&EPA
          United States
          Environmental Protection
          Agency
            Risk Reduction Engineering
            Laboratory
            Cincinnati, OH 45268
EPA/600/2-88/062
Apr. 1989
          Research and Development
Toxicity Reduction
Evaluation Protocol for
Municipal Wastewater
Treatment Plants

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                                                    EPA/600/2-88/062
                                                          April 1989
        Toxtcity Reduction  Evaluation  Protocol
                           for  Municipal
               Wastewater Treatment Plants
                                   by

                               John A. Botts
                            Jonathan W. Braswell
                                Jaya Zyman
                           Engineering-Science, Inc.
                            Fairfax, Virginia 22030
                            William L. Goodfellow
                     EA Engineering, Science and Technology
                           Sparks, Maryland 21152
                              Samuel B. Moore
                           Burlington Research, Inc.
                         Burlington, North Carolina 27215

                          Contract No. 68-03-3431
                               Project Officer

                              Dolloff F. Bishop
                         Treatment Assessment Branch
                      Risk Reduction Engineering Laboratory
                            Cincinnati, Ohio 45268
•
RISK REDUCTION ENGINEERING LABORATORY
 OFFICE OF RESEARCH AND DEVELOPMENT
 U.S. ENVIRONMENTAL PROTECTION AGENCY
         CINCINNATI, OHIO 45268

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                                 Disclaimer
This material  has  been funded wholly or in part  by the United States  Environmental
Protection Agency under contract  68-03-3431  to  Engineering-Science,  Inc. It  has
been subject  to the Agency's  review and it has been approved for  publication as an
EPA document. Mention of trade names or commercial products  does  not constitute
endorsement or recommendation.

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                                  Foreword
Today's  rapidly  developing  and changing  technologies  and industrial  products  and
practices  frequently  carry with them the increased generation of materials  that, if
improperly dealt with, can threaten both public health and the environment. The U.S.
Environmental Protection Agency is charged by Congress with protecting the nation's
land,  air,  and water  resources. Under a mandate of national environmental laws,  the
agency strives to formulate  and implement actions  leading to  a compatible balance
between human activities and the ability of natural systems to support  and nurture life.
These laws direct the EPA to perform research to define our environmental problems,
measure the impacts, and search for solutions.

The Risk  Reduction Engineering Laboratory  is responsible for planning,  implementing,
and  managing research, development,  and demonstration  programs to  provide  an
authoritative,  defensible engineering  basis in support of the  policies, programs,  and
regulations of the  EPA with  respect to drinking water, wastewater, pesticides,  toxic
substances,  solid  and  hazardous  wastes, and Superfund-related  activities.  This
publication is one of  the products of that research and  provides a vital communication
link between the researcher and the user community.

This  guidance document  on  municipal  toxicity  reduction  evaluations (TRE)  was
prepared  to  provide  technical support for water quality-based toxicity control in the
National Pollution  Discharge  Elimination System (NPDES). It was designed  to provide
guidance for  conducting TRE assessments  at  municipal wastewater treatment plants.
This guidance document describes the state-of-the-art procedures and the general
decision-making process for conducting municipal  TREs.
                                                      E. Timothy Oppelt,  Director
                                            Risk Reduction Engineering Laboratory
                                       in

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                                   Abstract
This document  presents  a generalized  protocol for conducting Toxicity  Reduction
Evaluations (TREs) at municipal wastewater treatment plants (WWTPs). This protocol
is designed to provide guidance to municipalities in preparing TRE plans, evaluating the
information generated during TREs, and developing  a technical basis for the selection
and implementation of toxicity control methods. A TRE  involves an evaluation of the
municipal WWTP  performance; an  identification of the  specific  toxicants  causing
effluent  toxicity;  a review  of the  pretreatment  and  local  limits programs;  a
characterization  of the nature,  variability  and sources of toxicity; and the evaluation,
selection and implementation of the toxicity control options.

Because of the  broad scope of this  protocol, it is to be expected that site specific
considerations may to some extent warrant modifications and tailoring of the protocol
approach for a  given  facility.  The protocol has  been  developed based on  current
research and experience.  TRE methods  and procedures will be updated and refined
based on the results of ongoing research and case studies.
                                       IV

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                                    Contents
                                                                            Page

Foreword   	,	   iii
Abstract	   iv.
Figures	 .   jx
Tables  	;	 .   x
Abbreviations and Symbols	   xi
Acknowledgements	,	   xiii

  1.   Introduction	  1-1
          Background	  1-1
          TRE Definition and Objectives  . .	 .	M-1-
          Components of the Municipal TRE Protocol	  1-2.
            Information and Data Acquisition	  1-2
            POTW Performance Evaluation   :	  1-2
            Toxicity Identification Evaluations  	  1-2
            Toxicity Source Evaluation (Tier I)  	  1-2
            Toxicity Source Evaluation (Tier II)  	  1-2
            POTW In-Plant Control Evaluation  	  1-2
            Toxicity Control Selection   	  1-4
            Toxicity Control Implementation   	  1-4
          Limitations of the Protocol  	  1-4
          Organization of the Document  	  1-4

  2.   Information and Data Acquisition   	  2-1
          Introduction   	  2-1
          POTW Design and Operations Data  	  2-1
          Pretreatment Program Data 	  2-1

  3.   POTW Performance Evaluation   	  3-1
          Introduction   	  3-1
          Operations and Performance Review  	  3-1
            Primary Sedimentation  	  3-1
            Aerobic Biological Treatment  	  3-1
            Organic Loading  	  3-3
            Oxygen Requirements 	  3-3
            Mean Cell Residence  Time   	  3-3
            Secondary Clarification  	  3-3
            Process Sidestreams  and Wastewater Bypasses  	  3-4
            Disinfection  	  3-4
          Optional TIE Phase I Tests  	  3-4
          Conventional Wastewater Treatability Testing   	  3-5
            Coagulation and Precipitation  	  3-6
            Sedimentation   	  3-6

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                          Contents (continued)
                                                                       Page

           Activated Sludge	   3-6
           Granular Media Filtration	 . .	   3-6
           Activated Carbon Adsorption	   3-6

4.    Toxicity Identification Evaluation	   4-1
       Introduction		   4-1
       Toxicity Test Procedures	   4-1
       Toxicity Characterization and Toxicant
         Identification  Procedures  	   4-2
           Phase I - Toxicity Characterization	   4-3
           Phase II -  Causative Toxicant Identification    ...... I........   4-3
           Phase III - Causative Toxicant Confirmation    . .	   4-3

5.    Toxicity Source Evaluation - Tier I   	   5-1
       Introduction	  .   5-1
       Sampling Location		   5-1
       Chemical-Specific Investigation	 . .	   5-2
         Pretreatment Program Review  	   5-3
       Refractory Toxicity Assessment	   5-3
         Biomass Toxicity  Measurement	   5-4
         Sample Collection	   5-6
         Sample Characterization and Preparation  	   5-6
         Preparation of Batch Test Mixtures	  .   5-7
         Performance of Batch Tests  	   5-7
         Toxicity Measurement	   5-8
         Data Evaluation	   5-8
         RTA Conclusions  	   5-9

6.    Toxicity Source Evaluation - Tier II	   6-1
       Introduction  	   6-1
       Refractory Toxicity Assessment  	   6-1
         Biomass Toxicity  Measurement  	   6-1
         Sample Collection, Characterization, and Preparation  	   6-1
         Preparation of Batch Test Mixtures	   6-1
         Performance of Batch Tests  	   6-2
         Inhibition Testing  (Optional)   	   6-4
         Toxicity Analysis  	   6-5
         Phase I - Toxicity Characterization    	   6-5
         Data Evaluation  	   6-5
       Pretreatment Control Evaluation	   6-7

7.    POTW In-Plant Control Evaluation	   7-1
       Introduction	   7-1
       Selection of Treatment Options for Testing	  .   7-1
                                     VI

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                          Contents (continued)
                                                                      Page
       Process Enhancement	   7-2
         Biological Process Control	   7-2
         Chemical Addition  	.:..............	   7-2
       Additional Treatment  	   7.3
         Equalization	   7-3
         Instrumentation/Control   . . .	   7-4
         Advance Wastewater Treatment	 .   7-4
       Treatability  Testing	   7.4
         Activated Sludge	   7-4
         Coagulation/Flocculation	   7.4
         Sedimentation		   7-4
         Granular Media Filtration	   7-4
         Granular Activated Carbon  	   7.4

8.    Toxicity Control Selection	   g - 1
       Introduction	   8-1
       Evaluation of Control Options	   8-1

9.    Toxicity Control Implementation	   9-1
       Implementation  	: . . .	   9-1
       Follow Up Monitoring	   9-1

10.    Quality Assurance/Quality Control	   10-1
       Introduction   	   10-1
       Sampling Collection and Preservation	   10-1
       Chain-of-Custody     .	   10-1
       Analytical QA/QC  	   10-2
         Toxicity Identification Evaluation   	   10-2
       ,  Refractory Toxicity Assessment and Treatability
           Tests	   10-3
         Chemical Analyses	   10-3
       Equipment Maintenance	   10-3
       Documentation and Reporting of Data	   10-4
       Corrective Action	 .	   10-4

11.    Healtb and Safety	   1 1 -1
       Ove|//ew  	   11-1
       Sample Collection and Handling  .	   11-1
       Analytical Methods	   11-1
         Toxicity Identification Procedures (TIE)   .......:	   11-1
         Refractory Toxicity Assessment and Treatability
           Tests	;	   11-2
         Chemical Analyses	   1 1 - 2
       GerieraX Precautions	 .   1 1 - 2
                                    VII

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                          Contents (continued)
12.
13.
Facilities and Equipment  	
  Introduction   	
   Toxicity Identification Evaluations   	
   Refractory Toxicity Assessment and Treatability
      Tests  	
   General Analytical Laboratory Equipment
Sample Collection and Handling
  Introduction   	
  Sampling Location	
  POTW Sampling  	
  Sewer Discharge Sampling   ,
Page

1 2-1
1 2-1
12-1

1 2-1
1 2-2

13-1
1 3-1
1 3-1
1 3-1
1 3-2
References	   14-1
Bibliography	   15-1
Appendices
      A.  Case Histories  	   A - 1
      B.  Pretreatment Program Review	   B - 1
                                    VIII

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                                    Figures
Number

   1-1


   3-1

   4-1

   5-1

   6-1


   7-1
                                                             Page
TRE Flow Diagram for Municipal Wastewater Treatment
  Plant  	   1-3

Plant Performance Evaluation 	   3-2

Toxicity Identification Evaluation  	   4-2

Tier  I:  Toxicity Source Evaluation 	   5-2

Tier  II:  Toxicity Source Evaluation (Source Ranking/
  Pretreatment Evaluation)  	   6-2

POTW In-Plant Control Evaluation	   7-1
                                        IX

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                                   Tables
Number                                                                 Page

  2-1        POTW Design and Operations Data	   2-2

  2-2        Pretreatment Program Data  	   2-3

  5-1        Tier I - Refractory Toxicity Assessment  	   5-5

  5-2         Synthetic Wastewater Composition	   5-7

  6-1        Tier II - Refractory Toxicity Assessment  	   6-3

  7-1        POTW In-Plant Control Technologies for Categories
               of Toxic Compounds  	'. .	   7-3

  8-1        Comparison of Selection Criteria  for Toxicity
               Control Operations  	   8-2

  B-1        PPR Data Sheet  	   B-2

  B-2        Data Sheet for Regression Analysis   	   B-3

  B-3        Summary of the PPR Chemical Optimization Procedure  	   B-4

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                       Abbreviations and Symbols
AA
ASTM
ATP
BOD
BOD5
C. dubia
CERCLA

CFR
COG
COD
Cr
CSO
Cu
DMR
DO
EC50
EDTA
EP
EPA
F/M
g/i
GAG
GC
H&S
HNO3
HPLC
ICP
IU
IWS
LC50

MCRT
mg/l
MLSS
• Atomic absorption
• American Society for Testing and Materials
• Adenosine triphosphate
• Biochemical oxygen demand
 5-day biochemical oxygen demand
 Ceriodaphnia dubia
 Comprehensive Environmental Response,  Compensation
   and Liability Act
 Code of Federal Register
 Chain-of-Custody
 Chemical oxygen demand
 Chromium
 Combined sewer overflow
 Copper
 Discharge monitoring report
 Dissolved oxygen
 Effective concentration causing a 50% effect in the test species
 Chelating agent
 Extraction procedure
 Environmental Protection Agency
 Food to microorganism ratio                               ;
 Grams per liter
 Granular activated carbon
 Gas chromatography
 Health and Safety
 Nitric acid
 High pressure liquid  chromatography
 Inductively coupled plasma spectrometry
 Industrial user
 Industrial waste survey
 Lethal concentration causing a 50% mortality in exposed test
  organisms
 Mean cell residence time
 Milligrams per liter
 Mixed liquor suspended solids
                                     XI

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                 Abbreviations and Symbols (continued)
MLVSS
MS
MSDS
NPDES
02
OSHA
OUR
PAC
PACT
pH

POTW
PPE
PPR
QA/QC
RAS
RBC
RCRA
RTA
SARA
SBOD5
SCOD
SIC
SOR
SOUR
SPE
SRT
SS
SSUR
TBTO
TCIP
TCLP
IDS
TIE
TKN
TP
TRC
TRE
TSDF
TSS
TTO
WWTP
xg
Zn
ZSV
- Mixed liquor volatile suspended solids
- Mass spectrometry
- Material safety data sheet
- National Pollutant Discharge Elimination System
- Oxygen
- Occupational Safety and Health Administration
- Oxygen uptake rate
- Powdered activated carbon
- Powdered activated carbon treatment
- Negative logarithm of hydrogen ion concentration or hydrogen
    potential
- Publicly owned treatment works
- Plant performance evaluation
- Pretreatment program review
- Quality assurance/quality control
- Return activated sludge
- Rotating biological contactor
- Resource Conservation and Recovery Act
- Refractory toxicity assessment
- Superfund Amendments and Reauthorization Act
- Five-day soluble  biochemical oxygen demand
- Soluble chemical  oxygen demand
- Standard industrial code
- Surface overflow rate
- Specific oxygen uptake rate
- Solid phase extraction
- Sludge retention time or sludge age
- Suspended Solids
- Specific substrate utilization rate
- Total brominated toxic organics
- Toxics control implementation plan
- Toxicity characteristic leaching procedure
- Total dissolved solids
- Toxicity identification  evaluation
- Total kjeldahl nitrogen
- Total phosphorus
- Total residual chlorine
- Toxicity reduction evaluation
- Treatment, storage, and disposal facility
- Total suspended solids
- Total toxic organics
- Wastewater treatment plant
- Times gravity
- Zinc
- Zone settling velocity
                                     XII

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p
                                               Acknowledgements
                       The TRE protocol was a cooperative effort by the EPA and three consulting firms:
                   Engineering-Science,  EA Engineering Science and  Technology,  and  Burlington
                   Research.  Individuals  listed  below are gratefully acknowledged  for their  technical
                   assistance.

                   Environmental Protection Agency                                               ;

                   Dolloff Bishop -  Risk Reduction Engineering Laboratory, Cincinnati
                                    (formerly Water Engineering Research Laboratory)
                   John Cannell - Permits Division, Washington, D.C.
                   Linda Anderson-Carnahan - Region IV, Water Management Division, Atlanta
                   Kenneth Dostal  - Risk Reduction Engineering Laboratory, Cincinnati
P
Additional Acknowledgements

Elizabeth C. Sullivan - CH2M Hill, Reston, Virginia
Mick Degraeve and James Fava - Battelle, Columbus Division
                                                         XIII

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                                             Section 1
                                           Introduction
Background

The  Toxicity  Reduction  Evaluation  Protocol  for
Municipal  Wastewater Treatment  Plants provides a
systematic framework  for  conducting  a toxicity
reduction evaluation (TRE) and a description  of  the
available methods and procedures, which experience
to date have shown to be  most useful. This protocol
is designed for use  by  municipal  facilities  [Publicly
Owned  Treatment  Works  (POTW)] which  are
conducting a TRE to meet NPDES whole effluent
toxicity  permit limits.   It  presents  methods  and
procedures that will be useful for:  1) the design  of a
TRE, 2) the development and review of a TRE plan,
3) the evaluation  of the results and data generated
during the TRE, and  4)  the development of a  sound
scientific and engineering basis for the selection and
implementation of  a toxicity control method.

This document supports the  integrated toxics control
strategy using whole  effluent  toxicity  and  pollutant
specific  limits described in previous EPA  guidance,
notably,  the Technical Support Document for  Water
Quality-based  Toxics  Control  (1985a)  and  The
Permit  Writer's  Guide to Water Quality-based
Permitting  for Toxic Pollutants (1987b). It has become
well recognized  that while  POTWs  may  achieve
effluent  limits for conventional  pollutants,  pass-
through of effluent  toxicity,  volatilization,  and
contamination of sewage sludges can still occur.  The
focus of this protocol is on the  reduction of toxicity in
municipal  wastewater treatment plant effluents.  It is
the responsibility of the  POTW to conduct a toxicity
reduction  evaluation  in  order  to  achieve  the TRE
objectives  and meet the  applicable NPDES  permit
limits. The regulatory authority will review the TRE
plan and carefully  monitor the  progress of the TRE,
providing direction as needed.

This  municipal TRE  protocol provides guidance  for
municipalities  and  their  consultants  on  how to
conduct a TRE  at  a  POTW. The methods  and
decision points which comprise a TRE  are described
in the  context of  an  overall generalized  approach.
Because  the  regulatory issues and treatment
operations are  unique for each  POTW,  not  all
elements of this protocol will apply to every case, and
each  municipality will need to develop its own site-
specific TRE  plan. The protocol has been developed
based on  the research and experience to  date. The
methods and procedures described will be updated
and  refined  based on  the  results  of  on-going
research and case studies.
TRE Definitions and Objectives

EPA's Permit Writer's Guide to Water Quality-Based
Permitting for Toxic Pollutants  (1987) defines  a TRE
as  "a step-wise  process which  combines  toxicity
testing and  analysis of the physical  and chemical
characteristics of causative toxicants to zero in on the
toxicants causing effluent toxicity and/or on treatment
methods which will  reduce the  effluent toxicity."
Because a TRE is conducted  in  a tiered  approach,
judgement is required  in  selecting the appropriate
steps for characterizing the  causative toxicants and
for evaluating options for controlling effluent toxicity.

To  support  TRE studies,  EPA  has developed a
guidance  manual  entitled  "Methods  for Aquatic
Toxicity   Identification  Evaluations  (Mount and
Anderson-Carnahan,  (1988a)   which  describes
procedures  for  identifying  the  toxicants  causing
effluent toxicity.  The TIE procedures  are a  basic
component of the municipal TRE protocol and  should
be  carefully  studied  prior  to  their application  in
municipal TREs. In addition EPA  has  developed a
general protocol for conducting  industrial TREs (Fava,
etal., 1988).

The overall objectives to be  achieved in a municipal
TRE are to:

  •  Evaluate the operation and  performance  of the
     POTW  to  identify and  correct  treatment
     deficiencies causing effluent toxicity;

  •  Identify the toxic  compounds  causing effluent
     toxicity;
                                                1-1

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  •  Trace the effluent  toxicants and/or toxicity  to
     their sources; and

  •  Evaluate, select and implement toxicity reduction
     methods  and  technologies  to  control effluent
     toxicity.

Components of the Municipal TRE
Protocol
The overall flowchart for a TRE program  is illustrated
in Rgure 1-1.  A brief description  of each major TRE
component is presented as follows.

Information and Data Acquisition

The  first step in  a  TRE  is the  collection  of  all
information and analytical data pertaining to effluent
toxicity.  This  information  includes  data on  the
operation and performance  of the  POTW  such  as
plant design criteria and discharge monitoring reports,
and  data  from the  POTW's  pretreatment  program
such as industrial waste survey applications and local
limits compliance  reports. The  POTW performance
data are evaluated in the  second stage of the TRE  as
described below. The pretreatment program data are
used  in the latter  stages of the TRE  to  assist  in
tracing the influent sources  of toxicity and/or toxics
which are contributing to the  POTW effluent toxicity.

POTW Performance Evaluation

POTW  operating  and  performance  data  can  be
evaluated  to  indicate  possible in-plant  sources  of
toxicity or operational deficiencies that  may  be
allowing toxicity pass-through. In parallel with  this
evaluation  an  optional toxicity characterization  test
(TIE Phase I) can  be performed  to  indicate the
presence of in-plant toxicants caused  by incomplete
treatment  (e.g.,  ammonia)  or  routine operating
practices (e.g., chlorine). If a treatment deficiency  or
operating  practice  is  causing  effluent  toxicity,
treatability  studies should be  conducted to evaluate
treatment modifications  for  reducing  the toxicity.  If
plant performance  is not a principal  cause  of the
toxicity problem or treatment  options do  not reduce
the toxicity, the TRE proceeds to TIE testing.

Toxicity Identification Evaluations

TIE  procedures utilize aquatic toxicity tests  of the
effluent following  bench top treatment  steps  to
characterize the classes of toxicants causing effluent
toxicity.  Subsequent  effluent  manipulations  in
conjunction with  chemical   analyses are  used  to
identify and   confirm  the  specific  toxicity-causing
compounds.

The  TIE protocol  is  performed  in  three phases:
toxicity characterization (Phase I), toxicant
identification  (Phase  II)  and  toxicant  confirmation
(Phase  III).  In  some  situations  POTW pretreatment
program data may help  in identifying  the  effluent
toxicants.   If  the specific  effluent toxicants  are
identified,  a  control  method  such   as  local
pretreatment limits may be implemented.  If additional
data  are required to determine  the  nature and
sources of the  toxicants, a toxicity  source  evaluation
is conducted.

Toxicity Source Evaluation (Tier I)

The  initial  stage of  a  toxicity source  evaluation
involves sampling the effluent of  sewer dischargers or
sewer lines  and analyzing the wastewaters for  toxics
and/or toxicity.  Because  the  toxicity of the POTW
influent wastewater  is not  necessarily  the  same
toxicity that  is observed in the POTW effluent,  sewer
samples are treated in a  simulation of the POTW's
biological  treatment process prior to toxicity  analysis
to  account for  the toxicity removal  provided by  the
POTW.

The  choice  of  chemical-specific  analyses  or toxicity
tests for source tracking will depend on the quality of
the  TIE  results.  Chemical-specific  tracking  is
recommended where the specific toxicants have been
identified and can be readily traced to the responsible
sewer dischargers. Toxicity tracking is required where
TIE data on  specific toxicants are not definitive.

If Tier I testing  is successful in  locating the  sources
that are contributing the  POTW effluent  toxicants,  a
toxicity  control  method such as local limits  can be
developed and  implemented.  If additional information
on toxic indirect discharges is  needed, further toxicity
source testing is conducted.

Toxicity Source Evaluation (Tier II)

A  Tier  II evaluation  is performed  to  confirm  the
suspected sources of toxicity identified in Tier  I. Tier
II testing  involves  testing the  toxicity of selected
sewer  dischargers  following   simulated  POTW
treatment as in  Tier  I.  Additional  characterization
steps are used in Tier II to  determine  the  relative
amount and the types of toxicity  contributed by each
discharger.  Tier  II  information is used to rank  the
indirect dischargers with respect  to their toxicity/toxics
loading  and  to  evaluate  local  limits  as  a  toxicity
control option.

POTW In-Plant Control Evaluation

A  POTW control evaluation is conducted  in parallel
with  the  Tier  II  assessment to evaluate  in-plant
options  for  reducing effluent  toxicity.  If  in-plant
control appears to be a feasible  approach,  treatability
testing  is used  to evaluate methods  for  optimizing
existing treatment processes and to assess  options
for additional treatment.
                                                  1-2

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P
                                                               NPDESTRE Permit Conditions
                                                              Requirements/Recommendations
                   _L
      Information and Data Acquisition
Pretreatment Program Review, POTW Design
          and Operating Review
                                        POTW Performance   I
                                       Evaluation (Figure 3-1 )^~"
                                       Toxicity Identification
                                       Evaluation (Figure 4-1)
                                            Additional
                                           Information
                                            Required
                                                   Yes
P
                                    Toxicity Source Evaluation-
                                          Tier I: (Figure 5-1)
                                            Additional
                                           Information
                                            Required
                                                   Yes
                    Toxicity Source Evaluation— Tier I
                      Source Ranking/Pretreatment
                           Evaluation (Figure 6-1)
                                          Initial Phase I
                                     Toxicity Characterization
                                                                      Yes
                                      Conventional Pollutant
                                         Treatability Tests
                                                                             Yes
                                             Toxicity
                                          Pass-Through
                                           or Treatment
                                            Inhibition
                                                                               No
                     No
  POTWIn-Plant
Control Evaluation
    (Figure 7-1 )
                                         Toxicity Control
                                            Selection
                                                                                                            No
                                         Toxicity Control
                                       Implementation and
                                       Follow-Up Monitoring
                  Figure 1-1.  THE flow diagram for municipal wastewater treatment plant.
                                                                       1-3

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Toxicity Control Selection

Using the results of the TIE testing, the Tier I and Tier
II toxicity source evaluation and the POTW treatability
testing, alternatives for effluent toxicity reduction  are
evaluated and the most feasible option(s) is selected
for implementation. The choice of a control  option(s)
is based on several technical and cost criteria.

Toxicity Control Implementation

The  toxicity control  method  or  technology  is
implemented and follow-up monitoring is conducted to
ensure that the control method achieves the TRE
objectives and meets permit limits.

Limitations of the Protocol

This  document  addresses the protocol for evaluating
and  implementing methods for reduction of  whole
effluent toxicity.  Because regulations concerning  the
transfer of toxics to sludge and air in POTWs are  still
under development, specific  procedures for sludge
and air toxics reduction are not discussed. The reader
may  consult EPA's  Guidance Document for Writing
Permit Requirements  for Municipal  Sewage Sludge
(1988a) regarding permit conditions for sludge.

The municipal TRE protocol was developed based on
the  results and findings  of  several TRE  and TIE
studies.  Some  of the procedures used in  these
studies,  especially  tools  for  toxicity  source
evaluations,  have not  been  widely  used  and  will
therefore  require  further  refinement  as  more
experience is gained.  Additionally, the feasibility and
effectiveness of in-plant and  pretreatment toxicity
control options  have not been well documented and
additional experience in this area is needed.

Organization of the Document

This  document  is  organized  according  to the
components of  the TRE protocol flowchart (Figure  1-
1).  The section headings are as follows:

  Section 2     Information and Data Acquisition

  Section 3     POTW Performance Evaluation

  Section 4     Toxicity Identification Evaluation

  Section 5     Toxicity Source Evaluation (Tier I)

  Section 6     Toxicity Source Evaluation (Tier II)

  Section 7     POTW In-Plant Control Evaluation

  Section 8     Toxicity Control Selection

  Section 9     Toxicity Control Implementation

Sections  10  through  13  describe  the  TRE
requirements for  quality assurance/quality  control,
health and  safety, facilities  and  equipment, and
sample collection and handling. In  Appendix A case
examples  of municipal  TREs  are discussed  with
respect to the study approach,  important findings and
problems  encountered. Appendix  B  provides   a
detailed description of selected TRE procedures.
                                                 1-4

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                                             Section 2
                               Information and Data Acquisition
Introduction
The  first step in a  TRE is the  collection  of  all
information  and  data that may relate  to effluent
toxicity and that might prove useful  in conducting the
TRE.  This  information is generally divided  into two
main categories:  POTW treatment  system data and
pretreatment program data.  In addition to historical
effluent toxicity data,  the pertinent POTW information
includes  data on the  treatment  plant's  design
capabilities, treatment performance,  and  operation
and  maintenance  practices.  The appropriate
pretreatment  program   information consists  of
industrial waste  survey  data,  and  pretreatment
monitoring and compliance reports.

A summary of existing information required for a TRE
is provided in the following subsections. It is important
to  emphasize  that drawing  preliminary conclusions
based on this initial  information can' be misleading.
Thus, the compiled data should be reserved for use
as indicated in subsequent steps of the TRE protocol.

