1T
             Q ff = POTW actual effluent flow (in mgd)

     Calculation of the dilution factor involves determining the total volume
of effluent discharged by the POTW into the receiving stream, either by actual
flow measurement or by estimation, using the actual POTW influent flow and
subtracting other sources of wastewater leaving the POTW, such as sludge flow.
Once the maximum allowable pollutant effluent concentration (C ff) is deter-
mined, the maximum allowable influent concentration to the POTW based on
protection of water quality is calculated using another version of the back
calculation formula, as follows:
                " 1-Ep
     Where:  Lp = Maximum allowable influent concentration to the POTW (in
                  mg/D
           C ff = Maximum allowable pollutant concentration at the POTW
            et    effluent (in mg/1)
             Ep = Reduction of pollutant of concern through the entire POTW
                  (expressed as a decimal)
If water quality is selected as a controlling in-plant criteria, the maximum
allowable influent concentration is converted to a mass loading prior to the
allocation procedure, as shown in previous sections.
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4.0  PROTECTION OF SLUDGE QUALITY
     The last major objective of the National Pretreatment Program is the gen-
eration of sludge that is compatible with the overall sludge management pro-
gram and consistent with the selected disposal option of the POTW.  Pollutant
discharge limits should be calculated so that the POTW sludge remains compat-
ible with the selected disposal option.  There are three basic methods which
POTWs utilize for sludge disposal at the present time:

     •  Incineration
     •  Landfilling
     •  Land application.

Each of these methods has different costs and benefits associated with its
use.  For this reason, the required sludge quality and degree of pretreatment
needed will also vary.

4.1  INCINERATION
     Incineration of sludges with high concentrations of priority pollutants
can volatilize organics and metals.  Little information exists on the release
of these pollutants into the air during incineration.  What is known about
incineration is that it is very expensive to operate and requires an air pol-
lution control permit.  If incineration is the disposal option used, the POTW
should sample and analyze the resulting ash to determine if the ash quality is
compatible with its disposal method.

4.2  LANDFILL DISPOSAL
     The determining factor for landfill disposal is whether the sludge is
classified as a hazardous waste.  To ensure that a particular sludge is not a
hazardous waste, the EP (extraction procedure) toxicity test must be per-
formed.  When landfill disposal is used by the POTW, the sludge leachate
should be sampled and analyzed when there is a possibility that the leachate
may contaminate or degrade groundwater or surface water resources.
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4.3  LAND APPLICATION
     To predict the sludge quality needed for land application, plant opera-
tional data should be analyzed, and land quality and quantity should be deter-
mined.  The POTW should know the general soil type and Cation Exchange
Capacity (CEC) of the land application site.  Table 4 provides Federal guide-
lines on loading limitations for land application of metal-bearing sludges.
In addition, each State may have its own land application limitations.  Both
Federal and State rules should be evaluated to determine necessary sludge
quality and allowable pollutant loads to the municipal treatment plant.  These
limitations should be utilized by the POTW to find the maximum cumulative pol-
lutant loading (L) for a specific contaminant.  Two procedures are described
below.  The first procedure is designed to assist the POTW in assessing sludge
disposal impacts while the second will help in establishing local discharge
limitations which will allow the POTW to dispose of its sludge properly and
economically.

4.3.1  Procedure to Assess Sludge Disposal Impacts
     In order to evaluate the impacts of possible sludge contamination, a POTW
must first analyze its final sludge product for each pollutant of concern.
Units of this analysis are generally in terms of milligrams of pollutant per
kilogram of sludge on a dry weight basis.  (If data are provided on a wet
weight basis, be sure to convert to dry weight using the sludge percent
solids.) After converting from mg/kg dry to Ibs/dry ton (by multiplying by
0.002), a maximum cumulative loading (L) for the appropriate pollutant of con-
cern is chosen based on the particular characteristics of the soil (Table 4 or
applicable State or local loading limitations).  Using these two values, the
maximum amount of sludge which can be applied per acre is determined, as
follows:
     Where:  AR = Maximum allowable amount of sludge applied per acre (in dry
                  tons/acre)
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                                    TABLE 4

           REQUIREMENTS FOR SLUDGE APPLICATION TO AGRICULTURAL LAND


PRIMARY REQUIRMENT - NITROGEN

     1.  Sludge application rates should provide total plant available nitro-
         gen fertilizer requirement of the crop growth, and the requirement to
         prevent nitrate pollution of groundwater.


ADDITIONAL REQUIREMENTS - TRACE METAL ELEMENTS

     1.  Maximum annual Cd loading:

         •  Jan. 1, 1981 to Dec. 31, 1985    1.25 kg/ha
         •  Beginning Jan. 1, 1986           0.50 kg/ha


     2.  Soil/sludge pH control

         •  pH of sludge amended soil should be maintained at 6.5 or greater


     3.  Total cumulative metal loadings (kg/ha)

                                Cation Exchange Capacity (meq/100 gm)
         Element                 0-5             5-15            >15
Pb
Zn
Cu
Ni
Cd
500
250
125
50
5
1000
500
250
100
10
2000
1000
500
200
20
     4.  Cd/Zn ratio of sludge applied should be less than 0.015 in naturally
         acidic soils.
Derived from Reference (7).
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             L = Maximum cumulative loading (in Ibs/acre)
             C = Pollutant concentration in sludge (in Ibs/dry ton)

     Using the maximum amount of sludge which can be applied per acre and the
available acreage for sludge application, the total amount of sludge that can
be applied is calculated as follows:

             TA = AR x A
     Where:  TA = Total amount of sludge allowable for disposal on available
                  acreage (in dry tons)
             AR = Maximum allowable amount of sludge applied per acre (in dry
                  tons/acre)
              A = Available acreage for sludge disposal (in acres)

     This total amount of sludge allowable for disposal on available acreage
is next divided by the POTW s current sludge generation rate to determine the
lifetime of the available acreage based on the amount of pollutant in the
sludge, as follows:
             T* =--
                   SG
     Where:  T* = Adjusted site lifetime (in years)
             TA = Total amount of sludge allowable for disposal on available
                  acreage (in dry tons)
             SG = POTW's current sludge generation rate (in dry tons/yr)

     This adjusted site lifetime can then be compared to the original lifetime
of the available acreage.  If the site lifetime is not reduced significantly,
the POTW may decide to set a threshold concentration at current pollutant
levels as a POTW protection criteria.  However, if the site lifetime is re-
duced significantly, the POTW must establish a local discharge limitation
which will allow an acceptable disposal site lifetime.
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4.3.2  Procedure to Establish Local Discharge Limitations to Protect POTW
       Sludge Disposal Options
     The maximum cumulative pollutant loading per acre (L, previously deter-
mined using the soil characteristics of the sludge disposal site), the amount
of available site acreage (A), and the original site lifetime (T) are used to
calculate the maximum allowable pollutant mass loading in the sludge to comply
with the maximum cumulative pollutant loading per acre and still maintain the
original site lifetime, as follows:
                  T x 365
     Where:  ML = Maximum allowable pollutant mass loading (in Ibs/day)
              L = Maximum cumulative pollutant loading per acre (in Ibs/acre)
              A = Available acreage (in acres)
              T = Original site lifetime (in years)
            365 = Conversion factor (in days per year)

     Next, the maximum allowable pollutant mass loading (ML ) to the influent
of the treatment plant,  to ensure appropriate sludge quality  for land  applica-
tion, can be calculated  by adjusting ML for removal through the entire plant,
as follows:
      Where: ML*  =  Adjusted maximum  allowable  pollutant mass  loading  (in
                   Ibs/day)
             ML  =  Unadjusted maximum  allowable  pollutant  mass  loading  (in
                   Ibs/day)
             Ep  =  Pollutant reduction through the  entire  POTW  treatment  system

      The  maximum allowable pollutant  concentration at  the influent of  the
 plant (C) can  be found by converting  the adjusted  maximum allowable  influent
 pollutant mass loading using  the mass conversion formula, as follows:
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               C      ML*
                   Q x 8.34
     Where:    L = Maximum allowable pollutant concentration (in mg/1)
             ML* = Adjusted maximum allowable influent mass loading (in
                   Ibs/day)
               Q = POTW design flow (in MGD)
            8.34 = Conversion factor
     This concentration is used as the sludge disposal in-plant criteria in
determining which in-plant criteria controls.  If the sludge disposal criteria
controls, the adjusted maximum allowable influent mass loading (ML*) is used
to begin the allocation procedure.
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5.0  ALLOCATION OF THE POLLUTANT LOAD TO INDUSTRY

     The final step in the process of setting effluent limitations is to
allocate the maximum pollutant loading to the treatment plant to the individ-

ual industrial dischargers. This may be accomplished in several ways, as dis-
cussed below.


