United States Environmental Protection Agency Environmental Monitoring and Suppoj Laboratory Cincinnati OH 45268 "TatX/1' Research and Development EPA-600/S4-81-033 July 1981 Project Summary Waste Discharge Monitoring Requirements Under the NPDES Permits Program Susan R. Moore and Terry C. Covert This study was conducted by Systems Research Company (SRC) to provide a means or "tool" to aid the Equivalency Staff of the Environ- mental Monitoring and Support Laboratory - Cincinnati (EMSL- Cincinnati) in evaluating and specifying comparability data requirements of applications submitted for the approval of alternate analytical methods under the "National Pollutant Discharge Elimination System" (NPDES) permits program. Based upon SRC's examination of "Effluent Guidelines and Standards" and NPDES permits, six tables were developed to provide information of the parameters most critical to the NPDES permits program', the type of discharge, and the parameters to be monitored, and the number of dischargers required to monitor specific parameters. The final report was submitted in fulfillment of contract number 68-03-2750 by SRC, Philadelphia, Pennsylvania, under the sponsorship of the U.S. Environmental Protection Agency (USEPA). Work was completed as of July 11, 1980. This Project Summary was developed by EPA's Environmental Monitoring and Support Laboratory. Cincinnati. OH. to announce key findings of the research project that is fully documented in a separate report of the same title (see Project Report ordering information at back). Introduction Under 40 CFR Amendments 136, published in the Federal Register, December 1, 1976, entitled, "Guidelines Establishing Test Procedures for the Analysis of Pollutants," the EMSL-Cincinnati Equivalency Program is responsible for developing a system for evaluating the equivalency of alternate analytical procedures proposed for both limited and nationwide use under the NPDES permits program. The current system for evaluating limited use applications from single NPDES permit holders includes the selection of random samples from each NPDES regulated outfall and the analysis of each sample by both an approved method and the proposed alternate method. Concurrently, the present equivalency program for NPDES nationwide approval of alternate test methods is based on comparability data obtained on representative samples from various industrial categories, identified by "Standard Industrial Classification" (SIC) codes, most significant to the NPDES program. Unfortunately, the listing of NPDES parameters versus major discharger SIC codes was incomplete. Accordingly, the EMSL- Cincinnati Equivalency Program awarded a contract to SRC to update and complete this listing. To produce this listing and the additional tabulations as found in this report, a two ------- Table 1. SIC Codes and Related Effluent Guidelines SIC Code Related Effluent Guidelines Subpart No. Total National Permits 2033 407A, 407B, 407C, 4O7F, 407G, 407H 2034 407C, 407E, 407F, 407G 2035 4O7F, 407G, 407H 2037 407'A, 407B, 407C, 407D, 407F. 407G 2038 407H 45 7 21 3 Table 2. Analytical Parameters for Required Testing for BPT and BA T for Each Point Source Regulation Subpart. Subpart No. SIC Code BPT BAT Subpart Description 405A 405B 405C 405D 405E 5143 2026 2026 2021 2022, 2026 10,22.106 10,22,106 10,22, 106 10,22.106 1O,22, T06 10,22, 106 10,22,106 •10.22.106 10,22. 106 10,22, 106 Dairy Products Processing Industry, Receiving Stations Dairy Products Processing Industry, Fluid Products Dairy Products Processing Industry, Cultured Products Dairy Products Processing Industry, Butter Dairy Products Processing Industry, Cottage Cheese and Cultured Cream Cheese phase effort was undertaken. The first phase, which consists of Tables 1 and 2, was based on analysis of "Effluent Guidelines and Standards" (1) and comparison with the SIC manual (2). The second phase, or Tables 3 through 6, was based on a study of representative samples of NPDES permits. The section, Results, provides information on the contents of each of the tables. Results Regulations promulgated under parts 400-460 of CFR Subchapter N "Effluent Guidelines and Standards," prescribe effluent limitations guidelines for existing sources, standards of performance of new sources, and pretreatment standards for new and existing sources. The SIC codes developed by the Statistical Policy Division of the Office of Management and Budget are used in the classification of establishments by the type of activity in which engaged. Four digit industry codes are assigned to establishments on the basis of primary activity, which is determined by the principal product or group of products produced or distributed, or services rendered. The 1972 edition of the SIC Manual was used for the preparation of this report. SIC (jodes and Related Effluent Guidelines Each point source category regulation subpart found in "Effluent Guidelines and Standards" was examined and the appropriate SIC codes identified by comparison with the SIC Manual. Table 1 includes all SIC codes found in the "Permits Compliance System NPDES Majors and SIC Code Analysis Printout" (3) with the appropriate effluent guidelines subpart numbers, and the total number of NPDES permits issued for each SIC code. Analytical Parameters for Required Testing for Best Practicable Technology (BPT) and Best A vailable Technology (BAT) Table 2 lists the applicable SIC codes, the current analytical parameters required testing for BPT, 1977, BAT, 1983, for each point source category regulation subpart as referenced in the "Effluent Guidelines and Standards." A regulation subpart description is also provided. The parameter numbers listed under BAT and BPT are those as referenced in 40 CFR 136, "Guidelines Establishing Test Procedures for the Analysis of Pollutants." For those ------- 'Table 3. NPDES Permit Analytical Parameters Priority