POTW Design and Operations Data

The primary objective in  retrieving POTW design and
operations information is to establish  a data base to
be  used in  the POTW  Performance  Evaluation
(Section 3). This information can  indicate possible
in-plant  sources  of  toxicity or operational  problems
that might be contributing  to treatment  interferences
or toxicity pass-through.  In addition, the POTW data
will be  useful in evaluating and  selecting ih-plaht-
toxicity control options (Section 7).

The pertinent POTW design and operations data to
be  gathered  include  treatment  system design
information  and the data routinely collected for
NPDES discharge monitoring reports (DMRs) and for
process control.   A list  of useful  POTW data is,
provided in Table 2-1.

Pretreatment Program Data

The  POTW pretreatment  program  data are  used
throughout the TRE.  These data are reviewed in the
Toxicity Identification Evaluation  (Section 4) to assist
in characterizing  and identifying the effluent toxicants,
and  they are evaluated  in  the  Toxicity Source
Evaluation (Section  5) to  aid in locating the influent
sources of toxicity.

The  appropriate  pretreatment  program  information
includes the data on the industrial  users (lUs)  of the
POTW (i.e.,  industrial manufacturers,  RCRA  waste
disposers, and CERCLA dischargers) and  the toxic
pollutant data on the POTW wastestreams.  A list of
suggested pretreatment data is shown in Table 2-2.
                                                 2-1

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Table 2-1.    POTW Design and Operations Data
    1,     NPDES permit requirements
              a.   Effluent limitations
              b.   Special conditions
              c.   Monitoring data and compliance history

    2.     POTW design criteria
              a.   Hydraulic loading capacities
              b.   Pollutant loading capacities
              c.   Biodegradation kinetics calculations/assumptions

    3,     Influent and effluent conventional pollutant data
              a.   Biochemical oxygen demand
              b.   Chemical oxygen demand (COD)
              c.   Suspended solids (SS)
              d.   Ammonia
              e.   Residual chlorine
              f.   pH

    4,     Process control data
              a.   Primary sedimentation - hydraulic loading capacity and BOD and SS removal
              b.   Activated sludge - Food-to-microorganism (F/M) ratio, mean cell residence time (MCRT), mixed liquor suspended
                   solids (MLSS), sludge yield, and BOD and COD removal
              c.   Secondary clarification - hydraulic and solids loading capacity, sludge volume index and sludge blanket depth

    5.     Operations information
              a.   Operating logs
              b.   Standard operating procedures
              c.   Operations and maintenance practices

    6.     Process sidestream characterization data
              a.   Sludge processing sidestreams
              b.   Tertiary filter backwash
              c.   Cooling water

    7.     Combined sewer overflow (CSO) bypass data
              a.   Frequency
              b.   Volume

    8.     Chemical coagulant usage for wastewater treatment and sludge processing
              a.   Polymer
              b.   Ferric chloride
              c.   Alum

    9.     RCRA reports [if POTW is considered a hazardous waste treatment, storage and disposal facility (TSDF)]
                                                           2-2

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             Table 2-2.    Pretreatment Program Data
                 1.
P
POTW influent and effluent characterization data
     a.   Toxicity
     b.   Priority pollutants
     c.   Hazardous pollutants
     d.   SARA 313 pollutants
     e.   Other chemical-specific monitoring results

Sewage residuals (i.e., raw, digested, thickened and dewatered sludge and incinerator ash) characterization data
     a.   EP toxicity
     b.   Toxicity Characteristic Leaching Procedure (TCLP)
     c.   Chemical analysis

Industrial waste survey (IWS)
     a.   Information on IDs with categorical standards or local limits and other significant non-categorical IDs
           (i)   number of lUs
           (ii)   discharge flow
     b.   Standard Industrial Classification (SIC) code
     c.   Wastewater flow
     d.   Types and concentrations of pollutants in the discharge
     e.   Products manufactured
     f.    Description of pretreatment facilities and operating practices

Annual pretreatment program report
     a.   Schematic of sewer collection system
     b.   POTW monitoring data
           (i)      discharge characterization data
           (ii)      spill prevention and control procedures
           (iii)      hazardous waste generation
     c.   ID self-monitoring data
           (i)      description of operations
           (ii)      flow measurements
           (iii)      discharge characterization data
           (iv)      notice of slug loading
           (v)      compliance schedule (if out of compliance)

Technically based local limits compliance reports

Waste hauler monitoring data and manifests

RCRA reports [if the POTW is considered a hazardous waste treatment, storage and disposal facility (TSDF)]
     a.   Hazardous waste manifests
     b.  Operating record
     c.   Biennial report
     d.  Unmanifested waste report

CERCLA reports (if the POTW accepts wastes from a superfund site)
     a.  Preliminary assessment
     b.  Site investigations
     c.  Remedial investigations
     d.  Feasibility studies
     e.  CERCLA decision documents

Evidence of POTW treatment interferences (i.e., biological process inhibition)
                                                                           2-3

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                                            Section 3
                                POTW Performance Evaluation
introduction
POTW  treatment  deficiencies  such  as  poor
conventional pollutant removal can have the effect of
increasing  effluent  toxicity.  Prior  to conducting
effluent toxicity characterization,  an evaluation of the
POTW operations and performance should be made
to identify and correct treatment deficiencies that may
be responsible for all or part of the effluent toxicity. A
POTW  performance  evaluation  (PPE)  can  be
conducted to indicate conventional pollutant treatment
deficiencies that may be  causing toxicity  and  to
evaluate  improvements in  operations  and treatment
that  may eliminate in-plant  sources of toxicity. The
flowchart for conducting a PPE is presented in Figure
3-1  .

The  PPE involves a review of the major treatment unit
processes (e.g., primary  sedimentation, activated
sludge and secondary  clarification) using wastewater
characterization  data  and  process  operations
information. Additionally, an optional  TIE  Phase  I
analysis (see Section 4) can be performed to indicate
the  presence  of  effluent  toxicants  caused  by
incomplete treatment (e.g.,  ammonia)  or  routine
operating practices (e.g., chlorine).  Based  on the
process  review results  and  the Phase  I data, options
for  improving operations  and  performance are
selected  and evaluated  in treatability  studies.  If
treatability tests are successful  in  identifying the
necessary  options for improving  conventional
pollutant treatment and for  reducing effluent  toxicity,
the  THE  proceeds  to  the  selection and
implementation of those options  (Sections 8  and 9).
If, however, the  treatment alternatives  do not reduce
effluent toxicity to acceptable  levels, further  effluent
toxicity characterization is  required  using  the TIE
procedures discussed in Section 4.

Operations and Performance Review
The  operations and performance review involves the
evaluation of the major POTW unit processes  using
the information described in Table 2-1. This  review
focuses on the secondary treatment system, because
secondary treatment is responsible for removing the
majority of the conventional and toxic pollutants from
municipal wastewater. Deficiencies in this system are
 more  likely to  result in incomplete  treatment  of
 wastewater toxicity.  Other unit processes  to be
 evaluated include  primary  sedimentation  and
 disinfection. Particular attention  is paid to chlorine
 disinfection because residual chlorine is highly toxic
 to aquatic life.

 Procedures for evaluating  and  improving POTW
 operations and performance are described  in EPA's
 "Handbook on Improving POTW Performance Using
 the  Composite  Correction  Approach"  (1984).  The
 composite correction approach utilizes a point system
 to quantify process performance and to indicate
 which treatment units need improvement.

 Primary Sedimentation

 Primary treatment processes are designed  to reduce
 the  loading   of  suspended solids  (SS),  5-day
 biochemical oxygen  demand (BODs) and  chemical
 oxygen demand (COD) on  the  secondary  treatment
 system. Toxics removal can also occur during primary
 sedimentation  from  the settling  of  insoluble or
 particulate  toxic wastewater constituents. Optimal
 removal of both toxic and conventional pollutants  in
 primary sedimentation  will  ultimately reduce  the
 amount of material passing through the  biological
 treatment process.

 Primary clarifier performance can  be evaluated by
 comparing surface  overflow rate (SOR), which is the
 average daily  flow divided  by the clarifier surface
 area, to the  expected BOD5  removal. A clarifier
 operating at an SOR of less than 25 m3/m2/day (600
 gpd/sq ft) should remove 35 to 45  percent of the
 influent BODs. A clarifier  operating  at an SOR of 25
 to 40  m3/m2/day (600-1,000  gpd/sq ft)  should
 remove 25 to 35  percent  of  the  influent  BODs
 (USEPA,  1984).  In  most  cases  COD   removal
 performance will be comparable  to the BOD removal
 performance.


Aerobic Biological Treatment

Aerobic biological treatment is a critical process  in a
 POTW,  because it is the  process  that  converts
organic  matter to settleable  microorganisms. Toxics
                                                3-1

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                                    Information and Data Acquisition
                                                                            Initial Phase I
                                                                        Toxicity Characterization
                                     Data Base on POTW Operation
                                          and  Performance

                                  Background-Historical Information
                                  Discharge Permits
                                  Process Control Data
                                  Biological Treatment Inhibition
                                  Chlorination Problems
                                  Treatment Bypasses
                                  Process Sidestream Discharges
                                  Sludge Toxicity
                                  Toxicity or Toxics Pass-Through
                                No
                                                    Yes
1
r
Bench Scale
Conventional
Treatability
Tests

1
1
r
Pilot Scale
Conventional
Treatability
Tests
i
r
                  Toxicity
                Identification
                 Evaluation
                 (Figure 4-1)
Toxicity/Toxics
 Pass Through
Toxicity Control
   Selection
            Figure 3-1.   Plant performance evaluation.
removal during aerobic biological treatment can occur
by biodegradation, adsorption onto the biological floe,
and  by  volatilization  of  volatile constituents. Key
factors affecting  toxics removal are the tendency  for
toxics to  biodegrade, volatilize,  or sorb onto  solids
and  the  degree  to  which  toxics  will inhibit  the
biological process.

Aerobic biological treatment systems that are typically
used in  POTWs  are  activated  sludge,  trickling filter
and  rotating biological contactor (RB3) processes. To
simplify the discussion of aerobic  biological treatment
             systems,  the following subsections  will  focus on the
             performance evaluation  of  the activated  sludge
             process,  which is the process most widely used  in
             POTWs.


             The  parameters that  are  used  to  evaluate  the
             operational  capability  of an activated sludge  system
             include organic loading,  oxygen  requirement  and
             mean cell retention time (MCRT).  Operating values
             for these parameters can  be  compared  to  design
             specifications or recommended  criteria to determine
                                                     3-2

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 how well the  activated sludge  process is being
 operated.

 Organic Loading -

 Organic loading on an activated sludge system affects
 the organic removal. efficiency, oxygen  requirement
 and sludge production  of  the  process.  The  most
 common measure Of organic loading in  suspended
 growth  processes  is  the  food-to-microorganism
 (F/M) ratio,  which is the organic  load removed per
 unit of  mixed  liquor   volatile suspended  solids
 (MLVSS) in the aeration  basin per unit time. High F/M
 ratios (i.e.,  high  organic loading) will result in low
 organic  removal efficiency, low oxygen  requirement
 and high sludge production. Low F/M ratios (i.e., low
 organic  loading) will cause  high  organic  removal
 efficiencies  and low sludge production, but high
 oxygen  requirements.  For  optimal   biological
 treatment, the F/M ratio in an activated sludge system
 is typically maintained in the range  of 0.2 to 0.4  Ib
 BODs/lb MLVSS-day for  conventional activated
 sludge,  0.05 to 0.15 Ib  BOD5/lb  MLVSS-day for
 extended aeration,  and  0.2 to  0.6  Ib BODs/lb
 MLVSS-day for  contact  stabilization (Metcalf  and
 Eddy, 1979).

 An activated sludge process operating at an F/M ratio
 that is substantially  lower than the design F/M ratio
 may indicate  biological  treatment performance
 problems. For example, the  Patapsco Wastewater
 Treatment Plant in Baltimore, Maryland was operated
 at an F/M ratio  of  0.40  Ib BODs/lb  MLVSS-day
 instead  of the design F/M  ratio of 0.55  Ib BODs/lb
 MLVSS-day, because the  POTW could not achieve
 consistent wastewater treatment  at the higher  organic
 loading.  The decreased treatment capacity  at  the
 POTW was thought to be due to the toxic effect that
 industrial wastewaters had  on the activated  sludge
 biomass (Slattery, 1987).

 Oxygen Requirement ~

 Microorganisms  in  the  activated sludge  system
 require oxygen to metabolize the organic  material in
 the wastewater. Oxygen  deficient  conditions  can
 result in lower treatment capacity,  and  hence  a
 greater potential  for toxics pass-through.  To  ensure
 an adequate supply of oxygen, the dissolved  oxygen
 (DO) level should  be   maintained  above 2 mg/l.
 Typical air requirements are 1,500 cu ft/lb BODs load
for conventional activated  sludge  and contact
stabilization, and 2,000 cu  ft/lb  BODs  load  for
extended aeration (USEPA, 1984).

The transfer of oxygen from the gas phase  to  the
liquid phase is a function of the aeration  equipment
and the basin  mixing conditions.  EPA's  Composite
Correction  Program  Manual (1984)  describes  a
procedure for estimating  oxygen transfer  capacity in
aerators based on equipment specifications. Another
estimate of  oxygen transfer  capacity  involves
 comparing the measured  oxygen uptake rate (OUR)
 of  the biomass to  the calculated theoretical  oxygen
 demand (USEPA, 1984) for the  aeration system. If
 the OUR results indicate  an oxygen demand that is
 greater than  the  calculated  oxygen  demand,  the
 oxygen supply may be inadequate. The opposite case
 (i.e., higher theoretical  oxygen demand  than actual
 oxygen demand) is preferred; however, a substantial
 difference may indicate inhibition of biomass activity.

 OUR measurements  were  used to  document  the
 start-up  performance  of  the  activated sludge
 treatment  process at  the  Patapsco  Wastewater
 Treatment Plant. During the start-up of the biological
 process,  the  OUR in  the  biomass  averaged  20
 mg/l/hr/g MLSS, and the POTW frequently exceeded
 its  conventional pollutant  permit limits (Botts et al.,
 1987). As the  biological system became acclimated to
 the wastewater, the effluent quality improved and the
 biomass OUR increased to an average of 50 mq/l/hr/q
 MLSS.

 Mean Cell Residence Time -

 In  the course of biological  treatment, the  activated
 sludge microorganisms convert some  of the organic
 matter in the  wastewater  to  new cell mass.  To
 achieve optimal  treatment, the biomass concentration
 in the aeration  tank is  held  at a constant level  by
 routinely wasting the  excess sludge.   Sludge  mass
 control can be practiced by maintaining a consistent
 average  age  of activated  sludge (i.e.,  mean  cell
 residence time)  in the system. Mean  cell residence
 time (MCRT) is calculated  by dividing the total sludge
 mass in the system by the amount of sludge that is
 wasted each day.

 Typical  MCRTs  for aeration processes are: 6 to  12
 days for conventional activated sludge,  10 to 30 days
 for  contact stabilization  and  20 to   40  days  for
 extended  aeration (USEPA,  1984).  During  the
 Patapsco TRE, the  MCRT of the  pure oxygen
 activated sludge process increased from an average
 13.8 days to 16.9 days over a 9 month period (Botts
 et.al., 1987).  This  increase  in MCRT appeared  to
 cause  a corresponding decrease in   OUR in the
 biomass  from  46.7 mg  O2/hr/g MLSS  to  25.2 mg
 O2/hr/g MLSS  over the same period. The increase in
 MCRT appeared to  be limiting  biomass activity,
 however, effluent quality as measured by toxicity and
 conventional pollutant removal was not affected.

 Secondary Clarification

 In order for the  activated sludge process to operate
 efficiently, the  secondary  clarifier  must  effectively
 separate solids from the liquid phase and concentrate
the  solids for subsequent return to the aeration basin.
 Solids-liquid separation is  influenced  to  a large
degree by  the aeration basin  operating  conditions
such as DO levels,  F/M  ratio and MCRT. Secondary
                                                3-3

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clarifier factors also have an important effect on solids
clarification.

Sludge settling characteristics are affected  by  how
the aeration  basin is operated. Low DO levels in the
aeration  basin  promote the  growth  of  filamentous
bacteria  which can  hinder solids settling, whereas
high DO levels lead to the  growth  of  fast settling
zoogleal-type bacteria. At very high organic  loadings
(high F/M) the activated sludge can be dispersed and
will not settle well. An example of this condition was
observed at  the East Side Sewage Treatment Plant in
Oswego, New  York,  which  experienced  sludge
bulking due  to high influent organic loadings (USEPA,
1984).  Sludge  settleability  was  improved  by
increasing the MCRT and the sludge return rate.

The performance of secondary, clarifiers in solids-
liquid separation is dependent on a variety of factors
including clarifier configuration, SOR, clarifier  depth at
the wiers, the type  of  sludge  removal  mechanism,
and the  return sludge  flow  rate. The  Composite
Correction  Program  Manual (1984)  describes  a
system  for  scoring  secondary  clarifier  performance
based on these factors.

Process Sidestreams and Wastewater Bypasses

Some wastewater and  sludge treatment processes
can produce  sidestream wastes  that  may  have  a
deleterious  effect  on  the wastewater  treatment
system or might contribute to the effluent toxicity.  In
addition  raw  or partially  treated wastewater  that
bypasses part or all of the  wastewater treatment
system  can  add  substantial  toxicity  to  POTW
discharge^).

Examples  of  POTW  sidestreams  include  sludge
processing  wastewaters from thickening, digestion,
and dewatering of sludges, cooling water blowdown,
and  backwash  from  tertiary filters.  Of these
wastewaters,  anaerobic  digestion  and   sludge
dewatering  sidestreams  can   contain  high
concentrations of  organic  material  (BODs)  and
nutrients (nitrogen  and  phosphorus)  which  can
represent a significant loading to the aeration basin.  In
addition, these and other  sidestreams  may contain
toxic material such  as metals from sludge dewatering
 treatment that may pass through the POTW.

 In some municipalities,  stormwaters  and sewage are
 still collected  in the same sewer system.  When  a
 large  storm  event occurs, the  combined sewer
 wastewater is  often  diverted  away from all or part  of
 the POTW  to prevent hydraulic over  loading, and the
 bypass  is discharged directly to the  receiving water.
 Combined sewer overflows (CSOs) can cause short-
 term exceedances in discharge permit limits for both
 toxic and conventional pollutants.

 The  PPE  should include  a  listing  of  all  process
 sidestreams and wastewater bypasses in the POTW,
and a review of the data on each  of these waste-
streams. Additional analytical and. toxicity data may be
needed to characterize the possible toxic constituents
and toxicity of the wastestreams. This information can
be used  to determine if  process  sidestreams are a
significant  source  of  pollutants or  toxicity,  and
whether  or not  current  treatment practices  are
sufficient to remove the  toxicity.  Information on the
frequency  and volume  of  CSOs,  relative to the
receiving wasteflow, can indicate  if CSOs  are  a
problem.


Disinfection

Disinfection  is  generally  achieved  by treating the
secondary effluent with  chlorine  and  allowing  a
sufficient  contact period prior  to  discharge.  The
chlorine dosage is usually based on the required level
of residual chlorine to  be maintained in  the  final
effluent which is specified in the NPDES permit.

The chlorine disinfection  process  should be carefully
evaluated because  residual  chlorine and  other  by-
products of chlorination  (i.e.,  mono- and  dichloro-
amines) are toxic to aquatic  life (Brungs,  1973). The
PPE focuses on the minimum amount of chlorine that
must  be  applied to achieve  the  desired  residual
chlorine concentration. Observations should be made
to determine how close  the actual  residual chlorine
level is to the required minimum  level. For example,
an average residual chlorine  level of  3.0  mg/l for  a
POTW with a minimum  permit  level of  1.0  mg/l
chlorine would indicate excessive chlorination.

If dechlorination  is practiced  following chlorination,
information  on the type and  amount  of  oxidant-
reducing  material used  should  be obtained; Some
dechlorinating  agents such as sulfur dioxide may be
toxic to aquatic life at high concentrations.

Optional TIE Phase I Tests

Optional  TIE  Phase  I analyses  (Mount  and
Anderson-Carnahan, 1988a)  can  be conducted  in
parallel with the  above operations  and performance
review  to  obtain  information  on  the  types  of
compounds causing the effluent toxicity. An overview
of the Phase I procedure is described in Section 4 of
this document.

The TIE Phase  I  testing in  the PPE  focuses on
characterizing toxicants that  may be present  in the
effluent  because  of  inadequate   treatment
 performance or routine operating practices. Although
the Phase I results  provide only an  initial indication of
the effluent toxicants,  when taken  together with the
 PPE  data  and a knowledge of the POTW treatment
 operations,  possible  in-plant  toxicants  can be
 suggested based on the  "weight  of evidence". .Using
 this information,  treatability  tests can be  devised to
                                                  3-4

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 evaluate  procedures  for  removing  the  suspected
 toxicants from the effluent.

 The  TIE  Phase  I  testing  includes  several
 characterization steps that can  be used  to  indicate
 the  presence  of "in-plant toxicants"  such  as
 suspended  solids, ammonia  and chlorine.  One step
 involves filtration to  remove  effluent particles, which
 include  residual  suspended solids  resulting from
 biological treatment. By testing the  toxicity  of
 unfiltered and filtered samples,  it  is possible  to
 determine whether or not the effluent  toxicity  is
 associated with these particles. Another Phase I step
 involves pH adjustment of the effluent sample to shift
 the equilibrium concentration  of ammonia between its
 toxic form  (NHs) and its essentially  nontoxic form
 (NH4 + ).  As pH  increases, the percentage  of total
 ammonia (NH3 -+ NH4 + ) present  as  NHs increases.
 If adjusting the effluent sample pH  to 8 increases the
 toxicity or if lowering the effluent sample pH to 6
 decreases the toxicity, the  identity of the effluent
 toxicant would  be consistent with  ammonia. Caution
 should  be used  in drawing  preliminary conclusions
 about these data, because the toxicant could actually
 be something that behaves in the  same manner as
 ammonia. A third Phase I step is designed to indicate
 whether  or  not wastewater  oxidants  such  as total
 residual chlorine  (i.e.,  free chlorine and  mono-  and
 dichloroamines) are causing the toxicity. Thiosulfate,
 a reducing agent, is added to aliquots of the effluent
 sample to eliminate total  residual chlorine  (TRC).
 Toxicity  tests  prior  to  and  following  thiosulfate
 treatment are used to indicate if TRC is  present in
 toxic amounts in the effluent.

 It is important to .note that each of the TIE Phase I
 characterization steps described above addresses  a
 broad class of toxicants rather than specific effluent
 constituents such as ammonia and  TRC (Mount and
 Anderson-Carnahan,  1988a).  For  example,  the
 oxidants  that are • neutralized  in the thiosulfate
 treatment  step  include bromine,  iodine  and
 manganous  ions  in  addition to   TRC.  Thus,  to
 substantiate the initial indication that specific toxicants
 are causing  effluent  toxicity, the  Phase  I  results
 should be compared with information from the POTW
 operations and  performance review. Using the
 previous  example, the  assumption  that TRC  is
 causing oxidant toxicity  would  be corroborated  if
 operations data show that the POTW maintains toxic
 concentrations of chlorine in the final effluent.
Conventional Wastewater Treatability
Testing

The  operations and performance review  information
may  identify areas in the POTW where improvements
in conventional pollutant  treatment may  reduce
toxicity  pass-through. This  information and the
 optional TIE Phase I data may also indicate in-plant
 sources of toxicants such as process sidestream by-
 passes or over chlorination that are causing effluent
 toxicity. IJsing these data, a  wastewater treatability
 program can be  devised  and implemented to assess
 in-plant options for improving conventional treatment
 and eliminating in-plant sources of toxicity.

 Treatability studies  are  recommended   prior  to
 comprehensive  TIE testing  (Section 4)  only  in
 situations where improvements  in  treatment
 operations  and performance are needed to attain
 acceptable conventional  pollutant treatment. These
 studies should  focus on  conventional pollutant
 treatment deficiencies  which  are  suspected  of
 contributing to effluent toxicity.  The  scope of the
 treatability studies program should be based  on  clear
 evidence  of a consistent treatment deficiency causing
 toxicity over time.  If  sufficient information is not
 available  to develop  a  straightforward treatability
 program,  additional data  must be  gathered in the
 subsequent stages  of the  TRE  before  in-plant
 toxicity control  (Section  7) can be evaluated.

 Treatability  studies can  range  from a   simple
 evaluation such  as  testing TRC  removal by
 dechlorination to an extensive effort involving  long-
 term  bench-  and  pilot-scale  work.  Prior  to
 beginning  these studies,  the  POTW operations and
 performance data and the  optional TIE Phase  I results
 should  be carefully reviewed and  an appropriate
 treatability test program should be developed using
 best professional judgement. It may  be necessary  to
 more completely  assess the nature and variability  of
 the effluent toxicity (Section 4) prior to implementing
 an extensive treatability effort.

 A treatability program can  be  devised to  evaluate
 modifications in existing  treatment  processes.  The
 evaluation  of additional treatment units  should be
 attempted  only after further effluent characterization
 studies (i.e.,  TIE) have  been  performed.  PPE
 treatability testing  may  involve  physical/chemical
 treatment  approaches  such  as  coagulation  and
 precipitation,  solids  sedimentation,  granular media
 filtration, and powdered  activated carbon adsorption,
 or biological treatment approaches such as activated
 sludge or sludge digestion. Because toxicity control is
 the ultimate goal of the  TRE, toxicity tests should be
 performed  in addition to  the  conventional pollutant
 analyses normally conducted  in  treatability  studies,
 Toxicity tests are used to assess the capability of the
 treatment modifications for toxicity reduction.

 The  following subsections  briefly describe some of
 the treatability tests that can be used to determine if
 improvements in conventional pollutant treatment will
 reduce effluent  toxicity.  As  shown  in  Figure  3-1;  if
this testing is successful in identifying  improvements
 in  conventional  pollutant treatment that will achieve
acceptable  levels  of  effluent  toxicity,  the  TRE
proceeds  to the  selection  and implementation' of
                                                 3-5

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those options (Sections  8  and 9).  If,  however, the
treatability data  indicate  that  improved  in-plant
treatment  will  not reduce  effluent toxicity  to
acceptable  levels,  further  effluent  toxicity
characterization is required  using the TIE procedures
(Section 4).

Coagulation and Precipitation
Coagulation  is  the  addition of a chemical  such  as
polymer or ferric chloride to wastewater that causes
the formation of  flocculant suspensions or insoluble
precipitates. Coagulation can be applied in POTWs to
improve  suspended  solids  settling  or  remove
phosphorus, heavy metals, and paniculate toxicity.

The optimum  conditions  for  coagulation  can  be
determined by conducting a series of jar tests. These
tests are  used  to  establish the  optimum  type and
dose of coagulant,  the proper  mixing conditions, and
the flocculant settling rates (Adams et al.,  1981).

Sedimentation
Sedimentation  is the process employed  to  remove
suspended solids or flocculant suspensions  from the
wastewater.  In general sedimentation  in  POTWs  is
characterized by flocculant settling for  wastewater
(i.e., primary clarification) and zone  settling for mixed
liquors  (i.e., secondary clarification) and sewage
sludges (i.e., sludge thickening).

Flocculant settling  rates  can  be converted to a
clarifier SOR by measuring the flocculant percent
removal with time  in a settling  column test (Adams
et.al., 1981). Using the  optimum range of flocculant
conditions determined in jar tests, a series of settling
column tests can be performed to compare particle
settling profiles  for various  coagulant  doses and
mixing conditions.

Zone settling can also be evaluated in settling column
tests. The settling velocity of mixed  liquor or sludge is
determined   by measuring  the  subsidence  of  the
liquid-solids  interface over  time (Adams et.al., 1981).
The test  is  repeated using the anticipated range of
suspended solids loading to the clarifier. Test results
are used to  calculate a solids flux curve that can be
 used for clarifier design.

 Activated Sludge
 Activated sludge is an aerobic treatment process that
 converts  organic matter to settleable microorganisms.
 Continuous flow and batch biological reactor tests are
 used to  assess pollutant or toxicity  treatability, and
 predict the  process kinetics  of  an activated sludge
system. A series of bioreactors are generally operated
under a range of F/M values to determine optimum
operating conditions (Adams et al., 1981).