5.1  ALTERNATIVE METHODS

     •  Single concentration or mass limit;  A single concentration or mass
        limitation can be established, which no industrial user (IU) can
        exceed, and, when domestic contribution is taken into account, will
        not exceed the allowable influent loading.  This method corresponds to
        the example calculation shown in Section 6 of the Appendix.  A single
        limit for all users may be easier to regulate and enforce.

     •  Proportionate:  Allocation can be accomplished proportionately, using
        various IU characteristics such as mass loading or flow rate to divide
        up the allowable pollutant discharge.  The preferred method of alloca-
        tion is the one based on mass loadings.  However, if concentration
        data is not available for each IU, the mass loading ratio may not be
        used, and proportionality will have to be based on another character-
        istic such as IU flow.  However, if the flow is based on water usage,
        this method penalizes the industrial user that recycles or reuses some
        portion of its wastewater.  This method may be desirable when there
        are only a few dischargers of a given pollutant in the entire indus-
        trial community.

     •  Technology-based:  Technology-based limitations are developed by con-
        sidering wastewater treatment systems for each particular industrial
        user that are best suited to that IU's wastewater.  Information on
        state-of-the-art treatment system performance can be obtained from EPA
        Development Documents supporting effluent limitations guidelines and
        standards.
5.2  OTHER CONSIDERATIONS

     •  Growth;  Expansion should also be considered in the POTW service area
        when allocating pollutant loading.  Expansion can include domestic
        contributions where future population growth can cause overloads of
        compatible pollutants, as well as future industrial contribution.  If
        land has been zoned for industrial parks or other developments, POTWs
        must allocate a certain portion of the allowable influent loading to
        this planned expansion.

     •  Design;  Proposed or planned design changes in the municipal treatment
        plant should be taken into account when developing and setting indus-
        trial effluent limitations.  For example, nitrification is a more
                                     B-22

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        sensitive process than activated sludge for some pollutants.  A POTW
        planning to upgrade would need to develop protection criteria for this
        process if it is the limiting factor for some pollutants.  Industrial
        discharge limits might then have to be made more stringent to protect
        the new design.  Industrial users should be kept informed of such
        plans and developments so that pretreatraent technologies are appro-
        priate over time.
5.3  PROCEDURE FOR ALLOCATION OF POLLUTANT LOADINGS TO INDUSTRY
     After determining the controlling in-plant criteria and converting the
maximum allowable influent concentration to mass (Ibs/day), the uncontrollable
fraction of the maximum allowable influent loading should be subtracted prior
to allocation.  For most POTWs , the uncontrollable fraction will be the pollu-
tants contributed by domestic wastewaters, and is determined by sampling a
typical domestic sewer interceptor where no industry exists.  Table 5 presents
data on typical background concentrations of various pollutants found in raw
sewage and other nonindustrial sources, but should only be used for comparison
purposes and preliminary calculations.

     Once the uncontrollable fraction of a pollutant is subtracted from the
maximum allowable influent loading, the controllable or allocatable fraction
remains.  After considerations such as expansion have been considered, allo-
cation of the controllable fraction is performed using one of the three
methods specified.  Procedures for single concentration and proportionate
allocation method follow.

     Single concentration allocation is performed by adding together the flows
of all current and future IUs contributing a specified pollutant of concern
and then applying the mass conversion formula, as follows:

     Single Concentration      ,   . .    Allocatable Fraction (Ibs/day)
     Limitation                     -  ~    (Qj + Q2 +Q3. . .) X 8.34
     Where:  (Q  + Q? + Q ) = Sum of all IUs1 flows which discharge the
                              specific pollutant of concern
                                     B-23

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                                    TABLE 5

                     TYPICAL BACKGROUND CONCENTRATIONS OF
                   TOXIC POLLUTANTS IN NONINDUSTRIAL SEWAGE
                  (INCLUDES DOMESTIC AND COMMERCIAL SEWAGE)*
     Toxic Pollutant                        "Background" Concentration

     Arsenic                                        0.003 mg/1

     Cadmium                                        0.003 mg/1

     Chromium (total)                               0.05 mg/1

     Copper                                         0.061 mg/1

     Cyanide                                        0.041 mg/1

     Lead                                           0.050 mg/1

     Nickel                                         0.021 mg/1

     Zinc                                           0.175 mg/1



* Concentrations are total pollutants except where otherwise indicated.

 References: (9)
                                     B-24

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     Proportionate allocation is based on a particular characteristic of each
industrial user.  For example, using each Ill's mass loading or wastewater flow
to establish the appropriate proportion, the allocation is performed as
follows:

     Proportionate Allocation Method 1 (Mass) ;

     Proportionate Concentration     A11     U1        .   , 1V  ,,  » „   1
     T. r_ _,   .,   _„ ,,,         =  Allocatable Fraction (Ibs/day) X 7-: — r-
     Limitation For IU ffl                                             (L )
     Where:  L.  = Current mass loading from IU #1 for a
                  specific pollutant (Ibs/day)
             L  = Total mass loading from all industrial
                  users for a specific pollutant (Ibs/day)
             Q  = Wastewater flow of IU #1 (MGD)
           8.34 = Conversion factor
This is the preferred method of proportionate allocation, if industrial user's
pollutant concentrations are known.  If they are not, the next method may be
used.

     Proportionate Allocation Method 2 (Flow);

     Proportionate Concentration     Ann                  .    .   .     n'
     Limitation For IU f 1         =  Allocatable Fraction (Ibs/day) X
                                                   Q  x 8.34
     Where:  Q  = Wastewater flow of IU #1 (MGD)
             Q  = Sum of wastewater flows for all lUs which discharge
                  a specific pollutant of concern
           8.34 = Conversion factor

The above procedures would be repeated for all industrial users discharging
that particular pollutant of concern.
                                     B-25

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6.0  A HYPOTHETICAL POTW EXAMPLE
     For reasons of brevity and simplicity, this example calculation of allow-
able influent loading to a POTW addresses only one pollutant, copper.  The
methodology presented here, however, will be equally applicable for calculat-
ing limits for other pollutants discharged by electroplaters or other indus-
tries.  Our hypothetical POTW utilizes an activated sludge unit for secondary
treatment and anaerobic digestion of sludge.  POTW sludge is applied on nearby
farmland.

     The treatment plant has a design flow of 10.0 MGD (9.9 MGD average).  The
POTW is required to develop a pretreatment program because it has an electro-
plating facility manufacturing printed circuit boards contributing copper to
its system.  The POTW pumps 0.2 MGD of raw sludge, thickens it from 1 percent
to 5 percent solids, and then pumps to anaerobic digesters.

     For the purpose of this example calculation, we will assume that the
electroplating facility discharges only copper.  The POTW has determined,
through its sampling program, that the average removal of copper through the
activated sludge portion of the treatment system is 83 percent with primary
treatment achieving an average of 25 percent removal.  The POTW has an NPDES
effluent limitation for copper of 1.0 mg/1.

