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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