Bioreactor  performance  is  evaluated  by measuring
pollutant  removals,  OUR,  MLVSS  and  the zone
settling  velocity  (ZSV)  of the sludge.  These
measurements  are  used  to  determine  the
biodegradation kinetics of the  wastewater and  the
preferred sludge  settling conditions.

Granular Media Filtration

Some  POTWs  utilize filtration  processes  following
secondary clarification to enhance suspended solids
removal. Filtration  performance  is  influenced  by the
physical/chemical properties of the granular media
and the wastewater.

The  main parameters to be varied in filtration testing
include hydraulic loading  rate, type and configuration
of the media, and, if necessary, type and dose of
chemical coagulant (Adams  et al., 1981).  Results of
filtration  testing  are used  to correlate  suspended
solids  removal with flow  rate, headless through the
filter with time, and  differential  headloss with solids
accumulation on the filter  media.

Activated Carbon Adsorption

Activated carbon may be  applied in powdered form to
the activated sludge process. The capability of carbon
adsorption  for  treatment  of organic  wastewater
constituents  or toxicity is determined  by conducting
batch  isotherm tests and  continuous-flow tests
(Adams et al., 1981).

The effectiveness of  carbon  in removing  BODs,
selected  organic  contaminants  (e.g.,  phenols) or
toxicity is predicted by  adding  known  amounts of
powdered  activated carbon to a  series  of batch
wastewater samples and measuring removal  of the
organic  constituents or toxicity. The  equilibrium
relationship between a wastewater and  carbon can
usually  be  described  either  by a  Langmier or
Freundlich  isotherm.   A  plot  of  equilibrium
concentration versus carbon capacity  is  used to
select the  required  carbon  concentration for
powdered activated carbon  (PAC)-activated sludge
processes.

Continuous-flow tests  are required to  confirm the
batch  isotherm results. PAC tests involve adding PAC
to  bench- or  pilot-scale  biological  reactors  and
monitoring the  removal  of  the  organic  wastewater
constituents  or toxicity.
                                                   3-6

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                                              Section 4
                                Toxicity Identification Evaluation
 Introduction
 Once the presence of toxicity has been  established,
 the  primary  components  of  toxicity  can  be
 characterized and  possibly identified through the use
 of toxicity identification evaluation procedures.  These
 procedures relate the  wastewater  components',
 physical/chemical characteristics to their toxicological
 characteristics  in   a  attempt  to  identify  the
 compound(s) causing  effluent toxicity.

 The TIE  procedures  as  described  by  Mount  and
 Anderson-Carnahan  (1988a,  1988b)  and  Mount
 (1988) consist  of  three phases: Phase I involves
 characterization of the toxic wastewater components;
 Phase II  is  designed to specifically  identify  the
 toxicants of concern;  and Phase  III is conducted to
 confirm the suspected toxicants. Figure 4-1 presents
 the= logical progression of these three phases  within
 the framework of a municipal TRE.

 The TIE  procedures  are applied to  POTW effluent
 wastewater samples.  A sufficient  number of effluent
 samples  should be  collected  to  characterize  the
 magnitude and variability of the effluent toxicants over
 time. To  ensure that the samples are representative
 of the effluent wastewater, a large  number of sam-
 ples may  need  to  be  collected.   Sampling  re-
 quirements for  TIE testing are  described in Section
 13. In  addition to POTW effluent TIE  testing,  the
 Phase  I  protocol may be applied to batch treated
 sewer  wastewaters, as described  in  Section  6, to
 characterize the components of the  POTW influent
 toxicity.

 Toxicity Tests

 Toxicity identification evaluations rely  on  the use of
 aquatic toxicity tests to  detect  the compounds
 causing wastewater toxicity. Acute toxicity tests  are
 generally used to indicate the presence of  toxicants
 as  the  effluent  is  manipulated  in TIE  testing.
 Presently, the TIE procedures do not address chronic
toxicity directly;  however, TIE  testing  can  be
 performed on effluents violating chronic toxicity limits,
 provided  that the effluent causes  significant lethality
 (e.g.,  >20% mortality in  100%  effluent) in an acute
 exposure period (i.e., 48  to 96 hr.). In this case the
 compound(s) causing acute toxicity are assumed  to
 be the same compound(s) causing chronic toxicity.
 This  hypothesis  is  tested in  the  Phase  III tests
 (Mount, 1988).   '   '  .

 The sensitivities of the test organisms used in toxicity
 tests can vary from species to species, therefore it is
 recommended  that  multiple  species  testing  be
 performed in the initial stages of the TIE to select an
 appropriately sensitive species  for the TIE program.
 Another criterion in test species selection  is that the
 species  be cost-effective  to use,  because  of  the
 large number of samples that may need to be tested.
 Test species commonly used for TIE toxicity tests are
 Ceriodaphnia or  Daphnia magna;  however,  other
 species  such  as fathead minnows  (Pimephates
 prometas) can also be used.

 Saltwater species are not recommended, because the
 tolerances of marine  organisms to the  TIE effluent
 manipulations have not been measured (Mount and
 Anderson-Carnahan,  1988a). In situations  where the
 POTW effluent is  discharged to  saline receiving
 waters, a freshwater species that is  responsive to the
 same toxicants as  the marine  species  should be
 chosen.  Phase  III  involves  minimal  effluent
 manipulation and a marine species should be used to
 confirm the Phase I and  II freshwater species results.

 Toxicity test procedures for TIEs are described in the
 Phase I  manual  (Mount  and  Anderson-Carnahan,
 1988a). The test  organisms are placed  into six test
 vessels:  one containing  the  highest test  sample
 concentration; four containing the appropriate range
 of sample dilutions; and one containing  only dilution
 water which  serves  as  the  control. Following  an
 appropriate exposure  period,  the  test  organism
 mortality  is determined and  an LCso  value ,(i-e.
 percent sample  concentration causing 50% mortality)
 is calculated. These tests  are usually performed with
 minimal quality assurance (e.g. duplicates may not be
required)  in. an effort to  collect as much  data on the
sample toxicity,  as quickly and inexpensively  as
possible.
                                                 4-1

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                                      Evidence of Toxicity Pass-Through or
                                             Treatment Inhibition
                                         Phase I Toxicity Characterization
                                           Initial Toxicity
                                           Baseline Toxicity
                                           pH Adjustment
                                           Aeration
                                           Filtration
                                           Cia Solid Phase
                                             Extraction/El ution
                                           Oxidant Reduction
                                           EDTA Chelation
                                           Graduated pH
             Information and
             Data Acquisition
          Pretreatment Program
                  Data
  Additional
 Information
  Required
                                         Phase II Toxicant Identification
                                       Specific Chemical Analytical Method
                                    Phase III Toxicant Confirmation Procedures
                                                 Additional
                                                 Information
                                                  Required
                    Toxicity Control
                       Selection
Toxicity Source
Evaluation Tier I
   (Figure 5-1)
,
r
POTWIn-Plant Control
Evaluation
(Figure 7-1 )
       Figure 4-1.  Toxicity identification evaluation.
When Phase  III is reached, definitive toxicity tests
using standard EPA procedures (Horning and Weber,
1985,  Peltier and  Weber,  1985, Weber et al.,  1988)
are recommended to confirm the suspected toxicants.
These tests should utilize the same test species that
is required for NPDES biomonitoring.
          Toxicity Characterization and Toxicant
          Identification Procedures

          The effluents of some municipal treatment  facilities
          can be extremely complex, particularly facilities which
          receive a significant amount of  industrial wastewater.
                                                     4-2

-------
 These effluents have posed a  problem in attempting
 to  determine  the compound(s)  causing  toxicity.
 Furthermore, effluents from POTWs with little  or no
 industrial  inputs  have  proven  to  be  difficult  to
 characterize. Nonetheless, the TIE  procedures  are
 useful in the identification of the toxic compound(s) in
 POTW effluents. These procedures allow the toxicity
 to be traced to a particular class of  compounds and
 sometimes to a particular compound(s).

 Phase I - Toxicity Characterization

 The first step in the TIE is to characterize the effluent
 toxicity using  the  Phase  I  approach  (Mount and
 Anderson-Carnahan,  1988a).  This  procedure
 involves  the use of several  bench-top treatment
 steps to determine the types of toxic components in
 the effluent.  Initially, the whole  wastewater sample is
 evaluated for "baseline" toxicity. If it  is toxic, aliquots
 of the sample are treated to remove certain types of
 compounds and the resulting acute  toxicity  of  these
 treated aliquots is measured.

 The Phase I characterization steps consist of toxicity
 degradation, aeration,  filtration,  Cia  solid phase
 extraction (all of these  procedures with  and without
 pH adjustment),  pH  adjustment,  oxidant-reduction,
 EDTA chelation,  and graduated pH  treatments. The
 toxicity  tests on aerated wastewater  samples are
 used to indicate if toxicity is associated with volatile or
 oxidizable compounds. The filtration step is designed
 to determine whether toxicity  is in  the suspended
 particulate  phase or in the soluble fraction. Aeration,
 in conjunction with pH adjustment is used to  evaluate
 toxicants with volatility, such as  ammonia or hydrogen
 sulfide. The toxicity associated  with the presence of
 oxidants  is evaluated  through sodium thiosulfate
 addition.  Cationic metal  toxicity is  evaluated through
 graduated EDTA addition. An  aliquot of  the effluent
 sample is  also  passed  through a C-\Q solid phase
 extraction (SPE) column  that  selectively  removes
 non-polar organic compounds.  If the effluent toxicity
 is removed or reduced by this treatment, the column
 is then eluted with.methanol and the  eluant is tested
for toxicity. If these Phase I tests  are  inadequate to
characterize the toxicants,  other techniques can  be
 used  such as  ion  exchange resins  for  anions and
cations; activated  carbon for various inorganic and
organic compounds; zeolite resins  for ammonia; and
molecular sieves such  as Sephadex  resins which
separate  compounds by molecular weight.

Pretreatment program data (Table  2-2) may provide
useful  information  to assist  in  the Phase  I
characterization. By reviewing available information on
 the pretreatment program, compounds that are known
 to  be toxic or problematic  in  the POTW  can  be
 compared to the Phase I results to assist in indicating
 the  effluent toxicants. This data comparison should
 not, however, replace the Phase II and III analyses.

 After successful completion of Phase I,  it may not be
 necessary  to  proceed  to  Phases  II and  III. If  the
 effluent  toxicity can  be  isolated to a class  of
 compounds (i.e.,  non-polar  organics, suspended
 particulates, volatile organics), treatability studies  can
 be designed to evaluate removal of the compounds
 causing  toxicity. These studies  may involved bench-
 scale or  pilot-scale testing procedures described in
 Section 7.

 Phase II - Causative Toxicant Identification

 The  Phase  II procedure  manual  (Mount  and
 Anderson-Carnahan, 1988b)  describes  specific  test
 methods that can be  used to  further identify specific
 causative  agents such  as  non-polar  organic
 compounds, ammonia,  cationic metals, or  chlorine.
 These methods are not intended as final proof that
 the compounds are causing  toxicity.  Phase  III tests
 are  required to confirm that  the  toxicants  are  the
 compounds  consistently  causing toxicity.  Depending
 on  the  characteristics of the  causative  chemicals,
 Phase II methods may entail the use of reverse phase
 HPLC columns to further separate  non-polar organic
 toxicants into more narrow fractions. This separation
 technique allows the identification of specific toxicants
 using  gas   chromatography/mass  spectrometry
 (GC/MS) procedures.

 Additional methods  for identification  of toxic  effluent
 components include: the  equitoxic solution test which
 evaluates the effect of pH adjustment and  dilution on
 ammonia toxicity; the zeolite resin test which  also can
 be  used  to  identify ammonia  toxicity;  and  atomic
 absorption  or  Inductively   Coupled  Plasma
 Spectrometry  (ICP) to  determine  which  cationic
 metals are  the toxicants.  Toxicant  identification
 procedures for other groups of causative toxicants  will
 be published by EPA as they become available.

 Phase HI - Causative Toxicant Confirmation

The  next  step  in the TIE is  Phase III which is the
toxicant  confirmation procedure  (Mount, 1988). The
toxicants  identified  in Phase  II  are confirmed by a
series of  test  steps  including  observation   of test
organisms symptoms;  additional  species  toxicity
testing;  and correlation of  toxicity and toxicant
concentration from multiple samples.
                                                  4-3

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                                              Section 5
                               Toxicity Source Evaluation -  Tier I
 Introduction
 A toxicity source evaluation is conducted to locate the
 sources of  influent  toxicity or  toxics that  are
 contributing  to the  POTW effluent  toxicity. This
 evaluation  is performed in two tiers. Tier I, which is
 discussed  in  this  section,  involves  sampling
 wastewater of indirect dischargers or sewer lines and
 analyzing the wastewaters for  toxics and/or  toxicity.
 Tier II, which is described in Section 6, is  performed
 to confirm the suspected sources of toxicity identified
 in Tier I testing.

 The flow diagram  for the Tier  I source evaluation is
 presented  in Figure  5-1.  Selection  of  sampling
 locations is  based  on  evidence  that  a  source
 contributes toxicants causing POTW effluent toxicity
 or  discharges substantial levels  of potentially toxic
 pollutants.  Sampling  of  wastewaters  from  indirect
 dischargers  is   recommended  where existing
 pretreatment program  data  or TIE  results  are
 adequate to  indicate that the  dischargers may
 contribute toxic pollutants that  cause POTW  effluent
 toxicity. Sewer line sampling can be used to locate
 toxic  sources by  process  of  elimination,  if
 pretreatment  program information and  TIE data are
 lacking, or sampling  of  indirect  dischargers  is not
 feasible (e.g., large number of IDs).

 The choice of chemical-specific analyses or  toxicity
 tests for source tracking will depend on the quality of
 the  TIE data  on  the  POTW effluent.  Chemical-
 specific investigation is recommended in cases where
 the  effluent  toxicants  have  been identified and
 presumably can be traced to the responsible sewer
 dischargers. In situations where TIE  data indicate that
 specific industrial chemicals such as  copper or phenol
 are the effluent toxicants, the TRE should proceed to
 the  evaluation  of local  pretreatment  limits  as
 described in Section 8.

 Toxicity tracking is required in  situations where TIE
data on specific toxicants are  not definitive. Prior to
toxicity  analysis, sewer samples are  afforded  the
 same:level  of biological treatment  as provided by the
 POTW for its influent wastewaters. If toxicity tracking
is successful  in locating sources that are contributing
toxicity,  the TRE  proceeds to the Tier II  source
 evaluation to confirm the toxic indirect dischargers. At
 this point, the POTW may require the Ills to conduct
 a TRE to reduce ID wastewater toxicity. It  may also
 be  possible in a  few  instances to  correlate  the
 pretreatment program data gathered at the beginning
 of  the TRE (Section  2)  with  the  effluent toxicity
 results to identify the influent sources of toxicity.


 Sampling Location

 Sampling locations for Tier I testing are established
 by reviewing the  pretreatment  program  data (Table
 2-2) and  the TIE  results, and  selecting the  sources
 that contribute relatively high loadings of potentially
 toxic pollutants  or toxicants identified in TIE  tests.
 Where possible,  the selection  of  sampling  locations
 should be based  on  TIE  results,  because the
 toxicants  causing  the  effluent toxicity  are the
 pollutants that must be controlled. Sampling  may be
 conducted at the  point where  the IU discharges its
 wastewater to the sewer or in the sewer lines of the
 sewer collection system, if no  IU  appears to be the
 source of  the  toxicants. A plan  for sewer  line
 sampling  can be devised  to  track toxic  sources
 through a  process of elimination of segments of the
 collection system (USEPA, 1983a).

 The choice of  IU discharge  sampling  or sewer line
 sampling  will  depend  on  the  number   of  lUs
 contributing to  the POTW,  the  quality  of  the
 pretreatment program data, and the TIE results. IU
 discharge sampling is recommended where the:

   « Number of lUs  is small enough so that sufficient
     test  data  can  be  collected with  the  allocated
     resources;

   « Pretreatment program  data  are sufficient to
     characterize each of the lUs; and

   • TIE data indicate  POTW effluent toxicants  that
     can be attributed to selected lUs.
In the  Patapsco  TRE indirect  dischargers were
selected for sampling based on evidence that the lUs
contributed substantial loadings  of toxicity  (as
                                                 5-1

-------
                                                  Results of
                                             Toxicity Identification
                                                  Evaluation
                                                  (Figure 4-1)
                   r
                                               Sample Collection
                                            Sewers/Point Discharges
                               Chemical-Specific
                                Investigation of
                           Selected Point Discharges or
                               Collection System
       Refractory Toxicity
     Assessment of Selected
       Point Discharges or
       Collection System
             Information and
             Data Acquisition
           Pretreatment Program
               Review (PPR)

                   Tier II: Toxicitv Source
                   Evaluation (Figure 6-1)
                   POTW In-PIant Control
                    Evaluation (Figure 7-1)
                                          Yes
             No
Additional
Information
 Required
                                                                                Toxicity Control
                                                                                  Selection
        Figure 5-1.  Tier I: toxicity source evaluation.
measured  by MicrotoxTM) and  toxicants  (non-polar
organic material)  identified  by TIE  tests  of  POTW
effluent (Botts etal.,  1987).  A  description  of  the
Patapsco study is given in Appendix A.

Sewer line sampling is recommended where:

   • A sewer line  sampling plan can  be  developed
     that will allow a more efficient method of toxicity
     tracking than sampling ID discharges;

   • Pretreatment program  data  are  limited  or
     unavailable; and

   • Sources of toxicants identified during the TIE are
     not obvious.
The Town of Billerica,  Massachusetts,  utilized  a
sewer line sampling approach to identify areas within
the sewer collection system that contribute toxicity  to
Ihe Town's wastewater treatment plant (Durkin et.al.,
1987). A description of the Billerica study is provided
in Appendix A.

Whether sampling of IU discharges or sewer lines is
conducted,  24-hour flow proportional  samples are
recommended to characterize daily variations in toxics
or toxicity while accounting for variations in flow. Flow
data  must  be  gathered  in  order to determine the
relative contributions of toxicants or toxicity from the
IDs.  Other  considerations  for  Tier I  sampling are
described   in   Section  13.  QA/QC  sampling
requirements are discussed in Section 10.

Chemical-Specific Investigation

A  chemical-specific approach can  be used to trace
the influent sources of toxics, if definitive TIE data on
the specific toxicants  causing POTW effluent toxicity
are available. This approach is not  recommended in
cases where the TIE data only indicate  a broad class
of  compounds  (e.g., polar  organic  compounds),
because the toxicants  may be contributed by  a large
                                                    5-2

-------
 number and  variety of sources which will be difficult
 to pinpoint by chemical tracking.

 The chemical-specific approach  involves testing  IU
 discharges or  sewer  line  samples  for  specific
 toxicants using chemical analysis techniques. In some
 cases  existing pretreatment  program  data  may be
 adequate  to  determine the Ills that are contributing
 the  toxicants. It  is  likely,  however,  that  further
 sampling  and analysis  will  be necessary,  because
 many toxicants other than those typically monitored
 (i.e., priority pollutants) are present in ID discharges.
 Existing pretreatment program data can be used  to
 reduce  the amount of sampling and  analysis by
 indicating  which sources  contribute toxics  that are
 similar to the effluent toxicants.

 Chemical  analysis  methods for priority pollutants are
 described in several EPA documents (USEPA 1979a,
 1979b, 1980,  1985b)  and Standard Methods for the
 Examination of Water and Wastewater (APHA,  1985).
 Analytical  techniques for  non-priority pollutants  can
 be  found  in  American  Society  for  Testing  and
 Materials  (ASTM)  manuals and  analytical chemistry
 journals such as  the Analytical  Chemistry  Journal.
 The selected analytical method should be verified  in
 the laboratory prior to sampling and analysis. Prior  to
 analysis,   a literature search should  be  made  to
 determine if the toxicant could be a biodegradation
 product resulting from POTW treatment. Where clear
 evidence  is available  to show that the  toxicant  is a
 treatment  by-product, the sewer  sample  should be
 analyzed for the precursor form(s) of the toxicant as
 well as the toxicant.

 In cases where Tier I  chemical tracking  is  successful
 in locating the IDs  that are responsible for the POTW
 effluent toxicants, the  TRE process can move  to the
 selection  and development  of  local  pretreatment
 regulations (Section 6). If the responsible ILJs can not
 be  located, the  TIE results should be reviewed to
 confirm previous conclusions. The chemical  analysis
 results should also be carefully reviewed to determine
 if errors  or wastewater  matrix  effects may have
 caused  inaccurate results.  In  cases where  the
 chemical-specific approach is  ultimately  not
 successful, the Tier  I testing should  be repeated
 using toxicity tests in lieu of chemical analysis as
 described  later in this section.
Pretreatment Program Review

It may be possible in a few cases to identify the toxic
influent sources by  comparing pretreatment program
information  on suspected influent toxics to chemical-
specific  data  on  POTW  effluent  toxics.  This
pretreatment program review  (PPR)  approach is
recommended only in situations where the POTW has
 only  a few  IDs which  have relatively non-complex
 discharges.

 The  PPR approach  was  applied at  the  Mt. Airey
 POTW in North Carolina  (Diehl and Moore,  1987)
 which receives  industrial wastewater from only a few
 sources,  predominately  textile  industries. In the Mt.
 Airey TRE, detailed information on the manufacturing
 processes  and wastewater  discharges  of  the
 industries  was  gathered (see  Table  2-2),  including
 data  on the toxicity and biodegradability of raw  and
 manufactured  chemicals  as  provided  in material
 safety  data  sheets  (MSDS). This information was
 used to  identify industrial  chemicals with  relatively
 high  potential  toxicity that may  be  present  in  the
 POTW effluent. Subsequent chemical analysis of the
 POTW effluent was  performed using  methods
 specifically designed  to  measure for  the suspected
 industrial  toxics. The chemical analysis results were
 compared with water  quality criteria and  toxicity
 values for individual compounds. Using this approach,
 alkyl  phenol ethoxylate surfactants,  phthalate esters
 and chlorinated solvents, largely  attributed to textile
 industries,  were identified  as the  primary  toxics
 causing the POTW effluent  toxicity.

 A description   of  PPR methods is  provided  in
 Appendix  A.  The methods  described involve a direct
 comparison of   IU chemical  data to  POTW effluent
 toxicity. It is important  to  emphasize that drawing
 preliminary conclusions based on  PPR results can be
 misleading, because IU monitoring information  could
 be incomplete,  chemical  analysis  techniques may not
 be sensitive  to low levels of effluent  toxics, and  the
 estimated  toxicity of individual  compounds  may  not
 reflect  the whole effluent toxicity.  Due  to  these
 factors,  comparisons of  suspected toxicants to
 effluent toxicity  may  yield  false   correlations.
 Whenever possible, results  of TIE testing should be
 used  in lieu of PPR results, because the  TIE. test
 directly measures the relative toxicity of  the effluent
 constituents.

 Refractory Toxicity  Assessment

 Influent toxicity tracking  is necessary when  TIE
testing  is  only  able  to  identify  a broad  class of
toxicants,  rather than specific  compounds,  that  are
causing the POTW  effluent  toxicity. Toxicity tracking
may also  be  required  in situations where there are a
large number of effluent toxicants  and  the occurrence
of these  toxicants  in the  POTW effluent  is  highly
variable. In this case toxicity testing  may  be  more
cost-effective than chemical  analysis.

The toxicity of influent wastewaters is  not necessarily
the  same  toxicity  that  is  observed  in the  POTW
effluent, because the  POTW is capable of  removing
or degrading toxic wastewater constituents. The level
                                                 5-3

-------
of toxicity  in  a  sewer discharge  which  could
potentially pass through the POTW must be estimated
by treating sewer samples  in a simulation  of the
POTW process prior to toxicity analysis. Based on the
experience to date, a simulation  of activated sludge
treatment has been developed  for  predicting the
potential  for a sewer discharge  to  contribute to the
POTW effluent toxicity. This treatment step accounts
for the toxicity removal  provided by the POTW.  A
toxicity  tracking  approach  can  be  applied  to  ID
discharges and sewer line wastewaters to locate the
sources  contributing either acute or  chronic toxicity
that is refractory to POTW treatment.

The  refractory toxicity assessment (RTA)  approach
involves  treating  sewer  samples  in  aerobic  batch
bioreactors and  testing  the  resulting effluents  for
toxicity. Batch bioreactors have been used by several
researchers to  screen  wastewaters for  activated
sludge inhibition (Grady, 1985, Adams et al.,  1981,
Philbrook and Grady, 1987,  and Kang et al.,  1983)
and  non-biodegradable  aquatic  toxicity (Dague and
Hagelstein, 1984, Lankford et al., 1987, and Sullivan
et al., 1987). Dague  and  Hagelstein  (1984) and
Lankford et  al.  (1987)  have found that toxicity
measurements coupled with bioreactor tests can be a
pragmatic  way to  evaluate  refractory  wastewater
toxicity.

The RTA  protocol  was  developed in the Patapsco
TRE (Botts et ai., 1987) to evaluate the  potential for
indirect  dischargers to  contribute  toxicity  that was
refractory to treatment provided by the POTW. This
protocol  involves  treating sewer samples in a bench-
scale batch reactor that is designed  to simulate, as
close as possible, the operating characteristics of the
POTW's activated  sludge  process (e.g.,  MLSS
concentration,  DO  level and  F/M). Acute  and/or
chronic  toxicity measurements of the batch effluent
indicate  the amount of refractory toxicity in the sewer
sample.  In the protocol,  coarse filtration of the decant
from the batch reactor is used to produce the  batch
effluent.  Decant-filtration  more closely simulates
sedimentation in  the full  scale plant because  batch
settling alone is not as efficient as the POTW settling
process.

A general  description  of  the   RTA procedure  is
presented as follows. A step by  step  protocol for
applying the  RTA  test  to  sewer  wastewaters is
provided in Table 5-1. It is important to note that the
RTA procedure  was developed  based  upon  the
experience to  date and additional  research  is in
progress to further refine the protocol. Public  works
managers should recognize that variations of the RTA
protocol can  be  used to  address  site-specific
circumstances.  Best professional  judgment will be
important in  applying  the procedures  and  in
interpreting the results.
Biomass Toxicity Measurement
During  the Patapsco TRE,  filtrate  from  coarse
filtration of the  POTW return activated sludge (RAS)
was found  to be acutely toxic to Ceriodaphnia (Botts
et al., 1987). The  high level of toxicity from  residual
biomass in the filtrate masked the measurement  of
batch effluent  toxicity,  and  thereby reduced the
effectiveness of  the  RTA  test  for  monitoring  ID
refractory toxicity. The existing data on the toxicity  of
sewage sludges is not sufficient  to  determine  how
widespread is  the  occurrence  of biomass  filtrate
toxicity.  The following discussion provides information
on how to proceed, if the  POTW biomass filtrate
toxicity presents an interference in the RTA test.

Additional testing was conducted during the Patapsco
TRE to  determine  if  the biomass toxicity interference
could be removed. TIE results found that the effluent
toxicity  was  caused mainly by  non-polar  organic
compounds which  preferentially adsorb onto  sewage
solids. Thus, tests were  performed to determine  if
solids  removal would reduce the Patapsco  RAS
toxicity. These  tests  demonstrated that toxicity in the
RAS coarse filtrate could be removed by filtering the
coarse  filtrate through a  0.2 pm  pore size  filter  to
remove colloidal material from the  liquid  (Botts et.al.,
1987).  Alternatively, centrifugation  of  the  coarse
filtrate at 15,000 xg  for 10 minutes also  substantially
reduced the  biomass toxicity.  Although  biomass
toxicity  can be  removed  by  applying these treatment
steps to  RTA  test  effluents, the  resulting  effluent
toxicity  will only indicate the soluble refractory toxicity
of the IU wastewater, instead of the total refractory
toxicity  (i.e., soluble and particulate).