     The POTW has documented upset and inhibition conditions at its treatment
plant caused by high copper concentrations.  The threshold copper concentra-
tions at the influent to each appropriate unit operation for this example are
as follow:

                         Activated sludge -   1.0 rag/1
                         Anaerobic digestion - 10.0 mg/1
                                      B-26

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6.1  CALCULATING MAXIMUM ALLOWABLE POLLUTANT LOAD TO THE POTW FOR COPPER

6.1.1  Preventing Inhibition of Treatment Plant Processes
     To determine the influent concentration of copper that will not inhibit
treatment plant process, the POTW must calculate in-plant criteria for both
the activated sludge process and the anaerobic digestion process to find the
controlling in-plant criteria concentration.

     (1)  Activated Sludge
          Using the back caluclation formula presented in Table 1, the in-
          plant criteria for the activated sludge process can be determined,
          as shown below:
          Where:  Activated sludge copper threshold concentration =1.0 mg/1
                  POTW % removal through primary treatment = 25% (or 0.25)
     (2)  Anaerobic Digestion
          Determining the allowable influent copper concentration for proper
          anaerobic digestion is slightly more complicated.  The allowable
          amount of copper, in Ibs/day, in the anaerobic digester is deter-
          mined by first calculating the flow of sludge to the anaerobic
          digester, and then applying the mass conversion formula shown in
          Table 1, using the anaerobic digestion copper threshhold concentra
          tion and the calculated flow rate, as follows:
          C\
           '
                    0.04 MGD (concentrated by extracting water from 1% to 5%)

          Allowable Cu mass loading to digester = (0.04 MGD)(10 mg/l)(8.34)
                                                = 3.34 Ibs/day
                                     B-27

-------
          Using the allowable amount of copper to the digester, an allowable
          influent concentration can be calculated, using another form of the
          mass conversion formula and the POTW design flow, as follows:
          Allowable influent Cu concentration =        wo     = 0.04 mg/1
                                                v, IU
          However, only 83 percent removal of copper is achieved through the
          entire treatment system and, therefore, only this portion of the
          influent copper reaches the digester.  Consequently, the allowable
          influent concentration is adjusted using another form of the back
          calculation formula as follows:
          Allowable influent Cu concentration =   „ '^g   = 0.048 mg/1
                                                  U .o j
6.1.2  NPDES Permit Compliance
     Using the back calculation formula presented in Table 1, the in-plant
criteria to meet the POTW NPDES permit requirement is calculated as follows:
     Where:  NPDES permit limitation =1.0 mg/1
             Reduction of copper through the entire POTW = 83% (or 0.83)

6.1.3  Determination of Possible Sludge Disposal Impacts
     In addition to the possible impacts mentioned above, sludge disposal
options may be limited for this hypothetical POTW because of the amount of
copper in its digested sludge, which it intends to apply to surrounding farm-
land.  In order to evaluate this possibility, the POTW has analyzed its
digested sludge and found it to contain 525 rag/kg (dry weight) of copper.
Converting to pounds per ton:

     Copper content of  =  525 mg/kg (dry weight) x 0.002 = 1.05 Ibs/dry ton
     digested sludge
                                     B-28

-------
     Using the most stringent total cumulative metal loading option from
Table 4 (125 kg/ha), and converting to Ibs/acre:

     Total cumulative metal loading        111 Ibs/acre     -    ,        ,
     	——r-.	-—3—r-6^—  =  .  ' .,   .'	  =  106 dry tons/acre
     Copper content of digested sludge     105 Ibs/ton

yields the maximum amount of sludge which can be applied in dry tons/acre.

     The hypothetical POTW applies approximately 45 dry tons/month of de-
watered digester sludge to about 410 acres of surrounding pasture and farm-
land.  Using the maximum amount of sludge which can be applied per acre and
the land available for application, the total amount of sludge which can be
applied for the lifetime of the sites can be calculated:

     Total sludge allowable        106 dry tons  x 410 acres   . _ .,.. ,
     c   ,.     ,        ,,  , n    =  	L	 = 43,460 dry tons
     for disposal on available               acre                 '      J
     acreage

     Using this total site lifetime application and the current sludge dis-
posal rate (45 dry tons/month), the lifetime of the sites available for appli-
cation is calculated:
     Lifetime of available      43,460 dry tons    n,,
             ..    ,  ,       = TT—j—	1	TT— = 966 months or 80 years
     acreage for sludge       45 dry tons/months                    J
     disposal
     Therefore, unless the original lifetime expectancy of the sludge disposal
sites is well over 80 years, this POTWs sludge disposal options will not be
affected by the current amount of copper in its sludge.  In addition, any
reduction of the POTW plant influent copper concentration due to other local
limitations will further lower the amount of copper in the sludge and extend
the useable lifetime of the sludge disposal sites.
                                     B-29

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6.1.4  Determination of Controlling In-Plant Criteria
     Reviewing the in-plant criteria for each condition;
          Activated sludge - 1.3 mg/1
          Permit conditions - 5.88 mg/1
          Anaerobic digestion - 0.048 mg/1
It can be seen that anaerobic digestion is the controlling in-plant criteria.
Therefore, it is possible that a POTW can be substantially below its permit
condition for a toxic pollutant and still experience inhibition and inter-
ference severe enough to prevent proper plant operation from that same pol-
lutant.

6.2  ALLOCATION OF LOCAL LIMITS FOR COPPER
     After calculating an allowable influent concentration of 0.048 mg/1 of
copper as an in-plant criteria for proper anaerobic digestion, the POTW must
allocate the required reduction to attain this concentration among its indus-
trial users.  The POTW has identified an electroplating facility as the only
major industrial user discharging copper to its system.  This facility has a
flow of 0.050 MGD and currently averages 7.0 mg/1 copper in its effluent.

     Using the allowable influent concentration, the allowable pollutant mass
loading is calculated:

          Allowable Ibs/day = (10.0 MGD)(0.048 mg/l)(8.34) = 4.0 Ibs/day

After sampling at a number of domestic interceptors, the POTW has determined
the copper concentration in domestic wastewater to be 0.025 mg/1.  Calculating
the current domestic copper mass loading:

          Domestic Ibs/day = (9.85 MGD)(0.025 mg/l)(8.34) = 2.1 Ibs/day

     The allowable copper which can be allocated to industry is then calcu-
lated by subtracting  the domestic background loading:
                                     B-30

-------
          Allowable Ibs/day =4.0 Ibs/day - 2.1 Ibs/day =1.9 Ibs/day

The current electroplating mass discharge is:

     Electroplating Ibs/day = (0.050 MGD)(7.0 mg/l)(8.34) = 2.92 Ibs/day

     This particular electroplating facility is subject to a categorical stan-
dard of 4.8 mg/1 for copper.  When compliance with this categorical standard
is achieved, the electroplating mass discharge will be:

     Electroplating Ibs/day = (0.050 MGD)(4.8 mg/l)(8.34) = 2.00 Ibs/day

     The POTW has two future contributions to its system planned.  One is a
housing project which will house approximately 500 people.  At an estimate of
150 gallons per person daily, the total wastewater flow increase is 0.075 MGD.
However, because of the high cost of copper, builders are planning to use PVC
pipe instead of copper pipe, which the POTW believes is the major source of
domestic copper contribution.  Therefore, the POTW is assuming a negligible
amount of copper in this additional flow.  The second future addition is a
brass plating operation, which will be a major discharger of copper.  This
facility will have a design flow of 0.025 MGD and is also subject to a cate-
gorical standard for copper of 4.8 mg/1.  Knowing that the existing facility
already exceeds the allocatable loading using the categorical standard, a more
stringent single concentration local limitation is established:

     Allowable electroplating	1.90 Ibs/day	,
     concentration              ~ (0.050 + 0.025 MGD)(8.34)       mg

Therefore, a single concentration local limitation of 3.0 mg/1 for both the
existing and future electroplating facilities will allow the POTW to meet its
allowable influent concentration and will not violate the controlling in-plant
criteria.
                                     B-31

-------
                              REFERENCES
1.  U.S. Environmental Protection Agency.  Federal Guidelines - State and
    Local Pretreatment Programs.  Vols. I, II, and III.  EPA-430/9-76-017a, b,
    and c.  January 1977.