Test Parameter No. Test Parameter Description Total Dischargers 1 2 3 4 5 22 pH 1020 Flow 1008 106 Total suspended residue, nonfilterable 937 10 BODs 609 114 Temperature 554 Table 4. Analytical Test Parameters by Number of Dischargers and SIC Codes (Nationwide) Test Parameter No. Description SIC Codes and Number of Dischargers Total Dischargers 22 Total 1020 4952 (47) 4911 (44) 2911 (18) 2621 (18) 3312 (16) 2869 (15) parameters not found in 40 CFR 136, the name of the parameter is listed. In the preparation of Tables 1 and 2, the cumulative list of CFR sections was examined to determine in which sections of the "Effluent Guidelines and Standards" changes have appeared through July 31, 1979. As a result, any necessary changes were made in the tables. Tables 3 through 6 were prepared from data collected from a representative sample of 1051 NPDES permits. Since it would not be feasible to examine every permit written, each USEPA regional office was requested to select and provide copies of 10% of the permits for each SIC code found in the National Majors Listing for each particular region. Because discrepan- cies exist relative to what constitutes a major discharger, major dischargers were those identified on the "National Majors Listing." The parameters included those listed in 40 CFR 136 as well as additional ones which required monitoring. If a permit listed a (parameter with effluent limitations, but no monitoring requirements, the parameter was not included for that particular permit and, therefore, was not included in the study. In general, the 40 CFR 400-460 subparts list effluent limitations, not monitoring requirements. The vast majority of the NPDES permits examined listed both monitoring requirements and effluent limitations for each outfall. In some instances, monitoring of intake water, treatment plant intake or receiving waters was required in the permit. These parameters were also included in the study. NPDES Permit Analytical Test Parameters Table 3 lists the analytical parameters by parameter number as found in 40 CFR 136 in descending order by the total number of major dischargers for each parameter. The listing also contains those test parameters written in permits not listed in 40 CFR 136. A total of 233 parameters, including the 115 numbered parameters was found in the sample of 1031 permits. Analytical Test Parameters by Number of Dischargers and SIC Codes Tables 4 and 5 list each parameter in descending order of total dischargers, all SIC codes performing the analyses, and the total number of major dischargers in each SIC code. These two tables are based on the sample of 1051 NPDES permits. Table 4 presents these relationships on a nationwide basis and Table 5 on a regional basis. S/C Codes with the Largest Number of Permits for Each Analytical Test Parameter Table 6 lists five SIC codes containing the largest number of nationwide permits for each analytical test parameter as referenced in 40 CFR 136. A description is also provided for each of the SIC codes as referenced in SIC Manual, 1972. Where fewer than five SIC codes can be specified for each parameter, no other SIC codes contained dischargers required to monitor that particular parameter. Examples of each of the tables follow. Conclusions As a result of this study, the Equiv- alency Program has a complete listing which provides information on the parameters most critical to the NPDES permits program. Data supporting the comparability of an alternate method would include analyses of a specified number of samples taken from each of the most applicable waste types or standard industrial classification code. References 1. "Effluent Guidelines and Standards." 40 CFR 400-460, Office of the Federal Register, General Services Administration, Washington, D.C., 1977. pp. 1 -762. 2. Standard Industrial Classification Manual. Office of Management and Budget, Washington, D.C. 1972. p. 649. 3. Permit Compliance System, NPDES Majors SIC Code Analysis. EPA, 1978 (Computer printout). ------- Table 5. Analytical Test Parameters by Number of Dischargers and SIC Codes (Regional} Region I Test Parameter No. Description SIC Codes and Total Number of Dischargers Dischargers 87 Zinc. Dissolved Total 3914 (1) 3613 (1) 3471 (1) 88 Nitrate as N Total 7215 (1) 3699 (1) 3674 (1) 1 1 1 Sulfide Total 3964 11) 2269 (1) 2253 (1) 25 Aluminum, Dissolved Total 3961 (1) 3613 (1) 37 Cadmium, Dissolved Total 3613 ft) 3471 (1) 3 3 3 2 2 Table 6. SIC Codes with the Largest Number of Permits for Each Analytical Test Parameter Test Parameter No. Description 1 Acidity as CACO3 2 Alkalinity as CAC03 Ammonia as N SIC Codes SIC Code Description 1211 Bituminous Coal 1211 Bituminous Coal 4952 Sewerage Systems 4911 Electric Services 2865 Cyclic (Coal Tar) Crudes, and Cyclic Intermediates, Dyes and Organic Pigments (Lakes and Toners) 2813 Industrial Gases 2911 Petroleum Refining 4952 Sewerage Systems 3312 Blast Furnaces (Including Coke Ovens), Steel Works, and Rolling Mills 2819 Industrial Inorganic Chemicals, not elsewhere Classified 2869 Industrial Organic Chemicals, not elsewhere Classified ------- This Project Summary was authored by Susan R. Moore of Systems Research Company, Philadelphia, PA 19104 and Terry C. Covert, who is also the EPA Project Officer (see below). The complete report, entitled "Waste Discharge Monitoring Requirements Under the NPDES Permits Program,"(Order No. PBS 1-196941; Cost: $35.00, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Environmental Monitoring and Support Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 * US GOVERNMENT PRINTING OFFICE. 1W1-757-01Z/7198 ------- United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 Postage and Fees Paid Environmental Protection Agency EPA 335 Official Business Penalty for Private Use $300 PS 0000329 U S ENVIR PROTECTION AGENCY REGION 5 LIBRARY 230 S DEARBORN STREET CHICAGO IL 60604 ------- |