Prior to conducting the RTA, aquatic  toxicity  tests of
the POTW activated  sludge should be performed  to
determine  if the sludge is toxic. This  testing  involves
filtering the activated sludge through  a coarse glass
fiber filter,  which is the same type of filter used for SS
analysis, and testing the filtrate toxicity (Mount and
Anderson-Carnahan,  1988a). If the biomass coarse
filtrate is observed to have toxicity that is equal  to or
less than  that of the  POTW effluent,  the  POTW
biomass can be used in  RTA testing. Small particle
filtration or centrifugation  of the resulting RTA batch
effluents will not be required.

If the biomass  coarse filtrate is observed to be more
toxic than the POTW effluent, the authors suggest the
use  of  a non-toxic biomass such  as another POTW
biomass or  a  commercially  available  freeze-dried
preparation. The non-toxic biomass will  not  be
acclimated to the  influent wastewaters of the POTW,
but  its use may allow  an estimate of the  non-
biodegradable  toxicity of the sewer  discharge. The
authors also recommend that the POTW activated
sludge  be used in a parallel series of RTA tests to
determine  the  amount of soluble  refractory toxicity in
the  sewer wastewater.  The  use of toxic POTW
biomass is suggested because it is acclimated to the
                                                  5-4

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Table 5-1. Tier I - Refractory Toxicity Assessment
 Biomass Toxicity Measurement:   •  •  •_"                                  •    -»                        , .
     *  Collects liters of fresh return activated sludge (HAS) and aerate vigorously for 15 minutes.
     •  Prepare glass fiber filter [same type used for SS analysis (APHA,  1985)] by rinsing two 50 ml volumes of high purity water through
        the filter.       .                                                     .                             ^r-j           M
     •  Filter RAS to.yield 200 ml of filtrate."
     •  Test RAS filtrate for acute toxicity using the procedure described by Mount and Anderson-Carnahan (1988a) or for chronic toxicity
        using the methods provided  by Horning and Weber (1985).
     •  Repeat above steps on several RAS samples.
     •  If RAS filtrate is  more toxic than the POTW effluent, obtain  non-toxic biomass  (e.g., another POTW biomass or a freeze-dried
        preparation)
 Sample Collection (volumes based on single sewer sample):
     •  Obtain 24-hour composite samples of sewer discharge (i.e., IU effluent or sewer line wastewater) and POTW primary effluent  Lag
        collection of primary effluent sample by the estimated travel time of sewer wastewater to POTW.  .
     •  Refrigerate 6  liters of sewer sample at 4°C until use.  Determine the maximum holding time by measuring sample toxicity over time
        using methods described by Mount and Anderson-Carnahan (1988a).                                                 .  .   .  ,
     •  Refrigerate 5  liters of primary effluent sample at 4°C'until use. Determine the maximum holding time as described above.
     •  Hold 3 liters of tap water for 2 days to dissipate chlorine.                 •                                     ;"             •
     •  Collect 10 liters of RAS (and non-toxic biomass) on day of test and aerate vigorously for 15 minutes before use.

 Sample Characterization (performed on day of sample collection):
     •  Analyze sewer wastewater for TKN, TP, TDS, COD, SCOD, pH.
     •  Use historical  ratio of COD/BOD5 of sewer wastewater, if available, to estimate BOD5.
     •  Prepare glass fiber filter as stated above. Filter RAS to yield 200 ml  of filtrate." Test filtrate for acute toxicity (Mount and Anderson-
        Carnahan, 1988a) or chronic toxicity (Horning and Weber, 1985).                                                         :.'
     •  Determine percent volume of sewer wastewater in POTW influent based on flow data.

 Sample Preparation:     .                  ,
     •  Add nutrients  to sewer sample to adjust BOD5/TKN/TP ratio to 100:5:1.
     •  Adjust pH of sewer sample to average pH value of POTW influent.
     •  Test  sample toxicity (Mount and  Anderson-Carnahan,  I988a) after nutrient addition and pH adjustment to determine if'these steos
        affect the sample toxicity.                                                                                             H

 Preparation of Batch Test Mixtures (three to six batch tests):
     •  Warm all refrigerated samples to  room temperature using 30°C water bath. Do not overwarm.                              .-••   .
     «  Select volume of  RAS (VB) to yield a MLSS concentration in 1.5 liters of batch  mixture that is equal to the average POTW MLSS
        If RAS is toxic (i.e., more toxic than POTW effluent), also select appropriate volume of nontoxic biomass (VNB).              ,    .' •
     •  Add RAS volume (VB) to three 2-liter beakers, add diffused air  (use air stone), and gently aerate. If RAS is toxic (i e  more toxic
        than POTW effluent),  add nontoxic biomass (VNB) to three additional beakers and aerate.
     e  Prepare 2 liters of synthetic wastewater solution using stock synthetic wastewater (Table 5-2) and the  tap water  Add volume of
        stock that will  yield a solution COD  equal to the primary effluent COD. Measure acute toxicity of the synthetic solution using  the
        procedure described by Mount and Anderson-Carnahan (1988a). Chronic toxicity can be measured using the methods described by
        Horning and Weber (1985).                                                                                           ,
     •  Measure sewer sample volume (VW) that will yield a percent volume in 1.5 liters equal to 10 times the nominal percent volume of
      :-.. sewer wastewater in the POTW influent.                                                                                 .

                                                                                                                  " (continued)"'
                                                             5-5

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Table 5-1.   Continued
 Performance of Batch Tests (total batch volume equals 1.5 liters):
     •  Add Vw and primary effluent to one beaker containing VB. If RAS is toxic (i.e., more toxic than POTW effluent), also add Vw and
        primary effluent to one beaker containing VNB.
     •  Add Vw and synthetic wastewater to one beaker containing VB. if RAS is toxic (i.e., more toxic than POTW effluent), also add Vw
        and synthetic wastewater to one beaker containing VNB.
     •  Add primary effluent to one beaker containing VB. If RAS is toxic (i.e., more toxic than POTW effluent), also add primary effluent to
        the remaining beaker containing VNB.
     •  Adjust aeration rate to allow complete mixing in all batch reactors. Periodically check DO level and maintain DO above 2 mg/l.
     •  Calculate the required reaction period necessary to achieve a batch F/M ratio (F/MB) equal to the nominal F/M ratio (based on
        SCOD) in the POTW.
     •  Periodically check the batch reactor pH. Adjust pH to 6-9 range, if necessary.
     •  Note: batch tests should be performed at room temperature.


 Effluent Toxicity Analysis:

     •  Slop aeration after the required reaction period and allow the VB  (and VNB) to settle for 15 minutes.
     •  Decant 200 ml of clarified batch supernatant from each beaker.  Rinse  glass fiber filters as stated above. Filter  each batch
        supernatant using separate filters.* Wash filter apparatus between each sample filtration using 10% HNO3, acetone and high purity
        water.
     •  Batch filtrates  that were  treated  with  toxic  biomass (VB) must be either filtered through prewashed  0.2 pm  glass  filters  or
        contnfuged at  10,000 xg for 10  to 15 min to remove colloidal size particles. Viscous mixtures may  require  faster or longer
        contnfugation (ASM,  1981).
     •  Prepare filter blanks for each filter type  using dilution water from toxicity test procedure.
     •  Analyze the batch filtrates, centrates, and filter blanks for acute toxicity using the procedure described by Mount and Anderson-
        Carnahan (1988a). Chronic toxicity can also be measured (Horning and Weber, 1985)
'Note:   Positive pressure filtering is required. Also, note that chronic toxicity measurement will require larger filtrate volumes as described by
        Horning and Weber (1985).
POTW influent wastewaters and will therefore provide
a level of batch  treatment that is more similar to the
treatment efficiency of the  POTW than that of the
unacclimated alternate biomass. In this  case, small
particle  filtration  or  centrifugation  is  required  to
remove  the  interfering  biomass   particles.   By
performing  RTA tests  with POTW biomass in parallel
with  RTA  tests  with  alternate  biomass,  both  the
soluble  and  total  refractory  toxicity of  the  ID
wastewater may be estimated.

Sample Collection
Wastewater and activated sludge samples  should be
collected according to the  procedures  described  in
Section  13.  Return  activated  sludge  (RAS)  is
recommended for use in batch  testing,  because  it is
in a  concentrated form that  can be  easily diluted  to
the  correct MUSS concentration. Mixed liquor from
the  POTW's aeration  basins  can be  used in lieu  of
RAS; however,  the  activated sludge  will need to be
thickened to the same SS concentration  as  that of the
RAS before use.

Sample Characterization and Preparation
The  sewer sample should be analyzed for total  and
soluble  COD,  total  kjeldahl nitrogen  (TKN),  total
phosphorus (TP), total dissolved solids (TDS) and  pH
on the day of sample collection. An estimate of the
sample BOD5 can be  calculated using historical data
on the COD/BOD5 ratio of the wastewater. Based on
these results, the BOD5/TKN/TP  concentration  ratio
of the sewer sample should be adjusted,  if necessary,
to 100:5:1  which is the typical  ratio  for municipal
sewage. This BODs/TKN/TP  ratio  will  ensure that
sufficient nutrients are available for consistent batch
treatment of the  IU  wastewaters.  Phosphorus should
be added in the form  of three  parts KH2PO4 to four
parts «2HPO4.  Nitrogen  should be added  as  urea
nitrogen.

Following  nutrient  addition,  the  pH  of  the sewer
sample should be adjusted to the average pH value of
the  POTW  influent.  Sulfuric  acid  and  sodium
hydroxide can be used for pH adjustment.

Following  nutrient addition  and pH adjustment,   the
sewer  sample  toxicity  should  be  measured   to
determine if the nutrients or  pH adjustment  cause a
change  in  sample  toxicity.  Substantial  differences
between the  initial toxicity  and  the adjusted  sample
toxicity may indicate the presence  of specific types of
toxicants. A discussion of the use of  pH adjustment
                                                      5-6

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 for toxicity characterization  is given by  Mount  and
 Anderson-Carnahan  (1988a).

 Preparation of Batch Test Mixtures

 The volume  of  RAS biomass (Ve), to be  used in
 batch  testing,  should  yield  a  batch  MLSS
 concentration  that is equal to the  average MLSS
 concentration  in  the POTW aeration  basins.  The
 amount of RAS to be added to the total batch volume
 of 1.5 liters is calculated as follows:
               _ POTW MLSS
             B ~   RAS SS
xl.5 liters.
The same equation is used to determine the alternate
(non-toxic)  biomass volume
A total of three batch influent solutions are prepared
for each  sewer sample: sewer  sample spiked  into
synthetic  sewage,  sewer sample  spiked into  POTW
influent (primary effluent) and primary effluent alone.
The synthetic wastewater provides  a standard  non-
toxic  substrate that will allow  consistent  batch
treatment of  the  ID wastewaters and  will  permit  a
determination  of the refractory  toxicity  of the  IU
wastewaters.  The  composition   of  this  synthetic
wastewater reflects  the  soluble  COD  (SCOD)  and
nutrient content of typical domestic sewage  (Table
5-2). Similar  synthetic preparations have  been used
as supplements in biodegradation  studies (Kirsh et.al.,
1 985) in lieu of domestic sewage.

   Table 5-2.    Synthetic Wastewater Composition*
    Constituent
                             Concentration (g/l)
    Bacto Peptone
    Beef Extract
    Urea
    NaCI
    CaCI2»2 H2O
    MgSO4.7 H2O

    KH2PO4
    K2HPO4
  32.0

  22.0

   6.0

   1.4

   0.8

   0.4

   3.5

   4.5
   'SCOD of the stock solution is 64,000 mg/l.

Prior to use in  RTA testing, the synthetic wastewater,
which has  an  SCOD of 64,000 mg/l,  is  diluted  in
dechlorinated tap water.  The  synthetic wastewater
should be diluted to  an  SCOD concentration that is
equal to  the average SCOD  concentration of the
POTW primary effluent. The  required stock synthetic
wastewater volume can be calculated as follows:
                            Stock Synthetic Wastewater Volume =

                                Primary Effluent SCOD
                                  64,000 mg/l SCOD
                                                      xl.5 liters
 The amount of sewer sample to  be used  in batch
 testing  should  reflect the  percent volume of sewer
 wastewater in the POTW influent. In some cases, the
 toxicity  in  sewer wastewater from small contributors
 may not be readily  observed when the wastewater is
 mixed by percent volume  with synthetic wastewater
 or  POTW  influent. Thus,  the authors recommend
 using a  volume of  sewer wastewater (Vw)  equal to
 ten times  the  percent volume of  sewer wastewater
 typically  found  in the  POTW influent. For example, if
 the sewer wastewater flow is 0.5 mgd and the POTW
 influent flow is  50 mgd, Vw would equal 10% of the
 batch influent  solution. In cases  where  the  sewer
 wastewater flow is > 10% of the POTW influent flow,
 the sewer sample would comprise 100% of the batch
 influent.

 Performance of Batch Tests
 In the batch tests, the sample/synthetic  solution  is
 used  to  measure the  refractory toxicity of the sewer
 sample. The sample/primary effluent solution  provides
 an  indication of the interactive effects  (e.g., additive
 or  antagonistic) that  can  occur  when  the sewer
 wastewater  and POTW influent  are  combined.  The
 third  batch  solution,  primary  effluent,  serves as a
 control  for the  sample/primary  effluent  test  by
 providing a measure of  refractory  toxicity in  the
 primary effluent.

 The batch influent solutions are mixed with RAS (VB)
 to yield a total batch volume of 1.5 liters and diffused
 air  is applied to  the  mixture. The diffused  aeration
 must  be performed in  appropriate laboratory fume
 hoods to prevent exposure of laboratory staff to  any
 toxic  vapors stripped  from the wastewater  samples
 (Section  11 ).The aeration  rate is adjusted to ensure
 complete mixing in the batch reactor  and to  maintain
 a DO concentration above 2 mg/l.

 The organic loading to the  batch reactors can vary
 substantially depending  on the  type  of sewer
 wastewater being  tested.  To  allow   comparable
treatment of the various  sewer wastewaters,  the
food-to-microorganism ratio of  the batch  reactor
 (F/MB) can  be  standardized  by  varying the  time of
 aeration.  F/MB  should be  made equal to the  F/M
 (based on  SCOD)  of  the  POTW bioreactors.  The
 required  batch  test  period can  be calculated  as
follows:

    ^ *D  • JfJ   •,   Batch InfluentSCOD(mg/Q
    Test Period (days) =	 :
                                                                             MLVSS(mg/l)xF/M
                                                                                                .B
                                                 5-7

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A typical test  period for a sewer  sample with COD
< 1000 will be appropriately 2 to 4 hours.
Toxlcity Measurement

Either  acute or chronic refractory toxicity can be
measured  in  RTA  testing.  Procedures for acute
toxicity measurement should  follow  the methods
described  by  Mount  and  Anderson-Carnahan
(1988a).  In order to  obtain comparable acute toxicity
results, RTA testing  should utilize the  same  species
that was used  for  TIE  tests.  Other  acute  toxicity
analyses  such as bacterial  bioluminescence  tests
(e.g., MicrotoxTM) can  be used  in conjunction  with
the  preferred  test  species to  provide additional
information. Chronic  toxicity testing should utilize the
same species that was  used for TIE testing.  Chronic
toxicity test methods are described by Horning and
Weber (1985).

The batch  test mixtures  are  prepared  for  toxicity
analysis  by  allowing the  mixed  liquors  to  settle,
decanting the clarified supernatant,  and filtering the
supernatant through a coarse  glass fiber filter. The
coarse filtration step is used to more closely simulate
the  POTW clarification process  because  the  batch
settling alone is not  as efficient as the  POTW settling
process.  If  toxic biomass  is  used in the RTA tests,
further particulate removal  is  required to measure the
soluble refractory toxicity in the sewer wastewater. In
this case, the coarse filtrate can be filtered through a
0.2  um pore size glass filter to remove colloidal size
particles from the wastewater. Membrane filters  such
as cellulose nitrate filters  are  not  recommended
because some soluble  organic  constituents  may
adsorb onto the filter.  Prior to sample  filtration,  all
filters  should be washed and filter blanks should  be
prepared using the  steps described in  Section 10.
Alternatively, the coarse filtrate can be centrifuged at
 10,000  xg  for  10   to 15  min to separate  colloidal
material from the wastewater (ASM, 1981).

Data Evaluation

 Results  of RTA testing are used to locate the sources
 that are contributing refractory toxicity to the POTW.
 A  discussion of the  evaluation of RTA results  is
 provided as follows.

 Results of RTA Tests if POTW Biomass is Non-
 Toxic -

 In  cases  where the  POTW  biomass  filtrate  is
 determined  to have toxicity that  is equal to or less
 than that of the POTW effluent, RTA tests will utilize
 POTW biomass and wastewater samples. Results for
 each  IU sample analysis will consist of data  on  three
 batch tests:  one test of sample/synthetic  sewage
 solution, one test of sample/primary effluent  solution,
 and one test of primary effluent. The batch test of the
sewer  sample/synthetic wastewater  solution  reveals
the  amount  of refractory  toxicity  in  the  sewer
wastewater excluding  the effects of other  influent
wastewaters.  Perhaps  the most important batch test
is  the  analysis of  the  sewer sample/primary  effluent
solution,  because  test data will indicate the toxicity
that  would realistically occur upon  mixture of  the
sewer  wastewater with POTW influent. Results of this
combined wastewater test are compared to results of
the  primary  effluent  batch test to  determine  if
combining the wastewaters  decreases the refractory
toxicity (i.e.,  antagonistic effect)  or increases  the
refractory toxicity  (additive   effect)  of  the  primary
effluent.

If  the  effluent  toxicity of the sewer sample/primary
effluent test is greater  than the  effluent toxicity of the
primary effluent test,  the sewer wastewater source
can  be presumed to  be a contributor  of refractory
toxicity. A list of toxic  sewer  sources  should  be
prepared  for further evaluation.  In  situations where
sewer  line tracking is  being  conducted, this  list  can
be compared to  a sewer collection system  map to
identify possible toxic ID dischargers on the sewer
lines.

Results of RTA Tests if POTW Biomass is
Toxic  -

In situations where  the POTW biomass  filtrate  is
found  to be more toxic than the POTW effluent, RTA
tests  will utilize  alternate (nontoxic)  biomass  and
wastewater in addition to tests  with POTW  biomass
and  wastewater. The data on each IU sample analysis
will  consist  of results of three batch  tests  using
alternate  biomass (i.e., one  test of  sample/synthetic
sewage, one test of  sample/primary  effluent,  and one
test of primary effluent); and results of three batch
tests using  POTW (toxic) biomass (i.e., using same
wastewaters  as above). The results  of tests  that use
alternate  biomass may provide an estimate  of non-
biodegradable toxicity  of the sewer  wastewater.  The
disadvantage of these tests  is that the biomass is not
acclimated   to the  POTW influent  wastewaters,
therefore the level of toxicity  reduction may not reflect
the  treatment  efficiency of batch  tests  using the
POTW acclimated biomass. Nonetheless,  the  non-
toxic  biomass tests  can give  an indication of the
relative level of refractory toxicity being contributed by
the  sewer wastewater  sources.

 Batch tests using toxic POTW biomass better reflect
the  treatment efficiency of the  activated  sludge
process;  however, manipulation of the batch effluent
 (i.e.,  centrifugation or small particle  filtering)  removes
 particles  that  normally  are  present in the POTW
 effluent.  Batch effluent treatment  is necessary  to
 remove   the  interfering toxic  biomass,  but  this
 treatment causes artificial  changes in  the  batch
 effluent toxicity. The advantage of toxic biomass tests
 is that  the soluble  refractory toxicity  of  source
                                                  5-8

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       wastewaters  can  be  determined.  The  nontoxic
       biomass tests cannot provide as good an estimate of
       soluble  toxicity,  because  this  biomass  is  not
       acclimated to the POTW influent wastewaters.

       RTA  tests which  utilize POTW  toxic biomass  and
       alternate biomass can provide information on both the
       soluble  and  total  refractory  toxicity  of  the  ID
       wastewater.  Further studies  are  in progress  to
       improve the utility of the RTA test for toxicity source
       evaluation.  These  studies  will  focus  on  the
       development of procedures to account for the toxicity
       interferences caused by toxic activated sludge.

       RTA Conclusions
       If  the RTA testing  is  successful in locating  the
       sources of refractory  toxicity,  further testing  is
required in  Tier  II  (Section  6)  to confirm the
suspected toxic  sources. Tier II testing is necessary
because Tier I information is not sufficient to proceed
to the evaluation and selection of pretreatment control
options  (Section  8).

In situations  where  RTA  testing proves  to  be  ,a
prodigious task,  the permittee may elect to evaluate
alternatives for in-plant toxicity  control (Section  7).
This choice may be determined by assessing the best
use of the resources that are available for the TRE.  In
this regard the POTW has the option to recover  costs
associated with toxicity source evaluation through the
process of local limits development.
•
                                                        5-9

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                                              Section 6
                              Toxicity Source Evaluation -  Tier II
Introduction
A Tier II evaluation is conducted to gather additional
information on the indirect dischargers to the POTW
to confirm the suspected sources of toxicity identified
in the Tier  I evaluation. Based  on the Tier I  data,
potentially toxic indirect dischargers are identified and
their wastewaters  are  sampled and analyzed using
the Tier II Refractory Toxicity Assessment procedure.
Like the  RTA step used  in the Tier I  evaluation, the
Tier II RTA estimates the toxicity that  is refractory to
POTW treatment and would therefore be expected to
pass through the POTW. The Tier. II RTA, however,
includes  several  additional  procedures for toxicity
assessment including:

   • a series of wastewater dilutions to determine the
     concentration of wastewater  at  which toxicity
     pass-through  would be expected to  occur at
     the POTW;
   • an  optional series of control tests  to allow  a
     comparison of the  relative  levels of  refractory
     toxicity and  inhibition effects  for the various
     sewer wastewaters; and
   • TIE Phase I  tests  of toxic  batch effluents to
     indicate the  components  of the  refractory
     toxicity.

A diagram of the Tier II  RTA is presented  in Figure
6-1. The step by step procedures for implementing
RTA tests are shown in Table 6-1.

The results  of the Tier II testing are  used to  rank
indirect  dischargers  in terms of  their potential  to
contribute inhibitory material or refractory  toxicity to
the POTW.  Results of the  optional   TIE  Phase  I
analysis  may also provide  important information on
the toxic components of  the sewer  wastewater. The
Tier II data are used  to identify the  major toxic
dischargers and to evaluate  pretreatment options for
controlling the discharge of toxics or toxicity by these
dischargers.  In situations  where existing pretreatment
regulations  (i.e., general, specific or categorical) are
insufficient for the  POTW to achieve  an  acceptable
level  of effluent  toxicity,  the  municipality  is
encouraged to develop local limits for its sewer users
(USEPA, 19873).
 Refractory Toxicity Assessment

 The procedures  for biomass toxicity  measurement,
 collection,  characterization and  preparation  of
 samples,  preparation  of  batch  test  mixtures,
 performance of the batch test, and batch test toxicity
 measurement are similar to those described  for Tier I
 RTA testing (Section 5). A description of the unique
 elements  and optional  steps  in the  Tier II  RTA
 procedures is provided as follows.


 Biomass Toxicity Measurement

 Results of  the  biomass  toxicity  measurement
 conducted in Tier I (Section 5) will dictate whether or
 not an alternative (nontoxic) biomass will be required
 for Tier II testing. If the POTW  biomass filtrate was
 found to be  less toxic than the POTW effluent in Tier
 I, only POTW biomass will be used in Tier II tests. If
 the POTW biomass filtrate was observed to  be more
 toxic than the  POTW effluent in Tier I, both the POTW
 biomass and a non-toxic  alternative  biomass will be
 needed for RTA testing in Tier II.


 Sample Collection, Characterization, and
 Preparation

 The procedures for collection,  characterization, and
 preparation  of samples  are the same  as  those
 described  in Section 5.  Sewer sampling locations for
 Tier II  testing are the  points of  discharge of the ID
 effluent to the sewer collection system.  If sewer line
 sampling was conducted in  Tier I, sufficient data
 should have been collected to identify the lUs  to be
 sampled for  Tier II.


 Preparation of Batch Test Mixtures

 The steps  for determining the  volume of  biomass
 (VB) and the  synthetic wastewater concentration to
 be  used in  batch  tests  are the same as  those
described for Tier I RTA testing (Section 5).  Because
 additional  dilutions  are performed in Tier  II  RTA
testing,  sufficient  biomass and synthetic wastewater
should be  prepared for seven  batch  tests (if the
 POTW biomass is non-toxic)  or fourteen batch  tests
                                                 6-1

-------
         Sludge Toxicity
            TCLP/EP
                                     Test Wastewater Selected from
                                     Tier I: Toxicity Source Evaluation
                                      Refractory Toxicity Assessment
                                    • Industrial Wastewater
                                       Dilution Series
                                    • Industrial Wastewater Spiked
                                       into Primary Effluent
                                    • Primary Effluent Control
                                    • Synthetic Sewage Control
                                    • Use POTW Acclimated Biomass
                                       (if toxic also use nontoxic
                                       biomass)
                                    • Use Same F/M as POTW
                                          Test Batch Effluents
Toxicity Pass-Through
   • Toxicity Test
Inhibition Testing
0 Oxygen Uptake
• COD Uptake
  Apply Phase I Toxicity
Characterization on Lowest
 IU Wastewater Dilution
                                      Confirm Specific Sources and
                                           Nature of Toxicity/
                                             Interference
                                         Toxicity Control Selection
        Figure 6-1.   Tier II: toxicity source evaluation (source ranking/pretreatment evaluation).
(if both toxic POTW biomass and non-toxic biomass
must be used).

Additional  IU  sample dilutions  are  performed to
determine the wastewater concentration that  causes
refractory toxicity to become apparent in the batch
test effluent. Three IU sample  volumes are used  in
RTA tests: one equivalent to two times the percent
volume of IU wastewater (Vw2) typically found in the
POTW influent; another equal  to five  times the
percent volume  of IU wastewater (Vws) in  POTW
influent; and  a third equal to ten times the proportion
of IU wastewater (Vwio) in POTW influent. In cases
where the  IU discharge flow is >20%  of the POTW
influent flow, the Vws and VWIQ  wi!l be 100% of tne
batch influent. If this occurs, the sample volumes can
be reduced to allow an appropriate range of  sample
dilutions to be tested.
                          Performance of Batch Tests

                          Tier II testing utilizes the same three types of influent
                          solutions applied  in Tier  I   RTA  tests:  IU  sample
                          spiked into synthetic sewage, IU sample spiked into
                          POTW primary effluent, and primary  effluent alone.
                          The difference between Tier  II and Tier I RTA testing
                          is that additional dilutions  of  IU sample are prepared
                          in Tier  II  using the synthetic  sewage  and  primary
                          effluent wastewaters. Also, extra volumes of the batch
                          influent  solutions  are   prepared  and   held  for
                          subsequent toxicity measurement.

                          The batch tests of the three types of influent solutions
                          provide  data on the level  of  refractory toxicity in  the
                          IU  wastewater. The sample/synthetic  solution  test
                          indicates the refractory toxicity of the IU wastewater
                          by  itself.  The sample/primary  effluent  solution
                                                   6-2

-------
         Table 6-1. Tier II - Refractory Toxicity Assessment
          Sample Collection (volumes based on single sewer sample):

               • Obtain 24-hour composite samples of IU discharge arid POTW primary effluent.  Lag collection of primary effluent sample by the
                 estimated travel time of ID wastewater to POTW.

               • Refrigerate 18 liters of sewer sample at 4°C until use. Determine the maximum holding time by measuring sample toxicity over time
                 using methods described by  Mount and Anderson-Carnahan (1988a).

               « Refrigerate 12 liters of primary effluent sample at 4°C until use. Determine the maximum holding time as described above.
               • Hold 9 liters of tap water for  2 days to dissipate chlorine.

               • Collect 10 liter grab sample of fresh return activated sludge (RAS) (and non-toxic biomass) on day of test and aerate vigorously for
                 15 minutes before use.
          Sample Characterization (performed on day of sample collection):
                 Analyze sewer wastewater for TKN, TP, TDS, COD, SCOD, and pH.