2.  U.S. Environmental Protection Agency.  Fate of Priority Pollutants in
    Publicly Owned Treatment Works.   EPA-440/1-82-303.  September 1982.

3.  Anthony, Richard M., and Breimhurst, Lawrence H. "Determining Maximum
    Influent Concentrations of Priority Pollutants for Treatment Plants."
    Journal of the Water Pollution Control Federation, Vol. 53.  October 1981.

4.  Dyer, Jon; Feiler, Howard; and Bernick, Arnold.  Handbook of Industrial
    Waste Pretreatment, Water Management Series.  New York:  Garland
    Publishing Inc.  1981.

5.  Eick, Richard W.  "History of Priority Pollutants at the District and
    Determination of Prohibitive Discharge Limits (PDL)." 2nd Edition.
    Sanitary District of Rockford, Illinois.  March 1982.

6.  U.S. Environmental Protection Agency.  Ambient Water Quality Criteria.
    EPA-440/5-80.  October 1980.

7.  U.S. Environmental Protection Agency.  "Municipal Sludge Management-
    Environmental Factors."  Federal Register, 41, No. 108, pp. 22531, 22543.
    June 1976.

8.  JRB Associates.  "How to Set Local Limits." Handout prepared for
    Pretreatment Seminars, sponsored by U.S. Environmental Protection Agency
    under Contract No. 68-01-5052.  May 1982.

9.  JRB Associates.  "Assessment of the Impacts of Industrial Discharges on
    Publically Owned Treatment Works."  Prepared for U.S. Environmental Pro-
    tection Agency under Contract No. 68-01-5052.  November 1981.
                                      B-32

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                                   EXHIBIT A

     This Exhibit presents a summary of national water quality criteria that
have been generated by EPA.  These numbers do not have any regulatory status;
they are intended to serve as general guidelines for the preservation of the
intended uses of water.  The criteria numbers on this table are organized
under two major headings:  aquatic life and human health.  The first heading
is further subdivided into acute and chronic criteria.  These two numbers
represent pollutant concentrations which, if not exceeded, should protect
most, but not necessarily all, aquatic life and its uses.  The aquatic life
criteria specify both acute (maximum) and chronic (24 hour average) concen-
trations.  The combination of the two numbers is designed to provide adequate
protection of aquatic life and its uses from acute and chronic toxicity and
bioconcentration while being more flexible than a one number criterion.

     The human health criteria are divided into two categories.  The first
group of numbers under water and organisms was generated assuming consumption
of both drinking water and aquatic organisms (i.e., fish) by humans.  The
second group of criteria was derived assuming the consumption of aquatic orga-
nisms only.  The criteria for human health are based on the carcinogenic,
toxic or organoleptic (taste and odor) properties of the pollutants.  The
meanings and practical uses of these criteria values vary accordingly.

     For carcinogenic substances, no scientific basis exists for estimating
"safe" levels.  Therefore, the criteria are expressed as ranges of values
corresponding to incremental cancer risks of 10   to 10   (one additional case
of cancer in a population ranging from ten million to 100,000, respectively).
A detailed discussion of these criteria, how they were developed and
qualifications regarding their use can be found in Reference 6.
                                     B-33

-------
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-------
     APPENDIX C
 PRIORITY  POLLUTANTS
        AND
CATEGORICAL INDUSTRY
     INFORMATION

-------
                             TABLE C.I
             MATRIX OF PRIORITY POLLUTANTS POTENTIALLY
               DISCHARGED FROM INDUSTRIAL CATEGORIES
     Table C.I lists the 25 categorical industries and the potential
priority pollutants that can occur in significant amounts in the
wastewater discharged from each group.  This does not mean that every
facility within a specific group discharges that pollutant; it does
mean that there is a high probability that it will be discharged,
based on a national survey of the industries conducted by USEPA.  In
addition, it does not mean that other priority pollutants will not be
found in significant quantities, but that, in general, the manufacturing
process and raw materials involved do not lead to the discharge of these
pollutants.

     NOTE:  The information in the table was developed from Industry
Summaries prepared by the USEPA, dated March 1979, from the published
development documents for effluent limitations from industrial point
source categories.  This information is subject to change, and, as
shown in Tables C.I and C.2, some industry groups may not be regulated.
                                C-l

-------
TABLE C.I £
H
CO
MATRIX OF PRIORITY POLLUTANTS &
POTENTIALLY DISCHARGED FROM §
INDUSTRIAL CATEGORIES *
h- ]
<
• POLLUTANT FOUND IN £J
SIGNIFICANT QUANTITY g
w
H
<
U
PRIORITY POLLUTANTS \^
1 . acenaphthene
2. acrolein
3. aery Ion itrile
4 . benzene
5 . benzidine
6. carbon tetrachloride
7. chlorobenzene
8 . 1,2 ,4-trichlorobenzene
9 . hexachlorobenzene
10. 1 , 2-dichloroethane
11. 1,1,1-tnchloroe thane
12 . hexachloroethane
13. 1,1-dichloroe thane
3-4. 1,1,2-trichloroethane
15. 1, 1,2,2-tetrachloroethane
16 . ch lor oe thane
17. bis(2-chloroethyl) ether
18 . 2-chloroethvl vinyl ether (mixed)
19 . 2-chloronaphthalene
20. 2,4,6-trichlorophenol
21. parachlorometa cresol
22 . chloroform (trichloromethane)
23. 2-chlorophenol
24. 1,2-dichlorobenzene
25 . 1, 3-dichlorobenzene
26. 1 , 4-dichlorobenzene
27. 3 , 3-dichlorobenzidine
28 . 1, 1-dichloroethvlene
29. 1,2-trans-dichloroethylene
30. 2 , 4-dichlorophenol
31 . 1 , 2~dichloropropane
32 . 1 , 2-dichloropropylene (1, 3-dichloropropene)
33- 2,4-dimethylphenol
34 . 2 , 4 -d in itro toluene
35 . 2, 6-dlnitro toluene
36. 1 , 2-diphenylhydrazine
37 . ethylbenzene
38 , fluorathene
39 . 4-chlorophenyl phenyl ether
40. 4-bromophenyl phenyl ether
41. bis(2-chloroisopropyl) ether
42 . bis (2-chloroethoxy) methane
43. met hygiene chloride (dichlorome thane)
44. methyl chloride (chloromethane)
45 . methyl bromide (bromomethane)
46. bromof orm (tribromomethane)
47 . dichlorobromomethane
48. chlorodibromomethane
49 . hexachlorobutadiene
50. hexachlorocvclooenfAdiene
51 . isoohorone
52. naphthalene
53. nitrobenzene
54. 2-nitroDhenoL
55 . 4-nitrophenol
56. 2,4-dinitrophenol
57. 4.6-dinitro-o-cresol
58 . N-nitrosodimethylamine
59 . N-nitrosodiphetiylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62. phenol
63. bis(2-ethylhexyl) phthalate
64 . butyl benzyl phthalate
ADHESIVE





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ALUMINUM FORMING





















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C-2

-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
CATEGORICAL INDUSTRY
\
65. di-n-butyl ohthalate
66. di-n-octvl phthalate
67. diethyl phthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1,2-benzanthracene)
70. benzo (a)pyrene (3,4-benzo~pyrene
71. 3,4-benzofluoranthene (benzo (b) fluoranthene)
72. benzo (k) f luoranthane (11 , 12-benEof luoranthene)
73. chrysene

