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
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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
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'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).
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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
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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
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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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