                 Use historical ratio of COD/BOD5 of sewer wastewater, if available, to estimate BOD5.
                 Determine percent volume of sewer wastewater in POTW influent based on flow data.

                 Prepare glass  fiber filters [same type used for SS analysis (APHA, 1985)] by rinsing two 50 ml volumes of high purity water through
                 each filter.  Filter 200  ml aliquots of samples of IU wastewater, primary effluent and RAS." Wash filter apparatus between each
                 sample filtration using  10% HNO3, acetone, and high purity water.

                 Test the filtrates of the IU wastewater, primary  effluent and RAS  for acute toxicity (Mount and Anderson-Carnahan, I988a) or
                 chronic toxicity (Horning and Weber,  1985).
P
Sample Preparation:

     •  Add nutrients to IU sample to adjust BOD5/TKN/TP ratio to 100:5:1.

     •  Adjust pH of IU sample to average pH value of POTW influent.

     •  Test sample toxicity (Mount and Anderson-Carnahan, 1988a) after nutrient addition and pH adjustment to determine if these steps
        affect the sample toxicity.


Preparation of Batch Test Mixtures (seven to fourteen batch tests):

     •  Warm all refrigerated samples to room temperature using 35°C water bath. Do not overwarm.

     •  Select volume of RAS (VB) to yield a MLSS concentration in 1.5 liters of batch mixture that is equal to the average POTW MLSS.
        If RAS is toxic (i.e., more toxic than POTW effluent), also select appropriate volume of non-toxic biomass (VNB).

     •  Add RAS volume (VB) to seven 2-liter beakers, add  diffused air (use  air stone), and gently aerate. If RAS is toxic (i.e., more toxic
        than POTW effluent), add non-toxic biomass (VNB) to seven additional  beakers and aerate.

     •  Prepare  2 liters of synthetic wastewater (Table 5-2) using the tap water. Add volume of stock that will yield a solution COD equal to
        the average primary  effluent COD. Measure acute toxicity of synthetic solution (Mount and Anderson-Carnahan 1988a). Chronic
        toxicity (Horning and Weber,  1985)  can also be measured.

     •  Measure IU sample volumes that will yield a percent volume in 1.5 liters equal to 2, 5,  and 10 times the nominal percent volume of
        IU wastewater in the POTW influent (VW2, VW5, VW10, respectively)



Performance of Batch Tests (total batch volume equals 1.5 liters):

    •••-  Mix VW2 and primary effluent (allow for excess of 200 ml). Add this mixture to one beaker containing VB. Keep the remaining 200
       , ml. If RAS  is toxic (i.e., more toxic than POTW effluent), also  add  additional VW2 and  primary effluent mixture to  one beaker
        containing VNB. Repeat these steps for VW5 and VW10.

     •:  Mix VW2 and synthetic wastewater (allow for excess of 200 ml). Add this mixture to one beaker containing VB. Keep the remaining
        200 ml.  If RAS is  toxic (i.e., more toxic  than POTW effluent), also add additional VW2 and synthetic wastewater mixture to one
        beaker containing VNB. Repeat these steps for VW5 and VW10.

     •  Add primary effluent to one beaker containing VB.  If RAS is toxic (i.e.,  more toxic than POTW effluent), also add primary effluent to
        remaining beaker containing VMB.
                 Adjust aeration rate to allow complete mixing in all batch reactors. Periodically check DO level and maintain DO above 2 mg/l.

                 Calculate the required reaction period  necessary to achieve a batch F/M ratio (FMB) equal to  the nominal F/M  ratio (based on
                 SCOD) in the POTW.

                 •Periodically check batch reactor pH. Adjust pH to 6-9 range, if necessary.

                 Note: batch tests should be performed at room temperature.

                 *-'- '                                                        '                                                 (continued)
                                                                       6-3

-------
Table 6-1.   Continued
 Inhibition Testing (optional - two additional batch tests).

     •   Prepare two synthetic wastewater solutions  using stock synthetic wastewater (Table 5-2) and tap water: one with an SCOD
         concentration equal to the average primary effluent SCOD and another with an SCOD level equal to that of the lowest sample
         dilution (i.e., VWio spiked into primary effluent).
     •   Add synthetic wastewater solutions to beakers containing VB- If RAS is toxic (i.e.,  more toxic than POTW effluent), also add
         synthetic solutions to beakers containing VNB-
     •   Perform batch tests in parallel with above batch tests.
     •   Subsample 300 ml from all batch reactors at 30 min. and every 2 hours following test initiation, and at the completion of the test.
         Upon  subsample collection,  immediately measure OUR using the BOD bottle method (APHA, 1985). Return the subsamples to
         the reactors immediately following use.
     •   Subsample 50 ml from all batch reactors at 5 minutes and ever 2 hours following test initiation, and at the completion of the test.
         Subsample SO ml of the original undiluted biomass stock. Filter the subsamples through a 0.45 u,m pore size filter. Measure the
         SCOD of the filtrates.


 Toxicity Analysis:

     •   stop aeration after the required reaction period and allow the VB (and VNB) to settle for 1 5 minutes.
     •   Decant 200 ml of clarified batch supernatant from each beaker. Prepare filters as described above. Filter the batch supernatants.*
         Rinse filtration equipment between sample filtrations as stated above.
     •   Batch filtrates that were treated with toxic  biomass (VB) must be  either filtered through  prewashed 0.2  pm glass  filters or
         centrifuged at 10,000 xg for  10 to 15 min  to remove colloidal size particles. Viscous  mixtures may require faster or longer
         centrifugation (ASM, 1981).
     •   Prepare filter blanks for each filter type using  dilution water from toxicity test procedure.
     •   Analyze the  untreated  solutions (batch influent), batch effluent and filter  blanks  for  acute toxicity (Mount  and Anderson-
         Carnahan, 1988a) or chronic toxicity (Horning and Weber, 1985).
 Phase I Toxicity Characterization (Optional)

     •   The batch effluent of the Vwio/synthetic wastewater test should be used for Phase I analysis. Phase I testing requires 3.5 liters
         for analysis, therefore the volume used in batch testing should be increased to a minimum of 7 liters.
     •   Following batch treatment, allow the VB (and VNB) to settle for 1 hour. Decant 3.5 liters of supernatant.
     •   Prepare coarse glass filters (SS type only) as described above. Filter the batch supernatant.*
     •   Analyze the batch effluent using the Phase I protocol (Mount and Anderson-Carnahan, I988a).
"Note:     Positive pressure filtering is required. Also note that chronic toxicity measurement will require larger sample volumes as described
          by Horning and Weber (1985).
provides  information on  the  possible  interactive
effects (e.g.,  antagonism,  additivity)  that  may occur
upon  mixture of  the ID  wastewater  and  the POTW
influent.  The  third batch  influent,  primary  effluent,
serves as  a  control  for  the  sample/primary  effluent
test by providing  data on the  refractory toxicity of the
primary effluent alone.

Following mixture of  the  batch  influents  with  the
biomass, the mixed liquors are aerated for a period of
time that will allow  comparable treatment of  the
sample dilutions.  Because the organic loading to the
batch  reactors  can  vary depending  on the  sample
concentration, the F/MB  should  be  standardized  by
varying the  time of aeration for each  sample  dilution.
The  procedure for calculating  the required reaction
period based on F/MB is described in  Section 5.
Inhibition Testing (Optional)

Biological treatment  inhibition can  be  assessed  by
monitoring  substrate (COD)  removal  and  oxygen
uptake rates  in  the  batch  tests  and comparing the
results of the IU sample batch tests to  the results  of
the  synthetic  wastewater  batch  tests.  If  COD   or
oxygen  removal rates in  ID  sample tests  are lower
than  those  in synthetic wastewater tests, biological
inhibition is  indicated.

Inhibition testing  requires  two  additional  batch
reactors  consisting of synthetic sewage  and biomass:
one  with a synthetic sewage SCOD  concentration
equal to  the  average   primary  effluent SCOD  and
another with a synthetic sewage SCOD  concentration
equal to the  SCOD level  of the  lowest  IU  sample
                                                        6-4

-------
dilution (i.e., Vwio spiked into primary effluent). The
two  synthetic  wastewater concentrations effectively
bracket the highest  and lowest  expected  SCOD
loadings to the batch reactors. This  range of  synthetic
sewage concentrations is necessary to compare COD
and  oxygen removal  rates  for  the wastewater
dilutions,  because COD and oxygen utilization  usually
increase  with increasing  wastewater strength. At high
soluble substrate concentrations (i.e., 1 mg/l SCOD to
4 mg/l MLVSS) the biomass activity  generally reaches
a maximum  rate. At soluble substrate concentrations
below this "plateau,"  biomass activity rates vary with
substrate concentration.  Thus, the  soluble substrate
concentrations  of the  ID sample tests  and the
synthetic sewage tests  must  be similar  to  allow an
accurate  comparison  of  COD and  oxygen utilization
rates for inhibition measurement.

Soluble COD removal  can be  used  as an indicator of
specific substrate  removal rate  (SSUR). SSUR  is
reported in units of mg/l  SCOD/g MLVSS/min, and is
calculated as shown in an equation  at the end of this
page.

The  POTW  biomass  used in  batch testing  contains
nonbiodegradable SCOD remaining from biological
treatment which must  be  accounted  for when
calculating the  SCOD of the batch effluent. This
correction for biomass SCOD  is calculated as shown
in an equation at the top  of the next  page.

Specific oxygen  uptake  rate  (SOUR) is reported  in
units of mg  02/l/g  MLVSS/min and is calculated as
follows:
  SOUR =
                      Oxygen Consumed
           MLVSS xD.O. Measurement Period (min)

The SSUR and SOUR data for the IU sample dilution
series and the two synthetic sewage tests  are plotted
against the SCOD  of the batch influent solutions. A
reduction in the  SSUR  and  SOUR rates of the IU
sample tests relative to the SSUR and SOUR rates of
the  synthetic control  tests (for samples  with
equivalent batch  influent  COD  concentrations)
indicates the presence of inhibitory  material in the IU
wastewater. The  degree of inhibition can be inferred
by the amount of  deviation  in the  biomass  activity
rates for IU sample tests compared to the biomass
activity rates for the control rates.

Toxicity Analysis
The  procedures  for  acute  and  chronic  toxicity
measurement of  the RTA samples  are the same as
 those described for Tier I  (Section 5). In addition  to
 the batch  effluent samples,  the batch  influent
 solutions are measured for  toxicity.

 Phase I Toxicity Characterization
 Phase I  tests can be applied to the batch effluent  of
 the lowest  dilution of  the sewer wastewater  in
 synthetic sewage  (i.e., highest wastewater strength).
. The purpose of this analysis is to determine the types
 of  toxicants causing refractory toxicity  in  the  IU
 wastewater. Results of  Phasp I  testing  can  be
 compared  to TIE results on  the POTW effluent  to
 indicate  whether or not  the  IU wastewater  contains
 refractory toxicants  that  were  also observed  in the
 POTW  effluent.  A  description  of  the Phase  I
 procedure is given in Section 4.

 Data Evaluation

 Results  of the Tier II evaluation are used to confirm
 the sources of the refractory toxicity identified  in  Tier
 I. Tests of the series of dilutions of the  IU wastewater
 samples can indicate the wastewater concentration  at
 which toxicity passthrough would  be expected  to
 occur at the POTW. This information can be used  to
 identify the  major contributors of  refractory toxicity  to
 the POTW.
 Results of RTA Tests if POTW Biomass is Non-
 Toxic --

 In  cases where  the  POTW biomass  filtrate is
 determined to be less toxic than the POTW effluent,
 RTA tests will utilize POTW biomass and wastewater
 samples. Results  for  each IU sample  analysis will
 consist of data on  seven batch tests: three tests of
 sample/synthetic  sewage  dilutions,  three tests of
 sample/primary effluent  dilutions,  and  one test of
 primary effluent.

 Sample/synthetic  sewage  tesf--The  batch tests of
 the series of IU sample/synthetic sewage dilutions;will
 reveal the  IU  wastewater concentration that causes
 toxicity to occur in the batch effluent. For example,
 batch  effluent  toxicity may  become apparent in tests
 of IU wastewater at sample concentrations five times
 the  wastewater  concentration  (Vws)  typically
 observed in the POTW influent,  but not at sample
 concentrations two times  the typical  wastewater
 concentration   (Vw2)-  In  this case toxicity  pass-
 through  occurred somewhere between two and five
 times the IU wastewater concentration typically "found
 in the POTW influent.
                            Batch Influent SCOD (mg/l) - Batch Effluent SCOD (mg/l)
                   oo UK = 	—	——•
                                       MLVSS (mglt) x Test Period (min)
                                                6-5

-------
                SCOD =
                          [ (VJx (SCOD Batch Reactor Effluent)] - [ (VJ x SCOD biomass)]
                             K                                      o
where VR is the total volume in the batch reactor,
and VB is the volume of RAS added to the reactor.

The relative amounts of refractory toxicity contributed
by the IDs can be determined by accounting for the
discharge flow of each of the tested IDs. The first
step is to convert the 48-hour LCso  values for each
sample  dilution to toxic units  (TU) by multiplying the
reciprocal of each LCso value  by  100  (i.e., 100/LCso).
The  toxic units  for  each sample dilution  series are
then summed and the total toxic units are  multiplied
by the  flow rate of  the  IU  discharge.  An  example
calculation is described below.

                                Sample Dilution
                              (Times  Percent Flow in
                                 POTW Influent)
  Batch effluent LCSO
  (as percent effluent):

  Batch effluent toxic units
2X

50
5X

30


3.3
10X

 10


 10
 Relative Score s Sum of TUs x IU Discharge Flow Rate,
     where sum TU ** 15.3, and
     IU Discharge Flow Rate = 1  mgd.

 Thus, the ID relative score  is:
     15.3 TU x 1 mgd  = 15.3 TU - million gal/day.

The relative scores of  the IU wastewaters are ranked
to  determine the major  contributors  of  refractory
toxicity. Although the relative score is in units of TU-
million  gal/day, it does  not  represent the  actual
toxicity  loading of the IU  wastewater.  Instead, the
relative score is an  estimate  for  comparing the
relative  levels of refractory toxicity contributed  by the
lUs.

Samplefprimary effluent fesfs—Resuits  of  the  batch
tests of the  series of  IU  sample/primary effluent
dilutions will  indicate the IU  wastewater concentration
that causes  refractory  toxicity to occur upon mixture
of the wastewater with POTW influent. These tests
are an  attempt to measure  the effects of  mixing the
IU wastewater with the POTW influent wastewater, as
would realistically take place in  the POTW influent.
Combining  the  wastewaters  may decrease the
refractory toxicity (i.e.,  antagonistic effect) or increase
the refractory toxicity  (i.e.,  additive effect)  of  the IU
wastewater.

The relative  level  of refractory toxicity contributed by
the lUs can be determined by calculating  a relative
score using the  batch  effluent  LCso f°r  each IU
sample  as described above.  This  relative  score will
account for  the antagonistic or additive toxic effects
 VR

that  may  occur upon  mixture  of the  IU  wastewater
with  the  POTW influent. Relative scores  for the lUs
can  be ranked to identify the major contributors of
refractory toxicity.

The  ranking of lUs based on the IU sample/primary
effluent tests is preferred over the  IU  ranking  based
on the IU  sample/synthetic sewage tests, because the
IU wastewater/primary  effluent  mixture better reflects
the composition of the  POTW influent. The IU ranking
can  be   used  to  determine  which  major  toxic
dischargers  should be  targeted  for  pretreatment
control.

Results of RTA Tests if POTW Biomass is
Toxic —

In situations  where  the  POTW  biomass filtrate is
found to  be more toxic than the POTW effluent, RTA
tests will  utilize  alternate (non-toxic)  biomass  and
wastewater in addition to tests with POTW biomass
and wastewater. The data on each IU sample analysis
will  consist of results  of seven batch tests  using
alternate biomass (i.e.,  three tests of sample/synthetic
sewage  dilutions,  three tests of  sample/primary
effluent dilutions, and one test of primary effluent) and
results of seven batch tests using POTW biomass
(i.e., using same wastewaters  as above). The batch
effluent results  of  tests  using POTW biomass will
indicate soluble refractory toxicity, because the toxic
biomass  particles  are  removed  (via filtration  or
centrifugation)  prior  to toxicity  analysis.   Batch
effluents  of tests using  alternate  biomass do not
require treatment for toxic particle removal, therefore,
the  batch effluent  results  will   reveal the  total
refractory toxicity of the IU wastewater.

Batch tests  using POTW to/omass--Batch  tests
which  utilize  POTW (toxic) biomass will  provide  an
indication of  the  soluble refractory  toxicity of the IU
wastewater.  The relative  contribution  of  soluble
refractory toxicity from  the lUs  can  be determined by
calculating relative scores for the IU sample/synthetic
sewage  dilution  tests  and  the  IU sample/primary
effluent dilution tests.

Batch tests  using alternate  b/omass--Batch  tests
that  utilize an  alternate  (non-toxic)  biomass provide
data on the total refractory toxicity (i.e.,  soluble and
particulate) of the IU wastewater. These tests are an
indirect measure of refractory toxicity because  an
alternate  biomass is   not  acclimated  to  the  POTW
influent wastewaters and the level of toxicity reduction
that  can be achieved by an unacclimated biomass will
not  be  the  same  as  that  achieved  by  POTW
acclimated  biomass.  In some  cases,  the  batch
                                                    6-6

-------
 influent  may  partially or completely  inhibit  toxicity
 degradation  when  unacclirhated  biomass  is used.
 Nonetheless,  batch tests utilizing  alternate  biomass
 may  give a relative estimate of,  the  level  of total
 refractory  toxicity contributed  by  Ills. The   relative
 contribution of refractory toxicity from the ILJs can be
 determined by calculating  relative  scores for the IU
 sample/synthetic sewage dilution tests and  the  ID
 sample/ primary effluent dilution tests.

 Toxicity  measurement  of  batch  influent
 so/uf/ons--The  batch  influent  solutions are  also
 measured  for toxicity to provide information  on the
 toxicity of the raw  (untreated)  IU  wastewater. This
 information can  be  used  together with the  batch
 effluent data on soluble and total refractory toxicity to
 identify the major toxic IDs.

 Results of Optional Inhibition Testing -

 The optional analyses for  wastewater  inhibition can
 also provide useful  data.  RTA  information  on  the
 potential for a  wastewater  to  inhibit biomass  activity
 can be  used ,to identify III  wastewaters that may
 interfere with the POTW biological treatment process.
 This information is  important  in  situations  where
 inhibitory  wastewater may  interfere with the  normal
 operation  of  the  biological  treatment process to the
 degree that it causes toxicity passthrough.

 Results of Optional TIE Phase I Testing -

 Phase  I analysis of  the batch treated wastewater can
 indicate the  types  of toxicants responsible  for  the
 refractory toxicity in the  IU wastewater. A comparison
 of these Phase I results with  the results of  the TIE
 analysis of the POTW effluent  will indicate whether or
 not the IU wastewater toxicants are the same types of
 toxicants observed  in the POTW effluent. lUs which
 discharge the same types of toxicants as those found
 in the  POTW effluent  should,  be candidates  for
 pretreatment control  evaluation.

 Pretreatment Control Evaluation

 Pretreatment control options can be developed by the
 POTW  to  prevent  the  pass-through of toxics and
toxicity, and treatment interferences, which have been
traced  to indirect dischargers. In  cases where current
pretreatment regulations are insufficient for the  POTW
to achieve  an acceptable level of effluent toxicity, the
municipality should  develop  local limits  for its sewer
users (USEPA,  1987a).

The  EPA  Local  Limits  Guidance Manual  (USEPA,
1987a) describes several technical approaches to the
development  of  local limits. These  approaches are
outlined as follows:

    •	Allowable Headworks  Loading  Method:
       Numeric limits are  defined based on the
       maximum loadings of pollutants that will allow
       compliance  with  receiving  water  quality
        criteria or sludge quality criteria, or protection
        against treatment interferences.
     •  Industrial  User Management Method: .Based
        on  an in-depth  review of IU practices the
        municipality  can  set narrative  limits for
        chemical  management practices  (e.g.,
        chemical  substitution,  spill  prevention  and
        slug loading control).
     •  Case  by Case Permitting: Technology-based
        limits are established based on levels that can
        be  feasibly  and economically achieved  by
        comparable industries.

 Some of the local limits approaches address specific
 issues  of concern related to toxics  or  toxicity. For
 example, the allowable headworks loading method  is
 well-suited  for  developing  limits to  prevent  the
 pass-through of toxic compounds identified by Tier I
 chemical-specific analysis  or by  POTW effluent TIE
 tests. This  method can be used to establish  the
 maximum level  of the toxic  pollutant that  can be
 safely received by the POTW without exceeding the
 effluent toxicity limit.

 The industrial user management  method  provides  a
 framework  for  implementing chemical  management
 practices including slug  discharge control.  In cases
 where IU  slug loadings contribute to POTW effluent
 toxicity, spill prevention  or load  equilization can be
 implemented at  the IU facility  to moderate the slug
 loadings. EPA's Slug Loading Control Manual (1988b)
 describes  methods for the  development  of  slug
 loading control programs.

 The case by  case permitting method can  be used
 when the POTW  effluent toxicity  cannot be traced to
 specific IU  chemicals, but information on the general
 classes of toxicants is available based on TIE results.
 In this case an engineering decision can be made in
 selecting a  pretreatment technology  for  removing
 general types of  toxicants  (i.e.,  non-polar  organic
 compounds). In  situations where the  sources of
 toxicity  have been identified,  the  POTW  has  the
 authority to  require the IU  to take steps to limit ,the
 discharge of refractory or inhibitory toxicity.

 Although EPA and the states have overview authority,
 the choice  of which technical  approach to  use for
 local limits development is the POTW's decision. The
 information  to  be used in  the  development  of local
 limits will include the data  gathered  in the TIE and
 toxicity source evaluations (Tier I and II). Methods for
 calculating  numerical limitations  and  preparing
 narrative limitations are described in the EPA Local
 Limits Guidance Manual (USEPA,  1987a). The goal in
developing  local  limits  is to implement pretreatment
 regulations that are technically and legally defensible.
The  local limits can include provisions for equitable
recovery of costs associated  with the toxicity source
evaluations and local limits development.
                                                 6-7

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                                               Section 7
                               POTW In-Plant Control Evaluation
Introduction

The objective of the in-plant control  evaluation is  to
select and evaluate feasible treatment options for the
reduction  of  refractory  toxicity   and/or  toxic
interferences  at  the  POTW.  Treatment options are
selected using the data gathered in the PPE (Section
3)  and  TIE  (Section  4) investigations  and  best
professional judgement. Following  this   selection
process, treatability testing is conducted to determine
the  toxicity  removal  effectiveness  and   operating
characteristics of the treatment options. The resulting
test data provide a  basis for the final  selection and
conceptual  design  of  feasible  POTW  process
modifications or additions.

A schematic of  the POTW in-plant control evaluation
is  presented in Figure 7-1.  Toxicity  control  options
are selected based on evidence that the options are
technically feasible and can  be integrated  into the
overall  design  of the treatment facilities.  Following
selection, the options are evaluated in bench-scale
tests which utilize acute  or  chronic toxicity tests  or
toxic chemical  analyses to evaluate the feasibility  of
the option for toxicity and/or toxics reduction. In some
cases,   pilot-scale  testing  may be  conducted  to
provide information for the design of  the  treatment
option.  An  optional  TIE  Phase  I  analysis  may  be
performed  to  evaluate  the  removal   of  selected
toxicants by the treatment option.

It is  important  to consider  that major changes  in
treatment plant  facilities  or  operations  may  not be
feasible  due to  the  cost of new facilities  or the
complexity of additional process  operations. In these
situations,  pretreatment  control  of toxicity  may  be
preferred to  in-plant control.

Selection  of Treatment Options for
Testing

The information  collected in the PPE  and TIE stages
of the  TRE is  reviewed and  evaluated  to select
possible feasible in-plant options  to  be  tested  in
treatability  studies.  The first step in  the  selection
process  is  to review  the PPE data on the POTW
design to establish the physical space available for
                            Select
                          Treatment
                          Options for
                            Testing
      Sludge
Bench Scale or Pilot Scale
    Treatability Test

Test Modification of Existing
   Process or Evaluate
    Additional Process
                                  Effluent
                          Toxicity Pass-
                         Through and/or
                          .Interference
                           (Optional)
                         Phase I Toxicity
                         Characterization
                     Toxicity Control Selection
 Figure 7-1.  POTW in-plant control evaluation.


new process  additions and to determine the  idle
facilities and equipment that could be used for toxicity
                                                    7-1

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control.  In addition, information on POTW operations
and maintenance should be reviewed to determine if
the POTW is capable of meeting the increased
operational control that may be required with  process
modifications  or additions. This  PPE information can
be compared  to the  TIE data to  identify  potential
control  options, and  to  determine  how the control
options  can  be integrated into the overall treatment
system design.

Secondly,  TIE Phase I data on the classes of effluent
toxicants  can be  used  to  select options  to  be
examined. For  example,  if  non-polar  organic
compounds  are frequently  observed to  be the
principal effluent toxicants, possible options would
include  granular media filtration, activated  carbon
adsorption,  or coagulation  and  precipitation. TIE
results on  specific effluent toxicants, which have been
identified and confirmed in Phases II and III, can also
be  used  to  determine  possible  in-plant  control
options. Although results on specific toxicants are well
suited for the application  of pretreatment  control
limitations, the municipality may choose to evaluate
in-plant  control of these  toxicants. An example  of
this case  is the treatment of  ammonia  by optimizing
the POTW activated sludge process (e.g.,  increase
MCRT) to  achieve nitrification. Wherever possible, the
in-plant  control evaluation should  be  performed  in
conjunction with the pretreatment control evaluation
to identify the  most  technically feasible and  cost-
effective control option.

In-plant  toxicity  control  may be achieved  by
enhancement of the existing treatment  system  or by
the implementation of  additional  treatment processes.
Possible in-plant  control  alternatives  for  different
categories of  toxic  compounds  are summarized  in
Table 7-1. A  description of these control alternatives
is provided as follows.

Process Enhancement

Biological Process Control

Biological  process  control is  generally limited  to
activated sludge  systems, although  some
modifications  to fixed film processes  (e.g.,  trickling
filters and rotating  biological contactors)  may be
feasible.  The  performance of  activated  sludge
systems is generally controlled  by  adjusting one  or
more of  three  process parameters: mean cell
residence  time, mixed liquor suspended solids and
food-to-microorganism  ratio.  The treatment
efficiency  of  the  activated sludge  system, and the
activated  sludge characteristics, are  controlled by
varying  these interrelated process  parameters.  A
description of the  use of  these  parameters for  toxics
control is provided as follows.
Mean Cell Residence Time -

Removal of  biodegradable  toxic  compounds  in
activated sludge  treatment may be improved by
increasing the MCRT (Adams et.al.,  1981).  MCRT
can  be increased  by lowering the  excess sludge
wasting rate.  Longer MCRTs  result  in an  increased
sludge  age  which  can   be beneficial  for  the
biodegradation of some types of organic compounds.

Mixed  Liquor Suspended Solids  -

High MLSS concentrations have been  shown  to
minimize the  effects of  inhibitory  pollutants on
activated sludge treatment  systems  (WPCF,  1976).
High MLSS concentrations  increase  the potential for
biodegradation and  sorption  of  toxic wastewater
constituents, and can aid in protecting the treatment
process from shock loadings.

Food-to-Microorganism  Ratio  —

A  decrease in F/M  (based  on   BODs)  effectively
decreases the organic  waste loading per  unit  of
biomass  which may  improve the biodegradation  of
toxic compounds (Adams et.al., 1981). The F/M  ratio
is  inversely related  to MCRT  and is an  alternative
parameter for controlling  activated sludge treatment.

Biological  process  control is not  as  easily
accomplished for  fixed film  processes,  such as
trickling filters or  RBCs. Some adjustments  can be
made,  however,  such as  varying the amount  and
point of wastewater recirculation in a trickling filter, to
increase the removal of  toxic pollutants. In addition,
secondary clarifier effluent  can  be  recirculated  to
dilute high-strength  wastes prior  to  treatment  in a
trickling  filter  or  RBC.  In some cases  inhibitory
pollutants may cause excessive sloughing of the  fixed
film  biomass.  This problem   may  be rectified by
returning thickened  secondary clarifier solids  to the
fixed film process to help maintain a  proper biomass
population.