74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1, 12-benzoperylene)
77. fluorene
78. phenanchrene
79. dibenzo(ah)anthracene (1.2,5.6~dibenzanthracene)
80. indeno (1,2, 3-cd)pyrene (2 , 3-o-phenvlenepyrene)
81. pyrene
82. tetrachloroethylene
83. toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4,4-DDE (p.p-DDX)
91. 4,4-DDD IP.P-TDE)
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin


96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide (BHC-hexachlbrocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polychlorinated biphenyl)
103. PCB-1242 (Arochlor 12421
104. PCB-1254 (Arochlor 1254)
105. PCB-1221 (Arochlo 1221)
106. PCB-1232 (Arochlo 1232)
107. PCB-1248 (Arochlo 1248)
108. PCB-1260 (Arochlo 1260)






109. PCB-1016 (Arochlo 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)
113. asbestos (fibrous.
L14. beryllium (total)
115. cadmium (total)
117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)






121. nickel (total)
122. selenium (total)
123. silver (total)
.24. thallium (total)
.25. zinc (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)


ADHESIVE
•

•
•















•


























•



•
•
•
•








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•


















•






























•
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•

•







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•










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•

































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•
•

•







FOUNDRIES





























































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•
•
•












C-3

-------
TABLE C.I (Continued) g
r~*
to
MATRIX OF PRIORITY POLLUTANTS g
POTENTIALLY DISCHARGED FROM H
INDUSTRIAL CATEGORIES ^
u
POLLUTANT FOUND IN g
SIGNIFICANT QUANTITY o
H
<
U
PRIORITY POLLUTANTS \_
1. acenaphthene
2. acrolein
3. acrylonitrile
4. benzene
5. benzidine
6. carbon tetrachloride
7 . chLorobenzene
8, 1, 2 ,4-trichlorobenzene
9. hexachlorobenzene
10. 1,2-dichloroethane
11. 1, 1, 1-trichloroechane
12. hexachloroethane
13. 1,1-dichloroethane
14. I,lj2-trichloroethane
15. 1,1,2,2-tetrachloroethane
16. chloroethane
17. bis(2-chloroechyl) ether
18. 2-chloroethvl vlnvl ether (mixedl
19. 2-chloronaphthalene
20. 2,4,6-trichlorophenol
21. parachlorometa cresol
22. chloroform (trichloromethanel
23. 2-chlorophenol
24. 1,2-dichlorobenzene
25. 1,3-dlchlorobenzene
26. 1,4-dlchlorobenzene
27. 3,3-dichlorobenzidine
28. 1.1-dlchloroethvlene
29. 1,2-trans-dichloroethvlene
30. 2,4-dichlorophenol
31. 1 , 2-dichloropropane
32. 1,2-dichloropropylene (1, 3-dichloropropene)
33. 2,4-dimethylphenol
34. 2,4-dinitrotoluene
35. 2,6-dinitrotoluene
36. 1,2-diphenylhydrazlne
37. ethylbenzene
38. fluorathene
39. 4-chlorophenyl phenvl ether
40. 4-bromophenyl j>henyl ether
41. bis (2-chloroisopropyl) ether
42. bis(2-chloroethoxy) methane
43. methylene chloride (dichloromethanel_
44. methyl chloride (chloromethane)
45. methyl bromide (bromomethane)
46. bromoform (tribromomethatie)
47. dichlorobromomethane
48. chlorodibromomethane
49. hexachlorobutadiene
50. hexachlorocvclooenta^iene
51. isophor^ne
52. naphthalene _
53. nitrobenzene
54. 2-nitroohenol
55. 4-nitrophenol
56. 2 ,4-dinitrophenol
57. 4,6-dinitro-o-cresol
58. N-nitrosodimethylamine
59. N-nitrosodiphenylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62 . phenol
63. bis(2-ethylhexyl) phthalace
64. butyl benzyl phthalate
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C-4

-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
CATEGORICAL INDUSTRY
\
65. di-n-butyl Dhthalate
66. di-n-octvl Dhthalate
67. diethvl Dhthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1.2-benzanthracene)
70. benzo(a)pyrene (3,4-benzo-pyrene
71. 3, 4-benzofluoranthene (benzo(b)fluoranthene)
72. benzo(k)fluoranthane (11 , 12-benzof luorantheneL
73. chrysene
74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1,12-benzoperylene)
77. fluorene
78. phenanthrene
79. dibenzo(ah)anthracene (1.2. 5.6-dibenzanthracene)
80. indeno (1, 2, 3-cd)pyrene (2,3-o-phenylenepyrene)
81. pvrene
82, tetrachloroethylene
83, toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4.4-DDE (p.p-DDX)
91. 4,4-DDD (p.p-TDE)
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin
96. endrin aldehyde
97. heptachlor
98. heptachlor epoxide (BHC-hexachlorocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polvchlorinated biohenvl)
103. PCB-1242 (Arochlo 1242)
104. PCB-1254 (Arochlo 1254J
105. PCB-1221 (Arochlo 1221)
106. PCB-1232 iArochlo 1232)
107. PCB-1248 (Arochlo 1248)
108. PCB-1260 (Arochlo 1260)
109. PCB-1016 (Arochlor 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)


113. asbestos (fibrous)
114. beryllium (total)
115. cadmium (total)
116. chromium (total)
117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
124. thallium (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)




i-i
w
w
H
CO
<3
&
o
03
M



















































•

•









LEATHER TANNING & FINISHING


















•
































•

•


•






METAL FINISHING


•







•






•
































•
•




•






NON-FERROUS METALS
•
•
•


•


•



•



•
•





















•


•



•
•

•
•
•

•

•
•
•
•




ORE MINING & DRESSING





















































•









ORGANIC CHEMICALS, PLASTICS
AND SYNTHETICS
•












•



•
•































•
•



•







PESTICIDES





















































•






•

•
PETROLEUM REFINING



















































•

•






•


PHARMACEUTICALS


















•




























•












•


PLASTICS PROCESSING


















































•

•

*








C-5

-------
1
>H
TABLE C.I (Continued) H
P
MATRIX OF PRIORITY POLLUTANTS §
POTENTIALLY DISCHARGED FROM M
INDUSTRIAL CATEGORIES <
u
i— i
POLLUTANT FOUND IN O
SIGNIFICANT QUANTITY w
E~<
<
CJ
PRIORITY POLLUTANTS \^
1. acenaphthene
2. acrolein
3. aery Ionic rile
4. benzene
5 . benzidine
6. carbon tetrachloride
7 . chlorobenzene
8. 1,2,4-trichlorobenzene
9 . hexachlorobenzene
10- 1,2-dichloroe thane
11. 1, 1,1- trichloroe thane
12 . hexachloroethane
13. 1 ,1-dichloroe thane
14. 1,1, 2- trichloroe thane
15 . 1,1,2, 2-tetrachloroethane
16. chloroe thane
17. bis(2-chloroethyl) ether
18. 2-chloroethvl vinyl ether (mixed)
19 . 2-chloronaphthalene
20. 2 1 4 7 6-trichlorophenol
21. parachlorometa cresol
22. chloroform (trichloromethane)
23. 2-chlorophenol
24 . 1,2-dichlorobenzene
25 . 1, 3-dichlorobenzene
26. 1,4-dichlorobenzene
27 . 3 , 3-dichlorobenzidine
28 . 1 . 1-dichloroe thvlene
29 . 1 , 2- trans-dichloroe thvlene
30. 2,4-dichlorophenol
31 . 1 7 2-dichloropropane
32 . 1 , 2-dichlorqpropylene (1 , 3-dichloropropene)
33. 2,4-dimethylphenol
34. 2, 4-dinitro toluene
35. 2, 6-d in itro toluene
36. 1 , 2-diphenylhydrazine
37 . ethylbenzene
38. fluorathene
39 . 4-chlorophenyl phenyl ether
40. 4-bromophenyl phenyl ether
41. bis(2-chloroisopro_pyl) ether
42 . bis (2-chloroethoxv) methane
43. me thvlene chloride (dichlorome thane)
44 . methyl chloride (chloromethane)
45. methyl bromide (bromomethane)
46. bromoform (tribromomethane)
47 . dichlorobromomethane
48 . chlorodibromome thane
49 . hexachlorobutadiepe
50. hexachlorocvcloopntadienfi
51 . isophorone
52 . naphthalene
53. nitrobenzene
54 . 2-nitroohenol
55 . 4-nitrophenol
56. 2,4-dinitrophenol
57. 4,6~dinitro-o-cresol
58. N-nitrosodimethylamine
59 . N-nitrosodiphenylamine
60. N-nitrosodi-n-propylamine
61. pentachlorophenol
62. phenol
63. bis(2-ethylhexy_l) phthalate
64 . butyl benzyl phthalate
PORCELAIN ENAMELING |
































































PULP, PAPER, AND FIBERBOARD |





















•










































STEAM ELECTRIC 1
































































TEXTILE MILLS





























































•
•

TIMBER PRODUCTS PROCESSING |




























































•
•







































































































































































































































































































































C-6

-------
TABLE C.I (Continued)
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
/ CATEGORICAL INDUSTRY |
65. di-n-butyl phthalate
66. di-n-octvl chthalate
67. diethvl phthalate
68. dimethyl phthalate
69. benzo(a)anthracene (1 , 2-benzanthracene)
70. benzo (a)pyrene (3,4-benzo-pyrene
71. 3, 4-benzofluoranthene (benzo(b)fluoranthene)
72. benzo (k) fluoranthane (11,12-benzof luoranthene)
73. chrysene
74. acenaphthylene
75. anthracene
76. benzo(ghi)perylene (1 , 12-benzoperylene)
77. fluorene
78. phenanthrene
79. dibenzo(ah)anthracene (1.2. 5.6-dibenzanthr<
icene)
80. indeno (1,2, 3-cd)pyrene (2, 3-o-phenvlenepyrene)
81. pyrene
82. tetrachloroethylene
83. toluene
84. trichloroethylene
85. vinyl chloride (chloroethylene)
86. aldrin
87. dieldrin
88. chlordane (technical mixture & metabolites)
89. 4,4-DDT
90. 4,4-DDE (p.p-DDX)


91. 4,4-DDD (p,p-TDE) _^
92. Alpha Endosulfan
93. Beta Endosulfan
94. endosulfan sulfate
95. endrin
96. endrin aldehyde
97. heptachlor

98. heptachlor epoxide (BHC-hexachlorocyclohexane)
99. Alpha-BHC
100. Beta-BHC
101. Gamma-BHC(lindane)
102. Delta-BHC (PCB-polighlorinated biphenyl)
103. PCB-1242 (Arochlor 1242)
104. PCB-1254 (Arochlor 1254J_
105. PCB-1221_(Arochlor 1221J_
106. PCB-1232 (Arochlor 1232J_
107. PCB-1248 (Arochlor 1248J_
108. PCB-1260 (Arochlor 1260)
109. PCB-1016 (Arochlor 1016)
110. toxaphene
111. antimony (total)
112. arsenic (total)


113. asbestos (fibrous)
L14. beryllium (total)
L15. cadmium (total)
116. chromium (total)



117. copper (total)
118. cyanide (total)
119. lead (total)
120. mercury (total)
121. nickel (total)
122. selenium (total)
123. silver (total)
124. thallium (total)
125. zinc (total)
126. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)


PORCELAIN ENAMELING


















































•
•
•

•

•



•



PULP, PAPER, AND FIBERBOARD
































































STEAM ELECTRIC |




















































•



•



•



TEXTILE MILLS

















•
•
•








































•



TIMBER PRODUCTS PROCESSING















































•



•
•
















































































































































































































































































































































C-7

-------
                                         TABLE  C.2
            STATUS  REPORT  OF CATEGORIES TOTALLY OR  PARTIALLY
                    EXCLUDED  FROM  PRETREATMENT  REGULATION
                                                            CATEGORY/SUBCATEGORY AFFECTED
             Industrial Category as  listed in        PARAGRAPH 8 EXCLUSION       PROJECT DEFERRED
            the EGD / NRDC Settlement Agreement        Total      Partial        Total      Partial
            Adhesive and Sealants
            Aluminum Forming
            Auto and Other Laundries
            Battery Mfg.	
            Carbon Black	
            Coal Mining	
            Coil Coating	
 468         Copper Forming
            Electrical and Electronic Products
            Electroplating	
 457        Explosives Mfg.
             Foundry
            _Gum and Hood Chemicals
             Ink Formulation
 415         Inorganic Chemicals
             Iron and Steel Mfg.
            Leather Tanning and  Finishing
            Mechanical Products   	
_433        2Metal Finishing
 421         Honferrous Metals Manufacturing
 471         Nonferrous Metals Forming	
 440         Ore Mining and Dressing	
 414         Organic Chemicals	
 446         Paint Formulation
_443         Paving and Roofing  Materials	
 455         Pesticides	
 419         Petroleum Refining	
 439         Pharmaceutical Mfg.	
 459         Photographic Equipment  and Supplies
 416         Plastics and Synthetics	
 463         Plastics Molding and  Forming
 466         Porcelain Enameling	
 448         Printing and Publishing	
 430         Pulp, Paper, and Faperboard
 428         Rubber Mfg.	
 470         Shipbuilding
 417         Soap and Detergent Mfg.
 423         Steam  Electric Powerplants
 410         Textile       	
 429         Timber
^he organic Chemicals and the Plastics and  Synthetics Categories  have been combined
   for BAT ruleraaking under the Organic/Plastic Category.
^The Electroplating  and the Mechanical Products Categories have been  combined for BAT
   ruleraaking under  the Metal Finishing Category.
Source:  This table  is an update of the July 1981 Summary of paragraph 8  Exclusions prepared by the Office of Quality
         the Effluent Guidelines Division, Office of Water Regulations and Standards, Office o£ Water, EPA..  It was at
         memorandum  from Jeffrey Denit, dated August 18, 1981.  This  information is subject to change.
                                                 C-8

-------
                        TABLE C.3
REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES
        Industry Category
                                                     SIC Code
                                     2891
       Adhesives and Sealants

       Aluminum Forming
         Rolling with Emulsions
         Rolling with Neat Oils
         Extrusion
         Drawing with Neat Oils
         Forging
         Drawing with Emulsions or Soaps

       Coal Mining

         Coal Preparation
         Acid/Ferrugenous Mine Drainage
         Alkaline Mine Drainage
         Areas under Reclamation
         Western Coal Mines
       Coil Coating

       • Steel Basis Material Coating
       • Galvanized Basis Material Coating
       • Aluminum Basis Material Coating

       Copper Forming

         Hot Rolling
         Cold Rolling
         Extrusion
         Drawing
         Pickling
         Alkaline Cleaning
         Forging
         Copper Foil Production

       Electroplating (Metal Finishing)

         Electroplating of Common Metals
         Electroplating of Precious Metals
         Electroplating of Speciality Metals
         Anodizing
         Coatings
         Chemical Etching & Milling
         Electroless Plating
         Printed Circuit Board
         Chemical Matching
         Immersion Plating
         Pickling
         Bright Dipping
         Alkaline Cleaning