Chemical Addition

The addition of  chemicals   or  additives  to
wastestreams in existing POTW treatment processes
can be  used  to improve pollutant removal. Nutrients
can be added to influent  wastewaters, which have low
nutrient levels relative to their carbonaceous content,
to  improve  biological treatment. Lime or caustic can
be used to adjust wastewater pH for optimal biological
treatment  or for coagulation   and precipitation
treatment. Other chemical coagulants are used to aid
in removal of  insoluble toxic pollutants and to improve
sludge settling. Powdered  activated carbon may be
applied  in activated sludge  systems to remove  toxic
organic compounds. A description of each of these
wastewater treatment additives is provided as follows.
                                                 7-2

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                 Table 7-1.   POTW In-Plant Control Technologies for Categories  of Toxic
                            Compounds
                     Biodegradable
                       Organic
                    Compounds and
                      Ammonia
Non-Biodegradable
     Organic
   Compounds
Volative Organic
  Compounds
 Heavy Metals and
Cationic Compounds
                  Biological Process    Filtration
                  Control
                 Biological Process
                 Control
                    Filtration
Nutrient Addition
Activated Carbon Aeration
Coagulation/
Precipitation
Coagulation/
Precipitation
pH Adjustment
Nutrient Addition -

Addition  of  phosphorus, nitrogen  or sulfur may  in
some cases improve biological treatment of industrial
wastewaters  with low nutrient concentrations.
Improved treatment  is  attributed  to correcting  a
nutrient deficient  condition resulting from a high
industrial to domestic wastewater ratio. The optimal
BOD5/N/P  ratio  for  municipal  activated sludge
treatment is 100:5:1.
pH  Adjustment  —

Lime and caustic addition can  be used  to increase
influent wastewater pH prior to primary sedimentation
to enhance  the precipitation of heavy metals.  Some
metals, however, such as iron and chromium will go
into solution rather than precipitate at alkaline pH. The
optimum  pH range for metals precipitation varies for
each type  of  metal  and the solubility/precipitation
equilibrium can be  affected by other factors such as
dissolved  solids concentrations  in the  wastewater.
Lime and  caustic can also be  used to  provide the
alkalinity necessary for efficient biological treatment.


Coagulant  Addition —

Polymers and inorganic coagulants such as alum and
ferric  chloride  can be  introduced  to  POTW
wastestreams  to help remove  insoluble pollutants.
Coagulants can  be  added to  POTW  influent
wastewater  to increase  the sedimentation  of  toxic
constituents  in primary treatment and  thereby
minimize  the  loading of toxic  pollutants  on  the
biological treatment process. Coagulants can also be
added  after  the  activated sludge aeration basins to
control sludge bulking or reduce effluent suspended
solids. The optimum conditions for coagulation can be
determined by conducting jar tests.  These tests are
used  to  establish the optimum  coagulant type  and
dose,  the  proper mixing  requirements,  and  the
flocculant settling rates for treatment  (Adams et al.,
1981).
                  Coagulants can adversely affect the characteristics of
                  sewage sludges and could thereby  alter  ultimate
                  disposal  methods.  Coagulants may  increase  the
                  toxicity of the sludge (as measured by TCLP) as a
                  result of the removal of toxic wastewater constitutents
                  or  as a result of the toxicity of the coagulant itself.
                  Thus, coagulants should be carefully evaluated prior
                  to use.

                  Activated  Carbon  --

                  The addition of powdered activated carbon (PAC) to
                  an  activated sludge unit can increase the removal of
                  toxic organic  chemicals. Organic  pollutants  that  are
                  not biodegraded can  be removed  by adsorption onto
                  the surfaces of activated  carbon particles. Activated
                  carbon  also improves sludge settleability by providing
                  dense  nuclei onto  which   sludge  floes  can
                  agglomerate.  The PAC process has  been  used in
                  municipal   wastewater treatment;   however,  recent
                  studies have  shown  (Deeny et.al.,  1988) that PAC
                  regeneration by wet-air oxidation  breaks  down  the
                  activated carbon particles to carbon fines, which carry
                  over the  secondary  clarifier weirs. In some cases
                  periodic additions of PAC to an aeration basin can be
                  used to minimize  the effects of toxic  slug  loadings
                  and thereby improve  the  stability  of  the activated
                  sludge system.

                  Additional Treatment

                  Where  process enhancement is not. feasible or  will
                  not provide adequate toxics removal, physical addition
                  to or modification of  the POTW can be undertaken.
                  Additional  treatment  processes  could   include
                  equalization prior  to  treatment,  instrumentation
                  control,  and  advanced   wastewater  treatment
                  processes such as coagulation/flocculation,  granular
                  media  filtration, and  granular activated  carbon
                  treatment.

                  Equalization
                  Equalization can be used prior to biological treatment
                  units to dampen the effect of slug  or diurnal loadings
                                                 7-3

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of high-strength  industrial  wastes.  Equalization
facilities  can  be  provided to  either  equalize
wastewater flows or wastewater concentrations. Flow
equalization  is partially provided by existing primary
sedimentation  tanks  and can  be  enhanced  by
increasing  the  size of  the  primary  tankage.
Concentration  equalization requires mixing  of the
wastewater to  moderate  intermittent  pollutant
loadings,  and  thus  separate  facilities  must  be
provided.

Instrumentation Control
Instrumentation/monitoring can  be used to  help
control  slug loadings  of toxic constituents  in the
POTW  influent wastewater.  For  example, transient
metals loadings  may  be  controlled  by   continuously
monitoring the  pH  and  conductivity of  the  influent
wastewater. A significant decrease in  pH  or  an
increase in conductivity may indicate a slug loading of
toxic  material  (e.g.,  heavy metals).  If this situation
occurs,  the  influent flow  can  be  manually  or
automatically diverted to a holding basin  until  the  pH
and conductivity in the influent return to normal. At
that  time, the  diverted  wastewater can be  slowly
added to  the influent  wastestream in such a manner
that the pollutant concentrations  are diluted prior to
treatment.

Advanced Wastewater Treatment

POTWs that  only utilize  primary  and  secondary
wastewater treatment may achieve toxicity or toxics
reduction  by the  addition  of advanced  wastewater
treatment process  such as  coagulation/flocculation,
sedimentation, granular media filtration,  and granular
activated  carbon.  Each  of  these  processes  can
provide enhanced removal of constituents which may
be causing effluent toxicity.

Treatability Testing

Bench-scale and pilot-scale treatability  tests are
commonly  used  to  simulate treatment options
selected  for  wastewater  testing.  Bench-scale  or
pilot-scale tests offer several advantages  compared
with  full-scale  monitoring,  including a  more
manageable size and the ability to vary the operating
conditions to evaluate toxicity  reduction. Treatability
methods can range from simple jar tests for testing
coagulation/flocculation  options  to  flow-through
bioreactors for investigating biodegradation kinetics of
wastewater treatment.
 During  treatability testing,  influent,  effluent  and
 sidestream wastewaters of the treatment process are
 tested for acute or chronic toxicity  using  methods
 described  by  Mount  and  Anderson-Carnahan
 (1988a)   and  Horning  and   Weber  (1985),
 respectively. Toxicity testing is  used to  assess the
effectiveness of the treatment process in reducing the
wastewater  toxicity and  to  determine  the fate  of
toxicity in the treatment process.  Definitive acute or
chronic  toxicity tests  (Peltier and Weber, 1985 and
Horning  and Weber,  1985,  respectively)  should  be
used  at  the completion of the treatability testing to
verify the option's capability  to  meet  the  NPDES
permit limit.

Activated Sludge

The  basic parameters of interest in  the design of
activated  sludge  systems include organic  loading,
oxygen  requirements,  nutrient requirements; sludge
production,  and  sludge settleability  and  return  rate.
Continuous  flow  systems  are most  useful  for
evaluation of activated sludge systems; however, in
some cases batch systems may provide sufficient
treatability information (Adams et al.,  1981).

Coagulation/Flocculation

The  evaluation of  coagulation and  flocculation
treatment involves the use  of bench-scale jar tests
or zeta  potential tests to  provide information on the
optimum coagulant type and  dosage,  mixing rates,
and flocculant settling rates for removal of solids  and
flocculant suspensions (Adams et al.,  1981).  Results
of these tests are  used to  devise  sedimentation
treatability  tests  for evaluating  full-scale
coagulation/flocculation processes.

Sedimentation

Sedimentation involves removal of suspended solids
or flocculant  suspensions  by gravity  settling.
Sedimentation is evaluated by conducting a series of
settling column tests which measure the settling rates
of solids or flocculant suspensions    (Adams et al.,
1981). Test results are used  to  calculate a settling
profile which can be used for clarifier design.

Granular Media Filtration

Filtration testing  involves  scaled-down  models
(usually  pilot-scale)  of full-sized  filters.  The choice
of filter  media and test flow  rates should correspond
to the   intended  design  and  operation  criteria.
Although  the  process scale  is  reduced, the  bed
gradation and thickness should be equivalent to  full-
scale to  predict actual treatment performance (Adams
et al., 1981).

Granular Activated Carbon

The  carbon adsorption  isotherm test  is  used to
determine the optimum type and dosage of activated
carbon for wastewater treatment (Adams et.al., 1981).
Results of this test are used to  prepare  bench-scale
or pilot-scale carbon  columns which are  used to
evaluate carbon exhaustion  rates and the effect of
carbon regeneration on toxicity removal performance.
                                                  7-4

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                                               Section 8
                                    Toxicity Control Selection
Introduction
 The goal  of  the  TRE is to select  and  implement
 toxicity control  methods  and technologies that will
 achieve  the TRE objective  of  meeting  the  permit
 limits  for  effluent toxicity. The process of toxicity
 control selection  involves an  assessment  of the
 potential control options and the selection of the best
 option(s) for toxicity reduction based on technical and
 cost considerations.  In the first  step of the selection
 process, information from  each  stage of the TRE is
 collected and reviewed to  ensure  that sufficient data
 are available. These data  should  include information
 on the magnitude and variability of the effluent toxicity
 and toxicants  over  time.  Following the  information
 review, the  data  are  evaluated to identify feasible
 toxicity control  options.  Finally,  the feasible options
 are  compared  to determine  the  preferred control
 option(s).

 The   choice   of  in-plant  toxicity   control  or
 pretreatment toxicity control will depend  largely on the
 technical  and economical  feasibility  of POTW
 treatment  modifications,  and  the quality of  the
 pretreatment data on  IDs that  contribute  refractory
 toxicity or toxicants  to  the POTW.  Pretreatment
 control will be  feasible in situations  where the TIE
 data  and  the  toxicity source evaluation  data are
 sufficient to definitively identify the sources of toxicity.
 These  data should  provide an  indication  of the
 variability of toxicity and toxics in the  ID discharge. If
 these conditions are satisfied, the municipality can set
 local  limits using the methods outlined  in Section 6.
 In-plant control  will be preferred in cases where the
 implementation  of feasible treatment modifications or
 additions  is more cost-effective  than  pretreatment
 control. In-plant options  provide the POTW a direct
 method of controlling  effluent toxicity;  however,  in-
 plant  modifications  or  additions may result in
 substantial  increases  in process  operation
 requirements and operating costs.

 Evaluation of Control Options

 The, TRE  protocol is  designed to identify possible
 methods for toxicity reduction at the earliest possible
 stage  in the TRE. As shown in  Figure  1-1, sufficient
 information  may  be  available  for toxicity control
evaluation  at  several  stages  in  the TRE:  at  the
completion of  the  PPE  conventional  pollutant
treatability tests,  following  the TIE,  after  Tier  I
chemical-specific testing,  at the end  of  the  Tier I!
pretreatment evaluation, and at the  completion of the
POTW  in-plant control evaluation.  The identified
control  options must be based on ample data that
clearly demonstrates the technical feasibility of each
option. Toxicity control options that are appropriate  for
each of these stages are described as follows.

PPE Treatability Tests

Treatability testing in the PPE may identify options  for
conventional  pollutant treatment which also  reduce
effluent toxicity to  acceptable levels.  In addition  the
optional TIE Phase I tests may provide information  on
the  presence  of  in-plant  toxicants   such   as
suspended solids or chlorine which  is  corroborated in
the operations and performance review. The Phase  I
information can be used to  identify options for  control
of the in-plant toxicants.

Potential  control  options  may  involve  treatment
modifications  or additions that are  necessary  to
improve conventional  pollutant treatment and  to
reduce  or  eliminate in-plant  sources  of identified
toxicants.  Examples  of these control  options include
dechlorination  treatment to eliminate  toxic levels  of
TRC  and  biological treatment  optimization  (e.g.,
increased  MCRT)  to improve conventional pollutant
removal which also reduces effluent toxicity.

TIE Tests

Results of Phase I testing may indicate the classes of
compounds causing  effluent toxicity (e.g., non-polar
organic compounds)  which  may  be amenable  to
certain  types of treatment (e.g., granular  media
filtration).  The feasibility of options for removal  of
broad classes of toxicants can  be evaluated  in  the
POTW  in-plant  control   evaluation  .(Section   7).
Feasible options developed from this evaluation  are
described in a following subsection.

Alternatively, results of Phases II and  III may identify
and  confirm  the specific  toxic compounds  in the
effluent. If the pretreatment  program  data are
                                                 8-1

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adequate  to determine the  sources of the toxicants,
local limits can be developed and evaluated as  noted
in Section 6. In this case, pretreatment control would
be preferred over in-plant control because of the lower
costs of  implementation. If sufficient pretreatment
program  data on  the toxicants  is  not available,
chemical-specific testing will be necessary to track the
sources of the toxicants.

Tier I Chemical-Specific Testing

Chemical-specific tracking in the Tier I evaluation may
locate  the sources  of  the  POTW effluent toxicants.
Once the sources  have  been identified,  local  limits
options can be developed and evaluated as discussed
in Section 6.

Tier II RTA Testing

Results of the Tier II testing are used to  identify the
lUs contributing  refractory  toxicity to the POTW. A
ranking system indicates the major toxic contributors.
Based on these results, the POTW can require the IU
to limit the discharge  of IU wastewater toxicity even
though the toxic  constituents of the wastewater have
not been  identified. In  some cases, the  municipality
may elect to perform optional TIE Phase I  analyses in
the RTA  to  provide  information on the toxic  ID
wastewater constituents. This  additional  testing  may
be  conducted so   that the  municipality can  set
numerical limits on a case by case basis.

POTW Treatability  Testing

POTW  treatability  testing  may indicate  the  in-plant
treatment options  that can be  applied  to  achieve
efficient toxicity reduction. These options  may include
process  enhancements such  as  biological  process
control and nutrient addition, or additional treatment
processes  such  as  equalization,  coagula-
tion/flocculation,  granular  media  filtration  and
granular activated carbon. The treatability data should
include information  on the  variability  of toxicity
treatment performance and  the design  criteria  for
implementing the treatment option.

Selection of Toxicity Control Options

To  aid in the  final  selection  of  toxicity control
alternatives, a list of pertinent selection criteria should
be  prepared as  shown in Table  8-1.   Appropriate
selection criteria include the  ability of each option to
reduce effluent toxicity to acceptable levels; the ability
to comply with  other NPDES  permit limits;  capital,
operational,  and  maintenance  costs;  ease   of
implementation;  reliability;  and the environmental
consequence of the remedy. Each alternative should
be rated in terms of these selection criteria and  the
alternative  with  the  least  points   based  on
environmental, technical, and  economic criteria should
be selected.

 Table 8-1. Comparison of Selection Criteria  for Toxicity
          Control Operations*
                                      Alternative
  Selection Criteria
A  B  C  D
      Ability to achieve effluent toxicity limits

      Ability to comply with other permits

      Capital Cost

      Operational Cost

      Maintenance Cost

      Ease of Implementation

      Reliability

      Environmental Impact
   Rating criteria is 1 to 10, with 10 being the least favorable
   situation.
                                                   8-2

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                                             Section 9
                               Tox/c/ty Control Implementation
Once the evaluation and  selection of toxicity control
options  has been completed, the final  steps  in the
TRE are the implementation of the  selected source
and  in-plant control  options,  and  follow  up
monitoring to ensure permit compliance. The  extent
of the implementation step will depend on the severity
of the effluent toxicity and  on  the complexity  of the
selected control  approaches.  Depending on the
findings of the TRE, implementation may be as simple
as modification of POTW operating  procedures  or as
complex as expansion  of the POTW's  Pretreatment
Program or the design  and  construction of new
treatment facilities.

Implementation

Using the results of the previous steps in the TRE, a
Toxics Control Implementation Plan  (TCIP)  should be
developed.  The TCIP should detail the results of the
TRE and  should specify  the  control  options  for
reducing toxicity to  allowable  levels.  For in-plant
control options,  the TCIP should provide  the basis of
design for the selected control options, provide capital
and operating costs, and define the time required for
design and construction.  For source control options,
the  selected  pretreatment  approach  should  be
detailed in the TCIP,  and should specify the basis of
selection and  technical justification of the local limits
and IU monitoring methods. In addition, the procedure
for implementing the  revised  pretreatment regulations
should be defined.

Follow Up Monitoring

Once a control technology has been  implemented, a
follow up monitoring program should be prepared and
implemented  to ensure the effectiveness  of the
selected  control  options.  In  most  cases,  the
conditions and frequencies of this program will be set
by  the regulatory  agency.  Additional  monitoring
requirements  set by the POTW  for monitoring or
reporting by the  IDs may  also  be  required. This
program  may include verification of statements from
industries that the required  reduction of toxicity has
been  made.  Intensive  effluent toxicity monitoring
should be performed  on  the POTW effluent to ensure
that toxicity has been reduced to acceptable levels
and that the  TRE objectives have  been met.  Any
specific toxicants that were determined to be  present
prior to implementation of control  technology should
be monitored  to ensure  that there is no excursion
from the effluent limitations.
                                                9-1

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                                            Section 10
                              Quality Assurance/Quality Control
Introduction
A Quality Assurance/Quality Control (QA/QC) program
for the TRE should be developed and implemented to
insure the reliability of the collected data. The QA/QC
program  should address  the monitoring  of = field
sampling  and measurement activities, the review of
laboratory   analysis  procedures,  and  the
documentation and reporting of the analytical data. A
QA/QC  program should  be designed  so  that
corrective action can  be  quickly  implemented  to
detect and eliminate erroneous or questionable  data
without undue expense to the project or major delays
in the schedule.

The  POTW  laboratory manager should  ensure  that
the  specific  QA/QC  requirements for TRE  activities
are  addressed  by the  facility's  QA/QC  plan.  If a
private consultant is  to be used for all or part of the
TRE testing, the POTW laboratory manager  should
request a QA/QC plan from  the consultant and review
the consultant's proposed QA/QC activities.  Whether
the TRE is to be performed by the POTW laboratory
or by a  consultant,  it is essential that the  project
organization   include  competent  chemists,
toxicologists  and engineers  who  have adequate
knowledge of TRE methods.

The QA/QC document should be prepared prior to the
initiation of the TRE,  and should contain the  following
elements:

  •  QA/QC  objectives;
  ®  Sample collection and  preservation techniques;
  •  Chain of custody procedures;
  e  Analytical QA/QC;
  «  Laboratory equipment maintenance;
  •  QA/QC  training requirements;
  9  Documentation and reporting  procedures;  and
  •  Corrective action protocols.

Sampling  Collection and Preservation

To  ensure  quality  control  in  sample  collection
activities, the TRE Sampling Plan (Section 13)  should
be strictly followed. In addition the QA/QC plan should
state the  minimum sample  volumes,  maximum
sampling holding  times  and  sample  preservation
techniques  for each analytical  method. The sampling
requirements  for  conventional  and priority pollutant
analyses are described  in   EPA's  Methods  for
Chemical Analysis of Water  and  Waste  (USEPA,
1979) and  Standard Methods for the  Examination of
Water and Wastewater  (APHA,  1985). Sampling
requirements  for acute toxicity  tests are provided by
Peltier and Weber (1985).

It is  important  to routinely assess the effects of
sampling holding  times  on wastewater toxicity to
predict  how  long samples can  be kept  before
changes in toxicity occur.  The TIE Phase  I manual
(Mount  and Anderson-Carnahan,  1988a)  describes
how  testing  the  sample  toxicity  on  the  day  of
collection and comparing  this  initial  toxicity to  its
baseline toxicity  (tested one day  later) can provide
information  on appropriate sampling holding times for
toxicity analysis.

Other QA/QC  considerations for  TRE sample
collection include  routine cleaning and inspection of
automatic  sampling  equipment,  cleaning  sample
containers  according to  the requirements  for each
analytical method, and the collection of duplicate
samples  and  field blanks.  Samples that are to be
used for toxicity  and  chemical  analyses  require
sample  containers that are both toxicologically and
analytically  clean.  Toxicity tests are sensitive to even
slight sample contamination,  thus equipment  and
containers  used  for  toxicity test samples require
special cleaning according  to procedures outlined in
Peltier and Weber (1985).

Chain-of-Custody

A chain-of-custody (COG)  form should  accompany
all samples to document the collection, preservation,
and  handling  of  samples.  The COC form should
indicate the sample  identification  number,  sample
type  (i.e.,  composite or grab), date  and time  of
collection, a brief  description of the sample, number
of samples  taken,  and name of  the person taking  the
sample. A field book should also be used to record
any  field observations or  conditions  noted  during
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sampling along with other pertinent information. Each
laboratory should identify a sample custodian to log in
and  store samples collected during  the TRE.  This
sample custodian should acknowledge receipt of the
sample by signing the COG form and noting the date
and time of  sample receipt,  the sample  identification
number,  and  the laboratory  assession  code. An
additional notation should be  made each time aliquots
of the sample are tested  for  toxicity by noting the
analysis date and time, the analyst, and any changes
in the nature of the sample toxicity over time. All COG
forms should be  maintained in a permanent file  so
that  information  on specific  samples can  be  easily
traced.

Analytical QA/QC
Analytical tests should provide  data of an acceptable
quality for characterizing wastewater toxicity and for
evaluating methods and  technologies for toxicity
reduction. Several of the test  methods described in
this document are new and  require careful attention
to unique QA/QC procedures. The  special QA/QC
procedures for  each  TRE  analytical   test  are
discussed  below.  Whenever  possible,  these
procedures should be followed  to ensure precise and
accurate results.

Toxicity Identification Evaluation

Special precautions for TIE tests are discussed in the
Phase I, II  and  III  manuals (Mount and  Anderson-
Carnahan,   1988a,  1988b  and  Mount,  1988).  In
general  strict  adherence  to  standard quality  control
practices  is not required  in  conducting Phase  I
analyses due to  the large number of toxicity tests to
be performed and the tentative nature of the toxicant
characterization.  Nonetheless,  system  blanks  and
controls  should  be used  whenever  possible  to
indicate  toxicity  artifacts  caused  by   the
characterization  procedures. In  Phase II  more
attention should be paid to quality control in order to
identify interferences in toxicant characterization and
identification. Still greater attention to quality control
should be provided in Phase III. Sample manipulation
should be minimized in Phase  III to prevent analytical
interferences  and  toxicity  artifacts,  and  field
replicates, system blanks,  controls  and calibration
standards should  be used  extensively to allow  a
precise  and accurate  determination of the sample
toxicants and toxicity.

Specific precautions for characterization (Phase I) and
toxicity testing  in TIE analyses are provided below.

Aeration —

For sample  air stripping or aeration tests, only a high
quality compressed air source should  be  used, oil,
water  and  dirt  are undesirable  contaminants in
compressed air;  therefore,  it is important to  use
equipment which generates dry, oil free air. oil sealed
air compressors should not be used. Simple aeration
devices, such  as  those  sold for use with aquariums
are acceptable provided that the ambient laboratory
air  is  uncontaminated  (Mount  and  Anderson-
Carnahan, 1988a).

Filtration -

High purity  water, which  has  been adjusted to  a
specified pH, should be  used to rinse filters between
filtration  steps (Mount and  Anderson-Carnahan,
1988a). Filtration  equipment  should be rinsed with
10% HNO3, acetone and  high  purity water between
sample aliquots.  Filter  toxicity  can be  checked  by
testing filtered  dilution water.

pH Adjustments  -

Two concerns in  the  pH  adjustment  step involve
artificial  toxicity  caused   by   excessive  ion
concentrations from the addition of acid and  base and
silver contamination from some  pH  probes. The
baseline toxicity test acts  as a control  for indicating
whether addition  of acid  and  base increase  the
wastewater toxicity. Because toxic concentrations of
silver can leach  from  refillable calomel electrodes,
only solid state pH probes should be used.

Methanol/Cfs Column -
HPLC-grade methanol  is  required  for  SPE column
preparation and extraction  steps. A blank toxicity test
should be conducted for each  methanol reagent lot.
In addition  a toxicity blank should be performed  on
each SPE column to check for  resin-related toxicity.

Oxidant Reduction -

Thiosulfate  used  in oxidant reduction tests  may  be
toxic  at  high  concentrations.   This potential
interference  can  be  checked  by adding increasing
quantities of thiosulfate to  aliquots of the wastewater
sample, testing the resulting toxicity, and comparing
this toxicity to the  sample's baseline toxicity.

EDTA  Chelation -

Toxicity caused by the addition of EDTA  can  be
identified by observing increases in toxicity, relative to
the  baseline toxicity,  when increasing  amounts  of
EDTA are added to the wastewater sample.

Toxicity Tests —

The organisms used to test the sample toxicity prior
to and  following each characterization step should not
be  subject to  undue  stresses such  as contamination
(Mount and Anderson-Carnahan, 1988a).  The test
organisms should have had no prior  exposure  to
pollutants  and  their  sensitivity  should  be  constant
over time. To assess changes in the sensitivity of the
test organisms,  a standard reference  toxicant test
should be  performed on  a  regular  basis and
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accompanying  quality  control  charts  should  be
developed  (Peltier and  Weber,  1985).  These  tests
should be  performed monthly and should  coincide
with the implementation  of TIE tests. If test organism
cultures are not maintained in the laboratory, standard
reference  toxicant tests should  be  performed with
each group of test organisms received. Information on
obtaining and culturing species for toxicity testing is
provided by Peltier and Weber (1985).

The quality of the dilution water used in toxicity tests
will depend on  the  purpose  of  the TIE  test  and
whether the test is  being  performed as an initial
characterization  (Phases I  and  II)  or  for  toxicant
confirmation (Phase  III).  Because  much of  Phase  I
and  parts  of   Phase  II rely on  relative  toxicity
measurement,  water  which  is of  consistent quality
and will support growth  and reproduction of the test
species is suitable for these phases of the TIE (Mount
and  Anderson-Carnahan, 1988a).  The  objective of
Phase 111,  however, is to confirm the true cause of
toxicity, thus artifacts are  to  be excluded  and  the
choice  of  dilution  water  should  follow  standard
toxicological practices (Peltier and Weber,  1985).  In
general the physical/chemical characteristics of  the
dilution  water  should reflect those of the receiving
water. Synthetic freshwater can be used for TIE tests;
however,  laboratory  deionized water  should  not be
used, because it may lack essential minerals such as
calcium and  magnesium  and may  introduce  toxic
levels of other  cations.

Most species used  in standard acute toxicity testing
do not require  feeding during the test.  The Phase I
manual (Mount and Anderson-Carnahan,  1988a),
however, recommends feeding the  organisms in  the
TIE  test solutions at the  beginning  of TIE toxicity
tests. Feeding requirements for selected species  are
described by Peltier and Weber (1985).

Dissolved  oxygen measurements  are generally  not
made during TIE toxicity tests because  the exposure
chambers have a surface to volume ratio that is large
enough for adequate oxygen diffusion. In cases where
low  DO is a   problem,  DO adjustment  should  be
performed at   a rate that will not  unintentionally
change the sample toxicity.