Source:  Summarized from (1) "Summary of Paragraph 8 Exclusions," EGD, OWRS,
         EPA, July, 1981; (2) Standard Industrial Classification Manual,
         Executive Office of the President, Office of Management and Budget,
         1972.
                                 C-9
                                     3353, 3355
                                     3353, 3355
                                     3354
                                     3353, 3355
                                     3463
                                     3353, 3355
                                     1111, 1112, 1211, 1213
                                     1111, 1112, 1211, 1213
                                     1111, 1112, 1211, 1213
                                     1111, 1112, 1211, 1213
                                     1211, 1213
                                     3479
                                     3479
                                     3479
                                     3351
                                     3351
                                     3351
                                     3351
                                     3351
                                     3351
                                     3351
                                     3497, 3351

                                     3471 & 3479

                                     (Some industries within
                                     these subcategories may
                                     not be subject to regu-
                                     lations)

-------
                    TABLE C.3   (Continued)

  REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES
          Industry Category
       SIC Code
Foundries
  Iron and Steel
  Copper
  Aluminum
  Zinc
  Lead
  Magnesium

Inorganic Chemicals

  Chlorine & Na or K Hydroxide
  Hydrofluoric Acid Production
  Na Dichromate & Sulfate Production
  Titanium Dioxide
  Aluminum Fluoride Production
  Chrome Pigment
  Copper Sulfate Production
  Hydrogen Cyanide Production
  Nickel Sulfate Production
  Sodium Bisulfite Production
  Sodium Silicofluoride Production

Iron and Steel Manufacturing
(BAT subcategorization scheme)
  Cokemaking
  Sintering
  Ironmaking
  Steelmaking
  Vacuum Degassing
  Continuous Casting
  Hot Forming
  Scale Removal
  Acid Pickling
  Cold Forming
  Alkaline Cleaning
  Hot Coating
Leather Tanning and Finishing
• Hair Pulp Unhairing with Chrome
     Tanning and Finishing
• Hair Save Unhairing with Chrome
     Tanning or Finishing
• Unhairing with Vegetable or
     Alum. Tanning and Finishing
• Finishing of Tanned Hides
• Vegetable or Chrome Tanning of
     Unhaired Hides
• Unhairing with Chrome Tanning and
     No Finishing
• Shearing
3322, 3324, 3325
3362
3361
3369
3369
3369
2812
2819
2819
2816
2819
2816
2819
2819
2819
2819
2819
3312
3312
3312
3312
3312
3312
3312, 3315, 33171
3312, 3315, 33171
3312, 3315, 33171
3316
3312, 3315, 3316, 33171
3312, 3315, 33171
3111

3111

3111
3111

3111

3111
3111
                            C-10

-------
                    TABLE C.3  (Continued)

  REGULATED INDUSTRIES SUBCATEGORIES WITH ASSOCIATED SIC CODES
          Industry Category
       SIC Code
Metal Finishing/Mechanical Products
Nonferrous Metals Manufacturing

  Bauxite Refining
  Primary Aluminum Smelting
  Secondary Aluminum Smelting
  Primary Copper Smelting
  Primary Copper Refining
  Secondary Copper
  Primary Lead
  Primary Zinc
  Metallurgical Acid Plants
  Primary Columbium Tantalum
  Secondary Silver - Photographic
  Secondary Silver - Nonphotographic
  Primary Tungsten
  Secondary Lead

Ore Mining and Dressing

• Base and Precious Metals
     (Cu, Pb, Zn, Ag, Au, Pt, Mo)
• Ferroalloy Ores
• Uranium, Radium, Vanadium Ores
• Tungsten Ore
• Nickel Ores
• Vanadium Ore (non-radioactive)
• Antimony Ore

Organic Chemicals, Plastics and
   Synthetic Materials

• Processes with Process Water,
     Contact as Steam Diluent
     Quench or Vent Gas Absorbent

Pesticides Chemicals

• Organic Pesticide Mfg.
• Metallo-Organic Pesticides
• Pesticide Chemicals Formulating

Petroleum Refining
  Topping
  Cracking
  Petrochemicals
  Lube
  Integrated
Large number of subcate-
gories including:  3411-29;
3432-66; 3482-3599; 3613-
23; 3629-39
2819
3334
3341
3331
3331
3341
3332
3333
3331, 3332, 3333
3339
3341
3341
3339
3341
1021, 1031, 1041, 1044,
1061
1061
1094
1061
1061
1094
1099

2865, 2869
2869, 28792
2869, 2879
2869, 2879
2911
2911
2911
2911
2911
                            C-ll

-------
                    TABLE C.3   (Continued)

  REGULATED INDUSTRIES SUBCATEGORIES WITH ASSOCIATED SIC CODES
          Industry Category
       SIC Code
Pharmaceutical Manufacturing
  Fermentation Products
  Extractions
  Chemical Synthesis Products
  Mixing/Compounding - Formulation
  Research

Plastics and Synthetics (Organic
   Chemicals, Plastics, Synthetic
   Materials)
  Polyvinyl Chloride
  Polyvinyl Acetate
  Polystyrene
  Polypropylene
  Polyethylene
  Cellophane
  Rayon
  ABS and SAN Resin - Copolymers
  Polyester
  Nylon 6
  Cellulose Acetate
  Acrylics
  Ethylene - Vinyl Acetate
  Polytetrafluoroethylene
  Polypropylene Fiber
2833, 2831
2831, 2833
2833
2834
2831, 2833, 2834
2821
2821
2821
2821
2821
2821
2823
2821
2821
2821
2823
2821
2821
2821
2823
  Alkyds & Unsaturated Polyester Resins 2821
  Cellulose Nitrate                    2821
  Polyamide (Nylon 6/12)               2821
  Polyester Resins (Thermoplastics)    2821
  Silicones                            2821
Porcelain Enameling
• Steel

• Cast Iron
• Aluminum
• Copper


Pulp, Paper and Paperboard

• Unbleached Kraft
• Sodium Based neutral Sulfite
     Semi-Chemicals
• Ammonia Based Neutral Sulfite
     Semi-Chemical
• Unbleached Kraft-Neutral Sulfite
     Semi-Chemical
• Paperboard from Wastepaper
• Dissolving Kraft
3631, 3632, 3633, 3639,
   3469, 3479, 3431
Mainly 3631, 3431
Mainly 3469, 3479, 3631
Mainly 3479, Limited use
   in 3469 and 3631
2611

2611

2611

2611
2631
2611
                             C-12

-------
                    TABLEC. 3   (Continued)
  REGULATED INDUSTRIAL SUBCATEGORIES WITH ASSOCIATED SIC CODES


          Industry Category	SIC Code	
Pulp, Paper and Paperboard (Continued)

  Market Bleached Kraft                2611
  OCT Bleached Kraft                   2611
  Fine Bleached Kraft                  2611
  Papergrade Sulfite                   2611, 2621
  Dissolving Sulfite Pulp              2611
  Groundwood - Thermo - Mechanical     2611, 2621
  Groundwood - CMN Papers              2611, 2621
  Groundwood - Fine Papers             2611, 2621
  Soda                                 2611, 2621
  Unbleached Kraft & Semi-Chemical     2611
  Semi-Chemical                        2611
  Wastepaper - Molded Products         2646
  Nonintegrated - Lightweight Paper    2621
  Nonintegrated - Filter and Nonwoven
     Pa'pers                            2621
  Nonintegrated - Paperboard           2631
  Deink                                2611, 2621
  Nonintegrated Fine Paper             2621
  Nonintegrated Tissue Papers          2631
  Tissue from Wastepaper               2647
  Papergrade Sulfite (Drum Wash)       2611, 2621

Steam Electric Power Generating
• Generating Unit                      4911, 4931
• Small Unit                           4911, 4931
• Old Unit                             4911, 4931
• Area Runoff                          4911, 4931