Refractory Toxicity Assessment and Treatability
Tests

RTA and  treatability  tests are subject to a variety of
potential interferences due  to the  large  number of
variables that  must be  accounted for and controlled
during testing. In performing toxicity tests for RTA and
treatability analyses,  it is  important to  hold  all
parameters potentially affecting  toxicity constant so
that  sample toxicity  is  the sole variable. Important
parameters to  be controlled in RTA testing include the
test solution temperature, DO level and pH.
The QA/QC concerns for toxicity analysis in RTA and
treatability  tests are the same as those expressed
above for TIE tests. Selection and use of test species
and.  dilution  water  should  follow  procedures
addressed  by  Mount  and  Anderson-Carnahan
(1988a).

Potential sources of toxicity  contamination should be
identified through the use of system  blanks. As  with
TIE testing, the filters  used  in RTA testing can be
tested to determine if toxicity is added during filtration.
Each of the solutions used  in RTA testing including
synthetic wastewater and activated sludge should be
checked for toxicity. In  the Patapsco  TRE, the return
activated sludge used  in the RTA batch tests  was
found to be acutely toxic to  Ceriodaphnia. Similarly,
the reagents  used  in  treatability testing  such as
chemical coagulants should be screened for toxicity.

To ensure precise and  accurate  results,  field
replicates,  calibration  standards,  and  analytical
replicates should  be routinely performed  during RTA
and treatability testing. Results of these quality control
analyses can  be  used to  calculate  the precision,
accuracy and the sensitivity of each method.

Chemical Analyses

Quality control for chemical analyses includes the use
of calibration  standards, replicate analyses,  spiked
sample  analyses,  synthetic  unknown analyses,. and
performance standards. The detection limits and the
recommended reagents  for   method  calibration  and
spiking are discussed in EPA's Methods for Chemical
Analysis of Water and  Wastes (1979)  and Standard
Methods for  Examination of Water and  Wastewater
(1985).  General  information  on laboratory  quality
control for chemical analyses is provided  in  EPA's
Handbook for  Analytical Quality Control in Water and
Wastewater Laboratories (1972).

Equipment Maintenance

All facilities and  equipment  such as  pH, DO  and
conductivity meters, spectrophotometers,  GC/MS and
HPLC  instruments  should  be  inspected  and
maintained   according   to  manufacturers'
specifications. A maintenance  log book  should be
used for each  major laboratory instrument.

The measurement of toxicity or trace compounds  in
wastewater samples requires the use  of carefully
cleaned  instruments  and   glassware.  Instruments
which  involve  flow-through  analysis  such  as
automated  spectrophotometers should be  inspected
to ensure  that flow-through  parts (i.e.,  tubing) are
periodically  replaced.  New  glassware  may  be
contaminated with trace amounts of metals, therefore
any glassware being used in  TIE toxicity tests for the
first time  should  be soaked for three days in 10%
nitric  acid  (Mount  and Anderson-Carnahan,  1988a).
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For subsequent use  in  TIE tests,  the  glassware
should be washed with detergent, and  sequentially
rinsed  with  10% HNOa, acetone  and finally high
purity water.

Documentation and Reporting of Data

Basic steps  in a successful QA/QC program are the
documentation of the analytical data in  meaningful,
exact terms, and reporting  the analytical data in a
proper form for future  interpretation  and  use.  To
ensure the reliability of the data, its handling must be
periodically  monitored  and  reviewed.  This review
generally consists of  three elements:  an assessment
of laboratory record keeping  procedures, a review of
the data calculations, and  a  review  of the final
reported data, on the  basis of these review steps and
the QA/QC analyses for precision and accuracy, the
data are accepted or rejected. This review process is
essential because some or all records  may have to
be submitted for review by State or Federal pollution
control agencies.
Corrective Action

Procedures  should  be established  to  ensure  that
QA/QC problems  such  as  improper  sampling
techniques,  inadequate  chain-of-custody  records
and poor precision and accuracy results are  promptly
investigated,  and  corrected.  When a  QA/QC
deficiency is noted, the cause of the condition should
be determined and corrective action  should be taken
to preclude repetition.
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                                            Section 11
                                       Health and Safety
Overview
A health and safety (H&S).plan may be necessary in
performing  TREs  in order to establish policies  and
procedures to protect workers from hazards posed by
TRE sampling and analytical activities. The general
guidelines outlined in this section should be integrated
into existing health  and safety  programs even  if a
specific H&S plan is not required. Whether a specific
H&S plan is  necessary or not will depend  on the
specific conditions under  which the TRE is  being
conducted.  For example, if the POTW operates under
a RCRA permit by rule,  then health and  safety must
be  addressed when  collecting   and analyzing
hazardous wastes.

Important considerations  for health and safety  for
TRE studies include:

  • Identification of personnel responsible for health
    and safety matters;
  • Health and safety training activities;
  • Protective equipment required for TRE activities;
  • Materials cleanup and disposal  procedures; and
  • Emergency response contingencies.

Detailed information on the preparation and scope  of
health  and  safety  plans  is  provided  in  the
Occupational Safety  and  Health  Administration's
(OSHA's) Safety and  Health Standards  for General
Industry (1976). The  following  subsections discuss
specific health and safety considerations  for selected
TRE activities.

Sample Collection and Handling

Working with  wastestreams of  unknown  composition
is  inherent to TREs.  Samples of  industrial  sewer
discharges, municipal wastewater and sewage sludge
can contain a variety of toxic and hazardous materials
(e.g.,  pathogens,  carcinogens,  mutagens  and
teratogens) at concentrations that can be harmful  to
human health.

It  is the  responsibility of  the  laboratory sample
custodian to ensure that TRE  samples are properly
stored,  handled  and  discarded  after  use.  Upon
sample storage, the sample custodian should indicate
the health and safety considerations for handling and
disposal of the sample.             •

Exposure to toxic and hazardous sample constituents
should be minimized during sampling handling. The
principal  routes of human exposure to toxics  is via
inhalation, dermal absorption  and/or  accidental
ingestion.  Exposure can be minimized  through  the
use of proper laboratory safety equipment such as
gloves, laboratory aprons or coats,  safety glasses,
pipetting  aids,  respirators,  and  laboratory hoods.
Laboratory hoods  are  especially  important  when
testing   wastewaters  containing  toxic volatile
substances  such  as  volatile  priority  pollutant
compounds, hydrogen sulfide,  or  hydrogen cyanide.
Proper dermal  protection such as  using neoprene
gloves  for  solvent-containing   wastes  is  also
important. Laboratory  managers  should  consult  the
manufacturers' specifications in selecting  appropriate
clothing  materials  for  protection against specific
chemicals.

Residual  wastewater samples and wastes generated
during TRE studies should be disposed of properly.
Residual  municipal wastewater  and  other  non-
hazardous wastes can  be disposed directly into  the
sink drain  if  the TRE  is being  conducted at  the
POTW. Residual industrial samples and other wastes
that potentially contain hazardous materials should be
decontaminated  and/or  disposed  of  in  accordance
with hazardous waste regulations (NIOSH,  1977).

Analytical Methods

Specific  precautions that  should be  followed  for
selected  TRE analytical techniques are described
below.

Toxicity Identification Procedures (TIE)

EPA's Phase  I  manual (Mount  and  Anderson-
Carnahan, 1988a) addresses the general  health and
safety concerns  involved in performing the Phase I-
III  analyses. Ventilation  is a specific concern  when
performing the Phase  I air-stripping tests. These
tests  should  be  performed  in  laboratory  hoods to
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prevent the inhalation of toxic  volatile compounds
resulting  from air-stripping.

Health and safety considerations for aquatic toxicity
testing are addressed by Peltier and  Weber (1985).
Special precautions  need to  be taken  for on-site
mobile laboratories in the handling and transportation
of chemicals, supply of adequate ventilation  and safe
electrical power, and disposal of waste materials.
Refractory Toxicity Assessment and Treatability
Tests
Proper ventilation is also important when conducting
refractory toxicity assessments and treatability tests in
the laboratory. Hoods  should be used to capture and
vent potential volatile compounds that are stripped
from the wastewater during biological treatment tests.


Physico-chemical treatability testing  may involve the
use of hazardous reagents such as acids or caustics.
Caution should be taken in the handling and disposal
of these chemicals.
Chemical Analyses

A  number  of reagents used for chemical-specific
analyses (e.g., priority pollutants, COD, etc.) are toxic
or hazardous substances. Analysts should be familiar
with safe handling procedures for all reagents used in
testing,  including the  practice  of proper chemical
storage  to  avoid storing  incompatible  chemicals
together  (Miller,  1985).  After  use,  the waste
chemicals should be converted into a less hazardous
form in the laboratory before disposal  (NRC, 1983) or
disposed of by a commercial disposal specialist.

General Precautions

Additional laboratory safety procedures (USEPA, 1977
and  ACS,  1979) that should  be followed in  TRE
studies  include:  1) the use  of safety and  protective
equipment  such as  eye protection (safety goggles,
eye  wash),  fire  hazard protection  (smoke and  fire
detectors, fire extinguishers), and  electrical  shock
protection  (ground-fault  interrupters  for  wet
laboratories); 2)  protocols  for  emergency response
and  materials cleanup; and 3) personnel training in
health and safety procedures.
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                                            Section 12
                                    Facilities and Equipment
Introduction

Laboratories  used  for  a  TRE study  should  be
equipped with all the basic and specialized  laboratory
equipment required  to  conduct  the  TRE,  and
laboratory personnel  should  be  skilled  and
experienced in operating this equipment. The facilities
and  equipment needed  to perform a TRE  will be
different  for each  POTW and  will  depend  on the
site-specific factors  involved in the TRE. In general,
the minimum  facilities and equipment for initiating a
TRE will include the  equipment used in the TIE Phase
I  characterization tests.  As  additional  information
becomes necessary, the facility and equipment needs
will be more  site-specific  and will depend both on
the physical/ chemical characteristics of the causative
toxicants and  on the toxicity control approaches to be
evaluated.  For example,  the selection of  bench-
scale equipment and/or  pilot  plant  facilities for
treatability  studies  will  be  dictated by  the  control
options  to be  tested  (i.e.,  physical/chemical
processes  such  as  filtration or  biological processes
such as increased SRT control).

The choice of whether to work  on-site or off-site
will depend on the  stage  of  the TRE, the methods
used  for tracing  toxicity  to  its sources,  and the
requirements  for treatability  testing. In  general, the
equipment and time required for conducting TIE tests
makes on-site  testing  less  feasible. If  the  loss of
sample toxicity over time is minimal, TIE samples can
be shipped and tested off-site,  usually at  less  cost
than on-site  testing. If  toxicity  tracking  using  RTA
tests is  required,  on-site  testing is  mandatory,
because  fresh  samples  of  the POTW acclimated
biomass  must be used. In addition, treatability tests
which require  continuous supplies of POTW influent
or process wastewaters  and/or activated  sludge  (i.e.,
flow-through bioreactor tests)  can  be more efficiently
conducted in on-site  facilities.  Some  treatability
evaluations require unique or sophisticated equipment
(e.g., ultra-filtration  apparatus)  that is  not readily
available for  on-site work. In these situations, the
equipment vendor  may be  able to conduct the
required tests at the manufacturing facility.
The general equipment requirements for each of the
main TRE methods are summarized below.

Toxicity Identification Evaluations

Laboratories  should  be stocked  with  all of  the
equipment  necessary  to  conduct  Phase   I
characterization tests including  filtration and air
stripping  equipment,  pH  meter,  Cta  solid  phase
extraction columns, fluid metering pumps, and the
required  reagents.  Because  of the  large number of
toxicity tests to be performed for Phase I testing,  it
may be  more cost-effective to culture  the  test
species than purchase  them.  Equipment needs for
culturing  standard  test  species are  described by
Peltier and Weber (1985).

More  sophisticated analytical equipment is required
for the Phase II causative toxicant identification  and
Phase  III causative toxicant confirmation procedures.
The  choice  of analytical  instruments for these
procedures will  depend  on the  compound  to be
measured. Equipment that may be required includes:
gas  chromatograph-mass  spectrometer  (GS/MS),
high  pressure liquid  chromatograph (HPLC),  atomic
absorption  spectrometer  (AA),  inductively coupled
plasma   spectrometer   (ICP),   UV-VIS
spectrophotometer, ion  chromatograph, ion  specific
electrodes, pH  meter, conductivity  meter  and
salinometer.  Use  of  inert  materials  such as
perfluorocarbon  plastics for Phase  II  and  III  are
recommended to protect  against  toxicity artifacts
(Mount and  Anderson-Carnahan, 1988a).

Refractory Toxicity  Assessment  and Treatability
Tests

Laboratories  should  be equipped  with the  basic
equipment for setting up  and  operating the RTA batch
reactors  including an air supply,  air diffusers, and  a
laboratory hood. Instruments for measuring inhibition
include  respirometer  and/or oxygen meters,  total
organic carbon (TOG) analyzer,  spectrophotometers
for COD and  nutrient analyses, drying oven, muffle
furnace,  and  analytical balance.  The  equipment for
toxicity testing  will depend on the choice of toxicity
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screening  tests.  Depending on  the species to be
used, it may be more economical to culture the test
organisms than purchase them. In some cases it may
be necessary to use a rapid  screening test such as
a bacterial bioluminescence test (e.g., Microtox TM).
General Analytical Laboratory Equipment
General laboratory equipment such as refrigerators, a
water  purification  system  and  commonly-used
reagents are  needed  to support the TIE and  RTA
analyses.
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                                            Section 13
                               Sample Collection and Handling
Introduction
The most important criterion in sampling is to obtain a
sample that is  representative of the discharge. To
ensure  that a  sample  represents the typical
toxicological and chemical  quality of the  wastewater,
several samples will need to be collected. Guidelines
for determining the number and frequency of samples
required for characterization are presented  in EPA's
Handbook for Sampling and Sample Preservation of
Water and  Wastewater (Berg, 1982). This handbook
should only be used as a guide,  however, because it
does  not  specifically  address the  requirements for
TRE sampling.

A sampling plan should be prepared to document the
procedures to be followed in TRE sampling.  This plan
should contain the following elements:

  •  Description of sampling locations;
  •  Sampling equipment and methodology;  and
  •  Sample delivery requirements.

These elements  are discussed  in the following
subsections. QA/QC procedures for  sampling, which
include identifying the minimum volume requirements,
holding  times  and  preservation   techniques  for
samples,  preparing  chain-of-custody forms,  and
maintaining sampling  equipment, are addressed in
Section 10.

Sampling Location

Sampling locations should be established where the
wastestream  is readily accessible  and  well-mixed.
When sampling  wastestreams within the POTW,  care
should be taken in excluding unwanted wastestreams
and  in  selecting  a sampling  point that  is  most
representative of  the  discharge  (e.g., the  common
discharge  channel for  secondary  clarifiers).  The
sampling  location for the POTW  effluent should
correspond with the  sampling point stated  in  the
NPDES  permit for biomonitoring. If the  permit does
not specify whether the effluent  sample  is to be
collected  prior  to   or   following   the
chlorination/dechlorination treatment process,  the
choice of  a  sampling location  will  depend on  the
toxicants of  concern. Sampling  before and after
chlorination/dechlorination  may  be  needed  to
differentiate  between toxicity  caused  by  pass-
through and toxicity resulting from  chlorination (i.e.,
TRC).

Wastewater sampling  for toxicity source evaluations
requires knowledge of sewer discharge locations. In
some cases ILJs may have multiple sewer discharges
which need to be accounted for. Sampling may  be
conducted at the point of sewer discharge or in areas
within the municipal  sewer  collection system. The
choice of  sampling locations for  sewer line tracking
will be based on existing pretreatment program data
indicating  the probable toxic  sewer  lines  within the
collection system. If these data are not available,   a
sampling scheme can be  devised  to  locate  toxic
sources through the  process  of  elimination  of
segments of the collection system.

RTA testing  requires  samples of the POTW influent
(primary effluent)  and  activated sludge.  Primary
effluent  samples  should be collected at the overflow
weirs of the primary  sedimentation tanks.  Activated
sludge samples can  be collected from the aeration
basin effluent weirs  or the  return  activated sludge
pipelines.

POTW Sampling

The  choice of grab or composite samples  of POTW
wastestreams (i.e., effluent and  influent wastewater
and  process wastestreams) will depend on  the
physical/chemical characteristics and  variability of the
toxicants.  Initial effluent  toxicity characterization
(Phase I)  should utilize 24-hour  composite samples
in  order to ascertain  the variability  of the  causative
agents over time. If acute effluent toxicity is  not easily
observed  in  24-hour  time composites,  flow
proportional composite or grab samples may be used
to  observe possible flow-related peaks of toxicity. In
the latter  phases  of the TIE,  grab  samples  are
recommended to determine the variability in the type
and  concentration of  effluent toxicants (Mount and
Anderson-Carnahan,  1988a). A  discussion  of  the
use  of grab versus composite sampling for toxicity
tests is  provided by Peltier and Weber (1985). The
choice of a sampling  technique for chemical-specific
analyses is dependent on the type of compounds to
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be measured (e.g., grab sampling for volatile organic
compounds).

When  evaluating the  treatment efficiency of the
POTW or its unit processes, collection of the influent
and  effluent wastewaters should  be lagged by the
hydraulic detention time of  the treatment  process  in
order  to get  comparable  samples.  In  addition,
samples  should  be collected  during  representative
discharge periods.  An evaluation of the condition  of
the facility's  treatment system at the time of sampling
can  be made by  comparing  the  effluent  sample
concentrations of BOD, TSS, and other pollutants  to
long-term  historical  averages  and/or  permitted
values for those parameters. Such a comparison will
provide an indication of the operational status of the
treatment system on the day of  sampling.

The  sample volume requirements for  Phase I tests
are provided in  the Phase I  manual (Mount  and
Anderson-Carnahan, 1988a). Volume  requirements
for POTW samples used in RTA tests are  given  in
Sections  5 and 6.

If TIE or  physical/chemical treatability testing is being
conducted off-site,  samples should be shipped  on
ice to  the testing facility. RTA and some biological
treatability tests require fresh or continuous  samples
of POTW wastestreams, which  requires testing to be
conducted  on-site. Samples  of activated  sludge
should be  delivered to the on-site laboratory  and
used immediately in testing to prevent changes in the
biomass  that can  occur  during  long  term  storage.
Biomass  samples should be vigorously aerated for a
minimum of 15 minutes before use in the RTA  or
treatability   tests.   POTW   influent and  process
wastewater   samples required  for on-site  RTA  or
treatability studies  should be  used on  the  day of
sample collection.

Sewer Discharge Sampling

As  with  POTW  sampling,  the choice  of  grab or
composite samples of indirect discharges will depend
on the physical/chemical characteristics and variability
of the toxicants. The sample type will also be dictated
by the stage of the  toxicity source evaluation. In Tier I
testing 24-hour  flow proportional composite samples
are recommended  to characterize  daily  variability
while accounting  for  variations  in  flow.  Flow
proportional  sampling  should  be  scheduled to
coincide  with  production schedules  for  industrial
discharges, the frequency of intermittent inputs for
RCRA discharges,  and  the schedule  of remedial
activities for CERCLA discharges. This information is
usually available in the POTW's pretreatment program
reports.

Sampling techniques for  flow proportional composites
should account  for  the potential  loss of  volatile
compounds.  For samples  collected  for  chemical
analysis or refractory  toxicity testing, zero headspace
sampling  methods  can be used to  minimize volatile
losses. In some cases grab sampling may be used in
lieu of zero headspace methods to reduce sampling
costs; however,  care  should be  exercised in
collecting samples  that  are representative  of the
discharge.

In the Tier II evaluation grab sampling can be used in
addition to  composite  sampling  to  assess  the
variability of the toxicants.  This type  of  sampling
requires  in-depth  knowledge  of  the  production
schedules and  the pretreatment operations  of the
discharger.
                                                13-2

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                                           Section 14
                                           References
Adams, C.E., D.L. Ford and W.W. Eckenfelder. 1981.
    Development of Design  and Operational  Criteria
    for Wastewater Treatment.  Enviro  Press,
    Nashville, Tennessee.

American Chemistry Society.  1979.  Safety in
    Academic  Chemistry  Laboratories.  ACS
    Publication Committee on Chemical Safety. 3rd
    Edition.

American Public  Health  Association. 1985. Standard
    Methods for  the Examination of  Water  and
    Wastewater. 16th Edition. American  Public Health
    Association, Inc., New York.American  Society for
    Microbiology.  1981.  Manual for  Methods for
    General Bacteriology,  p.  173. American Society
    for Microbiology, Washington, D.C.

Anderson-Carnahan  L.  and  D.I.  Mount.  1988a.
    Methods  for  Aquatic  Toxicity Identification
    Evaluations: Phase  I. Toxicity Characterization
    Procedures.  National  Effluent  Toxicity
    Assessment  Center,  Duluth,  Minnesota.  EPA
    600/3-88-034.

Anderson-Carnahan,  L.  and  D.I.  Mount.  1988b.
    Methods  for  Aquatic  Toxicity Identification
    Evaluations:  Phase  II.  Toxicity  Identification
    Procedures.  National  Effluent  Toxicity
    Assessment  Center,  Duluth,  Minnesota.  EPA
    600/3-88-035.

Berg,  E.  1982. Handbook for Sampling and Sample
    Preservation  of Water  and Wastewater.  U.S.
    Environmental  Protection Agency, Cincinnati,
    Ohio.  EPA 600/4-82-019.

Botts, J.A.,  J.W.  Braswell, E.G.  Sullivan,  W.C.
    Goodfellow, B.D. Sklar  and A.G.  McDearmon.
    1987.  Toxicity  Reduction  Evaluation at  the
    Patapsco  Wastewater Treatment  Plant. Water
    Engineering  Research  Laboratory, Cincinnati,
    Ohio.

Brungs, W.A.  1973. Effects  of Residual Chlorine on
    Aquatic Life.  Journal Water Pollution Control
    Federation. Vol. 45 No. 10 pp. 2180-2193.

Dauge, R.R. and  K. Hagelstein.  1984.  Use of Long
    Solids Retention Times to Improve  the Activated
    Sludge Biodegradation of a Complex Waste. In:
    Proceedings of the  Purdue Industrial  Waste
    Conference. Ann Arbor, Michigan.

Deeny,  K.,  J.  Heidman  and  J.  Condren.  1988.
    Evaluation of a  Full-Scale Activated Sludge
    System  Utilizing Powdered Activated Carbon
    Addition  with Wet Air  Oxidation. Water Pollution
    Control Federation Meeting, Dallas, Texas.

Diehl, R. and S. Moore. 1987. Case History: A North
    Carolina   Municipal   TRE.    Toxicity
    Identification/Reduction  Evaluation  Workshop,
    Water Pollution  Control  Federation Conference,
    Philadelphia, Pennsylvania.

Durkin,  P.F.,  C.R. Ott,  D.S.  Pottle  and G.M. Szal.
    1987.  The Use of the Beckman  MicrotoxTM
    Bioassay System to Trace Toxic Pollutants Back
    to Their Source in Municipal Sewerage Systems,
    In:  Proceedings  of  the Water  Pollution Control
    Federation Association  Annual Meeting, New
    Hampshire.

Fava, J.A., D. Lindsay, W.H. Clement, R. Clark, S.R.
    Hansen,  S.  Moore,and P.  Lankford.  1988.
    Generalized  Methodology for  Conducting
    Industrial Toxicity Reduction Evaluations. Water
    Engineering  Research Laboratory,  Cincinnati,
    Ohio.

Grady, C.P.L. 1985. Biodegradation: Its Measurement
    and  Microbiological Basis.  Biotechnology and
    Bioengineering,  Vol. 27 pp.  660-674.

Horning,  W.  and C.I.  Weber. (Eds.)  1985.  Short-
    Term Methods for Estimating the Chronic Toxicity
    of Effluents and Receiving Waters to Freshwater
    Organisms.  Environmental  Monitoring  and
    Support  Laboratory,  Cincinnati,  Ohio.  EPA
    600/4-85-014.

Jirka, A.M.  and  M.J.  Carter.  1975.  HACH  COD
    Procedure for the Bausch & Lomb Spec 20, Anal.
    Chem. Vol. 47 No. 8.

Kang, S.J. et al.  1983. ATP as a Measure of Active
    Biomass  Concentration and Inhibition in Biological
    Wastewater Treatment  Processes.   In:
    Proceedings  of  Purdue  Industrial Waste
    Conference, Ann Arbor, Michigan.
                                               14-1

-------
Kirsh, E.J., C.P.L. Grady and R.F.  Wukasch. 1985.
   Protocol  Development for the  Prediction  of the
   Fate of Organic Priority  Pollutants in Biological
   Wastewater Treatment Systems,  Environmental
   Protection Agency, Cincinnati, Ohio.

Lankford,  P.W.,  W.W. Eckenfelder Jr.,  and K.D.
   Torrens.  1987.  Technological  Approaches to
   Toxicity Reduction in Municipal and Industrial
   Wastewaters. Virginia Water Pollution  Control
   Association Meeting, Norfolk, Virginia.

Metcalf and Eddy, Inc. 1979. Wastewater Engineering
   Treatment/Disposal/ Reuse. McGraw Hill.

Miller,  R.J.  1985.  Tips for the Safe  Storage of
   Laboratory Chemicals Overflow, Volume II.

Mount,  D.I.  1988.  Methods  for  Aquatic Toxicity
   Identification Evaluations:  Phase III. Toxicity
   Identification Procedures.  National  Effluent
   Toxicity Assessment Center. Quluth,  Minnesota.
   EPA 600/3-88-036.

National Institute of Occupational Safety and Health.
   1977.  Working With  Carcinogens. Public  Health
   Service, Centers for Disease Control. Publication
   No. 77-206.

National Research Council.  1983. Prudent Practices
  . for the Disposal of Chemicals from Laboratories.

Neiheisel,  T.W., W.B. Horning,  B.M. Austern,  D.F.
   Bishop,  T.L.  Reed,  and J.F.  Estenik.  1988.
   Toxicity  Reduction  at  Municipal Wastewater
   Treatment Plants. Journal Water Pollution Control
   Federation. Vol. 60 No. 1   pp. 57-67.

Occupational Safety and  Health Administration. 1976.
   OSHA Safety and Health  Standards, General
   Industry. 29 CFR 1910. OSHA 2206 (Revised).

Peltier, W. and C.I. Weber. (Eds.) 1985.  Methods for
   Measuring the  Acute Toxicity  of Effluents to
   Freshwater  and  Marine  Organisms.  3rd  Edition.
   Environmental Monitoring and Support Laboratory,
   Cincinnati, Ohio.   EPA 600/4-85-013.

Philbrook,  D.M. and C.P.L. Grady. 1985. Evaluation of
   Biodegradation Kinetics for Priority Pollutants.  In:
   Proceedings of  the  Purdue  Industrial  Waste
   Conference. Ann Arbor, Michigan.

Slattery, G.H. 1984.  Effects  of  Toxic   Influent on
   Patapsco  Wastewater  Treatment  Plant
   Operations. Water Pollution Control  Federation
   Conference, New Orleans, Louisiana.

Sullivan, E.G., D.F. Bishop, J.A. Botts, J.W. Braswell,
   G.H. Slattery and W.L Goodfellow. 1987. Effluent
   Toxicity  Monitoring Methodology  Evaluated  for
    Five Industrial Dischargers.  Proceedings  of  the
    Purdue Industrial  Waste Conference,  Ann Arbor,
    Michigan.
Techline Instruments, Inc, 1984. Techline Laboratory
    Respirometer Operating Manual, Fond  du Lac,
    Wisconsin.

U.S.  Environmental  Protection  Agency.  1972.
    Handbook for Analytical  Quality Control  in Water
    and Wastewater Laboratories. USEPA. Analytical
    Quality Control Laboratory, Cincinnati Ohio.

U.S.  Environmental  Protection  Agency.  1977.
    Occupational Health and Safety Manual.  Office of
    Planning and Management, Washington, D.C.

U.S.  Environmental  Protection  Agency.  1979a.
    Methods for Chemical Analysis of Water  and
    Waste.  Cincinnati, Ohio. EPA 600/4-79-020.

U.S.  Environmental  Protection  Agency.  1979b.
    Methods  624  and 625: GC/MS  Methods  for
    Priority  Pollutants.  Federal  Register
    44(223):69532-69558.

U.S.  Environmental  Protection  Agency.  1980.
    Inductively Coupled Plasma/ Atomic Emissions
    Spectrometric  Methods for  Trace Elements
    Analysis of Water and Wastes.

U.S.  Environmental  Protection  Agency.  1983a..
    Guidance  Manual  for  Pretreatment Program
    Development. Office of  Water  Enforcement and
    Permits, Washington, D.C.

U.S.  Environmental  Protection  Agency.  1983b.
    Treatability Manual. Office of  Research  and
    Development.  Washington, D.C.  EPA 600/2-
    82-001a.

U.S.  Environmental  Protection  Agency.  1984.
    Handbook on  Improving  POTW  Performance
    Using   the  Composite  Correction  Program
    Approach.Center for  Environmental Research
    Information, Cincinnati, Ohio.  EPA 625/6-84-
    008

U.S.  Environmental  Protection  Agency.  1985a.
    Technical Support Document for Water Quality
    Based   Toxics  Control.   Office  of  Water
    Enforcement and Permits, Washington, D.C.

U.S. Environmental  Protection Agency. 1985b. Master
    Analytical Scheme  for Organic  Compounds  in
    Water.  Office  of Research and  Development.
    Cincinnati, Ohio.  EPA 600/4-85-008.

U.S.  Environmental  Protection  Agency.  1987a.
    Guidance  Manual  on  the  Development  and
    Implementation  of Local Discharge  Limitations
    Under the Pretreatment Program. Office  of Water
    Enforcement and Permits. Washington, D.C.

U.S. Environmental  Protection Agency. 1987b. Permit
    Writer's  Guide to  Water   Quality-Based
    Permitting  for  Toxic  Pollutants. Office of Water
    Enforcement and Permits, Washington, D.C.
                                                14-2

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U.S.  Environmental  Protection Agency. 1988a. Draft
   Guidance Document for  Writing  Case by  Case
   Permit Requirements for Municipal Sewage
   Sludge. Office of Water Enforcement and permits,
   Washington, D.C.
U.S. Environmental  Protection  Agency.  1988b.
    Development of  Sludge  Loading  Control
    Programs for Publicly Owned Treatment Works.
    Office of Water Enforcement and  Permits,
    Washington,  D.C.
Water Pollution Control  Federation. 1976. Operation
   of Wastewater Treatment Plants. A Manual of
   Practice.  Water  Pollution Control  Federation,
   Washington, D.C.

Weber,  C.I.,  W.B.  Horning,  D.J. Klemm,  W.T.
   Neiheisel, P.A.  Lewis, E.L.  Robinson,  J.
   Menkedick, and  F.  Kessler.  1988.  Short-term
   Methods for Estimating the  Chronic Toxicity of
   Effluents and Receiving  Waters to  Marine and
   Estuarine  Organisms.   U.S. Environmental
   Protection  Agency,  EPA/600/4-87-028.
   Cincinnati, Ohio.
                                             14-3

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                                           Sect/on f5
                                          Bibliography
Abel, M., W. Giger, and M. Koch, 1985. Behavior of
   Nonionic Surfactants in Biological Wastewater
   Treatment.  In:  Organic Micropollutants in  the
   Aquatic Environment.  Proceedings  of the  4th
   European Symposium, Vienna, Austria, October,
   1985.

Abel,  M.  and  W.  Giger.  1985. Determination  of
   Alkylphenols  and Alkylphenol  Mono   and
   Diethoxylate in  Environmental Samples by  High-
   Performance  Liquid Chromatography.  Analytical
   Chemistry Journal (57).

Abel,  M.  and  W.  Giger.  1985. Determination  of
   Nonionic  Surfactants  of the  Alkylphenol
   Polyethoxylate Type by High-Performance Liquid
   Chromatography.  Analytical  Chemistry Journal,
   57(13).

Ayres,  G.H. 1970. Quantitative Chemical  Analysis.
   Harper and Row, Inc., New York.

De Renzo, DJ.  1981. Pollution Control Technology
   for  Industrial  Wastewater.  Noyes   Data
   Corporation, New Jersey.

Eckenfelder, W.W.  1980. Principles of Water Quality
   Management, CBI Publishing Company.

Federal  Register.  1984. U.S.  EPA.  Development of
   Water Quality Based Permit Limitations for  Toxic
   Pollutants; National Policy.  Vol. 49 No. 48 March
   9, 1984.

Giger, W., E.  Stephanov,  and C. Schaffner.  1981.
   Persistent  Organic  Chemicals  in  Sewage
   Effluents:  Identification  of Nonxylphenols and
   Nonxylphenolethoxylates by  Gas Capillary  Gas
   Chromatography. Journal  of  Chemosphere,
   10(11).
Giger,  W.,  H.  Brunner, and  C.  Schaffner. 1984.  4-
    Nonxylphenol in Sewage Sludge: Accumulation of
    Toxic  Metabolites  from  Nonionic  Surfactants.
    Science Journal, 225.

Goodfellow, W.L.  and W.L. McCulloch.  1987.  A
    Technique  for the  Rapid Evaluation of Effluent
    Acute Toxicity. In: Proceedings of the 8th Annual
    SET AC Meeting, Pensacola, Florida.

Maromini,  A.  and  W.  Giger.  1987.  Simultaneous
    Determination  of  Linear  Alkylbenzenesulfonates,
    Alkylphenol Polyethoxylates and Nonxylphenol by
    High-Performance  Liquid  Chromatography.
    Analytical Chemistry Journal (59).

McEvoy,  J. and W.  Giger.  1986.  Determination  of
    Linear Alkylbenzenesulfonates in Sewage Sludge
    by  High Resolution Gas  Chromatography/Mass
    Spectrometry.  Environmental Science  and
    Technology Journal, 20(4).

Patterson, J.W.  1985.  Industrial  Wastewater
    Treatment Technology 2nd Edition. Butterworths.

Peters, R.W.  and Y. Ku, 1984.  Removal of Heavy
    Metals  from  Industrial  Plating Wastewaters by
    Sulfide Precipitation. Proceedings of the Industrial
    Wastes Symposium, (57th Annual Conference).

Water Pollution Control Federation. 1982. Wastewater
    Treatment Plant Design,  Manual of Practice No.
    8.

Water  Pollution Control  Federation.  1983.  Nutrient
    Control. Manual  of Practice FD-7,  Facilities
    Design.
                                               15-1

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                                             Appendix A
                                           Case Histories
A.  Baltimore, Maryland
In January 1986 the EPA, in cooperation with the City
of Baltimore, began  a research study to develop a
pragmatic approach  and  methods for  conducting
TREs at municipal wastewater treatment plants (Botts
et al.,  1987).   The  City's  Patapsco  Wastewater
Treatment Plant (WWTP) was selected for this study
because of substantive influent toxicity and history of
intermittent  pass-through  of  toxicity to  receiving
waters.  In addition, EPA was interested in conducting
a  TRE  at an urban wastewater treatment plant,  like
the Patapsco WWTP,  which receives its influent from
a wide range of industrial discharges. The objectives
of the  TRE were to  characterize the  WWTP's
capability for treatment of conventional pollutants and
toxicity,  evaluate techniques to identify  the specific
components of the toxicity, and assess  methods to
trace toxicity to its source(s).

The  study  results  demonstrated  that  the WWTP
influent  had  significant acute  and chronic toxicity and
substantial amounts of this  toxicity remained following
secondary  treatment  even though the  WWTP
achieved consistent  conventional pollutant removal.
An evaluation of the WWTP operations indicated that
the treatment performance  was not the major  cause
of the effluent  toxicity.   Ceriodaphnia dubia was a
more sensitive indicator of acute effluent  toxicity than
Mysidopsis bahia or MicrotoxTM.

A  toxicity identification evaluation identified  non-polar
organic  compound(s) as the main cause(s) of effluent
toxicity;  however, GC/MS  analysis  of  the  non-polar
organic  fractions of the wastewater did  not lead  to
definitive  determination  of  the specific non-polar
compounds.  The TIE  results did show, however,  that
the non-polar organic compounds have high octanol
to water partition coefficients. The compounds sorbed
onto solids in the plant effluent. Further testing found
that solids (> 0.2 pm)  were  the major toxic fraction.

An evaluation of toxic industrial wastewater samples
from selected candidate industries was performed  to
determine the major contributors of  refractory toxicity
to the WWTP.  The  results of this  evaluation were
used to rank  contributors  with respect  to their
refractory toxicity loading.
 B.  Akron, Ohio

 A survey of six  Ohio  municipal wastewater treatment
 plants  was conducted to  determine  the  level  of
 wastewater toxicity reduction that occurs in municipal
 treatment plants (Neiheisel  et.al., 1988).  Of the six
 WWTPs, the City of Akron wastewater treatment plant
 (Botzum WWTP)  received  the  most  toxic  influent
 wastewater. Although  the Botzum  WWTP achieved
 significant  toxicity reduction,  the  effluent  discharge
 comprised  a large proportion of the Cuyahoga River
 flow. A biological  impact assessment   study of the
 Cuyahoga River in 1984 revealed a severe impact on
 aquatic  communities downstream  of  the  plant
 discharge. A preliminary  review  of the  plant's
 operating records also revealed intermittent bypassing
 of raw  wastewater during storm events.

 On the basis of the  preliminary survey results, the
 Botzum WWTP  was selected  as a site for a toxicity
 reduction evaluation.  The TRE  involved conducting
 toxicity tests  of  the  plant  discharge,  including the
 bypass streams, to  characterize the  variability and
 source(s) of toxicity that may have an effect on the
 river water quality. In  addition, an attempt was made
 to identify the compounds causing the toxicity  through
 physico-chemical fractionation  and  toxicological
 examination (TIE) of the effluent.

 The TIE  testing  revealed that the toxicity was largely
 in the  eighty-five  percent  methanol eluate  of the
 SPE column, which indicates that the toxicant(s) is a
 non-polar organic  compound(s).  Metals were also
 identified as  possible  effluent toxicants. Results of
 acute  toxicity tests of the  effluent and the  CSO
 indicated that although bypassed wastewater may
 contribute intermittently to the poor river quality, the
 continuous  discharge of toxic materials  in the  effluent
was probably the major cause  of the observed
 impact.

 Continued toxicity monitoring indicated  that the acute
effluent toxicity  ended abruptly  in  the summer of
 1986. The cause of this abatement is not known, but
may have  been  related  to  one or  more  of the
following  events: an increase in  the concentration of
activated  sludge  solids in   the  plant bioreactors;
cessation  of discharge   by  a  large  chemical
                                                 A-1

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manufacturing plant; reduction in  the frequency of
wastewater bypassing; or the cumulative effects of
plant  process  and  pretreatment  program
improvements. Biosurveys of the Cuyahoga River in
1986, however, continued to show poor water quality
despite the decrease in effluent toxicity. It is possible
that  either not all of the toxic  wastewater sources
were identified, or the recovery rate  of the river is
slower than anticipated.

C.   Billerica, Massachusetts

A toxicity source evaluation  study  was conducted at
the Billerica WWTP to evaluate the usefulness  of the
Microtox toxicity  test  in  tracing  the source(s) of
toxicity  in  the  WWTP's  collection system (Durkin
et.al., 1987). Billerica WWTP was selected for this
study because its influent was found  to be toxic as
measured by MicrotoxTM.

The Billerica study was conducted in five stages: first,
an  initial screening  of  the  WWTP  influent was
conducted; next, toxicity  tests  were  performed  on
samples  from  pumping  stations  in  the  sewer
collection area;  the  time  of day  when toxicity  was
found in the  most toxic pump  station sewers  was
determined; toxicity screening was performed on the
main sewer lines above the  toxic pump stations; and
finally, testing of the tributaries to the  main  sewer
lines was initiated.

Of the eleven pump station  sewers tested, two were
found to have very toxic wastewaters. In one  of the
two  toxic pump  station sewers, high toxicity  levels
occurred only during a daily  8:00 am to  2:00 pm time
period.  Further  investigation  of this  pump  station
sewer   isolated the principal  source(s) of toxicity to
an industrial park.

This study was successful in screening for possible
sewer  collection  areas  contributing  toxicity  to  the
WWTP. This  screening  method  appears  to be  a
useful  initial  technique  for tracing WWTP  influent
toxicity. However,  a final determination of the sources
of toxicity  that are refractory to treatment provided by
the municipal WWTP would require treating the sewer
samples in a simulation of the WWTP prior to toxicity
analysis.

References

Bolts,  J.A.,  J.W. Braswell,  E.G. Sullivan,  W.C.
    Goodfellow, B.D.  Sklar and  A.G.  McDearmon.
    1987.   Toxicity Reduction  Evaluation   at  the
    Patapsco  Wastewater  Treatment  Plant. Water
    Engineering  Research  Laboratory,  Cincinnati,
    Ohio.

Durkin, P.P., C.R. Ott,  D.S.  Pottle and  G.M. Szal.
    1987.  The Use  of  the  Beckman MicrotoxTM
    Bioassay System to Trace Toxic Pollutants Back
    to  Their Source in Municipal Sewerage Systems.
    In:  Proceedings  of  the Water  Pollution  Control
    Federation Association Annual Meeting, New
    Hampshire.

Microbics  Corp. 1982. MicrotoxTM System Operating
    Manual, Carlsbad, California.

Neiheisel,  T.W., W.B.  Horning,  B.M.  Austern,  D.F.
    Bishop,  T.L.   Reed,  and J.F. Estenik. 1988.
    Toxicity  Reduction  at  Municipal Wastewater
    Treatment Plants. Journal Water Pollution  Control
    Federation. Vol. 60 No. 1    pp. 57-67.
                                                 A-2

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                                             Appendix B
                                  Pretreatment Program Review
 Introduction
 The objective  of  the  pretreatment  program  review
 (PPR) is to gather manufacturing, pretreatment, and
 discharge data on the industrial dischargers  to  the
 municipal treatment plant  (Table  2-2). These data
 together with  the  results of POTW effluent toxicity
 tests can be  used  to identify  possible sources  of
 toxicity  and provide insight as  to probable control
 technology options.  The  pretreatment  program
 information should  include  flow  and  chemical
 monitoring  data  on  the  IDs,  descriptions  and
 schedules of  industrial production campaigns,  and
 inventories of chemicals used in  production. The final
 outcome  of  this, review should  :be  an  improved
 understanding  of  the  industries' processes  and
 chemical  usage,  and  the  possible  identification  of
 sources of toxicity.. Source  identification through the
 pretreatment program review has been successful  in
 reducing effluent toxicity  at POTWs with  a limited
 number and type of industrial inputs (Diehl and Moore,
 1987).      ,                   .     '

 General Procedure

 The main steps  in  a PPR are to:  1)  gather the
 pertinent data;  2) compare the  data to POTW effluent
 toxicity  results  and/or  TIE data;  3) identify  potential
 influent  source(s)  of  toxicity;  and 4)  evaluate  and
 recommend a toxicity control  option(s).  A  brief
 description of each of these steps is as follows.

 Collect Data on Individual Dischargers to PQTW

 Data on all categorical, significant non-categorical and
 other potential  toxic dischargers  (e.g.,  Ills with local
 limits, and RCRA  and  CERCLA inputs) should  be
 collected. A list of pertinent information that should be
 considered in a PPR is presented  in Table 2-2. The
data collection  effort should include a survey of each
 IU, using the example checklist  shown in Table B-1.

 Information  on chemicals  that  may  be  used  in
 manufacturing  processes can  be obtained  from the
 Encyclopedia of Chemical Technology (Kirk-Othmer).
Although OSHA regulations require that information on
hazardous chemicals is to be  made  available to the
public  on Material Safety  Data  Sheets (MSDS),
information  on  various  "specialty" chemicals
 can be difficult to obtain. When data on a "specialty"
 chemical are not disclosed, a literature review can be
 performed  to determine the chemical's acute toxicity
 and  biodegradability.  This  information  allows
 assumptions  to  be  made  concerning   the
 biodegradability of the chemical at the POTW and the
 potential for the chemical to cause effluent toxicity. An
 initial indication of the possible toxics causing effluent
 toxicity can be made by comparing expected effluent
 toxics  concentrations to water quality  criteria  or
 toxicity values provided in the literature.

 Compare  PPR Data to POTW Effluent Toxicity
 Results

 Information on the magnitude, variability, and nature of
 the POTW effluent toxicity can be compared with the
 PPR  data  to  determine the sources(s) of  possible
 problem chemicals.  This comparison  can be made
 using statistical analyses to determine if the  variability
 in the source characteristics can be  related to  the
 variability in the POTW effluent toxicity. A description
 of  data analysis  techniques for  identification  of
 potential sources of toxicity follows.

 Data  Analysis  Techniques  for  Comparing  POTW
 and Industry Pretreatment Data

 Two types  of statistical  analyses can be  used  to
 compare the  pretreatment  program  and POTW
 effluent toxicity data: linear  regression (Draper  and
 Smith, 1966) and cluster analysis (Pielou,  1984 and
 Romesburg, 1984). Linear regression analysis is used
 to find correlations  among  the variables in  the
 database and  to  relate changes in POTW effluent
 toxicity   to the variables. A cluster analysis using
 pattern  recognition software can weigh  and evaluate
 the significance  of  toxics/toxicity correlations.  The
 determination of concentration/response relationships
 through statistical analysis should not be considered
 as a definitive  answer to  toxicity tracking because of
the complexity of the factors  contributing to toxicity in
 POTW effluents.

The  following  example  illustrates how a  stepwise
 linear regression technique  can  be  used  in  PPR
assessment. The technique is used to identify how
changes in  several variables can impact the presence
and variability, of effluent toxicity. Table  B-2  presents
                                                 B-1

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Table B-1.   PPR Data Sheet
 1.    Industry Name
       Notes:
 2.    Address
       Notes:
 3.    Industrial Category (SIC Code)
       Notes:
 4.    THE Objectives
       Notes:
 5.    Manufactured Products
       Notes:
 6.
Chemicals Used
Notes:
       a.   Amounts (write on MSDS)
            Notes:
        b.   MSDS
                                           All Attached
                                                                       Part. Avajjable
        c.   Process in which chemical is used
            (write on each MSDS)
            Notes:
        d.   Aquatic toxicity/bio
            degradability information
            on all chemical used. Review
            MSDS, supplier information
            and literature
            Notes:
                                                                None
                                                                                             Some
  7.    Engineering drawings of facility
        Notes:
        a.   Production flowchart
            and line schematic
            Notes:
                                                        'Available
                                                                                   No
        b.   All floor and process drains
            with schematic
            Notes:
                                                        Available
                                                                                   No
        c.   Wastewater pretreatment
            system schematic
            Notes:
                                                        Available
                                                                                   No
                                                             B-2

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Table B-1.    Continued
 8.
       Facility Records
       Notes:
       a.   Water usage, water bills
            Notes:
  Available
                             No
       b.   Discharge monitoring
            reports for 24 months
            Notes:
  Available
                             No
       c.   Pretreatment system
            operations data
            Notes:
  Available
                             No
       d.   Pretreatment system
            operator interview
            Notes:
 Available
                             No
       e.   Spill prevention
            control plan
            Notes:
Available
                           No
       f.    RCRA reports, hazardous
            waste manifests
            Notes:
Available
                           No
Table B-2.    Data Sheet for Regression Analysis
Month
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
1
LBS
0.80
1.01
1.20
1.25
1.16
0.90
0.90
1.20
1.30
1.27
1.10
0.90
2
INFLOW
1.2
1.5
1.7
1.7
1.6
1.2
1.2
1.6
1.8
1.7
1.6
1.2
3
OFLOW
1.0
1.2
1.4
1.5
1.4
1.0
0.9
1.4
1.6
1.4
1.4
1.0
4
COD
30
33
41
39
30
28
25
23
25
26
30
40
5
BOD5
10
11
15
14
12
11
10
9
15
18
17
21
6
CU
0.73
0.61
0.78
0.65
0.66
0.68
0.71
0.72
0.69
0.72
0.71
0.75
7
CR
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
8
ZN
1.6
1.9
2.0
1.6
1.5
1.4
1.8
1.9
2.0
2.1
1.9
2.0
9
LC50
20
20
18
18
22
30
40
38
40
33
28
22
                                                            B-3

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an  example  data sheet for a  POTW serving  one
manufacturing  plant.  In  this  example,  only a  few
POTW  effluent industry  variables were  used in  the
linear  regression  analysis;  however,   additional
variables  could also  be  added in  the  regression
analysis.


The following variables are the "X" variables:

Industry variables:

   IBS       = Manufactured  product  per month
                (millions of pounds)
   INFLOW  = Discharge flow  based  on  water
                usage (mgd)

POTW  effluent variables:

   OFLOW  = Recorded effluent flow (mgd)
   COD     = Chemical Oxygen Demand (mg/l)
   BODs     = Biochemical Oxygen Demand (mg/l)
   CU       = Copper (mg/l)
   OR       = Chromium  (mg/l)
   ZN       = Zinc (mg/l)
The following variable is the "Y" variable:

       LCgo   = Acute LC5Q as % effluent
By applying standard stepwise  linear regression, the
variables  OFLOW,  BOD5,   CR  and  CU  were
eliminated because they were insignificant to toxicity.
Stepwise linear regression showed that the remaining
(X) variables were significant as regressed versus (Y)
LCsrj.  This  analysis  indicated  that  ZN,  COD,  LBS,
and  INFLOW were correlated  with  POTW  effluent
toxicity.

Identify Source(s) of Toxicity

Based on the data analysis, a  list can be developed
of the possible contributors to effluent toxicity  at the
POTW. Of the potential toxicity control options, toxic
chemical  substitution  or elimination is  usually the
most pragmatic approach. Thus, a followup interview
with  the toxic discharger(s)  should  be conducted to
develop information  concerning techniques  for the
preferred  use of problem  chemicals. A list  of  useful
interview  questions is  shown  in  Table  B-3.  These
questions may enable the  industry to identify problem
areas  and possible corrective  actions in  the use of
toxic chemicals in manufacturing.

Recommend Toxicity Control Option(s)

Based on  the  results,  it  may  be  possible  to
recommend  several  conceptual  approaches  to
controlling toxicity. Toxicity control may be  practiced
at the industrial facility  or  at the POTW. Source
control may  include substitution   or elimination of
problem chemicals, flow reduction,  equalization, spill
control, and manufacturing  process  changes.  If
modifications  in the  POTW  are  recommended,
treatability studies will be required.
 Table B-3.   Summary of the PPR Chemical Optimization Procedure
          Objectives
          A.  Optimize chemical usage amounts in production and water treatment processes.
          B.  Optimize chemical structures in process chemicals insuring biodegradability or detoxification is possible.
          C  Establish process controls over incoming raw  materials,  measuring possible toxic components.  Example, corrosion-
              resistant finish put on steel by manufacturer which must be removed prior to part fabrication.


          Strategy
          A.  Determine what  the role of each chemical is in the process. This is done  by supplier interviews and review of data
              gathered during the initial survey. Ask the questions:

              Can less of this chemical be used?
              Has the optimum amount been determined for each process?
              Do other suppliers offer compounds that will perform as well at lesser concentrations?
              Is the compound in reality  a part of the manufacturer's water treatment system and independent of product production?

              OBJECTIVE: Use less chemicals per pound of product produced.

                                                                                                  (continued)
                                                     B-4

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Table B-3.    Continued
            B.   Discover the biodegradability and toxicity of the process chemical. This is done by supplier interview, review of MSDS
                information, and literature search. Suppliers may not want to supply exact chemical formulations. In this case, ask industry
                to request supplier to perform tests to develop needed data. Questions to ask:
                What are the components in the product?
                What is its aquatic toxicity?
                Is the product biodegradable?
                Are there other component chemicals on the market that meet manufacturing requirements, but are low in  toxicity and
                highly biodegradable?
                OBJECTIVE: Use chemicals that will not create toxicity problems.
            C.   Establish process controls over incoming raw materials. Many raw  materials have  chemicals used in their manufacturing
                which are removed  in the production of the final  product Many raw materials may have trace contaminants which may
                cause toxic problems. Questions to ask:
                What chemicals are used in the manufacturing of the raw material?
                What are the residual amounts of these raw material contaminants or by-products?
                Are there quality control procedures that measure the amounts of these chemicals?
                What are the statistical  process measures used in the monitoring of these chemicals in the raw materials?
                If these chemicals are  required to be removed before  the raw  materials can  be used in manufacturing the final product
                what purpose do the chemicals serve in raw material manufacturing?
                Can they be eliminated?
                Can they be made less toxic or more biodegradable?
                OBJECTIVE: Understand all  raw  materials being used and encourage development of QA procedures to monitor toxic
                chemicals removed during processing.          ;

 111. Outcome of Investigations
            A.   A  list of all chemicals  used in processing and manufacturing of  products. Included will be the amounts used, why the
                chemicals are used, and if optimization has been taken.
            B.   MSDS sheets for all chemicals used will be on file
            C.   A  list of chemicals applied or used in  the manufacturing of all raw materials will be on file under that raw material with the
  •              residual amounts noted  if possible.
            D.   A  list of all chemicals and raw materials purchased on a monthly basis and the amount of product produced.
                OBJECTIVE: Hard information to be used in data analysis.
    IV.      Use of opportunities available due to past experience
           A.
            B.
With experience in  various industries,  certain  chemicals will  become "known"
manufacturing.
                                                                                           as typically  used in  some  process of
                These known compounds can be categorized and toxicity determinations made. Once found toxic, the first information the
                industry must supply to the municipality conducting the TRE  is whether  or not these chemicals are  used in its
                manufacturing process, in raw materials, or in water treatment processes.                                       ,    ,
           C.   Letters also are sent to raw material suppliers asking if these compounds are used in raw material production. If they are,
                the supplier is asked to submit prototype alternative raw materials that do not contain these compounds.
           D.   This  can be  done at the beginning of the TRE as  past experience identifies the "typical" chemicals. Indeed control
                regulations also usually involve establishing limits for selected known toxics in industrial operations.
           E.   What is accomplished by this process can be remarkable. First, the supplier is alerted that these compounds can cause his
                customers problems. This makes him  search for an alternative raw material  source that is free of these  objectionable
                chemicals. A successful market search reduces  the market  demand for contaminated or objectionable raw material.
                Example: Total  brominated toxic organics (TBTO) limits in  North Carolina have eliminated TBTO biocides  from being
                applied to hosiery.

                                                                                                                     (continued)
                                                             B-5

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Table B-3.   Continued
     V.    Tests to help assess toxicity/biodegradability on specialty formulated chemicals and mixtures and to help evaluate competitive
          products.
          A.  BODs, BOD2rj
          B.  BOD5, BOD20 performed at LCso concentration with ET50 or LC50 concentration with ET50 or LC50 performed on settled
              effluent from test.
          C.  COD before and after BOD50 and BOD2o at LC50, ET50 concentrations.
          D.  Estimate biodegradability by using BOD5 and COD tests and the calculation (BOD5 - COD)/COD x 100 of a 10 or 20
              mg/l solutions of chemical. This can be repeated at a 20-day BOD.
          E.  Bkxnass Inhibition tests (detailed procedures in Section 6).
          F.  LCgg on products. Screening dilutions  1-10,000 ppm.
              OBJECTIVE: Help industry determine  relative biodegradability and toxicity of various raw materials, products, and by-
              products.
References

Diehl, R. and S. Moore,  1987. Case  History: A North
    Carolina  Municipal  TRE.  Toxicity  Iden-
    tification/Reduction Evaluation  Workshop, Water
    Pollution  Control  Federation  Conference,
    Philadelphia, Pennsylvania.
Draper  and Smith.  1966.  Step-wise  Multiple
    Regression:  Applied  Regression  Analysis.  John
    Wiley and Sons, p. 178.
Kirk-Othmer.  1982.  Encyclopedia  of  Chemical
    Technology, Wiley Interscience.

Pielou.  1984. Cluster  Analysis  Techniques:  The
    Interpretation  of  Ecological  Data,  Wiley
    Interscience.
Romesburg,  H.C.  1984.  Cluster  Analysis  for
    Researchers.  Lifetime Learning  Publications.
    Gelmont, California.
     ftU.S. GOVERNMENT PRINTING OFFICE: 1989-648-163/87092
                                                     B-6

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