Textile Industry

  Wool Scouring                        2299
  Wool Finishing                       2231
  Woven Fabric Finishing               2261, 2262, 2269
  Knit Fabric Finishing                2251-59
  Carpet Mills                         2271, 2272, 2279
  Stock and Yarn Dyeing & Finishing    2269
  Nonwoven Manufacturing               2297
  Felted Fabric Processing             2291

Timber Products
• Wood Preserving - Boultonizing       2491
• Wood Fuming and Fixtures  (with      2511, 2512, 2517, 2521
     and Without Water Wash Spray         2531, 2541
     Booths or Laundry Facilities)
*Mainly Zero Dischargers
2Low Flow or Zero Discharge
                            C-13

-------
                TABLE C.4




DETECTION LEVELS FOR PRIORITY POLLUTANTS
Detection
PRIORITY POLLUTANT3 Level (ug/L)
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
acenaphthene
acrolein
acrylonitrile
benzene
benzidine
carbon tetrachloride
chlorobenzene
1 ,2 ,4-trichlorobenzene
hexachlorobenzene
1 ,2-dichloroethane
1 ,1 ,1-trichloroethane
hexachloroethane
1 ,1-dichloroethane
1 ,1 ,2-trichloroethane
1 , 1 ,2 ,2-tetrachloroethane
chloroe thane
bis (2-chloroethyl) ether
2-chloroethyl vinyl ether (mixed)
2-chloronaphthalene
2 ,4 ,6-trichlorophenol
parachlorometa cresol
chloroform ( trichloromethane)
2-chlorophenol
1 ,2-dichlorobenzene
1 ,3-dichlorobenzene
1 ,4-dichlorobenzene
3 ,3-dichlorobenzidine
1 ,1-dichloroethylene
1 ,2-trans-dichloroethylene
2 ,4-dichlorophenol
1 ,2-dichloropropane
1 ,2-dichloropropylene (trans 1 ,3-dichloropropene)
2 ,4-dimethylphenol
2 ,4-dinitrotoluene
2 ,6-dinitrotoluene
1 , 2- d i pheny 1 hyd r a z ine
ethylbenzene
fluoranthene
4-chlorophenyl phenyl ether
4-bromophenyl phenyl ether
1.8
0.6
0.5
0.2
0.08
0.12
0.25
0.05
0.05
0.03
0.03
1.6
0.07
0.02
0.03
0.52
0.3
0.13
1.9
0.64
0.36
0.05
0.31
0.15
0.32
0.24
0.13
0.13
0.1
0.39
0.04
0.34
0.32
0.02
0.01
b
0.2
0.21
3.9
2.3
EPA
Method
610
603
603
602
605
601
601
612
612
601
601
625
601
601
601
601
611
601
625
604
604
601
604
601
601
601
605
601
601
604
601
601
604
609
609
b
602
610
611
611
                  C-14

-------
DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)
Detection
PRIORITY POLLUTANT3 Level (ug/L)
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
bis (2-chlorisopropyl) ether
bis (2-chloroethoxy) methane
methylene chloride (dichlororaethane)
methyl chloride (chloromethane)
methyl bromide (bromomethane)
bromoform ( tribromomethane)
dichlorobromome thane
chlorodibromome thane
hexachlorobutadiene
hexachlorocyclopentadiene
isophorone
naphthalene
nitrobenzene
nitrophenol
4-nitrophenol
2 ,4-dinitrophenol
4 ,6-dinitro-o-cresol
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-propylamine
pentachlorophenol
phenol
bis (2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
dimethyl phthalate
benzo (a) anthracene (1 ,2-benzanthracene)
benzo (a) pyrene (3 ,4-benzopyrene)
3 ,4-benzof luoranthene
benzo (k) fluoranthane (11, 12-benzof luoranthene)
chrysene
acenaphthylene
anthracene
benzo (ghi) perylene (1, 12-benzoperylene)
fluorene
phenanthrene
dibenzo (a,h) anthracene (1 ,2 ,5 ,6-dibenzanthracene)
indeno (1,2,3-cd) pyrene (2 ,3-o-phenylenepyrene)
pyrene
tetrachloroethylene
0.8
0.5
0.25
0.08
1.18
0.2
0.1
b
0.34
-
5.7
1.8
3.6
0.45
2.8
13.0
16.0
0.15
0.81
0.46
7.4
0.14
2.0
0.34
0.36
3.0
0.49
0.29
0.013
0.023
0.018
0.017
0.15
2.3
0.66
0.076
0.21
0.64
0.03
0.043
0.27
0.03
EPA
Method
611
611
601
601
601
601
601
601
612
c
609 FID
610
609 FID
604
604
604
604
607
607
607
604
604
606
606
606
606
606
606
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
610 HPLC
601
                        C-15

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    DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)
PRIORITY POLLUTANT
                  a
 Detection     EPA
Level (ug/L)  Method
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.
toluene
trichloroethylene
vinyl chloride (chloroethylene)
aldrin
dieldrin
chlordane (technical mixture & metabolites)
4, 4 '-DDT
4, 4 '-DDE (p, p'-DDX)
4, 4'-DDD (p, p'-TDE)
Alpha-endosulfan
Beta-endosulf an
endosulfan sulfate
endrin
endrin aldehyde
heptachlor
heptachlor epoxide
Alpha-BHC
Beta-BHC
Gamma-BBC (lindane)
Delta-BHC
PCB-1242 (Arochlor 1242)
PCB-1254 (Arochlor 1254)
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB-1248 (Arochlor 1248)
PCB-1260 (Arochlor 1260)
PCB-1016 (Arochlor 1016)
toxaphene
antimony (total)
arsenic (total)
asbestos (fibrous)
beryllium (total)
cadmium (total)
chromium (total)
copper (total)
cyanide (total)
lead (total)
mercury (total)
nickel (total)
selenium (total)
silver (total)
0.2
0.12
0.18
0.004
0.002
0.014
0.012
0.004
0.011
0.014
0.004
0.066
0.006
0.023
0.003
0.083
0.003
0.006
0.004
0.009
0.065
b
b
b
b
b
b
0.24
10
10
b
1
1
5
1
20
10
0.2
10
5
1
602
601
601
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
608
FUR6
FUR

FLAMEf
FUR
FUR
FUR
DIST8
FUR,
cv11
FUR
FUR
FUR
                            C-16

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             DETECTION LEVELS FOR PRIORITY POLLUTANTS (Continued)

                                                      Detection     EPA
         PRIORITY POLLUTANT3                         Level (ug/L)  Method
124.  thallium (total)                                    10         FUR
125.  zinc (total)                                         1         FUR
126.  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)           0.003
      This numbering does not correspond with numbers on EPA's list of pri-
      ority pollutants.

      No detection limit determined.
*%
      Flame ionization detection (FID).

      High pressure liquid chromatography (HPLC).

6     Furnace (FUR).

f     Flame (FLAME).
g     Distillation (DIST).

      Cold vapor (CV).

Source:  "Methods for Organic Chemical Analysis of Municipal and Industrial
         Wastewater," Environmental Monitoring and Support Laboratory,
         Cincinnati, OH  45268.  EPA-600/4-82-057.  July 1982.

         Table C.4 lists the analytical methods and appropriate detection
         limits for the EPA priority pollutants.  The information contained in
         "Methods for Organic Chemical Analysis of Municipal and Industrial
         Wastewater" represents an effort to provide procedures that are as
         uniform and cost effective as practical for a wide cross-section of
         chemical compound classes.  Due to the variable chemical and physical
         properties of the parameters, some compromises had to be made.
         Therefore, in some of the methods, the extraction procedures, cleanup
         procedures and determinative steps are not optimum for all param-
         eters.
                                     C-17

                                    U . S .  GOVERNMENT PRINTING OFFICEi  1983-421-545/3078

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